Income Tax Appellate Tribunal - Hyderabad
Pcr Developers Pvt.Ltd, Hyderabad vs Dcit, Circle-16(3), , Hyderabad on 23 February, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCH "B", HYDERABAD
BEFORE SMT P. MADHAVI DEVI, JUDICIAL MEMBER
AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER
ITA Nos. 676 & 677/Hyd/2011
Assessment Years: 2006-07 and 2007-08
M/s PCR Developers (P) Ltd., vs. Dy. Commissioner of Income-
Hyderabad. tax, Circle - 16(3),
Hyderabad.
PAN - AADCP 6653J
(Appellant) (Respondent)
ITA No. 753/Hyd/2014
Assessment Year: 2007-08
Dy. Commissioner of Income- vs. M/s PCR Developers (P) Ltd.,
tax, Circle - 16(3), Hyderabad. Hyderabad.
PAN - AADCP 6653J
(Appellant) (Respondent)
Assessee by : Shri S. Rama Rao &
Shri D. Satyanarayana
Revenue by : Smt. U. Mini Chandran
Date of hearing 24-01-2017
Date of pronouncement 23-02-2017
O RDE R
PER S. RIFAUR RAHMAN, A.M.:
The two appeals filed by the assessee are against the orders of CIT(A) with regard to appeal against 143(3) assessment for the AYs 2006-07 and 2007-08. The revenue has filed appeal against the order of CIT(A) with regard to appeal against 143(3) r.w.s. 147 assessment for the AY 2007-08.
2ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
ITA No. 676 & 677/Hyd/2011 for AY 2006-07 & 2007-08 by the assessee
2. As the issues in both these appeals are materially identical, we refer to the facts from AY 2006-07 being ITA No. 676/Hyd/2011.
3. Briefly the facts of the case are that the assessee company is engaged in the business of development of real estate, filed its e- return of income for the AY 2006-07 on 29/11/2006 admitting total income of Rs. 12,08,340/-. The AO completed the assessment u/s 143(3) of the Act by determining the total income at Rs. 43,93,962/-.
3.1 A survey under section 133A was conducted on the premises of the assessee on 28.02.2006 and books of accounts were impounded during survey. On examining the books of accounts, it was found that the assessee had made several payments in cash exceeding Rs. 20,000/- thereby violating the provisions of Section 40A(3) of the Act. The payments were primarily made towards land development, miscellaneous expenses, land payments. The Assessing Officer found that a large number of payments were made in violation of section 40A(3). Accordingly, the additions were made as per paras 3 to 8 of the Assessment Order.
4. During appeal proceedings, the assessee's main arguments were that the payments were made to poor agriculturists who did not have bank accounts. Secondly, the assessee stated that it did not hire any contractor and the payments with regard to the development works were made to the staff of the assessee and the mastries. It was also stated that the payments were made directly to the labourers. The third argument is that some of the payments were petty in nature and were made to various employees of the assessee.
5. After considering the submissions of the assessee, the CIT(A) confirmed the additions made u/s 40A(3) by the AO by observing as under:
3ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
1. There is no doubt about the fact that a large number of payments have been made violating the provisions of section 40A(3) of the Act.
2. The explanation that payments were made to poor land owners, who did not have bank accounts is completely unsubstantiated. The onus lies squarely on the assessee to not only provide details of its payments through entries in the books of account, but also to substantiate the arguments made by it. The assessee has not even provided full details of each and every transaction. Moreover, the lands were situated close to Shamshabad, which houses one of best Airports in the country along with many other facilities. The Assessing Officer has rightly stated that he cannot accept the aforementioned arguments of the assessee pertaining to no banking facilities.
Further, the argument that the land owners insisted on cash payments is also not valid. Not only it is violative of the legal Provisions, but it is also unsubstantiated. Further, the assessee has not provided a single shred of evidence to show that payments in small amounts were made to its workers directly. This argument is incorrect and is not supported by any evidence on record. Payments have been made to specific persons clearly indicated by the Assessing Officer in his order and these have been in violation of Section 40A(3). The other arguments of the assessee are also completely unsubstantiated. Even adequate details have not been provided by the assessee."
