Income Tax Appellate Tribunal - Hyderabad
Acit, Circle-7(1), Hyderabad, ... vs Kamineni Builders, Hyderabad, ... on 30 November, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCHES "B", HYDERABAD
BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER
AND
SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER
ITA No. Asst. Year Appellant Respondent
Income Tax
149/Hyd/15 2010-11 Officer,
Ward-7(1)
HYDERABAD
M/s. Kamineni Builders,
HYDERABAD
The Asst. [PAN: AAHFK9996L]
Commissioner of
1486/Hyd/16 2009-10 Income Tax,
Circle-7(1)
HYDERABAD
For Revenue : Shri L. Ramji Rao, DR
For Assessee : Shri K.C. Devdas, AR
Date of Hearing : 24-10-2017
Date of Pronouncement : 30-11-2017
ORDER
PER B. RAMAKOTAIAH, A.M. :
Both are Revenue's appeals for the A.Y 2010-11 and 2009- 10 respectively. Since common issue is involved, these are heard together and disposed-of by this common order.
ITA No. 149/Hyd/15 - AY. 2010-11:2. Brief facts of the case are that the assessee, which is engaged in the business of Real Estate, filed its return of income M/s. Kamineni Builders :- 2 -:
for the AY. 2010-11 originally on 21-03-2011 admitting taxable income of Rs. 49,84,618/-. Subsequently, the assessee filed a revised return of income on 18-05-2011 declaring taxable income of Rs.49,50,990/-. The case was selected for scrutiny under CASS to verify the income arising to the assessee on sale of a property. During the assessment proceedings u/s 143(3) of the Act, the AO observed that the assessee firm is carrying on business in real estate by purchase of land and sale thereof after division and development of plots and during the course of such business, has admitted receipts from the development of land at Rs. 3,90,64,918/-, receipts from sale of land at Rs. 1,89,14,882/- apart from closing stock of Rs. 4,15,50,289/-, but that the assessee had admitted a net profit of Rs. 47,96,566/- only, though the net profit derived by it was Rs. 4,08,42,873/- and that the balance profit of Rs. 3,60,46,308/- was not offered for taxation. The assessee was therefore, asked to explain as to why the remaining profit of Rs. 3,60,46,308/- was not offered to tax in the hands of the assessee firm. The assessee filed a letter dated 27- 02-2013 stating that the assessee entered into an MOU on 22-03- 2007 with M/s. Sindya Infrastructure Development Company Private Limited (herein after referred as SIDCPL or Company), Chennai, as per which, the said company has a charge on the gross receipts of the assessee i.e. 87.12% of the gross receipts after deducting cost of land development charges and brokerage for purchase of land and hence, SIDCPL has an overriding title over the said income and cannot be treated as income of the assessee.
M/s. Kamineni Builders :- 3 -:
3. The AO, was however, not convinced with the said contention of the assessee and held that the parting of share of the profit in favour of SIDCPL is only an application of income and not diversion of income by overriding title. The AO, therefore, brought the entire amount of profit to tax in the hands of the assessee.
ITA No. 1486/Hyd/16 - AY. 2009-10:4. In this assessment year, assessee-firm filed its return of income on 01-10-2010 admitting taxable income of Rs.19,06,910/-. Return was only accepted u/s 143(1). Subsequent to that the AO issued notice u/s. 148 of the Act, on 26-04-2013. Based on the information and documents furnished, the AO has passed the order u/s. 143(3) r.w.s. 147 of the Act on 20-03-2015 after disallowing a sum of Rs. 1,57,01,809/- being the share of profit paid to M/s. SIDCPL.
5. Aggrieved by the orders of the AO, assessee preferred appeals before the CIT(A). Before the Ld.CIT(A), assessee emphasized that the said amounts cannot be treated as the income as per the principle of 'doctrine of overriding title' as the said amount is a charge on the profit of assessee. Further claimed that though the amount was received by him, it was not part of their income, and it was received on behalf of the company to whom it was payable. It was further stated that:
"Assessee had borrowed the entire consideration and agreed to repay the same. Therefore, it is a case of diversion of income by overriding title and not the case of application of income. The true test for M/s. Kamineni Builders :- 4 -:
the application of the rule of diversion of income by an overriding charge is whether the amount sought to be deducted, in truth, never reached him as his income. That the payment made by assessee firm was taxed in the hands of the company, therefore there is no revenue leakage".
