ITO (TDS) TDS, Ward-I, Tirupathi, Tirupathi V. Southern Power Distribution Co. of A.P. Ltd., Tirupathi, Tirupathi

MA 29/HYD/2016

• Counselvise Citation: [2016] 112 COUNSELVISE.COM (IT) 5117 (ITAT-HYDERABAD)
• Duration Of Justice: 6 month(s) 25 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 28-09-2016
• Appeal Filed By: Department
• Bench Allotted: DB-B
• Next Hearing Date: 16-09-2016
• Assessment Year: 2008-2009
• Appeal Filed On: 04-03-2016
• Court: TRIBUNAL
• Department Lawyers: K J RAO
• Assessee Lawyers: M CHANDRAMOULESWARA RAO
• Keywords: Competent authority; TDS
• Section: 133A; 194C; 201(1)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES A, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER M.A. NOS. 29 & 30/HYD/2016 (ARISING OUT OF ITA NOS. 1327 & 1328/HYD/2014) ASSESSMENT YEARS: 2008-09 & 2009-10 INCOME TAX OFFICER (TDS), TDS WARD-1, TIRUPATI VS M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., TIRUPATI [TAN: HYDS08188F] (APPLICANT) (RESPONDENT) FOR REVENUE : SHRI K.J. RAO, DR FOR ASSESSEE : SHRI M. CHANDRAMOULESWARA RAO, AR DATE OF HEARING : 16-09-2016 DATE OF PRONOUNCEMENT : 28-09-2016 O R D E R PER B. RAMAKOTAIAH, A.M. : THESE TWO ARE MISCELLANEOUS APPLICATIONS PREFERRED B Y THE REVENUE AGAINST THE ORDERS OF THE ITAT IN ITA NOS. 132 7 & 1328/HYD/2014 AND C.O. NOS. 49 & 50/HYD/2014 DT. 31-07-2015. REVENUE HAS PREFERRED THE PRESENT MISCELLANEOUS APPLICATIONS ON THE FOLLOWING GROUNDS: 1. THE HON'BLE TRIBUNAL HAS ERRED IN ITS ORDER BY REFERRING CERTIFICATE U/S. 197 DT. 05.11.2009 ISSUED FOR THE ASST. YEAR 2 010-11 AS APPLICABLE FOR THE IMPUGNED ASST. YEAR 2008-09. TH US, ORDER OF THE M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 2 -: HON'BLE ITAT IN ITA NOS. 1327 & 1328/HYD/2014 DT. 3 1.07.2015 NEEDS TO BE REVIEWED. 2. THE REVENUE HAS PREFERRED APPEAL BEFORE HON'BLE TRIBUNAL AGAINST THE ORDER OF THE LD. CIT(A), VIJAYAWADA ON THE ISSU E WHETHER THE TRANSMISSION CHARGES PAID BY ASSESSEE DEDUCTOR WAS COVERED BY THE PROVISIONS U/S. 194-J/194-I AS OPINED BY THE AO OR 194-C AS OPINED BY THE LD. CIT(A) SINCE, IT HAS FAILED TO DE DUCT/SHORT DEDUCT TAX AT SOURCE ON THE TRANSMISSION & SLDC CHARGES FO R THE YEARS UNDER CONSIDERATION. BUT, THE HON'BLE TRIBUNAL HAS NOT GIVEN ANY FINDING ON THE GROUNDS OF THE DEPARTMENT THAT WHETH ER THE NATURE OF PAYMENT IS COVERED UNDER THE TDS PROVISIONS OF THE SECTION 194J/194-I AS HELD BY THE ASSESSING OFFICER OR 194C AS OPINED BY THE CIT(A). 