Income Tax Appellate Tribunal - Mumbai
Tata Motors European Technical Centre, ... vs Assessee on 22 December, 2014
.T.A.No.7630 and 1698/Mum/2012 1 ुं ई यायपीठ "के" मब आयकर अपील य अ धकरण, मब ुं ई IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH, MUMBAI BEFORE S/SHRI N.K.BILLAIYA, (AM) AND AMIT SHUKLA, (JM) सव ी एन. के. बलै या, लेखा सद य एवं अ मत शु ला, या यक सद य के सम आयकर अपील सं./I.T.A.No.7630/Mum/2012 I.T.A.No.1698/Mum/2014 ( नधारण वष / Assessment Years: 2008-09 and 2009-10) Tata Motors European बनाम/ Assistant Director of Income Tax Technical Centre Plc, (IT)(2(2), Vs. C/o third floor, Room No.116, 1st floor, Nanavati Mahalaya, Scindia House, 18, Homi Mody Street, Ballard Pier, Hutatma Chowk, Mumbai-400038 Mumbai-400001.
थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AACCT7506K (अपीलाथ /Appellant) .. ( यथ / Respondent) अपीलाथ ओर से / Assessee by : S/Shri R R Vora, Nikhil Tiwari and Manoj Anchalia यथ क ओर से/Revenue by : Shri S D Srivastava सन ु वाई क तार ख / Date of Hearing : 29.9.2014 घोषणा क तार ख /Date of Pronouncement : 22.12.2014 आदे श / O R D E R Per AMIT SHUKLA(JM) The aforesaid appeals have been filed by the assessee against the two separate impugned final assessment orders dated 25.12.2011 for the assessment year 2008-09 and 30.1.2014 for the assessment year 2009-10, passed in pursuance of directions by the Dispute Resolution Panel (DRP). Since issue involved in both the .T.A.No.7630 and 1698/Mum/2012 2 these appeals are common, arising out of similar facts, therefore, were heard together and are being disposed off by this consolidated order, for the sake of convenience.
2. To understand the implications of facts and issues involved, we will take up the appeal for the assessment year 2008-09, vide which following grounds of appeal have been taken:.
"1. A) The Transfer Pricing Officer (TPO) / Assessing Officer (AO) has erred in law and on facts in making addition of Rs.8,04,58.874/- by adopting Indian comparables as comparables for benchmarking international transactions of provisioning of services to Tata Motors Ltd. ("TML"). B) The TPO / AO ought to have accepted benchmarking carried out by the assessee and selection of UK companies as comparables for benchmarking the international transactions of the company considering the facts of the case of the appellant.
C) The TPO/ AO has erred in law and on facts in disregarding that in the previous assessment year, department has accepted and considered UK companies as comparables for the purpose of benchmarking of international transactions and hence the AO/ TPO should have followed the same as there is no change in the facts of the case.
2. Without prejudice to Ground No. 1 above,:
A) The TPO/ AO has erred in law and on facts in cherry picking 7 Indian companies as comparables which are functionally not comparable with the appellant. B) The TPO/ AO has erred in law and on facts in picking up companies with high margin instead of following detailed, systematic and methodical search process.
C) The learned TPO/ AO has erred in law and on facts in non granting Opportunity of cross examining the comparables selected by the TPO/ AO.
.T.A.No.7630 and 1698/Mum/2012 3
3. The learned TPO / AO has erred in law and on facts in not granting credit of TDS of Rs. 11,79,35,990/- out of total TDS credit of Rs.12.06.64,360.
4. The learned TPO / AO has erred in law and on facts in levying interest under section 23413 of the Act of Rs. 1,77,76,885.
