Income Tax Appellate Tribunal - Mumbai
Technimont Icb P.Ltd ( Successors To ... vs Assessee on 27 June, 2014
IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH, MUMBAI
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BEFORE SHRI R.C. SHARMA, ACCOUNTANT MEMBER AND
SHRI VIJAY PAL RAO, JUDICIAL MEMBER
vk;dj vihy la[;k/ITA NO.7576/Mum/2012
¼fu/kkZj.k o"kZ@Assessment year: - 2008-09
Tecnimont ICB Pvt. Ltd. Additional CIT-9(3) 2nd Floor,
(Successors to Engineering Vs. Room No. 229,
design Tecnimont ICB Pvt. Aaykar Bhavan, M.K. Road,
Ltd.) Tecnimont ICB House, New Marine Lines,
Chincholi Bunder, 504 Link Mumbai - 400 020.
Road, Malad (W) Mumbai -
400 064.
PAN AAACI2628B
Appellant Respondent
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Assessee By/fu/kkZ Shri M.P. Lohia
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Revenue By/jktLo Shri S.D. Srivastava.
Date of hearing
16.06.2014
Date of pronouncement
27.06.2014
ORDER
Per Vijay Pal Rao, JM
This appeal by the assessee is directed against the assessment order dated 15.11.2012 passed u/s 143(3) r.w.s 144C(13) of the Income Tax Act in parsuance to directions of Dispute Resolution Panel (herein after referred as Tecnimont ICB Pvt. Ltd.
DRP) dated 28.09.2012 u/s 144C(5) of the Income Tax Act for the A.Y. 2008-
09. The assessee has filed the concise grounds as under:-
"Based on the facts and circumstances of the case, Tecnimont 1GB Private Limited (successors to Engineering Design Tecnimont 1GB Private Limited) (hereinafter referred to as the Appellant) respectfully craves leave to prefer an appeal against the final order passed by the learned Additional Commissioner of Income-tax - 9(1) ('AO'), in pursuance of the directions issued by Dispute Resolution Panel- I (,DRP'), Mumbai under section 143(3) r.w.s.144C(13) of the Income-tax Act, 1961 (hereinafter referred to as the Act) on the following grounds which are independent and without prejudice to each other.
On the facts and circumstances of the case and in law, the AO/ Transfer Pricing Officer (TPO') based on directions of DRP:
General 1 erred in making a transfer pricing adjustment of Rs 29,08,51,336/-; 2 erred in adopting an approach based on unsubstantiated presumptions, surmises, conjectures and allegations for the purpose of making an adjustment to the international transactions, thereby violating the provisions of section 92 C(3) read wit h 92GA( 3) of the Act;
3 erred in ignoring the fact that since the Appellant is availing tax holiday u/s 10A of the Act, there is no motive or reason to shift profits out of India, curbing which is the basic intention of introducing the transfer pricing provisions;
Rejection of economic and comparability analysis 4 erred in not accepting the economic analysis undertaken by the 4 Appellant in accordance with the provisions of the Act read with the Rules, conducting a fresh search for the determination of the ALP in connection with the impugned international transaction and holding that the Appellant's international transaction is not at arm's length;
Order based on incorrect presumptions 5 erred in making incorrect presumptions like;
a) The Appellant operates on a cost plus 15% basis;
b) A ppe l l ant 's G l ob al A n al y t i c al Ce nt e r re n de rs c re di t a na l y t i c al and research services, which are also in the nature of KPO services;
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c) The Appellant is providing services exclusively to its AE, Thomson US;
d) The Appellant is engaged in equity and credit research services.
