Income Tax Appellate Tribunal - Bangalore
P. Anandkumar, Bangalore vs Department Of Income Tax on 17 July, 2008
IN THE INCOME TAX APPELLATE TRIBUNAL
"B" BENCH : BANGALORE
BEFORE SHRI SHAILENDRA KUMAR YADAV, JUDICIAL MEMBER
AND SHRI A. MOHAN ALANKAMONY, ACCOUNTANT MEMBER
ITA No.628/Bang/2008
Assessment year : 2002-03
The Income Tax Officer,
Ward 8(2),
Bangalore. : APPELLANT
Vs.
P. Anandkumar,
Prop. M/s. Paliath Enterprises,
No.307, Thimmaiah Road,
Benson Town,
Bangalore - 560 046. : RESPONDENT
C.O. No.76/Bang/2008
(Arising out of ITA No.628/Bang/2008)
Assessment year : 2002-03
P. Anandkumar,
Prop. M/s. Paliath Enterprises,
No.307, Thimmaiah Road,
Benson Town,
Bangalore - 560 046. : APPELLANT
Vs.
The Income Tax Officer,
Ward 8(2),
Bangalore. : RESPONDENT
ITA Nos.628, 981
& 982, CO 76 of 2008
Page 2 of 17
ITA No.981 & 982/Bang/2008
Assessment years : 2003-04 & 2004-05
P. Anandkumar,
Prop. M/s. Paliath Enterprises,
No.307, Thimmaiah Road,
Benson Town,
Bangalore - 560 046. : APPELLANT
Vs.
The Dy. Commissioner of
Income Tax,
Central Circle 1(2),
Bangalore. : RESPONDENT
Assessee by : Shri V. Chandrashekar
Shri Narendra Sharma
Respondent by : Smt. V.S. Sreelekha
ORDER
Per A. Mohan Alankamony, Accountant Member
These are four appeals - (i) the Revenue's appeal (ITA 628) & (ii) Cross objection by the assessee ( CO 76) for the AY 2002-03 and (iii) & (iv) assessee's appeals for the AYs 2003-04 and 2004-05 - all are directed against the orders of the CIT(A)-II, Bangalore.
As these appeals are inter-connected and pertain to the same assessee, for the sake convenience and clarity, they are considered together and disposed off in this common order.
ITA Nos.628, 981
& 982, CO 76 of 2008 Page 3 of 17 ITA NO: 628/2008 - AY 2002-03 [By Revenue]:
2. There was a slight delay in preferring this appeal by the Revenue.
The Revenue had furnished an affidavit, in original, wherein it has been claimed that there was an inadvertent error crept in, in the office of the CIT, B-IV, Bangalore, in noting the date of limitation for filing the appeal which had resulted in filing the appeal belatedly. As the Revenue was prevented by a reasonable cause, it was pleaded that the delay may be condoned.
3. After due consideration of the reasons put-forth by the Revenue, the delay in filing this appeal by the Revenue is condoned and the Registry was directed to take the appeal on record.
4. During the course of hearing before us, the Ld. D.R submitted that the ground Nos: 1 and 2 raised in the grounds of appeal were not pressed and, therefore, they were dismissed as not pressed.
5. As the fourth ground raised was general and not specific, it too was dismissed as non-consequential in nature. Thus, the lone ground of the Revenue which survived for adjudication is reformulated as under -
The CIT(A) erred to see the reason that as per s.234B(3) where, as a result of an order of reassessment or re-computation u/s 147/153A, the amount on which interest was payable under sub- sec.(1) is increased, the assessee shall be liable to pay simple interest at the rate of 1% for every month from the date of regular assessment and ending on the date of reassessment or re- computation u/s 147 or u/s 1543A of the Act.
6. We have duly considered the rival submissions and also perused the relevant records. The CIT(A), after deliberating the issue at length, has observed that -
ITA Nos.628, 981
& 982, CO 76 of 2008 Page 4 of 17 "8.5.......................In the assessment for the assessment year 2002-03, the AO has assessed the contract receipts amounting to Rs.12151444/- [which was accounted in the subsequent year by the appellant] and this amount also was subjected to TDS. Under the circumstances, it is seen that the appellant was not liable to pay advance tax. When such a liability is not there, question of charging interest u/s 234B does not arise. The shortfall in the payment of TDS during the year as per the reassessment order is mainly due to the fact that the appellant had in his original return of income claimed credit for TDS on the said amount of Rs.12151444/- in the return for the assessment year 2003-04 where originally he had declared the said receipts. In view of the above discussion, I am convinced that interest u/s 234B is not chargeable in the case of the appellant. However, while giving effect to this order, the AO is directed to ascertain and verify the above facts regarding TDS, the income returned in the original return and the claim for TDS made therein and income originally assessed u/s 143(3)."
