Subject: Sony Mobile Communication (India) Pvt Ltd. has rejected the contention of revenue on the applicability of bright line test
Referred Sections:
Section 92C(3) of the Act).
Section 92(3)
Section 10B(1)(c)
Referred Cases / Judgments
Soni Ericsson Mobile Communication India [P] Ltd Vs. CIT ITA No. 16/2014
1
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI `I-2' BENCH,
NEW DELHI
BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, AND
SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER
ITA No. 7574/DEL/2017
[A.Y 2013-14]
M/s Sennheiser Electronics India Ltd Vs. The A.C.I.T
102-A, First Floor, Time Tower Circle 4(1)
M.G. Road, Gurgaon, Haryana Gurgaon
PAN : AAKCS 4629 Q
[Appellant] [Respondent]
Date of Hearing : 10.09.2018
Date of Pronouncement : 19.09.2018
Assessee by : Shri Alok Vasant, Adv
Revenue by : Shri H.K. Choudhary, CIT-DR
Ms. Anchal Khandelwal, Sr.DR
ORDER
PER N.K. BILLAIYA, ACCOUNTANT MEMBER,
With this appeal, the assessee has challenged the correctness of
the order dated 29.11.2011 framed u/s 143(3) r.w.s 144C of the
Income-tax Act, 1961 [hereinafter referred to as 'the Act'].
2
2. The assessee is aggrieved by the addition to the total income of
the assessee using Bright Line Test on protective basis amounting to
Rs. 4,08,18,553/- and is further aggrieved by the addition of Rs.
5,95,56,701/- using cost plus method on substantive basis on account
of the alleged difference in arm's length price [ALP] of the
international transaction of advertisement, marketing and promotion
[AMP] expenses.
3. Briefly stated, the facts of the case are that the appellant
company was incorporated on 11.01.2007 as a subsidiary of
Sennheiser Global Operations Gmbh. The appellant company is
primarily engaged in the business of sales and distribution of
headphones, microphones, receivers, monitoring systems, tour guide
systems and aviation headsets. It imports goods from Sennheiser
Group Companies for reselling through its distributors in India. The
appellant company distributes all brands of the Sennheiser group
and has service centres located in Haryana, Mumbai and Bangalore
and also service products within and outside warranty. The
appellant also import spares from Sennheiser group Companies.
3
4. During the course of scrutiny assessment proceedings, the case
was referred to the TPO who framed order dated 26.10.2016 u/s 92CA
of the Act and determined adjustment of Rs. 4,33,12,598/- on account
of AMP adjustment. Pursuant to the order of the TPO, a draft
assessment order was passed on 19.12.2016 wherein the total income
was assessed at Rs. 6,13,75,390/- after making addition of Rs.
4,33,12,598/- on account of T.P. adjustment/addition.
5. Aggrieved by the proposed addition, the assessee company raised
objections against the draft assessment order before the DRP and the
DRP passed its order on 28.09.2017. Pursuant to the directions of the
DRP, the TPO finally framed the order and the same reads as under:
"The Hon'ble DRP has directed to apply bright line method for
computation of ALP of expenses. Hence, the working of adjustment
using bright line method is as under:
3.1 The assessee has incurred Rs. 3,75,58,618/- towards AMP
expenses during the year under consideration. During the course of
proceedings for AY 2012-13, this office had taken a stand that
bright line test should be applied and any AMP expenditure
incurred by the taxpayer in excess of the expenditure incurred by
the comparables should be considered as the expenditure incurred
4
by the taxpayer for the benefit of the parent AE and
corresponding adjustment should be made. The Ilon'ble High Court
in the case of Sony Mobile Communication (India) Pvt Ltd. has
rejected the contention of revenue on the applicability of bright
line test and corresponding calculations. The Department has filed
an appeal against the order of the Hon'ble High Court and
contesting the judgment before the Hon'ble Supreme Court.
Further, the Hon'ble DRP had also directed to apply bright line
method for computation of ALP of AMP expenses for the AY 2013-
14 vide its directions dated 28.09.2017.
3.2 The AMP/ sales of the final comparables as selected by the
assessee are as under-
1s- Name of comparables AMP Sales AMP /
.1 expenditure turnover (In Sales
Advanced Micronic Devices
0.
1 (In Rs.)
11,86,741 Rs.)
