Income Tax Appellate Tribunal - Hyderabad
Dcit, Circle-17(1), Hyd, Hyderabad vs Devgen Seeds & Crop Technology ... on 24 March, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCH "A", HYDERABAD
BEFORE SMT P. MADHAVI DEVI, JUDICIAL MEMBER
AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER
ITA No. 399/Hyd/2016
Assessment Year: 2011-12
Dy. Commissioner of Income- vs. Devgen Seeds & Crop
tax, Circle - 17(1), Hyderabad. Technology Pvt. Ltd.,
Secunderabad.
PAN - AACCD 5732 D
(Appellant) (Respondent)
Revenue by : Shri P. Chandra Sehkar
Assessee by : Shri K.R. Vasudevan &
Shri Ujjwal Tiwari
Date of hearing 30-01-2017
Date of pronouncement 24-03-2017
O RDE R
PER S. RIFAUR RAHMAN, A.M.:
This appeal is preferred by the Revenue against the order passed u/s 143(3) r.w.s. 92CA(3) and 144C(5) of the Income Tax Act, 1961 (in short 'Act') dated 25/01/2016 relating to AY 2011-12.
2. The assessee company is engaged in the business of agricultural operations i.e. cultivation of land, sowing, irrigation, production and sale of seeds grown primarily through conventional agricultural operations and trading of seeds. The assessee filed its return of income for the AY 2011-12 on 20/11/2011 admitting loss of Rs. 28,81,87,828/-. The return was processed u/s 143(1) accepting the income returned by the assessee. Subsequently, the case was selected for scrutiny under CASS and, accordingly, notice u/s 143(2) of the Act was issued. Since the assessee was involved in the international transaction in excess of Rs. 15 crores, the case was 2 ITA No. 399/H/16 Devgen Seeds & Crop Technology P. Ltd.
referred to Additional Director of Income-tax (Transfer Pricing), Hyderabad after getting approval from Commissioner of Income Tax - I, Hyderabad.
2.1 As per 3CEB report/TP document, the international transactions reflected are as under:
AE Nature of transaction Amount
Devgen Interest paid on fully
Singapore convertible debentures 68,00,000
Devgen Interest paid on External
Singapore Commercial Borrowings 89,35,357
Devgen Issue of share capital 20,00,00,000
Pte Ltd.
2.2 Examination of TP study conducted by tax payer
The taxpayer has carried out the economic analysis and has summarized it as under:
Nature of Amount MAM PLI Margin Margin of
international of compara
transaction taxpayer bles
Interest paid on 68,00,000 CUP NA NA NA
fully convertible
debentures
Interest paid on 89,35,357 CUP NA NA NA
External
Commercial
Borrowings
Issue of share 20,00,00,000 Valuation as per CCI Guidelines
capital
2.3 Analysis of the transactions:
As per the audited statement of accounts the financials of the taxpayer are as under:
Description Amount (Rs.)
Operating 585,253,806
Revenue
Operating cost 888,484,694
Operating Profit -303,230,888
OP/OC -51.81
OP/OR -34.13
3
ITA No. 399/H/16
Devgen Seeds & Crop Technology P. Ltd.
TPO has made 'ALP' adjustment on the payment of interest on
a) Fully Convertible Debentures (FCD)
b) External Commercial Borrowings (ECB) 2.4 Interest on Fully convertible Debentures (FCD):
During the TP proceedings, the assessee submitted that assessee has issued 1.7 crore unsecured fully convertible debentures (FCD) of Rs. 10/- each, aggregating Rs. 17 crores to Devgen Singapore for a maximum period of 15 years. Based on the terms of FCD's, fixed interest rate of 4% for years 1 and 2, then 12% from 3 to 5 would be payable. Interest rate for year 6 to 15 would be on a mutually agreed basis. It is also resolved that after a maturity period of 5 years or after mutually agreed period thereupon upto a maximum of 15 years from the date of issue, equity shares of Rs. 10 each be offered/issued to the holders of FCD in the ratio of 1:1. The assessee submitted that it has paid interest on FCD to Associate Enterprise (AE) at a simple average rate of interest of 8.8% per annum. The amount of interest rate paid has not been discounted to determine its present value. For the purpose of bench marking at this rate, the assessee had relied on the independent search conducted in Prowess database in FY 2009-10 as the terms and conditions of the arrangement remains the same. Based on the search conducted, the average rate of interest paid by the 2 broadly identified comparable independent companies, ranges from 6.78 percent to 12 percent with an arithmetical mean of 9.39 percent. Also the prime lending rate (PLR) for the same period ranges from 8.91 percent to 9.91 percent.
