Income Tax Appellate Tribunal - Mumbai
Lloyds Tsb Global Services P.Ltd , ... vs Assessee on 27 August, 2012
आयकर अपीलीय अिधकरण,
अिधकरण, मुंबई Ûयायपीठ 'क
के' मुंबई
IN THE INCOME TAX APPELLATE TRIBUNAL
"K" BENCH, MUMBAI
ौी बी.
बी रामकोटáय
रामकोटáय,
टáय लेखा सदःय,
सदःय एवं ौी अिमत शुÈला,
ला, Ûयाियक सदःय के सम¢
BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND
SHRI AMIT SHUKLA, JUDICIAL MEMBER
आयकर अपील सं. / ITA no. 5928/Mum./2012
(िनधा[रण वष[ / Assessment Year : 2008-09)
Lloyds TSB Global Services Pvt. Ltd.
Unit-2, "B" Wing, Tridib Bldg. Bagmane ....................... अपीलाथȸ /
Tech Park, C.V. Raman Nagar Appellant
Bangalore - 560 093
बनाम v/s
Dy. Commissioner of Income Tax
Circle-3(2), Aayakar Bhavan ................... ू×यथȸ /
101, M.K. Road, Mumbai 400 020 Respondent
ःथायी लेखा सं./ Permanent Account Number - AAACL9321N
िनधा[ǐरती कȧ ओर से / Assessee by : Mr. M.P. Lohia
राजःव कȧ ओर से / Revenue by : Mr. Ajeet Kumar Jain
सुनवाई कȧ तारȣख / आदे श घोषणा कȧ तारȣख /
Date of Hearing - 30.10.2012 Date of Order - 21.11.2012
आदे श / ORDER
ू×येक पीठ PER BENCH The present appeal preferred by the assessee, is directed against the final impugned assessment order dated 27th August 2012, which was passed in pursuance of the directions given by the Dispute Resolution Lloyds TSB Global Services Pvt. Ltd.
2Panel-I (for short "DRP"), Mumbai, for the quantum of assessment passed under section 144C(v) of the Income Tax Act, 1961 (for short "the Act") for the assessment year 2008-09. Following grounds have been raised by the assessee:-
"1. The learned AO erred in passing an order under section 143(3) r.w.s. 92CA and r.w.s 144C(5).
2. The learned Assessing Officer / Transfer Pricing Officer (TPO) erred in making an addition of Rs. 26,750,954 to the value of international transaction of rendering support services by the appellant. The AO / TPO erred in determining the average Profit Level Indicator (PLI) of the comparables at 30.84%.
3. The learned AO/ TPO erred in rejecting the documentation to the extent of the search process adopted by the appellant without providing any cogent reasons and requesting the appellant to conduct a fresh search for comparable companies:
4. Without prejudice, in the fresh search conducted by the appellant the learned A.O / TPO erred in rejecting five low margin earning comparable companies and accepting four high margin earning companies as comparable to the appellant without considering the fact that the low margin companies were engaged in the same activities as that of high margin companies.
5. The learned AO / TPO erred in identifying comparable companies based on the data available in the public domain at the time of conducting the assessment i.e using noncontemporaneous data for calculating arm's length price of the international transaction entered by the appellant.
6. The learned AO / TPO erred in using single year data for undertaking a comparability analysis that will not produce accurate results.
7. The learned AO / TPO erred in not considering the provisions of Section 92C(2) of the Act while determining the ALP."
2. The learned Counsel, Mr. M.P. Lohia, representing the assessee, during the course of hearing, submitted before us that he did not wish to press grounds no.3, 5, 6 & 7. Learned Departmental Representative did not object to the submissions of the assessee. Consequently, these grounds are dismissed as "not pressed".
Lloyds TSB Global Services Pvt. Ltd.
33. Ground no.1, is general in nature, hence, no separate adjudication is required.
4. Grounds no.2 and 4, the assessee has mainly challenged the addition of Rs. 2,67,50,954, on account of adjustment made in arm's length price (for short "ALP") on the value of international transactions.
