9911796707
TMI Blog2019 (4) TMI 1867X X X X Extracts X X X X X X X X Extracts X X X X ..... y the Dispute Resolution Panel (DRP) u/s 144C of the Act is ab initio bad in law and therefore the order passed by the Addl. CIT u/s 143(3) pursuant to the said order of the DRP is also bad in law and should be annulled. Without prejudice to the generality of the above ground, the DRP erred in passing the impugned order u/s 1 44C in violation of the provisions of that section and further erred in not giving the Appellant a reasonable opportunityof being heard in the matter and in passing the impugned order without fully appreciating the submissions made and the material placed before it during the course of the hearing. 2. Expenditure debited to Profit and loss account Rs. 15,33,86,228/- On the facts and in the circumstances of the case and in law the Appellant contends that the learned Addl. C.I.T. erred in proposing and the DRP erred in confirming disallowance of the following sums treating the same as capital expenditure and also further erred in coining to conclusion that these expenses were not incurred for the purposes of the business of the Appellant: No Particulars Amount Amount A Professional Fess - FES Division - 1 China Project Expenses 4,8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the circumstances of the case and in law the Appellant contends that the learned Addl C.I.T. erred in proposing and the DRP erred in confirming treatment of the provision for warranties made as at 31-03-2009 as inadmissible expenditure on the ground that this provision is in the nature of contingent liability and hence not an ascertained liability. The learned Addl C.I.T/DRP erred in coming to the conclusion that the Appellant had been unable to pass the tests prescribed by the Supreme Court in the case of Rotork India Ltd. The findings of the learned Addl C.I.T/DRP that in view of certain alleged infirmities and deficiencies the liability for warranty was not an ascertained liability, are perverse and, being contrary to facts are bad in law. The Claim of the Appellant be allowed 5. Disallowance U/s.40A(9) Rs. 2,59.650 representing the actual expenses incurred and Rs. 12,00,000/- being contribution to Mahindra Academy a) On the facts and in the circumstances of the case and in law the Appellant contends that the learned Addl C.I.T. erred in proposing and the DRP erred in confirming disallowance of deduction of Rs. 2,59,650/-, being the actual expenditure incurred during the y ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... C.I.T. ought to have treated the investment in trust as Taxable investment since it is a private trust and income earned therefrom is taxable in the hand of the Trust. 8. Adjustment u/s 92CA(3) to Arm's Length Price of international transaction adjustment of Rs. 4,62,38,658/- On the facts and in the circumstances of the case and in law. the learned Addl C.I.T./TPO erred in proposing and the DRP erred in confirming addition to the income of the Appellant a sum of Rs. 1,25,40,000 being adjustment in respect of corporate Guarantee and Rs. 3,36,98,658 by way of notional interest on the basis of Transfer Pricing Officer's order u/s 92CA on account of the determination of Arm's Length Price (ALP) on international transactions with an Associated Enterprise rejecting the contention of the Appellant that the same was not warranted on facts and in law. The order passed by the learned TPO u/s 92CA is contrary to the provisions of the Act dealing with determination of ALP. Addition be deleted. Without prejudice to the aforesaid ground, the learned Addl C.I.T. / DRP erred in confirming addition to total income on account of guarantee fees at 3%. If at all any adjustment was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erence to expenditure of Rs. 165,13,63,447incurred on in-house Scientific Expenditure rejecting the contention of the Appellant that it was entitled to the said deduction and also that non-receipt of form 3CL from DSIR was not determinative of the issue. The learned Addl C.I.T/DRP ought to have appreciated that submission of report in form 3CL was neither the obligation of the Appellant nor within its control and therefore cannot be a ground for sustaining disallowance. The learned Addl. C1T be directed to allow the claim of the Appellant. 