Chinta Satyanarayana, Hyderabad V. ACIT, Hyderabad

ITSSA 76/HYD/2005

• Counselvise Citation: [2011] 124 COUNSELVISE.COM (IT) 8637 (ITAT-HYDERABAD)
• Duration Of Justice: 5 year(s) 9 month(s) 14 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 21-01-2011
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: misc
• Appeal Filed On: 07-04-2005
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: SRINIVAS
• Assessee Lawyers: S RAMA RAO
• Keywords: Unexplained investment; Search and seizure; Block assessment

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD BEFORE SHRI G.C. GUPTA, VICE PRESIDENT AND SHRI AKBER BASHA, ACCOUNTANT MEMB ER IT (SS)A NO.76/HYD/05 : BLOCK ASST. PERIOD 1997-98 TO 2002-03 (UP TO 2-7-2002) CHINTA SATYANARAYANA, L.B. NAGAR, HYDERABAD. (PAN ABFPC 7006 A) VS ACIT, CENTRAL CIRCLE-5, HYDERABAD. (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI S. RAMA RAO RESPONDENT BY : SHRI SRINIVAS O R D E R PER AKBER BASHA, ACCOUNTANT MEMBER: THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST THE OR DER OF THE CIT (A)-I, HYDERABAD DATED 28-12-2004 AND IT PER TAINS TO THE BLOCK ASSESSMENT PERIOD FROM 1997-98 TO 2002-03 UP TO 2-7-200 2. 2. THE ASSESSEE RAISED THE FOLLOWING GROUNDS OF APPEAL:- 1. THE ORDER OF THE CIT (A) IS ERRONEOUS BOTH ON FA CTS AND IN LAW. 2. THE CIT (A) ERRED IN CONFIRMING THE ACTION OF THE A SSESSING OFFICER IN INCLUDING THE TRANSACTIONS BETWEEN SMT. CH. LAXMI, IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . WIFE OF THE APPELLANT AND SRI CHAITANYA EDUCATIONAL INSTITUTIONS AS THE TRANSACTIONS BELONGING TO THE APPELLANT. 3. THE CIT(A) ERRED IN CONFIRMING THE ACTION OF THE ASS ESSING OFFICER IN HOLDING THAT THE AMOUNT OF RS.2,49,960 RECE IVED DURING THE FINANCIAL YEAR ENDED 31-3-2001 BY THE APP ELLANTS WIFE REPRESENTS THE UNDISCLOSED INCOME OF THE APPELLAN T. 4. THE CIT(A) ERRED IN CONFIRMING THE ACTION OF THE ASS ESSING OFFICER IN HOLDING THAT THE AMOUNT OF RS.7,50,000 RECE IVED DURING THE FINANCIAL YEAR ENDED 31-3-2002 BY THE A PPELLANTS WIFE REPRESENTS THE UNDISCLOSED INCOME OF THE APPELLANT . 5. THE CIT(A) ERRED IN CONFIRMING THE ACTION OF THE ASS ESSING OFFICER IN HOLDING THAT THE AMOUNT OF RS.1,87,500 RECE IVED DURING THE FINANCIAL YEAR ENDED 31-3-2003 BY THE APP ELLANTS WIFE REPRESENTS THE UNDISCLOSED INCOME OF THE APPELLANT . 6. WITHOUT PREJUDICE THE ABOVE, THE LEARNED CIT(A) OU GHT TO HAVE CONSIDERED THE FACT THAT THE ENTIRE AMOUNT RECEIVED FR OM SRI CHAITANYA EDUCATIONAL INSTITUTIONS CANNOT BE CONSIDERED AS THE UNDISCLOSED INCOME WITHOUT ALLOWING ANY AMOUNT OF EXPENDITURE AND WITHOUT DEDUCTING WHAT WAS ALREADY ADMITTED BY SMT. LAXMI, WIFE OF THE APPELLANT. 