DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, VISAKHAPATNAM vs. ALAKRAM INTERNATIONAL TRADING COMPANY PRIVATE LIMITED, KOLKATA

PER S. BALAKRISHNAN, Accountant Member :

The captioned three appeals are filed by the Revenue against the orders of the Ld. Commissioner of Income Tax (Appeals)-3, Visakhapatnam [CIT(A)] in appeal No. 732/2019- 20/10489/CIT(A)-3/VSP/2020-21, dated 26/02/2021 [ITA No. 181/Viz/2021]; appeal No. 728/2019-20/10485/CIT(A)- 3/VSP/2020-21, dated 26/2/2021 [ITA No. 120/Viz/2021] and

3 appeal No. 730/2019-20/10487/CIT(A)-3/VSP/2020-21, dated

29/03/2021 (ITA No. 151/Viz/2021) arising out of the order

passed U/s. 143(3) r.w.s 153A of the Income Tax Act, 1961 for

the AY 2017-18. Since all these appeals are inter-connected,

these appeals are clubbed, heard together and disposed off in

this consolidated order. Appeal wise adjudication is given in the

following paragraphs of this order.

No. 120/Viz/2021 wherein the protective assessments have been

made by the Ld. AO and the grounds raised by the Revenue are

identical in nature. We shall take up ITA No. 118/Viz/2021 as a

lead appeal.

ITA No. 118/Viz/2021 (AY: 2017-18) (DCIT vs. M/s. Sri Bhagavan Niketan Ltd)

engaged in construction of residential houses at Marripalem,

Visakhapatnam in the name and style of ‘Happy Homes’, did not

file its return of income for the AY 2017-18. A search and

seizure operation U/s. 132 of the Act was conducted on

15/09/2017 by the Deputy Director of Income Tax (Inv.), Unit-

III(1), Visakhapatnam at the Registered Office premises of the

4 assessee-company in connection with the search and seizure

operations in the group case of Shri Alakram Satyanandam.

Simultaneously, survey operations U/s. 133A of the Act were

conducted at the office premises of the construction project

‘Happy Homes’, Marripalem, Visakhapatnam and consequent to

the search, the assessee company was centralized to DCIT,

Central Circle-2, Visakhapatnam vide proceeding of the Principal

Commissioner of Income Tax-4, Kolkata in F. No. Pr.CIT-

4/Tech/F-53/Centralization-Out/2017-18/11463-68, dated

13/3/2018. Accordingly, a notice U/s. 153A of the Act was

issued on 12/9/2018. In response to the notice, the assessee-

company filed its return of income on 29/11/2018 admitting an

income of Rs. 9,20,54,075/-. Thereafter, notice U/s. 143(2) of

the Act dated 18/2/2019 was issued and served on 24/2/2019.

Subsequently, notice U/s. 142(1) dated 14/3/2019 along with

questionnaire was issued and served on the assessee on

30/03/2019. In response, the Ld. Authorized Representative of

the assessee appeared and submitted the information called for.

During the course of search and seizure operations, certain

incriminating material was found and seized and it was noticed

that the assessee-company is in the construction of affordable

residential complex comprising of 360 residential units at

5 Marripalem, Visakhapatnam wherein the total saleable area for

the company is 4,87,031 sq ft. It was also noticed that inspite of

receiving advance for flats since FY 2014-15, the assessee-

company has not recognized any revenue in the return of income

filed till AY 2016-17 and also for the impugned assessment year.

It was pointed out to the assessee that the revised versions of

income computations and disclosure standards (ICDSs) were

issued vide CBDT Notification No. 87/2016 [S.O. 3079(E)], dated

29/9/2016 for the purpose of computation of income chargeable

to income tax which will apply to the AY 2017-18 and subsequent

AYs. Thereafter, Sri Alakram Satyanandam, Managing Director of

the assessee-company in his sworn statement recorded U/s.

