GOPINADHA NAGESWARA SARMA GANDHAM,HYDERABAD vs. INCOME TAX OFFICER, NAGARAMPALEM

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ITA 573/VIZ/2026Status: DisposedITAT Visakhapatnam16 October 2026AY 2020-2119 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the compensation received by the assessee from BSNL under the Voluntary Retirement Scheme – 2019 is eligible for exemption under Section 10(10B) of the Act. The Tribunal noted that the issue of entertaining fresh claims at the appellate stage was addressed by the Hon'ble High Court for the State of Telangana, which permitted the filing of revised returns and directed the assessing officer to consider the case on merits. Furthermore, the Tribunal acknowledged the consistent view taken by various Benches of the Tribunal across the country, which held that compensation received by BSNL employees under VRS-2019 is akin to retrenchment compensation eligible for exemption under Section 10(10B). Therefore, the Tribunal directed the Assessing Officer (AO) to verify the assessee's claim in light of these findings and allow the exemption under Section 10(10B) in accordance with law. Regarding the additional ground on leave encashment under Section 10(10AA)(i), the Tribunal admitted the ground, following the Supreme Court's decision in National Thermal Power Corporation Ltd. v. CIT, and set aside the issue to the AO for verification, considering the Kerala High Court's decision in Sanchar Nigam Pensioners Welfare Association v. Union of India.

What were the facts?

The assessee, Shri Gopinadha Nageswara Sarma Gandham, an ex-employee of BSNL, received ex-gratia compensation under the BSNL Voluntary Retirement Scheme–2019. For AY 2020-21, he received Rs. 15,58,069, claimed Rs. 5,00,000 as exempt under Section 10(10C), and offered the balance to tax. For AY 2021-22, he received Rs. 33,72,324 and offered the entire amount to tax. The assessee later sought exemption under Section 10(10B) before the Addl./Joint CIT(A), citing lack of awareness and incorrect advice, with significant delays in filing the appeals. The Addl./Joint CIT(A) condoned the delays but dismissed the appeals, holding that a fresh claim could not be entertained at the appellate stage and that the compensation was not retrenchment compensation.

What were the issues?

1. Whether the appellate authority has the power to entertain a fresh claim for exemption under Section 10(10B) of the Income-tax Act, 1961, at the appellate stage, when such a claim was not made in the original return of income, especially when the assessee attributes the omission to lack of awareness and incorrect professional advice? Assessee's Contention: The assessee argued that the appellate authority has the power to entertain fresh claims, and the Addl./Joint CIT(A) erred in rejecting the claim without considering judicial precedents. The assessee relied on various ITAT Benches' decisions that allowed similar claims for BSNL employees under Section 10(10B). Revenue's Contention: The Revenue supported the Addl./Joint CIT(A)'s order, arguing that a fresh claim for exemption under Section 10(10B) could not be entertained at the appellate stage as it was not claimed in the original returns. 2. Whether the compensation received by BSNL employees under the Voluntary Retirement Scheme–2019 is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, as retrenchment compensation? Assessee's Contention: The assessee contended that the compensation received under VRS-2019 is akin to retrenchment compensation contemplated under Section 10(10B) and is eligible for exemption, citing decisions of various ITAT Benches (Ahmedabad, Chennai, Bangalore, Pune). Revenue's Contention: The Revenue argued that the compensation received under VRS-2019 could not be treated as retrenchment compensation eligible for exemption under Section 10(10B).

Which sections of the Income-tax Act were involved?

Section 10(10C),Section 10(10B),Section 143(1),Section 10(10AA)(i)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH,

आदेश / ORDER PER MANJUNATHA G., A.M :

The captioned appeals filed by assessee are directed against separate, but identical, orders of the learned Addl./Joint Commissioner of Income Tax (Appeals) – Madurai, dated 30.03.2026, relating to the assessment years 2020-21 and 2021- 22. Since common issues are involved in both the appeals, they were heard together and are being disposed of by this consolidated order for the sake of convenience and brevity.

2.

