Income Tax Appellate Tribunal - Bangalore
Adecco India Private Limited, ... vs Deputy Commissioner Of Income Tax, ... on 10 January, 2023
IN THE INCOME TAX APPELLATE TRIBUNAL
"C" BENCH : BANGALORE
BEFORE SHRI N. V. VASUDEVAN, VICE PRESIDENT AND
SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER
IT(TP)A No.998/Bang/2022
Assessment Year : 2018-19
M/s. Adecco India Pvt. Ltd., Vs. DCIT,
B-9 13th Floor, Brigade Metropolis, Circle - 1(1)(1),
ITPL Main Road, Garudachar Palya, Bengaluru.
Mahadevapura,
Bengaluru - 560 048.
PAN : AABCG 3636 Q
APPELLANT RESPONDENT
Assessee by : Shri. Srinivas K. P, CA
Revenue by : Shri. Sreenivas T Bidari, CIT(DR)(ITAT), Bengaluru.
Date of hearing : 04.01.2023
Date of Pronouncement : 10.01.2023
ORDER
Per N. V. Vasudevan, Vice President :
This is an appeal by the assessee against the final order of assessment dated 25.08.2022, passed by the DCIT, Circle - 1(1)(1), National Faceless Appeal Centre (NFAC), Delhi, under section 143(3) read with Section 144C(13) of the Income Tax Act, 1961 (Act) in relation to Assessment Year 2018-19.
IT(TP)A No.998/Bang/2022 Page 2 of 19
2. The assessee is a private limited company incorporated under the provisions of The Companies Act, 1956, in the state of Karnataka. It is engaged in the business of recruitment, placement, temporary staffing and training services to its group companies outside India and unrelated parties in India.
3. The assessee filed its return of income for AY 2018-19 declaring Total Income of Rs. 47,25,17,720/-. The assessee was assessed u/s 143(3) and a draft order dated 29th July 2021 was issued by the AO proposing a Transfer Pricing adjustment of Rs.15,43,89,748/-. A rectification application was filed subsequently on receipt of the TP order. The TP adjustment was reduced to Rs.6,57,21,651/- vide order u/s 92 CA read with section 154 of the Income Tax Act, 1961 dated 1st October 2021. The assessee filed objections to the draft Assessment Order of the AO before the Dispute Resolution Panel ['DRP'] seeking deletion of the proposed transfer pricing adjustment. The DRP, vide its directions dated 28-06-2022 upheld the order of the TPO.
4. The present appeal is preferred against the Transfer Pricing adjustment of Rs. 6,55,13,030/- made by the TPO and adopted by the AO in the final assessment order dated 25.08.2022.
5. The issues in the appeal relates to the adjustment to the arm's length price of the international transactions of the assessee made by the learned TPO and upheld by the DRP. The TPO has made the following adjustments aggregating to Rs.6,55,13,030/-:
IT(TP)A No.998/Bang/2022 Page 3 of 19
a) Rs.5,96,82,063/- relates to adjustment of arm's length price on the service rendered; and
b) Rs.58,30,967/- relates to TP adjustment made on interest on delayed receivables
6. Adjustment to services rendered Rs.5,96,82,063/-:
The assessee provided human resource services to business organizations like temporary staffing, permanent placement, career placement, career transition, outsourcing managed service programs, recruitment process outsourcing and talent development. The assessee provided the above services to its Associated Enterprise (AE). Therefore, in terms of section 92 of the Act, the assessee has to justify that the consideration received by the assessee for services so provided were at Arm's Length. The documentation maintained by the assessee under section 92D of the Act was submitted to the TPO on 26th July 2021 in response to notice issued by the TPO dated 21st July 2021. This documentation contained profile of the Assessee and the group, nature of transactions entered into the Associated Enterprises (AEs), FAR analysis, detailed economic data analysis conducted by the Assesseeon the Prowess database, reasons for selection of Most Appropriate Method ("MAM") and such other information prescribed in Rule 10D of the Income tax Rules, 1962 (hereinafter called 'the Rules').
7. The TPO rejected the TP documentation on the following contentions mentioned in the order:
From the TP study it is seen that the taxpayer has used data available only upto August 31, 2018.
