M/s Bharat Motor Parcel Service, Rajahmundry V. THE ACIT, CIRCLE-1, Rajahmundry

ITA 588/VIZ/2013

• Counselvise Citation: [2016] 132 COUNSELVISE.COM (IT) 1185 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 2 year(s) 8 month(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 06-05-2016
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2008-2009
• Appeal Filed On: 04-09-2013
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: D KOMALI KRISHNA
• Keywords: Unexplained cash credit
• Section: 68

Judgement Text

ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 1 , , IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM . , . , $ BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER & SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ./I.T.A.NO.588/VIZAG/2013 ( / ASSESSMENT YEAR: 2008-09) M/S. BHARAT MOTOR PARCEL SERVICE RAJAHMUNDRY VS. ACIT, CIRCLE - 1, RAJAHMUNDRY [PAN: AABHD1457M ] ( / APPELLANT) ( / RESPONDENT) / APPELLANT BY : SHRI G.V.N. HARI, AR / RESPONDENT BY : SMT. D. KOMALI KRISHNA, DR / DATE OF HEARING : 02.05.2 016 / DATE OF PRONOUNCEMENT : 0 6 .05.2016 / O R D E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAI NST THE ORDER OF CIT(A), VISAKHAPATNAM DATED 30.7.2013 AND IT PERTAI NS TO THE ASSESSMENT YEAR 2008-09. ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 2 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E IS A PARTNERSHIP FIRM WHICH IS ENGAGED IN THE BUSINESS OF CARRYING O N TRANSPORT BUSINESS FILED ITS RETURN OF INCOME FOR THE ASSESSMENT YEAR 2008-09 ON 29.9.2008 DECLARING TOTAL INCOME OF RS.47,91,250/-. THE CASE HAS BEEN SELECTED FOR SCRUTINY UNDER CASS. ACCORDINGLY, NOTICE U/S 1 43(2) OF THE INCOME TAX ACT, 1961 (HEREINAFTER CALLED AS THE ACT) WAS ISSUED. IN RESPONSE TO NOTICE, THE A.R. OF THE ASSESSEE APPEARED FROM T IME TO TIME AND FURNISHED THE BOOKS OF ACCOUNTS AND OTHER DETAILS C ALLED FOR. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE A.O. NOTICED THAT THE ASSESSEE HAS SHOWN LOAN CREDITORS OF RS.15 LAKHS. TO ASCERTA IN THE CORRECTNESS OF THE CLAIM MADE BY THE ASSESSEE, THE A.O. ISSUED A S HOW CAUSE NOTICE AND ASKED TO FURNISH THE DETAILS OF LOAN CREDITORS INCLUDING CONFIRMATION LETTERS FROM THE PARTIES. IN RESPONSE TO SHOW CAUS E NOTICE, THE ASSESSEE HAS SUBMITTED THAT IT IS ACCEPTED THE UNSECURED LOA NS FROM PARTIES BY WAY OF DEMAND DRAFT AND CHEQUES. THE ASSESSEE ALSO FILED A CONFIRMATION LETTERS FROM THE PARTIES, WHEREIN THE PARTIES HAVE STATED THAT THEY HAVE ADVANCED LOANS TO THE ASSESSEE. THE A.O. AFTER CONSIDERING THE DETAILS FURNISHED BY THE ASSESSEE H ELD THAT THE ASSESSEE HAS FAILED TO PROVE THE CREDITORS TO THE SATISFACTI ON OF THE A.O. THE A.O. FURTHER HELD THAT THE ASSESSEE HAS NOT DISCHARGED I TS INITIAL BURDEN BY FILING THE IDENTITY, GENUINENESS AND CREDITWORTHINE SS OF THE CREDITORS. ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 3 THE A.O. FURTHER OBSERVED THAT THE ASSESSEE CLAIMED TO HAVE TAKEN UNSECURED LOANS FROM FOUR PARTIES. ON VERIFICATION OF THE DETAILS FURNISHED BY THE ASSESSEE, IT WAS NOTICED THAT ON T HE DATE OF TRANSFER OF AMOUNT TO THE ASSESSEE BANK ACCOUNT, THE PARTIES HA VE DEPOSITED CASH INTO THEIR BANK ACCOUNT. PRIOR AND SUBSEQUENT TO T HIS DATE, THE PARTIES HAVE NOT DONE ANY TRANSACTIONS IN THEIR BANK ACCOUN T. THEREFORE, OPINED THAT THE GENUINENESS OF THE TRANSACTION AND THE CAP ACITY OF THE PARTIES TO ADVANCE LOAN TO THE ASSESSEE IS IN DOUBTFUL. WI TH THESE OBSERVATIONS THE A.O. MADE ADDITIONS OF RS.15 LAKHS U/S 68 OF TH E ACT. 3. AGGRIEVED BY THE ASSESSMENT ORDER, THE ASSESSEE PREFERRED AN APPEAL BEFORE THE CIT(A). BEFORE THE CIT(A), THE A SSESSEE REITERATED THE SUBMISSIONS MADE BEFORE THE A.O. THE ASSESSEE FURTHER SUBMITTED THAT DURING THE YEAR UNDER CONSIDERATION IT HAS ACC EPTED LOANS FROM 4 PERSONS AGGREGATING RS.15 LAKHS. IT IS FURTHER SUB MITTED THAT IT HAS OBTAINED CONFIRMATION FROM THE PARTIES WHICH WAS FU RNISHED BEFORE THE A.O. THE A.O. WITHOUT EXAMINING THE CONFIRMATION LE TTERS SIMPLY, DISBELIEVED THE CONFIRMATION LETTERS AND MADE ADDIT IONS U/S 68 OF THE ACT. IT IS FURTHER SUBMITTED THAT WITH REGARD TO A MOUNT RECEIVED FROM TWO PERSONS NAMELY SRI T. BOSU BABU AND G. VIJAYA L AKSHMI WHO HAPPENED TO BE HUSBAND AND WIFE, SHRI T. BOSU BABU IS WORKING IN ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 4 ANTARIO AND THE LOAN HAS BEEN GIVEN OUT OF HIS PAST SAVINGS. THE PAYMENT HAS BEEN MADE THROUGH ACCOUNT PAYEE CHEQUE AND THE PARTIES HAVE CONFIRMED THE LOAN TRANSACTIONS. THEREFORE, TH E A.O. WAS NOT CORRECT IN COMING TO THE CONCLUSION THAT THE ASSESS EE HAS NOT DISCHARGED INITIAL BURDEN. IT IS FURTHER SUBMITTED THAT IN RES PECT OF OTHER TWO CREDITORS, THE PARTIES HAVE CONFIRMED THE LOAN BY F ILING NECESSARY CONFIRMATION LETTERS. THE PARTIES HAVE ENOUGH SOURC E OF INCOME TO SUBSTANTIATE THE LOAN GIVEN TO THE ASSESSEE. THE A. O. WITHOUT CONDUCTING ANY ENQUIRY WITH REGARD TO THE CREDITORS SIMPLY, DISREGARDED THE CONFIRMATION LETTER FILED BY THE ASSESSEE AND M ADE ADDITION U/S 68 OF THE ACT. 4. THE CIT(A) AFTER CONSIDERING THE EXPLANATIONS FU RNISHED BY