TSI BUSINESS PARKS (HYDERABAD) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-2(1), HYDERABAD

आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B‘ Bench, Hyderabad �ी रिवश सूद,�ाियक सद� एवं �ी मधुसूदन साविड़या लेखा सद� सम� | Before Shri Ravish Sood, Judicial Member A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No. 572/Hyd/2026 (िनधा�रण वष�/Assessment Year: 2022-23) M/s. TSI Business Parks Vs. Dy. CIT (Hyderabad) Private Ltd, Circle 2(1) Hyderabad Hyderabad PAN:AACCT4067B (Appellant) (Respondent) िनधा��रती �ारा/Assessee by: CAs Aliasgar Rampurwala and Pratik राज� व �ारा/Revenue by: Shri Waseem UR Rehman, CIT (DR) सुनवाई की तारीख/Date of hearing: 24/08/2026 घोषणा की तारीख/Pronouncement: 13/10/2026 ORDER Per Madhusudhan Sawdia, A.M:. This appeal is filed by TSI Business Parks (Hyderabad) Private Limited (“the assessee”), feeling aggrieved by the assessment order passed by the Assessing Officer (“AO”) under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (“the Act”) for A.Y. 2022-23 dated 17.12.2025 as per the directions of the Learned Dispute Resolution Panel-1 Bengaluru (“Ld. DRP”) dated 18.11.2025.

i) ITAT Hyderabad Benches in the case of Uber India Research & Development Private Vs. DCIT (ITA-TP No.106/Hyd/2022) ii) ITAT Bangalore Benches in the case of Marlabs Innovations Private Ltd Vs. DCIT (ITA No.833/Bang/2026 (TS-455-ITAT-2026 (Bang.)TP) iii) ITAT Bangalore Benches in the case of Symbol Technologies India Pvt. Ltd. Vs. DCIT (IT(TP)A No.626/Bang/2026 TS-484-ITAT 2026 (Bang)-TP)./ iv) ITAT Bangalore Benches in the case of Arm Embedded Technologies India Pvt. Ltd Vs. DCIT IT(TP)A No.785/Bang/2026 TS-497-ITAT-2026 (Bang)-TP. v) ITAT Bangalore Benches in the case of IQVIA RDS (India) (P) Ltd Vs. DCIT (2026) 185 Taxmnann.com 178 (Bangalore-Trib.) vi) ITAT Bangalore Benches in the case of Tavant Technologies India Private Ltd Vs. DCIT IT (TP)A No.1582/Bang/2024. vii) ITAT Bangalore Benches in the case of Xchnging Solutions Ltd Vs. DCIT (2021) 126 Taxmann.com 277 (Bangalore-Trib.) viii) ITAT Bangalore Benches in the case of Software Paradigms Infotech (P) Ltd Vs. Assistant Commissioner of Income Tax (2018) 89 taxmann.com 339 (Bangalore-Trib.) ix) ITAT Bangalore Benches in the case of VMware Software India (P) Ltd Vs. DCIT m(2022) 141 Taxmann.com 105 (Bangalore-Trib). x) ITAT Bangalore Benches in the case of Flextronics Technologies (India) Private Limited vs. Assistant Commissioner of Income Tax IT (TP)A No.832/Bang/2017. xi) ITAT Bangalore Benches in the case of July Systems and Technologies Private Limited Vs. DCIT IT (TP)A No.479/Bang/2016 & CO No.13/Bang/2017. xii) ITAT Delhi Benches in the case of Global One India (P) Ltd Vs. DCIT (2019) 112 taxmann.com 185 (Delhi-Trib). xiii) ITAT Delhi Benches in the case of Syniverse Technologies Services India P Ltd Vs. ACIT ITA No. 2056/Del/2022 (Delhi-Trib.) xiv) ITAT Delhi Benches in the case of Cambridge University Press and Assessment India (P) Ltd Vs. NFAC (2026) 185 taxmann.com 968 (Delhi-Trib.).

