Sri Sai Eswar Real Estates & Developers, Hyd, Hyderabad V. DCIT, Central Circle-5, Hyd, Hyderabad

ITA 859/HYD/2016

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 2464 (ITAT-HYDERABAD)
• Duration Of Justice: 11 month(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-05-2017
• Appeal Filed By: Assessee
• Bench Allotted: A
• Next Hearing Date: 16-05-2017
• Assessment Year: 2008-2009
• Appeal Filed On: 06-06-2016
• Court: TRIBUNAL
• Department Lawyers: SUMAN MALIK
• Assessee Lawyers: P MURALI MOHAN RAO
• Keywords: Business income; Additional evidence

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A, HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND SHRI V. DURGA RAO, JUDICIAL MEMBER ITA NO. ASST. YEAR APPELLANT RESPONDENT 856/HYD/16 2008-09 M/S. SRI SAI PRASANTHI REALTORS, HYDERABAD [PAN: ABIFS8348G] DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5, HYDERABAD 857/HYD/16 2009-10 858/HYD/16 2007-08 M/S. SRI SAI ESWAR REAL ESTATES & DEVELOPERS, HYDERABAD [PAN: ABBFS0824N] DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5, HYDERABAD 859/HYD/16 2008-09 FOR ASSESSEE : SHRI P. MURALI MOHAN RAO, AR FOR REVENUE : SMT SUMAN MALIK, DR DATE OF HEARING : 16-05-2017 DATE OF PRONOUNCEMENT : 26-05-2017 O R D E R PER B. RAMAKOTAIAH, A.M. : THESE ARE APPEALS BY TWO ASSESSEES FOR THE AYS. 2007 -08, 2008-09 & 2009-10 AGAINST THE ORDER(S) OF THE COMMISSI ONER OF INCOME TAX (APPEALS)-12, HYDERABAD. SINCE COMMON I SSUES ARE INVOLVED ON THE ISSUE OF PENALTY U/S. 271B, THESE APP EALS ARE HEARD TOGETHER AND DECIDED BY THIS COMMON ORDER. FOR THE SAK E OF ITA NOS. 856, 857, 858 & 859/HYD/2016 :- 2 - : CONVENIENCE, WE ARE DISCUSSING THE FACTS IN ITA NO. 856/HYD/2016 FOR AY. 2008-09. 2. BRIEFLY STATED, ASSESSEE IS ENGAGED IN THE BUSINESS OF PURCHASE OF LAND AND CONVERSION OF LAND INTO PLOTS ( REAL ESTATE BUSINESS). SEARCH & SEIZURE OPERATIONS WERE CONDUCTE D IN THE CASE OF THE M/S. SRI M. SAMBASIVA RAO AND OTHERS, HYD ERABAD AND ITS GROUP OF CASES ON 16-07-2008. DURING THE COURSE OF SEARCH OPERATIONS CONDUCTED IN THE CASE OF MR. S. YELLAIAH, PARTNER OF THE ASSESSEE-FIRM, M/S. SRI SAI PRASANTHI REALTORS, WHERE CERTAIN INFORMATION RELATED TO ASSESSEE-FIRM WAS NOTICED/FOUND AND SEIZED AND CONSEQUENT TO SEARCH PROCEEDINGS, ASSESSEE FILED ITS RETURN OF INCOME FOR THE AY.2008-09 ADMITTING AN INCOME OF RS.1 1,80,000/-, IN RESPONSE TO THE NOTICE ISSUED U/S. 153C OF THE INC OME TAX ACT [ACT]. DURING SEARCH PROCEEDINGS, THE PARTNER OF THE AS SESSEE-FIRM SRI S. YELLAIAH STATED THAT THE FIRM DID NOT FILE ITS RETU RNS OF