Income Tax Appellate Tribunal – Chennai
Andritz Separation And Pump … vs Dcit Corporate Circle 1(1), … on 6 June, 2019 आयकर अपील य अ धकरण, ‘डी’ यायपीठ, चे नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ (TP) BENCH : CHENNAI ी एन.आर.एस. गणेशन, या यक सद य एवं ी इंटूर रामा राव, लेखा सद य के सम [BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER] आयकर अपील सं./I.T.A. No. 2012/CHNY/2017 नधारण वष /Assessment year : 2013-2014. Andritz Separation and Pump The Deputy Commissioner of
Technologies India Pvt Ltd, Vs. Income Tax,
S.No.389, 400/2A, 400/2C, Corporate Circe 1(1)
Padur Road, Chennai.
Kuttampakkam Village,
Poonamallee Taluk,
Tiruvallur Dist.
Chennai 600 124. [PAN AAACN 1940M]
(अपीलाथ /Appellant) ( यथ /Respondent) अपीलाथ# क$ ओर से/ Appellant by : Shri. Sandeep Bagmar, Adv &’यथ# क$ ओर से /Respondent by : Shri. M. Srinivasa Rao, CIT. सन ु वाई क$ तार ख/Date of Hearing : 12-03-2019 घोषणा क$ तार ख /Date of Pronouncement : 06-06-2019 आदे श / O R D E R PER INTURI RAMA RAO, ACCOUNTANT MEMBER This is an appeal filed by the Assessee directed against the final assessment order dated 21.06.2017 for assessment year 2013-2014 :- 2 -: ITA No.2012/2017.

passed u/s.143(3) r.w.s. 144C (13) of the Income Tax Act, 1961 (in short ‘the Act’).

2. The Assessee raised the following grounds of appeal: ”1.1 On the facts and the circumstances of the case, the order passed by the Deputy Commissioner of Income Tax / Assessing Officer (‘Ld. AO’)./ Transfer Pricing Officer (‘Ld. TPO’), is bad in law and on facts.

1.2 On the facts and in the circumstances of the case and in law, the Ld. TPO/ the Ld. AO under the directions issued by the Hon’ble DRP, erred in making an addition to the Appellant’s total income of INR 1,76,58,850 based on the provisions of Chapter X of Income-tax Act, 1961 (‘the Act’).

1.3 The Ld. DRP erred in law by upholding/ confirming the action of the Ld. TPO who did not satisfy any of the conditions prescribed under Section 92C(3) of the Act before making an adjustment to the income of the Appellant.

2. Adjustment Relating to Payment of Management and Support Services Fees (‘Management Fees’) On the facts and in the circumstances of the case and in law, the Ld. TPO and Ld. AO under the directions issued by the Hon’ble DRP:

2.1 Erred in determining the Arm’s Length Price (‘ALP’) of intranational transaction pertaining to payment of management fees to its Associated Enterprises (AEs’) as ‘Nil’ as against INR 1,76,58,850 as determined by the Appellant.
:- 3 -: ITA No.2012/2017. 2.2 Erred by rejecting the aggregated approach
adopted by the Appellant under Transactional Net
Margin Method (‘TNMM’), without providing any
cogent reasons and on unsubstantiated basis. Erred by failing to appreciate that net operating profit
margin after deducting management charges of
the Appellant based on the TNMM applied in its
Transfer Pricing (‘TP’) study as required under section
92D of the Act read with Rule 1OD of the Income-tax
Rules, 1962 (‘Rules’), was higher than the arithmetic
mean of comparable companies, thereby confirming
the arm’s length nature of the intranational
transactions.

2.3 Erred by not appreciating the nature of business
of the Appellant and the need for management support
services from AEs, which was critical for the
Appellant’s business in India. Further, erred in not
appreciating that the management support services
received from the AE are closely linked to the
manufacturing function of the Appellant.

2.4 Erred by applying Comparable Uncontrolled Price
(‘CUP’) Method inappropriately and further erred by
not providing any comparable uncontrolled
transaction, thereby inappropriately applied Rule 1OB
and Rule 1OC.

Further erred in not bringing anything on record to
prove that the management services provided by the
AEs are generic in nature and erroneously concluding
that the services received are in the nature of
stewardship activities.

2.5 Erred in disregarding the submissions and
documentary evidences (emails copies, cost allocation
workings etc.) submitted by the Appellant towards
receipt of management services from its AEs.
:- 4 -: ITA No.2012/2017.