5. Brief facts of the case are that Lloyds TSB Global Services Pvt. Ltd. (for short "GSL"), incorporated in India in October 2003 and is subsidiary of Lloyds TSB Bank Plc. (for short "LTSB"). It is engaged in providing support services relating to over all management of LTSB's business in India and to overseas off-shore business operation risk and compliance and all necessary relationship in India. The scope of services rendered by the assessee GSL to LTSB has been enumerated in a letter dated 19th August 2005, written by the C.E.O. of the assessee company to the director of LTSB in the following manner:-
"Scope of Services:
3. As per GSLs arrangement with LTSB the overarching function of GsL is to provide support on issues which affect the conduct of business between LTSB and its Indian Outsource Partners. This includes support towards protecting LTSB from any brand risk and providing support to LTSB employees present in India from time to time in relation to the outsourced activities.
4. Specifically, under its arrangement with LTSB, GSL has been requested to provide the following support services to LTSB in relation to the outsourced activities.
UK Seconded Staff Welfare Support Supporting LTSP, employees sent to India in Connection with the outsourced activities on short or long term stays. This includes working with LTSB offshore units to develop templates for tracking staff movements mainly at weekends, and a documented set of local procedures covering staff medical welfare, administration of insurance and immigration matters, and LTSB issued guidelines on staff conduct and repatriation support.
Being the point of contact for the LTSB employees visiting India in connection wt the Outsourced activities if in need of assistance, including In a medical emergency.
Lloyds TSB Global Services Pvt. Ltd.
4Risk and Compliance Management Overseeing the implementation of LTSB'S risk management strategy and encouraging LTSB best practices in risk and compliance management in relation to the outsourced activities at the outsource partners offices / sites in India.
Conduct regular checks / audits, in conjunction with the LTSB International Security Consultant and LTSB business unit risk teams, on the Outsource Partners' business practices In the context of the performance of the outsourced activities and the welfare, health and safety of LTSB employees, if arty, visiting the Outsource Partners work site.
Incident end Crisis Management coordination In the event of a country specific or isolated risk to LTSB employees visiting India the CEO, GSL is responsible for convening and managing the Crisis Management Team, and implementation of the Crisis Management Plan, if deemed appropriate, and and in the manner agreed with LTSB. It is clarified that GSL's responsibilities are restricted to employees of LTSB visiting India and that the Outsource Partners are responsible for Crisis Management within their own businesses.
Corporate Social Responsibility (CSR) GSL is responsible for overseeing the Implementation of LTSB's CSR programme in each of the cities which the Outsource Partners operate. CSR implementation will include identifying suitable projects for LTSB's consideration, and advising LTSB of any potential risks that may arise to the LTSB brand on implementation of the same.
Industry representation In accordance with the directions of and under the express instructions of LTSB, represent LTSB in developing relationships with appropriate industry and government bodies (e.g. NASSCOM, British High Commission) and law enforcement agencies in relation to the outsourced activities In India and to assist the Lloyds 156 Group in its efforts to enhance end protect its reputation in India. Provide support to business units on industry regulation and trends Providing time to time updates regarding developments in the Indian SPO market and with regard to any regulatory or legislative changes in India which could impact the performance of LTSB's contracts with the Outsource Partners.
Liaising with LTSB's lawyers Fox Mandal in India for obtaining the above legal and regulatory updates and assist LTSB at their request Lloyds TSB Global Services Pvt. Ltd.
5and under their instructions, in the co-ordination with Fox Mandal of any legal matters in relation to the outsourced activities.
Supplier Management Support The primary supplier management relationship will be managed by LTSB from the UK. However, GSL will prvde LTSB with certain supplier management support services form time to time at LTSB's request such as seat utilisation audits at the location of the Outsource Provider."
6. For the services so rendered, the assessee was remunerated cost plus 10%. During the financial year 2007-08, the assessee has entered into following international transactions:-
(i) Rendering of support services LTSB - Rs. 14,37,84,205;
(ii) Reimbursement of expenditure - Rs. 5,82,33,539.
7. In relation to rendering of support services, the assessee in its T.P. study report has selected Transactional Net Margin Method (for short "TNMM") as most appropriate method and selected itself as "tested party"
for the purpose of bench marking the international transaction entered into with LTSB. In the said report, the assessee has used multiple year data of 2005-06, 2006-07, 2007-08 and identified thirteen comparables. The Transfer Pricing Officer (for short "TPO") to whom matter was referred by the Assessing Officer under Section 92CA(1) for determining ALP on International Transactions, rejected the assessee's selection for multiple year data on the ground that as per rule 10B, relevant year data should be used. He, therefore, required the assessee to compute Profit Level Indicator (for short "PLI") of the comparables using the F.Y. 2007-08 data. Thereafter, the assessee submitted that out of thirteen comparables selected by it, eight were not comparable due to various factors, which are enumerated in para 9 of TPO's order. The TPO finally rejected the assessee's entire T.P. study report on various grounds which has been discussed at Para-11 of the order.
