Income Tax Appellate Tribunal - Delhi
Ciena India P. Ltd., New Delhi vs Department Of Income Tax on 23 April, 2015
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCHES : I : NEW DELHI
BEFORE SHRI R.S. SYAL, AM AND SHRI C.M. GARG, JM
ITA No.3324/Del/2013
Assessment Year : 2008-09
Ciena India Pvt. Ltd., Vs. DCIT,
Plot No.14, Sector 32, Circle-3(1),
Echelon Institutional Area, New Delhi.
Gurgaon.
PAN: AACCC6131B
ITA No.2948/Del/2013)
Assessment Year : 2008-09
DCIT, Vs. Ciena India Pvt. Ltd.,
Circle-3(1), Plot No.14, Sector 32,
New Delhi. Echelon Institutional Area,
Gurgaon.
PAN: AACCC6131B
(Respondent)
(Appellant)
Assessee By : Shri Himanshu S. Sinha, Advocate &
Shri Md. Fahad Khalid, CA
Department By : Shri Judy James, Standing Counsel
Date of Hearing : 21.04.2015
Date of Pronouncement : 23.04.2015
ITA Nos.3324 & 2948/Del/2013
ORDER
PER R.S. SYAL, AM:
These two cross appeals - one by the assessee and the other by the Revenue - arise out of the order passed by the CIT(A) on 11.3.2013 in relation to the assessment year 2008-09.
2. Ground nos. 1(a) and (b) were stated by the ld. AR to be general not requiring any specific adjudication. These grounds, therefore, stand dismissed as not pressed.
3. Ground No. 1(c) is against the choice of certain comparables in respect of `Software development segment'.
4. Briefly stated, the facts of the case are that the assessee is a wholly owned subsidiary of Ciena Corporation, USA and is engaged in the business of provision of software development and marketing support services to its overseas group companies. The assessee reported four international transactions. The Assessing Officer (AO) referred the international transactions to the Transfer Pricing Officer (TPO) for determination of their arm's length price (ALP). Two of such 2 ITA Nos.3324 & 2948/Del/2013 transactions were accepted by the TPO as at arm's length price. The other two international transactions in dispute are 'Provision of software development services' with transacted value of Rs.98,42,37,491/-; and `Provision of marketing support services' with transacted value of Rs.4,21,25,941/-. The TPO examined the assessee's segmental results. As regards the segment of `Software development services', the assessee applied the Transactional Net Margin Method (TNMM) as the most appropriate method with the Profit level indicator (PLI) of Operating Profit/Total Cost (OP/TC). Profit margin in the software development service segment was declared by the assessee at 19.16%. In order to demonstrate that these services were provided at arm's length price, the assessee chose 20 companies as comparable. The TPO rejected the assessee's computation of arm's length price worked out on the basis of multiple year data of the comparables and proceeded to determine the ALP of such transactions by relying on the current year's data alone. He rejected 14 out of 20 companies chosen by the assessee as comparables and added new 13 companies to the list of comparables, 3 ITA Nos.3324 & 2948/Del/2013 with the final tally of 19 comparable companies giving their profit ratio as under:-
