IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH: `B ': NEW DELHI
BEFORE SHRI J.S. REDDY, ACCOUNTANT MEMBER
AND
SHRI GEORGE GEORGE K., JUDICIAL MEMBER
ITA No.5453 /Del /2011
Assessment Year: 2006-2007
DCIT, Circle 11(1), Vs. M/s Eicher Motors Limited
New Delhi. (erstwhile Eicher Goodearth Investment Ltd.)
3rd Floor, Select City Walk,
A-3 Dist. Centre Saket
New Delhi
ITA No.5089 /Del /2011
Assessment Year : 2006-2007
M/s Eicher Motors Ltd. (erstwhile Vs. ACIT, Range II
Eicher Goodearth Investment Ltd. ) New Delhi
3rd Floor, Select City Walk
A-3, Dist. Centre, Saket,
New Delhi-110017.
(Appellant) (Respondent)
Appellant by : Smt. Parminder Kaur, Sr. D.R.
Shri Ajay Vohara, Sr. Advocate
Respondent by: Ms. Gaurav Jain, Advocate.
ORDER
PER SHRI GEORGE GEORGE K, JM:
1. These are cross appeals directed against the CIT (A)'s order dated
14.09.2011. The relevant Assessment Year is 2006-07.
ITA No.5453&5089/Del /2011 2
Assessment Year : 2006-2007
2. We shall first take up Revenue's appeal for adjudication. In Revenue's
appeal, the following effective grounds are raised:-
i). On the facts and circumstances of the case and in law, the CIT(A)
has erred in deleting the addition of Rs.4,48,01,000/- made on
account of disallowance of expenses under the heads
manufacturing, trading and other expenses.
ii) On the facts and circumstances of the case and in law, the CIT(A)
has erred in restricting the addition of Rs.33,23,000/- to
Rs.1,26,710/- made u/s 14A read with Rule 8D of the I.T. Rules,
1962."
3. The facts in relation to the first ground are as follows:-
The assessee, a limited company, was engaged in the business of trading
various furnishing items through its retail outlets. In the trading division, the
assessee's total sale was Rs.1285.85 lakhs, against which, net profit declared
was Rs.456.15 lakhs. The Assessing Officer, in the course of scrutiny
assessment, compared the profit of the aforesaid trading division with net profit
achieved by other business carried on by the assessee, namely, manufacturing
and trading of maps and guides and export business. Since there was a low profit
in trading business, the Assessing Officer raised various queries to the assessee
to justify its low profit in the trading division. The assessee filed details
comprising of purchases made during the year, justification of low net profit on
account of heavy indirect expenses and division-wise profit and loss account for
the relevant year ending. The Assessing Officer was not satisfied with the reply
of the assessee and sought to verify the profit ability of trading division through
furnishing of purchase and sale vouchers of each single item traded in the
ITA No.5453&5089/Del /2011 3
Assessment Year : 2006-2007
trading division. Since the assessee could not furnish the details as required by
the Assessing Officer, the AO made an ad-hoc disallowance @ 10% of the total
expenses incurred by the assessee during the year including expenses incurred in
the other divisions, namely, manufacturing and sale of Map and guides and the
export division. Accordingly, out of the total expenses of Rs.4480.11 lakhs the
AO disallowed Rs.4.48 crores.
4. On appeal, the CIT (A) deleted the disallowance of the Assessing Officer.
The relevant findings of the CIT (A) reads as under:-
"3.6 I have carefully considered the assessment order,contentions
raised by the appellant in the submissions and the documents
available on record. In the assessment order, the assessing officer has
drawn adverse inferences mainly on the ground of net loss (after
excluding other income) suffered by the trading division during the
year and also due to failure on, the part of assessee in not furnishing
item-wise details of sale-purchase during the course of assessment
proceedings. In addition to above, the assessing officer also observed
that the assessee did not file details of expenses. I find the
observations of the assessing officer that no details of
expenses were filed to be incorrect inasmuch as the assessee had filed
details of' major expenses during the course of assessment
proceedings and no defect in same has been pointed out by the
assessing officer in the assessment order. The main reason for
disallowing expenses was, thus, low profitability and non-furnishing of
item-wise sale-purchase vouchers. It is seen that the assessee deals in,
approximately 25,000 items and for that reason could not furnish the
details as desired by the assessing officer during the course of
assessment proceedings within the short available time. However, the
assessee has filed the aforesaid details on sample basis during the
appeal proceedings, which were even sent to the assessing officer for
comments/verification. Since the main reason of the assessing officer
for disallowing the expenses is on the aforesaid ground only, in the
interest of justice it is necessary to admit the aforesaid details filed by
the assessee in the appeal proceedings. In view thereof, the aforesaid
evidences are admitted and are considered hereunder for adjudication
of the ground of appeal as above.
