Income Tax Appellate Tribunal - Hyderabad
G.V.K.Industries Ltd.,, Secunderabad vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD " A " BENCH, HYDERABAD
BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SHRI
SAKTIJIT DEY, JUDICIAL MEMBER
ITA No.620/Hyd/2009
Assessment Year 2002-03.
GVK Industries Ltd., -v- Asstt. CIT, Cir-2(2),
Secunderabad. Hyderabad.
PAN:AAACG7499 J
(Appellant) (Respondent)
Appellant by Shri V. Shiva Kumar
Respondent by Shri K. Gnana Prakash
Date of Hearing 22-08-2013
Date of pronouncement 18-10-2013
ORDER
PER SAKTIJIT DEY, J.M:
In this appeal, the assessee has challenged the order dated 27-2-2009 of CIT-II, Hyderabad passed u/s 263 of the Act pertaining to the assessment year 2002-03. The assessee has raised six grounds.
2. Ground Nos. 1 and 6 are general in nature and not required to be adjudicated upon.
23. In ground No. 2(a), the assessee has challenged the order passed u/s 263 of the Act to be barred by limitation. The ground reads as under:-
"The CIT ought to have seen that the order passed u/s 263 of the Act is beyond the time limit specified in clause (2) of section 263 and therefore bad in law.
4. Briefly the facts are, the assessee is a limited company carrying on business in generation and sale of power. In the impugned assessment year, the assessee filed its return of income declaring income of Rs.2,16,04,260/- under normal provisions of the Act and book profit of Rs.69,85,32,950/- under the provisions of section 115JB of the Act. In course of scrutiny assessment proceedings initiated by issuance of notice u/s 143(2) of the Act, the Assessing Officer after verifying the books of accounts and other information noticed that the assessee had added a sum of Rs.11,08,69,955/- being prior period adjustment. This amount of Rs.11,08,69,955/- also includes an amount of Rs.31,21,210/- being foreign exchange variation gain for the financial year 2000-01 relevant to the assessment year 2001-02. It was explained by the assessee that since the said amount of Rs.31,21,210/- has already been accepted in the assessment year 2001-02, it has to be excluded in the assessment year under consideration. The Assessing Officer finding the same to be correct reduced the same from total income. Further, the Assessing Officer while examining the assessee's claim u/s 80IA of the Act noticed that certain income which was considered for the purpose of claiming 3 deduction u/s 80IA was not derived from the activities of the undertaking of generation of power. The Assessing Officer therefore making certain adjustments to the claim of deduction u/s 80IA of the Act ultimately determined the total income under the normal provisions at Rs.2,17,23,084/- and the book profit for the purpose of section 115JB of the Act at Rs.69,85,32,950/- and completed the assessment accordingly. Subsequently, the Assessing Officer initiated action u/s 147 of the Act by issuing a notice u/s 148 of the Act on 8-6-2006.
5. The assessment was reopened on the reasons, as recorded by the Assessing Officer, as per the power purchase agreement entered into with APTRANSCO the assessee is reimbursed the income tax paid by it but which has not been offered to tax. The second issue for reopening the assessment was the excess insurance premium paid in earlier years amounting to Rs.1,37,82,234/- received during the financial year relevant to the assessment year under dispute is not eligible for deduction u/s 80IA of the Act. Though the assessee appeared in reassessment proceedings and objected to the escapement of income alleged by the Assessing Officer, the Assessing Officer however rejected the contention of the assessee and completed the assessment u/s 143(3) read with section 147 of the Act vide order dated 31-12-2007 by bringing to tax the income-tax reimbursed of amount of Rs.2,40,45,266/-. The Assessing Officer further concluded that the excess insurance premium received of Rs.1,37,82,234/- which was considered by the assessee while computing the 4 deduction u/s 80IA has to be reduced from the income while computing the deduction u/s 80IA as it is not derived from the business. Accordingly, the Assessing Officer completed the assessment. After completion of the assessment u/s 143(3) read with section 147 of the Act vide assessment order dated 31-12-2007, the CIT in exercise of powers conferred u/s 263 called for the assessment records and after examining the same was of the view that the assessment order dated 31-12-2007 passed u/s 143(3) read with section 147 of the Act is erroneous and prejudicial to the interests of revenue as the Assessing Officer has not excluded the refund of excess insurance premium and gain from foreign exchange fluctuations the total amounting both issues was Rs.13,60,28,581/- which was not derived from generation of power while computing the deduction u/s 80IA of the Act.