6. As regards the additions of Rs. 10,06,154/- & Rs. 6,16,109/- on account of commission payments, the assessee made payments of commission to an extent of Rs. 1,58,73,210/- with regard to four ventures. The AO made the disallowance for the reason that commission payments allowable would be 6.4% of the sale price and, therefore, he determined the commission payment at Rs. 71,50,000/- in respect of all projects. He arrived at the proportionate amount disallowable for the year under consideration at Rs. 10,06,154/- and Rs. 6,16,109/- for the two ventures undertaken during the year.
7. Before the CIT(A), it was submitted that the AO was not justified in restricting the commission payments based on the statements of the persons to whom the commission was paid and copies of the statements so recorded were not provided to the 4 ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
assessee. It was further submitted that in the assessment order the AO mentioned at page 11 the rate of commission ranges between Rs. 50 and 100/- per sq.yd. and arrived at a rate of 4% to 8% based on the sale price of each sq. yard but restricted the same to 6.4%. It was submitted that this is the probable amount arrived at by him as against the actual amount paid and recorded in the books of account. Finally, it was submitted that as the AO did not provide an opportunity to cross examine the persons to whom commission was paid, the assessee submitted that the addition made by the AO was not justifiable.
8. The CIT(A) after considering the submissions of the assessee observed that no enquiry had been conducted at the back of the assessee and it was the assessee who was asked by the AO to provide details of all the persons, to whom commissions were paid. He observed that as clearly brought out in the assessment order by the AO, the assessee could not even furnish the names and address of most of the persons to whom it had claimed to have given commission payments. It did not identify the transaction wise commission payments, the rates at which commissions were paid or any agreement of commission. He observed that moreover, the AO had rightly pointed out that the commission payments debited to the level of 20% is excessively high and does not confirm to either the market rates or human probability and moreover, the assessee did not make any specific request during the assessment proceedings for examination of its own commission agents. In view of the above observations, the CIT(A) confirmed the additions made by the AO towards commission payments.
9. Aggrieved by the order of the CIT(A), the assessee is in appeal before us raising the following grounds of appeal:
1. The order of the learned Commissioner of Income-Tax (Appeals) is erroneous, unjust and contrary to the facts of the case.5
ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
2. The learned Commissioner of Income-Tax (Appeals) erred in holding that the provisions of Sec. 40A(3) would apply in respect of the payments made for acquisition of land in Silicon County and further erred in confirming the addition made by the Assessing Officer of Rs. 7,71,298/-.
3. The learned Commissioner of Income-Tax (Appeals) erred in holding that the provisions of Sec.40A(3) would apply in respect of the payments made for acquisition of land in Silicon County-II and further erred in confirming the addition made by the Assessing Officer of Rs. 7,06,659/-.
4. The learned Commissioner of Income- Tax (Appeals) erred in confirming the addition of Rs.11,554/- being disallowance made u/s 40A(3) in respect of land development expenses incurred by the appellant for Silicon County-II.
5. The learned Commissioner of Income-Tax (Appeals) erred in confirming the addition of Rs.1,18,605/- being disallowance made u/s 40A(3) in respect of land development expenses incurred by the appellant for Silicon County.
6. The learned Commissioner of Income- Tax (Appeals) erred in confirming the addition of Rs.8,587/- being disallowance made u/s 40A(3) in respect of business promotion expenses incurred by the appellant for Silicon County.
7. The learned Commissioner of Income- Tax (Appeals) erred in confirming the addition of Rs.6,660/- being disallowance made u/s 40A(3) in respect of land commission payments incurred by the appellant for Silicon County.
8. The learned Commissioner of Income-Tax (Appeals) erred in applying the provisions of Sec.40(a)(ia) in respect of Silicon County-II and further erred in arriving at the disallowance of Rs. 46,751/-.
9. The learned Commissioner of Income-Tax (Appeals) erred in arriving at a disallowance of Rs.10,06,154/- on account of payments towards commission in respect of Silicon County.
