M/s. K.V.A. Crystal Estates (P) Ltd., Hyderabad V. DCIT, Central Circle-7, Hyderabad

ITA 80/HYD/2012

• Counselvise Citation: [2015] 140 COUNSELVISE.COM (IT) 98500 (ITAT-HYDERABAD)
• Duration Of Justice: 3 year(s) 7 month(s) 25 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-09-2015
• Appeal Filed By: Assessee
• Bench Allotted: B
• Next Hearing Date: 19-08-2015
• Assessment Year: 2006-2007
• Appeal Filed On: 23-01-2012
• Court: TRIBUNAL
• Department Lawyers: RAJAT MITRA
• Assessee Lawyers: N NAGARAJU
• Keywords: Business income; Additional evidence
• Section: 131

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES B, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER I.T.A. NO. 80/HYD/2012 ASSESSMENT YEAR: 2006-07 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., HYDERABAD [PAN: AACCK6267E] VS INCOME TAX OFFICER, WARD-2(1), HYDERABAD (APPELLANT) (RESPONDENT) FOR ASSESSEE : SHRI N. NAGARAJU, AR FOR REVENUE : SHRI RAJAT MITRA, DR DATE OF HEARING : 19-08-2015 DATE OF PRONOUNCEMENT : 18-09-2015 O R D E R PER B. RAMAKOTAIAH, A.M. : THIS IS AN APPEAL BY ASSESSEE AGAINST THE ORDERS O F THE COMMISSIONER OF INCOME TAX (APPEALS)-III, HYDERABAD DATED 23-11-2011. ASSESSEE HAS RAISED THREE GROUNDS ON THE ISSUE OF C ONFIRMATION OF RS. 60 LAKHS OUT OF THE TOTAL ADDITION OF RS. 78,20,000/- MADE BY THE ASSESSING OFFICER (AO). IT WAS THE CONTENTION THAT CIT(A) ER RED IN NOT ACCEPTING THE REPORT OF THE REMAND SENT BY THE AO WHILE CONFIRMIN G THE ABOVE AMOUNTS. 2. BRIEFLY STATED, ASSESSEE IS A COMPANY DERIVING I NCOME FROM BUSINESS OF REAL ESTATE. IN THE IMPUGNED ASSESSMEN T YEAR, ASSESSEE FILED I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 2 -: RETURN OF INCOME SHOWING INCOME OF RS. 1,23,850/-. AO IN THE COURSE OF SCRUTINY PROCEEDINGS NOTICED THAT THERE WAS INTRODU CTION OF SHARE APPLICATION MONEY AMOUNTING TO RS. 2,83,20,000/- DU RING THE PREVIOUS YEAR. IN THE COURSE OF ENQUIRY, ASSESSEE SUBMITTED MANY CONFIRMATION LETTERS, BUT AO DID NOT AGREE ON CERTAIN AMOUNTS RE CEIVED BY ASSESSEE AND MADE ADDITION TO AN EXTENT OF RS. 78,20,000/- C ATEGORIZED AS : A. CASES WHERE NO CONFIRMATIONS ARE SUBMITTED -RS. 66 ,22,000/- B. CASES WHERE PAN WAS NOT QUOTED- RS. 12,00,000/ - 3. ASSESSEE CONTESTED BEFORE THE LD. CIT(A) AND FUR NISHED ADDITIONAL INFORMATION. THIS INFORMATION WAS SENT TO THE AO O N REMAND AND ON ENQUIRY, AO SUBMITTED REPORT THROUGH ADDL. COMMISSI ONER THAT ALL THE CREDITS SEEMS TO BE GENUINE. HOWEVER, ADDL. COMMIS SIONER DEFERRED FROM THE REPORT OF THE AO AND SENT HIS FORWARDING R EPORT, EXPRESSING