7. THE CIT(A) ERRED IN CONFIRMING THE ACTION OF HAVE ASSESSING OFFICER IN MAKING ADDITION OF RS.2,86,200/- ON THE G ROUND THAT THE PAYMENT WAS MADE TO SRI M. RAMESH. 8. THE CIT (A) ERRED IN CONFIRMING THE ACTION OF THE A SSESSING OFFICER IN CHARGING INTEREST UNDER SECTION 158BFA OF RS.9 ,284/-. 9. THE CIT (A) ERRED IN CONFIRMING THE ACTION OF THE A SSESSING OFFICER IN LEVYING SURCHARGE OF RS.44,210/-. 10. ANY OTHER GROUND THAT MAY BE URGED AT THE TIME OF HEARING. 2 IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE, AN INDI VIDUAL IS WORKING AS ASST. EXECUTIVE ENGINEER (I & CAD), HYDERABA D. ACCORDING TO THE PERSONAL PROFILE FURNISHED BY THE ASSESSEE, HE HA D COMPLETED GRADUATION IN ENGINEERING IN JNTU, HYDERABAD IN THE YEAR 1979 AND HAD JOINED THE SERVICE WITH GOVERNMENT OF ANDHRA PRADESH A S JUNIOR ENGINEER IN 1980. IN RESPECT OF HIS SALARY EARNINGS, H E HAD BEEN FILING RETURNS OF INCOME FROM THE ASSESSMENT YEAR1997-98 TO 200 2-03. THE DEPARTMENT CONDUCTED SEARCH AND SEIZURE OPERATIONS AT T HE PREMISES OF THE ASSESSEE ON 2-7-2002. THE SEARCH IS SAID TO BE IN CON SEQUENCE TO THE SEARCH CONDUCTED IN THE CASE OF SRI CHAITANYA EDUCAT IONAL INSTITUTIONS. THE ASSESSEES WIFE SMT. CH. LAKSHMI ENTER ED INTO AN AGREEMENT WITH SRI CHAITANYA GROUP OF EDUCATIONAL IN STITUTIONS FOR UNDERTAKING LECTURES IN MATHEMATICS AT THE COLLEGE PR EMISES AND THE INFORMATION SEIZED FROM THE PREMISES OF SRI CHAITANYA GROUP OF INSTITUTIONS SHOWED THAT THE ASSESSEES WIFE SMT. LAKSHMI W AS IN RECEIPT OF CONSIDERATION IN LIEU OF THE SERVICES RENDERED AS PE R THE AGREEMENT ENTERED INTO. THE ASSESSEES WIFE IS SEPARATELY ASSESSE D TO INCOME-TAX AND SHE FILED RETURN OF INCOME FOR THE ASSESSMENT YEAR 1 997-98 EVEN PRIOR TO THE DATE OF SEARCH DISCLOSING THE RECEIPT FROM THE SAID EDUCATIONAL INSTITUTION. THE ASSESSING OFFICER ISSUED NOT ICE UNDER SECTION 158BC OF THE ACT TO THE ASSESSEE AND THE ASSESSEE FILED TH E RETURN OF INCOME IN FORM NO.2B ON 30-4-2004 ADMITTING THE UNDI SCLOSED INCOME BE RS. NIL. THE ASSESSEE CONTENDED BEFORE THE ASSESSING O FFICER THAT HE DID NOT RECEIVE ANY CONSIDERATION FROM SRI CHAITA NYA GROUP OF INSTITUTIONS AND THAT HIS WIFE WAS IN RECEIPT OF THE AMOUNTS AND SHE ADMITTED SUCH RECEIPTS IN HER RETURNS OF INCOME FILED FOR THE ASSESSMENT YEARS UNDER CONSIDERATION. THE ASSESSING OFFICER REJECTED THE 3 IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . CONTENTION OF THE ASSESSEE AND HELD THAT THE AMOUNTS RECE IVED BY THE ASSESSEES WIFE FROM CHAITANYA GROUP OF INSTITUTIONS REP RESENT