GOODRICH AEROSPACE SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU

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ITTPA 428/BANG/2023Status: DisposedITAT Bangalore11 September 2025AY 2011-1213 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the final assessment order passed by the AO on 29/03/2023 is barred by limitation as per Section 144C(13) of the Act. The Tribunal relied on the principles laid down by the Hon'ble Bombay High Court in Vodafone Idea Ltd. vs. CPC and the Hon'ble Telangana High Court in Rapiscan Systems Pvt. Ltd. vs. ADIT, which emphasize that procedural defects or delays in adhering to the timelines prescribed under Section 144C can vitiate the entire proceeding and defeat the object of providing an alternate dispute resolution mechanism. The Tribunal noted that the DRP's directions were received by the AO on 27/02/2023, and the FAO was passed on 29/03/2023. The Tribunal found that the FAO was not passed within the stipulated period. Consequently, the Tribunal set aside the final assessment order on this legal ground alone. The other grounds raised by the assessee on merits were not adjudicated in view of the order passed on the legal plea, and it was left open to the assessee to raise them at the appropriate time if required.

What were the facts?

The assessee, M/s. Goodrich Aerospace Services Pvt. Ltd., filed an appeal against the final assessment order (FAO) dated 29/03/2023 passed by the Assessing Officer (AO) for Assessment Year 2011-12. The dispute primarily concerns a transfer pricing adjustment. An earlier assessment order dated 28/12/2015 had made a TP adjustment of INR 9,12,40,797. This was later reduced to INR 6,72,93,994 by an order u/s 154. The Tribunal, in an earlier order dated 24/04/2019, set aside the order and directed the TPO to re-examine the adjustment. The TPO then made an adjustment of INR 5,53,59,850 in the engineering design services segment. The DRP rejected the assessee's objections. The AO passed the FAO on 29/03/2023 pursuant to DRP directions received on 27/02/2023. The assessee's appeal challenges the FAO on grounds of limitation and the transfer pricing adjustment.

What were the issues?

1. Whether the final assessment order passed by the Assessing Officer is barred by limitation under Section 144C(13) of the Income Tax Act, 1961? - Assessee's Contention: The FAO passed on 29/03/2023 is barred by limitation as it was not issued within 30 days from the end of the month in which the DRP's directions were issued, as prescribed by Section 144C(13). - Revenue's Contention: Not recorded in the judgment. 2. Whether the transfer pricing adjustment of INR 5,53,59,850 made by the AO/TPO/DRP for international transactions is correct? - Assessee's Contention: The AO/TPO/DRP erred in determining the adjustment. Specifically, they erred in including certain companies as comparables (Holtec Consulting Pvt Ltd, SS Infrastructure Development Consultants Ltd, Mahindra Consulting Engineers Ltd., Tata Consulting Engineers Ltd, Korus Engineering Solutions Pvt. Ltd., H S C C (India) Ltd., Feedback Infra Pvt. Ltd.), rejecting the assessee's TP documentation, modifying filters applied by the assessee, applying different financial year ending filters, applying a service income filter of 75%, rejecting companies with a ratio of employee cost to sales less than 25%, adopting an erroneous approach for the Related Party Transactions filter, holding that current year data should be used, and rejecting claims for working capital differential and risk difference. - Revenue's Contention: Not recorded in the judgment.

Which sections of the Income-tax Act were involved?

Section 144C,Section 144C(13),Section 92CA,Section 92C(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI, VICE – & SHRI SOUNDARARAJAN K.

For Appellant: Shri K.R. Vasudevan, Advocate
For Respondent: Smt. Suganthamala T M, CIT-DR

IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE

BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER

IT(TP)A No. 428/Bang/2023 Assessment Year : 2011-12

M/s. Goodrich Aerospace Services Pvt. Ltd., 14/1 and 15/1, Maruthi The Deputy Industrial Estate, Commissioner of Phase 2, Hoody Village, Income Tax, Whitefield Road, Circle – 3(1)(1), KR Puram, Bengaluru. Vs. Bengaluru – 560 048. PAN: AAACB8857H APPELLANT RESPONDENT

Assessee by : Shri K.R. Vasudevan, Advocate Revenue by : Smt. Suganthamala T M, CIT-DR

Date of Hearing : 17-06-2025 Date of Pronouncement : 11-09-2025

ORDER PER SOUNDARARAJAN K., JUDICIAL MEMBER

This is an appeal filed by the assessee challenging the final assessment order of the AO dated 29/03/2023 and raised the following grounds: “The grounds hereinafter taken by the Appellant are without prejudice to one another. I. Grounds on Invalid order issued by the Assessing Officer ("AO")

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1.

