Income Tax Appellate Tribunal - Mumbai
Godrej Household Products Ltd , Mumbai vs Assessee on 28 August, 2013
आयकर अपील य अ धकरण "K " यायपीठ मंब
ु ई म।
IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH, MUMBAI
ी पी.एम. जगताप, लेखा सद य एवं अ मत शु ला, या यक सद य के सम ।
BEFORE SHRI P.M. JAGTAP, AM AND SHRI AMIT SHUKLA, JM
आयकर अपील सं./I.T.A. No. 7369/Mum/2010
( नधारण वष / Assessment Year : 2006-07
M/s Godrej Household बनाम/
बनाम Additional
Products Ltd. (Earlier Commissioner of income
Vs.
Godrej Sara Lee Ltd. Tax - Range 10(2),
(Now amalgamated into Aayakar Bhavan,
Godrej Consumer Mumbai - 400 020.
Products Ltd.),
Kalyaniwalla & Mistry,
Army & Navy Building,
3 r d Floor,
148, Mahatma Gandhi
Road, Fort,
Mumbai - 400 001.
थायी ले खा सं . /PAN : AAACT1921C
(अपीलाथ /Appellant) .. ( यथ / Respondent)
Appellant by Shri F.V. Irani
Respondent by : Shri Chandrajit Singh
सनवाई
ु क तार ख / Date of Hearing : 28-08-2013
घोषणा क तार ख /Date of Pronouncement : 22-11-2013
आदे श / O R D E R
PER P.M. JAGTAP, A.M. :
पी.एम. जगताप, लेखा सद य This appeal filed by the assessee is directed against the order of the Addl. CIT 10(2) Mumbai (Assessing Officer) dated 30-11-2009 passed u/s 143(3) r.w.s. 144-C(1) of the Income tax Act, 1961 (the Act).
2 ITA 7369/M/2010
2. The first issue relating to the restriction of assessee's claim for deduction u/s 80IB/80IC of the Act is raised by the assessee in ground No. 1 & 2 which read as under:-
"1. The learned Dispute Resolution Panel erred in holding that the assessee has claimed excess deduction u/s 80IB/80IC of the Act.
2. The learned Dispute Resolution Panel erred in disregarding the method of allocation consistently adopted by the appellant and in re-allocating 50% of the following overheads of the non-eligible undertakings to the eligible undertakings of the appellant, while computing the deduction u/s 80IB/80IC of the Act:-
- Miscellaneous Expenses
- Conveyance and Traveling Expenses
- Rent, Rates and Taxes
- Advertisement and publicity
- Schemes and promotions
3. The assessee in the present case is a company which is engaged in the business of manufacturing and marketing of household insecticides and air fresheners such as mats, coils, electronic mosquito destroyers under the brand name of Goodnight, Jet, Banish, Hit etc. The return of income for the year under consideration was filed by it on 19-10-2006 declaring total income of Rs. 12,29,90,492/- under the normal provisions of the Act and book profit of Rs. 58,52,58,709/- as per the provisions of section 115JB of the Act. All the manufacturing units of the assessee are situated in backward areas as specified in Eighth Schedule of the Income Tax Act which are eligible for deduction either at 100% or 30% of its profits u/s 80IB/80IC of the Act. The assessee was also having non 80IB units/segment representing its trading activity and the total turnover of this segment during the year under consideration was Rs. 80,04,65,664/- out of the total turnover of Rs. 476,76,04,000/-. The direct expenditure related to this trading activity was purchases of Rs. 64,76,53,049/- and after reducing the same from the corresponding sales, the gross profit was declared at Rs. 15,28,12,615/-. The common administrative & selling expenses were allocated by the assessee to
3 ITA 7369/M/2010 the eligible as well as non-eligible units/segment in the ratio of sales. During the course of assessment proceedings, the assessee was called upon by the A.O. to explain why certain expenditure such as miscellaneous expenses, conveyance and traveling expenses, rent rates and taxes, advertisement and publicity and schemes and promotions should not be entirely allocated to 80IB (eligible) segment. In reply, the following explanation was offered by the assessee:-
"Overheads allocation We would like to draw to your attention that while looking at a figure of Rs 12.72 crores of overheads, one has to see that the total figure was 154.63 crores out of which Rs 141.91 crores has been allocated to eligible units only.
