DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), HYDERABAD vs. MAGNA HOMES, HYDERABAD
Income Tax Appellate Tribunal, HYDERABAD BENCHES “B”, HYDERABAD
Before: SHRI LALIET KUMAR & SHRI MADHUSUDAN SAWDIAAssessment Year: 2018-19
PER LALIET KUMAR, J.M:
This appeal is filed by the Revenue feeling aggrieved by the order passed by the Commissioner of Income Tax (Appeals)
– 11, Hyderabad dated 19.01.2024 for the A.Y. 2018-19. 2
ITA 327/Hyd/2024
The grounds raised by the assessee read as under : “1. Whether the Ld. CIT(A), in the facts and circumstances of the case, is correct in restricting the addition to Rs. 1,51,42,632/-, thereby deletmg the balance addition of Rs. 4,05,62,427/- taking the benchmark of Rs. 1,550/-per sft. And ignoring the admission given by Sri Kondal Rao and Sn P Koteswara Rao partners of the assessee-firm?
Whether the Ld. CIT(A), in the facts and circumstances of the case, is correct that any advance substantially received can be construed as a discounted sale?
Whether the Ld. CIT(A), in the facts and circumstances of the case, is correct in adopting the correct comparable market rate for construction of villa and also for purchase of site cost, which were duly considered by the Assessing Officer while arriving the rate per sft. of Villa?
Whether the Ld. CIT(A), in the facts and circumstances of the case, is correct in adopting the same value of Rs. 1,550/- per sq.ft uniformly for all villas with different specifications including luxurious villas?
The brief facts of the case are that the appellant filed its return of income for AY 2018-19 on 19.07.2018 admitting total loss of Rs.64,33,701/-. A Survey operation u/s. 133A was carried out in the case of the appellant on 13.02.2020, in connection with the Search and seizure operations u/s. 132 of the Act in the case of M/s. Lotus Farms, Bengaluru. During the course of the Survey, certain incriminating material was impounded. When the same was confronted to the partner of the firm, Sri Kondala Rao, he had admitted the undisclosed consideration of Rs.4,09,39,850/- and Rs. 1,47,65,209/- in the hands of the appellant. However, the appellant retracted from the admission given during the survey proceedings and has not admitted in its return of income filed on 19.07.2018. Thereafter, notice under section 148A(b) was issued to the appellant on 16.03.2022 and in response, the appellant has 3 ITA 327/Hyd/2024
not furnished any information. Order u/s. 148A(d) was passed with the prior approval of the specified authority. Accordingly, notice u/s. 148 of the Act was issued to the appellant on 30.03.2022. However, the appellant has not filed any return of income, in response to the said notice. Notices u/s.142(1) were issued subsequently calling for information. After verifying the information submitted by the assessee, Assessing Officer completed the assessment interalia making the addition of Rs.5,57,05,059/-, on account of discounted of sales, thereby assessing the total income at Rs.4,92,71,358/-. Thus, Assessing
Officer completed the assessment u/s 147 of the Act and passed assessment order on 28.03.2023. 4. Aggrieved with such assessment order, the assessee has filed the appeal, before the LD.CIT(A), who dismissed the appeal of the assessee by observing as under :
“In the instant case assessment u/s. 147 of the IT act was completed, making the addition of Rs.5,57,05,059/-, being discounted sales.
Brief facts of the case are that the appellant is a partnership firm, which was constituted during FY 2016-17 i.e AY 2017-18. The appellant is in to real estate activities and construction of residential villas. A survey operation u/s. 133A was conducted on 13.02.2020 in the case of the appellant firm, in connection with the Search and Seizure operations carried out u/s. 132 of the Act in the case of M/s. Lotus Farms,
Bangalore.
It was seen that the appellant firm started construction of residential villas in the name and style of `Magnas Majestic Meadows' near Kollur in the year FY 2016-17. A total of 272 villas were proposed to be constructed on an area of 28.10 acres. During the course of survey proceedings, certain incriminating material was found and impounded, which indicated that 12 villas were sold at a price lower than the average rate at which similar villas were sold. When the same was confronted with the partner of the firm, Shri M Kondal Rao during the Survey, he had 4
ITA 327/Hyd/2024
stated that there have been some discounted sales to certain persons, who were either related to partners of the appellant firm or the firm got benefited from the persons for sales. The details of the villas and reasons thereof for discounted sales, as furnished by the partner during the survey was as under:
S.