Further, erred in law and on facts by disregarding the commercial agreements entered into by the Appellant and questioning the commercial expediency of the Appellant.

3. Grounds in relation to penalty recommended u/s 271(1)(c) of the Act The Ld. AO erred in law and facts in by initiating penalty proceedings based on the erroneous inference that the Appellant has failed to furnish accurate particulars of income thus resulting in concealment of income”. 3. In addition to the above grounds, the following additional grounds were also raised.

”The Appellant humbly submits that the below grounds are independent and without prejudice to one another and in addition to the Grounds of Appeal filed on 18 August 2017.

1. The Learned Transfer Pricing Order (‘TPO’) exceeded its jurisdiction by not appreciating that the powers of the TPO under Section 92CA of the Income Tax Act is distinct from Section 37 of the Income Tax Act.

The finding of the Learned TPO that the Appellant did not benefit from the services received, tantamount to usurping the powers of the Assessing Officer to disallow any expenditure u/s 37, thus the Learned TPO exceeded its jurisdiction.

The Appellant craves leave to add to or alter, by deletion, substitution or otherwise, any or all of the above grounds of appeal, at any time before or during the hearing of the appeal”.
:- 5 -: ITA No.2012/2017.

4. The brief facts of the case are as under:

The appellant namely M/s. Andritz Separation and Pump Technologies Pvt Ltd, is a company incorporated under the provisions of the Companies Act, 1956. It is wholly owned subsidiary of Andritz AG, Austria. It is engaged in the business of design, manufacture, supply and commissioning of all equipment related to dewatering and drying systems. The return of income for the AY 2013-14 was filed on 28.11.2013 disclosing total income of Rs. 7,09,45,210/-. The assessee also reported the following intranational transactions in form 3CEB. Sl. Nature of intranational Name of Associated Value MAM
No transaction Enterprise ( in INR)
1 Purchase of raw Lenser Malaysia 97662879 materials/ components Andritz Germany 38691197 Andritz Slovak 1524406 Republic Andritz France 53057 Andritz Singapore 9791443 Andritz South Africa 5550994 Sub Total 150273976 2 Sale of finished goods Andritz Singapore 104382527 TNMM
3 Royalty paid Andritz AG 32160565 4 Consultancy charges Andritz AG 122808 paid Andritz US 294956 Sub Total 417764
5 Commissioning & Andritz Singapore 558096 Installation service :- 6 -: ITA No.2012/2017. 6 Lenser Malaysia 319533 Andritz AG 20728309 Sub Total 21047842 7 Repair /service charge Andritz South Africa 444926 received
8 Information Andritz AG 2657940 technology service charge
9 Exhibition and Andritz KMP 216900 seminar expenses
10 Reimbursement of Andritz Singapore 21091 expenses Lenser Malaysia 59565 Andritz South Africa 616577 Sub Total 697233
11 Dividend paid Andritz AG 32590500
12 Liquidated damages Lenser Malaysia 665183 received Total 34,61,13,452 and adopted Transactional Net Margin Method (hereinafter referred to as ”TNMM”) as most appropriate method for benchmarking the above transactions including transaction of royalty. The Assessing Officer (hereinafter referred to as ”AO”) noticing the above intranational transactions referred the matter to the Transfer Pricing Officer (hereinafter referred to as ”TPO”) u/s.92CA(1) of the Act for the purpose of benchmarking the above international transactions. The TPO after giving an opportunity of hearing to the assessee had proceeded to benchmark the above international transactions by :- 7 -: ITA No.2012/2017.

rejecting the transfer pricing study report submitted by the assessee and adopted comparable uncontrolled price (hereinafter referred to as ”CUP”) by treating each transaction as a separate clause of transaction. The TPO had proceeded benchmarking the transactions of royalty payments of I1,45,01,150/- and management fees of I1,76,58,850/-. While accepting that the transaction of royalty is at ALP, the TPO had proceeded to benchmark transaction of management fees of I1,76,58,850/- by CUP method. During the course of proceedings before the TPO, assessee had submitted an agreement dated 1.4.2012 entered by the appellant with its Associated Enterprise in terms of which management services rendered by the appellant are as under:-

MANAGEMENT SERVICES Service Provider shall provide management services to the benefit of the Andritz group of entities. Such services include in general activities related to:

• Development of the strategic orientation of the division within the whole Group and the overall responsibility that strategic targets are achieved • Support in compiling the yearly budgets in line with the strategic targets • Involvement in all relevant decision processes within the division to ensure the achievement of the strategic / budgeted targets, with respect to:
:- 8 -: ITA No.2012/2017. the organisational structure personnel investments projects, including R&D projects • Sales and representation activities, Contacts to key customers, etc. Consulting and monitoring the process of projects through project reviews • Consulting with regard to new business activities Service provider shall provide to the service receive, any other management service other than those mentioned above that may be advisory services; assistance and support to the financial purchasing, quality and engineering, tracking the corporate goals that the company may look for and without limitation to the following areas:-
Legal and Insurance advisory.
Financial Advice.
Advice on purchase of materials and equipment. Search for providers Budgeting, regular monitoring of them Preparation of feasibility plans.
Advice on grants and aids.
Advice on Corporate image and external relations, investment and diveastitures research. Human resources advisory.
Tax advice.
The assessee company also submitted copies of correspondences in the form of emails, the assessee company had with its Associated :- 9 -: ITA No.2012/2017.

Enterprise in an attempt to prove rendering of management services to the assessee by its Associated Enterprise. Considering all these evidences, the TPO held that an independent entity could not have paid management fees and therefore placing reliance on the para 7.6 of the OECD guidelines held that in the absence of evidence to prove the services rendered by the associated enterprise, the Arms Length Price was determined at Nil and accordingly suggested Arms Length Price adjustment of I1,76,58,850/- vide order dated 20.10.2016 passed u/s.92CA(3) of the Act. After receipt of the TPO order, a draft assessment order was passed by the Assessing Officer on 26.12.2016 under section 143(3) r.w.s. 144C(1) of the Act proposing to make an Arms Length Price adjustment of I1,76,58,850/-. After receipt of the draft assessment order, objection was filed before the Dispute Resolution Panel, (hereinafter referred to as ”DRP”) contesting that the transaction of intra group services is a closely linked with the manufacturing activity of the assessee and therefore the TPO ought to have accepted the transfer pricing study of the assessee ought not have applied CUP method in order to benchmark the transaction of intra group services and also contending that it is outside the jurisdiction of the TPO to question the necessity of intra group services. Ld. DRP considering the submissions of the appellant and also placing reliance on the decisions of Bangalore Bench of the :- 10 -: ITA No.2012/2017.

Tribunal in the cases of Gemplus India (P) Ltd vs. ACIT, 3 Taxmann.com 755 and Volvo India (P) Ltd vs. CIT, 77 taxmann.com 207, held that in the absence of proof for rendition of services, the TPO was justified in determining the Arms Length Price transaction of intra group services being Nil. After receipt of the TPO order, the Assessing Officer had passed the final assessment order u/s.143(3) r.w.s. 144C(13) of the Act vide order dated 21.06.2017. 5. Being aggrieved, the appellant is in appeal before us in the present appeal. It is submitted before us that once the expenditure was allowed u/s.37 (1) of the Act, the TPO was not justified to go into the question of necessity of expenditure as well as rendition of services, the Arms Length Price adjustment cannot be determined at Nil by applying the parameters laid down in Section 37 of the Act. In this connection he placed reliance on the decision of Hon’ble Bombay High Court in the case of CIT vs. Lever India Exports Ltd, (2017) 78 taxmann.com 88 and also filed additional grounds of appeal. 6. On the other hand, ld. Sr. Departmental Representative placed reliance on the orders of the TPO/ DRP. 7. We heard the rival submissions and perused the material on record. The issue involved in the present appeal is whether or not the TPO is justified in making Arms Length Price adjustment in respect of :- 11 -: ITA No.2012/2017.

international transaction of intra group services of I1,76,58,850/-. The TPO had suggested Arms Length Price adjustment in respect of intra group services on the ground that there was no proof in support of rendition of services for intra group services and services were not commensurate with the amount of the fees paid. Therefore, TPO inferred that no independent enterprise would not be willing to pay the amount of intra group service placing reliance on OECD guidelines at para 7.6, which is extracted hereunder:- ”under the arm’s Length principle, the question whether an intra-group service has been rendered when an activity is performed for one or more group members by another group member should depend on whether the activity provides a respective group member with economic or commercial value to enhance its commercial position. This can be determined by considering whether an independent enterprise incomparable circumstances would have been willing to pay for the activity in-house for itself. If the activity is not one for which the independent enterprise would have been willing to pay or perform for itself the activity ordinarily should not be considered as an intra-group service under the arms length principle”.
held that the ALP management fees paid should be determined at Nil. The significant fact which needs to be noted from the proceedings before the TPO is that assessee had filed certain evidences in the form of emails, in an attempt to prove the receipt of services. Considering this evidence, the TPO had given finding that the payments made are not commensurate with services rendered and the merely :- 12 -: ITA No.2012/2017.

