M. Navaneetha, Hyderabad V. DCIT, Central Circle-2, Hyderabad

MA 211/HYD/2012

• Counselvise Citation: [2013] 123 COUNSELVISE.COM (IT) 9833 (ITAT-HYDERABAD)
• Duration Of Justice: 3 month(s) 3 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 11-01-2013
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: misc
• Appeal Filed On: 08-10-2012
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: M H NAIK
• Assessee Lawyers: D RANGA RAO
• Keywords: Difference of opinion; Change of opinion

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A', HYDERABAD BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIA L MEMBER M.A. NO. IN ITA/CO NO. ASSESS MENT YEAR APPLICANT RESPONDENT 203/HYD/2012 1099/HYD/2010 76/HYD/2010 2007-08 SMT. M.POCHAMMA, JEEDIMETLA VILLAGE R.R. DISTRICT (PAN BCGPM 2668 K) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 204/HYD/2012 1100/HYD/2010 77/HYD/2010 2007-08 SMT. M. KAUSALYA, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN APSPM 3327 D) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 205/HYD/2012 1101/HYD/2010 78/HYD/2010 2007-08 SHRI M.SURENDHAR, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN APSPM 3344 N ) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 206/HYD/2012 1102/HYD/2010 79/HYD/2010 2007-08 SHRI M.B.JANARDHAN, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN BCGPM 2666 H ) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 207/HYD/2012 1103/HYD/2010 80/HYD/2010 2007-08 SMT. M.SARASWATHI, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN BCGPM 2409 A ) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 208/HYD/2012 1104/HYD/2010 81/HYD/2010 2007-08 SHRI M.B.SUDARSHAN JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN ADFPM 7337 D) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 209/HYD/2012 1105/HYD/2010 82/HYD/2010 2007-08 SMT. M.NARSAMMA, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN BCGPM 3080 H ) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 210/HYD/2012 1106/HYD/2010 83/HYD/2010 2007-08 SHRI B.N.CHANDRA MOHAN JEEDIMETLA VILLAGE, R.R. DISTRICT DY. COMMI- SSIONER OF INCOME-TAX M.A. NOS.203 TO 213/HYD/2012 (IN NO.ITA NO.1099 TO 1110/ HYD/2011 & COS THEREIN) SMT. M.POCHAMMA AND ORS, JEEDIMETLA VILLAGE, HYDERABAD 2 (PAN AKOPB 1415 A ) CENTRAL C IRCLE 2, HYDERABAD 211/HYD/2012 1107/HYD/2010 84/HYD/2010 2007-08 SMT. M.NAVANEETHA, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN BCGPM 2665 E ) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 212/HYD/2012 1108/HYD/2010 85/HYD/2010 2007-08 SMT M.SWAROOPA, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN BCGPM 2410 M ) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD 213/HYD/2012 1109/HYD/2010 86/HYD/2010 2007-08 SMT. M.PUSHPAMMA, JEEDIMETLA VILLAGE, R.R. DISTRICT (PAN APSPM 5223 L ) DY. COMMI- SSIONER OF INCOME-TAX CENTRAL CIRCLE 2, HYDERABAD APPLICANTS BY : SHRI D.RANGA RAO RESPONDENT BY : S HRI M.H.NAIK DR DATE OF HEARING 16 . 