3. SINCE, THE HON'BLE ITAT IN ITA NOS. 1327 & 1328/ HYD/2014 DT. 31.07.2015 HAS NOT GIVEN ANY FINDING AND THE MAIN G ROUND RAISED BY THE DEPARTMENT NEEDS TO BE REVIEWED IN VIEW OF T HE ABOVE STATED FACTS. 4. ANY OTHER GROUND THAT MAY BE URGED AT THE TIME O F HEARING. 5. IN VIEW OF THE FOREGOING, IT IS SUBMITTED THAT, THE HON'BLE ITAT MAY KINDLY CONSIDER THE ABOVE SUBMISSIONS AND PASS APPROPRIATE ORDERS AS DEEMED FIT. 2. BEFORE ADVERTING TO THE DECISION ON THE CONTENTIONS RAISED BY THE REVENUE, IT IS NECESSARY TO STATE CERTAIN FACTS. ASSESSEE IS A POWER DISTRIBUTION COMPANY AND A SURVEY U/S. 133A OF THE INCOME TAX ACT [ACT] WAS CONDUCTED BY THE DCIT, TDS-3(1), VIJAYAWADA IN THE PREMISES ON 29-09-2008. ON NOTICI NG THAT TAX WAS NOT DEDUCTED AT SOURCE ON CERTAIN PAYMENTS MADE TOWAR DS LEGAL CHARGES, TECHNICAL FEES, RENTS AND TRANSMISSION CHARGES, PROCEEDINGS U/S. 201(1) AND 201(1A) WERE INITIATED BY THE DCIT, TDS-3(1), VIJAYAWADA. HE HAS PASSED ORDERS (WHICH ARE NOT IN THE IMPUGNED APPEALS) AND ON FURTHER APPEAL, THE CIT(A), TIRUPATI VIDE APPEAL NOS. 517/DCIT/CIR-3(1)/TDS/VJY CIT(A)/TPT/ 9-10 DT. 25-06-2010 HAS HELD THAT THE SERVICES RENDERED BY AP TRANSCO FOR TRANSMISSION OF POWER THROUGH THEIR LINES COULD ONLY BE IN THE M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 3 -: CATEGORY OF RENTALS BUT NOT WORK CONTRACT OR ROYALTY. HOWEVER, HE WAS ON THE OPINION THAT WHETHER THE SAME WOULD COME WITHI N THE MISCHIEF OF 194J OR 194I WOULD ONLY BE ACADEMIC AS AMOUNT OF DEDUCTION OF TAX ON THE PAYMENTS BEING MADE UNDER THESE PROVISIONS WAS SAME AT 10%. AFTER HOLDING AS SUCH, LD.CIT(A) IN THE ORDER HOWEVER, NOTICED THAT ASSESSEE-COMPANY HAS BE EN ISSUED A CERTIFICATE BY A COMPETENT AUTHORITY TO DEDUCT TAX AT 1 .75% OF THE PAYMENTS BEING MADE. ACCORDINGLY, AFTER DISCUSSING THE PROVISIONS U/S. 197, LD.CIT(A) HELD THAT ASSESSEE CANNOT BE HELD AS ASSESSEE- IN-DEFAULT, IF THE DEDUCTION AT 1.75% WOULD BE ADEQUATE TO MEET THE LIABILITY. ACCORDINGLY, FOR AYS. 2008-09, 2009- 10 & 2010-11 UPTO AUGUST, 2009, LD.CIT(A) ALLOWED THE APPEALS PARTL Y. AS FAR AS THE AMOUNT OF TAX U/S. 201(1), HE HAS NOTICED THAT AO HI MSELF HAS TAKEN COGNIZANCE OF THE RATIO IN THE CASE OF HINDUSTAN COCA-COLA BEVERAGES PVT. LTD., VS. CIT [293 ITR 226] (SC). (WRO NGLY MENTIONED AS [295 ITR 226]) 3. AFTER THIS ORDER WAS PASSED BY THE LD.CIT(A), AO P ASSED AN ORDER RAISING DEMAND U/S. 201(1A) DT. 30-03-2012, WHICH HAS GIVEN RISE TO IMPUGNED PROCEEDINGS. IN SPITE OF CLEA R DIRECTIONS OF THE CIT(A) THAT TAX DEDUCTION AT 1.75% WOULD SATISFY THE LIABILITY, AO HOWEVER, CONSIDERED THAT CIT(A) HAS UPHELD DEDUCTIO N U/S. 194I AND CALCULATED THE SHORTFALL IN DEDUCTION AND DEL AY IN PAYMENT AT 11.3% AND LEVIED INTEREST U/S. 201(1A). 