132(4) of the Act on 14/11/2017 admitted to disclose the revenue

of the assessee-company on “Percentage Completion Method” as

mandated by the above CBDT Notification, for the AY 2017-18 in

the return of income filed in response to notice U/s. 153A of the

Act. Based on the incriminating documents found and seized as

Page No.4 of Annexure-A/Satyanandam/Res/01 wherein it was

mentioned that M/s. Alakram International Trading Company

Private Limited wherein Sri Alakram Satyanandam is a Director

has purchased 4 Acres of land in Vellanki Village, Anandapuram

for Rs. 16 Crs from DRK Reddy Educational Society. During the

6 course of the search proceedings in the office of M/s DRK Reddy

Educational Society on 16/9/2017, Sri Dwarampudi

Satyanarayana Reddy, Secretary of M/s. DRK Reddy Educational

Society in his sworn statement recorded U/s. 132(4) of the Act

admitted that he received a total consideration of Rs. 16 Crs (Rs.

4.13 Crs through cheque and Rs. 11.86 Crs in cash) for the sale

of 4 Acres of land in Vellanki Village, Anandapuram. Sri Alakram

Satyanandam in his sworn statement recorded U/s. 132(4) of the

Act on 14/11/2017 admitted that the assessee-company has

purchased 3.90 Acres of land from M/s. DRK Educational Society

for Rs. 16 Crs and has paid Rs. 11.86 Crs in cash in addition to

the consideration as per the registered sale deeds of Rs. 4.13 Crs.

On being questioned about the source of Rs. 11.86 Crs in cash

Sri Alakram Satyanandam in his statement recorded U/s. 132(4)

of the Act dated 14/11/2017 stated that the source is from the

share application money received from M/s. Dolphin Highrise for

Rs. 2 Crs and share application money from M/s. Bhagavan

Niketan for Rs. 9.80 Crs. It was noticed that as per the cash book

impounded of M/s. Alakram International Trading Company Pvt

Ltd for the period 1/4/2016 to 31/3/2017 there is no such

transaction of providing share capital by the assessee-company

to M/s. Alakram International Trading Company Private Limited.

7 Thereafter, a show cause notice was issued to the assessee to

prove the identity, creditworthiness of the parties and

genuineness of the transactions. In response, the assessee

submitted its reply dated 23/12/2019 stating that the sources of

the share application money invested by the assessee-company

are out of the funds available with the company by way of income

received during the FY 2016-17 and all these transactions are

recorded in the books of accounts and the company has filed the

return of income and paid the taxes accordingly. Further, it was

submitted by the assessee company that the cash books and

other documents impounded during the search proceedings are

not audited books of accounts while the return of income filed by

the assessee is based on the audited financials and it was

submitted to the Ld. AO during the assessment proceedings. The

Ld. AO did not accept the explanation of the Assessee’s

Representative and observed that the assessee has revised the

cash book by showing cash balance of Rs. 6,32,87,966/- as on

1/4/2016 and has also taken advantage of telescoping of profit

offered under “Percentage Completion Method” for the cash

payments made towards share application to M/s. Alakram

International Trading Company Pvt. Ltd. The Ld. AO therefore

treated the source of payments remained unexplained and

8 assessed it substantively in the hands of M/s. Alakram

International Trading Company Pvt Ltd. And protectively in the

hands of the assessee-company by considering a sum of Rs.

8,25,03,350/- as unexplained investment U/s. 69 r.w.s 115BBE

of the Act. Aggrieved by the order of the Ld. AO, the assessee

filed an appeal before the Ld. CIT(A).

made by the Assessee’s Representative and the audited financial

statements and found that the transactions of share application

are recorded in the books of accounts of the assessee-company

and the assessee-company has filed the return of income

admitting a total income of Rs. 9.18 Crs and has paid the taxes

accordingly. Since the transactions are recorded in the books of

account of the assessee-company as well as in the books of

account of M/s. Alakram International Trading Company Private

Limited, the Ld. CIT(A) deleted the addition made by the Ld. AO

U/s. 69 of the Act thereby partly allowed the appeal of the

assessee. Aggrieved by the order of the Ld. CIT(A), the Revenue

is in appeal before us by raising the following grounds of appeal:

“1. On the facts and circumstances of the case, the Ld. CIT(A) erred in deleting the addition made by the AO of unexplained investment U/s. 69 r.w.s

9 115BBE of the Act holding that the Assessing Officer failed to establish that the investment made by the appellant were not recorded in the books of account even though the AO has made the addition with reference to the cash books impounded of M/s. Alakram International Trading Company Pvt Ltd., for a period of 1/4/2016 to 31/3/2017 as per which no such transaction of providing share capital was recorded in the books of the company.

that the transactions were not recorded in the books of accounts

impounded during the search and seizure operations and

thereafter the assessee has submitted revised books of accounts

before the Ld. AO, recording these cash transactions, is an

afterthought of the assessee and therefore, the Ld. AO has rightly

10 made the additions U/s. 69 of the Act. He therefore pleaded that

the order of the Ld. AO be upheld.

