ITO, Hyderabad V. M/s Lakshmi Srinivasa Mutually Aided Coop Credit Society Ltd., Secunderabad

ITA 784/HYD/2006

• Counselvise Citation: [2014] 120 COUNSELVISE.COM (IT) 6451 (ITAT-HYDERABAD)
• Duration Of Justice: 7 year(s) 10 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-07-2014
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 24-05-2011
• Assessment Year: 2003-2004
• Appeal Filed On: 31-08-2006
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: S RAMA RAO
• Keywords: Revised return
• Section: 133A; 147; 68; 148

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES B : HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER ITA.NO. A.Y. APPELLANT RESPONDENT 686/HYD/2006 2002-2003 ITO, WARD 11(2), HYDERABAD M/S. LAKSHMI SRINIVASA FINANCE CORPORATION, SECUNDERABAD PAN AABFL-3306- R-L-311 784/HYD/2006 2003-2004 FOR REVENUE MR. SOLGY JOSE T. KOTTARAM FOR ASSESSEE MR. S. RAMA RAO DATE OF HEARING 21.05.2014 DATE OF PRONOUNCEMENT 16.07.2014 ORDER PER BENCH. THESE TWO APPEALS ARE BY REVENUE AGAINST THE TWO SEPARATE ORDERS OF THE CIT(A)-VI, HYDERABAD DATED 0 7.03.2006 AND 18.05.2006 FOR THE ASSESSMENT YEARS 2002-2003 A ND 2003-2004. THE REVENUE HAS RAISED COMMON GROUNDS AN D FOR THE SAKE OF RECORD, THE GROUNDS IN A.Y. 2002-2003 A RE EXTRACTED AS UNDER : 1. THE LD. CIT(A) ERRED IN TREATING THE ASSESSEE AS C OOP SOCIETY AND ALLOW DEDUCTION U/S. 80P WHEN THE IRREGULARITIES NOTICED IN CHARGING OF INTEREST, UTI LISATION OF FUNDS, BOGUS DEPOSITORS WERE DETECTED BY THE A.O. 2. THE LD. CIT(A) OUGHT TO HAVE CONFIRMED THE ACTION O F THE A.O. IN DENYING THE CLAIM U/S. 80P AS THE ASSESSEE VIOLATED THE BYE LAWS AND PRINCIPLES STIPULATED U/S . 3 OF THE MUTUALLY AIDED COOPERATIVE SOCIETY 1995 ACT. 3. THE LD. CIT(A) ERRED IN DIRECTING TO DELETE THE ADD ITION MADE U/S. 68 OF THE I.T. ACT AS THE ASSESSEE COULD NOT 2 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD DISCHARGE THE INITIAL RESPONSIBILITY IN FURNISHING THE DETAILS OF DEPOSITORS AND SHARE HOLDERS. 4. THE LD. CIT(A) ERRED IN DIRECTING TO ALLOW THE EXPE NDITURE TOWARDS INTEREST PAYMENT WHEN THE DEPOSITS WERE NOT PROVED AS GENUINE. 2. BRIEFLY STATED, ASSESSEE IS A COOPERATIVE SOCIE TY CARRYING ON BUSINESS OF BANKING/CREDIT FACILITIES. IT WAS CONSTITUTED ON 12.07.2001 AND WAS REGISTERED UNDER COOPERATIVE SOCIETIES ACT WITH REGISTRAR OF MUTUALL Y AIDED SOCIETIES, HYDERABAD. ASSESSEE SOCIETY FILED ITS RE TURN OF INCOME BEFORE THE ADIT (EXEMPTION)-II, HYDERABAD ON 19.08.2002 ADMITTING INCOME OF NIL CLAIMING BENEFIT UNDER SECTION 80P OF