11 .2012 DATE OF PRONOUNCEMENT 11.1.2013 O R D E R PER SAKTIJIT DEY, JUDICIAL MEMBER: BY THESE APPLICATIONS UNDER S.254(2) OF THE INCOME- TAX ACT, 1961, THE APPLICANT-ASSESSEES HAVE PRAYED FOR RECTI FICATION/RECALL OF THE ORDER OF THIS TRIBUNAL DATED 20.7.2012 ON THE APPEA LS OF THE REVENUE AND THE CROSS-OBJECTIONS OF THE ASSESSEE, BEING ITA NOS .1099 TO 1109/HYD/2010 AND THE CROSS-OBJECTIONS OF THE ASSES SEE THEREIN, BEING C.O. NO. 76 TO 86/HYD/1012, FOR THE ASSESSMENT YEAR 2007-08, ON THE GROUND THAT CERTAIN MISTAKES APPARENT FROM RECORD H AVE CREPT INTO THE SAME. 2. REITERATING THE AVERMENTS MADE IN THE PRESENT A PPLICATION, THE LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSESSEES , SUBMITTED THAT THE M.A. NOS.203 TO 213/HYD/2012 (IN NO.ITA NO.1099 TO 1110/ HYD/2011 & COS THEREIN) SMT. M.POCHAMMA AND ORS, JEEDIMETLA VILLAGE, HYDERABAD 3 OBSERVATION OF THE TRIBUNAL IN PARA 10 OF ITS ORDER THAT THE ASSESSEES HAVE TRANSFERRED 15% OF THE DEVELOPED LAND IS NOT CORREC T BECAUSE NO DEVELOPED LAND HAS BEEN HANDED OVER. SIMILARLY, IN PARA 14 IT HAS BEEN MENTIONED THAT THE AGRICULTURAL LAND HAS BEEN TRANS FERRED TO M/S. FORTUNE CONSTRUCTIONS PVT. LTD. AND IN THIS TRANSACTION, WH ICH CLEARLY SHOWS THAT NO DEVELOPED LAND HAS BEEN RECEIVED. INVITING OUR ATT ENTION TO PARA 15, IT IS SUBMITTED THAT THE TRIBUNAL MENTIONED THAT THE LAND HAS BEEN CHANGED TO RESIDENTIAL AREA ONLY ON 21.09.2005 AND THE REGULAR SALE DEED IS EXECUTED ON 20.4.2006, AND ALTHOUGH THE PERMISSION HAS BEEN GIVEN, THE LAND REMAINED AS AGRICULTURAL LAND AND THERE WAS NO RIGH T ON THE PART OF THE ASSESSEES TO TAKE UP ANY ACTIVITY. THE COMPLEXION OF LAND HAS NOT CHANGED AND ONLY M/S. KONCEPT NIRMAN PVT. LTD. HAS TAKEN THE ACTIVITY. IN THIS TYPE OF SITUATION, HE SUBMITTED THAT THE ASSES SEES COULD NOT HAVE TRANSFERRED THE DEVELOPED PROPERTY AS NOTED BY THE TRIBUNAL. IT IS ALSO MENTIONED THAT THE DECISION OF THE SUPREME COURT IN THE CASE OF SMT. SARIFABIBI MOHD. IBRAHIM V/S. CIT (204 ITR 631) BAS ED ON FACTS, WHICH ARE DISTINCT FROM THE FACTS OF THE PRESENT CASES, AND T HE TRIBUNAL AS SUCH IS NOT JUSTIFIED IN FOLLOWING THE SAID DECISION. SIMILARLY , IT IS SUBMITTED THAT THE FACTS IN THE CASE OF CIT V/S. SMT.SANJEEDA BEGUM( ), RELIED UPON BY THE ASSESSEE ARE SIMILAR TO THE ONES