TMI Blog2011 (6) TMI 682X X X X Extracts X X X X X X X X Extracts X X X X ..... al an influence on the determination of transfer pricing in relation to the transaction being compared than other datas for period not more than two years prior to such financial year may be used. Thus, the view point of the Transfer Pricing Officer for using the current year data is upheld. For finding out comparable Assessees who have uncontrolled international transactions of similar nature - We are in view that product produced by the assessee in itself is of a complex nature, which required skilled work force. We find certain comparables which were found acceptable by the assessee in the financial year 2004-05 all of a sudden become incomparable in the financial year 2005 06. It suggests that efforts of the financial analyst was to prepare the documentation in such a fashion which would give the result near to the result disclosed by the assessee. The TPO has considered this aspect elaborately - Thus Assessee is high end service provider. Search Methodology for selecting Comparables - The approach of the TPO ought to be judicious. The comparability between a controlled transaction and uncontrolled transaction is a comparison of condition which is broader than a mer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his issue without making a proper analysis. On perusal of the assessment order, we find that the AO while considering the ratios laid down by the Special Bench of the Income-tax Appellate Tribunal has observed that the Special Bench was not correct in interpreting the law. In our opinion, it is not for the AO to comment upon the orders of the higher authorities rather she is bound to follow them. Following the decision in the case of AMWAY INDIA ENTERPRISES. VERSUS DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1), NEW DELHI. [ 2008 (2) TMI 454 - ITAT DELHI-C] we held that, the assessee has not acquired any ownership in the alleged licence and the licences shelf life is less than two years. The nature of the assessee's business is such that it required computer software. Therefore, the expenses incurred by the assessee for obtaining the licence to use the software is to be treated as revenue expenditure - Decision in favour of Assessee. Amount paid to Noida Development Authority - Capital or Revenue in Nature? - The name of the allottee has been got changed by the assessee - For which Assessee was directed to pay charges for change in ownership - HELD THAT:- The learned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7.88% in asstt. year 2003-04. Ld. CIT(A) has reduced this percentage to 16.16% by applying more filters in selecting the comparables. In this way, the adjustment recommended by the TPO has been marginally reduced. The assessee is disputing additions made on the recommendation of the TPO for making adjustment in its arms length price, whereas revenue in its appeal is disputed the reduction made by the Ld. CIT(A) in working out the PLI at 16.16%. Similarly, in asstt. year 2004-05, assessee has worked out average operating profit on total cost ratio at 8.93%. TPO recommended it 17.50%. Ld. CIT(A) reduced it to 16.33%. Both parties are disputing the retention of the adjustment recommended by the TPO and reduction of the adjustment made by the Ld. CIT(A). In asstt. year 2006-07, there is no difference in the method applied by the assessee. It had shown PLI at 11.6%. The TPO worked out the average of OP over TC i.e. PLI at 18.13%. Ld. DRP has upheld the recommendations made by the TPO for making adjustment in the ALP of international transaction. The assessee is impugning the addition on the basis of such recommendation. Asstt. Year 2003-04 4. The brief facts of the case are t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sed by the assessee in the shape of profit whether it is consumerate with the function performed, assets used and risk assumed. The business profile and operating model noticed by the Ld. CIT(A) read as under :- A. Business Profile: 4.4 Before adjudicating on the TP issue, it would be appropriate to sketch the business profile of the appellant as described in the TP report :- (i) The ST Group (headquartered in Netherlands) is a global group that designs, develops, manufactures and markets a broad range of semiconductor integrated circuits (ICs) and discrete devices used in a wide variety or microelectronic applications, including telecommunications systems, computer systems, consumer products, automotive products, industrial automation and control systems. (ii) The product portfolio covers all major categories of semiconductor devices, dedicated ICs, microprocessors and semi conductors, memories, standard ICs (iii) ST Group is the world s leading supplier of MPEG-2 decoder ICs, digital set-top box ICs and EPROM non-volatile memories and also the second leading supplier of analog and mixed-single ICs, disk drive ICs, Smart card ICs and EEPROM memories. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly performs the routine service function in the life cycle provided by the ST Group, within the framework of budgets decided between ST India and ST Group, which shows that all high value functions are performed by ST Group. STML undertakes all the common functions such as finance and accounting, budgeting, system maintenance, personnel management, human resource management etc. that re carried out by business irrespective of its size and nature. 