Appeal Details
Counselvise Citation
[2022] 106 COUNSELVISE.COM (IT) 1523 (ITAT-HYDERABAD)
Assessee PAN
Bench
Appeal Number
CRN Number
Duration Of Justice
1 year(s) 7 month(s) 14 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
28-08-2022
Appeal Filed By
Department
Order Result
Allowed
Bench Allotted
DB-A
Assessment Year
2015-2016
Appeal Filed On
14-01-2021
Judgement Text
ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 1 of 16 आयकर अपील य अ धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad Before Shri R.K. Panda, Accountant Member AND Shri Laliet Kumar, Judicial Member ITA Nos.60 & 61/Hyd/2021 Assessment Years: 2015-16 & 2016-17 A.C.I.T. Central Circle 3(2) Hyderabad Vs. Sri P. Shivmohan Reddy Hyderabad PAN:AEJPP6241H (Appellant) (Respondent) Assessee by : Shri K.C. Devdas, CA Revenue by: Shri Rajendra Kumar, CIT(DR) Date of hearing: 20/07/2022 Date of pronouncement: 29 /08/2022 ORDER Per R.K. Panda, A.M The above two appeals filed by the Revenue are directed against the separate orders dated 21.09.2020 of the learned CIT (A)-11, Hyderabad relating to A.Ys. 2015-16 & 2016- 17 respectively. Since common grounds have been raised by the assessee in both the appeals, therefore, these were heard together and are being disposed of this by common order. ITA No.60/Hyd/2021 – A.Y 2015-16 2. Facts of the case, in brief, are that the assessee is an individual and is deriving income from capital gains. He filed his original return of income u/s 139(4) of the I. T. Act on 23.2.2017 ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 2 of 16 declaring total income of Rs.8,42,71,175/-. The same was processed by the CPC on 28.7.2017. Subsequently, the case was selected for scrutiny under CASS and accordingly notice u/s 143(2) was issued on 18.9.2017. In the meantime, a search and seizure operation u/s 132 of the I. T. Act was conducted in the case of M/s. Jade Infra Projects Group and related cases on 21.11.2017. The case of the assessee was also covered. Therefore, the assessment proceedings were abated due to search and seizure operations. 3. Subsequently, the Assessing Officer issued notice u/s 153A of the Act to the assessee on 29.5.2018 and the assessee in response to the same filed his return of income on 20.8.2018 admitting total income of Rs.15,89,14,771/-. The Assessing Officer issued statutory notices u/s 143(2). Initially there was no compliance to the statutory notices for which the Assessing Officer initiated penalty proceedings u/s 271(1)(b) and order u/s 271(1)(b) was also passed on 21.11.2019 levying penalty of Rs.10,000/-. During the course of assessment proceedings, the Assessing Officer noted that certain incriminating materials were found and seized during the course of search and the statement of Shri P. Shivmohan Reddy i.e., the assessee was recorded in which he accepted that he has been receiving money in the form of cash from the buyers on sale of immovable properties. He noted that the assessee in his statement recorded u/s 132(4) had admitted an amount of Rs.3,84,70,000/- on account of cash received over and above the registered sale consideration for the impugned A.Y. However, the assessee in his return of income has not disclosed the same. The Assessing Officer extracted the questions put to the assessee during the course of search and the reply of the assessee to such queries, the relevant portion of which are as under: ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 3 of 16 “During sworn statement recorded on 23.11.2017 as per answer to question No.23, you have clearly confirmed that Rs.3,84,70,000/- was received in the form of cash by you for the A.Y 2015-16. It was stated as under, an extract of the same is produced hereunder: 22. Please give details of total commercial space sold belongs to you in Imperial Towers, Ameerpet, Hyderabad (year-wise). A. I am submitting the details of commercial space sold which belongs to me in Imperial Towers as under: A.Y 2015-16 15388 sq.ft (excluding to sale of space to my son). A.Y 2016-17 13502 sq.ft A.Y 2017-18 1950 sq. ft Total sq. ft sold 30840 sq.ft ========= 23. You deposed as reply to Q.No.20 above that you have received an amount of Rs.2500 per sq.ft in cash over and above the registered value. Similarly, you have made total sale of 30840 sq.ft during the A.Ys 2015-16 to 2017-18 in Imperial Towers, Ameerpet, Hyderabad. Please give details of cash received in the above three A.Y which was not accounted for. A. I am submitting the said details as under: A.Y Sq.Ft.sold Regd.value Actual amount received (Rs.) Difference in Rs. 2015-16 15388 83440000 121910000 38470000 2016-17 13502 61255463 95010463 33755000 2017-18 1950 8150000 13025000 4875000 Total 77100000 In view of the above, I will voluntarily offer an amount of Rs.7,71,00,000 towards taxation in the respective A.Ys in addition to the registered sale consideration received as per the annexure enclosed. Accordingly, I will file the return of income for the A.Ys 2015-16 to 2017-18 and pay the taxes applicable. 