IT(TP)A No.998/Bang/2022 Page 4 of 19 Further in paras 5 and 6, the TPO has given certain general comments regarding "Analysis of TP document" and "Rejection of the taxpayer's TP study.
8. Based on the TP order, the reasons for rejection of the TP documentation is not clear. It is very evident that there are no specific reasons for rejecting the TP documentation submitted by the assessee company. Moreover, the TPO has applied the search process as applicable to ITES segment though the assessee do not operate in that segment at all. Thus, it is clear that the basis for rejection of the TP documentation is factually wrong.
9. The DRP has also upheld the order of the TPO on the basis of wrong understanding of facts as mentioned below:
Para Comments /Directions of the Assessee's objections to the same No. DRP 2.1.1 "The assessee has not applied This is factually wrong since the the employee cost > 25% of Assessee had considered all these total operating cost filter, the filters in the TP documentation.
income from core service > 75% Pages 69-70 of the Paper Book I. of sales filter, export service income > 75% of sales filters and considering companies with different financial year ending (i.e., not March 31, 2016) while making the comparable IT(TP)A No.998/Bang/2022 Page 5 of 19 Para Comments /Directions of the Assessee's objections to the same No. DRP analysis."
2.1.2 The non-application of these The Assessee company had applied filters have resulted in non- all the appropriate filters as compliance to these mandatory specified in Pages 69-70 of the requirements specified in the Paper book 1.
above Rule, and as a result the
comparability analysis is not in
accordance with the
requirements of section 92C
read with Rule 10B
2.1.3 The assessee had not considered Data of the relevant year was
current year data for comparable considered. Pages 69, 72-73 of the analysis Paper Book I.
10. We shall first take up for consideration ground Nos. 2 to 4 raised by the assessee which reads as follows:
2. The learned TPO has erred in making a search for the keywords "ITES", "BPO", "Call Centre", "Medical Transcription", "Computer software", "Business Services & Consultancy" and "Other Consultancy" instead of searching for "Placement & HR Consultancy Service" which is the business of your appellant. The DRP has erred in upholding this view of the TPO.
3. The learned TPO and DRP has grievously erred in ignoring the margin analysis prepared by your Assesseefor its AE exports business and domestic business to unrelated parties. The TPO has grievously erred in applying TNMM on an overall basis at the entity level though detailed workings and supporting documents were made available to the TPO. The DRP has erred in upholding this action of the TPO.
4. The learned TPO has grievously erred in rejecting all the 16 companies selected by your Assesseein its TP documentation IT(TP)A No.998/Bang/2022 Page 6 of 19 maintained u/s 92D as comparable to its business. No reason has been given for exclusion of these companies as comparable.
The DRP has erred in not adjudicating on this matter.
11. As can be seen from ground No.2, the main grievance of the assessee is that the TPO considered the assessee as ITeS company whereas the assessee is only a human resource provider. The TPO has erred in making a search for the keywords "ITES", "BPO", "Call Centre", "Medical Transcription", "Computer software", "Business Services & Consultancy"
and "Other Consultancy" instead of searching for "Placement & HR Consultancy Service" which is the business of the assessee.
12. In this regard, we find that in TP documentation and in the response dated 28th July 2021 to the SCN issued by the TPO it was submitted by the assessee that it is rendering human resource related services. The assessee's primary business is recruitment services and temporary staffing. (Page 16 of the paper book 1). Moreover, the TPO has himself stated so in the order u/s 92CA in page 4 of the order.
13. We also find that the segment applicable to the assessee for TP benchmarking is "Placement services", "recruitment services" etc as done by the assessee in the TP documentation. In fact, the assessee requested the TPO to do a search on Recruitment, Placement services segment which is the most appropriate in its case and accept its bench marking analysis.
14. As per para 9.1 of the Order u/s 92CA, while doing a search on prowess, the TPO had made a search for the following keywords "ITES", IT(TP)A No.998/Bang/2022 Page 7 of 19 "BPO", "Call Centre", "Medical Transcription", "Computer software", "Business Services & Consultancy" and "Other Consultancy" instead of searching for "Placement & HR Consultancy Service". The assessee does not render any services in the nature considered by the TPO as key words. Also, the services rendered by the assessee do not fall under these categories of business as Placement and HR consultancy services is completely different from the business of "ITES", BPOs, call centres etc considered by the TPO.
