TMI Blog2015 (3) TMI 494X X X X Extracts X X X X X X X X Extracts X X X X ..... s so arranged that the business transacted between them produces to the assessee more than the ordinary profits with the intent of abusing tax concession. Quite clearly, in the entire assessment order, there is no whisper of any material or evidence in this regard. We thus conclude, holding that in the present case, the Assessing Officer has not proved that any arrangement had been arrived between the parties which resulted in higher profits. Consequently, the re-working of the profits by Assessing Officer by invoking section 10A r.w.s. 80-IA(10) of the Act is not justified. The action of the Assessing Officer to restrict the deduction u/s 10A of the Act to ₹ 7,74,60,281/- as against the claim of ₹ 36,35,09,382/- is hereby set-aside. Thus, assessee succeeds on this aspect. - Decided in favour of assessee. Transfer pricing adjustment - computation of arm's length price with its associated enterprises in respect of System Integration segment of the assessee - adoption of most appropriate method - Held that:- The objective of adopting the most appropriate method, which in the present case is TNM Method, is to determine the arm's length price of the international tr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... direct the Assessing Officer/TPO to include the said concern in the final set of comparables. - Decided in favour of assessee. - Shri G.S. Pannu And shri R.S. Padvekar JJ. For the : Mr. Percy Pardiwalla Mr. Venkat Raman Iyer For the Respondent : Mr. Ajit Korde ORDER Per G. S. Pannu, AM The captioned appeal has been preferred by the assessee pertaining to the assessment year 2006-07, which is directed against the order of the Dy. Commissioner of Income Tax, Circle 7, Pune (in short the Assessing Officer ) passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (in short the Act ) dated 25.11.2010, which is in conformity with the directions given by the Dispute Resolution Panel, Pune (in short the DRP ) dated 29.09.2010. 2. In this appeal, the Grounds of Appeal raised by the assessee read as under: - Based on the facts and circumstances of the case, Honeywell Automation India Limited (hereinafter referred to as the 'Appellant') respectfully craves leave to prefer an appeal against the order passed by the Deputy Commissioner of Income Tax, Circle - 7 ('AO') in pursuance of the directions issued by Dispute Resolution Panel ('DRP'), Pune, dated 29 Septemb ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 'more than ordinary profits' during the year under appeal; 9. failed to appreciate that the onus is on the Department to prove with substantial evidences that the business of the Appellant is 'arranged' so as to have supernormal profits and mere inferences without substantiating the allegations would not suffice; Computation of operating margins of the Appellant 10. erred in computing the operating margins earned by the Appellant (from its STP operations) without considering travel, and other costs 3 reimbursed by its customers as a part of its operating cost and operating income. Disallowance of provision for expenses amounting to ₹ 17,200,000 11. erred in disallowing the provision in respect of 'C' forms not received and sales tax set off, on the ground that the same are governed by the provisions of section 43B of the Act, without appreciating that the same represented ascertained liability towards claims which may not be available Transfer Pricing adjustment under provisions of Chapter X of the Act in respect of international transactions under the system integration segment of the Appellant, with its Associated Enterprises (hereinafter referred to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Appellant on total transactions (i.e. controlled as well as uncontrolled) instead of applying the shortfall in the margin only to controlled transactions. 3. The substantive dispute in this appeal is manifested by the abovestated Ground of Appeal Nos.2 to 10, which relates to the quantum of deduction allowable to the assessee under the provisions of section 10A of the Act. Although, assessee has raised multiple Grounds of Appeal on this aspect but the sum and substance of the dispute relates to the quantification of deduction allowable to the assessee u/s 10A of the Act with respect to the profits derived from the export of engineering/software services. 4. The appellant-company is, inter-alia, engaged in the export of IT enabled engineering/software services to its associated enterprise abroad as well as to the non-related parties. The services are rendered from three units, which are duly registered with Software Technology Park of India (STPI) authorities. Out of the three units, two of them, namely, STPI-I STPI-II are located at Pune and the third unit is located at Chennai. The profits derived by the aforesaid three units are entitled for deduction u/s 10A of the Act an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ile carrying out the comparability analysis under the TNM Method and therefore according to him, the profits declared by the assessee in the 10A Units were not the ordinary profits and that they should be