The learned TPO / AO has erred in law and on facts in levying interest under section 234C of the Act of Rs.10,878/-"
3. Brief facts qua the issue relating to Transfer Pricing Adjustment of Rs.8,04,58,878/- are that, the assessee, Tata Motor European Technical Centre PLC (TMETC) is incorporated in the United Kingdom (UK) and is resident of UK. The assessee is having technical expertise of Automotive Industries of European Standards, and is wholly owned subsidiary of Tata Motors Ltd (TML). The TML entered into design and engineering service agreement with the assessee for providing design, engineering, testing and validation, research and development of automobiles, including progrmme management for the automotive and aerospace industries. For rendering these services for the TML, the assessee sent its employees in India by deputing engineers and technical personnel at TML's factory/establishment in India. Thus, the assessee had a Service PE in India. The assessee, for rendering design and engineering services for TML during the year, had received an .T.A.No.7630 and 1698/Mum/2012 4 amount of Rs.31,98,72,720/- and the operating profit for the year was shown in the following manner :
Total operating income Rs. 31,98,72,720 Total operating cost Rs.29,27,04,244 Operating profit Rs.2,71,68,476 OP/TC% 9.28%
In the TP study report, for the purpose of benchmarking its transaction and the margin, the main factors which were taken into account were that, the design and engineering services for automotive industries is highly Specialized services and considering the nature of automotive industries in terms of global standards, competition and growing compliance requirements towards safety and environmental norms, the parallels are not available in India.
The other factors for consideration were that, as against the operation cost incurred by the PE, the major portion was towards the salary of the employees who had special skills and knowledge and were paid salary in UK only. The PE did not had any independent business in India and it does not enter into any contract with outside party in India. Considering these factors and FAR analysis which was effected by demographic and economic factors in UK, the assessee searched for UK comparables rendering similar kind of services in UK. Thus TMETC (i.e the assessee) was taken as tested party for .T.A.No.7630 and 1698/Mum/2012 5 benchmarking the ALP. Based on FAR analysis and by adopting TNMM as the most appropriate method and PLI as OP/TC, the assessee selected four overseas comparables located in UK to benchmark the Arm Length Price of the transactions with the AE i.e TML, which were as under :
S.No. Name of the 2007 2006 2005% 3 year
comparables % % weighted
Avg.(%)
1 Dytcna limited 4.17 6.74 4.86 5.26
2 Ricardo PLC 8.34 10.11 6.90 8.47
3 Online Design 6.98 5.85 5.47 6.22
and
engineering
Ltd.
4 Acteon group 21.87 19.63 10.60 18.31
Ltd
Average 10.34 10.59 6.96 9.57
Assessee's 9.28%
profit margin
Since, for the year 2007 the average profit margin of the comparables was arrived at 10.34%; therefore, the assessee's profit margin being at 9.28%, was stated to be at Arm's Length range.
4. The Transfer Pricing Officer (TPO) though accepted the TNMM method and the PLI employed by the assessee for determining the ALP of its international transactions, however, completely disagreed with the selection of foreign comparables based in UK, as he held that it is not tenable under the Indian Transfer Pricing Rules and .T.A.No.7630 and 1698/Mum/2012 6 provisions. His other reasoning was that, that since the PE of the assessee is located in India and carrying out its business within the Indian territory, therefore, it should be treated as business entity in India, akin to the other corporate entities doing business in India.
Further assessee's direct and indirect cost are incurred in and in connection with business transactions in India and therefore, Indian comparables should be selected for benchmarking the assessee's margin. The TPO, hence selected 7 Indian comparables having average mean margin of 36.77% which are as under :
S.No. Company Name OT /TC
1 Mahindra Consulting Engineers Ltd 28.96%
2 Alplangeo (India) Ltd. 41.58%
3 Stup Consultants Pvt Ltd. 36.72%
4 Semac Ltd 49.65%
5 Mitcon Consultancy Services Ltd. 41.21%
6 Kirloskar Consultants Ltd 21.29%
7 Computronics Financial 38.02%
Average Mean 36.77%
In response to the show cause notice, the assessee gave detailed submissions justifying the selection of foreign comparables, which have been incorporated by the TPO at para 8 of his order.
Assessee' contention has been rejected by him in detail, as per the discussions appearing at pages 5 to 9 of the order and accordingly, he benchmarked the assessee's margin with the mean profit .T.A.No.7630 and 1698/Mum/2012 7 margin of the 7 Indian comparables and made adjustment of Rs.8,04,58,874/- in the following manner:
Total Operating Income Rs.31,98,72,720/-
Total operating cost Rs.29,27,04,244/- Operating profit Rs.2,71,68,476/- Profit Margin of assessee 9.28% Arm' Length Profit Margin (36.77% of OC) Rs.10,76,27,350/- Arm's Length value of transactions Rs.40,03,31,594/- 95% of Arm's Length Value Rs.38,03,15,014 Difference being shortfall in OP being Rs.8,04,58,874/- adjustment
5. One of the main objection of the assessee before the DRP was that, in the immediately preceding year i.e. in the assessment year 2007-08, on identical international transactions, the TPO has accepted the UK comparables, selected from foreign data for bench marking the international transactions of the assessee and therefore, in this year also the TPO should have accepted the foreign comparables. The DRP rejected the assessee's contentions and other objections on the ground that the tested party is the Indian PE, who is working in the Indian business environment and the mere fact that the employees get paid in European or UK currency will not decide the selection of foreign comparables. For the purpose of Income tax, the PE has to be treated as distinct and separate enterprise of the foreign company and therefore, the TPO has rightly selected Indian companies as comparables. For other objections .T.A.No.7630 and 1698/Mum/2012 8 also, the DRP rejected the assessee's contention and upheld the order of the TPO.
