DCIT, Circle-8(1), Hyd, Hyderabad V. Value Labs, Hyd, Hyderabad

ITA 817/HYD/2016

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 2254 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 6 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 15-12-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2009-2010
• Appeal Filed On: 31-05-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: P MURALI MOHAN RAO
• Assessee Lawyers: P SOMASEKHAR REDDY
• Keywords: Depreciation; Transfer pricing; International transaction
• Section: 143(3); 10B; 147; 148

Judgement Text

ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 1 OF 10 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD B BENCH, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NOS.836, 815, 816, 817/HYD/2016 & 916/HYD/2017 (ASSESSMENT YEARS:2004-05, 2007-08, 2008-09, 2009-1 0) DY. COMMISSIONER OF INCOME TAX, CIRCLE 8(1) HYDERABAD VS M/S. VALUE LABS HYDERABAD PAN: AAEFV 9532 G (APPELLANT) (RESPONDENT) ITA NO.475/HYD/2017 (A.Y. 2012-13) M/S. VALUE LABS HYDERABAD PAN: AAEFV 9532 G VS DY. COMMISSIONER OF INCOME TAX, CIRCLE 8(1) HYDERABAD (APPELLANT) (RESPONDENT) FOR ASSESSEE : SHRI P. SOMA SEKHAR REDDY, DR FOR REVENUE : SHRI P. MURALI MOHAN RAO O R D E R PER SMT. P. MADHAVI DEVI, J.M. ABOVE APPEALS ARE FILED BY THE REVENUE AS WELL AS THE ASSESSEE FOR THE A.YS 2004-05, 2007-08 TO 2009-10 & 2012-13. ITA NO.836/HYD/2016 A.Y 2004-05 2. THIS APPEAL IS FILED BY THE REVENUE AGAINST THE ORDER OF THE CIT (A)-2, HYDERABAD, DATED 26.2.2016 DIRECT ING THE AO TO DATE OF HEARING: 07.12.2017 DATE OF PRONOUNCEMENT: 15 . 1 2 .2017 ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 2 OF 10 ALLOW EXPENDITURE CLAIMED BY THE ASSESSEE U/S 10B O F THE ACT, EVEN THOUGH THE ASSESSEE HAS NOT BEEN APPROVED AS A 100% EOU BY THE BOARD APPOINTED IN THIS BEHALF BY THE CENTRA L GOVT. 3. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE IS ENGAGED IN THE BUSINESS OF RENDERING SOFTWARE DEVELOPMENT S ERVICES TO ITS ASSOCIATE ENTERPRISES (AE) LOCATED IN VARIOUS PLACE S OUTSIDE INDIA. FOR THE A.Y 2004-05, THE ASSESSEE FILED ITS RETURN OF INCOME ON 1.11.2014 DECLARING AN INCOME OF RS.1,66,03,779. AN ORDER U/S 143(3) WAS PASSED ON 29.12.2006 DETERMINING THE TAX ABLE INCOME OF THE FIRM AT RS.2,55,79,796 AFTER DISALLOWING THE EXCESS OF THE EXEMPTION CLAIMED U/S 10B OF THE ACT AGGREGATING TO RS.65,95,053. THEREAFTER, THE AO NOTICED THAT THE C LAIM MADE BY THE ASSESSEE FIRM U/S 10B OF THE ACT IS NOT CORRECT . THEREFORE, THE ASSESSMENT WAS REOPENED U/S 147 OF THE