THE ASSESSEE HELD THAT THE ASSESSEE HAS NOT DISCHARGED INITIAL BURDEN CAST UPON IT BY FILING IDENTITY, GENUINENESS OF THE TRAN SACTIONS AND CREDITWORTHINESS OF THE PARTIES. THE CIT(A) FURTHE R HELD THAT WITH REGARD TO THE CREDIT IN THE NAME OF T. BOSU BABU AND SMT. G. VIJAYA LAKSHMI, IT WAS NOT EXPLAINED HOW A PERSON WORKING IN ANTARIO H AD SENT A LETTER ON A PLAIN PAPER AND WHAT WAS HIS SOURCE FOR CASH DEPO SIT IN HIS ACCOUNT WHEN HE WAS A NON-RESIDENT. IT IS FURTHER OBSERVED THAT SMT. G. VIJAYA LAKSHMI STATED TO HAVE ADVANCED THE MONEY OUT OF HE R HUSBANDS ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 5 SURPLUS INCOME, BUT IT WAS NOTED THAT THE SAME DAY THE CASH WAS DEPOSITED INTO THE ACCOUNT OF THE LOAN CREDITOR. WIT H REGARD TO THE CREDIT IN THE NAME OF SMT. G.P. VIJAYA LAKSHMI, IT WAS CLA IMED THAT THE LOAN CREDITOR HAS ADVANCED THE LOAN OUT OF ACCUMULATED A GRICULTURAL INCOME. ON PERUSAL OF THE PATTADAR PASS BOOK, REVEALED THAT THE LANDS OWNED BY THE CREDITOR IS A DRY LAND AND EVEN HER CREDITWORTH INESS FOR ADVANCING AN AMOUNT OF RS.4 LAKHS REMAINS IN DOUBT. THE CIT(A) FURTHER OBSERVED THAT MERE FILING OF CONFIRMATION LETTER WOULD NOT D ISCHARGE THE BURDEN OF THE ASSESSEE. IT IS SETTLED LAW THAT THE ASSESSEE IS REQUIRED TO PROVE THE IDENTITY, CREDITWORTHINESS AND GENUINENESS OF THE L OAN TRANSACTIONS. THE ASSESSEE HAS FAILED TO PROVE THE CREDITWORTHINESS O F THE SO CALLED CREDITORS AND GENUINENESS OF THE TRANSACTIONS. WITH THESE OBSERVATIONS, CONFIRMED THE ADDITIONS MADE BY THE A.O. AGGRIEVED BY THE CIT(A) ORDER, THE ASSESSEE IS IN APPEAL BEFORE US. 5. THE LD. A.R. OF THE ASSESSEE SUBMITTED THAT THE CIT(A) IS NOT JUSTIFIED IN SUSTAINING THE ADDITIONS OF RS.15 LAKH S MADE BY THE A.O. U/S 68 OF THE ACT TOWARDS UNEXPLAINED CASH CREDITS. TH E A.R. FURTHER SUBMITTED THAT THE ASSESSEE HAS DISCHARGED ITS INIT IAL BURDEN BY FILING CONFIRMATION LETTERS. IT IS FURTHER SUBMITTED THAT THE PARTIES HAVE CONFIRMED THE TRANSACTIONS BY FILING CONFIRMATION L ETTERS AND ALSO BANK ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 6 STATEMENTS. THE A.O. WITHOUT EXAMINING THE DETAILS SIMPLY DISBELIEVED THE CONFIRMATION LETTERS FILED BY THE RESPECTIVE PA RTIES AND MADE ADDITIONS U/S 68 OF THE ACT. THE LD. A.R. FURTHER ARGUED THAT THE ASSESSEE HAS ACCEPTED LOANS FROM FOUR PARTIES. OUT OF THE FOUR PARTIES, TWO PERSONS NAMELY SHRI T. BOSU BABU AND SMT. G. VI JAYA LAKSHMI HAVE CONFIRMED THE LOAN TRANSACTION BY FILING THE CONFIR MATION LETTERS. IT IS FURTHER SUBMITTED THAT THE ASSESSING OFFICER HAS IS