Income Tax Appellate Tribunal - Hyderabad
Asmitha Microfin Limited,, Hyderabad vs Assessee on 30 January, 2015
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCHES "B", HYDERABAD
BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER
AND
SHRI SAKTIJIT DEY, JUDICIAL MEMBER
I.T.A. No. 137/HYD/2013
Assessment Year: 2009-10
Asmitha Microfin Ltd., Addl. Commissioner of
HYDERABAD Vs Income Tax,
[PAN: AADCA 9399 Q] Range-1,
HYDERABAD
(Appellant) (Respondent)
For Assessee : Shri S. Rama Rao, AR
For Revenue : Shri D. Sudhakar Rao, DR
Date of Hearing : 26-11-2014
Date of Pronouncement : 30-01-2015
ORDER
PER B. RAMAKOTAIAH, A.M. :
This is an assessee's appeal filed against the order of the Commissioner of Income Tax(Appeals)-II, Hyderabad dated 16-10-2012. Assessee raised the following two grounds which are relevant for consideration in this appeal:
i. On the facts and in the circumstances of the case, the learned Commissioner of Income Tax (Appeals) has erred in law, by confirming that surplus on value realized, aggregating to Rs.13,09,44,315/- being the gross future receivable value of :- 2 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., interest, (to the extent not accruing upto the end of the financial year) - by the discounting of the maturity value of loan portfolio of Rs.3,02,40,48,665/- on assignment of the said value of loan portfolio to commercial banks - as income accruing during the year.
ii. On the facts and circumstances of the case, the Commissioner of Income Tax (Appeals) has also erred in law, in confirming the disallowance of Rs.3,22,00,000/- being the value of Employee Stock Option granted and opted by the employees, not a business expenditure and as a notional capital expenditure.
2. Briefly stated, assessee is a Micro Finance Institution and filed return of income declaring Rs.35,29,35,971/-. In the scrutiny of return, Assessing Officer noticed that assessee did not offer entire gains received on sale of portfolio loans but amortized the same and offered only part gain during the year. He also noticed that on one closed loan portfolio sold to HDFC bank entire gain was offered to tax. In addition to the issue of gain on sale of loan portfolio, Assessing Officer also disallowed claim of expenditure on account of ESOPs to an extent of Rs.3,22,00,000/-. The Ld.CIT(A) confirmed the additions of the above amounts, hence assessee is in appeal.
3. We have heard the Ld.Counsel for assessee and Ld.DR in detail and perused the Paper Book placed on record.
4. Ground No.1 is on the issue of confirming an amount of Rs.13,09,44,315/- being the amount received by discounting the maturity value of loan portfolio on assignment to commercial banks as income during the year. Assessee being micro finance institution, sells its loan portfolios to commercial banks for obtaining capital refinancing funds. As a part of the business activity, the existing loan portfolios are bundled and sold to schedule commercial banks so that assessee :- 3 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., receives revolving credit limits in its business. As per the practice, assessee sold its existing loan portfolios to an extent of Rs.302.40 Crores during the year including the future interest receivables. Assessee offered gain during the year, on proportionate basis out of future receivable interest and amortized balance of the amount to an extent of Rs.13,09,44,315/- to later years, on the reason that the amount to that extent being on the gross future receivable value of interest has not accrued up to the end of financial year. Since the amount was discounted only, the gain on value of amount pertaining to the accrued interest was offered as income and the balance amount on the future receivables in the next financial year was deferred to the later year. Assessing Officer after examining the clauses of the agreement, guidance note of ICAI on accounting of securitization of assets and also the agreements entered by assessee with the commercial banks for portfolio buyout, collection agents agreement has come to conclusion that assessee has postponed the revenue of the above amount without valid reasons and in violation of guidance note on securitization of assets. His conclusions in para V in page 4 of the order is as under:
"a) The transaction is a complete buyout of loan portfolio by the bankers and the asset is derecognized from the books of the assessee;
b) The collection agent's agreement fixes certain fee for collection and attendant work and it is for the assessee to take a decision whether he should incur huge cost for doing work for a nominal fee or not. Merely, because huge costs are involved in collection work, the transaction cannot be treated as a service strip transaction.