The final assessment order ("FAO") passed by the learned Assessing Officer ("AO-) is bad in law and is liable to be quashed for the reason that the same is barred by limitation. 2. The FAO passed by the learned AO is bad in law and liable to be quashed for the reason that it is not line with the statutory procedure prescribed in sections 144C(13) of the Act, wherein the FAO ought to be issued within the prescribed timelines as per the Income Tax Act 1961 ("the Act"). 3. The learned AO had issued the FAO beyond the prescribed due date as per the Act without giving cognizance to the communication made by the Transfer Pricing Officer ("TPO") to the jurisdictional AO dated 20 December 2022. II. Transfer Pricing The grounds mentioned hereinafter are without prejudice to one another. 4. The Learned AO, Learned TPO and Hon'ble Dispute Resolution Panel ("Hon'ble DRP") grossly erred in determining an adjustment of INR 5,53,59,850/- for the international transactions of the Appellant u/s 92CA of the Act. 5. The Learned AO/ Learned TPO/ Hon'ble DRP erred in including the following companies, as comparable, which did not satisfy the test of comparability: 5.1. Holtec Consulting Pvt Ltd 5.2. SS Infrastructure Development Consultants Ltd 5.3. Mahindra Consulting Engineers Ltd. 5.4. Tata Consulting Engineers Ltd 5.5. Korus Engineering Solutions Pvt. Ltd. 5.6. H S C C (India) Ltd. 5.7. Feedback Infra Pvt. Ltd. 6. The Learned AO/ Learned TPO/ Hon'ble DRP erred in rejecting the TP documentation maintained by the Appellant by invoking provisions of sub-section (3) of 92C of the Act. 7. The learned AO / learned TPO/ Hon'ble DRP erred in rejection/ modification of filters applied by the Appellant while undertaking comparability analysis and in conducting a fresh comparability analysis by applying additional filters for determination of the arm's length price

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for international transactions pertaining to contract engineering design services rendered by the Appellant. 8. The Learned AO/ Learned TPO/ Hon'ble DRP erred in applying different financial year ending filter while selecting the comparable companies. 9. The Learned AO/Learned TPO/Hon'ble DRP erred in applying the service income filter of 75% to sales, leading to a narrower comparable set. 10. The Learned AO/Learned TPO/Hon'ble DRP erred in rejecting companies having ratio of employee cost to sales of less than 25%. 11. The Learned AO/ Learned TPO/ Hon'ble DRP adopted an erroneous approach of computing the Related Party Transactions filter of 25% for accepting/ rejecting comparable companies. 12. The learned AO / learned TPO erred in holding that current year (FY 2010-11) data for comparable companies should be used and disregarded the application of multiple year / prior year data as used by the Appellant in the TP documentation. 13. The learned AO/ learned TPO ought to have allowed the Appellant's claim towards working capital differential existing between the Appellant vis-à-vis independent comparable companies. 14. The learned AO/ learned TPO ought to have allowed the Appellant's claim towards the risk difference between the Appellant vis-à-vis the comparable companies. The appellant craves leave to add, alter, rescind and modify the grounds herein above or produce further documents, facts and evidence before or at the time of hearing of this appeal. For the above and any other grounds which may be raised at the time of hearing, it is prayed that necessary relief may be provided.”

2.

The brief facts of the case are that the assessee engaged in the manufacturing and export of air safety evacuation system, assembly of aircraft lighting systems, cargo power system and electrical power system.