The Company's total overhead expenses under following heads have been allocated to various units on actual basis where applicable and general overheads on sales basis Employee Costs Rs 27,04,75,709 Admin and Other Expenses Rs 22,75,90,572 Advt. selling and promotions Rs 38,22,18,426 Excise Duty Rs 37,64,34,934 Freight, power and fuel Rs 28,96,31,483 Total Rs 1,54,63,51,124 Detailed basis of allocation is as in sheet enclosed - Ann 2. Out of above administration expenses and overheads (including head office expenses) etc have been allocated on a sales to turnover ratio over all units. As is evident from the enclosed sheet, 91.8% of above expenditure has been allocated to the eligible units and 8.2% only to non 80IB business.
Basis of allocating overheads to sales to total sales has been accepted as a fair basis over past several years of the Company's assessments. Such allocation of sates turnover to total turnover are also been recognized by various courts as a reasonable basis.
The Assessing Officer had not appreciated the fact that the 'trading' activity was only of same products as those manufactured by assessee. Normally, when production targets are not met, to meet sales targets, the Company procures similar products from vendors and sells them under own brand name as own products.
4 ITA 7369/M/2010 Such expenses are related to selling the goods and will be incurred whether the goods are manufactured or purchased. Since the Brand belongs to Godrej Sara Lee, all expenses related to selling a product will have to be allocated to the goods sold and the source of procurement does not have any relation. Since A&P schemes and freight are related to selling & distributing products the same has been allocated to Non 80 IB units as well. 84% of advertisement, selling etc are allocated and reduced from eligible units only. Hence, as the expenses have been allocated on a reasonable basis and on sales basis, and we request you not to reallocate without any basis."
4. Based on the above submission made by the assessee, the A.O. proceeded to examine the basis of allocation of expenditure of Rs. 12.72 crores to non 80IB unit/segment in respect of each head of expenditure and recorded his findings/observations on such examination as under:-
Miscellaneous Expenses Rs.7275 5681/-.
Against the non eligible income of Rs.85,9837,989/- ,the assessee has claimed miscellaneous expenses of Rs 72,75,568 based on allocation of sales ratio. Details of miscellaneous allocated expenses reveal expenses of general administrative nature. The allocation of Rs.72,75,568/- appear to be on very high side and not reasonable. Further, it is necessary to keep in mind that the trading is not the main activity of the assessee. The purchases and sales are in the bulk as the assessee is not a small retailer. Hence, after taking in to account all probabilities the 50% of Rs.72,75,568/-which works out to Rs. 36,37,784/- is held as reasonable expenditure related to non-80IB section. Consequently, the balance expenditure of Rs.36,37,784/- is held as pertaining to the manufacturing units of the assessee.
4.7 Conveyance & Traveling Rs. 46,78,131 and Rent, rates & taxes Rs. 48,28,515.
Considering the fact that the trading is not the main activity, only 50% of the conveyance, traveling and rent, rates & taxes are held reasonable, as related to Non-801B activities. Accordingly, Rs 47,53,324/- is allocated under these heads. The balance expenditure of Rs. 47,53,324/-is held as pertaining to manufacturing unit.
4.8 Advertisement and Publicity Rs.4, 23,76,829/-
The assessee has allocated advertisement expenses on the basis of turnover. The trader normally would never incur expenditure on advertisement and brands of the manufacturer out of the trading profit. It appears excessive for a trader to spend such huge amount on the item. The trader would normally sell the goods which are popular and fast moving in the market. It is also extraordinary profit in trading 5 ITA 7369/M/2010 activity undertaken by the assessee. The G.P ratio in the trading section of the assessee is 12.92% before reducing selling and distribution expenses and freight. After allocation of advertisement of Rs 423,76,829/-,and schemes and promotions, the ratio becomes 6.59%. It is, therefore, clear that allocation of advertisement and publicity expenses to trading activity is higher.
However, bearing in mind the assessee's submission, as above, a distinction has been drawn out between a pure trading activity on behalf of another and activity of assessee. It is to be appreciated that the Company is a single entity and selling products on its own account and not for any other manufacturer and trading activity was only of same products as those manufactured by assessee. As per assessee, when production targets are not met, to meet sales targets, the Company procures similar products from vendors and sells them under own brand name as own products.
Therefore, though some expenses on advertisement, publicity and have to be allowed, it cannot be a very large amount. I, therefore allow 50% as reasonable expenses under this head. Therefore an amount of Rs 2,11,88,415 is considered reasonable and allocated to non eligible business segment and Rs 2,11,88,415/- is allocated as pertaining to manufacturing units of the assessee.
