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Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI
Before: SHRI N.R.S. GANESAN & SHRI S. JAYARAMAN
आदेश /O R D E R
PER N.R.S. GANESAN, JUDICIAL MEMBER:
Both the Revenue and the assessee have filed the appeals
against the very same order of the Commissioner of Income Tax
(Appeals), Puducherry, dated 27.01.2017 and pertain to the
assessment year 2011-12. Therefore, we heard both the appeals
together and disposing the same by this common order.
There was a delay of 146 days in filing the appeal by the
Revenue in I.T.A. No.2189/Chny/2017. The Revenue has filed
application for condonation of delay. Having heard the Ld. D.R. and
the Ld.counsel for the assessee, this Tribunal finds that there was a
reasonable cause for not filing the appeal by the Revenue within the
prescribed time before this Tribunal. Therefore, the delay of 146
days in filing the appeal before this Tribunal is condoned and the
appeal of the Revenue is admitted.
Dr. M. Srinivasa Rao, the Ld. Departmental Representative,
submitted that the assessee is engaged itself in the business of e-
publishing. According to the Ld. D.R., the assessee-company
undertakes editorial services, multilingual typesetting and data
3 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
conversion. The assessee-company admittedly transacted with its overseas associated concerns to the extent of more than ₹15 Crores. According to the Ld. D.R., the Assessing Officer referred the matter to the Transfer Pricing Officer as required under Section 92CA of the Income-tax Act, 1961 (in short 'the Act'). The Transfer Pricing Officer by an order dated 31.12.2014, found that the transactions with Associated Enterprise outside India was within arm's length and therefore, no adjustment was considered necessary.
Dr. M. Srinivasa Rao, the Ld. D.R. further submitted that the assessee claimed ₹6,59,53,207/- towards outsourcing charges. According to the Ld. D.R., the assessee explained before the Assessing Officer that the outsourcing charges was ₹3,64,21,499/- on which tax was deducted. However, the outsources charges to the extent payment made ₹2,95,31,708/- on which tax was not deducted at source. The Ld. D.R. further submitted that the assessee has paid to non-residents at USA, UK, Germany and Spain in respect of whom the tax was not deducted. Therefore, according to the Ld. D.R., the Assessing Officer found that the assessee has not deducted tax as required under Section 195 of
4 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
the Act. Accordingly, the payment made to the non-residents at USA, UK, Germany and Spain to the extent of ₹2,95,31,708/- was
disallowed under Section 40(a)(ia) of the Act.
Dr. M. Srinivasa Rao, the Ld. D.R. further submitted that the
payment made to different persons at USA, UK, Germany and
Spain as detailed at page 3 to 7 of the impugned order of the
CIT(Appeals) was disallowed by the Assessing Officer for non-
deduction of tax. Referring to the order of the CIT(Appeals), the Ld.
D.R. submitted that all the recipients are foreign nationals and the
nature of work done by them was listed out at page 3 to 5 of the
assessment order. According to the Ld. D.R., all these works done
by the non-residents at USA, UK, Germany and Spain involved
technology. However, there was no transfer of technical services.
Hence, according to the Ld. D.R., the question of “make available”
theory is not applicable at all. The CIT(Appeals) found that the non-
residents have provided technical services. Since the technology
was not made available to the assessee by the non-residents at
USA & UK, so that the assessee could perform those services
independently, he deleted the disallowance made by the Assessing
Officer by citing provisions in the Double Taxation Avoidance
5 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
Agreement between India & USA and India & United Kingdom. In
respect of the payment made to the non-residents at Germany and
Spain, the CIT(Appeals) found that even though the services
rendered by the non-residents at Germany and Spain were
technical services, the “make available” clause is not available in
the Double Taxation Avoidance Agreement between India &
Germany and India & Spain. Therefore, he confirmed the
disallowance made by the Assessing Officer in respect of non-
resident at Germany and Spain.
According to the Ld. D.R., the Department has filed the
appeal against the order of the CIT(Appeals) in respect of the
payment made to the non-residents at USA and UK. However, in
respect of the payment made to non-residents at Germany and
Spain, the assessee has filed the appeal. According to the Ld.
