.T.A.No.7630 and 1698/Mum/2012
1
, " "
IN THE INCOME TAX APPELLATE TRIBUNAL "K" BENCH, MUMBAI
BEFORE S/SHRI N.K.BILLAIYA, (AM) AND AMIT SHUKLA, (JM)
. . , ,
./I.T.A.No.7630/Mum/2012
I.T.A.No.1698/Mum/2014
( / Assessment Years: 2008-09 and 2009-10)
Tata Motors European / Assistant Director of Income Tax
Technical Centre Plc, (IT)(2(2),
Vs.
C/o third floor, Room No.116, 1st floor,
Nanavati Mahalaya, Scindia House,
18, Homi Mody Street, Ballard Pier,
Hutatma Chowk, Mumbai-400038
Mumbai-400001.
./ ./PAN/GIR No. : AACCT7506K
( /Appellant) .. ( / Respondent)
/ Assessee by : S/Shri R R Vora, Nikhil Tiwari
and Manoj Anchalia
/Revenue by : Shri S D Srivastava
/ Date of Hearing
: 29.9.2014
/Date of Pronouncement : 22.12.2014
/ O R D E R
Per AMIT SHUKLA(JM)
The aforesaid appeals have been filed by the assessee against
the two separate impugned final assessment orders dated
25.12.2011 for the assessment year 2008-09 and 30.1.2014 for the
assessment year 2009-10, passed in pursuance of directions by the
Dispute Resolution Panel (DRP). Since issue involved in both the
.T.A.No.7630 and 1698/Mum/2012
2
these appeals are common, arising out of similar facts, therefore,
were heard together and are being disposed off by this consolidated
order, for the sake of convenience.
2. To understand the implications of facts and issues involved, we
will take up the appeal for the assessment year 2008-09, vide which
following grounds of appeal have been taken:.
"1. A) The Transfer Pricing Officer (TPO) / Assessing
Officer (AO) has erred in law and on facts in making addition of
Rs.8,04,58.874/- by adopting Indian comparables as
comparables for benchmarking international transactions of
provisioning of services to Tata Motors Ltd. ("TML").
B) The TPO / AO ought to have accepted benchmarking
carried out by the assessee and selection of UK companies as
comparables for benchmarking the international transactions of
the company considering the facts of the case of the appellant.
C) The TPO/ AO has erred in law and on facts in
disregarding that in the previous assessment year, department
has accepted and considered UK companies as comparables
for the purpose of benchmarking of international transactions
and hence the AO/ TPO should have followed the same as
there is no change in the facts of the case.
2. Without prejudice to Ground No. 1 above,:
A) The TPO/ AO has erred in law and on facts in cherry
picking 7 Indian companies as comparables which are
functionally not comparable with the appellant.
B) The TPO/ AO has erred in law and on facts in picking up
companies with high margin instead of following detailed,
systematic and methodical search process.
C) The learned TPO/ AO has erred in law and on facts in
non granting Opportunity of cross examining the comparables
selected by the TPO/ AO.
.T.A.No.7630 and 1698/Mum/2012
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3. The learned TPO / AO has erred in law and on facts in
not granting credit of TDS of Rs. 11,79,35,990/- out of total TDS
credit of Rs.12.06.64,360.
4. The learned TPO / AO has erred in law and on facts in
levying interest under section 23413 of the Act of Rs.
1,77,76,885.
The learned TPO / AO has erred in law and on facts in levying
interest under section 234C of the Act of Rs.10,878/-"
3. Brief facts qua the issue relating to Transfer Pricing Adjustment
of Rs.8,04,58,878/- are that, the assessee, Tata Motor European
Technical Centre PLC (TMETC) is incorporated in the United
Kingdom (UK) and is resident of UK. The assessee is having
technical expertise of Automotive Industries of European Standards,
and is wholly owned subsidiary of Tata Motors Ltd (TML). The TML
entered into design and engineering service agreement with the
assessee for providing design, engineering, testing and validation,
research and development of automobiles, including progrmme
management for the automotive and aerospace industries. For
rendering these services for the TML, the assessee sent its
employees in India by deputing engineers and technical personnel at
TML's factory/establishment in India. Thus, the assessee had a
Service PE in India. The assessee, for rendering design and
engineering services for TML during the year, had received an
.T.A.No.7630 and 1698/Mum/2012
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amount of Rs.31,98,72,720/- and the operating profit for the year
was shown in the following manner :
Total operating income Rs. 31,98,72,720
Total operating cost Rs.29,27,04,244
Operating profit Rs.2,71,68,476
OP/TC% 9.28%
In the TP study report, for the purpose of benchmarking its
transaction and the margin, the main factors which were taken into
account were that, the design and engineering services for
automotive industries is highly Specialized services and considering
the nature of automotive industries in terms of global standards,
competition and growing compliance requirements towards safety
and environmental norms, the parallels are not available in India.