c) The agreement for portfolio buyout and collection are separate and distinct. The sale of portfolio is unconditional. As per para 6 of the guidance note, servicing of the asset by itself can not lead to a situation of partial de-recognition of asset and thereby revenue from the asset;
:- 4 -: I.T.A. No. 137/Hyd/2013
Asmitha Microfin Ltd.,
d) The procedure prescribed for collection and the costs involved in service are not material for recognition of revenue from the sale of portfolio;
e) The difficulty in estimation of servicing costs or obligation to service the portfolio are not relevant for recognition of revenue from sale of portfolio as both are distinct and separate functions performed by the assessee;
f) The interest income received on sale of portfolio has no link with service cost. Also, there is no interest strip or service strip in the agreement to sell the portfolio;
g) Keeping of cash collaterals (10% of the value of purchase consideration as well as part of the collection amounts in excess of principal) indicates only a contingent liability. The second part of the cash collateral is out of the funds belonging to the assignee only.
Only the first part is out of the amounts received by the assessee. No one prevents the assessee in claiming trading loss, if any time, the cash collateral is liquidated. In the present case, even such liquidation never happened;
h) The statement that even if borrowings are not realized, the assessee meets the obligations in practice is only a self-serving statement. As per the agreement, there is no binding on the assessee to pay its own amounts when loans are not collected from the borrowers. If for the sake of its convenience, the assessee adopts a practice (subject to proof), this does not mean that the revenue has to be deferred."
5. Assessee carried the matter to Ld.CIT(A) and gave detailed submissions mainly relying on the accounting principles being followed and accounting standards and guidance note issue by the ICAI particularly AS-9 on Revenue recognition. Ld.CIT(A) after considering the detailed submissions and various clauses of the agreement, however, did not agree with the contentions and summed up the issue as under
vide para 4.10 of the order.
a) The transaction is a complete buyout of loan portfolio by the bankers and the asset is derecognized from the books of the assessee;
:- 5 -: I.T.A. No. 137/Hyd/2013
Asmitha Microfin Ltd.,
b) The collection agent's agreement fixes certain fee for collection and attendant work and it is for the assessee to take a decision whether he should incur huge cost for doing work for a nominal fee or not. Merely, because huge costs are involved in collection work, the transaction cannot be treated as a service strip transaction;
c) The agreement for portfolio buyout and collection are separate and distinct. The sale of portfolio is unconditional. As per para 6 of the guidance note, servicing of the asset by itself can not lead to a situation of partial de-recognition of asset and thereby revenue from the asset;
d) Portfolio sell out has been reduced from the current assets in the balance sheet of the appellant;
e) The procedure prescribed for collection and the costs involved in service are not material for recognition of revenue from the sale of portfolio;
f) Clause 9 reproduced above shows clearly how the transaction to be treated - only when in partial derecognition the expenditure and consideration need to be amortised over the term of secured borrowing or recognized immediately in the statement of P&L and not in total derecognition.
g) The difficulty in estimation of servicing costs or obligation to service the portfolio are not relevant for recognition of revenue from sale of portfolio as both are distinct and separate functions performed by the assessee;
h) The interest income received on sale of portfolio has no link with service cost. Also, there is no interest strip or service strip in the agreement to sell the portfolio;
i) Keeping of cash collaterals (10% of the value of purchase consideration as well as part of the collection amounts in excess of principal) indicates only contingent liability. The second part of the cash collateral is out of the funds belonging to the assignee only.
Only the first part is out of the amounts received by the assessee. No one prevents the assessee in claiming trading loss, if any time, the cash collateral is liquidated. In the present case, even such liquidation never happened;
j) The statement that even if borrowings are not realized, the assessee meets the obligations in practice is only a self-serving :- 6 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., statement. As per the agreement, there is no binding on the assessee to pay its own amounts when loans are not collected from the borrowers. If for the sake of its convenience, the assessee adopts a practice (subject to proof), this does not mean that the revenue has to be deferred.
k) As per collection agent agreement - the grounds on which the collection agent is treated as defaulter does not speak of making it liable for the non-recovery of loans. Only thing required is to remit the amounts realized/collected to the Assignee's on the payout dates.