ACT BY ISSUA NCE OF THE NOTICE U/S 148 DATED 28.3.2011. DURING THE RE-ASSES SMENT PROCEEDINGS, THE AO OBSERVED THAT U/S 10B OF THE AC T, THE ASSESSEE SHOULD BE AN UNDERTAKING WHICH HAS BEEN AP PROVED AS A 100% EXPORT ORIENTED UNDERTAKING BY THE BOARD A PPOINTED IN THIS BEHALF BY THE CENTRAL GOVT. IN EXERCISE OF THE POWERS CONFERRED BY SECTION 14 OF THE INDUSTRIES (DEVELOPM ENT AND REGULATION) ACT, 1951 AND THE RULES MADE THEREUNDER . THE AO ALSO OBSERVED THAT THE ASSESSEE IS ONLY REGISTERED AS A 100% EOU BY STPI. THEREFORE, HE DISALLOWED THE CLAIM OF DEDU CTION U/S 10B OF THE ACT AND BROUGHT TO TAX. AGGRIEVED, THE ASSES SEE FILED AN APPEAL BEFORE THE CIT (A) WHO ALLOWED THE SAME AND AGGRIEVED BY THE RELIEF GRANTED BY THE CIT (A), THE REVENUE IS I N APPEAL BEFORE US. ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 3 OF 10 4. THE LEARNED DR RELIED UPON THE ORDER OF THE AO W HILE THE LEARNED COUNSEL FOR THE ASSESSEE SUPPORTED THE ORDER OF THE CIT (A) AND HAS ALSO PLACED RELIANCE UPON THE DECIS ION OF THE COORDINATE BENCH IN THE CASE OF SECUNDERABAD SOFTWA RE SERVICES PVT. LTD VIDE ITA NO.1501/HYD/2011, DATED 10.04.201 2 WHEREIN, UNDER SIMILAR SET OF FACTS AND AFTER FOLLOWING THE VARIOUS DECISIONS OF THE COORDINATE BENCHES OF THIS TRIBUNAL, IT HAS BEEN HELD THAT WHERE THE ASSESSEE IS REGISTERED UNDER THE STPI AS A 100% EOU, IT IS ENTITLED FOR DEDUCTION U/S 10B OF THE ACT. RE LEVANT PARAGRAPHS ARE REPRODUCED HEREUNDER FOR READY REFER ENCE: 6. WE HEARD THE PARTIES AND PERUSED THE IMPUGNED ORDERS OF THE LOWER AUTHORITIES. THE ONLY QUESTION THAT CLINCHES THE ISSUE INVOLVED IN THIS APPEAL IS WHETH ER FOR BECOMING ELIGIBLE TO THE DEDUCTION UNDER S.10B OF T HE ACT, WHETHER IT IS ENOUGH IF THE ASSESSEE IS REGIST ERED WITH SOFTWARE TECHNOLOGY PARK OF INDIA AS A 100% EO U OR IT IS ALSO NECESSARY FOR THE ASSESSEE TO HAVE TH E APPROVAL OF THE BOARD CONSTITUTED BY THE CENTRAL GOVERNMENT UNDER S.14 OF THE INDUSTRIES (DEVELOPMEN T AND REGULATION) ACT , 1951. THE CIT(A) HAS DECIDED THIS ISSUE IN FAVOUR OF THE ASSESSEE, AND HELD THE ASSES SEE AS ELIGIBLE FOR DEDUCTION UNDER S.10B OF THE ACT, FOLL OWING THE DECISIONS OF THE CO-ORDINATE BENCHES OF THE TRI BUNAL IN THE FOLLOWING CASES- (A) VSN MAKRO TECHNOLOGY P. LTD. V/S. ACIT (ITA NO.1057/HYD/2010) DATED 13.1.2011, WHEREIN THE STIL L EARLIER DECISION OF THE TRIBUNAL IN THE CASE OF INF OTECH ENTERPRISES LTD. (SUPRA), RELIED BY THE ASSESSING O FFICER IN THE IMPUGNED ASSESSMENT ORDER HAS BEEN CONSIDERE D AND THE SAME HAS BEEN HELD TO BE INAPPLICABLE AS TH E SAME