ITA No.5453&5089/Del /2011 4
Assessment Year : 2006-2007
3.7 I have found that the assessee has earned gross profit of 31.57%
from sale-purchase of goods in the trading division during the
relevant previous year. This substantiates the assertion of the
appellant that the goods were sold by the assessee at profit only. The
loss has been suffered by the assessee due to incurring of various
indirect expenses in the nature of heavy rent of retail outlets opened
at posh localities and at prominent locations commanding higher
rent, other indirect expenses in the nature of salaries, advertisements,
routine management and administration expenses aggregating to
407.22 lacs. The details of these expenses incurred during the year
were also submitted by the assessee during the course of assessment
proceedings. The assessing officer has not raised any doubt on same
or has not even pointed out a single instance of unvouched/ inflated
expenditure. The results of the trading division have been arrived at
on the basis of books of account which are duly audited and no
adverse inference in maintenance thereof has been pointed out by the
auditors. The assessing officer has also not pointed out any defect in
maintenance of books of account nor rejected the same and has
finally _completed the assessment on the basis of such accounts itself.
Under these circumstances, in my view, there was no basis for the
assessing officer to doubt the profit declared by the trading division
and disallow the expenses incurred during the year on ad-hoc basis.
In view of the discussion as above, I am inclined to accept the
profit declared by the assessee in the trading division and therefore
the ad-hoc disallowance of expenses made by the assessing officer is
directed to be deleted. The appellant succeeds in this ground".
5. The Revenue, being aggrieved, is in appeal before us. The ld. D.R. relied
on the order of the Assessing Officer. On the other hand, the ld. A.R. reiterated
the submission made before the Income Tax authorities.
6. We have heard rival submission and perused the material on record. The
A.O. disallowed on ad-hoc basis 10% of the total expenditure for the reason that
the assessee could not furnish item-wise details of purchase and sale of goods.
The contention of the assessee is that it is dealing in various items of goods
ITA No.5453&5089/Del /2011 5
Assessment Year : 2006-2007
(more than 25000 items) and details sought for by the Assessing Officer could
not be furnished fully due to paucity of time (details called on 26.12.2007 and
the assessment was completed on 31.12.2007). However, in appellate
proceedings, on queries raised by the CIT(A), the assessee had furnished item
wise details of the trading division along with vouchers for purchase and sale
thereof on sample basis, vide letter dated 30.03.2010. The details furnished by
the assessee as per the CIT (A) direction was forwarded to the AO for his
comments. The AO furnished a report vide his letter dated 30.04.2010. In the
report, the Assessing Officer did not raise any objection to the assessee's case on
merits but technical objections were raised by placing reliance on Rule 46A of
the I.T. Rules, 1962. Admittedly, in this case, the books of account were
accepted by the Assessing Officer and no adverse inference in maintenance
thereof was pointed out. The entire expenses incurred during the year was duly
vouched and supported by necessary documents. The Assessing Officer could
not have made any ad-hoc disallowances without pointing out even a single
instance of inflation of expenditure. Another reason, for making the above said
disallowance was on account of low profit in trading division. As mentioned
earlier, the gross margin was worked out on the basis of books of account which
were duly audited and accepted as correct and complete. The gross profit with
regard to sale and purchase of goods in the trading division was at rate of
31.57% and there were various in direct expenses in the nature of high rental for
retail outlets in prominent location. This had pushed down the net profit rate.
ITA No.5453&5089/Del /2011 6
Assessment Year : 2006-2007
The CIT (A) has categorically found gross profit earned from the trading
division of the assessee is reasonable and has also examined the vouchers of
purchase and sale of goods made by the assessee on a sample basis and has
found same is to be correct. These findings of the CIT (A) has not been
dispelled by the Revenue placing any material/ documents. Therefore, we see no
reason to interfere with the order of the CIT (A). Accordingly, we dismiss this
ground of the Revenue.
