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Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM
Before: SHRI DUVVURU RL REDDY, HON’BLE & SHRI S BALAKRISHNAN, HON’BLE
Per Shri S.Balakrishnan, Accountant Member :
This appeal is filed by the assessee against the final assessment order passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (in short ‘Act’) in DIN & Order No.ITBA/AST/S/143(3)/2022-23/1043663982(1) dated 29/06/2022 for the Assessment Year (A.Y.)2018-19 arising out of the directions of the Learned Dispute Resolution Panel-1, Bengaluru-1 in F.No.209/DRP-1/BNG/2021-22 dated 23.05.2022 passed u/s 144C(5) of the Act for the A.Y.2018-19. 2 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
Brief facts of the case are that the assessee is a company, engaged in the business of export of processed and frozen shrimp, shrimp feed and power generation from windmills. The assessee entered into various international transactions with its Associated Enterprises (AE) and bench marked it’s international transactions under Transaction Net Margin Method (TNMM). The assessee filed it’s return of income for the assessment year 2018-19 on 28.11.2018 admitting a total income of Rs.300,91,81,980/-. The case was referred to the Transfer Pricing Officer [TPO] for determining Arms Length Price (ALP) u/s 92CA(3) in respect of its international transaction entered into with AE. In response to the notices of the Ld. TPO, the assessee filed various submissions online, through e-proceeding facility from time to time. The Ld.TPO vide its order in DIN No. ITBA/TPO/F/92CA3/2021-22/1034557999(1) dated 31/07/2021 has recommended the following adjustments :
Sl. Adjustment u/s No. Description 92CA(3)(in Rs.)
Corporate Guarantee 1,62,65,401
Outstanding Trade receivable 6,06,88,411 Total adjustment u/s 92CA(3) 7,69,33,812
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Pursuant to the order of the Ld.TPO, the AO has passed a draft assessment order u/s 143(3) r.w.s. 144C of the Act on 21.09.2021 and made an upward TP adjustment and assessed the total income at Rs.308,75,13,245/- by making the following disallowances :
Disallowance u/s 80G 1,69,500
Disallowance u/s 92 CA(3) 7,69,33,812
Disallowance u/s 14A r.w.Rule 8D 12,27,953 Total 7,83,31,265
Aggrieved by the order of the Ld.AO, the assessee filed objections before the Ld.DRP-9, Bengaluru and challenged the upward adjustments. The Ld.DRP, relying on various judicial precedents confirmed the disallowance proposed by the AO, but directed the AO to verify the claim with regard to exemption of dividend from investment in Devi Sea Foods Inc., USA to the extent of 80,90,000/- and if found correct, exclude the same while computing the disallowance as per Rule 8D of I.T.Rules, 1962. Aggrieved by the order passed by the AO based on the directions of the Ld.DRP, the assessee is in appeal before us and raised the following grounds :
The Final Assessment order incorporating Transfer Pricing adjustment passed by the learned Assessing Officer
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(“AO”) pursuant to directions issued by the Dispute Resolution Panel (“DRP”) under the Income Tax Act, 1961 (“the Act”) is contrary to law, facts and circumstances of the present case. Adjustment towards interest on Overdue receivables
1 The Transfer Pricing Officer (TPO)/AO erred in imputing notional interest on overdue receivables from Associated Enterprise (AE) and the DRP erred in sustaining the said adjustment.
The DRP/ TPO/AO failed to appreciate that the delay in the realization of outstanding receivables from AE cannot be considered as an international transaction as it does not fall within the purview of the capital financing as contemplated under section 92B of the Act.
The DRP/TPO/AO erred in not appreciating the fact that the Act provides for taxing only real income whether received or accrued under the normal provisions.
The DRP/TPO/AO erred in not appreciating the fact that transfer pricing adjustment cannot be made on hypothetical and notional basis until and unless there is some material on record that there has been under charging of real income.
Without prejudice to the above, the DRP/TPO/AO erred in imputing notional interest on delayed receivables despite the fact that the primary transaction has already been tested and considered to be at arms length under Transaction Net Margin Method at the entry level , ought not to have separately benchmarked outstanding receivables.