HAS BEEN RENDERED PRIOR TO ISSUANCE OF INSTRUC TION NO.1 DATED 31.3.2006 BY THE CBDT AND LETTER DATED 23.3.2006 ISSUED BY THE MINISTRY OF COMMUNICATIONS AND TECHNOLOGIES. (B) DCIT V/S. VALLIANT COMMUNICATION LTD. (ITA NO.2706/DEL/2008 DATED 23.4.2010) (2010-TIOL-452- ITAT-DEL), WHEREIN THE STILL EARLIER DECISION OF TH E DELHI ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 4 OF 10 BENCH IN THE CASE OF ITO VS. REGENCY CREATIONS LTD. (ITA NO.4006/DEL/2006) DATED 13.4.2006 HAS BEEN FOLLOWED. (C) SMT. K.SUDHA RANI V/S. ITO (ITA NO.1750/HYD/2008) DATE 30.10.2009. CONSISTENT WITH THE VIEW TAKEN BY VARIOUS BENCH OF THE TRIBUNAL, INCLUDING THE BENCHES AT HYDERABAD, IN SIMILAR MATTERS, WE HOLD THAT THE ASSESSEE, HAVING BEEN REGISTERED WITH THE STPI, IS ENTITLED FOR DEDUCTION UNDER S.10B OF THE ACT. IN THAT VIEW OF THE MATTER, WE FI ND NO INFIRMITY IN THE IMPUGNED ORDER OF THE CIT(A), WHIC H IS ACCORDINGLY CONFIRMED AND THE GROUNDS OF THE REVENU E ARE REJECTED. 7. IN THE RESULT, APPEAL OF THE REVENUE IS DISMISSE D. RESPECTFULLY FOLLOWING THE SAME, THE GROUND OF APPE AL IS REJECTED AND CONSEQUENTLY, THE REVENUES APPEAL IS DISMISSED . ITA NOS.815 TO 817/HYD/2016 & ITA NO.916/HYD/2017 A.YS 2007-08 TO 2009-10 5. ITA NO.815/HYD/2016 IS FOR THE A.Y 2007-08, 816/HYD/2016 IS FOR THE A.Y 2008-09 AND ITA NOS.817/HYD/2016 AND ITA NO.916/HYD/2017 ARE FOR A. Y 2009- 10. ALL THESE ARE THE APPEALS FILED BY THE REVENUE FOR THE RESPECTIVE A.YS. ITA NO.817/HYD/2016 IS AN APPEAL F OR THE A.Y 2009-10 FOR THE ASSESSMENT ORDER PASSED U/S 143(3) OF THE ACT, WHILE FOR THE SAME A.Y 2009-10, ITA NO.916/HYD/2017 IS FOR THE RE-ASSESSMENT ORDER PASSED U/S 143(3) R.W.S. 147 OF THE ACT. IN ALL THESE APPEALS, THE COMMON GROUND RAISED BY THE REVENUE IS AGAINST THE DIRECTION OF THE CIT (A) TO REDUCE THE COMMUNICATION CHARGES AND BAND WIDTH VOIP CHARGES BOTH FROM EXPOR T TURNOVER ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 5 OF 10 AS WELL AS THE TOTAL TURNOVER FOR COMPUTING DEDUCTI ON U/S 10A OF THE ACT. ACCORDING TO THE REVENUE, IT SHOULD BE EXC LUDED ONLY FROM THE EXPORT TURNOVER AND NOT FROM THE TOTAL TUR NOVER. 6. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE MATERIAL ON RECORD, WE FIND THAT THIS IS COVERED IN FAVOUR OF THE ASSESSEE BY THE DECISION OF THE HON'BLE KARNATAKA H IGH COURT IN THE CASE OF CIT VS. TATA ELXSI LTD, REPORTED IN 349 ITR 98 AND ALSO THE HON'BLE JURISDICTIONAL HIGH COURT IN THE CASE O F B.A.CONTINUUM REPORTED IN ITTA NO.440/2017. WE FIND THAT THE CIT (A) HAS FOLLOWED VARIOUS DECISIONS OF