The other factors for consideration were that, as against the operation
cost incurred by the PE, the major portion was towards the salary of
the employees who had special skills and knowledge and were paid
salary in UK only. The PE did not had any independent business in
India and it does not enter into any contract with outside party in
India. Considering these factors and FAR analysis which was
effected by demographic and economic factors in UK, the assessee
searched for UK comparables rendering similar kind of services in
UK. Thus TMETC (i.e the assessee) was taken as tested party for
.T.A.No.7630 and 1698/Mum/2012
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benchmarking the ALP. Based on FAR analysis and by adopting
TNMM as the most appropriate method and PLI as OP/TC, the
assessee selected four overseas comparables located in UK to
benchmark the Arm Length Price of the transactions with the AE i.e
TML, which were as under :
S.No. Name of the 2007 2006 2005% 3 year
comparables % % weighted
Avg.(%)
1 Dytcna limited 4.17 6.74 4.86 5.26
2 Ricardo PLC 8.34 10.11 6.90 8.47
3 Online Design 6.98 5.85 5.47 6.22
and
engineering
Ltd.
4 Acteon group 21.87 19.63 10.60 18.31
Ltd
Average 10.34 10.59 6.96 9.57
Assessee's 9.28%
profit margin
Since, for the year 2007 the average profit margin of the comparables
was arrived at 10.34%; therefore, the assessee's profit margin being
at 9.28%, was stated to be at Arm's Length range.
4. The Transfer Pricing Officer (TPO) though accepted the TNMM
method and the PLI employed by the assessee for determining the
ALP of its international transactions, however, completely disagreed
with the selection of foreign comparables based in UK, as he held
that it is not tenable under the Indian Transfer Pricing Rules and
.T.A.No.7630 and 1698/Mum/2012
6
provisions. His other reasoning was that, that since the PE of the
assessee is located in India and carrying out its business within the
Indian territory, therefore, it should be treated as business entity in
India, akin to the other corporate entities doing business in India.
Further assessee's direct and indirect cost are incurred in and in
connection with business transactions in India and therefore, Indian
comparables should be selected for benchmarking the assessee's
margin. The TPO, hence selected 7 Indian comparables having
average mean margin of 36.77% which are as under :
S.No. Company Name OT /TC
1 Mahindra Consulting Engineers Ltd 28.96%
2 Alplangeo (India) Ltd. 41.58%
3 Stup Consultants Pvt Ltd. 36.72%
4 Semac Ltd 49.65%
5 Mitcon Consultancy Services Ltd. 41.21%
6 Kirloskar Consultants Ltd 21.29%
7 Computronics Financial 38.02%
Average Mean 36.77%
In response to the show cause notice, the assessee gave detailed
submissions justifying the selection of foreign comparables, which
have been incorporated by the TPO at para 8 of his order.
Assessee' contention has been rejected by him in detail, as per the
discussions appearing at pages 5 to 9 of the order and accordingly,
he benchmarked the assessee's margin with the mean profit
.T.A.No.7630 and 1698/Mum/2012
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margin of the 7 Indian comparables and made adjustment of
Rs.8,04,58,874/- in the following manner:
Total Operating Income Rs.31,98,72,720/-
Total operating cost Rs.29,27,04,244/-
Operating profit Rs.2,71,68,476/-
Profit Margin of assessee 9.28%
Arm' Length Profit Margin (36.77% of OC) Rs.10,76,27,350/-
Arm's Length value of transactions Rs.40,03,31,594/-
95% of Arm's Length Value Rs.38,03,15,014
Difference being shortfall in OP being Rs.8,04,58,874/-
adjustment
5. One of the main objection of the assessee before the DRP was
that, in the immediately preceding year i.e. in the assessment year
2007-08, on identical international transactions, the TPO has
accepted the UK comparables, selected from foreign data for bench
marking the international transactions of the assessee and therefore,
in this year also the TPO should have accepted the foreign
comparables. The DRP rejected the assessee's contentions and
other objections on the ground that the tested party is the Indian PE,
who is working in the Indian business environment and the mere fact
that the employees get paid in European or UK currency will not
decide the selection of foreign comparables. For the purpose of
Income tax, the PE has to be treated as distinct and separate
enterprise of the foreign company and therefore, the TPO has rightly
selected Indian companies as comparables. For other objections
.T.A.No.7630 and 1698/Mum/2012
8
also, the DRP rejected the assessee's contention and upheld the
order of the TPO.