24. Do you want to say anything A Nothing” 4. He, therefore, confronted the same to the assessee. The assessee submitted an affidavit filed before the investigation wing for retraction of the sworn statement. However, the Assessing Officer rejected the same on the ground that the same is an afterthought without any proper substantial explanation. Since the assessee during the course of search in the statement had categorically admitted that the difference between the ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 4 of 16 registered value and the actual amount received in the form of cash to the extent of Rs. 3,84,70,000/- will be offered for taxation and will file the income tax return accordingly in his own sworn statement and since the assessee did not disclose the income so received in the return of income filed in response to notice u/s 143(2), the Assessing Officer made the addition of the same to total income of the assessee. 5. Before the learned CIT (A), the assessee challenged the addition made by the Assessing Officer. It was submitted that an affidavit retracting from the statement so made during the course of search in the statement recorded u/s 132(4) was filed before the Investigation Wing on 13.1.2018. It was submitted that the purported document which is part of the material found has no base at all for estimating the undisclosed income of the assessee for various A.Ys. It was submitted that the document i.e., page 48 itself was forcefully written from the assessee by the Departmental Officials at the time of search for the reasons best known to them. The answers to the statement recorded on 23.11.2017 was also extracted from the assessee who was not in proper state of mind and not knowing the implications. After consulting the legal practitioners, the assessee immediately filed an affidavit before the DDIT (Inv.) on 13.01.2018 wherein it was contended that the sworn statement dated 23.11.2017 was not voluntary and the document was forcefully written and the statement was also recorded under coercion and the assessee was not in proper state of mind. However, the Revenue Officials have not acted upon the affidavit so made by the assessee. Further, the document so seized was not signed by the assessee himself. It was just written forcibly and confirmed with the assessee as if it is found and ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 5 of 16 seized by the Department at his residential premises. Therefore, this document has no evidentiary value. 6. Referring to certain decisions it was submitted that the statement given under force or coercion is not valid under the law and the same cannot fasten a liability on a taxpayer. It was argued that mere admission does not per se become income of the assessee. It should be a valid statement in the eyes of law, taking into a/c the factual and legal position of the case. Further, it was submitted that although the assessee has given the details of the units sold, parties to whom the units were sold and the contact details were offered, the Assessing Officer without making any further enquiries acted merely based on the sworn statement of the assessee which was subsequently retracted by him within reasonable time and made the addition as unaccounted business receipts which is not legal in the eyes of law. Further, there is no evidence on record to show that the assessee has received any extra money for sale of unit at Imperial Towers, Ameerpet, Hyderabad over and above what is recorded in the sale deeds. Therefore, the addition made based on unauthenticated paper is not valid. 7. Relying on various decisions, it was argued that the addition made by the Assessing Officer is not justified. The CBDT instructions dated 18.12.2014 was also brought to the notice of the learned CIT (A) according to which the Board itself was aware of the undue influence, coercion that have come to the notice of the CBDT and that some of the appellants were forced to admit undisclosed income during search/survey conducted by the Department and in many such cases, such admissions were retracted in subsequent proceedings since the same are not ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 6 of 16 backed by credible evidence. It was accordingly directed to the Field Officer to focus on evidences during search and survey and to strictly avoid obtaining admission of additional income under coercion or undue influence. 