Briefly stated, the facts of the appeals filed by the assessee are that the assessee, Shri Gopinadha Nageswara Sarma Gandham, was an employee of the Department of Telecommunications, Government of India, and was subsequently absorbed by Bharat Sanchar Nigam Limited (BSNL), a Central Government Public Sector Undertaking. Pursuant to the decision of the Union Cabinet for revival and restructuring of BSNL, the Government of India approved the Voluntary Retirement Scheme–2019 for eligible BSNL employees. The assessee opted for the said scheme and received ex-gratia compensation from BSNL. For the Assessment Year 2020-21, the assessee received ex-gratia compensation of

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Rs.15,58,069/- and claimed exemption of Rs.5,00,000/- under Section 10(10C) of the Income-tax Act, 1961 (the Act), offering the balance amount of Rs.10,58,069/- to tax. The assessee filed his return of income on 29.12.2020, which was processed by the Central Processing Centre (CPC), Bengaluru, under Section 143(1) of the Act on 06.01.2021, accepting the returned income without any adjustment. For the Assessment Year 2021-22, the assessee received ex-gratia compensation of Rs.33,72,324/- under BSNL VRS-2019 and offered the entire amount to tax. The assessee filed his return of income on 04.11.2021, which was processed under Section 143(1) of the Act on 05.03.2022, accepting the returned income without any adjustment.

3.

The assessee filed the captioned appeals before the learned Addl./JCIT(A), inter alia, making a fresh claim of exemption under Section 10(10B) of the Act in respect of the compensation received from BSNL under the Voluntary Retirement Scheme–2019. The assessee contended that, due to lack of awareness of the correct legal position and incorrect professional advice, he could not claim the exemption under Section 10(10B) of the Act while filing his respective returns of income. In respect of the Assessment Year

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2020-21, the assessee had claimed exemption of Rs.5,00,000/- under Section 10(10C) of the Act and offered the balance compensation to tax, whereas, for the Assessment Year 2021-22, the entire compensation was offered to tax. Subsequently, upon becoming aware of judicial precedents holding that compensation received by BSNL employees under VRS-2019 was eligible for exemption under Section 10(10B) of the Act, the assessee preferred appeals before the learned Addl./JCIT(A), along with petitions for condonation of delay, seeking exemption in respect of the compensation received under the said scheme.

4.

The learned Addl./JCIT(A), after considering the relevant facts of the respective cases, condoned the delay in filing both appeals. In respect of the Assessment Year 2020-21, there was a delay of 4 years, 11 months and 2 days, whereas, in respect of the Assessment Year 2021-22, there was a delay of 3 years, 9 months and 5 days. Thereafter, the learned Addl./JCIT(A) proceeded to adjudicate the issues raised by the assessee. The learned Addl./JCIT(A) observed that the assessee had not claimed exemption under Section 10(10B) of the Act in the respective returns of income. While considering the decision of the Hon’ble

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Bombay High Court in the case of CIT v. Pruthvi Brokers & Shareholders Pvt. Ltd. the learned Addl./JCIT(A) observed that the said decision did not discuss the powers of the CIT(A)/JCIT(A) to allow a fresh claim made by the assessee. Accordingly, the learned Addl./JCIT(A) held that the fresh claim of exemption could not be entertained at the appellate stage and that the assessee could make such a claim by filing a revised return of income or a rectification application. On the merits of the claim, the learned Addl./JCIT(A) held that the compensation received under BSNL VRS-2019 was towards voluntary retirement and did not constitute retrenchment compensation eligible for exemption under Section 10(10B) of the Act. Accordingly, the learned Addl./JCIT(A) dismissed both appeals.

5.

Aggrieved by the orders of the learned Addl./JCIT(A), the assessee is now in appeals before the Tribunal.

6.

The learned counsel for the assessee, Shri Nanduri Venkata Vithal, C.A., referring to the appeals filed by the assessee and the consequential orders passed by the learned Addl./JCIT(A), submitted that the learned Addl./JCIT(A), after condoning the delay in filing both the appeals, dismissed the appeals on the

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ground that the fresh claim made by the assessee for exemption u/s 10(10B) of the Act was not maintainable at the appellate stage. He submitted that the assessee had made the fresh claim of exemption u/s 10(10B) of the Act on account of subsequent judicial precedents rendered in favour of similarly placed BSNL employees on the issue of taxability of compensation received under the VRS-2019 Scheme. He further submitted that, due to incorrect professional advice and lack of awareness of the correct legal position, the assessee could not claim the benefit of exemption u/s 10(10B) of the Act while filing the respective returns of income. He contended that the appellate authority has the power to entertain a fresh claim in accordance with law and that the learned Addl./JCIT(A) had erred in rejecting the claim without considering the judicial precedents relied upon by the assessee. He further submitted that similar claims made by other BSNL employees have been considered by various Benches of the Tribunal and relief has been granted by allowing exemption u/s 10(10B) of the Act. Therefore, he submitted that the fresh claim made by the assessee should be admitted and appropriate relief be granted in accordance with law.