7. As regards the second ground, namely reducing the addition u/s 14A to
Rs.1,26,710/- from Rs.33,23,000/-. The facts in brief are as follows. In the
computation statement filed along with the return of income, it was noticed by
AO that assessee has earned dividend income of Rs.4,47,30,053/-, which has
been claimed as exempt u/s 10(33) of the IT Act. The assessee was asked to
explain why disallowance u/s 14A should not be made on exempted dividend
income. The assessee has submitted that no part of the interest expenditure and
administrative expenses has been incurred in relation to earning of dividend
income. It was submitted that investment in shares on which dividend has been
received, were made in earlier years, out of interest free owned funds and no
part of the borrowed funds were used in earlier years for the same. It was also
submitted that no fresh investment in shares have been made during the previous
year relevant to AY 2006-07 and increase in the amount of investment is
pursuant to Scheme of Amalgamation of subsidiary company of the assessee. It
was further submitted that amount borrowed during the years were used for the
ITA No.5453&5089/Del /2011 7
Assessment Year : 2006-2007
purpose of business of the assessee as is evident from the cash flow statement
attached along with the return. The assessee has further submitted that
disallowance of notional interest and administrative expenses u/s 14A made in
AY 2004-05 has already been deleted by the CIT(A)-XIII, New Delhi. The
assessee has relied on various case laws in support of its contention and stated
that no disallowance u/s 14A is applicable in the case of the assessee. The AO,
however, rejected the contentions of the assessee. The Assessing Officer applied
the provision of Section 14A of the Act and computed the disallowance of
Rs.33.23 lakhs out of the total interest and administrative expenses incurred in
the current assessment year. The amount disallowed was arrived at by applying
the following method:
i) Interest expense was apportioned in the ratio of investment on
which exempt dividend income was received during the year to
total funds available for investment;
ii) Administrative expenses were apportioned in the ratio of 0.5%
percent of the average value of investment which had resulted in
exempt dividend income.
8. The calculation of disallowance made by the AO is as under:-
(A) Interest paid (Rs.75.17 lacs) Rupees in lakhs
Dividend 447.30
Amount invested in shares to earn such dividend (A) 2,942.47
Share capital + Reserve surplus 7,925.48
Loans (secured + unsecured) 2,833.54
Total Funds available (B) 10,759.02
Interest paid 75.17
Interest related to dividend income
(75.17x2,942.47/10,759.02) 20.56
ITA No.5453&5089/Del /2011 8
Assessment Year : 2006-2007
(B) Administrative expenses @ 0.5% of average value of
Investment in shares (2,534.21X0.5%) 12.67
________
Total disallowance 33.23 lakhs
9. Aggrieved by the disallowance of interest and administrative expenses,
the assessee filed an appeal before the CIT(A). The CIT (A) reduced the
disallowance made u/s 14A to Rs.1,26,710/- being 0.05% of the average value
of the investment in shares. The relevant finding of the CIT (A) reads as
follows:-
"5.3. I have carefully considered the assessment order as well as the
contentions raised by the appellant in the written submission. The
appellant has contended that no borrowed funds was used for the
investments and moreover the investments were made in earlier years
and the increase in investment in shares was by virtue of shares of
certain companies which vested with the appellant co on
amalgamation. The A.O has also riot established any nexus between
the investment and borrowed funds. On the basis of cash flow
statement, it is observed that the appellant has enough interest free
funds in the form of reserves and surplus. The additional investment
during the year is only Rs.7.02 lacs. Therefore after consideration of
the entire facts of the case, am unable to confirm the addition of
interest apportioned to dividend income by the A.O of Rs.20,56,000/-.
As regards the apportionment of administrative expenses, it
is nobody's case that no expenses have been incurred and the
investments were automatically made without anybody taking a
decision to make the investment. The Bombay High Court in the case
of Godrej and Boyce in 234 CTR 1 while ruling that Rule 8D was
applicable from AY 08-09, however, held that even in earlier years the
expenditure incurred for earning exempt income would have to be
apportioned and disallowed. The appellant has also submitted that the
only expenditure which may have some relation with the exempt
income would be the salary paid to Deputy GM Finance. However, I
am unable to agree with this view. The decision for investment even
for controlling stakes would be taken by the management. After
consideration of the case in its totality, it would be fair and reasonable
to restrict the disallowance to .05% of the average value of
ITA No.5453&5089/Del /2011 9
Assessment Year : 2006-2007
investments in shares (2,534.21X0.05%) which works out to
Rs.1,26,710/. Therefore, the addition to this extent is confirmed."
