Vinod Aerukula, Hyderabad V. ITO, Ward-4(3), Hyderabad

ITA 99/HYD/2017

• Counselvise Citation: [2021] 108 COUNSELVISE.COM (IT) 0699 (ITAT-HYDERABAD)
• Duration Of Justice: 4 year(s) 5 month(s) 25 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 15-07-2021
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB-A
• Assessment Year: 2008-2009
• Appeal Filed On: 20-01-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: M NARMADA
• Keywords: Sale consideration of property below Jantri Value; Capital asset; Cost of acquisition; Set aside; Capital Gains
• Section: 143(3); 50C

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A : HYDERABAD (THROUGH VIDEO CONFERENCE) BEFORE SHRI S.S.GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER ITA NO. A.Y. APPELLANT RESPONDENT 1614/HYD/16 2008-09 THE INCOME TAX OFFICER, WARD-4(3), HYDERABAD SRI A.VINOD, HYDERABAD [PAN: AOOPA5855R] 1616/HYD/16 SRI A.SRINIVAS GOUD, HYDERABAD [PAN: AMOPA5039R] 98/HYD/17 SRI A.ARJUN GOUD, HYDERABAD [PAN: AMOPA5083F] THE INCOME TAX OFFICER, WARD-4(3), HYDERABAD 99/HYD/17 SRI ARUKULA VINOD, HYDERABAD [PAN: AOOPA5855R] 100/HYD/17 SMT. MOOLA PADMAJA, HYDERABAD [PAN: AOIPP2482B] 101/HYD/17 SMT.P.LAVANYA, HYDERABAD [PAN: ATLPP1018R] 102/HYD/17 SMT.A.GIRIJA, HYDERABAD [PAN: AMOPA5084C] 205/HYD/17 A.SRINIVAS GOUD, HYDERABAD [PAN: AMOPA5039R] FOR ASSESSEE : S HRI K .C.DEVDAS, AR FOR REVENUE : S MT. M.NARMADA, DR DATE OF HEARING : 2 1 - 0 6 - 20 2 1 DATE OF PRONOUNCEMENT : 1 5 - 0 7 - 2021 O R D E R PER S.S.GODARA, J.M. : THE INSTANT BATCH OF EIGHT APPEALS PERTAINS TO SIX ASSESSEES VIZ. SRI A.VINOD, SRI A.SRINIVAS GOUD, SR I A.ARJUN GOUD, SMT.MOOLA PADMAJA, SMT.P.LAVANYA & SMT.A.GIRIJA. ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 2 -: 2. THE REVENUES TWIN APPEALS ITA NOS.1614/HYD/2016 AND 1616/HYD/2016 IN RESPECT OF SRI A.VINOD AND SRI A.SRINIVAS GOUD AND LATTER TAXPAYERS CROSS-APPEALS IT A NO.205/HYD/2017 ALONGWITH REMAINING ASSESSEES APPE ALS ITA NOS.98 TO 102/HYD/2017 ARISE AGAINST THE CIT(A)-1, HYDERABADS SEPARATE ORDERS; ALL DATED 17-08-2016 PAS SED IN CASE NOS.0644, 0641, 0640, 0643, 0645 & 0642/CIT(A) - 1/HYD/2014-15/2016-17 ; INVOLVING PROCEEDINGS U/S. 143(3) R.W.S. 147 OF THE INCOME TAX ACT, 1961 [IN SHORT, THE ACT] ; RESPECTIVELY. HEARD BOTH THE PARTIES. CASE FILES PERUSED. 3. IT TRANSPIRES AT THE OUTSET THAT THESE ASSESSEES INSTANT APPEALS SUFFER FROM 60 DAYS IDENTICAL DELAY EXCEPT IN CASE OF SRI A.SRINIVAS GOUD (80 DAYS DELAY) STATED TO BE ATTRIBU TABLE TO THE REASON(S) BEYOND THEIR CONTROL AS PER CONDONATION PETITION(S)/AFFIDAVIT(S). NO REBUTTAL HAS COME FROM THE DEPARTMENTAL SIDE. THE IMPUGNED DELAY IS CONDONED IN ALL THE ABOVE SAID APPEALS THEREFORE. 