Rejection of Business Activity profile 6 erred in holding that the Appellant's business activity is similar to KPO without assigning any valid reasons and without analyzing business activity of the Appellant in the right perspective;
Comparables selected by Assessing Officer/TPO 7 erred in selecting following com parables though they are functionally different compared to the business activities of the Appellant :
• Acropetal Technologies • Crossdomain Solutions Limited • Exclerx Services Limited • Mold-Tek Technologies Limited • Triton Corp Limited
8 erred in selecting Mold-Tek Technologies though not comparable in view of the fact that there was a demerger as well as acquisition du ring the year and without appreciating that TPO itself rejected Allsec Technologies as a comparable on similar grounds during his search process;
9 Without prejudice to the above, if Mold Tek Technologies is accepted as a comparable, then Allsec Technologies should also be considered as a comparable;
10 Without prejudice to the above, erred in applying incorrect margin of 96.66% for Mold Tek Technologies as against the correct margin of 15.05% as worked out by the Appellant;
11 erred in continuing "M/s Coral Hubs Ltd." as a part of comparable set, even though the DRP specifically directed to exclude it from the comparable set;
12 Without prejudice to the above, while treating the Appellant's business activity similar to KPO, erred in rejecting following 5 companies out of 11 comparables mentioned in the show cause notice without assigning any valid reasons even though they fulfilled all the quantitative filters adopted by the TPO:
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• Aditya Birla Minacs Worldwide Ltd.
• R Systems International Ltd.
• Spanco Ltd.
• Accentia Technologies Ltd.
13 W ITHOUT PREJUDICE TO THE ABOVE , WHILE TREATING THE A PPELLANT ' S BUSINESS ACTIVITY SIMILAR TO KPO, ERRED IN NOT SELECTING THE FOLLOWING 7 COMPARABLES IN THE COMPARABILITY STUDY UNDERTAKEN BY THE TPO EVEN THOUGH THEY FULFILLED ALL THE QUANTITATIVE FILTERS ADOPTED BY THE TPO:
• Infosys BPO Limited • Asit C Mehta Financial Services Ltd • E4e healthcare Business Services Pvt Ltd Adjustment on account of cost of new hires/ trainees
14 While computing margin for the appellant's comparables, erred in not granting adjustment on account of cost of new hires/ trainees who remained unproductive during the year being under training;
Risk Adjustment 15 erred by not making suitable adjustments to account for differences in the risk profile of the Appellant vis-a-vis the co parables."
2. At the time of hearing the Ld. Authorized Representative of the assessee has submitted that subsequent to the directions of DRP dated 28.09.2012, the assessee has filed a rectification petition under Rule 13 of the Income Tax (Dispute Resolution Panel Rules 2009) on 27.12.2012. The DRP disposed of the rectification petition vide order dated 10.03.2014, thereby directed the Assessing Officer/TPO to recompute the margin of Mold- Tek Technologies Ltd after considering the loss on derivatives as an operating item. He has filed a copy of the DRP order dated 10.03.2014 whereby the directions are modified. The Ld. Authorized Representative has then submitted that in view of the rectified directions of DRP, the ground no. 8, 10 and 11 of the concise grounds became infructuous. The Ld. DR has not
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disputed this fact that in view of the modified/rectified directions of DRP, ground nos. 8,10 and 11 of the assessee's appeal became infructuous.
3. In view of the above submissions and the order of DRP dated 10.03.2014, the ground nos. 8,10 and 11 are dismissed being infructuous.
4. Groun no. 1 to 3 are general in nature and do not require any specific finding or adjudication.
5. Ground Nos. 4 to 7, 12 and 13 are in relation to the rejection of comparables selected by the assessee and inclusion of fresh comparables by TPO and thereby making the addition/adjustment.