4. ON AN APPEAL BY ASSESSEE, RELYING ON THE ORDER O F THE ITAT IN CENTRAL POWER DISTRIBUTION COMPANY, HYDERABAD , LD.CIT(A) VIDE ORDERS DT. 28-03-2014 HAS HELD AS UNDER: M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 4 -: '5.1 I HAVE CONSIDERED THE FACTS OF THE CASE, THE O RDER OF THE ASSESSING OFFICER AS WELL AS THE SUBMISSIONS OF THE APPELLANT . I FIND THAT THE ASSESSING OFFICER PASSED ORDER U/S. 201(1A) OF THE ACT TOWARDS INTEREST ON TDS DUES WHICH WERE COMPUTED BY HIM AT 11.33% AS PRINCIPLE TDS AMOUNT. I FIND THAT IN THE CASE OF THE APPELLANT, THE COMMISSIONER OF INCOME-TAX (APPEALS), TIRUPATHI VIDE HIS ORDER NO. 517/DCIT. CIR- 3(1)/TDS/VJY/CIT(A)/TPT/09-10 DATED 25.06.2010 HAS DELETED THE ENTIRE DEMAND BY HOLDING THAT TRANSMISSION CHARGES PAID TO M/S. APTRANSCO FOR TRANSMISSION OF POWER THROUGH THEIR L INES WOULD ONLY BE IN THE CATEGORY OF RENTALS BUT NOT WORK CONTRACT NO R ROYALTY. THE CIT(A) ALSO LAID EMPHASIS ON THE CERTIFICATE U/S. 197 OF T HE ACT, ISSUED BY VALID AUTHORITY TO THE APPELLANT FOR DEDUCTION OF TAX AT A LOWER RATE I.E, 1.75%. THE ASSESSING OFFICER IGNORED ALL THE ABOVE FACTS A ND COMPUTED INTEREST U/S. 201(1A) ON THE AMOUNT OF TDS COMPUTED AT 11.33 % INSTEAD OF 2% U/S. 194C AND IN THE CASE OF THE APPELLANT @ 1.75% SINCE THE APPELLANT BEARING A CERTIFICATE FOR LOWER DEDUCTION OF TAX U/ S. 197 OF THE ACT. IN THIS REGARD, I RELY UPON THE DECISION OF THE HON'BLE ITA T, HYDERABAD BENCH-A IN THE CASE OF M/S. CENTRAL POWER DISTRIBUTION COMP ANY OF AP LIMITED WHEREIN IT WAS HELD THAT TRANSMISSION CHARGES PAID TO M/S. APTRANSCO ARE AKIN TO TRANSPORTATION OF ELECTRICITY AND TDS I S TO BE MADE U/S. 194C AT @2%. ACCORDINGLY, I HOLD THAT THE ORDER IN QUES TION PASSED BY THE ASSESSING OFFICER IS BAD IN LAW AND HENCE CANCELLED '. 4.1. HOWEVER, IN THE APPEAL PREFERRED BY THE REVEN UE, REVENUE HAS RAISED GROUNDS ON THE MERITS OF DEDUCTION U/S. 194C OR U/S. 194J WHICH WAS NOT A SUBJECT MATTER OF THE PROCE EDINGS. IN FACT LD CIT(A) IN AN EARLIER PROCEEDING HAS ALREA DY GAVE IN FAVOUR OF REVENUE THAT 194C DOES NOT APPLY. REVENUE SHOULD NO T HAVE ANY GRIEVANCE ON THAT. WHY THE GROUNDS WERE RAISED ARE BEST KNOWN TO AO/CIT. CONSEQUENTLY, ITAT HAS DECIDED THE APPEALS AS UNDER: 3. AFTER CONSIDERING THE RIVAL CONTENTIONS AND THE ORDERS PLACED ON RECORD BY THE LD. COUNSEL, WE ARE OF THE OPINION THAT BOTH AO AND CIT(A) ARE NOT CORRECT IN CONSIDERING THE ISSUES. FIRST OF ALL TH E GROUNDS RAISED BY REVENUE ARE MAINLY ON MERITS OF DEDUCTION