HARLAND CLARKE HOLDING SOFTWARE INDIA PRIVATE LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE 2(2), CHENN

आदेश / O R D E R

PER GEORGE MATHAN, JUDICIAL MEMBER

This is an appeal filed by the assessee against the order

passed by the Deputy Commissioner of Income-tax, Corporate Circle 4(2)

(‘AO) in No.H-502/TPO-2(1)/A.Y 2013-14 vide order dated 28.10.2016 in

pursuant to the directions issued by the Dispute Resolution Panel-2, (‘DRP),

Bengaluru in F.No.266/DRP-2/BANG/2016-17 dated 06.09.2017 for assessment year 2013-14.

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Assessee, and Mr.Srinivasa Rao Vara represented on behalf of the

Revenue.

grounds:-

“Grounds of Appeal

The grounds of appeal listed below are without prejudice to each other.

Ground of objection I — General ground

The order of the learned Deputy Commissioner of Income Tax, Company Circle 2(2), Chennal (‘Assessing Officer’ or ‘AO’) passed pursuant to the order of the learned Transfer Pricing Officer-V, Chennal (‘Transfer Pricing Officer’ or ‘TPO’) and the directions issued by the Hon’ble Dispute Resolution Panel — II (the ‘DRP’), to the extent prejudicial to the Appellant, is erroneous, bad in law, and contrary to the facts and circumstances of the case.

Issue I — Grounds relating to Transfer Pricing Matters Ground of objection 2 — Rejection of economic analysis of the Appellant without any cogent reasons

The Ld. AO/ TPO and the Hon’ble DRP have erred, in law and in facts by disregarding the economic analysis undertaken by the Appellant in accordance with the provisions of the Income tax Act, 1961 read with Income tax Rules, 1962 (the Rules) for determination of arm’s length price of the 1— international transaction of the Appellant. The TPO also conducted a fresh economic analysis for selection of comparable companies without providing any cogent reasons for undertaking the same.

Ground of objection 3— Objection on comparable companies

The learned AOITPO and Hon’ble DRP have erred in law and facts, by considering companies that do not satisfy the comparability parameters (evidenced from the website, annual reports and information available in the public domain) as comparable to the business of the Appellant. The Hon’ble DRP has accepted functional comparability of additional companies identified by the Assessee, however, inadvertently rejected the ground of objection raised by the Assessee.

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Ground of objection 4—Application of invalid fillers

The learned AO/TPO and the Hon’ble DRP have erred, in law and in facts, by modifying certain quantitative and qualitative filters applied by the Appellant (without providing any cogent reasons) and applying certain additional filters, which are arbitrary in nature, for the purposes of determination of arm’s length price.

Ground of objection 5 — Non-grant of working capital adjustment

The Lcd. AO/TPO arid Hon’ble DRP have erred in law and facts, by not making suitable adjustments to account for working capital differences between the Appellant vis-a-vis the comparables and in the process also neglected the Indian transfer pricing regulations, OECD guidelines on transfer pricing and various judicial precedence.

Ground of objection 6— Non-grant of risk adjustment

The TPO/AO and the Hon’ble DRP have erred, in law and facts, by not making suitable adjustments to account for differences in the level of risk of the Assessee vis-à-vis the comparable companies under sub-rule(3) of Rule- 10B.

Ground of objection 7— Erroneous re-characterization of the segments

The learned AO/TPO/ DRP have erred in facts and in circumstances of the case by erroneously understanding the business of the Company and adopting erroneous segmentation for the purpose of comparability analysis.

Ground of objection 8— Cherry picking of comparable companies

Without prejudice to the above, the ld. AO /TPO and the Hon’ble DRP have erred in law and facts, and violated principles of natural justice by not providing the detailed process (i.e. accept /reject matrix and the reason of rejections of the companies rejected qualitatively) of the fresh economic analysis conducted for identification of comparable companies, and thus have resorted to cherry picking of the companies undertaking non- comparable activities.

Ground of objection 9— Erroneous treatment of expenses The learned AOITPO has erred in law and facts, by considering provision for bad and doubtful debts to be non-operating item.

