Income Tax Appellate Tribunal - Chandigarh
Dcit, Ludhiana vs M/S The Ludhiana Central Co Operative ... on 21 September, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
CHANDIGARH BENCHES 'A' CHANDIGARH
BEFORE SMT. DIVA SINGH, JUDICIAL MEMBER AND
DR. B.R.R. KUMAR, ACCOUNTANT MEMBER
ITA No. 749/Chd/2017
Assessment Year: 2010-11
Dy.CI T Vs. M/s The Ludhiana Central Co-
Circle-6, Operative Bank Ltd., Near Sadar
Ludhiana Police Station, Civil Lines, Ludhiana
PAN No. AAAJT1911B
(Appellant) (Respondent)
Appellant By : Sh. Parveen Jindal
Respondent By : Dr. Gulshan Rai
Date of hearing : 07/09/2017
Date of Pronouncement : 21/09/2017
ORDER
PER DR. B.R.R. KUMAR, A.M.
The appeal filed by the Revenue is directed against the order dated 24/02/2017 passed by the CIT(A)-3, Ludhiana.
2. The Revenue has raised only one effective ground which reads as under:
i. On t h e f act s an d ci rc um st an c es of t h e ca s e t h e Ld. CI T( A ) h a s err ed i n al l o wi n g rel i ef of addi t i on m ade b y t h e AO on a cco u n t of i n t erest a cc r u ed on n on p erf o rm i ng a ss et s b y i gnori n g t h e deci si on of t h e Hon ' b l e S up rem e C o urt i n t h e ca se of St at e B an k of Tra van c ore ( 1 58 I T R 1 02 ) . F u rt h er, t h e L d. CI T( A ) h a s wr o n gl y rel i ed up on t h e f i n di n g of Hon 'b l e D el h i Hi gh C o urt i n t h e c a s e of Va si st h Ch a y V yap a r Lt d. wh i ch i s a No n B an k i n g Fi n an ci al C or p or at i on S oci et y re gi st ere d u n der P un jab St at e C o- op e rat i ve S oci et i es Act . Mo r e ov er, t h e d eci si on of t h e Ld. C IT ( A ) i s p erv er se a s t h e a ss es se e i s f ol l o wi n g m er can t i l e s yst em of a cc o un t i n g.
3. The issue raised in the present appeal pertains to deletion of Rs. 2,67,88,000/- by the CIT(A) on account of interest on loans categorized as NPA 2 on accrual basis as against receipt basis claimed by the assessee. The addition was made by the AO on the basis that the assessee was following mercantile system of accounting and hence the interest on NPA's needs to be included.
4. The similar issue has been earlier dealt by the Coordinate Bench of ITAT, Chandigarh in the assessee's own case for the AY 2009-10. Before us the Ld. DR relied on the order of the AO while the Ld. AR relied on the earlier order of the ITAT Chandigarh Bench. For brevity and ready reference the relevant portion of the order in the case of the assessee in ITA No. 562/CHD/2013 is reproduced hereunder:
13. We f i n d t h at t h e i ss ue of acc o un t i n g f or i n t er est on st i ck y l oan s / NP A ' s, h a s b e en d eal t wi t h i n a n um b e r of de ci si on s b ot h b y t h e Ap e x C o urt an d va ri o u s Hi gh C o u rt s an d Tri b un al s al s o, wh er ei n af t er ap p l yi n g t h e " R eal In c om e Th e o r y" , t h e p r es c ri b ed A cc o un t i n g St an d a rd i s s ue d b y I C A I o n Re ven u e R ec o gn i ti on , A S- 9, t h e acc o un t i n g p ract i se of t h e a s se es se e r e l at i n g t o i nt erest o n st i ck y l oan s an d t h e RB I g ui del i n es rel at i n g t o acc o un t i n g f or i n t e re st on N P A' s, i t wa s h el d t h at s uc h i n com e wa s t a xab l e i n t h e y ea r of rec ei p t on l y, wh en i ts r eal i sat i on b ec om e s r ea s on abl y c ert ai n .