U/S. 194J OR 194-I, EVEN THOUGH MATTERS WERE CRYSTALLISED AND THOSE PROVISIO NS ARE NOT APPLICABLE TO THE FACTS OF ASSESSEE'S CASE. THERE WAS IN FACT AN ORDER OF LD.CIT(A) DIRECTING ACCEPT TO THE EXTENT OF 1.75% RATE OF TDS , AS ASSESSEE HAS OBTAINED A CERTIFICATE FOR LESSER DEDUCTION U/S 197 OF THE ACT. HAVING ISSUED CERTIFICATE TO ASSESSEE, ALLOWING IT TO DEDU CT TAX @ 1.75%, WE ARE M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 5 -: UNABLE TO UNDERSTAND HOW AO CAN DEMAND TAX DEDUCTIO N AT SOURCE @ 10% PLUS SURCHARGE. TO THAT EXTENT GROUNDS ARE INFRUCT UOUS. BE THAT AS IT MAY, WE ARE ALSO NOT IN A POSITION TO APPROVE THE CANCEL LATION OF ENTIRE INTEREST LEVIED BY THE LD.CIT(A). AO HAS TO EXAMINE WHETHER THERE IS ANY DEFAULT IN DEDUCTING TAX @ 1.75% BY ASSESSEE AND IN CASE TH ERE IS ANY DEFAULT OR DELAY IN REMITTING THE TAX INTEREST U/S. 201(1A), C ERTAINLY INTEREST U/S 201(1A) IS ATTRACTED. IN VIEW OF THIS, MODIFYING T HE ORDER OF CIT(A) PARTIALLY, WE DIRECT THE AO TO EXAMINE THE FACTS AG AIN AND IN CASE THERE IS NO DEDUCTION OR DELAY IN REMITTING THE AMOUNTS AS P ER THE PROVISIONS OF THE ACT, INTEREST U/S. 201(1A) CAN BE CHARGED FOR THE I MPUGNED YEARS. AO IS HOWEVER, DIRECTED THAT TAX DEDUCTIBLE SHOULD BE ARR IVED AT 1.75% AS PER THE DIRECTIONS OF CIT(A), CONSEQUENT TO THE CERTIFI CATE OF LOWER DEDUCTION GRANTED BY THE AO. IN VIEW OF THIS, ORDER OF CIT(A ) TO THE EXTENT OF DELETING ENTIRE INTEREST STANDS MODIFIED. AO IS DIRECTED TO RE-WORKOUT THE INTEREST IF ANY, AFTER GIVING DUE OPPORTUNITY TO ASSESSEE. REV ENUE'S APPEALS ARE PARTLY ALLOWED. 5. IN THIS BACKGROUND, THE PRESENT MISCELLANEOUS APPLICATIONS WERE PREFERRED BY THE AO. IN FACT, AO O RIGINALLY PREFERRED THE MISCELLANEOUS APPLICATIONS IN ONE APPL ICATION VIDE APPLICATION DT. 04-03-2016, EVEN THOUGH THERE ARE TWO APPEALS. CONSEQUENTLY, DEFECT NOTICE WAS ISSUED VIDE THIS OFFIC E LETTER DT. 09- 03-2016. LATER AGAIN, ONE MORE COPY WAS RECEIVED ON 15-04-2016, AGAIN ANOTHER LETTER WAS ISSUED TO ITO, WARD-I, TIRUP ATI, REQUESTING TO SUBMIT TWO MORE ORIGINAL COPIES OF MISCELLANEOUS A PPLICATIONS TO BE FILED FOR EACH ASSESSMENT YEAR SEPARATELY VIDE LE TTER DT. 20-04- 2016. THEREAFTER, TWO SEPARATE MISCELLANEOUS APPLIC ATIONS FOR EACH ASSESSMENT YEAR WAS FILED ON 20-05-2016, BUT STILL WIT H DEFECTS, WITHOUT ENCLOSING THE APPROVAL OF LD.CIT. LATER ON, THE DEFECTS WERE RECTIFIED AND THE APPEALS WERE TAKEN ON RECORD. 