Ground of objection 10— Use of single year data (which was not available at the time of maintaining TP documentation) –

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The Ld. TPO/ AO and the Hon’ble DRP have erred in law and in facts, by determining the arm’s length margin! price using only Financial Year 2012-13 data, as against multiple year data adopted by the Appellant without appreciating that multiple year data has an influence on the determination of transfer prices in relation to the international transactions and also not giving due cognizance to the rules notified by the CBDT vide Notification No. 83/2015 [F.No. 142/25/2015-TPOJ.

Ground of objection 11- +/-3% tolerable range as provided in proviso to Section 92C(2) of the Act.

The Ld. TPO/ AO and the Hon’ble DRP have erred in law and in facts, in computing the arm’s length price without giving benefit of +/- 3 percent under the proviso to Section 92C of the Act.

Issue 2—Grounds relating to Corporate Tax Matters

Ground of objection 12 — Depreciation on computer software

The learned AO has erred in treating computer software as ‘Intangible assets’ eligible for depreciation at the rate of 25 percent as against treating it as ‘Computers including computer software’ eligible for depreciation at the rate of 60 percent as claimed by the Appellant.

Ground of objection 13 —Set-off of brought forward Minimum Alternate Tax (‘MAT’) credit

The learned AO has erred in law by not considering the eligible brought forward MAT credit to be set-off against the tax on assessed income.

Issue 3— Erroneous levy of interest under section 234B and 234C Ground of objection 14 — Erroneous levy of interest under Section 234B and Section 234C

The learned AO and the Hon’ble DRP have erred in levying interest under section 234B and 234C of the Act despite the fact that the additions to the income were un-anticipated and there would be consequential reduction in the interest once the application is allowed on the issue under appeal.

Issue 4— Initiation of penalty proceedinqs

Ground of objection 15— Initiation of penalty proceedings

The Id. AO has erred in initiating penalty proceedings under Section 271(1)(c) of the Act, without appreciating the fact that the transfer pricing adjustments arising on account of difference in the approaches adopted by

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the Appellant vis-à-vis the Ld. TPO/ AO does not amount to any concealment of particulars of income or furnishing of inaccurate particulars by the Appellant.

did not sish to press Grounds Nos.1,2,4,6,7,9 & 11. Ld.A.R has accordingly

withdrawn the said grounds. Consequently, the same are dismissed as not

pressed.

4.1 It was submitted by ld.A.R that Grounds Nos.3, 5, 8 and 10 were

issues against the order of the TPO and the direction of the DRP in respect

of Transfer Pricing matters.

4.2 It was a further submission that Ground No.12 was Corporate Tax

matter in respect of treating the software as ‘Intangible assets’ eligible for

depreciation at the rate of 25% or 60%.

4.3 It was a submission that Grounds Nos.13 relating to MAT Credit was

not argued by ld.A.R. Consequently, the same is dismissed as not pressed.

4.4 It was a submission that Ground Nos.14 was consequential in nture in

levying of interest under sections 234B & 234C of the Act and Ground No.15

was against the initiation of penalty u/s.271(1)(c) of the Act. The grounds

Nos.14 & 15 were not argued by ld.A.R. Consequently, the same is dismissed

as not pressed.

that the assessee has three lines of business; i) Software Development

Services, ii) Content Development Services and iii) on-line Tutoring services.

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It was a submission that when the assessee had done transfer pricing study,

it had treated the software development services and the content

development services as Information Technology Services (I.T.Services) and

in respect of on-line tutoring services, the same was treated as Information

Technology Enabled Services (I.T.E.S). It was a submission that the ld.

Assessing Officer however treated the software development services as

Information Technology Services, but treated the content development

services and the on-line tutoring services as Information Technology Enabled

Services. It was a submission that the software development services

involved software development process. It was a submission that no

adjustment was found necessary by the ld. Assessing Officer in respect of

software development services, income earned from software development

services was disclosed by the assessee. In respect of content development

services, which was in nature of transforming the business requirement of

the assessee’s group companies into instructional design, story board

creation, animation, graphics and learning. In respect of online tutoring

services, which involved providing on-line tutoring services to its customers

as per the direction of its group industries. The ld. Assessing Officer found

that the PLI adopted by the assessee, when compared to net margin of

selected comparables were lower, in consequential made an adjustment

about 10.53%. It was a submission that the assessee’s profit margin was

10.37% and the profit margins of the comparables was arrived at 20.90%.