INVOLVED IN THE PR ESENT CASE, AND THE TRIBUNAL HAS NOT EVEN MADE A MENTION OF THIS DECISI ON IN THE IMPUGNED ORDER, WHICH THEREFORE, NEEDS TO BE RECTIFIED/RECAL LED. THE LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSESSEE SUBMITTE D THAT THE TRIBUNAL SHOULD HAVE FOLLOWED THE DECISION OF ALLAHABAD HIG H COURT IN THE CASE OF CIT V/S. SMT.SANJEEDA BEGUM (2006)154 TAXMAN 346(A LL) INSTEAD OF THE DECISION OF THE HONBLE SUPREME COURT IN THE CASE O F SMT.SARIFABIBI MOHD. IBRAHIM (SUPRA). TO SUM UP, IT IS SUBMITTED THAT T HE ORDER OF THE TRIBUNAL DATED 20.7.2012 WARRANTS RECTIFICATION/RECALL FOR THE FOLLOWING REASONS- (A) THE CONCLUSION THAT THE DEVELOPED PROPERTY HAS BEEN SOLD IS NOT IN ORDER M.A. NOS.203 TO 213/HYD/2012 (IN NO.ITA NO.1099 TO 1110/ HYD/2011 & COS THEREIN) SMT. M.POCHAMMA AND ORS, JEEDIMETLA VILLAGE, HYDERABAD 4 (B) NO DIRECTION AS TO PROPER COMPUTATION OF CAPITAL GA IN HAS BEEN GIVEN. (C) A RETURN FOR THE ASSESSMENT YEAR 2001-02 HAS BEEN F ILED AND BY VIRTUE OF THE PROVISION OF THE ACT, THE ASSESSME NT IS DEEMED TO HAVE BEEN COMPLETED. THERE IS NO MENTION OF THIS ASPECT IN THE ORDER OF ITAT. 8. THE LEARNED DEPARTMENTAL REPRESENTATIVE, ON THE CONTRARY, OPPOSING THE ABOVE CONTENTIONS OF THE ASSESSEE, STR ONGLY SUPPORTING THE ORDER OF THE TRIBUNAL DATED 20.7.2012 SUBMITTED THA T THERE IS NO MISTAKE APPARENT FROM RECORD IN THE ORDER OF THE TRIBUNAL, AND ALL THAT THE ASSESSEE IS SEEKING THROUGH ITS ELABORATE ARGUMENTS, IS ONLY A REVIEW OF THE ORDER OF THE TRIBUNAL DATED 30.7.2012, BY RE-ARGUING ITS CAS E. SINCE SUCH A REVIEW IS NOT POSSIBLE IN THESE PROCEEDINGS UNDER S.254(2) OF THE ACT, IT IS SUBMITTED THAT THE PRESENT APPLICATION OF THE ASSES SEE IS LIABLE TO BE REJECTED. 9. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AND PE RUSED THE ORDER OF THIS TRIBUNAL DATED 20.7.2012, IN THE LIGH T OF THE DETAILED AVERMENTS MADE ON VARIOUS ASPECTS BY THE ASSESSEE I N THE PRESENT APPLICATION. WE FIND THAT THE ASSESSEES BY THE PRE SENT APPLICATIONS ARE MERELY DISPUTING THE FINDINGS OF THE TRIBUNAL IN RE LATION TO THE NATURE OF LAND. THE GRIEVANCE OF THE ASSESSEES IN THE PRESEN T APPLICATIONS IS ALSO ON ACCOUNT OF NON-MENTIONING OF CERTAIN CITATIONS RELI ED UPON AND ALSO CERTAIN CONTENTIONS ADVANCED BY THE LEARNED AUTHORISED REPR ESENTATIVE FOR THE ASSESSEES BEFORE THE TRIBUNAL. A CAREFUL READING OF THE ORDER OF THE TRIBUNAL, CLEARLY REVEALS THAT ALL THE CONTENTIONS OF THE PARTIES BEFORE IT HAVE BEEN DULY CONSIDERED AND FINDINGS HAVE BEEN GI VEN BASED ON THE MATERIAL APPARENT FROM RECORD. WE DO NOT FIND ANY MATERIAL OMISSION OR MISTAKE ON THE PART OF THE TRIBUNAL