12. Disallowance u/s. 40a(ia) of Dealer Incentive Rs. 128,09.72,000/- and Service Coupon Rs. 38,92,51,000/- On the facts and in the circumstances of the case and in law the learned Addl C.I.T. erred in proposing and the DRP erred in confirming disallowance u/s 40a(ia) of Dealer Incentive Rs. 128,09,72,000 & Service Coupon 38,92,51.000 aggregating to Rs. 167,02,23,000 rejecting Appellant's contention that tax was not deductible on dealer incentive & service coupon under Section 19411 & 194C respectively. In any event the learned Addl. C.I.T./DRP ought not to have, made disallowance u/s 40a(ia) in those cases where the payees had filed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in proposing and the DRP erred in not allowing deduction for difference in exchange of Rs. 251.63 crores as claimed by the Appellant in the computation of income. The Learned Addl CIT/DRP ought to have accepted the contention that there is no requirement in the Law to capitalize the difference in exchange to the capital assets acquired by the Appellant as also the loss arising due to difference in exchange was not contingent in nature and therefore was allowable as revenue deduction while computing the taxable income of the Appellant. Without prejudice to the aforesaid contention that the difference in exchange was allowable as revenue deduction, the Learned Addl CIT/DRP ought to have allowed depreciation on such difference in exchange as capitalized in the books of accounts. 17. Disallowance of deduction under section 80 1C - Rudrapur Unit On the facts and in the circumstances of the case and in law the Appellant objects to the arbitrary methodology of calculation of profits derived from the Appellant's Rudrapur Unit directed by the DRP and applied by Learned Addl CIT which has resulted in restricting deduction u/s. 801C to Rs. 99,76,03,710 as against Rs. 359,67,62,8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng that 'adjustment to closing stock does not warrant any corresponding adjustment to opening stock of the same year' and further that 'adjustment in purchases is to be allowed only to the extent of unutilized CEXVAT credit available at the end of the year for raw material still in the closing stock of the assessee', both rulings being contrary to among others, the scheme of the Act itself. Without prejudice to the aforesaid contention the learned Addl. CIT erred in not allowing deduction for Rs. 53.60 crore being the amount of unutilized CKXVAT credit as on 31/3/2008 brought to tax in AY 2008-09 Addition of Rs. 22.95 crore made by the learned Addl. CIT be deleted and deduction of Rs. 17.10 crore claimed by the Appellant be allowed. 20. Adjustment to business income and income from other sources Rs. 84.10 crores The DRP erred in directing learned Adl. CIT to assess business income of Rs. 84.10 crores as income from other sources which direction is contrary to facts and the position in law. The learned Addl. CIT be directed to accept the head of income as shown in the Return of income in respect of the said income of Rs. 84.10 crores. Your appellant rese ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ital assets that have come into existence on incurring the expenditure and the definite cost of acquisition of such capital asset, to the Assessing Officer within 7 days of the receipt of the directions so as to enable him to quantify the depreciation allowable correctly. Further, ITAT on similar issue in the assessment year 2006-07 and 2007-08 has decided the matter in the favour of revenue. Accordingly, we hold the expenditure to be capital and leave the allowability of depreciation to results of the verification by the Assessing Officer . Since, issue is covered in favour of the revenue, we do not find any infirmity in the action of the DRP, accordingly, we uphold the same. Ground No.3:- Disallowance of Pro-rata Premium of Rs. 74,11,35,248/- payable on redemption of Foreign Currency Convertible bonds. 7. At the outset on this issue, learned Counsel of the assessee submitted that ITAT has decided the similar issue in favour of the assessee in A.Y.2006-07 and 2007-08. He submitted that the DRP has also recognised this fact, however, they have noted that matter has not attained finality and they have accordingly upheld the disallowance. Hence, learned Counsel of the assessee ple ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nce. 4.12. The assessee has also not been able to establish the stability and certainty of facts and the principles applied in its method of calculation of the provision over various years. We find that in Rotork India Ltd. case of SC, the warranty provision was held as an ascertained liability since the provision was on a scientific basis. However, on facts as already explained in this case, it cannot be said that the provision has any scientific basis. The estimate is not reasonable rather it is arbitrary and skewed with actuals. Hence, the SC case in Rotork Controls does not apply. DRP in FY 2008-09 has also held similarly. We also agree to the same. Hence objection of the assessee on this ground is rejected. 