ACIT, Circle -16(2), Hyderabaad, Hyderabad V. Ramoji Rao (HUF), Hyderabad

ITA 60/HYD/2015

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 91630 (ITAT-HYDERABAD)
• Duration Of Justice: 3 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-05-2015
• Appeal Filed By: Department
• Bench Allotted: A
• Next Hearing Date: 07-05-2015
• Assessment Year: 2010-2011
• Appeal Filed On: 12-01-2015
• Court: TRIBUNAL
• Department Lawyers: RAMAKRISHNA BANDI
• Assessee Lawyers: V RAGHAVENDRA RAO
• Keywords: Bad and doubtful debts
• Section: 143(3); 14A

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A, HYDERABAD BEFORE SHRI P.M. JAGTAP, ACCOUNTANT MEMBER AND SMT. P. MADHAVI DEVI, JUDICIAL MEMBER ITA NO. A.Y. APPELLANT RESPONDENT 60/HYD/2015 2010 - 11 ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD M/S. RAMOJI RAO, (HUF), HYDERABAD [PAN: AADHR 6836E] 66/HYD/2015 2010 - 11 CH. RAMOJI RAO (HUF), HYDERABAD [PAN: AADHR 6836E] DY. COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD FOR REVENUE : SHRI RAMA KRISHNA, BANDI, DR FOR ASSESS EE : SHRI V. RAGHAVENDRA RAO, AR DATE OF HEARING : 0 7 - 0 5 - 201 5 DATE OF PRONOUNCEMENT : 08 - 0 5 - 2015 O R D E R PER SMT. P. MADHAVI DEVI, J.M. : BOTH ARE CROSS-APPEALS FOR THE ASSESSMENT YEAR (AY) 2010-11. BRIEF FACTS OF THE CASE ARE THAT, THE ASSESSEE-HUF FILED ITS RETURN OF INCOME FOR THE RELEVANT ASSESSMENT YEAR RETURNING T OTAL INCOME OF RS. 2,84,31,658/-. DURING THE ASSESSMENT PROCEEDIN GS U/S. 143(3) OF THE INCOME TAX ACT [ACT], THE ASSESSING OFFICER (AO ) OBSERVED THAT THE ASSESSEE-HUF HAS BORROWED FUNDS FROM THE PUBLIC THR OUGH VARIOUS DEPOSIT SCHEMES ON WHICH THE HUF IS CLAIMING INTERE ST EXPENDITURE. HE OBSERVED THAT THE BORROWED FUNDS WERE UTILIZED FOR INVESTMENTS IN NON- INCOME YIELDING ASSETS OR THE INCOME FROM WHICH IS EXEMPT FROM TAX AND THEREFORE IS NOT ALLOWABLE U/S. 14A OF THE ACT. HE THEREFORE DISALLOWED I.T.A. NOS. 60 & 66/HYD/15 M/S. CH. RAMOJI RAO (HUF) :- 2 -: INTEREST U/S. 14A OF THE ACT. FURTHER, HE ALSO OBS ERVED THAT THE ASSESSEE HAS CLAIMED A SUM OF RS. 25,67,127/- AS BAD DEBTS W RITTEN OFF. THE AO OBSERVED THAT THESE BAD DEBTS WRITTEN OFF BELONG TO USHA KIRAN MOVIES INTERNATIONAL AND ADVANCES GIVEN TO VARIOUS FILM PR ODUCTION COMPANIES AND SINCE THE FILMS WERE NOT STARTED OR WERE ABANDO NED, THEY WERE WRITTEN OFF. SINCE THE ASSESSEE HAS NOT FURNISHED ANY PROOF IN SUPPORT OF THE ADVANCE PAYMENTS, THE AO DISALLOWED THE SAME. AGGRIEVED BY THE DISALLOWANCES, ASSESSEE PREFERRED AN APPEAL BEFORE THE CIT(A), WHO GRANTED PARTIAL RELIEF TO THE ASSESSEE. AGAINST TH E ADDITIONS CONFIRMED BY THE CIT(A), ASSESSEE IS IN APPEAL BEFORE US WHILE T HE REVENUE IS IN APPEAL AGAINST THE RELIEF GIVEN BY THE CIT(A). 