9911796707
TMI Blog2024 (5) TMI 440X X X X Extracts X X X X X X X X Extracts X X X X ..... rica are in its initial years. Since both these AEs are in their initial years of operations, their respective profitability will be lower than the comparable companies in their respective region, since the AEs have to incur huge expenditure on marketing of products, while the comparable companies are established players. As noticed by us earlier, so far the assessee herein is concerned and qua the transfer pricing provisions, what is required to be seen is whether the price realized on export of products to their AEs is at arms length or not. The fact the profitability of AEs is lower than the profitability of comparable companies, would also show that the assessee has not under invoiced the sales. In the instant case, the details extracted in the table above matches with the above said criteria. Since the comparable companies selected in the respective Geographical locations are established players, the profit ratio of comparable companies are to required to be considered only to show that the profit ratio of the assessee was lower than their profit ratio. In this view of the matter, the difference in accounting period may not be that much relevant. As noticed that the above said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the assessee has furnished the Balance-sheet of Buddy I unit , Solan unit (Baddi-II) and Sikkim unit. On a Perusal of the balance-sheets of these three units, we notice that they have sufficient Reserves and surplus. Further, they have not taken any amount either from Head office. These units did not borrow money from other persons also. On the contrary, the Balance Sheets would show these units have given money to the Head office. Since these units have not taken money from Head office, the question of allocating interest expenses of the HO to these units will not arise. Hence, the reasoning given by the AO would fail in respect of these three units. Hence there is not necessity to allocate interest expenditure of Head office to the above said two units. Since all the facts are already available on record, there was no necessity for the Ld CIT(A) to restore the issue again for verification of factual aspects. Accordingly we modify the order passed the learned CIT(A) on this issue and direct the AO to delete the allocation of interest expenses made to these three units. Disallowance of Sales Promotion Expenses in the form of freebies to doctors and medical professionals u/s 37(1) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of its Swiss subsidiary named Glenmark Holding S.A Switzerland - CIT(A) deleted adjustment made in respect of guarantee commission - HELD THAT:- We notice that the Ld CIT(A) has followed the decisions rendered by the Hon ble jurisdictional Bombay High Court in the assessee s own case [ 2017 (2) TMI 1305 - BOMBAY HIGH COURT ] and the Tribunal passed in the assessee s own case in an identical issue and accordingly deleted the transfer pricing adjustment made in respect of guarantee commission. Hence, we do not find any reason to interfere with the order passed by Ld CIT(A) on this issue. Allocation of R D expenses to the units eligible for deduction u/s 80IC/80IE - HELD THAT:- Tribunal in the assessee s own case in AY 2010-11 [ 2019 (2) TMI 1067 - ITAT MUMBAI ] and accordingly remitted this issue to the file of AO. In our view, no prejudice is caused to the revenue by the decision of CIT(A), since the matter required factual verification. Accordingly, we uphold the order passed by CIT(A) on this issue. Disallowance made u/s 14A r.w.r. 8D - Expenses incurred earning exempt income - HELD THAT:- As decided in Envestor Ventures Ltd. [ 2021 (1) TMI 922 - MADRAS HIGH COURT ] answering ques ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cular 5 of 2012 does not subsist for the disallowance of sales promotion expenses. 6. It can be noticed that certain issues are common in the appeals of both the parties. Accordingly, they are disposed of together. 7. The facts relating to the case are stated in brief. The activities of the assessee are described as under by the Transfer pricing officer (TPO):- "The assessee is the ultimate holding company of the Glenmark Group. It is a Research led Global, fully integrated pharma company head quartered in Mumbai, incorporated in 1977, and engaged in the business of manufacturing and marketing of formulations in India. Globally it enjoys diversified presence in regulated and developing international market. Post Restructuring in 2008, the company now focuses on manufacturing and marketing FDF. The specialty business comprising branded generics and R & D is part of the assessee." Since the assessee had entered into international transactions, the AO referred the matter of determination of Arms Length Price of the same to the TPO, who proposed additions by way of transfer pricing