4.5.3 ST Group owns significant tangibles and intangibles that are used in manufacturing and other activities. The tangible assets deployed by STML are to the extent of Rs. 112.30 crores which include office equipments (64.8 crores), building (30.3 crores), leasehold land (8.9 crores) and furniture and fixtures (8.4 crores). In addition to the tangible assets, certain intangible assets are deployed by STML. During the course of its functioning, STML develops certain intangibles without having any proprietary rights on them. The details, as per the TP report, are as under :- STML uses the process know-how , software, operating / quality standards, designs, diagrams, technical specifications, etc. developed / owned by S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... various quantitative and qualitative filters to the set of potential comparables. He also found that assessee has relied multiple year data and had focused on the operating results of comparable over the three Financial years i.e. Finance year 2000-2001 to 2002-03. The arithmetic mean of the 14 comparables identified by the assessee was worked out at 11.88%. The assessee has shown operating profit over cost at 9.87%. It was submitted by the assessee that NCP margin shown by it at 9.87% is within the variation allowed by the proviso to section 92C(2) of the Income Tax Act and, therefore, no adjustment is required. Ld. TPO has observed that assessee has considered itself a low end risk, captive software service provider to ST group, whereas according to the Ld. TPO the assessee is to be characterise as a performer of high end activity relating to value added segment Embedded Technologies for high profit margins. According to the Ld. TPO the assessee has characterised its functional profile improperly, it led to incorrect selection of comparable by applying wrong quantitative and qualitative filters . The TPO has also observed that it has used multi year data which is not permissi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... chnologies. (vi) STML specializes in developing high value VLSI intellectual Property (IP s), System on Chip (SOC s), embedded software for end applications and IT infrastructure. (vii) STML was also a major contributor to the development of the latest Nomadik chip family which will enable portable terminals to play music, take pictures, record video, and host two-way communication (viii) The Transfer Pricing Report admits that the design centre of STML is the most import centre of the group for intellectual property creation. (ix) STML renders designing services using the latest 2D and 3D CAD with critical software. The ICs design/software development services performed by STML require a high level of expertise in the field of software engineering. (x) The agreement between assessee and parent company states that the ST Netherlands is interested for the furtherance and recognition of its leading position as supplier of a broad range of semiconductor device in a wide variety of semiconductor applications, to develop its intellectual property portfolio through the procurement of state of art development services. (xi) The agreement further states ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in a number of aspects of the associated enterprise and the independent enterprise involved in the transactions in order for the controlled transactions to be comparable (vi) Various factors other than products and functions that can significantly influence net margins. (vii) Net margins may be directly affected by such forces operating in the industry as follows Threat of new entrants Competitive position Management efficiency and individual strategies Threat of substitute product Varying cost structures as reflected in the age of the plant and equipment Differences in the cost of capital self financing versus borrowing Degree of business experience whether the business is in a start up phase or is mature: (viii) Net margins are also indirectly affected by a plethora of other forces as each of the above mentioned factors in turn can be influenced by numerous other elements. For example the threat of new entrants will be determined by such elements as product differentiation, capital requirements, and government subsidies and regulations. (ix) In case of stark differences between controlled and uncont ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ection 92C(2). The assessee further contended that the TPO ought to have not relied upon the current year data alone. He should have appreciated the TP report submitted by the assessee on the basis of multiple year data. 11. The Ld. CIT(A) has considered the submissions of the assessee in detail. With regard to its first objection that reference made by the AO to the TPO is bad in law. Ld. CIT(A) , on the strength of special bench order of the ITAT in the case of M/s. Aztec Software Technology Services Ltd. Vs. ACIT 294 ITR (AT) 32 rejected its ground of appeal. According to the