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7.

The learned counsel for the assessee, on the issue of taxability of compensation received from BSNL under the VRS-2019 Scheme, submitted that the issue is covered in favour of the assessee by the decisions of various Benches of the Tribunal, including the ITAT, Ahmedabad, Chennai, Bangalore and Pune, wherein it has been held that compensation received by employees of BSNL under the VRS-2019 Scheme is akin to retrenchment compensation contemplated u/s 10(10B) of the Act and, in view of the second proviso to section 10(10B) of the Act, the compensation is eligible for exemption. He further submitted that, in cases where the assessee had made a fresh claim for exemption during the appellate proceedings, the claim had been entertained and the matter was directed to be considered by the A.O. in accordance with law. Therefore, he submitted that the fresh claim made by the assessee for exemption u/s 10(10B) of the Act should be admitted and appropriate directions be issued to the A.O. to verify the claim and allow exemption in accordance with law.

8.

The learned Senior A.R. for the Revenue, Shri A.P. Babu, on the other hand, supporting the orders of the learned Addl./JCIT(A), submitted that the assessee had made a fresh

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claim for exemption u/s 10(10B) of the Act before the learned Addl./JCIT(A), which was not claimed in the respective returns of income filed by the assessee and, therefore, such a fresh claim could not be entertained at the appellate stage. Accordingly, he submitted that the learned Addl./JCIT(A) had rightly rejected the fresh claim made by the assessee and that the orders of the learned Addl./JCIT(A) did not call for any interference.

9.

The learned Senior A.R. for the Revenue further submitted that the compensation received by the assessee from BSNL under the VRS-2019 Scheme could not be treated as retrenchment compensation eligible for exemption u/s 10(10B) of the Act. He submitted that, as per the Scheme introduced by BSNL itself, it was clear that the same was a Voluntary Retirement Scheme and the assessee could either accept or decline the Scheme, and there was no compulsion on the assessee to opt for VRS under any circumstances. Therefore, re-characterisation of the compensation received by the assessee under the VRS-2019 Scheme as retrenchment compensation and allowing exemption u/s 10(10B) of the Act was not justified. The learned Senior A.R. further submitted that, for the assessment year 2020-21, the assessee

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had received compensation of Rs.15,58,069/-, claimed exemption of Rs.5,00,000/- u/s 10(10C) of the Act and offered the balance amount of Rs.10,58,069/- to tax. For the assessment year 2021- 22, the assessee had received compensation of Rs.33,72,324/- under the VRS-2019 Scheme and offered the entire amount to tax. He further submitted that the employer, i.e., BSNL, had also deducted tax at source on such compensation in accordance with the applicable provisions of the Act. From the above, it is clear that the compensation received by the assessee from BSNL was compensation under a Voluntary Retirement Scheme falling u/s 10(10C) of the Act and not retrenchment compensation falling u/s 10(10B) of the Act. Therefore, he submitted that the subsequent claim made by the assessee for exemption u/s 10(10B) of the Act could not be accepted and that both the appeals filed by the assessee should be dismissed.

10.

We have heard both parties, perused the material available on record and had gone through the orders of the authorities below. We have also carefully considered the plethora of judicial precedents referred to by the learned counsel for the assessee on these issues. Insofar as the issue relating to the condonation of

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delay is concerned, we find that the very same issue has been considered by the Coordinate Bench of the ITAT, Bengaluru, in the case of Basappa Balarama and Murthy Rangappa (supra), wherein, in para 15, the Tribunal has held as under:

“15. However, with respect to condonation of delay, the ld. AR submitted that the ld. CIT(A) should have condoned the delay as in the case of 72 cases before the Coordinate Benches across the country in the case of BSNL employees on identical facts and circumstances, delay has been condoned by the ld. CIT(A) itself ranging from 900 to 2000 days. The assessee has produced the list of 72 cases where the delay is condoned by the ld. CIT(A). Further in case of 144 appeals, the Coordinate Benches have condoned the delay in the case of BSNL employees on identical facts and circumstances. Thus on the parity itself, the appeal of the assessee should have been admitted by the ld. CIT(A). Accordingly, I reverse the order of the ld. CIT(A) in not condoning the delay.”

11.