adjustment. Hence the AO passed the draft assessment order making additions on account of transfer p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not accept the same. The TPO expressed the view that the companies have different financial year ending cannot be considered to be comparable. He further expressed the view that the companies having different format and non-availability of Balance Sheet, not having proper figure of RPT and unclear description of function are not reliable. Accordingly, the AO held that the AEs cannot be treated as tested parties. Accordingly, the TPO held that ALP of margin should be taken as the rate of 10.86% earned on sale to non-AEs both in domestic and Export market. Accordingly, he made transfer pricing adjustment of Rs. 1,37,66,503/- and Rs. 63,09,494/- respectively for the exports made to South Africa and Mexico. 8.4 The Ld CIT(A) agreed with the views expressed by TPO. With regard to the Principle of Consistency, the Ld CIT(A) held that the decision of TPO is based on facts applicable to the year. He also pointed out that the fact that the AEs are different accounting years is a significant defect. Accordingly, he confirmed the transfer pricing adjustment made by the TPO. 8.5 We heard the parties on this issue and perused the record. There is no dispute that the foreign AEs were accepted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the preceding years. 8.7 The ld A.R submitted that, if the issue is approached in this way, what is required to be seen is whether the assessee has made profits from export of goods to its AEs and whether the profitability of AEs was less than that of the comparable companies. The Ld A.R submitted that the data relating to the above said two AEs corresponds to the above said approach. The relevant details are tabulated as under:- (A) Glenmark, South Africa:- (Rs. In lacs) S.No. Particulars AY 2013-14 AY 2014-15 1 Exports by assessee 1495.18 2038.25 2 Gross profit earned by assessee 139.94 273.04 3 Gross margin earned by assesse 9.36% 13.40% 4 Margin earned by GPL, SA -3.98% -36.44% 5 Operating margin range of comparables 1.78% to 12.41% 2.12% to 9.54% 6 Mean Operating margin of comparables 8.20% 8.10% 7 Operating margin earned by assessee on export of goods to AE (OP/TC) 0.07% 3.85% (B) Glenmark, Mexico (Rs. In lacs) S. No. Particulars AY 2014-15 AY 2015-16 AY 2016-17 1 Exports by assessee 440.72 1649.10 1210.61 2 Gross profit earned by assessee 28.97 586.11 346.41 3 Gross margin earned by assesse 6.57% 35.54% 28.61% 4 Mar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... while the comparable companies are established players. As noticed by us earlier, so far the assessee herein is concerned and qua the transfer pricing provisions, what is required to be seen is whether the price realized on export of products to their AEs is at arms length or not. Further, the fact the profitability of AEs is lower than the profitability of comparable companies, would also show that the assessee has not under invoiced the sales. In the instant case, the details extracted in the table above matches with the above said criteria. Since the comparable companies selected in the respective Geographical locations are established players, the profit ratio of comparable companies are to required to be considered only to show that the profit ratio of the assessee was lower than their profit ratio. In this view of the matter, the difference in accounting period may not be that much relevant. 8.9 We have noticed that the above said methodology adopted by the assessee has been accepted by the TPO in the earlier years. Further, the table above would show that the profitability of the assessee in exporting products to these two AEs is increasing year after year. Under these set ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) took the view that the AO has not examined factual aspects relating to R & D expenses incurred and accordingly restored the issue to the file of AO for the limited purpose of examining the expenses and deciding the eligible amount of deduction. The revenue is aggrieved with the relief granted to the assessee. However, the assessee is aggrieved by the decision of Ld CIT(A) in restoring the issue to the file of AO for examining the expenses. 