THE ACT. ACCORDING TO THE ASSESSEE, THERE WAS A NET LOSS AS PER P & L ACCOUNT AND EVEN OTHERWISE TH E INCOME IS EXEMPT UNDER SECTION 80P OF THE I.T. ACT. A.O. COND UCTED SURVEY UNDER SECTION 133A OF THE ACT AT THE BUSINES S PREMISES OF M/S. LAKSHMI SRINIVASA FINANCE CORPORATION ON 05.12.2003. IN THE COURSE OF SURVEY, IT WAS FOUND O UT THAT ASSESSEES GROUP IS RECEIVING INTEREST ON THE ADVAN CES MADE AT 4% PER MONTH WHEREAS, IT WAS RECORDED AT 2.25% IN T HE BOOKS OF ACCOUNTS. ON THE REASON THAT THE CASE OF THE ASS ESSEE SOCIETY IS LINKED WITH THAT OF THE PARTNERSHIP FIRM OF M/S LAKSHMI SRINIVASA FINANCE CORPORATION. A.O. GOT THE JURISDICTION AND THEN INITIATED PROCEEDINGS UNDER S ECTION 147 BY ISSUING A NOTICE UNDER SECTION 148 OF THE I.T. A CT ON 26.12.2003. ASSESSEE MODIFIED THE NIL RETURN OF INC OME BY FILING A RETURN ON 01.10.2004 ADMITTING GROSS TOTAL INCOME OF RS.1,99,211/- AND AGAIN CLAIMING EXEMPTION UNDER SE CTION 80P OF THE I.T. ACT. IN THE REVISED RETURN OF INCOM E, ASSESSEE RE-CALCULATED INTEREST RECEIVED ON THE BASIS OF NOT INGS FOUND IN 3 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD THE SURVEY. A.O. DETERMINED THE TOTAL INCOME AT RS.74,57,050/- BY TREATING THE DEPOSITS RECEIVED AS UNEXPLAINED AND AT THE SAME TIME DENYING THE CLAIM OF 80P ON THE REASON THAT ASSESSEE HAS VIOLATED THE BYE LAWS OF THE SOCIETY AND BOOKS OF ACCOUNTS ARE NOT MAINTAINED PR OPERLY. 3. BEFORE THE LD. CIT(A), ASSESSEE CONTENDED THAT ASSESSEE WAS CHARGING INTEREST AT 4% AND WITH THE A PPROVAL OF THE BOARD THEY WERE CREDITING THE P & L ACCOUNT WIT H 2.25% INTEREST AND BALANCE AMOUNT COLLECTED WAS DEPOSITED WITH THE SOCIETY KNOWN AS CDR ACCOUNT. IT WAS SUBMITTED THAT NO MONEY WAS WITHDRAWN FROM THE SOCIETY. THE FUNDS WER E ALWAYS AVAILABLE WITH THE SOCIETY IN ITS BUSINESS ACTIVITY . THERE WAS NO LOSS TO THE SOCIETY AND NONE OF THE MEMBERS HAVE BE NEFITTED INDIVIDUALLY. EVEN THOUGH THE METHOD ADOPTED WAS NO T APPROPRIATE, SINCE, FUNDS WERE UTILIZED BY THE SOCI ETY FOR ITS BUSINESS, THERE WAS NO VIOLATION OF ANY BYE LAW. WI TH REFERENCE TO CERTAIN TRANSACTIONS OF MR. T. VENKAT, THE SON-I N-LAW OF THE MANAGING DIRECTOR OF THE SOCIETY IT HAD CLARIFIED, AS EXTRACTED IN PARA 5.6 OF THE CIT(A) ORDER THAT THERE IS NO IN VESTMENT IN THE NAME OF THE SAID PERSON. WITH REFERENCE TO DEPO SITS, ASSESSEE SOCIETY CLARIFIED THAT THE DEPOSITS WITHDR AWN ARE NOT FOR THE PURPOSE OF PURCHASING OF LAND FOR THE SOCIE TY BUT THE DEPOSITS WERE WITHDRAWN BY THE INDIVIDUAL MEMBERS F OR THEIR OWN PURPOSES. IT CLARIFIED FURTHER