10 The Revenue, being aggrieved, is in appeal before us.
11. We have heard both the parties and perused the material on record.
Admittedly, the dividend which is exempt from taxation is earned on account of
investment made in share in the earlier years. The additional shares allotted to
the assessee's company in the current assessment year were on account of
amalgamation of subsidiary companies. Therefore, no portion of the interest
expenses incurred was in relation to investments in shares. As rightly pointed
out by the CIT (A), the AO has not established any nexus between the
investment and the borrowed funds. On the facts and circumstances of the case
and perusal of the cash flow statement, the CIT(A) has categorically found that
the assessee had enough interest free funds in the form of reserves and surplus
and there was no relation between the interest expenditure and the dividend
income. Therefore, disallowance of interest expenditure, by invoking the
provision of Section 14A, was uncalled for and, hence, we confirm the CIT(A)'s
order on this aspect.
11.2 As regards the disallowance of administrative expenditure, the CIT(A),
following the judgment of the Hon'ble Bombay High Court in the case of
Godrej and Boyce reported in 234 CTR 1, held that the Rule 8D is not
retrospective and applicable for and from A.Y. 2008-09. The CIT (A) had,
however, held that some administrative expenditure is relatable for earning of
ITA No.5453&5089/Del /2011 10
Assessment Year : 2006-2007
dividend income. The CIT (A) calculated the disallowance at 0.05% of the
average value of investments in shares (2,534.21X.05%) which works out to
Rs.1,26,710/-. This estimation of administrative expenses relatable to the
earning of dividend income is reasonable and justifiable on the facts and
circumstances of this case. Therefore, we find no infirmity in the order of the
CIT (A), warranting our interference. It is ordered accordingly.
Assessee's appeal - ITA No. 5089/12
The effective revised grounds raised by the assessee read as follows:
i) That the Commissioner of Income Tax (Appeals)-V, New Delhi has
grossly erred on facts and in law in confirming the disallowance of
repair and maintenance expenses related to building and office
equipment to the tune of Rs. 19,94,640/- alleging the same (as)
capital expenditure.
ii) That the Commissioner of Income Tax (Appeals)-V, New Delhi has
grossly erred on facts and in law in confirming the disallowance
u/s 14A to the tune of Rs. 1,26,710/- being 0.05% of the average
value of investments in shares.
12. With reference to the first revised ground raised by the assessee, the brief
facts are as follows:
During the relevant previous year, the assessee had incurred an
expenditure of Rs. 85,65,757/- under the head `repairs and maintenance' which
was claimed as revenue expenditure. However, the AO treated the same as
capital in nature on the ground that the details of such expenses could not be
verified. On further appeal, the CIT (A) confirmed the disallowance of following
expenses, aggregating to Rs. 19,94,640/-:
ITA No.5453&5089/Del /2011 11
Assessment Year : 2006-2007
Repair & Maintenance Expenses Building
Particulars Amount in Rs.
Amount of Painting and Repair Work at Ballabgarh 76,419
Repair of meter room 92,995
Renovation at Ballabgarh 1,01,985
Renovation at Ballabgarh 1,16,197
Renovation at Ballabgarh 1,46,908
Painting work at Ballabgarh 1,50,000
Sub-Total 6,84,504
Repair & Maintenance Expenses Office Equipment
Particulars Amount in Rs.
Annual Maintenance Charges 1,10,200
Up-gradation Charges 1,14,535
Fee paid for installation of licenses for additional users in existing software 89,482
Fee paid for installation of licenses for additional users in existing software 96,777
Fee paid for installation of licenses for additional users in existing software 1,45,600
Bandwidth usage charges 2,43,542
License fee for Citrix Presentation Software 1,02,000
Fee paid for installation of licenses for additional users in existing software 4,08,000
Sub-total 13,10,136
Gross Total 19,94,640
13. As regards the expenses of Rs. 6,84,504/- incurred towards repairs
of existing factory building at Ballabgarh, the CIT(A) sustained the
disallowance on the ground that the expenditure was incurred on complete
overhauling of the existing factory involving overhaul of the main-hall, meter
room, main gate, demolition of front wall, etc., which cannot be said to be a
routine repair and maintenance expenditure, for being allowed as revenue
ITA No.5453&5089/Del /2011 12
Assessment Year : 2006-2007
expenditure. In respect of Rs. 19,94,640 incurred towards up-gradation of
existing soft-wares, annual maintenance charges for such soft-wares or
purchasing additional licenses for additional users of existing software, as per
details above, the same was disallowed by relying on the decision of the Special
Bench of Tribunal in the case of Amway India Enterprises: 111 ITD 112 (SB)
on the ground that the expenditure incurred on acquisition of licenses for
software has been held to be capital expenditure in the said decision.