DOUBTS ABOUT THE GENUINENESS OF THE CREDITS AND ALS O QUESTIONING THE ADMISSIBILITY OF ADDITIONAL EVIDENCE, AS HE WAS OF THE OPINION THAT ADMISSION OF ADDITIONAL EVIDENCE CANNOT BE ROUTINEL Y ALLOWED. ADDL.CIT REPORTED EVEN ON MERITS THAT ASSESSEE COMPANY HAS N O CASE BECAUSE IF THE COPIES OF THE BANK STATEMENT FILED AS PROOF INV ESTMENT IN THE COMPANY BY DIFFERENT INDIVIDUAL IS SEEN, IT IS A ST RANGE COINCIDENCE THAT A DAY BEFORE OR THE DATES BEFORE THE MONEY IS INVESTE D, THERE ARE DEPOSITS INTO INDIVIDUAL ACCOUNT OF INVESTORS AND SUBSEQUENT LY, THE SAME IS INVESTED IN THE COMPANY BY THE INDIVIDUAL BY ISSUIN G A CHEQUE OR DRAFT. IN VIEW OF THE ABOVE, ADDL. CIT REQUESTED THE CIT(A ) TO UPHOLD THE ORDER. 4. LD. CIT(A) HOWEVER, WHILE CONSIDERING THE REMAND REPORT, EXAMINED EACH OF THE CREDITS IN HIS OWN WHILE CONFI RMING SOME AND DELETING SOME, HE GAVE RELIEF TO AN EXTENT OF RS. 1 9 LAKHS WHILE CONFIRMING ADDITION TO AN EXTENT OF RS. 59,20,000/- . ASSESSEE IS AGGRIEVED. I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 3 -: 5. WE HAVE HEARD THE LD. COUNSEL FOR ASSESSEE AND L D. DR IN DETAIL AND PERUSED THE PAPER BOOK PLACED ON RECORD CONTAIN ING 71 PAGES. AS SEEN FROM THE CONFIRMATION FILED BY ASSESSEE AND R EMAND REPORT OF THE AO, THERE IS NO DISPUTE WITH REFERENCE TO THE FACT THAT ALL THE PARTIES WHO HAVE GIVEN SHARE APPLICATION MONEY ARE IDENTIFIED A ND GENUINE. IT IS ALSO A FACT ON RECORD THAT AMOUNTS RECEIVED BY THE COMPA NY ARE BY WAY OF CHEQUES OR DRAFTS AND THERE ARE NO CASH TRANSACTION S. AS SEEN FROM THE AOS REPORT, MOST OF THE PERSONS ARE HAVING GENUINE CREDITWORTHINESS AND HIS REPORT WAS THAT THE CREDITS ARE ACCEPTABLE AS GENUINE. THEREFORE, PRIMA FACIE THERE IS NO CASE FOR ADDITION, HOWEVER, SINCE LD. C IT(A) EXAMINED EACH ISSUE, WE INTEND TO EXAMINE HIS OPINI ON ON THE BASIS OF THE EVIDENCE PLACED ON RECORD. I. CREDIT IN THE NAME OF SHRI A. VIJAY SEKHAR REDDY: S HRI A. VIJAY SEKHAR REDDY HAS FILED CONFIRMATION LETTER ALONG WI TH PHOTO COPY OF IT RETURN FOR AY. 2006-07 AND STATED THAT HE HAS INCOM E FROM CABLE OPERATIONS AND HIS WIFE IS WORKING WITH GLR NEW MOD EL JUNIOR COLLEGE, DILSUKHNAGAR AND SHE ALSO HAS SOME AGRICUL TURAL INCOME. IN SUPPORT OF THE DEPOSITS IN HIS BANK ACCOUNT, HE HAS FURNISHED PASS BOOK OF HIS WIFE FROM WHICH SHE HAS ISSUED CHEQUES OF RS. 3,60,000/- AND RS. 1,40,000/- TO HIS CREDIT. AO ACCEPTS THAT THIS TRANSACTION TO BE GENUINE. LD. CIT(A) DID NOT AGREE ON THE REASON THAT AO HAS NOT MENTIONED ABOUT THE PARTICULARS OF CHEQUES OF VARIO US AMOUNTS REFERRED BY