7. At the out-set, we would like to point out that as per the s.251(1)(a) of the Act, the power of the Ld.CIT(A) in remitting back any issue to the AO for fresh consideration/verification etc., has been dispensed with by the Finance Act, 2001, w.e.f. 1/6/2001.
However, the CIT(A) had raised an issue, according to which, the assessee was not liable to pay any advance tax and thus, the assessee's case doesn't fall within the ambit of s.234B to charge interest. In view of the above, we are of the considered view that the AO should look into this aspect whether the assessee were liable to be charged interest u/s 234B of the Act. If so, the Revenue's argument that the assessee shall be liable to pay simple interest at the rate of 1% for every month from the date of regular assessment and ending on the date of reassessment or re- computation u/s 147 or u/s 1543A of the Act is finding solace from the ruling of the Hon'ble ITAT, Mumbai 'I' Bench in the case of ACIT v. Ronald ITA Nos.628, 981 & 982, CO 76 of 2008 Page 5 of 17 Nardi reported in (2007) 14 SOT 24, wherein the Hon'ble Tribunal has observed thus -
"Once an order of reassessment is passed under s.143(3)/148, the original order determining the total income under s.143(1) or 143(3) or 144 gets merged with the order of reassessment for the simple reason that two orders determining the total income cannot stand together. It therefore logically follows that the figures of total income determined and tax, interest etc., thereon have to be incorporated in the reassessment order passed under s.143(3)/147 and in the computation sheet accompanying therewith. If the AO had not followed the aforesaid course of action, the total income originally determined under s.143(1) or 143(3) or 144 and tax, interest, etc., thereon would have escaped taxation. The assessee did not challenge the levy of interest under s.234B(1) as per the intimation originally issued under s.143(1). The AO is, therefore, justified in incorporating the said figure of interest originally charged under s.234B (1) as per the intimation issued under s.143(1), in the computation sheet accompanying the order of reassessment passed under s.143(3)/147. This position is quite clear, obvious and patent on bare perusal of the statutory provisions and therefore does not admit of any debate. The action of the AO in incorporating the interest originally charged under s.234B(1) as per intimation, in the computation sheet accompanying the reassessment order is, therefore, correct."
Thus, the AO is directed to verify whether interest u/s 234B can be charged in the case of the assessee and if so, the AO shall be within his domain to incorporate the interest levied u/s 234B(1) and in addition should levy interest u/s 234B(3) for every month from or part of month comprised in the period commencing on the day following the date of determination of total income u/s 143(1) and ending on the date of reassessment under section 143(3)/147 on the amount by which the tax on the total income determined on the basis of the reassessment exceeded the tax on the total income determined u/s 143(1). It is ordered accordingly. ITA Nos.628, 981
& 982, CO 76 of 2008 Page 6 of 17 CO NO: 76/2008 - AY 2002-03 [By the assessee]:
8. The assessee has raised nine exhaustive grounds in his cross objection. However, during the course of hearing, the Ld. A.R. submitted that ground Nos:1,2,3,4 were not pressed and, accordingly, they are dismissed as not pressed.
9. On a perusal of the remaining grounds, we find that ground Nos:6, 7, 8 and 9 were general in nature and no specific issues involved and, therefore, they are dismissed as non-consequential.
10. The lone ground survives for adjudication was that -
"the authorities below were not justified that the income of Rs.1,43,27,626/- [ i.e., Rs.12151444 + 217652 (sic) 2176182] was relating to the AY 2003-04 as admitted by the assessee which was assessed for the AY.03-04 and taxing the same for the AY 2002-03 amounts to double taxation."