THE ITAT WHICH ARE IN CONSONANCE WITH THE DECISION OF THE HON'BLE KARNATA KA HIGH COURT (CITED SUPRA) WHEREIN IT HAS BEEN HELD THAT F OR THE PURPOSE OF COMPUTATION OF DEDUCTION U/S 10B OF THE ACT, IF ANY EXPENDITURE IS EXCLUDED FROM THE EXPORT TURNOVER, T HEN THE SAME SHOULD ALSO BE EXCLUDED FROM THE TOTAL TURNOVER. RE SPECTFULLY FOLLOWING THE SAME, WE DO NOT SEE ANY REASON TO INT ERFERE WITH THE ORDER OF THE CIT (A) FOR ALL THE A.YS AND THE REVEN UES APPEALS ARE ACCORDINGLY DISMISSED. ITA NO.475/HYD/2017 (ASSESSEES APPEAL) FOR A.Y 201 2-13 7. THIS IS ASSESSEES APPEAL FOR THE A.Y 2012-13. I N THIS APPEAL, THOUGH THE ASSESSEE HAS RAISED AS MANY AS S EVEN GROUNDS OF APPEAL AND A NUMBER OF SUB-GROUNDS UNDER EACH OF THE GROUND, WE FIND THAT ONLY TWO ISSUES ARE ARISIN G IN THIS APPEAL. THE ISSUES ARE (I) (ALP ADJUSTMENT IN RESPE CT OF SOFTWARE DEVELOPMENT SERVICES; AND (II) INTEREST ON RECEIVAB LES. ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 6 OF 10 8. AS REGARDS THE FIRST ISSUE, THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE AO HAS NOT FOLLOWED THE DIRECTION OF THE DRP TO TAKE THE PROFIT BEFORE DEPRECIATION OF BOTH THE ASSESSEE AS WELL AS COMPARABLE COMPANIES FOR DETERM INING THE ALP, AS THE ASSESSEE IS A PARTNERSHIP FIRM, WHILE T HE COMPARABLES TAKEN BY THE TPO ARE COMPANIES AND THE RATE OF DEPR ECIATION IS HIGH IN THE CASE OF THE FIRM. HE HAS DRAWN OUR ATTE NTION TO THE DIRECTIONS OF THE DRP AT PARA 2.4 AT PAGE 5 OF ITS ORDER WHEREIN THE DRP HAS DIRECTED THE AO TO CONSIDER THE MARGIN IN THE CASE OF THE ASSESSEE AS WELL AS THE MARGINS OF THE COMPARAB LE COMPANIES AFTER EXCLUDING THE DEPRECIATION. HE SUBMITTED THAT THE AO HAS NOT FOLLOWED THE SAID DIRECTION WHILE PASSING THE F INAL ASSESSMENT ORDER. 9. THE LEARNED DR HOWEVER, SUPPORTED THE ORDERS OF THE AUTHORITIES BELOW. 10. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE MATERIAL ON RECORD, WE FIND THAT THE DRP, BY FOLLOW ING THE DECISION OF THE HON'BLE JURISDICTIONAL HIGH COURT I N THE CASE OF BA CONTINUUM IN ITTA NO.440/2017, HAS DIRECTED THE AO TO CONSIDER THE MARGINS OF THE ASSESSEE AS WELL AS THE COMPARABLES AFTER EXCLUDING THE DEPRECIATION. SINCE THE AO HAS NOT FOLLOWED THE SAID METHOD WHILE COMPUTING THE ALP, WE DIRECT THE AO TO RE- COMPUTE THE ALP AFTER TAKING THE MARGINS OF THE ASS ESSEE AS WELL AS THE COMPARABLES AFTER EXCLUDING THE DEPRECIATION , IN ACCORDANCE WITH THE DIRECTIONS OF THE DRP. THE GROU NDS ON THIS ISSUE ARE THEREFORE, TREATED AS ALLOWED FOR STATIST ICAL PURPOSES. ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 7 OF 10 11. AS REGARDS SECOND ISSUE OF INTEREST ON RECEIVAB LES IS CONCERNED, THE LEARNED COUNSEL FOR THE ASSESSEE SUB MITTED THAT THE ASSESSEE HAD TRANSACTIONS WITH BOTH THE AES AND NON-AES AND HAS NOT CHARGED INTEREST ON THE RECEIVABLE FR OM THE AES AS WELL AS THE NON-AES AND THEREFORE, IT SHOULD NOT BE TREATED AS AN INTERNATIONAL TRANSACTION. HE SUBMITTED THAT THE AO HAS CHARGED INTEREST @ 14.75% ON THE AMOUNT RECEIVABLE AFTER AL LOWING CREDIT PERIOD OF 30 DAYS, WHEREAS THE DRP HAS EXTENDED THE PERIOD TO 60 DAYS. HE SUBMITTED THAT WHEN THE ASSESSEE IS NOT CH ARGING INTEREST ON RECEIVABLE FROM NON-AES ALSO AND SINCE THE CREDIT PERIOD ALLOWED BY THE ASSESSEE IS NOT EXTENDED BEYO ND SIX MONTHS IN MOST OF THE CASES AND BEYOND 12 MONTHS IN ONE CASE, THE INTEREST CHARGED BY THE DEPARTMENT AT 14.75% ON THE TOTAL OF THE RECEIVABLES IS NOT SUSTAINABLE. EVEN OTHERWISE, HE SUBMITTED THAT SINCE THE PAYMENTS ARE FROM AES OUTSIDE INDIA, THE INTEREST RATES PREVALENT IN INDIA SHOULD NOT HAVE BEEN CHARG ED. 12. THE LEARNED DR, HOWEVER, SUPPORTED THE ORDERS O F THE AUTHORITIES BELOW. 13. HAVING REGARD TO THE RIVAL CONTENTIONS AND THE MATERIAL ON RECORD, WE FIND THAT IN MOST CASES OF T HE AES, THE AMOUNTS WERE RECEIVED WITHIN A PERIOD OF SIX MONTHS EXCEPT IN ONE CASE WHERE IT WAS RECEIVED AFTER 12 MONTHS. WE FIND THAT THE COORDINATE BENCH OF THIS TRIBUNAL IN THE CASE OF GS S INFOTECH LTD IN ITA NO.497/HYD/2015 HAS CONSIDERED SIMILAR ISSUE AND AT PARA 10 TO 12 OF ITS ORDER HAS HELD AS UNDER: ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 8 OF 10 10. ASSESSEE RELIED ON THE FOLLOWING CASE LAW THAT NO INTEREST CAN BE CHARGED ON CREDIT WHICH ARE GIVEN IN THE COU RSE OF BUSINESS. NO INTEREST CAN BE CHARGED ON MOBILIZATION ADVANCE & IT CANNOT BE TREATED AS LOAN AS IT HAS BEEN GIVEN DURING THE COURSE OF BUSINESS. PEGASYSTEMS WORLDWIDE INDIA PVT. LIMITED, HYDERABAD, ITA NO.1758/H 2014 --------------------------------------- INDO AMERICAN JEWELLERY LTD. VS. DCIT 9(2), MUMBAI. [2012] 1 8 TAXMANN.COM 303 (MUM.) LITNAS INDIA (P.) LTD., VS. ACIT [2012] 27 TAXMANN.COM 300 (MUMBAI-TRIB.) EVONIK DEGUSSA INDIA (P.) LTD., VS. ACIT - OSD CIRCLE- 3(1), TAXMANN.COM 285 (MUMBAI) NIMBUS COMMUNICATIONS LTD., TAXMANN.COM 298 (MUMBAI-TRIB.) INTEREST CHARGED ON RECEIVABLES 10.1. THE DR HOWEVER, WHILE ACCEPTING THAT LEVY WAS FOR THE PERIOD BEYOND THE ACCOUNTING YEAR, HOWEVER, JUSTIFIED THE LEVY OF INTEREST ON RECEIVABLES. 