4.13. Furthermore as evident from the table at para 4.13 ante, the actual utilization over the years is much less than the provision made. Therefore, it is evident that the assessee is making excessive provision of warranty. Though, the AO has allowed the deduction on actual utilization basis in this AY, it is not known whether in earlier AY's also the deduction has been allowed on actual utilization basis only. The closing balance in the warranty provision account ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ively viewed as one and not on a vehicle by vehicle basis as intended by the DRP In view of facts noted by the DRP the issue should not be referred back to the AO unlike in the earlier years." 12. Upon careful consideration, we find that ITAT in assessee's own case in earlier years remitted the issue to the file of the Assessing Officer and directed that the issue be decided in accordance with Hon'ble Supreme Court decision in the case of Rotork Controls Ltd.,(supra). In our considered opinion, we should follow the principles of precedents and the earlier direction of ITAT in assessee's own case. It is not at all the case that the decision of ITAT consistently in assessee's own case has been reversed by the Hon'ble Supreme Court. That in earlier years, pursuant to the ITAT direction AO has passed perfunctory cannot be a ground for us to deviate from following precedents as above. Accordingly, following precedents as above, we remit the issue to the file of the Assessing Officer to examine the issue by following the decision of Apex Court in the case of Rotork Controls Ltd., (supra.) Ground No.5 : Disallowance u/s.40A(9) of Rs. 2,59,650/- and Rs. 12,00,000/- Main contribution to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ected by the Assessing Officer. The Assessing Officer has applied rule 8D and accordingly computed the disallowance and DRP has confirmed the same. Now, the ld. Counsel of the assessee has made following submissions before us. There is no disallowance u/r 8D(i); As regards disallowance under Rule 8D(ii) & (iii) the AO may be directed to re-compute the disallowance towards other expenditure after reducing investment on which no exempt income has been received {Reliance Industries Limited [TS-259-ITAT-2017(Mum) Reliance is also placed on following case laws: * Bombay High Court in the case of CIT V/s HDFC BANK LTD. [2014] 366 ITR 505 (Bom) and Mumbai ITAT in the case of Yes Bank Ltd. v. ACIT (2016) 46 ITR 317 (Mum.)(Trib.) has held that no disallowance under Rule 8D(2)(i) and (ii) is required to be made, as the non- interest bearing funds available with the assessee are more than the amount of investment which generate tax free income. In Appellant's case tax- free investments as on 31.03.2009 is Rs. 5221.61 crores, as against shareholders' funds of Rs. 5249.53 crores. Therefore, in view Bombay High Court decision, no disallowance should be made under Rule 8D(2)(ii).( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n this issue following aforesaid precedent. Ground No.10: Addition u/s.40(a)(ia) in respect of year end provision of Rs. 18,37,00,791/- 23. On this issue we note that ITAT has allowed the assessee's claim in A.Yrs. 2006-07, 2007-08 and 2008-09. The DRP has also noted the same but has confirmed the AO's order by observing that matter has not reached its finality. Respectfully following the order of ITAT in assessee's own case, we set aside the order of the authorities below and decide in favour of the assessee. Ground No.11: Weighted deduction u/s 35(2AB) with reference to expenditure of Rs. 165,13,63,447/- incurred on scientific expenditure: 24. On this issue the disallowance was made on the ground that form 3CL has not been furnished. We note that in earlier year i.e., for A.Y.2008-09, Tribunal has noted the submission from assessee that once the R & D facilities are approved and DSIR has not rejected the application submitted by the assessee, it could be presumed that the application has been accepted. Further that failure on the part of DSIR to confirm the authorities in time cannot be reason for taking back deduction to the assessee. Noting the above and following judicia ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on, the same has been restored back to the file of the Assessing Officer. Thus, consistent with the view taken therein, we also restore this issue back to the file of the Assessing Officer for fresh adjudication and also to consider the case law as relied upon by the learned Counsel for the assessee. Thus, ground no.14, is partly allowed for statistical purposes." 