CONSIDERATION FOR THE SERVICES RENDERED BY THE ASSESSEE AL ONE. THE ASSESSING OFFICER ALSO EXTRACTED FROM THE STATEMENTS RECORD ED BY THE ADI AND HIMSELF. THE ASSESSING OFFICER CAME TO CONCLUSION T HAT THE AMOUNTS RECEIVED FROM SRI CHAITANYA EDUCATIONAL INSTI TUTIONS BY THE ASSESSEES WIFE RELATE TO THE ASSESSEE. THE ASSESSING OFFICER WITHOUT DEDUCTING ANY AMOUNTS TOWARDS EXPENDITURE TREATED TH E GROSS RECEIPT FROM CHAITANYA EDUCATIONAL INSTITUTIONS BY THE ASSESSEES WIFE AS THE INCOME OF THE ASSESSEE. BESIDES, THE ASSESSING OFFICER ALSO TRE ATED THE AMOUNT OF RS.2,38,500/- SAID TO HAVE BEEN PAID TO SRI M. RAMESH AS THE UNDISCLOSED INCOME THE ASSESSEE WITHOUT PROVIDING SET OFF TO THE INCOME ASSESSED. AGGRIEVED BY THE ORDER OF THE ASSESSING OFFICER, THE ASSESSEE WENT IN APPEAL BEFORE THE CIT [A]. ON APPEAL, THE C IT [A] CONSIDERED THE SUBMISSIONS MADE BY THE ASSESSEE AND HELD THAT THE ADDITI ONS MADE BY THE ASSESSING OFFICER ARE CORRECT. AGGRIEVED FURTHER, THE ASSESSEE IS IN APPEAL BEFORE US. 3. GROUND NO.1 AND 10 ARE GENERAL IN NATURE AND HENCE NO ADJUDICATION IS REQUIRED. GROUND NO. 9 IS NOT PRESSED BY THE LEARNED COUNSEL FOR THE ASSESSEE AND THE SAME IS DISMISSED AS NOT PR ESSED. GROUND NO. 8 IS WITH REGARD TO CHARGING OF INTEREST U NDER SECTION 158 BFA. SINCE THE GROUND IS CONSEQUENTIAL IN NATURE AND T HE SAME IS DISPOSED OFF ACCORDINGLY. GROUNDS NO.2 TO 6 RELATE TO THE REMUNERATION RECEIVED FROM SRI CHAITANYA EDUCATIONAL INSTITUTE OF RS.2,49,960/- FOR THE ASSESSMENT YEAR 2001-02 AND RS.7,50,000 FOR ASSESSME NT YEAR 2002-03 AND RS.1,87,500 FROM 1.4.2002 TO 2.7.2002 TO TALLING TO RS.11,87,460 ALLEGED TO HAVE BEEN RECEIVED BY THE ASSESS EES WIFE 4 IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . ASSESSED AS UNDISCLOSED INCOME IN THE HANDS OF THE ASSESSEE. THE LEARNED COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE ASSESSEE S WIFE SMT. LAKSHMI ENTERED INTO AN AGREEMENT WITH SRI CHAI TANYA EDUCATIONAL INSTITUTIONS FOR CONDUCTING THE CLASSES. SHE ENGAGED THE SERVICES OF OTHER LECTURERS INCLUDING HER HUSBAND IN DISCHARGING HE R EDUCATIONAL OBLIGATION WITH THE INSTITUTION. SRI CHAITANYA EDUCA TIONAL INSTITUTION ISSUED CHEQUES IN FAVOUR OF SMT. LAKSHMI AND NOT IN FA VOR OF THE ASSESSEE. THE CERTIFICATES IN FORM NO.16A WERE ALSO ISSUED BY SRI CHAITANYA EDUCATIONAL COMMITTEE IN FAVOR OF SMT. LAK SHMI. SHE FILED HER RETURN OF INCOME FOR ASSESSMENT YEAR 2001-02 ON 26-7 -2001 SHOWING INCOME OF RS.2,54,000/- AS AGAINST INCOME RECEIV ED THROUGH CHEQUE OF RS.1,74,000 INCLUDING THE CASH PORTION OF THE AMOUNT, THE TOTAL AMOUNT RECEIVED AS PER THE MATERIAL