6. Ld. CIT (A) granted relief to the assessee by accepting the 'principle of diversion of income by overriding title' and after observing that similar payment in the AYs. 2007-08 to 2010-11 has been allowed by the AO and therefore, the 'rule of consistency and uniformity' has to be followed. The order for AY 2009-10 is extracted for the sake of brevity.
"As per the MOU between the appellant and Sindya Infrastructure Development Co. Pvt. Ltd. dated 22-3-2007, the appellant company received Rs.8 crores from Sindya Infrastructure Development Company Pvt. Ltd., as under:
29-06-2006 - 2 crore
31-6-2006 - 6 crore
After receiving the money from Sindya Infrastructure Development Company Pvt. Ltd. the appellant entered MOU with HDFC for development of land on 22-3-2007.
It is pertinent to mention that the amount paid by Firm of Rs 1,57,01,809 paid to the company was shown as income of the company. However the company did not pay any taxes in view of brought forward losses.
It is pertinent to mention that the same issue was decided in favour of the appellant by the CIT(Appeals) for A.Y. 2010-11 in appeal No. 0095/13- 14/ CIT(A)-VI dtd12-11-2014 where in the CIT(A) observed that :
This practice/ method of accounting has been fallowed by the appellant firm from 2007-08 onwards which were accepted by the department and the amount of Rs. 3,60,46,408/- claimed and debited to profit and loss account for the year under reference is an similar lines and as per the MOU. There is no change in facts and law for A.Y. 2007-08 to 2010-11, and under the circumstances, the argument of the appellant appears reasonable and there is no reason to disturb the claim. The decision of Supreme Court in the case of Radha Soami Satsang Vs. CIT (193 ITR 321) support the cause of the appellant Thus, on the lines of the argument based on facts and the judicial "decisions, there is no ground for the Assessing Officer to treat the claim of expenses, being M/s. Kamineni Builders :- 5 -:
the diversion of profits, on different footing from the other years and for disallowing the same. Accordingly, the addition held to be unsustainable. Thus, based both on facts and the judicial decision, the addition of Rs. 3,60,46,408/- is ordered to be deleted being unsustainable. This ground of appeal is treated as Allowed".
8. In view of the appellants agreement with the Company, the company is entitled to 87.12% of the profits and accordingly the appellant is eligible to claim Rs. 1,57,01,809/-".
Aggrieved by the relief given by the CIT (A), the Revenue is in appeal before us for AY 2009-10 and AY. 2010-11.
7. The learned DR, while supporting the order of the AO has drawn our attention to the various clauses of the MOU to demonstrate that the assessee was only parting with the profits of the company and was retaining its share of 12.88% of the receipts. He submitted that the word "retain" itself demonstrates that the entire profit was of the assessee and it was applying its profit by parting with 87% of the gross receipts after meeting the expenditure, in favour of M/s. SIDCPL and therefore, it is clearly application of income. In support of the contention that the principles of diversion of income by overriding title do not apply to the facts of the case before us, he placed reliance upon the decision of the Hon'ble Supreme Court in the case of CIT vs. Sitaldas Tirathdas reported in (1961) [41 ITR 367].
8. The learned Counsel for the assessee, on the other hand, submitted that it was with the advances received from M/s. SIDCPL, that the assessee had purchased the land from HDFC Ltd and therefore, the said company had the charge over the property. He submitted that the intention of both the parties is evident from M/s. Kamineni Builders :- 6 -:
the MOU wherein it is clearly stated that the property has been purchased with the advance given by M/s. SIDCPL and further that the assessee has not been able to repay the amount and hence 87% of the profits was to be shared by M/s. SIDCPL. He submitted that the Revenue has lost sight of the fact that the assessee could not have purchased the land, leave alone earning any profit, but for the advances of Rs.8.00 crores from M/s. SIDCPL. He also submitted that the assessee had been able to repay only a part of the advances during the relevant previous year. In support of his contention that the charge of M/s. SIDCPL over the gross receipts is nothing but diversion of income by overriding title, the learned Counsel for the assessee placed reliance upon the following decisions:
(a) I.T.A.T Order in the case of C. Narendranath in ITA No.48/Hyd/2013, dated: 26/11/2014
(b) Jamshedpur Motor Accessories Stores vs. C.I.T (Patna) 95 ITR 664
(c) C.I.T vs. C.V. Soundararajan and Another 8 & 9 (Madras) 150 ITR 80
(d) C.I.T vs. M.D. Manohar Rao (A.P High Court) 155 ITR 696
(e) CIT vs. Excel Industries Ltd (Supreme Court) 358 ITR 295
(f) CIT vs. Gopal Purohit (Bombay) 336 ITR 287
(g) C.I.T vs. A.R.J. Security Printers (Delhi) 264 ITR 276.