xv) ITAT Hyderabad Benches in the case of Gameloft Software Private Ltd Vs. ITO in MA No.62/Hyd/2023 & ITA No.432/Hyd/2018 dated 27.02.2024. 7. Per contra, the Learned Departmental Representative (“Ld. DR”) relied upon the orders of the lower authorities. He submitted that the Ld. DRP had upheld the determination of the arm’s length price made by the Ld. TPO and that the AO had incorporated the transfer pricing adjustment sustained by the Ld. DRP in the final assessment order. According to him, the grievance of the assessee concerned only the consequential computation after considering the disallowance already made under section 94B of the Act. Such a computational omission, which he submitted, would not render the entire assessment order void. Accordingly, he prayed that the assessee’s contention seeking quashing of the final assessment order be rejected. 8. We have heard the rival submissions and perused the material available on record including the case laws relied upon. The issue arising from Ground No. 3 is whether the omission to give appropriate adjustment for the interest expenditure already disallowed under section 94B of the Act renders the entire final assessment order liable to be quashed, or whether the omission requires correction by restoring the matter to the AO for the limited purpose of correctly implementing the directions of the Ld. DRP. There is no dispute that the directions issued by the Ld. DRP are binding upon the AO. Section 144C(10) of the Act expressly provides that every direction issued by the Ld. DRP shall be binding upon the AO, and section 144C(13) of the Act requires the assessment to be completed in conformity with those directions. Thus, the AO cannot ignore, modify or substitute his own conclusion for any direction issued by the Ld. DRP. This requirement applies equally to the direction sustaining the transfer pricing adjustment and to the direction requiring avoidance of double disallowance. In this regard, we have gone through para nos. 3 to 5 of the final assessment order, which is to the following effect:

“4. We have carefully considered the rival contentions and perused the records. 5. The Assessing Officer has recorded thus in his order: “5. The DRP by its order dated 28.12.2016 gave certain directions to the TPO. The AO thereafter passed the impugned order without incorporating the directions given by the DRP dated 28.12.2016. The following were the relevant observations of the AO in the final order of assessment dated 31.01.2017, which is the order impugned in this appeal. “Accordingly, adjustments as determined by the TPO to ALP of Rs. 40,11,77,583/- was added to the retuned income of the assessee and draft assessment order was passed on 29.03.2016 under the provisions of section 144C of the Income-Tax Act,1961. The assessee based on the draft assessment order filed its objections before the Hon’ble DRP, Bangalore on 29.04.2016. The Hon’ble DRP vide its directions issued u/s. 144C(5) r.w.s.144C(8) of the IT Act dated 28.12.2016 has given relief relating to the TP adjustment. 5. On receipt of direction of Hon’ble DRP a reference was made to TPO for reworking the ALP adjustment as per DRP’s direction. The OGE. in respect of DRP’s directions connected with the TP adjustments has not been received. As this is a time barring assessment proceedings the assessment order is passed based on the TP adjustment mentioned in the draft assessment order. On receipt of the order giving effect from TP necessary action for a either increase or decrease of the TP adjustment will be done u/s.154 of the IT Act. 6. As the assessee company has furnished inaccurate particulars penalty proceedings u/s.271(1)(c) is initiated separately. Considering the directions issued by the Hon’ble DRP, the assessment is completed as under.