44,86,16,502 0.26%
(%)
Ltd.
2 Dax Networks Ltd. 16,06,768 37,92,97,823 0.42%
3 Priya Ltd. 20,18,929 2,11,17,30,474 0.10%
4 Redington (India) Ltd. 54,01,64,000 2,28,99,05,57, 0.24%
5 Salora International Ltd 20,69,000 000
3,64,63,68.00 0.06%
Average AMP/ Sales ratio in case of comparable 0
companies 0.22%
Senheiser Electronics India 3,75,58,618 61,63,22,571 6.09%
Pvt. Ltd.
3.3 The mean of the "expenditure incurred on AMP/sales" of
such companies is the "bright line". Any expenditure in excess of
the bright line is for the promotion of brand/trade name (which is
owned by the AE) that needs to be suitably compensated by the
AE. The amount which represents the bright line and the amount
5
that should have been compensated to the taxpayer company are
computed hereunder:
Particulars Value
Value of gross sales 61,63,22,571
AMP/Sales of comparables 0.22%
Amount that represent hi i&nt line 13,55,910
Expenditure on AMP by taxpayer 3,75,58,618
Expenditure in excess of bright line 3,62,02,708
3.4 Since the amount of Rs. 3,62,02,708/- was spent by the
taxpayer company over and above the bright line limit for provision
of services related to AMP purely for the AE, an independent
entity under similar circumstances would have charged a mark-up
on this amount, for the money spent and for the service element.
The Hon'ble DRP had directed to apply mark up of SBI base rate
plus 300 basis points in the case of the assessee for the AY 2012-
13. The SB1 base rate comes to 9.75% for the FY 2012-13, Hence,
mark up of 12.75% is applied on the amount of Rs. 3,62,02,708/-
for computation of ALP.
3.5 Therefore, the taxpayer company should have been
compensated by the AE at Rs. 3,62,02,708/- plus mark-up @
12.75% (Rs. 46,15,845/-) for undertaking advertisement,
marketing and publicity activities purely for AE and most
importantly creating a marketing intangible for the AE. The net
6
adjustment therefore works out to Rs. 4,08,18,553/-. Accordingly,
adjustment of Rs. 4,08,18,553/- is made on protective basis.
The Hon'ble DRP has directed to re-compute the adjustment by
following the manner of computing ALM and ALP adjustment as
demonstrated in para 8.1.3 of the DRP's order dated 28.10.2016
for the AY 2012-13. The calculation of adjustment for the year
under consideration is as under-
S.No. Particulars Value (Rs.)
AMP expenses after excluding selling 3,75,58,618
expenses (A)
1 Reimbursement received from AE (B) Nil
Total expenditure incurred by assessee 3,75,58,618
on AMP (C)
Sales 61,63,22,571
C.O.G.S 38,86,69,622
2
Gross Profit 22,76,52,949
Markup (gross profit margin) (D) 58.57%
3 ALP of AMP expenses (E)=(C*D)+C 5,95,56,701
4 Adjustment u/s 92CA = (E)-(B) 5,95,56,701
Accordingly, adjustment of Rs. 5,95,56,701/- is made on
substantive basis by using cost plus method.
5. Therefore, in view of the direction of the Ld DRP-1, New Delhi
the earlier adjustment of Rs. 4,33,12,598/- is being revised to Rs
5,95,56,701/- on substantive basis. Besides, an adjustment of Rs,
7
4,08,18,553/- is being made on protective basis. The A.O. shall
enhance the income of the assessee by an amount of Rs.
5,95,56,701/- in computation of its total income while passing the
Final Order."
6. Aggrieved by this, the assessee is before us.
7. At the very outset, the ld. counsel for the assessee stated that
the directions of the DRP followed by the TPO, applying Bright Line
Method has been discarded by the Hon'ble Jurisdictional High Court of
Delhi in Tax Appeal No. 16 of 2014 by listing its findings as under:
"18. Rejecting the application of bright line test, the Hon'ble
High Court of Delhi has listed its findings as under:
" (i) In case of a distributor and marketing AE, the first
step in transfer pricing is to ascertain and conduct
detailed functional analysis, which would include AMP
function expenses
(ii) The second step mandates ascertainment of
comparables or comparable analysis. This would have
reference to the method adopted which matches the
functions and obligations performed by the tested party
including AMP expenses.