IN RECORDING TH E CONTENTIONS OF LEARNED AUTHORISED REPRESENTATIVE FOR THE ASSESSEES BEFORE IT. IT IS NEITHER M.A. NOS.203 TO 213/HYD/2012 (IN NO.ITA NO.1099 TO 1110/ HYD/2011 & COS THEREIN) SMT. M.POCHAMMA AND ORS, JEEDIMETLA VILLAGE, HYDERABAD 5 EXPECTED NOR PRACTICABLE TO EXPECT AN APPELLATE AUT HORITY TO RECORD ALL THE CONTENTIONS OF THE PARTIES VERBATIM IN THE ORDER OF THE TRIBUNAL, AND IT WOULD BE SUFFICE AND MEET THE ENDS OF JUSTICE, IF T OTALITY OF THE APPELLATE ORDER REFLECTS THE CONSIDERATION OF ALL THE CONTENT IONS URGED BY THE PARTIES BEFORE IT. BY THE CONTENTIONS URGED IN THE PRESEN T APPLICATIONS, WE FIND THAT THE ASSESSEE-APPLICANTS ARE MERELY DISPUTING T HE FINDINGS OF THE TRIBUNAL AND SEEKING A REVIEW OF THE ORDER OF THE T RIBUNAL, WHICH IS NOT POSSIBLE IN THESE PROCEEDINGS UNDER S.254(2) OF THE ACT. 15. IT IS WORTHWHILE NO NOTE AT THIS STAGE THAT THE PROVISIONS OF S.254(2) OF THE INCOME-TAX ACT, 1961 EMPOWERS THE T RIBUNAL TO RECTIFY A MISTAKE. HOWEVER, THE SCOPE AND AMBIT OF THE AFORE SAID PROVISION IS VERY LIMITED. THE POWER CONFERRED ON THE TRIBUNAL FOR R ECTIFICATION HAS TO BE EXERCISED IN TERMS OF THE PROVISION. THE RECTIFICA TION, AS ENVISAGED IN THE AFORESAID PROVISION, IS CONFINED TO MISTAKES WHICH ARE APPARENT FROM RECORD AND ARE PATENT AND OBVIOUS, AND ARE NOT SUCH WHICH COULD BE ESTABLISHED ONLY BY LONG-DRAWN ARGUMENTS AND DEBATE OR BY A PROCESS OF INVESTIGATION AND RESEARCH. THE SCOPE OF S.254(2) CANNOT BE ENLARGED SO AS TO EMPOWER THE TRIBUNAL TO REVIEW ITS OWN ORDER. IF TWO VIEWS ARE POSSIBLE ON A POINT OF LAW AND ONE OF THE ALTERNATI VES IS ADOPTED IN ITS PREVIOUS ORDER, IT CANNOT BE HELD THAT THERE IS A M ISTAKE APPARENT FROM RECORD ON ACCOUNT OF NON-ADOPTION OF THE OTHER POSS IBLE VIEW. UNLESS THERE ARE MANIFEST ERRORS WHICH ARE OBVIOUS CLEAR A ND SELF-EVIDENT, THE TRIBUNAL CANNOT RECALL ITS PREVIOUS ORDER, IN AN AT TEMPT TO RE-WRITE THE ORDER. THE TRIBUNAL, BEING A CREATURE OF THE STATUT E, HAS TO ACT WITHIN THE LIMITS LAID DOWN BY THE STATUTE. IT HAS NO INHEREN T POWER OF REVIEW. HENCE, SUCH POWER CANNOT BE ASSUMED IN THE GUISE OF RECTIFICATION ENVISAGED UNDER S.254(2) OF THE ACT, FOR RECALLING ITS OWN ORDER AND HEARING IT AFRESH. WE MAY DRAW SUPPORT IN THIS BEH ALF BY THE RATIO LAID DOWN BY THE JURISDICTIONAL HIGH COURT IN THE CASE O F CIT V/S. VED PRAKASH (209 ITR 448)(AP), WHEREIN IT HAS BEEN HELD AS FOLL OWS- M.A. NOS.203 TO 213/HYD/2012 (IN NO.ITA NO.1099 TO 1110/ HYD/2011 & COS THEREIN) SMT. M.POCHAMMA AND ORS, JEEDIMETLA VILLAGE, HYDERABAD 6 'IF TWO VIEWS ARE POSSIBLE ON A POINT OF LAW, AND O NE OF THE ALTERNATIVES IS ACCEPTED