Since the average rate of interest paid by the assessee to AE is less than the average interest rate paid by independent companies and the average PLR rate, hence, the interest paid by the assessee is within the arm's length price.
2.5 The TPO observed that the taxpayer paid interest of 4% during this AY to AE on FCD and the contention of the assessee cannot be accepted because average rate of interest payable to AE is 8.8% for 5 years, this figure was arrived at by the assessee after taking average 4 ITA No. 399/H/16 Devgen Seeds & Crop Technology P. Ltd.
rate of interest to be paid during the 5 years. However, no such averaging is allowed as transaction is to be taken year on year basis. The TPO further observed that the assessee paid interest of 4%, which is required to be compared with LIBOR/SIBOR under CUP. The average one year SIBOR during the year ranged from 0.78 to 0.94 and the average of which works out to 0.86% which is much less than the interest paid by the taxpayer, necessitating adjustment. He observed that various judicial forums have held that for international loan transaction LIBOR is appropriate CUP. A few of them are Four Soft Ltd., Quark Systems Ltd., Dr. Reddy, Aurobindo etc. by ITAT, Hyderabad Benches. All the courts have generally held a mark-up of 200 basis points to be reasonable. Accordingly, the TPO worked out the ALP of interest on FCD as under:
Interest @ 4% on Rs. 17,00,00,000 Rs. 68,00,000 Interest @ Sibor + 200 bp (0.86+2 = 2.86) Rs. 48,62,000 Excess paid Rs. 19,38,000 Accordingly, TPO made the "ALP" adjustment to the extent of Rs. 19,38,000/-.
2.6 Interest paid on External Commercial Borrowings (ECB):
During FY 2008-09, the assessee borrowed sum aggregating SGD 24.3 million from Devgen, Singapore. The agreement was entered into on December 15, 2008 and duration of the agreement is till July 15, 2014. The loan was borrowed at a fixed interest rate 5.94 percent per annum, which was determined at 3 months SIBOR + 500 basis points at the date of disbursement of loan i.e. 2 nd February, 2009. For the purposes of this borrowing, assessee falls under automatic approval route prescribed by the ECB/FCCB guidelines, the above borrowing has been permitted by the RBI and has been allotted a loan registration No. 2008709 vide approval No. DSIM/BPSD/4886/04.61.19/2008-09.5 ITA No. 399/H/16
Devgen Seeds & Crop Technology P. Ltd.
2.7 The assessee submitted before the TPO that assessee has compared ECB interest rate 5.94% against LIBOR. The same was explained in assessee's TP Memorandum in para 5.2 (refer page 227 of paper book - II). Based on the TP Memorandum, the assessee considered the payment of interest on arm's length as the interest rate charged during FY 2010-11 is lower than the LIBOR. Further, assessee submitted that all the terms and conditions of the loan are within the regulatory framework laid down by RBI and the amount paid in respect of interest on the loan appears to be consistent with the arm's length principle.
2.8 The assessee further submitted that based on the corroborative approach as explained in TP Memorandum, interest on ECB at three years average effective rupee cost of 8.72% is lower than the average range of PLR 8.91 to 9.91 percent.
2.9 The TPO observed that the assessee paid an interest of 5.94% during FY under consideration to its AE. The assessee further stated Assessee's interest on ECB at 3 years average effective rupee cost of 8.72% is lower than the average range of PLR 8.91 to 9.91 per cent.
The interest to be paid on external commercial borrowing should be compared with the PLR prevailing in the country which extended the loan and not the India's PLR. The issue has been considered. Various judicial forums have held that for international loan transaction LIBOR is appropriate CUP. A few of them are Four Soft Ltd., Quark Systems Ltd., Dr. Reddy, Aurobindo etc., by Hyderabad ITAT. All the courts have generally held a mark-up of 200 basis point to be reasonable. However, during the year under consideration, the assessee paid interest of 5.94% which is higher than the 3 month Sibor rate. The 3 month Sibor rates during the year ranged from 0.44% to 0.63% with an average of 0.50%, necessitating adjustment. Accordingly the Arm's Length Price of interest on ECB is worked out as under:
Interest @5.94% on loan taken = Rs.89,35,357 Interest @ Sibor+200 bp (0.50+2=2.50) =Rs.37,60,672 6 ITA No. 399/H/16 Devgen Seeds & Crop Technology P. Ltd.