The history of the case, in brief, is that the assessee had furnished his ROI admitting an income of Rs.546400/- which was processed u/s 143(1) of the Act. Subsequently, the assessment was concluded u/s 143(3) of the Act, determining the total income at Rs.6.47 lakhs which was set aside by the CIT, B-IV directing the AO to verify the assessee's contention of contract receipt of Rs.44.18 lakhs representing advances only on which TDS was effected and also directed not to give credit on TDS on advances which had not been included in the turnover declared in the P & L account. While verifying the contract receipts and the balance sheet, the AO stumbled upon the fact that Rs.1.24 crores was claimed to have been received from M/s.Prestige Leisure Resorts (P) Ltd as advance for work. On verification ITA Nos.628, 981 & 982, CO 76 of 2008 Page 7 of 17 of the ledger account of the assessee in the books of the said company, the closing balance as on 31.3.02 was Nil due to the fact that the assessee got the final payment of Rs.1.20 crores on 31.12.01, the receipt of which should have been declared as contract receipt.
11. The assessee's premise was subjected to a survey on 8.8.05. Consequent upon the survey, the following contract works executed by the assessee were unearthed:
(i) Prestige Leisure Resorts (P) Ltd. Bills settled on 4.12.01 Rs.1,60,00,000
(ii) Millenium Developers 21,76,182 Complying with the notice u/s 148, the assessee came up with a revised ROI admitting a total income of Rs.8058140/-. After deliberating the issue at a greater length and also corroborating the assessee's admission recorded on oath on 8/8/2005, the AO had worked out the receipts as under:
M/s.Prestige Leisure Resorts (P) Ltd:
Bill settled for Rs.1,60,00,000
Amounts already accounted for - FY 99.00 Rs.2039250
FY 00-01 1200000
S.T. @ 4% 609306 38,48,5566
1,21,51,444
M/s.Talisma Corporation Ltd:
Completed the work for Rs.34.94 lakhs for the period ended 31.3.2001 but was not accounted in the sales. The assessee on oath, had admitted and agreed to consider this as sales for the FY 00-01 and, accordingly, considered by the AO for the purpose of arriving at the profit.
Thus, the AO concluded the assessment in taking into account these amounts, aggregating to Rs.1,43,27,626/- [12151444 + 2176182] and arrived at the taxable income at Rs.8159540/-. This has been done by the ITA Nos.628, 981 & 982, CO 76 of 2008 Page 8 of 17 AO on the basis of the assessee's assertion on oath on 24/8/2005 and the Revised Return furnished on 16.11.2005 wherein the assessee himself had arrived at the total income at Rs.8058140.
12. However, the assessee took up the issue before the CIT(A) with an argument that "the receipts which have been assessed in the reassessments should have been considered in the assessment years for which he had declared them as the accounts maintained by the appellant were systematic and the mere claim for a receipt does not result in accrual of income unless the counterpart of the appellant had accepted the same." After due consideration of the argument put-forth by the assessee and placing reliance on the following case laws:
(i) Rameshchandra & Co. v. CIT (1987) 168 ITR 375 (Bom);
(ii) Narayan Bhagawantrao Gosavi Balajiwale v. Gopal Vinayak Gosavi & Others [AIR 1960 SC P.100 (V - 47 - C 18)]; &
(iii) Pullengode Rubber Produce Co v. State of Kerala & Anr. [91 ITR 18 - SC ] the Ld.CIT (A) brushed aside the contentions and went ahead with the observations that -
"6. .................. On a careful consideration of the assessment order and the sworn statement recorded on 8/8/2005 during the course of survey, it is clear that the appellant has in fact received the sum and also completed the work during the assessment years in which the AO has reassessed them and not in the assessment year in which they were offered by the appellant. Further, the transactions in those cases were complete in all respects as admitted by the appellant in answer to question No.14 of his sworn statement. It is also seen from questions No.15 to 17 and the appellant's answer to them in the sworn statement that the appellant's transactions in respect of contract works with the clients were completed and final bill was settled with the amounts received by the appellant, but the same were not accounted for in the relevant accounting years, in spite of the fact that they were settled much before the end of the ITA Nos.628, 981 & 982, CO 76 of 2008 Page 9 of 17 financial years. From these facts, it is clear that the appellant's contention as mentioned above is not justified and cannot be entertained.
....................................".