6. IN THE COURSE OF PRESENT PROCEEDINGS, LD. DR SUBM ITTED THAT CERTIFICATE ISSUED ON 05-11-2009 WOULD APPLY FOR AY. 2010-11, WHEREAS THE SAME IS NOT APPLICABLE FOR THE IMPUGNED ASSESSMENT YEARS, THEREFORE, THE FINDINGS OF THE ITAT NEEDS TO BE REVIEWED. M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 6 -: 7. WHEN QUESTIONED WHETHER THE DATE OF CERTIFICATE U/S. 197 WAS DISCUSSED IN ANY OF THE ORDERS IN THE IMPUGN ED APPEALS, LD. DR FAIRLY ADMITTED THAT THE DATE OF CERTIFICATE WAS NO WHERE MENTIONED EXCEPT IN THE PETITION. IT WAS FURTHER SUBMITTED THAT THE ORDER OF CIT(A) DT. 25-06-2010 WAS SEPARATELY APPEAL ED AND HON'BLE HIGH COURT IS SEIZED OF THE MATTER, AS THE APPEA LS PREFERRED BY REVENUE WERE ADMITTED. WHEN IT WAS SPECIFICALLY A SKED WHETHER THERE WAS ANY MISTAKE IN THE ORDER OF THE ITAT, HE SUBM ITTED THAT THE ISSUE WHETHER TDS IS TO BE DEDUCTED U/S. 194C OR 194I REQUIRES TO BE ADJUDICATED. 8. AFTER CONSIDERING THE RIVAL CONTENTIONS, WE ARE OF THE OPINION THAT MISCELLANEOUS APPLICATIONS RAISED BY REV ENUE ARE MISCONCEIVED. THE ONLY ISSUE WHICH WAS SUBJECT MATTER OF APPEAL IN THE ORDER OF THE CIT(A) WAS LEVY OF INTEREST U/S. 20 1(1A) AND NOT WHETHER TDS WAS TO BE DEDUCTED U/S. 194C OR 194I. THA T ISSUE WAS CONCLUDED BY THE ORDER OF THE LD.CIT(A), TIRUPATI DT. 25-06- 2010, WHICH WAS THE SUBJECT MATTER OF APPEALS SEPARAT ELY. EVEN THOUGH THE COPIES OF THOSE ORDERS AND THE ORDER OF THE ITAT ON THAT ISSUE WAS NOWHERE REFERRED TO EITHER IN THE ORDERS OR IN THE SUBMISSIONS BEFORE US, THE DR SUBMITS THAT THE MATTERS AR E PENDING BEFORE THE HIGH COURT ON THAT ISSUE. WE WERE NOT INFORMED ABOUT THESE PENDING MATTERS, BUT THE FACT IS THAT W HETHER THE ISSUE OF TDS HAS TO BE DONE U/S. 194C OR 194I IS NOT THE SUBJECT MATTER OF THE APPEAL IN THE PRESENT PROCEEDIN GS. 8.1. WHAT IS THE SUBJECT MATTER OF APPEAL BEFORE US I N APPEALS IS LEVY OF INTEREST U/S. 201(1A). IN SPITE OF LD.CIT(A) ORDER DT. 25-06-2010 WHERE IN IT WAS CLEARLY HELD THAT CERTIFI CATE ISSUED M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 7 -: BY THE COMPETENT AUTHORITY IS VALID AS THE COMPANYS P AST RECORD WOULD HAVE BEEN CONSIDERED IN ARRIVING AT A DECISION TO ISSUE A LOWER DEDUCTION U/S. 197 AND CLEARLY DIRECTED THAT IN THIS BACKGROUND, THE APPELLANT CANNOT BE HELD AS ASSESSE E-IN-DEFAULT IF THE DEDUCTION AT 1.75% WOULD BE ADEQUATE TO MEET TH E LIABILITY. IN SPITE OF CLEAR DIRECTIONS OF CIT(A) TO CONSIDER TAX DE DUCTION AT 1.75%, LD.AO VIOLATED THE SAME AND CALCULATED THE TAX D EDUCTIBLE TAKING 11.33% AS THE BASIS AND RAISED HEFTY DEMANDS. LD.CIT(A) ON NOTICING THAT THERE IS ALREADY A DIRECTION TO CONSID ER ONLY LOWER RATE OF 1.75% HOWEVER, CANCELLED THE ENTIRE