15. The DRP has also upheld the order of the TPO without giving any specific findings for following the same. The DRP has stated in para 2.2.2 as under:
"We agree with the TPO in considering the assessee is into the field of staffing and HR services and providing back-end support services to its AEs"
16. The assessee does not provide any back-end support services to its AEs. The TPO has also stated that the assessee has rendered "Placement services" or "recruitment services". Even the definition of ITES as per Rule 10A of the Income Tax Rules, 1962 does not include "Placement and recruitments Services". We are therefore of the view that the addition made on account of transfer pricing should be set aside to the AO/TPO for a fresh analysis considering assessee as Placement and HR Consultancy Service provider. The AO/TPO will do a fresh analysis as stated above after due opportunity to the assessee of being heard.
17. The connected grievance of the assessee is that TPO has grievously erred in ignoring the margin analysis prepared by the assessee for its AE IT(TP)A No.998/Bang/2022 Page 8 of 19 exports business and non-AE domestic business to unrelated parties. The TPO has grievously erred in applying TNMM on an overall basis at the entity level though detailed workings and supporting documents were made available to the TPO. The grievance is projected in ground No.3 raised before the Tribunal.
18. In this regard, we find that the assessee had entered into various transactions with its AEs during the year. The Assessee had adopted the MAM applicable for each type of transaction separately as listed out appropriately against the type of transaction as per the documentation maintained under section 92D of the Income tax Act, 1961. The reason for adopting each of the method is given in detail therein. The TPO rejected the ALP determined by the assessee and the MAM adopted by the assessee for each of the transaction and instead adopt TNMM as the MAM for all the transactions entered into with AEs by the assessee.
19. This is a fundamentally faulty way of assessing the Arms' Length Price ("ALP") of the international transactions undertaken by the assessee with AEs since the Revenue transactions with AE constitute only 0.75% of the total "Revenue from Operations" earned by the assessee and expenditure transactions with AE constitute only 0.62% of total expenses incurred. Hence, to apply TNMM on an overall basis at the entity level is against the basic canons of transfer pricing law.
20. The assessee had already furnished to the TPO that the net operating margin analysis of the AE and non-AE segment in the TP documentation. As can be seen from therein, the net operating margins of the AE segment is IT(TP)A No.998/Bang/2022 Page 9 of 19 20.20%. The assessee requested the TPO to consider this instead of looking at the overall margins of the company which includes negligible transactions with AEs.
21. In page 3 of the order, the TPO has computed the net operating margins of the assessee stating that it is "segmental financials of the taxpayer as computed by the TPO". However, the TPO has computed the margins of the assessee at the entity level and not considered the segment margin analysis given by the assessee in the TP documentation nor has computed the segmented margin himself. The TPO had wrongly made transfer pricing adjustment with reference to the total costs incurred / revenue earned by the Company, without considering the facts that it includes substantial revenue and expenses with non-AEs. The TPO then proportionately reduced the adjustment to AE transactions.
22. The TPO has not assigned any reasons in the order for not considering the allocation of expenses done by the taxpayer. Moreover, certain expenses are incurred exclusively for non-AE transactions. It is not appropriate to allocate the same to AE segment also based on turnover since it has nothing to do with the AE business segment.
23. Certified segmental margin analysis was furnished to the Hon'ble DRP during the course of the proceedings before them on 3rd and 10th June 2022. (Pages 3726-3728 of paper book 9). The DRP ignored this and stated that there is no audited segmental data available in para 2.3.4 of the DRP order dated 28th June 2022.
IT(TP)A No.998/Bang/2022 Page 10 of 19
24. The DRP has also stated in para 2.3.3 of its order that "The entire argument of the assessee is theoretical because we will not be in a position to get information about the comparables at transaction level and hence, no comparison can be carried out at the transaction level." The DRP has also stated further in para 2.3.4 that "Even as per TP study of the assessee there is no segregation of profits between the AE transactions and non-AE transactions. The assessee has not computed the margins for the AE transactions which are reliable. Hence it is not possible to arrive at net profits for AE and non-AE transactions separately."
25. These observations of the Hon'ble DRP are factually incorrect as the assessee had filed the net operating margin analysis of the AE and non-AE segment in its documentation maintained u/s 92D of the Income tax Act, 1961. A certified statement of the same was subsequently filed before the Hon'ble Panel on 3rd and 10th June 2022. (Pages 3726-3728 of paper book
9).