(h) CIT vs. Sitaldas Tirathdas (Supreme Court) 41 ITR 367 M/s. Kamineni Builders :- 7 -:
(i) Hon'ble A.P. High Court in the case of Spectra Shares and Scrips P Ltd vs. CIT reported in 36 taxmann.com 348
(j) Official Trustee of West Bengal vs. C.I.T, West Bengal-
II, Calcutta 116 ITR 219
(k) CIT, Bombay City -I vs. Crawford Bayley & Co 22 106 ITR 884
(l) CIT, Bombay City -II vs. Nariman B. Bharucha & Sons 130 ITR 863
9. Ld. Counsel also placed on record Paper Book, explaining the transactions of assessee with that of the company to support that assessee could not repay the amounts and the incomes were offered by the other company. On a query, whether incomes were divided between the two parties as per the MOU, it was fairly admitted that in the first year, assessee has not parted with the income and the entire income was offered in the firm's hands. Only in later year i..e, AY. 2009-10, the income was distributed which was offered by the company as well. There is no evidence on record that incomes were distributed in later years. It was the contention of Ld. Counsel that in a project of this nature, where development is involved, assessee has offered about 12.88% which is more than 8% being determined by the ITAT in various other cases.
10. We have considered the rival contentions and perused the documents placed on record in the form of paper book. Before adverting to the rival contentions and adjudication of the issue, it is necessary to consider the following facts:
M/s. Kamineni Builders :- 8 -:
a. There is no dispute with reference to the fact that the said M/s. Sindya Infrastructure Development Company (P) Ltd., (SIDCPL) has advanced funds to assessee-firm on 28-06-2006 to an extent of Rs. 2 Crores and on 31-07-2006 to an extent of Rs. 6 Crores. Assessee has entered into MOU on 22-03-2007 wherein it was agreed that the appellant could carry out the development of land into plots and sell the same and distribute the profit (after expenditure) in the ratio of 87.12% to the said SIDCPL, balance 12.88% to be retained by the assessee-firm. As seen from the financials for the period 01-04-2006 to 31-03-2007, assessee's gross receipts on development of land and sale of land were to the tune of Rs. 1,05,36,668/-, having closing balance of Rs.
8,39,94,008/-. The net profit earned in that year was Rs. 19,69,838/-. For that assessment year AY 2007-08, assessee has filed return of income on 31-05-2010 ( Belatedly) admitting income of Rs. 25,47,842/-. This income includes profit of Rs. 19,69,838/- and disallowance of amount u/s. 40(a)(ia). This indicates that for the assessment year ending 31-03-2007, the profits earned were not shared between the two, even though MOU was stated to have been entered on 22-03-2007. As on 31-03- 2007, assessee has repaid more than Rs. 2 Crores of loan and the outstanding amount was only Rs. 5.95 Crores against SIDCPL. As seen from the ledger account also, assessee was able to repay an amount of Rs. 2,05,00,000/- to the said company. However, as seen from the financials placed on record in the Paper Book from pg. 120 onwards including assessment order in the case of SIDCPL dt. 24-12-2009, M/s. Kamineni Builders was not shown in the balance sheet under any of the head. While disallowing the interest on the interest free advances made, the AO of the said M/s. Kamineni Builders :- 9 -:
company had determined the interest free advances made to M/s. Kalpatharu Infrastructure Development Pvt. Ltd., and disallowed the amount paid to M/s. Kalpatharu Enterprises Pvt. Ltd., whereas the interest free deposit given to M/s. Kamineni Builders was not shown or reflected anywhere so as to verify the same. Thus, there is no evidence of assessee firm being shown as debtor or the profit was shared as decided in the MOU relied on.