description of services does not establish rendition of services, further TPO observed that emails talks about setting of the targets for the assessee and these emails are in relation to regulation of the assessee company by the Associated Enterprise. These findings of the TPO remain. Therefore, the inescapable conclusion to be drawn is that there was no evidence on record to prove rendition of services. In the circumstances, the ratio of the decisions of Bangalore Bench of the Tribunal in the cases of 3M India Ltd vs. Addl. CIT, (2016) 70 taxmann.com 231 and Volvo India (P) Ltd , 77 taxmann.com 207 and 89 taxmann.com 79 (supra) are squarely applicable to the facts of the present case. Wherein the Co-ordinate Bench of the Tribunal in the case of Volvo India (P) Ltd 77 Taxmann.com 207 observed at paras 10 to 12 are as under:-

”10. We heard the rival submissions and perused the material on record. The issue in the present appeal is whether the AO/TPO was justified in adopting the ALP at Rs.Nil in respect of management and support services fee paid by the appellant to its AE. Primarily, the TPO determined the ALP as Nil for the following reasons:
i. The assessee paid management fee through a single invoice, raised much after the closure of the financial year. ii. The assessee failed to produce any evidence regarding the expenditure incurred by the Associated Enterprise on behalf of the assessee.
iii. The Associated Enterprise, Volvo Truck Corporation also did not furnish any details of expenditure incurred by it in connection with the management fee received by it.
:- 13 -: ITA No.2012/2017.
iv. The assessee changed its stand many times during the course of the hearings that the payment is made towards marketing services and/ or brands, trademarks etc. 11. No doubt, now it is settled proposition of law that it is beyond scope
and powers of AO/TPO to question the necessity of incurring any
expenditure. The Hon’ble Delhi High Court in the case of CIT Vs. EKL
Appliance Ltd. 345 ITR 241 held that TPO cannot determine the ALP at
Nil by holding that there was no need to incur any expenditure. The above
decision was followed by the several coordinate benches of the Tribunal,
some by them are as follows:-
i. Dresser- Rand India (P) Supra ii. Ercission India P Ltd vs. DCIT, (2012) 25 taxmann.com 472 (Delhi) iii AWB India (P) Ltd vs. ACIT (IT Appeal No.4454 of 2011) Delhi-ITAT) AY 2007-2008. iv SC Enviro Agro India Ltd vs. Dy. CIT, (2013) 34
taxmann.com 127/143 ITD 95 (Mum. Tribunal).

v Abhishek Auto Industries Ltd. vs. Dy. CIT (2011) 9 taxmann.com 27 (Delhi).

vi McCann Erickson India (P) Ltd (supra).

vii DSM Anti-Infectives India Ltd vs. Add. CIT (2014) 50 taxmann.com 239 (Chd-Trib).

viii TNS India (P) Ltd (Supra). ix Atotech India Ltd vs. ACIT, (2014) 148 ITD 670/ 42 taxmann.com 468 (Delhi- Tribunal) x Nippon Leakless Talbros vs. ACIT, (IT Appeal No.5931 (Del of 2012) Asst. Year. 2008-09. xi Nippon Leakless Talbros vs. ACIT, (IT (TP)Appeal
No.475 (Del of 2015) Asst. Year. 2010-11.