The DRP/AO/TPO ought to have appreciated that the appellant has earned a very high arms length net margin than that of the comparable companies (ie., 2 0.98% as against 4.38% to 6.03% with export incentive considered as operating income and 12.49% and -0.38% without export incentive). It impliedly demonstrates that the appellant is compensated for cost o f delayed receivables through higher operating margin embedded in sales to AE.
Without prejudice to the above, the DRP/TPO/AO erred in not appreciating that the appellant has not charged
5 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
interest on delayed realization of outstanding receivables from Non-AE's and as such trade receivable transactions with respect to AE are to be deemed to have been done on arm's length basis by applying internal CUP method, as resorted by the appellant.
The DRP/AO/TPO ought to have appreciated that the internal CUP is superior and more appropriate in the given facts of the case compared to external CUP method adopted by TPO.
Without prejudice to the above, the DRP/TPO/AO erred in not considering the fact that that the CUP method mandates precise and exact comparability and as such the TPO erred in incorrectly adopting external CUP method and imputing interest as per SBI short term deposit rates, which is not applicable in respect of deemed secondary transaction.
The DRP erred in stating that details of Non –AEs relating to credit period, terms etc. was not provided without appreciating that the said details was already provided to DRP / TPO.
Without prejudice to the above, the DRP /TPO/AO erred in not appreciating that unlike in the ca se of a service provider who witnesses prompt realization of dues as the services are already rendered, the turnaround time of realization of invoices raised by an exporter would be wide as there would be delay in transit of goods to the purchaser.
Ground No.1 is general in nature, which does not require specific adjudication. The main issue in other grounds is with respect to upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises (AEs). The Learned Authorized Representative (Ld. AR) submitted that the assessee has adopted Transaction Net Margin Method
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(TNMM) and therefore the interest on outstanding receivables is subsumed in the Arm’s Length Price (ALP) charged to the AEs. The AR further submitted that the assessee’s operating margin is 20.98% as compared to the comparable selected by the Ld. TPO where the operating margin is at 4.38% to 6.03%. The Ld. AR confirmed that no interest is charged on the outstanding receivables either to AE or Non-AE parties. The Ld. AR relied on the following case laws: (i) PCIT vs. Kusum Health Care (P) Ltd – [2018] 99 [2020] 113 taxmann.com 393 (Delhi HC). (iii) Pegasystems Worldwide India Pvt Ltd vs. ACIT – [2015] 64 taxmann.com 470 (Hyd. Trib.) (iv) DCIT vs. CCL Products (India) (P) Ltd – [2019] 106 taxmann.com 11 (Visakhapatnam – Trib.) (v) Vestas Technology R & D Chennai Private Limited vs. ACIT – ITA No. 3081/Chny/2016 (Chennai Trib.) (vi) Gimpex (P) Limited vs. ACIT –[2019] 105 taxmann.com 365 (Chennai Trib.) (vii) Det Norske Veritas vs. ADIT – [2016] 67 taxmann.com 16 (Mum. Trib.) (viii) Hackett Group (India) Ltd vs. DCIT [2020] 116 Taxmann.com 631 (Hyd. Trib.) (ix) ERM India (P) Ltd. Vs. NEC [2021] 132 taxmann.com 220 (Delhi Trib.) (x) Turner International India (P.) Ltd vs. ACIT [2020]115 taxmann.com 334 (Delhi Trib.) (xi) Agilent Technologies India (P.) Ltd vs. DCIT – [2021] 124 taxmann.com 561 (Delhi Trib.) (xii) Indo American Jewellery Ltd vs. CIT – [2014] 44 taxmann.com 310 (Bombay HC).
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(xiii) Sharda Spuntex vs. PCIT – 93 taxmann.com 498 (Raj. HC) (xiv) CIT vs. Vaibhav Gems Ltd – 99 taxmann.com 2 (SC) (xv) CIT vs. Vaibhav Gems Ltd – [2017] 88 taxmann.com 12 (Raj. HC) The Ld. AR heavily relied on the ratio laid down in PCIT vs. Kusum Health Care (P) Ltd [2018] 99 taxmann.com 431 (Delhi).