THAT AMOUNTS IN CDR ACCOUNT WERE IN TACT AND NONE OF THE SAID ACCOUNTS WERE CLOSED AND MONIES WERE NEVER PAID TO OUTSIDERS. VIDE PARA 5.11 ASSESSEE ALSO EXPLAINED THE OBSERVATIONS OF THE A.O . THAT WHY DIFFERENT SETS OF BOOKS ARE MAINTAINED AND HOW THE ASSESSEE WAS ACCOUNTING THE TRANSACTIONS. THERE WERE DETAILE D SUBMISSIONS MADE BY THE ASSESSEE WHICH WERE EXTRACT ED BY 4 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD THE LD. CIT(A) IN PARA 5. AFTER CONSIDERING THE CON TENTIONS, THE LD. CIT(A) VIDE PARA 6 OF THE ORDER OBSERVED THAT A SSESSEE SOCIETY HAS NOT VIOLATED THE PROVISIONS OF THE COOP ERATIVE SOCIETIES ACT. HIS DETAILED ORDER IN PARA 6 IS AS U NDER : 06. I HAVE CAREFULLY CONSIDERED THE SUBMISSIONS MA DE BY THE AR OF THE APPELLANT AND ORDER MADE BY THE ASSES SING OFFICER. IT IS SEEN FROM THE ORDER OF THE ASSESSING OFFICER THAT FOR THE FOLLOWING REASONS, THE ASSESSING OFFIC ER TREATED THE SOCIETY AS AN AOP AND NOT AS A CO-OP. S OCIETY. '1. THE ASSESSING OFFICER TREATED THE SOCIETY AS AN AOP AND HELD THAT EXEMPTION U/S 80P IS NOT AVAILABLE FO R THE FOLLOWING REASONS: A) THE INTEREST RECEIPT WAS NOT RECORDED AT THE RAT E AT WHICH IT WAS COLLECTED BUT WAS RECORDED AT 2.25% AS AGAINST 4% COLLECTED. B) THE ASSESSING OFFICER STATED TO HAVE EXAMINED SR I T. VENKAT WHO SEEMS TO HAVE STATED THAT HE WAS NOT A MEMBER OF THE SOCIETY. C) ONE OF THE DIRECTORS SRI N. BALRAJ STATED THAT S OME OF THE DEPOSITS WERE MADE IN THE NAMES OF VARIOUS PERSONS. D) AN AMOUNT OF RS.2,88,062/- WAS WITHDRAWN CANCELL ING THE DEPOSITS OF THE SOCIETY AND LAND WAS PURCHASED FOR RS.2,88,062/-. E) THE APPELLANT MAINTAINED THREE SETS OF BOOKS FOR THE SAME PERIOD. 4. LD. CIT(A) ALSO ANALYSED THE PROVISIONS OF SECT ION 80P AND DEFINITION OF COOPERATIVE SOCIETY PROVI DED UNDER SECTION 2.19 OF THE I.T. ACT AS UNDER : 5 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD 07. I HAVE CAREFULLY CONSIDERED THE SUBMISSIONS MADE BY THE LEARNED AR. THE DEFINITION OF THE WORD 'CO- OP. SOCIETY' IS PROVIDED BY SEC.2(19) OF THE I.T. A CT WHICH IS REPRODUCED HEREUNDER: 'CO-OPERATIVE SOCIETY' MEANS A CO-OPERATIVE SOCIETY REGISTERED UNDER THE CO-OPERATIVE SOCIETIES ACT, 19 12 (2 OF 1912) OR UNDER ANY OTHER LAW FOR THE TIME BEING IN FORCE IN ANY STATE FOR THE REGISTRATION OF CO-OPERA TIVE SOCIETIES' 07.1. ACCORDING TO THE SAID PROVISION IF A SOCIETY IS REGISTERED UNDER THE CO-OPERATIVE SOCIETIES ACT, 19 12, IT IS ONLY A CO-OPERATIVE SOCIETY. WHETHER A SOCIETY IS A CO- OPERATIVE SOCIETY OR NOT CAN ONLY BE DETERMINED BY THE