6. The CIT accordingly issued a show cause notice u/s 263 of the Act on 26-9-2008 proposing to revise the assessment order passed for the impugned assessment year as the Assessing Officer has failed to exclude the prior period income and foreign exchange variation while computing deduction u/s 80IA of the Act. The assessee in its reply to the show cause notice submitted that the excess insurance premium of Rs.1,37,80,234/- was rightly excluded by the Assessing Officer while computing the deduction u/s 80IA of the Act, hence, the proceedings u/s 263 of the Act cannot be initiated. It was further submitted by the assessee that the Assessing Officer has finally completed the assessment under the provisions of 5 section 115JB and therefore there was no prejudice to the interests of revenue as the income u/s 115JB is not to be sought to be revised in the proceedings initiated u/s 263 of the Act. So far as gain on account of foreign exchange fluctuations is concerned, it was submitted by the assesses that the two amounts of Rs.1,80,64,366/- and Rs.70,94,260/- totalling to Rs.2,51,58,626/- represented the surplus or deficit in the foreign exchange variation account credited at the end of the financial year. Hence, it forms part of sale revenue and should be considered as income derived from business. After receiving the reply from the assessee, the CIT though accepted the fact that the refund of insurance premium of Rs.1,37,80,234/- forms part of other income as per schedule-I of profit and loss account was considered by the AO, the refund of Rs.4,75,13,685 which was exactly of the same nature but was credited below the line as prior period income was not considered by the Assessing Officer for the purpose of restricting the deduction u/s 80IA of the Act.
7. The CIT further stated that regarding the foreign exchange fluctuation, the issue involved is in respect of amount of Rs.2,51,58,626/- which represented foreign exchange fluctuation gain for the current year as well as an amount of Rs.6,33,56,270/- which represented foreign exchange fluctuation gain of the prior period and credited below the line as prior period income on account of foreign exchange fluctuations. Hence, the total amount which is required to be reduced from the eligible income for computing the deduction 6 u/s 80IA is Rs.13,60,28,581/-. The assessee in its further submission contended that the original assessment in the case of the assessee was completed on 26-10-2004 and the reopening of the assessment was made on two grounds which are (i) income-tax reimbursed by APTRANSCO should have been assessed as income of the assessee and (ii) refund of excess insurance premium of Rs.1,37,80,234/- which was taxable u/s 41 was not eligible for deduction u/s 80IA. The reassessment order was passed on 31-12-2007 treating the income-tax reimbursed by AP TRANSCO as income of the assessee and also disallowing deduction/s 80IA on the refund of insurance premium holding the same as not eligible income for the purpose of deduction u/s 80IA of IT Act.
8. It was further submitted by the assessee that the CIT (A) vide order dated 25-8-2008 has also set aside the addition in respect of income-tax reimbursement by AP TRANSCO whereas in respect of deduction u/s 80IA on refund of excess insurance premium, the CIT (A) held that the refund received should be set off against insurance premium paid and only the balance, if any, should be considered for disallowance. It was submitted by the assessee that the reopening u/s 147 was not done for considering the disallowance of prior period adjustments while computing deduction u/s 80IA of the Act. The assessee therefore submitted, since the issue on which the CIT issued notice u/s 263 of the Act is not the subject matter for reopening the assessment but was the issue decided in the original assessment therefore the assessment order which can 7 be subject to the proceedings u/s 263 of the Act, is the original assessment order dated 26-10-2004 and not the reassessment order passed u/s 143(3) read with section 147 of the Act. It was therefore contended by the assesssee that since the notice issued u/s 263 of the Act is dated 26-11-2008 it is therefore beyond the time limit of 2 years prescribed u/s 263 of the Act as the original assessment was completed on 26-10-2004. The CIT however rejected the contention of the assessee by holding that when the assessment is reopened u/s 147 of the Act, the entire assessment is open before the Assessing Officer and he can make enquiry and if justified make additions other than the escaped income as per the reasons recorded while reopening the assessment. In this context, the CIT relied on two judgments of Hon'ble Supreme Court in case of V. Janardhan Reddy and Others vs. CIT 75 ITR 373 and in case of Mewalal Dwaraka Prasad (176 ITR 529). With the aforesaid observation, the CIT rejected the assessee's contention with regard to the validity of the proceedings as being time barred.
