RENAULT NISSAN AUTOMOTIVE INDIA PRIVATE LIMITED,KANCHEEPURAM vs. ACIT CORPORATE CIRCLE 5(1), CHENNAI

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ITTPA 38/CHNY/2019Status: DisposedITAT Chennai31 January 2023AY 2013-1418 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the Transfer Pricing Officer (TPO) erred in classifying the assessee as a contract manufacturer without providing valid reasons or findings on who supplied the necessary materials and technology for car manufacturing. The Tribunal found that the TPO's adoption of 'any other method' under Rule 10AB of the IT Rules, 1962, by computing 3% on value added cost and a routine return of 8.19% on capital employed, was not in accordance with law due to lack of clarity and justification for the return on capital employed. The Tribunal held that the Transactional Net Margin Method (TNMM) was the most appropriate method, especially since the TPO had accepted it in subsequent years without significant changes in facts. The Tribunal directed the TPO to benchmark the international transactions using TNMM. Regarding the provident fund provision, the Tribunal found that while the assessee provided details of the provision, it did not furnish information on whether the payment was accepted or an appeal was preferred. The AO's disallowance was based on the provision being a contingent liability without sufficient detail. Therefore, the Tribunal set aside this issue to the file of the AO for further verification and decision in accordance with law. The ground challenging the rejection of the 'one economic unit' approach was dismissed as not pressed by the assessee.

What were the facts?

The assessee, Renault Nissan Automotive India Private Limited, filed an appeal against the final assessment order passed by the Assessing Officer (AO) for Assessment Year 2013-14. This order was passed under Section 143(3) read with Section 92CA and 144C(1) of the Income-tax Act, 1961, pursuant to directions from the Dispute Resolution Panel (DRP). The dispute primarily concerns transfer pricing adjustments and the deductibility of a provision for provident fund. The assessee's transfer pricing study, functional analysis, and arm's length profit calculations were challenged by the lower authorities. The AO also disallowed a provision made for differential provident fund payments.

What were the issues?

1. Whether the lower authorities erred in making upward adjustments to the Appellant's international transactions by rejecting its transfer pricing study, functional analysis, and arm's length profit calculations, and by not granting appropriate economic adjustments, thereby misapplying Section 92C of the Act? 2. Whether the lower authorities erred in rejecting the 'overseas tested party' approach used by the Appellant for benchmarking international transactions, and in observing that the Appellant did not provide documentation for the overseas tested party performing least complex functions? 3. Whether the lower authorities erred in disregarding the Appellant's functional profile and arbitrarily re-characterizing it as a contract manufacturer, contrary to Section 92C of the Act? 4. Whether the lower authorities erred in the methodology used for computing arm's length profit, by incorrectly applying transfer pricing methods, failing to identify uncontrolled transactions, and imputing an arbitrary return on capital employed, contrary to Section 92C of the Act? 5. Whether the lower authorities erred in treating the Investment Promotion Subsidy (IPS) incentive as a non-operating item and excluding it from net operating margins, and in restricting its credit to the risk-free return on capital employed? 6. Whether the lower authorities erred in not providing appropriate economic adjustments for forex loss, capacity utilization, customs duty, and working capital? 7. Whether the lower authorities erred in not allowing the deduction claimed by the Appellant for a provision created with respect to a demand raised by the provident fund authorities, stating it was contingent in nature, contrary to Section 37 of the Act? Assessee's Contentions: The assessee argued that its transfer pricing study, functional analysis, and arm's length profit calculations were valid. It contended that the 'overseas tested party' approach was appropriate and had been accepted in a previous year. The assessee argued it was not a contract manufacturer and that the IPS incentive should be treated as part of regular business operations. It also argued for economic adjustments and the deductibility of the provident fund provision as it was quantified and not contingent. The assessee relied on various precedents. Revenue's Contentions: The revenue, through the AO and DRP, rejected the assessee's transfer pricing approach, re-characterized the entity, and made adjustments based on their own analysis, including a routine return on capital employed. The AO disallowed the provident fund provision as a contingent liability.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 92CA,Section 144C(1),Section 144C(5),Section 92C,Section 37

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI

Before: SHRI V. DURGA RAO, HON’BLE & SHRI G. MANJUNATHA, HON’BLE

Hearing: 14.12.2022Pronounced: 31.01.2023

PER G. MANJUNATHA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is directed against the final assessment order passed by the Assessing Officer u/s. 143(3) r.w.s. 92CA r.w.s. 144C(1) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”), dated 28.02.2019

:-2-: IT(TP)A. No: 38/Chny/2019 in pursuant to DRP directions issued u/s. 144C(5) of the Act dated 10.01.2019 and pertains to assessment year 2013-14.