INCOME FOR THE A.YS. 2008-09 YET AND ADMITTED TO OFFER AN UNDIS CLOSED INCOME OF RS. 11,80,000/- FOR THE YEAR. TOTAL SALES M ADE DURING THE RELEVANT ASSESSMENT YEAR WAS SHOWN AT RS. 1,17,31,100/ - ON WHICH THE INCOME OF RS.11,80,000/- WAS ADMITTED. THE TO TAL INCOME WAS ASSESSED AT RS. 11,80,000/- BUT AO INITIAT ED PENALTY PROCEEDINGS U/S.271B. 3. AO WAS OF THE OPINION THAT THOUGH ASSESSEE HAS MENTIONED THAT THE ACCOUNTS OF THE ASSESSEE-FIRM GOT AUDITED ON 15-0 9-2008, AS EVIDENCED FROM THE ROI FILED THE SAME HAS NOT BEEN ENCLOSED, WHILE FILING THE RETURN OF INCOME FOR THE ASSESSMENT YEAR AND AS PER THE PROVISIONS OF THE SECTION 44AB OF THE ACT, ASSESSEE WAS UNDER OBLIGATION TO NOT ONLY GET ITS BOOKS OF ACCOUNTS AUDITED BUT ALSO TO ITA NOS. 856, 857, 858 & 859/HYD/2016 :- 3 - : ENCLOSE/FURNISH A COPY OF THE REPORT TO THE INCOME TAX AUTHORITIES ON OR BEFORE THE DUE DATE OF FILING OF RETURN OF INCO ME FOR THE RELEVANT ASSESSMENT YEAR. IN THIS CASE, ASSESSEE SHOUL D HAVE FILED ITS AUDITED REPORT ON OR BEFORE 31-10-2008, WHICH WAS NOT DONE AND ASSESSEE FILED ITS RETURN OF INCOME ONLY ON 25-03 -2010 IN CONSEQUENCE OF SEARCH PROCEEDINGS. AO DID NOT TAKE C OGNIZANCE OF THE SUBMISSIONS OF ASSESSEE THAT AUDIT REPORT DT.15-09-20 08 (AS MENTIONED IN ASSESSMENT ORDER), WAS OBTAINED BEFORE DU E DATE, WHICH WAS SHOWN TO HAVE FURNISHED ALONG WITH RETURN O F INCOME FURNISHED ON 25-03-2010. AO WAS OF THE OPINION THAT I T CLEARLY ATTRACTS THE PENALTY PROCEEDINGS U/S.271B OF THE ACT. AC CORDINGLY, LEVIED PENALTY OF RS.64,088/-, WHICH WAS EQUIVALENT TO 0.5% OF TURNOVER/GROSS SALES OF RS. 1,71,31,100/-, FOR THE YE AR. 4. BEFORE THE LD.CIT(A), ASSESSEE OBJECTED THE SAID L EVY OF PENALTY. AFTER CONSIDERING THE EXPLANATION OF ASSESSE E, CIT(A) DISMISSED THE APPEAL OF ASSESSEE BY STATING AS UNDER: 6.0 PERUSED OF SUBMISSIONS OF THE APPELLANT AND TH E OBSERVATIONS OF THE AO, BOTH IN THE ASSESSMENT ORDER AS WELL AS THE PEN ALTY ORDER. AS COULD BE SEEN FROM THE FACTS OF THE CASE, THE APPELLANT S HOWN TO BE ENGAGED IN THE BUSINESS OF REAL ESTATE AND HAS RECORDED GROSS RECEIPTS OF RS.1.17 CRORES FOR THE YEAR UNDER REFERENCE, BUT NO RETURN OF INCOME WAS FURNISHED BEFORE THE DUE DATE WHICH IS 31-10-2008. RETURN FOR THE YEAR WAS SHOWN TO HAVE FLIED ONLY ON 25-03-2010 AND IN CONSEQUENCE OF SEARCH PROCEEDINGS IN THIS GROUP ON 16-07-2008. AS PER THE AO NEITHER THE AUDIT REPORT WAS FURNISHED BEFORE THE DUE DATE NOR ALONG WITH THE RETURN OF INCOME FILED ON 25-03-2010 OR DURING ASSESSMENT PRO CEEDINGS, THOUGH IT WAS OBTAINED ON 15-09-2008, BUT DUE TO THE