14. Th e Ap e x C o urt i n t h e ca se of UC O B an k , Cal c ut t a V s. CI T, West B en gal ( 19 99 ) 4 S up rem e C o urt Ca s es 59 9 a p p ro v ed t h e recei p t b a si s o f acco un t i n g f or i nt ere st on loan s wh o s e rec o ver y wa s d o ub t f ul , h ol di n g t h e sam e t o b e i n accord an ce wi t h acc o un t i n g p ract i ce an d i n con f orm i t y wi t h t h e m et hod p re s c ri b ed un der se ct i on 14 5 o f t h e Act . Th e rel ev an t fi n di n gs of t h e Ap ex C o urt a r e a s f ol l o ws :
"We have to consider whether interest on a loan whose recovery is doubtful and which has not been recovered by the assessee-bank for the last three years but has been kept in a suspense account and has not been brought to the profit and loss account of the assessee, can be included in the income of the assessee for the assessment year 1981-82. It is the case of the assessee that in respect of loans which are advanced by it to various customers, recovery of some loans is very doubtful. It is doubtful whether even the interest on the loans advanced will be recovered from the customer. In such cases, the interest calculated on the loan amount is credited in a suspense account. This amount is not brought to the profit and loss account of the assessee-bank because these are amounts which are not likely to be realised by the bank. Hence they do not form a part of the real income of the bank. If and when any such amount or a part of it is recovered, it is included in that assessment year in the total income of the assessee for the purpose of payment of income-tax.
The method of accounting which is followed by the assessee-bank is mercantile system of accounting. However, the assessee considers income by way of interest pertaining to doubtful loans as not real income in the year in which it accrues, but only when it is realised. A mixed method of accounting is thus followed by the assessee-bank. This method of accounting adopted by the assessee is in accordance with accounting practice. In Spicer and Pegler's Practical Auditing the relevant passage occurring at page 186-187 has been reproduced in the minority 3 judgment of this Court in State Bank of Travancore v. Commissioner of Income-tax, Kerala [(1986) 158ITR 102 at p.i2o]. It is as follows:
"Where interest has not been paid, it is sometimes left out of account altogether. This prevents the possibility of irrecoverable interest being credited to revenue, and distributed as profit. On the other hand, this treatment does not record the actual state of the loan account, and in the case of banks and other concerns whose business it is to advance money, it is usual to find the interest is regularly charged up, but when its recovery is doubtful, the amount thereof is either fully provided against or taken to the credit of an Interest Suspense Account and carried forward and not treated as profit until actually received."
Similarly, referring to interest on doubtful debts, Shukla and Grewal on Advanced Accounts, Ninth Edition at page 1089 state as follows: "Interest on doubtful debts should be debited to the loan account concerned but should not be credited to interest account. Instead, it should be credited to Interest Suspense Account. To the extent the interest is received in cash, the Interest Suspense Account should be transferred to Interest account; the remaining amount should be closed by transfer to the Loan account. This treatment accords with the principle that no item should be treated as income unless it has been received or there is a reasonable certainty that it will be realised.
(Vide State Bank of Tranvacore v. CIT [supra]i The assessee's method of accounting therefore, transferring the doubtful debt to an interest suspense account and not treating it as profit until actually received, is in accordance with accounting practice.
Under Section 145 of the Income-tax Act, 1961, income chargeable under the head "profits and gains of business or profession or income from other sources" shall be computed in accordance with the method of accounting regularly employed by the assessee; provided that in a case where the accounts are correct and complete but the method employed is such that in the opinion of the Income- tax Officer, the income cannot properly be deduced therefrom, the computation shall be made in such manner and on such basis as the Income-tax Officer may determine. In the present case the method employed is entirely for a proper determination of income." (emphasis supplied by us) 15 . F urt h e r the Ap ex C o urt al s o r ef err ed to the CBDT Ci rc ul ar dat e d 9 t h Oct o b e r 1 98 4 st at i n g t h at i n t er est on l oan s on w h i ch t h ere h as b ee n n o r ec o ver y f or 3 y ear s w i l l be s ub je ct ed t o t a x o n r ec ei p t b a si s , an d h el d a s f ol l ow s :
"The question whether interest earned, on what have come to be known as "sticky" loans, can be considered as income or not until actual realization, is a question which may arise before several income tax officers exercising jurisdiction in different parts of the country. Under the accounting practice, interest which is transferred to the suspense account and not brought to the profit and loss account of the company is not treated as income. The question whether in a given case such "accrual" of interest is doubtful or not, may also be problematic. If, therefore, the Board has considered it necessary to lay down a general test for deciding what is a doubtful debt, and directed that all income tax officers should treat such amounts as not forming part of the income of the assessee until realized, this direction by way of a circular cannot be considered as travelling beyond the powers of the Board under Section 119 of the 4 Income Tax Act. Such a circular is binding under Section 119. The circular of 9th of October, 1984, therefore, provides a test for recognising whether a claim for interest can be treated as a doubtful claim unlikely to be recovered or not. The test provided by the said circular is to see whether, at the end of three years, the amount of interest has, in fact, been recovered by the bank or not. tfu is not recovered for a period of three years, then in the fourth year and onwards the claim for interest has to be treated as a doubtful claim which need not be included in the income of the assessee until it is actually recovered."
