INCOME TAX OFFICER, WARD - 3, HYDERABAD vs. SRI INDRA POWER ENERGIES LIMITED, HYDERABAD

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ITA 1353/HYD/2025Status: DisposedITAT Hyderabad29 July 2026AY 2017-1819 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s deletion of additions for unexplained cash deposits (Section 69) and cash credit (Section 68) after considering documentary evidence. However, the disallowance of expenditure was restricted.

What were the facts?

The Revenue appealed the CIT(A)'s order which deleted additions made by the AO for unexplained cash deposits and cash credit. The AO had disallowed a portion of 'Other expenses' due to lack of bills/vouchers.

What were the issues?

Whether the CIT(A) erred in admitting additional evidence and deleting additions without proper verification, and if the disallowance of expenses was justified without supporting evidence.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 69,Section 68,Section 46A(3),Section 250(4),Section 188

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘B’ Bench, Hyderabad

Before: Shri Manjunatha G. & Shri Ravish Sood

Hearing: 18/06/2026

आयकर अपीलीय अिधकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad Before Shri Manjunatha G., Accountant Member and Shri Ravish Sood, Judicial Member आ.अपी.सं /ITA No.1353/Hyd/2025 (िनधा�रण वष�/Assessment Year:2017-18) Income Tax Officer, Vs. Sri Indra Power Energies Ward-3, Limited, Hyderabad Hyderabad. PAN: AAFCS6524H (Appellant) (Respondent) िनधा��रती �ारा/Assessee by: Shri Sashank Dundu, Advocate राज� व �ारा/Revenue by: Shri K Prasad, Sr-AR सुनवाई की तारीख/Date of Hearing: 18/06/2026 घोषणा की तारीख/Date of 29/07/2026 Pronouncement: आदेश / ORDER PER RAVISH SOOD, J.M: The present appeal filed by the Revenue is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (for short, “CIT(A)”), dated 17/06/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 143(3) of the Income Tax Act, 1961 (for short, “the Act”), dated 22/12/2019. The Revenue has assailed the impugned order of the CIT(A) on the following grounds of appeal:

2 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited “1. The order of the Ld. CIT(A) is erroneous both on facts and in law. 2. The Ld. CIT(A) erred in admitting additional evidence/submissions from the assessee during the appellate proceedings-pertaining to the unexplained cash credit and unexplained cash deposits-without affording an opportunity to the Assessing Officer to examine the same, in contravention of Rule 46A(3) of the Income-tax Rules, 1962. 3. The Ld. CIT(A) erred in deleting the addition of Rs 65,00,000/- made under section 69 of the Act on account of unexplained cash deposits during the demonetisation period, solely on the basis of submissions made during appellate proceedings and without independent verification or calling for a remand report from the Assessing Officer. 4. The Ld. CIT(A) erred in deleting the addition of Rs 15,57,342/- made under section 68 of the Income-tax Act, 1961, without proper verification of the identity, creditworthiness, and genuineness of the transaction relating to cash credit received from M/s Chitturi Projects Pvt. Ltd. 5. The Ld. CIT(A) erred in deleting the disallowance of expenses amounting to Rs 14,49,521/- (out of the total disallowance of Rs 48,31,739/- under 'Other Expenses'), without proper supporting evidence viz., bills/vouchers being furnished by the assessee and without calling for any remand report from the Assessing Officer to verify the claim. 6. The appellant craves leave to add, amend, alter, or withdraw any of the above grounds at the time of hearing.”

2.

Succinctly stated, the assessee company, which is engaged in the business of generation and transmission of electricity on a commercial basis from a Bio Mass Power Plant, had filed its return of income for AY 2017-18 on 31/10/2017, declaring a loss of Rs.1,38,31,750/-. Subsequently, the case of the assessee company was selected for scrutiny assessment under “CASS”, and a notice under section 143(2) of the Act was issued and served upon it.