Lloyds TSB Global Services Pvt. Ltd.6
8. The TPO further required the assessee to conduct fresh search for the comparables using data of F.Y. 2007-08 and in pursuance of which the assessee submitted fresh set of following nine comparable companies having arithmetic mean of 16.10% as against 10.32% shown by the assessee.
Sl.no. Name of Company 'PLI'
1. Access India Advisors Ltd. 45.97%
2. E D C I L (India) Ltd. 5.2%
3. I C R A Management Consulting 3.22%
Services Ltd.
4. I D C (India) Ltd. 14.87%
5. In House Productions Ltd. 0.56%
6. India Tourism Devp. Corpn. Ltd. 9.4%
7. Indus Technical & Financial 13.53%
Consultants Ltd.
8. Inmacs Management Services 49%
Ltd.
9. Overseas Manpower Corp. Ltd. 3.13%
Arithmetic Mean 16.10%
9. The TPO, from the said comparables, however, accepted four comparable companies and rejected the five comparables in the following manner:-
Sl.no. Name of Company Remarks of the TPO
1. Access India Advisors Ltd. Selected in the TP study. Rejected vide letter dated 11th April 2011, selected in the fresh search.
Accepted by the TPO.
2. E D C I L (India) Ltd. EdCIL( India) Limited is offering consultancy services areas of education and human resource development, in India and beyond national boundaries with special focus on developing countries of Lloyds TSB Global Services Pvt. Ltd.
7Asia and Africa. The functional profile of the company is different from the taxpayer.
3. I C R A Management IMaCS is a management consulting Consulting Services Ltd. firm and is engaged in Consulting, Analytics and Transaction Advisory services. The company is functionally different from the assessee.
4. I D C (India) Ltd. Accepted as comparable.
5. In House Productions Ltd. The company is into Medical Business Process Outsourcing business(BPO). The functional profile of the company is different from the taxpayer.
6. India Tourism Devp. The Corporation is running hotels, Corpn. Ltd. restaurants at various places for tourists, besides providing transport facilities, In addition, the company is engaged in production, distribution and sale of tourist publicity literature and providing entertainment and duty free shopping facilities to the tourists.
The functional profile of the company Is different from the taxpayer.
7. Indus Technical & Accepted as comparable Financial Consultants Ltd.
8. Inmacs Management Accepted as comparables Services Ltd.
9. Overseas Manpower OMG is engaged in the business of Corp. Ltd. finding suitable overseas placements for the Indian professionals, skilled workers and others, who are desirous of securing jobs abroad. The functional profile of the company is different from the taxpayer. Therefore, the TPO has rejected it as comparables.
10. Before the TPO, the assessee made detail objections about the functional comparability of the five comparable companies rejected by Lloyds TSB Global Services Pvt. Ltd.
8him, the same has been discussed from Pages-7 to 11 of the TPO, however, The TPO rejected the said contentions of the assessee and after short listing following set of four comparable companies for the purpose of bench marking the international transactions :-
Sl.no. Name of Company PLI (OP/OC) IN %
1. Access India Advisors Ltd. 45.97
2. E D C I L (India) Ltd. 14.87
3. Indus Technical and 13.53
Financial Consultants Ltd.
4. Inmacs Management 49.00
Services Ltd.
Average PLI 30.84
He made the upward adjustment of ALP at Rs.2,67,50,954/-
11. Thereafter, the assessee preferred to file detail objections before the DRP for the inclusion of five comparable companies which has been rejected by the TPO. However, the DRP rejected the assessee's contention and upheld the findings of the TPO. Against such directions, the assessee is in appeal before the Tribunal.
12. Learned Counsel, Mr. M.P.Lohia, after referring to the facts of the case and the nature of services provided by the assessee to its parent company, submitted before us that out of the nine comparable companies, which were finally selected after detail search process as per the direction of the TPO, the four comparable companies having high margin have been cherry picked by the TPO and the five comparable companies having low profit margin has been rejected. He referred to the functional profile and the business description of the comparable companies which are appearing at Pages-68 to 71 of the paper book and submitted that the basis for Lloyds TSB Global Services Pvt. Ltd.