28. Accordingly following the precedents from ITAT in assessee's own case, we decide the issue of dealer incentives in favour of the assessee and the issue of disallowance on service coupons is remitted to the file of the Assessing Officer in accordance with the direction of ITAT in earlier years. Ground No.13:Disallowance of Depreciation of Rs. 18,34,496/- on intangible asset:- 29. On this issue, the ld. Counsel of the assessee fairly agreed that ITAT has disallowed assessee's claim in A.Y.2007-08 and 2008-09. Respectfully following the decision referred as above, we uphold the order of the Assessing Officer on this issue. Ground No.14: Octroi Incentive of Rs. 4489 lakhs treated as revenue receipt and not capital receipt:- 30. On this issue, ld. Counsel of the assessee submits that ITAT has rejected the assessee's ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essed as business income and not from the income from house property." 34. Respectfully following the precedent, we decide the issue in favour of assessee. Ground No.16: Disallowance of difference in exchange loss claimed as revenue expenditure Rs. 251,63,00,000/- 35. Brief facts of the case are that during the year, the assessee claimed a deduction of Rs. 251.63 crores out of computation of income on account of difference in exchange arising out of repayment of foreign currency loans / revaluation of foreign currency. The loans have not been repaid during the year. The loans are said to have been utilized towards purchase of fixed assets as well as for certain current assets. The assessee has given details of foreign exchange fluctuation expenses and application of the foreign exchange loans as under:- Particulars Profit & Loss F.2009 Rs. In lakhs Capital Expenditure tfsT In lakhs f orex Reserve Rs. In lakhs t Utilisation of forex reserve Zero Coupon Foreign Currency Convertible bonds loan 19507 16496" 3011 Investment in Mahindra Gears International Limited, Mauritius and Mahindra Overseas Investment Company (Mauritius)Limited. HSBC Loan 5181 4904 277 Investment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee it is seen that the assessee has secured foreign currency loan from banks Rs. 378 crores (302 crores in preceding year) and unsecured foreign currency loans on FCCB and bank is Rs. 1587 crores (1293 crores in preceding year). The secured loan includes Rs. 253 crore short term loans. From the schedule of fixed assets in the balance sheet it is seen that the assessee has added fixed assets Rs. 1291 crore during the year. The capital WIP on 31st March is 646.73 crores whereas in the preceding year it was 546.45 crores. 21.6. The addition to the assets have been made under various heads including land, building, plant and machinery, furniture fittings and vehicles, development and software expenditure. The assessee pas not furnished details of foreign exchange loss attributable to various items of capital assets and WIP. In absence of details of application of foreign exchange loans to different items of capital assets it is not possible to attribute such loss to any item of capital asset as cost of acquisition of such asset and allow depreciation. From application of loan as given in the table, it is evident that loan has been applied also for investment in equity of Foreign ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unting principles laid down in Accounting Standards notified by the ICAI would govern. In Woodward Governor India P Ltd the SC has held (para 17) that Accounting Standard 11 is mandatory. The AS dealt with by the Court was the one ' revised in 1994 para 10 of which provided for adjustment of carrying amount of fixed assets for exchange differences; On the other hand, Para 13 of if AS 11 revised in 2003 provides that exchange differences arising on settlement or revaluation of monetary items should be treated as income or expense of the relevant period. Similarly, Income Computation and Disclosure Standards notified under s 145(2) we-f AY 2017-18 provide in Para 5 (1) that expenses differences should be recognized as income or expense in the relevant year In his submissions before the Delhi High Court in the case of Chamber of Tax Consultants wherein the constitutional validity of ICDS was challenged the Additional Solicitor General. Appearing on hehalf of the Union of India submitted that the changes brought about (by ICDS) are only aimed at bringing uniformity and clarity in the computation of income. Therefore in terms of AS 11 (revised 2003) and ICDS VI, all exchan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the observations of the DRP in this regards