26. It is relevant to note the provisions of Rule 10B(1)(e) of the Income Tax Rules, 1962 ('the Rules') which provides for the manner of determination of ALP of an international transaction while applying TNMM that reads as under:
[10B. Determination of arm's length price under section 92C.
(1) For the purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely:
(a).............
IT(TP)A No.998/Bang/2022 Page 11 of 19
(e) transactional net margin method, by which --
(i) the net profit margin realized by the enterprise from an international transaction entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by the enterprise or having regard of any other relevant base;
Clause (i) of Rule 10B(1)(e) of the Rules specifically provides that net profit margin realized by an enterprise from an international transaction is to be computed as the law mandates that whenever TNMM is applied or sought to be applied, as a 1st step the profit margin realized from the international transaction is to be computed. Accordingly, undertaking a companywide analysis of the profitability is not in compliance the provisions of the Income-tax Act, 1961 (the Act). More so when the revenue transactions with AE is less than 1% of total revenue.
27. Further, the guidance from OECD Transfer Pricing Guidance on Multinational Enterprises and Tax Administrations (2017) "3.42 An analysis under the transactional net margin method should consider only the profits of the associated enterprise that are attributable to particular controlled transactions. Therefore, it would be inappropriate to apply the transactional net margin method on a company-wide basis if the company engages in a variety of different controlled transactions that cannot be appropriately compared on an aggregate basis with those of an independent enterprise. Similarly, when analyzing the transactions between the independent enterprises to the extent they are needed, profits attributable to transactions that are not similar to the controlled transactions under examination should be excluded from the comparison. Finally, when profit margins of an independent enterprise are used, the profits attributable to the transactions of the IT(TP)A No.998/Bang/2022 Page 12 of 19 independent enterprise must not be distorted by controlled transactions of that enterprise."
28. Hence, the guidance from the Indian legislation on transfer pricing as well as the global guidance on transfer pricing, which is followed by several countries, voices out the same principle of benchmarking only the profitability of the international transactions and not the profitability of the whole company.
29. The Hon'ble Mumbai High Court in the case of CIT vs. Thyssen Krupp Industries India Pvt. Ltd. [2016] 70 taxmann.com 329 (Bombay), wherein the Hon'ble High Court observed as under:
"....... We find that in terms of Chapter X of the Act, re-determination of the consideration is to be done only with regard to income arising from International Transactions on determination of ALP. The adjustment which is mandated is only in respect of International Transaction and not transactions entered into by assessee with independent unrelated third parties. This is particularly so as there is no issue of avoidance of tax requiring adjustment in the valuation in respect of transactions entered into with independent third parties. The adjustment as proposed by the Revenue if allowed would result in increasing the profit in respect of transactions entered into with non- AE. This adjustment is beyond the scope and ambit of Chapter X of the Act."
30. Likewise, the Hon'ble Co-ordinate Bench, Bangalore, in the case of Genisys Integrating Systems (India) Pvt. Ltd. vs. DCIT [2012] 20 taxmann.com 715 (Bang - Trib.) and several other judgements have also explicitly held that while determining the ALP, transfer pricing adjustments should be restricted to only international transactions between AEs, and observed as under:
IT(TP)A No.998/Bang/2022 Page 13 of 19 "...... Chapter-X of IT Act relates to special provisions relating to avoidance of tax and sec.92 therein relates to computation of income from international transactions having regard to ALP. Thus, it can be seen that only international transactions between the associated enterprises either or both of whom are non-resident are to be computed having regard to ALP. This issue is also covered by the decisions relied upon by the learned counsel for the assessee. Accordingly, the AO is directed to make the transfer pricing adjustments by restricting the adjustments to the transactions of the AE only by adopting the operating revenue and operating costs of these transactions only."