9rejection of 5 comparables by the TPO on the ground that they are functionally different from the assessee are not correct. In support of his contention, he gave detail analysis of each and every five comparables which were rejected by the TPO. Alternatively, he submitted that if the criteria of functional similarity is to be taken into consideration, then none of the 4 comparables selected by the TPO can be said to be similar in nature. The TPO has done cherry-picking of high profit margin companies only and nothing else. He further brought to our notice that in the earlier assessment year i.e., 2007-08, the TPO has accepted the assessee's comparables out of which ICRA Management Consulting Services Ltd. and EDCIL India Ltd., were common. Once these two companies have been held to be comparable in the immediately preceding assessment year, then how the same two companies can be said to be functionally different in the present assessment year. He, therefore, pleaded that rule of consistency should be followed at least for these two companies.
13. Finally, he submitted the business description and functional profile of all the nine companies before us in the form of chart and heavily relied upon the same.
14. Per Contra, the learned Departmental Representative, relying upon the reasoning given by the TPO for rejecting the five comparables analysed the business description and functional profile of each and every comparables rejected by the TPO, vis-à-vis the business activity and functional profile of the assessee company. In the case of 'India Tourism Development Corp.' (ITDC), he submitted that it is a public sector undertaking which is operating in the business of hotel / restaurant operation; duty free shops / duty paid shops operations travel and tour operations; sound and light show (SEL); Ashok Reservation and Marketing Service Division (ARMS); Misc. operations; and construction and consultancy projects. Regarding segmental information about SEL and ARMS which has been taken into account by the assessee for benchmarking, he submitted that this division of ITDC is also functionally Lloyds TSB Global Services Pvt. Ltd.
10different which is evident from the description of the said activities given in Director's report, the relevant portion of which has been given at Pages- 248 and 249 of the paper book. He submitted that this division carries on the functions of handling of events and conferences, promotion and marketing of ITDC hotels and reservation of ITDC hotel by centralized reservation services. Whereas, assessee's scope of activities is entirely different, therefore, the functional test fails in the case of this company even at segmental level with that of the assessee and, hence, it has been rightly rejected by the TPO. He also drew our attention to the Profit & Loss account and the segmental details of ITDC and pointed out that income from services rendered by this company itself is functionally different from that of the assessee.
15. Regarding EDCIL, Educational Consulting India Ltd., he submitted that this company is also a public sector undertaking which is mainly engaged in recruitment of teachers and experts for clients in India and abroad and also focuses on promotion of Indian education at abroad. Even otherwise also, technical assistance and human resources development HRD which has been taken by the assessee as comparable is also different from the business profile of the assessee as these do not come within the purview of business support services. HRD functions are basically related to promotion of Indian education abroad and recruitment of personnel in middle East and African companies. The said company was having projects only for Government. The income from technical assistance is from educational aids and other Govt. projects and its income from HRD are mostly from placement of personnel. This company is, therefore, not comparable with that of the assessee.
16. Regarding ICRA Management Consulting Services, Ld. CITDR submitted that the area of the business activity of this company is risk management strategy, project consulting, transaction advisory policy, regulation and development consultancy. He specifically drew our attention to director's report as appearing in the paper book and drew our specific Lloyds TSB Global Services Pvt. Ltd.
11attention to one of the activities which relates to transportation in urban sectors and involvement in policy formulation, regulatory reform in investment advisory services. Thus, this company, he pleaded, is also functionally different from that of the assessee. He further submitted that even if this company along with EDCIL India Ltd. have been accepted to be comparable in the earlier years, then also it cannot be taken as comparable in this year as once error has been committed in the earlier year, the same should not be allowed to be perpetuated in the next year. For this, he relied on the judgment of the Hon'ble Supreme Court in Distributors (Baroda) Pvt. Ltd. v/s Union of India, [1985] 155 ITR 120 (SC).
17. Regarding Overseas Manpower Corporation Ltd., he submitted that it is a Government of Tamil Nadu Undertaking and basically is a placement company and its main source of income is from recruitment services only. Further, he submitted that this company is also doing air ticketing business. Therefore, this company cannot be taken as a comparable as the functional test completely fails in this case.