ORDER. THIS FORUM CONSIDERING THAT THERE WAS ALREADY SEPARATE ORDERS FOR FIXING THE RATE AT 1.75% HOWEVER, MODIFIED THE ORDERS OF CIT(A) AND AO IS DIRECTED TO RE-WORKOUT THE INTEREST IF ANY, AFTER GIVIN G DUE OPPORTUNITY TO ASSESSEE. IN THE ORDER ITSELF IT WAS CL EARLY STATED THAT THE GROUNDS RAISED BY REVENUE ARE MISCONCEIVED; THEREFORE THE PRESENT APPLICATIONS CONTESTING THAT THERE IS NO ADJUDIC ATION ON THE ISSUE ARE MISCONCEIVED AND MISDIRECTED. 9. AS SEEN FROM THE APPLICATIONS AND APPROVAL GIVEN BY THE CIT, WE ARE OF THE OPINION THAT THERE IS NO APPLICATION OF MIND EITHER BY THE AO OR BY THE LD.CIT. THIS SORT OF MISCON CEIVED APPLICATIONS WILL ONLY INCREASE THE WORK LOAD ON THE TRIBUNAL. AS CAN BE SEEN, EVEN THE MISCELLANEOUS APPLICATIONS WER E NOT PROPERLY FILED AND THIS OFFICE HAS TO RESORT CORRESPONDENCE WIT H AO TO MAKE HIM FILE PROPER APPLICATIONS. KEEPING THESE FACTORS IN MIND, WE ARE CONSTRAINED TO LEVY A COST OF RS. 100/- TOKENLY ON THE AO AND ANOTHER RS. 100/- ON CIT FOR PERSUING THE APPEALS B Y WAY OF MISCELLANEOUS APPLICATIONS EVEN THOUGH THE ISSUE DOES NOT ARISE AT ALL AND THERE IS NO ERROR OR MISTAKE IN THE ORDERS OF ITAT. THIS COST M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 8 -: SHOULD BE PAID TO THE PRIME MINISTERS RELIEF FUND WI THIN ONE MONTH AND SHOULD BE INTIMATED TO THE REGISTRY ON OR BEFO RE 30 TH NOVEMBER, 2016. WE ALSO ADVISE THE ADMINISTRATIVE COM MISSIONER TO APPLY HIS MIND AND PURSUE THE APPEALS CORRECTLY AND SHOULD NOT RESORT TO UNNECESSARY APPEALS AND RAISE THE GROUNDS WH ICH ARE NOT RELEVANT AND DOES NOT ARISE OUT OF THE ORDERS ISSUED BY THE LD.CIT(A). WE HOPE A BETTER SENSE WILL PREVAIL ON TH E SENIOR OFFICERS WHO SHOULD TAKE INTEREST IN THE MATTERS OF SE COND APPEAL IN NOT ONLY PREFERRING THE GROUNDS PROPERLY BUT ALSO TO DECIDE WHETHER THE APPEAL SHOULD BE PREFERRED OR NOT AND MO RE SO IN THE FORM OF MISCELLANEOUS APPLICATIONS LIKE THIS. WITH THE SE OBSERVATIONS, AND WITH LEVY OF COSTS, WE DISMISS BOTH THE MISCELLANEOUS APPLICATIONS AS INFRUCTUOUS. ORDER PRONOUNCED IN THE COURT ON 28 TH SEPTEMBER, 2016 SD/- SD/- (P. MADHAVI DEVI) (B. RAMAKOTAIAH) JUDICIAL MEMBER ACCOUNTANT ME MBER HYDERABAD, DATED 28 TH SEPTEMBER, 2016 TNMM M.A. NOS. 29 & 30/HYD/2016 M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., :- 9 -: COPY TO : 1. THE INCOME TAX OFFICER (TDS), TDS WARD-I, TIRUPA TI. 2. M/S. SOUTHERN POWER DISTRIBUTION CO. OF AP LTD., D.NO. 19-13-65/A, KESAVAYANA KUNTA, TIRUPATI. 3. CIT (APPEALS), VIJAYAWADA. 4. CIT (TDS), HYDERABAD. 5. D.R. ITAT, HYDERABAD. 6. GUARD FILE.