4.9 Schemes and Promotions Rs. 83,09,430:
The assessee has allocated Rs.83,09,430/- out of schemes and promotional expenses to trading unit. It is a well known practice that the manufacturers float different schemes for branded goods manufactured by them. These are all done to promote the particular brand in the market and boost the sales. The trader usually has nothing to do with this. As discussed in para above, and on same basis, though some expenses on schemes have to be allowed, it cannot be a very large amount. I, therefore, allow 50% as reasonable expenses under this head. Therefore an amount of Rs 41,54,715/- is considered reasonable and allocated to non eligible business segment and Rs 41,54,715/- is allocated to manufacturing units."
5. On the basis of above observations/findings, the A.O. arrived at a conclusion that the following expenditure actually pertaining to the manufacturing unit eligible for 80IB/80IC deductions was wrongly allocated by the assessee to non 80IB unit/segment:
Rs. 36,37,784/- Out of Misc. expenses
Rs. 47,53,324/- Out of conveyance, traveling and
rent, rates & taxes.
Rs.2,11,88,415/- Out of Advertisement & publicity
6 ITA 7369/M/2010
Rs. 41,54,715/- Out of Schemes and Promotions
Rs.3,37,34,238/- Total
Accordingly, the above expenses were re-allocated by the A.O. to the 80IB units/segment and consequently the claim of the assessee for deduction of Rs. 47,46,23,571/- was restricted by the A.O. to Rs. 45,13,35,909/- in the draft assessment. The assessee raised objection to this disallowance proposed by the A.O. in the draft assessment before the D.R.P. challenging the basis of allocation of expenses adopted by the A.O. The D.R.P., however, did not find the said objection sustainable and accepting the basis given by the A.O. for re-allocation of expenses in the draft assessment order as scientific, the objection raised by the assessee on this issue was overruled by the D.R.P. Accordingly, the disallowance proposed in the draft assessment order on account of deduction u/s 80IB/80IC of the Act was confirmed by the A.O. in the final assessment order passed u/s 143(3) r.w.s. 144C(13) of the Act vide order dated 30-8-2010.
6. The ld. counsel for the assessee submitted that the only dispute involved on this issue is relating to the allocation of certain expenses between the 80IB unit/segment and non 80IB segment. He submitted that although the non 80IB units/segment was engaged in trading activity, the products finally sold out of trading were the same as manufactured by the assessee in eligible units. He contended that the selling expenses such as advertisement & publicity, schemes and promotions etc. thus were rightly allocated by the assessee between the eligible units and non-eligible units on turnover basis and there was no reason for the A.O. to change the said basis and make the reallocation on adhoc basis. He explained the nature of expenditure incurred by the assessee on sales promotion, advertisement and various schemes and contended that the same was incurred to create and promote the brand image for the products manufactured and dealt with by the assessee company. He submitted that since the goods purchased from third parties were also being 7 ITA 7369/M/2010 sold as a part of trading activity in the same brand name, the expenditure incurred on sales promotion, advertisement and schemes was for the purpose of sale of goods, whether manufactured or purchased. He submitted that similarly, the other expenditure incurred by the assessee were necessary for selling the finished goods which were manufactured as well as procured from third parties and the same therefore were rightly allocated by the assessee company between eligible segment and non-eligible segment in the ratio of turnover. He contended that this basis of allocation was adopted by the assessee company only in respect of common expenses and all the expenses which were directly attributable to the eligible units had been duly allocated to the said units. He contended that the allocation of indirect expenses thus was made by the assessee company by adopting reasonable basis and there was no justification in the action of the A.O. in adopting an adhoc basis and reallocate 50% overheads from non-eligible segment to eligible segment. Relying on the decision of Hon'ble Supreme Court in the case of Consolidated Coffee Ltd. v. State of Karnataka (2001) 248 ITR 432 (SC), he contended that the bifurcation of common expenses was rightly made by the assessee on the basis of turnover, which was reasonable basis. He also contended that a similar method adopted by the assessee for allocation of common expenses in the earlier years was accepted by the Department.
7. The ld. D.R., on the other hand, strongly relied on the orders of the A.O. and DRP in support of the Revenue's case on this issue. He submitted that the allocation of common expenses made by the assessee on turnover basis was not accepted by the A.O. for specific reasons given in his order. He contended that keeping in view the said reasons given by the A.O., further adjustment was required to be made in the allocation of expenses between eligible segment and non-eligible segment and if at all such adjustment made by the A.O. to the extent of 50% of the corresponding expenses is found to be not reasonable, the same can be suitably varied. He contended that the non-
8 ITA 7369/M/2010 eligible segment was carrying on trading activity and this being the undisputed position, some adjustment is required to be made in the allocation of common expenses made by the assessee on turnover basis.