The Ld. Departmental Representative (Ld. DR) argued that there are huge delays in the receivables from AEs and hence interest is to be charged on the same on notional basis. The Ld. DR referred to the expression of “international transaction” as given in Explanation (i)(c) to section 92B of the Act and argued that deferred receivables would constitute international transaction. The Ld. DR further argued that the deferred payments or receivables arising during the course of business is in the nature international transaction and hence interest to be charged on the same. The Ld. DR further countered that the notional interest cannot be subsumed in the TNMM. The Ld. DR also argued that non-charging of interest to non-AEs is irrelevant. The Ld. DR referred to the decision of the Delhi Tribunal in the case of Bechtel India Pvt Ltd in ITA No.6530/Del/2016, dated 16 thMay, 2017. 8 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
We have heard the rival submissions and perused the material available on record and the orders of the Authorities below. Similar issue was considered in the assessee’s own case for the A.Y.2017-18 in I.T.A.No.75/Viz/2022 dated 09.09.2022. For the sake of clarity, we extract relevant part of the order of the Tribunal (supra) as under :
“7. We have heard the rival submissions and perused the material available on record and the orders of the Authorities below. Admitted facts are that the assessee sells to both the AEs non-AE where the AE being the major debtor. There is no dispute with regard to the fact that receivables is included under the definition of international transaction consequent to the amendments made by the Finance Act, 2012 w.e.f 01.04.2002. Therefore we are of the considered view that there is no merit in the argument of Ld AR that receivables is not an international transaction. Whether separate adjustment is required to be made in respect of receivables is the subject matter. The assessee also submitted the working capital adjustment made to the operating margin of the comparable companies and the assessee. From the submissions made by Ld AR, we find that if the export incentives are considered as non-operating income, the operating profit ratio of the comparable companies is 1.28% as against the operating margin of 4.17% of the assessee. Alternatively, if the export incentives are considered as operating income, the operating margin of the comparable companies is 8.08% vis-à-vis the assessee at 12.15%. We find from the above working the assessee’s margin is significantly higher than the operating margin of the comparable companies. There may be a delay in the collection of receivables even beyond the agreed time limits due to a variety of factors which has to be decided on a case to case basis. When TNM method is considered as the most appropriate method, which was also not disputed by Revenue, the net margin thereunder would take care of such notional interest cost. It was further explained by Ld.AR that the impact of the delay in collection of receivables would have a bearing on the working capital of the assessee. We find that these working capital adjustments on the ALP has been already factored in its pricing / profitability vis-à-vis that of its comparables. We therefore are of the considered view that any further adjustment to the margin of the assessee on the outstanding receivables cannot be 9 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
justified and no separate upward adjustment on outstanding export receivables is required and therefore we direct the Ld.AO to delete the upward adjustment made towards overdue receivables from AE. We therefore allow this ground raised by the assessee.”
Respectfully following the ratio laid down by the coordinate bench of the Tribunal, we allow this ground raised by the assessee.
The assessee raised the following grounds with respect to adjustment towards corporate guarantee:
“3. 1. The TPO/AO erred in imputing corporate guarantee commission at the rate of 1.8% of the actual loan utilized by AE and the DRP erred in partially sustaining the said adjustment though it has given direction to reduce it to 1% of the actual loan utilized by A.E.
The DRP/TPO/AO failed to appreciate that the extending guarantee for loan taken by AE cannot be considered as an international transaction as it does not fall within the purview of “capital financing” as contemplated under section 92B of the Act.
The DRP/TPO/AO erred in not appreciating the fact that the Act provisions for taxing only real income whether received or accrued under the normal provisions.
The DRP/TPO/AO erred in not appreciating the fact that the Appellant has not incurred any cost in providing corporate guarantee and as such the Appellant cannot be expected to charge commission for providing corporate guarantee.