6. Before us, ld. counsel Shri Rajan Vora, submitted that the assessee being UK based company having its principal business in UK from where it manages the services provided to TML motors and all its employees are UK nationals having technical knowledge of automotive industries and economic environment of European Countries and therefore, based on the nature of business and geographical factors, the comparability analysis can be done only through selection of UK comparables engaged in the similar activities, for the proper determination of ALP. The TMETC-PE is not influenced by the Indian economic/financial environment and there are no Indian employees. All the costs considered for attribution of PLI are incurred by TMETC in UK only. Even under the Indian Transfer Pricing Regulations, comparability analysis based on FAR is the most crucial part for bench marking the Arm's Length Price, which is mainly based on selection of comparables having similar kind of business, functions and environment. In support of his proposition, for the selection of foreign comparables he relied upon the following Tribunal decisions:
a) Global Vantedge Pvt Ltd (2010) TIOL-24-ITAT-Del) and .T.A.No.7630 and 1698/Mum/2012 9
b) Ranbaxy India Ltd (299 ITR (AT) 175 (Del) He further submitted that OECD guidelines, and UN Practical Manual on Transfer Pricing for the developing countries have recognized that foreign comparables can be taken into consideration, if the tested party has been chosen as the foreign company. The aforesaid decisions of the Tribunal have taken into cognizance such OECD guidelines and UN manual. Thus, he submitted that selection of foreign comparables for the purposes of comparability analysis and bench marking the Arm's Length Price should be taken into consideration. Without prejudice to the above, he also made detailed submissions with regard to the 7 comparables chosen by TPO, to demonstrate that there are no actual comparables having similar profile and functions with that of the assessee and therefore, no company in India can be considered as comparable with the assessee. He also filed written synopsis, with regard to each comparables, to show, how they are functionally not comparable with the assessee.
7. On the other hand, the ld. CIT DR strongly relied upon the order of TPO and the direction given by DRP and submitted that, if the PE of the assessee has been considered as Indian entity, functioning in India and all its services are being rendered in India, then its .T.A.No.7630 and 1698/Mum/2012 10 margin for the Indian transaction have to be bench marked with the Indian comparables. Thus, the TPO has rightly adopted Indian comparables for bench marking the ALP of the assessee for its services rendered to Tata Motors.
8. We have heard the rival submissions, perused the relevant findings of the TPO as well as directions of DRP and also material placed on record. The assessee, TMETC is UK based company which is wholly owned subsidiary of Tata Motors Ltd, India. Its business activities primarily involved providing of automobile design and engineering services to the TML and for rendering these services the TMETC-UK sends its employees/engineers to India. It is in this background, the TMETC has been considered as having a service PE in India and therefore, its profit from Indian operation is taxable in India. For the purposes of TP analysis, the assessee has selected TMETC as the tested party, since all its operating cost are incurred in UK, having employees based in UK, therefore, it has selected comparable companies from UK having similar kind of functions and rendering similar services. It has selected four UK based comparables having average arithmetic mean of 10.3% for the year 2007, and therefore, it was stated that its margin of 9.8% (OP/TC) is at arm's length range.