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Originally an assessment order was passed u/s. 143(3) r.w.s. 144C of the Act on 28/12/2015 in which the TP adjustment was made at Rs. 9,12,40,797/-. The said adjustment was made pursuant to the earlier direction of the Ld.DRP dated 23/11/2015. Subsequently, an order u/s. 154 was passed by the AO on 28/12/2015 in which the addition of TP adjustment was reduced from Rs. 9,12,40,797/- to Rs. 6,72,93,994/-. The said order was challenged before this Tribunal and this Tribunal vide an order dated 24/04/2019, set aside the order passed u/s. 154 and issued directions to the transfer pricing officer for making the adjustment properly. The transfer pricing officer complied with the directions of the Tribunal and passed an order u/s. 92CA(3) of the Act in which the addition of transfer pricing adjustment was made at Rs. 5,53,59,850/- in the engineering design services segment. Earlier the adjustment as per the order u/s. 154 was Rs. 6,72,93,994/-in the same segment. The TPO made the said adjustment by treating the transactions between the assessee and its AE as ITeS and determined the arms length price of the international transaction. The TPO adopted the average profit margin of 10 comparable companies selected from independent search process by applying TNMM. As against the said adjustment, the assessee filed their objections before the DRP, Bangalore and submitted that the TPO had treated the assessee company as ITeS, whereas the assessee is in the segment of engineering design services and therefore the comparables selected by the TPO is not correct. The Ld.DRP directed the TPO to exclude 7 comparables out of the 10 comparables. Thereafter the TPO had reduced the TP adjustment to Rs. 6,72,93,994/-.

3.

As against the said directions, the assessee as well as the revenue filed appeals before this Tribunal.

4.

This Tribunal vide its order dated 24/04/2019 in IT(TP)A No. 116/Bang/2016 had set aside the order of the AO on the issue of determination of ALP and remitted the same to the file of the TPO with the direction to decide the characterisation of the services performed by the

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assessee. Subsequently, the services rendered by the assessee was categorised as engineering design services and a show cause notice was issued for which the assessee also filed their response on 25/01/2022. The TPO had not accepted the filters applied by the assessee and rejected the transfer pricing study of the assessee and proceeded to determine the arms length price by conducting an independent search for comparables. The TPO proceeded to conduct the search based on the functions of the assessee, assets employed and the risks taken by the assessee. Several methods were adopted by the TPO and the comparables were selected by him and finally the TPO proposed to determine the ALP in respect of the engineering design services by applying the Transactional Net Margin Method as the most appropriate method in the facts and circumstances of the case. Finally the TPO had proposed an addition of Rs. 5,53,59,850/- as the transfer pricing adjustment to arrive at arms length price of the international transactions reported by the assessee. To that effect, a draft assessment order was passed. As against the said draft assessment order, the assessee filed their objections in form 35A. The Ld.DRP after considering the objections had rejected all the contentions raised by the assessee vide its order dated 15/12/2022. The AO pursuant to the directions of the Ld.DRP had passed the final assessment order on 29/03/2023 by saying that the DRP directions were received in their office on 27/02/2023.

5.

As against the final assessment order, the assessee is in appeal before this Tribunal.

6.

At the time of hearing, the Ld.AR heavily relied on the legal ground that the final assessment order passed on 29/03/2023 vide directions issued by the Ld.DRP u/s. 144C(13) of the Act is barred by limitation. The Ld.AR also relied on the said provision and submitted that the final assessment order should be passed within 30 days from the end of the month in which the direction was issued. The Ld.AR take us through the

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provisions and also submitted that the order of the DRP is dated 15/12/2022 and therefore under the faceless assessment scheme, the order would have been uploaded in the portal on 15/12/2022 itself and therefore the AO would also receive the said order on the said date and therefore their contention that the said direction was received on 27/02/2023 is against the facts of the case and therefore the final assessment order is an illegal order and passed by the AO beyond the period of limitation. The Ld.AR also filed a paper book and also brought to our notice that the Ld.TPO has passed the order on 20/12/2022 based on the direction issued by the Ld.DRP whereas the AO made the final order on 29/03/2023 which is beyond the period prescribed under the Statute and not sustainable. The Ld.AR also filed a notes to arguments about the limitation issues and also filed a counter to the AO’s report. Apart from that, the Ld.AR also filed 3 compilation of case laws in support of their argument that the final assessment order is barred by limitation. On merits the Ld.AR also submitted that the Ld.DRP erred in including the 7 companies as comparables when they did not satisfy the test of comparability.