Per contra, the Ld. Authorized Representative of the

assessee submitted that the books of accounts seized and

impounded during the search and seizure operations were not

audited and the return of income was filed based on the audited

books of accounts. The Ld. AR referred to the paper book

wherein the audited financials were submitted before the Ld.

Revenue Authorities as well as before us. The Ld. AR also further

referred to the revised cash books wherein the cash transactions

are recorded in the books of accounts of the assessee-company

and hence no additions can be made U/s. 69 of the Act. The Ld.

AR fully supported the order of the Ld. CIT(A).

available on record as well as the orders of the Ld. Revenue

Authorities. Admittedly, there is a huge investment of Rs. 9.88

Crs by cash and cheque towards share application money in M/s.

Alakram International Trading Company Private Limited for

acquisition of 10,97,815 shares. The Ld. AO has accepted the

payments made by cheque to the extent of Rs. 1.63 Crs and

treated the balance amount of Rs. 8.25 Crs as unexplained

11 investment U/s. 69 r.w.s 115BBE of the Act. The case of the Ld.

AO is that the assessee has not recorded these cash transactions

in the books of accounts impounded during the search and

seizure operations, but has entered these cash transactions in

the revised books of accounts. However, the Ld. AO failed to

appreciate the fact that the return of income has been filed based

on the audited financial statements which discloses the cash

transactions in the books of accounts of the assessee-company.

Further, from the submissions of the Ld. AR, we find that the

assessee-company has also shown investments in 11,07,815

Equity shares of M/s. Alakram International Trading Company

Private Limited in Schedule-9 “Current Investments” which is an

Annexure to the Financial Statements for the FY 2016-17. The

Ld. AO has merely relied on the impounded books of accounts

and has concluded that these transactions are not recorded in

the cash book impounded during the search and seizure

operations. Further, the Ld. AO did not consider the fact that

the due date for filing of return of income for the AY 2017-18 has

not expired. The return of income filed by the assessee based on

the audited financial statement accounts were not considered by

the Ld. AO to the limited extent of the cash transactions /

investments by the assessee company. The Ld. AO however, has

12 not disputed the total income declared by the assessee while

filing the return of income U/s. 153A of the Act based on the

audited Financial Statement Accounts. It is also found in the

order of the Ld. AO that the Ld. AO has merely based on

surmises and assumptions and has framed the assessment by

taxing the investments made by way of cash U/s. 69 of the Act.

We extract below section 69 of the Act for the sake of brevity.

“Sec 69. Where in the financial year immediately preceding the assessment year the assessee has made investments which are not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers no explanation about the nature and source of the investments or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, the value of the investments may be deemed to be the income of the assessee of such financial year.”

investments which were not recorded in the books of accounts

maintained by the assessee and has been made in the Financial

Year immediately preceding the Assessment Year are the

prerequisites for invocation of section 69 of the Act. However, in the

instant case, it is found that the assessee had sufficient cash balance for

making investments in M/s. Alakram International Trading Company

Private Limited which was duly recorded in the books of accounts and

which was disclosed while filing the return of income. We therefore find

13 that the Ld. CIT(A) has rightly considered the above facts and therefore

we find no infirmity in the order of the Ld. CIT(A). Accordingly, all the

grounds raised by the Revenue are dismissed.

I.T.A. No.120/Viz/2021 (Assessment Year :2017-18) (DCIT vs. M/s. Dolphin Highrise Private Limited)

grounds of appeal:

“1. On the facts and circumstances of the case, the Ld. CIT(A) erred in deleting the addition made by the AO of unexplained investment U/s. 69 r.w.s 115BBE of the Act holding that the Assessing Officer failed to establish that the investment made by the appellant were not recorded in the books of account even though the AO has made the addition with reference to the cash books impounded of M/s. Alakram International Trading Company Pvt Ltd., for a period of 1/4/2016 to 31/3/2017 as per which no such transaction of providing share capital was recorded in the books of the company.