10. The learned Commissioner of Income-Tax (Appeals) erred in arriving at a disallowance of Rs.6,16,109/- on account of payments towards commission in respect of Silicon County-II." 9.1 The grounds raised by the assessee in AY 2007-08 are as follows:
" 1. The order of the learned Commissioner of Income-Tax (Appeals) is erroneous, unjust and contrary to the facts of the case.6
ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
2. The learned Commissioner of Income-Tax (Appeals) erred in confirming the addition of Rs.1,48,89,771/- made by the Assessing Officer applying the provisions of Sec. 40A(3) in respect of the following projects:
a) Highway Paradise .. Rs.17,76,764
b) Silicon County .. Rs.18,08,077
c) Silicon County-II .. Rs.16,02,401
d) Silicon County-III .. Rs.66,13,927
e) Royal Residency .. Rs.29,37,438
f) Crystal Park .. Rs. 1,51,164
3. The learned Commissioner of Income-Tax (Appeals) erred in confirming the addition of Rs.88,93,980/- being the disallowance of proportionate commission paid during the previous year under consideration.
4. The learned Commissioner of Income- Tax (Appeals) erred in confirming levy of interest u/s 234B of Rs.30,64,681/- and u/s 234C of Rs.26,427/-."
10. Ld. AR submitted that the assessee is in business of development of real estate. In that process, it has bought agricultural lands in and around Shamshabad area. All these lands were directly purchased from villagers wherein there is no banking facility available at the relevant point of time when the assessee purchased the lands. However, he objected to the observation of CIT(A) that Shamshabad area is well developed and it had banking facilities. He submitted that these were subsequent developments due to various developments carried out by the Govt. When the assessee bought various lands from the land owners who are basically agriculturists, the payments were made to landlords at the time of purchase. He submitted that no doubt payments were made in cash more than Rs. 20,000/-, but, these payments were as per rule 6DD(g) of the Rules. Hence, the provisions of section 40A(3) will not apply in respect of these payments. He further submitted that the assessee has made submissions before the AO that during this AY, payments were not at all considered as expenditure in the P&L A/c, the question of disallowance u/s 40A(3) will not arise as these payments were shown as advances given to land owners. Further, ld. AR relied on the order 7 ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
of the coordinate bench of this Tribunal in the case of Sahitya Housing Pvt. Ltd. Vs. DCIT in ITA No. 246/Hyd/2011, order dated 24/01/2014. Ld. AR also submitted a chart of land owners showing the details such as location of land, amount paid to the land owners and addresses of the parties.
10.1 With regard to ground Nos. 8 & 9, pertaining to disallowance u/s 40(a)(ia) and other expenditure, ld. AR submitted that for the land development expenses, assessee has made payments directly to the employees of the company to carry out the expenditure relating to land development in the villages where there is no banking facility, as it is necessitated that employees of the company had to carry large amount of cash to carry out developments at the site where there is no banking facilities.
10.2 With regard to commission payments, ld. AR submitted that in the real estate business, commission agents play a crucial role as they have to approach, convince and bring the customers to the company. The Company is bound to announce attractive commission for the agents in order to improve the business, which was in fact around 20% of the sale price. He reiterated that the payment made by the assessee to the agents were according to the policy adopted by the assessee and were actual payments made to the agents. He, therefore, contended that AO cannot determine quantum of commission which the company should have incurred.
11. Ld. DR basically supported the orders of AO and CIT(A) and further substantiated and argued that rule 6DD(g) basically speaks about only ordinary residence of the parties. It is relevant to notice that chart submitted before the Hon'ble Tribunal by the AR in which the addresses were given, which highlights that ordinary residence of the parties, who sold land to the assessee are ordinary residents in and around Hyderabad where there is no shortage of banking facilities. It is only to infer that these payments were made in the place of residence and not in the place of sale, hence, she 8 ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
vehemently argued that these payments were not as per rule of exclusion under rule 6DD(g) of the Rules.
11.1 For the other types of payments for land development and commission, she relied on the orders of revenue authorities.