HIM AND HE HAS ALSO NOT MENTIONED AS TO WHEN THE ALLEGED CHEQUES WERE ISSUED FROM THE ACCOUNT OF HIS WIFE. THIS REASONING GIVEN BY THE CIT(A) IS NOT ACCEPTABLE FOR THE SIMPL E FACT THAT THE AMOUNTS WERE RECEIVED BY THE COMPANY FROM THE SAID VIJAY SEKHAR REDDY BY WAY OF BANK CHEQUES WHICH WAS ACCEPTED BY THE AO AND FURTHER IN THE WRITTEN SUBMISSIONS FILED BEFORE THE CIT(A), IT WAS EXPLAINED THAT HE HAS TAKEN TWO CHEQUES BEARING NO. 735640 DT. 01- 01-2006 FOR RS. 3,60,000/- DRAWN ON CANARA BANK, DI LSUKHNAGAR BRANCH AND RS. 1,40,000/- VIDE CHEQUE NO. 01486 DT. 01-01-2006 I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 4 -: DRAWN ON INDIAN BANK, KUKATPALLI BRANCH WHICH WERE IN TURN GIVEN AS SHARE APPLICATION MONEY TO THE COMPANY. MOREOVE R, SAID VIJAY SEKHAR REDDY IS AN ASSESSEE WITH PAN AJVPA8592M. H E WAS ALSO ALLOTTED 5,000 SHARES OF RS. 10/- EACH AND BALANCE AMOUNT OF RS. 4,50,000/- WAS RETURNED TO HIM IN SUBSEQUENT YEAR. IN VIEW OF THIS, WE ARE OF THE OPINION THAT THE REASONS FOR REJECTIN G ASSESSEES CONFIRMATIONS BY THE CIT(A) ARE NOT VALID. THEREFO RE, THE CREDIT FROM SHRI A. VIJAY SEKHAR REDDY HAS TO BE ACCEPTED AS GE NUINE. II. DILEEP BAJAJ : SHRI DILEEP BAJAJ IS A RESIDENT OF JAYA SINGAPUR AND AN INCOME TAX ASSESSEE WITH PAN AAYPB2609R. HE HAS ISSUED CHEQUE NO. 227161 DT. 04-11-2005 DRAWN ON HDFC BANK , SANGLI BRANCH AND HE HAS FILED CONFIRMATION LETTER ALONG W ITH BANK STATEMENT, PASSPORT AND IS A BUSINESS MAN BY OCCUPA TION. JUST BECAUSE THERE ARE CASH DEPOSITS IN HIS BANK ACCOUNT BEFORE ISSUING CHEQUES TO ASSESSEE, IT CANNOT BE STATED THAT CASH DEPOSITS ARE FROM ASSESSEE COMPANY. SINCE THE SAID PERSON IS IN THE BUSINESS, IT COULD BE HIS BUSINESS RECEIPTS DEPOSITED IN HIS ACCOUNT I N MAHARASHTRA. SINCE THE PARTY IS AN EXISTING PERSON WITH INCOME T AX DEPARTMENT, AT BEST THE AO/ CIT(A) COULD HAVE REFERRED THE CASH D EPOSITS TO THE AO OF SHRI DILEEP BAJAJ. IN THIS CASE, AS THE PERSON IS IDENTIFIED BEING AN INCOME TAX ASSESSEE, AND ALSO CONFIRMED HAVING GIVE N THE AMOUNTS, THE SAME HAS TO BE ACCEPTED AS GENUINE. ORDER OF C IT(A) IS ACCORDINGLY SET ASIDE TO THAT EXTENT. III. SHRI P.C. RAMI REDDY: SHRI P.C. RAMI REDDY DEP OSITED AN AMOUNT OF RS. 10 LAKHS TOWARDS SHARE APPLICATION MONEY BY WAY OF CHEQUE NO. 404631 DT. 28-12-2005 DRAWN ON ANDHRA BANK VIJA Y NAGAR COLONY BRANCH, HYDERABAD. HE HAS SUBMITTED HIS RAT ION CARD AS PROOF OF HIS RESIDENCE AND FILED CONFIRMATION LETTE RS. HE WAS ALSO ALLOTTED 10,000 SHARES OF RS. 10/- EACH AND BALANCE OF RS. 9 LAKHS I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 