2. THE FIRST GROUND OF APPEAL RAISED BY THE ASSESSE E IS GENERAL IN NATURE AND NEEDS NO ADJUDICATION. GROUND NO.2 IS A GAINST THE DISALLOWANCE OF INTEREST AMOUNT OF RS. 1,56,13,754/ - U/S. 14A OF THE ACT. DURING THE ASSESSMENT PROCEEDINGS, THE AO NOT ICED THAT INVESTMENTS IN SHARE CAPITAL AND SHARE APPLICATION MONEY WERE MADE OUT OF BORROWED FUNDS OF MARGADARSHI FINANCIERS WHI CH IS A DIVISION OF HUF. ASSESSEE HAD STATED THAT ONLY RS. 11 CRORES W ERE USED FROM THE BORROWED FUNDS OF THE MARGADARSHI FINANCIERS AND TH E BALANCE OF RS. 18.87 CRORES IS MET OUT OF INTERNAL GENERATION OF O THER DIVISIONS OF HUF UNITS. HE OBSERVED THAT EACH DIVISION OF THE HUF I S NOT A SEPARATE LEGAL ENTITY AND THEREFORE, THE HUF AS A WHOLE IS RUNNING ONLY ON BORROWED FUNDS AND RETURNING HUGE LOSSES. HE THUS DID NOT A CCEPT THE ASSESSEES CONTENTION OF INTERNAL ACCRUALS OF OTHER DIVISIONS OF HUF FOR INVESTMENT IN RESIDENTIAL PROPERTY / WITHDRAWALS ETC. THE AO CALLED FOR THE YEAR- WISE DETAILS OF VARIOUS INVESTMENTS MADE BY THE HUF AS A WHOLE ALONG WITH THE PROFIT AVAILABLE FOR THE HUF TO MAKE SUCH INVESTMENTS. THE ASSESSEE WAS ALSO REQUIRED TO FURNISH THE CASH FLOW STATEMENT OF THE HUF AS A WHOLE, FROM THE YEAR IN WHICH THE ABOVE IN VESTMENTS WERE I.T.A. NOS. 60 & 66/HYD/15 M/S. CH. RAMOJI RAO (HUF) :- 3 -: MADE, IN ORDER TO VERIFY THE UTILIZATION OF INCOME/ PROFIT GENERATED BY THE HUF FOR THE PURPOSE OF MAKING THE INVESTMENTS. THE ASSESSEE SUBMITTED THE DETAILS. BUT, THE AO WAS NOT SATISFI ED WITH THE SAME AND HELD THAT THE DETAILS FURNISHED WERE INCOMPLETE AND DID NOT PROVE THE AVAILABILITY OF INCOME GENERATED BY THE HUF FOR MAK ING THE ABOVE INVESTMENTS VIZ-A-VIZ THE BORROWED FUNDS. THE AO T HERE AFTER WORKED OUT THE CUMULATIVE INTEREST DISALLOWABLE U/S. 14A ON BORROWALS TO REPAY INTEREST AT RS. 1,56,13,754/- BOTH U/S. 36(1)(III) AS WELL AS U/S. 14A OF THE ACT. THE CIT(A) HAS CONFIRMED THE ADDITION. A T THE TIME OF HEARING, THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE SAME ISSUE HAD ARISEN IN ASSESSEES OWN CASE FOR THE AYS. 2005-06 TO 2008-09 AND A BENCH OF THIS TRIBUNAL VIDE ORDERS DATED 20-02-2015 HAS HELD THAT SUCH DISALLOWANCE CANNOT BE MADE. A COPY OF THE SAID OR DER IS FILED BEFORE US. WE FIND THAT ONE OF US I.E., AM WAS A SIGNATORY TO THE SAID ORDER. PARA 9 OF THE TRIBUNAL ORDER IS AS UNDER: '9. WE HAVE HEARD THE ARGUMENTS OF BOTH THE SIDES A ND ALSO PERUSED