6. Ld.Counsel referring to the orders of authorities and the Paper Book filed, explained that assessee sells the loan portfolio to the banks and obtains revolving credit. As a part of the buyout, assessee has to keep certain deposits with the banks to the extent of 10% on the capital advanced and also to the extent of 10% on the discount value of future receivables. Referring to account policies being followed and the guidelines issued, it was the submission that even though assessee has discounted the loan portfolio and receivable interest on the loan portfolio to the extent of interest receivable during the year was only considered for the purpose of offering gain, whereas the gain attributable to future interest i.e., interest accruing later accounting year was offered in that year. It was submitted that one loan portfolio to HDFC bank and DCB bank were closed during the year. Therefore, the entire gain was offered to tax during the year as noted by the Assessing Officer in page 2 of the order. However, it was submitted that even though the loan portfolios were sold to the banks, more particularly to ICICI bank, assessee was assigned the job of collecting amounts and remitting it to the bank on which assessee gets commission. In the case of any default on the loan portfolio, there is liability on the assessee and therefore on prudential Revenue recognition norms, entire income cannot be offered to tax. It was further submitted that same principle is being followed year after :- 7 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., year and the Revenue has accepted the same up to AY.2007-08. It was further submitted that there is no loss to the Revenue as income is offered in the immediately succeeding year and offered the same and generally does not go more than two years. Ld.Counsel also submitted that the portfolio sale is conditional and the principal amount and future interest are discounted separately. In support of the entries passed, assessee placed on record the entries passed in one portfolio sale in order to explain how income is considered accrued, only to the extent of interest accruing during the financial year. It was submitted that if the portfolio loan was for a period of twelve months and if part of the interest falls in the later account year, then when the same was discounted, the gain on the interest accruing during the year was only considered as income and the balance is offered in the later year. Since there is no revenue loss over a period of time, Assessing Officer's addition is not correct to that extent. He also explained the principles involved in securitization of assets and AS-9 which assessee is following.
7. Ld.DR however, relied on the detailed analysis made by the Assessing Officer and Ld.CIT(A).
8. We have considered the issue and examined the documents and agreement placed on record. There is no dispute with reference to the fact that assessee has transferred by way of direct assignment to and in favour of banks (purchaser), certain identified loan receivables together with all rights and interest receivable for a purchase consideration paid by the purchaser upon execution of deed and assignment. The purchase consideration is generally arrived at by calculating the value of receivables based on discounted cash flow method which is equivalent to interest rate, if it is viewed as a borrowing. Assessee also signed an agreement to collect the receivables assigned and ensuring the payment :- 8 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., of the same to the banks on specified dates every month. It is the contention that assignment of loans has been accruing in accordance with AS-9 which covers revenue recognition norms, guidance note on accounting for securitization issued by the ICAI and keeping in view an important principle of accounting i.e., matching principles. Assessee mainly considers para 5 of the AS-9 on revenue recognition which is mainly concerned with the timing of recognition of revenue, the statement of profit and loss of an enterprise. It is the argument that when uncertainties exist regarding determination of the amount or its associated costs, these uncertainties may influence the timing of revenue recognition. It is also the contention that consideration received together with the nominal fee for services is to be matched against discounting charges, which is akin to interest, servicing cost and loan arising of default by end borrowers. In the year under consideration, the total purchase consideration was Rs.302.40 Crores which includes discounted value of future interest receivables to an extent of Rs.18.87 Crores. Out of this, Rs.5.78 Crores were amortized and recognized during the FY.2008-09 ( this AY) and balance amount of Rs.13.09 was recognized subsequently in the previous year 2009-10 i.e., next assessment year.
9. In order to understand the issue, the accounting entries passed by assessee were placed on record. For the sake of explanation, the sale of portfolio in ICICI 6A, dt.19-03-2009 were explained.
( in Rs)
Date of transaction : 19-03-2009
Book value of the loan 22,79,34,100
Future interest 2,96,16,526
Discounting charges 1,41,74,070
Purchase consideration received 24,33,76,556
Net gain on transaction 1,54,42,456
Unamortized gain 1,54,42,456
:- 9 -: I.T.A. No. 137/Hyd/2013
Asmitha Microfin Ltd.,
10. Thus, as can be seen from the above, on a book value of Rs.22.79 Crores loan portfolio and future interest receivable on the above loan of Rs.2.96 Crores, assessee entered into agreement for sale and received purchase consideration of Rs.24.34 Crores. Assessee received gain of Rs.1,54,42,456/- and the entire amount was deferred to later year. The entries passed by assessee in this regard are as under:
Date Particulars Dr./ Amount Amount Remarks Cr. Rs. Rs.