2.

The assessee has raised the following grounds of appeal: “GROUNDS OF APPEAL (Annexure to Form 36) The grounds of appeal listed below are independent and without prejudice to each other. 1. GENERAL GROUND 1.1. The lower authorities have, in the facts and circumstances of the case, erred in passing orders with unwarranted adjustments to the reported income of the Appellant by misapplying the provisions of the Act, by adopting faulty assessment procedures to finalize the adjustment, such as, but not limited to, rejection of (a) transfer pricing study, (b) analysis of the functions carried out by the Appellant and (c) arm's length profit arrived at by Appellant and by not granting appropriate economic adjustments. 2. TRANSFER PRICING ADJUSTMENT 2.1. The lower authorities erred in the facts and circumstances of the case and in law, in making an upward adjustment to the Appellant's international transactions. 2.2. Approach for benchmarking the international transactions: 2.2.1. Without prejudice to the above grounds, the lower authorities had erred in the facts and circumstances of the case and in law, in rejecting the 'overseas tested party' approach used to benchmark the international transactions in the Transfer Pricing study maintained by the Appellant and not appreciating that a similar approach for benchmarking the imports was accepted in a previous year by the TPO. 2.2.2. The lower authorities erred in observing that appellant has not placed any document to show that overseas tested party perform the least complex functions. 2.3. Characterization of the entity 2.3.1. The lower authorities erred in the facts and circumstances of the case and in law, in disregarding the

:-3-: IT(TP)A. No: 38/Chny/2019 functional profile of the Appellant and by arbitrarily re- characterizing the Appellant as a contract manufacturer. 2.4. Methodology used for computing arm's length profit 2.4.1. The lower authorities erred in facts and circumstance of case and in law, by incorrectly applying the transfer pricing methods, as required under Section 92C of the Act, while determining the arm's length price ('ALP') of the transactions. The lower authorities erred in not identifying any uncontrolled transaction for the determination of ALP and by merely adopting the TP policy in addition to imputing an arbitrary return on capital employed to determine the ALP. 2.4.2. Without prejudice to the argument on the above, the Ld. TPO/ AO erred in the facts and circumstances of the case and in law, by not following the directions of Ld. DRP lo compute the return based on average capital employed instead of year- end capital employed. 2.4.3. The lower authorities erred in facts and circumstances of the case and in law, in restricting the credit of the Investment Promotion Subsidy ('IPS') incentive to the extent of risk free return on capital employed, without appreciating the fact that IPS incentive is a subsidy in relation to regular business operations of the Appellant. 2.4.4. The lower authorities erred in facts and circumstances of the case and in law, in proposing an adjustment at the entity level, instead of restricting the adjustment to the value of international transactions, without appreciating that the international transactions account for only 48 percent of the total costs. 2.5. Computation of net margins of the Appellant 2.5.1. The lower authorities had erred in the facts and circumstances of the case and in law, in treating the IPS incentive as a non-operating item and excluding the same in computing the net operating margins of the Appellant without appreciating the nature of IPS incentive. 2.5.2. Without prejudice to other grounds, the lower authorities had erred in the facts and circumstances of the case and in law by considering IPS incentive as non-operating in nature for computation of the net margin of the Appellant, however, the IPS incentive has been offered to tax in the return of income. 2.6. Economic adjustment;