Income as per Nil Return of Income Add: TP Adjustment 40,11,77,583 Less: B/F Loss Set 40,11,77,583 Off Total Assessed Nil Income 1. Balance Tax Nil Payable Issue Demand Notice & Penalty notice accordingly.” 6. Shri. Suryanarayana is right in his submission that under Section 144C of the IT Act, the Assessing Officer is bound by the directions issued by the DRP and required to pass the assessment order in conformity with the directions issued within one month from the end of month in which such directions are issued. 7. The ITAT has recorded that impugned order is not in conformity with the provisions of Section 144C of the IT Act and barred by time. 8. Shri.Dilip’s contention is, the Assessing Officer has rightly passed the order within time. But it is relevant to note that the said order is not in conformity with Section 144C of the IT Act. Hence, no exception can be taken to the impugned order passed by the ITAT. Hence, we proceed to pass the following: ORDER (1) Appeal is dismissed (2) Question of law answered in favour of assessee and against the Revenue. No costs” 13. On perusal of the above, we find that the reliance placed by the assessee on the order of Hon’ble Karnataka High Court in the case of PCIT/DCIT Vs. VMware Software India Pvt. Ltd.(Supra) is misplaced. The material distinction in that case is that the AO had completed the final assessment without awaiting the TPO’s order giving effect to the directions of the Ld. DRP. Instead, the AO adopted the transfer pricing adjustment contained in the draft assessment order and proposed to give effect to any subsequent increase or decrease through rectification under section 154 of the Act. In those circumstances, the final assessment had been completed before the effect of the DRP’s directions on the transfer pricing adjustment was determined. The assessment order was, therefore, held not to have been passed in conformity with the directions of the Ld. DRP as required under section 144C(13) of the Act. The facts of the present case stand on a different footing. Here, the Ld. TPO passed the order giving effect to the directions of the Ld. DRP on 16.12.2025, and the AO passed the final assessment order thereafter on 17.12.2025. The transfer pricing adjustment incorporated in the final assessment order was the adjustment sustained by the Ld. DRP. The AO neither substituted a different determination of the arm’s length price nor proceeded on the basis that the transfer pricing adjustment would be determined subsequently. The omission concerns the consequential adjustment required to avoid double disallowance of the interest expenditure already disallowed under section 94B of the Act. We do not consider that omission inconsequential, since the direction requiring avoidance of double disallowance was also binding upon the AO. Nevertheless, the nature of the omission is relevant in determining the appropriate relief. The record indicates that the transfer pricing determination upheld by the Ld. DRP was adopted in the final assessment order, whereas the consequential relief relating to the overlapping disallowance was not correctly reflected in the computation. The defect can, therefore, be remedied by directing the AO to give full effect to the existing directions of the Ld. DRP, without requiring a fresh determination of the arm’s length price. 14. The other decisions of the coordinate benches relied upon by the Ld. AR also do not warrant quashing of the assessment order in the facts before us. The principle that the AO must comply with the binding directions of the Ld. DRP is not in dispute. However, its application must take into account the nature of the departure and the relief necessary to correct it. In the present case, the omission relates to giving computational effect to the alternate relief directed by the Ld. DRP. Consequently, the decisions concerning completion of an assessment contrary to the substantive determination directed by the Ld. DRP are distinguishable. Accordingly, we are unable to accept the contention that the entire final assessment order deserves to be quashed merely because the adjustment required to avoid double disallowance was omitted. At the same time, the assessee is entitled to implementation of the direction issued by the Ld. DRP. To the extent that the interest expenditure already disallowed under section 94B of the act forms part of the expenditure subjected to the transfer pricing adjustment, the same expenditure cannot be added again contrary to that direction. Considering the facts and circumstances of the case, we restore this issue to the file of the AO to verify the amount of interest expenditure already disallowed by the assessee under section 94B of the Act and its overlap with the expenditure covered by the transfer pricing adjustment. The AO shall thereafter recompute the consequential addition and the total income strictly in accordance with the directions of the Ld. DRP, ensuring that the same expenditure is not subjected to double disallowance. The AO shall afford adequate opportunity of being heard to the assessee and pass a reasoned order in accordance with law. Accordingly, the plea seeking quashing of the final assessment order is rejected, and Ground No. 3 is partly allowed for statistical purposes in the above terms. 15. Ground Nos. 4 and 5 relate to the transfer pricing adjustment in respect of interest paid by the assessee on CCDs. The Ld. AR submitted that the assessee had paid interest of Rs. 133,41,28,419/- on CCDs issued to its AEs. The Ld. TPO determined the arm’s length price of such interest at Nil by recharacterizing the CCDs as equity, and the adjustment was incorporated by the AO in the assessment order. The Ld. AR contended that CCDs retain their character as debt until their actual conversion into equity and, therefore, interest payable thereon during the period preceding conversion is allowable as business expenditure. In support of this contention, the Ld. AR relied upon the decision of the Chennai Bench of the Tribunal in the case of Stahl India Pvt. Ltd. Vs. DCIT, IT(TP)A No. 52/CHNY/2024, dated 10.12.2024, for the Assessment Year 2020-21. He submitted that the Tribunal, after considering the decision of the Hon’ble Rajasthan High Court in the case of CIT Vs. Secure Meters Ltd., 321 ITR 611, and the decision of the Bangalore Bench of the Tribunal in CAE Flight Training (India) Pvt. Ltd., 2019 (8) TMI 554, held that the TPO exceeded his jurisdiction in recharacterizing CCDs as equity. The Tribunal further held that CCDs constitute debt until their conversion into equity and that interest payable thereon during such period is deductible expenditure.