The DRP/TPO/AO failed to appreciate that the appellant has extended guarantee to its wholly owned subsidiary Devi Sea Foods Inc., USA (ie., Associated Enterprise) for furthering assessee’s own business and as 10 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
such it is shareholder’s function, which does not warrant a commission.
Without prejudice to the above grounds, the DRP/TPO/AO erred in holding that the extension of corporate guarantee has impacted the credit rating of the Assessee and consequently impacted the intangible asset without appreciating that actually there is no impact on the credit rating of the Assessee.
Without prejudice to the above grounds, the DRP/TPO/AO erred in holding that the extension of corporate guarantee is a liability and as such it has impact on the profits of the Assessee without appreciating that there was no default and as such no liability accrue during the subject AY.
The DRP erred in considering bank guarantee rate to be not less than one percent per annum on the amount guaranteed prescribed by CBDT vide Jun 2017 notification for the purpose of benchmarking the corporate guarantee transaction.
The DRP/TPO/AP failed to appreciate that commercial bank guarantee cannot be considered as an identical transaction under CUP method.
The DRP/TPO/AO erred in not appreciating the fact that the loan availed by AE was secured and the AE had sufficient current assets (i.e. loan utilized during the subject AY is U 1,87,08,352/- as against net current assets of U 3,52,08,209/-) approximately 1.88 times the credit availed by the AE. This shows that there was no chance of the Assessee being called upon by the bank to satisfy the obligation of the AE (and factually the same has not occurred till date as well).
11 The DRP/TPO/AO erred in not appreciating the fact that due to the skewed debt-equity ratio of the AE, the 11 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
banks would not be willing to grant loan unless it is guaranteed by the Parent (i.e. Assessee) and providing such guarantee is an onerous responsibility of a shareholder.
The DRP/TPO/AO ought to have appreciated that the provision of corporate guarantee has not resulted in reduction of rate of interest and the AE has not derived any benefit which has an impact on its profits or loss or assets.
The DRP/TPO/AO erred in not adopting any of the prescribed methods for benchmarking the corporate guarantee transaction.
Without prejudice to the above, the DRP/TPO/AO ought to have to appreciate that the 0.50% of the guarantee commission charged by the assessee on corporate guarantee given which comes to 0.80% of the actual loan utilized by A.E is higher than that of the 0.5% rate of guarantee commission as held in various judicial precedents.
In any event, the rate of 1% rate of corporate guarantee determined by DRP is high and arbitrary.
The issue raised in the Grounds of Appeal is with respect to adjustments made by the TPO/DRP in the corporate guarantee commission on the gross guarantee given to AE. The Ld. AR pleaded that it is not an international transaction as the assessee has not charged the AE. However, the Ld. AR submitted that in the case of CIT vs. Redington India Ltd [2021] 430 ITR 298, Hon’ble
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Madras High Court held that corporate guarantee given to the AE is covered by the retrospective amendment made by the Finance Act, 2012. The ld. AR relied on the following case laws: (i) DCIT vs. EIH Ltd – [2018] 89 taxmann.com 417 (Kolkata Trib). (ii) GVK Power & Infrastructure Ltd vs. ACIT – [2018] 94 taxmann.com 415 (Visakhapatnam Trib.) (iii) CIT vs. Everest Kanto Ltd – 378 ITR 57 (Bombay HC) (iv) PCIT vs. Thomas Cook Ltd – ITA Nos. 712 & 713/2017, dated 26/08/2019. 10. The Ld. AR further submitted that the Hon’ble Courts and Tribunals have held that 0.50% on an average as corporate guarantee commission on the guarantees extended to AE, should it be treated as international transaction. The Ld. AR pleaded that the AE of the assessee had utilized only $ 13.88 Million U and hence if the Hon’ble Bench decided to uphold the corporate guarantee as an international transaction it may be charged @ 0.50% on the amount utilized by the AE, during the subject AY. The Ld. AR also referred to the OECD guidelines wherein it is mentioned that corporate guarantee is not an international transaction and it is only a shareholder’s obligation. The Ld. AR further submitted that merely relying on the information obtained U/s. 133(6) of the Act which was not shared with the assessee, the 13 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
Ld. TPO has erred in determining the rate @ 1.8% of the corporate guarantee given to AEs.