.T.A.No.7630 and 1698/Mum/2012 11
9. The sole issue before us is, whether the assessee was justified in carrying out comparative analysis on the basis of UK based comparables, rather than by selecting Indian comparables. The TPO's main objection is that, since the Indian PE is performing its function in India and rendering services to Indian company, therefore, margins for the Indian operation has to be bench marked with the Indian comparables. Indian Transfer Pricing Regulations specifically Rule 10B of the Income Tax Rules, 1962 does not specify that the comparability analysis of international transactions has to be strictly with the Indian companies but, it only lays down that comparability with uncontrolled transactions has to be chosen with reference to :
(2) For the purposes of sub-rule (1), the comparability of an international transaction with an uncontrolled transaction shall be judged with reference to the following, namely:--
(a) the specific characteristics of the property transferred or services provided in either transaction;
(b) the functions performed, taking into account assets employed or to be employed and the risks assumed, by the respective parties to the transactions;
(c) the contractual terms (whether or not such terms are formal or in writing) of the transactions which lay down explicitly or implicitly how the responsibilities, risks and benefits are to be divided between the respective parties to the transactions;
(d) conditions prevailing in the markets in which the respective parties to the transactions operate, including the geographical location and size of the markets, the laws and Government orders in force, costs of labour and capital in the markets, overall economic development and level of competition and whether the markets are wholesale or retail."
.T.A.No.7630 and 1698/Mum/2012 12 Thus, the Indian Transfer Pricing Regulations while selecting comparable companies lays emphasis on FAR analysis, and conditions prevailing in the markets in which the parties operate for carrying out the comparability analysis. If such comparability analysis could not be done properly with the Indian comparables looking to the characteristics and nature of the functions performed and services rendered then, it has to be seen from the angle who is selected as "tested party" and based on that, comparables are to be chosen from the economic factors and the functions performed in the conditions prevalent of the tested party. If the tested party itself is foreign based and the services rendered by it is very specific, for which the Indian comparables are not available or functionally not comparable then, it cannot be held that foreign comparables cannot be selected for benchmarking the Arm's Length Price or margin. Indian Transfer Pricing Regulation does not puts any fetters on selection of foreign comparables, if conditions are as such, that the Indian comparables do not stand the test of comparability with the tested party. Answer to this has been given in the OECD Transfer Pricing Guidelines which provides that non-domestic comparables should not be automatically rejected and it has to be seen on case by case basis by the reference to the extent to which they satisfy .T.A.No.7630 and 1698/Mum/2012 13 the comparability factors. The relevant paragraph of the OECD guidelines reads as under :
"A.4.3.2 Foreign source or non domestic comparables 3.5 Taxpayers do not always perform searches for comparables on a country-by-country basis, e.g. in cases where there are insufficient data available at the domestic level and/or in order to reduce compliance costs where several entities of an MNE group have comparable functional analyses. Non-domestic comparables should not be automatically rejected just because they are not domestic. A determination of whether non- domestic comparables are reliable has to be made on a case-by-case basis and by reference to the extent to which they satisfy the five comparability factors. Whether or not one regional search for comparables can be reliably used for several subsidiaries of an MNE group operating in a given region of the world depends on the particular circumstances in which each of those subsidiaries operates. See paragraphs 1.57-1.58 on market differences and multi-country analyses. Difficulties may also arise from differing accounting standards"
10. If the tested party has been selected consistent with the functional analysis of the controlled transaction and is a least complex party to the controlled transaction, then even if it is a foreign party, the same should be taken as the basis for carrying out comparability analysis with the uncontrolled transaction by taking into account the business environment in the country where the tested party is being bench marked. Internationally, it has been recognized that choice of the tested party should be such having least complexity and should be the party in respect of which most .T.A.No.7630 and 1698/Mum/2012 14 reliable data for comparability is available. The UN Manual on Transfer Pricing, in Chapter 5 envisages the selection of tested party in the following manner :
"5 . 3. 3. Selection of the Tested Party 5.3.3.1. When applying the Cost Plus Method, Resale Price Method or Transactional Net Margin Method (see further Chapter 6) it is necessary to choose the party to the transaction for which a financial indicator (mark-up on costs, gross margin, or net profit indicator) is tested. The choice of the tested party should be consistent with the functional analysis of the controlled transaction. Attributes of controlled transaction(s) will influence the selection of the tested party (where needed). The tested party normally should be the less complex party to the controlled transaction and should be the party in respect of which the most reliable data for comparability is available. It may be the local or the foreign party. If a taxpayer wishes to select the foreign associated enterprise as the tested party, it must ensure that the neces- sary relevant information about it and sufficient data on comparables is furnished to the tax administration and vice versa in order for the latter to be able to verify the selection and application of the transfer pricing method."