19- For amount received from ICICI Bank t/ws Portfolio Assignment Entry
Mar-09 ICICI Bank (Bank) A/c Dr 20,17,26,102 passed
ICICI Buyout Loan - 2 (Loan) Cr 20,17,26,102 when
A/c Assignment
(Amount received from ICICI Bank t/ws portfolio assignment) takes place
19- For Cash Collateral -1 (10% of Purchase Consideration) Kept with ICICI Bank and
Mar-09 released only after completion of the tenure Fixed Deposit Pledged with Dr 2,43,37,656 Entry ICICI Bank Ltd passed ICICI Buyout Loan - 2 (loan) Cr 2,43,37,656 when A/c Assignment takes place (10% of Purchase consideration kept with ICICI Bank as Cash collateral, which is to be released only on completion of the Tenure) 19- For Cash Collateral -2 (Purchase Consideration minus Book value) Kept with ICICI Mar-09 Bank and released in 9 Monthly instalments Fixed Deposit Pledged with Dr 1,54,42,466 Entry ICICI Bank Ltd., passed ICICI Buyout Loan - 2(Loan) Cr 1,54,42,466 when A/c Assignment takes place (Difference of Amount from Purchase consideration to Book value will kept as CC-2 and released in monthly rests) 19- For broken period Interest Charged by Bank Entry Mar-09 Interest- ICICI Buy Out Dr 18,70,332 passed ICICI Buyout Loan - 2 (Loan) Cr 18,70,332 when A/c Assignment takes place (Broken period Interest Charged by Bank) 19- For Transferring of Portfolio from AML Books Entry Mar-09 ICICI Buyout Loan - 2 (Loan) Dr 22,79,34,100 passed A/c when Loan to Members A/c Cr 22,79,34,100 Assignment (Portfolio of AML is transferred from the Books) takes place 19- For Booking of Net gain (Future Interest mimus Discounting Charges) Mar-09 ICICI Buyout Loan - 2 (Loan) Dr. 1,54,42,456 Entry A/c passed :- 10 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., Unamortized Gain on Cr 1,54,42,456 when Assignment (Liability) A/c Assignment takes place 30-Apr- For Booking of Net gain related to Current Financial Year Similarly 09 Unamortized Gain on Dr. 7,88,164 entries are Assignment (Liability) A/c passed Gain on Assignment A/c Cr 7,88,164 every month (Booking of Gain from Unamortized gain for First Month) for transferring Gain from Unamortize d Gain on proportion basis till the completion of Tenure 31- Bank A/c Dr Dr 5,13,17,763 Similarly Mar-09 ICICI Buyout Loan recovery Cr 5,13,17,763 entries are (liability passed Monthly Due Collected from Clients is kept as liability every month 10- ICICI Buyout Loan Recovery Dr. 5,13,17,763 for May-09 (liability) transferring Cr 5,13,17,763 amounts collected from clients to bank 15- Maturity of FD kept as Cash Collateral -2 Similarly May-09 ICICI Bank (Bank) Dr 15,04,878 entries are Fixed Deposit pledged with Cr 15,04,878 passed ICICI Bank Ltd every month (First month Maturity amount received, FD pledged by ICICI bank for on Maturity Loan 6) of FD's placed with ICICI bank till the completion of Tenure 15- Maturity of FD kept as Cash Collateral -1 This entry Mar-10 passes only ICICI Bank (Bank) Dr 2,61,08,294 after Fixed Deposit pledged with Cr 2,43,37,656 completion ICICI Bank Ltd of the Interest on FD Cr 17,70,638 tenure for (Maturity amount received against FD pledged with ICICI Bank on releasing of completion of the Loan Tenure) FD kept as CC-1 with ICICI Bank
11. As can be seen from the above, assessee's book value and the future interest receivable totaling to Rs.25,75,50,626/- out of which discount was given to an extent of Rs.1,41,74,070/- and mainly on :- 11 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., future interest receivables. Thus, out of the interest receivables of Rs.2,96,16,526/- as future interest, assessee discounted the same for an amount of Rs.1,41,74,070/- and received the gain of Rs.1,54,42,456/-. Thus, short of the accounting entries made, the basic principle involved in this sale of portfolio is that as far as principal amount is concerned, no discount was considered as the entire portfolio was given at the book value only. Only interest receivable sold to the purchaser, however, was discounted. Thus, as seen from the above example out of Rs.2.96 Crores receivable, assessee discounted to an extent of Rs.1.41 Crores and showed the gain of Rs.1.54 Crores. It is assessee's contention that the entire amount of Rs.2.96 Crores, being future interest receivable, is not accruing during the year. Therefore, the gain on discounting of that is not an amount accrued during the year and so, the same is deferred to later year. It is this amount which is under dispute. As this transaction given as an example above has occurred on 19th March 09 and as no interest is receivable during that month, assessee has deferred the entire amount of gain to the later year. There are many such transactions entered regularly by assessee during the course of year and to the extent of amount discounted, assessee is accordingly offering income on the proportion of interest accrued during the year.