18. Regarding Inhouse Production Ltd., he submitted that this company is mainly engaged into knowledge processing outsourcing (KPO) and is entirely different from the functions carried out by the assessee. He further submitted that its main business is healthcare and media division which too are only related to KPO only and is also doing inhouse production. In support of his contention, he referred to the Director's report of the company as appearing in the paper book. Thus, this company, he pleaded, is also entirely different from the assessee and, therefore, the same has been rightly rejected by the TPO for taking into comparability analysis.
19. The learned Counsel for the assessee, in his rejoinder, submitted that one has to see the overall function and cannot see vertically because otherwise no two companies have similar functions. All these companies Lloyds TSB Global Services Pvt. Ltd.
12are into business support services which has a very vide connotation. If the criteria of rejection as have been canvassed by the learned Departmental Representative and by the TPO, then even the four comparables selected by the TPO are also functionally different. Just because the four companies have very high profit margin, therefore, they cannot be held to be functionally same and other companies which have a lower profit margin can be held to be functionally different. He, therefore, submitted that such cherry picking by the TPO is uncalled for. Regarding objection of the companies by the learned Departmental Representative that they are Public Sector Undertakings he submitted that the same does not have any bearing on the operating margin. In support of this contentions, he relied upon the decision of the ITAT, Pune Bench, in the case of Vishay Components India P. Ltd. v/s DCIT, ITA no.133/Pn./2011. For the proposition that one has to go by the horizontal set of comparables of particular kind and class of services because it is very difficult to get accurate comparables having exact functional profiles. He placed heavy reliance on the decision of the ITAT, Delhi Bench, in the case of Actis Advisors P. Ltd. v/s DCIT, ITA no.5277/Del./2011.
20. We have carefully considered the rival contentions of the parties, perused material placed on record and the impugned orders. The limited issue that is required to be adjudicated is whether the five comparable companies which has been rejected by the TPO on the ground that they are functionally different from the assessee can be included for comparability analysis for benchmarking the ALP of the assessee company. Insofar as the application of TNNM is concerned for bench marking the international transaction for determining the ALP, there is no dispute. For carrying out comparability analysis, comparison of controlled transactions with an uncontrolled transaction has to be seen whether they are comparable having regard to the characteristic of the property and service transferred, functions performed taking into assets used and risk assumed Lloyds TSB Global Services Pvt. Ltd.
13and other economic circumstances. While carrying out the comparability analysis one has to see economically significant activities and the responsibility taken by the unrelated parties in relation to the tested party. In this case, after detail search process and using various filtrations, nine comparable companies were short listed by the assessee as per the direction of the TPO. Out of such nine companies, four of them have been accepted by the TPO, prima-facie, which were having high PLI (Profit Level Indicator). He has rejected the other five companies mainly on the ground that they were functionally different without giving any reasons as to how the other four companies which has been accepted by him are functionally similar to that of the assessee's business activities. Be that as it may be, the four companies viz.; (i) Access India Advisors Ltd.; (ii) IDC India Ltd.;
(iii) Indus Technical and Financial Consultants Ltd. and (iv) Inmacs management Services Ltd., both the parties have accepted to be a fit comparable cases. Now we have to see whether other five comparables are to be included in the comparability analysis or not. The business activities carried out by the assessee has been discussed in detail in the forgoing paragraphs which are mostly in the nature of business support services and liaisoning.
21. In the case of ITDC Ltd., it is seen that this company is mainly engaged in the business of running of hotel and restaurants at various tourist places besides providing transport facilities. Its main business activities revolve around promotion of tourism in India. Even going by the segmental data of reservation, marketing service and event management as adopted by the assessee for comparison, it is seen that these functions are entirely different from that of the activities of the assessee company. Under the ARMS division i.e., reservation and marketing services, this company is mainly handling event and conferences, promotion and marketing of ITDC hotels and reservations. The SEL i.e. sound and light activities carried on by this company are also different. The segmental details and also income from such service goes to show that income from Lloyds TSB Global Services Pvt. Ltd.
14services rendered have been classified into several categories which are entirely different from each other. The contentions raised by the learned Departmental Representative that the functional profile of the company is entirely different from the activities carried on by the assessee appears to be acceptable. Therefore, in our opinion, going by the functional profile as available on record before us, this company has rightly been rejected by the TPO and cannot be included as a comparable entity even at a segmental level for conducting any comparability analysis. Accordingly the assessee's contention for including the said company is rejected.