11. WE HAVE CONSIDERED THE ISSUE AND EXAMINED THE CONTENTIONS. AS SEEN FROM ASSESSEE'S CONTENTIONS, ASSESSEE IS NEITHER CHARGING INTEREST ON ANY OF THE RECEIVABLES OUTSTANDING. THERE IS ALSO NO BASIS FOR ADOPTING ONLY TWO MONTHS AS CREDIT PERIOD. RBI ITSE LF ALLOWS AN YEAR FOR THE AMOUNTS TO BE REALISED, IF T HEY ARE IN FOREIGN EXCHANGE. WHETHER IT IS AE OR NON-AE , IT IS IN THE INTEREST OF BUSINESS THAT ASSESSEE REC EIVES THE FOREIGN EXCHANGE EARLY SO THAT IT CAN CLAIM ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 9 OF 10 DEDUCTION U/S. 10A. THEREFORE, IN OUR VIEW, PUTTING A LIMIT OF TWO MONTHS OF CREDIT PERIOD ITSELF IS ARBI TRARY. MOREOVER, AS SEEN FROM THE CALCULATION PROVIDED IN PAGE 7 OF THE ASSESSMENT ORDER, THE DATE OF REALIZA TION WAS SHOWN AS 02- 02-2011 AND INTEREST WAS LEVIED FROM 01-04-2010 TO 02-02-2011 WHICH IS NOT PERTAINING TO THE YEAR UNDER CONSIDERATION. AS FAR AS THIS YEAR IS CONCERNED, THE INVOICES RAISED ON 31-1 2- 2009 WERE OUTSTANDING ONLY FOR A PERIOD OF THREE MONTHS BY THE END OF THE ACCOUNTING YEAR. WE ARE OF THE OPINION THAT THIS PERIOD IS REASONABLE AND SO N O INTEREST CAN BE LEVIED, JUST BECAUSE AMOUNTS ARE SHOWN AS 'OUTSTANDING'. ACCORDINGLY, WE CANCEL THE INTEREST LEVIED AND ALLOW ASSESSEE'S CONTENTIONS. GROUNDS ARE CONSIDERED ALLOWED. 12. IN THE RESULT, APPEAL IS CONSIDERED ALLOWED FOR STATISTICAL PURPOSES. 14. RESPECTFULLY FOLLOWING THE SAME, WE HOLD THAT W HERE THE ASSESSEE IS NOT CHARGING INTEREST ON BOTH AE AN D NON-AE TRANSACTIONS AND THE RECEIVABLES ARE OUTSTANDING FO R A PERIOD OF LESS THAN SIX MONTHS, NO INTEREST CAN BE CHARGED. F OR THE RECEIPTS BEYOND SIX MONTHS ALSO, WE FIND THAT THE INTEREST I S NOT CHARGEABLE BECAUSE THE ASSESSEE HAS NOT CHARGED ANY INTEREST ON RECEIVABLE FROM THE NON-AES. THEREFORE, THE GROUNDS OF APPEAL RELATING TO THIS ISSUE ARE ALSO TREATED AS ALLOWED. 15. IN THE RESULT, ASSESSEES APPEAL IS PARTLY ALLO WED FOR STATISTICAL PURPOSES. ITA NOS 836 815 816 916 817 AN D 475 VALUE LABS HYDERABAD. PAGE 10 OF 10 16. TO SUM UP, REVENUES APPEALS FOR ALL THE A.YS A RE DISMISSED AND ASSESSEES APPEAL FOR A.Y 2012-13 IS TREATED AS PARTLY ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 15 TH DECEMBER, 2017. SD/- SD/- (S.RIFAUR RAHMAN) ACCOUNTANT MEMBER (P. MADHAVI DEVI) JUDICIAL MEMBER HYDERABAD, DATED 15 TH DECEMBER, 2017. VINODAN/SPS COPY TO: 1 DY. COMMISSIONER OF INCOME TAX, CIRCLE 8(1), 6 TH FLOOR, ROOM NO.605, SIGNATURE TOWERS, KODAPUR, HYDERABAD 2 P. MURALI & CO. CAS, 6-3-655/2/3, 1 ST FLOOR, SOMAJIGUDA, HYDERABAD 500082 3 CIT (A)-2 HYDERABAD 4 PR. CIT 2 HYDERABAD 5 THE DR, ITAT HYDERABAD 6 GUARD FILE BY ORDER