5 -: WAS RETURNED TO HIM BY CHEQUE IN THE SUBSEQUENT YEA R. AO ON EXAMINATION U/S. 131 GOT REPLY FROM ASSESSEE THAT H E IS THE RETIRED CIVIL SURGEON AND AT PRESENT COULD NOT BE PRESENT P HYSICALLY DUE TO HIS ABSENCE FROM HYDERABAD. IT WAS FURTHER SUBMITT ED THAT HIS SON WHO IS A SOFTWARE ENGINEER HAS PROVIDED PART OF THE FUNDS BY WAY OF CITI BANK CHEQUES AND HE HAS EXPLAINED THE SOURCE O F RS. 10 LAKHS. AS FAR AS COMPANY IS CONCERNED, SHRI P.C. RAMI REDD Y IS IDENTIFIED AND HIS CONFIRMATIONS ARE ACCEPTED BY THE AO. IF T HERE IS ANY DOUBT ABOUT HIS SOURCE OF HIS FUNDS, THE COMPANY IS NOT E XPECTED TO PROVIDE CONFIRMATION OF THE SOURCE OF SOURCE. IN FACT AS S EEN FROM THE BANK ACCOUNTS AND ALSO STATEMENTS OF THE AO IN THE REMAN D REPORT, HE HAS RECEIVED FUNDS BY WAY OF CHEQUES ONLY FROM HIS SON AND ANOTHER FRIEND. SINCE HE WAS AN ASSESSEE WITH THE DEPARTME NT AND ALSO RETIRED CIVIL SURGEON, CREDITWORTHINESS OF SAID SHR I P.C. RAMI REDDY CANNOT BE DOUBTED. IN VIEW OF THIS WE ARE NOT IN A GREEMENT WITH THE ORDER OF THE CIT(A) AND ACCORDINGLY, THE SAME IS SE T ASIDE AND AO IS DIRECTED TO ACCEPT THE GENUINENESS OF THE CREDIT. IV. SHRI SANNUTI SRINIVASULU: THIS PERSON INVESTED AN AMOUNT OF RS. 10 LAKHS TOWARDS SHARE APPLICATION MONEY AND IN THI S CASE ALSO IT WAS EXPLAINED THAT AMOUNTS WERE RECEIVED BY WAY OF TWO CHEQUES IN THE MONTH OF MARCH, 2006 DRAWN ON ING VYSYA BANK, P RODDUTUR BRANCH, AP. HE HAS FILED CONFIRMATION LETTER, COPY OF HIS BALANCE SHEET AND ALSO THE ASSESSMENT ORDER BY ITO, PRODDUT UR. IN THIS CASE ALSO, HE WAS ALLOTTED 10,000 SHARES OF RS. 10/- EAC H AND BALANCE OF 9,00,000 WAS RETURNED TO HIM BY WAY OF CHEQUE IN TH E SUBSEQUENT YEAR MUCH BEFORE THE ENQUIRY BY THE AO. AO ALSO ISS UED SUMMON U/S. 131 AND CONFIRMED THAT SHRI SANNUTI SRINIVASUL U IS BEING ASSESSED IN WARD-2, PRODDUTUR AND INVESTMENT IN KVA CRYSTAL ESTATES, HAS BEEN SHOWN IN THE ASSET IN THE BALANCE SHEET OF SHRI SANNUTI SRINIVASULU. IN SPITE OF CLEAR EVIDENCE FU RNISHED BY ASSESSEE, WE ARE UNABLE TO AGREE WITH THE CIT(A)S OPINION TH AT HE HAS NOT I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 6 -: ISSUED COPY OF THE BANK ACCOUNT, WHEN ASSESSEE IS A LREADY ASSESSED WITH DEPARTMENT AT ANOTHER PLACE.. THE REASONS GIVE N BY CIT(A) ARE BASICALLY INTENDED TO REJECT THE CREDITWORTHINESS O F THE SAID PERSON. THE SAME CANNOT BE APPROVED. ACCORDINGLY, AO IS DI RECTED TO ACCEPT THE GENUINENESS AS PER HIS OWN REMAND REPORT SUBMIT TED EARLIER. V. SHRI MALLIKARJUNA RAO : THIS PERSON INVESTED AN AMOUNT OF RS. 5 LAKHS ON BEHALF