D.R., the services rendered by the non-residents are technical
services, therefore, the assessee is bound to deduct tax at the time
of making the payment. Inviting the attention of this Tribunal to the
order of the CIT(Appeals), more particularly at page 26 para 7.8.10,
the Ld. D.R. submitted that the services rendered by the non-
residents are technical services and the said services were utilised
6 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
in India. Therefore, the fee paid for technical services would be
taxable in India. In other words, according to the Ld. D.R., all the
payments made to the non-residents are taxable in India in the
hands of the non-residents. Hence, the assessee is liable to deduct
tax under Section 40(a)(ia) of the Act. Therefore, according to the
Ld. D.R., the CIT(Appeals) ought not to have deleted the
disallowance made by the Assessing Officer in respect of the
payments made to non-residents at USA & UK also.
On a query from the Bench when the Assessing Officer at
para 6 of his order categorically says that the services rendered by
the non-residents did not involve any technology, can the Revenue
now claim before this Tribunal that the services rendered by the
non-residents are technical services? The attention of the Ld. D.R.
was also invited to the grounds of appeal raised before this Tribunal
by the Revenue that the only grievance of the Department appears
to be that the assessee has not filed Form 15CA and 15CB and the
nature of the work rendered by the non-residents are not technical
services, the Ld. D.R. submitted that the CIT(Appeals) at para
7.8.10 has found that the services rendered by the non-residents
are technical services. However, there was no transfer of technical
7 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
services. Hence, according to the Ld. D.R., the assessee is liable to
deduct tax under Section 195 of the Act.
On the contrary, Shri S. Sridhar, the Ld.counsel for the
assessee, submitted that the services rendered by the non-
residents at UK, USA, Germany and Spain are not technical
services. Referring to the assessment order, the Ld.counsel
submitted that the payments were made to individuals and
corporate bodies who are non-residents in both the appeals.
According to the Ld. counsel, there was no obligation to deduct tax
under Section 195 of the Act since the payments made to them are
not taxable in India. According to the Ld. counsel, all the non-
residents are foreign nationals and they are residing outside India.
The services were also rendered outside India. The non-residents,
who rendered service, have not visited India at any point of time.
The non-residents who rendered services have no permanent
establishment or business connection in India. According to the Ld.
counsel, the services rendered by the non-residents are copy
editing, indexing and proof reading which are all essentially non-
technical services. It cannot also be considered to be professional
services as defined under Section 9 of the Act and under respective
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Double Taxation Avoidance Agreements. The Chartered
Accountants certified that the payments made to non-residents are
not taxable in India and such certificates were filed before the
respective bankers before remitting the payments.
Referring to the assessment order, more particularly at page
3, the Ld.counsel for the assessee submitted that copy editing is
nothing but formatting, style and accuracy of text. The copy writer
cannot change the substance of the text. According to the Ld.
counsel, copy editing was done before typesetting and proof
reading. At the best, according to the Ld. counsel, the copy editing
involves spelling correction, punctuation, grammar, terminology, etc.
to ensure that the sentences are formed in such a manner that the
readers of the text can understand easily the substance. In other
words, according to the Ld. counsel, copy editors are expected to
ensure that the text flows in the language in which they are copy
editing. According to the Ld. counsel, in no way it involves a
technical service, hence, the payment made for copy editing cannot
be considered to be a technical service.
9 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
Now coming to indexing, the Ld.counsel for the assessee
submitted that the indexing is nothing but an arrangement of entries
designed to enable the readers to locate information in the
documents. According to the Ld. counsel, the process of creating
an index is called indexing and the person who does it is called
indexer. The main task of indexer is classification of the documents
to indicate what the document is about and to summarise the
content to increase its identifiability. The indexer may not be
conversed with subject matter of the text. According to the Ld.
counsel, the indexation cannot be considered to be a technical
service at all.
Now coming to proof reading, the Ld.counsel for the
assessee submitted that the proof reader compares the copy with
corresponding typeset to identify any error in the manuscript page.