Excess paid =Rs.51,74,685 Accordingly, TPO made "ALP" adjustment of Rs. 51,74,685/-.
3. Aggrieved with the above order, the assessee preferred an appeal before the DRP.
4. As regards the interest on ECB, the DRP observed that adjustment on payment of interest of Rs. 51,74,685/- forming a view that when the interest paid to the bank (which can be considered as internal CUP) is at 11.7%, the payment of interest @ 5.94% for AY 2011-12 is reasonable and to be considered at arm's length and also considered the fact that assessee has not incurred any potential loss by borrowing money from AE.
4.1 As regards, interest on FCB, the DRP deleted the interest adjustment of Rs. 19,38,000/- holding that the interest paid for the AY at 4% is much less than the interest charged by independent bank in respect of working capital loss. Further, the DRP has relied on the decision of ITAT Bangalore bench in the case of M/s Logix Micro Systems Ltd. ( ITA No. 524/Bag/2009) wherein it was held that interest at 5% to be considered to be arm's length with regard to receivables from foreign AEs.
5. Aggrieved with the above order, the revenue is in appeal before us raising the following grounds of appeal:
"1. The order of DRP is erroneous both in law and facts of the case.
2. The DRP erred in deleting the adjustment made on interest on ECB/FRD without properly appreciating the facts as to why the interest rate is taken as LIBOR/SIBOR."
6. Ld. DR submitted that the assessee has borrowed ECB/FRD from its AEs since it is an international transaction, the interest has to be paid based on LIBOR/SIBOR. He substantiated the findings of the TPO in his order and submitted that various judicial pronouncements given by the Hon'ble ITAT, Hyderabad that for receiving interest from 7 ITA No. 399/H/16 Devgen Seeds & Crop Technology P. Ltd.
its AEs, bench marking was already done in various cases that it should be LIBOR + 200 basis points. The assessee has adopted rate of 4% without any basis in the case of FRD and LIBOR + 500 basis points on ECB. He further submitted that the bench marking has to be on international level and he objected to the bench marking considering the domestic interest rate. He submitted that DRP is not justified giving relief to assessee taking bench mark on domestic interest rate. He vehemently argued that adoption of SIBOR + 500 basis points is factually incorrect and he relied on the findings of TPO. Ld. DR relied on the order of ITAT Delhi Bench in the case of Brahma Center Development (P) Ltd. Vs. ITO, [2016] 72 Taxmann.com 304.
7. The ld. AR, on the other hand, submitted that the assessee has already submitted that TP Memorandum before the TPO and it had bench marked the interest rate based on LIBOR/SIBOR. He submitted that ECB and FRD are for a period of 5 years and above. Ld. AR brought to our notice the TP Memorandum (refer pages 212 to 228). Further, ld. AR submitted that as per the RBI guidelines, loan with average maturity period of 3 years and upto 5 years cost ceiling over 6 months LIBOR is 300 basis points. For the average maturity period of loan more than 5 years, the cost ceiling over 6 months LIBOR is 500 basis points. He submitted that in the given case, the assessee has borrowed the loan from its AEs for a period of 5 years and above, the payment of interest to its AEs is within the RBI guidelines. He further submitted that the banks to lend the money, will consider the terms and conditions of the loan, such as, tenure, seniority, security, call/put option, credit quality of the borrower, market in which the loan is extended etc., which are crucial factors in determination of the interest rate. The pricing/fixing of the interest rate by the banks are depending on the security risk and tenure of the loan. For bench marking with the given case, it has to be determined based on the level playing field adopted by the banks. Accordingly, spread of 500 8 ITA No. 399/H/16 Devgen Seeds & Crop Technology P. Ltd.
basis points is as per the international guidelines as well as the Master Circular on ECB by RBI.