No Villa
No.
Name of Purchaser
Sale
Price
/
sg.ft
Explanations for low sale value
1
199
Jnana Deva
Reddy Nalla
927 He facilitated the land deal and helped in getting the land for development
2
190
E. Venkatesh
930 He facilitated the land deal and helped in getting the land for development
3
217
M Kondal Rao 1113 He is one of the partners, hence sold for lesser value.
4
270
M. Surekha
952 She is the wife of one of the partners; shri.
Damodar Reddy. Hence, sold for lesser price
5
202
M Arun
Madhav
1020 He is son of the partners; shri. Damodar
Reddy. Hence, sold for lesser price
175
Nagaraju
1124 He helps is getting sales from his friends and relatives. Hence, sold for lesser price
7
118
Lavudya
Karuna
1440 She helps is getting sales from her friends and relatives. Hence, sold for lesser price
8
115
Danturi
Sireesha
1533 She being one of the first customer and the market during the period was very weak.
Hence, sold for lesser price
9
227
M Padmaja
1824 Customer upfront paid substantial amount and also helped in getting few sales through his influence. Hence, sold for lesser price
10 190
Arun Madhav 1967 He is the son of one of the partners; shri.
Damodar Reddy. Hence, sold for lesser price
11 153
M. Koteswara
Rao
2347 He being one of the partners and have paid substantial amount towards advance.
Hence, sold for lesser price
5
ITA 327/Hyd/2024
12 80
Hari Hara kumar
1263 He is advocate who helped in getting the landed property where the villas and constructed which is litigation in the courts for more than two decades. Hence, sold for lesser price.
In his sworn statement recorded during the survey proceedings, Sri
Kondal Rao has accepted that the sale price is below the market value and has computed the differential sale consideration, taking the sale price of Rs.2350 per sq.ft. and admitted the difference amount as additional income of the appellant on account of discount given out of their personal consideration.
As seen from the above, the market rate was considered as Rs.2350 per
SFT and computed the difference as additional income. As per the above computation, the total additional income worked out was Rs.5,23,81,984/-, out of which Rs.4,09,39,850/- pertains to the assessment year under consideration and the remaining
Rs.1,14,42,134/- pertains to next assessment year, AY 2.019-20. During post survey proceedings, it was seen from the impounded material that there were four more villas which were also sold at a relatively lower price, the details of which are as under:
S
No Customer
Name
Villa
No Sq ft Sale Price
P r i c e
/ Sq f t
Booking date
Actual price
Difference
Difference sale price
1Dontala Shanti
261
4225 3945500
933.85
18.09.2017
2350
1416.15
5983234
2G. V.
Maheswara
Rao
201
4225 3918750
927.51
22.11.2017
2350
1422.49
3916575
3Chelluri
Mohana
Vamsi
Krishna/
Sri Lakshmi
235
3400 3125750
919.34
01.12.2017
2350
1431
4865400
4Gutupalli
Venkaiah
Naidu
237
3029 7053700
2329
09.01.2019
2500
171
517959
Total
1,52,83,168
The above was confronted with Mr. P. Koteshwar Rao, executive partner of the appellant firm in his sworn statement recorded during the post- survey proceedings. The partner, Sri P. Koteshwar Rao has accepted the 6
ITA 327/Hyd/2024
difference amount of Rs.1,52,83,168/- as additional income of the appellant firm in similar lines to the earlier admission given during the Survey. Out of Rs.1,52,83,168/-, the amount of Rs.1,47,65,209/- pertains to the present assessment year AY 2018-19 and Rs.5,17,959/- pertains to AY 2019-20. Thus, for AY 2018-19, the total additional income, as admitted by the partners of the firm during the survey and post survey proceedings, cumulate to Rs.5,57,05,059/-. The villa wise additional income is summed up as under:
Sr
No Name of the Buyer
Date of Booking
Villa
No.
Total
SFT
Sale price per SFT
(in Rs.)