“7. Brief facts in relation to above issue are as follows:- 7.1 The assessee company on 25.04.2014, issued 76,88,412 CCDs of Rs.190 to its AE, Stahl Netherlands BV ("Stahl Netherlands") for Rs.146 crores. The CCDs are convertible into 76,88,412 equity shares of Rs.10 each and would be converted into equity shares on 30.04.2024 or at any earlier time at the discretion of debenture holder. The coupon rate for the CCD was fixed at 11.00% payable per annum. During the impugned AY, the assessee has accrued interest on CCDs amounting to Rs.9,58,98,001/-. 7.2 The TPO treated the CCDs as equity thereby treating the ALP of interest on CCDs as 'NIL' and arrived at a TP adjustment of Rs.9,58,98,001/-. The DRP upheld the TPO's order. 7.3 Aggrieved by the TPO's/DRP's orders, the assessee raised this issue before the Tribunal. The ld.AR submitted that the TPO has exceeded his jurisdiction in re-characterizing CCD's as equity. It is submitted that it is judicially well settled proposition that CCD's constitute debt and interest payable thereon is deductible expenditure till the same is converted into equity. In this context, the ld.AR relied on various judicial pronouncements. The reliance placed by the TPO and DRP on the judgment of the Hon'ble Apex Court in the case of Narendra Kumar Maheshwari reported in AIR 1989 (SC) 2138 and the RBI, FDI policy and FEMA regulations were distinguished by the ld.AR. 7.4 The ld.DR supported the orders of the AO and the DRP. 7.5 We have heard rival submissions and perused the material on record. The TPO exceeded his jurisdiction in recharacterizing CCDs as equity, in line with thin capitalization, which cannot be applied in the present case. It has been a judicially well settled proposition that CCDs constitute debt and interest payable thereon is a deductible expenditure till the time the same are converted into equity. The Hon'ble Rajasthan High Court in the case of Secure Meters Ltd reported in 321 ITR 611 (Raj), held that the debentures when issued is a loan, and therefore, whether it is convertible, or non-convertible, does not militate against the nature of the debenture, being loan. The relevant finding of the Hon'ble High Court read as follows:- "8. Thus, it was held, that the expenditure incurred in procuring the loan was revenue expenditure within Section 10(2)(xv) of the old Income Tax Act, which corresponds to Section 37 of the present Act. By going through the said judgment it further transpires, that the Hon'ble Supreme Court also proceeded to examine the aspect of purpose of raising loan, and its immediate or subsequent utilisation for different purpose, and examined, that even if a loan is raised for purchasing raw material, and after raising the loan the company finds it un-necessary to buy raw material and spends the amount on capital asset, still it cannot be said to be capital expenditure, as it was held, that purpose for which the new loan was required was irrelevant to the question as to whether the expenditure for obtaining loan was revenue or capital expenditure. We are told that relying on this judgment, many of the High Courts of the country have consistently taken the view, that the expenditure incurred in issuing any debentures, and raising loan on debentures, is admissible, obviously because the debenture is also a loan. 9. At this stage it was contended by the learned counsel for the Revenue, that a distinction should be drawn between the convertible, and non-convertible debentures, inasmuch as if the debenture is converted into shares, then it partakes the character of capital, and in that event, the expenditure would not be revenue expenditure, and would be capital expenditure. Learned counsel for the assessee informs, that though it has not come on record so far, but as a matter of fact the debentures issued were of convertible nature. Then, the learned counsel for the assessee argued, relying upon the judgment of Calcutta High Court, in C.I.T. Vs. East India Hotels, reported in 252 ITR-860, that the expenditure incurred, even in raising loan by convertible debenture would also be admissible as revenue expenditure. The Calcutta High Court had adopted the reasoning, that conversion of debentures results into repayment of loan, and issuance of shares. This is one aspect of the matter. In our view, the other more important aspect of the matter is, that the Hon'ble Supreme Court in India Cement's case has clearly excluded this aspect from consideration, by holding, that it is irrelevant to consider the object, with which the loan was obtained. Admittedly the debentures when issued is a loan, and therefore, whether it is convertible, or non-convertible, does not militate against the nature of the debenture, being loan, and therefore, the expenditure incurred would be admissible as revenue expenditure. 10. Thus, we do not find any error in the finding of the learned Tribunal on this aspect also. Consequently, question no. 2 also as framed, is required to be, and is, answered against the Revenue, and in favour of the assessee." 7.6 The Bangalore Bench of the ITAT in the case of CAE Flight Training (India) Pvt. Ltd., reported in 2019 (8) TMI 554 has held that CCDs are to be considered as Debt only till they are converted as equity. Further, we place reliance on the following judicial pronouncement, which have upheld the same view:- i) Bangalore Bench of the Tribunal in the case of Embassy One Developers Pvt. Ltd., 2020 (12) TMI 110 ii) Mumbai Bench of the Tribunal in the case of Indorama Ventures Oxides Ankleshwar (P.) Ltd., TS-471-ITAT-2024 iii) Bangalore Bench of the Tribunal in the case of Wework India Management (P.) Ltd., reported in 150 taxmann.com 432 7.7 The reliance by the Ld. DRP on the judgment of the Hon'ble Supreme Court in the case of Narendra Kumar Maheshwari, supra is misplaced. The Hon'ble Supreme Court judgment was in the context of Companies Act, 1956 and Securities (Contract and Regulation) Act, 1956 and the issue was whether Controller of Capital issues has the power to allot inter alia CCD. Further, the reliance placed by the DRP on the RBI FDI policy and FEMA regulations is misplaced. Since in the case of fully convertible debentures, there is no future repayment obligation, the same was considered as equity for the purpose of FDI policy. This definition of convertible debentures given by RBI is in the context of FDI policy to exercise control on future re- payment obligations in convertible foreign currency. Such definition of the term convertible debentures cannot be applied in other context such as allowability of interest on such debentures during pre-conversion period or regarding payment of dividend on such convertible debentures during reconversion period or regarding granting of voting rights to the holders of such convertible debentures before the date of conversion. This was also upheld by the Bangalore Bench of the Tribunal in the case of CAE Flight Training (India) Pvt. Ltd., (supra).” 18. On perusal of the above, we find that the Tribunal, after considering the decisions of Hon’ble Rajasthan High Court in the case of CIT Vs. Secure Meters Ltd (Supra). and the decision of the Bangalore Bench of the Tribunal in the case of CAE Flight Training (India) Pvt. Ltd. (Supra), held that CCDs retain their character as debt until conversion into equity. It further held that the TPO could not recharacterize such instruments as equity and deny the interest payable thereon merely because they were compulsorily convertible at a future date. Following the aforesaid decision of the Chennai Bench of the Tribunal, we accept the contention of the assessee that the CCDs constitute debt until their actual conversion into equity and that interest payable thereon during such period is allowable as business expenditure, subject to determination of its arm’s length rate. Accordingly, the determination of the arm’s length price of interest at Nil by recharacterizing the CCDs as equity cannot be sustained.