9.4 With regard to the dispute as to whether the cost of contract R & D expenses or contract revenue should be deducted from R & D expenses for the purposes of computing deduction u/s 35(2AB) of the Act, the Ld CIT(A) noticed that the Mumbai bench of Tribunal has held in the case of ACIT vs. Wokhardt Ltd (ITA No.71/Mum/2007) that the income arising from contract R & D expenses should not be reduced. In support of this proposition, the assessee also placed reliance on the decision rendered by Hon'ble Karnataka High Court in the case of Microlabs Ltd (2016)(383 ITR 490)(Kar), wherein also identical view has been expressed. The Ld CIT(A) also noticed that the Ld CIT had initiated revision proceedings in the case of the assessee in AY 2012-13 for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee has set up various undertakings in different states. Four of its units, viz., Baddi unit (Baddi-I), Solan unit (Baddi-II), Buddi-III unit and Sikkim unit are eligible for deduction u/s 80IC/80IE of the Act. The AO noticed that the assessee has incurred interest expenses of Rs. 6.43 crores in Head office and it has been allocated to 'Baddi-III' unit only. The Assessing Officer took the view that the funds available with Head Office is general pool of funds, i.e., included both own funds and borrowed funds. The AO took the view that these units are using funds from head office, the interest expenses should be allocated to all the four units in the ratio of Sales. If the interest expenses is so allocated, then the profits of these units will get reduced, in which case, the quantum of deduction u/s 80IC/80IE shall also come down. The same will result in increase of total income. 10.2 However, the assessee contended that the 3 units, viz., Baddi unit (Baddi-I), Solan unit (Baddi-II), and Sikkim unit have been established long back and they have got sufficient own funds, i.e, they do not use funds of Head office. It was submitted that these units, on the contrary, have given fun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unds of head office have been utilized by those units. It is the contention of the assessee that it has furnished the financial statements of the various units before the AO, which would show that they were having enough Reserves and Surplus. It is also stated that these units have not taken money from the Head office. All these facts are very much visible from the financial statements filed before AO/CIT(A). Accordingly, it was contended that there was no necessity to allocate interest expenses and also to restore the issue again for verification of these factual aspects again. 10.6 We notice that the assessee has furnished the Balance-sheet of Buddy I unit at page No. 238 to 252 of the paper book, Solan unit (Baddi-II) at pages 253 to 267 of paper book and Sikkim unit at page No. 284 to 294 of the paper book. On a Perusal of the balance-sheets of these three units, we notice that they have sufficient Reserves and surplus. Further, they have not taken any amount either from Head office. These units did not borrow money from other persons also. On the contrary, the Balance Sheets would show these units have given money to the Head office. These details are tabulated below:- (Rs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... accordingly reduced the profit eligible for deduction under those sections. 11.2 Before Ld CIT(A), the assessee relied upon the decision rendered by the Tribunal in the assessee's own case in AY 2013-14, wherein the Tribunal had deleted the addition following the decision rendered by the co-ordinate bench in the case of PHL Pharma P Ltd (2017)(49 CCH 124)(Mum). The Ld CIT(A) in principle agreed with the same. However, he took the view that it is open to decide whether the expenses is wholly and exclusively incurred for the business and the accounts are correct and complete. Accordingly, he examined the vouchers and supporting documents relating to the claim of Sales promotion expenses. He noticed that major expenses have been incurred on food and beverages, travel and hotel accommodation. He noticed that the expenses on medical literature, actual direct medical service, expenses on medical camps are minimal. He also noticed that the conference expenses itself cost Rs. 27.91 crores of which actual medical component was minimal. Accordingly, the Ld CIT(A) took the view that all the expenses cannot be considered to have been incurred for business purposes. In this view of the matter, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he above that expenditures amounting to Rs. 227,94,36,291/- (200,02,56,927 + 27,91,79,364) are not in the nature of freebie given to doctors or in violation of MCI guidelines. The above expenditures are business expenditures incurred for employees and sales promotion which are allowable u/s. 37 of the Act. 31) It is submitted that since the above expenditures cannot be said to be incurred in violation of MCI guidelines, it is humbly prayed that the Assessing Officer may be directed to remove the above expenditure of Rs. 227,94,36,291/- while working out the total expenditure that could be considered in violation of MCI guidelines. 