3 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited 3. During the course of the assessment proceedings, the AO called upon the assessee company to furnish details of “Other expenses” of Rs.1,84,56,747/- along with copies of the ledger extracts and bills/vouchers for necessary verification. However, as the assessee company failed to furnish the bills/vouchers and the copies of the ledger extracts as directed by the AO, the latter disallowed 30% of the expenditure of Rs.1,84,56,747/- and made an addition/disallowance of Rs.55,37,024/-.

4.

The AO further observed that the assessee company during the demonetization period, i.e., 09/11/2016 to 31/12/2016, had made cash deposits of Rs. 65 lakhs in its account No.1320132000000013 held with The Karur Vysya Bank Ltd, Gangavathi, Karnataka. As the assessee company failed to come forth with any explanation which would reveal that the subject cash deposits were either sourced out of the opening cash balance as on 09/11/2016 or out of cash collections made during the demonetization period or the cash withdrawals made from the bank account, the AO made an addition of the entire amount of Rs.65 lakhs under Section 69 of the Act.

5.

Also, the AO observed that during the subject year, the non- current liabilities of the assessee company, i.e., long-term borrowings, had increased from Rs.2,46,84,278/- to Rs.5,14,42,036/-. The assessee

4 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited company, upon being queried regarding the aforesaid issue, submitted details of borrowings during the assessment proceedings. The AO, upon perusal of the record and the details filed by the assessee company, observed that the assessee company, during the subject year, had, inter alia, received a sum of Rs. 15,57,342/- from M/s Chitturi Projects P. Ltd. However, as the assessee company failed to furnish the requisite details which would substantiate the identity and creditworthiness of the aforesaid lender, the AO, being of the view that the onus cast upon the assessee company to substantiate the authenticity of the subject transaction had not been discharged, held the said amount as an unexplained cash credit under section 68 of the Act.

6.

The AO based on his aforesaid deliberations vide his order passed under section 143(3) of the Act, dated 21/12/2017 after making the aforementioned additions/disallowance determined the loss of the assessee company at Rs. 82,94,726/-, and at the same time made separate additions, viz., (i) unexplained cash deposits made in the bank account during the demonetization period under section 69 of the Act: Rs.65 lakhs; and (ii) unexplained cash credit under section 68 of the Act: Rs.15,57,342/-.

7.

Aggrieved, the assessee company carried the matter in appeal before the CIT(A), who vide his letter dated 20/01/2022 directed the

5 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited assessee company to produce before him, viz. (i). evidences in respect of disallowance of expenses; and (ii). copy of bank account statement in respect of cash credit during demonetization; and (iii). copy of confirmation letter in respect of unsecured loan addition. Thereafter, the CIT(A) found favor with the contentions advanced by the assessee company and allowed the appeal.

8.

The Revenue, being aggrieved with the order of the CIT(A), has carried the matter in appeal before us.

9.

We have heard the Learned Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record.

10.

Shri K Prasad, Learned Senior Departmental Representative (for short, “Ld. Sr-DR”), at the threshold of hearing of the appeal submitted that the CIT(A) had on the basis of certain additional evidences which were admittedly filed in the course of the hearing of the appeal before him grossly erred in law and facts of the case in vacating two additions made by the AO, viz., (i) addition of the amount claimed by the assessee company to have been received from M/s. Chitturi Projects P. Ltd: Rs.15,57,342/-; and (ii) part disallowance of expenditure in the absence of relevant details/evidences of the expenditure claimed by the assessee company: Rs.55,37,024/-. Elaborating on his contention, the Ld. DR