xii Hughes Systique India (P) Ltd vs. ACIT (2013) 36 taxmann.com 41 (Delhi- Trib) xiii Knorr- Bremse India (P) Ltd vs. ACIT, (2013) 56 SOT 349/ 27 Taxmann.com 16 (Delhi -Tribunal) :- 14 -: ITA No.2012/2017.
xiv Thyssen Krupp Industries India (P) Ltd vs.ACIT, (2013) 55 SOT 497/ (2012) 27 Taxmann.com 334 (Mum- Tribunal) xv LG Polymers India (P) Ltd vs. Addl. CIT (2011) 48 SOT 269/ 15 taxmann.com 79 (Vishakhapatnam) 12. Thus in the light of the above legal position, the ALP of services of AE cannot be determined at Nil by questioning the necessity of benefits of expenditure incurred. But the matter does not end there. The onus lies on the assessee to prove that the services are actually rendered by the AE. But the assessee had failed to discharge this onus lying upon it despite being asked to do so by the TPO. The TPO had especially invited the assessee company to produce the proof in support of the services rendered by AE. The appellant only had tried to prove this by producing some correspondence which does not prove that the services are actually rendered. The failure by the assessee to discharge the onus can be presumed that the assessee had no evidence to establish that services of management support are rendered by its AE in consideration to payment of Rs.26,22,19,000/-. This presumption can be drawn even as per the provisions under section 86 of Indian Evidence Act. The submission that the TPO had impliedly accepted the rendition of services cannot be accepted as there was no finding given by the TPO that services are actually rendered. In fact, the TPO while summarizing this observation vide page No. 30 of his order vide column No.6 had specifically mentioned that the assessee had failed to prove that the services are actually rendered by AE. Furthermore the finding of the TPO that the invoice was raised much after the closure of the accounting year and the payment of management fee in nothing but siphoning of the profits from India with the intention of avoiding tax are serious enough to doubt the genuineness of transactions. The appellant had made no effort to controvert the findings of the TPO. Therefore, in our considered opinion the TPO/AO is justified in adopting ALP at Nil”.
The Co-ordinate Bench of the Tribunal in the case of Volvo India (P) Ltd , 89 Taxmann.com 79 held at para 20(5) as under;- ”20. (5)The other reason assigned by the TPO is that the appellant had
failed to substantiate the actual rendering of services by the AE to the
appellant. Undisputedly, the appellant had not made any efforts to
substantiate the rendering of services by its AE before the lower
authorities. This is evident from the fact that the appellant had filed an
application before us for admission of additional evidence in support of :- 15 -: ITA No.2012/2017.

rendition of services by the AE. We shall deal with the application for
admission of additional evidence in the later part of this order. But at
criterian consideration for determining the ALP at Rs. Nil. Needless to say
that when the services are not actually rendered in terms of the master
agreement, it is nothing but a sham transaction and the real purpose of the
transaction is something else than what is apparent. Now it is trite law that
in the absence of any evidence in support of rendering of services by the
AE, the TPO is justified in adopting the ALP of such management fee at ‘Nil’. Reliance in this regard is placed on the following decisions:- (i) Decision of the coordinate Bench of the Tribunal in the assessee’s own case
for the AY 2005-06 in Volvo India (P.) Ltd. v. CIT[2017] 77 taxmann.com 207
(Bang. – Trib.). The relevant paragraphs are extracted hereunder 11. No doubt, now it is settled proposition of law that it is beyond scope and powers of AO/TPO to question the necessity of incurring any expenditure. The Hon’ble Delhi High Court in the case of EKL Appliance Ltd. (supra) held that TPO cannot determine the ALP at Nil
by holding that there was no need to incur any expenditure. The
above decision was followed by the several coordinate benches
of the Tribunal, some by them are as follows i. Dresser-Rand India (P.) v. Addl. CIT [2011] 13 traxmann.com 82/[2012] 53 SOT 173 (Mum.) ii. Ericsson India (P.) Ltd. v. Dy. CIT[2012] 25 taxmann.com 472 (Delhi) iii. AWB India (P.) Ltd. v. ACIT [IT Appeal No. 4454 of 2011] (Delhi);
iv. SC Enviro Agro India Ltd. v. Dy. CIT[2013] 34 taxmann.com 127/143 ITD 195 (Mum. – Trib.) v. Abhishek Auto Industries Ltd. v. Dy. CIT[2011] 9 taxmann.com 27 (Delhi) vi. McCann Erickson India (P.) Ltd. v. Addl. CIT[2012] 24 taxmann.com 21 (Delhi) vii. DSM Anti-Infectives India Ltd. v. Addl. CIT[2014] 50 taxmann.com 239 (Chd. – Trib.) viii. TNS India (P.) Ltd. v. Asstt. CIT[2014] 48 taxmann.com 128/[2015] 152 ITD 123 (Hyd. – Trib.) :- 16 -: ITA No.2012/2017.