12. This system of account being done by assessee is more or less similar to the bill discounting system, which is generally followed by many in the business. In the bill discounting system, a person who discounts the bill takes the interest amount upfront when he discounts the bill by way of 'front end discount', the income accrues at that point of time. What is material is the certainty of the date of discount. In this case, assessee contends that the gain on the transaction has not accrued as the future interest receivable is not an accrued income. However, this aspect cannot be accepted as assessee has received the :- 12 -: I.T.A. No. 137/Hyd/2013 Asmitha Microfin Ltd., discounted amount as a part of sale consideration. Even though, there are certain deposits kept with the banks for the purpose, the fact is that out of the total portfolio including the future interest of Rs.25.75 Crores, Assessee did receive Rs.24.33 Crores as can be seen in the transaction stated above. Therefore, at the time of sale of portfolio, there is a gain of Rs.1.54 Crores. This amount received by assessee is in a way discounted interest on the future receivables. Since this amount is already received by assessee, question of postponing the accrual does not arise. Had assessee been accounting the interest receivables as and when accrued, without sale of the portfolio, it has to be admitted that future interest cannot be taken as income. However, when assessee bundles it and sells it as a portfolio for a discount, the amount did accrue and received on the date of entering agreement. As can be seen from the above example, out of the total amount of Rs.2,96,16,526/- receivable in a later year, assessee discounted Rs.1,41,74,070/- and has received an amount of Rs.1,54,42,456/- as gain, out of the total price received of Rs.24,33,76,256/- [that total amount Rs.24,33,76,256 - Rs.22,79,34,100 = 1,54,42,456]. Thus, in a way, out of the book value of Rs.22.79 Crores of portfolio, assessee did receive Rs.24.33 Crores thereby having the gain of Rs.1.54 Crores. Since the transaction happened on 19th March, the entire amount is to be accounted as income on that transaction as a gain.
13. Similar issue was considered by the Hon'ble Madras High Court in the case of TVS Finance and Services Ltd., Vs. JCIT [318 ITR 435 (Mad)] on the issue of accrual of income and timing of accrual on discounting of bills. The Hon'ble Madras High Court held as under:
"Where bills are discounted the accrual of interest is certain and arises on the date of discount.
:- 13 -: I.T.A. No. 137/Hyd/2013
Asmitha Microfin Ltd.,
The assessee was a non-banking finance company engaged in lease, hire purchase, bills discounting and mortgage loans. The Assessing Officer held that the whole of the income from bill discounting accrued at the time of discounting the bill. This was confirmed by the Tribunal. The assessee claimed the provision it had made towards bad debts under the RBI norms was deductible. The Assessing Officer and the Tribunal rejected the claim.
Held, (i) that the Tribunal was right in concluding that the uncertainty regarding the discharge of the bill or rediscounting has no relevance. The transaction of discounting is complete at the moment the customer is given 90 per cent of the value of the bill. The discount is equivalent to the interest and it accrued at that point.
(ii) That the debts were shown as written off on the basis of the formula given by the Reserve Bank of India. Writing off the debt as bad requires judgment on the part of the person carrying on the business but in the present case, the debts had been 'written off' merely on the basis of the RBI norms and nothing more. Thus, they were not deductible under section 36.