THE RELEVANT MATERIAL ON RECORD. AS RIGHTLY CONTENDED BY THE LEA RNED COUNSEL FOR THE ASSESSEE, INVESTMENT MADE IN THE SHARE APPLICATION MONEY TILL ITS CONVERSION INTO SHARES BEING NOT CAPABLE OF EARNING ANY INCOME, WHICH IS E XEMPT FROM TAX, EXPENDITURE INCURRED BY THE ASSESSEE IN RELATION TO THE MAKING OF SUCH INVESTMENTS INCLUDING INTEREST PAID ON THE BORROWED FUNDS TO THE EXTENT I NVESTED IN SHARES APPLICATION MONEY CANNOT BE DISALLOWED BY INVOKING THE PROVISIO NS OF S.14A. THE LEARNED CIT(A), IN OUR OPINION, THEREFORE, WAS CORRECT IN HOLDING THAT THE PROVISIONS OF S.14A WERE NOT APPLICABLE FOR MAKING DISALLOWANCE O N ACCOUNT OF INTEREST ATTRIBUTABLE TO THE INVESTMENTS MADE BY THE ASSESSE E IN SHARE APPLICATION MONEY, BUT FINALLY CONFIRMING THE DISALLOWANCE MADE BY THE ASSESSING OFFICER ON ACCOUNT OF SUCH INTEREST BY HOLDING THAT THE SAME D ID NOT REPRESENT THE EXPENDITURE WHOLLY AND EXCLUSIVELY INCURRED BY THE ASSESSEE FOR THE PURPOSE OF ITS BUSINESS. AS REGARDS QUANTUM OF INTEREST DISALL OWED BY THE ASSESSING OFFICER, WE FIND THAT THE DISALLOWANCE OF INTEREST COMPUTED BY THE ASSESSING OFFICER ON COMPOUNDING BASIS WAS NOT SUSTAINABLE, AS THE SAME RESULTED IN NOTIONAL DISALLOWANCE, WHICH IS NOT PERMISSIBLE IN LAW, AND THE LEARNED CIT(A) THEREFORE, WAS FULLY JUSTIFIED IN DIRECTING THE ASSESSING OFFI CER TO VERIFY THE ACTUAL EXPENDITURE INCURRED BY THE ASSESSEE ON ACCOUNT OF INTEREST ON THE BORROWED FUNDS UTILISED FOR MAKING PAYMENT OF SHARE APPLICAT ION MONEY AND TO RESTRICT THE DISALLOWANCE TO THAT EXTENT. WE THEREFORE, FIND NO MERIT IN GROUND NOS. 2 TO 4 RAISED BY THE REVENUE IN ITS APPEAL AND DISMISS THE SAME'. I.T.A. NOS. 60 & 66/HYD/15 M/S. CH. RAMOJI RAO (HUF) :- 4 -: SINCE THE FACTS AND CIRCUMSTANCES ARE THE SAME, WE REMAND THE ISSUE TO THE FILE OF THE AO FOR VERIFICATION AS DIR ECTED BY THE TRIBUNAL IN THE EARLIER ASSESSMENT YEARS. GROUND NO.2 IS THUS ALLOWED FOR STATISTICAL PURPOSES. 3. AS REGARDS GROUND NO.3, THE AO HAS DISALLOWED A SUM OF RS. 1,94,38,246/- BEING COMPOUND INTEREST ON INVESTMENT ON RESIDENTIAL BUILDING IN RAMOJI FILM CITY. 4. THE LD. COUNSEL FOR THE ASSESSEE RELIED UPON THE ORDER OF THE TRIBUNAL WHILE THE LD. DR SUPPORTED THE ORDERS OF T HE AUTHORITIES BELOW. 