16. Th i s vi e w wa s r e af fi rm ed i n a l at er jud gm en t b y t h e Ap ex C o urt i n Mer can t i l e B an k Lt d., V s . CI T, B om b a y Ci t y- III ( 2 00 6 ) 5 S S C 2 21.
17. F urt h e r t h e i s s u e o f t a x a b i li t y of i n t ere st on N P A acc o un t s on rec ei p t b a si s b y C o op erat i ve B an k s h a s b een d eal t wi t h b y va ri o u s Hi gh C o urt s, wh e rei n i t wa s h el d t h at t h e a s se s se e wa s b o un d b y RB I gui del i n e s t o acc o un t f or s uch i n t ere st on r ecei p t b a si s an d b y vi rt ue of t h e p r o vi si on s of sect i on 45 Q of t h e R B I Act , t h e RB I gui del i n e s h a d an ov er ri di n g ef f ect ov er ot h e r Act s i n cl u di n g t h e In com e Ta x Act , 19 6 1.
18. Th e G uja rat Hi gh C o u rt i n t h e ca se of Pr . CI T- 5 V s. Sh ri Mah i l a Se wa Sah a k a ri B an k Lt d. ( Ta x Ap p eal N o. 53 1 of 201 5 dat e d 5.8 .2 01 6 .rel yi n g up on t h e deci si on of t h e ap e x c o urt i n S o ut h er n Te ch n ol ogi es Li m i t ed v s JC I T, C oi m b at or e, ( 20 10 ) 3 20 IT R 57 7, h el d t h at s o f a r a s In c om e Re c ogn i t i on wa s c on c ern ed e ven t h e A O h ad t o f ol l o w t h e RB I Di rect i on s, 19 98 i n vi ew of s ect i on 4 5 Q of t h e RB I Act an d sect i on 14 5 of t h e In com e T a x Act h a d n o r ol e t o p l ay i n t h e sam e. Th e H on ' b l e C o u rt h el d at p a ra 2 0 t o 23 of i t s or de r a s f ol l o ws :
20. Section 45Q finds place in Chapter IIIB of the RBI Act. Thus, the provisions of Chapter RIB of the RBI Act have an overriding effect qua other enactments to the extent the same are inconsistent with the provisions contained therein. In order to reflect a bank's actual financial health in its balance sheet, the Reserve Bank has introduced prudential norms for income recognition, asset classification and provisioning for advances portfolio of the co-operative banks.
The guidelines provided thereunder are mandatory and it is incumbent upon all co-operative banks to follow the same. Insofar as income recognition is concerned, clause 4.1.1 of the circular provides that the policy of income recognition has to be objective and based on the record of recovery. Income from non-performing assets (NPA) is not recognised on accrual basis but is booked as income only when it is actually received. Therefore, banks should not take to income account interest on non-performing assets on accrual basis. Thus, in view of the mandate of the RBI Guidelines the assessee cannot recognise income from non-performing assets on accrual basis but can book such income only when it is actually received. Thus, this is a case where at the threshold, the assessee, in view of the RBI Guidelines cannot recognise income from NPA on accrual basis. This is, therefore, a case pertaining to recognition of income and not computation of the income of the assessee.
21. The Supreme Court in Southern Technologies Limited (supra) has held that the 1998 Directions are only disclosure norms and have nothing to do with computation of total income under the IT Act or with the accounting treatment. The 1998 Directions only lay down the manner of presentation of NPA provision in the balance sheet of an NBFC. The 5 court has referred to the deviations between the RBI Directions and the Companies Act as follows:
"42. Broadly, there are three deviations:
(i) in the matter of presentation of financial statements under Schedule VI to the Companies Act;
(ii) in not recognising the "income" under the mercantile system of accounting and its insistence to
follow cash system with respect to assets classified as NPA as per its norms
(iii) in creating a provision for all NPAs summarily as against creating a provision, only when the debt is doubtful o f recovery under the norms of the accounting standards issued by the Institute o f Chartered Accountants of India.
