Asst. Commissioner of Income Tax, Circle-1, Warangal V. Warangal Urban Co-operative Bank Limited , Hyderabad

ITA 674/Hyd/2019

• Counselvise Citation: [2021] 108 COUNSELVISE.COM (IT) 7012 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 11 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-04-2021
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB-A
• Next Hearing Date: 24-02-2021
• Assessment Year: 2013-2014
• Appeal Filed On: 06-05-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SUNIL KUMAR PANDEY
• Assessee Lawyers: P MURALI MOHAN RAO
• Keywords: Depreciation; Earning of tax free income; Additional evidence; Non-deduction of tax; TDS; Rule 8D
• Section: 14A; 40(a)(ia); 201(1); 201; 43; 9(1); 9(1); 9(1); 13; 32; 139

Judgement Text

ITA NO 674 OF 2019 WARANGAL URBAN COOP. BANK LTD HYDERABAD PAGE 1 OF 7 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD A BENCH, HYDERABAD (THROUGH VIDEO CONFERENCING) BEFORE SHRI S.S. GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA NO.674/HYD/2019 ASSESSMENT YEAR: 2013-14 ASSTT. CIT, CIRCLE 1 WARANGAL VS. M/S. WARANGAL URBAN COOP. BANK LTD WARANGAL PAN:AAAAW0651J (APPELLANT) (RESPONDENT) REVENUE BY: SRI SUNIL KUMAR PANDEY, DR ASSESSEE BY : SRI P. MURALI MOHAN RAO DATE OF HEARING: 24/02/2021 DATE OF PRONOUNCEMENT: 09/04/2021 ORDER PER S.S. GODARA, J.M. THIS REVENUES APPEAL FOR A.Y 2013-14 ARISES FROM T HE CIT(A)-3, HYDERABADS ORDER DATED 15.02.2019 PASSED IN APPEAL NO. 0105/AC-CIR-1/WGL/CIT(A)-3/2016-17, IN PROCEEDINGS U/S.143(3) OF THE INCOME TAX ACT, 1961 [IN SHORT, THE ACT]. HEARD BOTH THE PARTIES. CASE FILE PERUSED. 2. THE REVENUE HAS PLEADED THE FOLLOWING SUBSTANTIV E GROUND IN THIS APPEAL: 1. THE LEARNED CIT(A) ERRED ON BOTH LAW AND FACTS OF THE CASE. 2. THE LEARNED CIT(A) ERRED IN ALLOWING THE APPEAL WITHOUT APPRECIATING THE FACT SITUATION OF THE CASE IN HAND. ITA NO 674 OF 2019 WARANGAL URBAN COOP. BANK LTD HYDERABAD PAGE 2 OF 7 3. THE LEARNED CIT(A) ERRED IN ALLOWING THE APPEAL WITHOUT FOLLOWING THE DUE PROCEDURE AS LAID DOWN UN DER RULE 46A OF THE INCOME TAX RULES, 1962. 4. THE LEARNED CIT(A) ERRED IN ALLOWING THE APPEAL WITHOUT HEARIN9 THE AO. 5. ANY OTHER GROUND(S) THAT MAY BE URGED AT THE TIM E OF HEARING. 