b. Coming to AY. 2008-09 i.e., for the year ending 31-03-2008, assessee has shown a profit of Rs. 47,06,063/- on receipt of Rs. 6,28,95,338/-. For this year, however, assessee has shown the share of gross profit at Rs. 3,43,59,901/- stated to have been paid to SIDCPL and offered only net income of Rs. 47,06,073/-, even though the profits from the transactions were shown at Rs. 3,49,39,739/-. The amount was shown as 'profit on sale of land' in the case of SIDCPL (in Schedule 8 of that accounts). As pointed out by the CIT(A), the same was adjusted in the net losses. However, there is no discussion on this issue in the hands of the company in their assessment. The account copies furnished particularly of assessee's account in SIDCPL do indicate that outstanding balance as on 22-02-2007 was Rs. 5,95,00,000/-. However, the journal entry passed on 01-04-2007 has the following explanation:
'Being advanced for land entry passed in the earlier year, now rectified and transferred to the respective accounts to tally the inter account balances'.
M/s. Kamineni Builders :- 10 -:
Thus, the debit entry as on 31-03-2007 was nullified on 01-04- 2007. Thereafter, that company went on to pay more than Rs. 5 Crores of amount to assessee towards 'account' upto 02-11-2007. Subsequently, also assessee paid an amount on 21-05-2008 to an extent of Rs. 7,20,00,000/- and the year ending balance was a credit balance, which means assessee has over paid to an extent of Rs. 2.83 Crores. Thus, the argument that assessee has to discharge the loan by way of agreement to share profits has no validity at all.
c. For the year ending 31-03-2009, assessee has shown receipts of Rs. 2.20 Crores and earned a gross profit of Rs. 1,73,86,209/- and the share of profit to that company was determined at Rs. 1,57,01,809/-. In the company's accounts, however, this amount was not shown as income at all, even though for 31-03-2008, amount of Rs. 3,43,59,901/- as claimed by assessee was shown. In the order for AY. 2009-10 also, there is no discussion about this amount supposed to have been received from assessee-firm nor was offered as income in that year. The account copy of SIDCPL indicate that an amount of Rs. 5 Crores was adjusted on 01-04-2009 towards Smt. Sunitha Reddy with the entry 'being advance pending allotment of shares received from SR wrongly classified under Kamineni Builders now rectified'. These, transactions indicate that assessee and M/s.
SIDCPL had some other transactions, which has no bearing on the claim of profit being shared.
d. For year ending 31-03-2010, the financials of SIDCPL indicate that profit from M/s. Kamineni Builders M/s. Kamineni Builders :- 11 -:
Rs. 3,60,46,308/- was offered as income. The same amount was also claimed by assessee in its financials for 31-03-2010 and net profit of Rs. 47,96,565/- was only offered.
e. For the year ending 31-03-2011, assessee had no sales and only closing stock was shown being the opening stock but the operations resulted in a loss of Rs. 38,765/-. This loss along with other expenditure was claimed at Rs. 3,97,928/-, but the net loss was not divided between the two companies, as per the agreement.
f. However, in the subsequent year ending on 31-03-2012, assessee has shown gross profit of Rs. 3,05,57,192/- and this profit was again shared with SIDCPL at Rs. 2,65,87,139/-. The financials of SIDCPL for these years, however, were not placed on record, so as to examine whether the said company offered the income or not.
11. As seen from the above, there is no consistency in claims either by assessee or by the said company SIDCPL. As far as year ending 31-03-2007 was concerned for which return was filed in May 2010, the entire profit was offered, even though the so called agreement was dated 22-03-2007 and was operative in 2007 itself. As already pointed out, that company has offered incomes only in two years, as seen from the information placed on record and upto 31-03-2008 or even subsequently, M/s. Kamineni Builders was not even shown as a debtor in its schedules. Therefore, the very basis of distribution is giving a doubt about the real arrangement between the parties.
M/s. Kamineni Builders :- 12 -:
12. Coming to the legal propositions, we find that the Hon'ble Supreme Court in the case of CIT vs. Sitaldas Tirathdas (Supreme Court) [41 ITR 367] has brought out the difference between the application of income and diversion of income by overriding title. It has been held that the true test for the application of the rule of diversion of income by overriding charge is the nature of the obligation i.e. whether the amount sought to be deducted reached the assessee as his income which the person is obliged to apply or whether an amount by the nature of the obligation cannot be said to be a part of the income of the assessee. It has been held that where by the obligation, the income is diverted before it reaches the assessee, it is deductible, but where the income is required to be applied to discharge an obligation after such income reaches the assessee, then it is application of income.