Sl.No. Name of the Company Sales (Rs. Cr.) OP to Total Cost
1. Avani Cincom Technologies 3 21.65
2. Bodhtree Consulting Ltd. 10.42 19.14
3. Celestial Biolabs 20.21 87.94
4. e-zest Solutions Ltd. 7.66 28.95
5. Flextronics (Aricent) 958 8.07
6. iGate Global Solution Ltd. 781.51 13.9
7. Infosys 156.48 40.41
8. Kals Information Systems Ltd. (Seg.) 2.05 41.94
9. LGS Global Ltd. 136.52 26.64
10. Mindtree Ltd. (Seg.) 572.96 17.51
11. Persistent Systems Ltd. 409.88 27.23
12. Quintegra Solution Ltd. 89.88 21.74
13. R systems International (seg.) 144.56 15.3
14. RS. Software (India) Ltd. 101.11 7.79
15. Sasken Communication Technologies 389 13.44 Ltd. (seg.)
16. Tata Elxsi (Seg.) 342.05 18.97
17. Thirdware Solution Ltd. 522.76 18.01
18. Wipro Ltd. (Seg.) 11955.6 28.38
19. Softsol India Ltd. 23.65 42.15 Avg 26.20 4 ITA Nos.3324 & 2948/Del/2013
5. After considering the objections raised by the assessee, the TPO worked out the average of the operating profit margin of the above 19 companies at 25.20% and accordingly proposed transfer pricing adjustment of Rs.5,25,78,549/-. The addition was made by the Assessing Officer at this level. The ld. CIT(A) held Celestial Biolabs as incomparable; adjusted margins of profit of two companies, namely, Kals Information Systems Ltd., and Softsol India Ltd. With the revised list of 18 companies, the ld. CIT(A) computed average of the OP/TC of these companies at 20.48%. Since the PLI of the assessee was at 19.15%, being within the permissible range, he ordered for the deletion of addition of Rs.5.25 crore and odd.
6. We have heard the rival submissions and perused the relevant material on record. It can be seen from the orders of the authorities below that neither the application of TNMM as the most appropriate method nor the PLI has been disputed for determination of the ALP in the `Software development services' segment. Even though the ld. CIT(A) has ordered for the deletion of addition on account of TP 5 ITA Nos.3324 & 2948/Del/2013 adjustment in respect of this international transaction, the assessee is still aggrieved against the inclusion of the following three companies in the list of comparables :-
i) Infosys Technologies Ltd.;
ii) Persistent Systems Ltd.; and
iii) Wipro Ltd.
7. But for the inclusion of the above three companies in the final list of comparables, the assessee is satisfied with all the findings given by the TPO, as endorsed in the first appeal, in respect of other issues connected with the determination of ALP of the international transaction of `Provision of software development services'. We will take up the above three companies, one by one, for the purposes of ascertaining as to whether they are comparable or not. Before embarking upon the exercise of making comparison of these three companies with the assessee, it is sine qua non to consider the functional profile of the assessee under this segment. It can be seen from the TPO's order that he has simply stated that the assessee is engaged in the provision of 6 ITA Nos.3324 & 2948/Del/2013 software development services, but, has not spelt out the further details of the precise nature of actual services rendered. We have gone through the assessee's TP study report, a copy of which is available on pages 12- 127 of the paper book, from which some assistance is available on the question of determination of the exact nature of services. The Ciena Group is a supplier of communications networking equipment, software and services that support the delivery and transport of voice, video and data services. The products of Ciena Group include optical networking, broadband networking and data networking products along with network and services management software used in communication networks and followed by telecommunications service providers across the globe. The Group specializes in transitioning legacy communications networks to be converged, next generation architecture capable of delivering a mix of high band width services. The assessee is engaged in design, development and maintenance of software, which essentially include the activities, namely, Software development services; Procurement, research and technology; Development of design; After-sales activity; and Accounting/administration. The assessee provides contractual 7 ITA Nos.3324 & 2948/Del/2013 software development services to its group companies alone and not to outsiders. These services include maintenance and updation activities. The assessee entered into an agreement with its holding company, Ciena, USA to continue to assist Ciena, USA in research and development activities related to Ciena, USA products. A copy of this Agreement dated 10.4.2006 is available on record. As per this Agreement, the assessee provided software development/Engineering Design/research related to Ciena, USA products and technology. The assessee is compensated by its USA Associated enterprise (AE) with aggregate of direct and indirect costs incurred by it in performing the services to Ciena, USA plus suitable mark-up to be decided on agreed basis from time to time. For the year under consideration, the assessee was compensated with a mark- up of 19%. As per this Agreement, there is a Confidentiality clause by which all information communicated to one party by the other can be used only for the purposes of this Agreement. Clause (9) of the Agreement is captioned as 'Intangible Property Rights.' This clause provides that the assessee, at no time, shall acquire or retain any right, title or interest whatsoever in the work done 8 ITA Nos.3324 & 2948/Del/2013 by it. This clause further provides that the intellectual property rights in the format, presentation, procedures, process, computer software and other material of whatever nature created, developed or enhanced by Ciena India in the course of providing the services to Ciena, USA 'shall be and remain the sole property of Ciena, USA absolutely.' From the above clauses of the Agreement, it is manifest that the assessee is simply a captive unit providing software development services to its AEs without acquiring or retaining any intellectual property rights in the work done by it for and on behalf of its foreign AE, for which it is compensated with actual costs incurred plus 19% mark up. Total operating revenue of the assessee from this segment stands at Rs.98.42 crore with the operating costs at Rs.86.95 crore, giving profit before interest and tax at Rs.11.46 crore and the resultant profit ratio of 13.19%. With the above understanding of the nature of services provided by the assessee to its AEs under this segment, we will espouse the disputed companies for consideration as to their comparability or otherwise.