22. Now, coming to the EDCIL and ICRA Management Consulting Services, we find that these companies were accepted as a comparable by the TPO in the immediately preceding assessment year 2007-08 and there was no dispute among the parties in that year for taking them as a comparable company. Moreover, going by the functional profile specifically that of ICRA Management Consultant Services, prima-facie, it is seen that it is also engaged in the business support services like strategy risk management, process consulting, transaction advisory policy and regulation and development consulting. These functions are, by and large, similar to the assessee's activities also. Therefore, this company on merits also is includable in the set of companies. In the case of EDCIL, though main activities are functionally different, however, its technical assistance segment can be broadly considered to be functionally similar to the assessee. Since this company has been accepted as a comparable by the Department as well as by the assessee, therefore, following the rule of consistency, we hold that this company should also be included as comparable. We also find merits in the contentions of the Ld. Counsel that in the earlier year once these two companies have been found to be functionally similar, then in this year they cannot be rejected on functional analysis. Thus, both the aforesaid companies i.e. ICRA Management and EDCIL are directed to be included as comparable for the purpose of Lloyds TSB Global Services Pvt. Ltd.
15comparability analysis for determining the ALP of the international transactions of the assessee company.
23. Regarding Overseas Manpower Corp. Ltd., it is seen that it is purely recruitment and placement company and its main revenue is from recruitment services only. Thus, not only the functional profile, the other test of comparability analysis also fails in this case. Therefore, we fully agree with the contention of the Ld. CITDR that this company has rightly been rejected by the TPO for the purpose of comparability analysis and is to be excluded.
24. Lastly, in the case of Inhouse Productions Ltd., it is seen that this company is mainly engaged in the business of Knowledge Process Outsourcing (KPO) in the field of healthcare and is also engaged in media. The functions and the business activities of this company as seen from the records is not comparable to that of the business activities carried on by the assessee and the functional profile is also different. Therefore, this company has rightly been rejected by the TPO.
25. Thus, in our view, besides four companies, accepted both by the TPO as well as by the assessee, two more companies should also be included namely EDCIL and ICRA Management Services for the purpose of comparability analysis for determining the ALP. The balance three companies are to be excluded. The TPO is directed to work out the arithmetic mean for the finally selected six companies and determine the ALP. Accordingly, grounds no.2 and 4, are partly allowed.
26. In ground no.9, the assessee is aggrieved by the failure of the Assessing Officer to grant credit for advance tax of Rs. 64,07,100.
27. After hearing both the parties and going through the record, we direct the Assessing Officer to give credit of the advance tax paid after verifying it from AS26 or as per the challan. Accordingly, ground no.9, is treated as allowed subject to verification by the Assessing Officer.
Lloyds TSB Global Services Pvt. Ltd.
1628. पǐरणामतः िनधा[ǐरती कȧ अपील आंिशक ःवीकृ त कȧ जाती है ।
28. In the result, assessee's appeal is partly allowed.
आदे श कȧ धोषणा खुले Ûयायालय मɅ Ǒदनांकः 21/11/2012 को कȧ गई । Order pronounced in the open Court on 21/11/2012 Sd Sd/- Sd/-
बी.
बी. रामकोटáय
रामकोटáय अिमत शुÈला
लेखा सदःय Ûयाियक सदःय
B. RAMAKOTAIAH AMIT SHUKLA
ACCOUNTANT MEMBER JUDICIAL MEMBER
मुंबई MUMBAI, Ǒदनांक DATED: 21/11/2012
आदे श कȧ ूितिलǒप अमेǒषत / Copy of the order forwarded to:
(1) िनधा[ǐरती / The Assessee;
(2) राजःव / The Revenue;
(3) आयकर आयुƠ(अपील) / The CIT(A);
(4) आयकर आयुƠ / The CIT, Mumbai City concerned; (5) ǒवभागीय ूितिनिध, आयकर अपीलीय अिधकरण, मुंबई / The DR, ITAT, Mumbai; (6) गाड[ फाईल / Guard file.
स×याǒपत ूित / True Copy आदे शानुसार / By Order ूदȣप जे. चौधरȣ / Pradeep J. Chowdhury वǐरƵ िनजी सिचव / Sr. Private Secretary उप / सहायक पंजीकार / (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, मुंबई / ITAT, Mumbai