According to the Ld. counsel, proof reader or typesetter, graphic
artist does not require to have any qualification. Referring to the
project management, the Ld.counsel submitted that it is a work
given by publisher right from the receipt of manuscript till the
release of book for final printing. According to the Ld. counsel, the
service provider coordinates with other parties on the instructions of
10 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
the service recipient and reports on the progress of the work until
the delivery of text to the author or publisher. In fact, according to
the Ld. counsel, they are coordinating with people, integrating and
performing the activities so as to deliver the text to the assessee in
a feasible manner. Referring to the ancillary services, the
Ld.counsel submitted that the service provider may alter the designs
in such a manner that the requirement of author or publisher is
fulfilled. For all these services referred above, according to the Ld.
counsel, the service provider need not have any knowledge about
the subject of the text. The service provider need not understand
the material being copy edited or indexed or subjected to proof
reading. According to the Ld. counsel, it is only a clerical work
carried on by the assessee through outsourcing from the individuals
/ corporate body outside the country. The services rendered by the
non-resident, such as editing, indexing, proof reading, etc., are not
technical service. Moreover, no technology also involved.
Therefore, the payment made to them by the assessee is not
taxable in India. Hence, according to the Ld. counsel, the assessee
is not liable to deduct any tax at the time of payment.
11 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
Referring to the decision of this Bench of the Tribunal in
Cosmic Global Ltd. v. ACIT (2014) 34 ITR(Trib) 114, the Ld.counsel
for the assessee submitted that translation work was held to be not
a technical service. According to the Ld. counsel, this decision was
distinguished by the CIT(Appeals) as not applicable to the facts of
the case without any reason or justification. Referring to the
assessment order, more particularly page 6, the Ld.counsel
submitted that the legal service rendered from abroad was held to
be not taxable in India without any fixed base in IMP Power Ltd. v.
ITO (2007) 107 TTJ (Mum) 522. It was also found to be not taxable
in India when information service rendered by electronic media
promoting downloading in India by the Authority for Advance Ruling
in ABC Ltd. (2006) 284 ITR 1. According to the Ld. counsel, the
services rendered by the non-residents are not technical services at
all. The Assessing Officer himself found in the assessment order
that the services rendered by the non-residents are not technical
services.
Referring to page 8 of the assessment order, the Ld.counsel
for the assessee submitted that the expression “fees for technical
services” as defined in Explanation 2 to Section 9(1)(vii) of the Act
12 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
was considered by the Mumbai Bench of this Tribunal in TUV
Bayren (India) Ltd. in I.T.A. No. 4944/Mum/2002. The Tribunal
found that technical service requires expertise in technology and
providing the client such technical expertise. In the present case,
according to the Ld. counsel, the persons who copy edited, indexed
and done proof reading have no expert knowledge in the subject of
the text. Therefore, according to the Ld. counsel, this cannot be
considered to be a technical service.
Referring to managerial service, the Ld.counsel for the
assessee submitted that the Mumbai Bench of this Tribunal found
that the managerial service is used in the context of running the
business of the client. In this case, according to the Ld. counsel,
there is no such requirement of running and managing the business
of the assessee by the non-residents, therefore, the payment
cannot be considered to be for managerial service. The Mumbai
Bench also found that the consultancy service is to be understood
as advisory service wherein necessary advice and consultation was
given to its clients for the purpose of client’s business. According to
the Ld. counsel, in the present case, it is a simple copy editing,
indexing and proof reading of the text and the persons, who carried
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on the work, have no expert knowledge in respect of the text they
copy edited, indexed and done proof reading.