Since, the assessee himself had come forward to offer these amounts aggregating to Rs.1.43 crores for taxation in the assessment year 2002.03 by furnishing a revised return, he cannot himself rescind now. Had he offered the said sums for taxation for the AY 2003-04 too as claimed by him, the assessee shall be at liberty to approach the AO for redressal by way of an application under section 154 of the Act.
ITA NO: 981/2008 - AY 2003-04 [By the assessee]:
13. There was a considerable delay in preferring this appeal. The Ld. A R of the assessee vide application dated: 17/7/2008 [accompanied by an affidavit of the assessee in original] submitted that the entire file pertaining to the AY in question was with the assessee's previous AR who was instructed to take further action on receipt of the order of the first appellate authority. However, the then AR was of the view that there was no case for further appeal and as such no appeal could be preferred within the stipulated time. On the advice of the present counsel, this appeal was filed which caused a considerable delay in doing so. It was pleaded that since the assessee was prevented by a reasonable cause in filing the appeal in time, the delay caused may be condoned and the appeal be admitted for adjudication.
14. On the other hand, the Ld.D.R had vehemently opposed in condoning the delay and acceding to the assessee's request. To drive ITA Nos.628, 981 & 982, CO 76 of 2008 Page 10 of 17 home her point, she had placed reliance in the case of Surinder Kumar Boveja v. CWT reported in (2006) 287 ITR 52 (Delhi).
15. We have duly considered the rival submissions. With due respects, we have perused the case law on which the Revenue had placed reliance. In that case, the assessee got part relief granted by the first appellate authority, but preferred not to appeal against it. He had, however, appealed against the order of the CWT(A) after an inordinate delay only after the Tribunal made some observation in his favour preferred by the revenue. Whereas in the present case, the CIT (A) had dismissed the assessee's appeal in toto and even though he was aggrieved, he had not preferred an appeal, ostensibly, on the advise of his previous AR. Thus, the assessee's case is on the different footing and the case law relied on by the D.R, in our considered view, is distinguishable. In the interest of natural justice and equity and also the assessee was prevented by a reasonable cause, the delay is condoned and the appeal is admitted.
16. The assessee has raised nine (sic) seven grounds, out of which, ground Nos:1,6 and 7 are general and no specific issues involved and, therefore, they are dismissed as non-consequential. With regard to the condonation of delay in filing the appeal [ground No.5] has already been addressed to.
17. In the remaining grounds, the crux of the issue is largely confined to:
The authorities below were not justified in dropping the proceedings put in motion u/s 147 of the Act after having taxed the income of the assessee in the preceding year which has resulted in taxing the same amount twice.ITA Nos.628, 981
& 982, CO 76 of 2008 Page 11 of 17 Briefly, the issue is that for the AY in question, the assessee had originally admitted an income of Rs.1439906/- which was processed u/s 143(1) of the Act. Consequent to survey operation in the assessee's premise and in compliance with the Notice u/s 148 of the Act, the assessee had furnished a revised return on 16/11/2005, declaring a loss of Rs.71.82 lakhs. During the course of reassessment proceedings, after making prima facie adjustments and taking into account the income other than the income from business of Rs.2.22 lakhs and the proposed disallowance of Rs.1.32 lakhs, the AO found that the re-assessment in question will result in a loss of Rs.70.5 lakhs and also refund of Rs.4.73 lakhs plus interest u/s 244A of the Act.
18. For having initiated the proceedings u/s 147 of the Act, if re- assessment were to be concluded in the instant case, it would result in loss as against the income arrived at by processing the original ROI u/s 143(1) of the Act and drawing strength from the ruling of the Hon'ble Apex Court in the case of CIT v. Sun Engineering Works (P) Ltd. reported in (1992) 198 ITR 297, the AO had dropped the proceedings initiated u/s 147 of the Act.