7.1 Ld. AR relied on the following cases:
1. Tech Mahindra Ltd. Vs. DCIT, ITA No. 1176/Mum/2010
2. Tricom India Ltd., ITA No. 322/Mum/2014
3. Apollo Tyres Ltd. Vs. ACIT, ITA No. 616/Coch/2011
4. M/s Aithent Technologies Pvt. Ltd., ITA No. 3647/Del./2007
5. M/s Siva Industries & Holdings Ltd. Vs. ACIT, ITA No. 2148/Mds/2010.
6. M/s Cotton Natuals (I) Pvt. Ltd. Vs. DCIT, ITA No. 5855/Del./2012.
7. Vijay electrical Ltd. Vs. Addl. CIT, ITA No. 1140 & 1159/Hyd/2013.
8. Tooltech Global Engineering Pvt. Ltd. Vs. DCIT, ITA No. 273/PN/2014
9. TTK Prestige Ltd. Vs. ACIT, ITA No. 1257/Bang./2011
10. Kohinoor Foods Ltd., Vs. ACIT, ITA No. 3688 to 3691/Del/2012.
8. In the rejoinder, ld. DR submitted that assessee has not submitted any document in support of adopting 500 basis points before the TPO. The TPO has adopted 200 basis points relying on the case laws, which were before him.
9. Considered the rival submissions and perused the material facts on record as well as the decisions cited. While passing the order, the AO/TPO relied on the following decisions of the ITAT, Hyderabad.
9.1 M/s Four Soft Ltd., Vs. DCIT, ITA No. 1495/Hyd/2010 for AY 2006-07, order dated 9 th September, 2011. The coordinate bench in this case has held as under:
"19. We have considered the rival submissions and perused the materials available on record. We do not find any merit in the arguments of the learned departmental representative as we find that the ALP is to be determined for the international transaction, that is, on international loan and not for the domestic loan. Hence, the comparable, in respect of foreign currency loan in the international market, is to be LIBOR based which is internationally recognised and adopted. In our considered view, the DRP rightly directed the assessing officer to adopt the LIBOR plus for the purpose of TP adjustment. Our view is fortified by the decision of the Madras Bench in the case of Siva Industries [supra]. We do not find any merit in the arguments of the learned counsel for the assessee that the DRP should have adopted the EURIBOR for the purpose of the 9 ITA No. 399/H/16 Devgen Seeds & Crop Technology P. Ltd.
TP adjustments, as we find that the mostly used and recognised benchmark rate for international loan is LIBOR based. Hence, the DRP rightly directed the assessing officer to adopt the LIBOR rates. We confirm the directions of the DRP."
9.2 Aurobindo Pharma Ltd. Vs. ACIT, [2014] 42 Taxmann.com 556 (Hyd. In this case, the coordinate bench has held as under:
4.3 We have considered the issue and examined the facts. With reference to principle that LIBOR + specific percentage points is to be considered as ALP, there is no dispute as this issue was decided by various coordinate benches of Tribunal in various cases.
Few of them are as under:
4.4 In the case of Siva Industries & Holdings Ltd. 46 SOT 112 (Chennai) held that "A perusal of the order of the TPO clearly shows that the assessee had raised the funds by way of issuance of 0 per cent optional convertible preferential shares. Thus it is noticed that the funds raised by the assessee company for giving the loan to India Telecom Holdings Ltd., Mauritius, which is its Associated Enterprises and which is the subsidiary company, is out of the funds of the assessee company. It is not borrowed funds. The assessee has given the loan to the Associated Enterprises in US dollars. The assessee is also receiving interest from the Associated Enterprises in Indian rupees. Once the transaction between the assessee and the Associated Enterprises is in foreign currency and the transaction is an international transaction, then the transaction would have to be looked upon by applying the commercial principles in regard to international transaction. If this is so, then the domestic prime lending rate would have no applicability and the international rate fixed being LIB OR would come into play. In the circumstances, we are of the view that it LIB OR rate which has to be considered while determining the arm's length interest rate in respect of the transaction between the assessee and the Associated Enterprises. As it is noticed that the average of the LIB OR rate for 1-4-2005 to 31-3-2006 is 4.42 per cent and the assessee has charged interest at 6 per cent which is higher than the LlBOR rate, we are of the view that no addition on this count is liable to be made in the hands of the assessee. In the circumstances, the addition as made by the Assessing Officer on this count is deleted".