From the findings given by the Coordinate Bench of the ITAT, Bengaluru, we find that, in identical cases of BSNL employees, the delay has been condoned by the learned Addl./JCIT(A) himself in a number of cases, even though the delay ranged between 900 days and 2000 days. The Tribunal further noted that, in more than 144 cases, the Coordinate Benches of the Tribunal have condoned the delay in the cases of BSNL employees on identical facts and circumstances. In the present case, we find that the learned Addl./JCIT(A) has already condoned the delay of 4 years, 11 months and 2 days for A.Y. 2020-21 and 3 years, 9 months

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and 5 days for A.Y. 2021-22 in filing the appeals. Therefore, the issue of condonation of delay does not arise for our consideration. Accordingly, we proceed to consider the other issues raised by the assessee in the present appeals.

12.

Having said so, let us come back to the issue on hand. Admittedly, the assessee is an employee of BSNL and opted for the Voluntary Retirement Scheme - 2019 and received compensation during the relevant financial years. It is also an admitted fact that the assessee had filed his respective returns of income and offered the compensation received from BSNL to tax after claiming exemption u/s 10(10C) of the Act, wherever claimed, and the same has been accepted by the A.O. in the intimations issued u/s 143(1) of the Act. However, the assessee made a fresh claim for exemption in respect of the compensation received from BSNL under the Voluntary Retirement Scheme - 2019 u/s 10(10B) of the Act for the first time before the learned Addl./JCIT(A). The learned Addl./JCIT(A) rejected the fresh claim on the ground that the same could not be entertained at the appellate stage and, on merits, held that the compensation received under the Voluntary

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Retirement Scheme was not eligible for exemption u/s 10(10B) of the Act.

13.

The learned counsel for the assessee has cited a plethora of judicial precedents, including the decisions of various Benches of the Tribunals, and we find that, in a number of cases, the Coordinate Benches of the Tribunals across the country have taken a consistent view and held that compensation received by employees of BSNL under the Voluntary Retirement Scheme - 2019 is exempt u/s 10(10B) of the Act. The Coordinate Benches have further directed the A.O. to allow exemption in respect of the compensation received from BSNL u/s 10(10B) of the Act, after considering the revised statements of total income filed by the assessees, and to determine the tax payable, if any, in accordance with law.

14.

We further note that, the Coordinate Bench of the ITAT, Chennai Bench in the case of Shri Sekar Gnanaprakasam Vs. DCIT in ITA Nos.1608 & 1609/CHNY/2026, dated 21.05.2026, under an identical set of facts, held as under:

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“11. We have heard the rival submissions and perused the material available on record, including the written submissions filed by the assessee and the judicial precedents relied upon. The short issue involved in the present appeals is whether the ex-gratia compensation received by the assessee under the BSNL VRS-2019 scheme is eligible for exemption u/s.10(10B) of the Act. From the materials placed before us, it is evident that the BSNL VRS-2019 scheme was formulated pursuant to the revival package approved by the Government of India and the Union Cabinet on 23.10.2019. It is further borne out from the records that the compensation payable under the scheme was funded through Government budgetary support. During the course of hearing, the assessee present submitted that though the nomenclature is mentioned as VRS, it is in effect a retrenchment scheme, since BSNL could not pay salary to employees just before rolling out the scheme. Therefore, the scheme partakes the character of a Government-approved retrenchment compensation scheme and cannot be treated as an ordinary voluntary retirement scheme simpliciter. 12. We further find that identical issue had come up for consideration before the Chandigarh Bench of the Tribunal in the case of Harish Kumar vs. ITO, wherein the Tribunal held that the ex-gratia compensation received under BSNL VRS-2019 is eligible for exemption u/s.10(10B) of the Act. Similar view has also been consistently taken by various appellate authorities across the country in the cases relied upon by the assessee. The Revenue has not brought on record any contrary judicial precedent to take a different view in the matter. 13. Considering the facts and circumstances of the case and respectfully following the judicial precedents cited supra, we hold that the ex-gratia compensation received by the assessee under the BSNL VRS-2019 scheme is eligible for exemption u/s.10(10B) of the Act. Consequently, the additions made by taxing the ex-gratia compensation are directed to be deleted. The AO is also directed to grant consequential relief, in accordance with law, in respect of exemption claimed u/s.10(10AA) of the Act, if otherwise found eligible.”

15.