3. THE REVENUES CASE AS PER ITS PLEADINGS IN NUT S HELL IS THAT THE CIT (A) HAS ERRED IN LAW AND ON FACTS IN R EVERSING THE ASSESSING OFFICERS ACTION INTER ALIA INVOKING SECT ION 40(A)(IA) DISALLOWANCE OF RS.3,72,35,416/- ON INTEREST PAYMEN TS MADE BY ASSESSEE TO ITS MEMBERS. THE CIT (A)S ORDER TO TH IS EFFECT READS AS UNDER: X) THE APPELLANT FILED THE APPEAL BELATEDLY ON THE GROUND THAT THE APPEAL PAPERS WERE MISPLACED BY THE OFFICE STAFF AND COULD BE TRACED OUT SUBSEQUENTLY AND HENCE THE APPEAL COULD BE FILED WITH THE DELAY OF ONE DAY ONLY. THE REASON FOR THE DELAY IN THE FILING OF APPEAL HAS BEEN DULY CON SIDERED AND THE DELAY IS CONDONED. XI) GROUND NOS.1 AND 9 IN APPEAL ARE GENERAL IN NAT URE AND DOES NOT CALL FOR ADJUDICATION. XII) GROUND ROUND NOS.2, 3 AND 4 IN APPEAL RELATES TO DISALLOWANCE U/S 40(A)(IA) AND TDS IN RESPECT OF IN TEREST PAYMENTS TO THE MEMBERS OF THE SOCIETY. FACTS OF TH E CASE, GROUNDS OF APPEAL, ASSESSMENT ORDER AND SUBMISSIONS OF THE APPELLANT WERE PERUSED. IT IS ALSO SEEN THAT TH E APPELLANT HAD PREFERRED ADDITIONAL GROUNDS WITH REF ERENCE TO ADDITIONS MADE U/S.40(A)(IA) WHICH ARE REFERRED TO AS ADDITIONAL GROUNDS NO.10, 11 AND 12. IT IS SEEN THA T THE ADDITIONAL GROUNDS DO NOT INVOLVE NEW FACTS AND ARE NOT ANY FINDINGS WHICH ATTRACT THE PROVISIONS OF RULE 4 6A. THE ADDITIONAL GROUNDS RELATE TO JUDICIAL DECISIONS WHI CH ARE SAID TO BE APPLICABLE TO THE FACTS OF THE CASE. IT IS SEEN THAT A DISALLOWANCE OF RS.3,72,35,416/- WAS MADE IN ASSESSMENT BY INVOKING SECTION 40(A)(IA) OF THE INCOME TAX ACT. THE APPELLANT SUBMITTED DURING THE COURSE OF APPEAL PROCEEDINGS THAT THE APPELLANT WAS NOT TO BE HELD IN DEFAULT U/S.201(1)/201(1A) OF THE ACT AND THAT T HE PAYEE HAD ALREADY OFFERED THE SAID RECEIPT TO TAX. THE AP PELLANT SUBMITTED THAT WHEN THE APPELLANT IS NOT IN DEFAULT UJS.201(1)/201(1A), THE PROVISIONS OF SECTION 40(A) (IA) CANNOT BE INVOKED. THE RELEVANT PROVISION MADE IN T HE ACT W.E.F 01.04.2013. HOWEVER, THE APPELLANT ALSO PLACE D ITA NO 674 OF 2019 WARANGAL URBAN COOP. BANK LTD HYDERABAD PAGE 3 OF 7 RELIANCE ON THE JUDGEMENT OF THE HON'BLE DELHI HIGH COURT IN THE CASE OF CIT VS. ANSAL LAND MARK TOWNSHIP (P.) L TD, [2015J 61 TAXMANN.COM 45 (DELHI)/377 ITR 635 (DELHI ), WHEREIN IT WAS HELD IN PARA 11 AS UNDER: 'THE FIRST PROVISO TO SECTION 201(1) OF THE ACT HAS BEEN INSERTED TO BENEFIT THE ASSESSEE. IT ALSO STATES TH AT WHERE A PERSON FAILS TO DEDUCT TAX AT SOURCE ON THE SUM PAI D TO A RESIDENT OR ON THE SUM CREDITED TO THE ACCOUNT OF A RESIDENT SUCH PERSON SHALL NOT BE DEEMED TO BE AN ASSESSEE I N DEFAULT IN RESPECT OF SUCH TAX IF SUCH RESIDENT HAS FURNISHED HIS RETURN OF INCOME UNDER SECTION 139 OF THE ACT. NO DOUBT, THERE IS A MANDATORY REQUIREMENT UNDER SECTION 201 TO DEDUCT TAX AT SOURCE UNDER CERTAIN CONTINGENCIES, B UT THE INTENTION OF THE LEGISLATURE IS NOT TO TREAT THE AS SESSEE AS A PERSON IN DEFAULT SUBJECT TO THE FULFILMENT OF THE CONDITIONS AS