Income Tax Appellate Tribunal - Hyderabad
M/S Biligiri Agro Farms Pvt. Ltd, ... vs Department Of Income Tax on 8 May, 2014
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCH "B", HYDERABAD
BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER
AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER
Sl.
No. ITA No. A.Y. Appellant Respondent
The DCIT M/s. Manaslu Agro Farms
1. 62/Hyd/2014 2008 09 Central Circle 9, Pvt. Ltd., Hyderabad
Hyderabad PAN: AAFCM3723J
2. 63/Hyd/2014 2010 11 do do
M/s. Trishul Greenfields
3. 64/Hyd/2014 2008 09 do Pvt. Ltd., Hyderabad
PAN: AACCT8481F
4. 65/Hyd/2014 2010 11 do do
M/s. Kanigiri Agro Farms
5. 66/Hyd/2014 2008 09 do Pvt. Ltd., Hyderabad
PAN: AADCK2607H
6. 67/Hyd/2014 2010 11 do do
M/s. Biligiri Agro Farms
7. 68/Hyd/2014 2010 11 do Pvt. Ltd., Hyderabad
PAN: AADCB3655N
M/s. Bahudhanya Agro
8. 69/Hyd/2014 2010 11 do Farms P. Ltd., Hyderabad
PAN: AADCB3016F
M/s. Dhatu Agro Farms
9. 70/Hyd/2014 2010 11 do Pvt. Ltd., Hyderabad
PAN: AACCD7486N
M/s. Hakra Agro Farms
10. 71/Hyd/2014 2010 11 do Pvt. Ltd., Hyderabad
PAN: AABCH9513R
M/s. Kolar Greenlands
11. 72/Hyd/2014 2010 11 do Pvt. Ltd., Hyderabad
PAN: AACCK9653Q
M/s. Saravati Greenlands
12. 73/Hyd/2014 2010 11 do Pvt. Ltd., Hyderabad
PAN: AAKCS4594C
M/s. Atreyee Agro Farms
13. 74/Hyd/2014 2010 11 do Pvt. Ltd., Hyderabad
PAN: AACGA7006B
M/s. Balaghat Greenfields
14. 75/Hyd/2014 2008 09 do Pvt. Ltd., Hyderabad
PAN:AADCB0292R
M/s. Koel Agro Farms
15. 76/Hyd/2014 2010 11 do Pvt. Ltd., Hyderabad
AACGK9656M
Revenue by: Sri Solgy Jose T. Kottaram
Assessee by: Sri K.C. Devdas
Date of hearing: 08.05.2014
Date of pronouncement: 28.05.2014
2
ITA No. 62/Hyd/2014 & Ors.
M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
===============================
ORDER
PER BENCH:
All the above appeals are by the Revenue directed against different orders of CIT(A)-VII, Hyderabad dated 30.10.2013 in respect of different assessees for A.Ys. 2008-09 and 2010-11. Since the issues involved in all these appeals are identical, they are clubbed together, heard together and disposed of by this common order for the sake of convenience.
2. As the issues and facts are common, for the sake of brevity, we are narrating the grounds and facts as in ITA No. 62/Hyd/2014 in respect of M/s. Manslu Agro Farms Pvt. Ltd., for A.Y. 2008-09.
3. The grounds raised by the Revenue are as under:
1. The Ld. CIT(A)-VII, Hyderabad has erred in both facts and in law.
2. The Ld. CIT(A)-VII, Hyderabad ought to have appreciated the fact that under the facts and circumstances of the case, the AO was right in charging interest on the monies given by it as advances.
3. The Ld. CIT(A)-VII, Hyderabad ought to have appreciated the fact that the assessee company has neither written off the advances nor has made any provision for doubtful debts even in subsequent years. Also, the assessee company has approached judicature for justification of their claim of having advanced the monies along with interest (termed by the company as "Damages") from the recipient company i.e. M/s. SCSL which has merely placed these amounts under "Suspense" - without denying having received these monies by it.3 ITA No. 62/Hyd/2014 & Ors.