8. We have considered the rival submissions and also perused the relevant material available on record. It is observed that out of the total overheads of Rs.154.63 crores incurred by the assessee during the year under consideration, overheads to the extent of Rs. 141.91 crores were directly allocated by the assessee to the eligible units being directly attributable to the said segment. The balance amount of overheads to the extent of Rs. 12.72 crores representing the indirect expenses were allocated by the assessee between the eligible business and non-eligible business in the ratio of turnover and this basis adopted by the assessee was accepted by the A.O. except in the case of advertisement & publicity expenses amounting to Rs. 4.23 crores, schemes and promotions expenses amounting to Rs. 0.83 crores, miscellaneous expenses amounting to Rs. 0.72 crores, conveyance and traveling expenses amounting to Rs. 0.47 crores and rent, rate & taxes amounting to Rs. 0.48 crores. As explained by the ld. counsel for the assessee before us, the expenditure on advertisement & publicity and schemes and promotions was incurred mainly to create and promote the brand image for the company's product and this position was accepted even by the A.O. in his order. The, A.O., however, held that the trader normally would never incur expenditure on advertisement and brands of the manufacturer out of the trading profit. He, however, appears to have overlooked the fact that goods procured from the third party were sold by the assessee company as a part of trading activity under the same brand name and the benefit of the said expenditure thus was available equally to the trading segment. Incidentally, the A.O. also impliedly accepted this position while observing in his order that such expenses on advertisement & publicity and schemes have to be allocated to some extent to the non-eligible segment. He, however, held that such 9 ITA 7369/M/2010 allocation could not be very large amount and accordingly re-allocated 50% of the said expenses to eligible unit on adhoc basis. In our opinion, such re- allocation made by the A.O. on adhoc basis cannot be sustained having regard to all the facts of the case including especially the fact that the expenditure on advertisement & publicity and schemes was in the nature of selling expenses and the allocation made by the assessee of the said expenses on the basis of turnover was quite reasonable. The allocation so made by the assessee also cannot be said to have resulted in allocation of large amount of expenses to the non-eligible business as alleged by the A.O. since the gross profit ratio as shown by the assessee in the trading segment was 12.92% and even after allocating advertisement, schemes and promotions expenses on the basis of turnover, the profit of trading segment was 6.59%.
9. Similarly, the other indirect expenses on conveyance and traveling, rate and taxes and miscellaneous were incurred by the assessee during the normal course of its business of selling the finished goods, whether manufactured or procured from third party and since the said expenses were incurred equally for the benefit of eligible business as well as non-eligible business of trading, we are of the view that the basis of turnover adopted by the assessee to allocate the said expenses was more scientific and reasonable. On the other hand, the reallocation of the said expenses made by the A.O. on adhoc basis was not supported or substantiated by him and the same, in our opinion, cannot be accepted as a reasonable basis. In the case of Consolidated Coffee Ltd. v. State of Karnataka (supra) cited by the ld. counsel for the assessee, it was held by the Hon'ble supreme Court that when a bifurcation of expenses is not possible, some reasonable test will have to be adopted and that adoption of the method of apportioning on the basis of gross receipts could not be said to be a perverse method to apply. Keeping in view the decision of Hon'ble Supreme Court in the case of Consolidated Coffee Ltd. v. State of Karnataka (supra) and having regard to the facts of the case, we 10 ITA 7369/M/2010 are of the view that the allocation of expenses made by the assessee between eligible business and non-eligible business for the purpose of computing deduction u/s 80IB/80IC of the Act was reasonable and there was no justifiable reason for the A.O. to disturb the same and make re-allocation on adhoc basis. We, therefore, delete the addition made by the A.O. by restricting the claim of the assessee for deduction u/s 80IB/80IC of the Act by re- allocating the common indirect expenses and allow ground No. 1 & 2 of the assessee's appeal.
10. During the course of appellate proceedings before the Tribunal, the assessee has sought to raise the following additional grounds:-
"1) The Assessing Officer/Transfer Pricing Officer erred in making a transfer pricing adjustment of Rs. 10,05,360/- in respect of guarantee given by the Appellant on behalf of its Associated Enterprises.