SUED SUMMONS TO THE PARTIES TO APPEAR BEFORE HIM ON 30.12.2010. HOWEVE R, THE FACT IS THAT AS PER THE SUMMONS, SHE WAS REQUIRED TO ATTEND ON 3 0.11.2010 AND SHE WAS SERVED THE SUMMONS ON 30.12.2010. THEREFORE, S HE COULD NOT ATTEND. THE A.O. WITHOUT CONDUCTING FURTHER ENQUIRI ES WITH REGARD TO THE CREDITORS SIMPLY, DISREGARDED THE CONFIRMATION LETT ERS TO MAKE ADDITIONS U/S 68 OF THE ACT. IN RESPECT OF OTHER TWO CREDITOR S, THE PARTIES HAVE ENOUGH SOURCE OF INCOME TO EXPLAIN THE LOAN ADVANCE D TO THE ASSESSEE. THE PARTIES HAVE FILED NECESSARY PROOF OF HAVING AG RICULTURAL LAND AND ALSO STATED THAT THEY HAVE ADVANCED THE MONEY OUT O F THEIR AGRICULTURAL INCOME. THE TRANSACTION HAS BEEN MADE IN BANKING C HANNEL. THEREFORE, THE A.O. WAS NOT CORRECT IN DOUBTING THE GENUINENES S OF THE TRANSACTIONS. THE ASSESSEE HAS DISCHARGED ITS INIT IAL BURDEN BY FILING THE NECESSARY CONFIRMATION LETTERS. THE IDENTITY OF THE PARTIES HAS BEEN PROVED. THE GENUINENESS OF THE TRANSACTIONS AND CRE DITWORTHINESS OF THE ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 7 PARTIES ALSO HAVE BEEN PROVED. ONCE ALL THE INGREDI ENTS OF SECTION 68 ARE PROVED BEYOND DOUBT, THE A.O. CANNOT MAKE ANY ADDIT IONS U/S 68 OF THE ACT. THE LD. D.R. ON THE OTHER HAND, STRONGLY SUPP ORTED THE ORDER OF THE CIT(A). 6. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE MA TERIALS AVAILABLE ON RECORD. THE A.O. MADE ADDITIONS OF RS .15 LAKHS U/S 68 OF THE ACT TOWARDS UNEXPLAINED CREDITS. THE A.O. WAS OF THE OPINION THAT THE ASSESSEE HAS NOT PROVED THE GENUINENESS OF THE TRANSACTIONS AND CREDITWORTHINESS OF THE PARTIES. IT WAS FURTHER OB SERVED THAT MERE FILING OF CONFIRMATION LETTERS WOULD NOT DISCHARGE THE BUR DEN CAST UPON THE ASSESSEE. AS PER SECTION 68 OF THE ACT, THE ASSESS EE HAS TO DISCHARGE INITIAL BURDEN CAST UPON IT BY FILING IDENTITY, GEN UINENESS OF THE TRANSACTIONS AND CREDITWORTHINESS OF THE PARTIES. THE A.O. OBSERVED THAT THE ASSESSEE HAS FAILED TO PROVE THE TRANSACTIONS B Y NECESSARY EVIDENCE. IT IS THE CONTENTION OF THE ASSESSEE THAT IT HAS DI SCHARGED THE INITIAL BURDEN CAST UPON IT BY FILING NECESSARY CONFIRMATIO N LETTERS. THE ASSESSEE FURTHER CONTENDED THAT THE IDENTITY OF THE PARTIES HAS BEEN PROVED. THE GENUINENESS OF THE TRANSACTION AND CRE DITWORTHINESS OF THE PARTIES HAVE BEEN PROVED BY FILING NECESSARY CONFIR MATION LETTERS ALONG ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 8 WITH PROOF OF INCOME TO SUBSTANTIATE THE LOANS ADVA NCED TO THE ASSESSEE. 