4. WE FIRST ADVERT TO THE REVENUES APPEALS ITA NOS. 1614/HYD/2016 AND 1616/HYD/2016 RAISING THE FOLLOWIN G IDENTICAL SUBSTANTIVE GROUNDS AS UNDER: (I) LD. CIT(APPEALS) ERRED IN DIRECTING THE ASSESS ING OFFICER TO ADOPT THE OPEN LAND VALUE OF RS 4,53,75,000/- AS SALE CON SIDERATION AS AGAINST RS 12,18,13,120/- CONSIDERED BY THE ASSESSI NG OFFICER @ RS 8,000/- PER SQ. YD. FOR THE PURPOSE OF COMPUTATION OF CAPITAL GAINS ON TRANSFER OF THE SUBJECT PROPERTY BY THE ASSESSEE AN D OTHER CO-OWNERS. (II) LD. CIT(APPEALS) FAILED TO NOTE THAT AS PER TH E REGISTERED DOCUMENT FOR TRANSFER OF SUBJECT PROPERTY THE MARKET VALUE O F THE PROPERTY IS RS 38,40,00,000/- ON WHICH THE ASSESSEE AND OTHER CO-O WNERS HAVE PAID STAMP DUTY AND REGISTRATION CHARGES AS PER THE ENDORSEMENT OF THE REGISTERING AUTHORITY IN THE CONVEYANCE DEED. ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 3 -: (III) LD.CIT(APPEALS) OUGHT TO HAVE APPRECIATED THA T MARKET VALUE ADOPTED BY THE ASSESSING OFFICER AS SALE CONSIDERAT ION IS BASED ON THE CERTIFICATE ISSUED BY THE REGISTERING AUTHORITY AND THEREFORE THE ADDITION MADE BY THE ASSESSING OFFICER ON THIS GROU ND IS BASED ON CREDIBLE EVIDENCE AND REASONABLE. (IV) THE APPEAL CRAVES LEAVE TO ADD/ DELETE, SUBSTI TUTE, AMEND ANY GROUNDS OF APPEAL AT THE TIME OF HEARING. (V) FOR THESE AND OTHER GROUNDS THAT MAY BE CANVASS ED AT THE TIME OF HEARING OF THE APPEAL, IT IS BESEECHED THAT ADDITIO N MADE BY THE ASSESSING OFFICER ON ACCOUNT OF LONG TERM CAPITAL G AINS FROM TRANSFER OF PROPERTY BE RESTORED. 5. BOTH THE LEARNED REPRESENTATIVES NEXT TAKE US TO THE CIT(A)S DETAILED DISCUSSION DELETING THE IMPUGNED AD DITION AS UNDER: 5. GROUND-L: ADDITION U/S. 50C: DURING THE SURVEY CONDUCTED ON 14-03-2013 IN THE PR EMISES OF M/S.WESTERN CONSTRUCTIONS A PARTNERSHIP FIRM, IT WA S NOTICED THAT THE LAND ADMEASURING AN EXTENT OF ACRES 06.02 GUNTAS SI TUATED AT DARGA HUSSAIN SHAHWALI VILLAGE, SERILINGAMPALLY MANDAL, R ANGA REDDY DISTRICT, WAS GIVEN FOR DEVELOPMENT ON 03-05-2007. THE DEVELOPMENT AGREEMENT RECOGNIZE THE FOLLOWING FAMILY MEMBERS AS THE CO-OWNERS OF THE LAND. 1. SMT.A.GIRIJA 2. SRI A.ARJUNGOUD 3. SRI A.VINOD 4. SRI M.PADMAJA 5. SRI A.SRINIVASGOUD 6. SRI P.LAVANYA IT IS SEEN FROM THE DEVELOPMENT AGREEMENT THAT THE APPLICANT ALONG WITH CO-OWNERS HAD GIVEN THE LAND OF 6 ACRES 2 GUNT AS FOR DEVELOPMENT OF WHICH THE BUILDERS SHARE