The ACIT, 3(1), Indore V. M/S. KEHEMS ENGINEERING PVT. LTD., Indore

ITA 602/IND/2014

• Counselvise Citation: [2016] 133 COUNSELVISE.COM (IT) 5880 (ITAT-INDORE)
• Duration Of Justice: 1 year(s) 3 month(s) 12 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-01-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2010-2011
• Appeal Filed On: 23-09-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R R MEENA
• Assessee Lawyers: MANOJ PHADNIS
• Keywords: Corroborative evidences

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL, INDORE BENCH, INDORE BEFORE SHRI D.T. GARASIA, JUDICIAL MEMBER AND SHRI B.C.MEENA, ACCOUNTANT MEMBER I.T.A.NO. 602 /IND/201 4 A.Y. : 2010-11 ACIT, M/S.KEHEMS ENGINEERING PRIVATE LTD., 3(1), VS. INDORE. INDORE. APPELLANT RESPONDENT PAN NO.AABCK3441M APPELLANTS BY : SHRI R.R.MEENA, DR RESPONDENT BY : SHRI MANOJ PHADNIS, CA DATE OF HEARING : 04. 1 1 .2015. DATE OF PRONOUNCEMENT : 05 . 01 .201 6 ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 2 2 O R D E R PER D. T. GARASIA, J.M. TH IS APPEAL BY THE REVENUE IS DIRECTED AGAINST THE OR DER OF CIT(A)-I, INDORE, FOR THE ASSESSMENT YEAR 2010-11. 2. THE GROUNDS RAISED BY THE REVENUE IN THIS APPEAL AR E AS UNDER :- ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE LD. CIT(A) (I) ERRED IN DELETING THE ADDITION OF RS. 39,91,541/- ON ACCOUNT OF DISALLOWANCE OF FINANCE & INTEREST CHARGES WITHOUT CONSIDERING THAT IF THE ASSESSEE H AD INTEREST-FREE FUNDS WHICH WAS ADVANCED AS INTEREST- FREE DEPOSIT TO ITS SISTER CONCERN AND THEN THE ASSESSEE BORROWS INTEREST-BEARING FUNDS TO MEET ITS BUSINESS NEEDS; IT ONLY MEANS THAT THE DIVERTED FUN D HAS BEEN SUPPLEMENTED BY THE INTEREST-BEARING FUNDS . (II) ERRED IN DELETING THE AFORESAID ADDITION WITHOUT APPRECIATING THE FACT THAT THE ASSESSEE COMPANY WAS ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 3 3 INCORPORATED IN OCTOBER, 1994, RAISED SHARE CAPITAL & OTHER FUNDS AND MORE THAN 98% OF THE FUND SO RAISED WAS GIVEN TO THE SISTER-CONCERN IN MARCH,1995, ITSE LF. NO PRUDENT BUSINESS ENTITY WOULD STRIP ITSELF OFF T HE ENTIRE FUND IT HAS. CLEARLY, THE ADVANCING OF DEPOS IT TO THE SISTER-CONCERN HAD NO BUSINESS EXIGENCY; AND ON THIS GROUND ALONG, THE ADDITION WAS REQUIRED TO BE UPHELD. (III) ERRED IN DELETING THE AFORESAID ADDITION WITHOUT APPRECIATING THAT NO BREAK-UP OF INTEREST FEE FUNDS AND INTEREST-BEARING FUNDS WAS PROVIDED BY THE ASSESSEE; HENCE, IT IS INCORRECT TO SAY ON THE PART OF THE LD. CIT(A) THAT THE SAID ADVANCE TO THE SISTER- CONCERN (GIVEN IN 1995) STILL REPRESENTS INTEREST-F REE FUNDS (IN F.Y. 2009-10). (IV) ERRED IN DELETING THE AFORESAID ADDITION IGNORING T HE FACTS NARRATED IN THE ASSESSMENT ORDER AND FURTHER IGNORING THE CASE OF ACIT VS. PUNJAB STAINLESS STEE L INDUSTRIES, 128 ITR 12, WHICH IS SQUARELY APPLICABL E ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 4 4 IN THE ASSESSEES CASE. (V) ERRED IN DELETING THE ADDITION OF RS. 2,00,000/- ON ACCOUNT OF THE ASSESSEES FAILURE TO PRODUCE CORROBORATIVE EVIDENCE AND TO ESTABLISH THAT THE EXPENSES WERE IDENTICAL TO BUSINESS, WITHOUT APPRECIATING THAT THE ASSESSEE WAS DULY BOUND TO PRODUCE/ESTABLISH THE SAME, WHICH IT HAS FAILED DESPITE CONSUMING ADEQUATE OPPORTUNITIES. 