5.1 The assessee has electronically filed its return of income on 29.09.2008 declaring total income of Rs. 12,24,93,560/-. The assessee company is engaged in the business of export and informatin technology enabled services under the STPI scheme of Govt. of India as 100% export unit. During the year under consideration the assessee company has provided engineering design services using CAD/CAM software to its AEs (associate enterprises). The assessee filed report in the form no. 3CEB along with the return of income declaring international transactions. The Assessing Officer made a reference u/s 92CA(1) to the transfer pricing officer (TPO) for computation of arm's length price (ALP) in relation to the international
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transactions. The TPO noted the international transactions of the assessee in para 4 of the order as under:-
Sl. Name of the AE Name of International Amount (In INR) Most No. Transactions Appropri ate Method
1. Tecnimont SpA Supply of engineering design Rs. 1,092,846,852 TNMM and technical services Administrative services Rs.7,590,924/-
2. Sofregaz S.A. Supply of engineering design Rs.5,198,550/- TNMM and technical services Administrative services Rs. 167,025
3. TWS SA Supply of engineering design Rs. 35,823,201/- TNMM and technical services Administrative services Rs. 774, 099/-
4. Technimont India Supply of engineering design RS. 240,606,763/- TNMM Project Office and technical services
5. Tecnimont SpA Reimbursement of Cost Rs. 15,275,686/- At cost allocation 6 Tecnimont SpA Recover of Expenses Rs.124,539,636/- At cost 5.2 The assessee filed its TP study report and shown the margin at 19.46% on operating income which has been bench marked by the average PLI of comparables at 16.61% by applying TNMM as most appropriate mehod. Thus the assessee claimed that the price charged for its international transaction is higher than the arithematical mean price and, therefore, the price charged by the assessee on its international transactions is at arm's length. The assessee has selected six comparables on the basis of search
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conducted in the public data bases, prowess and capital line plus. The TPO noted that the assessee has derived the net profit margin at 19.46% during the year under consideration and bench marked its international transaction by taking a set of six comparable companies in ITES and BPO sector. He has further noted that the assessee has used three years data of these six comparables for the purpose of bench marking and the arithematic mean of the net profit margin of the comparable companies which comes to 16.61%/. The first objection of the TPO against the comparable selected by the assessee was that the functions performed by the assessee by providing services to its AEs is similar to that provided by KPO. Therefore, the companies selected by the assessee in the ITES and BPO sector for bench marking its international transaction was found by the TPO not comparable with the functions performed by the assessee in providing the services which are in the nature of KPO. Further the TPO has also questioned the use of three/multi year data instead of current year data of the comparable companies. Accordingly the TPO rejected all six comparables selected by the assessee and undertook a fresh search for selecting the comparables in the KPO field. The TPO has applied various filters in searching for comparables including the companies whose data is not available for the F.Y. 2007-08 and the companies that are not mainly engaged in KPO services were excluded. Since the other filters applied by the TPO are not in dispute before us, therefore, we are referring mainly two criteria against which the assessee has raised serious objections. The assessee took operating profit to total income as profit level indicator (PLI) whereas the TPO has considered the operating profit to operating expenses/cost as appropriate PLI. By applying the filter/criteria for search of the companies, the TPO finally shorted out 13 companies for further examination and inclusion of comparables. Out of these
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13 companies, the TPO slected final set of six comparables which were engaged in the KPO services. During the course of proceedings the assessee submitted before TPO that the entire set of KPO companies are not comparables as its activities are more akin to BPO and raised the objection against the comparability of each of the companies selected by the TPO. The TPO rejected the objections raised by the assessee and finally arrived at arithematic mean margin at 49.88% by considering the operating profit to total cost as PLI. The TPO has also rejected the claim of the assessee for risk adjustment on account of difference in the risk profile vis-à-vis comparable selected by TPO. Accordingly the TPO made an adjustment of Rs. 29,08,51,336/- on the basis of arm's length price determined at Rs. 1,69,56,75,115/- by taking the mean margin at 49.88% of the six comparables finally selected by the TPO. The Assessing Officer framed the draft assessment order against which the assessee filed objections before the DRP. The DRP vide its direction dated 28.09.2012 directed the Assessing Officer/TPO to exclude one company namely M/s Coral Hubs Ltd from the set of comparables selected by the TPO. Further the DRP vide order dated 10.03.2014 have passed the modified directions on the rectification petition of the assessee in respect of mistake in the calculation of margin of M/s Moldtek Technologies Ltd. The DRP has directed the Assessing Officer/TPO to recompute the margin of Mold Tech Technologies in a manner similar to that of assessee's in respect of forex exchange gains and losses inlcuding that of derivatives.