14. The contentions/submissions of the assesse before us, briefly, are as
under:
Ø That the factory building was constructed way back in 1981 and since the
building was in continuous use during the course of business activity for
over two decades, certain repairs and alterations required to be effected
for smooth functioning of the existence business operation. Accordingly,
a sum of 6.84 lakhs was incurred on the building which was quite nominal
and the same required to be allowed as revenue expenses;
With regard to the expenses on soft-ware licenses, it was contended that
Ø It was for up-gradation of existing soft-ware or purchasing of new
licenses for additional users of existing soft-wares
15. In view of the above, it was submitted that the expenses claimed
being legitimate revenue expenses, the same is required to be allowed as
deduction. On the other hand, the learned DR supported the stand of the
authorities below in rejecting the assessee's claim.
16. We have carefully considered the rival submissions. It is a fact that
the assessee had acquired the land at Ballabgarh in the year 1979 on which
factory building was constructed and, accordingly, capitalized in the books on
the year ending 31.3.1981 for an aggregate amount of Rs. 85,99,124/-. It was
ITA No.5453&5089/Del /2011 13
Assessment Year : 2006-2007
also a fact that since then the building was put to use in the course of business
carried on by the assessee and for the continuous use of the building for a long
period of over 20 years, the factory building had naturally required certain
repairs and alterations for uninterrupted and smooth operations of the business
in the said building. Considering the life of the building and the total amount of
expenditure of Rs. 6,84,504/- incurred on repair of the aforesaid factory during
the year was nominal compared to the total construction cost of building of Rs.
85,99,124/- in the year 1981. As argued by the learned AR during the course of
hearing, the aforesaid expenses were incurred towards repair and renovation of
the existing factory building which did not result in acquisition of any new
capital asset nor increase in production capacity of the factory. The aforesaid
repair expenses at the factory building only facilitated smooth functioning of the
existing operations carried out at the factory. Therefore, we are of the view that
the said expenditure cannot be said to be capital in nature. Under the provisions
of the Act, an expenditure incurred on repair of building for the purposes of
business, which is not capital in nature is allowable deduction under section 30
or 37(1) of the Act. Expenditure in the nature of current repairs of building is
allowable deduction under section 30 of the Act. If the repair expenditure, which
is incurred for the purposes of business, does not fall within the nature of
expenses specified in, inter alia, section 30, and not being in the nature of capital
expenditure, is allowable deduction under section 37(1) of the Act. The Hon'ble
Supreme Court in the cases of (i) CIT v. Sarvana Spinning Mills P. Ltd.: 293
ITA No.5453&5089/Del /2011 14
Assessment Year : 2006-2007
ITR 201 (SC) & (ii) Ramaraju Surgical Cotton Mills: 294 ITR 328 (SC) has
held that if a repair expenditure does not fall within the meaning of `current
repair' under section 30, but does not result in acquisition of any new capital
asset, can be allowed as revenue expenditure under the residuary provision of
section 37(1) of the Act. Expenditure is regarded as capital expenditure, if the
same results in (i) acquisition of capital assets; or (ii) benefit of enduring nature
in the capital field or adds to the profit earning apparatus of an assessee. Since
the expenditure incurred by the present assessee on the existing factory building
did not - (i) result in acquisition of any new capital asset, in as much as, the
building was old and had already stood capitalized in the books for the year
ending 31.3.1981 and (ii) even add to the profit earning capacity of the factory
since the renovation in the factory had no bearing on increase in the profit
earning capacity; such renovation only facilitated smooth functioning of the
existing operations or profit earning capacity of the factory building, we are of
the view that the expenditure being not capital in nature and having been
incurred for the purpose of business, is allowable as revenue expenditure under
section 30 or 37(1) of the Act. For the above proposition, we rely on the
judgments of the Hon'ble Supreme court in the cases of (i) Assam Bengal
Cement Co. Ltd. v. CIT: 27 ITR 34 (SC); (ii) Empire Jure Co. Ltd. v. CIT: 124
ITR 1 (SC); (iii) CIT v. Associated Cement Companies Ltd.: 172 ITR 257 (SC);
and (iv) Alembic Chemcial Works Co. Ltd. v. CIT: 177 ITR 377 (SC ).