M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
===============================
4. The facts, in brief, are that the assessee company is one of the 37 companies which was under the control of Sri B Ramalinga Raju and his family members and had transactions with M/s. Satyam Computer Services Ltd. (for short SCSL). Sri B Ramalinga Raju was the erstwhile Chairman of M/s. SCSL. On 7th January, 2009, Sri B. Ramalinga Raju, lifted the veil of secrecy on the affairs of the company M/s. SCSL and made a confessional statement addressed to the Board of Directors of the Co., M/s. SCSL. The same was marked to various authorities like SEBI and Stock Exchanges. In this statement, a key item was regarding the balance sheet of the company M/s SCSL as on 30.09.2008, having an understated liability of Rs. 1230 crores on account of the funds arranged by him. It was stated that this amount of Rs. 1230 crores was arranged to M/s Satyam (not reflected in the books of Satyam) to keep the operations going on by resorting to pledging of all the promoters shares and raising funds from NBFCs etc. He had also enclosed to his confessional statement by way of Annexure, a statement showing the amounts given to M/s SCSL by these 37 companies. The total amount given was Rs.
142S crores and after reducing an amount of Rs. 194.60 crores (details of which was also given) received by various companies from M/s SCSL, net amount given to M/s SCSL was quantified at Rs. 1230.40 crores. A summary of the amounts given by various companies is as hereunder:
4 ITA No. 62/Hyd/2014 & Ors.M/s. Manaslu Agro Farms Pvt. Ltd. & Ors. =============================== Table showing net amount of Rs. 1230 crores given to Satyam as summarized from the statement of Sri B. Ramalinga Raju.
Amount Net recd.
Amount given to SCSL (in amount
From
S. crores) given to
Company SCSL (in
No. SCSL
crores)
(in
Up to FY FY FY 2008-
Total crores)
2007-08 2008-09 09
1 Amaravati Greenlands Pvt Ltd 104.22 0.00 104.22 0.00 104.22
2 Bangar Agro Farms Pvt Ltd 10.00 0.00 10.00 0.00 10.00
3 Pavitravati Green Fields Pvt Ltd 80.78 0.00 80.78 0.00 80.78
4 Vamadeva Greenlands Pvt Ltd 10.00 0.00 10.00 0.00 10.00
5 Himavat Green Fields Pvt Ltd 36.95 5.00 41.95 0.00 41.95
6 Kailash Green Fields Pvt ltd 34.40 6.00 40.40 0.00 40.40
7 Mahakali Green Fields Pvt Ltd 36.00 0.00 36.00 0.00 36.00
8 Meghana Agro Farms Pvt Ltd 35.95 0.00 35.95 0.00 35.95
9 Surasa Greenlands Pvt ltd 34.72 1.00 35.72 1.00 34.72
10 Madeswara Green Fields Pvt Ltd 34.43 1.00 35.43 0.00 35.43
11 Teepa Agro Farms Pvt Ltd 34.83 6.00 40.83 1.00 39.83
12 Malaprabha Greenfields Pvt Ltd 35.99 0.00 35.99 0.00 35.99
13 Netravati Green Fields Pvt Ltd 34.83 6.00 40.83 1.00 39.83
14 Banganga Agro Farms Pvt ltd 35.97 0.00 35.97 0.00 35.97
15 Koel Agro Farms Pvt ltd 35.98 0.00 35.98 0.00 35.98
16 Saravati Green Lands Pvt Ltd 36.23 0.00 36.23 0.00 36.23
17 Ahar Green Fields Pvt Ltd 36.24 0.00 36.24 0.00 36.24
18 Balaghat Green Fields Pvt Ltd 36.25 0.00 36.25 0.00 36.25
19 Kolar Green Fields Pvt Ltd 36.23 0.00 36.23 0.00 36.23
20 Atreyee Agro Farms Pvt Ltd 30.00 5.00 35.00 0.00 35.00
21 Dhatu Agro Farms Pvt Ltd 30.00 5.00 35.00 0.00 35.00
22 Hakra Agro Farms Pvt Ltd 30.00 10.00 40.00 0.00 40.00
23 Bahudhanya Agro Farms Pvt Ltd 30.00 10.00 40.00 0.00 40.00
24 Manaslu Agro Farms Pvt Ltd 32.00· 8.00 40.00 0.00 40.00
25 Trishul Green Fields Pvt Ltd 33.00 7.00 40.00 0.00 40.00
26 Kanigiri Agro Farms Pvt Ltd 30.00 10.00 40.00 8.00 32.00
27 Pingala Agro Farms Pvt Ltd 20.00 17.00 37.00 25.00 12.00
28 Bilgiri Agro Farms Pvt Ltd 25.00 15;00 40.00 15.00 25.00
29 Kalindi Green Fields Pvt Ltd 20.00 20.00 40.00 24.50 15.50
30 Panchakalyani Agro Farms Pvt Ltd. 0.00 47.90 47.90 22.65 25.25
31 Panchamukhi Agro Pvt Ltd 0.00 45.20 45.20 19.66 25.54
32 Parvatagiri Agro Farms Pvt Ltd 0.00 42.90 42.90 20.82 22.08
33 Saptaswara Agro Farms Pvt Ltd 0.00 35.00 35.00 15.25 19.75
34 Ekadanta Green Fields Pvt Ltd 0.00 36.50 36.50 17.92 18.58
35 Giriputra Green Fields Pvt Ltd 0.00 36.50 36.50 17.85 18.65