12. In the rejoinder, ld. AR read out Rule 6DD(g), in which not only the rule speaks about ordinary residence, but, it also speaks about "
"or carrying of any business, profession or vocation, in any such village or town". He reiterated that the payments were made to the land owners after the registration in the villages itself and the payment in the place of villages also falls within the rule 6DD(g). He submitted that rules should be applied in toto and not interpreting part of the rule. He relied on the order of the coordinate bench in the case of Sahitya Housing Pvt. Ltd. (supra).
13. Considered the rival submissions and perused the material facts on record. Similar issue came up for consideration before the coordinate bench of this Tribunal in case of Sahitya Housing Pvt. Ltd. (supra) wherein the coordinate bench observed as under:
"13. We have heard the arguments of both the parties, perused the record and have gone through the orders of the revenue authorities. Sec 40A(3) reads as under: Provided that no disallowance shall be made and no payment shall be deemed to be the profits and gains of business or profession under sub section (3) and this sub section where a payment or aggregate of payments made to a person in a day, otherwise than by an account payee cheque drawn on a bank or account payee bank draft, exceeds twenty thousand rupees in such cases and under such circumstances as may be prescribed having regard to the nature and extent of banking facilities available considerations of business expenditure and other relevant factors.
14. The exceptions to the application of sec 40A (3) is laid down in Rule 6DDJ. Rule 6DD after its amendment from 1995, reads as under:
Rule 6DD Prior to 25.7.1995, clause (j) of Rule 6DD of the IT Rules read as follows:
6DD....... i) in any other cause, where the assessee satisfies the Assessing Officer that the payment could not be made by a cross cheque draw on a bank or by a drawn on a bank or by a crossed bank draft......
(1) due to exceptional or unavoidable circumstances or 9 ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
(2) because payment in the manner aforesaid was not practicable, or would have caused genuine difficulty to the payee, having regard to the nature of the transaction and the necessity for expeditious settlement thereof.
And also furnishes evidence to the satisfaction of the Assessing Officer as to the genuineness of the payment and identity of the payee".
The above clause (j) of Rule 6DD has been omitted by the IT (fourteenth amendment) Rules 1995 w.e.f. 27.5.1995. It is pertinent to refer at this juncture, to the decision of Hon'ble Andhra Pradesh High Court in the case of Smt. Ch. Mangayamma Vs. Union of India and others (239 ITR 687), wherein considering the constitutional validity of the provisions of S.40A(3) of the Act in the light of the above amendment made to Rule 6DD of the IT Rules, the Hon'ble High Court observed and held at page 693 of the Reports (239 ITR 687) as follows:
"In view of the aforesaid principles as laid down and the object as sought to be achieved u/s 40A(3) of the Act, any changes made in the subordinate legislation would not in any way affect the substantive provision. Moreover, by deleting the circumstances as contemplated earlier, viz., sub clauses (1) and (2) of rule 6DD(j) the objects of curbing the circulation of black money and regulating the business transactions become more strengthened and it avoids any undue advantage being taken by unscrupulous assessees or litigation being multiplied. As the position stands now 20% of the cash transactions exceeding Rs.20,000 are disallowed in computing the business expenditure but not the entire Rs.20,000/- While the amended provision confers advantage to the assessee to this extent, the circumstances permitted to be taken into account by the Assessing authority are no longer available by reason of deletion of old rule 6DD(j). But that by itself does not make section 40A(3) arbitrary and unconstitutional. One cannot plead ignorance of law and make cash payments contrary to law. It is too late in the day to accept any such proposition. Furthermore, in the present day banking scenario, the mode of payment by way of crossed cheques or demand drafts cannot be said to be onerous duty case on an assessee which can be made a foundation for attacking the validity of the said section. Therefore, it is not open for attacking the provision as violative of any provision of the constitution. There is no arbitrariness or discrimination in the said provision warranting interference by this court under the circumstances.
In view of the above there is absolutely no merits in the challenge made as to the validity of section 40A(3) of the Act by mere deletion of sub clauses (1) and (2) of rule 6DD(j). The said provision is perfectly valid and we may hasten to add that the deletion of sub clauses (1) and (2) of rule 6DD(j) is only a step forward in the achievement of the avowed object envisaged u/s 40A(3) of the Act.