2) The Assessing Officer erred in including the rate of guarantee commission determined by the Transfer Pricing Officer while determining the average rate of guarantee commission to be charged to the Associated Enterprise and in not considering the direction of the Dispute Resolution Panel to re-work the rate of guarantee commission by considering the average rates of the financial and performance guarantee charged by ICICI Bank.
3) Without prejudice, and in any event, the Appellant submits that the transfer pricing adjustment made in respect of guarantee given by the Appellant on behalf of its Associated Enterprise is highly arbitrary and excessive and requires to be reduced substantially."
11. The assessee has filed an application seeking admission of the aforesaid additional ground. As submitted in the said application, the issue raised in the additional ground relating to transfer pricing adjustment of Rs. 10,05,360/- made in respect of guarantee fees is arising from the orders of the authorities below but the same remained to be raised inadvertently in the grounds originally taken in the appeal filed before the Tribunal. Since this position is clearly evident from the orders of the authorities below and the ld. D.R. has also not disputed the same, we admit the additional grounds raised 11 ITA 7369/M/2010 by the assessee and now proceed to consider and decide the issue raised therein relating to the transfer pricing adjustment of Rs. 10,05,360/- made in respect of guarantee fees.
12. During the year under consideration, the assessee had given guarantee to banks on behalf of its subsidiary in Bangladesh. The said subsidiary had taken the loan from City Bank in Bangladesh for which a guarantee had been given by the assessee to the constituent branch of Citi Bank in India. The amount of bank Guarantee was Rs.5.68 crores.This international transaction of the assessee company with its associated concern was referred by the A.O. to the T.P.O. along with other international transactions for determining the Arm's Length Price (ALP). In this regard, the stand taken by the assessee before the T.P.O. was that it had not incurred any financial costs by way of Bank Guarantee commission, bank charges etc. and since this transaction had no bearing on its profits, losses or assets, no pricing should be put to such non-existent transaction. The T.P.O. did not accept the stand taken by the assessee on this issue. According to him, the transaction relating to provision of guarantee and the payment of commission for such guarantee was covered within the definition of the term "International transaction" given in section 92-B of the Act. He also held that the said Transaction would certainly have a bearing on the profits, income, losses or assets of the assessee. He, therefore, proceeded to determine the ALP of the compensation required to be recovered by the assessee from its Associate Enterprise (AE) for providing the Bank Guarantee. In this regard, he made certain enquiries from Bank which revealed that the HSBC Ltd., Mumbai was charging the Bank Guarantee fee at the rates ranging between 0.15% to 3%. He also found from the Website of Allahabad Bank that the said bank was charging bank Guarantee fees @ 3% per annum. He, therefore, adopted the Arm's Length Rate of bank Guarantee at 3% of the guarantee amount and proposed the 12 ITA 7369/M/2010 transfer pricing adjustment of Rs. 17,04,000/- being 3% of the bank Guarantee amount of Rs. 5.68 crores.
13. The assessee objected to the transfer pricing adjustment in respect of guarantee commission by filing its objection before the D.R.P. It was submitted on behalf of the assessee before the D.R.P., inter alia, that the Arm's Length Rate of guarantee commission taken by the T.P.O. at 3% was highly excessive because ICICI in assessee's own case was charging guarantee commission @ 1.5% per annum for financial guarantee and 0.8% for performance guarantee. Keeping in view this submission of the assessee, the D.R.P. directed the A.O. to work out the Arm's Length Rate of guarantee commission by including the rates of guarantee commission charged by ICICI Bank in assessee's own case. Accordingly, the A.O. worked out the Arm's Length Rate of guarantee commission at 1.77% by taking the average of 3% adopted by the T.P.O. and 1.50% and 0.80% charged by ICICI Bank in assessee's own case for financial guarantee and performance guarantee. Accordingly, the transfer pricing adjustment in respect of guarantee commission was made by the A.O. to the extent of Rs. 10,05,360/-.
14. The ld. counsel for the assessee in support of the assessee's case on this issue relied on the order of the co-ordinate Bench of this Tribunal dated 12-6-2013 passed in the case of M/s Nimbus Communications Ltd. (ITA No. 3664 & 2359/Mum/2010) wherein the Arm's Length Rate of guarantee commission was taken by the Tribunal at 0.5%. The ld. D.R., on the other hand, strongly relied on the orders of the authorities below in support of the Revenue's case on this issue.