6. Before us, the Ld. Authorized Representative of the assessee has submitted that the TPO has rejected the comparables selected by the
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assessee on the basis of wrong facts and assumption and solely on the ground of KPO and BPO as a criteria of functional comparability. The Ld. Authorized Representative has submitted that this issue of comparability of BPO and KPO and determination of arm's length price has been considered and decided by the Special Bench of this Tribunal vide its decision dated 7.03.2014 in the case of M/s Maersk Global Centres Vs. ACIT In ITA No. 7446/Mum/2012. The Special Bench has held that the potential comparables of ITES sector level can be selected by applying broad functional test at first stage and classification of ITES into low end BPO services and high end KPO services for comparability analysis would not be fair and proper. Thus the functional comparability of the assessee with the potential comparables should be based on actual nature of business activities and not on the nomenclature of KPO and BPO. The Ld. Authorized Representative then took us to the business profile of the assessee and submitted that the assessee is primarily engaged in providing engineering design support services to its AEs. The core EPC team of the AE closely work with the customer and the technology provider to convert the basic design into workable detailed design. In order to save on labour cost, portion of the low end design and drawing work is outsourced by the AE to the assessee. He has further submitted that the business profile of the six companies selected by the assessee as comparable is similar to the business of the assessee. The Ld. Authorized Representative has then referred the business description of INFOTECH from the annual report placed at page 737 of the paper book and submitted that the company is specialized in geospatial, engineering design and IT solutions. Its range of services include digitization of drawings and maps, photogrammetary, computer aided design/engineering (CAD/CAE), design and modelling repair development engineering etc. Thus the business
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profile of the comparable is similar to the assessee's business. He has then referred the business profile of Rolta India at page 698 and 701 and submitted that the said company is also in the engineering and design business as one of its segment and, therefore, the said segment is comparable with the assessee. The next comparable selected by the assessee is Onward Technology and the business profile of the Onward Technology Ltd. has been referred in the Director's report at page 791 of the paper book. The Ld. Authorized Representative has submitted that the Onward Technology is in the Mechanical Engineering design services. Its clients include global Fortune 1000 manufacturing companies in the automotive, agricultural, heavy engineering, electrical equipments and Aerospace Industry. Thus the segment data used by the assessee having relation to the comparable business of the assessee. The Ld. Authorized Representative then referred the business profile of TATA ELXSI LIMITED at page no. 755 of paper book and submitted that the said company is in the Prodcut Design Services, Innovation Design Engineering and Visual Computing Labs. The assessee has used segmental data of design engineering segment, therefore, the business of the design engineering segment providing integrated styling and mechanical design solution is similar to the assessee's business activity and, therefore it is a good comparable. The Ld. Authorized Representative then referred the business profiel of the Neil Soft Ltd. and submitted that the said company is also in the similar line of business providing engineering product/product lifecycle, CAD/CAM/CAE design automation application development etc. The last comparable of the assessee is Geometric Ltd and the Ld. Authorized Representative has referred the business profile of the said company at page 839 of the paper book and submitted that the results of computer aided design/computer aided 10 | P a g e Tecnimont ICB Pvt. Ltd.
manufacturing and computer aided manufacturing product, therefore, this company is also a good comaprable.
7. The Ld. Authorized Representative then referref the comparables selected by the TPO and submitted that non of the companies is functionally comparable with the assessee and some of the companies selected by the TPO has different nature of business. However without prejudice the right and contention of the assessee, the Ld. Authorized Representative has submitted that even if the TPO's comparable after the order of DRP are taken into consideration along with the assessee's comparable then the mean margin of the eleven comparables comes to 23.53% which is less than the assessee's operating profit margin of 24.17% and, therefore, the assessee's price is at arm's length and no adjustment is required to be made. He has further contended that even if all 13 companies are filtered by the TPO by applying the common filter are takenn into account, the arithematic mean of the operating profit of all these companies comes to 19.87% which is much below the operating profit of the assessee at 24.17%. The Ld. Authorized Representative has further pointed out that the TPO though raised an objection of using multi year data instead of current year, however, during the proceedings before the TPO, the assessee furnished the current year data and revised updated margins of the comparables selected by the assessee which comes to 15.31%. The TPO has duly noted this fact in para 8.3 but rejected the comparables selected by the assessee.
8. On the other hand, the Ld. DR has strongly relied upon the orders of authorities below and submitted that the TPO has selected a set of 11 | P a g e Tecnimont ICB Pvt. Ltd.
companies which are similar and comparable to the business of the assessee and further the decision of Special Bench in the case of M/s Maersk Global Centres Vs. ACIT (supra) was not available before the authorities below.
