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TMI Blog2015 (5) TMI 1251X X X X Extracts X X X X X X X X Extracts X X X X ..... x. The remaining common issues involved in these appeals are incidental to the main issue and they mainly relate to the determination of the quantum of income that is chargeable to tax in the hands of the assessee once the head of income is determined/decided. Since the issues involved in the case of all the fourteen assessee's as well as the facts relevant thereto are materially similar, we take the case of M/s. Goman Agro Farms Pvt. Ltd. for the purpose of narrating the facts in detail and considering and deciding the issues involved in the light thereof. 3. The assessee M/s. Goman Agro Farms Pvt. Ltd. is a company. It acquired lands in two pieces to the extent of seven acres in the financial year 2002-03 at Survey No. 194 Bachupalli Village, Ranga Reddy District. Thereafter, it incurred some expenditure on fencing, laying of roads, etc. in respect of the said land during the financial years 2002-03 to 2005-06. On 30.12.2005, the assessee company and thirteen other companies who had also owned lands adjacent to the land of the assessee company, entered into development agreement with M/s. Maytas Properties P. Ltd. As per the said development agreement, the developer agreed t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mination, he recorded his findings/observations in detail as under- "5.1 The family members of Sri B. Ramalinga Raju entered into real estate business In a very planned, systematic manner by floating the companies and acquisition of lands in the vicinity indicates that. As part of it, various companies under their own family members management were floated, lands were acquired In the vicinity. The dates of acquisition of lands in the same survey numbers around the same time period clearly indicates that, fourteen companies acquired land in such a way that, if pooled they will form a single piece of continuous land that can be used on a future date without any hindrances. (The topography of the site with survey numbers is enclosed with this assessment order as annexure) The above also Indicates that at the time of purchase of lands itself, the clear intention of companies and the individuals involved in it was to develop them on future date and sell them after making profit. 5.2 All the land owning companies pooled up their land facilitating a joint mega venture by a common agreement with developer i.e., M/s. Maytas Properties Pvt. Ltd. and planned their activities in such a man ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation of undivided share of land also, the pooled-up land was treated as "single piece of land". Even the sale proceeds received from various flat/bungalow buyers' were passed on to the land owning companies in the ratio of their land holding in the pooled up lands. 5.8 For all practical purposes such as sale of land, sharing of the sale proceeds etc., the activity was carried out as a single business venture only. The assessee-company and 13 other land owning 'companies with the help of the agreement with the developer carried out systematic, and planned activity of development of the area, construction of the apartments and bung lows, sale of the built-up area to various buyers, advertisement of the venture etc. 5.9 Though the lands were claimed to be agricultural lands, no agricultural activity was carried in these lands during any of the years. In fact, the land was subjected to various developmental activities such as, fencing, road laying etc., over a period of time. 5.10 On close observation of the financial statements of the assessee-company and 13 other companies which were land owners, it is clear that, in these cases, investment was not through the surplus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bsequent developmental activities by the developer, the land became easily salable at more profitability. d. As mentioned above, the land purchased was not sold as it was subsequently. There were certain Incidents i.e. various developmental activities and constructions thereon, were closely associated with the sale of land. e. The developmental activities, construction and systematic marketing are the usual activities associated with a regular business of construction of dwelling units. In the regular business of construction, the businessman will acquire the land, make it suitable for the developmental activities proposed,' construct dwelling units as per the requirements, market them, and sell to various buyers though its deployed staff. The activities of the assessee-company In the present case can also be closely compared with the regular activities in the business of construction of dwelling units. f. The purchase of the lands and sale of the dwelling units are repeated activities carried by the assessee company. It is clear from the following: Details of lands acquired during the F.Y. 2002-03: S. No. Location Survey No. Extent of land acquired Considera ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bours Sy. no 196 & 195 Nagavali GL Sy no.195p Himigiri GF Sy.No. 194p Himigiri GF 2 194 2.00 Sy. no 191 Nallamala A F Sy. no 196 Nagavali GL Sy no.195p Himigiri GF Sy.N o.194p Himigiri GF ...." 