19. Agitated, the assessee took up the issue before the CIT (A) who after considering the contention of the assessee, has observed thus -
"5.1.......................The AO has elaborately discussed the reasons for dropping the reassessment proceedings and has also relied on the decision of the Hon'ble Supreme Court in the case of Sun Engg Cited above. It is my considered opinion that the appeal filed against the order dropping the reassessment proceedings is not maintainable. Section 246A gives the list of orders which are appealable before the CIT(A) in which an order of the AO dropping the proceedings u/s 147 is not included. According to section 246A(1)(b), an order of assessment, reassessment or re-computation under section 147 ... is one of the appealable orders. However, in ITA Nos.628, 981 & 982, CO 76 of 2008 Page 12 of 17 the case of the appellant, the AO has neither made an assessment/re-assessment nor has he made a re-computation under the said section. Hence, the appeal is not maintainable. The assessments are reopened under section 147 for bringing to tax the escaped income. Further, in the appellant's case, the AO has reopened the assessment by issue of a Notice u/s 148 and having found that there was no escapement of income, he has dropped the reassessment proceedings so initiated. Once, the proceedings under section 147 are dropped, the position reverts to the income originally returned by the appellant or assessed for the said year and, therefore, there is no prejudice or an additional liability created. Therefore, there is no cause of action. In the present appeal, the appellant is seeking a reduction in the income returned and this not a power granted to the CIT(Appeals). The assessee is free to pursue the alternative remedies available under section 264/154 as the case may be."
20. Aggrieved, the assessee has come up with the present appeal. On verification of the relevant records, we find that consequent on the survey operation, the assessee, in his statement dated 24.8.2005 on oath, answering to question No.6, had affirmed that "Since the WIP was only an estimated figure, I have no objection for adopting the value of work in progress of Rs.28,00,000/- as on 31.3.2003 and for computing income accordingly." However, in the return filed earlier, the assessee had shown the work-in-progress only at Rs.26 lakhs. In the opinion (belief) of the AO that there was an escapement of income to the extent of Rs.2 lakhs [Rs.2800000 - 2600000] and accordingly issued a notice u/s 148 of the Act. During the course of re-assessment proceedings and after taking into account the revised return furnished by the assessee - admitting a loss of Rs.71.82 lakhs - the AO found that the re-assessment would result in a loss of Rs.70.50 lakhs. Thus, the AO, taking refuge in the verdict of the Hon'ble Supreme Court referred supra, he dropped the proceedings initiated u/s 147 of the Act.
ITA Nos.628, 981
& 982, CO 76 of 2008 Page 13 of 17
21. With due respects, we have perused the observations of the highest judiciary of the land referred supra. For ready reference, the relevant portion of the Hon'ble Court's observation is reproduced as under:
"we find that, in proceedings under section 147 of the Act, the Income-tax Officer may bring to charge items of income which had escaped assessment other than or in addition to that item or items which have led to the issuance of the notice under section 148 and where reassessment is made under section 147 in respect of income which has escaped tax, the Income-tax Officer's jurisdiction is confined to only such income which has escaped tax or has been under-assessed and does not extend to revising, reopening or reconsidering the whole assessment or permitting the assessee to re- agitate questions which had been decided in the original assessment proceedings. It is only the underassessment which is set aside and not the entire assessment when reassessment proceedings are initiated. The Income-tax Officer cannot make an order of reassessment inconsistent with the original order of assessment in respect of matters which are not the subject matter of proceedings under section 147. An assessee cannot resist validly initiated reassessment proceedings under this section merely by showing that other income which had been assessed originally was at too high a figure except in cases under section 152(2). The words "such income" in section 147 clearly refers to the income which is chargeable to tax but has "escaped assessment" and the Income- tax Officer's jurisdiction under the section is confined only to such income which has escaped assessment. It does not extend to reconsidering generally the concluded earlier assessment. Claims which have been disallowed in the original assessment proceeding cannot be permitted to be re-agitated on the assessment being reopened for bringing to tax certain income which had escaped assessment because the controversy on reassessment is confined to matters which are relevant only in respect of the income which had not been brought to tax during the course of the original assessment. A matter not agitated in the concluded original assessment proceedings also cannot be permitted to be agitated in the reassessment proceedings unless relatable to the item sought to be taxed as "escaped income ". Indeed, in the reassessment proceedings for bringing to tax items which had escaped assessment, it would be open to an assessee to put forward claims for deduction of any expenditure in respect of that income or the non-taxability of the items at all. Keeping in view the object and ITA Nos.628, 981 & 982, CO 76 of 2008 Page 14 of 17 purpose of the proceedings under section 147 of the Act which are for the benefit of the Revenue and not an assessee, an assessee cannot be permitted to convert the reassessment proceedings as his appeal or revision, in disguise, and seek relief in respect of items earlier rejected or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to escaped income ", and re-agitate the concluded matters. Even in cases where the claims of the assessee during the course of reassessment proceedings relating to the escaped assessment are accepted, still the allowance of such claims has to be limited to the extent to which they reduce the income to that originally assessed. The income for purposes of "reassessment" cannot be reduced beyond the income originally assessed......"