:-4-: IT(TP)A. No: 38/Chny/2019 2.6.1. The lower authorities erred in facts and circumstances of the case and in law, by not providing appropriate economic adjustments for differences on account of forex loss, capacity utilization, customs duty and working capital in computing the arm's length price and proposing a TP adjustment. 2.7. Other grounds: 2. 7.1. Without prejudice to the above grounds, the lower authorities erred in the facts and circumstances of the case and in law, in rejecting the 'One economic unit' approach adopted by the Appellant for determining the ALP of its international transactions, without appreciating its business model and other economic aspects of its business. 2.7.2. Without prejudice to the above grounds, the lower authorities erred in the facts and circumstances of the case and in law, in rejecting the Indian benchmarking analysis (using Indian comparables) submitted by the Appellant as part of the transfer pricing assessment proceedings. DEDUCTIBILITY OF PROVISION FOR PROVIDENT FUND DEMAND RAISED BY THE AUTHORITIES 3.1. The lower authorities erred in facts and circumstances of the case and in law by not allowing the deduction claimed by the appellant for provision created with respect to the demand raised by the provident fund authorities. 3.2. The lower authorities erred in not allowing deduction under section 37 of the Act for the provision created with respect to the demand raised by the provident fund authorities by stating that the said provision is contingent in nature. 3.3. The lower authorities erred in facts by not appreciating the fact that the provision is not contingent in nature as it has been quantified vide the order issued by the provident fund authorities and accordingly, provision has been created in the books of the appellant including interest. 3.4. Further, the lower authorities failed to appreciate the applicability of the principles upheld by courts in the precedents relied on by the Appellant. The Appellant prays that directions be given to grant all such relief arising from the grounds of appeal mentioned supra and all consequential relief thereto.

:-5-: IT(TP)A. No: 38/Chny/2019 The Appellant craves leave to add to and/or to alter, amend, rescind, modify the grounds herein above or produce further documents before or at the time of hearing of this Appeal.”

3.

The assessee had also filed a petition for admission of additional grounds on 12.12.2022 and taken certain legal grounds challenging final assessment order passed by the Assessing Officer contrary to directions issued by the DRP in violation to provisions of section 144C(13) of the Act. The relevant additional grounds of appeal filed by the assessee are as under: ADDITIONAL GROUNDS OF APPEAL 4. FINAL ASSESSMENT ORDER NOT IN CONFORMITY WITH THE DRP DIRECTIONS AND LIABLE TO BE QUASHED 4.1 The final assessment order passed by the Learned Assessing Officer ("Ld. AO") is not in conformity with the provisions of section 144C(13) of the Act and hence bad in law, liable to be quashed. 4.2 The Ld. AO has grievously erred in law by passing the final assessment order not in accordance with the directions issued by the Hon'ble Dispute Resolution Panel ("Hon'ble DRP") and thereby grossly violating the express mandatory provisions as laid down in section 144C(13) of the Act, and making the final assessment order invalid and void-ab-initio. 4.3 The Ld. AO ought to have passed the final assessment order in conformity with the directions issued by the Hon'ble DRP. However, the Ld. AO has just merely incorporated the transfer pricing ("TP") adjustment as-is from the draft assessment order without considering any of the directions issued by the Hon'ble DRP, which have a mandatory binding on the Ld. AO by virtue of the express provisions stipulated in section 144C(5) and 144C(13) of the Act. ANY RECTIFICATION TO AN INVALID ORDER IS ALSO INVALID, BARRED BY LIMITATION OF TIME AND LIABLE TO BE QUASHED 5.1 The Ld. AO erred in law by passing a rectification order under section 154 of the Act in respect of an already void-ab- initio final assessment order without appreciating that the

:-6-: IT(TP)A. No: 38/Chny/2019 resultant order would also be rendered void and hence would be liable to be quashed. 5.2 The Ld. AO has passed the rectified order under section 154 of the Act on 4 April 2019 which is in fact beyond the due date for completion of assessment as per section 144C(13) of the Act and hence is liable to be quashed on the grounds of period of limitation as well. 6. FINAL ASSESSMENT ORDER PASSED UNDER INCORRECT SECTION AND LIABLE TO BE QUASHED 6.1 The final assessment order passed under section 143(3) read with section 92CA read with 144C(1) by the Ld. AO is void-ab-initio and liable to be quashed. 6.2 The Ld. AO ought to have passed the final assessment order under section 143(3) read with section 92CA read with section 144C(13) of the Act. However the ld. AO has grossly erred in passing under section 143(3) read with section 92CA read with section 144C(1) of the Act which provides for passing of draft assessment order instead of section 144C(13)of the Act and therefore the final assessment order dated 28 February 2019 is invalid and liable to be quashed. 7. ECONOMIC ADJUSTMENT TO ELIMINATE DIFFERENCES IN RISK PROFILE 7 .1 The Learned Transfer Pricing Officer ("Ld. TPO") erred in facts and circumstances of the case and in law, by providing appropriate economic adjustment to eliminate the differences on account of risk profile of the Appellant while computing the arm's length price and proposing a transfer pricing adjustment. 7.2 Without prejudice to any of the other grounds, the ld. TPO while treating the Appellant as a contract manufacturer bearing nil risks ought to have granted risk adjustment to eliminate the differences on account of risk profile of the Appellant. However, the Ld. TPO has computed the arm's length price and imputed a transfer pricing adjustment without factoring the said economic adjustment (i.e., risk adjustment). The Appellant prays to your Honor's to permit raising the above additional grounds of appeal and claim as part of the appeal filed for AY 2013-14. The Appellant craves leave to add, alter, vary, omit, amend or delete one or more of the above grounds of appeal at any time before, or at the time of. hearing of the appeal, so as to enable the Hon'ble ITAT to decide this appeal according to law.”