FACT THA T THE SAID REPORT WAS MISPLACED ON ACCOUNT OF ABSENCE OF ACCOUNTANT. THE AO HAD ARRIVED THE CONCLUSION THAT AS THE SAID REPORT WAS NOT FURNISHE D EITHER BEFORE THE DUE DATE OR AT THE TIME OF ASSESSMENT, AS SUCH THE ASSE SSEE IS LIABLE TO BE VISITED WITH THE PROVISIONS OF SEC.271B, SINCE THE ASSESSEE IS FAILED TO EXPLAIN WITH JUSTIFIABLE REASONS. ACCORDINGLY, THE PENALTY OF RS. 64,088/- BEING 0.5% ON TOTAL RECEIPTS/GROSS RECEIPTS OF RS.L ,17,31,100/-, WAS LEVIED. THE REASONS EXPLAINED BY THE ASSESSEE ARE T OO VAGUE TO EXPLAIN THE ITA NOS. 856, 857, 858 & 859/HYD/2016 :- 4 - : FAILURE IN EXPLAINING THE DELAY IN SUBMITTING OF AU DIT REPORT, WHICH WAS CLAIMED TO BE OBTAINED ON DTD.15-09-2008 AND ASSESS EE FAILED TO FILE IT BEFORE THE DUE DATE OR FURNISH A COPY BEFORE THE AO , DURING ASSESSMENT PROCEEDINGS. THE PROVISIONS OF SEC.271B STIPULATE T HAT THE ASSESSEE WOULD BE LIABLE FOR PENALTY OF AMOUNT EQUAL TO ONE HALF P ERCENT OF TOTAL SALES/TURNOVER OR GROSS RECEIPTS OR BUSINESS OR PRO FESSION AS THE CASE MAY BE, IF ASSESSEE FAIL TO GET HIS/IT'S ACCOUNTS AUDIT ED IN RESPECT OF ANY PREVIOUS YEAR OR YEARS RELEVANT TO THE ASSESSMENT Y EAR, OR FURNISH A REPORT OF SUCH AUDIT AS REQUIRED U/S.44AB. AS COULD BE SEE N FROM THE LANGUAGE USED IN THE SAID PROVISION, THE ASSESSEE IS REQUIRE D TO GET ACCOUNTS AUDITED OR FURNISH SUCH REPORT AS STIPULATED U/S.44 AB, WHICH STIPULATE THAT THE ACCOUNTS OF PREVIOUS YEAR RELATED TO ASSES SMENT YEAR ARE REQUIRED TO BE AUDITED BEFORE THE DUE DATE AND FURNISH THE R EPORT IN PRESCRIBED FORMAT BY THAT DATE. IN THIS CASE THE DUE DATE FOR GETTING THE ACCOUNTS AUDITED WAS 31-10-2008, WHERE AS THE AUDIT REPORT I S SHOWN TO BE DTD.15- 09-2008. HOWEVER, NO SUCH REPORT WAS FURNISHED BY T HAT DATE AND IN THIS CASE THE RETURN OF INCOME WAS FURNISHED ONLY ON 25- 03-2010, WHERE THERE WAS ONLY REFERENCE TO THE AUDIT REPORT AND NO SUCH REPORT WAS SHOWN TO HAVE BEEN EITHER FILED OR MADE AVAILABLE TO THE AO. THIS IS QUITE IN VIOLATION OF THE PROVISIONS OF SEC.44AB AND 271B. T HE CASE LAWS AND CIRCULARS RELIED UPON BY THE ASSESSEE WAS ONLY REFE RRING TO A SITUATION WHERE THE AUDIT REPORT COULD HAVE BEEN FILED, EVEN AFTER THE DUE DATE, IF IT WAS OBTAINED BEFORE THE SAID DUE DATE. IN THIS CASE , NO SUCH INFORMATION WAS AVAILABLE TO INDICATE THAT SUCH AUDIT WAS DONE AND REPORT WAS OBTAINED BEFORE THE DUE DATE, THOUGH IT WAS MENTION ED THAT SUCH REPORT WAS OBTAINED ON 15-09-2008. THERE WAS NO OCCASION F OR THE ASSESSEE TO PROVE THAT SUCH AUDIT REPORT WAS FURNISHED ALONG WI TH RETURN OF INCOME, BY THE DUE