5. WE FIND THAT THE TRIBUNAL IN ASSESSEES OWN CASE FOR THE AYS. 2005-06 TO 2008-09 AT PARA 26 OF ITS ORDER HAS HELD AS UNDER: '26. WE HAVE HEARD THE ARGUMENTS OF BOTH THE SIDES AND ALSO PERUSED THE RELEVANT MATERIAL ON RECORD. THE LEARNED COUNSEL F OR THE ASSESSEE HAS REITERATED BEFORE US THE SUBMISSIONS MADE BY THE ASSESSEE ON S IMILAR ISSUE BEFORE THE LEARNED CIT(A) FOR ASSESSMENT YEAR 2005-06, THAT OUT OF THE TOTAL INVESTMENT OF RS.29.68 CRORES MADE IN THE RESIDENTIAL BUILDING, A SUM OF RS.18.68 CRORES WAS OUT OF OWN FUNDS, WHEREAS THE BALANCE AMOUNT OF RS. 11 CRORES ONLY WAS UTILISED OUT OF THE FUNDS BORROWED ON INTEREST. HE HAS CONTE NDED THAT INTEREST ATTRIBUTABLE ONLY TO THE BORROWED FOUNDS, THEREFORE, IS LIABLE T O BE DISALLOWED AND THE DISALLOWANCE OF RS.4,39,25,177 MADE BY THE ASSESSIN G OFFICER ON THIS COUNT IS EXCESSIVE AND UNREASONABLE. IN THIS REGARD, IT IS OBSERVED THAT KEEPING IN VIEW THE SIMILAR STAND TAKEN BY THE ASSESSEE IN ASSESSME NT YEAR 2005-06, A DIRECTION WAS GIVEN BY THE LEARNED CIT(A) TO THE ASSESSING OF FICER TO VERIFY THE EXACT AMOUNT OF INTEREST EXPENDITURE INCURRED BY THE ASS ESSEE WITH RESPECT TO THE RESIDENTIAL BUILDING AT RAMOJI FILM CITY AND MAKE A DISALLOWANCE TO THAT EXTENT. IN HIS IMPUGNED ORDER FOR ASSESSMENT YEAR 2006-07, THE LEARNED CIT(A) HAS FOLLOWED HIS OWN ORDER FOR THE ASSESSMENT YEAR 2005 -06 AND HAS GIVEN A SIMILAR DIRECTION TO THE ASSESSING OFFICER TO VERIFY THE EX ACT AMOUNT OF INTEREST EXPENDITURE CLAIMED BY THE ASSESSEE WITH RESPECT TO THE RESIDENTIAL BUILDING AT RAMOJI FILM CITY AND MAKE DISALLOWANCE TO THAT EXTE NT. WE THEREFORE, FIND NO INFIRMITY IN THE IMPUGNED ORDER OF THE LEARNED CIT( A) ON THIS ISSUE AND UPHOLDING THE SAME, WE DISMISS GROUND NO.3 OF THE ASSESSEES APPEAL'. 6. WE FIND THAT IN THE ORDER IMPUGNED BEFORE US, TH E CIT(A) HAD NOT REMITTED THE ISSUE TO THE FILE OF AO AS DONE IN THE YEARS 2005-06 TO 2008- I.T.A. NOS. 60 & 66/HYD/15 M/S. CH. RAMOJI RAO (HUF) :- 5 -: 09 BUT HAS CONFIRMED THE ADDITION MADE BY THE AO. IN THE LIGHT OF THE DIRECTIONS OF THE TRIBUNAL IN THE ASSESSEES OWN CA SE FOR THE EARLIER ASSESSMENT YEAR, WE SET ASIDE THE ISSUE TO THE FILE OF AO AND DIRECT THE AO TO VERIFY THE EXACT AMOUNT OF INTEREST EXPENDITU RE INCURRED BY THE ASSESSEE WITH RESPECT TO RESIDENTIAL BUILDING AT RA MOJI FILM CITY AND MAKE DISALLOWANCES TO THAT EXTENT ONLY. THE GROUND NO.3 IS ACCORDINGLY ALLOWED FOR STATISTICAL PURPOSES. 7. GROUND NO.4 IS AGAINST THE ADDITION OF RS. 6,23, 826/- ON ACCOUNT OF DISALLOWANCE OF INTEREST ATTRIBUTABLE TO DOMESTI C EXPENDITURE. WE FIND THAT THIS ISSUE HAS ALSO ARISEN IN THE ASSESSEES O WN CASE FOR THE EARLIER ASSESSMENT YEAR AND THE TRIBUNAL AT PARA 20 OF ITS ORDER HELD AS UNDER: '20. WE HAVE HEARD THE ARGUMENTS OF BOTH THE SIDES AND ALSO PERUSED THE RELEVANT MATERIAL ON RECORD.. THE LEARNED DEPARTME NTAL REPRESENTATIVE HAS CONTENDED THAT