9. The learned authorised representative for the assessee orally and through his written submission has contended before us that as per the power purchase agreement entered with AP TRANSCO monthly payment towards power has been made by AP TRANSCO by way of actual expenses incurred which included foreign exchange variation amount. Accordingly, AP TRANSCO was paying the assessee on monthly basis foreign exchange variation on principal repayment on foreign exchange loan. It 8 was contended that foreign exchange variation component comprised in bills is to be credited to foreign exchange variation account and would be utilised for payment of principal to foreign exchange lender. The surplus or deficit in the foreign exchange variation account would be debited/credited to the Profit & Loss A/c. It was therefore submitted that the foreign exchange variation amount is part of sale revenue and same cannot be considered as income not derived from business while computing the deduction u/s 80IA of the Act. So far as refund of excess insurance premium is concerned, it was submitted that the Assessing Officer while completing the reassessment has already excluded refund of excess insurance premium of Rs.1,37,80,234/-.
10. The learned AR submitted that the assessment in case of the assessee was reopened specifically on two grounds which are for adding the income tax receivable and not allowing deduction u/s 80IA in respect of refund of insurance premium of Rs.1,37,80,234 and the reassessment was completed by bringing to tax the aforesaid two amounts. The additions/ disallowances were also challenged before the CIT (A). The CIT (A) while sustaining the addition on account of income-tax receivable directed the Assessing Officer to set off the insurance premium against the insurance premium paid and bring to tax only the balance amount if any. It was submitted that in the original assessment completed u/s 143(3) vide order dated 26-10-2004 the Assessing Officer has already considered all the issues on the basis of which the CIT has invoked his 9 jurisdiction u/s 263 of the Act and these issues were not subject matter of reopening and also not subject matter of re- assessment order passed u/s 143(3) read with section 147 of the Act. It was therefore submitted that if at all an error can be attributed; it is only with reference to the original assessment order and not the re-assessment order. He therefore contended that the notice u/s 263 of the Act having been issued beyond two years from the end of the financial year in which the regular assessment order was passed, is barred by limitation and therefore invalid.
11. The learned AR referring to the letter dated 9-8-2004 issued by the Assessing Officer during the original assessment proceedings submitted that the Assessing Officer being conscious of the prior period income of Rs. 11,08,69,955/- in the context of deduction claimed u/s 80IA of the Act had called for information from the assessee. The assessee in response furnished a detailed information vide letter dated 24-9-2004 and the Assessing Officer after properly verifying the facts and material had accepted the assessee's claim and completed the assessment accordingly. It was therefore submitted that the issue raised in the proceedings u/s 263 of the Act not being the subject matter of reassessment proceedings, the issuance of notice beyond two years from the end of the financial year in which the original assessment order was passed is barred by limitation. In this context, the learned AR relied upon a judgment of Hon'ble Bombay High Court in case of CIT vs. ICICI Bank Ltd. (19 Taxmann. Com. 142 (Bom).
1012. The learned Departmental Representative, on the other hand, submitted that once the assessment is reopened the entire issue can be considered by the Assessing Officer, hence the limitation will be counted from the end of the year in which the order u/s 143(3) read with section 147 of the Act is passed.
13. We have considered rival submissions of the parties and perused the material on record. Before we proceed with the merits of the issue, we have to bear in mind the following dates which are very much crucial for deciding the issue.
i) 26-10-2004 - assessment order u/s 143(3) passed for the assessment year under dispute.
ii) 31-12-2007 - assessment order u/s 143(3) read with section 147 of the Act
iii) 26-11-2008 - notice u/s 263 of the Act was issued by the CIT.
It is the contention of the assessee that the proceedings initiated u/s 263 of the Act is time barred as it is beyond the period of two years from the end of the financial year in which the original assessment order u/s 143(3) of the Act was passed. Such contention of the assessee is based on the premises that the issue on which the CIT has invoked jurisdiction u/s 263 of the Act was never the subject matter of reassessment proceedings. Whereas it is the stand of the department that once the assessment is reopened, the entire issue is open for consideration by the Assessing Officer and if he fails to consider any other income in addition to the escaped 11 income on the basis of which the reopening was made, then the limitation should begin to run from the order passed u/s 143(3) read with section 147 of the Act as this order is erroneous and prejudicial to the interests of revenue.