8
(iii) A comparable is acceptable, if based upon comparison
of conditions a controlled transaction is similar with the
conditions in the transactions between independent
enterprises. In other words, the economically relevant
characteristics of the two transactions being compared
must be sufficiently comparable. This entails and implies
that difference, if any, between controlled and
uncontrolled transaction, should not materially affect the
conditions being examined given the methodology being
adopted for determining the price or the margin. When
this is not possible, it should be ascertained whether
reasonably accurate adjustments can be made to
eliminate the effect of such differences on the price or
margin. Thus, identification of the potential comparables
is the key to the transfer pricing analysis. As a sequitur,
it follows that the choice of the most appropriate
method would be dependent upon availability of potential
comparable keeping in mind the comparability analysis
including befitting adjustments which may be required.
As the degree of the comparability increases, extent of
potential differences which would render the analysis
inaccurate necessarily decreases.
9
(iv) The assessed, i.e. the domestic AE must be
compensated for the AMP expenses by the foreign AE.
Such compensation may be included or subsumed in low
purchase price or by not charging or charging lower
royalty. Direct compensation can also be paid. The
method selected and comparability analysis should be
appropriated and reliable so as to include the AMP
functions and costs.
(v) Where the Assessing Officer/TPO accepts the
comparables adopted by the assessed, with or without
making adjustments, as a bundled transaction, it would be
illogical and improper to treat AMP expenses as a
separate international transaction, for the simple reason
that if the functions performed by the tested parties
and the comparables match, with or without adjustments,
AMP expenses are duly accounted for. It would be
incongruous to accept the comparables and determine or
accept the transfer price and still segregate AMP
expenses as an international transaction.
(vi) The Assessing Officer/TPO can reject a method
selected by the assessed for several reasons including
want of reliability in the factual matrix or lack / non-
10
availability of comparables. (see Section 92C(3) of the
Act).
(vii) When the Assessing Officer/TPO rejects the
method adopted by the assessed, he is entitled to select
the most appropriate method, and undertake
comparability analysis. Selection of the method and
comparables should be as per the command and directive
of the Act and Rules and justified by giving reasons.
(viii) Distribution and marketing are inter-connected and
intertwined functions. Bunching of inter-connected and
continuous transactions is permissible, provided the said
transactions can be evaluated and adequately compared
on aggregate basis. This would depend on the method
adopted and comparability analysis and the most reliable
means of determining arm`s length price.
(ix) To assert and profess that brand building as
equivalent or substantial attribute of advertisement and
sale promotion would be largely incorrect. It represents a
coordinated synergetic impact created by assortment
largely representing reputation and quality. `Brand' has
reference to a name, trademark or trade name and like
11
`goodwill` is a value of attraction to customers arising
from name and a reputation for skill, integrity, efficient
business management or efficient service. Brand creation
and value, therefore, depends upon a great number of
facts relevant for a particular business. It reflects the
reputation which the proprietor of the brand has
gathered over a passage or period of time in the form of
widespread popularity and universal approval and
acceptance in the eyes of the customer. Brand value
depends upon the nature and quality of goods and
services sold or dealt with. Quality control being the
most important element, which can mar or enhance the
value.
(x) Parameters specified in paragraph 17.4 of the order
dated 23rd January, 2013 in the case of L.G. Electronics
India Pvt Ltd (supra) are not binding on the assessed or
the Revenue. The `bright line test` has no statutory
mandate and a broad-brush approach is not mandated or
prescribed. We disagree with the Revenue and do not
accept the overbearing and orotund submission that the
exercise to separate routine` and `non-routine` AMP or
brand building exercise by applying `bright line test` of
non-comparables should be sanctioned and in all cases,
12
costs or compensation paid for AMP expenses would be
`NIL`, or at best would mean the amount or compensation
expressly paid for AMP expenses. It would be
conspicuously wrong and incorrect to treat the
segregated transactional value as NIL` when in fact the
two AEs had treated the international transactions as a
package or a single one and contribution is attributed to
the aggregate package. Unhesitatingly, we add that in a
specific case this criteria and even zero attribution could
be possible, but facts should so reveal and require. To
this extent, we would disagree with the majority decision
in L.G. Electronics India Pvt. Ltd. (supra). This would be
necessary when the arm`s length price of the controlled
transaction cannot be adequately or reliably determined
without segmentation of AMP expenses.