DATE, WHICH IS 31-10-2008 FOR THE YEAR U NDER REFERENCE, WITH NO RETURN OF INCOME WAS FURNISHED BEFORE 25-03-2010 AND NO AUDIT REPORT WAS FURNISHED SEPARATELY BY THAT DATE I.E., 31-10-2 008. FURTHER, THE SAID REPORT WAS ALSO ESTABLISHED TO HAVE NOT BEEN FILED/ FURNISHED AT THE TIME OF ASSESSMENT PROCEEDINGS, WITH NO SUCH REPORT AVAILAB LE BEFORE THE AO AT THE TIME OF PENALTY PROCEEDINGS. IN FACT, THE ASSES SEE WAS ON RECORD TO SHOW THAT SUCH REPORT WAS NOT AVAILABLE WITH THEM, DUE TO MISPLACEMENT OF THE SAID REPORT BY ACCOUNTANT. PART OF THE STATE MENT OF FACTS (SOF) FURNISHED ALONG WITH APPEAL CLEARLY INDICATES THIS FACTUAL POSITION. FOR SAKE OF CLARITY, THE RELEVANT POSITION IS REPRODUCE D RUNS AS UNDER: 'AT THE TIME OF ASSESSMENT OF THE ASSESSEE'S CASE, THE ABOVE TAX AUDIT REPORT COULD NOT BE FURNISHED DUE TO MISPLACEMENT OF THE S AME DUE TO NON AVAILABILITY OF THE CONCERNED ACCOUNTANT AND HENCE COULD NOT PRO DUCED/SUBMITTED WHICH MAY PLEASE BE CONSIDERED AND PENALTY MAY NOT BE LEV IED.' 6.1 THUS, AS COULD BE SEEN FROM THE FACTS OF THE CA SE, THE APPELLANT COULD NEITHER PROVE THAT THE ACCOUNTS WERE AUDITED BEFORE THE DUE DATE NOR ESTABLISH THAT COPY OF AUDIT REPORT WAS OBTAINED, W ITH SUCH REPORT NEITHER ITA NOS. 856, 857, 858 & 859/HYD/2016 :- 5 - : FILED BY DUE DATE OR EVEN AFTERWARDS. THUS ON THE F ACTS OF THE CASE, IT CLEARLY ATTRACTS THE PENALTY U/S. 271B OF I.T.ACT A ND AS PER THE SAID PROVISIONS PENALTY OF RS.64,088/-, BEING 0.5% OF TO TAL SALES OF RS.L,17,13,100/- FOR THE YEAR UNDER REFERENCE IS HE LD TO BE SUSTAINED, THE MAIN GROUNDS RELATED TO THE ISSUE, THUS ARE TREATED AS DISMISSED. 5. AGGRIEVED BY THE SAID ORDER OF THE LD.CIT(A), ASSE SSEE HAS FILED AN APPEAL BEFORE US WITH THE FOLLOWING GROUNDS : 1. THE ORDER OF THE LD. CIT (A)-12, HYDERABAD IS ER RONEOUS BOTH ON FACTS AND IN LAW. 2. THE LD. CIT (A) ERRED IN UPHOLDING THE DECISION MADE BY THE AO IN IMPOSING THE PENALTY U/S. 271B, WHICH IS NOT CORREC T AND NOT JUSTIFIED. 3. THE LD. CIT (A) OUGHT TO HAVE APPRECIATED THE FA CT THAT THE ACCOUNTS OF THE COMPANY HAVE DULY BEEN, AUDITED UNDER THE PROVI SIONS OF SECTION 44AB OF THE LT. ACT, 1961 WITHIN THE SPECIFIED TIME LIMIT THEREIN AND THE TAX AUDIT REPORTS ARE AVAILABLE WITH THE ASSESSEE. 4. THE LD. CIT (A) OUGHT TO HAVE APPRECIATED THE FA CT THAT THE COMPANY HAS NOT MADE ANY DELIBERATE DEFIANCE OF LAW OR A CONSCI OUS DISREGARD TO THE OBLIGATIONS CAST U/S 44AB AND 139(1) OF THE I.T. AC T, 1961. 