These deviations prevail over certain provisions of the Companies Act, 1956 to protect the depositors in the context of income recognition and presentation of the assets and provisions created against them. Thus, the P&L account prepared by NBFC in terms of the RBI Directions, 1998 does not recognise "income from NPA" and, therefore, directs a provision to be made in that regard and hence an "add back". It is important to note that "add back" is there only in the case of provisions. [Emphasis supplied]"
22. Therefore, in terms of the above decision, where an assessee makes provision for NPA and seeks deduction of such amount under section 36fl)(vii) or section 37 of the Act, then in the computation of income, the RBI Guidelines would have no role to play, and hence, an add back. Insofar as income recognition is concerned, the Supreme Court has held thus:
"Applicability o f Section 145
57. At the outset, we may state that in essence the RBI Directions, 1998 are prudential/provisioning norms issued by RBI under Chapter III-B of the RBI Act, 1934. These norms deal essentially with income recognition. They force the NBFCs to disclose the amount of NPA in their financial accounts. They force the NBFCs to reflect "true and correct" profits. By virtue of Section 45-Q, an overriding effect is given to the RBI Directions, 1998 vis-a-vis "income recognition" principles in the Companies Act, 1956. These Directions constitute a code by itself. However, these RBI Directions, 1998 and the IT Act operate in different areas. These RBI Directions, 1998 have nothing to do with computation of taxable income. These Directions cannot overrule the "permissible deductions" or "their exclusion" under the IT Act. The inconsistency between these Directions and the Companies Act is only in the matter of income recognition and presentation of financial statements. The accounting policies adopted by an NBFC cannot determine the taxable income. It is well settled that the accounting policies followed by a company can be changed unless the AO comes to the conclusion that such change would result in understatement of profits. However, here is the case where the AO has to follow the RBI Directions, 1998 in view of Section 45-Q of the RBI Act. Hence, as far as income recognition is concerned, Section 145 of the IT Act has no role to play in the present dispute."
Thus, insofar as income recognition is concerned, the court has held that even the Assessing Officer has to follow the RBI Directions, 1998 in view of section 45Q of the RBI Act and that as far as income recognition is concerned, section 145 of the Income Tax Act, has not role to play.
23. In the light of the above discussion what emerges is that while determining the tax liability of an assessee, two factors would come into play. Firstly, the recognition of income in terms of the recognised accounting principles and after such income is recognised, the computation thereof, in terms of the provisions of the Income Tax Act, 6 1961. Insofar as the computation of taxability is concerned, the same is solely governed by the provisions of the Income Tax Act and the accounting principles have no role to play. However, recognition of income stands on a different footing. Insofar as income recognition is concerned, it would be the RBI Directions which would prevail in view of the provisions of section 45Q of the RBI Act and section 145 would have no role to play.
Hence, the Assessing Officer has to follow the RBI Directions.
19. F urt h e r rel yi n g up on t h e d eci si on of t h e D el h i Hi gh C o urt i n t h e ca se of C IT V s. Va si st h Ch a y V yap a r Lt d. ( 201 1 ) 33 0 I T R 44 0, t h e C o u rt h el d t h at t h e A O h a s t o f ol l o w R B I di rect i on s on R ev en u e Re c ogn i t i on , an d h el d a s f ol l o ws "25. The distinction drawn by the Delhi High Court is that while the accounting policies of adopted by the NBFC cannot determine the taxable income. However, insofar as income recognition is concerned, the Assessing Officer has to follow the RBI Directions, 1998 in view of section 45Q of the RBI Act. That insofar as income recognition is concerned section 145 of the Income Tax Act, 1961 has no role to play."