3. GROUND NO. 1 RELATES TO THE ADDITION OF RS 39,91,54 1/- ON ACCOUNT OF DISALLOWANCE U/S 36(1)(III) OF THE INCOM E-TAX ACT, 1961. 4. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE F ILED THE RETURN OF INCOME FOR THE ASSESSMENT YEAR 2010-11 T HROUGH E- FILING VIDE ACKNOWLEDGEMENT NUMBER 157622771220910 DECLARING TOTAL INCOME OF RS 28,31,680/-. DURING TH E ASSESSMENT PROCEEDINGS, THE LD. AO HAS MADE CERTAIN ADDITIONS AGAINST WHICH THE ASSESSEE IS IN APPEAL. THE ASSESS EE COMPANY HAD GIVEN A DEPOSIT OF RS 610 LACS IN 1995 TO M/S KEHEMS ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 5 5 CONSULTANTS PRIVATE LIMITED IN PURSUANCE OF LICENSE AGREEMENT TO ACQUIRE TECHNOLOGY AND THE RELEVANT TECHNICAL KN OW-HOW. THE COPY OF THE AGREEMENT AND THE RELATED DETAILS WERE FILED BEFORE THE AO. BY THE ASSESSEE VIDE REPLY DATED 25 TH MARCH 2013. THE ASSESSEE HAS FURTHER INFORMED VIDE ITS REPLY DATED 28 TH MARCH THAT THE ASSESSEE COMPANY HAD GIVEN A D EPOSIT OF RS 610 LACS IN 1995 TO M/S KEHEMS CONSULTANTS PRIVATE LIMITED I N PURSUANCE OF LICENSE AGREEMENT TO ACQUIRE TECHNOLOG Y AND THE RELEVANT TECHNICAL KNOW-HOW. THE COPY OF THE AGREEM ENT AND THE RELATED DETAILS WERE ALSO FILED WITH THE REPLY DATE D 25 TH MARCH 2013. THE DEPOSIT WAS GIVEN IN THE YEAR 1995 OUT OF SHARE CAPITAL AND OTHER INTEREST FREE FUNDS AVAILABLE WIT H THE COMPANY IN 1995. THE SAID DEPOSIT HAS NOW REDUCED TO RS 485 LACS DURING THE YEAR UNDER ASSESSMENT. DURING THE YEAR, THE COMPANY HAS PAID INTEREST AND BANK CHARGES AMOUNTIN G TO RS 39,91,541/-. THIS AMOUNT IS INCURRED ON THE AGGREGA TE LOANS OF RS 2,09,01,707/-. OUT OF THIS, RS 1,91,96,921/- IS CASH CREDIT LOANS AGAINST THE STOCKS AND THE SUNDRY DEBTORS AND THE REMAINING RS 17,04,785/- IS TOWARDS THE FINANCE FOR THE ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 6 6 VEHICLES. THESE LOANS HAVE BEEN ACQUIRED MUCH LATER TO THE FINANCIAL YEAR 1995 WHEN THE COMPANY HAD GIVEN THE SECURITY DEPOSITS. THUS THE INTEREST PAID IS TOWARDS THE LOA NS BORROWED FOR THE PURPOSE OF THE BUSINESS OF THE COMPANY. THE DEPOSIT OF RS 485 LACS OUTSTANDING AS AT 31 ST MARCH 2010 IS NOT FINANCED FROM THE BORROWED MONEY BUT IS FROM THE SHARE CAPIT AL RAISED BY THE COMPANY IN THE YEAR 1995. ON THE BASIS OF THE C LEAR FACTS AS MENTIONED ABOVE, THE INTEREST PAID BY THE COMPANY C ANNOT BE CONSIDERED AS BEING IN ANY WAY ATTRIBUTABLE TOWARDS THE INTEREST FREE DEPOSIT GIVEN BY THE COMPANY. THE AGGREGATE OF THE SHARE CAPITAL AND FREE RESERVES OF THE COMPANY ARE AS UND ER:- PARTICULARS 31.03.2 010 31.03.2009 SHARE CAPITAL 5,49,76,300.00 5,49,76,300.00 RESERVES AND SURPLUS 2,34,36,064.00 2,16,35,207.00 TOTAL 7,84,12,364.00 7,66,11,507.00 INTEREST FREE DEPOSIT 4,85,00,000.00 4,85,00,000.00 THAT FROM THE FOREGOING IT WILL BE EVIDENT THAT THE INTEREST FREE FUNDS AVAILABLE WITH THE COMPANY ARE FAR IN EXCESS OF THE INTEREST FREE LOAN GIVEN BY THE COMPANY. THIS IS WI THOUT ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 7 7 PREJUDICE TO THE CONTENTION THAT AS THE DEPOSIT IS GIVEN IN THE YEAR 1995, THIS COMPARISON ITSELF IS NOT WARRANTED. 5. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE AO OBSERVED FROM THE SCHEDULE-8 OF THE BALANCE SHEET R ELATING TO LOANS, ADVANCES AND DEPOSITS, THE ASSESSEE COMPANY HAS SHOWN ADVANCES AT RS. 5,09,61,406.31 NARRATING AS DEPOSIT WITH GOVERNMENT DEPARTMENT AND OTHERS. THE ASSESSE E WAS ASKED TO SUBMIT THE DETAILS OF THESE ADVANCES AND A MOUNT OF INTEREST RECOVERED. IN RESPONSE THE ASSESSEE SUBMIT TED THE LIST OF ADVANCES/DEPOSITS. THE AO FOUND THAT THE ASSESSE E HAD ALSO MADE DEPOSIT OF RS. 4,85,00,000/- TO ITS SISTER CON CERN M/S. KEHEMS CONSULTANTS PRIVATE LIMITED AND NO INTEREST ON THIS AMOUNT HAS BEEN CHARGED AND THE ASSESSEE WAS ASKED AS TO WHY THE INTEREST PAID BY THE ASSESSEE SHOULD NOT BE DISALLOWED KEEPING IN VIEW THAT THE ASSESSEE HAS MADE INTEREST FREE ADVANCE TO ITS SISTER CONCERN BY WAY OF SECURITY DE POSIT AGAINST BUSINESS RIGHT. IN REPLY THE ASSESSEE SUBMITTED ITS REPLY DATED 28.03.2013 THAT IT HAVE SUFFICIENT INTEREST FREE FU ND FOR MAKING THE ADVANCES TO ITS SISTER CONCERN AND THE ADVANCES MADE IN THE ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 8 8 YEAR 1995. THE SUBMISSION OF THE ASSESSEE WAS CONSIDERED BUT THE SAME WAS NOT ACCEPTABLE AS THE COMPANY HAVE BOT H TYPES OF FUND I.E. INTEREST FREE AS WELL INTEREST BEARING DU RING THE YEAR UNDER CONSIDERATION. HE FURTHER MENTIONED THAT THE ASSESSEE COMPANY WAS INCORPORATED IN OCTOBER,1994 AND THE AS SESSEE COMPANY HAD GIVEN ADVANCES IN MARCH,1995, AS SUCH A T THAT TIME THE COMPANY COULD HAVE ONLY ITS SHARE CAPITAL AS INTEREST FREE FUNDS. HE FURTHER OBSERVED THAT THE PAID UP SH ARE CAPITAL OF THE COMPANY EVEN AT THE END OF THE YEAR UNDER CONSI DERATION WAS RS. 5,49,76,300/-. HE FURTHER OBSERVED THAT TH E AMOUNT OF PAID UP CAPITAL OF THE COMPANY AT THE END OF THE YE AR IN MARCH, 1995 I.E. AT THE TIME OF MAKING INTEREST FREE ADVA NCES TO ITS SISTER CONCERN MUST HAVE LESS THAN THE AMOUNT AS ST ATED IN BALANCE OF THE YEAR. AS SUCH THE ASSESSEES CLAIM T HAT IT HAVE INTEREST FREE FUND ON THE DATE OF MAKING ADVANCE TO ITS SISTER CONCERN IS TOTALLY WRONG. THE AO FURTHER RELIED ON THE HONBLE ITAT, DELHI, IN CASE OF ACIT VS. PUNJAB STAINLESS S TEEL INDUSTRIES REPORTED IN 128 ITR 12. IN THIS CASE, TH E ASSESSEE CLAIMED THAT IT GAVE INTEREST FREE ADVANCES FROM I TS OWN FUNDS ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 9 9 AND THEN BORROWED FUNDS FROM BANKS CAN BE TREATED A S FOR SUPPLEMENTING CASH DIVERTED BY ASSESSEE WITHOUT ANY BENEFIT TO IT-CLAIM FOR DEDUCTION OF INTEREST ON BORROWING DIS ALLOWED BY AO AND CONFIRMED BY THE ITAT. THE AO DISALLOWED THE F INANCE AND INTEREST CHARGES CHARGED IN THE PROFIT AND LOSS ACC OUNT AT RS. 39,91,541/- AND ADDED TO THE INCOME OF THE ASSESSEE . 