SEIZED FROM SRI CHAITANYA EDUCATIONAL INSTITUTION. THE ASSESSEE SRI CH. SATYANARA YANA WAS AN EMPLOYEE WITH THE STATE GOVERNMENT WORKING AS ASSISTA NT ENGINEER, CENTRAL DIVISION, DESIGNS ORGANIZATION, AND IRRIGATI ON DEPARTMENT AND WAS IN RECEIPT OF SALARY FROM CHIEF ENGINEER. DURING THE BLOCK PERIOD, THE ASSESSEE WAS EMPLOYED IN THE STATE GOVERNMENT AND THEREFORE, IT IS NOT CORRECT TO SAY THAT HE WAS EMPLOYED WITH SRI CHAIT ANYA EDUCATIONAL COMMITTEE. IN THE CIRCUMSTANCES, THE AMOUNTS RECEIVED FR OM SRI CHAITANYA EDUCATIONAL INSTITUTION ARE ASSESSABLE IN TH E HANDS OF WIFE AND NOT IN THE HANDS OF THE ASSESSEE. FOR THE ASSESSMENT Y EAR 2002- 03, SMT. LAKSHMI FILED HER RETURN OF INCOME ON 17-6-2 004 SHOWING INCOME OF RS.3,53,210 AFTER CLAIMING EXPENDITURE OF RS. 4,00,580/- FROM THE RECEIPT OF RS.7,50,000 RECEIVED FROM SRI CHAITANY A EDUCATIONAL INSTITUTION. THE ASSESSING OFFICER OUGHT TO HAVE CONSID ERED THE EXPENDITURE OF RS.4,00,580 WHICH WAS INCURRED ON PRI NTING AND STATIONERY, BOOKS AND PERIODICALS, SALARY TO ASSISTANTS, D EPRECIATION ON 5 IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . CAR, CONVEYANCE, ETC., FOR ASSESSMENT YEAR 2003-04, THE RE TURN WAS FILED ON 31-3-2003 SHOWING INCOME OF RS.2,60,770 AFTER CLAIM ING EXPENDITURE OF RS.3,04,890 FROM THE RECEIPT OF RS.6,00 ,000. THEREFORE, IT IS NOT PROPER ON THE PART OF THE ASSESSING OFFICER TO CONSIDER THE ENTIRE AMOUNT OF RS.1,87,500 AS UNDISCLOSED INCOME OF THE ASSESSEE . IT HAS BEEN FURTHER CONTENDED THAT THE ASSESSING OFFICER HAS MAINLY RELIED ON THE DEPOSITION OF THE ASSESSEE AT THE TIME OF SEARCH AND T HE DEPOSITION OF THE ASSESSEES WIFE DURING THE COURSE OF ASSESSMENT P ROCEEDINGS. THE DEPOSITION OF THE ASSESSEE AT THE TIME OF SEARCH ALON E CANNOT BE CONSIDERED FOR ASSESSMENT PARTICULARLY WHEN THE SEIZED DOCU MENT CLEARLY SHOWS THAT THE AMOUNT WAS PAID TO THE ASSESSEES WIFE. FURTHER, THE ASSESSEE IS AN EMPLOYEE OF THE STATE GOVERNMENT AND CANN OT BE CONSIDERED AS AN EMPLOYEE OF SRI CHAITANYA EDUCATIONAL INSTITUTION. SINCE THE ASSESSEES WIFE FILED THE RETURN OF INCOME PRIO R TO THE DATE OF SEARCH, THE AMOUNTS RECEIVED BY HER THROUGH CHEQUES CAN NOT BE INCLUDED IN THE HANDS OF THE ASSESSEE. IT IS SUBMITTED THAT THE ENTIRE AMOUNT RECEIVED FROM SRI CHAITANYA EDUCATIONAL INSTITU TIONS CANNOT BE CONSIDERED AS THE UNDISCLOSED INCOME WITHOUT ALLOWING AN Y AMOUNT OF EXPENDITURE AND WITHOUT DEDUCTING WHAT WAS ALREADY A DMITTED BY SMT. LAXMI. ALTERNATIVELY, IT IS SUBMITTED THAT ON SIMILAR MATTER IN THE CASE OF N. SRINIVASA RAO AND OTHERS IN IT(SS) A NO. 32/HYD/2 006 THIS BENCH OF THE TRIBUNAL IN ITS ORDER DATED 13-2-2009 HELD THA T THE SALARY RECEIVED BY THE ASSESSEES FOR THE ASSESSMENT YEARS 2002-03 AND 2003-0 4 CANNOT BE TREATED AS UNDISCLOSED INCOME OF THE ASSESSEE IN THE BLOCK ASSESSMENT ON THE GROUND THAT THE DUE DATE OF FILING TH E RETURN FOR THOSE YEARS WAS NOT OVER BY THE DATE OF SEARCH. 