6 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited submitted that the assessee company during the assessment proceedings despite having been specifically directed to produce copy of the ledger extracts and bills/vouchers for verification of the “Other expenses” of Rs.1,84,56,747/-, failed to furnish the same, as a result whereof the AO was constrained to disallow 30% of the subject expenditure, which, thus, had resulted to a disallowance of Rs.55,37,024/- in the hands of the assessee company. Elaborating further on his contention, the Ld. DR submitted that the assessee company had, in the course of the proceedings before the CIT(A), produced the bank statement and ledger extracts to support his aforesaid claim for deduction of the “Other expenses” of Rs. 55.37 lakhs (approx.) that was disallowed by the AO while framing the assessment. Also, the Ld. DR submitted that, though the assessee company, in the course of the assessment proceedings, failed to place on record supporting documentary evidence to substantiate the transaction of receipt from M/s. Chitturi Projects P. Ltd. a sum of Rs. 15,57,341/-, which, thus, had resulted in treating the same as an unexplained cash credit in its hands under section 68 of the Act, but had thereafter filed before the CIT(A) the confirmation letter of the aforementioned lender as additional evidence. The Ld. AR, to buttress his contention that the assessee had filed before the CIT(A) the aforesaid additional documentary evidence, drew our attention to Column Nos. 12 and 12.1

7 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited of the Memorandum of Appeal in “Form-35” filed before the CIT(A), wherein the assessee company/appellant had categorically admitted of having furnished additional evidence under Rule-46A of the Income tax Rules, 1962. Apart from that, the Ld. DR submitted that as the assessee company had failed to come forth with any irrefutable explanation regarding the source of the cash deposit of Rs. 65 lakh during the demonetization period, the AO had rightly made an addition of the entire amount under Section 69 of the Act.

11.

Per contra, Shri Sashank Dundu, Advocate, Ld. Authorized Representative (for short, “AR”) appearing for the assessee respondent supported the order of the CIT(A). It was submitted that each of the additions made by the AO was based on surmises and conjectures and was not supported by any cogent material. It was further submitted that the CIT(A), after a detailed appreciation of the documentary evidence that was called for by him in exercise of powers vested with him under Section 250(4) of the Act r.w. Rule 46A(4) of the Income tax Rules, 1962, and was placed on his record, had rightly deleted the impugned additions and granted appropriate relief. The Ld. AR submitted that as the appeal filed by the Revenue was devoid and bereft of any substance, the same be dismissed.

8 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited 12. We have heard the Ld. Authorized Representatives of both parties, perused the orders of the authorities below and the material available on record, as well as considered the judicial pronouncements pressed into service by them.

13.

We shall first advert to the Ld. DR’s grievance relating to the relief granted by the CIT(A) based on the additional documentary evidence that was allegedly considered by him in violation of Rule 46A. In our view, the said grievance of the revenue is misconceived. We say so, for the reason that as brought to our notice by the Ld. AR, the CIT(A) had, in the course of the appellate proceedings, vide his letter dated 20/01/2022, directed the assessee company to produce before him, viz. (i) evidence in respect of disallowance of expenses; (ii) copy of bank account statement in respect of cash credit during demonetization; and (iii). copy of confirmation letter in respect of unsecured loan addition, Page 110 of APB. As per Section 250(4) r.w Rule 46A(4) of the Income tax Rules, 1962, the CIT(A), in the course of hearing of the appeal, is vested with the power to direct the assessee to produce documents which he is of the view are required for adjudicating the issues involved in the appeal. In our view, the documents produced by an assessee pursuant to a specific direction by the CIT(A) cannot be brought within the strict meaning of additional evidence under Rule 46A(1). Such

9 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited documents are brought on record because the appellate authority considers them necessary for fair adjudication under Section 250(4) r.w Rule 46A(4). In our view, unlike Rule 46A, which governs cases where the assessee invokes the Rule, Rule 46A(4) preserves the independent powers of the CIT(A) to call for documents, and, thus, both operate in their respective independent fields. We, thus, are of firm conviction that as in the present case the CIT(A) had vide his letter dated 20/01/2022 (supra) on a suo motto basis, without being prompted by the assessee, while dealing with the appeal, considered it fit to make a further enquiry by virtue of the powers vested with him under sub-section (4) of Section 250, and had called for the production of the aforesaid documents, viz. (i). evidence in respect of disallowance of expenses; (ii). copy of bank account statement in respect of cash credit during demonetization; and (iii). copy of confirmation letter in respect of unsecured loan addition, the requirements of Rule 46A were not required to be followed. We thus find no infirmity in the calling for and considering of the aforesaid documents by the CIT(A), and, thus, reject the aforesaid contention of the Ld. DR.