Referring to page 26 of the assessment order, more
particularly para 6, the Ld.counsel for the assessee submitted that
the Assessing Officer in categorical term found that the nature of
service rendered by the non-residents does not involve any
technical service. According to the Ld. counsel, provisions of
Section 9(1)(vii) of the Act will apply only in the case of application
of technology and if such technology is made available to the
assessee so as to enable to function independently. According to
the Ld. counsel, the Assessing Officer specifically found that since
there is no technology involved, the provisions of Section 9(1)(vii) of
the Act may not apply to all the above services. The only
observation of the Assessing Officer at para 6, according to the Ld.
counsel, was that certificates in Form 15CA and 15CB were not
obtained and filed. The Assessing Officer further found that forms
were not filed in Form 15CA and 15CB, the assessee was required
to deduct tax on payment made to the non-residents for the above
services. According to the Ld. counsel, when the Assessing Officer
himself found that the services rendered by the non-residents are
14 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
not technical services, it cannot now be claimed that the services
rendered by the non-residents are technical services by the
CIT(Appeals).
The Ld.counsel for the assessee further submitted that the
Department has appealed against the order of the CIT(Appeals) in
respect of payment made to non-residents at USA and UK. In
respect of the payment made to the non-residents at USA and UK,
the CIT(Appeals) deleted the disallowance made by the Assessing
Officer on the ground that the technology was not made available to
the assessee, therefore, there cannot be any disallowance under
Section 40(a)(ia) of the Act. However, in respect of payment made
to non-residents at Germany and Spain, the CIT(Appeals) found
that the “make available” clause was not available in Double
Taxation Avoidance Agreement between India and Germany and
India and Spain. Therefore, the CIT(Appeals) found that the
services rendered by the non-residents are technical services,
hence, the payment made to non-residents by the assessee is
taxable in India, hence, the assessee is liable to deduct tax.
Therefore, the assessee filed appeal against the order of the
CIT(Appeals) in respect of payment made to non-residents at
15 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
Germany and Spain. The Ld.counsel further submitted that in
respect of USA, UK, Germany and Spain, the services rendered by
the non-residents are not technical services, therefore, it cannot be
considered to be fees for technical services. Hence, the non-
residents are not liable to pay tax in India in respect of the payments
received from the assessee. Therefore, according to the Ld.
counsel, the assessee is not liable to deduct tax under Section 195
of the Act, hence, there cannot be any disallowance under Section
40(a)(ia) of the Act.
We have considered the rival submissions on either side and
perused the relevant material available on record. It is not in
dispute that the assessee has paid to the non-residents to the extent of ₹2,95,31,708/-. The assessee claims that the services
rendered by the non-residents at UK, USA, Germany and Spain are
not technical in nature. Therefore, the non-residents are not liable
to pay tax in India, hence no tax needs to be deducted as provided
under Section 195 of the Act. The Assessing Officer, after
extracting the submission of the assessee and the case laws
referred by the assessee, the details of the payments made to
various individuals and corporate bodies outside the country, has
16 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
observed as follows at para 6 on page 26 of his order. For the
purpose of convenience, we are reproducing the para 6, which
reads as follows:-
“6. From the foregoing, the very intention of the Act is clear that there should not be any omission to deduct tax at source on the pretext that the person is not having a residence or place of business or business connection in India or any other presence in any manner whatsoever in India. As per DTAA, the term “professional services” defined as independent activities of scientific, literary, artistic, educational or teaching activities as well as individual activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants. The question arises whether all the above services would be taxable as income by way of fees for technical services as defined in Explanation to Sec. 9(1)(vii). As seen from the nature of services rendered by the non resident individuals, the work of translation, copy editing and indexing do not involve any technology. Provisions of Section 9(1)(vii) will apply only in case of application of technology and if such technology is made available to the Indian company could independently perform the technical function with such knowledge imparted to the nonresident company. Since there is no technology involved, the provisions of Section 9(1)(vii) would not apply to all the above said services. Besides the certificates in form 15CA and 15CB were not obtained and filed online. Hence, the assessee was required to deduct tax on the payments made to non residents for the above services, provisions of Section 195(6), 195(2), (3) and (7) have not been complied with.”