6. On the basis of the above findings, the Assessing Officer was of the view that the relevant transaction of the assessee company was not a simple case of disposing of a capital asset, but could definitely be viewed as plunge into the business activity which was nothing but an adventure in the nature of trade. According to him, the profit arising from such transaction therefore, was nothing but an adventure in the nature of trade. According to him, the profit arising from such transaction therefore, was required to be brought to tax under the head 'income from business or profession' and not capital gain. He therefore, afforded one more opportunity to the assessee to show cause as to why the income returned by it under the head capital gains should not be brought to tax under the head 'profits and gains of business or profession'. Availing the said opportunity, the following explanation was offered by the assessee vide its letter dated 20.10.2010. "...... We ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by him in the show cause notice. He held that a mere treatment given by the assessee company to the land as fixed asset in the Balance Sheet stating that it was an agricultural company was not conclusive in this regard and all the facts of the case since the inception of the case till the disposal of the asset were required to be considered to decide the issue. Accordingly, based on the various findings/observations recorded by him, the Assessing Officer held that the transactions carried out by the assessee company was nothing but an adventure in the nature of the trade and the profit arising out of such transactions was required to be brought to tax in its hands under the head 'profits and gains of business or profession' and not capital gains. Accordingly, after deducting the cost of land of Rs. 16,62,085 and allowable expenditure of Rs. 33,036 from the gross sale proceeds of Rs. 7,90,82,029, income of the assessee from the relevant transactions chargeable to tax under the head 'profits and gains of business or profession' was worked out by the Assessing Officer at Rs. 7,73,86,908 in the assessment completed under S.143(3) vide order dated 2.12.2010 for the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat transaction of purchase of land could not be assumed, without there being anything more, to be a venture in the nature of trade. Reliance was also placed by the assessee on the decision of the Hon'ble Madras High Court in the case of CIT V/s. Kastoori Estate P. Ltd. (62 ITR 578) in support of its contention that the best price realised on any investment made in capital asset, after developing the land would be construed as capital appreciation, which is chargeable to tax as capital gain and not as profit from an adventure in the nature of trade. It was contended on behalf of the assessee company that the entire income earned by it from the transfer of land as per the development agreement and further sale of flats and bungalows received as consideration for land was assessable in its hands under the head 'capital gains' and not as 'business income. 10. Without prejudice to its main contention and as an alternative, it was also submitted by the assessee company that the second leg of transaction i.e. sale of flats and bungalows could be considered as business income, consequent to the conversion of these assets into stock in trade in terms of S.45(2) of the Act. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... "income" of the appellant is "finalized" only after the developer Co. finalizes its accounts and allots 27% of the income to the land owning Cost is amount of 27% is in turn distributed among the land owning companies in the ratio in which they contributed land to the total project. It is interesting to note that even in the written submissions filed, the appellant had clearly stated that it was entitled to receive 27% of profit of the developer company as the share/due to the 14 land owning companies that had entered into the development agreement. Please see 1st item of submissions in the table at Para 5.. (d) The above practice of computing income is strange when the appellant claims that its income is taxable under the head capital gains. The appellant speaks of a development agreement and two stages of income which it classified as long term and short term capital gains and had even offered, as an alternate plea, to consider the receipt from second leg of transaction as business income consequent to conversion of capital asset as business asset. Yet, it does not consider the provisions of section 2(47)(v) and nor does it keep in view of the decisions Hon'ble Bombay High ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome/revenue/receipts of the Co. For the 14 land owning Cost, the net revenue (after costs) came to Rs. 97 crores (as against 101 crores in the table supra). To match this revenue, the construction cost was estimate at Rs. 62.95 crores. Both the Revenue (97.07 crores) an construction cost (Rs. 62.95 crores) were then apportioned to the 14 land owning Cost. The appellant's share came to 7.90 crores of revenue and 5.12 crores of cost of construction. This 5.12 crores was taken as long term capital gains and from this the cost of land (after indexation) was reduced to arrive at long term capital gains of Rs. 4.86 crores. From the net receipts of Rs. 7.65 crores tabled supra, this amount of Rs 4.86 crores was reduced and the balance Rs. 2.78 crores was taken as short term capital gains. (h) Thus, it may be seen that the receipts offered to tax a re NOT the "proceeds" on account of transfer of land through the development agreement and the subsequent sale proceeds of flats/villas that were sold during the year, and which come to appellant's share. Instead, a percentage of developer's income from this project (computed independently) was considered as appellant's income. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppellant clearly was looking for a part of these profits that accrue to the developer as well. (k) Secondly, by linking the profit to the developer's profit, which in turn can computed as percentage completion method, the appellant ensures that the incomes offered to tax are spread over a period and the tax payments are thus rolled over a span of 3 or 4 years (as long as the project takes to complete) instead of paying the bulk of tax liability at one go in the initial year when the land was transferred to the developer. (l) Thirdly, the profits offered to tax also would factor the costs and the land owner companies like appellant, end up lowering their profits by underwriting the developer's costs and cost escalate on through the mechanism of percentage completion method of computing the developer's profits. The appellant has no business or contractual obligation to do so. (m) The above becomes amply clear when we examine the appellant's own return for AY 2009-10 and its assessment, wherein there is substantial discussion about the downward revision of income of the developer company and the consequent revision in the 2% of profit being shared with the land o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ere linked to the profits of the developer even though it had no business to do so as per the development agreement. This is the real reason for the difference in the execution of this development agreement when compared to other development agreements." 12. On the basis of the reasons given above, the learned CIT(A) held that the intention behind the entire transaction on the part of the assessee was clearly established as that of adventure in the nature of trade and therefore, profit arising from the said transaction was chargeable to tax under the head 'profits and gains of business/profession' as rightly held by the Assessing Officer and not under the head 'capital gains' as claimed by the assessee. 13. As regards the alternative contention raised by the assessee relying on the provisions of S.45(2), the CIT(A) held that the very act of the assessee company of linking its income to the developer's income was sufficient to make it clear that from the beginning, there were no separate and distinct activities of first converting the fixed asset as stock in trade and then exploiting the same commercially. He also noted that the assessee company was neither tra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rcentage completion was reduced in assessment year 2009-10 as compared to assessment year 2008-09, resulting in reversal of income. 16. It was claimed by the assessee in this regard that the percentage completion for assessment year 2008-09 was tagged to the projected cost of Rs. 584,72,39,037, but owing to the increase in the budgeted cost for assessment year 2009-10, the percentage completion was reduced for assessment year 2009-10 in comparison with assessment year 2008-09. This claim of the assessee was not accepted by the Assessing Officer. According to him, the Revenue for the land owning companies based on the agreements for sale already entered into was fixed and the same could not be in the negative as claimed by the assessee. He also observed that design of the project remaining the same, there was no way that the budgeted cost to the same design could escalate to such an extent as claimed by the assessee within a period of one year. He held that the increase in the estimated budgeted cost as claimed in assessment year 2009-10 was itself flawed and the claim of the assessee of such escalation and calculation of less percentage completion based on such escalation could no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gal cases. The Special Auditor had also reported in his report that there was no need to refund any amount in the wake of cancellation of the agreements for sale, as sought by some customers by filing legal cases. It was also found by the Assessing Officer that the collection of amount from the customers was to the tune of 87% of the agreements for sale entered into by the developer company and there was no way by which the assessee company could be denied its share by the developer of these receipts. According to the Assessing Officer, there was thus no uncertainty in collection of the amounts already received from the customer and consequently, no reversal of income could justifiably be made on the basis of cancellation or legal cases. He also noted that such a cancellation in any case was neither agreed by the developer or even by the land owner companies including the assessee company. He therefore held that the reversal of income as claimed by the assessee company on account of cancellation or legal cases could not be accepted. 