5. THE LD. CIT (A) OUGHT TO HAVE APPRECIATED THE FA CT THAT IMPOSING OF PENALTY U/S. 271B IS NOT AUTOMATIC OR MANDATORY AND THE ASSESSING OFFICER IS VESTED WITH THE DISCRETION EITHER TO IMP OSE OR NOT TO IMPOSE THE PENALTY DEPENDING UPON THE FACTS AND CIRCUMSTANCES OF THE CASE. GROUND NO. 6 IS GENERAL IN NATURE. 6. LD. COUNSEL INITIALLY FILED ADDITIONAL EVIDENCE IN THE FORM OF AUDIT REPORT BUT IN THE COURSE OF PRESENT PROCEEDINGS, W ITHDREW THE ADDITIONAL EVIDENCE. IT WAS THE SUBMISSION OF THE LD. COUNSEL THAT THERE IS NO NEED TO ENCLOSE THE AUDIT REPORT WHEN THE RETU RNS WERE FILED, AS PER THE BOARD CIRCULAR NO. 5 OF 2007 DT. 26 -07-2007. HE REFERRED TO PARA 6 OF THE SAID CIRCULAR PARTICULARLY ITEM NO. (I) WHICH IS AS UNDER: ITA NOS. 856, 857, 858 & 859/HYD/2016 :- 6 - : (I) THE REPORT OF AUDIT UNDER SECTION 44AB IS NOT TO BE ATTACHED WITH THE RETURN. IT SHOULD NOT BE FURNISHED SEPARATELY ALSO BEFORE OR AFTER THE DUE DATE. HOWEVER, AN ASSESSEE SHOULD GET THE REPORT OF AUDIT FROM AN ACCOUNTANT UNDER SAID SECTION BEFORE THE DUE DATE O F THE FURNISHING OF THE RETURN AND SHALL FILL OUT THE RELEVANT COLUMNS OF T HESE FORMS ON THE BASIS OF SUCH REPORT. THE ASSESSEE SHOULD RETAIN THE REPORT WITH HIMSELF. IT MAY BE FURNISHED IN ORIGINAL DURING THE ASSESSMENT PRO CEEDINGS. NO PENALTY UNDER SECTION 271B SHALL BE INITIATED OR LEVIED FOR NOT FURNISHING THE TAX AUDIT REPORT ON OR BEFORE THE DUE DATE. HOWEVER, I F THE AUDIT REPORT HAS NOT BEEN OBTAINED BEFORE THE DUE DATE, PROVISIONS O F SECTION 271B SHALL BE ATTRACTED. (II) 6.1. IT WAS THE SUBMISSION THAT ASSESSEE HAS FILED THE RETURN WHICH WAS NOT TREATED AS DEFECTIVE AND AO HAS COMPLETED THE ASSESSMENT U/S. 153C AND INITIATED THE PENALTY ONLY O N THE REASON THAT AUDIT REPORT WAS NOT ENCLOSED TO THE RETURN OF INCO ME, WHICH WAS NOT REQUIRED AS PER THE BOARD CIRCULAR. HE FURTHE R SUBMITTED THAT THERE IS NO ALLEGATION BY THE AO THAT ASSESSEE-FIRM HAS NOT COMPLETED THE AUDIT AND OBTAINED REPORT BUT THE ISSUE B EFORE THE AO WAS ONLY THAT ASSESSEE SHOULD HAVE FILED ITS AUDIT REPORT, WHICH WAS NOT DONE. IT WAS THE SUBMISSION THAT AS THERE IS NO REQUIREMENT TO FILE THE AUDIT REPORT, ASSESSEE HAS NOT FI LED THE SAME ALONG WITH THE RETURN THOUGH ASSESSEE OBTAINED THE AUDIT REPORT BEFORE THE DUE DATE. 7. LD. DR, HOWEVER, SUBMITTED THAT ASSESSEE HAS NOT PLA CED AUDIT REPORT ON RECORD AND CIT(A) HAS GIVEN A FINDIN G ON THAT AND CONFIRMED THE PENALTY ON THE REASON THAT THE AUDIT WAS NO T EVEN CONDUCTED. ITA NOS. 856, 857, 858 & 859/HYD/2016 :- 7 - : 8. WE HAVE CONSIDERED THE RIVAL CONTENTIONS AND PERUSE D THE ORDERS OF THE AUTHORITIES. AS SEEN FROM THE ORDER OF TH E AO U/S. 153C, IT IS VERY CLEAR