STIPULATED IN THE FIRST PROVISO TO SECTION 201(1 ). THE INSERTION OF THE SECOND PROVISO TO SECTION 40(A)(IA ) ALSO REQUIRES TO BE VIEWED IN THE SAME MANNER. THIS AGAI N IS A PROVISO INTENDED TO BENEFIT THE ASSESSEE. THE EFFEC T OF THE LEGAL FICTION CREATED THEREBY IS TO TREAT THE ASSES SEE AS A PERSON NOT IN DEFAULT OF DEDUCTING TAX AT SOURCE UN DER CERTAIN CONTINGENCIES. ' FROM THE ABOVE, THE APPELLANT SUBMITTED THAT IT WAS CLEAR THAT WHEN THERE IS NO DEFAULT U/S 201 OF THE ACT CO ULD NOT BE SUSTAINED. THE APPELLANT FURTHER SUBMITTED THAT THE CBDT IN CIRCULAR NO. 5 OF 2005 DATED 15TH JULY, 200 5 HAS ALSO CLARIFIED THAT THE PROVISIONS OF SECTION 40 (A )(IA) OF THE ACT IS TO AUGMENT COMPLIANCE OF TDS PROVISIONS IN C ASE OF RESIDENTS AND CURB BOGUS PAYMENTS TO THEM BUT NOT I N RESPECT OF THE EXPENSES GENUINELY INCURRED BY THE A SSESSEE FOR THE BUSINESS OPERATIONS AND HENCE THE APPELLANT SUBMITTED THAT THE DISALLOWANCE U/S 40(A)(IA) OF TH E ACT MAY PLEASE BE DELETED. FURTHER, THE APPELLANT ALSO PLACED RELIANCE ON THE JUDGMENT OF THE JURISDICTIONAL TRIBUNAL IN THE CASE OF DCIT VS M/S VISU INTERNATIONAL LIMITED [ITA NO. 488&621/HYD/201 31 WHEREIN IT WAS HELD THAT: 'THE LEARNED COUNSEL FOR THE ASSESSEE HAS CONTENDED THAT THE ASSESSEE COMPANY HAS NOT BEEN TREATED AS THE ASSESSEE IN DEFAULT UNDER SECTION 201(1) OF THE ACT FOR ITS FAILURE TO DEDUCT TAX AT SOURCE FROM THE PAYMENT MA DE ON ACCOUNT OF AUDIT FEE AND THEREFORE, NO DISALLOWANCE CAN BE MADE ON ACCOUNT OF AUDIT FEE, AS PER THE SECOND PRO VISO TO S.40(A)(IA). ALTHOUGH THE LEARNED DEPARTMENTAL REPRESENTATIVE HAS CONTENDED THAT THE SAID SECOND P ROVISO HAS BEEN INSERTED IN THE STATUTE BY THE FINANCE ACT , 2012 WITH EFFECT FROM 1.4.2013, IT IS NOTED, THE SAME HA S BEEN TREATED AS RETROSPECTIVELY APPLICABLE FROM 1.4.2005 BY THE COORDINATE BENCH (BANGALORE) OF THIS TRIBUNAL IN TH E CASE OF G. SHANKAR VS. ACIT (ITA NO. 1832/BANG/2013 FOR ITA NO 674 OF 2019 WARANGAL URBAN COOP. BANK LTD HYDERABAD PAGE 4 OF 7 ASSESSMENT YEAR 2005-06). WE, THEREFORE, RESTORE TH IS ISSUE TO THE FILE OF THE ASSESSING OFFICER FOR THE LIMITE D PURPOSE OF VERIFYING AS TO WHETHER THE ASSESSEE COMPANY IS TRE ATED AS AN ASSESSEE IN DEFAULT UNDER S.201(1) OF THE ACT FO R ITS FAILURE TO DEDUCT TAX AT SOURCE FROM THE PAYMENT MA DE ON ACCOUNT OF AUDIT FEE. IF IT IS FOUND ON SUCH VERIFI CATION THAT NO ORDER UNDER SECTION 201 (1) IS PASSED TO THIS EF FECT, THE ASSESSING OFFICER IS DIRECTED TO DELETE THE DISALLO WANCE MADE UNDER S. 40(A)(IA)' FROM THE ABOVE, IT IS APPARENT THAT WHEN THERE IS N O DEFAULT UNDER SECTION 201, THE