19. The Assessing Officer accordingly proceeded to recognize/determine the income of the assessee company on the basis of percentage completion in res ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpanies, a number of purchasers had tendered their applications for cancellation of agreements for sale and had also filed legal suits against the assessee as well as the developer. It was submitted that as a result of these cancellations/litigations, it was prudent not to recognize the revenue merely on the basis of agreement for sale unless the said agreements were registered or at least the possession of the flats/bungalows was handed over. It was contended that the cancellation/litigation created uncertainties in the generation of revenue and accordingly, the revenue recognised earlier on the basis of agreements for sale was revered due to cancellation/legal cases following the Accounting Standard 9 on revenue recognition. It was contended that such cancellations/legal cases were as good as sales returns in the trading activity and therefore, the corresponding sale earlier recognized was required to be reversed. It was submitted that the method of accounting was accordingly changed to recognise the income only when there was registration of agreements for sale or at least, where possession was complete and when there was no registration or possession, revenue was not recognised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fication of the said mistakes under S.154 was rejected by the Assessing Officer, a finding may be given on this aspect as well. 23. After considering the submissions made by the assessee and perusing the relevant material on record, the learned CIT(A) first decided the issue regarding the head of income under which the income determined by the Assessing Officer was chargeable to tax in the hands of the assessee. In this regard, he relied on the findings given by him on a similar issue as involved in the assessment year 2008-09 and following the same, he held that income in question was chargeable to tax in the hands of the assessee as business income and not capital gain. 24. As regards the change in the method of accounting as adopted by the assessee for recognizing the income for the assessment year under consideration i.e. assessment year 2009-10, the learned CIT(A) held that apart from the reasons given by the Assessing Officer, there were following fundamental reasons for not accepting the change in the method of accounting adopted by the assessee.- "(a) It is not a simple case of recognizing income based on only sale registrations actually done or possession handed over v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is. Further, it is not as if the entire consideration amount is being recognized. Only a part of it is being recognized by the developer by linking the revenue recognition of such receipts to percentage completion of work method. (e) The appellant had made much about the department's attachment proceedings u/s 281B and its stoppage of registrations. It is to be seen that the main developer/builder, who is also registering actual property and who is under actual fire and who is accountable to buyers and public is not using this reason to change its method recognizing revenue from AFSs. This is because of two (sic). The developer had already received substantial portion of consideration for sale (85% and above as mentioned in the assessment order) and was also doing the construction work and to that extent, even as per accounting norms, acknowledged that already a certain portion of the sale receipts had accrued to it as revenue and so should be offered to tax. The percentage of such receipts accrued to it was mathematically arrived at through percentage completion method, which is an accepted procedure as per Accounting Standards. The second reason is that the attachment by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ound himself in agreement with the stand of the assessee that the income determined by the Assessing Officer as a result of mistakes committed was in excess by Rs. 40,90,710. Accordingly, he directed the Assessing Officer to reduce the income of the assessee company by Rs. 40,90,710. Accordingly, the appeal filed by the assessee before him for assessment year 2009-10 was partly allowed by the learned CIT(A). Aggrieved by the order of the learned CIT(A) for the assessment year 2009-10, both the Revenue and the assessee have preferred their appeals before the Tribunal. 27. The main common issue involved in this case as raised in grounds No. 2 and 3 of the assessee's appeal for assessment year 2008-09 and grounds No. 3 and 4 of the assessee's appeal for assessment year 2009-10 relates to the determination of the head of income under which the income arising to the assessee from the transfer of land as a result of development agreement and subsequent sale of flats and bungalows received as consideration for the sale of land is chargeable to tax in its hands, while the incidental issue which is directly linked with this main issue relating to the assessee's alternative clai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he land for the purpose of business of real estate development is baseless, as the developer company was incorporated only in the year 2005 whereas lands were purchased by the land owing companies in the year 2002. He contended that even the various events enumerated and relied upon by the Assessing Officer to hold that the entire activity was business activities have happened during the post-development agreement period and the said events, at the most, can only show that the activities carried on by the assessee company, after the execution of development agreement are in the nature of business activities. He contended that in this scenario, the assessee company can be said to have converted their agricultural land held as capital asset into stock in trade on the date of development agreement and the alternative contention of the assessee company will come into play, at this juncture, so that the income earned by the assessee company can proportionately be brought to tax partly as capital gains and partly as business income. 