“ 23. In view of this matter and considering the facts of the present cases, and also by considering ratios of various High Courts, we are of the considered view, that once the CCDs issued by the appellant are denominated in Indian currency, the interest payment on the said CCDs is to be benchmarked with reference to the rate of interest applicable to the loans extended in currency concerned. Since the CCDs issued by the appellant are in the nature of rupee denominated loan, in our considered view, FCCD/CCD cannot be construed on par with the foreign currency loan for the purpose of benchmarking. Further, LIBOR plus 200 basis points being the interest rate prevalent in the international market and applicable to foreign currency loans cannot be applied to benchmark interest on the appellants CCDs. Further, the said interest has to be benchmarked against the interest rates prevailing in the domestic market and similar debt instrument, such as the domestic prime lending rate (PLR). Therefore, we are of the considered view that as regards TP adjustment made in respect of interest paid/payable on CCD/NCD/other debentures, which are denominated in Indian currency, the benchmark is to be by applying PLR against LIBOR. Accordingly, we answer the question referred to for the Special Bench as under : Whether as regards TP adjustment (i) Yes, in favour of the assessees. (ii) made in respect of interest paid /Interest paid/payable on FCCDs/NCDs/payable on FCCDs/NCDs/ other debentures, which are denominated debentures, which are denominated in in Indian currency to be bench marked by Indian currency the benchmarking is applying PLR rates." to be made by applying PLR as against LIBOR?” 22. On perusal of the above, we find that the Special Bench specifically held that where CCDs are denominated in Indian currency, the interest payable thereon is to be benchmarked with reference to the rate of interest applicable to loans extended in the currency concerned. It accordingly held that interest on CCDs denominated in Indian rupees should be benchmarked by applying the PLR. In the present case, there is no dispute that the CCDs issued by the assessee are denominated in Indian rupees. Therefore, respectfully following the decision of the Special Bench in the case of Hyderabad Infratech Pvt. Ltd. Vs. JCIT (supra), we accept the contention of the assessee and direct the TPO/AO to benchmark the interest paid on the CCDs by applying the applicable SBI PLR and recompute the transfer pricing adjustment, if any, accordingly, after affording a reasonable opportunity of being heard to the assessee. Accordingly, ground nos. 4 and 5 are partly allowed for statistical purposes. 23. Ground Nos. 6 and 7 relate to the addition of Rs. 133,41,28,419/- made by the AO on account of interest on CCDs. The Ld. AR submitted that, out of the said amount, the assessee had already disallowed Rs. 124,88,19,430/- under section 94B of the Act in its return of income. Therefore, the addition made by the AO resulted in a double disallowance to the extent of Rs. 124,88,19,430/-. While adjudicating ground No. 3 concerning the legal issue, we have restored the matter to the file of the AO to give effect to the directions of the Ld. DRP. The issues raised in ground Nos. 6 and 7 are subsumed in our findings on ground No. 3. Accordingly, these issues are also restored to the file of the AO for giving effect to the directions of the Ld. DRP after necessary verification. The AO shall verify the disallowance already made by the assessee under section 94B of the Act and ensure that the same amount is not disallowed twice. Accordingly, ground nos. 6 and 7 are allowed for statistical purposes. 24. Under ground No. 8, the Ld. AR submitted that the assessee was eligible for set-off of brought forward losses of Rs. 110,25,79,507/-. However, the AO allowed set-off only to the extent of Rs. 51,28,20,033/-, resulting in a short allowance of Rs. 58,97,59,474/-. Since this issue requires factual verification, we restore the same to the file of the AO with a direction to verify the availability and eligibility of the brought forward losses and allow them to set-off in accordance with law, after affording a reasonable opportunity of being heard to the assessee. Accordingly, ground no. 8 is allowed for statistical purposes. 25. Under ground No. 9, the Ld. AR submitted that the book profit of the assessee was Rs. 52,71,91,564/-, whereas the AO adopted book profit of Rs. 74,43,68,945/- for the purposes of section 115JB of the Act. The discrepancy requires factual verification. Accordingly, we restore this issue to the file of the AO with a direction to verify the computation of book profit furnished by the assessee and determine the correct book profit under section 115JB of the Act in accordance with law, after affording a reasonable opportunity of being heard to the assessee. Accordingly, ground no. 9 is allowed for statistical purposes. 26. Under ground no. 10, the Ld. AR submitted that the assessee was eligible for TDS credit of Rs. 15,96,76,138/-. However, the AO granted credit of only Rs. 15,92,19,820/-, resulting in a short grant of TDS credit of Rs. 4,56,318/-. Since this issue also requires factual verification, we restore the same to the file of the AO with a direction to verify the assessee’s claim and grant the correct amount of TDS credit in accordance with law, after affording a reasonable opportunity of being heard to the assessee. Accordingly, ground no. 10 is allowed for statistical purposes.