We further note that, the Hon'ble High Court for the State of Telangana in the case of Sri Vissamsetty Ramakrishna Vs. The PCIT-4 and two others in W.P.No.19498 of 2026, vide order dated 15.07.2026 has considered an identical issue of claim of exemption under Section 10(10B) of the Act, in light of challenging

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the order passed by the Pr.CIT-4 under Section 119(2)(b) of the Income-tax Act, 1961 rejecting the application filed by the assessee seeking permission to file revised returns of income for making a claim under Section 10(10B) of the Act, and while allowing the Writ Petition filed by the assessee, quashed the impugned order and remitted the matter to respondent No.1 with a direction to permit the petitioner to file/submit revised returns of income for claiming exemption u/s 10(10B) of the Act, and thereafter consider the claim on merits. The relevant findings of the Hon'ble High Court are as under:

“6. When we look into the averments made in respect of identical claims being allowed by the Benches of Income Tax Appellate Tribunal at Chandigarh, Ahmedabad, Pune, Mumbai, Indore and Bangalore, in identically placed BSNL retirees, this Court is of the considered view that when similar fact was brought to the notice of the respondent- Department, the respondents ought to have appreciated the bona fides of the petitioner and the application filed by the petitioner under Section 119(2)(b) of the Act seeking condonation of delay to file revised ITRs for the Assessment Years 2020-21 and 2021-22, ought to have been considered by the respondent-Department with a more pragmatic and liberal approach, by appreciating the genuine hardship that the petitioner had been put to or would be put to, in case if the application seeking for condonation is not allowed. 7. A plain reading of the impugned order does not disclose whether respondent No.1 had considered and appreciated the orders passed by Benches of Income Tax Appellate Tribunal at Chandigarh, Ahmedabad, Pune, Mumbai, Indore and Bangalore, in identically placed BSNL retirees, and also by other Commissioner of Income Tax (Appeals) in its proper perspective, more particularly, when those orders have not been challenged any further and they have attained finality. 8. To make things worse for the respondent-Department, learned counsel for the petitioner has produced before the Court another order passed by the Income Tax Appellate Tribunal, Hyderabad 'SMC' Bench, at

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Hyderabad, dated 03.07.2026, wherein in a batch of appeals the lead matter being I.T.A.Nos.903 and 904/HYD/2026, wherein similar view had been reiterated by the Bench. In the said judgment, it appears that similar view has also been followed earlier by the Income Tax Appellate Tribunal, Chennai Bench in the case of Shri Sekar Gnanaprakasam vs. DCIT¹ and also by the Income Tax Appellate Tribunal, Bengaluru Bench in the case of Basappa Balarama and Murthy Rangappa vs. Income Tax Officer, Ward 12, wherein the Coordinate Benches across the country have granted relief and condoned the delay. 9. For all the aforesaid said reasons and also taking into consideration the consistent view taken by various Benches of the Tribunal across the country, we are inclined to allow the instant writ petition. The impugned order passed by respondent No.1 under Section 119(2)(b) of the Income Tax Act, 1961 bearing DIN and Letter No.ITBA/COM/F/17/2026- 27/1089643736(1), dated 12.06.2026, for the Assessment Years 2020- 21 and 2021-22, stands quashed and set aside. The matter stands remitted to respondent No.1. The petitioner herein is permitted to file / submit revised Income Tax returns. Thereafter, the respondent No.1 is directed to consider the case of petitioner on merits.” 16. Coming back to the additional ground raised in ITA No. 573/Viz/2026 for A.Y. 2020-21, seeking exemption towards leave encashment u/s 10(10AA)(i) of the Act, the learned counsel for the assessee submitted that the additional ground filed by the assessee raises a legal issue which can be taken up at any stage of the proceedings, including the pending proceedings before the Tribunal. Therefore, in view of the decision of the Hon’ble Supreme Court in the case of National Thermal Power Corporation Ltd. v. CIT reported in (1998) 229 ITR 383 (SC), the additional ground filed by the assessee should be admitted.

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17.

The learned Senior A.R. for the Revenue, on the other hand, opposed the admission of the additional ground and submitted that the additional ground should not be admitted at this stage, as the facts relating to whether the claim of the assessee u/s 10(10AA)(i) of the Act is in accordance with the provisions of law cannot be verified unless the relevant details are available.

18.

