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Income Tax Appellate Tribunal - Vizag
Kv Narasimha Rao, Visakhapatnam vs Department Of Income Tax on 7 April, 2011

ITA No 57 of 2009 KV Narasimha Rao Visakhapatnam

IN THE INCOME TAX APPELLATE TRIBUNAL

VISAKHAPATNAM BENCH, VISAKHAPATNAM

BEFORE: SHRI SUNIL KUMAR YADAV, JUDICIAL MEMBER

AND

SHRI BR BASKARAN, ACCOUNTANT MEMBER

ITA No.57/Vizag/2009

Assessment Year: 2004-05

ACIT Circle-3(1) K.V. Narasimha Rao, Visakhapatnam Visakhapatnam Vs.

(Appellant) (Respondent) PAN No:AHCPK 4037 C

Appellant By: Shri D.S. Sunder Singh, Sr.DR

Respondent By: Shri C. Kameshwara Rao, CA

ORDER

Per Shri B. R. BASKARAN, Accountant Member:

The appeal of the revenue is directed against the order dated 25.11.2008 passed by learned CIT(A)-I, Visakhapatnam and it relates to the assessment year 2004-05.

2. The revised grounds raised by the revenue read as under: "1. The learned CIT (A) erred in law in disposing the appeal without having jurisdiction over the case as the appellate jurisdiction lies with the CIT (A)-XXV, Mumbai consequent to service of the demand notice.

2. The learned CIT (A) erred in condoning the delay in the filing of appeal, on the basis of the affidavit filed by the Authorised Representative of the assessee, whereas, the affidavit is required to be filed by the assessee himself in so much as he is to affirm the facts in his knowledge as well as the reason for which delay occurred.

3. The learned CIT (A) erred in not confirming the order of the Assessing Officer with regard to treatment of income as salary income as against the claim of the appellant that it was income from business or profession.

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4. The learned CIT (A) has grievously erred in allowing the claim of expenditure, as the assessee failed to produce any evidence whatsoever before the Assessing Officer. During the course of the assessment proceedings, he ought to have got it examined before allowing it.

5. The revenue craves to add, alter, amend and modify any ground, as may be found necessary at the time of appeal hearing".

3. The facts relating to the case are stated in brief. The assessee is a Marine Engineer. He filed his return of income for the year under consideration with the Income Tax Officer-25(2)(4), Mumbai. The said Assessing Officer completed the assessment there of on 15-12-2006. As per the demand notice issued to the assessee, the appeal lies with Learned CIT(A)-XXV, Mumbai. However the assessee filed the appeal against the said assessment order before Learned CIT(A), Visakhapatnam on 24.09.2007 with a delay of about eight months. The learned CIT (A), Visakhapatnam heard the said appeal filed on 12-11-2008 and passed order on 25-11-2008. Against the said order of the learned CIT (A) the revenue has filed this appeal before us raising objections on technical issues and also on merits.

4. In the first ground, the revenue is contending that the Learned CIT(A), Visakhapatnam has no jurisdiction to pass the impugned appellate order. The facts relating to the same are stated in brief. As stated earlier, the assessment for the year under consideration was completed by the ITO in Mumbai and hence normally the appeal lies with the Learned CIT(A) in Mumbai. However, after the completion of the impugned assessment, the assessee shifted his permanent establishment from Mumbai to Visakhapatnam. Accordingly, vide letter dated 12-9-2007, he requested the Income Tax Officer Mumbai to transfer the record to the Income tax office, Visakhapatnam and the copies of said letter were marked to Commissioner

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of Income Tax located at Mumbai and Visakhapatnam. After sending the above cited letter, the assessee filed the impugned appeal before the learned CIT (A) Visakhapatnam on 24-9-2007, without waiting for the order for transferring the assessment records. There after the assessee sent another letter with a similar request on 26-12-2007 to the Income tax officer, Mumbai and the copies of said letter were marked to Chief Commissioner of Income Tax, Visakhapatnam and also to the Commissioners of Income Tax, located at Visakhapatnam and Chennai. Thereafter the assessee started filing his return of income with the Income tax office, Visakhapatnam. For assessment year 2007-08, he filed the return of income on 15.10.2007 and for assessment year 2008-09, the return of income was filed on 16.9.2008. The return of income filed for assessment year 2007-08 was also processed under section 143(1) by ACIT, Circle-3(1) Visakhapatnam on 24-7-2008. As per the document filed by the revenue before us, the assessee's records were transferred from Mumbai to Visakhapatnam on 12.8.2008. As stated earlier, the Learned CIT(A), Visakhapatnam heard the appeal on 12.11.2008 and disposed of the same on 25.11.2008.