ix. Atotech India Ltd. v. Asstt. CIT[2014] 148 ITD 670/42 taxmann.com 468 (Delhi – Trib.) x. Nippon Leakless Talbros v. ACIT [IT Appeal No. 5931 (Delhi) of 2012] xi. Nippon Leakless Talbros v. ACIT [IT (TP) Appeal No. 475 (Delhi) of 2015] xii. Hughes Systique India (P.) Ltd. v. Asstt. CIT[2013] 36 taxmann.com 41 (Delhi – Trib.) xiii. Knorr-Bremse India (P.) Ltd. v. Asstt. CIT[2013] 56 SOT 349/[2012] 27 taxmann.com 16 (Delhi – Trib.) xiv. Thyssen Krupp Industries India (P.) Ltd. v. Asstt. CIT[2013] 55 SOT 497/[2012] 27 taxmann.com 334 (Mum. – Trib.) xv. LG Polymers India (P.) Ltd. v. Addl. CIT[2011] 48 SOT 269/15 taxmann.com 79 (Visakha).

12. Thus in the light of the above legal position, the ALP of services
of AE cannot be determined at Nil by questioning the necessity of
benefits of expenditure incurred. But the matter does not end there.
The onus lies on the assessee to prove that the services are actually
rendered by the AE. But the assessee had failed to discharge this
onus lying upon it despite being asked to do so by the TPO. The
TPO had especially invited the assessee company to produce the
proof in support of the services rendered by AE. The appellant only
had tried to prove this by producing some correspondence which
does not prove that the services are actually rendered. The failure
by the assessee to discharge the onus can be presumed that the
assessee had no evidence to establish that services of management
support are rendered by its AE in consideration to payment of Rs.
26,22,19,000/-. This presumption can be drawn even as per the
provisions under section 86 of Indian Evidence Act. The submission
that the TPO had impliedly accepted the rendition of services cannot
be accepted as there was no finding given by the TPO that services
are actually rendered. In fact, the TPO while summarizing this
observation vide page No. 30 of his order vide column No. 6 had
specifically mentioned that the assessee had failed to prove that the
services are actually rendered by AE. Furthermore the finding of the
TPO that the invoice was raised much after the closure of the
accounting year and the payment of management fee in nothing but
siphoning of the profits from India with the intention of avoiding tax
are serious enough to doubt the genuineness of transactions. The
appellant had made no effort to controvert the findings of the TPO.
Therefore, in our considered opinion the TPO/AO is justified in :- 17 -: ITA No.2012/2017.

adopting ALP at Nil.

The ratio of the decision of Hon’ble Bombay High Court in the case of Lever India Exports Ltd (supra) relied on by the ld. Authorised Representative does not come to the rescue for the reasons that even the Bangalore Benches of the Tribunal in the mentioned cases held that it is outside the scope of jurisdiction of the TPO to question the necessity, benefit of expenditure while determining the Arms Length Price of international transaction. But, once the assessee had failed to prove the rendition of services, it is nothing but sham transaction intended to shift the tax base of the country, falling within the jurisdiction of Chapter X of the Income Tax Act, 1961. Therefore, we hold that the TPO was justified in determining Arms Length Price of the management fee paid at `Nil.

8. The grounds of appeal raised contending that the management fee paid is closely linked with the main activity of the assessee cannot be accepted for the reason that there was no proof of rendition of service, thus the other grounds of appeal are dismissed. 9. The additional grounds of appeal filed by the assessee are also dealt by us supra. In the light of our finding that the absence of :- 18 -: ITA No.2012/2017.

proof of rendition of service renders the transaction sham, such sham transaction squarely fall within the domain of Chapter X of the Act. We do not find any merits in the additional grounds of appeal filed by the assessee. Hence the additional grounds of appeal filed by the assessee are dismissed.

10. In the result, the appeal filed by the assessee is dismissed. Order pronounced on 6th day of June, 2019, at Chennai. Sd/- Sd/- (एन.आर.एस. गणेशन) (इंटूर रामा राव) (N.R.S. GANESAN) (INTURI RAMA RAO)
या यक सद य/JUDICIAL MEMBER लेखा सद य/ACCOUNTANT MEMBER चे नई/Chennai .दनांक/Dated:6th June, 2019. KV आदे श क$ & त0ल1प अ2े1षत/Copy to: 1. अपीलाथ#/Appellant 3. आयकर आय3 ु त (अपील)/CIT(A) 5. 1वभागीय & त न7ध/DR 2. &’यथ#/Respondent 4. आयकर आय3 ु त/CIT 6. गाड फाईल/GF

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