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ITA Nos.3324 & 2948/Del/2013 Infosys Technologies Ltd.
8.1. The TPO noticed that this company was finding place in the accept/reject matrix and was rejected in the TP documentation by saying that it failed functional area comparability. The TPO found this company to be into software development services qualifying all the filters applied by him. The assessee raised certain objections to the inclusion of this company, but without any success. The TPO computed operating profit margin of this company at 40.41% and included it in the final list of comparables. The assessee is aggrieved against the inclusion of this company in the set of comparables.
8.2. We have considered the rival submissions and perused the relevant material on record. It can be seen that the TPO included this company in the list of comparables by rejecting the assessee's contention about the brand of this company helping in earning huge profits and also the brand related profits swelling its ultimate profit rate. We find that the assessee is a captive unit rendering services to its AEs alone without acquiring any intellectual property rights in the work done by it in the 10 ITA Nos.3324 & 2948/Del/2013 development of software. The Hon'ble Delhi High Court in CIT vs. Agnity India Technologies (P) Ltd. (2013) 219 Taxmann 26 (Del) considered the giantness of Infosys Ltd., in terms of risk profile, nature of services, number of employees, ownership of branded products and brand related profits, etc. in comparison with similar factors prevailing in the case of Agnity India Technologies Pvt. Ltd., being, a captive unit providing software development services without having any IP rights in the work done by it. After making comparison of various factors as enumerated above, the Hon'ble Delhi High Court held Infosys Ltd., to be incomparable with Agnity India Technologies Pvt. Ltd. The facts of the instant case are more or less similar inasmuch as the assessee is also a captive service provider with a limited number of employees at its disposal and also not owning any branded products with no expenditure on R&D at its own etc. When we consider the cumulative effect of all the above factors, we find that by no standard, the assessee can be compared with Infosys Technologies Ltd. Respectfully following the judgment of the Hon'ble jurisdictional High Court in Agnity India (supra), we hold that Infosys Technologies Ltd. to be incomparable with 11 ITA Nos.3324 & 2948/Del/2013 the assessee company. This company is, therefore, directed to be excluded from the list of comparables.
Persistent Systems Ltd.
9.1. The TPO observed this company to be engaged in software development services with predominant revenues from software development services. He called for some information u/s 133(6) of the Act from this company regarding break up of software products and software development services. On consideration of such information, he observed that around 95.1% of the total revenue of this company was from software development services and the remaining amount was from software products. After considering the assessee's objections, the TPO included it in the list of comparables. The assessee is aggrieved against the consideration of this company as comparable.
9.2. We have heard the rival submissions and perused the relevant material on record. It can be seen from the information supplied by this company u/s 133(6) of the Act, a part of which has been reproduced in the TPO's order, that this company 'has developed a few of its own 12 ITA Nos.3324 & 2948/Del/2013 products in the area of identity management connectors.' Revenue from product licences stands at Rs.288.93 million as against the revenue from software development services at Rs.4829.57 millions. Though this company is more engaged in software development services, but, is also a software product company, which is evident from the information supplied by it to the TPO. Thus, the total profits of the company on entity level also, inter alia, include revenue from product licences. As there is no separate segmental information and it has been considered as comparable on entity level, it implies that the total revenue considered also consist of some part from product licences. In such circumstances, it is not possible to ascertain the impact of such revenue on the total revenue of this company. Further, there is no information available from the Annual report of this company or the data collected by the TPO u/s 133(6) of the Act to divulge the amount of revenue from software development services alone to the exclusion of revenue from product licences. As the assessee is not engaged in the sale of any software products, this company on entity level, cannot be considered as comparable. The Delhi Bench of the Tribunal in the case of Toluna 13 ITA Nos.3324 & 2948/Del/2013 India Pvt. Ltd. Vs. ACIT (ITA No.5645/Del/2011, vide its order dated 26.8.2014 has held Persistent Systems Ltd. to be incomparable with Toluna India Pvt. Ltd., also a company engaged in providing software development services to its related parties alone. Similar view has been taken by the Tribunal in Lear Automotive India Pvt. Ltd. Vs. ACIT (ITA No.5612/Del/2011) vide its order dated 22.12.2014. The ld. DR could not point out any distinguishing feature in the factual matrix of the assessee in question and Toluna India Pvt. Ltd., and Lear Automotive India Pvt. Ltd. Since both these companies are also engaged in the business of providing software development services to its AEs, similar to the activity done by the assessee, respectfully following the precedents, we order for the exclusion of this company from the list of comparables.