9. We have considered the rival submissions and carefully perused the relevant materials on record. We have given our deep thought on the issue of comparability of he companies selected by the assessee as well as by the TPO. The business profile of the assessee has been recorded by the TPO at page 22 of its order as under:-
"It was submitted that assessee is primarily engaged in providing engineering design support services to its AE's. The AE's of the assessee are in the business of executing turnkey engineering, procurement and construction contracts (EPC) for customers. Since the AE's do not possess their own technology for building plants; they approach global players like Mitshibushi. KBR etc for licensing the basic design and technology.
The core EPC team of the AE closely work with the customer and the technology provider to convert the basic design into workable detailed design. In order to save on labour cost; portion of the low end design and drawing work is outsourced by the AE to the assessee. The employees of the assessee are largely draftsmen and CAD/CAM operators who convert the instructions provided by the core team into drawings. These drawings are checked and verified by the Core team of the AE; including the customer and the project managers appointed by the customer. The corrections suggested by the Core team are executed by EDTCIB and resubmitted to the Core team."
10. The assessee is a wholly owned subsdiary of Tecnimont ICB Pvt. Ltd. and engaged in the execution of computer software and information technology enables services, engineering design under the software development park scheme of Govt. of India. At the outset we note that the TPO has rejected the six comparables selected by the assessee on the 12 | P a g e Tecnimont ICB Pvt. Ltd.
ground that the set of companies selected by the assessee as comparables are in the BPO services and, therefore, not comparable with the services of the assessee which is in the nature of KPO. It is pertinent to note that the TPO has not undertaken the exercise of comparing the actual functions and business profile of the assessee with the comparables selected by the assessee but the rejection of the comparables selected by the assessee is based only on the ground of BPO and KPO services. In the recent decision of SB of this Tribunal in the case of M/s Maersk Global Centres Vs. ACIT (supra), the Special Bench has considered and decided this issue in para 78 as under:-
"To sum up, we hold that the potential comparables of ITES sector level can be selected by applying broad functional test at first stage and although the comparables so selected can be put to further test, depending on facts of each case, by comparing the specific functions performed in the international transactions with that of uncontrolled transactions to attain the relatively equal degree of comparability as discussed above, the classification of ITES into low-end BPO services and high-end KPO services for comparability analysis would not be fair and proper. The first question referred to this Special Bench is whether for the purpose of determining the arm's length price of international transactions of the assessee company providing back office support services to their overseas associated enterprises, companies performing KPO functions should be considered as comparable ?. In our opinion, the answer to this question will depend on the facts and circumstances of each case inasmuch as if the assessee company, on the basis of its own functional profile, is found to have provided to its AE the low- end back office support services like voice or data processing services as a whole or substantially the whole, the companies providing mainly high-end services by using their specialized knowledge and domain expertise cannot be considered as comparables."
11. Thus it is clear that the classification of Information Technology Enables Services (ITES) into low end BPO services and high end KPO services for comparability analysis is not just and proper, and, therefore, the action of the TPO in rejecting the comparables by applying the criteria of BPO and KPO is 13 | P a g e Tecnimont ICB Pvt. Ltd.
not sustainable in view of the decision of Special Bench. We further note that the assessee has used the segmental data for determining the arm's length price and taken the mean profit of each comparable only from the segmental data/results. Though the TPO initially raised an objection of using multiple year data, however, we note that during the couse of proceedings before the TPO, the assessee furnished the updated current year data, mean margin of the comparables based on the current year data. This fact has been recorded by the TPO at page 23 of the order. The relevant part of the TPO order is as under:-
"As regards years for which the data has been used in the documentation, the assessee submitted that the comparable data for FY 2007-08 was not available in all cases, at the time of complying with the documentation requirements under the Act by the specified date. Further, rejection of the documentation prepared by the assessee on the above ground would be contrary to what is prescribed under the Act and the relevant rules A reference was made to the definition of the term "arm's length price" under section 92F(ii), Rule 10C. Rule 100(3) and Rule 100(4). Further reference was also made to the ITAT ruling, Bangalore bench in Philips Software Centre Pvt. LId Vs ACIT (11 9 TT J 721). Assessee also submitted updated margins of comparable pertaining to FY 2007-08 which works out to 15.31%."