8. Based on the arguments advanced by the assessee, the learned CIT(A) deleted the addition by observing as under: “ 7.0) I have gone through the facts of the case and the 7.0) the gone submissions of the appellant. The basis of addition the year under consideration is the noting on page 48 of Annexure A/PSMR/Hyd/17- 18/2, dated 15.03.2015. The paper purportedly contain the details of sale of unit no.5A, Ground Floor to one Sri RBN Murthy, wherein the calculation is made @ Rs.8,000/- per sq.ft. for 2300 sq.ft sold to him. The appellant's statement was recorded on 23.11.2017 during the course of search. The appellant has filed retraction in the form of affidavit dated 13.01.2018 wherein it was alleged that the above notings were got written during the course of search. There is no discussion in the order about the contents of the retraction statement/affidavit filed by the appellant. The appellant categorically stated that the contents of the paper were got written during search and the AO, simply, without bringing any facts on record has made addition based on the contents of above and the disclosure made by the AO. The appellant has pointed out that the sales were made to reputed companies (TATA AIG) at Rs.5,750/- per sq.ft. only. In view of the factual position as above and the fact that there is no evidence to show that consideration in cash was received from other buyers, the addition made does not stand on sound footing. The addition made by the AO is not backed by any corroborative evidence. The notings on a rough paper cannot be sold evidence for making addition, that too when the document/contents itself is challenged by the AO. The action of the AO in relying on the statement u/s 132(4) and the document whose authenticity is challenged by the appellant, without bringing any corroborative evidence on record, is not justified. No efforts were made to conduct any enquiries with the buyers to support the contention of the AO. Keeping in view the facts and circumstances of the case as above, the addition is not warranted and the same is deleted. The relevant grounds are allowed”. 9. Aggrieved with such order of the learned CIT (A) the Revenue is in appeal before the Tribunal by raising the following grounds of appeal: “ 1.The ld.CIT(Appeal) erred both in law and on facts of the case in allowing relief to the assessee. ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 7 of 16 2. The ld.CIT(Appeal) erred in deleting the addition made by the AO of Rs. 3,84,70,000/- on account of on-money receipt on sale of units at Imperial Towers, Ameerpet, Hyderabad, which is admitted by the assessee during the course of search, on the basis of seized material. 3. The ld.CIT(Appeal) ought to have appreciated the efforts and documentary evidence being seized material brought on record which is marked as page no. A8 of Annexure A/PSMR/Hyd/17-18/2 based on which addition was made. 4. The ld.CIT(Appeal) erred in not considering the fact that the provisions of section 132(4A) and section 292C of the Act are applicable in respect of the seized document on the basis of which addition was made. 5. The appellant craves leave to amend or alter any ground(s) or add a new ground which may be necessary”. 10. The learned DR heavily relied on the order of the Assessing Officer. He submitted that the assessee during the course of recording of his statement u/s 132(4) of the I.T. Act had himself calculated the undisclosed income on account of cash received over and above the registered sale consideration at Rs.3,84,70,000/- for A.Y 2015-16 Rs.3,37,55,000/- for A.Y 2016- 17 and for A.Y.2017-18 at Rs.48,75,000/- for three A.Ys. Therefore, retracting the same and not admitting the same in the return of income filed u/s 153A is not justified. He submitted that the ld CIT (A) without appreciating the facts properly has deleted the addition which is not justified. He submitted that the powers of the learned CIT (A) are co-terminus with that of the powers of the Assessing Officer and he can do what the Assessing Officer failed to do. Therefore, under the facts and circumstances of the case, the learned CIT (A) was not justified in deleting the addition. 11. The learned Counsel for the assessee, on the other hand, heavily relied on the order of the learned CIT (A). Reiterating the submissions made before the learned CIT (A), he ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 8 of 16 submitted that during the course of search proceedings, the Department forcefully recorded a sworn statement from the assessee for accepting that he has received additional consideration over and above the sale value of the units on a piece of paper which was made available to the assessee to write during the course of search proceedings. He submitted that the statement of the assessee was recorded u/s 132(4) on 23.11.2017. However, the assessee filed an affidavit before the DDIT (Inv.) on 30.11.2018 stating that while giving statement he was in a mental agony and the answer given therein was incorrect. He had categorically stated that he has not received any cash over