(xi) The Assessing Officer/TPO for good and sufficient
reasons can debundle interconnected transactions, i.e.
segregate distribution, marketing or AMP transactions.
This may be necessary when bundled transactions cannot
be adequately compared on aggregate basis.
13
(xii) When segmentation or segregation of a bundled
transaction is required, the question of set off and
apportionment must be examined realistically and with a
pragmatic approach. Transfer pricing is an income
allocating exercise to prevent artificial shifting of net
incomes of controlled taxpayers and to place them on
parity with uncontrolled, unrelated taxpayers. The
exercise undertaken should not result in over or double
taxation. Thus, the Assessing Officer/TPO can segregate
AMP expenses as an independent international
transaction, but only after elucidating grounds and
reasons for not accepting the bunching adopted by the
assessed, and examining and giving benefit of set off.
Section 92(3) does not bar or prohibit set off.
(xiii) CP Method is a recognised and accepted method
under Indian transfer pricing regulation. It can be applied
by the Assessing Officer/TPO in case AMP expenses are
treated as a separate international transaction, provided
CP Method is the most appropriate and reliable method.
Adoption of CP Method and computation of cost and gross
profit margin comparable must be justified.
14
(xiv) The object and purpose of Transfer Pricing
adjustment is to ensure that the controlled taxpayers
are given tax parity with uncontrolled taxpayers by
determining their true taxable income. Costs or expenses
incurred for services provided or in respect of property
transferred, when made subject matter of arm`s length
price by applying CP Method, cannot be again factored or
included as a part of interconnected international
transaction and subjected to arm`s length pricing."
8. Keeping in mind the aforesaid findings of the Hon'ble High Court
of Delhi [supra], we find that the assessee company is engaged in the
business of sales and distribution of headphones, microphones,
receivers, monitoring systems, tour guide systems and aviation
headsets. It also imports goods from Sennheiser group companies for
reselling through its distributors in India. It also undertakes after-sales
services.
9. The assessee has adopted TNMM as the most appropriate method
with operative profit to sales as PLI and the same is as under:
15
International Transfer Profit level Sennheiser Margin Compar
transaction pricing indicator[PLI] India Total -ables
method value of findings
transaction arithmeti
[Amount in c mean
NRI]
Purchase of 304238583
Goods
Provision of 7584825
services Transact Operating
Allocation of -ional Net Profit/Operating 1609631 3.71% 2.57%
expenses paid Margin sales [OP/Sales]
Reimbursement Method 61,848
of expenses [TNMM]
paid
Purchase of 426.514
advertisement
material
Reimbursement 1659460
of expenses
received
10. There is no quarrel so far as the most appropriate method i.e.
TNMM is concerned. It can be seen from the aforementioned chart
that the appellant's margin is 3.71%, whereas the comparable's margin
is 2.57%.
11. It is true that there was no agreement, understanding or
arrangement between the appellant and its AEs for incurrence of such
expenditure by the appellant.
16
12. As mentioned elsewhere, the TPO has followed Bright Line
Method for computing the ALP of the transaction. The appellant's
AMP/sales ratio is at 6.09% and that of the comparables is 0.22%,
taking a mark up of 12.75% on cost, which is wrongly adopted as cost
plus mark up at 58.57% while giving effect to the directions of the DRP.
13. The functions performed by the AEs are manufacturing, Research
and Development, Corporate Strategy and New Product Development
and Marketing and Sales.
14. We find that the advertisement spend by the appellant was with
a focus on selling the product by highlighting its features to potential
customers on one to one basis, most commonly through direct mail, e-
mail and online marketing.
15. In our considered opinion, the AMP expenses incurred were not
with a view to benefit the AEs but to only increase the appellant's own
sales.
16. The functions performed by Sennheiser group are described in
the following para:
17
"Manufacturing
Sennheiser group manufactures its products at three
factories, located at Germany, Ireland and the USA
respectively. In addition, it uses capacities at long-term
partner companies in Europe, Asia and America who fulfil
their strict quality requirements.
The product portfolio of Sennheiser group includes
microphones, Neumann microphones, wireless microphone
and monitor systems, conference and visitor information
technology, and headsets for aviation etc. In addition,
the company provides central Logistics services for
products manufactured by our Asian partner companies.