ADDITIONS MADE U/ S 40(A)(IA ) OF THE ACT CANNOT BE SUSTAINED. THE APPELLANT ALSO PLACED RELIANCE ON THE DECISION OF THE JURISDICTIONAL ITAT IN THE C ASE OF COUNTRY CLUB HOSPITALITIES & HOLIDAYS LIMITED VS. A CIT IN ITA.NO.1S04/HYD/2012. FURTHER, THE APPELLANT ALSO SUBMITTED THAT THE FACTS OF THE APPELLANT'S CASE IS DIFFERENT FROM THE FACTS OF THE CASE OF M/ S. PALAM GAS LIMIT ED (81 TAXMAN.COM 43)(SC) WHERE THE ISSUE IS 'PAID/ PAYABL E' WHEREAS IN THE APPELLANT'S CASE THERE IS NO PROCEED INGS U/S.201(1)/201(1A) TO INVOKE SECTION 40(A)(IA). CON SIDERING THE FACTS, ISSUES AND CIRCUMSTANCES OF THE INSTANT CASE, GROUND NO.2, 3 AND 4 IN APPEAL ARE ALLOWED. XIII) GROUND NO.5 IN APPEAL RELATES TO PAYMENT OF R S.40, 159 J - BEING EMPLOYEES CONTRIBUTION TO EPF U/S 2(2 4) (X) R.W.S. 36(1) (V). THE SUBMISSIONS OF THE APPELLANT ARE EXTRACTED BELOW; 'IN THE COURSE ASSESSMENT THE LD. AD HAS MADE AN AD DITION TOWARDS BELATED PAYMENT OF EMPLOYEES CONTRIBUTION T O PROVIDENT FUND IN TERMS OF SECTION 2(24) (X) OF THE ACT READ WITH SECTION 36(1) (V) OF THE ACT. AT THIS POINT IT MAY BE SUBMITTED THAT, THOUGH THE EPF WAS PAID BELATEDLY, IT WAS PAID WELL BEFORE THE DUE DATE FOR FILING OF THE RET URN U/ S 13 9(1) OF THE ACT. AS PER PROVISIONS OF SECTION 43 B OF THE ACT, THE EPF PAID BEFORE THE DUE DATE FOR FILING OF THE RETURN OF INCOME IS ALLOWABLE AS INCURRED AN PAID DURING THE YEAR. THE CHALLAN FOR THE AMOUNT PAID IS FILED ALONG WITH THE SUBMISSIONS. THUS, NO ADDITION IS CALLED FOR U/ S 2 (24) (X) OF THE ACT. IN THIS REGARD, RELIANCE IS PLACED ON THE FOLLOWING CASE LAWS: C. KARNATAKA HIGH COURT IN THE CASE OF CIT V/S. SAB ARI ENTERPRISES (298 IUTR 141)-KAR. D. DECISION OF ITAY, HYDERABAD IN THE CASE OF YBRAN T DIGITAL LTD VS DCIT DATED 05.03.2014 IN ITA NO. 1769/HYD/20 12. SINCE, IN THE PRESENT CASE THE AMOUNT OF EPF IS DUL Y PAID BEFORE THE DUE DATE OF FILING OF RETURN U/ S.139(1) OF THE ACT, NO DISALLOWANCE IS WARRANTED. IT IS, THEREFORE, PRA YED TO ALLOW THE EXPENDITURE. ITA NO 674 OF 2019 WARANGAL URBAN COOP. BANK LTD HYDERABAD PAGE 5 OF 7 CONSIDERING THE PAYMENT OF EPF HAS BEEN MADE BEFORE THE DUE DATE FOR FILING OF RETURN AND RESPECTFULLY FOLL OWING THE RATIO OF THE DECISIONS REFERRED TO ABOVE, GROUND NO .5 IN APPEAL IS ALLOWED. XIV) GROUND NO.6 IN APPEAL RELATES TO DISALLOWANCE OF THE REDUCTION IN THE VALUE OF GOVERNMENT SECURITIES OF AN AMOUNT OFRS.6,91,000/-. THE SUBMISSIONS OF THE APPE LLANT ARE EXTRACTED BELOW: 'THE AO HAD DISALLOWED THE DEPRECIATION CLAMED IN T HE PREMIUM PAID ON GOVERNMENT SECURITIES AT RS. 6,91,0 00/-, TREATING IT AS