15. Therefore the only exception that the Assessee can claim is when payments are required to be made on days when the Banks were closed on account of holidays or strike. Transactions after the banking hours in the course of regular business will not fall within this exception. In those transactions, the payment is not required to be made when the banks are closed i.e. after banking hours. Further the purpose of the disallowance u/s 40A (3) is to dissuade transactions by cash.
16. Sec 40A(3) itself provides that the exceptions will have to be prescribed having regard to the nature and extent of banking facilities available, considerations of business expediency and other relevant factors. Taking all these factors, considering the nature of activity of the Assessee and the necessity for them to pay cash to the land owners we are 10 ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
of the opinion that the condition under Rule 6DD for exemption viz., transactions should have taken place on Bank Holidays should be read down in the case of the Assessee.
17. In the case under consideration, no banking facility is available where the properties were purchased by Assessee, therefore, there was no choice for the assessee except to make the payments in cash due to exceptional or unavoidable circumstances as provided under Rule 6DD. In view of the above discussion, we set aside the order of CIT(A) and delete the addition of Rs. 4,09,98,105/- made u/s 40A(3) of the Act."
13.1 In the case under consideration, the facts are similar to the facts in the above decision of the coordinate bench. As per the said decision, the payments are made in the place of registration wherein there is no banking facilities, are not covered by the provisions of section 40A(3). In the given case, ld. DR submitted that as per 6DD(g), the ordinary residence of the land owners are relevant, as the payment would have made in the place of residence not in the place of registration. We are not in a position to appreciate this view because the rule 6DD(g) excludes the payment, which is made in a village or town, which on the date of such payment is not served by any bank, to any person who ordinarily resides, or is carrying on any business, profession or vocation, in any such village or town. In the above rule, with regard to the person who receives the payment, it prescribes two situations wherein first situation, rule allows the payer to pay in the place of residence and in the second situation, the payment made in the place of the dealing or place of registration in which the person carries the business, profession or vocation. In the given case, the assessee claims that the payment was made in the place of vocation and the revenue infers that the payment was made in the place of residence due to the fact that the banking facilities are available in the place of residence. The revenue has not substantiated its claim that the payments were actually made in the place of residence. In the absence of such evidence, we are inclined to accept the contention of the assessee that these payments were made in the place of vocation i.e., the payments were made in villages where the agricultural lands are situated.
11ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
13.2 Considering the above discussion and the decision of the coordinate bench which is directly on this point, we set aside the orders of CIT(A) and allow the appeals of the assessee in both the years under consideration.
13.3 With regard to land development expenditure, these expenses were incurred in the villages to develop the land, where there is no banking facilities. Hence, we are inclined to accept the contention of the assessee that these payments were made directly to the employees of the company to carry out the development work. Accordingly, these expenses are also not hit by the provisions of section 40A(3).
13.4 With regard to payment of commission, we have noticed that the AO has disallowed the payment to agents due to the fact that genuineness of the payments were not proved due to non-compliance to the notices of AO and mismatch of the signatures on the confirmation letters submitted by the assessee. The ld. AO had accepted the payments which are properly documented. Hence, we accept the findings of the AO and accordingly grounds raised by the assessee in this regard are dismissed.
14. In the result, both the appeals of the assessee are partly allowed.
ITA No. 753/Hyd/2014 by the revenue for AY 2007-0815. In this appeal, the revenue has raised the following grounds of appeal:
i. The order of the CIT(A) is erroneous both in law and in facts of the case.
ii. The CIT(A) erred in deleting the disallowance of Rs.1,29,10,312/- made u/s 40A(3) of the Act representing the payments made in cash to land owners.
iii. The CIT(A) erred in deleting the disallowance of Rs.49,900/- made u/s 40A(3) towards payments made to employees for incurring expenditure on development.12
ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
iv. The CIT(A) erred in ignoring the provisions of Rule-46A where in the CIT(A) has to call for remand report from the Assessing Officer, before accepting the additional evidence produced before him.
v. The CIT(A) erred in ignoring the provisions that the Company will not get any immunity from the application of provisions of section 40A(3), as the assessee failed to produce evidence in support of its claim that the circumstances stipulated under Rule 6DD(g) were prevailing on the dates of payments in cash. vi. The CIT(A) erred in ignoring the fact that the assessee had filed separate Trading and P & L Account for separate ventures and shown payments to same agents who are commonly employed. Thus the CIT(A) erred in deleting the disallowance of Rs.49,900/- made u/s 40A(3) towards payments agents."