6. Before us, ld. counsel Shri Rajan Vora, submitted that the
assessee being UK based company having its principal business in
UK from where it manages the services provided to TML motors
and all its employees are UK nationals having technical knowledge
of automotive industries and economic environment of European
Countries and therefore, based on the nature of business and
geographical factors, the comparability analysis can be done only
through selection of UK comparables engaged in the similar activities,
for the proper determination of ALP. The TMETC-PE is not
influenced by the Indian economic/financial environment and there
are no Indian employees. All the costs considered for attribution of
PLI are incurred by TMETC in UK only. Even under the Indian
Transfer Pricing Regulations, comparability analysis based on FAR
is the most crucial part for bench marking the Arm's Length Price,
which is mainly based on selection of comparables having similar
kind of business, functions and environment. In support of his
proposition, for the selection of foreign comparables he relied upon
the following Tribunal decisions:
a) Global Vantedge Pvt Ltd (2010) TIOL-24-ITAT-Del) and
.T.A.No.7630 and 1698/Mum/2012
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b) Ranbaxy India Ltd (299 ITR (AT) 175 (Del)
He further submitted that OECD guidelines, and UN Practical
Manual on Transfer Pricing for the developing countries have
recognized that foreign comparables can be taken into consideration,
if the tested party has been chosen as the foreign company. The
aforesaid decisions of the Tribunal have taken into cognizance such
OECD guidelines and UN manual. Thus, he submitted that selection
of foreign comparables for the purposes of comparability analysis and
bench marking the Arm's Length Price should be taken into
consideration. Without prejudice to the above, he also made detailed
submissions with regard to the 7 comparables chosen by TPO, to
demonstrate that there are no actual comparables having similar
profile and functions with that of the assessee and therefore, no
company in India can be considered as comparable with the
assessee. He also filed written synopsis, with regard to each
comparables, to show, how they are functionally not comparable
with the assessee.
7. On the other hand, the ld. CIT DR strongly relied upon the order
of TPO and the direction given by DRP and submitted that, if the
PE of the assessee has been considered as Indian entity, functioning
in India and all its services are being rendered in India, then its
.T.A.No.7630 and 1698/Mum/2012
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margin for the Indian transaction have to be bench marked with the
Indian comparables. Thus, the TPO has rightly adopted Indian
comparables for bench marking the ALP of the assessee for its
services rendered to Tata Motors.
8. We have heard the rival submissions, perused the relevant
findings of the TPO as well as directions of DRP and also material
placed on record. The assessee, TMETC is UK based company
which is wholly owned subsidiary of Tata Motors Ltd, India. Its
business activities primarily involved providing of automobile design
and engineering services to the TML and for rendering these
services the TMETC-UK sends its employees/engineers to India. It
is in this background, the TMETC has been considered as having a
service PE in India and therefore, its profit from Indian operation is
taxable in India. For the purposes of TP analysis, the assessee has
selected TMETC as the tested party, since all its operating cost are
incurred in UK, having employees based in UK, therefore, it has
selected comparable companies from UK having similar kind of
functions and rendering similar services. It has selected four UK
based comparables having average arithmetic mean of 10.3% for the
year 2007, and therefore, it was stated that its margin of 9.8%
(OP/TC) is at arm's length range.