Wipro Ltd. (Seg.) 10.1. The assessee rejected this company in its TP document by treating it as functionally different. The TPO observed that the IT services segment of this company on standalone basis was comparable 14 ITA Nos.3324 & 2948/Del/2013 with the assessee company. He sought some information from this company u/s 133(6) of the Act and, thereafter, came to the conclusion that its IT services segment was comparable with the assessee. In doing so, he rejected the assessee's contention about branding and turnover, which was also taken by the assessee against the inclusion of Infosys Technologies Ltd. The ld. CIT(A) upheld the finding of the AO/TPO in treating it as a correct comparable. The assessee is aggrieved. 10.2. We have heard the rival submissions the perused the relevant material on record. It can be observed from the TPO's order itself that the facts and circumstances of Wipro Ltd., are somewhat similar to Infosys Technologies Ltd., inasmuch as he has proceeded to reject the assessee's objections by relying on the reasoning given by him for the inclusion of Infosys Ltd. It is further observed that Wipro Limited (Seg.) was considered as comparable by the TPO in the case of Toluna India (supra) and Lear Automotive (supra). The Tribunal, in both the cases, has held Wipro Ltd. (Seg.) as not comparable. This company is also operating as a full-fledged risk taking entity; engaged in providing 15 ITA Nos.3324 & 2948/Del/2013 technology infrastructure services, testing services, package implementation having more than 82,000 employees. It has its own R&D centre. It incurred around 11% of net sales as expenditure on research and development. None of the above factors match with the assessee company. Respectfully following the above precedents, we hold that this company is not comparable.
10.3. There is another reason for holding this company as incomparable. It can be seen that there was a merger of Wipro Infrastructure Engineering Ltd., Wipro Healthcare IT Ltd., Quantech Global Services Ltd., with this company during the year in question. This merger was approved by the Hon'ble Karnataka High Court and the Hon'ble AP High Court during the financial year 2007-08. The Mumbai Bench of the Tribunal in Petro Arandite (P) Ltd. Vs. DCIT (2013) 154 TTJ (Mum) 176 has held that a company cannot be considered as comparable because of financial results distorted due to mergers and demergers, etc. Similar view has been taken by the Delhi Bench of the Tribunal in the case of Toluna India Pvt. Ltd. (supra). As there were 16 ITA Nos.3324 & 2948/Del/2013 amalgamations in Wipro Ltd. during the financial year in question, this fact also makes it incomparable with the assessee company. In view of the foregoing reasons, we direct to exclude Wipro Limited (Seg.) from the list of comparables.
11. No other aspect of the computation of ALP of the international transaction of `Provision of software development services' has been challenged by the assessee in the present appeal. The impugned order is ergo set aside on the question of determination of the ALP of the `Software development services' segment and the matter is remitted to the file of AO/TPO for computing ALP of the international transaction of this segment afresh in consonance with our above directions. Needless to say, the assessee will be allowed a reasonable opportunity of being heard.
12. Ground no. 1(d) is against the exclusion of certain companies from the list of comparables in the 'Marketing support services' segment. Briefly stated, the facts of this ground are that the assessee reported international transaction of 'Provision of marketing support services' 17 ITA Nos.3324 & 2948/Del/2013 with the transacted value of Rs.4,21,25,941/-. The assessee employed TNMM as the most appropriate method with the PLI of Operating profit to Total cost (OP/TC). The assessee's profit margin under this segment was declared at 13.58%. The assessee chose 11 companies as comparables whose average profit margin was within the permissible range of the assessee's profit margin under this segment. For the reasons given in his order, the TPO completely rejected the assessee's list of comparables and chose 10 new companies as comparable. The average operating profit margin of these companies was computed at 22.5% and, accordingly, transfer pricing adjustment of Rs.33,13,077/- was proposed by the TPO, which was eventually made by the AO. The ld. CIT(A) excluded Apitco Ltd., Rites Ltd., and Vapi Waste and Affluent Management Company Ltd. from the final list of comparables drawn by the TPO. This resulted into the deletion of addition on account of transfer pricing adjustment under this segment. Both the sides are in appeal against the impugned order to the extent it is prejudicial to them. Whereas the assessee has challenged the inclusion of Choksi Laboratories Ltd., and WAPCOS Ltd. (Seg.) in the list of 18 ITA Nos.3324 & 2948/Del/2013 comparables, the Revenue is aggrieved only against the exclusion of Apitco Ltd.