36 Aranya Agro Farms Pvt Ltd 0.00 14.50 14.50 3.95 10.55
37 Ekalavya Agro Farms Pvt Ltd 0.00 14.50 14.50 1.00 13.50
Total 1020.00 405.00 1425.00 194.60 1230.40
5. As can be seen from the above table, the assessee, gave an amount of Rs. 32.00 crores to M/s SCSL during the year 2008-09. The source for giving this amount was on account of share application money received. The assessee, gave the amount of Rs. 32.00 crores to M/s SCSL as a temporary 5 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== advance on various dates. The balance sheet and P&L A/c filed along with the return shows the amounts as share application money and temporary advance. No income is shown during the year. In the assessment order, The AO calculated interest on these advances given for the year on the number of days for which the temporary advance was given and brought such amounts to tax on accrual basis as per Table below and as mentioned in para 3 of the assessment order. The AO computed interest on these advances @ 18% because the company made a claim on M/s SCSL for repayment of these advances along with damages claimed at 18% per annum from the date of advance.
No. of
Date of Advance days up
Bank Interest
advance amount (Rs.) to
31.3.08
31/01/2008 HDFC Bank Ltd 50,00,000 61 1,50,411
31/01/2008 HDFC Bank Ltd 5,75,00,000 61 17,29,726
31/01/2008 HDFC Bank Ltd 5,75,00,000 61 17,29,726
28/02/2008 HDFC Bank Ltd 4,50 00,000 33 7,32,329
28/02/2008 HDFC Bank Ltd 4,50 00,000 33 7,32,329
28/02/2008 HDFC Bank Ltd 6,00,00,000 33 9,76,438
28/03/2008 HDFC Bank Ltd 5,00,00,000 4 98 630
Total 32,00,00,000 61,49,589
6. In the course of assessment proceedings, the assessee strongly objected to such an assessment and filed a detailed reply to the show cause notice issued.
7. The Assessing Officer observed that the assessee companies are following mercantile system of accounting, and since they have made a claim for recovery of advances along with the right to receive interest, interest on such advances has accrued to the assessee as per the trade, custom and usage. In view of the same, he issued show cause notices to the 6 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== assessees seeking explanation as to why the interest at the rate of 18% per annum from the date of advance should not be added to the total income for the relevant assessment year, viz. assessment year 2008-09. The assessees submitted detailed replies stating the erstwhile Chairman of M/s. SCSL Shri Ramalinga Raju, in his letter dated 78th January, 2009 has stated that the Balance Sheet of the M/s. SCSL as on September 30, 2008 carried an interest liability of Rs. 12,304 Millions, on account of the funds arranged by him. On January 8, 2009, the said company, M/s. SCSL, received letters from 37 companies, including the four assessees herein, requesting confirmation by way of acknowledgement of the alleged amounts received as alleged advances. All these letters were followed by legal notices from these companies dated 4th/5th August, 2009.
8. It was submitted that the M/s.SCSL has not acknowledged any of its liability to any of the 37 companies and has replied to the legal notices stating that the claims are legally untenable and that the Enforcement Directorate is investigating the matter under the Prevention of Money Laundering Act of 2002 and directed the companies to furnish details with regard to the alleged advances and has further directed the companies not to return the alleged advances until further instructions from the Enforcement Directorate. It was further submitted that the assessees herein have filed suits for recovery of advances before the City Civil Court, Secunderabad on November 11, 2009 and have also claimed 7 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== interest at the rate of 18% per annum towards damages. It was also reiterated that the company M/s. SCSL have denied liability to repay the alleged advances and also interest thereon and therefore, there is no admission of liability and accrual of interest thereon.