Per contra, The Ld.DR submitted that Rule 10TD of the Safe Harbour Rules specifies that Corporate Guarantee to be charged at 2%. The Ld. DR further submitted that the Ld. DRP has rightly considered the issue and thereby upheld the ALP rate of 2% adopted by the Ld. TPO in respect of adjustment made to the corporate guarantee given to AE. The Ld. DR therefore pleaded that the order of the Ld.DRP / Ld.AO be upheld.
Responding to the argument by the Ld.DR, the Ld.AR submitted that the assessee has to apply for opting under Safe Harbour Rules, which in the instant case the assessee has not exercised that option and hence Safe Harbour Rules cannot be applied in the instant case.
We have heard both the parties and perused the material available on record and the orders of the Authorities below. Similar issue was considered in assessee’s own case for the A.Y.2017-18 in I.T.A.No.75/Viz/2022 dated 09.09.2022. For the 14 ITA No.156/Viz/2022, A.Y.2018-19 Devi Sea Foods Limited, Visakhapatnam
sake of clarity, we extract relevant part of the order of the Tribunal (supra) as under :
“11. We have heard both the parties and perused the material available on record and the orders of the Authorities below. It is observed from the order of the Ld. TPO that the Ld. TPO has obtained from various banks the rate of fees charged by them on the issuance of financial guarantees for the computation of ALP. The Ld. TPO has thus concluded that the median of the ALP works out to 1.9% for the corporate guarantee of above Rs. 10 Crs. The Ld. TPO referred to section 92B of the Act which read as “any other transaction having a bearing on the profits, income, losses or assets of such enterprises” and thus concluded that in the instant case the corporate guarantee issued on behalf of its AEs must be taxed @ 1.9% on the guaranteed amount. The Ld. TPO also observed in para 12.10 of his order that “when a default is made in making repayment by the principal debtor, the banker will be able to proceed against the guarantor/surely” and hence this being the contingent liability on the assessee, we find that the Ld. TPO made the adjustment by instances referring to the commercial banks providing financial guarantees but did not contemplate the issue of corporate guarantee. The concept of bank guarantees and corporate guarantees was explained in the case of Prolifics Corporation Ltd in ITA No.237/Hyd/2014, dated 31/12/2014 by the Hyderabad Tribunal wherein it has observed that the provisions of corporate guarantee always involves risk and there is a service provided to the AEs in increasing its creditworthiness in obtaining loans in the market. We find that there must be a minimum charge on the P & L Account but there is an enhanced risk which cannot be ruled out in providing guarantees. Ultimately, the Hon’ble Tribunal upheld the adjustment made on guarantee commissions given to AEs. The reliance placed by the Ld. AR on the Bombay High Court decision in the case of CIT vs. Everest Kanto Ltd reported in 378 ITR 57 wherein the corporate guarantee commission was considered as an international transaction and the rate restricted to 0.50% of the corporate guarantee. We find merit in the arguments of the Ld. AR that the rate of corporate guarantee should be restricted to the amount utilized by the AE, @ $ 11.5 Million U , but should not be applied on the gross corporate guarantee. In view of the above discussion and by respectfully following the ratio laid down by the Hon’ble Bombay High Court in the case of CIT vs. Everest Kanto Ltd (supra) we are of the considered view that the corporate guarantee commission is an international transaction and should be charged
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@ 0.50% on the corporate guarantee amount utilized, by the AE. We therefore allow the grounds raised by the assessee.”
Respectfully following the ratio laid down by the coordinate bench of the Tribunal, we allow this ground raised by the assessee.
The assessee raised the following grounds with respect to disallowance U/s. 14A of the Act. Disallowance under section 14A
The AO erred in making disallowance under section 14A of the Act and the DRP erred in sustaining the said disallowance.