Marke t price per
Difference adopted by AO for addition
Amount of addition
1Lavudya Karuna
29.09.2017
118
4156
1,440 2,350
910
37,81,960
2Danturi Sireesha
05.10.2017
155
4800
1,533 2,350
817
39,21,600
3E Venkatesh
27.11.2017
90
4156
930. 2,350
1,420
59,01,520
4M Kondal Rao
27.11.2017
217
3727
1,113 2,350
1,237
46,10,299
5M Sureka
23,11.2017
270
4004
952
2,350
1,398
55,97,592
6M Arun Madhav
29.11.2017
202
3770
1,020 2,350
1,330
50,14,100
7P Koteswara Rao
07.07-2017
153
4260
2,347 2500
153
6,51,780
8Nagaraju
16.02.2018
175
4224
1,124 2,550
1,426
60,23,424
9Hari Hara Kumar
31.03.2018
80
4225
1,263 2,550
1,287
54,37,575
10Dontala Shanti
18.09.2017
261
4225
934
2,350
1,416
59,83,234
11GV Maheswara Rao
22.11.2017
201
4225
928
2,350
1,422
39,16,575
12Chelluri
Venkaiah
Naidu
01.12.2017
235
3400
919
2,350
1,431
48,65,400
TOTAL
5,57,05,059
However, the appellant has not included the above additional income in its return of income filed for the assessment year under consideration.
The AO stated that there is no reason for the retraction from the admission of additional income during the survey and post survey proceedings.
Further, considering the nature and quality of construction of villas as well as the amenities and facilities that were provided (which has also been brought out by the AO in the assessment order), the AO concluded that the minimum value of construction would be at least Rs.2350 per sq.ft and any sale that would be made even without profit would at least
7
ITA 327/Hyd/2024
be at Rs.2350 per sq.ft. Accordingly,the AO made the differential amount of Rs.5,57,05,059/- to the returned income.
It is important to note that during the course of Survey operation u/s.
133A, no unaccounted cash was found at the premises of the appellant firm nor any evidence was unearthed to indicate that the appellant has received on-money in cash on sale of these villas. There was evidence on record to indicate that certain villas have been sold at a lesser price but no evidence of on-money or unaccounted cash with respect to these villas were found. The appellant admitted that these have been sold at a discounted rate either to relatives or related parties or to persons who facilitated the development of the project or the sales.
The admission of income was made by the partner of the appellant firm when difference in sale prices were confronted to him. Even in the statement of the partners of the appellant firm, they have admitted additional income on account of lower rate in certain villas but it is necessary to note that they have not stated anywhere that the additional consideration was received. Therefore, there is no primary evidence of receipt of unaccounted consideration by the appellant found during the Survey nor it was stated by partners of the appellant firm.
Further, with regard to these villas, the villa wise details of receipts of consideration submitted by the appellant during the appeal proceedings is brought out as under:
*****
It is seen that certain part of the advances were received post survey operation, in respect of the villa Nos. 118, 270 and 175, which were not considered by the AO as part of the consideration while arriving at the cost of the respective villa and the same are considered in the present adjudication. The relevant ledger account copies of these villas as submitted by the appellant is as under:
*****
It is seen that the project got completed only subsequently and the appellant, from these villa owners, have received substantial sums in advance. It is seen that 84% of the cost of the villas has been received by the appellant much in advance. The appellant does not have much funds and the advances so received have gone into the project and also is a huge impetus to funds, otherwise, the appellant needs to borrow funds from outside and that has an interest cost to the same. Therefore, any advance substantially received cannot be construed as a discounted sale, as in normal bookings, the initial offer prices are much lower when the 8
ITA 327/Hyd/2024
project is launched and the prices of finished goods or projects which have taken off are much higher.
The developers and builders use the initial booking advances as working capital for the project and therefore, discount the rates and also the raising of finances is a challenge and the interest portion is not only high but also requires servicing, whereas, with regard to advances, the promise is only of delivery and that too when the project gets completed.
There is no evidence on record to indicate anything otherwise than what has been observed above. Before computing the advances in relation to the time value of money, it would be also proper to arrive at the cost of the project per sq.ft. The AO has taken the value at Rs.2350 per sq.ft in spite of the denial and subsequent retraction by the appellant.