4.1 According to the Learned Departmental Representative, the assessee should have filed the appeal at Mumbai and then he should have asked for transfer of the same to Learned CIT(A), Visakhapatnam. Only if the procedure stated above had been followed, the Ld CIT(A), Visakhapatnam would have got proper jurisdiction to adjudicate the impugned appeal. Since the assessee has failed to follow the procedure stated above, the Learned CIT(A), Visakhapatnam cannot be said to have jurisdiction over the impugned appeal and consequently his order is liable to be quashed.

4.2 However, the Learned Authorised Representative submitted that the mistakes pointed out by Learned D.R can almost be treated as procedural

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lapse and for such kind of procedural lapses, the order of Learned CIT(A) cannot be held to be invalid or without jurisdiction. He further submitted that the assessee has first filed a letter on 12-09-2007 to the Assessing Officer, Mumbai giving intimation of change of his permanent establishment and accordingly requested him to transfer the records from Mumbai to Visakhapatnam. The copies of said letter were also sent to the Commissioner of Income tax located both at Mumbai and Visakhapatnam. Only after filing the above said letter, the assessee has filed the impugned appeal before the learned CIT(A), Visakhapatnam in good faith and with the belief that his assessment records would be transferred from Mumbai to Visakhapatnam. With the same belief only, the assessee has also started filing returns of income for the subsequent years with the Income tax office, Visakhapatnam and his return of income for assessment year 2007-08 was also processed by ACIT, Circle-3(1), Visakhapatnam on 24.7.08 and refund of Rs.41,522/- was also granted, i.e. even prior to the transfer of records from Mumbai to Visakhaptnam on 12.8.2008. In any case, the Learned CIT(A) has heard the appeal and passed the impugned order only after such transfer of record. He accordingly submitted that the assessee has all through acted in good faith and hence the procedural or technical lapses if any, would not invalidate the order passed by Learned CIT(A). The Learned A.R also relied upon certain case law on the impugned subject and they are dealt with in subsequent paragraphs.

4.3 We have heard the rival submissions on the impugned issue of jurisdiction of Learned CIT(A). Section 120(1) of the Act states that the income tax authorities shall exercise their powers in accordance with such directions as the Board may issue. As per sec. 120(3), following criteria shall be taken regard of viz., (a) territorial area; (b) persons or class of persons; (c) incomes or classes of income; and (d) cases or classes of cases. Under section 124 states about the jurisdiction of the Assessing Officers. Sec. 127

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of the Act provides for transfer of cases from one Assessing Officer to another Assessing Officer. As per sec. 124(4), the dispute with regard to the jurisdiction of the Assessing Officer shall be decided by the Director General/Chief commissioner/Commissioner. Thus it could be seen that the issue regarding jurisdiction of Assessing Officer is treated as an administrative issue. The Act does not prescribe any procedure, if the assessee is not satisfied with the decision of Director General/Chief Commissioner/Commissioner.

4.4 It is to be noted here that there is no specific provision in the Act which prescribes the jurisdiction of the Learned CIT(A). During the course of hearing, it was submitted by Learned D.R that the jurisdiction of Learned CIT(A) is decided on the basis of the jurisdiction of the Assessing Officer only. However the revenue did not bring any directions/orders issued by CBDT in this regard. Further, it is also not known whether the CBDT has addressed the issue of jurisdiction of Learned CIT(A), whenever there is transfer of cases from one Assessing Officer to another Assessing Officer. Hence we proceed to dispose of this ground on the basis of rival contentions and material on record.