.T.A.No.7630 and 1698/Mum/2012
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9. The sole issue before us is, whether the assessee was justified
in carrying out comparative analysis on the basis of UK based
comparables, rather than by selecting Indian comparables. The
TPO's main objection is that, since the Indian PE is performing its
function in India and rendering services to Indian company, therefore,
margins for the Indian operation has to be bench marked with the
Indian comparables. Indian Transfer Pricing Regulations specifically
Rule 10B of the Income Tax Rules, 1962 does not specify that the
comparability analysis of international transactions has to be strictly
with the Indian companies but, it only lays down that comparability
with uncontrolled transactions has to be chosen with reference to :
(2) For the purposes of sub-rule (1), the comparability of an
international transaction with an uncontrolled transaction shall be
judged with reference to the following, namely:--
(a) the specific characteristics of the property transferred or
services provided in either transaction;
(b) the functions performed, taking into account assets employed
or to be employed and the risks assumed, by the respective
parties to the transactions;
(c) the contractual terms (whether or not such terms are formal or
in writing) of the transactions which lay down explicitly or
implicitly how the responsibilities, risks and benefits are to be
divided between the respective parties to the transactions;
(d) conditions prevailing in the markets in which the respective
parties to the transactions operate, including the geographical
location and size of the markets, the laws and Government
orders in force, costs of labour and capital in the markets,
overall economic development and level of competition and
whether the markets are wholesale or retail."
.T.A.No.7630 and 1698/Mum/2012
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Thus, the Indian Transfer Pricing Regulations while selecting
comparable companies lays emphasis on FAR analysis, and
conditions prevailing in the markets in which the parties operate for
carrying out the comparability analysis. If such comparability analysis
could not be done properly with the Indian comparables looking to
the characteristics and nature of the functions performed and
services rendered then, it has to be seen from the angle who is
selected as "tested party" and based on that, comparables are to be
chosen from the economic factors and the functions performed in
the conditions prevalent of the tested party. If the tested party itself is
foreign based and the services rendered by it is very specific, for
which the Indian comparables are not available or functionally not
comparable then, it cannot be held that foreign comparables cannot
be selected for benchmarking the Arm's Length Price or margin.
Indian Transfer Pricing Regulation does not puts any fetters on
selection of foreign comparables, if conditions are as such, that the
Indian comparables do not stand the test of comparability with the
tested party. Answer to this has been given in the OECD Transfer
Pricing Guidelines which provides that non-domestic comparables
should not be automatically rejected and it has to be seen on case
by case basis by the reference to the extent to which they satisfy
.T.A.No.7630 and 1698/Mum/2012
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the comparability factors. The relevant paragraph of the OECD
guidelines reads as under :
"A.4.3.2 Foreign source or non domestic comparables
3.5 Taxpayers do not always perform searches for
comparables on a country-by-country basis, e.g. in
cases where there are insufficient data available at the
domestic level and/or in order to reduce compliance
costs where several entities of an MNE group have
comparable functional analyses. Non-domestic
comparables should not be automatically rejected just
because they are not domestic. A determination of
whether non- domestic comparables are reliable has to
be made on a case-by-case basis and by reference to
the extent to which they satisfy the five comparability
factors. Whether or not one regional search for
comparables can be reliably used for several subsidiaries
of an MNE group operating in a given region of the world
depends on the particular circumstances in which each of
those subsidiaries operates. See paragraphs 1.57-1.58 on
market differences and multi-country analyses. Difficulties
may also arise from differing accounting standards"
10. If the tested party has been selected consistent with the
functional analysis of the controlled transaction and is a least
complex party to the controlled transaction, then even if it is a
foreign party, the same should be taken as the basis for carrying out
comparability analysis with the uncontrolled transaction by taking
into account the business environment in the country where the
tested party is being bench marked. Internationally, it has been
recognized that choice of the tested party should be such having
least complexity and should be the party in respect of which most
.T.A.No.7630 and 1698/Mum/2012
14
reliable data for comparability is available. The UN Manual on
Transfer Pricing, in Chapter 5 envisages the selection of tested
party in the following manner :
"5 . 3. 3. Selection of the Tested Party
5.3.3.1. When applying the Cost Plus Method, Resale Price
Method or Transactional Net Margin Method (see further
Chapter 6) it is necessary to choose the party to the
transaction for which a financial indicator (mark-up on costs,
gross margin, or net profit indicator) is tested. The choice of the
tested party should be consistent with the functional analysis
of the controlled transaction. Attributes of controlled
transaction(s) will influence the selection of the tested party
(where needed). The tested party normally should be the less
complex party to the controlled transaction and should be the
party in respect of which the most reliable data for
comparability is available. It may be the local or the foreign
party. If a taxpayer wishes to select the foreign associated
enterprise as the tested party, it must ensure that the neces-
sary relevant information about it and sufficient data on
comparables is furnished to the tax administration and vice
versa in order for the latter to be able to verify the selection
and application of the transfer pricing method."