13. In the case before us, the assessee had received an advance of Rs.8 Crores on 28-06-2006 and 31-07-2006 from SIDCPL and has utilized the said advance for purchase of land at Chengalpet, Chennai from HDFC Chennai, by entering into an agreement dated 28-06-2006. At that point of time, there is no obligation on the part of the assessee, to part with any of the receipts or even profit from the sale of such land. It is only a receipt of advance which was stated to be returned within the period agreed to by and between the parties on or before 31-03- 2007. Thereafter, it was stated, that when the assessee could not repay the advance to SIDCPL as agreed to and the assessee entered into an MOU dated 22-03-2007 to assign/nominate 87.12% of the share in the profits, which is defined in the MOU to M/s. Kamineni Builders :- 13 -:
mean 'surplus remaining after deduction from out of total sale receipts of land, cost of acquisition of land, development charges, brokerage charges on purchase of lands and other incidental expenses'. Therefore, it is clear that the so called obligation of the assessee, arises only by virtue of the MOU dated 22-03-2007, that too, by way of agreement between parties, not connected with property as such.
14. Since the amount of Rs. 2.05 Crores was already paid by the time the MOU entered, the distribution of profit at 87.12% also gives rise to a doubt about the ratio that was determined.
The project was to be undertaken by the firm and only the profits are to be shared, not the losses, after set off of all expenditures. If there is an obligation at the source, then the losses arising also gets shared. As seen from the terms of agreement, this can only be considered as appropriation of the profits but not a 'diversion by overriding title'. The principles are very clear that the obligation has to be to the source. In this case, this obligation is created by the parties by way of subsequent agreement, much later to the advancing of money to assessee-company (with or without interest) and part of the payment was already repaid out of the total amount borrowed. The way incomes were offered in assessee's hands in the first year, even though agreement was entered as early as 22-03-2007 and the return was filed much later on in May 2010 and that company was offering incomes only in two years and not offering in some years, even though it has received substantial amounts in three years (as per details placed on record), do indicate that there is no consistency in claims and M/s. Kamineni Builders :- 14 -:
the reasons for offering in some years and not offering in other years is not explainable/verifiable on the record.
15. One of the arguments raised by Ld. Counsel is that assessee offered more than 8% profit on the development, accordingly, those claims are allowable. We do not agree with this argument. As seen from the P&L A/c of the firm, the profits itself are very high. As per the MOU also only the profits are being shared at that ratio. Therefore, after earning profits, portion of the amount is apportioned, which cannot be considered as expenditure in the hands of firm, who has undertaken the development of the property. What could be the source of the funds for investing property is a separate consideration, while the so called MOU entered, subsequent to the property being purchased and developed, cannot be considered as an obligation created at source, so as to claim diversion of income. Since it is only an appropriation of the profits by way of a separate arrangement by the so called agreement, we are of the opinion that the AO is correct in treating it as application of income, but not diversion at source.
16. Ld.CIT(A) even though has stated some of the facts, we are of the opinion that he has applied the principles incorrectly and therefore, his order cannot be sustained. The other aspect which CIT(A) has considered is consistency in accounts, even though this concept also was not applied properly. As already stated, assessee has not distributed the profits for the year ending 31-03-2007 (already noted, the return was filed in May, 2010) and the entire profits were offered, even though it was claimed that M/s. Kamineni Builders :- 15 -:
there was an agreement dt. 22-03-2007. As verified from the documents placed on record, the said company also did not offer the incomes, even though it has received in some years. Basically, M/s. Kamineni Builders is even not shown as 'debtor or as an investment' in any of the schedules, whereas another sister concern is being shown as party to whom the funds are advanced interest free. That AO's disallowance of interest free on two sister concerns in the hands of company is indication that M/s. Kamineni Builders is not shown in the books of the said company (as verified by us from the documents placed on record). In view of these facts available on record, we are of the opinion that assessee did indeed earn very high margin of profits and for unexplained reasons, the same was distributed/applied to discharge its obligation of repaying the loan. Accordingly, we are of the opinion that this obligation cannot be considered as an expenditure or as diversion of income. We have no hesitation in setting aside the order of the CIT(A) and restoring the order of AO for the impugned assessment years.