CAPITAL IN NATURE. A DECISIVE POINT HERE IS THAT AS PER THE PROFIT AND LOSS ACCOUNT, THE ASSESSEE HA S NOT CLAIMED ANY DEPRECIATION ON PREMIUM PAID ON THE GOVERNMENT SECURITIES FOR THE ABOVE SAID AMOUNT OF RS. 6,91,000/-. AS OBSERVED, THE DEPRECIATING CLAIMED O N THE GOVERNMENT SECURITIES IS FOUND TO BE ZERO. AS COULD ALSO BE NOTICED FROM THE COMPUTATION STATEMENT EVEN, NO ADJUSTMENT (DEDUCTION FOR THIS AMOUNT) WAS MADE TO THE NET PROFIT, TO SUGGEST THAT THE ASSESSEE CLAIMED DEPREC IATION EITHER AS PER STRAIGHT LINE METHOD OR AS PER REDUCE D BALANCED METHOD UNDER SECTION 32 OF IT ACT . IT IS A FACT THAT THE ASSESSEE HAS TAKEN CERTAIN GO VERNMENT SECURITIES DURING THE YEAR UNDER REFERENCE AND PAID PREMIUM FOR A SUM OF RS. 6,91,500/-. THIS WAS DEBIT ED TO P&L A/ C AND CREDITED TO GOVERNMENT SECURITIES ACCO UNT, AS THE SAME IS AN ALLOWABLE EXPENDITURE. IT IS NOT THE QUESTION OF THE PREMIUM ON GOVERNMENT SECURITIES BEING ALLOW ABLE OR NOT. TO EVIDENCE OR THE ABOVE FACT, WE ARE SUBMITTI NG HEREWITH THE COPIES OF P&L A/ C. FOR THE PERIOD 1/4 /2012 TO 31/03/2013. ALSO WE ARE ENCLOSING HERE WITH THE COMPUTATION STATEMENT FOR KIND PERUSAL AND DECISION ON THE ISSUE. THUS, IT IS A BIG MISNOMER/MISCONCEPTION TO PRESUME THAT THE ASSESSEE CLAIMED DEPRECIATION ON THE GOVERNMENT SECURITY AND TO DISALLOW AN UNCLAIMED EXPENDITURE. IT IS THEREFORE, PRAYED TO DELETE THE ADDITION. CONSIDERING THE SUBMISSION MADE BY THE APPELLANT AN D EXPLANATIONS GIVEN, IT IS HELD THAT THE DISALLOWANC E MADE IS NOT WARRANTED AND HENCE, GROUND NO:6 IN APPEAL IS ALLOWED. XV) GROUND NO.7 IN APPEAL RELATES TO DISALLOWANCE U JS.14A OF RS.10,714/-. THE SUBMISSIONS OF THE APPELLANT AR E EXTRACTED BELOW: 'DURING THE COURSE OF ASSESSMENT THE AO MADE A DISALLOWANCE U/ S 14A R.W.S RULE BD OF IT RULES 196 2; FOR A SUM OF RS. 10,714/- TOWARDS DEEMED EXPENDITURE RELA TING ITA NO 674 OF 2019 WARANGAL URBAN COOP. BANK LTD HYDERABAD PAGE 6 OF 7 TO INVESTMENT, THE INCOME THEREFORE WHICH IS EXEMPT . THIS IS WORKED OUT BASING ON A PRESUMPTION THAT THE INTERES T EXPENDITURE BOOKED IS FOR EARNING OF EXEMPT INCOME. IN THIS REGARD, WE WOULD LIKE TO SUBMIT THAT, WHERE THE ASSESSING OFFICER CONTEMPLATES DISALLOWANCE U/ S 14 A, HE IS REQUIRED TO RECORD SATISFACTION WHICH HAS TO BE DONE WITH REGARD TO ACCOUNTS OF THE ASSESSEE. THE ASSESSING O FFICER HAS MADE THE DISALLOWANCE TREATING IT AS INTEREST O N FUNDS WHICH HAVE BEEN DEPLOYED AS INVESTMENTS, THE INCOME ARISING THERE FROM WHICH IS NOT INCLUDABLE IN TAXAB LE INCOME. IN THIS CASE, AO HAS CALCULATED DISALLOWANCE BASED ON THE INTEREST WITHOUT