On a careful reading of the observations of the Hon'ble Court, we are of the unanimous view that the AO was within his domain to drop the proceedings initiated u/s 147 of the Act.
22. Before parting with, we would like to make it clear that if the apprehension of the assessee that the same income in two consecutive years were subjected to double taxation, the assessee shall be at liberty to approach the appropriate authorities for redressal under section 264 or 154 of the Act, as the case may be.
ITA NO: 982/2008 - AY 2004-05 [By the assessee]:
23. For this assessment year, the assessee has raised nine exhaustive grounds. On a perusal, we find that the ground Nos:1,2,3,4, 8 and 9 are general in nature and no specific issues involved and, therefore, they are dismissed as non-consequential.
24. With regard to the submission of the assessee to condone the delay in filing the appeal [ground No.7], we would like to point out that the reasons set-out by us in the fore-going paragraph for the immediate ITA Nos.628, 981 & 982, CO 76 of 2008 Page 15 of 17 preceding assessment year hold good for this assessment year too. Thus, the delay in preferring this appeal is condoned and the appeal is admitted for adjudication.
25. The remaining two grounds (Ground Nos: 5 and 6) survived for consideration are reformulated as under:
(i) the authorities below erred in disallowing depreciation of Rs.117263/- on the ground that for the AY 03-04 there was no loss as per the return filed on 1.2.03 and that the proceedings initiated u/s 148 of the Act was dropped and no assessment was made; &
(ii) the authorities erred in assessing the income on the basis of the assessee's consent which is against the spirit of the ruling of the Apex Court reported in 91 ITR 18.
On a cursory perusal of the impugned order of the AO, we find that the AO stated thus, "3. While filing the revised return of income and arriving at the income as per the P & L account as above, the assessee had debited depreciation of Rs.117263/- which was not entitled as per the return of income filed for the AY 2003-04 on 1.12.2001." As no details were available on the records to ascertain the details of depreciation claimed by the assessee and disallowed by the AO, in the interest of natural justice and fair-play, this issue is remitted back on the file of the AO to look into the grievance of the assessee and to take appropriate action in accordance with the provisions of the Act and Rules. While doing so, the AO shall afford a reasonable opportunity to the assessee of bearing heard. It is ordered accordingly.
ITA Nos.628, 981
& 982, CO 76 of 2008 Page 16 of 17
26. The other grievance of the assessee is that the authorities erred in assessing the income on the basis of the assessee's consent which is against the spirit of the ruling of the Apex Court reported in 91 ITR 18. With due respects, we have perused the ruling of the Apex Court referred supra. The highest judiciary of the land had observed that "an admission is an important piece of evidence. But it is not conclusive. It is open to the assessee to show that it is incorrect and the assessee should be given a proper opportunity to show that the account books did not disclose the correct facts". In the issue on hand, we find that the assessee's admission of additional income was voluntary which had not been proved by the assessee to be erroneous. In these circumstances, the reliance placed on the above referred case law is distinguishable and not directly applicable to the facts of the case on hand.
In the result:
(i) the Revenue's appeal for the AY 2002-03 in ITA 628/08 is treated as partly allowed for the statistical purpose;
(ii) The assessee's Cross Objection for the AY 2002-03 in CO No.76/08 is dismissed;
(iii) The assessee's appeal for the AY 2003-04 in ITA No.981/08 is dismissed;
(iv) The assessee's appeal for the AY 2004-05 in ITA No.982/08 is partly allowed for the statistical purposes.ITA Nos.628, 981
& 982, CO 76 of 2008 Page 17 of 17 Pronounced in the open court on this 30th day of November, 2009.
Sd/- Sd/-
( SHAILENDRA KUMAR YADAV ) (A. MOHAN ALANKAMONY )
Judicial Member Accountant Member
Bangalore,
Dated, the 30th November, 2009.
Ds/-
Copy to:
1. Appellant
2. Respondent
3. CIT
4. CIT(A)
5. DR, ITAT, Bangalore.
6. Guard file (1+1)
By order
Assistant Registrar
ITAT, Bangalore.