OF HIS CO-BROTHER-IN-LAW SHRI A. JA GADISH AND GAVE CONFIRMATION ACCORDINGLY. IN THE BOOKS OF ACCOUNTS OF ASSESSEE- COMPANY, IT WAS CLEARLY NOTED THAT DD OF RS. 2,50,0 00/- WAS RECEIVED FROM SHRI A. JAGADISH AND CHEQUE NO. 741256 OF ANDH RA BANK, SULTAN BAZAR BRANCH FOR AN AMOUNT OF RS.2,50,000 WA S ALSO RECEIVED FROM SHRI A. JAGADISH TOTALING TO RS. 5 LAKHS. HOW EVER, THIS AMOUNT WAS SHOWN IN THE NAME OF SHRI MALLIKARJUNA RAO, WH O HAPPENED TO BE THE CO-BROTHER-IN-LAW. SHARES OF 10,000 WERE AL LOTTED VALUED AT RS. 1 LAKH AND BALANCE OF THE AMOUNT WAS RETURNED B Y WAY OF CHEQUE ON 02-04-2007 AGAIN TO MR. A. JAGADISH. THE SAME W AS ALSO CONFIRMED BY SHRI MALLIKARJUNA RAO, WHEN SUMMONS WE RE ISSUED BY AO WHO FOUND THE TRANSACTION TO BE GENUINE. WE DO NOT FIND ANY REASON TO DISBELIEVE THE SAME. ACCORDINGLY, AO IS DIRECTED TO ACCEPT THE SAME. THE REASONING GIVEN BY THE CIT(A) IS AVO IDED AS IT DOES NOT REQUIRE ANY FURTHER CLARIFICATION. VI. SHRI V. K. GANGADHAR : IN THIS CASE, AO MADE AN ADDITION OF RS. 9,20,000/- WHICH WAS DIRECTED TO BE ENHANCED TO RS. 10 LAKHS BY THE CIT(A). THE FACTS ARE THAT SHRI V. K. GANGADHAR, R ESIDENT OF NAGARJUNA NAGAR, YELLAREDDY GUDA, HYDERABAD ASSESSE D BY ITO, WARD-6(4) HAVING PAN ABUPG4714A IS AN ASSESSEE. HE HAS INVESTED RS. 10 LAKHS VIDE CHEQUE NO. 143741 DT. 27-12-2005 DRAWN ON OBC, AMEER PET BRANCH. HE WAS ALLOTTED 10,000 SHARES OF RS. 10/- EACH ON 15-11-2006 AND BALANCE OF RS. 9 LAKHS WAS RETURN ED BY WAY OF CHEQUES ON 11-04-2007. HE NOT ONLY FILED CONFIRMAT ION LETTER BUT ALSO I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 7 -: COPY OF HIS ACKNOWLEDGMENT OF HAVING FILED RETURN A ND INTIMATION. THE REASON FOR NOT ACCEPTING THIS AMOUNT SEEMS TO T HE FACT THAT LD. CIT(A) NOTICES THAT THE SAID SHRI V. K. GANGADHAR R ECEIVED ON 26-12-2005 RS. 10 LAKHS FROM ANOTHER BANK ACCOUNT W HICH CAME THROUGH CLEARANCE FROM SECUNDERABAD. SINCE THAT S OURCE WAS NOT EXPLAINED, HE DISBELIEVES THE CREDIT IN THE HANDS O F ABOVE PERSON. WE ARE UNABLE TO SUBSCRIBE THE OPINION OF THE CIT(A) S INCE SHRI V. K. GANGADHAR IDENTIFIED, IS ALREADY AN ASSESSEE ON REC ORD AND FURTHER CREDIT IN HIS ACCOUNT CAME THROUGH ANOTHER BANK ACC OUNT BY WAY OF CLEARING, HIS CREDITWORTHINESS CANNOT BE DOUBTED AS FAR AS COMPANY IS CONCERNED. THE REASONING GIVEN BY THE CIT(A) IS AS KING FOR SOURCE OF SOURCE WHICH IS NOT REQUIRED TO BE EXPLAINED IN THE ASSESSEES HANDS. SINCE THE FACTS INDICATE THAT SHRI V. K. GANGADHAR HAS GENUINELY MADE INVESTMENT AND COMPANY ALSO ALLOTTED SHARES AN D RETURNED THE BALANCE MONEY