4.5 In the instant case, we have already noticed that the assessee, after filing a letter dated 12.9.2007 requesting for transfer of records, has preferred appeal before Learned CIT(A), Visakhapatnam against the assessment order passed by the Assessing Officer located at Mumbai. There after the assessee has also started filing his return of income for the subsequent years also in the Income tax office, Visakhapatnam. It is pertinent to note that his return of income for assessment year 2007-08 was processed in the Income tax office, Visakhapatnam and refund was also granted, prior to the date of transfer of records. The assessment records were actually transferred on 12.08.2008. Thus, from the conduct of

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the assessee narrated above, it is seen that the assessee has acted in good faith all through, with the firm belief that his assessment records would be transferred from Mumbai Income tax officer to Visakhapatnam Income tax office. We have also noticed that the Learned CIT(A) has heard the appeal and also passed the order only after the transfer of records from Mumbai to Visakhapatnam. We were told that the Learned CIT(A) issues the notice of hearing to the Assessing Officer also, but the Assessing Officer did not raise the issue of jurisdiction before learned CIT(A). However, at the time of hearing before us, the Learned D.R contended that the notice of hearing was not served on the Assessing Officer; but he could not substantiate his contentions with any evidence.

4.6 The present appeal was originally filed by the department in February, 2009. In the original grounds of appeal, the issue of jurisdiction was not raised. Later the department has riled revised grounds of appeal in February 2011 and in that the department has raised the issue of jurisdiction of Learned CIT(A). During the course of hearing, the Learned A.R also submitted that if the department's objection is accepted for a moment, then the Assessing Officer, who filed the present appeal and the Learned CIT, who authorised the filing of appeal also cannot have jurisdiction to institute the present appeal before this bench of the Tribunal. In that case, the Learned CIT should have requested the Learned CIT, Mumbai to file appeal before the ITAT, Mumbai against the impugned appellate order. Accordingly, it was submitted by Learned A.R that the department has indirectly accepted the jurisdiction of Learned CIT(A) by their conducts at different stage, i.e. they have accepted and processed the return of income filed by the assessee; they did not raise any objection before learned CIT(A); they have filed appeal before the Tribunal and hence they are not entitled to raise the issue of jurisdiction for the first time before the Tribunal that too, after passing of more than three years from the date

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of filing of appeal by the assessee. In this regard, the Learned A.R took support from the following case law:-

(a) Raja of Venkatagiri Vs. CIT (1955) (28 itr 189 (A.P) (b) Kakunuru Venkata Reddy Vs. CIT (1979) (118 ITR 917 (A.P)

4.7 In the case of Raja of Venkatagiri, (Supra), the issue was whether the appellate authority was right in admitting and disposing of the appeal filed by the assessee, even if the assessee did not pay the tax. As per sec. 30(1) of the Income tax Act, 1922, no appeal shall lie unless the tax has been paid. The assessee therein was granted instalments to pay the tax. By the time the appellate authority disposed of the appeal, the assessee had already paid the tax. The revenue raised the question of jurisdiction of Appellate Assistant Commissioner (AAC) for the first time before the Tribunal because, as per sec. 30(1) of 1922 Act, no appeal shall lie unless the tax has been paid. The revenue did not raise the issue of jurisdiction before AAC and allowed the appeal to be disposed of on merits. The Hon'ble Jurisdictional High Court held that in this kind of situation, it is not open to contend the said issue for the first time before the Tribunal. Though the facts in this case are different, yet the ratio of this decision is that the department should first raise its objections over such kind of technical matters before the appellate authority.