6 IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . 4. ON THE OTHER HAND, THE LEARNED DEPARTMENTAL REPRE SENTATIVE RELIED ON THE ORDERS OF THE AUTHORITIES BELOW. 5. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AND PERUSED TH E MATERIAL AVAILABLE ON RECORD. WE FIND THAT THE ISSUE RELATING TO THE ALLEGED REMUNERATION RECEIVED BY THE ASSESEES WIFE WHI CH WAS TREATED AS UNDISCLOSED INCOME IN THE HANDS OF THE ASSESSEE FOR T HE ASSESSMENT YEARS 2002-03 AND 2003-04 IS NOT COVERED BY THE DECISI ON OF THE TRIBUNAL IN THE CASE OF N. SRINIVASA RAO AND OTHERS (SU PRA) AND THE FACTS AND THE CIRCUMSTANCES OF THIS CASE ARE DISTINGUISHABLE FROM THE FACTS OF THE INSTANT CASE. IN THAT CASE, ALL THE ASSESSMENTS ARE MAD E BY THE ASSESSING OFFICER ARE RELATED TO THE LECTURERS/STAFF OF TH E CHAITANYA INSTITUTION AND NOT FOR THE SPOUSES OF THE ASSESSEES. IN OTHER WORDS, THE QUESTION OF WHETHER ALLEGED PAYMENT MADE BY THE CHAI TANYA COMMITTEE IS TO BE TREATED AS UNDISCLOSED INCOME OF THE ASSESSEE OR A SSESSEES WIFE WAS NOT THE SUBJECT MATTER OF THE APPEAL IN THOSE CASES. IN THE CASE UNDER CONSIDERATION, IT IS THE CONTENTION OF THE DEPA RTMENT THAT THE ASSESSEE WRONGLY TREATED THE REMUNERATION RECEIVED FROM CHAITANYA EDUCATIONAL COMMITTEE IN THE HANDS OF HIS SPOUSE AND B UT FOR THE SEARCH; THIS FACT WOULD NOT HAVE COME TO THE KNOWLEDGE OF THE DEPARTMENT THAT THE LECTURES WERE DELIVERED BY THE A SSESSEE AND THE REMUNERATION WAS RECEIVED IN THE NAME OF THE WIFE. HENCE, THE SAID ALLEGED REMUNERATION NEEDS TO BE TREATED AS UNDISCLO SED INCOME OF THE ASSESSEE. WE FIND MERIT IN THE CONCLUSIONS REACHED BY TH E LOWER AUTHORITIES THAT THE REMUNERATION RECEIVED FROM SRI CHAITANYA EDUCATIONAL COMMITTEE WAS INCOME OF THE ASSESSEE AS HE W AS QUALIFIED TO BE A LECTURER IN THE INSTITUTION WHICH IS SUPPORTED BY THE IDENTITY CARD ISSUED BY THE INSTITUTION TO THE ASSESSEE AND OTHER RELEV ANT FACTS BROUGHT ON RECORD BY THE DEPARTMENT. IN OUR OPINION, THE REMUNERATION 7 IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . RECEIVED BY THE ASSESSEE WAS NOT DISCLOSED TO THE DEPARTME NT EITHER BEFORE THE SEARCH OR AFTER THE SEARCH. AFTER CONSIDERIN G THE TOTALITY OF FACTS AND THE CIRCUMSTANCES OF THE CASE, WE ARE OF THE O PINION THAT THE CIT (A) IS PERFECTLY JUSTIFIED IN TREATING THE ALLEGE D REMUNERATION RECEIVED BY THE ASSESSEES WIFE WHICH WAS TREATED AS UN DISCLOSED INCOME IN THE HANDS OF THE ASSESSEE FOR ALL FINANCIAL YE ARS UNDER CONSIDERATION. HENCE NO INTERFERENCE IS CALLED FOR ON T HIS ISSUE AND ACCORDINGLY WE CONFIRM THE ORDER OF THE CIT (A) AND RE JECT THE GROUND RAISED BY THE ASSESSEE. 