16. Briefly the facts of the case are that for the AY 2007-08, the assessee filed its return of income on 30/10/2007 admitting an income of Rs. 1,33,57,380/-. The AO issued notices u/s 143(2) and 142(1) of the IT Act. The assessee filed all the details. The AO completed the assessment u/s 143(3) on 31/12/2009 determining the total income at Rs. 3,71,41,126/-. The AO, thereafter, issued notice u/s 148 on 29/03/2012 requiring the assessee to file the return of income. The AO did not furnish the reasons for reopening the assessment. In response to the show cause notice, the assessee filed detailed explanation as to why the provisions of section 40A(3) are not applicable. The AO, however, completed the assessment u/s 143(3) rws 147 on 28/12/2012 determining the total income at Rs. 5,01,01,342/- disallowing an amount of Rs. 1,29,10,312/- representing the payments made to the land owners by applying the provisions u/s 40A(3) and also disallowed Rs. 49,900/- representing the land development expenses.
17. Aggrieved by the order of the AO, the assessee preferred an appeal before the CIT(A) and filed written submissions, which were extracted by the CIT(A) in his order at pages 2 to 4 of the order wherein details of cash payment for purchase of land for AY 2006-07 and 2007-08 in a tabular form were also there.
13ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
18. The CIT(A) after considering the submissions of the assessee, observed that except in the case of Maheswaram, the lands are situated in the villages which are not covered by banking facilities. He noted that the assessee submitted that the payments were made at the site to all the agriculturists and that at the time of making such payment, the villages were not governed by banking facilities. The CIT(A), therefore, held that the exceptions provided in Rule 6DD(g) would apply and provisions u/s 40A(3) would not apply. He, accordingly, deleted the addition of Rs. 1,29,10,312/-.
18.1 With regard to the addition made of Rs. 49,900/- u/s 40A(3) of the Act, the assessee submitted that the payments were made to the employees for incurring the expenditure on development. Each payment made by the employees is not more than Rs. 20,000/-. The CIT(A), therefore, held that the provisions u/s 40A(3) would not apply and accordingly, the addition of Rs. 49,900/- made by the AO deleted by the CIT(A).
19. Aggrieved by the order of the CIT(A), the revenue is in appeal before us.
20. Considered the rival submissions and perused the material facts on record. While deleting the addition made by the AO u/s 40A(3), the CIT(A) categorically held that the exceptions provided in rule 6DD(g) would apply and provisions u/s 40A(3) would not apply after considering the submission of the assessee that the payments were made at the site to all agriculturists and that at the time of making such payment, the villages were not governed by banking facilities. Therefore, following the conclusions drawn in assessee's appeals (supra), we uphold the order of the CIT(A) on this issue and the grounds raised by the revenue are dismissed.
21. In the result, appeal of the revenue is dismissed.
14ITA No. 676 & 677/H/11 & 753/H/14 M/s PCR Developers (P) Ltd.
22. To sum up, both the appeals of the assessee are partly allowed and the appeal of the revenue is dismissed.
Pronounced in the open court on 23 rd February, 2017.
Sd/- Sd/-
(P. MADHAVI DEVI) (S. RIFAUR RAHMAN)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Hyderabad, Dated: 23 rd February, 2017
kv
Copy to:-
1) M/s PCR Developers Pvt. Ltd., C/o Shri S. Rama Rao, 3-6-643, Shriya's Elegance, Flat No. 102, St. No. 9, Himayat Nagar, Hyderabad - 29.
2) DCIT, Circle - 16(3) Hyderabad
3) CIT(A) - V, Hyderabad 4 CIT - IV, Hyderabad
5) The Departmental Representative, I.T.A.T., Hyderabad.
6) Guard File