7. SECTION 68 OF THE ACT PROVIDES FOR ADDITION, WHE RE ANY SUM IS FOUND CREDITED IN THE BOOKS OF AN ASSESSEE MAINTAIN ED FOR IN PREVIOUS YEAR AND THE ASSESSEE OFFERS NO EXPLANATIONS ABOUT THE NATURE AND SOURCE THERE OF OR EXPLANATIONS OFFERED BY THE ASSE SSEE IS NOT IN THE OPINION OF THE A.O. SATISFACTORY, THEN SUM SO CREDI TED MAY BE CHARGED TO INCOME TAX AS THE INCOME OF THE ASSESSEE OF THAT PR EVIOUS YEAR. A PLAIN READING OF SECTION 68 OF THE ACT MAKES IT CLEAR THA T ANY SUM FOUND CREDITED IN THE BOOKS OF ACCOUNTS OF THE ASSESSEE, IT IS THE DUTY OF THE ASSESSEE TO PROVE TO THE SATISFACTION OF THE A.O. T HAT THE CREDITS ARE GENUINE. IT IS THE RESPONSIBILITY OF THE ASSESSEE TO PROVE THE IDENTITY, GENUINENESS OF THE TRANSACTIONS AND CREDITWORTHINES S OF THE PARTIES. ONCE THE INITIAL BURDEN DISCHARGED BY THE ASSESSEE, THEN THE BURDEN SHIFTS TO THE REVENUE TO PROVE OTHERWISE. BUT, THE ASSESSEE NEEDS TO DISCHARGE THE INITIAL BURDEN BY FILING THE NECESSAR Y DETAILS TO THE SATISFACTION OF THE A.O. 8. IN THE PRESENT CASE ON HAND, ON PERUSAL OF THE D ETAILS FILED BY THE ASSESSEE, WE FIND THAT ALTHOUGH THE ASSESSEE STATED TO HAVE FILED THE CONFIRMATION LETTERS, THE OTHER TWO INGREDIENTS OF THE SECTION I.E. THE ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 9 GENUINENESS OF THE TRANSACTIONS AND THE CREDITWORTH INESS OF THE PARTIES ARE IN DOUBTFUL. OUT OF THE FOUR LOAN CREDITORS, T WO CREDITORS NAMELY SHRI T. BOSU BABU AND HIS WIFE SMT. G. VIJAYA LAKSHMI HA VE ADVANCED AN AMOUNT OF RS.10 LAKHS. IT IS THE CLAIM OF THE ASSE SSEE THAT SHRI T. BOSU BABU IS WORKING IN ABROAD AND THE MONEY HAS BEEN GI VEN OUT OF HIS PAST SAVINGS. THE ASSESSEE FILED A PAPER BOOK CONTAINING THE CONFIRMATION LETTERS FILED BY THE PARTIES ALONG WITH THEIR BANK STATEMENT. ON VERIFICATION OF THE BANK STATEMENT FILED BY THE ASS ESSEE, WE NOTICED THAT THE PARTIES HAVE DEPOSITED CASH ON THE SAME DAY WHE N THE MONEY HAS BEEN TRANSFERRED TO THE ASSESSEE BANK ACOUNT. THE PARTIES HAVE NOT EXPLAINED HOW A PERSON WORKING IN ABROAD HAS DEPOSI TED CASH IN TO THE NORMAL SAVINGS BANK ACCOUNT MAINTAINED IN INDIA, WH EN HE IS NOT PERMITTED TO OPERATE NORMAL BANK ACCOUNT IN INDIA. SIMILARLY, HIS WIFE SMT. G. VIJAYA LAKSHMI STATED TO HAVE ADVANCED THE LOAN OUT OF HER HUSBANDS SAVINGS. ON VERIFICATION OF HER BANK STAT EMENT, WE FIND THAT THE SAME DAY SHE HAD DEPOSITED CASH AND TRANSFERRED THE MONEY TO THE ASSESSEE BANK ACCOUNT. EXCEPT THESE TWO TRANSACTIO NS, SHE HAD NOT MADE ANY SUBSTANTIAL TRANSACTIONS IN HER BANK ACCOU NT. WE FURTHER OBSERVED THAT SHE HAS NOT ASSESSED TO INCOME TAX AN D SHE DOES NOT HAVE ANY SOURCE OF INCOME TO ADVANCE LOAN TO THE AS SESSEE. WHEN SHE DOES NOT HAVE ANY SOURCE OF INCOME TO JUSTIFY THE L OAN OF RS.5 LAKHS, THE ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 10 ASSESSEE HAS FAILED TO DISCHARGE HIS INITIAL BURDEN OF PROVING CREDITWORTHINESS OF THE PARTIES. 