and above the registered value as mentioned in the reply to question No.23. Further, there was no supporting evidences. The assessee had also stated that he was forced to give in writing of the same on the date of search by the officials of the Department and the assessee has not signed the papers. It was further submitted that although the assessee had given the names and complete address of the persons who purchased the flats, however, the Assessing Officer had not conducted any independent enquiry from the said buyers to ascertain as to whether they have given any extra money over and above what is mentioned in the sale deed. Therefore, in the absence of any corroborative evidence and merely based on a piece of paper found from the assessee, which was not signed by him and the statement which was subsequently retracted no addition can be made. 12. Referring to the decision of the Hon'ble Supreme Court in the case of CIT vs. S. Khader Khan Son (2012) reported in 352 ITR 480, he submitted that the Hon'ble Supreme Court upheld the decision of the Hon'ble Madras High Court (300 ITR ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 9 of 16 157) wherein it was held that section 133A does not empower any Income Tax Officer to examine any person on oath and therefore, the statement recorded u/s 133A has no evidentiary value and any admission made during the course of survey cannot be the basis for addition. 13. Referring to the decision of the Hon'ble A.P. High Court in the case of CIT vs. Naresh Kumar Agarwal reported in 369 ITR 171, he submitted that the Hon'ble High Court has held that retraction made within a period of 60 days is a valid retraction. It has been held that if the statement made during the course of search remains the same it can constitute the basis for proceeding further under the Act even if there is no other material. If, on the other hand, statement is retracted the Assessing Officer has to establish his own case and the statement that too retracted from the assessee cannot constitute the basis for an order u/s 158BC of the I.T. Act. 14. Referring to the decision of the Hon'ble Supreme Court in the case of CIT vs. P.V. Kalyanasundaram reported in (2007) 294 ITR 49 (S.C), he drew the attention of the Bench to the head notes which read as under: “ Certain land was sold for a sum of Rs. 4.10 lakhs. In the course of a search and seizure, contradictory statements of the vendor were recorded and loose sheets allegedly in the hands of the purchaser were found. The Assessing Officer concluded that the sale consideration was actually Rs. 34.85 lakhs and not Rs. 4.10 lakhs as recited in the deed of sale and made an addition of Rs. 30,75,005/- as undisclosed income for the block period April 1, 1988, to December 8, 1998, in the hands of the respondent (assessee). The Commissioner (Appeals), after examining the entire matter, held that the statements of the vendor could not be relied upon particularly as the floor price fixed by the authorities for such property was much lower than the value which would result if the sale deed had been registered at Rs. 34.85 lakhs and deleted the addition. The Appellate Tribunal affirmed the decision of the Commissioner (Appeals) holding, inter alia, that the notings on the loose sheets were vague and could not be relied upon. On appeal under section 260A of the ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 10 of 16 1961, the High Court, Income-tax Act, borrowing extensively from the orders of Commissioner (Appeals) and the Appellate Tribunal, held that no substantial question of law arose out of the order of the Appellate Tribunal. On appeal by Department before the Supreme Court: Held, affirming the decision of the High Court, that the implication of contradictory statements made by the vendor or whether reliance could be placed on the loose sheets recovered in the course of the raid were all questions of fact, and no question of law arose out of the order of the Decision of Appellate Tribunal”. 15. Referring to the decision of the Hon'ble Supreme Court in the case of Mehta Parikh & Co. vs. CIT reported in 30 ITR 181, he drew the attention of the Bench to the following observations of the Hon'ble Supreme Court: “ It has to be noted, however, that beyond these calculations of figures, no further scrutiny was made by the Income-tax Officer or the Appellate Assistant Commissioner of the entries in the cash book of the appellants. The cash book of the appellants was accepted and the entries therein were not challenged. No further documents or vouchers in relation to those entries were called for, nor was the presence of the deponent of the three affidavits considered necessary by either party. The appellants took it that the affidavits of these parties were enough and neither the Appellate Assistant Commissioner, nor the Income-tax Officer, who was present at the hearing of the appeal before the Appellate Assistant Commissioner, considered it necessary to call for them in order to cross examine them with reference to the statements made by them in the affidavits. Under these circumstances it was not open to the Revenue to challenge the correctness of the cash book entries or the statements made by those deponents in their affidavits.” 