7.

The Ld.DR submitted that the directions of the Ld.DRP was received by the AO on 27/02/2023 and therefore the final assessment order is within the period of limitation as prescribed u/s. 144C(13) of the Act. The Ld.DR also filed a written submission dated 05/11/2024 enclosing the copies of the material correspondence and also the intimation letter sent by the Ld.DRP in which the date seal of the various offices were affixed. In the said written submissions, the Ld.DR also filed a copy of the ledger maintained by the DCIT and submitted that the DRP directions were received by the AO on 27/02/2023 and therefore the final assessment order dated 29/03/2023 is within the period of limitation prescribed u/s. 144C(13) of the Act. The Ld.DR also relied on the single Judge order of the Hon’ble Madras High Court in case of M/s. Extreme Networks India Pvt. Ltd. vs. DCIT in W.P. No. 25807 of 2022 & W.M.P. Nos. 24863 & 24864 of 2022 dated 09/05/2025.

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8.

We have heard the arguments of both sides and perused the materials available on record.

9.

Before proceeding the matter on merits, we are inclined to decide about the legal plea raised by the assessee, whether the impugned final assessment order dated 29/03/2023 is barred by limitation or not. We have perused the documents in support of the said legal plea raised by the assessee. The Ld.DRP had issued directions on 15/12/2022 and the intimation letter furnished by the Ld.DR also pointed out that the said intimation was sent on 15/12/2022. The said intimation letter exhibits that the document identification number was generated on 15/12/2022 which means that the said document was uploaded through the portal of the department on 15/12/2022 itself. Once the directions were uploaded in the portal, it should be presumed that the said order was also communicated to the AO on 15/12/2022 itself.

10.

We have also considered the fact that the entire assessment proceedings are governed by the faceless assessment under the e- assessment Scheme, 2019. In the said e-assessment Scheme, it was clearly mentioned in para no. 4 (1)(ii) which reads as follows: “4. E-assessment Centres.– (1) For the purposes of this Scheme, the Board may set up- (i) a National e-assessment Centre to facilitate the conduct of e-assessment proceedings in a centralised manner, which shall be vested with the jurisdiction to make assessment in accordance with the provisions of this Scheme; (ii) Regional e-assessment Centres as it may deem necessary to facilitate the conduct of e-assessment proceedings in the cadre controlling region of a Principal Chief Commissioner, which shall be vested with the jurisdiction to make assessment in accordance with the provisions of this Scheme;

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11.

Therefore the directions once uploaded in the portal of the department, it will be immediately available to the National e-Assessment Centre and therefore it is deemed that the Faceless Assessment Officer has received the said communication on the date of uploading the said directions. Further, as seen from the order giving effect to the directions of the Ld DRP by the TPO, the same was passed on 20/12/2022 itself. Therefore the directions of the Ld DRP was received by all the authorities on 15/12/2022 itself. The above said facts, which are borne out from the records, would establishes the fact that the directions of the Ld.DRP was also deemed to be received by the National e-Assessment Centre on 15/12/2022 itself. When the said directions were uploaded on 15/12/2022 and DIN has been generated for the said documents, it should be presumed that the said order was communicated to the National E-Assessment Centre on 15/12/2022 itself. In the e-Assessment Scheme, we cannot accept that the directions would be forwarded by physical mode. Moreover, the documents filed by the Ld.DR also shows that the DIN was generated on 15/12/2022 itself and therefore the document would be available in the portal on the said date.

12.

Apart from filing a loose sheet that too without any authentication and without any affidavit in support of the said loose sheets, the department cannot rely on the loose sheets to show that the AO had not viewed the directions of the DRP in an earlier period of time. It is not the case of the revenue that there are some glitches in the portal. Even assuming that there are some glitches, it should be brought to the notice of the concerned authorities in time. In the present case, there is no such defence raised by the revenue and also no such documentary evidences were furnished before us to show that there are some glitches.

13.

In the present case, the directions were communicated to the National e-Assessment Centre by uploading the DRP directions on 15/12/2022 and therefore the final assessment order should have been passed on or before

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30/01/2023. But in the present case, the final assessment order was passed on 29/03/2023 and therefore the said final assessment order is certainly beyond the period prescribed u/s. 144C(13) of the Act.