It is very pertinent to note here that in Chapter 10, of the UN Manual, in Para 10.4.1.3, Indian Transfer Pricing Regulation have accepted the foreign comparables in cases where the foreign AE is the least complex entity and requisite information about the tested party and comparables re available. The relevant paragraph reads as under :-
"10.4.1.3 The regulations prescribe mandatory annual filing requirement as well as maintenance of contemporaneous .T.A.No.7630 and 1698/Mum/2012 15 documentation by the tax payer in case international transactions between associated enterprises cross a threshold and contain stringent penalty implication in case of non- compliance. The preliminary onus of proving the arm's length price of the transaction lies with the taxpayer, The Indian transfer pricing administration prefers Indian comparables in most cases and also accepts foreign comparables in cases where the foreign associated enterprises is the less or least complex entity and requisite information is available about the tested party and comparables."
Thus, the Indian Transfer Pricing does not reject the concept of foreign comparables, if the tested party is foreign AE. The blanket assumption by the TPO and DRP that foreign comparables cannot be accepted at all, is not correct. Similarly, US TP Regulations for the purpose of Bench marking under comparable method has laid down the following criterion for selection of tested party:
"(2) Tested party -(i) In general. For purposes of this section, the tested party will be the participant in the controlled transaction whose operating profit attributable to the controlled transactions can be verified using the most reliable data and requiring the fewest and most reliable adjustments, and for which reliable data regarding uncontrolled comparables can be located. Consequently, in most cases the tested party will be the least complex of the controlled taxpayers and will not own valuable intangible property or unique assets that distinguish it from potential uncontrolled comparables."
Further Para § 1.482-1 (C) viz, relevant factors for comparability of uncontrolled companies is reproduced as under:
(ii) Different geographic markets--('A) In general uncontrolled corn parables ordinarily should be derived from the geographic market in which the controlled taxpayer operates, because .T.A.No.7630 and 1698/Mum/2012 16 there may be significant differences in economic conditions in different markets. If information from the same market is not available, an uncontrolled comparable, derived from a different geographic market may be considered if adjustments are made to account for differences between the two markets. If information permitting adjustments for such differences is not available, then information derived from uncontrolled comparables in the most similar market for which reliable data is available may be used, but the extent of such differences may affect the reliability of the method for purposes of the best method rule. For this purpose, a geographic market is any geographic area in which the economic conditions for the relevant product or service are substantially the same, and may include multiple countries, depending on the economic conditions."
11. Here in this case, there can no dispute with regard to the fact that the tested party is TMETC, whose operating profit is to be bench marked by carrying out functional analysis of its controlled transactions for which reliable data for its comparability is available in the country where it is located, then such comparables has to be taken into account for carrying out the comparability analysis for the purpose of Transfer Pricing and bench marking the Arm's Length Price. The TMETC for the purpose of rendering services in India is incurring all its cost in UK like direct costs, employee costs, legal and professional fees, rent and other operating expenses, then for the purpose of computation of PLI, these costs have to be taken into consideration for determining the profit margin. Since all the main costs attributable to the PE are based on cost incurred in UK, then it can be very well said that PE is influenced by the economic and .T.A.No.7630 and 1698/Mum/2012 17 financial conditions of UK, as against the Indian economic factors. The Indian economic factors are not at all influencing the cost or margin of the assessee, hence it cannot be held that Indian comparables can be used to bench mark the TMETC transaction and the price with Tata Motors. For this reason, the finding of the TPO as well as DRP that PE is an Indian enterprise, working in India and therefore, its margin is to be bench marked with Indian comparables is not accepted. The PE in India is a service PE, having no establishment in India, nor incurring any costs, deployed any assets, therefore, cannot be held that it is an independent Indian enterprise. Nothing has been brought on record that assessee's PLI is influenced by the economic factors in India, viz, attribution of costs, assets or other factors relevant for determination of profits are based in India. Thus, in our opinion, the Transfer Pricing Officer and DRP were not correct in holding that UK comparables cannot be taken into consideration for the purposes of comparative analysis and bench marking the assessee's margin. Accordingly, we hold that under the facts and circumstances of the case, the foreign comparables i.e. UK comparables can be taken into account for carrying out FAR analysis and bench marking the Arm's Length margin of the assessee's transactions with its AE and the selection of the Indian comparables by the TPO is not accepted. Since the .T.A.No.7630 and 1698/Mum/2012 18 TPO has not carried out any comparability analysis or FAR analysis in respect of UK comparables chosen by the assessee, therefore, he is directed to carry out such analysis and benchmark the assessee's margin. If such comparables do not stand the test of comparability then, TPO may search other comparable after confronting to the assessee. In that case, for the search of comparability assessee will provide necessary assistance to the TPO. With this direction, the matter of transfer pricing adjustment is restored back to the file of the TPO/AO. The Ground No.1 as raised by the assessee is thus treated as partly allowed for statistical purposes.