4.8 In the case of Kakunuru Venkata Reddy, (Supra), ex-parte order was passed in the hands of the assessee, since he did not file any return of income in response to the notice issued to him. In the appeal filed before the appellate authority, substantial relief was granted. Hence the revenue filed appeal before the Tribunal and the assessee filed cross objection. In the first appeal as well as in the cross objection, the assessee raised the question of jurisdiction of the Income tax officer, without raising the same before the Income tax officer. Since the assessee was unsuccessful on this

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ground, he filed appeal before the High Court. The Hon'ble Jurisdictional High Court answered the territorial issue against the assessee. While deciding the issue the Hon'ble High Court also considered sec. 21 of CPC. The relevant observations of the Jurisdictional High Court are extracted below:

"6. In the case of inherent lack of jurisdiction before an authority, the question of jurisdiction can be raised at any stage of the enquiry and even in collateral proceedings is well known. The objection based on territory is not in that sense a fundamental question. The IT Act (S.124) evolved a scheme with a view to work out such objections. A procedure is laid down in sub-s.(5) and (6) of s.124: could it be bypassed and said that the assessee is clothed with the right to object to the jurisdiction of the officer and his authority without recourse to the procedure in sub ss.(5) and (6)?. The answer having regard to the scheme, in our view, should be in the negative. The legal maxim generalibus specialia derogant also indicates that the right has to be worked out within the framework of the scheme and it is reasonable to hold that the plea is not entertainable and the assessee is precluded at subsequent stages of the proceedings under the Act".

....

8. "Therefore, on the facts it is not possible to hold that cl.(b) of sub-s.(5) is not attracted.

Apart from the provisions in the act, the general principles governing appeals indicate objections based as to "territory" should be decided at the inception and at the earliest opportunity. Sec.21 of the CPC is a pointer in that direction. In Scotland the principle "Forum non Conveniens" speaks of such a right. The word "conveniens" in Scottish law is not the same as the word "convenience" in English. Lord Dunedin points out that in Scottish Law "conveniens" means "appro- priate" (1962 Supreme Court (HL) page 18). The wholesome principle is now being grafted in England. The right to "object to the seat of judgment" in our jurisprudence must be decided at the inception, otherwise the "forum shopping" (the expression has no implication in a pejorative sense) in sequel if allowed at later stages brings forth the lamentable consequence of making the entire proceedings in vain. The assessee and the Revenue both under the IT Act (if objection

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is not raised before the ITO) have had dissipated in the end their time and energy in sleeveless errand".

4.9 For the sake of convenience, we extract below Sec. 21 of The Code of Civil Procedure, 1908:

"21. Objections to jurisdiction:-

(1) No objection as to the place of suing shall be allowed by any Appellate or Revisional Court unless such objection was taken in the Court unless such objection was taken in the Court of first instance at the earliest possible opportunity and in all cases where issues are settled at or before such settlement, and unless there has been a consequent failure of justice.

(2) No objection as to the competence of a Court with reference to the pecuniary limits of its jurisdiction shall be allowed by any Appellate or Revisional Court unless such objection was taken in the Court of first instance at the earliest possible opportunity, and, in all cases where issues are settled, at or before such settlement, and unless there has been a consequent failure of justice. (3) No objection as to the competence of the executing Court with reference to the local limits of its jurisdiction shall be allowed by any Appellate or Revisional Court unless such objection was taken in the executing Court at the earliest possible opportunity and unless there has been a

consequent failure of justice".

4.10 Thus it is seen that, as per the decision of Hon'ble jurisdictional High Court and also as per sec. 21 of CPC, the issue with regard to the territorial jurisdiction of Learned CIT(A) should have been raised before the learned CIT(A) himself at the earliest possible opportunity or otherwise it should be shown that there has been a consequent failure of justice. In our view, the above said legal propositions shall equally apply to the revenue also. In the instant case, the revenue has not raised the instant issue

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before Learned CIT(A). It was also not shown before us that there was a consequent failure of justice. Hence, in our view, the revenue is precluded from raising the issue of jurisdiction of Learned CIT(A) at this stage and accordingly we dismiss the said ground of revenue.

5. The next ground relates to the issue of validity of affidavit filed by the authorised representative of the assessee explaining the reasons for the delay in filing the appeal before Learned CIT(A). The facts relating to the said issue are stated in brief. The assessee filed appeal before the learned CIT (A) beyond the limitation period with a delay of about eight months. The Authorised Representative of the assessee filed an affidavit explaining the reasons for the delay in filing the appeal. On the strength of the said affidavit, the Learned CIT(A) condoned the delay and admitted the appeal. According to the revenue, the affidavit in such kind of situation is required to be filed by the assessee himself, as he has to affirm the facts which are within his knowledge and the reasons are known to him only. The Learned D.R reiterated the same contentions before us.