IS 52%. AS PER SRO'S VALUE FOR REGISTRATION GIVEN IN THE DEVELOPMENT DEED, THE COST PER ACRE TAKEN FOR THE PURPOSE OF REGISTRATION IS RS.75 LAC PER AC RE. THE ASSESSING OFFICER CALLED FOR VALUE AS PER SRO A S ON 03-05-2007. THE SRO CERTIFICATE IS AS FOLLOWS: (A) VALUE OF AGRICULTURAL LAND: RS.75,00,000 PER ACRE (B) RESIDENTIAL : RS.8,000 PER SQUARE YARD (C) COMMERCIAL : RS.11,000 PER SQUARE YARD ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 4 -: THE VALUE OF LAND' OF RESIDENTIAL IS RS.8,000/- PER SQUARE YARD. THE ASSESSING OFFICER TOOK THE VALUE AS PER SRO AND CAL CULATED AS FOLLOWS: TOTAL LAND 6 ACRES 2 GUNTAS LAND IN SQUARE YARDS 29,282 SQ. YDS BUILDERS SHARE 52% OF 29,282 SQ.YDS 15,226.64 SQ. Y DS RATE PER SQUARE YARD AS PER SRO CERTIFICATE RS.8,000/- VALUE OF LAND TRANSFERRED TO THE BUILDER RS.12,18,1 3,120/- SHARE OF THE ASSESSEE 40% OF RS.12,18,13,120/- RS.4,87,25,248/- THE FULL VALUE OF CONSIDERATION IS THEREFORE TAKEN AT RS.4,87,25,248/- THE TOTAL CONSIDERATION WAS VALUED AT RS.12,18,13,1 20/-. BEFORE ME, THE APPLICANT ARGUED THAT: A) THE SECTION 50C SAYS: 'WHERE THE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF THE TRANSFER BY AN ASSESSEE OF A CAPITAL ASSET, BEING L AND OR BUILDING OR BOTH, IS LESS THAN THE VALUE ADOPTED OR ASSESSED [O R ASSESSABLE] BY ANY AUTHORITY OF A STATE GOVERNMENT (HEREAFTER IN T HIS SECTION REFERRED TO AS THE 'STAMP VALUATION AUTHORITY'') FOR THE PUR POSE OF PAYMENT OF STAMP DUTY IN RESPECT OF SUCH TRANSFER, THE VALUE S O ADOPTED OR ASSESSED [OR ASSESSABLE] SHALL, FOR THE PURPOSES OF SECTION 48, BE DEEMED TO BE THE FULL VALUE CONSIDERATION RECEIVED OR ACCRUING AS A RESULT OF SUCH TRANSFER. ' B) THE APPLICANT HAS OFFERED SALE VALUE AS PER REGI STRAR VALUE ON THE DAY OF REGISTRATION. THIS VALUE IS MORE ACCURATE TH AN LATER CALLED ON, VALUE BY THE ASSESSING OFFICER. C) THE LAND SOLD IS NOT PLOTTED RESIDENTIAL SITE. I N FACT A LONG STRETCH OF AGRICULTURAL LAND. NO EXPENSE HAS BEEN CLAIMED TOWA RDS LAYING OF ROAD OR SITE EXCAVATION. THE SRO VALUE SUGGESTED BY THE ASSESSING OFFICER IS FOR DEVELOPED RESIDENTIAL SITE AND NOT F OR A PIECE OF LAND. THERE IS STRENGTH IN THE ARGUMENT OF THE APPLICANT. FIRSTLY, SECTION 50C VERY CLEARLY TALKS ABOUT VALUE ADOPTED BY THE A UTHORITY FOR THE PURPOSE OF PAYMENT OF STAMP DUTY IN RESPECT OF SUCH TRANSFER. THE APPLICANT HAS SUBMITTED REGISTERED DEED WHICH VERY CLEARLY SAYS THE SALE VALUE IS SAME AS THE SRO VALUE FOR THE STAMP D UTY PURPOSE. THE ASSESSING OFFICER DID NOT VERIFY THE ISSUE AS TO WH Y THE SRO