16. Referring to the decision of the Hon'ble Supreme Court in the case of CIT vs. Shivakami Co. P Ltd reported 159 ITR 71, he submitted that unless there is evidence that more than what was stated was received, no higher price can be taken to be the basis for computation of capital gains”. 17. Relying on various other decisions, he submitted that section 132(4) statement which was subsequently retracted has no evidentiary value unless backed by corroborative evidence. He again reiterated that the so-called statement was forcefully ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 11 of 16 recorded from the assessee and the so called piece of paper was also written by the assessee under coercion from the Department and it does not contain his signature. The statement so made u/s 132(4) was retracted within a period of 60 days and despite supplying of full details such as name and address of the persons who had purchased the flats, no independent enquiry or investigation was conducted by the Assessing Officer, therefore, under these circumstances, the learned CIT (A) is fully justified in deleting the addition. 18. We have heard the rival arguments made by both the sides, perused the orders of the AO and the learned CIT (A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us by both sides. We find the AO in the instant case made addition of Rs.3,84,70,000/- on account of cash received over and above the registered sale consideration on the basis of the statement made by the assessee u/s 132(4) of the Act during the course of search on 23.11.2017. We find the learned CIT (A) deleted the addition the reasons of which have already been reproduced in the preceding paragraphs. It is the submission of the learned DR that the assessee in his statement recorded u/s 132(4) had declared undisclosed income of Rs.7,71,00,000/-. Although the assessee had stated that he has retracted from the statement by offering the additional income, however, the same was an afterthought without any supporting evidence and therefore, is a self-serving document. It is his submission that since the powers of CIT (A) are co-terminus with that of the power of the Assessing Officer, the learned CIT (A) could have directed the Assessing Officer to conduct further enquiries on the basis of submissions made by the assessee and ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 12 of 16 he simply could not have accepted the submission of the assessee and deleted the addition. 19. We find some force in the above arguments of the learned DR. It is an undisputed fact that the assessee during the course of search in his statement recorded u/s 132(4) on 23.11.2017 had declared undisclosed income of Rs.3,84,70,000/- for the impugned A.Y, Rs.3,37,75,000/- for A.Y 2016-17 and Rs.48,75,000/- for A.Y 2017-18 all totaling to Rs.7,71,00,000/-. Although the assessee had filed an affidavit before the Investigation Wing on 13.1.2018 retracting the statement so made, however, the fact of such retraction when brought to the notice of the Assessing Officer was rejected by him in absence of any substantive explanation and treating the same an afterthought. A perusal of the seized document shows that the assessee has sold Unit No.5 at Ground Floor to one Mr. R.B.N. Murthy for a consideration of Rs.1,92,50,000/- out of which the cheque amount was shown at Rs.1,35,00,000/- and the balance amount was received in cash. We find the assessee had sold various units during the financial year 2015-16 to 2017-18 to different persons, the details of which are as under: S. No Date F.Y Name of the vendee Floor Builtup Area sq.ft Sale consideration Rate per sft. 1 27.2.15 2014-15 S.Rajmouli & others Gr.Floor 340 19,62,000 5771 2 27.2.15 2014-15 -do- 1 st 8108.18 4,06,88,000 5018 3 19.3.15 2014-15 K.Krishna Gr.Floor 1840 1,09,20,000 5935 4 19.3.15 2014-15 R.B.N. Murty Gr.Floor 2300 1,35,00,000 5870 5 19.3.15 2014-15 K.Durgaprasad Gr.Floor 2300 1,35,00,000 5870 6 16.3.15 2014-15 Sunmeet Singh Kohli & others Gr.Floor 500 28,70,000 5740 7 25.3.15 2014-15 Siva Charan Reddy7 th Floor 2380 1,00,13,000 4207 8 10.2.16 2015-16 Vesta Tech. Pvt Ltd 4 th floor 2800 1,17,55,000 4198 9 25.2.16 2015-16 S.Rajmouli & Others 2 nd floor 10702 4,95,00,463 4625 ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 13 of 16 10 1.12.16 2016-17 Kanakadurga Chit Fund Ltd 3 rd floor 1950 81,50,000 4179 11 10.8.17 2017-18 TATA AIG General Insurance 3 rd floor 