32) It is submitted that out of the balance expenditure of Rs. 164,93,43,639/-(392,87,79,930 - 227,94,36,291) there could be certain expenditure incurred on account of freebie paid to doctors or in violation of MCI guidelines. The CIT(A) has estimated the expenditure to be 7.7% of the total expenditure. It is submitted that the percentage adopted by the CIT(A) is on higher side. It is humbly prayed that reasonable percentage may be estimated on the balance expenditure of Rs. 164,93,43,6397- that could have been incurred on account of freebie paid to d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the expenses incurred by it are not in the nature of freebies. Very same contentions have been made before the tax authorities. It is the contention of the assessee that the sales promotion expenses to the extent of 227,94,36,291/- (200,02,56,927 + 27,91,79,364) are not in the nature of freebies given to doctors or in violation of MCI guidelines. Remaining expenditure is Rs. 164.93 crores. There should not be any doubt that actual expenses incurred on freebies are required to be disallowed under section 37(1) of the Act. Accordingly we are of the view that this issue requires fresh examination at the end of the Assessing Officer. Accordingly we set aside the order of the learned CIT(A) passed on this issue and restore the same to the file of the Assessing Officer. 11.8 The amount so disallowed may be distributed between the eligible units and the deduction u/s 80IC/80IE may be computed accordingly. 12. The next issue relates to the disallowance of claim made u/s 32AC of the Act. Under the provisions of sec.32AC of the Act, a deduction @ 15% of the actual cost of new assets acquired and installed is allowable (a) if the aggregate cost of new assets exceed one hundred crores o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d to an investment allowance of 15 percent of the investment in such new assets. The intention of the legislature was to provide incentive to the taxpayers making substantial investments in plant or machinery and thereby boost the manufacturing sector in the economy. 226. The assessee claimed the amount of Rs. 3,43,97,11,256/- as deduction u/s. 32AC which includes Rs. 248,65,65,041/- towards cost of components of plant or machinery lying as CWIP as on 1.4.2013 but aggregated and installed as 'plant' or 'machinery' during the FY 2013-14. Further an amount of Rs. 8,32,42,289/- was claimed in respect of the assets which are eligible for depreciation at the rate of 100 per cent but installed and put to use for less than 180 days and hence depreciation was claimed to the extent of only 50% of its actual cost during the FY 2013-14. 227. The AO rejected the claim of the assessee on the following grounds: "i. The word "and" signifies that both acquisition and installation of assets should be after 31/03/2013 and not merely the installation ii. The assets which are eligible for 100% depreciation even though put to use for less than 180 days are not el ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e the 1st day of April, 2014, if the aggregate amount of actual cost of such new assets exceeds one hundred crore rupees; and (b) for the assessment year commencing on the 1st day of April, 2015, of a sum equal to fifteen per cent of the actual cost of new assets acquired and installed after the 31st day of March, 2013 but before the 1st day of April, 2015, as reduced by the amount of deduction allowed, if any, under clause (a). (1A) Where an assessee, being a company, engaged in the business of manufacture or production of any article or thing, acquires and installs new assets and the amount of actual cost of such new assets acquired and installed during any previous year exceeds twenty-five crore rupees, then, there shall be allowed a deduction of a sum equal to fifteen per cent of the actual cost of such new assets for the assessment year relevant to that previous year: Provided that no deduction under this sub-section shall be allowed for the assessment year commencing on the 1st day of April, 2015 to the assessee, which is eligible to claim deduction under sub-section (1) for the said assessment year. (1B) No deduction under sub-section (1A) shall be allowed for any as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t and machinery. This benefit will be available for three years i.e. for investments up to 31.03.2017. The Scheme announced last year will continue to operate in parallel till 31.03.2015." 234. The memorandum explaining the provision of Finance (No.2) Bill, 2014 in respect of the aforesaid amendment stated as under:- "FINANCE (No. 2) BILL, 2014 PROVISIONS RELATING TO DIRECT TAXES Investment Allowance to a Manufacturing Company In order to encourage the companies engaged in the business of manufacture or production of an article or thing to invest substantial amount in acquisition and installation of new plant and machinery, Finance Act, 2013 inserted section 32AC in the Act to provide that where an assessee, being a company, is engaged in the business of manufacture of an article or thing and invests a sum of more than Rs. 100 crores in new assets (plant and machinery) during the period beginning from 1st April, 2013 and ending on 31st March, 2015, then the assessee shall be allowed a deduction of 