restricted to the ordinary profits in such business based on the margins of the comparables selected by the assessee itself. The operating profit margin of the comparables was taken by the Assessing Officer at 17.06% after the adjustment directed by the Dispute Resolution Panel (i.e. DRP) and after comparing it with the assessee s margin of 10A Units of 80.06%, the profits in excess of the operating profit margins of the comparables was considered as more than ordinary profits declared by the assessee, which was computed at ₹ 28,60,49,101/-. In this manner, the Assessing Officer determined the ordinary profits, which according to him, was reasonably deemed to have been derived from the business of 10A Units at ₹ 7,74,60,281/- as against ₹ 36,35,09,382/- declared by the assessee. Hence, the deduction u/s 10A of the Act was restricted to ₹ 7,74,60,281/- as against ₹ 36,35,09,382/- based on the operating profit margin of the comparables selected by the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... more than the ordinary profits which might be expected to arise in such eligible business, the Assessing Officer shall, in computing the profits and gains of such eligible business for the purposes of the deduction under this section, take the amount of profits as may be reasonably deemed to have been derived therefrom. 9. Section 10A of the Act is a special provision in respect of newly established undertakings in free trade zone, etc.. Section 10A postulates a deduction of such profits and gains as are derived by an undertaking from the export of articles or things or computer software for a period of ten assessment years beginning with the assessment year relevant to the previous year in which the undertaking begins to manufacture or produce such articles or things or computer software, as the case may be, while computing the total income of an assessee. Shorn of other details, for the present it would suffice to note that the three units of the assessee, namely, Unit No.I II at Pune and Unit at Chennai are recognized as STPI Units in accordance with the Software Technology Park Scheme of the Government of India and they are eligible for the benefits of section 10A of the Act. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... udgement of the Hon ble Karnataka High Court in the case of CIT vs. H.P. Global Soft Ltd., 342 ITR 263, which was referred to in the course of hearing before us. In the case before the Karnataka High Court, the issue was similar inasmuch as therein, the Assessing Officer had invoked the provisions of section 80-I(9) r.w.s. 10A(6) of the Act while re-determining the claim of exemption in terms of the then prevailing section 10A(4) of the Act, and the assessment years were 1995-96 to 1998-99. The provisions of section 10A(6) r.w.s. 80-I(9) of the Act, which were before the Hon ble Karnataka High Court are quite similar to the provisions of section 10A(7) r.w.s. 80-IA(10) of the Act before us. The Hon ble Karnataka High Court, upheld the stand that the requirements of the provisions of section 80-I(9) of the Act are two-fold, namely that there should be a close connection between the assessee and the other person, which may be a reason for the assessee to earn higher profits but, more importantly there should be material to indicate that assessee had indulged in an arrangement with the other person so as to produce to the assessee more profits than ordinarily what profits the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ang.) has also held that the conditions of the section have to be objectively satisfied by the Assessing Officer, based on cogent reasoning and evidence. 12. At the time of hearing, the Ld. Representative for the assessee vehemently argued that the provisions of section 10A(7) r.w.s. 80-IA(10) of the Act are inapplicable in the present case because there is no material lead by the Revenue to say that there was any arrangement between the assessee and the associated enterprises which produced to the assessee more than the ordinary profits within the meaning of section 10A(7) r.w.s. 80-IA(10) of the Act. According to the Ld. Representative, the transactions of the assessee by way of rendering software engineering services to its associated enterprises abroad are not arranged so to yield any extraordinary profits to the assessee. The Ld. Representative pointed out that assessee was charging the same rate for services rendered to associated enterprises as well as to the non-related parties. The details of rates charged by the assessee to the third parties vis- vis the related parties have also been placed in the Paper Book along with sample copies of invoices raised on the and non-rela ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ployees in the course of rendering engineering/software services. Assessee was also reimbursed incidental expenses incurred by it viz. visa costs, work permit costs, etc. and therefore the cost of sales was on lower side, as a result of which the percentage of Operating profit to total cost shows a higher percentage, although the impact on profit remains unaltered. All these points, which were raised before the Assessing Officer, have been reiterated before us to show that the higher profits are not attributable to any arrangement with associated enterprises but due to business reasons. 