VALUE GIVEN IN THE REGISTERED DEED IS AS PER ACRES AND IN FORMATION CALLED IN A LATER DATE IS NOT CALLED FOR VALUE AS PER ACRES. THE CONTENTION OF THE APPLICANT THAT THIS LAND IS NOT SUBJECTED TO ANY IM PROVISATION. THAT IS TO SAY THERE IS NO ROAD LAYING OR EVENING OF THE SO IL. THE ASSESSING ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 5 -: OFFICER HAS NOT TAKEN THESE ISSUES BEFORE COMING TO CONCLUSION. THERE CANNOT BE TWO DIFFERENT VALUES FOR SRO, FOR THE SAM E LAND. IN THIS BACKGROUND, I ALLOW THE CONTENTION OF THE APPLICANT . 6. WE HAVE GIVEN OUR THOUGHTFUL CONSIDERATION TO RIVAL PLEADINGS AGAINST AND IN SUPPORT OF THE CIT(A)S ACTIO N REVERSING THE ASSESSMENT FINDINGS MAKING THE IMPUGNED LONG TERM CAPITAL GAIN ADDITION(S). THERE IS HARDLY ANY DI SPUTE THAT THE REGISTERED DEVELOPMENT AGREEMENT HEREIN WAS EXECUTED ON 03-05-2007 EARLIER WITH M/S.NEELIMA CONSTRUSTIONS AND THAN WITH M/S.WESTERN CONSTRUCTIONS; RESPECTIVELY. THIS RE GISTERED DEVELOPMENT AGREEMENT STATED THE LAND IN ISSUE TO BE 6 AC RES 2 GUNTAS. THERE IS FURTHER NO ISSUE THAT THE ASSESSEES H AD VERY WELL DECLARED THEIR RESPECTIVE CAPITAL GAINS, SHARE-W ISE; RESPECTIVELY. 7. LEARNED DEPARTMENTAL REPRESENTATIVE INVITED OUR ATTENTION TO THE ASSESSING OFFICERS ASSESSMENT ORDER(S) DT.28- 05-2014 INTER ALIA STATING THAT HE HAD PROCEEDED TO MAKE THE IMPUGNED ADDITION(S) AFTER GETTING THE STAMP VALUE FROM THE SROS OFFICE QUA THE LAND IN QUESTION IN SQUARE YARDS; RESIDENTIAL AND COMMERCIAL, AS THE CASE MAY BE; THAN HAVING ACCEPTED THE ASSESSEES COMPUTATION DECLARING THE SAME AT RS.75,00,000/- PER ACRE ONLY. IT WAS THE SAID SROS REPORT WHICH LED TO THE IMPUGNED ADDITION(S) BEING MADE IN ASSESSEES HANDS AND REVERSED IN THE CIT(A)S FOREGO ING DETAILED DISCUSSION. 8. WE HAVE GIVEN OUR THOUGHTFUL CONSIDERATION TO REVENU ES VEHEMENT CONTENTIONS SEEKING TO REVIVE THE ASSESSING OF FICERS ACTION AND FIND NO MERIT IN THE SAME. THIS IS FOR THE PRECISE REASON THAT SECTION 50C NOWHERE CONFERS ANY JURISDICTI ON TO ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 6 -: THE ASSESSING AUTHORITY TO CHANGE THE NATURE OF THE CA PITAL ASSET OTHER THAN THAT DECLARED IN THE CORRESPONDING TRAN SFER INSTRUMENT U/S.2(47)(V) OF THE ACT. HON'BLE APEX COUR TS RECENT LARGER BENCHS DECISION IN COMMISSIONER OF CUSTOMS V S. DILIP KUMAR (2018) 9 SCC 1 (FB)(SC) SETTLES THE LAW THAT ONLY STRICT INTERPRETATION IS TO BE ADOPTED WHILST CONSTRUING A TAXING OR AN EXEMPTION PROVISION; AS THE CASE MAY BE. COUPLED WI TH THIS, THE CRUCIAL STATUTORY EXPRESSION