Thus, the difference of 10.53% differential was adjusted upwards. It was a

submission that the assessee was not challenging the shifting of the content

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development services from Information Technology Services to Information

Technology Enabled Services. The assessee was basically challenging the

comparables. It was a submission that the claim of assessee revolved around

the exclusion of 4 of the comparables as taken by the ld. Assessing Officer

and inclusion of one comparable, which had been discarded by the ld.

Assessing Officer. The ld.A.R drew our attention to list of comparables taken

by the TPO at page 25 of the Paper book which is as follows:

Comparables Margin (OP/OC) E4e Health Care Ltd 19.24 Jindal Intelicom Ltd 7.71 MPS Ltd.(Rejected by DRP) 28.22 Microgentic Systems Ltd. 16.25 ICRA Online Ltd. 25.48 Infosys BPO ltd 29.28 Acropetal Technologies Ltd 14.43 Hartron communication Ltd. 33.60 Accentia Technologies Ltd. 13.90 Average 20.90%

5.1 Further, ld.A.R filed a Note as follows:-

Harland Clarke Holding Software India Private Limited (Harland India)

Before the Income Tax Appellate Tribunal — Chennai “D” Bench Summary of Key contentions — Assessment Year 2013-14

Key Objections on comparable companies

Name of Companies to be Excluded –Ground No.3 Support from judicial company pronouncements-covered

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judgements GE Converteam EDC Private Hartron Significant fluctuations in the turnover - Where Limited (ITAT Chennai )A.Y 2009- revenue has increased 350% compared to previous Communi 10 (Page 8 in para 9) years (Page 6 of paper book 3) cations Ltd Bangalore Tribunal in case of SAP High fluctuation in margins -The margins of Hartron (harton) LABS India Pvt. Ltd. (Page 6 in para 7.2.2) has highly fluctuated which is as follows: Q Logic (India) (P.) Ltd. (ITAT Year 2010- 2011- 2012- 2013- 2014- PUNE) (Page 9 in para 15) 11 12 13 14 15 Turnover 2.08 3.81 18.43 10.33 14.37 INR Crores % of - +82.86 383.1 -43.95 39.19 change

Year 2010- 2011- 2012- 2013- 2014- 11 12 13 14 15 Profit/Loss -2.03 -1.41 4.61 -0.26 -3.74 INR Crores % of -97.56 25.05 -26.02 -37.15 -2.52 change

-Unreliable financial information –Qualification in theAuditor report. (Page 14 of Paper book 3)

Pg.439-440 of paperbook for objections before DRP Pg.332-334 of paperbook for objections before TPO

Significant difference in turnover -(Infosys Turnover - Bombay High Court in Infosys is INR 1831 crores case of Pentair Water BPO Ltd [39 times the turnover of the Assessee] India Pvt Ltd (Page 18) (Infosys) - Significant brand value in market. - Difference in nature of services — Varied High end - BNP Paribas Global services. Securities (I.T.A.No.2141/ Significant asset base - lnfosys BPO’s Asset is of CHNY/2017) AY 2013-14 2446 Crores whereas of the Assessee 1.63 Crores. (Page-3 in para 5)

Pg. 444-445 of paper book for objections before DRP Pg. 332-334 of paper book for objections before TPO

ICRA - Functionally different— KPO services & High-end. - Delhi High court in Online (Page 112 of PB 3) Evalueserve SEZ Limited ‘ (Gurgaon) Pvt. Ltd. ‘lCRA’ Pg. 435-437 of paper book for objections before DRP (Page 3 in para 6) Pg. 322-323 of paper book for objections before TPO - Delhi High Court in Rampgreen Solutions Private Limited

E4e Functionally different — KPO services & High end Delhi High court in Health (Page 136 of PB 3) Evalueserve SEZ Business - Absence of Segmental information — Varied (Gurgaon) Pvt. Ltd.

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(E4e) services & no segment. (Page 3 in para 6) - Bangalore ITAT in Pg. 448 of paper book for objections before DRP Nvidia Graphics Private Limited

Delhi High Court in R Different Financial year –Data Extrapoltion can be Mckinsey Knowledge Systems obtained. Centre India Pvt Ltd. (addition (Page 11) ally Pg. 349-351of paper book for objections before DRP Pg. 451-452 of paper book for objections before TPO identifie Delhi ITAT in case of United d by Health Group Information assessee Services Private Ltd before (Page 29 in para 54) TPO)

Operating margins of comparables are considered without adjusting for differences arising out of working capital positions.