29. As regards the applicability of the provisions of S.45(2) to determine the income of the assessee company, the learned counsel for the assessee submitte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the area to the land owner 1,10,70,00,000 Less: Indexed Cost of 73%of the land 7,42,34,336x73% 5,41,91,065 Long Term Capital Gain 1,05,28,08,935 2 Consideration of sale of proportionate constructed area - Ac 37.79 out of Ac 85.93 97,07,88,393 Calculation of cost price: 3 Proportionate cost of constructed area 110,70,00,000x37.79/85.93 48,68,32,654 Land Cost 2,00,43,271 (7,42,34,386-5,41,91 ,065)x37.79/85.93 88,14,561 49,56,47,215 Proportionate Business Income 47,51,41,178 105,28,08, 935x37. 79/85. 93 46,30,00,694 Total 93,81,41,872 ......" 30. The learned Departmental Representative, on the other hand, relied on the orders of the authorities below in support of the revenue's case that the intention of the assessee company right from the beginning was to acquire the land for the purpose of real estate development and the same, therefore, constituted an adventure in the nature of trade. He contended that the entire income of the assessee company from th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... various events to arrive at a conclusion that the intention of the assessee companies right from the beginning was to acquire and hold the lands as stock in trade for the purpose of carrying on the business of real estate development. However, most of the events relied upon by the authorities below are subsequent events occurring after the date of development agreement and the same in our opinion, cannot be relied upon to come to the conclusion that the intention of the assessee company right from the beginning was to purchase the land as stock in trade for carrying on real estate development business. 33. In order to ascertain whether it is a case of capital asset or stock in trade, the intention at the time of acquisition thereof is material and the subsequent events cannot change the nature of the asset, which is to be determined on the basis of the intention of the assessee at the time of acquisition. In the present case, the intention of the assessee company as gathered from the main object for which it was established and the accounting treatment given in the books of account was to acquire the lands as capital assets, in order to carry on agricultural operations and the sub ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is 70% of the total land, as the balance 30% of the total land area is retained by him, being the undivided share in the land attributable to the 30% built up area to which he is entitled to receive form the developer as consideration. The purpose or intention to accept sale consideration in the form of built up area on the part of the land owner is either to replace one capital asset, i.e. land by another capital asset, i.e. built up area, or to sell the built up area to third parties in order to make more profit. In case of former, the new capital asset is retained and held by the land owner either for his own use or as long term investment and the sale thereof results in capital gains, long term or short term depending on the period of holding. In the latter case, the land owner practically becomes dealer in built up area, having an intention to make more profit as a result of increase in the market rate on sale of the built up area. In the process, he also indirectly undertakes the risk associated with execution and completion of project as well as fluctuation in market rate of units. In such cases, the built up area takes the form of stock in trade and the excess profit earned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly with other 13 land owning companies. As a single business venture for all practical purposes, verification of the sale deed executed in favour of various flat/bungalow buyers also indicated that for the registration of undivided share of land, the entire pooled land of about 85 acres was taken as single piece of land and the sale proceeds received from various flat/bungalow buyers was passed to the land owning companies in the ratio of their land holdings. 