15. Apart therefrom, it has also been pointed out that assessee is a public limited company listed on the stock-exchange wherein the overseas Honeywell entities owned 81.24% of shareholding and the public shareholding is to the extent of 18.76%. It was pointed out that initially TATA group was also owning shares in the assessee company to the extent of 40% and Honeywell entities held 41% and the balance 19% was held by the public. This pattern had changed from November, 2004 onwards when the TATA group gave up its shareholding in the assessee company. On the basis of the aforesaid shareholding patte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ief or satisfaction as is the case with invoking of section 147/148, etc.. The following portion of section 80-IA(10) of the Act was emphasized ..the Assessing Officer shall, in computing the profits and gains of such eligible business for the purposes of the deduction under this section, take the amount of profits as may be reasonably deemed to have been derived to say that it does not require the Assessing Officer to precisely determine the eligible profits, but only a prima-facie satisfaction about presence of more than the ordinary profits would suffice. It is sought to be emphasized that because of the presence of the words .as may be reasonably deemed to have been derived . in section 80-IA(10) of the Act, a much lighter burden of proof is put on the Assessing Officer for computing tax avoidance. As per the Ld. CIT-DR, similar to the Transfer Pricing Provisions, the said Provision does not require a precise accuracy on the part of the Assessing Officer. At this point, the Ld. CIT-DR relied upon the decision of the Hon ble Kerala High Court in the case of Abdul Vahab P. vs. ACIT, (2012) 249 CTR 102 (Kerala) wherein the word appears has been understood to imply a prima-facie sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o made a submission that even if the computation of excess profits done by the Assessing Officer based on the margin of the comparable is not found to be a good methodology, yet the failure of computation process by the Assessing Officer would not vitiate the invoking section 10A(7) r.w.s. 80-IA(10) of the Act in the present case. The excess profits according to him can be computed by an appropriate method by remanding the matter back to the file of the Assessing Officer. In any case, it has been contended section 80-IA(10) of the Act requires computing of more than ordinary profits in the eligible business. Comparable companies are in the same line of the business and having similar functions performed, assets employed and risks assumed as the assessee, therefore, comparable companies are carrying on eligible business, and thus the profits margin of comparable reflect ordinary profits. 21. With regard to the assessee s plea that even after the expiry of section 10A benefits, assessee was declaring healthy profits, the Ld. CIT-DR pointed out that what matters in future years is the actual amount of the taxes paid and not merely the profits generated in the Unit. It was also contend ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erns or different units of the same concern. [underlined for emphasis by us] 23. Quite clearly, the provisions of section 10A(7) of the Act intend to plug abuse of tax concession by manipulation of profits between associated concerns or between different units of the same concern. The objective of the aforesaid Provision is that the tax concessions are not abused by manipulation of profits. In our considered opinion, the aforesaid explanation in the CBDT Circular (supra) signifies the legislative intent and it is also manifested in the language of section 10A(7) r.w.s. 80-IA(10) of the Act. We say so for the reason that the phraseology of section 80-IA(10) of the Act itself suggests that the profits and gains of an eligible business cannot be tinkered with by the Assessing Officer merely because they are more than the ordinary profits or that they are quite high. The existence of substantial or more than ordinary profits by itself does not sufficiently empower the Assessing Officer to disregard them and determine the profits which he may consider to be reasonably deemed to have been derived therefrom. The presence of the expression the course of business is so arranged . that the b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mean an agreement or an understanding between the parties concerned. The relevant portion of the decision of the Hon ble Bombay High Court has been reproduced in the earlier part of this order, according to which, it is said that the term arrangement in plain language means any agreement or understanding between the parties concerned. On this basis, the Ld. CIT-DR submitted that undeniably there is an agreement between the assessee and the associated enterprises whereby the services have been provided by the assessee to them and therefore the same is to be understood as an arrangement within the meaning of section 10A(7) r.w.s. 80-IA(10) of