BY WAY OF CHEQUES MUCH BEFORE THE ENQ UIRY HAS STARTED, THE SAME CANNOT BE DOUBTED. ACCORDINGLY, AO IS DIRECTED TO ACCEPT THE AMOUNT OF RS. 10 LAKHS. VII. SHRI V.P. PULLAIAH : IN THIS CASE, SAID PERSON HAS INVESTED AN AMOUNT OF RS. 10 LAKHS, HAD FILED CONFIRMATION LETT ERS AND AO ACCEPTS THAT HE IS ALSO ASSESSED BY ITO, WARD-I, PR ODDUTUR. IT WAS EXPLAINED BY ASSESSEE THAT HE IS ASSESSED WITH PAN AADHV7015B BY ITO, WARD-I, PRODDUTUR. OUT OF RS. 10 LAKHS, HE HA S ISSUED VARIOUS CHEQUES TO THE TUNE OF RS. 9,50,000/- AND ONLY RS. 50,000/- BY WAY OF CASH ON 12-01-2006. HOWEVER, ENTIRE AMOUNT WAS SHOWN IN THE BALANCE SHEET, COPY OF WHICH WAS FURNISHED IN RESPO NSE TO THE SUMMONS ISSUED. IN VIEW OF THIS, WE DIRECT THE AO TO ACCEPT THE GENUINENESS OF THE ABOVE CREDIT. 6. AS CAN BE SEEN FROM THE FACTS INVOLVED IN THIS C ASE, AO ACCEPTED THE GENUINENESS OF THE CREDITS IN HIS REMAND REPORT . ADDL.CIT IN HIS WISDOM, REQUESTED THE CIT(A) NOT TO ADMIT THE ADDIT IONAL EVIDENCE. WE I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 8 -: ARE NOT SURE UNDER WHAT PROVISIONS, ADDL. CIT CAN R EQUEST THE CIT(A) NOT TO ADMIT THE ADDITIONAL EVIDENCE, WHEN THE ADDITION AL EVIDENCE WAS ADMITTED AND THEN SENT TO AO FOR EXAMINATION AS PER RULE 46A. HAVING ADMITTED THE ADDITIONAL EVIDENCE, THEN ONLY ISSUE O F EXAMINATION BY THE AO COMES UNDER THE RULE 46A. AT THE TIME OF SENDIN G REMAND REPORT, WE ARE NOT SURE HOW ADDL. CIT CAN REQUEST THE CIT(A) N OT TO ADMIT THE ADDITIONAL EVIDENCE WHICH WAS ALREADY ADMITTED. TH IS REPORT OF THE ADDL. CIT ITSELF IS NOT ACCORDING TO THE PRESCRIBED PROCE DURES AND LAW. BE THAT AS IT MAY, ASSESSEE HAS DISCHARGED ITS ONUS, WHICH WAS ALSO ENQUIRED BY THE AO WHO MADE THE ADDITIONS AND WAS SATISFIED BY THE GENUINENESS OF THE CREDITS. THE ORDER CIT(A) REJECTING THE GENUIN ENESS ON VARIOUS FLIMSY REASONS CANNOT BE ACCEPTED. THEREFORE, ASSESSEES GROUNDS ARE ALLOWED. 7. IN THE RESULT, APPEAL IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 18 TH SEPTEMBER, 2015 SD/- SD/- (P. MADHAVI DEVI) (B. RAMAKOTAIAH) JUDICIAL MEMBER ACCOUNTANT MEMBER HYDERABAD, DATED 18 TH SEPTEMBER, 2015 TNMM I.T.A. NO. 80/HYD/2012 M/S. K.V.A. CRYSTAL ESTATES (P) LTD., :- 9 -: COPY TO : 1. M/S. K.V.A. CRYSTAL ESTATES (P) LTD., 13-6-445/A /2, CRYSTAL GARDENS, RING ROAD, MEHDIPATNAM, HYDERABAD. C/O. N . NAGARAJU, ADVOCATE & TAX CONSULTANT, FLAT NO. 12, M ANOHAR APTS, VIDYANAGAR, HYDERABAD. 2. THE INCOME TAX OFFICER, WARD-2(1), HYDERABAD. 3. CIT (APPEALS)-III, HYDERABAD. 4. CIT-II, HYDERABAD. 5. D.R. ITAT, HYDERABAD. 6. GUARD FILE.