Having considered the additional ground raised by the assessee and the arguments of both sides, we find that the assessee has raised an additional ground seeking exemption towards leave salary u/s 10(10AA)(i) of the Act and claimed that the omission to make such a claim earlier was due to a bona fide mistake and not on account of any deliberate intention. Further, the issue is stated to be covered by the decision of the Hon’ble Kerala High Court in the case of Sanchar Nigam Pensioners Welfare Association v. Union of India, Writ Petition No. 16360 of 2023, dated 06.02.2026. Considering the fact that the additional ground raises a legal issue and by respectfully following the decision of the Hon’ble Supreme Court in the case of National Thermal Power Corporation Ltd. v. CIT (supra), we admit the additional ground filed by the assessee for adjudication.

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19.

Coming back to the issues on merits, we have heard the learned counsel for the assessee and the learned Senior A.R. for the Revenue on the issue of exemption towards leave salary under section 10(10AA)(i) of the Act, in the light of the decision of the Hon’ble Kerala High Court. The Hon’ble Kerala High Court has considered the very same issue of exemption towards leave salary under section 10(10AA)(i) of the Act in the case of employees of BSNL and, after considering the relevant Central Civil Services (Pension) Rules, 1972 and the Voluntary Retirement Scheme of BSNL, held that the employees of BSNL are entitled to exemption under section 10(10AA)(i) of the Act towards leave salary. In the present case, the assessee has raised a claim for exemption under section 10(10AA)(i) of the Act. However, the facts with regard to fulfilment of the conditions for claiming such exemption are not readily available before us for verification. Therefore, in our considered view, the issue needs to be set aside to the file of the A.O. for consideration. Thus, the ground relating to the claim of exemption under section 10(10AA)(i) towards leave salary is set aside to the file of the A.O., and the A.O. is directed to verify the claim of the assessee in the light of the provisions of section 10(10AA)(i) of the Act and the conditions provided therein, having

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regard to the facts of the present case, and also decide the issue by considering the decision of the Hon’ble Kerala High Court in the case of Sanchar Nigam Pensioners Welfare Association v. Union of India (supra), in accordance with law.

20.

In this view of the matter and considering the facts and circumstances of the case, and also by respectfully following the decisions of the Coordinate Benches of the Tribunal referred to hereinabove and keeping in view the observations made by the Hon’ble High Court for the State of Telangana referred to hereinabove, we are of the considered view that, the compensation received by the assessee from BSNL under the Voluntary Retirement Scheme – 2019 is eligible for exemption u/s 10(10B) of the Act. Therefore, we direct the A.O. to verify the claim of the assessee in the light of our findings given hereinabove and allow the exemption claimed by the assessee u/s 10(10B) of the Act, in accordance with law, and determine the tax payable, if any, by the assessee, in accordance with law.

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21.

In the result, the appeals filed by the assessee in ITA Nos. 573 and 574/Viz/2026 for the assessment years 2020-21 and 2021-22 are allowed for statistical purposes.

Order pronounced in the Open Court on 16th October, 2026.

Sd/- Sd/- श्री विजय पाल राव (मंजूनाथ जी) (VIJAY PAL RAO) (MANJUNATHA G.) उपाध्यक्ष /VICE PRESIDENT लेखा सदस्य/ACCOUNTANT MEMBER

Hyderabad, dated 16.10.2026. TYNM/sps आदेशकी प्रतिलिपि अग्रेषित/ Copy of the order forwarded to:- 1. निर्धारिती/The Assessee : GOPINADHA NAGESWARA SARMA GANDHAM, NO 406, SRI SRINIVASA NIVAS, D.NO.1-5-569/1, ROAD NO 3, NEW MARUTHI NAGAR, CHAITHANYAPURI COLONY S.O, SAROORNAGAR, K.V.RANGAREDDY, 500060, TELANGANA, INDIA, GUNTUR-522004, ANDHRA PRADESH 2. राजस्व/ The Revenue : INCOME TAX OFFICER, NAGARAMPALEM, GUNTUR, ANDHRA PRADESH - 522004, GUNTUR-522004, ANDHRA PRADESH 3. The Principal Commissioner of Income Tax, Guntur विभागीयप्रतिनिधि, आयकर अपीलीय अधिकरण, विशाखापत्तनम / 4. DR, ITAT, Visakhapatnam 5. गार्डफ़ाईल / Guard file

आदेशानुसार / BY ORDER TIRUPATI YAMINI Digitally signed by TIRUPATI YAMINI NAGA MALLESWARI NAGA MALLESWARI Date: 2026.10.16 11:21:25 +05'30' Senior Private Secretary, ITAT, Hyderabad.

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