6. THE MATTER CARRIED TO THE LD. CIT(A) AND THE LD. CI T(A) DELETED THE ADDITION. 7. THE LD. DR RELIED UPON THE ORDER OF AO. 8. THE LD. AUTHORIZED REPRESENTATIVE FOR THE ASSESSEE HAS CONTENDED THAT THE LD. AO HAS FAILED TO TAKE PROPER NOTE OF THE BALANCE SHEET OF THE COMPANY FOR THE PERIOD ENDING 31 ST MARCH 1996, BEING THE FIRST ACCOUNTING YEAR OF THE COMPA NY, WHICH VERY CLEARLY SHOWS THE FOLLOWING POSITION:- PARTICULARS 31.03.1996 SHARE CAPITAL 4,50,03,000 RESERVE AND SURPLUS 35,36,189 UNSECURED LOANS FROM PROMOTERS 1,34,36,221 TOTAL 6,19,75,410 INTEREST FREE DEPOSITS 6,10,00,000 ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 10 10 THE L D. AO HAS FAILED TO FOLLOW THE DIRECT DECISION OF H ON'BLE BOMBAY HIGH COURT IN THE CASE OF CIT VS. RELIANCE UTILITIES AND POWER LIMITED, (2009) 313 ITR 340, WHEREIN IT IS HELD THAT WHERE THE ASSESSEE POSSESSED SUFFICIENT INTEREST FREE FUN DS OF ITS OWN WHICH WERE GENERATED IN THE COURSE OF THE RELEVANT FINANCIAL YEAR, PART FROM SUBSTANTIAL SHAREHOLDERS FUNDS, PRE SUMPTION SANDS ESTABLISHED THAT THE INVESTMENT IN SISTER CON CERNS WERE MADE BY THE ASSESSEE OUT OF INTEREST-FREE FUNDS AND THEREFORE NO PART OF INTEREST ON BORROWINGS CAN BE DISALLOWED ON THE BASIS THAT THE INVESTMENTS WERE MADE OUT OF INTEREST BEAR ING FUNDS. THE LD. AO HAS ERRED IN LAW IN PLACING RELIANCE ON THE DECISION OF DELHI ITAT REPORTED AS THE ASSESSEE CLAIMED THAT IT GAVE INTEREST-FREE ADVANCES FROM ITS OWN FUNDS AND THEN BORROWED FUNDS FROM BANKS CAN BE TREATED AS FOR SUPPLEMENTIN G CASH DIVERTED BY ASSESSEE WITHOUT ANY BENEFIT TO IT - CL AIM FOR DEDUCTION OF INTEREST AN BORROWING DISALLOWED BY AO AND CONFIRMED BY THE ITAT. IT IS WELL SETTLE PRINCIPLE THAT IN THE EVENT OF TWO CONFLICTING DECISION OF HIGH COURT, THE DECI SION WHICH IS IN FAVOR OF THE ASSESSEE SHOULD BE FOLLOWED CIT V S. VEGETABLE ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 11 11 PRODUCTS LTD.[1973] 88 ITR 192 SC. IN THE PRESENT C ASE THE ID. AO HAS FOLLOWED THE DECISION OF ITAT IN CONTRAST TO A DECISION OF THE HIGH COURT. THE DECISION RENDERED IN THE CASE OF ACIT VS. PUNJAB STAINLESS STEEL INDUSTRIES REPORTED IN 128 I TR 12 IS BASED ON FACTS COMPLETELY DIFFERENT FORM THE INSTAN T CASE AND IS THEREFORE NOT APPLICABLE IN THE ASSESSEES CASE. TH E ADDITION MADE BY THE ID. AO IS NOT SUSTAINABLE ON THE FACTS AND IN LAW AND THEREFORE THE ADDITION MADE BE DELETED. 9. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PA RTIES. LOOKING TO THE FACTS AND CIRCUMSTANCES OF THE CASE, WE FIND THAT THE ASSESSEE WAS HAVING SUFFICIENT INTEREST FREE FU NDS TO EXTEND AN ADVANCE OF RS. 6.10 CRORES TO ITS SISTER CONCERN IN THE ASSESSMENT YEAR 1996-97. THE LD. DR COULD NOT POINT OUT ANYTHING CONTRARY TO THE FINDING OF THE LD. CIT(A). WE UPHOLD THE ACTION OF THE LD. CIT(A). GROUND NO. 1 OF THE REVEN UE IS DISMISSED. GROUND NO. 2 : 10. GROUND NO. 2 RELATES TO THE ADDITION OF RS. 2,00,0 00/- MADE ON ACCOUNT OF DISALLOWANCE OF CERTAIN EXPENSE S. ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 12 12 11. THE AO MADE FURTHER LUMP SUM DISALLOWANCE OF RS. 2,00,000/- IN THE EXPENSES CLAIMED BY THE ASSESSEE ON THE GROUND THAT CERTAIN EXPENSES WERE NOT PROPERLY VOUC HED AND OPEN TO VERIFICATION. HE FURTHER MENTIONED IN THE O RDER THAT FOR AVAILING THE CLAIM OF ANY EXPENDITURE U/S 37, THE O NUS WAS ON THE ASSESSEE TO ESTABLISH THAT THE EXPENDITURE WAS EXCLUSIVELY INCURRED FOR THE PURPOSE OF BUSINESS ACTIVITY. MERE PRODUCTION OF VOUCHERS AND INVOICES ARE NOT SUFFICIENT TO EXPLAIN THE REASONABLENESS AND GENUINENESS OF SUCH EXPENDITURE. IT WAS OBLIGATORY ON THE PART OF THE ASSESSEE TO FURNISH O THER CORROBORATIVE EVIDENCES ALONGWITH THE VOUCHERS RELE VANT TO THE EXPENDITURE. THE ASSESSEE COULD NOT EXPLAIN ALL THE EXPENSES THAT ARE DEBITED TO THE PROFIT AND LOSS ACCOUNT CON CLUSIVELY WITH THE SUPPORT OF CORROBORATIVE EVIDENCES AND HE MADE LUMP SUM DISALLOWANCE OF RS. 2,00,000/-. 12. THE MATTER CARRIED TO THE LD. CIT(A) AND THE LD. CI T(A) HAS DELETED THE DISALLOWANCE MADE BY THE ASSESSING OFFI CER OBSERVING AS UNDER :- 6. GROUND NO. 2 IS AGAINST A L UMP SUM DISALLOWANCE ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 13 13 OF RS. 2 LAKH FROM CERTAIN EXPENSES WHICH ARE NOT PROPERLY VOUCHED. THIS IS AN AD HOC DISALLOWANCE, WHERE AO HAS NOT EVEN IDENTIFIED AS TO WHICH EXPENSES IS QUESTIONABLE AND UNVOUCHED. OUT OF ALL THE EXPENSES DEBITED IN THE PROFIT AND LOSS ACCOUNT, HE HAS MADE AD HOC DISALLOWANCE OF RS. 2 LAKH. SUCH AD HOC DISALLOWANCES WITHOUT IDENTIFICATION OF EXPENSE WHI CH IS NOT PROPERLY VOUCHED AND WITHOUT FINDING ANY DEF ECT IN ANY VOUCHERS IS NOT AT ALL JUSTIFIED WHEN APPELL ANT IS A COMPANY WHOSE BOOKS OF ACCOUNT ARE DULY AUDITED. GROUND NO.2 OF APPEAL IS ALSO ALLOWED. 13. THE LD. DR RELIED UPON THE ORDER OF THE AO. 14. THE LD. AUTHORIZED REPRESENTATIVE CONTENDED THAT TH E ADDITIONS WERE MADE ON AD-HOC BASIS. THE ID. AO HAS NOT POINTED OUT ANY SPECIFIC DEFECTS. THE ID. AO HAS AL SO NOT CONSIDERED THAT THE ACCOUNTS ARE DULY AUDITED AND T HAT THERE ARE NO QUALIFICATION IN THE ACCOUNTS. THE LD. AUTHO RIZED REPRESENTATIVE RELIED ON THE ORDER OF THE LD. CIT(A ). 15. WE HAVE HEARD THE RIVAL CONTENTIONS OF BOTH THE PAR TIES. ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 14 14 THE LD. DR COULD NOT POINT OUT ANYTHING CONTRARY TO THE FINDING OF THE LD. CIT(A). WE UPHOLD THE ACTION OF THE LD. CIT(A). GROUND NO.2 OF THE REVENUE ALSO FAILS. 16. IN THE RESULT, THE APPEAL OF THE DEPARTMENT IS DISM ISSED. THIS ORDER HAS BEEN PRONOUNCED IN THE OPEN COURT ON 5 TH JANUARY, 2016. SD/- (B. C. MEENA) ACCOUNTANT MEMBER SD/- ( D.T.GARASIA) JUDICIAL MEMBER DATED : 5 TH JANUARY, 2016. CPU* 9.10 ACIT,3(1), INDORE. VS. M/S. KEHEMS ENGINEERING PRI VATE LIMITED, INDORE. I.T.A.NO. 602/IND/2014 A..Y.2010-11 15 15