ADMINISTRATORS OF THAT LAW AND NOT BY THE INCOME-TA X AUTHORITIES. INCOME-TAX ACT DID NOT PROVIDE ANY DIS CRETION TO THE ASSESSING OFFICER TO EITHER ASSESS A SOCIETY AS A CO- OPERATIVE SOCIETY OR AS AN ADP. THE APPELLANT HEREI N IS NO DOUBT CARRYING ON THE BANKING BUSINESS ACTIVITIE S ON CO-OPERATIVE LINES. EVEN IF WHAT THE ASSESSING OFFI CER MENTIONED ABOUT ACCOUNTING ENTRIES WERE TO BE CONSIDERED, THE APPELLANT CONTINUES TO BE A CO-OPER ATIVE SOCIETY CARRYING ON BUSINESS OF BANKING. THE APPELL ANT IS REGISTERED AS A CO-OP. SOCIETY AND HAS TO BE TREATE D AS SUCH. 07.2. FURTHER, I ALSO FIND THAT THE OMISSIONS SAID TO HAVE BEEN FOUND, BY THE ASSESSING OFFICER A RE NOT ENOUGH TO NEGATE THE CLAIM OF THE STATUS OF THE ASSESSEE AS A CO-OPERATIVE SOCIETY. FURTHER, SEC.80 P CATEGORICALLY MENTIONS THAT ANY INCOME OF A CO- OPERATIVE SOCIETY ENGAGED IN CARRYING ON THE BUSINESS IS EXEMPT FROM TAX. THERE ARE NO SUCH CONDITIONS FOR EXEMPTION GRANTED U/S 80P. THEREFORE, I DO NOT FIND ANY REASON FOR THE ASSESSING OFFICER TO REJECT DEDUCTION U/S BAP CLAIMED BY THE APPELLANT. HENCE, I DIRECT THE ASSESSING OFFICER TO ALLOW THE DEDUCTION CLAIMED BY THE APPELLANT U/S.80P OF THE ACT. 6 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD 5. WITH REFERENCE TO THE ADDITION UNDER SECTION 68, LD. CIT(A) EXAMINED THE FACTS IN DETAIL AND THE DETAIL ED SUBMISSIONS OF THE ASSESSEE ARE EXTRACTED IN PARA 1 0 OF THE ORDER AND LD. CIT(A) CONCLUDED AS UNDER WHILE DELET ING THE ADDITION. 10.8. A SIMILAR ISSUE AROSE IN THE CASE OF THE PARTNERSHIP FIRM M/S. LAKSHMI SRINIVASA FINANCE CORPORATION IN THAT CASE THE APPELLANT FILED BEFORE ME THE APPLICATIONS FOR MAKING THE DEPOSITS, THE AFFIDAVIT S FROM THE AGENTS WERE ALSO PRODUCED AND SUBMITTED BEFORE THE ASSESSING OFFICER. THERE IS NO INFORMATION TO THE C ONTRARY WITH THE ASSESSING OFFICER. IN VIEW OF THE ABOVE AN D IN VIEW OF MY OBSERVATIONS IN THE CASE OF PARTNERSHIP FIRM M/S. LAKSHMI SRINIVASA FINANCE CORPORATION, HENCE, I DIRECT THE ASSESSING OFFICER TO DELETE THE ADDITION MADE OF RS.65,63,750/- TOWARDS DEPOSITS AND THE INTEREST OF RS.3,51,180/-. 6. SIMILARLY ADDITION OF SHARE CAPITAL OF RS.3,65,0 00/- WAS ALSO DELETED VIDE PARA 11.2 AS UNDER : 11.2. THE LEARNED AR, THE APPELLANT FILED LIST OF T HE MEMBERS OF THE SOCIETY WHO CONTRIBUTED TO THE SHARE CAPITAL, COPIES OF THE APPLICATIONS FILED BY THE ME MBERS FOR THEIR ADMISSION. THESE COPIES WERE AVAILABLE AT THE TIME OF SURVEY OPERATION AND THE REGISTER OF THE DEPOSIT ORS WAS ALSO FOUND AT THE TIME OF SURVEY. KEEPING IN VIEW O F THE ABOVE SUBMISSIONS OF THE APPELLANTS AR I DIRECT TH E ASSESSING OFFICER TO DELETE THE ADDITION MADE OF RS.3,65,000/- TOWARDS SHARE CAPITAL. 