Particulars E4e Jindal Microgen IRCA Infosys Acroetal Hartron Average WC days 70 35 30 39 278 4 67 67

Particulars WC Days Comparable companies (Average) 67 Harland India 15

Judicial Precedents - Delhi ITAT in Agilent Technologies (International) Pvt Ltd., - M/s.Mobis India Ltd Vs. DCIT (ITA No.2112/Mds./2011 in Hon’ble Chennai ITAT.

Harland India’s Margins – 10.39% (Page 17of Appeal set)

TPO Comparables E4e Health Care Ltd Jindal Intelicom Ltd MPS Ltd.(Rejected by DRP) Microgentic Systems Ltd. ICRA Online Ltd. Infosys BPO ltd Acropetal Technologies Ltd Hartron communication Ltd. Accentia Technologies Ltd.(Rejected by DRP)

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TP Study comprables Aptech Ltd. Compucom Software Ltd. First Object Technology Ltd. Usha Martin Education Ltd. NIIT Ltd. Education initiative Pvt Ltd.

• The Company has claimed depreciation on software licenses at the rate of 60 percent.

• The description of additions made to computer software during the subject AY are as follows:

Description of Asset Date put to Amount use (inINR) Microsoft Visual Professional 2-May-12 9,01,602 Microsoft Visual Studio Professional 2-May-12 4,55,107 Minitab 16 for windows license 9-May-12 79,111 SPSS Statistic License 18-May-12 1,28,605 8 to 16 partition license 14-Jun-12 61,619 Vmware License 1-Jul-12 6,71,153 Access 2010 lifetime license 10-Jul-12 8,231 Net Software 25-Oct-12 97,801 Vmware License 4-Dec-12 1,48,926 ReSharper 7.0 C# Edition Commercial 13-Dec-12 14,106 License ReSharper 7.0 Edition Commercial 18-Feb-13 15,380 License Total 25,81,641

Remarks made by the learned AO The learned AO has relied on the ruling of Sony India Private limited Vs. Additional CIT [ ITA Nos. 4008 & 4994/Del/20101 (Delhi Tribunal)

Contention of the Appellant • The decision relied by the AO is prior to amendment to Income tax rules, 1962 (‘the Rules’). • The following case laws have held that computer software is eligible for depreciation at 60 percent: • I-Flex Solutions Ltd [225 Taxmann 37] (Bombay HC) • M/s TNQ Books and Journals Pvt Ltd [in ITA 752/Mds/2015] (Chennai Tribunal) • Amway India Enterprises vs. DCIT and M/S SQL Star International Limited [301 ITR 1] (Delhi Tribunal) (Special Bench)”

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communication Ltd., was an incomparable with the assessee because

there was significant fluctuations in the margins. It was submitted by

ld.A.R that the turnover of M/s.Hartron communication Ltd., is also

substantially higher than that of the assessee. M/s.Hartron

communication Ltd., was also in the business of health care services

and consequently could not be compared to that of the assessee. In

respect of variation in respect of the margins, ld.A.R placed reliance on

the decision of the Co-ordinate Bench of this Tribunal in the case of

M/s.GE Converteam EDC Pvt. Ltd., in ITA No.973/Mds/2014 vide order

dated 25.01.2017 wherein relying upon the decision of Delhi Bench in

the case of M/s.Ciena India Pvt Ltd., in ITA No.1453/Del./14 dated

24.04.2015 wherein it has been held that Once it is held that the

profits do not represent fair profitability on year to year basis, this

company loses its tag of an effective comparable.

6.1 In respect of second comparable being M/s.Infosys BPO Ltd.,

it was submitted by ld.A.R that the same was not liable to be

considered as a comparable in so far as M/s.Infosys BPO Ltd., is much

larger company comparable to that of the assessee company and the

turnover of M/s.Infosys BPO Ltd., was 39 times the turnover of the

assessee and M/s.Infosys BPO Ltd., had significant brand value in

market. For this ld.A.R placed reliance on the decision of Co-ordinate

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Bench of this Tribunal in the case of M/s.BNP Paribas Global Securities

in ITA No.2141/Chny/2017 dated 06.03.2018.