the Act. Along with the aforesaid, it has also been emphasized, on the basis of the language of section 80-IA(10) of the Act that, the Assessing Officer is not required to be prove that there is an arrangement for producing more than ordinary profits. Whereas, as per the Ld. CIT-DR, section provides that arrangement leading to production of more than ordinary profit will satisfy the necessary condition of section 80-IA(10) of the Act. Thus, according to the Ld. CIT-DR, in the instant case there is an arrangement and it has lead to production of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 391(1), however, in any opinion somewhat restricts this otherwise unlimited import of the term arrangement in so far as the said section applies only to an agreement or understanding between the company and its creditors or any class of them, or between the company and its members or any class of them, or between the company and its members or any class of them, which would necessarily mean that it must be an agreement or understanding which affects their rights [underlined for emphasis by us] 27. The aforesaid clearly points out that the Hon ble High Court imparted meaning to the word arrangement in the context of section 391(1) of the Companies Act, 1956 to mean that it must be an agreement or understanding which affects the rights between the company and its creditors or any class of them and between the company and its members or any class of them. By the same analogy in the present context, we have to understand the meaning of the expression as arranged in section 10A(7) r.w.s. 80-IA(10) of the Act to mean a situation whereby the course of business has been so arranged that the business transacted produces to the assessee more that the ordinary profits with an intent to abuse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appellate authorities. The primary rule of evidence is that what is apparent is real unless proved otherwise by the person alleging it otherwise. The manner of satisfaction outlined in the section should be based on evidence and not on surmise or suspicion. The question is not whether the onus is light or heavy but whether the AO has discussed objectively the conditions mentioned in the section to disturb the results declared by the appellant. In this case, the AO has failed to adduce any evidence or reason to satisfy the invoking of s. 80-1(9). First of all, a mere substantial profit does not give rise to any valid view that there could be any arrangement. It is a case of joint venture listed Indian company, where all arrangements are open for scrutiny and acceptance not only by digital group worldwide but also from joint venture partners and shareholders. Digital group overseas will not pay undue sum, which it cannot recoup entirely to exclusion of others. Hence nothing can be arranged to the exclusive benefit of overseas partner. One cannot presume the existence of close connection or possibility of an arrangement for earning more than ordinary profits. In this case the profits ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t margins of the assessee are substantially higher than the average operating margin of the comparables selected by the assessee in its Transfer Pricing Study. This has formed the basis for the Assessing Officer to say that assessee has earned more than ordinary profits which might be expected to arise in such a business. Be that as it may, the aforesaid is not enough to say that the course of business has been so arranged to result in more than ordinary profits. However, from the side of the Revenue, it was pointed out that the Transfer Pricing comparability analysis itself suggests that the profit margins of the assessee are more than the ordinarily accepted margin in this line of business. The moot question is as to whether the same can be considered as a material to indicate that the course of business between the assessee and the associated enterprises has been so arranged, so as to result in more than the ordinary profits within the meaning of section 10A(7) r.w.s. 80-IA(10) of the Act. In this context, we may refer to the decision of the Chennai Bench of the Tribunal in the case of Visual Graphics Computing Services India (P) Ltd. vs. ACIT, 148 TTJ 621 (Chennai), wherein fol ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... transfer pricing matters and those procedures and rules can be used only for the purpose serving the object of section 92. When the Transfer Pricing Officer states that there is no need of transfer pricing adjustment, the matter should end there and any other adjustment that the Assessing Officer would like to make with reference to the first segment must be made independent of the order of the Transfer Pricing Office under section 92CA. To state in simple terms, the transfer pricing regime is different from regular computation of income. Section 10A belongs to that part of regular computation of income and it should be computed independent of transfer pricing regulations and transfer pricing orders. It is not therefore, permissible for the Assessing Officer to work out section 10A deduction on the basis of arm's length price profit