14.

We shall now deal with the ad hoc disallowance of part of the expenditure booked by the assessee company under the head “Other expenses” in its profit & loss account.

10 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited 15. Ostensibly, the record reveals that the AO noticed that the assessee company had debited aggregate expenditure of Rs.1,84,56,747/- under the head “Other expenses” to its Profit & Loss Account. The AO held certain reservations regarding the allowability of the said expenditure, but without identifying any specific item as being non-genuine or inadmissible, proceeded to disallow 30% thereof on an ad hoc basis, resulting in a disallowance of Rs.55,37,024/-. As observed hereinabove, the assessee company, pursuant to the directions of the CIT(A), had, inter alia, produced before him copies of the ledger accounts of the expenses that were booked by him under the head “Other expense” aggregating to Rs. 1,84,56,747/-.

16.

We find that a careful examination of the material available on record reveals that the aggregate expenditure of Rs.1,84,56,747/- included an amount of Rs.1,36,25,008/- debited under the head “Aroma Biotech – Write-off”. As is discernible from the documentary material placed before us, the assessee company itself had voluntarily disallowed the said amount while computing its taxable income, Page 36 to 50 of APB. Once the assessee company had suo motu excluded the aforesaid expenditure from its claim of deduction, the same could not have again formed part of the expenditure base on which the AO proceeded to estimate the disallowance. Accordingly, once the amount of

11 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited Rs.1,36,25,008/- representing “Aroma Biotech – Write-off” is excluded, the expenditure that survives for consideration works out to Rs. 48,31,739/-. It is further borne out from the record that the aforesaid amount includes a donation of Rs. 94,492/-, which, by its very nature, is not allowable as a deduction while computing the business income of the assessee company. Consequently, the expenditure that could legitimately form the basis of any estimation is confined to Rs. 47,37,247/-.

17.

At this stage, it would be relevant to examine the foundation on which the AO proceeded to estimate the disallowance at 30%. We find that the assessment order does not reveal that the books of account maintained by the assessee company were rejected. In our view, the adoption of a flat rate of 30% remains unsupported by any discernible rationale.

18.

We are of firm conviction that although an estimate may, in appropriate circumstances, be resorted to by the AO, but such estimate cannot rest upon mere suspicion or conjecture. It must have a reasonable nexus with the facts emerging from the record and be founded upon objective considerations. An ad hoc disallowance made without identifying any specific defect in the books of account cannot

12 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited ordinarily be sustained merely because the AO entertains a general doubt regarding the claim of expenditure.

19.

In the facts of the present case, we find that while the approach adopted by the AO in making a blanket disallowance of 30% cannot be approved, at the same time, the nature of certain expenses and the overall factual backdrop justify a reasonable estimate to safeguard the interests of the Revenue. Considering the entirety of the facts and circumstances, we are of the considered view that restricting the disallowance to 10% of the eligible expenditure of Rs. 47,37,247/- would adequately meet the ends of justice.

20.

Accordingly, the disallowance on an estimated basis is restricted to Rs.4,73,725/- (being 10% of Rs.47,37,247/-). Further, the amount of donation of Rs.94,492/-, which is admittedly not allowable as a business deduction, shall stand separately disallowed. Consequently, the total disallowance sustained by us works out to Rs.5,68,217/-. Accordingly, the AO is directed to recompute the income in the backdrop of our aforesaid observations.

21.

We shall now advert to the next issue relating to the deletion of the addition made by the AO under Section 69 of the Act in respect of cash deposits made during the demonetization period.

13 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited

22.