Sennheiser India does not perform any manufacturing
activity.
Research and development
Research and development activity is a centralized
activity done by the AEs. The group has a large research
and development centre in Germany and has research and
development offices in California and Singapore9.
Sennheiser India does not play any role in the research
and development activity performed by the group.
18
Corporate Strategy
The ultimate parent company formulates the overall
corporate strategy for the benefit of the entire group.
The corporate strategy of Sennheiser India is based on
the broader guidelines set by the ultimate parent
company.
New Products development
AEs decide on the introduction of any new products and
accordingly send relevant advertising and promotional
materials to Sennheiser India for distribution to
customers in its sales territory, this includes products
arid information and materials to be used in training the
distributor's personnel.
Thus, the product conceptualization is the function of
AEs and all related research & development activities are
carried out by the AEs.
Sennheiser group owns the Intellectual Property Rights
relating to products (patents), corporate logo/
trademark, technical know-how (in the form of presses
and technical data), quality standards, etc.
19
Marketing and Sales
AEs perform marketing activity through its wide network
of dealers and direct sales force team for promoting and
marketing the Products in order to expand its market
share in the Territory and defend its market position as
against its competitor.
The marketing strategy relating to positioning of new
services or solutions, launching a new service line or
solution, developing plans to capture a certain segment of
the market, etc. are all developed by the AEs.
17. The functions performed by the appellant company are described
in the following para:
"Sennheiser India procures head phones, microphones and
wireless systems (hereafter the "Products"; from its
AEs. The Company does not purchase any goods from any
third party vendor. However, there is no sale to any AE
by Sennheiser Electronics (India) i.e. the ultimate
customers for the traded products are unrelated parties.
The majority of the sales take place in the Indian
Territory. The customers include Production Studios,
Airlines, Audio & TV Channels, Call Centres in India.
20
The AE sells goods to the Sennheiser India at a price list
which is same for all the other fellow subsidiaries. The
Sennheiser India sells goods to distributors or other
"middle men" at an approximate gross margin of 45%.
Distribution and inventory Management
Sennheiser India is responsible for its own inventory
management. Sennheiser India sells in the domestic
market against a confirmed order from the customer
Further, Sennheiser India maintains warehouses at
various locations for facilitating distribution of goods in
various parts of India.
Quality control is undertaken by each manufacturer
before they are shipped to India. Once the goods reach
the Indian shore, Sennheiser India also performs quality
check.
Marketing & Sates of Finished Goods
Sennheiser India is responsible for distribution, invoicing,
collection, ordering or delivery to the end-user as well as
wholesalers.
Sennheiser India is responsible for marketing and other
sales promotion activities. Marketing strategy required to
be followed in India is performed by Sennheiser India
21
based on the broad guidelines as provided by Sennheiser
group.
All the brochures and other marketing literature is
designed and developed by Sennheiser India with inputs
regarding brochure specification from the parent
company. Sennheiser India is responsible for controlling
and coordinating the marketing activities in India.
Sennheiser India also provides after sales support for
both direct and indirect sales. Direct sales are the sales
made by Sennheiser India to the customer in India, In
respect of indirect sales AEs sell directly to customers in
India.
Sennheiser India provides a warranty for the equipment
supplied to the customer. In case of any warranty claims
made by the customers Sennheiser India either repairs or
replaces such goods. Thereafter, Sennheiser India is
reimbursed for the actual expenses incurred for
replacement/ repair under warranty, on cost to cost basis
without any mark up by the AEs.
The Company also provides training to the customers with
regard to the operation of the equipment. Sennheiser
India handles all customer complaints as well as the
billings and collection to/from the customers.
22
Training to the sales force regarding the operation and
mechanism of the product is provided by Sennheiser
India. Information on the Products and information and
materials to be used in training the employees to perform
the Marketing Services are developed by Sennheiser
group at the request of Sennheiser India.
Administration
Sennheiser India is responsible for all its local
administrative functions like, human resource,/recounting
and IT. It also prepares its own financial statements."
18. The ld. DR had vehemently contended that since there was no
agreement, understanding or arrangement between the assessee and
its AEs, respective functions performed cannot be determined. The ld.
DR further contended that since the Bright Line Test has been negative
by the Hon'ble High Court, let the TPO adjudicate the issue afresh
after determining the respective functions and frame de novo
assessment.