9. After considering the assessee's submissions, the Assessing Officer held that since the assessee companies are following mercantile system of accounting, they ought to have accounted for the interest on accrual basis, as the assessees have inherent right to receive the interest on the sum advanced, as evidenced from its claim. He therefore, brought to tax the interest income working out the same at the rate of 18% p.a. on the advances given by the assessee companies.
10. Aggrieved, the assessees preferred appeals before the CIT(A), reiterating the submissions made by the assessees before the Assessing Officer and also placing reliance upon the decisions of various High Courts with regard to the accrual of income. The learned CIT(A) after considering the assessee's submissions and placing reliance upon the decision of the Hon'ble Delhi High Court in the case of Paragon Constructions (I)) P. Ltd., reported in 274 ITR 413, has held that it cannot be held that interest income has definitely accrued and arisen to the assessee at the rate of 18% as held by the Assessing Officer, and that as and when the City Civil Court finalised the said interest rate mentioned therein, the interest can be taxed in the year in which the Court pronounces its order on the Civil Suit, pending before it. Thus, the CIT(A) allowed the assessees' 8 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== appeals. Aggrieved by the relief given by the CIT(A), the Revenue is in appeal before us.
11. The Learned Departmental Representative, Sri Solgy Jose T. Kottaram, submitted that the issue of advances by the four assessee companies to M/s. SCSL was admitted by the statement of Shri Ramalinga Raju on 7th/8th January, 2009.
The further fact that these amounts have been advanced by the assessee companies to M/s. SCSL through banking channels and also that these companies have issued legal notices for recovery of advances and also have thereafter filed civil suits for recovery of advances along with interest proves the fact that the assessees herein have advanced the amounts to M/s. SCSL. He submitted hat once it is proved that the advances have been made by the assessee companies to M/s.SCSL, the companies following the mercantile system of accounting, ought to have accounted for the interest income in their books of account for the relevant accounting year. He submitted that the CIT(A) has erroneously held that the interest income is to be brought to tax in the year in which the City Civil Court decides the matter and pronounces its order with regard to rate of interest on the suit amount. He submitted that the income of the relevant assessment year has to be brought to tax in that year only. He submitted that the income or liability cannot be preponed or postponed to another assessment year. Thus, according to him, the order of the CIT(A) in the case of the assessees is erroneous and has to 9 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== be set aside and the assessment orders on this issue have to be restored.
12. The learned counsel for the assessee, Shri Devdas, on the other hand, supported the orders of the CIT(A) and submitted that the important factor to be considered is that the company, M/s.SCSL, has denied its liability to pay any amounts to the assessee companies, and therefore, there is no certainty of recovery of the temporary advances itself given by the assessee companies. He therefore, submitted that due to the uncertainty of the recovery of the temporary advances itself, there is no certainty of receipt of interest income on such temporary advances. It is further submitted that there was no contract between the assessee companies and M/s. SCSL to receive interest on these temporary advances and in the absence of such contract, the interest income cannot be deemed to have arisen or accrued to the assessees. He further submitted that the advances have been made out of share application monies and not out of borrowed funds, and therefore, it cannot be presumed that the assessee has incurred any interest expenditure by advancing the interest free loans to the sister concerns, and therefore, no notional interest can be brought to tax even on this count.
13. Having heard both the parties and having considered the rival contentions and the material on record, we find that the basis for bringing to tax the notional interest income on advances allegedly made by the assessee company to M/s.
SCSL are the Civil Suits filed by the assessee companies for 10 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== recovery of the suit amounts along with interest at the rate of 18% per annum. The undisputed facts are that the assessees have advanced the loans/temporary advances to M/s. SCSL and this fact has come to light only by the statement of Sri Ramalinga Raju dated 7th/8th of January, 2009. Further, the assessees have advanced the loans or temporary advances through banking channels and immediately after the statement of Sri Ramalinga Raju, the assessees have also issued legal notices for the repayment of the loans and also filed civil suits for recovery of the loan amounts along with interest in the City Civil Court, Secunderabad. Therefore, the liability may have been denied by M/s. SCSL, but as far as the assessees are concerned, there is no dispute or controversy with regard to the loans advanced by them to M/s. SCSL. The only dispute now is with regard to the liability of M/s. SCSL and the right of the assessee to receive interest at the rate of 18% per annum. Another undisputed fact is also that there is no contract between the assessee and M/s. SCSL with regard to the advances and the interest thereon. In the absence of any such contract to receive the interest on the advances given by the assessee companies, it cannot be said that the assessee companies have any right to receive such amounts of interest or that the interest income has accrued to the assessees.