As is discernible from the assessment order, the assessee company had deposited cash aggregating to Rs.65,00,000/- in its bank account maintained with Karur Vysya Bank during the demonetization period. The AO was not satisfied with the explanation furnished by the assessee company regarding the source of the said deposits and, treating the explanation as unacceptable, brought the amount to tax under Section 69 of the Act.

23.

Before the CIT(A), and again before us, the consistent explanation of the assessee company has been that the cash deposited during the demonetization period represented cash that had been withdrawn earlier from the very same bank account in several tranches immediately preceding the announcement of demonetization. The Ld. AR, to buttress the aforesaid factual position, placed reliance upon the relevant bank statement to establish the movement of funds.

24.

We have thoughtfully considered the contentions advanced by the Ld. Authorized Representatives of both parties and carefully examined the documentary evidence placed on record. We find on a perusal of the bank statement that prior to the cash deposits of Rs.65,00,000/- made on 14.11.2016, the assessee company had withdrawn cash aggregating to Rs.72,00,000/- from the very same bank account in eight separate

14 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited tranches during the period from 05.11.2016 to 08.11.2016. The factum of such withdrawals is not in dispute. The assessee's explanation that the cash deposited on 14.11.2016 represented a part of the cash withdrawn immediately prior to demonetization finds substantial support from the banking records. Rather, we find that the AO has not brought any material on record to demonstrate that the cash withdrawn had been utilized for any other purpose or had ceased to remain available with the assessee company as on the date of redeposit. In the absence of any such material, the explanation furnished by the assessee company cannot be discarded merely on the basis of suspicion.

25.

In our view, it is a settled principle that where an assessee establishes, on the strength of documentary evidence, a direct nexus between earlier cash withdrawals and subsequent cash deposits, the burden shifts upon the Revenue to dislodge such explanation by bringing cogent material on record. Also, a mere disbelief or suspicion, however strong, cannot take the place of proof. Accordingly, an addition under Section 69 cannot be sustained in the absence of material establishing that the explanation offered by the assessee is inherently improbable or demonstrably false.

26.

In the present case, the Revenue has not pointed out any discrepancy in the bank statements, nor has it brought any material to

15 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited establish that the cash withdrawn during the period from 05.11.2016 to 08.11.2016 was either spent or otherwise unavailable for redeposit on 14.11.2016. The explanation of the assessee, therefore, remains uncontroverted by any objective evidence. Apart from that, we are unable to comprehend that now when the subject bank account No.1320132000000013 held by the assessee company with Karur Vysya Bank forms part of its books of account, then, on what basis without rejecting its books of account the AO could have drawn adverse inferences regarding the duly accounted source of the subject cash deposits in the said bank account. At this stage, it would be apposite to observe that not only the AO while framing the assessment had failed to reject the books of account of the assessee company, but on the contrary has determined the assessed income based on the loss returned by the assessee company, which, thus, reveals that he had completely accepted the source of the subject cash deposits accounted by the assessee company in its books of account.

27.

In view of the aforesaid factual position, we find no infirmity in the conclusion arrived at by the CIT(A) in deleting the addition made under Section 69 of the Act. We, therefore, uphold the order of the CIT(A) on the subject issue.

16 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited 28. We shall now deal with the last issue relating to the deletion of the addition made under Section 68 of the Act in respect of the unsecured loan received by the assessee company from M/s Chitturi Projects Private Limited.

29.

As is discernible from the assessment order, we find that the AO has treated the amount of Rs.15,57,344/- received by the assessee company from M/s Chitturi Projects Private Limited as an unexplained cash credit under Section 68 of the Act. The primary reason assigned by the AO was that the assessee company had not furnished a confirmation of account from the creditor during the assessment proceedings.

30.

As observed hereinabove, the assessee company, pursuant to the directions of the CIT(A) vide his letter dated 20/01/2022, inter alia, produced before him the confirmation of the lender, viz. M/s Chitturi Projects Private Limited, the relevant ledger extracts, the bank statements evidencing the movement of funds through normal banking channels, and the audited financial statements disclosing the transaction as a related-party transaction. It was also explained that the subject amount was received from the said associate company after compliance with the provisions of Section 188 of the Companies Act, 2013, and was disclosed in the financial statements in accordance with AS 18.