BY THE TRIBUNAL, IT CANNOT BE HELD THAT TH E MISTAKE IS APPARENT FROM THE RECORD, UNLESS THERE ARE MANIFEST ERRORS WHICH ARE OBVIOUS, CLEAR AND SELF- EVIDENT, THE TRIBUNAL CANNOT RECALL ITS PREVIOUS OR DER IN AN ATTEMPT TO REWRITE THE ORDER. A CHANGE OF OPINION BY THE TRIBUNAL CONS ISTING OF THE SAME MEMBERS SHALL NOT JUSTIFY RECTIFICATION, NOR CAN FRESH THIN KING BROUGHT IN BY NEW MEMBERS OF THE TRIBUNAL JUSTIFY REWRITING OF THE ORDER UNDE R THE GUISE OF RECTIFICATION. THE ONLY FACT THAT HAD THE SECOND SET OF MEMBERS HEARD THE APPEAL, THEY WOULD HAVE DECIDED IN FAVOUR OF THE ASSESSEE IS NOT A REASON F OR THEM TO RECALL AN ORDER ALLEGEDLY FOR THE PURPOSE OF RECTIFICATION OF A MIS TAKE. SIMILARLY, IN THE CASE OF CIT VS. ITAT & ANR. 206 I TR 126 THE ANDHRA PRADESH HIGH COURT HELD AS UNDER: 'THE APPELLATE TRIBUNAL, BEING A CREATURE OF THE ST ATUTE, HAS TO CONFINE ITSELF IN THE EXERCISE OF ITS JURISDICTION TO THE E NABLING OR EMPOWERING TERMS OF THE STATUTE. IT HAS NO INHERENT POWER. EVE N OTHERWISE, IN CASES WHERE SPECIFIC PROVISION DELINEATES THE POWERS OF T HE COURT OR TRIBUNAL, IT CANNOT DRAW UPON ITS ASSUMED INHERENT JURISDICTION AND PASS ORDERS AS IT PLEASES. THE POWER OF RECTIFICATION WHICH IS SPECIF ICALLY CONFERRED ON THE TRIBUNAL HAS TO BE EXERCISED IN TERMS OF THAT PROVI SION. IT CANNOT BE ENLARGED ON ANY ASSUMPTION THAT THE TRIBUNAL HAS GO T AN INHERENT POWER OF RECTIFICATION OR REVIEW OR REVISION. IT IS AXIOM ATIC THAT SUCH POWER OF REVIEW OR REVISION HAS TO BE SPECIFICALLY CONFERRED ; IT CANNOT BE INFERRED. UNLESS THERE IS A MISTAKE APPARENT FROM THE RECORD IN THE SENSE OF PATENT, OBVIOUS AND CLEAR ERROR OR MISTAKE, THE TRIBUNAL CA NNOT RECALL ITS PREVIOUS ORDER. IF THE ERROR OR MISTAKE IS ONE WHICH COULD B E ESTABLISHED ONLY BY LONG-DRAWN ARGUMENTS OR BY A PROCESS OF INVESTIGATI ON AND RESEARCH, IT IS NOT A MISTAKE APPARENT FROM THE RECORD. IF TWO VIEW S ARE POSSIBLE ON A POINT OF LAW, AND ONE OF THE ALTERNATIVES IS ACCEPT ED IN ITS PREVIOUS ORDER, IT CANNOT BE HELD THAT THE MISTAKE IS APPARENT FROM THE RECORD. UNLESS THERE ARE MANIFEST ERRORS WHICH ARE OBVIOUS, CLEAR AND SELF- EVIDENT, THE TRIBUNAL CANNOT RECALL ITS PREVIOUS ORDER IN AN ATT EMPT TO REWRITE THE ORDER.' AT THE COST OF REPETITION, WE WOULD LIKE TO REITERA TE THAT ON GOING THROUGH THE ORDER PASSED BY THE TRIBUNAL, WE ARE CONVINCED THAT THE TRIBUNAL PASSED THE ORDER, AFTER MARSHALLING ALL THE FACTS CONSIDERING THE SUBMISSIONS MADE BEFORE IT AND APPLYING ITS MIND TO THE DECISIONS CITED BEFORE IT. WE DO NOT FIND ANY MISTAKE IN THE ORDER OF THE TRIBUNAL OF THE NATURE AS ENVISAGED UNDER S.254(2) OF THE