special bench decision of the Tribunal, AO was not supposed to demonstrate avoidance of tax before invoking the provision for making a reference. Thus the reference was not mechanical one. Ld. CIT(A) similarly rejected the contention of assessee that AO has accepted the recommendations made by the TPO mechanically. The Ld. CIT(A) relied upon the decision of the special bench of ITAT. The next objection raised by the assessee before the Ld. CIT(A) was whether multiple year data is to be used for identifying the comparable or current year data has to be used. Ld. CIT(A) has dealt with this issue in detai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . An arithmetic mean of NCP in respect of these four companies comes out to 16.16%. He upheld the adjustment by applying this ALP. Ld. TPO has recommended an adjustment of ₹ 10,35,72,191/- with the ratio worked out by the Ld. CIT(A), it comes out to ₹ 8,30,01,779/-. The Ld. CIT(A) in this way deleted the adjustment to the extent of ₹ 2,05,70,412/-. The revenue is impugning this deletion whereas assessee is impugning the confirmation of addition at ₹ 8,30,01,779/-. Asstt. year 2004-05 14. In this asstt. year, there is no disparity on facts the TPO has recommended adjustment of ₹ 13,23,25,016/-. Ld. CIT(A) upheld the adjustment of ₹ 11,42,89,458/-. He has deleted the addition of ₹ 1,80,35,558/-. The PLI computed by the Ld. CIT(A) is at 16.33%. In Asstt. year 2006-07 15. There is no disparity on facts in this year also. Assessee has disclosed two international transactions with its AE in the TP report submitted in Form No.3CEB. The PLI disclosed by the assessee at 11.6%. In the TP report, it has selected 30 comparable and computed their weighted mean at 13.3%. Learned TPO has rejected the comparables selected by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee 20. The assessee has contended before the Ld. TPO that section 92C and section 92D read with rule 10D clearly indicate that documentation (including the bench marking / analysis) is required to be maintained by the assessee to establish and support the arms length nature of its international transaction. The assessee is required to maintain TP documentation contemporaneously . Such documentation should exist latest by 31st October of the relevant financial year. This make it clear that legislature prefers the determination of ALP between this date. Thus the data used in determination of ALP should be available latest by November, 30 and not beyond. Therefore, the use of current year data which was not available at that stage would be nothing but hardship to the tax payers and in contrary to the intend of the legislature. The assessee has relied upon the decision of ITAT in the case of Philips Software Centre Pvt. Ltd. 2008 vs. ACIT 119 TTJ 721 ITAT Bangalore. Ld. DR. on the other hand submitted that Rule 10B (4) is quite clear in this regard. It mandate the assessee to use current year data. The multiple year data is permitted to be used only in those cases, where n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... htly upheld the view point of TPO for using current year data. 23. The next step for determination of A.L.P. of the international transactions entered by the assessee with its associate enterprises is to find out the comparable assessees who have uncontrolled international transactions of similar nature. Before finding out the comparable, it is necessary to find out the status of assessee i.e. what it manufactures and with whom it can be compared. This dispute arises because the Assessing Officer termed the assessee as high end performer in the field of computer software whereas according to the assessee its activities are of low end. Thus, we have to first decide:- whether characterization of the assessee s business by the Learned TPO as high end service provider is correct ? . 24. The learned counsel for the assessee while impugning the findings of the learned revenue authorities, pointed out that assessee is a subsidiary of ST Microelectronics PTe Ltd. Singapore, which is a wholly owned subsidiary of ST Microelectronics, Neitherland. It had commenced its commercial operation in financial year ended on 31.3.1993. It is engaged in the business of rendering integrated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d verification stage. According to the assessee, it is critical stage which requires high infusion of capital in order to test the designed product. There is no contribution of ST India in performance of this stage. Stage No.5: At this stage, manufacturing and fabrication taken place. According to the assessee, it also involves high capital and it is highly complex process. There is no role of ST India in carrying out this activity. Stage No. 6: In this stage, sales marketing and customers support are performed. On the strength of this flow chart, The learned counsel for the assessee submitted that ST India is involved only at one stage and that too with a limited scope of work. It has no say in the process of conceptualization of any product. It works only on the specification given by the ST group for the designing and development of IC. On the strength of these details, he submitted that the role of ST