If one looks into the financials, the average cost of construction works out to be Rs.2,176/- per Sq.ft. and the same is calculated as under:
Particulars
FY 2016-
17
2017-18
2018-19
2019-20
2020-21
2021-22
Total
Operating and other expenses
4,92,01,94
4
18,06,48,0
28
28,99,85,
219
45,19,40,
00 6
47,48,69,69
5
76,52,13,54
3
2,21,18,58,435
Employee cost
1,07,507
22,03,147
17,52,23
4
22,06,755
20,82,926
13,12,282
96,64,851
Depreciation
35,667
2,46,107
2,33,094
2,26,648
2,16,005
1,68,894
11,26,415
Other expenses -
69,64,22
1
61,95,207
39,85,774
1,20,15,967
2,9 1,6 1,169
Cost of Construction
4,93,45,11
8
18,30,97,2
82
29,89,34,
768
46,05,68,6
1 6
48,11,54,40
0
77,87,10,68
6
2,25,18,10,870
Cost incurred in the year
48
177
289
445
465
752
Cost incurred in the year
Cost: incurred in the year jCumulalive
)
48
225
513
958
1,423
2,176
Cost incurred in the year
(Cumulative.)
Thus, the cost of the project is Rs.2176 per Sq.ft and not Rs.2350 per
Sq.ft. Further, the time value of advances or the cost of construction is considered when substantial advance was received from these villa owners, the same works out to be as under:
FY 2016-
2017-
2018-
2019-20
2020-21
2021-22
17
18
19
Discounting the cost of construction @,1Z,Y,0
1,235
1,383
1,549
1,735
1,943
2,176
9
ITA 327/Hyd/2024
It is seen that 68% advance was received in FY 2017-18 and the same increased to 84% in FY 2018-19. If one considers that all the advance was received in FY 2018-19, the cost of construction discounted on interest works out to be Rs.1549 per Sq.ft and let that be considered at Rs.1550 per Sq.ft as a round figure. The reason for benchmarking the rate to Rs.1550 per Sq.ft is because 16% of the advance was yet to be received and 68% advance has already been received in the earlier year i.e. FY
2017-18. Therefore, approximately, Rs.1550 per Sq.ft is a fair benchmarking considering time value of money and otherwise.
Now, it is also important to consider the SRO value of these properties and to verify whether the same is higher than Rs.1550 per Sq.ft. The appellant has submitted a certificate obtained from SRO, regarding the value of the land Rs.2500 per Sq.yd and construed area at Rs.700 per
Sq.ft as on 01.12.2017 and as on 01.12.2018 on the basis of the same, the cost works out to be as under of each villa:
Sr
No Villa
No.
Area in Sq.
Yds.
SRO value of Land
(@Rs.
2500 per sq.yd)
Total const ructe d area in Sq.ft
SRO Value of Building
(@Rs.700
per Sq.ft)
SRO
Value of the Property
SRO
Value computin g per sq.ft.
Per S FT
Cost as per
AO
1
Lavudya
Karuna
118
300
750000
4,156
29,09,200
36,59,200
880
1,440
2
Danturi
Sircesha
155
400
1000000
4,800
33,60,000
43,60,000
908
1,533
3
E Venkatesh
90
300
750000
4,156
29,09,200
36,59,200
880
930
4
M Kondal Rao
217
314
785000
3,727
26,08,900
33,93,900
911
1,113
5
M Sureka
270
324
810000
4,004
28,02,800
36,12,800
902
952
6
M Arun Madhav
202
383
957500
3,770
26,39,000
35,96,500
954
1,020
7
_
P Koteswara
Rao
153
400
1000000
4,260
29,82,000
39,82,000
935
2,347
8
Nagaraju
175
300
750000
4,224
29,56,800
37,06,800
878
1,124
9
Hari Hara
Kumar
80
300
750000
4,225
29,57,500
37,07,500
878
1,263
10
Dontala Shand
261
311
777500
4,225
29,57,500
37,35,000
884
934
11
CIV Maheswara
Rao
201
300
750000
4,225
29,57,500
37,07,500
878
928
1 2
Chelluri
Venkaiah Naidu
235
222
555000
3,400
23,80,000
29,35,000
863
919
10
ITA 327/Hyd/2024
Thus, the SRO value ranges from Rs.863 per sq.ft to Rs.954 per sq.ft on the basis of the constructed area and in all the cases, Therefore, it would be fair to benchmark the higher value which is the basic cost of construction and land value at an average rate of Rs.1550 per sq.ft which is as per books to calculate the discounted sales. It would be also proper to note that if the appellant wants to argue that these were with regard to rendering of service, then the TDS provisions will kick in and none of these villa owners have reflected that as income, therefore, the discounted value if commensurate to rendering of service would get disallowed as per Sec. 40(a)(ia) and become income of the appellant itself.