12. It is clear that after submitting the updated margins of the comparables, the objection of using multiple year data ceased to exist. Once the criteria adopted by the TPO for rejecting the comparable of the set of companies selected by the assessee is not found proper then the comparability has to be analysed on the basis of real nature of the business activities of the assessee as well as the comparables and further where the segmental data are used then the only business activity of the particular segment of comparable has to be compared with the business activity of the assessee. We find that the business profile of the six comparables selected by the assessee and 14 | P a g e Tecnimont ICB Pvt. Ltd.
particularlly the segment of engineering design services are similar to that of the assessee's services provided to the AEs, therefore, when the International transaction of the assessee company in respect of of the services provided to the AEs are similar to the business profile of the comparables and a particular segment of the comparable then the rejection of the comparables selected by the assessee is not proper and justified. Without going into the comparbility of the companies selected by the TPO, if we consider the alternative submission of the assessee that the comparables selected if as well as the five comparables of the TPO after the DRP order rejecting one out of six comparables, the mean margin of eleven companies comprising six selected by the assessee and five of the TPO comes to 23.53%. The assessee has given the details of the operating profit of all the eleven companise comprising the six comparables selected by the assessee and five of the TPO as under:-
Margin of comparable companies as documented in the transfer pricing study of EDTICB plus the companies adopted by the learned TPO:
SrNo Name of the Company Operating profit/
operating cost
1 Rolta India Limited (Seg) 49.06%
2 Infotech Enterprise Limited (Seg) 15.38%
3 Tata Elxsi Limited (Seq) 18.18%
4 Onward Technoloqies Limited (Seq) -1.63%
5 Neilsoft Ltd 5.55%
6 Geometric Limited (Seq) 5.30%
7 Acropetal Technologies (Seg) 35.30%
8 Crossdomain Solutions Ltd 26.96%
9 Eclerx Services Ltd 65.88%
10 Mold-tek Technologies Ltd 15.05%
11 Triton Corp Ltd 23.81%
Arithmetic Mean 23.53%
13. The assessee also filed the computation which shows that the assessee's operating profit by using PLI as OP/OC from the international transaction is 24.17% 15 | P a g e Tecnimont ICB Pvt. Ltd.
which is more than the arithematic mean/ALP based on the set of eleven comparables including the assessee's as well as the TPO's selected companies. It is pertinent to note that even after accepting the comparable companies selected by the assessee, the TPO has power u/s 92 CA(3) to gather and consider all relevant materials and information apart from the evidence, information and documents provided by assessee as required under section 92 D(3) of Income Tax Act to determine the ALP in relation to the international transaction. Further the TPO is also empowered under section 92 CA(7) to exercise any of the powers specified in clauses (a) to (d) of sub-section (1) of section 132 or sub-section 6 of section 133 or 133A for the purpose of determining the ALP. Therefore, under the provisions of transfer pricing the TPO is not precluded from carrying out fresh search for gathering more relevant information for the purpose of determining the ALP. Thus large size of comparable would give better and adequate representation of uncontrolled price in turn a proper and more realistic price can be determined to compare with the price of international transaction. Thus, by considering the total no of comparables comprising assessee's as well as TPO's and mean margin thereof, we find that assessee's international transactions are at arm's length and, therefore, no adjustment is called for.
14. As regards Ground nos.9, 14 and 15, in view of our finding on the issue of comparable and determination of ALP and consequential adjustment, ground nos. 9, 14 and 15 of the revised grounds become infructuous and need no adjudication.
13. In the result appeal of the assessee is partly allowed..
Order pronounced in the open court today i.e 27-6-2014
Sd/- Sd/-
(R.C. Sharma) (Vijay Pal Rao)
ys[kk lnL;)
(Accountant Member/ys lnL; U;kf;d lnL;)
(Judicial Member/U;kf;d lnL;
Mumbai dated 27-6-2014
SKS Sr. P.S,
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Tecnimont ICB Pvt. Ltd.
Copy to:
1. The Appellant
2. The Respondent
3. The concerned CIT(A)
4. The concerned CIT
5. The DR, "J" Bench, ITAT, Mumbai
By Order
Assistant Registrar
Income Tax Appellate Tribunal,
Mumbai Benches, MUMBAI
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