ASSESSABLE IN SECT ION 50C CAME TO BE INSERTED BY WAY OF FINANCE (NO.2) ACT, 2009 W.E.F.01-10-2009 WHEREAS WE ARE IN AY.2008-09 ONLY. WE THUS HOLD IN THE FOREGOING FACTUAL BACKDROP THAT THE CIT(A) HAS RIGHTLY REVERSED THE IMPUGNED LONG TERM CAPITAL GAIN M ADE IN THE ASSESSEES HANDS. THE SAME STANDS AFFIRMED ACCORD INGLY. THE REVENUES TWIN APPEALS ITA NOS. 1614/HYD/2016 A ND 1616/HYD/2016 RAISING THE INSTANT SOLE ISSUE FAIL THE REFORE. 9. WE ARE NOW LEFT WITH ASSESSEES APPEALS ITA NOS. 9 8 TO 102/HYD/2017 AND ITA NO.205/HYD/2017 (SUPRA). THEIR IDENTICAL SOLE SUBSTANTIVE GROUND PLEADS THAT THE CIT(A) HAS ERRED IN LAW AND ON FACTS IN DISALLOWING COST OF ACQU ISITION CLAIM TO THE TUNE OF RS.3 CRORES PAID TO SHRI A.SAHDE VA AND SHRI A.KRISHNA TO THE TUNE OF RS.1.5 CRORES EACH. THE ASSESSING OFFICERS ASSESSMENT ORDER(S) HELD IN IDE NTICAL TERMS THAT THESE ASSESSEES HAD FAILED TO PROVE THE PURPOSE OF THE IMPUGNED PAYMENT(S) OVER AND ABOVE THE COMPROMISE TERM S WHICH ALLOWED ONLY RS.8 CRORES OUT OF THAT CLAIMED TO TH E TUNE OF RS.11 CRORES. 10. THE CIT(A) HAS RESTORED THE INSTANT ISSUE BACK TO ASSESSING OFFICER AS UNDER: ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 7 -: 6. GROUND-2: DISALLOWANCE OF RS.3,00,00,000/- CLAI MED BY THE APPELLANT TOWARDS COST OF ACQUISITION: THE APPLICANT SUBMITTED THAT THEY HAVE MADE PAYMENT OF RS.1.5 CRORE TO SRI A. SAHADEVA AND SRI A.KRISHNA EACH. TH IS PAYMENT OF SRI A.SAHADEVA WAS RECEIVED BY HIS LEGAL REPRESENTATIVE MRS. A. VIMALA MRS. A.VIMALA IS A NOT INCOME TAX ASSESSEE AND IS R ESIDENT OF HYDERABAD. SRI A. KRISHNA WAS RETIRED GOVERNMENT TE ACHER AND NOT INCOME TAX ASSESSEE. BOTH ARE ASSESSED IN RANGE-7, HYDERABAD. IN REGARD TO OFFERING THIS INCOME BOTH THE RECIPIENTS HAVE NOT OFFERED IN THEIR RETURN OF INCOME. THE APPLICANT SUBMITTED THAT THESE PAYMENTS WERE MA DE THROUGH CHEQUES AS DETAILS GIVEN BELOW: S.NO. NAME CHEQUE NO. DATE NAME OF THE BANK 1 SRI A.KRISHNA 192590 11-05-2007 ICICI BANK 2 SMT.A.VIMALA 192592 15-05-2007 ICICI BANK THESE PAYMENTS WERE MADE TO SETTLE THE DISPUTE FOR WHICH THE APPLICANT WAS ON LEGAL BATTLE BEFORE HON'BLE HIGH C OURT OF ANDHRA PRADESH AND GET POSSESSION OF THE PROPERTY. THE HON 'BLE COURT HAD AS PER ORDER NO.402 OF 2006 & ASMP NO.2773 OF 2006 ASKED THE APPLICANT TO PAY RS.8 CRORES TO THE DISPUTED MEMBER S FOR SETTLEMENT. HOWEVER, FURTHER RS.3 CRORES WERE PAID TO SRI A.KRI SHNA AND SMT.A.VIMALA TO COME TO A CONCLUSIVE END. 11. WE FIND NO REASON TO EXPRESS OUR AGREEMENT WITH TH E LEARNED CIT(A)S FOREGOING REMAND DIRECTIONS