Anyways, no substantiation of service has been proved and the related parties have been sold in certain cases at a value lower than the time value of money also. Therefore, the same needs to be taxed accordingly.
Therefore, considering the benchmarking of cost of construction at Rs.1550/- per Sq.ft, the difference in sale consideration is worked out for these villas as under:
Sr
No Name of the Buyer Vill a No.
Total are of villa in sq.ft.
Amount received by the appellant excluding
GST
Sale price per sq.ft
(in Rs.)
BenchmarkDiferenc e Price
Amount of addition
1Lavudya Karuna
118 4156
77,08,884
1855
1550
-
Danturi Sireesha
155 4800
73,67,217
1535
1550
15
606
437
72783
2517990
1628541
3E Venlcatesh
90 4156
39,23,810
944
1550
4M Kondal Rao
21.7 3727
41,48,309
1113
1550
5M Sureka
270 4004
80,36,286
2007
1550
6M Arun Madhav
202 3770
38,47,619
1021
1550
529
1995881
7P Koteswara Rao
153 4260
99,98,268
2347
1550
-
8Nagaraju
175 4224
75,90,474
1797
1550
-
9Hari Nara Kumar
80 4225
53,68,530
1271
1550
279
1180220
10
11
Dontala Shanti
261 4225
35,22,770
834
1550
716
3025980
GV Maheswara Rao
201 4225
39,71,763
940
1550
610
2576987
11
ITA 327/Hyd/2024
12Chelluri
Venkaiah
Naidu
235 3400
31,25,750
919
1550
631
2144250
15142632
As per the above working, taking the benchmarking of Rs.1550 per sft, the effective sale consideration works out to Rs.1,51,42,632/-, which should have been charged on the basis of cost itself from these related parties/relatives. In view of the same, this amount of Rs.1,51,42,632/- is treated as sale consideration which should have been into taxation as per the cost price of the appellant and if it had anything to do with services rendered, then the said service quantum in rupees/value would attract disallowance on account of TDS provisions. Needless to state anything sold at cost price is the discretion of the appellant as long as no losses are incurred, the AO cannot dictate the terms of profit to the business of the appellant.
In view of the above, addition is to be restricted to Rs.1,51,42,632/- and the balance addition of Rs. 4,05,62,427/- is deleted accordingly. The ground nos. 5, 10 and 11 are partly allowed accordingly.”
Aggrieved with the order of LD.CIT(A), the Revenue is now in appeal before us.
Before us, ld.DR submitted that LD.CIT(A) erred in restricting the addition to Rs.1,51,42,632/- and deleting the balance addition of Rs.4,05,62,427/-. It was submitted that during the course of the survey, the assessee’s partners admitted to having sold certain villas at a price below the market rate, and the difference was rightly computed as additional income by the Assessing Officer (AO). The Ld.DR argued that the AO had determined the fair market rate of Rs. 2,350 per sq. ft. based on incriminating material seized during the survey and statements recorded from the partners of the firm. The partners had admitted that these villas
12
ITA 327/Hyd/2024
were sold at a lower price either due to personal relations or certain benefits received in connection with the project. Furthermore, during the post-survey proceedings, additional villas were identified as being sold below the average price, further reinforcing the AO’s stand that the assessee had earned unaccounted income.
The Ld.DR further submitted that LD.CIT(A) while reducing the addition, did not fully appreciate the fact that no independent third-party valuation was submitted by the assessee to justify its claims of lower sale prices. The benchmarking at Rs. 1,550 per sq. ft. by the CIT(A) was, according to the DR, arbitrary and lacked a sound basis. The AO had considered multiple factors, including cost of construction, market trends, and project specifications, and arrived at Rs. 2,350 per sq. ft., which should have been upheld in full. The DR urged that the order of the AO be reinstated.