We have carefully gone through the ground No.2 in the
grounds of appeal raised by the Revenue before this Tribunal. For
17 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
the purpose of convenience, ground No.2 raised before this Tribunal
is reproduced, which reads as follows:-
“2. The learned CIT(A) failed to appreciate the fact that the nature of services rendered by the non-resident individuals do not involve any technology. As per DTAA, the term “professional services” defined as independent activities of scientific, literary, artistic, educational or teaching activities as well as independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants. As seen from the nature of services rendered by the non-resident individuals, the work of translation, copy editing and indexing do not involve any technology. Since there is no technology involved, the provisions of Sec. 9(1)(vii) would not apply to all the above said services. Besides, the certificates in Form 15CA and 15CB were not obtained and filed online. Hence, the assessee was required to deduct tax on the payments made to non-residents for the above services.”
From the above finding recorded by the Assessing Officer at
para 6 of the impugned assessment order and the ground No.2
raised before this Tribunal by the Revenue, it appears the main
claim of the Revenue is that the services rendered by the non-
residents do not involve any technology and it is a specific case of
the Department as raised in ground No.2 before this Tribunal that
since there is no technology involved, the provisions of Section
9(1)(vii) of the Act would not apply to the above said services. The
Revenue appears to have grievance with regard to failure of the
18 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
assessee to file certificates in Form 15CA and 15CB. However, the
CIT(Appeals), after examining the services rendered by the non-
residents, found that the non-residents who rendered services do
not have any permanent establishment in India. The CIT(Appeals)
also found that there was no business connection within the
meaning of Section 9(1)(i) of the Act. Therefore, the CIT(Appeals)
found that Section 9(1)(i) of the Act has no application to this case
and payments received by the non-residents cannot be assessed as
their business income in India under Section 9(1)(i) of the Act. This
finding of the CIT(Appeals) was not challenged or disputed by the
Revenue. For the purpose of convenience, we are reproducing the
finding recorded by the CIT(Appeals) at pages 22 and 23 at para
7.7 which reads as follows:-
“7.7 It is seen that the A.O. invoked S 9(1)(i) and its Explanation with reference to ‘business connection’ and held that there is business connection and so the payments are taxable in the hands of non-residents in India. To the assessee in India, the non-residents rendered services abroad and not in India. In the instant case, it cannot be said that the non-residents carried out their business activity through a person in India. Those non-residents do not have PE in India. As such, there is no business connection within the meaning of section 9(1)(i). Hence, in the facts and circumstances of the case, I hold section 9(1)(i) has no application in this case and the payments
19 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
received by the non-residents cannot be assessed as their business income in India u/s 9(1)(i).”
However, the CIT(Appeals) found that the services rendered
by the non-residents are technical in nature. At para 7.8.7., the
CIT(Appeals) referred certain professionals and observed that the
services rendered by them are technical nature. At para 7.8.8, the
CIT(Appeals) referred the decision of this Tribunal in Cosmic Global
Ltd. (supra) and found that this decision is not applicable to the facts
on hand. It is not in dispute that this Tribunal in categorical term
found that language translation is not a technical service. The
Mumbai Bench of this Tribunal in IMP Power Ltd. (supra) found that
even the legal service rendered from abroad was not taxable in
India without permanent establishment in India. The CIT(Appeals)
without considering these decisions, has simply referred to some of
the provisions which are not connected with the present case and
distinguished the case of Cosmic Global Ltd. (supra) without
recording any reasons. It is a well settled principle of law when the
authorities, who are exercising the judicial power, find that a
particular judgment is applicable or not applicable, they are
expected to record the reasoning why it is applicable / not
applicable.
20 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
We have carefully gone through the decision of this Bench in
Cosmic Global Ltd. (supra). This Tribunal found that translation of
language is not technical service. The translation of a text from
one language to another cannot be considered to be technical
service as held by this Bench of the Tribunal. The copy editing,
indexing and doing proof reading required only knowledge in the
language and it does not require to have necessary expertise in the
subject matter of text. Therefore, the CIT(Appeals) is not correct in
saying that the services rendered by the non-residents are technical
services. Since the services rendered are not technical services,
this Tribunal is of the considered opinion that the payment received
by the non-residents from the assessee is not taxable in India. In
IMP Power Ltd., (supra), the Mumbai Bench of this Tribunal found
that even legal fees paid in U.K. is not taxable in India. Hence,
there cannot be any disallowance. Therefore, the assessee is not
liable to deduct tax as required under Section 195 of the Act. The
Apex Court has also examined this issue in Transmission
Corporation of A.P. Ltd. v. CIT (1999) 239 ITR 587 and found that
when the payment made to non-resident is not taxable in India, it is
not necessary to deduct tax under Section 195 of the Act.