14. On a perusal of the reasons recorded for reopening of the assessment which was communicated to the assessee vide letter dated 4-7-2006 a copy of which is placed before us, the assessment was reopened on the following reasons:-
"The assessee is in the business of generation and sale of power. The assessee company is having a Power Purchase Agreement with the TRANSO. As per clause 3.4 of the said PPA, the income- tax paid by the assessee company has to be reimbursed by the TRANSCO. In accordance with the said PPA the assessee company raised bills for the income-tax paid by it. As per the provisions of the Income Tax Act, the income tax received/ receivable is the income of the assessee. However, the assessee neither offered the same as income from other sources nor credited to the sales revenue. Therefore, the income of the assessee is under stated to that extent.
As per note 9 of the schedule L to the annual accounts, the provision for taxation was made taking into consideration of income tax receivable from TRANSCO. As discussed in the assessment order for the a.y. 2003-04,the income tax receivable from the TRANSCO is taxable, not only under normal provisions of the Act but also u/s 115JB of the Act. The assessee's treatment of income tax receivable like the sale taxi excise duty collection and setting off the same against the tax payments is not correct. The income tax receivable/received is nothing but the additional income to the assessee arrived at as per accounts. Therefore, the same has to be added to the income arrived at as per P&L Ale. As discussed in the assessment order for thea.y,2003-04. While the provision for income tax required was Rs.5,34,37,770/-,the assessee made the provision at Rs.2,93,92,504/-. The difference of Rs.2,40,45,266/- represents the income tax receivable on reimbursement. Therefore, the income tax receivable of 12 Rs.2,40,45,266/- has to be treated as income of the assessee and added to the taxable income under normal provisions and also u/s 115JBof the Act. Failure to do so resulted in escapement of income to that extent.
Further, the miscellaneous income of Rs.I,44,31,764/- consists of excess insurance premium (paid in earlier years) of Rs.I,37,80,234/- received in this year. Since the amount was taxable u/s 41 of the Act, it is not eligible for deduction u/s 801A of the Act. However, the same was allowed as deduction us/s 80lA while completing the assessment u/s 143(3)."
15. As would be evident from the reasons recorded hereinabove, the assessment was reopened basically on the following two issues:-
i) Assessee has not offered to tax the reimbursement of income-tax receivable of Rs.2,40,45,266/- and
ii) While computing deduction u/s 80IA of the Act, the amount of excess insurance premium paid earlier amounting to Rs.1,37,82,034/- received during this year though was not eligible income for computing deduction u/s 80IA of the Act but the deduction was also allowed on the said income.
The assessment was ultimately completed u/s 143(3) read with section 147 of the Act by the Assessing Officer on the basis of the aforesaid reasons recorded by bringing to tax the income tax receivable amounting to Rs.2,40,45,266/- and excluding from the income an amount of Rs.1,37,82,234/- for the purpose of computing the deduction claimed u/s 80IA of the 13 Act. Thus, it would be clear the assessment u/s 143(3) read with section 147 of the Act was completed in terms with the reasons recorded. It is further revealed from the order of the CIT that he has directed the Assessing Officer to re-compute the deduction claimed u/s 80IA of the Act by excluding the amount of Rs.6,12,93,919/- being the excess insurance premium and the amount of Rs.8,85,14,896/- representing gain on foreign exchange fluctuation.