1 Per contra, LD.AR submitted that the benchmarking adopted by the AO was excessive and did not reflect the commercial reality of the real estate market. It was argued that the assessee, being a developer, had to adopt a pricing strategy that ensured continuous cash flow, and as part of this strategy, certain villas were sold at discounted rates in exchange for benefits such as land facilitation, marketing assistance, and early financing. The ld.AR contended that the AO failed to consider the fact that a substantial portion of the sale consideration was received in advance, which significantly reduced the financing burden on the assessee. In real estate projects, early buyers often receive discounts because their
13
ITA 327/Hyd/2024
payments help fund ongoing construction. The ld.AR pointed out that in the present case, approximately 84% of the project’s cost was funded through customer advances, which eliminated the need for high-interest borrowings. Furthermore, the ld.AR submitted that the LD.CIT(A) had correctly undertaken a financial analysis and arrived at a reasonable benchmark of Rs. 1,550 per sq. ft. by considering actual cost of construction, time value of money and SRO rates. The AR strongly argued that no addition was warranted as there was no evidence of unaccounted cash transactions or receipt of on-money. It was asserted that the LD.CIT(A) had rightly rejected the AO’s arbitrary benchmarking at Rs. 2,350 per sq. ft., and no further enhancement should be made beyond Rs. 1,550 per sq. ft.
We have heard both sides and perused the material on record. In the present case, the issue revolves around the differential sale consideration of villas, where the AO made an addition based on an assumed market rate of Rs. 2,350 per sq. ft., while the CIT(A) restricted the addition by benchmarking at Rs. 1,550 per sq. ft. The assessee contended that the villas were sold at lower rates due to commercial reasons such as early bookings, marketing assistance, and advance payments, which played a crucial role in financing the project and reducing borrowing costs. The AO, on the other hand, determined the market rate based on survey proceedings and the statements of the partners, concluding that the differential amount should be taxed as additional income.
14
ITA 327/Hyd/2024
We have carefully examined the order of the LD.CIT(A), including the various tables presented therein and reproduced hereinabove. The first table lists 12 villas that were sold at lower prices, along with the names of the buyers and the reasons for discounted sales, such as relationships with partners, facilitation of land deals, or assistance in sales. The second table provides details of additional villas identified during post-survey proceedings, showing their square footage, sale price, and market price, which formed the basis for further additions. The third table consolidates the total differential sale consideration computed by the AO, summing up to Rs. 5,57,05,059/-. The LD.CIT(A) after reviewing the financial data, prepared another set of tables analyzing the cost of construction across financial years, which averaged Rs. 2,176 per sq. ft. Another table considered the time value of money due to advances received and discounted the construction cost to Rs. 1,550 per sq. ft., which was then used as the benchmark to restrict the addition to Rs. 1,51,42,632/-. Upon reviewing these tables and the overall reasoning of the LD.CIT(A) we find that while the approach taken is reasonable, the benchmarking at Rs. 1,550 per sq. ft. does not fully account for the variations in villa specifications, amenities, and industry practices. The project involved high-end villas, and the pricing structure should reflect this aspect. Although the assessee’s argument regarding commercial justifications and advance payments is valid, the valuation must also consider the overall pricing trend of similar properties. Therefore, we find it appropriate to benchmark the rate at Rs. 1,800 per sq. ft., which balances both
15
ITA 327/Hyd/2024
the assessee’s explanations and the revenue’s concerns regarding underreported income. We may also mention that Assessing
Officer in A.Y. 2019-20 had also adopted the rate at Rs.1,800 per sq. ft in the case of assessee in his order dt.30.03.2024. In view of the foregoing reasoning, we believe that this adjustment considers the assessee's commercial reasons while ensuring a fair and reasonable valuation of the project’s pricing. Accordingly, the addition is partly sustained based on this revised benchmark, and the appeal is partly allowed.
In the result, the appeal of the Revenue is partly allowed.
Order pronounced in the Open Court on 11th February, 2025. (MADHUSUDAN SAWDIA)
ACCOUNTANT MEMBER
Hyderabad, dated 11.02.2025. TYNM/sps
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ITA 327/Hyd/2024
Copy to:
S.No Addresses
1
M/s. Magna Homes, Flat No.G-1, Magnum Opus, Road No.2,
Cyber Hills, Gachibowli, Hyderabad – 500032. 2
The Deputy Commissioner of Income Tax, Central Circle – 3(1),
Hyderabad.
3
Pr.CIT (Central), Hyderabad.
4
DR, ITAT Hyderabad Benches
5
Guard File
By Order