GOING A GAINST THE AMENDMENT IN SECTION 251(1)(A) OF THE ACT VIDE FINANCE ACT, 2001 W.E.F.01-06-2001 OMITTING THE CLINCHING STATUTORY EXPRESSION OR HE MAY SET ASIDE. THE FACT ALSO REMA INS THAT THE ASSESSEES HAVE NOT BEEN ABLE TO PROVE AS TO UNDER W HAT CIRCUMSTANCES THEY HAD TO PAY THE IMPUGNED SUM TOTALLING TO RS.3 CRORES (SUPRA) OVER AND ABOVE RS.8 CRORES AS P ER THE TERMS OF SETTLEMENT. WE THEREFORE DEEM IT APPROPRIATE THAT THESE ASSESSEES NEED TO BE AFFORDED ONE MORE EFFECTIVE INNINGS BEFORE THE ASSESSING OFFICER TO EXPLAIN THE JUSTIFICATIO N OF RS.3 CRORES MADE TO THE TWIN RECIPIENTS (SUPRA) AS FALLING U/S.48(I) ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 8 -: AND (II) OF THE ACT; AS THE CASE MAY BE. THESE ASSESSE ES ARE DIRECTED TO APPEAR THEMSELVES OR THROUGH THEIR AUTHORI SED REPRESENTATIVE; AS THE CASE MAY BE ON OR BEFORE 31-10- 2021 WITH ALL THE SUPPORTIVE EVIDENCE; AT THEIR OWN RISK AND RESPONSIBILITY TO BE FOLLOWED BY THREE EFFECTIVE OPPOR TUNITIES OF HEARING FOR THE CONSEQUENTIAL VERIFICATION. THE SOLE SUBSTANTIVE GROUND RAISED IN ITA NO.98/HYD/2017 AND ALL THE REMA INING CORRESPONDING ASSESSEES APPEALS IS TREATED AS ALLOWE D FOR STATISTICAL PURPOSES IN ABOVE TERMS. 12. TO SUM-UP, REVENUES TWIN APPEALS ITA NOS.1614 & 1616/HYD/2016 ARE DISMISSED AND THE ASSESSEES APPEA LS ITA NOS.98 TO 102/HYD/2017 & 205/HYD/2017 ARE TREATED AS ALLOWED FOR STATISTICAL PURPOSES. A COPY OF THIS COMMO N ORDER BE PLACED IN THE RESPECTIVE CASE FILES. ORDER PRONOUNCED IN THE OPEN COURT ON 15 TH JULY, 2021 SD/- SD/- (LAXMI PRASAD SAHU) (S.S.G ODARA) ACCOUNTANT MEMBER JUDICIAL MEM BER HYDERABAD, DATED: 15-07-2021 TNMM ITA NOS. 1614 & 1616/HYD/2016 98, 99, 100, 101, 102 & 205/HYD/2017 :- 9 -: COPY TO : 1.THE INCOME TAX OFFICER, WARD-4(3), HYDERABAD. 2.SRI A.VINOD, 301, PRASANTHI ARCADE, D.NO.2-2-58, AMBERPET MAIN ROAD, HYDERABAD. 3.SRI A.SRINIVAS GOUD, 301, PRASANTHI ARCADE, D.NO. 2-2-58, AMBERPET MAIN ROAD, HYDERABAD. 4.SRI A.ARJUN GOUD, C/O.V.SRIDHAR & CO., 12-2-823/A /78, GEETHA APARTMENTS, SANTOOSH NAGAR COLONY, MEHDIPATNAM, HYDERABAD. 5.SMT.MOOLA PADMAJA, C/O.V.SRIDHAR & CO., 12-2- 823/A/78, GEETHA APARTMENTS, SANTOOSH NAGAR COLONY, MEHDIPATNAM, HYDERABAD. 6.SMT.P.LAVANYA, C/O.V.SRIDHAR & CO., 12-2-823/A/78 , GEETHA APARTMENTS, SANTOOSH NAGAR COLONY, MEHDIPATNAM, HYDERABAD. 7.SMT.A.GIRIJA, C/O.V.SRIDHAR & CO., 12-2-823/A/78, GEETHA APARTMENTS, SANTOOSH NAGAR COLONY, MEHDIPATNAM, HYDERABAD. 8.CIT(APPEALS)-1, HYDERABAD. 9.PR.CIT-1, HYDERABAD. 10.D.R. ITAT, HYDERABAD. 11.GUARD FILE.