21 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
Therefore, there cannot be any disallowance under Section
40(a)(ia) of the Act
In view of the above, we are unable to uphold the orders of
the CIT(Appeals) in respect of the payment made to non-residents
who are in USA and UK. However, in respect of payments made to
non-residents at Germany and Spain, we confirm the order of the
Assessing Officer not on the ground on which the CIT(Appeals)
deleted the disallowance but on the ground that such payments
made by the assessee to non-residents at Germany and Spain are
not liable for taxation in India. In other words, the non-residents in
Germany and Spain also not rendered any technical service.
Hence, the assessee is not required to deduct tax under Section
195 of the Act.
The next objection of the Revenue is that the assessee has
not filed certificates in Form 15CA and 15CB as required. We have
carefully gone through the provisions of Section 195 of the Act.
Section 195(6) of the Act says that the person responsible for
paying to a non-resident any sum whether or not chargeable under
the provisions of Income-tax Act, shall furnish the information
22 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
relating to payment of such sum, in such form and manner, as may
be prescribed. Rule 37BB of the Income-tax Rules provides for
furnishing such information in Form 15CA and 15CB. Sub-section
(6) of Section 195 of the Act does not require the assessee to
deduct tax. What is required is furnishing information in the
specified form, namely, Form 15CA and 15CB. However, sub-
section (1) of Section 195 of the Act requires the assessee to
deduct tax at the time of credit of such income to the account of the
payee. The Apex Court in Transmission Corporation of A.P.
Ltd.(supra) examined this issue and while interpreting Section
195(1) of the Act held that the taxpayer in India is liable to deduct
tax in case the payment made to non-resident is liable for taxation in
India. Therefore, the assessee is required to deduct tax under
Section 195(1) of the Act. Provided the non-resident recipient is
liable to pay tax. The violation of Section 195(6) of the Act and
failure to file certificates in Form 15CA and 15CB is punishable
separately under Section 271I of the Act. Therefore, at the best, for
the failure of the assessee for furnishing Form 15CA and 15CB, the
Assessing Officer may initiate penalty proceeding under Section
271I of the Act. However, there cannot be any disallowance under
23 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
Section 40(a)(ia) of the Act. In other words, Section 195(6) of the Act, which requires the assessee to furnish information, does not require the assessee to deduct tax at the time of payment. Therefore, the question of disallowance under Section 40(a)(ia) of the Act does not arise for consideration.
In view of the above discussion, the payment made to the non-residents at UK, USA, Germany and Spain cannot be disallowed. Accordingly, the order of the CIT(Appeals) in respect of payment made to the non-residents at USA and UK is set aside and the disallowance made by the Assessing Officer is deleted.
In the result, the assessee’s appeal in I.T.A. No.598/Chny/2017 is allowed. However, the Revenue’s appeal in I.T.A. No.2189/Chny/2017 is dismissed. Order pronounced in the court on 11th October, 2019 at Chennai. sd/- sd/- (एस. जयरामन) (एन.आर.एस. गणेशन) (S. Jayaraman) (N.R.S. Ganesan) लेखा सद�य/Accountant Member �या�यक सद�य/Judicial Member चे�नई/Chennai, �दनांक/Dated, the 11th October, 2019.
Kri.
24 I.T.A. No.2189/Chny/17 I.T.A. No.598/Chny/17
आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. �नधा�रती /Assessee 2. Assessing Officer 3. आयकर आयु�त (अपील)/CIT(A), Puducherry 5. �वभागीय ��त�न�ध/DR 6. गाड� फाईल/GF. 4. Principal CIT, Puducherry