23
19. We have given thoughtful consideration to this contention of the
ld. DR. We do not find much force in the contention of the ld. DR
because the TPO, while framing the order u/s 92CA(3) of the Act was
well aware with the decision of the Hon'ble jurisdictional High Court of
Delhi in the case of Soni Ericcson Mobile Communication India Pvt Ltd
reported at 276 CTR 97, and therefore, it cannot be said that the TPO
was not aware that the Bright Line test has been discarded by the
Hon'ble High Court of Delhi. Relevant observations of the TPO are at
page 8 of his order. It was only on the basis of Bright Line test that
the impugned ALP adjustment was made, but that approach has
already been negatived by the Hon'ble High Court. Therefore, we see
no reason to remit the matter to the file of the TPO as is prayed for by
the ld. DR. A remand to the assessment stage cannot be a matter of
routine. It has to be so done only when there is anything in the facts
and circumstances to so warrant or justify. In our considered opinion,
no new facts have emerged and all the facts brought on record during
the course of assessment proceedings, do not indicate legally
sustainable basis for remitting the matter to the file of the TPO.
24
20. Simply because the department has not accepted the judgment
of the Hon'ble Jurisdictional High Court of Delhi, the binding nature of
such judgment is not mitigated in any manner. Unless the Hon'ble
Supreme Court reverses the judgment of any High Court, the same
holds field, and remains binding on all the authorities working under its
jurisdiction.
21. As mentioned elsewhere, the TPO has adopted cost and mark up
of 58.57%, whereas the appellant earns gross margin of 34.30%. A bare
perusal of the mandate of section 10B(1)(c) postulates under said
clause (ii) that "the amount of a normal gross profit mark-up to such
costs ..............in a comparable uncontrolled transaction ........is
determined." Thus, it is vivid that it is adjusted g.p. mark-up of the
comparables which is applied to the direct and indirect cost incurred
by the assessee in respect of international transaction for determining
ALP under cost plus method and there is no mandate for considering
the assessee's own g.p. rate for this purpose. We, therefore, do not
agree with the working done by the TPO in this regard.
25
22. We further find that the TPO has resorted to segregation of AMP
expenses as a separate international transaction requiring independent
bench marking by considering the same set of comparables as adopted
by the assessee. The Hon'ble High Court of Delhi in the case of Soni
Ericsson Mobile Communication India [P] Ltd Vs. CIT ITA No. 16/2014
has held that once the Assessing Officer/TPO accepted and adopted
TNMM but chooses to treat a particular expenditure like AMP as a
separate international transaction without bifurcation/segregation, it
would lead to unusual and incongruous results as AMP expenses was the
cost or expenses and was not diverse. Even if the AMP expenses
incurred by the appellant company are bench marked on a separate
basis, no adjustment on account of AMP expenses would survive
because of the following :
Particulars Amount (Rs)
Operating Margins of the assessee (OP/Revenue) 3.71%
(A)
Revenue of the assessee (B) 61,63,22,894
Operating profit of the assessee (C = A*B) 2,28,37,894
AMP expenses (Excl. sales commission and 3,75,58,618
discount)(D)
Operating Profit before AMP expenses, being
6,03,96,512
separately benchmarked (E = C+D)
Arm's length operating margin (F) 2.57%
Arm's length operating profit (G = B*F) 1,58,39,490
26
Profit available for set off (H = E-G) 4,45,57,022 -
SBI Base rate plus 300 basis points adopted by
12.75%
TPO for benchmarking AMP expenses (I)
Compensation for AMP expenses computed by 4,08,18,553
TPO
Adjustment on Account of AMP expenses after (37,38,469)
set off (K = J-H)
23. Considering the facts of the case in totality from all possible
legal angles, we do not find any plausible reason for TP adjustment on
account of AMP expenses. We, accordingly, direct the Assessing
Officer to delete the impugned adjustments.
24. In the result, the appeal filed by the assessee in ITA No.
7574/DEL/2017 is allowed.
The order is pronounced in the open court on 19.09.2018.
Sd/- sd/-
[SUDHANSHU SRIVASTAVA] [N.K. BILLAIYA]
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated: 19th September, 2018
VL/
27
Copy forwarded to:
1. Appellant
2. Respondent
3. CIT
4. CIT(A)
5. DR
Asst. Registrar,
ITAT, New Delhi
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