The AO/DRP failed to appreciate that in the absence of dividend income, the provisions of section 14A of the Act will not be applicable.
Without prejudice to the above, while computing the average value of investments under Rule 8D(ii), the AO ought to have excluded the investments which did not yield dividend income.
The Appellant craves leave to add, alter, amend, substitute, rescind, modify and / or withdraw in any manner whatsoever all or any of the foregoing grounds of appeal at or before the hearing of the appeal.
The issue raised by the assessee in the Grounds of Appeal is with respect to disallowance U/s. 14A of the Act r.w.r 8D. The Ld. AR argued that the assessee has not earned any exempt income warranting the disallowance u/s. 14A of the Act. The Ld. AR
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pleaded that the assessee’s holding shares is merely to retain the controlling interest and no income has been received by the assessee during the impugned assessment year. The Ld. AR relied on the following decisions: (i) CIT vs. Chettinad Logistics P. Ltd – 95 taxmann.com 250 (Supreme Court). (ii) CIT vs. Chettinad Logistics P. Ltd – [2017] 80 taxmann.com 221 (Madras) (iii) Marg Ltd vs. CIT – 120 taxmann.com 84 (Madras)
The Ld. AR placed heavy reliance on the judgment of the Hon’ble Supreme Court in the case of CIT vs. Chettinad Logistics P. Ltd., [2018] 95 taxmann.com 250 (SC).
Per contra, the Ld. DR supported the order of the Ld. AO.
We have heard both the sides and perused the materials available on record and the orders of the Authorities below. Similar issue was considered in assessee’s own case for the A.Y.2017-18 in I.T.A.No.75/Viz/2022 dated 09.09.2022. For the sake of clarity, we extract relevant part of the order of the Tribunal (supra) as under :
“15. We have heard both the sides and perused the materials available on record and the orders of the Authorities below. We find from the records submitted by the Ld. AR that the assessee has not earned any exempt income during the relevant assessment year
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mandating the invoking of provisions of section 14A of the Act. The Hon’ble Supreme Court in CIT vs. Chettinad Logistics (P.) Ltd (supra) has dismissed the SLP of the Revenue and held that section 14A can only be triggered if assessee claims any expenditure against an income which does not form part of the total income under the Act. The Hon’ble Supreme Court further observed that Rule 8D only provides for a method to determine the amount of expenditure incurred in relation to income which does not form part of the total income of the assessee. Respectfully following the ratio laid down by the Hon’ble Supreme Court, we allow the appeal of the assessee on this ground.” Hence, respectfully following the ratio laid down by the Hon’ble Supreme Court as well as the Tribunal (supra), we allow the appeal of the assessee on this ground.
In the result, appeal of the assessee is allowed. Pronounced in the open Court on the 16th December, 2022. (दुव्वूरु आर.एल रेड्डी) (एस बालाकृष्णन) (DUVVURU RL REDDY) (S.BALAKRISHNAN) न्याययक सदस्य/JUDICIAL MEMBER लेखा सदस्य/ACCOUNTANT MEMBER Dated : 16.12.2022 L.Rama,SPS
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आदेश की प्रयियलयि अग्रेयषि/Copy of the order forwarded to:- यनर्ााररिी/ The Assessee–M/s. Devi Sea Foods Limited, 50-1-51/1,
ASR Nagar, Seetammadhara, Visakhapatnam-530013, Andhra Pradesh. राजस्व/The Revenue – Deputy Commissioner of Income Tax,
Circle-3(1), Visakhapatnam.
The Principal Commissioner of Income Tax, आयकरआयुक्त ( अिील)/ The Commissioner of Income Tax (Appeals)
National Faceless Appeal Centre, Delhi. यवभागीयप्रयियनयर्, आयकरअिीलीयअयर्करण, यवशाखािटणम/
DR,ITAT, Visakhapatnam गार्ाफ़ाईल / Guard file 6. आदेशानुसार / BY ORDER
Sr. Private Secretary ITAT, Visakhapatnam