6.2 In respect of third comparables being M/s.ICRA Online Ltd.,

it was submitted by ld.A.R that the said comparable was not in the

processing services, more specifically known as KPO Services, which is

hired services. It was a submission that as KPO services were specific

services and hired services, the same cannot be compared to the

services rendered by the assessee.

6.3 In respect of fourth comparables being M/s.E4e Health

Business, It was a submission that the said comparable was again in

the KPO services and there was no segmented information available in

respect of the same. It was a prayer that this company was to be

excluded as incomparable.

6.4 In respect of fifth comparables being M/s.R.Systems, it was

submitted by ld.A.R that this company was liable to be treated as one

of the comparables, but the same had been rejected by the TPO and

the DRP on the ground that the financial year was different. It was a

submission that M/s.R.Systems was following financial year from

January to December, whereas the assessee was following financial

year from April to March. It was a submission that the assessee had

re-worked the account sof the said comparable and had taken average

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of the quarterly results and placed the same before the TPO and the

DRP. It was a submission that this comparable was liable to be

considered. In respect of M/s.R.Systems, ld.A.R placed reliance in the

decision of Delhi High Court in the case of MCKINSEY Knowledge

Centre India Pvt. Ltd., in ITA 217/2014 dated 27.03.2015 wherein it

has been held that if from the available data on record, the results for

financial year can reasonably be extrapolated, then the comparable

cannot be excluded solely on the ground that the comparables have

different financial year endings. It was a submission that working

capital adjustment was liable to be granted to the assessee.

depreciation on the software license @ 60%. The break-up of the cost

of the software license was specifically shown at Para-7 of the Note

submitted by the ld.A.R. Ld.A.R placed reliance on the decision of the

Bombay High Court in the case of M/s.I-Flex Solutions Ltd. reported

in225 Taxmann 37 (Bom.) wherein the Hon’ble Bombay High Court

had held that in the case of that assessee, the software cannot be

worked in isolation and it has to be loaded on the computer and

consequently, it was an integral part of the computer in consequence

the software was clubbed with the computers as depreciable asset

eligible for depreciation @ 60% as against 25% as intangible asset

granted by the ld. Assessing Officer.

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the directions of the DRP.

the issue raised by the assessee, in respect of M/s.Hartron

communication Ltd., which has been claimed for exclusion by the

assessee, on account of the high turnover, and fluctuations are in

margins. It is noticed that Hon’ble Delhi High Court in the case of

M/s.MCKINSEY Knowledge Centre India Pvt Ltd., referred to supra,

which has been referred to by the assessee itself shows that if from

the available date on record, the results for the financial year can be

reasonably extrapolated, then the comparable cannot be excluded

solely on the ground that the comparables have different financial year

endings. Applying the said principles clearly shows that there is a

variation in the margins for various assessment years, does not mean

that the margins for particular year cannot be considered. It would be

very much available to the assessee to point out the reasons for the

higher rate of margins in the case of particular comparable. But that is

not open, what is specifically kept in mind that is that method had

been applied herein, is TNMM i.e. Transactional Net Margin Method,

whether the turnover is high or not, would not make a different nor

would be the question working capital adjustments be required, what

is being compared as a percentage of profitability. It is very much

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open to the assessee to point out how the percentages as disclosed by

the comparables are higher on account of from specific reasons as

long as the products deal with the comparables and the assessees are

comparable, then it is only a net margin, which is being compared. It

would not lead to the requirements of the exclusion of any particular

comparable. In the case of M/s.Hartron communication Ltd., no such

specific reason for exclusion has been pointed out. In the

circumstances, we are of the view that the comparables taken by the

ld. Assessing Officer /TPO representing M/s.Hartron communication

Ltd., does not call for exclusion. The same also goes for the case of

M/s.Infosys BPO Ltd. It is the TNMM method, which is being applied

and the margins are in the percentage and no way such margins are

effected substantially on account of the turnover. In fact, from the

Note of the assessee, the assessee itself said that the turnover of

M/s.Infosys BPO Ltd., is 39 times the turnover of the assessee.

However, the asset basis of the M/s.Infosys BPO Ltd., is `2446 crores

whereas that of the assessee is `1.63 crores. This clearly shoes that

M/s.Infosys BPO Ltd., is holding much higher asset possession, which

would fairly lead to higher depreciation, and high capital costs. It

would only go to represent its profitability. In respect of M/s.ICRA

Online Ltd., the assessee claims the same to be KPO services more

specifically Knowledge processing services. In respect of E4e Health

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Business also, the assessee claims the same to be KPO services.