9. SIMILARLY, THE ASSESSEE CLAIMED TO HAVE RECEIVED TWO LOANS FROM SMT. G.P. VIJAYA LAKSHMI AND A. VENKATA RAO. IT IS THE CONTENTION OF THE ASSESSEE THAT BOTH THE PARTIES ARE AGRICULTURISTS A ND HAVE EARNED AGRICULTURAL INCOME. THE PARTIES HAVE FILED CONFIR MATION LETTERS TO SUBSTANTIATE THE LOAN GIVEN TO THE ASSESSEE. THE A SSESSEE HAS FILED COPIES OF CONFIRMATION LETTERS FILED BY THE PARTIES AND THEIR BANK PASS BOOKS. ON VERIFICATION OF THE BANK STATEMENT FILED BY THE ASSESSEE, WE NOTICED THAT THE CREDITORS HAVE DEPOSITED CASH AND TRANSFERRED THE SAME TO THE ASSESSEE BANK ACCOUNTS. EXCEPT THESE TWO TR ANSACTIONS, THEY ARE NOT HAVING ANY CONSIDERABLE BANK TRANSACTIONS IN TH EIR BANK ACCOUNT. UNDER THESE CIRCUMSTANCES, WE ARE OF THE OPINION TH AT THE ASSESSEE HAS NOT DISCHARGED ITS BURDEN BY PROVING THE CREDITWORT HINESS OF THE PARTIES. WE FURTHER OBSERVED THAT ALTHOUGH THE PARTIES HAVE F ILED THE CONFIRMATION LETTERS, THE OTHER INGREDIENTS OF THE SECTION I.E. THE GENUINENESS OF THE TRANSACTIONS AND CREDITWORTHINES S OF THE PARTIES REMAIN IN DOUBTFUL. THE ASSESSEE HAS FAILED TO PRO VE THE TRANSACTION TO BE GENUINE AND ALSO FAILED TO ESTABLISH THE CAPACIT Y OF THE CREDITORS TO ADVANCE LOAN TO THE ASSESSEE. THEREFORE, WE ARE OF THE OPINION THAT THE ITA NO.588/VIZAG/2013 M/S. BHARAT MOTOR PARCEL SERVICE, RAJAHMUNDRY 11 CIT(A) HAS RIGHTLY UPHELD THE ADDITIONS MADE BY THE A.O. WE DO NOT SEE ANY ERROR OR INFIRMITY IN THE ORDER PASSED BY THE C IT(A). HENCE, WE INCLINED TO UPHOLD THE ORDER OF CIT(A) AND DISMISS THE APPEAL FILED BY THE ASSESSEE. 10. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS DISMISSED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 6 TH MAY16. SD/- SD/- ( . ) ( . ) (V. DURGA RAO) (G. MANJUNATHA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 06.05.2016 VG/SPS )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT M/S. BHARAT MOTOR PARCEL SERVICE , D.NO.29-1-33, BHARAT BHAVAN, G.T. ROAD, OPP. NAGADEVI THEATRE, RA JAHMUNDRY 2. / THE RESPONDENT THE ACIT, CIRCLE-1, RAJAHMUNDRY 3. + / THE CIT, VISAKHAPATNAM 4. + ( ) / THE CIT (A), VISAKHAPATNAM 5. # . , . , # / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // 12 . (SR.PRIVATE SECRETARY) . , # / ITAT, VISAKHAPATNAM