Apollo Tyres Ltd. v. CIT

255 ITR 273Supreme Court of India2002#88 most cited

What is Apollo Tyres Ltd. v. CIT authority for?

For the purpose of computing book profits under Section 115J, arrears of depreciation, including those arising from assets working extra shifts, are a necessary charge on profits if debited to the profit and loss account and are allowable as such.

657

judgments rely on this decision, according to BharatTax’s citation analysis of 367,659 Indian tax judgments — from 2008 to 2026.

Also referred to as

Apollo Tyres Ltd v CIT · Section 115J · Section 115JB · book profits · minimum alternate tax · MAT · depreciation arrears · extra shift depreciation · debit to profit and loss account · allowable charge on profits

Also reported as

122 Taxmann 562174 CTR 521

Sections most often in play

Section 115JBSection 14ASection 143(3)Section 37(1)Section 147Section 8DSection 92CA(3)Section 195
Read the full judgment

Issues it is cited on

section 115jb(2)section 115jabook profitssection 115jsection 115jbsection 35disallowance u/s 14adisallowance under section 14asection 115section 80iasection 32section 14a

Judgments citing Apollo Tyres Ltd. v. CIT

DCIT (OSD) Cir 2(2), Mumbai vs. Nhava Sheva International Container Terminal P. Ltd, Mumbai

In the result, the Revenue’s appeal is dismissed and the assessee’s appeal is partly

ITA 2935/MUM/2012[2008-09]Status: DisposedITAT Mumbai28 Sept 2018AY 2008-09

Bench: Shri Shamim Yahya, Am & Shri Pawan Singh, Jm

For Appellant: Shri Girish DaveFor Respondent: Shri Kiran Unavekar
Section 115J

…ons and deductions to the net profit appearing in the profit and loss account to compute the book profit. M/s. NhavaSheva International Container Terminal Pvt. Ltd. • The Company invites attention of your goodself in the case of Apollo Tyres Ltd. v CIT (2002) 255 ITR 273 wherein the Hon'ble Supreme Court has held: "the Assessing Officer while computing the income under Section 115JB has only the power of examining whether the books of account are certified by the authorities under the Companies Act as having been properly maintained in accordance with the Companies Act. The Assessing Officer thereafter has the li…

ACIT, New Delhi vs. M/S. Escorts Mahle Ltd. (Now Known As M/S. Federal Mogul Goetze India Ltd.), New Delhi

The appeal of the revenue is dismissed

ITA 6688/DEL/2015[2003-04]Status: DisposedITAT Delhi19 Sept 2018AY 2003-04

Bench: Shri Amit Shukla & Shri Prashant Maharishiacit, Vs. Escorts Mahle Ltd. Circle-9(1), (Now Known As M/S. Federal New Delhi Mogul Goetze India Ltd), A-26/3, Mohan Cooperative, Industrial Estate, Mathura Road, New Delhi Pan: Aaace1749F (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri Sanjai Kumar Yadav, Sr. DR
Section 115J

…the book profit u/s 115JB the above expenditure have been considered by the assessee in its books of account as ascertained liability. The ld CIT(A) has deleted the above adjustment to the book profit relying upon the decision of the Hon'ble Supreme Court in 255 ITR 273. As the coordinate bench while dealing with the issue under the normal computation of total income has categorically held that all these provisions are ascertained liabilities and the ld AO is merely guided by the words provisions for narrating the expenses. We do not find any infirmity in the order of the CIT(A). In view of this we also do not f…

The ACIT, Gnr Circle, Gandhinagar vs. M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar

Appeal of the Revenue is dismissed

ITA 419/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2008-09

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…normal provisions of income tax act. Assessee’s claims fails on all accounts, it is neither being contingent liability nor a provision made but an actual claim debited to the profit and loss account. (iv) The Hon’ble Supreme Court in the case of Apollo Tyres 255 ITR 273, had held that no adjustments to the book profits as per the audited accounts are permissible, beyond what is specifically mandated in section 115JA/JB. No remission of an expense, correctly credited to the profit and loss account by the assessee as its income; forming part of its profit as per audited account can be allowed as deduction later on…

The ACIT, Gnr Circle, Gandhinagar vs. M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar

Appeal of the Revenue is dismissed

ITA 2556/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2009-10

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…normal provisions of income tax act. Assessee’s claims fails on all accounts, it is neither being contingent liability nor a provision made but an actual claim debited to the profit and loss account. (iv) The Hon’ble Supreme Court in the case of Apollo Tyres 255 ITR 273, had held that no adjustments to the book profits as per the audited accounts are permissible, beyond what is specifically mandated in section 115JA/JB. No remission of an expense, correctly credited to the profit and loss account by the assessee as its income; forming part of its profit as per audited account can be allowed as deduction later on…

M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar vs. The Jt.CIT., Gnr Range, Gandhinagar

Appeal of the Revenue is dismissed

ITA 2473/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2009-10

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…normal provisions of income tax act. Assessee’s claims fails on all accounts, it is neither being contingent liability nor a provision made but an actual claim debited to the profit and loss account. (iv) The Hon’ble Supreme Court in the case of Apollo Tyres 255 ITR 273, had held that no adjustments to the book profits as per the audited accounts are permissible, beyond what is specifically mandated in section 115JA/JB. No remission of an expense, correctly credited to the profit and loss account by the assessee as its income; forming part of its profit as per audited account can be allowed as deduction later on…

M/S. Gujarat Industrial Investment Corporation Ltd., Gandhinagar vs. The Addl.CIT., Gandhinagar Circle, Gandhinagar

Appeal of the Revenue is dismissed

ITA 208/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2008-09

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…normal provisions of income tax act. Assessee’s claims fails on all accounts, it is neither being contingent liability nor a provision made but an actual claim debited to the profit and loss account. (iv) The Hon’ble Supreme Court in the case of Apollo Tyres 255 ITR 273, had held that no adjustments to the book profits as per the audited accounts are permissible, beyond what is specifically mandated in section 115JA/JB. No remission of an expense, correctly credited to the profit and loss account by the assessee as its income; forming part of its profit as per audited account can be allowed as deduction later on…

M/S. Gujarat Industrial Investment Corporation, Gandhinagar vs. The Dy.CIT., Gandhinagar Circle, Gandhinagar

Appeal of the Revenue is dismissed

ITA 1170/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2007-08

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…normal provisions of income tax act. Assessee’s claims fails on all accounts, it is neither being contingent liability nor a provision made but an actual claim debited to the profit and loss account. (iv) The Hon’ble Supreme Court in the case of Apollo Tyres 255 ITR 273, had held that no adjustments to the book profits as per the audited accounts are permissible, beyond what is specifically mandated in section 115JA/JB. No remission of an expense, correctly credited to the profit and loss account by the assessee as its income; forming part of its profit as per audited account can be allowed as deduction later on…

The Dcitgandhinagar Circle, Gandhinagar vs. M/S. Gujarat Industrial Investment Corporation, Gandhinagar

Appeal of the Revenue is dismissed

ITA 1115/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad18 Sept 2018AY 2007-08

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Surendra Kumar, CIT-DRFor Respondent: Shri Sanjay R. Shah, A.R
Section 115Section 14A

…normal provisions of income tax act. Assessee’s claims fails on all accounts, it is neither being contingent liability nor a provision made but an actual claim debited to the profit and loss account. (iv) The Hon’ble Supreme Court in the case of Apollo Tyres 255 ITR 273, had held that no adjustments to the book profits as per the audited accounts are permissible, beyond what is specifically mandated in section 115JA/JB. No remission of an expense, correctly credited to the profit and loss account by the assessee as its income; forming part of its profit as per audited account can be allowed as deduction later on…

DCIT, Circle - 3(1), Kolkata vs. M/S. Tata Metaliks Limited, Kolkata

ITA 1481/KOL/2017[2011-12]Status: DisposedITAT Kolkata12 Sept 2018AY 2011-12

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 115JSection 143(3)Section 43B

…" of the company. Since, in the present case, the subsidy has been credited to P& L a/c, in order to work out the real profit of the company u/s 115JB said amount needs to be deducted, following the decision of the Hon'ble Supreme Court in Apollo Tyres (2002) 255 ITR 273 (SC) rw Indo Rama Synthetics (I) Ltd vs CIT(2011) 330 ITR 363(SC). The appellant has also relied upon the judgment in the case of CIT vs Veekaylal Investments CO.(P) Ltd (2001) 249 ITR 597(BOM), although the copy of judgment in this case was not furnished. The reliance on the decision by the Hon'ble Mumbai High Court by the appellant is found to…

M/S Tata Metaliks Ltd., Kolkata vs. DCIT, Cir-3(1), Kolkata

ITA 1153/KOL/2017[2011-12]Status: DisposedITAT Kolkata12 Sept 2018AY 2011-12

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 115JSection 143(3)Section 43B