:-7-: IT(TP)A. No: 38/Chny/2019 4. The Ld. Counsel for the assessee, submitted that the additional grounds raised by the assessee challenging validity of assessment order passed by the AO goes to root of the matter, which can be raised any time including proceedings before the Tribunal and thus, prayed for admission of additional grounds.

5.

The Ld. DR, on the other hand strongly opposing additional grounds filed by the assessee submitted that petition filed by the assessee should not be admitted at this stage, because the assessee could not able to demonstrate with evidence that facts with regard to legal grounds raised in petition are already on records and further, there is no necessity of getting fresh facts to resolve the issue. Therefore, the petition filed by the assessee for admission of additional grounds should be rejected.

6.

We have heard both the parties and considered relevant contents of petition filed by the assessee for admission of additional grounds and we find that grounds taken by the assessee challenging the validity of final assessment order passed by the AO contrary to provisions of section 144C(13) of

:-8-: IT(TP)A. No: 38/Chny/2019 the Act, and consequent rectification order passed u/s. 154 of the Act, quo limitation applicable for passing final assessment order and also application of wrong provisions for final assessment order are purely a legal issue which can be taken at any time of proceedings including the proceedings before the Tribunal and thus, by following the decision of Hon’ble Supreme Court in the case of CIT vs Kanpur Coal Syndicate (1964) 53 ITR 225 (SC) and also the decision of Hon’ble Madras High Court in the case of Ramco Cements Ltd (2015) 373 ITR 146 (Mad), we admit additional grounds filed by the assessee challenging validity of assessment order passed by the AO and other issues because said grounds are purely a legal grounds which can be admitted at any time of proceedings including proceedings before the Tribunal. Thus, we admit petition filed by the assessee for admission of additional grounds.

7.

The Ld. Counsel for the assessee, referring to ground no. 4.1 to 4.3 of additional grounds submitted that the final assessment order passed by the AO is not in conformity with DRP and liable to be quashed. He further referring to ground no. 5.1 to 5.2 submitted that although, the AO has rectified

:-9-: IT(TP)A. No: 38/Chny/2019 the said mistake in order passed u/s. 154 of the Act, once final assessment order is void-ab-initio, then resultant rectification order would also be rendered as void and hence would be liable to be quashed. The Ld. Counsel for the assessee, referring to ground no. 6.1 to 6.2 of the additional grounds submitted that the AO has passed final assessment order u/s. 143(3) r.w.s. 92CA r.w.s. 144C(1) of the Act, contrary to provisions of section 144C(13) of the Act. Therefore, said order becomes void-ab-initio and liable to be quashed.

8.

The Ld. DR, on the other hand supporting order of the AO, submitted that although while passing final assessment order, the AO has violated directions given by the DRP in allowing relief to the extent of adjustment restricted to international transactions, but subsequently, an application moved by the assessee has passed an order u/s. 154 of the Act and rectified the final assessment order in conformity with directions given by the DRP and thus, there is no merit in additional ground raised by the assessee. He further, submitted that although the AO has referred section 144C(1) of the Act, in the final assessment order, but said reference is a technical error which does not vitiate the assessment order.

:-10-: IT(TP)A. No: 38/Chny/2019 Therefore, he submitted that the ground raised by the assessee may be rejected.

9.