4.5 In the case of CIT Vs. Tech Mahindra Ltd. 46 SOT 141 (Mum) tribunal held that "
When there is a choice between the interest rate of a currency other than the currency in which transaction has taken place and the interest rate in respect of the currency in which transaction has taken place, in our considered view, the latter should be adopted. In Siva Industries & Holdings Ltd.'s case ( supra ), co-ordinate Bench was making a choice between the PLR (Prime Lending Rate in India) and the LIB OR (London Inter Bank Offered Rate). The co-ordinate Bench held that "once the transaction between the assessee and the Associated Enterprises is in foreign currency and the transaction is an international transaction, then the transaction would have to be looked upon by applying the commercial principles in regard to international transactions", and accordingly proceeded to take into account interest rate in terms of LIBOR basis. We have adopted the same approach by taking into account the commercial principles and practices with regard to a US Dollar denominated extended credit for arriving at the benchmark rate, and take LIB OR as the base. Accordingly, the LIBOR (US Dollar) has to be as benchmark for US Dollar transactions - rather than the rate of interest on domestic borrowings, even which is lower than the interest rate of
10 per cent taken as ALP by the TPO, or, for that purpose, rate of interest on any other currency loans."
10 ITA No. 399/H/16Devgen Seeds & Crop Technology P. Ltd.
4.6 In the case of M/s Four Soft Ltd Vs DCIT Circle-l(3), Hyderabad, ITA No. 1495/Hyd/2010 tribunal held that "We have considered the rival submissions and perused the materials available on record. We do not find any merit in the arguments of the learned departmental representative as we find that the ALP is to be determined for the international transaction, that is, on international loan and not for the domestic loan. Hence, the comparable, in respect of foreign currency loan in the international market, is to be LIBOR based which is internationally recognized and adopted. In our considered view, the DRP rightly directed the assessing officer to adopt the LIB OR plus for the purpose of TP adjustment. Our view is fortified by the decision of the Madras Bench in the case of Siva Industries".
4.7 Similar view has been taken in the case of Tata Auto comp Systems Limited vs. ACIT, ITAT Mumbai, ITA NO. 7354/MUM/11(A. Y. 2007-08).
4.8 On the legal principles there is no dispute that LIBOR specific percentage points has to be considered as ALP. There is also no basis, as rightly observed by the DRP, to adopt corporate bonds rate at 17.26%. Therefore, in principle we agree with Assessee's contentions that libor + percentage points is to be accepted. However, it is seen from the details furnished at page 91 of paper book, few of loans provided in AY 2003-04 and 2004-05 in the case of Arubindo and Arubindo Farmo industria Farmaceutica Ldta and loans obtained from Axis bank and Federal Bank where the rate of interest paid was LIBOR +2.1% and LIBOR +3.25%. On these loans Assessee seems to have advanced at LIBOR +3% to Aurbindo whereas rate of interest received in Aurobindo Farmo industria Farmaceutica LTDA is 13.06%. Therefore, to the extent of advances which were given at a rate lesser than the rate at which those are obtained, the AO is directed to examine and if so, the rate of interest paid should be considered as ALP in order to determine the interest received. With these directions, this ground considered partly allowed.
9.3 In the case of Dr. Reddy's Laboratories Ltd. Vs. Addl. CIT, [2014] 48 Taxmann.com 374 (Hyd.), the coordinate bench has held as under:
"11. We have considered the rival contentions. Since the assessee has accepted 7 per cent. in the earlier years. The Tribunal felt that 7 per cent is reasonable and accordingly LIBOR linked interest was not considered. The issue in Four Soft Ltd. (supra) relied upon by the assessee is not about bank interest rate or fixed deposit interest rate. The issue contested was rate of LIBOR, the actual LIBOR rate as per the assessee was 4-l2 per cent whereas the Dispute Resolution Panel has taken LIBOR at 5.7 per cent. The Tribunal has directed the Assessing Officer to examine the correct rate of LIBOR and adopt LIBOR + rate in that case. There are other judgments also where 6 per cent. interest received was considered as LIBOR + 157 base points, so, 7 per cent interest rate approved would be about LIBOR + 257 base points. The co-ordinate Benches are approving on different factual situation, LIBOR + I per cent to 3 per cent and considering that, we also feel that 7 per cent rate is reasonable which is equivalent to LIBOR + 2 per cent. Be that as it may, since the assessee has accepted 7 per cent in the earlier year and that is the basis for directing to adopt 7 per cent by the Tribunal, we do not see any reason to modify the directions of the Tribunal in this regard. Accordingly, this contention of the assessee is rejected."11 ITA No. 399/H/16
Devgen Seeds & Crop Technology P. Ltd.