17. Assessee's Counsel has relied on various cases law as stated above. We are of the opinion that the principle established in various case law is based on the judgment of Hon'ble Supreme Court in the case of CIT Vs. Sitaldas Tirathdas (supra), but the facts of case are entirely different so as to make applicable to assessee's case.
18. In the case of ACIT Vs. Mr. C. Narendranath in ITA No. 48/Hyd/2013 (AY. 2008-09) dt. 26-11-2014, the issue is with reference to adopting sale consideration. There, the facts indicate M/s. Kamineni Builders :- 16 -:
that the land owner has to pay corpus fund, infrastructure fund and difference on account of teakwood falling to his share to the builder by an agreement. The builder instead of collecting the same from the flat owners, passed on the responsibility to the land owner. Thus by virtue of clause in the agreement, there is an obligation created under the agreement and while calculating the sale consideration for the purpose of capital gains, the amounts paid towards infrastructure expenditure and corpus fund etc., were allowed to be deducted. In that context, while determining the 'full value of consideration', it was held that it was an obligation to pay by virtue of the agreement. The facts in that case are entirely different.
18.1. In the case of Jamshedpur Motor Accessories Stores Vs. CIT [95 ITR 664] (Pat), there was an agreement to pay profits instead of interest while borrowing the amount itself. In that context, the claim of profit was held to be the business expenditure 'wholly and exclusively laid out for the purpose of business'. The facts in that case also indicate that there was a prior agreement before borrowing the money to pay the interest which is charged on the profits of assessee. No such fact exists in this case.
18.2. In the case of CIT Vs. C.V. Soundararajan and Another [150 ITR 80] (Mad), the facts indicate that there was a family partition in which assessee's were allotted a property in which their mother was given a 'right of residence' consequently, the amount paid to the mother was considered to be allowable as there is an obligation to pay as assessees did not have any absolute right over the property. We are afraid that the principles laid down by the M/s. Kamineni Builders :- 17 -:
Hon'ble Madras High Court in that case do not apply to the facts of the case, as there is no obligation to the property at all, but the obligation was created by arrangement/agreement between the parties subsequently.
18.3. Similarly, the facts in the case of CIT, AP Vs. M.D. Manohar Rao is that there is diversion by overriding title. In that case, there is an agreement for sale of land and the land was subsequently acquired by Government. The excess price received belongs to the purchaser as per the agreement. Therefore on the facts of the case, it was held that amount of compensation in excess of agreed sale price was diverted by overriding title from seller. The facts of that case and the principle laid down therein do not apply to assessee's case at all.
18.4. The rest of the cases relied upon by assessees Counsel are on the principle of consistency. As already discussed above, neither party is following any consistent method of accountancy or claims. In view of that, even though there is no dispute with reference to the 'principle of consistency' on the facts of the case those decisions do not apply to assessee's case.
19. In view of that, we are of the opinion that there is only an application of income by virtue of subsequent agreement by assessee and there is no obligation or diversion by overriding title attached to the property, particularly in view of the fact that assessee has agreed only to share the profits but not the losses and this agreement was subsequently entered, which cannot be considered as an obligation on the source itself. In view of that, we M/s. Kamineni Builders :- 18 -:
set aside the order of CIT(A) and restore the order of AO for both the assessment years.
20. In the result, both the appeals of Revenue are allowed.
Order pronounced in the open court on 30th November, 2017 Sd/- Sd/-
(P. MADHAVI DEVI) (B. RAMAKOTAIAH)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Hyderabad, Dated 30th November, 2017
TNMM
M/s. Kamineni Builders
:- 19 -:
Copy to :
1. The Asst. Commissioner of Income Tax, Circle-7(1), Hyderabad.
2. The Income Tax Officer, Ward-7(1), Hyderabad.
3. M/s. Kamineni Builders, H.No. 10-3-316/A, Masab Tank, Hyderabad.
4. CIT (Appeals)-VI, Hyderabad.
5. CIT (Appeals)-3, Hyderabad.
6. CIT-VI, Hyderabad.
7. Pr.CIT-3, Hyderabad.
8. D.R. ITAT, Hyderabad.
9. Guard File.