20. Th e B om b a y Hi gh C o urt i n t h e ca s e of C IT Vs . D eo gi ri Naga ri Sah ak a ri i B an k Lt d. & Ot h er s, 379 I T R 24 1 rei t erat ed t h e ab o ve p ro p osi t i on b y h ol di n g at p a ra 9 of i t s or d er a s f ol l o ws :
"9. The Income Tax Appellate Tribunal has referred the case of M/s. Vasisth Chay Vyapar Limited 330 ITR 440 (Delhi). In this case, the revenue relied upon the decision of the Hon'ble Supreme in the case of Southern Technologies Ltd. supra. The learned Income Tax Appellate Tribunal has reproduced the observations made by the Delhi High Court while referring the said case of M/s Southern Technologies Limited supra. The assessee herein being a Cooperative Bank also governed by the Reserve B an k of India and thus the directions with regard to the prudential norms issued by the Reserve Bank of India are equally applicable to the Co-operative banks. The Hon'ble Supreme Court in the case of Southern Technologies Limited supra held that, provisions of Section 45Q of Reserve Bank of India Act has an overriding effect vis-a-vis income recognition principle under the Companies Act. Hence, Section 45Q of the RBI Act shall have overriding effect over the income recognition principle followed by cooperative banks. Hence, the Assessing Officer has to follow the Reserve Bank of India directions 1998, as held by the Hon'ble Supreme Court. "
2 1. F urt h e r r el yi n g up on t h e de ci si on of t h e A p ex C o u rt i n t h e ca s e of U C O B an k , C al c ut t a an d Me rc an t i l e B an k Lt d. ( s u p ra ) i t al l o we d t h e a ss e ss ee 's ap p e al .
2 2. It i s evi den t f rom t h e ab o ve t h at t h e i ss ue reg a r di n g t a xab i l i t y of i nt ere st on NP A ' s i s set t l ed i n f avo ur of t h e a sse s s ee a s b ei n g t a xab l e i n t h e y ea r of re cei p t .
2 3. Th e gri ev an c e of t h e Re ven u e t h at t h e Hon 'b l e S up r em e C o urt 's de ci si on i n th e ca se of St at e B an k of Tr avan c or e ( s up r a ) ap p l i es t o t h e p re se n t ca s e, we f i n d i s m i sp l aced, si n ce a s p oi n t ed o ut ab o ve b y t h e L d. co un sel of t h e a sse s se e, i t h as b een o ve r rul ed b y t h e Ap ex C o u rt i t sel f i n t h e ca se of U C O B an k Li m i t ed ( s up ra ) wh e rei n i t wa s p oi n t ed o ut b y t h e Ap ex C o urt t h at wh i l e ren deri n g t h e ju dgm en t i n t h e ca s e of St at e B an k of Tr ava n c or e ( s up r a ), t h e ci rcul a r dat e d 9 .1 0.1 98 4 h ad n ot b e en b r o ugh t t o t h e n ot i ce of t h e C o urt , n or t h e s ub se q u en t d eci si on of t h e Ap ex C o u rt i n t h e ca s e of 7 K. P. Va rgh es e V s . IT O ( 198 1 ) 1 31 I T R 5 97 ( S C ). Th e rel ev an t ex t ract s of t h e de ci si on i n U C O B an k Li m i t ed a r e r ep r od u ce d h er e un d er :
"There are, however, two derisions of this Court which have been strongly relied upon by the respondents in the present case. The first decision is the majority judgment in The State Bank of Travancore v. Commissioner of Income- Tax, Kerala (1986 (158) TTR 102) derided by a Bench of three Judges of this court by a majority of two to one. This judgment directly deals with interest on 'sticky advances" which have been debited to the customer but taken to the interest suspense account by a banking company. The majority judgment has referred to the circular of 6th of October, 1952 and its withdrawal by the second circular of 20th of June, 1978. The majority appears to have proceeded on the basis that by the second circular of 20th June, 1978 the Central Board had directed that interest in the suspense account on "sticky" advances should be includible in the taxable income of the assessee and all pending cases should be disposed of keeping these instructions in view. The subsequent circular of 9th of October, 1984 by which the assessment year 1979-80 the banking companies were given the benefit of the circular of 9th of October, 1984, does not appear to have been pointed out to the Court. What was submitted before the Court was, that since such interest had been allowed to be exempted for more than half a century, the practice had transformed itself into law and this position should not have been deviated from. Negativing this contention, the Court said that the question of how far the concept of real income enters into the question of taxability in the facts and circumstances of the case, and how far and to what extent the concept of real income should intermingle with the accrual of income, will have to be judged "in the light of the provisions of the Act, the principles of accountancy recognised and followed, and feasibility" . The Court said that the earlier circulars being executive in character cannot alter the provisions of the Act. These were in the nature of concessions which could always be prospectively withdrawn. The Court also observed that the circulars cannot detract from the Act. The decision of the Constitution Bench of this Court in Navnitlal C. Javeri v. K.K. Sen (Supra), or the subsequent decision in K.P. Varghese v. Income Tax Officer (supra) also do not appear to have been pointed out to the Court. Since the later circular of 9.10.1984 was not pointed out to the Court, the Court naturally proceeded on the assumption that the benefit granted under the earlier circular was no longer available to the assessee and those circulars could not be resorted to for the purpose of overcoming the provisions of the Act. Interestingly, the concurring judgment of the second judge has not dealt with this question at all but has decided the matter on the basis of other provisions of law. "
2 4. Th e ref or e, t h e con t en t i on of t h e Re ven u e t h at t h e deci si on i n t h e ca se of St at e B an k of Tr a van c o re ( s up ra ) a p p l i es t o t h e a ss es s ee ' s c a s e i s di sm i ssed.