7. SIMILAR FACTS ARE INVOLVED IN A.Y. 2003-2004 AL SO WHEREIN ASSESSEE ADMITTED THE GROSS INCOME AT RS.32 ,17,640/- AND CLAIMED DEDUCTION UNDER SECTION 80P(2). A.O. HO WEVER, ASSESSED THE INCOME AT RS.2,48,30,154/- BY MAKING A DDITION OF INTEREST RECEIVED AT RS.71,15,940/-, UNEXPLAINED DEPOSITS AT 7 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD RS.1,70,21,500/-, SHARE CAPITAL AT RS.4,06,125/- AN D MEMBERS CAPITAL AT RS.84,985/-. LD. CIT(A) SIMILARLY IN THE DETAILED ORDER DELETED VARIOUS ADDITIONS WHILE ALLOWING DEDU CTION UNDER SECTION 80P. 8. LEARNED D.R. SUBMITTED THAT ASSESSEE IS NOT ELIGIBLE FOR DEDUCTION UNDER SECTION 80P WHEREAS, L D. CIT(A) ALLOWED THE DEDUCTION. HE RELIED ON THE FINDINGS OF THE A.O. TO SUBMIT THAT ASSESSEE HAS VIOLATED THE PROVISIONS OF MUTUALITY AIDED SOCIETY AND THEREFORE, DEDUCTION UNDER SECTIO N 80P SHOULD NOT HAVE BEEN ALLOWED. FURTHER, WITH REFEREN CE TO DEPOSITS SINCE EVIDENCES WERE NOT FURNISHED BY THE ASSESSEE, A.O. WAS CORRECT IN MAKING THE ADDITIONS UNDER SECT ION 68 OF THE ACT AND THEREFORE, LD. CIT(A) WAS NOT CORRECT I N DELETING THE AMOUNTS. LEARNED A.R. HOWEVER, RELIED ON THE DETAIL ED SUBMISSIONS MADE BEFORE THE LD. CIT(A) AND SUPPORTE D THE CONTENTIONS WITH PAPER BOOKS PLACED ON RECORD. 9. WE HAVE CONSIDERED THE ISSUE AND EXAMINED THE RIVAL CONTENTIONS. AS FAR AS THE SO-CALLED IRREGULA RITIES AND VIOLATION OF PROVISIONS OF MUTUALLY AIDED COOPERATI VE SOCIETY ACT ARE CONCERNED, MANY OF THE IRREGULARITIES HAVE BEEN EXAMINED BY THE LD. CIT(A) IN DETAIL AND HAS COME T O A CORRECT CONCLUSION THAT ASSESSEE HAS MAINTAINED BOOKS OF AC COUNTS, FUNDS OF THE SOCIETY HAVE NOT BEEN UTILIZED BY ANY OF THE MEMBERS AND EVEN THOUGH AMOUNTS ARE DIFFERENTLY ACC OUNTED FOR, ENTIRE FUNDS WERE AVAILABLE WITH THE SOCIETY. NOT ONLY THAT, ON THE BASIS OF THE VERY SAME BOOKS IMPOUNDED DURIN G THE SURVEY, ASSESSEE WAS IN A POSITION TO WORK OUT THE INCOMES AND FILED REVISED RETURNS. EVEN OTHERWISE, SINCE ASSESS EE IS ELIGIBLE FOR DEDUCTION UNDER SECTION 80P, THE LD. CIT(A) HAS CORRECTLY CONCLUDED THAT THE INCOMES EARNED BY THE SOCIETY WO ULD GET 8 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD EXEMPTION UNDER THE PROVISIONS OF 80P. WE, THEREFOR E, DO NOT FIND ANY REASON TO INTERFERE WITH THE ORDER OF THE LD. CIT(A) AS HE HAS EXAMINED THE ISSUES BOTH FACTUALLY AND LEGAL LY. WE CONFIRM THE ORDER OF THE LD. CIT(A). ACCORDINGLY, G ROUND NOS. 1 AND 2 OF THE REVENUE ARE REJECTED. 