14.

We have also perused the judgment of Hon’ble Delhi High Court in case of Louis Dreyfus Company India (P.) Ltd. vs. DCIT reported in [2024] 159 taxmann.com 244 wherein it was held as follows: “17. As is manifest from a reading of sub-section (13) of Section 144C of the Act, the AO is not accorded any discretion in the framing of an order of assessment once directions have come to be framed by the DRP. In fact, the provision requires the AO to frame an order of assessment in conformity with those directions and without providing any further opportunity of hearing to the assessee. This principle of law has been affirmed by the Bombay High Court in the aforenoted paragraphs of Vodafone Idea and in Shell India Markets Private Limited v. Additional Commissioner of Income Tax Officer, National Faceless Assessment Centre & Ors10. The relevant paragraph of the decision in Shell India are extracted hereinbelow: “10. Sub-section (13) of Section 144C, therefore, is very clear inasmuch as the Assessing Officer shall, upon receipt of the directions issued under sub-section (5), in conformity with the directions, complete the assessment within one month from the end of the month in which such direction is received. Sub-section (13) also provides that the Assessing Officer can complete the assessment without providing any further opportunity of being heard to the assessee. This means that the moment the Assessing Officer receives the directions under sub- section (5), he has to straightaway complete the assessment and he does not even have to hear the assessee. The Assessing Officer shall simply comply with the directions received from the DRP within one month from the end of the month in which such direction is received.” 18. In this backdrop, we note that both the judgments of the Bombay High Court in Shell India and Vodafone Idea construe the time lines as provided in Section 144C to be mandatory in character. In our considered opinion, this interpretation is in accord with the intent behind insertion of that provision and the bare text and spirit of that section. Thus, we accord our approval to the interpretation

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as set out in the aforenoted decisions of the Bombay High Court. 21. We, however note that paragraph 4(2) of the E-as, 2019 makes the following salient provisions:- “4(2). All communication among the assessment unit, review unit, verification unit or technical unit or with the assesse or any other person with respect to the information or documents or evidence or any other details, as may be necessary for the purposes of making an assessment under this Scheme shall be through the National e-assessment Centre.” 22. It is thus manifest that as per the provisions of E-as, 2019, all orders, notices and decisions have to be necessarily uploaded on the ITBA portal and as part of the larger faceless assessment regime which now holds the field. The uploading of the directive of the DRP on the ITBA portal would thus constitute valid and sufficient service and the period of limitation as prescribed in Section 144C(13) of the Act would be liable to be computed bearing that crucial date in mind. Once the aforesaid position becomes clear, it is evident that the order of assessment, if at all could have been framed lastly by 31 July 2022. There has thus been an abject failure on the part of the first respondent to comply with the mandatory timelines as incorporated in the aforenoted provisions. Accordingly, the writ petition is liable to be allowed and the impugned order of assessment and the consequential penalty proceedings are thus liable to be set aside on this short score alone.”

15.

We have also perused the judgment of Hon’ble Bombay High Court in case of Vodafone Idea Ltd. vs. CPC reported in [2023] 156 taxmann.com 258 wherein it was held as under: “20. Section 144C of the Act is a self contained provision which carves out a separate class of assessees, i.e., 'eligible assessee'. Section 144C of the Act was inserted in the Finance Act of 2009 and came into effect from 1st October 2009. In the notes on clauses to the Finance Bill, 2009 (Budget 2009-2010), the reason for insertion of Section 144C is given as under : “The subjects of transfer pricing audit and the taxation of foreign company are at nascent stage in India. Often