It is very pertinent to note here that in Chapter 10, of the UN
Manual, in Para 10.4.1.3, Indian Transfer Pricing Regulation have
accepted the foreign comparables in cases where the foreign AE is
the least complex entity and requisite information about the tested
party and comparables re available. The relevant paragraph reads
as under :-
"10.4.1.3 The regulations prescribe mandatory annual filing
requirement as well as maintenance of contemporaneous
.T.A.No.7630 and 1698/Mum/2012
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documentation by the tax payer in case international
transactions between associated enterprises cross a threshold
and contain stringent penalty implication in case of non-
compliance. The preliminary onus of proving the arm's length
price of the transaction lies with the taxpayer, The Indian
transfer pricing administration prefers Indian comparables in
most cases and also accepts foreign comparables in cases
where the foreign associated enterprises is the less or least
complex entity and requisite information is available about the
tested party and comparables."
Thus, the Indian Transfer Pricing does not reject the concept of
foreign comparables, if the tested party is foreign AE. The blanket
assumption by the TPO and DRP that foreign comparables cannot
be accepted at all, is not correct. Similarly, US TP Regulations for the
purpose of Bench marking under comparable method has laid down
the following criterion for selection of tested party:
"(2) Tested party (i) In general. For purposes of this section,
the tested party will be the participant in the controlled
transaction whose operating profit attributable to the controlled
transactions can be verified using the most reliable data and
requiring the fewest and most reliable adjustments, and for
which reliable data regarding uncontrolled comparables can be
located. Consequently, in most cases the tested party will be
the least complex of the controlled taxpayers and will not own
valuable intangible property or unique assets that distinguish it
from potential uncontrolled comparables."
Further Para § 1.482-1 (C) viz, relevant factors for
comparability of uncontrolled companies is reproduced as
under:
(ii) Different geographic markets--('A) In general uncontrolled
corn parables ordinarily should be derived from the geographic
market in which the controlled taxpayer operates, because
.T.A.No.7630 and 1698/Mum/2012
16
there may be significant differences in economic conditions in
different markets. If information from the same market is not
available, an uncontrolled comparable, derived from a different
geographic market may be considered if adjustments are made
to account for differences between the two markets. If
information permitting adjustments for such differences is not
available, then information derived from uncontrolled
comparables in the most similar market for which reliable data
is available may be used, but the extent of such differences
may affect the reliability of the method for purposes of the best
method rule. For this purpose, a geographic market is any
geographic area in which the economic conditions for the
relevant product or service are substantially the same, and
may include multiple countries, depending on the economic
conditions."
11. Here in this case, there can no dispute with regard to the fact
that the tested party is TMETC, whose operating profit is to be
bench marked by carrying out functional analysis of its controlled
transactions for which reliable data for its comparability is available
in the country where it is located, then such comparables has to be
taken into account for carrying out the comparability analysis for the
purpose of Transfer Pricing and bench marking the Arm's Length
Price. The TMETC for the purpose of rendering services in India is
incurring all its cost in UK like direct costs, employee costs, legal
and professional fees, rent and other operating expenses, then for
the purpose of computation of PLI, these costs have to be taken into
consideration for determining the profit margin. Since all the main
costs attributable to the PE are based on cost incurred in UK, then
it can be very well said that PE is influenced by the economic and
.T.A.No.7630 and 1698/Mum/2012
17
financial conditions of UK, as against the Indian economic factors.
The Indian economic factors are not at all influencing the cost or
margin of the assessee, hence it cannot be held that Indian
comparables can be used to bench mark the TMETC transaction and
the price with Tata Motors. For this reason, the finding of the TPO as
well as DRP that PE is an Indian enterprise, working in India and
therefore, its margin is to be bench marked with Indian comparables
is not accepted. The PE in India is a service PE, having no
establishment in India, nor incurring any costs, deployed any assets,
therefore, cannot be held that it is an independent Indian enterprise.