15% of cost of new assets for assessment years 2014-15 and 2015-16. As growth of the manufacturing sector is crucial for employment generation and development o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... various location in India. Huge plant and machineries are required for the manufacturing of cement. These plants are in the nature of complex machineries. Various components purchased by the assessee are to be assembled and commissioned together which takes substantial amount of time given the complexity, size and nature of the machinery/ project/ plant required for the business. The sheer size of various plants/ machineries constructed and put to use during the year is evident from the fact that as on 1 April 2013, the capital work-in-progress of the assessee was Rs. 1,657 crores and to convert them into plant, additional purchase of individual components worth Rs. 635 crores was made during the year. Unless and until the machinery are assembled and commissioned together, the plant does not come into existence. Therefore, the meaning of word "acquisition" will have to be considered in light of the nature of various plants the assessee was constructing. The plant is acquired only when all the components of machinery are assembled and commissioned together. 238. In this regard it is worth noting the first proviso to sub-section (1A) of section 32AC. It is provided that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... viso to section 32(1), we must give the same interpretation. 241. We further note that the issue relating to availability of additional depreciation under section 32(1)(iia) wherein the phrase used is "acquired and installed after the 31st day of March" has been subject matter of litigation. The Coordinate Bench of this Tribunal in the case of Euro Pratik Ispat Pvt. Ltd. vs. ACIT (ITA No. 1682/Mum/2011) has observed as under : "In our opinion machinery was installed in the AY under appeal, though acquisition of the P&M had started in earlier year AY. Till a machine is not assembled in a manner that it could be used to manufacture, it cannot be held that it had been installed. Mere purchasing or shifting it to factory premises is not enough. Assessee had claimed additional depreciation @ 10%, as the P&M had worked for a period less than one year. It is a common phenomenon that in big projects, installation of machinery takes very long time because of the sheer volume of the work to be carried out. If an assessee is not successful in installing P&M in one year and carries forward the installation work in subsequent year / years it cannot be denied any benefit on th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... drawn to the following observations of Hon'ble Supreme Court in the case of Bajaj Tempo Ltd. v. CIT [1992] 196 ITR 188 (SC): "The provision in a taxing statute granting incentives for promoting growth and development should be construed liberally; since the provision for promoting economic growth has to be interpreted liberally, restrictions on it too has to be construed so as to advance the objective of the provisions and not to frustrate it." "The words used u/s 32(1)(iia) of the Act are 'acquired and installed' after 31st day of March 2005. The assessee company did purchased new machineries and plant prior to 31-03-2005 as well after 31-03-2005 for the coke production plant being set up by the assessee company but the installation of the entire new plant and machineries as an integrated activity for setting up industrial project for coke production plant which started in financial year 2004-05 were completed after 31- 03-2005 and commercial production of the new coke production plant being set up by the assessee company started in April 2005 i.e. in financial year 2005-06 when the new coke production plant set up by the assessee company became opera ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... visualized in itemized manner as unless these new plant and machineries are integrated together they will not achieve the desired results. The assessee company has finally installed the entire new plant and machineries in April 2005 i.e. after 31-3-2005 and assessee company is entitled to the benefit u/s 32(1)(iia) of the Act for claiming additional depreciation in the impugned assessment year because what is relevant is that new machineries and plant which were acquired before 31- 03-2005 and also post 31-03-2005 were all purchased as an integrated activity connected with the common and sole objective directed towards activity of the assessee company to set up new coke production plant which become operational in financial year 2005-06 with completion of installation of these new plant and machineries in April 2005 when all these machineries and plant were put to use after installation with start of commencement of commercial production of LAM coke in April 2005 when the new coke production plant