14 entries of investment in share application money is available.

to that of the Grounds of Appeal raised in ITA No.118/Viz/2021

(AY 2017-18) in the case of DCIT vs. M/s. Sri Bhavan Niketan

Limited (supra). Since the Grounds raised in both these appeals

are identical, our decision given in the appeal ITA No.

118/Viz/2021 mutatis mutandis applies to this appeal of the

Revenue in ITA No. 120/Viz/2021. Accordingly, we hereby hold

that there is no infirmity in the order of the Ld. CIT (A) and

dismiss all the grounds raised by the Revenue.

ITA No. 151/Viz/2021 (AY: 2017-18) (DCIT vs. M/s. Alakram International Trading Co. (P) Ltd)

CIT (A)-3, Visakhapatnam in appeal No. 730/2019-

15 20/10487/CIT(A)-3/VSP/2020-21, dated 29/3/2021 arising out

of the order passed U/s. 143(3) r.w.s. 153A of the Act for the AY

2017-18.

engaged in the business of retail trade of garments in the name

and style of ‘Pavan-Family Offer Mall’ and also involved in the

construction of affordable dwelling units in the name of ‘Dolphin

Heights’. A search and seizure operation U/s. 132 of the Act was

conducted on 15/9/2017 by the Deputy Director of Income Tax

(Inv.), Unit-III(1), Visakhapatnam at the Registered Office

premises of M/s. Alakram International Trading Company Private

Limited, Kolkata in connection with the search and seizure

operations in the Group cases of Shri Alakram Satyanandam.

Simultaneously, survey operations U/s. 133A of the Act were

conducted on the retail garments shop and in the office at

construction site of Dolphin Heights. The assessee-company has

not filed its return of income U/s. 139(1) of the Act and

subsequently, after search proceedings, the assessee filed its

return of income U/s. 139(4) on 7/11/2017 admitting a total

income of Rs. 2,80,85,895/-. The case was centralized to Central

Circle (2), Visakhapatnam vide proceedings of the Principal

16 Commissioner of Income Tax, Kolkata vide order No. 12/2017-18,

dated 5/3/2018. The assessee company in response filed its

return of income on 30/11/2018 admitting a total income of Rs.

2,80,85,895/-. Thereafter, a notice U/s. 143(2) of the Act dated

18/2/2019 was issued and served on the assessee on

24/2/2019. Subsequently, notice U/s. 142(1) of the Act along

with a questionnaire was issued and served on the assessee on

30/3/2019. In response to the above notices, the assessee

furnished its books of accounts and other required information.

On verification of the books of accounts it was noticed that the

assessee has not recognized the revenue in the return of income

filed till AY 2016-17 as well as for the impugned Assessment

Year. It was pointed out to the assessee that the revised versions

of income computations and disclosure standards (ICDSs) were

issued vide CBDT Notification No. 87/2016 [S.O. 3079(E)], dated

29/9/2016 for the purpose of computation of income chargeable

to income tax which will apply to the AY 2017-18 and subsequent

AYs. Thereafter, Sri Alakram Satyanandam, Managing Director of

the assessee company while recording the statement U/s. 132(4)

of the Act on 14/11/2017 agreed to disclose the revenue of the

assessee company on “Percentage Completion Method” for the AY

2017-18 and accordingly filed the return of income in response to

17 the notice U/s. 153A of the Act for the AY 2017-18 admitting a

total income of Rs.2,42,10,414/-. It was noticed that the

assessee company has purchased an immovable property of 3.90

Acres of land at Vellanki, Anandapuram, Visakhapatnam from

M/s. DRK Reddy Educational Society for a registered sale

consideration of Rs. 4.13 Crs. During the course of search

proceedings a hand written paper was found and seized vide

Annexure-A/Satyanandam/Res/01 wherein the value of the

property was mentioned as Rs. 16 Crs for 4 Acres of land. During

the course of the search proceedings in the office of M/s. DRK

Reddy Educational Society, Sri Dwarampudi Satyanarayana,

Secretary of M/s. DRK Reddy Educational Society admitted that

the total consideration of Rs. 16 Crs (Rs. 4.13 Crs through

cheque and Rs. 11.86 Crs in cash) paid. It was explained by Sri

Alakram Satyanandam, Director of the assessee-company, in his

sworn statement recorded U/s. 132(4) of the Act on 14/11/2017

that the source of cash is the share application money received

from M/s. Dolphin Highrise Private Limited and M/s. Sri

Bhagwan Niketan Private Limited. It was observed by the Ld. AO

that M/s. Dolphin Highrise Private Limited has invested a sum of

Rs. 1,79,00,1000/- as share application / share capital money in

cash in the assessee’s company out of the income received during

18 the FY 2016-17. Further, it was also submitted by the assessee

that M/s. Sri Bhagwan Niketan Private Limited has invested a

total sum of Rs.9,88,03,350/- out of which a sum of Rs.