12. In view of the decision as given in ground No.1, ground No.2 has become purely academic and therefore no adjudication is required.
13. Ground No.3 raised by the assessee is not pressed, therefore, same is dismissed as not pressed.
14. In Ground No.4, the assessee has challenged the levy of interest u/s 234B of the Act of Rs.1,77,76,885/-
15. In this regard, the ld. AR submitted that this issue is squarely .T.A.No.7630 and 1698/Mum/2012 19 covered in favour of the assessee by the decision of the Hon'ble Bombay High Court in the case of Director Of Income-tax (International Taxation). Vs. NGC Network Asia(2009) 313 ITR 187(Bom). Accordingly, we direct the AO to follow the decision of jurisdictional High Court (supra), if the ratio is applicable on the facts of the case.
16. In Ground No.5, the assessee has challenged the levy of interest u/s 234C of the Act of Rs.10.878/-
17. Before us, the ld. counsel submitted that no interest u/s 234C should levied as the same is leviable on the returned income. Accordingly, we direct the AO to charge interest u/s 234C on the returned income.
18. Thus, the appeal of the assessee is treated as partly allowed for statistical purposes.
19. The assessee has also raised the following as additional grounds:
"6. Without prejudice to the all other grounds, the Hon'ble DRP should have directed fresh comparability analysis to select Indian comparables which are functionally comparable to appellant, as comparables chosen by the AO/TPO to benchmark the transition are functionally different;.
7. Without prejudice to the all other grounds , the ld. TPO/AO has erred in not considering the correct operating .T.A.No.7630 and 1698/Mum/2012 20 margin of the appellant i.e. 27.61% (i.e. OP/OC), while computing the arms-length price of appellants international transactions and instead of considering 9.28% as operating margin of the appellant"
20. In the assessment year 2009-10 also the assessee has raised exactly similar ground. However, In view of the decision given in respect of ground No.1, the additional grounds have become purely academic and the same is dismissed as infructuous. ITA No.1698/Mum/2014 (AY-2009-10)
22. The sole issue raised in this appeal by the appellant is that the AO has erred in making addition on account of transfer pricing adjustment of Rs.5,38,24,761/- by selecting the Indian companies as comparables, instead of foreign companies for benchmarking the international transaction of provision of services, with the AE .
23. Since the issue raised is similar to ground raised in the appeal of assessee for the assessment year 2008-09 vide ground No.1, on similar set of facts, therefore, finding given therein will apply mutatis mutandis to this ground also in this year. Therefore, ground raised by the assessee is treated as partly allowed for statistical purposes.
.T.A.No.7630 and 1698/Mum/2012 21
24. In the result, the appeals of the assessee are partly allowed for statistical purposes.
Order pronounced in the open court on 22nd Dec,2014 nd आदे श क घोषणा खल ु े यायालय म दनांकः 22 Dec, 2014 को क गई sd/- sd/-
(एन. के. बलै या/N.K.BILLAIYA) (अ मत शु ला /AMIT SHUKLA) लेखा सद य / ACCOUNTANT MEMBER या यक सद य / JUDICIAL MEMBER मुंबई Mumbai : on this 22nd Dec, 2014 व. न.स./ SRL , Sr. PS
आदे श क त ल प अ े षत/Copy of the Order forwarded to :
1. अपीलाथ / The Appellant
2. यथ / The Respondent.
3. आयकर आयु त(अपील) / The CIT(A)-
4. आयकर आयु त / CIT
5. वभागीय त न ध, आयकर अपील य अ धकरण, मुंबई / DR, ITAT, Mumbai
6. गाड फाईल / Guard file.
आदे शानुसार/ BY ORDER, true copy सहायक पंजीकार (Asstt. Registrar) आयकर अपील य अ धकरण, मुंबई /ITAT, Mumbai