16. On perusal of the materials placed on record, it is seen that the amount of Rs.6,12,93,919/- is the refund of excess insurance premium relating to prior period and amount of Rs.11,08,69,955/- is relating to prior period income. The original assessment order passed u/s 143(3) of the Act read along with the reply submitted in response to the questionnaire issued by the Assessing Officer during the original assessment proceedings would confirm the fact that the aforesaid two amounts were considered by the Assessing Officer while completing the assessment u/s 143(3) of the Act vide assessment order passed on 26-10-2004. It is also a fact very much evident on record that these amounts were never subject matter of reopening of assessment as per the reasons recorded. In the aforesaid circumstances, if at all any prejudice has been caused to the revenue on account of erroneous order passed by the Assessing Officer, then that order is the original assessment order dated 26-10-2004 and not the order passed u/s 143(3) read with section 147 of the Act on 31-12-2007. Therefore, in our view, the limitation of 14 two years period prescribed u/s 263 of the Act should begin to run from the end of the financial year in which the order was passed u/s 143(3) of the Act on 26-10-2004 and not from the re-assessment order passed u/s 143(3) read with section 147 of the Act on 31-12-2007 as under no circumstances, the re- assessment order can be said to be erroneous and prejudicial to the interests of revenue. The Hon'ble Bombay High Court in case of CIT vs. ICICI Bank Ltd., (19 Taxmann. Com. 142 (Bom), while considering identical issue held in the following manner:-
"5. The issue as to when the period of limitation would commence for an order under Section 263 was considered by the Supreme Court in CIT vs. Alagcndran Finance Ltd. [2007) 293 ITR 1/162 Taxman
465. In that case. orders of assessment for Assessment Years 1994-95. 1995-96 and 1996-97 were passed on 27 February 1997. 12 May 1997 and 30 March 1998. In the said orders of assessment the assessee's return under the head "lease equalisation fund" was accepted. Proceedings for reassessment were initiated and were completed on 28 March 2002. The proceedings for reassessment, however, were in respect of three items and the assessee's return in respect of lease equalisation fund was not the subject matter of the reassessment proceedings. The Commissioner invoked his jurisdiction under Section 263 on 29 March 2()()4 in respect the return under the head of "lease equalisation fund".
On these facts the Supreme Court held that only that part of the order of assessment which related to the lease equalisation fund was found to be prejudicial to the interest of the revenue. The proceedings for reassessment had nothing to do with that head of income and hence the doctrine of merger would not apply in a case of that nature. The Supreme Court further held that once an order of asscssment is reopened, the previous assessment will be held to be set aside and the whole preceding would start 15 afresh but that would not mean that even when the subject matter of reassessment is distinct and different, the entire proceeding of assessment would be deemed to have been reopened. Since the Commissioner in exercise of his revisioual jurisdiction reopened the order of assessment in relation to the lease equalisation fund which was not the subject matter of the reassessment proceedings, the period of limitation provided under sub-section (2) of Section 263 would, it was held ,begin to run from the date of the order of assessment and not from the order of re-assessment.
6. But the submission which has been urged by the counsel for the revenue is that the decision of the Supreme Court in Alagendran Finance was rendered on 27 July 2()07 which was prior to the amendment of section 147 by the insertion of Explanation 3. The counsel submits that as a result of the insert ion of Explantion 3, once an assessment is reopened, the Assessing Officer is entitled to assess or reassess the income in respect of any issue which has escaped assessment though the reasons in respect of such issue have not been included in the reasons recorded under Section 148(2). On this basis it is urged that when the Assessing Officer reopened the assessment on 26 March 2002 the entire assessment was at large and hence he ought to have applied the amended provisions of Section 36(1)(vii) particularly the explanation thereto.
7. This aspect of the matter has been considered in a judgment of a Division Bench of this Court in Ashoka Buildcon Ltd. v. Asstt. CIT (2010) 325 ITR 574/191 Taxman 29. The Division Bench considered a similar submission based on Explanation 3 which was inserted in Section 147 by the Finance Act of 2009 with retrospective effect from 1/4/1989. Negativing the submission. the Division Bench held as follows:
" ... Where a reassessment has been made pursuant to a notice under Section 148 the order of reassessment prevails in respect of those items which form part of reassessment. On items which 16 do not form part of the reassessment, the original assessment continues to hold the field. When the Assessing Officer reopens an assessment on a particular issue, it is open to him to make a reassessment on that issue as well as in respect of other issues which subsequently come to his notice during the course of the proceedings under Section 147. The submission of the revenue is that by not passing an order of reassessment in respect of other independent issues. The order of the Assessing Officer can be construed to be erroneous and to be prejudicial to the interests of the Revenue within the meaning of Section 263. The submission cannot be accepted in the facts of the present case. The substantive part of Section 147 as well as Explanation enables the Assessing Officer to assess or reassess income chargeable to tax which he has reason to believe had escaped assessment and other income which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under the section. There is nothing on the record of the present ease to indicate that there was any other income which had come to the notice of the Assessing Officer as having escaped assessment in the course of the proceedings under Section 147 and when he passed the order of reassessment. The Commissioner, w\hen he exercised his jurisdiction under Section 263, in the facts of the present case, was under a bar of limitation since limitation would begin to run from the date on which the original order of assessment was passed. We must however clarify that the bar of limitation in this case arises because the revisional jurisdiction under Section 263 is sought to be exercised in respect of issues which did not form the subject matter of the reassessment proceedings under Section 143 (3) read with 147. In respect of those issues, limitation would commence with reference to the original order of assessment. If the exercise of the revisional jurisdiction under Section 263 was to be in respect of issues which formed the subject matter of the reassessment after the original assessment was reopened, the 17 commencement of limitation would be with reference to the order of reassessment. The present case does not fall in that category."