15. We have considered the rival submissions and also perused the relevant material available on record. It is observed that a similar issue relating to determination of Arm's Length Rate of guarantee commission was involved in 13 ITA 7369/M/2010 the case of Nimbus Communications Ltd. (supra) and the same was decided by the Tribunal vide para No. 10 of its order as under:-
"10. As regards the rate of guarantee commission, it is noted that the arm's length price of guarantee commission was determined by the TPO by applying CUP method and the arithmetic mean of 1.5% of the guarantee commission charged by the HSBC Bank in the range of 0.15 to 3% was taken as arm's length price. The ld. CIT(A) upheld the CUP method applied by the TPO but adopted the rate of 0.25% of guarantee fee as arm's length price relying on the decision of French Court in the case of Societe Carrefour. The ld. D.R., at the time of hearing before us has relied on the decision of the co-ordinate Bench of this Tribunal in the case of M/s Everest Kanto Cylinder Ltd. (supra) wherein while accepting the CUP method as the most appropriate method for benchmarking the guarantee fee, the Tribunal accepted 0.5% guarantee fee/commission to be at arm's length after taking into consideration the rates of guarantee commission charged by various banks including the guarantee commission charged by the HSBC Bank in the range of 0.15% to 3%. Since the facts involved in the present case are materially similar to the facts involved in the case of Everest Kanto Cylinder Ltd. (supra), we prefer to follow the decision rendered by the co-ordinate Bench of this Tribunal in the said case over the decision of French Court in the case of Societe Carrefour (supra). We, accordingly modify the impugned order of the ld. CIT(A) on this issue and direct the A.O. to recompute the commission for guarantee given by the assessee to its Associated Enterprises @ 0.5% being the arm's length price. Ground No. 1 of Revenue's appeal is thus partly allowed whereas ground No. 2 of assessee's appeal is dismissed."
16. A perusal of the relevant portion of the Tribunal's order reproduced above shows that the ALP of guarantee commission was determined by the TPO in the case of Nimbus Communications Ltd. (supra) by applying CUP method and the arithmetic mean of 1.5% of the guarantee commission charged by the HSBC Bank in the range of 0.15 to 3% was taken as ALP. The ld. CIT(A) upheld the CUP method applied by the TPO but adopted the rate of 0.25% of guarantee fee as Arm's Length Price relying on the decision of French Court in the case of Societe Carrefour. The Tribunal, however, adopted the rate of guarantee commission at 0.5% as the ALP after taking into consideration the rates of guarantee commission charged by the various banks including the guarantee commission charged by HSBC Ltd. in the range of 0.15% to 3%. In the present case, the facts involved are similar to 14 ITA 7369/M/2010 the case of Nimbus Communications Ltd. (supra) inasmuch as the rates of guarantee commission charged by the various banks are found to be in the range of 0.15% to 3.0% and this being so, we take the rate of guarantee commission at 0.5% as ALP by respectfully following the decision of co- ordinate Bench of this Tribunal in the case of Nimbus Communications Ltd. (supra). The A.O. is accordingly directed to recompute the addition to be made on account of transfer pricing adjustment in respect of guarantee commission by taking the Arm's Length Rate of guarantee commission at 0.5%. The additional grounds raised by the assessee thus are partly allowed.
17. In the result, appeal of the assessee is partly allowed.
Order pronounced in the open court on 22nd November, 2013.
.
आदे श क घोषणा खले
ु यायालय म दनांकः 22-11-2013 को क गई ।
Sd/- sd/-
(AMIT SHUKLA) (P.M. JAGTAP)
या यक सद य JUDICIAL MEMBER लेखा सद य / ACCOUNTANT MEMBER
मंुबई Mumbai; दनांक Dated 22-11-2013
व. न.स./ RK , Sr. PS
आदे श क त ल प अ े षत/Copy
षत of the Order forwarded to :
1. अपीलाथ / The Appellant
2. यथ / The Respondent.
3. आयकर आयु (अपील) / The Addl CIT--10(2), Mumbai.
4. आयकर आयु / DRP -1, Mumbai
5. वभागीय त न ध, आयकर अपील य अ धकरण, मंुबई / DR, ITAT, Mumbai K Bench
6. गाड फाईल / Guard file.
ु / BY ORDER,
आदे शानसार
स या पत त //True Copy//
उप/सहायक पंजीकार (Dy./Asstt.
उप/ Registrar)
आयकर अपील य अ धकरण,
धकरण, मंुबई / ITAT, Mumbai