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the Assessing Officers and Transfer Pricing Officers tend to take a conservative view. The correction of such view take very long time with the existing appellate structure. With a view to provide speedy disposal, it is proposed to amend the Income-tax Act so as to create an alternative dispute resolution mechanism within the income-tax department and accordingly, section 144C has been proposed to be inserted so as to provide inter alia the Dispute Resolution Panel as an alternative dispute resolution mechanism.” 21. Thus, if the provisions of Section 144C as mandated by the Statute are not strictly adhered the entire object of providing for an alternate redressal mechanism in the form of DRP stand defeated. That is not the intention of the legislature when the provision was introduced in the Act. Section 144C(10) of the Act provide that the directions of DRP are binding on the AO. By failing to pass any order Gitalaxmi 18/20 903-oswpl-15398-2023-J.doc in terms of the provision, the AO cannot be permitted to defeat the entire exercise and render the same futile. When a Statute prescribes the power to do a certain thing in a certain way, then the thing must be done in that way and other methods of performance are forbidden. Once the statute has prescribed a limitation period for passing the final order, it is expected that the internal procedure of the department should mould itself to give meaning to and act in aid of the provision. Any procedural defect (there is none in this case) in the internal mechanism of the working of E- assessment Scheme, cannot operate against the interest of assessee. Hence, the FAO cannot be believed that the DRP direction was received by him only on 23rd August 2023 despite being uploaded on the ITBA portal on 25th March 2021. The failure on the part of department to follow the procedure under Section 144C of the Act is not merely a procedural irregularity, but is an illegality and vitiates the entire proceeding.”

16.

We have also perused the judgment of Hon’ble Telangana High Court in case of Rapiscan Systems Pvt. Ltd. vs. ADIT in W.P. Nos. 44891 and 44915 of 2022 dated 09/01/2025 in which it was held as under: “31. The Income Tax Department through communication dated 30.06.2022 (Annexure P-19) informed that the order under Section 144C(5) dated 30.06.2022 is having

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Document No.(DIN) ITBA/DRP/M/144C(5)/2022- 23/1043689612(1). This is a system generated document and it does not require any signature. A conjoint reading of communications dated 30.01.2024 and 05.03.2024 (Annexure P-18) and communication dated 30.06.2022 (Annexure P-19) leaves no room for any doubt that DRP's directions were despatched on 30.06.2022 and also uploaded on the portal on the same date. Thus, the DRP/originator had lost control over it on the date and time the said directions were uploaded on the portal. Hence, same must be treated to be a 'receipt' by the recipient i.e., the assessing officer on the same day i.e., 30.06.2022. (See paragraph No.26.7 of Suman Jeet Agarwal v. Income-tax Officer 11, where the Delhi (2022) 449 ITR 517 SP,J & Dr.GRR,J Wps_44891 & 44915 of 2022 High Court poignantly held that the portal of the department is the 'computer resource in the control of the department'). 32. In view of forgoing discussion, there is no cavil of doubt that assessing officer received the DRP's directions on 30.06.2022 and therefore, the limitation must be counted from that date and not from 05.07.2022. The impugned assessment orders dated 30.08.2022 and 01.09.2022 that were issued counting the limitation from 05.07.2022 in both the Writ Petitions are liable to be set aside as the same are issued beyond permissible period of limitation.”

17.

In the light of the principles laid down by the three Hon’ble High Courts and by following the said principles we are of the firm view that the final assessment order passed by the AO on 29/03/2023 is barred by limitation as per Section 144C (13) of the Act. In similar circumstances, in another appeal in the case of M/s. Goldman Sachs Services Pvt. Ltd. vs. DCIT in IT(TP)A No. 836/Bang/2022 vide order dated 25/07/2025, we took the very same view and held that the final assessment order passed by the AO is barred by limitation.

18.

We have also considered the judgment of the Hon’ble Madras High Court relied on by Ld.DR and the said judgment is on different facts and it would not be taken as a precedent for the present case.

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19.

We, therefore, set aside the final assessment order passed by the AO on the legal ground of barred by limitation raised by the assessee. We have not adjudicated the other grounds raised by the assessee on merits in view of the order passed by us on the legal plea. We left it open to the assessee to raise it at the appropriate time as and when the same is required.

20.

In the result, the appeal filed by the assessee is allowed.

Order pronounced in the open court on 11th September, 2025.

Sd/- Sd/- (PRASHANT MAHARISHI) (SOUNDARARAJAN K.) Vice – President Judicial Member

Bangalore, Dated, the 11th September, 2025. /MS / Copy to: 1. Appellant 2. Respondent 3. CIT 4. DR, ITAT, Bangalore 5. Guard file 6. CIT(A) By order

Assistant Registrar, ITAT, Bangalore

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