2 5. Th e a r g um en t of t h e l ea rn ed D. R. t h at t h e de ci si on of t h e Del h i Hi gh Co u rt i n t h e ca s e of V a si st h Ch a y V ya p a r Lt d. ( s up ra ) wo u l d n ot ap p l y t o t h e a s se s se e 's ca s e si n ce t h e a ss e ss e e i s a co op erat i ve s o ci et y wh i l e i n t h e ca s e of Va si st h Cha y V yap a r Lt d . ( s up r a ), t h e a s se ss ee wa s a NB F C, i s al s o di sm i ssed si n ce t h e p ri n ci p l e en u n ci at ed b y t h e D el h i Hi gh C o urt i n Va si st h Ch a y V yap a r Lt d. ( s up ra ) h a s b een f ol l o we d i n t h e ca s e of S h ri Mah i l a Se wa Sah ak a ri B an k Lt d. ( s up ra ) b y t h e H on 'b l e G uja rat Hi gh C o urt an d va ri o us ot h er d eci si on s ci t ed b y t h e a s se s se e bef o re u s , an d t h e a ss es s ee i n al l t h o se ca se s b ei n g a c o op e rat i ve b an k , t h e 8 deci si on ren de red t h er ei n sq ua r el y a p p l i es t o t h e ca se of t h e a s se s see .
2 6. Th e a rg um en t of t h e l ea rn ed D . R. t h at t h e a sse s se e i s f ol l o wi n g t h e m erc an t i l e sy st em of ac co un t i n g i s als o di s m i ssed si n ce t h i s a sp ect h a s b e en d eal t wi t h b y v a ri o u s Hi gh C o urt s ref er re d t o ab ov e wh er ei n t h ey h av e ca t ego ri cal l y hel d t h at ev en f ol l o wi n g t h e m e rca n t i l e sy st em of a cc o un t i n g t h e i n t ere st o n N P A acc o un t can n ot b e sai d t o h av e ac c r ue d i n t h e i m p ugn e d y ea r si n ce t h e rec o ve r y o f t h e sam e wa s i m po ssi b l e an d ev en ot h er wi s e f or t h e p urp o se of In com e Rec o gn i t i on t he RB I Di re ct i on s, 19 9 8, h ad t o b e f ol l o we d i n vi e w of s ect i on 45 Q of t h e RB I Act .
2 7. In t h e l i gh t of t h e ab ov e di sc u s si on we f i n d n o i n fi rmi t y i n t h e or de r of t h e CI T ( A ) h ol di n g t h e i n t erest on NP A' s a s t a xa b l e i n t h e yea r of r ec ei p t , s o a s t o wa r ran t i n t er f eren c e.
5. Following the aforementioned order in the case of the assesssee on the similar issue the order of the Ld. CIT(A) which was based on the earlier Tribunals order, we decline to interefere in the order of the Ld. CIT(A).
6. In the result appeal of the Revenue is dismissed.
Order pronounced in the Open Court on
Sd/- Sd/-
(DIVA SINGH) (DR. B.R.R. KUMAR)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated : 21/09/2017
AG
Copy to: The Appellant, The Respondent, The CIT, The CIT(A), The DR