13. We have heard the rival submissions and perused the relevant material on record. Before examining the comparability or otherwise of the companies challenged before us, it is of utmost importance to consider the nature of activity carried out by the assessee in the provision of marketing support services. There is no elaboration of the nature of services in the Agreement between the assessee and Ciena Corporation, USA, except for mentioning in Schedule 2: 'Provision of other such services to Ciena, USA as Ciena, USA may reasonably request from time to time.' The TPO has also not discussed the nature of services under this segment except for recording the description of transactions with its nomenclature being 'Provision of marketing support services.' When we advert to the TP study report, it can be found that the functions performed by the assessee in the provision of marketing support services are indicated at page 29 of the paper book, as under:- 19
ITA Nos.3324 & 2948/Del/2013 • "Marketing: Marketing activities undertaken by Ciena India includes identifying potential customer, collecting market related information, attending trade exhibitions and industry shows, etc. • Sales support: Sales support activities comprise gathering information and analyzing industry information, making presentations on Ciena products and services and providing relevant support to Ciena, US.
• Technical Support: Ciena India also provides technical support services to the customers. During FY 2007-08, the Company rendered training and installation support to the end customers of Ciena US. Also, Ciena India received training on technical matters from Ciena Group."
14. From the above description of Marketing support services performed by the assessee for its foreign AE, it is patent that the assessee's nature of work basically includes identifying potential customers and providing technical support services to the customers of its AE. The work of identifying customers is carried out by collecting 20 ITA Nos.3324 & 2948/Del/2013 market related information, attending trade exhibitions, etc. With this background in mind about the nature of services provided by the assessee under this segment, we now proceed to examine whether or not the companies under challenge are comparable.
Choksi Laboratories Ltd.
15. The TPO visited the website of this company and noticed that it was engaged in providing 'analysis, calibrations, pollution control and consultancy services' to a broad spectrum of industries. By considering such nature of services provided by this company, the TPO held that these were similar to the services provided by the assessee to its AE. We have gone through the Annual report of this company, which is available on pages 2370 onwards of the paper book. Note no. 8 to Part B - 'Notes forming part of the accounts' - provides that this company is a commercial testing house engaged in testing of various products and also offers services in the field of pollution control as allied activity. Para 2 of the Annexure to the auditor's report also clarifies that this is a company engaged in rendering services 'for testing purposes.' From the 21 ITA Nos.3324 & 2948/Del/2013 above description of the nature of services carried on by this company, it is evident that it is basically engaged in providing testing services for various products and also offers services in the field of pollution control. As against this, the services provided by the assessee are purely in the nature of identifying customers for its AEs and providing technical support services to their customers. We fail to appreciate as to how marketing support services can be equated with testing services. When we peruse Schedule of fixed assets of this company, it can be seen that the major asset is 'Instruments.' It is with the help of these instruments that the company is providing services in the nature of testing of various products. By no standard, this company can be considered as comparable with the assessee company. We, therefore, direct the exclusion of this company from the list of comparables. WAPCOS Ltd. (Seg.) 16.1. The TPO considered this company as comparable by observing that it was providing support services in terms of technical support, technical know-how valuation and assistance in 22 ITA Nos.3324 & 2948/Del/2013 development/upgradation of potential suppliers, etc. The assessee's objections about the functional dissimilarity of this company, were rejected.