5.1 However the learned Authorised Representative, by placing reliance on the decision of Hon'ble Kerala High Court in the case of ITO vs. P.B. Babu reported in (1995) 213 ITR 219 (Ker), submitted that it is not compulsory that the assessee himself has to file an affidavit in support of the condonation petition.

5.2 We have gone through the decision in the case of P.B.Babu referred (Supra). In that case the Hon'ble Kerala High Court has held as under: "It is also not compulsory that the complainant himself has to file an affidavit in support of the condonation petition. Any person who is acquainted with the facts of the case and the person who is in the know of things is competent to file an affidavit justifying the grounds for not filing the appeal in time. Therefore, there is no merit in the above two

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contentions raised by the learned Counsel for the respondent".

Thus it is held by Hon'ble Kerala High Court that the affidavit can be filed by any person who is acquainted with the facts of the case. In the instant case, it was submitted by the learned Authorised Representative that he was fully acquainted with the facts and hence he himself filed the affidavit explaining the reasons for the delay in filing the appeal before the learned CIT (A). In view of the decision of the Hon'ble Kerala High Court cited above, the contention of the revenue that the assessee himself has to file the affidavit fails and accordingly we dismiss the ground relating to the same.

6. In the next ground the revenue is assailing the decision of Learned CIT(A) in holding that the income received by the assessee is assessable as business income. The facts relating to the said issue are stated in brief. As stated earlier, the assessee is a Marine engineer. He was employed with M/s Shipping Corporation of India Ltd (SCI) earlier and also for some part of the year under consideration. Thereafter, he resigned the job and started his own professional consultancy concern by name "Oceanic Offshore Services". He entered into a contract with a concern named M/s Evangrove Shipping (P) Ltd for offering consultancy services and received a sum of Rs.15,13,926/-, against which he claimed expenditure to the tune of Rs.10,71,901/-. During the course of assessment proceeding, the Assessing Officer noticed that the assessee while working with SCI, had actually worked in a ship named "MSV Samudra Suraksha". The said ship had been taken on a contract by SCI from ONGC. Later the SCI sub-let the said contract to a company named M/s Evangrove Shipping Pvt. Ltd. In this process, the assessee continued to provide services in the same ship. While the assessee had offered the income received from SCI as "Salary Income", he has offered the income received from M/s Evangrove Shipping Pvt. Ltd

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as "Professional Income". Hence the Assessing Officer examined the terms of contract entered between the assessee and M/s Evangrove Shipping Services and came to the conclusion that the assessee has only received "Salary" under the garb of consultancy services. Accordingly the Assessing Officer assessed the entire receipt of Rs.15,13,926/- under the head "Income from salary". He further held that the expenditure of Rs.10,86,174/- claimed by the assessee cannot be allowed as the assessee has failed to adduce supporting evidences, even if the receipt of Rs.15,13,926/- is treated as Business receipts. In the appeal proceedings, the Learned CIT(A) held that the amount of Rs.15,13,926/- received by the assessee has to be treated as business receipts. With regard to the expenditure claimed by the assessee, the Learned CIT(A) directed the Assessing Officer to make a disallowance of 10% of the said claim.

6.1 The Learned Departmental Representative submitted that the assessee is continued to be employed in the same ship and there was only change in the management. The terms of contract clearly show that the relationship between the parties was only an employer-employee relationship. Accordingly he contended that the impugned receipt of Rs.15,13,926/- has to be assessed only under the head "Income from salary". On the contrary, the Learned A.R placed heavy reliance on the order of Learned CIT(A).

6.2 We notice that the assessee has advanced following contentions before Learned CIT(A), viz.,

(a) unlike salary income, his monthly receipts are not of identical amount.

(b) The statutory allowances like PF, ESI are not allowed to him. (c) The TDS has been deducted at the rates applicable to Professional charges.