35. The position that emerges in the case of the assessee company as a result of development agreement as well as subsequent events enumerated above is similar to the one as envisaged in S.45(2)of the Act, and we, therefore, find merit in the alternative contention of the learned counsel for the assessee that the income arising from transfer of land by way of development agreement and subsequent sale of flats and bungalows received as sale consideration for transfer of land is required to be computed as per the provisions of S.45(2). The question, however, is how to give effect to the provisions of S.45(2) in the facts and circumstances of the case, so as to determine the income of the assessee chargeable to tax under the hea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... consideration realised or accruing on transfer of the capital asst. In the present case, 27% of the built up area of the project was received by the assessee as consideration for transfer of 73% of the land area, and therefore, cost of construction of this 27% area can reasonably be taken as the fair market value of 73% of the land area on the date of conversion. As submitted by the learned counsel for the assessee in this regard, the total cost of construction of the project was initially estimated by the developer at Rs. 410 crores for the total built up area of 26.94 lakhs sq. ft. which gives the rate of cost of construction at around Rs. 1,500 per sq. ft. Applying the said rate, the cost of construction of the 27% of the total built up area of the project comes to around Rs. 110 crores and the same, in our opinion, can reasonably be taken as fair market value of the 73% of the land area and accordingly, fair market value of the total land can be worked out on pro-rata basis, for adopting the same as full value of the consideration received or accruing as a result of the transfer of the capital asset for the purposes of S.48 in order to compute the capital gains. From the value ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CG @ 1500 per sq. ft. 15,00,000 Profit @ 857 per sq. ft.(3000-2143) 8,57,000 II Year 1000 sq. ft. @ 3500 per sq. ft. 35,00,000 LTCG @ 1500 per sq. ft. 15,00,000 Profit @ 1357 per sq. ft.(3500-2143) 13,57,000 III Year 1000 sq. ft. @ 4000 per sq. ft. 40,00,000 LTCG @ 1500 per sq. ft 15,00,000 Profit @ 1857 per sq. ft.(4000-2143 18,57,000 OVERALL POSITION Total Sales 1,05,00,000 LESS: Indexed Cost of Acquisition 19,30,000 Total Profits 85,70,000 -taxable as capital gain 45,00,000 - taxable as business income 40,70,000 39. In view of the above discussion, we direct the Assessing Officer to compute the income of the assessee form transfer of land held by the assessee company as capital asset by way of development agreement and subsequent sale of flats and bungalows received as consideration for such transfer which took the character of stock in trade on conversion in the manner and as per the method specified above, relying on the provisions of S.45(2). We accordingly partly allow grounds No. 2 and 3 of the assessee's appeal for assessment year 2008-09 and grounds No. 3 and 4 of the assessee's appeal for assessment year 2009-10. Ground No. 4 of the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o assess the ultimate collection with reasonable certainty is lacking at the time of raising any claim, Revenue recognition is postponed to the extent of uncertainty involved. In such cases, it may be appropriate to recognise revenue only when it is reasonably certain that the ultimate collection will be made. When the uncertainty relating to collectabilty arises subsequent to the time of sale, it is more appropriate to make a separate provision to reflect the uncertainty. It is also provided that when recognition of revenue is postponed due to the effect of uncertainties, it is considered as revenue of the period in which it is properly recognised. 37. In the present case, as a result of extra-ordinary events witnessed by the Satyam group of companies to which the assessee company belonged in the month of January, 2009, there was uncertainty with regard to the completion of project by the assessee company and delivery of units booked. Keeping in view this uncertainty, some of the agreement holders tendered applications for cancellation of the units booked and demanded refund of the advances paid. Some of the agreement holders also filed cases against the assessee company for can ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lready recognised earlier on the basis of cancellations/legal cases." Following our decision rendered in the case of M/s. Hill County Properties Ltd. (supra), we direct the Assessing Officer to adopt the date of registration of agreement or possession of units as the date of sale of units for the purpose of computing the income of the assessee as per the provisions of section 45(2) of the Act. 41. The issues raised in ground No. 5 of the assessee's appeal for assessment year 2008-09 and grounds No. 8 and 9 of the assessee's appeal for assessment year 2009-10 relating to the levy of interest under S.234A and S.234B are consequential and the Assessing Officer is accordingly directed to allow consequential relief to the assessee on this issue. 42. As regards the appeals filed by the other thirteen assessee companies, it is observed that all the issues involved therein as well as material facts relevant thereto are similar to the case of M/s. Goman Agro Farms Pvt. Ltd., except that in the case of two companies, viz. M/s. Konar Greenlands Pvt. Ltd. and M/s. Swrnamukhi Greenfields Pvt. Ltd., there are no appeals filed by the assessee for assessment year 2008-09. We therefore, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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