Sub-section (2) of Section 263 stipulates a period of limitation of two years within which an order under sub-section (1) has to be passed. Under sub-section (2) no order under Section 263(1) can be made after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. The order of assessment under Section 143(3) in the present case allowed the deduction which was claimed under Section 36(1)(vii). Section 36(1)(viia) and in respect of foreign exchange rate difference. Neither in the first order of reassessment dated 22 Fcbruarv, 2000 nor in the second order of reassessment dated 26 March 2002 were these aspects determined. In other words on the aforesaid three issues, the original order of assessment dated 10th March, 1999 passed under Section 143(3) continued to hold the field. Once that is the position, then clearly the doctrine of merger would not apply. The order under Section 143(3) passed on 10 March 1999 cannot stand merged with the orders of reassessment in respect of those issues which did not form the subject matter of the reassessment. Consequently, Explanation 3 to section 147 will not alter that position. Explanation 3 only enables the Assessing Officer, once an assessment is reopened, to assess or reassess the income in respect of any issue, even an issue in respect f which no reasons were indicated in the notice u/s 148(2). This, however, will not obviate the bar of limitation u/s 263(2). Where the jurisdiction u/s 263(1) is sought to be exercised with reference to an issue which is covered by the original order of assessment u/s 143(3) and which does not form the subject matter of the reassessment, as in the present case, limitation must necessarily begin to run from the order u/s 143(3). Before concluding we may also take notice of the fact that the second order of reassessment dated 26 March 2002 has been set aside by the Tribunal on 27 August 2010. An appeal against the order of the Tribunal is pending before this 18 court for admission. However, we have considered this appeal independently and have come to the conclusion that the invocation of the jurisdiction u/s 263 was barred by limitation. Accordingly, we answer the question of law in the affirmative."
17. Thus, as per the ratio laid down by the Hon'ble Supreme Court which has been followed by the Hon'ble Bombay High Court, the limitation prescribed u/s 263(2) of the Act would begin to run from the original assessment order and not from the re-assessment order. The Hon'ble Court further held that the scope of reassessment cannot be extended to the extent of the issues which were never subject matter of re-assessment; hence the doctrine of merger would not apply. Therefore considered in the light of the ratio laid down as above by the Hon'ble Bombay High Court, since the issues on which the CIT invoked jurisdiction u/s 263 were never subject matter of reassessment proceedings, the notice issued u/s 263 of the Act on 26-11-2008 from the end of the financial year 2004-05 is barred by limitation and consequently the order passed u/s 263 of the Act is also invalid. In this view of the matter, we hold that the order passed u/s 263 by the CIT being void ab initio is legally unsustainable and accordingly the same is set aside.
18. The ground raised by the assessee is thus allowed.
19. Since while deciding the assessee's ground No.2(a), we have held that the order passed u/s 263 of the Act being barred by limitation is legally unsustainable, the other grounds raised by the assessee on merit of the issues are rendered merely 19 academic in nature and hence not required to be adjudicated upon.
20. In the result, the appeal is allowed.
Order pronounced in the court on 18-10-2013.
Sd/- Sd/-
( CHANDRA POOJARI) (SAKTIJIT DEY)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Hyderabad,
Dated the 18 th October, 2013
Copy to:-
1) C/o GVK Industries Limited, 156-159, Paigah House,
SP Road, Secunderabad.
2) ACIT, Cir-2(2), Hyderabad.
3) CIT-II, Hyderabad.
4) The Departmental Representative, I.T.A.T.,
Hyderabad.
Jmr*