8,25,03,350/- was received in cash and the balance of Rs. 6.3

Crs by way of bank transactions. On verification of the balance

sheet for the year ending 31/3/2017 it was noticed that M/s.

Dolphin Highrise Private Limited was allotted 1,98,900 shares

and M/s. Bhawan Niketan Private Limited was allotted 11,07,815

shares. Subsequently, a show cause notice was issued to the

assessee on 16/12/2019 wherein the Ld. AO brought to the

notice of the assessee that as per the balance sheet for the FY

ending 31/3/2017 no such entry of share application money nor

any allotment of shares are available. The Ld. AO observed that it

is only a book entry without actual receipt of funds. Further, it

was also observed by the Ld. AO that as per the cash book

impounded for the period 1/4/2016 to 31/3/2017 no such cash

transaction of receiving share application money was found and

the assessee was asked as to why it should not be treated as

unexplained investment U/s. 69 of the Act. In response, the

assessee filed a reply on 23/12/2019 stating that the assessee

has received the funds from M/s. Dolphin Highrise Private

Limited and M/s. Sri Bhagwan Niketan Private Limited towards

19 share capital and these transactions are recorded in the books of

accounts. Further, the assessee also submitted that the cash

book found and impounded during the course of the search are

not audited books of accounts. The Ld. AO did not accept the

explanation of the assessee and found that the claim of the

assessee regarding the source of the cash is out of the share

capital, is only a book entry made in the financials without

corresponding actual flow of cash. The Ld. AO therefore

concluded that since the sources remained unexplained, the

same is treated as unexplained cash credit in the hands of the

assessee and taxed it U/s. 68 r.w.s 115BBE of the Act. The Ld.

AO found that no cash withdrawals corresponding to the receipts

in bank for linking the amount of Rs. 1.63 Crs through banking

channels as a source for cash payment for purchase of land, did

not accept the assessee’s explanation. Therefore the Ld. AO

treated a sum of Rs. 10,04,04,350/- [Rs. 8,25,03,350 + Rs.

1,79,00,1000] as unexplained cash credit U/s. 68 of the Act. The

remaining sum of Rs. 1.63 Crs received through banking

channels along with Rs. 18,95,650/- [Rs. 11.86 Crs – Rs.

11,67,04,350] was treated as unexplained investment towards

purchase of land U/s. 69 r.w.s 115BBE of the Act. Aggrieved by

20 the order of the Ld.AO, the assessee filed an appeal before the

Ld. CIT(A)-3, Visakhapatnam.

by the Assessee’s Representative and by relying on the decision of

the Hon’ble Delhi High Court in the case of CIT vs. Nipuan Auto

(P.) Ltd [2014] 49 taxmann.com 13 (Delhi) allowed the appeal of

the assessee. Aggrieved by the order of the Ld.CIT(A), the

Revenue is in appeal before us by raising the following grounds of

appeal:

“1. On the facts and circumstances of the case, the Ld. CIT(A) erred in deleting the addition made by the AO who held that the assessee failed to establish the receipt of cash as share application money which were not recorded in the books of account of respective companies viz., M/s. Bhagwan Niketan Limited and M/s. Dolphin Highrise Private Limited as per the impounded cash book.

supported the order of the Ld.AO.

Per contra, the Ld. Authorized Representative fully

supported the order of the Ld. CIT(A). The Ld. AR further

submitted that these cash transactions are being recorded in the

audited financial statements based on which the return of income

was filed by the assessee and hence recorded in the books of

accounts of the assessee-company and the investor companies.