are in accordance with the above said expeditions. In this view of the matter, we do not find any infirmity in the order of DRP, hence, we are upholding the same. Ground No.17: Deduction u/s.80IC of Rs. 359,67,62,865/- in respect of Rudrapur Unit which was restricted to gross total income 43. Brief facts of this issue are that the assessee claimed a deduction of Rs. 102.42 crores under Section 80IC of the Act in the original return but subsequently reduced the claim to Rs. 86.44 crores in the revised return. Thereafter the assessee submitted the computation of total income during the assessment proceeding and has claimed a deduction of Rs. 359.67 crores u/s 80IC. It submitted that the amount eligible for claimed enhanced deduction of Rs. 359.67 crores but the actual claim was restricted to available business income after excluding the long term capital gains. The assessee before the AO furnished auditor's report in Form 10CCB n 10.01.2013 together with unit wise computation of profit eligible for deduction u/s 80IC, profit and loss account of Rudrapur unit, balance sheet of Rudrapur unit, alongwith relevant schedules and Annexur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re the DRP and submitted various documents. After examining the same, ld. DRP has held as under:- 22.10. From the above documents furnished by the assessee it is seen that the assessee undertook a project for expansion of its industrial undertaking at Rudrapur in Financial year 2003-04 which is evident from various documents filed as above. The expansion project is said to be completed on 20th December 2004 as per 10CCB report. The gross value of plant and machinery as on 31/03/2005 is Rs. 1456 lakhs. Thus there is an addition of exceeding 1228 lakhs in plant and machinery during FY 2004-05. 22.11. On the basis of above documents it is evident that the assessee has undertaken expansion of its tractor manufacturing unit at Udhamsingh Nagar and such expansion has been completed in FY 2004-05. Since the addition in plant and machinery for such expansion is exceeding 50% of the gross value of plant and machinery before such expansion was undertaken, the expansion amounts to'' substantial expansion" as defined in Clause (ix) of Section 80IC(8) of the Act. 22.12. Further it is declared in Form 10CCB that plant and machinery valued Rs. 135.31 lakhs have been transferred to R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... OST PROFIT QTY SP TOT COST PROFIT QTY SP TOT COST PROFIT 265 Dl 18,091 7,106 244,427 212,871 31,556 275 Dl 35,224 11,038 267,119 218,247 48,772 81 249,802 207,425 42,377 295 Dl 475 Dl 1,092 226,850 50,990 6,988 279,539 223,805 55,734 5984 280,516 237,458 43,058 575 Dl F2004 RDPR NGPR KNDV QTY SP TOT COST PROFIT QTY SP TOT COST PROFIT QTY SP TOT COST PROFIT 265 Dl 8,277 312,678 258,556 54,123 5,429 300,951 268,702 32,248 275 Dl 15,525 334,659 265,721 68,938 765 347,012 279,325 67,687 28 300,304 256,055 44,248 295 Dl 623 355,348 305,371 49,977 7,222 345,543 314,390 31,152 475 Dl 13,090 358,311 276,026 82,285 4,433 361,081 290,896 70,186 1,324 377,730 316,371 61,3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the DRP under cover of letter dated 20/11/2013 wherein all these aspects have been exhaustively dealt with. * As regards in per tractor sales price at different plants noticed by you it may be clarified that under each model there are various variants as well whose prices differ from other variants in that model category. Thus 265DI model has different variants such TR265B, TR265NBP, TR265NST, TR265NSTCM. All India prices of the same variant are almost the same for all plant locations. 22.18. The above submission of the assessee has been considered carefully. There are inherent contradictions and the assessee's submission that all India prices of same variant of 3 given model are the same for all plant locations is found to be inconsistent with the above data of sale prices submitted. 22.19. Regarding the variation in cost of production of traitors at Nagpur and Rudrapur, the assessee has explained that labour cost at Nagpur unit is Rs. 11879 per tractor whereas for Rudrapur Unit -unit labour cost is Rs. 3774. In this manner the assessee has tried to explain cost differential of about Rs. 8000 per tractor. However the labour cost at Rudrapur is only about 40% of labour co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ocable to Rudrapur unit. It has been submitted that no interest expenses is allocable to Rudrapur unit. No allocation of other expenses claimed in t not debited in P&L account has been made to Rudrapur Unit. 22.23. On the above facts, it is evident that the profits of Rudrapur unit are inflated due to variation in cost, variation in sale price and defective allocation of head office expenses, defective allocation of R & D expenses, non-allocation of other expenses and deduction claimed in computation, interunit transfers to Rudrapur unit not being at market price etc. Therefore the unit wise accounts prepared by the assessee as produced before the AO (though not produced before us) are rejected as they do not represent true and fair results of the different units of the assessee company. 