generated out of the order of the Transfer Pricing Officer. In fact these issues have already been considered in various orders of the Tribunal. The Income-tax Appellate Tribunal, Chennai A Bench in the case of Tweezerman (India) P. Ltd. v. Addl. CIT [2010] 4 ITR (Trib) 130 (Chennai) (133 TTJ 308) has considered the matter in detail and held that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erial or evidence in this regard. In-fact, the approach of the Assessing Officer is quite misdirected as the following discussion in his order shows :- Accordingly, the section only encumbers the A.O. to examine if the profits derived from the eligible business by the assessee is more than the ordinary profits, then the A.O. has to arrive as to what could be the reasonable profit from the such eligible business and such profit has to be then taken as reasonably deemed to have been derived from the eligible business for the purposes of computing deduction under the section. 33. The aforesaid discussion in the assessment order reveals that as per the Assessing Officer, the existence of close connection and more than ordinary profits is enough to assume an arrangement as contemplated u/s 80- IA(10) of the Act. The aforesaid understanding, in our view, is directly contrary to the judgement of the Hon ble Karnataka High Court in the case of H.P. Global Soft Ltd. (supra) and our discussion in the earlier part of this order. 34. In view of the aforesaid, we conclude by holding that in the present case, the Assessing Officer has not proved that any arrangement had been arrived between the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated by section 92(1) of the Act. In its Transfer Pricing Study, assessee segregated the international transactions in three heads, namely, Distribution Segment; Software Engineering Services Segment; and, System Integration Segment. In order to determine the arm's length price in all the three categories, assessee adopted the Transactional Net Margin (TNM) Method as the most appropriate method. As per the Transfer Pricing Study, the assertion of the assessee was that the entire set of international transactions entered with the associated enterprises were at an arm's length price and that no adjustment was required to be made to the stated value of the international transactions. The Assessing Officer had made a reference to the Transfer Pricing Officer (in short TPO ) u/s 92CA(1) of the Act for computing of arm's length price in relation to the international transactions carried out by the assessee with its associated enterprises. The TPO has passed an order u/s 92CA(3) dated 12.10.2009 determining the arm's length price of the international transactions entered by the assessee with its associated enterprises. So far as the segments of Distribution and Software En ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that international transaction pertaining to the Manufacturing System Segment was at an arm's length price. 41. Now, with respect to the IS-Infra segment, assessee canvassed that the said segment was functionally different from the Manufacturing Systems Segment. Therefore, the activities of IS-Infra were analyzed and benchmarked separately. In the IS-Infra segment, assessee had computed a loss which was sought to be justified on the basis of various economic and commercial reasons viz. Technological inefficiency, Operating failures, and other marketing and administrative failures. The stand of the assessee was that the said segment of business was not the traditional business of the Honeywell Group. The functionally different nature of business, the relative newness of the business of the said segment coupled with the economic and commercial reasons for the losses, was canvassed to be the key reasons for which it was considered appropriate to evaluate the IS-Infra segment separately. On the basis of the above explanation, it was contended that pricing of the international transactions pertaining to the IS-Infra segment were consistent with the arm's length price. 42. Anoth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee, the TPO observed that the combined operating profit to gross sales in respect of the combined System Integration segment was 3.89% and for the individual segments i.e. IS-Infra and Manufacturing System segment it stood at (-) 22.86% and 4.69% respectively. Moreover, the TPO considered the operating margins of the comparable companies considering their financial data only for the financial year 2005-06 as it pertained to the year under consideration as against assessee s stand in the Transfer Pricing Study of adopting multiple year s financial data of the comparable companies. This aspect of the matter is not in dispute before us, and we do not dwell further on this. Be that as it may, in the combined System Integration segment, the TPO considered the operating margins of the comparable companies before and after making adjustments for the bad debts, which as under :- Systems Integration Segment Sr. No. Dataflag Name of the Company OP/Sales(Before bad debts adjustment) Adjusted OP/Sales (After bad debts adjustment) 1. Prowess Aplab Limited 10.07% 11.13% 