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(d) There is no employer-employee relationship between the assessee and the company, which is a mandatory condition for assessing the receipt under the head "Income from Salary".

6.3 The Learned CIT(A) re-examined the issue in the light of submissions made by the assessee and held as under and accepted the contentions of the assessee.

6.4 We notice that the Assessing Officer has considered certain clauses in the contract entered by the assessee with the above said company and came to the conclusion that the terms of contract are only in the nature of employment contract only. It is a well settled proposition that the employer-employee relationship should exist between the parties in order to tax the receipt under the head "Income from salaries". The assessee is rendering services "on board" and he is constrained to remain in the ship. Hence, in order to protect mutual interests, it is quiet normal to include certain clauses which are identical with the clauses normally entered into in a service agreement. Considering the terms of contract, the Learned CIT(A) has given a clear finding that the employer-employee relationship does not exist between the assessee and the company. The view of the Learned CIT(A) is further fortified by the fact that the company cited above has deducted the TDS by treating the payments made to the assessee as "Professional payments". Considering these facts, we are of the view, the Learned CIT(A) is right in holding that the impugned receipts cannot be assessed as Salary income.

7. In the next ground, the revenue is assailing the decision of Learned CIT(A) in allowing 90% of the expenditure claimed by the assessee. The Assessing Officer held that that entire expenditure claimed by the assessee cannot be allowed, even if the amount received by the assessee is treated as "Professional income", as the assessee failed to produce any evidence.

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However, the learned CIT(A) noted that the accounts of the assessee have been audited under section 44AB of the Act and tax audit report has also been furnished to the Assessing Officer and the net profit declared by the assessee worked out to 29.19%. The Learned CIT(A) also noticed that the tax auditors has reported that the expenditure claim of the assessee included personal expenditure to the tune of Rs.13,743/-. Accordingly, the Learned CIT(A) directed the Assessing Officer to disallow the personal expenditure of Rs.13,743/- claimed by the assessee and also further amount equivalent to 10% of the remaining amount of expenses.

7.1 The Learned D.R submitted that the assessee could not support the expenditure claim with proper vouchers and accordingly contended that the Learned CIT(A) is wrong in restricting disallowance to only 10% of the total expenditure claim. The Learned A.R however supported the order of Learned CIT(A).

7.2 We have heard the rival contentions on this issue. The Assessing Officer disallowed the entire claim mainly because the assessee did not produce the supporting vouchers before him. However, the said observations of the Assessing Officer are only alternative one, since he had already assessed the entire amount received by the assessee as "Salary Income". In the preceding paragraphs, we have confirmed the order of Learned CIT(A) in holding that the income received by the assessee has to be assessed under the head "Income from Business". It cannot be denied that once a business is set up, it is inevitable to incur certain expenses. In the instant case, the assessee is mainly working on "On board ship" and hence the expenses should normally be more on account of salary. However, it is the duty of the assessee to produce supporting evidences to prove the claim of expenses. In this case, the assessee has failed to produce them before the Assessing Officer. Hence, on a conspectus of the matter, we are of the view that the rate of disallowance made by the Assessing

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Officer may be increased from 10% to 15% and in our view the same would meet the ends of justice. We order accordingly. The order of learned CIT(A) is modified accordingly.

8. In the result, the appeal of the revenue is partly allowed.

Pronounced in the open Court on 7th April, 2011.

Sd/- Sd/- (SUNIL KUMAR YADAV) (B R BASKARAN) Judicial Member Accountant Member

PVV/SPS

Visakhapatnam,

Date: 07-04-2011

Copy to

1 The ACIT, Circle-3(1) Visakhapatnam

2 Shri Varaha Narasimha Rao, K. Door No.1-68-41, MIG-I, Plot No.1A, Sector-3, MVP Colony, Visakhapatnam 530 017

3 The CIT -1, Visakhapatnam

4. The CIT(A)-I, Visakhapatnam

5 The DR, ITAT, Visakhapatnam.

6 Guard file.

By Order

Senior Private Secretary

INCOME TAX APPELLATE TRIBUNAL

VISAKHAPATNAM

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