THE CLAIM OF THE ASSESSEE OF HAVING MADE THE WITHDRAWALS FOR HOUSEHOLD PURPOSES OUT OF THE PROFITS GENERATED IN M/S. USHODAYA NEWS AGENCY WAS NOT SUPPORTED BY ANY EVIDENCE AND STILL THE LEA RNED CIT(A) ACCEPTED THE SAME WITHOUT DISCUSSING THE RELEVANT FACTS AND FIGU RES AND WITHOUT REFERRING TO ANY DOCUMENTARY EVIDENCE. WE FIND MERIT IN THIS CON TENTION OF THE LEARNED DEPARTMENTAL REPRESENTATIVE. IT IS OBSERVED THAT N O CASE WAS MADE OUT BY THE ASSESSEE BEFORE THE ASSESSING OFFICER TO SHOW THAT THE WITHDRAWALS FOR HOUSEHOLD PURPOSES WERE MADE BY THE ASSESSEE OUT OF THE PROFITS GENERATED IN M/S. USHODAYA NEWS AGENCY AND THIS CLAIM APPARENTLY MADE BY THE ASSESSEE FOR THE FIRST TIME BEFORE HIM WAS ACCEPTED BY THE L EARNED CIT(A) WITHOUT DISCUSSING THE RELEVANT FACTS AND FIGURES AND WITHO UT REFERRING TO ANY DOCUMENTARY EVIDENCE, WHICH SUPPORTED THE CLAIM OF THE ASSESSEE. AS CONTENDED BY THE LEARNED COUNSEL FOR THE ASSESSEE, THE ASSESS EE, HOWEVER, IS IN A POSITION TO ESTABLISH HIS CLAIM BY PRODUCING THE RELEVANT EV IDENCE AS WELL AS BY FURNISHING THE RELEVANT FACTS AND FIGURES. HEW HAS REQUESTED THAT ONE MORE OPPORTUNITY MAY, THEREFORE, BE GIVEN TO THE ASSESSEE TO MAKE OU T ITS CASE BEFORE THE ASSESSING OFFICER. SINCE THE LEARNED DEPARTMENTAL REPRESENTATIVE ALSO HAS NO OBJECTION IN THIS REGARD, WE SET ASIDE THE ORDER OF LEARNED CIT(A) ON THIS ISSUE AND RESTORE THIS SAME TO THE FILE OF THE ASSESSING OFFICER FOR DECIDING IT AFRESH, AFTER GIVING THE ASSESSEE SUFFICIENT OPPORTUNITY TO ESTABLISH ITS CLAIM THAT THE WITHDRAWALS FOR HOUSE HOLD EXPENSES WERE MADE OUT O F THE PROFITS GENERATED IN USHODAYA NEWS AGENCY AND NOT OUT OF THE BORROWED FU NDS. GROUND NO.6 OF THE REVENUES APPEAL FOR ASSESSMENT YEAR 2006-07 IS ACC ORDINGLY TREATED AS PARTLY ALLOWED FOR STATISTICAL PURPOSES'. I.T.A. NOS. 60 & 66/HYD/15 M/S. CH. RAMOJI RAO (HUF) :- 6 -: 8. IN VIEW OF THE SAME, WE SET ASIDE THE FINDINGS O F THE AO AND REMIT THE ISSUE TO THE FILE OF AO WITH A DIRECTION TO VER IFY THE CLAIM OF THE ASSESSEE DENOVO AFTER GIVING THE ASSESSEE A FAIR OPPORTUNITY TO EST ABLISH ITS CLAIM THAT THE WITHDRAWALS FOR THE HOUSEHOLD EX PENSES WERE MADE OUT OF THE PROFITS GENERATED AND NOT OUT OF THE BORROWE D FUNDS. THIS GROUND OF APPEAL IS ACCORDINGLY TREATED AS ALLOWED FOR STA TISTICAL PURPOSES. 