Order pronounced in the Open Court on 13th October, 2026. Sd/- Sd/- (RAVISH SOOD) (MADHUSUDAN SAWDIA) JUDICIAL MEMBER ACCOUNTANT MEMBER Hyderabad, dated 13th October, 2026. Vinodan/sps

Copy to: S.No Addresses 1 TSI Business Parks (Hyderabad) Private Ltd, S.Y. No.115 (Part), Waverock Building, TSIIC IT/ITeS SEZ, Nanakramguda Village, Gachibowli, Peeramcheru, Hyderabad 500008 2 Dy. CIT, Circle 2(1) Room No. 514, 5th Floor, Signature Towers, Sy. No.6(P) of Kondapur, Sy. No.37(P) of Kothaguda, Opp: Botanical gardens, Serilingampalli(M) RR Distt., Hyderabad 500084 3 Pr. CIT/Director of Income Tax (IT&TP), Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File

By Order TUMMALACHARLA Digitally signed by TUMMALACHARLA LAKSHMI NARAYANA DN: cn=TUMMALACHARLA LAKSHMI LAKSHMI NARAYANA, c=IN, o=INCOME TAX APPELLATE TRIBUNAL, ou=INCOME TAX NARAYANA APPELLATE TRIBUNAL, CHENNAI BENCH Date: 2026.10.14 09:58:37 +05'30'

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