14. Let us know examine the legal principles governing such issues-
1. The Hon'ble Supreme Court in the case of CIT V/s. Walchand & Co. P. Ltd. (65 ITR 381), while considering the provisions of S.10(2)(xv) and S.33(iv) of the Indian 11 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== Income-tax Act, 1922, has held that in applying the test of commercial expediency or determining whether an expenditure was wholly and exclusively laid out for the purpose of business, the reasonableness of the expenditure has to be judged from the point of view of the businessman and not of the Revenue.
2. The Hon'ble Bombay high Court in the case of CIT V/s. Reliance Utilities and Power Ltd. (313 ITR 340) held that if there were funds available both interest free and overdraft and /or loans taken, then a presumption would arise that investment would be out of the interest free funds generated or available with the assessee, if interest free funds would be sufficient to make the investments.
3. The Hon'ble Gujarat High Court in the case of Highways Constructions P. Ltd. V/s. CIT (199 ITR 702), was dealing with a case of an assessee company which had advanced interest free loans to directors from amounts borrowed on interest. The Hon'ble High Court held that there was no finding of fact to the effect that actually loan had been granted to the Managing Director or any other person on interest or any interest had actually been collected, but the collection of the interest was not reflected in the accounts. The Hon'ble high Court after observing that the finding of the ITO was that the assessee should have collected interest, held that if the assessee had not bargained for interest or had not collected the same, the Income Tax Officer could not fix a notional interest as due or as collected by the assessee, as there was no provision in the Income-tax Act, empowering the income-tax authority to include in the taxable income, any interest which was not due or not collected by the assessee, and the addition of an amount as notional interest was not justified.
4. Hon'ble Punjab & Haryana High Court in the case of CIT V/s. Abhishek Industries Ltd. (286 ITR 1), was dealing with a case of interest free advances given to sister concerns on the basis of which the assessing 12 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== authority has disallowed interest paid by the assessee on borrowed funds. The Hon'ble High Court has held that the nexus between the interest bearing funds and the advances made to the sister concerns is not proved and therefore, there cannot be any disallowance of interest expenditure.
15. Applying the above rationale propounded by the Hon'ble Supreme Court as well as the Hon'ble High Courts, in the cases discussed above, we observe that the following points emerge -
(a) It is for the assessee to decide how it conducts its business;
(b) Where an assessee advances interest free loans to its sister concerns, unless nexus between interest bearing funds and the interest free advances is proved, expenditure on account of interest on borrowed funds cannot be disallowed nor it can be presumed that the assessee has collected interest from its sister concerns on the advances given.
(c) Where the funds have been advanced out of any interest free funds, then the disallowance of interest on borrowed funds cannot be made;
(d) Unless and until there is a contract between the parties for charging of interest on the funds advanced, the notional interest income cannot be brought to tax.
16. 14. Applying these principles to the facts of the cases before us, we find that the assessees have stated before the CIT(A) that the amounts advanced are from out of the share application monies and temporary advances. It is so stated on the basis of entries in the Balance Sheet and the Profit & Loss Accounts of the respective assessees filed along with their returns of income. In the absence of any contract between the 13 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== assessee companies and M/s. SCSL for charging of interest on the advances, the assessees are not entitled to receive any interest income on such advances. Therefore, merely because the assessee is following mercantile is system of accounting, it cannot be said that the interest has accrued to the assessees. Further, merely because the assessees have claimed interest at the rate of 18% per annum in the suits filed for recovery of advances, it cannot be said that the said rate of interest is applicable as M/s. SCSL has not admitted the liability of even the amounts of advance. As such, we find that there is no certainty with regard to the said rate of interest. Therefore, it cannot be presumed that the interest accrued to the assessee at the rate of 18% p.a. as claimed by the assessees in the suits filed for recovery of advances. The Civil Courts would consider and decide the liability of M/s. SCSL to repay the amounts of advances and would also consider the liability of M/s. SCSL to pay interest thereon and the rate of interest at which the advances should be repaid. Therefore, unless and until the liability to pay the advances and the rate of interest at which the temporary advances are to be repaid is determined by the Civil Court, it cannot be said that the same has accrued or arisen to the assessees. However, if the assessees had advanced interest bearing funds as interest free advances, the interest paid by the assessees towards such borrowed funds would have to be disallowed and treated as the income of the respective assessees. The Hon'ble Punjab and Haryana High Court in the case of Abhishek Industries (supra) has held that the nexus between the interest bearing funds and the interest 14 ITA No. 62/Hyd/2014 & Ors. M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
=============================== free advances will have to be proved before making the disallowance of interest and bringing it to tax. We find that neither the Assessing Officer nor the CIT(A) has examined the issue from this angle. Therefore, the orders of the CIT(A) and the Assessing Officers are set aside and the issue is remitted to the file of the Assessing Officer of the respective assessees for de novo consideration in the light of our observations above. Further, we hold that if the amounts advanced to M/s. SCSL by the respective assessees are from their own funds, then the interest expenditure cannot be disallowed and brought to tax. Needless to mention that the Assessing Officer shall give fair opportunity of hearing to the assessees before passing any orders in the light of our above observations and in accordance with law.