We have heard both the parties, perused materials available on record and gone through orders of the authorities below. As regards final assessment order not in conformity with the DRP directions as per the provisions of section 144C(13) of the Act, we find that although the AO has initially violated the DRP directions, in respect of relief allowed towards restriction of TP adjustment to international transactions, but on an application by the assessee, the AO has passed order u/s. 154 of the Act and rectified the final assessment order in conformity with directions given by the DRP and in our considered view, said order is in conformity with provisions of section 144C(13) of the Act. Therefore, we are of the considered opinion that there is no merit in the grounds taken by the assessee challenging the validity of final assessment order and consequent rectification order in light of limitation provided for passing final assessment order. In so far as, the second argument of the assessee in light of reference of provisions of section 144C(1) of the Act, instead of provisions of section 144C(13) of the Act, we find that said lapse is only a

:-11-: IT(TP)A. No: 38/Chny/2019 technical error, which does not vitiate the whole assessment proceedings. Further, the AO has taken a broader view and referred to provisions of section 92CA of the Act, which speaks about transfer pricing adjustment and also taken a reference to DRP directions and thus, we are of the considered view that mere mentioning of different section in the final assessment order does not vitiate any assessment proceedings. Therefore, we reject the ground taken by the assessee.

10.

The next issue that came up for our consideration from various grounds of assessee’s appeal is upward adjustment to international transactions of the assessee with its Associate Enterprises (AE). The Ld. Counsel for the assessee, submitted that the assessee has benchmarked international transactions with its AE by adopting one economic unit approach method and has adopted TNMM as most appropriate method with OP/OC as PLI. The TPO has rejected TP study conducted by the assessee by adopting TNMM as most appropriate method and has chosen ‘other method’ and has suggested upward adjustment on value added cost @ 3% and also 8.19% return on capital employed without giving any reasons as to how the method selected by the assessee suffered from infirmity.

:-12-: IT(TP)A. No: 38/Chny/2019 Further, the TPO himself has accepted TNMM as most appropriate method in subsequent assessment years. Therefore, there is no reason for the TPO to adopt ‘any other method’ in the impugned assessment year. Thus, the ld. Counsel for the assessee, submitted that the matter may be set aside to the file of the TPO to re-examine the method adopted by the assessee to benchmark international transactions with its AE.

11.

The Ld. DR, on the other hand submitted that the TPO has given various reasons to reject TP study conducted by the assessee by adopting TNMM as most appropriate method and as per the TPO, the assessee has been classified as a contract manufacturer and in this segment, there are no comparables to examine the transactions of the assessee. Therefore, as prescribed u/r. 10AB of IT Rules, 1962, the AO has adopted ‘any other method’ by taking into account the price which has been charged or paid, which would have been charged or paid, for the same and similar uncontrolled transaction, with or between non-associated enterprises, under similar circumstances, considering all the relevant facts. Further, the TPO had also stated why he has adopted 3% on value added

:-13-: IT(TP)A. No: 38/Chny/2019 cost and 8.19% of return on capital employed. Therefore, there is no reason to set aside the appeal to the file of the TPO to re-examine transactions of the assessee with its AE.

12.

We have heard both the parties, perused materials available on record and gone through orders of the authorities below. From the impugned assessment year, there is a significant change in functions carried out by the assessee and as noted by the TPO, the assessee is manufacturing cars for Nissan Motors India Ltd and Renault India Private Ltd. Based on the functions carried out by the assessee, the TPO has classified assessee as a contract manufacturer. According to the TPO, the assessee do not assume any significant risk which a professional manufacturer of cars assume. Therefore, he was of the opinion that the assessee cannot be considered as entrepreneur engaged in the business of manufacturing of cars. We find that although the TPO has classified assessee as a contract manufacturer, for the purpose of benchmarking its international transactions, he has not given any valid reason to come to such a conclusion that the assessee is not assuming any significant risk that of a manufacturer of car is assuming. In our considered view, when the assessee is involved in

:-14-: IT(TP)A. No: 38/Chny/2019 manufacturing of car, the risk involved and functions performed by the assessee may be or equivalent to functions performed and risk assumed by other manufacturer. However, in case of contract manufacturer, they assume limited risk going by the industrial standard like, carrying out manufacturing operations and employing required labour, other technology and material required for manufacturing process will be given by the principal. In this case, the AO had not given any findings as to who is providing necessary material for manufacturing of cars and required technology. Therefore, in our considered view, the TPO has completely erred in classifying assessee as a contract manufacturer for the purpose of benchmarking its international transactions with PE.