India can be categorized a low end risk free captive design and development. The learned counsel for the assessee thereafter appraised us as to how assessee did not take any risk. He referred to the risk associated with the assessee vis- -vis its AE. For buttressing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... learned professor relied upon by the Learned CIT(Appeals) as well as the circumstance pointed out by the Learned TPO (extracted supra). In assessment year 2006-07, Learned DRs have pointed out that there is no disparity on facts. They have submitted that ST India is on of the largest design centres of ST group outside Europe. ST India has established a design centre at NOIDA and a Branch Office at Bangalore. The design centre employees around 1600 people. It develops Libraries of re- usable IP's based upon UNICAD and the CAD platform, specially advanced system on chip (SOC) solution for digital consumers, computer, telecom and automotive application. They further submitted that ST India also provides local marketing information service to the group companies. 28. We have duly considered the rival contentions and gone through the record carefully. The operative force of assessee s arguments regarding characterizing it as a low end risk free captive service provider, is that most of the functions in producing integrated semiconductors are being performed by ST Group. The role of the assessee is limited. We have taken cognizance of assessee s business profile as well as operat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion in such a fashion which would give the result near to the result disclosed by the assessee. Learned TPO in all the three assessment years and the Learned CIT(Appeals) in assessment years 2003-04 and 2004- 05 has considered this aspect elaborately. The objections pointed out by the learned counsel for the assessee during the course of assessment proceedings are peripheral objections, a suitable adjustment can be made while selecting the comparables which can take care of their objections. After considering the detailed findings of Learned CIT(Appeals) in these two assessment years on this issue as well as the discussion made by the learned TPO in all the three years, we do not find any force in the objections raised by the assessee. Learned TPO has rightly treated the assessee as a high end service provider. 29. The next area of dispute between the parties is whether learned TPO has rightly rejected the search mythology applied by the assessee as well as the comparables selected by the assessee. In assessment year 2003-04, assessee has selected 14 comparables in its TP report. It has applied quantitative filter as well as qualitative filer. Under quantitative filter, it has e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ities Below. 31. We have duly considered the rival contentions and gone through the record carefully. In assessment year 2003-04, learned TPO while pointing out the defects in the TP report has observed that assessee is engaged in a specialized area of development of embedded technology under the overall guidance from the parent group companies. No doubt assumption of risk and development of intangible assets is limited but still assessee did not make any attempt to take note of this characteristic of the service provided in the selection of comparables. According to the learned TPO, the assessee assumes man power risk while performing its function. The nature of job undertaken by the assessee involves deployment of highly skilled technical manpower. This aspect was not applied by the assessee while conducting the functional analysis of the comparable in the TP report. It has not applied appropriate filter to fine tune the selection of comparables incorporating this important aspect carried out by the assessee. He has observed that assessee has employed highly skilled manpower which indicates that employees cost to the total cost is 53.69%, thus this filter ought to have been co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be made within the ambit of procedure provided in the Act as well as Rule 10B of the Income-tax Rules. The approach of the Learned TPO ought to be judicious. The comparability between a controlled transaction and uncontrolled transaction is a comparison of condition which is broader than a mere comparison of price or margin. Where it is found that the conditions were imposed which differ from those which would be made between independent enterprises, transfer pricing adjustment are to be made. Thus, the learned TPO while evaluating the TP study made by the assessee arrived at a conclusion that assessee has left over various angles in identifying the comparables. He has highlighted those aspects in the order and thereafter proceeds to identify fresh comparables. This exercise has been done after giving proper opportunity of hearing to the assessee. 