…" of the company. Since, in the present case, the subsidy has been credited to P& L a/c, in order to work out the real profit of the company u/s 115JB said amount needs to be deducted, following the decision of the Hon'ble Supreme Court in Apollo Tyres (2002) 255 ITR 273 (SC) rw Indo Rama Synthetics (I) Ltd vs CIT(2011) 330 ITR 363(SC). The appellant has also relied upon the judgment in the case of CIT vs Veekaylal Investments CO.(P) Ltd (2001) 249 ITR 597(BOM), although the copy of judgment in this case was not furnished. The reliance on the decision by the Hon'ble Mumbai High Court by the appellant is found to…

J. B Boda & Co. P.Ltd, Mumbai vs. DCIT 1(2), Mumbai

Appeal stands allowed

ITA 486/MUM/2017[2011-12]Status: DisposedITAT Mumbai07 Sept 2018AY 2011-12

Bench: Shri Joginder Singh, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: Indra Anand, Ld. ARFor Respondent: A.Mohan, Ld. Sr. DR
Section 115Section 115JSection 143(3)

…ITA No. 486/Mum/2017 J.B. Boda & Co. Pvt.Ltd Assessment Year-2011-12 आयकर अपीलीय अिधकरण “जे” "ायपीठ मुंबई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI जोिग"र िसंह,"ाियक सद" एवं "ी मनोज कुमार अ"वाल, लेखा सद" के सम"। BEFORE SHRI JOGINDER SINGH, JM AND SHRI MANOJ KUMAR AGGARWAL, AM आयकरअपीलसं./I.T.A. No.486/Mum/2017 (िनधा"रणवष" / Assessment Year: 2011-12) J.B. Boda & Co. Private Limited Deputy Commissioner of Income Tax -1(2) बनाम/ [Presently ACIT-1(2)(1)] Maker Bhavan,1 Aaykar Bhavan, M.K.Road Sir V.T.Marg Vs. Mumbai-400 020 Mumbai – 400 020 "थायीलेखासं./जीआइआरसं./PAN/GIR No. AABCJ-2289-F (अपीलाथ"/Ap…

Balaji Energy Private Limited, Hyderabad vs. DCIT, Circle-1(2), Hyderabad

ITA 910/HYD/2017[2013-14]Status: DisposedITAT Hyderabad31 Aug 2018AY 2013-14

Bench: Smt. P. Madhavi Devi & Shri Inturi Rama Raoassessment Year: 2013-14

For Appellant: Sri A.V. RaghuramFor Respondent: Smt. Esther Minghauvung, DR
Section 115JSection 143(3)

…cation by the Statutory auditors to the effect that the financial statements of the company were not drawn in accordance with the Schedule-3 of the Companies Act, 2013. He also relied upon the judgment of the Hon’ble Supreme Court in the case of Apollo Tyres [255 ITR 273] (SC) in support of the contention that the Assessing Officer had no power to disturb the book profits as disclosed by P & L Account in the absence of finding that the P & L Account and balance sheet were not drawn in accordance with the Accounting Standards or in terms of the provisions of Schedule-3 of the Companies Act, 2013. 5. On the other h…

Assistant Commissioner of Income Tax, Circle-2, Jaipur vs. M/S. Om Metal Infraproject Limited, Jaipur

In the result, appeal of the revenue is dismissed

ITA 759/JPR/2018[2014-15]Status: DisposedITAT Jaipur15 Aug 2018AY 2014-15

Bench: The Hon’Ble Apex Court In Cit V/S M/S Sbbj In Slp (C) No. 16249/2014? (Ii) Whether On The Facts & Circumstances Of The Case & In Law The Ld. Cit(A) Was Justified In Deleting The Disallowance Of Rs. 44,02,000/- U/S 14A R.W.R 8D Of The I.T. Act When The Assessee Has

For Appellant: Shri B.V. Maheshwari (CA)For Respondent: Shri Varinder Mehta (CIT-DR) fu/kZkfjrh dh vksj ls@
Section 115JSection 14A