Nothing has been brought on record that assessee's PLI is
influenced by the economic factors in India, viz, attribution of costs,
assets or other factors relevant for determination of profits are based
in India. Thus, in our opinion, the Transfer Pricing Officer and DRP
were not correct in holding that UK comparables cannot be taken
into consideration for the purposes of comparative analysis and
bench marking the assessee's margin. Accordingly, we hold that
under the facts and circumstances of the case, the foreign
comparables i.e. UK comparables can be taken into account for
carrying out FAR analysis and bench marking the Arm's Length
margin of the assessee's transactions with its AE and the selection
of the Indian comparables by the TPO is not accepted. Since the
.T.A.No.7630 and 1698/Mum/2012
18
TPO has not carried out any comparability analysis or FAR analysis
in respect of UK comparables chosen by the assessee, therefore,
he is directed to carry out such analysis and benchmark the
assessee's margin. If such comparables do not stand the test of
comparability then, TPO may search other comparable after
confronting to the assessee. In that case, for the search of
comparability assessee will provide necessary assistance to the
TPO. With this direction, the matter of transfer pricing adjustment is
restored back to the file of the TPO/AO. The Ground No.1 as raised
by the assessee is thus treated as partly allowed for statistical
purposes.
12. In view of the decision as given in ground No.1, ground No.2
has become purely academic and therefore no adjudication is
required.
13. Ground No.3 raised by the assessee is not pressed, therefore,
same is dismissed as not pressed.
14. In Ground No.4, the assessee has challenged the levy of
interest u/s 234B of the Act of Rs.1,77,76,885/-
15. In this regard, the ld. AR submitted that this issue is squarely
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19
covered in favour of the assessee by the decision of the Hon'ble
Bombay High Court in the case of Director Of Income-tax
(International Taxation). Vs. NGC Network Asia(2009) 313 ITR
187(Bom). Accordingly, we direct the AO to follow the decision of
jurisdictional High Court (supra), if the ratio is applicable on the
facts of the case.
16. In Ground No.5, the assessee has challenged the levy of
interest u/s 234C of the Act of Rs.10.878/-
17. Before us, the ld. counsel submitted that no interest u/s 234C
should levied as the same is leviable on the returned income.
Accordingly, we direct the AO to charge interest u/s 234C on the
returned income.
18. Thus, the appeal of the assessee is treated as partly allowed
for statistical purposes.
19. The assessee has also raised the following as additional
grounds:
"6. Without prejudice to the all other grounds, the Hon'ble
DRP should have directed fresh comparability analysis to select
Indian comparables which are functionally comparable to
appellant, as comparables chosen by the AO/TPO to
benchmark the transition are functionally different;.
7. Without prejudice to the all other grounds , the ld.
TPO/AO has erred in not considering the correct operating
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20
margin of the appellant i.e. 27.61% (i.e. OP/OC), while
computing the arms-length price of appellants international
transactions and instead of considering 9.28% as operating
margin of the appellant"
20. In the assessment year 2009-10 also the assessee has raised
exactly similar ground. However, In view of the decision given in
respect of ground No.1, the additional grounds have become purely
academic and the same is dismissed as infructuous.
ITA No.1698/Mum/2014 (AY-2009-10)
22. The sole issue raised in this appeal by the appellant is that the
AO has erred in making addition on account of transfer pricing
adjustment of Rs.5,38,24,761/- by selecting the Indian companies as
comparables, instead of foreign companies for benchmarking the
international transaction of provision of services, with the AE .
23. Since the issue raised is similar to ground raised in the appeal
of assessee for the assessment year 2008-09 vide ground No.1, on
similar set of facts, therefore, finding given therein will apply mutatis
mutandis to this ground also in this year. Therefore, ground raised by
the assessee is treated as partly allowed for statistical purposes.
.T.A.No.7630 and 1698/Mum/2012
21
24. In the result, the appeals of the assessee are partly allowed for
statistical purposes.
Order pronounced in the open court on 22nd Dec,2014
nd
22 Dec, 2014
sd/- sd/-
(. . /N.K.BILLAIYA) ( /AMIT SHUKLA)
/ ACCOUNTANT MEMBER / JUDICIAL MEMBER
Mumbai : on this 22nd Dec, 2014
. ../ SRL , Sr. PS
/Copy of the Order forwarded to :
1. / The Appellant
2. / The Respondent.
3. () / The CIT(A)-
4. / CIT
5. , , / DR,
ITAT, Mumbai
6. / Guard file.
/ BY ORDER,
true copy
(Asstt. Registrar)
, /ITAT, Mumbai
|