16.2. After considering the rival submissions and perusing the relevant material on record, we find from the Annual report of this company that it has two segments, namely, 'Consultancy and engineering projects' and 'Lumpsum turnkey projects.' The TPO has taken 'Consultancy and engineering project segment' for the purposes of comparison with the assessee company. This company is engaged in infrastructure development projects. This company is also working as independent review and monitoring agency for projects in some States. It is also providing supervision and quality control consultancy for construction/upgradation of rural roads under PMGSY. It also secured projects for development and hygiene education, development of dry pit latrines, designs for local conditions for household and schools and solid waste management. It also secured projects for transmission line Kirti Irti to Sta, Treng, Camhodia. A review of the above services provided 23 ITA Nos.3324 & 2948/Del/2013 by this company, it can be easily ascertained that it is nowhere close to the rendering of marketing support services, which is being done by the assessee under this segment. The nature of activity done by the assessee is quite distinct from this company. We, therefore, direct to exclude WAPCOS Ltd. (Seg.) from the list of comparables.
17.1. The Revenue is aggrieved against the exclusion by the ld. CIT(A) of Apitco Ltd. This company was considered as comparable by the TPO. The ld. CIT(A) noticed that this company to be engaged in providing technical and engineering services and also executing projects on turnover basis. He, therefore, held this company to be not comparable.
17.2. Having heard the rival submissions and perused the relevant material on record, we find from the Annual report of this company that it is engaged in providing several services, viz., Micro Enterprises Development, Skill Development, Entrepreneurship Development, Research Studies, Project related Services, Infrastructure Planning & Development, Environment Management, Energy related Services, 24 ITA Nos.3324 & 2948/Del/2013 Cluster Development, Technology Facilitation, Asset Reconstruction & Management Services, Emerging Areas. It can be seen from the nature of operations carried out by this company that the same is towards Micro enterprises development, Skill development and Project related services, etc., also including Infrastructure planning and development along with Energy related service and Cluster development. A part of its activities has got some resemblance with the nature of service provided by the assessee under this segment. The ld. CIT(A) has recorded that 'only 12% of total income of this company is from research studies which is akin to the nature of services provided by the assessee company.' This contention has not been controverted by the ld. DR with any clinching evidence. When we consider the operations of this company as enumerated above and the fact that this company has maintained accounts on entity level and there is no bifurcation available in respect of the services similar to those provided by the assessee under this segment, this company on entity level cannot be considered as comparable. We, therefore, hold that the ld. CIT(A) was justified in considering this company as not comparable.
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ITA Nos.3324 & 2948/Del/2013
18. Ground nos. 2 and 3 of the assessee's appeal were not pressed. The same, therefore, stands dismissed.
19.1. Ground no. 2 of the Revenue's appeal is against the deletion of addition made by the AO on account of training and recruitment expenses. The assessee claimed deduction for a sum of Rs. 2,24,62,589/- towards recruitment and training expenses. The AO allowed 20% deduction for such expenses in the current year and treated the remaining 80% as capital expenditure, for which disallowance was made for a sum of Rs.1,79,70,072/-. The ld. CIT(A) deleted this addition.
19.2. After considering the rival submissions and perusing the relevant material on record, we find that the view taken by the ld. CIT(A) accords with the judgment dated 27.4.2010 of the Hon'ble jurisdictional High Court in the case of CIT vs. Solus Pharmaceuticals Ltd., in which it has been held that the training expenses are to be allowed as revenue expenses. We, therefore, uphold the view taken by the ld. CIT(A). This ground fails.
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ITA Nos.3324 & 2948/Del/2013
20. The last ground is against the deletion of addition on account of Sundry balances written off without giving any opportunity to the AO examine the evidence filed by the assessee before the ld. first appellate authority. The ld. AR fairly admitted that the ld. CIT(A) partly deleted the addition by considering additional evidence which was not there before the AO. Under such circumstances, we do not propose to examine the merits of the addition, which has been deleted in violation of rule 46A of the Income-tax Rules, 1962. Accordingly, the impugned order on this issue is set aside and the matter is sent to the file of AO for deciding it afresh as per law, after allowing a reasonable opportunity of being heard to the assessee. Needless to say, the assessee will be at liberty to lead any fresh evidence before the AO in this regard.
21. In the result, both the appeals are allowed for statistical purposes.
The order pronounced in the open court on 23.04.2015.
Sd/- Sd/-
[C.M. GARG] [R.S. SYAL]
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated, 23rd April, 2015.
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ITA Nos.3324 & 2948/Del/2013
dk
Copy forwarded to:
1. Appellant
2. Respondent
3. CIT
4. CIT (A)
5. DR, ITAT
AR, ITAT, NEW DELHI.
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