become operational and their acquisition which concluded in financial year 2005-06 is to be seen in composite manner rather than in itemized manner as in an itemized capacity said new pla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ase of PCIT vs. IDMC Ltd. [2017] 393 ITR 441 also took a similar view on the issue and has observed as under: "Applying law laid down by the Supreme Court in various decisions to the facts of the case on hand, if the submission on behalf of the revenue is accepted, it will lead to an absurd and unjust result and the purpose and object of granting the additional depreciation will be frustrated. If the contention on behalf of the revenue is accepted, in that case, the assessee shall never get the additional depreciation as provided under section 32(1)(iia). In the facts and circumstances of the case, the twin conditions of the acquired and installed shall never be satisfied in a year and therefore, the assessee shall never get any depreciation. The purpose and object of granting additional depreciation under section 32(1)(iia) is to encourage the industries by permitting the assessee setting up the new undertaking/ installation of new plant and machinery and to give a boost to the manufacturing sector by allowing additional depreciation deduction. Thus, as rightly held by the Tribunal the provisions of section 32(1)(iia) are required to be interpreted reasonably and purposivel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h are considered as plant and machinery for the type of business they are in, will not be eligible to claim deduction under section 32AC since according to the Revenue the designs, drawing, plans are not installed by the assessee. 246. It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean "or". The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: "Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and sufficient reason". As a matter of statutory interpretation, it is well settled that the expression "and" can in a given context be read as "or" (see in this context Ishwar Singh Bindra v. State of UP AIR 1968 SC 1450). This submission was opposed on behalf of the assessee by urging that in the context of sub-section (2A), it has been held by this Court in Sahara India (Firm), Lucknow (supra) that the word "and" is used in the conjunctive sense. Undoubtedly the expression "and&qu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s. CIT (LTU) (ITA No. 4815/Mum/2018 dated 01-09-2021) Accordingly, following the above said decisions, we hold that the actual cost of plant and machinery transferred during the year from Capital work in progress standing as on 01-04-2013 should also be considered for ascertaining the aggregate cost of assets acquired and installed during the year. In the instant case, the aggregate cost of assets transferred from Capital work in progress and the purchased during the year has exceeded the threshold limit of Rs. 100 crores. Hence, the deduction u/s 32AC of the Act claimed by the assessee is allowable. Accordingly, we set aside the order passed by Ld CIT(A) on this issue and direct the AO to allow the deduction claimed by the assessee u/s 32AC of the Act. 13. We shall now take up the issues urged by the revenue. The first issue urged by the revenue relates to the relief granted in respect of transfer pricing adjustment made on Corporate Guarantee commission. 13.1 The assessee had provided guarantee in favour of its Swiss subsidiary named Glenmark Holding S.A - Switzerland. Most of the loans were availed by the above said subsidiary in the earlier years and brought forward during t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ith the order passed by Ld CIT(A) on this issue. 14. The next issue urged by the revenue relates to the allocation of R & D expenses to the units eligible for deduction u/s 80IC/80IE of the Act. It is pertinent to note that the assessee did not press the corresponding ground raised by it. The AO had allocated R & D expenses to Mahape and Sinnar units and accordingly reduced the deduction allowable u/s 80IC/80IE of the Act. It is the submission of the assessee that it did not carry on any R & D activity in the above said two units and hence the R & D expenses were not allocated to these two units. 14.1 The Ld CIT(A) noticed that an identical issue has been remitted to the file of AO by the Tribunal in AY 2010-11. Following the same, the Ld CIT(A) remitted this issue to the file of AO in order to verify as to whether any R & D activity was carried out at the above said two units. The revenue is aggrieved. 14.2 We noticed that the Ld CIT(A) has followed the decision taken by the Tribunal in the assessee's own case in AY 2010-11 and accordingly remitted this issue to the file of AO. In our view, no prejudice is caused to the revenue by the decision of Ld CIT(A), since the matter req ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