22.24. However the profit of Rudrapur unit is allowable as deduction under section 80-IC. The AO has computed the profit of Rudrapur unit in proportion to turnover. In absence of reliable unit wise accounts of; the assessee company, this basis is reasonable. Accordingly, the AO is directed to determine the business profit of Rudrapur unit by allocating the business income assessed as per order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... penses have rightly been not allocated to Rudrapur Unit as they are not directly or indirectly related to the Rudrapur Unit :- 1. Difference in exchange relatable to loan debited to fixed assets. 2. Donation 3. Employee cost liability on account of ESOP 4. Expenditure incurred for employee welfare 5. Provision for premium on redemption of FCCB 6. Deduction u/s.35 DDA 54. It has further been submitted the claim is duly supported by an audit report in form 10CCB. All expenses have been captured from trial balance at Rudrapur. Farm equipment sector is also subject to cost audit report which is on record by AO. All figures are duly reconciled with the cost audit report. 55. We have carefully considered the submissions and perused the records. We find that the dispute resolution panel has given several reasons for holding that profit of the Rudrapur unit is inflated to claim higher deductions. Per contra learned Counsel of the assessee has given elaborate reasons submitting that these are not sustainable. We find that as regards the objection of the Dispute Admisison Panel regarding absence of detail of employee cost of Nagpur Unit and Rudrapur unit, we find that assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee in Haridwar Unit, profit for which are otherwise eligible for deduction u/s.80IC. The ld. Counsel of the assessee has submitted as under:- "Hon ITAT has directed AO to quantify losses of the unit under section 80-IC in AY 2006-07 (page 64 para 21) being the first year of the claim and followed in AY 2008-09 (page no.31-32 para 101) While giving effect to ITAT orders for AY 2006-07 & 2007-08 & 2008-09 AO has passed orders quantifying such losses." In accordance with the above, we direct the AO accordingly. Ground No.19: Adjustment to closing stock -145A-adjustment - Rs. 22,95,00,000/- 62. On this issue, it is the contention of the ld. Counsel of the assessee that in earlier years ITAT had remitted the matter to the AO for giving proper effect to stocks, purchases and sales and arrive at definite conclusion. It is claimed by the ld. Counsel of the assessee that A.Yrs. 2006-07, 2007-08 and 2008-09, the AO has given effect to the order of the ITAT and has concluded that no addition is warranted u/s.145A. Furthermore, assessee's Counsel placed reliance upon Hon'ble Bombay High Court in the case of Diamond Dye Chem Ltd., We find that ITAT for A.Y.2008-09 has given following ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the interest income and business of the assessee. Surplus fund not immediately required in business is invested to earn interest. Admittedly, money lending is not the business of assessee. On the facts in this case, interest income is from FDs and ICDs etc. wherein surplus funds have been deployed temporarily. Mumbai High Court in case of Swani Spices P. Ltd. 332 ITR 288 (Bom) has held that interest earned from surplus funds kept as deposits is assessable as income from other sources. Hence applying the SC decision in Liberty India (supra) and also Pandian Chemicals 262 ITR 278 and Bombay HC in Swani Spices (supra) it is held that interest income in this case is assessable under head 'Income from Other Sources'. Accordingly, AO is directed to assess interest income of the assessee and dividend-from foreign subsidiaries (if any) under the head 'Income from Other Sources'." 65. The submission of ld. Counsel of the assessee on this issue is as under:- "Interest earned on temporary deployment of surplus business funds hence assessable under the head Business income as in the past Case law relied upon by the DRP (Swani Spices 332 ITR 268)(Bom) was rendered in the cont ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