2. Prowess Ador Powertron Limited 11.93% 11.93% 3. Prowess Hindustan Dorr-Oliver Ltd. 5.55% 5.55% 4. Prowess Raunaq Internation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpared it with the operating margin of the assessee at 3.89% relating to the System Integration segment as a whole including IS-Infra. As a consequence, the TPO computed the adjustment of ₹ 22,90,17,412/- that was required to be made to the value of the international transactions grouped under the System Integration segment inclusive of IS-Infra segment, in order to bring it to the level of arm's length price. The concluding para of the order of the TPO reads as under :- [22] In view of the facts of the case, deliberation as above the so called two segments of the assessee i.e. Manufacturing Segment and IS-Infra Segment is clubbed together for the purposes of this analysis. Further the PLI adopted is profit over the sales and not the adjusted profit over the sales as submitted by the assessee and the set of comparables is adopted as given in the show cause notice with the mean operating profit to sales of two comparables at 9.87% against the operating profit margin of the assessee at 3.89%. Considering the above, an adjustment as worked out under is necessary to be made to the total income of the company so that the international transactions grouped under the Systems Int ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... associated enterprises and not on the total value of the transaction in the System Integration segment which included transactions with non-related parties also. 50. The Ld. CIT-DR has contested the plea of the assessee by pointing out that under the TNM Method the profitability of the assessee s System Integration segment has been compared vis- -vis the profitability of the comparables at the segmental level and therefore the shortfall in the margin was required to be applied to total transactions including those with nonrelated parties in order to determine the Transfer Pricing adjustment. 51. On this aspect, in the earlier part of this order, we have reproduced the conclusion of the TPO as well as the manner in which he has computed the adjustment of ₹ 22,90,17,412/-, which according to him is required to be made to the international transactions of System Integration segment of the assessee in order to be bring it to the level of arm's length price. Pertinently, the mean operating profit of the comparables was deduced at 9.87% and the operating margin of the assessee s System Integration segment was adopted at 3.89%. The shortfall between the mean operating margin of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dustan Dorr-Oliver Ltd. from the final set of comparables. On this aspect, we find that in terms of the discussion in the para 3.4.2 of the show-cause notice dated 18.06.2009 issued by the TPO, the said concern has been excluded on the ground that it has not incurred any bad debts. As noted by us earlier, the TPO has observed that operating margins of certain companies did not change before and after the bad debts adjustments, which indicated that such concerns did not have any bad debts at all. Since assessee had incurred bad debts, the TPO considered only those concerns as comparables who had incurred bad debts and thereby excluded such concerns from the list of comparables which did not have any bad debts at all. Hindustan Dorr-Oliver Ltd. was excluded from the list of comparables by the TPO on this count. 54. Though the Ld. Representative for the assessee contended that the action of the TPO was unjustified in-principle, so however, it is pointed out that by applying the filter adopted by the TPO himself, the said concern could not have been excluded from the list of comparables as it had incurred bad debts related expenditure. In this context, the Ld. Representative for the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ustment is restricted to the transactions with associated enterprises alone and Hindustan Dorr-Oliver Ltd. is included as a comparable in the final set of comparables and also without making adjustment for the bad debts, etc. the value of international transactions of the assessee falls within +/- 5% range of the mean operating margins of the comparables, and therefore in terms of section 92C(2) of the Act no adjustment would be required to be made to the stated value of the international transactions with associated enterprises. Since the appellant has succeeded on the aspect of restricting the adjustment to the international transactions alone and also on the inclusion of Hindustan Dorr-Oliver Ltd. as a comparable, the other Grounds of Appeal on the aspect of the Transfer Pricing adjustment are rendered academic and are not being adjudicated for the present. Thus, on the Ground of Appeal Nos.12 to 17 assessee partly succeeds. 57. The Ground of Appeal No.11 is relating to disallowance of Provision for expenses amounting to ₹ 1,72,00,000/-, which has not been pressed at the time of hearing and is accordingly dismissed. 58. In the result, the appeal of the assessee is partly a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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