10. WITH REFERENCE TO ISSUE OF CREDITS CONTESTED I N GROUND NOS. 3 AND 4, THE LD. CIT(A) IN FACT, EXAMIN ED THE METHOD OF RECEIVING DEPOSITS BY THE ASSESSEE. ASSES SEE AS WELL AS THE FIRM M/S. LAKSHMI SRINIVASA FINANCE CORPORAT ION ARE FOLLOWING THE SAME METHODOLOGY OF ACCEPTING DEPOSIT S OF SMALL AMOUNTS AND THESE DETAILS ARE MAINTAINED IN SEPARAT E REGISTERS. IN THE COURSE OF ASSESSMENT PROCEEDINGS NECESSARY CONFIRMATIONS WERE FILED. THEREFORE, IT CANNOT BE S AID THAT THESE FUNDS ARE UNEXPLAINED AS FAR AS THE ASSESSEE IS CON CERNED. MOREOVER, ASSESSEE IS IN THE FINANCE BUSINESS AND A LL RECEIPTS AND PAYMENTS WERE DULY ACCOUNTED FOR. NOT ONLY THAT , VARIOUS AGENTS AND DEPOSITORS WERE ALSO EXAMINED IN THE COU RSE OF ASSESSMENT OF M/S. LAKSHMI SRINIVASA FINANCE CORPOR ATION AND THE LD. CIT(A) BASED ON THE FINDINGS THEREIN HA D DELETED THE AMOUNTS IN ASSESSEES CASE ALSO. WE HAD AN OCCA SION TO EXAMINE THE ISSUES IN THE CASE OF M/S. LAKSHMI SRIN IVASA FINANCE CORPORATION IN ITA.NO.783, 369, 370, 371 & 785/HYD/2006 EVEN DATED JULY, 2014 AND SINCE THE FI NDINGS ARE SIMILAR, WE DO NOT FIND ANY REASON TO INTERFERE WITH THE ORDER OF THE LD. CIT(A). ACCORDINGLY, GROUND NOS. 3 AND 4 OF THE REVENUE ARE REJECTED. 11. WITH REFERENCE TO GROUND NO.4 OF ALLOWING EXPENDITURE TOWARDS INTEREST PAYMENT, SINCE, THESE ARE ARISING FROM THE VERY SAME BOOKS OF ACCOUNTS WHICH ARE IMPO UNDED BY THE A.O. IN THE COURSE OF SURVEY PROCEEDINGS, WE DO NOT FIND 9 ITA.NO.686 & 784/HYD/2006 M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOP. CREDIT SOCIETY, SECBAD ANY REASON NOT TO ALLOW THE EXPENDITURE WHICH WAS A LREADY RECORDED IN THE BOOKS. THERE IS NO MERIT IN REVENUE GROUND AND ACCORDINGLY, GROUND NO.4 OF THE REVENUE IS REJE CTED. 12. SINCE, FACTS ARE SIMILAR IN A.Y. 2003-2004, TH E FINDINGS ABOVE WILL EQUALLY APPLY TO OTHER ASSESSME NT YEAR AS WELL. THEREFORE, GROUNDS RAISED BY THE REVENUE FOR THE A.Y. 2003-2004 ARE ALSO REJECTED. 13. IN THE RESULT, APPEALS OF THE REVENUE ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT O N 16.07.2014. SD/- SD/- (SAKTIJIT DEY) (B.RAMAKOTAIAH) JUDICIAL MEMBER ACCOUNTANT MEMBER HYDERABAD, DATED 16 TH JULY, 2014. VBP/- COPY TO 1. INCOME TAX OFFICER, WARD 11(2), HYDERABAD. 2. M/S. LAKSHMI SRINIVASA MUTUALLY AIDED COOPERATIV E CREDIT SOCIETY LTD., 12-1-508/67, LAKSHMINAGAR, NORTH LALA GUDA, SECUNDERABAD. 3. CIT(A)-VI, 3 RD FLOOR, AAYAKAR BHAVAN, BASHEERBAGH, HYDERABAD. 4. CIT-V, HYDERABAD 5. D.R. ITAT B BENCH, HYDERABAD.