9.4 From the above judicial pronouncements, the coordinate bench has adjudicated that in respect of foreign currency loan in the international market, the LIBOR based interest has to be adopted. In the case of Four Soft and Aurobindo (supra), the coordinate bench has only adjudicated that LIBOR based interest alone are to be considered for "ALP adjustment not the domestic PLR. In the case of Dr. Reddy Labs (supra), the coordinate bench has only confirmed the interest rate already accepted by the assessee at 7%, which was considered to be reasonable. Nowhere, it was adjudicated that the bench marking of interest at LIBOR + 200 bps. Moreover, all the interest rates were received by the assessee for making investment in AEs, in the given case, assessee had borrowed the loan and paid the interest. The bench marking has to be done keeping in mind the internal as well as external "CUP".
9.5 After careful analysis of the judicial pronouncements and RBI guidelines, we are of the view that the assessee has borrowed the loan from its AEs in terms of FCD and ECB. For the purpose of "FCD", the bench marking has to be done considering the internal as well as external "CUP". Obviously, the interest charged is better than internal "CUP". The external "CUP" are the rates available in the international market. The assessee has already submitted that the LIBOR rate at that point of time was 1.24% with the spread of 500 bps, it comes to 5.24%, which is less than 4% charged by the assessee. With regard to ECB, the bench marking has to be done on External "CUP" at the rate available in the international market. The assessee has already considered this aspect and compared the LIBOR and SIBOR rates at that point of time and considered the SIBOR based rate with 500 bps is favourable to the assessee. Accordingly, the assessee has adopted SIBOR + 500 bps as the ALP.
9.6 The ld. DR has vehemently put forth his argument for adopting 500 bps instead of adopting 200 bps as adopted by TPO. We found that there is no basis for adopting one spread of 200 bps in the judicial pronouncement nor it is prudent in the banking sector. In our 12 ITA No. 399/H/16 Devgen Seeds & Crop Technology P. Ltd.
considered view, we cannot adopt the 200 bps as universal rate for all types of loan. The loans are categorized as long term and short term i.e. working capital loan. We observe that the banks are adopting the 200 bps on working capital loans as spread and higher rates beyond 500 bps on the long term loans such as term loans. The Pricing of Interest on term loans are determined based on the security, net worth, ratings, term of loan etc. The more risk involved, the pricing decision of the banks will change. The RBI in its prudential norms has given windows for the pricing of interest and the spread. Based on the RBI guidelines, the term up to 5 years, can have spread of 300 bps and beyond 5 years, it can be 500 bps. Taking the clue from this guideline, we can come to understand that the assessee has properly allowed its AEs to adopt the spread of 500 bps. In our considered view, the relevant issue is to charge the interest on international transaction based on the LIBOR or any other rates which are the basis for negotiation between the contracting parties and the rates of interest or spread cannot be the same for all the international loans irrespective of their terms, risk etc.
10. In view of the above discussion, we find no infirmity in the order of the DRP in deleting the adjustment made on interest on ECB/FRD and accordingly, we uphold the order of the DRP and dismiss the grounds raised by the revenue.
11. In the result, appeal of the revenue is dismissed.
Pronounced in the open court on 24 th March, 2017.
Sd/- Sd/-
(P. MADHAVI DEVI) (S. RIFAUR RAHMAN)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Hyderabad, Dated: 24 th March, 2017
kv
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ITA No. 399/H/16
Devgen Seeds & Crop Technology P. Ltd.
Copy to:-
1) ACIT, Circle - 17(1), 9 th Floor, Signature Towers, Kondapur, Hyderabad.
2) M/s Devgen Seeds and Crops Technology Pvt. Ltd., Surya Towers, 105, SP Road, Hyderabad.
3) DRP, Bangalore.
4 CIT - 5, Hyderabad
5) The Departmental Representative, I.T.A.T., Hyderabad.
6) Guard File