17. Further, same view was taken by this Tribunal in the case of other assessees viz., M/s. Banganga Agro Farms Pvt.
Ltd., & Others in ITA Nos. 1852 to 1855/Hyd/2013. Accordingly, on similar lines, we are inclined to remit the issue back to the file of the AO for fresh consideration.
18. In the result, all the appeals of the Revenue are allowed for statistical purposes.
Order pronounced in Open Court on 28th May, 2014 Sd/- Sd/-
(ASHA VIJAYARAGHAVAN) (CHANDRA POOJARI)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Hyderabad, dated the 28th May, 2014
tprao
15
ITA No. 62/Hyd/2014 & Ors.
M/s. Manaslu Agro Farms Pvt. Ltd. & Ors.
===============================
Copy to:
1. The Deputy CIT, Central Circle-9, 8th Floor, Aayakar Bhavan, Basheerbagh, Hyderabad-500 004.
2. M/s. Manaslu Agro Farms Pvt. Ltd., R.K. Residency, H. No. 8-3-229/D/32, III Floor, Venkatgiri, Yousufguda, Hyderabad.
3. M/s. Trishul Greenfields Pvt. Ltd., R.K. Residency, H. No. 8- 3-229/D/32, III Floor, Venkatgiri, Yousufguda, Hyderabad.
4. M/s. Kanigiri Agro Farms Pvt. Ltd., R.K. Residency, H. No. 8-3-229/D/32, III Floor, Venkatgiri, Yousufguda, Hyderabad.
5. M/s. Biligiri Agro Farms Pvt. Ltd., Flat No. 102, Dhanunjaya Nagar, Rajiv Nagar, Yousufguda, Hyderabad-45.
6. M/s. Bahudhanya Agro Farms P. Ltd., H-17, Flat No. 201, Tulsi Apts., Madhura Nagar, SR Nagar, Hyderabad-38.
7. M/s. Dhatu Agro Farms Pvt. Ltd., H-17, Flat No. 201, Tulsi Apts., Madhura Nagar, SR Nagar, Hyderabad-38.
8. M/s. Hakra Agro Farms Pvt. Ltd., H-17, Flat No. 201, Tulsi Apts., Madhura Nagar, SR Nagar, Hyderabad-38.
9. M/s. Kolar Greenlands Pvt. Ltd., H. No. 1-11-195, Flat No. 503, Shamlal Buildings, Begumpet, Hyderabad-72.
10. M/s. Saravati Greenlands Pvt. Ltd., H. No. EWS 1040, III Phase, KPHB Colony, Kukatpally, Hyderabad-72.
11. M/s. Atreyee Agro Farms Pvt. Ltd., H-17, Flat No. 201, Tulsi Apts., Madhura Nagar, SR Nagar, Hyderabad-38.
12. M/s. Balaghat Greenfileds Pvt. Ltd., B-79, Madhura Nagar, Hyderabad-38.
13. M/s. Koel Agro Farms Pvt. Ltd., H. No. EWS 1040, III Phase, KPHB Colony, Kukatpally, Hyderabad-72.
14. The CIT(A)-VII, Hyderabad.
15. The CIT (Central), Hyderabad
16. The DR, B Bench, ITAT, Hyderabad.