13.

Having said so, let us come back to the method followed by the assessee and the TPO. The assessee has followed TNMM as most appropriate method with OP/OC as PLI. The TPO has rejected TNMM as most appropriate method and has adopted ‘any other method’ as prescribed u/r. 10AB of the IT Rules, 1962 and has computed 3% on VAC and a routine return of 8.19% on capital employed to be a deemed arm’s

:-15-: IT(TP)A. No: 38/Chny/2019 length price for the functional profile of the assessee. The TPO while adopting 3% on value added cost has taken cost plus margin charged in similar case. However, when it comes to return on capital employed, the TPO has not given any reason as to how 8.19% of return on capital employed is reasonable for the given facts and circumstances of the case. Further, there is no clarity on how the TPO has arrived at capital employed in the business. Therefore, we are of the considered view that the method followed by the TPO in terms of Rule 10AB of IT Rules, 1962 is not in accordance with law, having regard to facts and circumstances of this case and thus, we reject ‘any other method’ adopted by the TPO.

14.

In so far as TNMM method selected by the assessee, the assessee has consistently adopted TNMM as most appropriate method with OP/OC as profit level indicator. In subsequent assessment years, the TPO himself had accepted TNMM as most appropriate method without there being any significant change in facts, when compared to impugned assessment year. Since, we have already stated in earlier part of this order that the TPO has not given valid reasons for rejecting TNMM method and adopting any other method, we are of the

:-16-: IT(TP)A. No: 38/Chny/2019 considered view that, TNMM is most appropriate method in the given facts and circumstances of this case and thus, we direct the TPO to benchmark international transactions with its AE by adopting TNMM as most appropriate method. The TPO is free to examine basis followed by the assessee, including comparable selected for benchmarking its transactions. The TPO is also free to examine operating margin computed by the assessee. Needless to say, the assessee is also free to raise all objections in so far as computation of operating margin by inclusion of certain items of income and expenditure.

15.

As regards other grounds taken by the assessee including challenging rejection of one economic unit approach, during the course of hearing, the Ld. Counsel for the assessee fairly agreed that the assessee does not want to press the grounds challenging rejection of one economic unit approach and thus, the ground raised by the assessee has been dismissed as not pressed.

16.

The next issue that came up for our consideration from ground no. 3 of assessee’s appeal is disallowance of other provisions u/s. 37 of the Act. The assessee has debited Rs. 10

:-17-: IT(TP)A. No: 38/Chny/2019 crores on account of other provisions. The assessee was called upon to explain the nature of provisions created and in response, the assessee submitted that during the financial year 2012-13 relevant to assessment year 2013-14, the company has made a provision for provident fund payment raised by the PF authorities towards differential amount. The AO rejected arguments of the assessee and disallowed provisions created for differential provident fund payable on the ground that the said provision is only contingent liability which is not crystallized in the relevant assessment year.

17.

We have heard both the parties, perused materials available on record and gone through orders of the authorities below. Although, the assessee has submitted details with respect to provisions under the head ‘other provisions’ and explained that it is towards differential amount of provident fund payable to PF authorities, but no details has been given whether the assessee has accepted the payment or preferred an appeal before the appellant authorities. The AO had also made disallowance towards provisions on the ground that said provision is only a contingent liability without giving any details as to how said liability is contingent in nature.

:-18-: IT(TP)A. No: 38/Chny/2019 Therefore, we are of the considered view that the issue needs to go back to the file of the Assessing Officer for further verification and thus, we set aside the issue to the file of the AO and direct the AO to re-examine the issue and decide in accordance with law.

18.

In the result, appeal filed by the assessee is treated as partly allowed for statistical purposes. Order pronounced in the court on 31st January, 2023 at Chennai. Sd/- Sd/- (वी दुगा� राव) (जी. मंजुनाथ) (V. DURGA RAO) (G. MANJUNATHA) �याियकसद�य/Judicial Member लेखासद�य/Accountant Member चे�ई/Chennai, �दनांक/Dated: 31st January, 2023 JPV आदेश क� �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु� (अपील)/CIT(A) 4. आयकर आयु�/CIT 5. िवभागीय �ितिनिध/DR 6. गाड� फाईल/GF

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