32. As far as assessment year 2006-07 is concerned, learned TPO has observed that search straightgy of the assessee in identifying the comparable is not scientific. According to him, it was not based on any key value driver for the IT Industry. He observed that salary and wages are the key drivers for the IT Industry. The use of level ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he result declared by it. It used to select different filters for selecting or eliminating the comparables in each assessment year in such a way that would give only uniform result. Therefore, this issue is decided against the assessee in all the assessment years. 33. The next area of dispute between the parties is selection of comparable companies for the benchmarking analysis of ALP relating to international transaction. In assessment year 2003-04, learned TPO has selected 23 comparables which have been reproduced by the Learned CIT(Appeals) on page 7 while taking cognizance of Table No.10. Learned CIT(Appeals) did not accept two filters applied by the learned TPO, one relates to related party transaction and the other relates to employees cost over total cost. He ultimately identified four companies who are broadly functionally similar comparables. The four cases relied upon by the Learned CIT(Appeals) in Table No.12 reads as under: S. No. Company name Functional Profile RPT % Standalone Turnover Employee cost/Total cost% Fixed Asset turnover ratio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 92 43.7 4.89 13.31 35 Visualsoft Technology Ltd. Company is a focused IT company operating in Software Dev. Services and Products. Nil 155.56 67.93 1.74 30.17 Arithmetic Mean 60.53 2.58 16.33 35. In assessment year 2006-07, learned TPO has identified 12 comparables. They are as under: S. No. Company Name FY OP/TC% 1 Bodhtree Consulting Ltd 16.52 2 Lanco Global Systems Ltd. 5.88 3 Exensys software solutions Ltd. 26.18 4 Sankhya Infotech Ltd. 25.27 5 Visualsoft Technologies Ltd. 13.05 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uld have not been rejected. The main emphasis is that simply on conjectures and surmises, search carried out by the assessee cannot be disregarded. He made a reference to the order of the ITAT in the case of Mentorgraphic Vs. DCIT reported in 109 ITD 101 (Delhi). He also pointed out that Learned CIT(Appeals) agreed to the assessee that it is a risk free captive service provider but simultaneously made a reference to the Article of the Profession, Deepak Bagai for terming the assessee as belonging to a sunshine sector. He further submitted that Learned CIT(Appeals) has finalized six comparables but then excluded two in assessment year 2003-04 for non-availability of data. Now, the data are available and if they are included then NCP margin will be within the range of plus/minus 5% contemplated in the proviso to section 92C(2) and no adjustment would require. 38. In assessment year 2006-07, learned counsel for the assessee raised multifold submissions for pointing defect in the ultimate selection of comparables. Firstly, he contended that learned TPO did not grant proper opportunity of hearing for rebutting the selection of 19 companies out of which 12 has been selected by him. He ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... account the difference, if any, between the international transaction and the comparable uncontrolled transaction or between the enterprises entering into such transaction which could materially effect the amount of net profit margin in the open market. This rule suggests that adjustment required to be made for comparability. Sub-rule (2) of Rule 10B further provides how to judge the comparability of international transaction with uncontrolled transaction. This rule reads as under: (2) For the purposes of sub-rule(2), the comparability of an international transaction with an uncontrolled transaction shall be judged with reference to the following, namely: a) the specific characteristics of the property transferred or services provided in either transaction; b) the functions performed, taking into account asserts employed or to be employed and the risks assumed, by the respective parties to the transactions; c) the contractual terms (whether or not such terms are formal or in writing) of the transactions which lay down explicitly or implicitly how the responsibilities, risks and benefits are to be divided between the respective parties to the transactions; ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the three assessment years as well as in assessment year 2007-08, which is placed in the paper book of the department, we find that learned TPO had made efforts to identify the comparables whose functions performed are similar to the assessee. He has applied the filter, quantitatively as well as qualitatively in eliminating the factors which effect the result of the alleged comparables so that the difference between the operations of assessee as well as such comparables who worked in uncontrolled transactions can be neutralized. The arguments raised by the assessee in assessment year 2006-07 are touching only peripheral aspects. Learned TPO has started investigation quite well in time and has provided sufficient opportunity for giving comments. We have already held that learned TPO has rightly rejected the TP study made by the assessee and proceed to make fresh search. All other arguments made by the assessee in the written submissions as well as addressed before us were in the background of putting the assessee as a low end performer. At every stage, their emphasis was that it is a risk free captive service provider, it cannot be compared with other software development. We do no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o verify this aspect and make necessary corrections in the arithmetic mean of all these comparables. As far as other arguments are concerned, we do not find any force in the contentions of the assessee as well as of revenue for selecting the comparables. 