6. GROUND NO.7 RELATES TO THE ADDITION OF RS.2,86,200 /- ON ACCOUNT OF ON-MONEY PAID FOR PURCHASE OF PLOT AT GREE N HILLS COLONY, HYDERABAD. WE FIND THAT IN THE WRITTEN SUBMISSIONS FI LED BEFORE THE CIT (A), WHEREIN IT WAS SUBMITTED THAT THE PROPERTY WAS PURCHASED BY THE ASSESSEES WIFE SMT. C. LAKSHMI AND THE TOTAL CONSIDERATI ON WAS RS.2,38,500/- PAID TO SRI D. VEERESH AND RS.2,00,000/- PAID TO MR. RAMESH. MR. RAMESH ENTERED INTO AN AGREEMENT WITH TH E OWNER FOR PURCHASE OF THE PROPERTY AT RS.5,24,700/- AND THE SALE COULD NOT GO THROUGH AS MR. RAMESH WAS NOT INTERESTED TO PURCHASE TH E PROPERTY. THE ASSESSEES WIFE AGREED TO PAY RS.2,38,500/- TO THE VENDOR AND SETTLE THE CLAIM OF MR. RAMESH BY PAYING A SUM OF RS.2 ,00,000/-. THE CIT (A) HELD THAT THE ASSESSEES WIFE SMT. C. LAKSHMI D OES NOT HAVE INDEPENDENT SOURCE OF INCOME AND THE MONEY HAS BEEN PAID BY THE ASSESSEE FROM HIS OWN UNDISCLOSED SOURCES. NO EVIDENCE HAS BEEN PRODUCED TO SHOW THAT HIS WIFE PAID CASH OF RS.2,00,000 TO MR. RAMESH TO SETTLE THE CLAIM. THE AGREEMENT OF SALE CLEARLY SHO WED THAT THE PLOT WAS INTENDED TO BE PURCHASED FOR RS.5,24,700/- OUT OF WHICH RS.2,38,500/- WAS PAID AS PER THE AGREEMENT AND THE BALANCE OF 8 IT(SS) A NO.76/HYD /05 CHINTA SATYANARAYANA, HYD . RS.2,86,200/- WAS PAID FROM UNDISCLOSED SOURCES AND THE REFORE THE ASSESSING OFFICER TREATED THE SUM OF RS.2,86,200 AS UNEXP LAINED INVESTMENT IN THE HANDS OF THE ASSESSEE. AFTER CONSIDERIN G THE FACTS AND THE CIRCUMSTANCES OF THE CASE AND IN THE ABSENCE OF ANY D OCUMENTARY EVIDENCE BROUGHT ON RECORD BY THE ASSESSEE, THE AUTHORIT IES ARE PERFECTLY JUSTIFIED IN TREATING THE SUM OF RS.2,86,200/ - AS UNEXPLAINED INVESTMENT IN THE HANDS OF THE ASSESSEE AND THE ORDERS OF THE AUTHORITIES BELOW ARE UPHELD ON THIS ISSUE AND ACCORD INGLY THE GROUND RAISED BY THE ASSESSEE IS REJECTED. 7. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DISMISSED . ORDER PRONOUNCED IN THE COURT ON 21-01-2011. SD/- SD/- (G.C. GUPTA) (AKBER BASHA) VICE PRESIDENT. ACCOUNTANT MEMBER. DT/- 21-01-2011. COPY FORWARDED TO: 1. SRI S. RAMA RAO, ADVOCATE, 103, INDIRADEVI NILAYAM , STREET NO.7, HIMAYATNAGAR, HYDERABAD. 2. 3. 4.. 5. JMR* ACIT, CENTRAL CIRCLE-5, HYDERABAD. CIT (A)-I,, HYDERABAD. CIT, AP. HYDERABAD. THE DR, ITAT, HYDERABAD. 9