…e ITAT, Mumbai in the case of Goldgerg Finance (P.) Ltd. Vs ACIT [2017] 78 taxmann.com 123 (Mumbai - Trib.) …………………..………………….. ………………………………………….. (vi) It may be mentioned that in a number of judicial pronouncements, the case of Apollo Tyres Ltd. v. CIT [2002] 255 ITR 273/122 Taxman 562 (SC), has been distinguished. In these judgements, it has been observed that the object of Minimum Alternate Tax (MAT) provisions incorporated in Sec.ll5JB of the Act was to bring out real profit of companies and the thrust was to find out real working results of company. It was further observed that inclusion of receipt which are…

Acmevac Pumps & Engg. Pvt. Ltd., Thane vs. ACIT - 2(1)(1), Mumbai

ITA 5155/MUM/2016[2012-13]Status: DisposedITAT Mumbai10 Aug 2018AY 2012-13

Bench: Shri Joginder Singh() & Shri G Manjunatha ()

Section 115JSection 143(2)Section 143(3)Section 48(1)

…cope for the AO to make adjustments to book profit except as provided under Explanation 1 to section 115JB. In support of its arguments, assessee has relied upon 8 ITA 5155/Mum/2016 the decision of Hon’ble Supreme Court in the case of Apollo Tyres Ltd vs CIT 255 ITR 273 (SC). The assessee also relied upon the decision of jurisdictional High Court in the case of CIT vs Akshay Textile Trading & Agencies Pvt Ltd 304 ITR 401 (Bom). 9. We have heard both the parties and perused the material available on record. The fact with regard to the impugned dispute are that the assessee has credited profit derived from transfe…

Gujarat Fluorochemicals Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Circle-1(1)(1), Vadodara

In the result, both appeals of the assessee are partly allowed

ITA 805/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad03 Aug 2018AY 2012-13

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

For Appellant: Shri S.N. Soparkar and Shri Parin Shah, ARFor Respondent: Shri O.P. Vaishnav, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14A

…ith Explanation 115JB not specifically mentioning Section 14A of the Act, the addition of Rs. 89,00,000 was not justified. The view taken by the 1TAT cannot be faulted with. It is consistent with the decision in Apollo Tyres Ltd. v. Commissioner of Income Tax 255 ITR 273 (SC) which held that "the Assessing Officer does not have the jurisdiction to go behind the net profit shown in the profit and loss account except to the extent provided in the Explanation to Section 115J." The Court declines to frame a question on the above issue." 21. Apart from the above, we have a binding precedent before us - One from Hon’b…

Gujarat Flurochemicals Limited., Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, both appeals of the assessee are partly allowed

ITA 2744/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad03 Aug 2018AY 2013-14

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

For Appellant: Shri S.N. Soparkar and Shri Parin Shah, ARFor Respondent: Shri O.P. Vaishnav, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14A

…ith Explanation 115JB not specifically mentioning Section 14A of the Act, the addition of Rs. 89,00,000 was not justified. The view taken by the 1TAT cannot be faulted with. It is consistent with the decision in Apollo Tyres Ltd. v. Commissioner of Income Tax 255 ITR 273 (SC) which held that "the Assessing Officer does not have the jurisdiction to go behind the net profit shown in the profit and loss account except to the extent provided in the Explanation to Section 115J." The Court declines to frame a question on the above issue." 21. Apart from the above, we have a binding precedent before us - One from Hon’b…

DCIT 3(3)(1), Mumbai vs. Radha Madhav Investment Ltd, Mumbai

Appeal stands allowed to that extent

ITA 1028/MUM/2017[2013-14]Status: DisposedITAT Mumbai27 Jul 2018AY 2013-14

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./I.T.A. No.1028/Mum/2017 (िनधा"रणवष" / Assessment Year: 2013-14) Radha Madhav Investments Limited Deputy Commissioner Of Income 11-A, Mittal Chambers Tax -3(3)(1) बनाम/ Dr. Rajni Patel Marg, Nariman Point Room No.609, 6Th Floor Vs. Mumbai-400 021 Aaykar Bhavan, M.K.Road Mumbai-400 020 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacr-4063-M (अपीलाथ"/Appellant) (""थ" / Respondent) :

For Appellant: Vijay Mehta, Ld. ARFor Respondent: Ram Tiwari, Ld. DR
Section 115JSection 143(3)Section 14A

…ratio of decision of Hon’ble Supreme Court rendered in CIT Vs. Vegetable Products Limited [1973 88 ITR 192]. The decision in PCIT Vs. Bhushan Steel Ltd., in turn, placed reliance on the decision of Hon’ble Supreme Court rendered in Apollo Tyres Ltd. Vs. CIT [255 ITR 273] which held that the Assessing Officer did not have the jurisdiction to go behind the net profit shown in the Profit & Loss Account except to the extent provided in Explanation to Section 115J. Similar view has been expressed by our jurisdictional Bombay High Court rendered in CIT Vs. JSW Energy Limited [2015 60 Taxmann.com 303], CIT v. Essar Tel…