43. The assessees have contended that benefit of proviso appended to section 92C of 5% has not been given to the assessee. 44. With the assistance of learned representatives, we have gone through the record carefully. Learned CIT(Appeals) in assessment year 2003-04 has examined this issue in detail. He observed that in order to avoid hardships to the assessees in the initial years of implementation of the TP provisions, the Government of India, through a prices note issued by the Ministry of Finance on 22nd August 2001 expressed its intention that no adjustment could be made if the transfer price adopted by the assessee was within the band of 5% of the ALP determined by the Assessing Officer. CBDT had issued Circular No.12 on 23.8.2001 specifying that Assessing Officer shall not make any adjustment to the price shown by the assessee if it is within the 5% band, the effect of the Circular was that transfer price shown by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d out in the transfer pricing analysis with the help of a sample set of comparables. There is no scope for any standard deduction under this rule. In other words, if the ALP falls outside the tolerance band, TP adjustment would have to be made for the difference between the ALP determined by the A.O. based on the arithmetical mean of the prices and the price shown by the assessee 45. The contention of the learned counsel for the assessee was that arithmetic mean of the comparable price should be reduced by 5% for determining the ALP. He pointed out that in 2009, the proviso appended to section 92C has been amended but this amendment would be applicable prospectively, because the basis of determination of ALP in respect of international transaction get changed. This amendment effects imposing a new liability by taking the option away from the taxpayers. Thus, according to the learned counsel for the assessee, the amended proviso is not applicable. On the other hand, Learned DR has submitted that under the proviso no standard deduction has been provided to the assessee. 46. On due consideration of the facts and circumstances and perusal of the proviso introduced in 2002 as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re for the period up to two years. There is no enduring benefit accrued to the assessee. It had not acquired any ownership right over that product. The ownership title for the software remained with the vendor and the assessee had only license to use this software. The assessee has relied upon the decision of ITAT in the case of AM WAY India Enterprises Vs. DCIT reported in 111 ITD 113 (Del). Special Bench has laid down various tests which would be helpful for the adjudicating authority to decide whether expense incurred by the assessee is of capital nature or of revenue nature. According to the assessee, the ITAT has basically laid down three tests which are ownership tests, test of enduring benefit and functional tests. If all the three tests are applied on the facts of the assessee then it would reveal that it is a revenue expenditure. The learned counsel for the assessee further relied upon the order of the ITAT rendered in the case of DCIT vs. Mohindra Reality Info. Developers reported in 2011 TIOL 115. On the other hand, Learned DR relied upon the order of the Assessing Officer. 49. We have duly considered the rival contentions and gone through the record carefully. We f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld. Both these pleas have been rejected by the learned DRP. According to the learned DRP, cost of acquisition or cost of improvement can be included for the purpose of indexation while computing the capital gain under sec. 48 of the Act. The charges paid by the assessee to NOIDA Development Authority are neither cost of acquisition or the cost of improvement. Therefore, it cannot be included in the value of assets. 51. Before us, learned counsel for the assessee has pointed out the letter of NOIDA Authority available at pages 666 to 668 of the paper book and submitted that the expenses paid by the assessee be allowed to it. On the other hand, Learned DR relied upon the order of the Assessing Officer. 52. We have duly considered the rival contentions and gone through the record carefully. From the perusal of the letter written by NOIDA Authority, exact nature of charges is not discernible, whether it is paid in lieu of stamp duty for change in name of owner in the revenue record? Learned representative failed to bring the revenue laws of the UP State authorizing the NOIDA Authority for charging such an amount. Assessing Officer has also not examined the issue elaborately. In t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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