ACT. PERMITTING THE ASSESSEE TO RAISE THE S AME ISSUES OVER AGAIN IN THE GUISE OF RECTIFICATION WILL AMOUNT TO RECALLING THE APPEAL ORDER IN ITS ENTIRETY AND RE-HEARING IT AFRESH, WHICH IS NOT WITHIN THE SCOPE AND AMBIT OF S.254(2) OF THE ACT. THE CONTENTION OF THE LEARNED AUTHORISED REP RESENTATIVE FOR THE ASSESSEES THAT THE DECISION OF THE ALLAHABAD HIGH COURT IN TH E CASE OF SMT. SANJEEDA M.A. NOS.203 TO 213/HYD/2012 (IN NO.ITA NO.1099 TO 1110/ HYD/2011 & COS THEREIN) SMT. M.POCHAMMA AND ORS, JEEDIMETLA VILLAGE, HYDERABAD 7 BEGUM (SUPRA) SHOULD HAVE BEEN FOLLOWED INSTEAD OF FOLLOWING THE DECISION OF THE HONBLE SUPREME COURT IN THE CASE OF SMT. SARIF ABIBI MOHD. IBRAHIM (SUPRA) CLEARLY SHOWS THAT THE ASSESSEES THROUGH THESE APPL ICATIONS ARE MERELY DISPUTING THE COURSE ADOPTED AND THE CONCLUSIONS ARRIVED AT B Y THE TRIBUNAL, WHICH IS NOT A MISTAKE APPARENT FROM RECORD. 16. IN THE LIGHT OF THE FOREGOING DISCUSSION, WE F IND NO MERIT IN THE PRESENT APPLICATION OF THE ASSESSEE, WHICH IS ACCOR DINGLY REJECTED. 17. IN THE RESULT, ALL THESE MISCELLANEOUS APPLICA TIONS OF THE ASSESSEES ARE REJECTED. ORDER PRONOUNCED IN THE COURT ON 11.1.2013 SD/- SD/- (CHANDRA POOJARI) (SAKTIJIT DEY) ACCOUNTANT MEMBER JUDICIAL MEMBER DATED/- 11 TH JANUARY, 2013 COPY FORWARDED TO: (1) SMT. M.POCHAMMA, D.NO.10-3, MEENAKSHI ESTATES, JEED IMETLA VILLAGE, R.R. DISTRICT (2) SMT. M. KAUSALYA, D.NO.10-3, MEENAKSHI ESTATES, JEE DIMETLA VILLAGE, R.R. DISTRICT (3) SHRI M.SURENDHAR, D.NO.10-3, MEENAKSHI ESTATES, JEE DIMETLA VILLAGE, R.R. DISTRICT (4) SHRI M.B.JANARDHAN, D.NO.10-3, MEENAKSHI ESTATES,J EEDIMETLA VILLAGE, R.R. DISTRICT (5) SMT. M.SARASWATHI, D.NO.10-3, MEENAKSHI ESTATES, J EEDIMETLA VILLAGE, R.R. DISTRICT (6) SHRI M.B.SUDARSHAN, D.NO.10-3, MEENAKSHI ESTATES, JEEDIMETLA VILLAGE, R.R. DISTRICT (7) SMT. M.NARSAMMA, D.NO.10-3, MEENAKSHI ESTATES, JEE DIMETLA VILLAGE, R.R. DISTRICT M.A. NOS.203 TO 213/HYD/2012 (IN NO.ITA NO.1099 TO 1110/ HYD/2011 & COS THEREIN) SMT. M.POCHAMMA AND ORS, JEEDIMETLA VILLAGE, HYDERABAD 8 (8) SHRI B.N.CHANDRA MOHAN, D.NO.10-3, MEENAKSHI ESTATE S, JEEDIMETLA VILLAGE, R.R. DISTRICT (9) SMT. M.NAVANEETHA, D.NO.10-3, MEENAKSHI ESTATES, J EEDIMETLA VILLAGE, R.R. DISTRICT (10 SMT M.SWAROOPA, D.NO.10-3, MEENAKSHI ESTATES, JEED IMETLA VILLAGE, R.R. DISTRICT (11) SMT. M.PUSHPAMMA, D.NO.10-3, MEENAKSHI ESTATES, JE EDIMETLA VILLAGE, R.R. DISTRICT (12) DY. COMMISSIONER OF INCOME - TAX, CENTRAL CIRCLE 2, HYDERABAD (13) COMMISSIONER OF INCOME - TAX (CENTRAL ), HYDERABAD (14) COMMISSIONER OF INCOME - TAX(APPEALS) I, HYDERA BAD (15) DEPARTMENTAL R EPRESENTATIVE, ITAT, HYDERABAD B.V.S