17 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited 31. We have given our thoughtful consideration to the contentions advanced by the Ld. Authorized Representatives of both parties and perused the material available on record. The addition under Section 68 has its genesis in the absence of a confirmation of account before the AO. As observed by us hereinabove, the CIT(A) had, vide his letter dated 20/01/2022, in exercise of the powers vested with him under Section 250(4) r.w Rule 46A(4), inter alia, directed the assessee company to place on record a copy of the confirmation letter of the subject unsecured loan that it had received during the year under consideration. In compliance, the assessee company furnished the confirmation of the lender, viz. M/s Chitturi Projects Private Limited before him, Page 103 of APB. In our view, as the lender had vide his letter both confirmed the loan advanced to the assessee company through Cheque/bank transfer during the year under consideration, as well as the fact that an amount of Rs. 15,57,342/- was outstanding from the assessee company on 31/03/2017, therefore, the CIT(A) has rightly vacated the addition made by the AO who had recharacterised the amount received as an unexplained cash credit under Section 68 of the Act. We further find that the subject transaction was routed entirely through normal banking channels and stood disclosed as a related-party transaction in the audited financial statements of the assessee company. As observed by the CIT(A), the transaction was entered into after complying with the

18 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited requirements of Section 188 of the Companies Act, 2013, and was disclosed in the financial statements as per AS 18, which lends substantial credence to the genuineness of the transaction.

32.

It is also pertinent to observe that no material has been brought on record to indicate that the lender (an associate entity) was non- existent, that the funds had emanated from the assessee company itself, or that the banking transaction was a mere accommodation entry, and the addition has been sustained primarily on account of the absence of a confirmation during the assessment proceedings, without any further investigation into the surrounding facts.

33.

In our considered view, the cumulative effect of the documentary evidence placed on record, namely, the banking trail, the confirmation filed before the CIT(A) (as per his directions), the statutory disclosure of the transaction as a related-party transaction in the audited financial statements, the compliance with Section 188 of the Companies Act, 2013, sufficiently establishes the genuineness of the impugned transaction. In these circumstances, we find no justification to interfere with the well-reasoned finding recorded by the CIT(A) deleting the addition made under Section 68 of the Act. We, therefore, uphold the order of the CIT(A) deleting the addition of Rs. 15,57,342/- made by the AO under Section 68 of the Act.

19 ITA No.1353/Hyd/2025 ITO vs. Sri Indra Power Energies Limited

34.

In the result, the appeal filed by the Revenue is partly allowed inasmuch as the disallowance of expenditure is restricted to Rs.5,68,217/- in terms of our observations hereinabove, while the order of the CIT(A) deleting the additions made under Sections 69 and 68 of the Act is upheld.

Order pronounced in the open court on this 29th day of July, 2026.

Sd/- Sd/- (MANJUNATHA G.) (RAVISH SOOD) ACCOUNTANT MEMBER JUDICIAL MEMBER Hyderabad, Dated 29th July,2026. *OKK / SPS Copy to: S.No Addresses 1 Sri Indra Power Energies Limited Η. Νο. 8-2-120/110/115 G-1 Vijaya Residency Road No. 14 Banjara Hills Hyderabad 5000344, Hyderabad, Telangana-500034. 2 Income Tax Officer, Ward-3, Hyderabad 7th Floor Signature Towers Kothaguda Kondapur Hyderabad, Hyderabad, Telangana-500084 3 The Pr.CIT, Hyderabad 4 The DR, ITAT Hyderabad Benches 5 Guard File By Order 83d21a35-1e2e-44e4- Digitally signed by 83d21a35-1e2e-44e4- b81c-9caf0129bd05 b81c-9caf0129bd05 Date: 2026.07.30 10:54:07 +05'30' Sr. Private Secretary, ITAT, Hyderabad.

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