He therefore pleaded that the order of the Ld. CIT(A) be upheld.

available on record as well as the orders of the Ld. Revenue

Authorities. The case of the Ld. AO is that the cash books and

the Balance Sheet impounded at the time of search does not

provide details of any entries pertaining to receipt of share

application money. However, the Ld. AO failed to consider the

fact that the return of income has been filed based on the audited

books of accounts which was produced during the scrutiny

proceedings before the Ld. AO for verification. It was submitted

22 by the Ld.AR that the investments in the assessee-company by

the investor companies were out of the funds available by way of

income received during the FY 2016-17. The Ld. AO has not

disputed the return of income filed investor companies but has

disputed the receipt of cash by the assessee-company towards

share capital. We also find from the paper book submitted by the

Ld. AR wherein financial statements disclose the allotment of

shares to M/s. Bhagwan Niketan Limited and M/s. Dolphin

Highrise Private Limited. The Ld. AO relied on the material

impounded during the search proceedings which did not contain

any details about the allotment of shares but has failed to

consider the audited financial statements, based on which the

return of income is filed, and submitted during the assessment

proceedings wherein it can be seen that the details of allotment

of shares and receipt of cash for subscription towards share

capital was duly recorded in the books of accounts by the

assessee-company. It was also clearly established by the

assessee that the cash payments were made out of the funds

available with the assessee-company by way of income during the

FY 2016-17. The Ld. AO has accepted the books of accounts for

the purpose of disclosure of the profit declared by the assessee-

company and investor companies while filing the return of

23 income U/s. 153A of the Act whereas did not accept the cash

transactions recorded in the books of account for the purpose of

receipts towards share capital. It was also noticed that the Ld.

AO has not rejected the books of accounts. Further, the Ld. AO

has accepted and satisfied with the genuinity of the share

application money received through banking channels amounting

to Rs. 1.63 Crs. The Ld. AO has not disputed the investment

made by M/s. Bhawan Niketan Limited and M/s. Dolphin

Highrise Private Limited but has only contested the cash receipts

from the investor companies towards share capital. The Ld. AO

failed to consider the fact that the investor companies have

declared income based on the audited books of accounts which

was submitted to the Ld. AO during the assessment proceedings,

which was utilized for subscribing to share capital. The Ld. AO

on the one hand accepted the income declared by the investor

companies but has denied to accept the fact that there is a cash

surplus in the books of accounts of the investor companies which

was invested in the investee company towards share capital. We

find that the Ld. CIT(A) has considered all the above facts and

has rightly deleted the addition made by the Ld. AO thereby

allowing the appeal of the assessee and therefore there is no

24 infirmity in the order of the Ld. CIT(A). Accordingly, all the Grounds raised by the Revenue are dismissed.

Pronounced in the open Court on 30th January, 2024.

Sd/- Sd/- (दु�वू� आर.एल रे�डी) (एस बालाकृ�णन) (DUVVURU RL REDDY) (S.BALAKRISHNAN) �या�यकसद�य/JUDICIAL MEMBER लेखा सद�य/ACCOUNTANT MEMBER Dated : 30/01/2024 OKK - SPS

आदेश क� ��त�ल�प अ�े�षत/Copy of the order forwarded to:- �नधा�रती/ The Assessee – M/s. Sri Bhagavan Niketan Limited, D.No. 1. V-122/A/1, Quality Haat, 1st Floor, Room No.4, S A Farooqu Road, Metlabruz, Kolkata-32, PIN: 700018, West Bengal. (ii) M/s. Dolphin Highrise Private Limited, D.No. V-122/A/1, Quality Hat, 1st Floor, S A Farooque Road, Metlabruz, Kolkata-32, PIN: 700018, West Bengal. (iii) M/s. Alakram International Trading Company Private Limited, D. No. V-122/A/1, Quality Haat, 1st Floor, Room No. 4, S A Farooque Road, Metllabruz, Kolkata-32, PIN: 700018.

25 राज�व/The Revenue – The Deputy Commissioner of Income Tax, 2. Central Circle-2, Pratyakshakar Bhavan, Sector-8, MVP Double Road, Visakhapatnam, Andhra Pradesh – 530017. 3. The Principal Commissioner of Income Tax, आयकर आयु�त (अपील)/ The Commissioner of Income Tax 4. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, �वशाखापटणम/ DR, ITAT, 5. Visakhapatnam गाड� फ़ाईल / Guard file 6. आदेशानुसार / BY ORDER

Sr. Private Secretary ITAT, Visakhapatnam