Assistant Commissioner of Income-Tax vs. M/S. Abhay Cotex Pvt. Ltd., Jalna

In the result, the appeal of the Revenue is dismissed

ITA 1423/PUN/2016[2011-12]Status: DisposedITAT Pune18 Jul 2018AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm आयकर अपील सं आयकर अपील सं. / Ita No. 1423/Pun/2016 आयकर अपील सं आयकर अपील सं िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2011-12 िनधा"रण वष" िनधा"रण वष"

For Appellant: Shri Rahul Kaul & Shri Anand PartaniFor Respondent: Shri Mukesh Jha
Section 115JSection 32

…in elaborate discussion was made as to why capital receipt i.e. subsidy has to be reduced from book profit for the purpose of computing the MAT profit under section 115JB of the Act. It was held that the Hon'ble Supreme Court in the case of Apollo Tyres Ltd. (255 ITR 273) had not overlooked the basic legislative intention regarding the nature of items to be excluded in computing, the book profits for the purpose of section 115JA. While rendering the decision on this issue, the undersigned had 9 M/s. Abhay Cortex Pvt. Ltd. also placed reliance on the decision in the case of Balrampur Chini Mills Ltd (238 ITR 445)…

DCIT, Cir-11(1), Kolkata vs. M/S Haldia Petrochemicals Ltd., Kolkata

In the result, the appeal of the assessee is partly allowed and appeal of the Revenue is dismissed

ITA 168/KOL/2016[2004-05]Status: DisposedITAT Kolkata06 Jul 2018AY 2004-05

Bench: Hon’Ble Shri P.M.Jagtap, Am & Shri S.S.Viswanethra Ravi, Jm ] Assessment Year : 2004-05

For Appellant: Shri Harakamal Chakravorty, ARFor Respondent: Shr P.K.Srihari, CIT
Section 115J

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH ‘A’ KOLKATA [Before Hon’ble Shri P.M.Jagtap, AM & Shri S.S.Viswanethra Ravi, JM ] Assessment Year : 2004-05 Haldia Petrochemicals Ltd. -versus- A.C.I.T., Circle-8 Kolkata Kolkata (PAN : AAACH 7360 R) (Appellant) (Respondent) Assessment Year : 2004-05 D.C.I.T., Circle-11(1) -versus- Haldia Petrochemicals Ltd. Kolkata Kolkata (PAN: AAACH 7360 R) (Appellant) (Respondent) For the Assessee : Shri Harakamal Chakravorty, AR For the Respondent: Shr P.K.Srihari, CIT Date of Hearing : 09.05.2018. Date of Pronouncement : 06.07.2018. ORDER Per S.S.Viswanethra Ravi, JM Bot…

Haldia Petrochemicals Ltd., Kolkata vs. ACIT, Cir-8, Kolkata

In the result, the appeal of the assessee is partly allowed and appeal of the Revenue is dismissed

ITA 1533/KOL/2015[2003-2004]Status: DisposedITAT Kolkata06 Jul 2018AY 2003-2004

Bench: Hon’Ble Shri P.M.Jagtap, Am & Shri S.S.Viswanethra Ravi, Jm ] Assessment Year : 2004-05

For Appellant: Shri Harakamal Chakravorty, ARFor Respondent: Shr P.K.Srihari, CIT
Section 115J

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH ‘A’ KOLKATA [Before Hon’ble Shri P.M.Jagtap, AM & Shri S.S.Viswanethra Ravi, JM ] Assessment Year : 2004-05 Haldia Petrochemicals Ltd. -versus- A.C.I.T., Circle-8 Kolkata Kolkata (PAN : AAACH 7360 R) (Appellant) (Respondent) Assessment Year : 2004-05 D.C.I.T., Circle-11(1) -versus- Haldia Petrochemicals Ltd. Kolkata Kolkata (PAN: AAACH 7360 R) (Appellant) (Respondent) For the Assessee : Shri Harakamal Chakravorty, AR For the Respondent: Shr P.K.Srihari, CIT Date of Hearing : 09.05.2018. Date of Pronouncement : 06.07.2018. ORDER Per S.S.Viswanethra Ravi, JM Bot…