31. Similar views have been expressed by:
a. The Hon'ble Mumbai High Court in the case of CIT vs. Hindustan Unilever Ltd. [2016] 72 taxmann.com 325 (Bombay);
b. The Hon'ble Tribunal, Hyderabad Bench, in the case of Alumeco India Extrusion Ltd. vs. ACIT [2013] 38 taxmann.com 371 (Hyderabad - Trib.) and c. The Hon'ble Tribunal, Delhi Bench, in the case of Cornell Overseas Pvt. Ltd. vs. DCIT
32. The assessee had furnished the net operating margin analysis of the AE and non-AE segment in pages 67-68 of the TP documentation. As can be seen from therein, the net operating margins of the AE segment is 20.20%. (Pages 112-113 of Paper book 1). There was no reason for the TPO to look at the overall margins of the company which includes substantial transactions with non-AEs and to make a transfer pricing adjustment with reference to the total costs incurred / revenue earned by the Company, which includes considerable expenses and sales with non-AEs. This is factually wrong. It may also be noted that the AO has not assigned any reasons for ignoring the margin analysis and allocation of expenses of AE and non-AE segment furnished by the appellant. The AO has also not IT(TP)A No.998/Bang/2022 Page 14 of 19 stated as to why he had redone the margin analysis by allocating all expenses on turnover basis rather than accept the basis of allocation followed by the assessee.
33. For the reasons stated above, we allow ground No.3 raised by the assessee and direct the AO/TPO to consider the margin analysis as provided by the assessee relating to AE segment alone. In view of the decision on ground Nos.2 and 3, grounds 4 to 20 raised by the assessee become academic and hence not adjudicated.
Grounds 21-24: Interest on delayed receivables Rs.58,30,967/-
34. The grievance of the assessee on Grounds 21 to 24 is that the TPO has grievously erred in computing interest of Rs.9,18,58,103/- which was subsequently reduced to Rs.31,90,006/- vide TPO order dated 01/10/2021 on delayed trade receivables. This was further increased to Rs.58,30,967/- by the TPO while giving effect to the order of the DRP by not netting off amount due as payables to AE though this was done in the order u/s 92CA dated 29th July 2021. The TPO held that delay in realizing the receivables from the AE is one form of shifting profits from India and was an international transaction and ALP has to be computed for such delay in realization of receivables from the AO. The TPO computed interest on delayed receivables in the following manner:
"25.2 The taxpayer has furnished the details of receivables realised during FY 2017-18. On perusal of the details, it is noticed that the taxpayer is contending that the bills have been realised within 180 days. However, the TPO is of the opinion that in a normal course of business, such long delayed payments are not allowable IT(TP)A No.998/Bang/2022 Page 15 of 19 and the credit period has been restricted to 30 days. The interest on delayed receivables has been recomputed by allowing 30 days of credit and for the balance period, interest is calculated, using the rate of interest as discussed paragraph 23.20 above. The detailed computation is as follows:
Amounts in Rs. 31.03.2018 31.03.2017
Receivables from AEs (A) 1,793,909,031 1,610,029,625
Payable due to AEs (B) 204,927,166 152,308,234
Net receivables (C=A-B) 1,588,981,865 1,457,721,391
Average Net receivables 1,523,351,628
Interest Rate 6.57%
Period of delay (days) 335
Interest Amount 91,858,103
Thus, arm's length interest amount to be charged works out to be Rs. 91,858,103/-. The same is treated as adjustment u/s 92CA for interest on delayed receivables."
The DRP confirmed the correctness of the action of the TPO.
IT(TP)A No.998/Bang/2022 Page 16 of 19
35. Before the Tribunal, the learned counsel for the assessee submitted that the TPO and DRP ignored the plea of the assessee that the weighted average collection period for the year was 55 days. It was also submitted that the assessee does not agree with the following facts considered by the TPO and upheld by the DRP:
Sl Facts modified by the Our Objections No TPO 1 Wrong number of days Without prejudice to the submission
considered as period of that no adjustment is required, it was delay submitted to the TPO that the weighted average collection period was only 55 days. Hence, the delay of 335 days as computed by the TPO is wrong.
2 Wrong rate of interest Without prejudice to the submission considered that no adjustment is required, the DRP had held that interest has to be computed at rates applicable for short term deposits.
In the view of the appellant, six months USD LIBOR plus 200 basis points will be an appropriate rate that can be considered for computation of interest. This works out to only 3.318%. The TPO has not given any workings for the interest computation of Rs.58,30,967/- computed by him in the OGE order to DRP directions.