14. Since, principles of bill discounting and accounting entries are similar to the portfolio sale/securitization of loan portfolios, being the method involved being same, we uphold the orders of Assessing Officer and CIT(A) on the issue. In fact, both Assessing Officer and CIT(A) analyzed the accounting principles, agreements and came to conclusion that the amounts have accrued at the time of sale of portfolio. We affirm the same and hold that the amount of Rs.13,09,44,315/- being the amount of discounted future interest received by assessee during the year is taxable in the year. Accordingly, we uphold the orders of Assessing Officer and reject the ground of assessee.
15. Ground No.2 is on the issue of disallowance of Rs.3.22 Crores being value of Employees Stock Option granted and opted by the employees holding it as not business expenditure but a notional capital expenditure.
:- 14 -: I.T.A. No. 137/Hyd/2013
Asmitha Microfin Ltd.,
16. At the outset, it was fairly admitted that this issue was covered by the orders of Special Bench of ITAT, Bangalore in the case of Biocon Ltd., Vs. DCIT 144 ITD 21 (2013). The Hon'ble Special Bench held as under:
(i) The difference (discount) between the market price of the shares and their issue price is "expenditure" in the hands of the assessee because it is a substitute to giving direct incentive in cash for availing the services of the employees. There is no difference between a case where the company issues shares to the public at market price and pays a part of the premium to the employees for their services and another where the shares are directly issued to employees at a reduced rate. In both situations, the employees stand compensated for their effort. By undertaking to issue shares at a discount, the company does not pay anything to its employees but incurs the obligation of issuing shares at a discounted price at a future date. This is nothing but "expenditure" u/s 37(1);
(ii) The liability cannot be regarded as being "contingent" in nature because the rendering of service for one year is sine qua non for becoming eligible to avail the benefit under the scheme. Once the service is rendered for one year, it becomes obligatory on the part of the company to honor its commitment of allowing the vesting of 25% of the option. The liability is incurred at the end of the first year though it is discharged at the end of the fourth year when the options are exercised by the employees. The fact that some options may lapse due to non-exercise/ resignation etc does not make the entire liability contingent;
(iii) However, the obligation to issue shares at a discounted premium does not arise at the stage the options are granted. It arises at the stage that the options are vested in the employees. The amount deductible has to be determined based on the period and percentage of vesting under the ESOP scheme;
(iv) There is likely to be a difference in the quantum of discount at the stage of vesting of the stock options (when the deduction is allowable) and at the stage of exercise of the options. The difference has to be adjusted by making suitable northwards or southwards adjustment at the time of exercise of the option depending on the market price of the shares then prevailing. The fact that the SEBI Guidelines do not provide for the adjustment of discount at the time of exercise of options is irrelevant because accounting principles cannot affect the position under the Incometax Act.
:- 15 -: I.T.A. No. 137/Hyd/2013
Asmitha Microfin Ltd.,
(v) On facts, the assessee's method of claiming a larger deduction in the first year defies logic. As the options vest equally over a period of four years, the deduction ought to be claimed in four equal installments on a straight line basis.
17. While considering the issue, Special Bench has considered the decision of Ranbaxy Laboratories [124 TTJ 771 (Delhi)] which was reversed and decision of S.S.I. Ltd., Vs. DCIT [85 TTJ 1049 (Chennai)] was approved. Like-wise decision of Spray Engineering Devices Ltd., [53 SOT 70 (Chd)] was also approved.
18. In view of the above, Assessing Officer is directed to work out the deduction keeping in mind the principle laid down by the Hon'ble Special Bench on the issue. Assessee should be given due opportunity to make submissions. This ground is allowed for statistical purposes.
19. In the result, appeal is partly allowed.
Order pronounced in open Court on 30th January, 2015.
Sd/- Sd/-
(SAKTIJIT DEY) (B. RAMAKOTAIAH)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Hyderabad, Dated 30th January, 2015.
TNMM
:- 16 -: I.T.A. No. 137/Hyd/2013
Asmitha Microfin Ltd.,
Copy to :
1. Asmitha Microfin Ltd., Hyderabad, C/o. Sri S.Rama Rao, Advocate, 102, Shriya's Enclave, 3-6-643, Street No.9, Himayatnagar, Hyderabad.
2. Addl. Commissioner of Income Tax, Range-1, Hyderabad.
3. CIT(A)-II, Hyderabad
4. CIT-I, Hyderabad
5. D.R. ITAT, Hyderabad.