ITA No.5453&5089/Del /2011 15
Assessment Year : 2006-2007
17. In respect of expenditure on Software Licenses, we find that the
CIT (A) had held that such expenditure to be capital expenditure on the ground
that the assessee had acquired capital asset, viz., soft-ware by relying on the
decision of the Special Bench of this Tribunal in the case of Amway India
Enterprises v. DCIT reported in 111 ITD 112. In this connection, we would like
to point out that the said finding of the Special Bench has since been modified
by the Hon'ble jurisdictional High Court in the case of CIT vs. Asahi India
Safety Glass Ltd.: 346 ITR 329 (Del). In that case, the Hon'ble Court had held
that the expenditure incurred towards purchase of application software, which
does not add to the profit-earning apparatus of an assessee, nor vests ownership
rights to an assessee and further considering that the same has to be up-dated
from time to time, cannot be said to be an expenditure incurred on capital
account. Thus, the Court held that expenditure on purchase of software is
allowable revenue expenditure. Various High Courts have also taken a similar
view on the issue. To illustrate further, in the following cases, the Hon'ble
Courts have held similar view:
(i) CIT v. Amway India Enterprises: 346 ITR 341 (Del.)
(ii) CIT vs Varinder Agro Chemicals Ltd.: 309 ITR 272 (P&H)
(iii)CIT vs G.E. Capital Services Ltd.: 300 ITR 420 (Del.)
(iv)CIT vs Kotak Securities Ltd. (No. 1): 346 ITR 349 (Bom.)
( v)CIT vs Raychem RPG Ltd.: 346 ITR 138 (Bom.)
18. Deriving strength from the aforesaid decisions, we are of the view
that the ratio laid down by the said Courts is squarely applicable to the facts of
ITA No.5453&5089/Del /2011 16
Assessment Year : 2006-2007
the case under consideration. In the present case, the assessee is engaged in the
business of manufacturing/ publishing and sale of city maps, manufacturing and
trading of furnishing items, etc. Thus, the assessee is not engaged in the
business of manufacturing software or rendering services, through use of soft-
wares. The soft-wares, if any, acquired by the assessee during the relevant year
or up-gradation of existing software acquired in the earlier year, were merely
application of soft-wares which enabled the assessee to execute tasks in the field
of accounting, purchases, inventory maintenance, etc. and, thus, facilitating
smooth carrying on of the business operations. In other words, such application
of software, in our view, did not result in creation of any new profit-earning
apparatus or source of income for the assessee. Further, considering that the
assessee only acquired license to use the soft-wares, it did not amount to have
any ownership right in such software, and that the assessee cannot even be said
to have acquired any capital asset to consider such licence fee paid as capital
expenditure.
19. In overall consideration of the facts of the issue, we are of the view
that the expenditure incurred on up-gradation of existing soft-wares or payment
of license fee for new soft-wares for additional users cannot be said to be capital
in nature. In substance, the claim of the assesse is an allowable revenue
expenditure. It is ordered accordingly.
ITA No.5453&5089/Del /2011 17
Assessment Year : 2006-2007
20. With reference to ground No. 2 namely disallowance by confirming
provisions u/s 14A we find no merits in the contentions raised by the assesee in
view of reasoning in paragraph 11 and 11.1 of this order. Hence, revised ground
No. 2 raised is dismissed.
21. In the result, (i) the Revenue's appeal is dismissed; &
(ii) the assessee's appeal is partly allowed.
The decision was pronounced in the open court on 21st November, 2014.
Sd/- Sd/-
(J.S. REDDY) (GEORGE GEORGE K.)
Accountant Member Judicial Member
Dated: November, 21st ,2014.
Aks/-
Copy forwarded to
1. Appellant
2. Respondent
3. CIT
4. CIT(A)
5. DR
Asst. Registrar, ITAT, New Delhi
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