36. It was contended that the TPO has wrongly applied an allowable credit period of 30 days for the assessee. The generally accepted credit period in the absence of agreed credit period is 90 days and this norm has IT(TP)A No.998/Bang/2022 Page 17 of 19 been overlooked. It was contended that as per Rule 10CB of the Income tax Rules, 1962, the allowable time limit for repatriation of excess money or part thereof on primary TP adjustment is 90 days and hence there is no basis for the TPO to consider 30 days as normal credit period. Though arguments were advanced that delay in realization of receivables does not give raise to a separate international transactions, we find that the law is by now settled that it is an international transaction and separate benchmarking has to be done in this regard and this aspect was agreed by the parties in Court. We therefore do not wish to set out the submissions made in this regard by the parties.
37. In the order u/s 92CA dated 29th July 2021, the TPO had computed interest on the net receivables (i.e., receivables from AE less payables to AE). However, in the OGE order to the DRP directions, the TPO has computed interest on delayed receivables from AE without considering the amount payable to AE. This has resulted in enhancing the levy of interest from Rs.31,90,006/- vide TPO order dated 01-10-2021 to Rs.58,30,967/- vide OGE order dated 22-07-2022 (Pages 165-167 of the appeal petition) based on which the AO has passed the final assessment order. This is prima facie wrong to look at transactions on a standalone basis instead of looking at the full picture. The details of the same were filed with the TPO during DRP OGE proceedings vide submissions dated 18-07-2022 enclosed in Pages 3745-3764 of Paper book 9. This has been ignored by the TPO. We are of the view that the computation has to be made on the net amount i.e, excess of receivables over payables. We hold and direct accordingly.
IT(TP)A No.998/Bang/2022 Page 18 of 19
38. We are also of the view that the adoption of SBI short term deposit rates as done by the revenue has not been approved in several decisions of the ITAT and it is only the LIBOR rate that has to be applied. In addition to the LIBOR rate, based on the credit rating appropriate percentage points towards credit risk alone can be added. The TPO should re-compute interest on delayed receivables based on the correct parameters for average collection period and rate of interest as give above. The issue is accordingly set aside to TPO/AO.
Ground 25: Disallowance of belated remittance of ESI / PF
39. A sum of Rs.17,90,490/- relates to disallowance of belated remittance of ESI/PF dues disallowed by CPC vide its order dated 23-12-2019. The AO following the total income computed by CPC determined the total income in the order passed u/s.143(3) of the Act. Against the said addition the assessee has raised ground No.25 before the Tribunal. The impugned disallowance has been made u/s.36(1)(va) of the Act. On the above issue, it is not disputed that as per the decision of the Hon'ble Supreme Court rendered in the case of CHECKMATE SERVICES PVT LTD VS CIT-1 in CIVIL APPEAL 2833/2016 vide its judgment dated 12 October 2022 decided the issue on allowability/treatment of 'delayed' Employee PF Contribution payment in hands of assessee under provisions of Income Tax Act and held that Section 36(1)(va) and Section 43B(b) operate on totally different equilibriums and have different parameters for due dates, i.e., employee's contribution is linked to payment before the due dates specified in the respective Acts and employer's contribution is linked to the payment before the prescribed due date for filing of return u/s. 139(1) of Income Tax Act, 1961.The result of IT(TP)A No.998/Bang/2022 Page 19 of 19 any failure to pay within the prescribed dates also leads to different results. In the case of employee's contribution, any failure to pay within the prescribed due date under the respective PF Act or Scheme will result in negating employer's claim for deduction permanently forever u/s.36(1)(va). On the other hand, delay in payment of employer's contribution is visited with deferment of deduction on payment basis u/s.43B and is therefore not lost totally. Therefore, as per the above decision, the disallowance made by the Revenue authorities, were fully justified. Accordingly, Grd.No.25 is dismissed.
40. In the result, appeal of the assessee is partly allowed.
Pronounced in the open court on the date mentioned on the caption page.
Sd/- Sd/-
(CHANDRA POOJARI) (N. V. VASUDEVAN)
Accountant Member Vice President
Bangalore,
Dated: 10.01.2023.
/NS/*
Copy to:
1. Appellants 2. Respondent
3. CIT 4. CIT(A)
5. DR 6. Guard file
By order
Assistant Registrar,
ITAT, Bangalore.