19000 10,92,50,000 5750 12 1.9.17 2017-18 Pratyusha Gorinka & Pradeepa Rao Gr.Floor 1180 82,60,000 7000 534000 28,03,68,463 5,250 20. Although it is the submission of the learned Counsel for the assessee that he has retracted from the statement within a period of 60 days by filling an affidavit before the Investigation Wing, we find the Assessing Officer rejected such retraction treating the same as an afterthought and not based by any substantive explanation. Further, it is also an admitted fact that the assessee was not complying to the statutory notices before the Assessing Officer for which penalty of Rs.10,000/- was levied under the provisions of section 271(1)(b) of the I. T. Act. So far as the contention of the learned Counsel for the assessee that the Assessing Officer has not made any enquiry is concerned, which the CIT (A) has also accepted, we find the CIT (A) failed in his duty by not conducting any enquiry himself by calling for a remand report from the Assessing Officer or by giving direction to him to conduct further enquiries before deciding the issue. It is the settled proposition of law that the powers of the CIT (A) are co- terminus with that of the Assessing Officer. If the Assessing Officer has failed to do something, the CIT (A) can do the same. Since the assessee in the instant case has sold flats in different floors to different persons at different rates, and a piece of paper was found during the course of search containing cash receipts, therefore, the CIT (A) atleast should have conducted some enquiries by directing the Assessing Officer to conduct further enquiries by calling for details or by summoning other parties to find out the truth. Since the learned CIT (A) has failed in his duty by not directing the Assessing Officer to conduct enquiries before ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 14 of 16 coming to the conclusion that the assessee has not received any extra money over and above what has been declared in the return and since the assessee himself has admitted before the Investigation Wing by declaring additional income of Rs.7,71,00,000/- for the A.Ys 2015-16 to 2017-18, therefore, considering the totality of the facts of the case and in the interest of justice, we deem it proper to restore the issue to the file of the Assessing Officer with a direction to decide the issue afresh by conducting further enquiries either by calling for information or by issuance of summons to various other parties as he deems fit on the basis of details given by the assessee before the learned CIT (A) and decide the issue as per fact and law. Needless to say, the Assessing Officer shall give due opportunity of being heard to the assessee as per law. We hold and direct accordingly. The Grounds raised by the Revenue are accordingly allowed for statistical purposes. ITA No. 61/Hyd/2021 A.Y 2016-17 21. The grounds raised by the Revenue reads as under: “1. The ld.CIT(Appeal) erred both in law and on facts of the case in allowing relief to the assessee. 2. The ld.CIT(Appeal) erred in deleting the addition made by the AO of Rs3,37,55,000/- on account of on-money receipt on sale of units at Imperia. Towers, Ameerpet, Hyderabad, which is admitted by the assessee during the course of search, on the basis of seized material. 3. The ld.CIT(Appeal) ought to have appreciated the efforts and documentary evidence being seized material brought on record which is marked as page N o.48 of Annexure A/PSMR/Hyd/17-18/2 based on which addition was made. 4. The ld.CIT(Appeal) erred in not considering the fact that the provisions of section 132(4A) and section 292C of the Act are applicable in respect of the seized document on the basis of which addition was made. 5. The appellant craves leave to amend or alter any ground or add a new ground(s which may be necessary”. ITA Nos 60 and 61 P Shivmohan Reddy Hyderabad Page 15 of 16 22. After hearing both sides, we find the grounds raised by the Revenue are identical to the grounds of appeal in ITA No.60/Hyd/2021. We have already decided the issue and the grounds raised by the Revenue has been allowed for statistical purposes. Following similar reasonings, the grounds raised by the Revenue are allowed for statistical purposes. 23. In the result, both the appeals filed by the Revenue are allowed for statistical purposes. Order pronounced in the Open Court on 29 th August, 2022. Sd/- Sd/- (LALIET KUMAR) JUDICIAL MEMBER (R.K. PANDA) ACCOUNTANT MEMBER Hyderabad, dated 29 th August, 2022. Vinodan/sps Copy to: S.No Addresses 1 ACIT Central Circle 3(2) 7 th Floor, Aayakar Bhavan, Hyderabad 2 Shri P. Shivmohan Reddy, 6-3-1085/1 Alpine Heights, Raj Bhavan Road, Somajiguda, Hyderabad 3 CIT (A)-11,Hyderabad 4 Pr. CIT- Central, Hyderabad 5 DR, ITAT Hyderabad Benches 6 Guard File By Order
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