CONSIDERING THE FACT THAT THERE IS NO FRESH INVESTMENT. (VIII) IN THIS REGARD, WE WOULD ALSO LIKE TO SUBMIT THE FOLLOWING FACTS WHICH MAY PLEASE BE CONSIDERED IN F AVOR OF THE ASSESSEE. (F) THE ASSESSING OFFICER HAS NOT PRIMA FACIE FOUND ANY EXPENDITURE RELATING TO THE BORROWED CAPITAL WHICH WAS INVESTED IN THE ASSET, THE INCOME ARISING THERE FRO M WHICH IS EXEMPT. (G) THE ASSESSING OFFICER HAS NOT PRIMA FACIE SATIS FIED HIMSELF THAT, THERE IS A CLAIM OF EXPENDITURE TOWAR DS INTEREST ON THE BORROWED CAPITAL WHICH WAS INVESTED IN AN ASSET THE INCOME THERE FROM WHICH IS EXEMPT. (H) THE ASSESSING OFFICER HAS NOT ESTABLISHED ANY N EXUS BETWEEN EXPENDITURE BOOKED AND THE INVESTMENT MADE THE INCOME THERE FROM WHICH IS EXEMPT. (I)THE ASSESSING OFFICER HAS WRONGLY APPLIED THE RU LE 8D, WHEN THE ASSESSEE HAS MAINTAINED BOOKS OF ACCOUNT A ND GOT THEM STATUTORILY AUDITED. (J) THE ASSESSING OFFICER HAS ERRED IN CALCULATING THE DISALLOWANCE U/S 14A IN TERMS OF RULE 8D BY WRONG APPLICATION OF THE RULE. CONSIDERING THE SUBMISSION MADE BY THE APPELLANT AN D EXPLANATIONS GIVEN, IT IS HELD THAT THE DISALLOWANC E UJS.14A MADE IS NOT WARRANTED AND HENCE, GROUND NO.7 IN APP EAL IS ALLOWED. 4. LEARNED DR FAILS TO DISPUTE THE CLINCHING FACT T HAT THE CIT (A) HAS NOWHERE ADMITTED ANY OF THE ASSESSEES ADDITIONAL EVIDENCE DURING THE COURSE OF FIRST APPEAL PROCEEDI NGS. COUPLED WITH THIS, WE MAKE IT CLEAR THAT THE REVENUE HAS NO T RAISED ANY ITA NO 674 OF 2019 WARANGAL URBAN COOP. BANK LTD HYDERABAD PAGE 7 OF 7 OTHER GROUNDS SPECIFICALLY SEEKING TO REVERSE THE C IT (A)S IMPUGNED ACTION ON ANY OTHER ASPECT ON MERITS. WE T HUS QUOTE HON'BLE APEX COURTS DECISION IN CIT VS. PILLIAH AN D SONS ON 13 OCTOBER, 1966 EQUIVALENT CITATIONS: 1967 63 ITR 411 (SC) THAT THIS TRIBUNAL NEED NOT RECORD ITS OWN FINDING ON FA CTS IF ITS EXPRESSES COMPLETE AGREEMENT WITH THE CIT()AS CONC LUSION UNDER CHALLENGE. WE ADOPT THE SAME REASONING HERE AS WELL AND AFFIRM CIT (A)S ACTION DELETING THE IMPUGNED DISALLOWANCE /ADDITION MADE BY THE ASSESSING OFFICER. 5. THIS REVENUES APPEAL IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 9 TH APRIL, 2021. SD/- SD/- (LAXMI PRASAD SAHU) ACCOUNTANT MEMBER (S.S. GODARA) JUDICIAL MEMBER HYDERABAD, DATED 9 TH APRIL, 2021. VINODAN/SPS COPY TO: 1 ACIT, CIRCLE 1 NO.1-8-610, 3 RD FLOOR, MAYURI COMPLEX, NAKKALAGUTTA, HANAMKONDA, WARANGAL 506001 2 M/S WARANGAL URBAN COOP. BANK LTD, H.NO.8-11-45, 1 ST FLOOR, OPP: INTEZARGUNJ, POLICE STATION, RNT ROAD, WARANGA L 506001 3 CIT (A)-3 HYDERABAD 4 PR. CIT 3 HYDERABAD 5 THE DR, ITAT HYDERABAD 6 GUARD FILE BY ORDER