9. GROUND NO.5 IS CONSEQUENTIAL TO THE ABOVE GROUND S AND THEREFORE NEEDS NO ADJUDICATION. THE ASSESSEES APPEAL IS TH EREFORE TREATED AS PARTLY ALLOWED FOR STATISTICAL PURPOSES. REVENUES APPEAL (ITA NO. 60/HYD/2015) 10. IN THE REVENUES APPEAL, THE ONLY GROUND OF APP EAL IS AGAINST THE DELETION OF THE ADDITION MADE ON ACCOUNT OF DISALLO WANCE OF BAD DEBTS WRITTEN OFF. THE LD. DR HAS SUBMITTED THAT BEFORE THE AO, THE ASSESSEE HAD CLAIMED THAT RS. 25,67,127/- WERE ADVANCES GIVE N TO VARIOUS FILM PRODUCTION COMPANIES FOR THE FILMS WHICH DID NOT UL TIMATELY TAKE OFF AND THEREFORE THE SAME WERE WRITTEN OFF. IT IS SUBMITT ED THAT CIT(A) HAS ERRONEOUSLY HELD THEM TO BE 'BAD DEBTS WRITTEN OFF' WITHOUT VERIFICATION OF THE BOOKS OF ACCOUNT OF THE ASSESSEE. HE DREW OUR ATTENTION TO PARA 10 OF THE ORDER OF CIT(A), WHEREIN IT IS MENTIONED THA T ASSESSEE HAD STATED THAT THE ABOVE SUM WAS CONSIDERED AS INCOME IN THE EARLIER YEARS AND THEREFORE SHOULD NOT BE DISALLOWED THIS YEAR AS IT WAS WRITTEN OFF IN THE BOOKS OF ACCOUNT. THUS, ACCORDING TO HIM, THE CIT( A) HAS ALLOWED THE CLAIM WITHOUT ANY VERIFICATION AND THEREFORE, THE A DDITION SHOULD BE CONFIRMED. THE LD. COUNSEL FOR THE ASSESSEE, ON TH E OTHER HAND, SUPPORTED THE ORDER OF CIT(A) AND HAS ALSO FURNISHE D THE DETAILS OF THE ADVANCES GIVEN BY THE ASSESSEE AND ALSO THE LEDGER EXTRACTS OF THE BAD I.T.A. NOS. 60 & 66/HYD/15 M/S. CH. RAMOJI RAO (HUF) :- 7 -: DEBTS WRITTEN OFF. IT IS CERTIFIED BY HIM THAT LED GER EXTRACTS OF BAD DEBTS WRITTEN OFF WERE FILED ONLY BEFORE THE CIT(A). 11. CONSIDERING THE RIVAL CONTENTIONS, WE FIND THAT THE CIT(A) HAS NOT VERIFIED THE DETAILS FILED BY THE ASSESSEE, EVEN TH OUGH THE SAME WERE NOT FILED BEFORE THE AO. IN VIEW OF THE SAME, WE DEEM IT FIT AND PROPER TO REMIT THIS ISSUE ALSO TO THE FILE OF AO FOR VERIFYI NG THE DETAILS FILED BY THE ASSESSEE. NEEDLESS TO MENTION THAT THE ASSESSEE SH ALL BE GIVEN FAIR OPPORTUNITY OF HEARING. 12. IN THE RESULT, REVENUES APPEAL IS TREATED AS A LLOWED FOR STATISTICAL PURPOSES. 13. IN THE RESULT, ASSESSEES APPEAL IN ITA NO. 66/ HYD/2015 IS PARTLY ALLOWED FOR STATISTICAL PURPOSES AND REVENUES APPE AL IN ITA NO. 60/HYD/2015 IS ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN OPEN COURT ON 8 TH MAY, 2015 SD/- SD/- (P.M. JAGTAP) (P. MADHAVI D EVI) ACCOUNTANT MEMBER JUDICIAL MEMBER HYDERABAD, DATED 8 TH MAY, 2015 TNMM I.T.A. NOS. 60 & 66/HYD/15 M/S. CH. RAMOJI RAO (HUF) :- 8 -: COPY TO : 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-16 (2), AAYAKAR BHAVAN, BASHEERBAGH, HYDERABAD. 2. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16( 2), ROOM NO. 611, 6 TH FLOOR, AAYAKAR BHAVAN, BASHEERBAH, HYDERABAD. 3. M/S. CH. RAMOJI RAO (HUF), NO.3, CHIKOTI GARDENS , BEGUMPET, HYDERABAD. 4. CIT(APPEALS)-V, HYDERABAD. 5. CIT-IV, HYDERABAD 6. D.R. ITAT, HYDERABAD.