THAT AO HAS INITIATED PENALTY PR OCEEDINGS FOR NOT ENCLOSING THE AUDIT REPORT, BUT NOT FOR COMPLETING TH E AUDIT BEFORE THE DUE DATE. BOARD CIRCULAR NO. 5 OF 2007 C LEARLY STATES THAT WHILE UPLOADING THE RETURN, NO AUDIT REPORT SHOULD BE ATTACHED TO THE RETURN AND ALSO FURTHER STATES THAT IT SHO ULD NOT BE FURNISHED SEPARATELY ALSO BEFORE OR AFTER DUE DATE. NON-ENCLOSURE OF AUDIT REPORT TO THE RETURN OF INCOME DOES NOT ATTRACT ANY P ENALTY U/S. 271B, AS SPECIFIED IN THE BOARD CIRCULAR EXTRACT ED ABOVE. SINCE AO HAS INITIATED THE PENALTY PROCEEDINGS ONLY FO R NON- ENCLOSURE OF AUDIT REPORT ALONG WITH THE RETURN, WE A RE OF THE OPINION THAT THE SAME IS NOT ATTRACTING PENALTY, ON THE FACTS OF THE CASE, AS ASSESSEE HAS COMPLIED WITH THE BOARD CIRCULA R. IF THE AUDIT REPORT WAS NOT ENCLOSED TO THE RETURN OF INCOME FILED BY ASSESSEE SUBSEQUENTLY IN RESPONSE TO PROCEEDINGS U/S. 153C, AO SHOULD HAVE TREATED THE RETURN AS DEFECTIVE RETURN. NO SUCH ACTION WAS TAKEN BY THE AO, WHICH INDICATES THAT THE RETURN IS C OMPLETE IN ALL RESPECTS. SINCE PRIOR APPROVAL OF THE ADDL. C IT U/S. 153D WAS ALSO TAKEN BY THE AO BEFORE COMPLETION OF ASSESSME NT, WE ARE OF THE OPINION THAT NON ENCLOSURE OF AUDIT REPORT TO THE RETURN OF INCOME DOES NOT ATTRACT PENALTY PROCEEDINGS U/S. 271B. ACCORDINGLY, PENALTY LEVIED IS CANCELLED. 9. IN THE RESULT, THIS APPEAL OF ASSESSEE IS ALLOWED. 10. THE FACTS IN OTHER THREE APPEALS ARE SIMILAR AND THE PENALTY WAS INITIATED ONLY FOR NON-ENCLOSURE OF AUDIT REPORT TO THE RETURN OF INCOME. SINCE BOARD CIRCULAR SPECIFICALLY STATES THAT E NCLOSURE OF ITA NOS. 856, 857, 858 & 859/HYD/2016 :- 8 - : AUDIT REPORT WAS NOT REQUIRED, WE ARE OF THE OPINION THAT PENALTY PROCEEDINGS U/S. 271B ARE NOT ATTRACTED ON THE FACTS OF TH E CASE. ACCORDINGLY, PENALTIES IN OTHER THREE APPEALS ARE ALS O CANCELLED AND APPEALS ARE ALLOWED. 11. TO SUM-UP ALL THE APPEALS ARE ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 26 TH MAY, 2017 SD/- SD/- (V. DURGA RAO) (B. RAMAKOTAIAH) JUDICIAL MEMBER ACCOUNTANT MEMB ER HYDERABAD, DATED 26 TH MAY, 2017 TNMM COPY TO : 1. M/S. SRI SAI PRASANTHI REALTORS, HYDERABAD. C/O. P. MURALI & CO., CHARTERED ACCOUNTANTS, 6-3-655/2/3 , 1 ST FLOOR, SOMAJIGUDA, HYDERABAD. 2. M/S. SRI SAI ESWAR REAL ESTATES & DEVELOPERS, HYDERABAD. C/O. P. MURALI & CO., CHARTERED ACCOUNTA NTS, 6-3-655/2/3, 1 ST FLOOR, SOMAJIGUDA, HYDERABAD. 3. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL C IRCLE- 5, HYDERABAD. 4. CIT (APPEALS)-12, HYDERABAD. 5. PR.CIT-(CENTRAL), HYDERABAD. 6. D.R. ITAT, HYDERABAD. 7. GUARD FILE.