M/s.R.Systems, which has been claimed by the assessee to be

included, is also KPO services. Knowledge Processing Out sourcing, the

said services include research, information gathering and information

driven force. KPO is the service offered learning solution, content

development etc. This is obtained from typing KPO or Knowledge

Processing services on the internet in Google. Clearly the assessee has

admitted itself in the business of content developments and on line

tutoring, thus the assessee itself is in the KPO services, therefore it

would be held that ICRA Online Ltd., or E4e Health Business, or in any

different functioning, consequently the same has correctly taken as

comparable. M/s.R.Systems has been additionally identified by the

assessee as comparable, but has been excluded by the TPO and DRP

on account of different financial years, cannot be excluded in so far as

the said M/s.R.systems is also doing the system of KPO and the

finance of the said M/s.R.Systems has been re-worked on quarterly

basis and the average of the same has also been determined by the

assessee. The average of which has been produced before the TPO

and the DRP. The same being comparable to the assessee’s business,

the ld. TPO is directed to re-work the PLI after taking into

consideration M/s.R.systems as the comparable. The assessee is to

provide the financial re-working to the TPO for the necessary

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adjustments. In the circumstances, the prayer of exclusion of

M/s.Harton Communictions, M/s.Infosys BPO Ltd., M/s.ICRA Online

Ltd., and E4e Health Business from the list of comparables stands

rejected and the assessee’s request for including of M/s.R.Systems as

comparable stands accepted.

mentioned earlier the methodology applied herein is TNMM, no specific

adjustments towards working capital is permitted, in so far as making

only an adjustment of one item being working capital will make the

financials of the comparable unworkable. What is comparable is the

percentage of the margins, and obviously when arriving at the margins

for each of the comparables, such comparables would have taken into

consideration their cost of working capital. Therefore, any tinkering to

that would have a negative impact, which could be many of the

financials of comparables unworkable. It must be remembered that

when arriving at margins, various components would go into its

calculations, such as the cost of capital, the number of employees,

number of working days, type of assets, cost of assets etc. If each of

these is to be adjusted, then there would be no comparison. Basically,

TNMM what is being looked at, is the margin that normally comparable

business would generate. This being so, the working capital

adjustments applied for stand rejected.

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the software, the list of the software on which the assessee is claiming

depreciation clearly shows that these are not softwares that running

the computes. Admittedly, these softwares can be used in a computer

only, but the computer is not dependent on these softwares. These are

softwares, which are used by the assessee for its specific business

purposes. A perusal of the decision of the Bombay High Court in the

case of CIT Vs.I-Flex Solutions Ltd., in [2014] 46 Taxmann.com

88(Bom.) says that the Appellate Authority therein had held that the

software therein was an integral part of the computer. The software in

the case of the assessee is not an integral part of the computer, but

are softwares which are used in the computers for the specific

business purpose of the assessee. For computer to run there are basic

specific software, these softwares are an integral part of the computer.

As without such software, the computer would be just a box incapable

of doing anything or function as a computer. Now to such a computer,

further softwares are added, depending upon the business

requirements of the assessee, those softwares are not an integral part

of the computers. In the present case, the softwares on which the

assessee is claiming depreciation @ 60% are not such softwares,

which are the integral part of the computers, but that the list of

software mentioned by the assessee, which are used for the specific

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business purpose of the assessee, in consequence the same cannot be

held as integral part of the computer, and cannot be eligible for

depreciation @ 60%. Ground No.12 of the assessee’s appeal stands

dismissed.

Order pronounced in the open court after conclusion of hearing on 30th October, 2018, at Chennai.

Sd/- Sd/- (एस जयरामन) ( जॉज� माथन) (S. JAYARAMAN) (GEORGE MATHAN) लेखा सद�य/Accountant Member �या�यक सद�य/JUDICIAL MEMBER चे�नई/Chennai �दनांक/Dated: 30th October, 2018. K S Sundaram आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 3. आयकर आयु�त (अपील)/CIT(A) 5. �वभागीय ��त�न�ध/DR 2. ��यथ�/Respondent 4. आयकर आयु�त/CIT 6. गाड� फाईल/GF