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TMI Blog2019 (10) TMI 192X X X X Extracts X X X X X X X X Extracts X X X X ..... ral justice. Without prejudice to the above, the order issued by the AO is bad in law insofar as the fact that the AO did not issue to Telelogic India Private Limited (`the Appellant or 'the Company'), a show cause notice, as per proviso to section 92C(3) of the Income-tax Act, 1961 ['the Act']. c) The AO has erred in law in making a reference to the Deputy Commissioner of Income Tax - Transfer Pricing - V [`TP0'], inter alia, since he has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. The AO also erred in not following the provision contained in section 92CA (1) of the Act. 2.The fresh comparable search undertaken by the TPO is bad in law. a) The AO/TPO erred on facts and in law in conducting fresh benchmarking analysis using non contemporaneous data and substituting the Appellant's analysis with fresh benchmarking analysis on his own conjectures and surmises. Thus the Appellant prays that the fresh benchmarking analysis conducted by the learned TPO is liable to be quashed. b) On the facts and in the circumstances of the case and in law, the learned TPO erred in not demonstratin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . data which was not available in public domain, in arriving at a fresh set of companies using his power under section 133(6), which is grossly unjustified. l) The AO/TPO also erred on facts and in law in excluding the foreign exchange gain or loss while calculating the net margins of the comparable companies. 4. Erroneous data used by the AO/TPO a) The AO/TPO has erred in law in using data, which was not contemporaneous and which was not available in the public domain at the time of conducting the transfer pricing study by the Appellant. b) The AO/TPO erred in law in not applying the multiple-year data while computing the margin of alleged comparable companies as such data had an influence in determining the pricing policy of the Appellant. 5. Non-allowance of appropriate adjustments to the comparable companies, by the AO/TPO The AO/TPO erred in law and on facts in not allowing appropriate adjustments under Rule10B to account for, inter alia, differences in (a) accounting practices, (b) marketing expenditure, (c) research and development expenditure and (d) risk profile between the Appellant and the comparable companies. 6. Variation of 5% from the arithmetic mean ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in this regard. 11 Non issue of refund The learned AO has erred in considering that refund of Rs. 1,120,000 has been issued to t Appellant under section 143(1) of the Act when no such refund has been issued to the Appellant inspite of clear directions of the Hon'ble DRP in this regard 12 Interest under section 234B of the Act. The learned AO has erred in levying interest under section 234B of the Act amounting to Rs. 2,049,088. 13 Interest under section 234D of the Act. The learned AO has erred in levying interest under section 234D of the Act amounting to Rs. 173,600 where no refund has been issued to the Appellant. 14 Penalty under section 271(1)(C) The learned AO has erred in initiating penalty proceedings under section 271(1)(c) of the Act. 15 Directions issued by the Honorable Dispute Resolution Panel (DRP). a) The Honorable DRP has erred in law and on facts in not taking cognizance of the objections filed by the Appellant in relation to the draft assessment order/TP Order issued by the AO/ TPO in the proceedings before them. b) The Honorable DRP erred in facts and in law in confirming the draft assessment order of the AO. 16 Relief a) The Appella ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5,91,07,951/- 4. International telemarketing 1,18,03,842/- 5. Rendering of software development services 14,13,65,683/- 6. Reimbursement of expenses 12,87,191/- 7. Recovery of expenses 2,00,07,085/- Ld.AR submitted that except for software development services and ITES services rendered to AE all other transactions have been held to be at arms length price by Ld. TPO. From TP study is observed that assessee had used TNMM as the most appropriate method by using OP/OC as PLI for computing net margin of assessee. Ld.AR submitted that in the above table, transactions at Serial No.2, 3 and 4 pertains to ITES segment and transaction at Serial No.5 pertains to software development service segment. 3. ITeS Segment: He submitted that under ITES segment, assessee has earned margin of 13.22% as against following 23 comparables selected by assessee which had an average margin of 13.08%. Sl.No. Name of the company 1 Allsec Technologies Ltd., 2 Ask me Info Hubs Ltd., 3 B2 K Corp.Pvt.Ltd. 4 BNR Udyog Ltd 5 CMC Limited., 6 Cosmic Global Ltd. 7 Datamatics Technologies Ltd., 8 Firstsources Solutons Ltd. 9 Fortune Infotech Ltd., 10 Galaxy Com ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee Consulting Ltd. (SWD Seg.), 6 BT TechNet Ltd., 7 C M C Ltd., 8 Computech International Ltd., 9 Essel Software & Services Ltd., 10 Exensys Software Solutions Ltd., 11 FCS Software Solutions Ltd., 12 Geomeric Software SolutinsCo.Ltd., 13 Goldstone Technologies Ltd., 14 HCL Technologies Ltd., 15 Helios & Matheson Information Technology Ltd., 16 Hexaware Technologies Ltd., 17 ICSA (India) Ltd., 18 Infosys Technologies Ltd., 19 Infotech Enteprises Ltd 20 Intertec Communications Ltd., 21 KALS Information Systems Ltd., 22 KPIT Cummins Infosystem Ltd., 23 Lanco Global Systems Ltd., 24 Larsen & Toubro Infotech Ltd., 25 Maars Software International Ltd., 26 Mascon Global Ltd 27 Meltar Information Technologies Ltd., 28 Mphasis Ltd., 29 Nav-Parva Technologies Pvt.Ltd., 30 Orient Information Technology Ltd., 31 PSI Data Systems Ltd., 32 Patni Computer systems Ltd., 33 Powersoft Global Solutions Ltd., 34 Prithvi Information Solutions Ltd., 35 R S Software (India) Ltd., 36 R Systems International Ltd., 37 Ramco Systems Ltd., 38 Saksoft Ltd., 39 SQL Star International Ltd., 40 Sasken Communic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... segment DRP did not direct for adjustment on depreciation. 4.1 Upon receipt of DRP directions, assessing officer passed final assessment order by making an addition in the hands of assessee as under: Net Profit of STP Unit 2,76,11,149 Addition under the head non-deduction of Tax at source as discussed in para-9.1 to 9.5 2,15,579 Assessed Net Profit of 10A unit 2,78,26,728 Less:10A deduction 2,69,82,007 Taxable Income 8,44,721 Loss of Non-10A Unit (-)43,26,551 Addition under the head Transfer Pricing 2,77,23,017 Assessed Income of Non-STP 2,33,96,466 Computation of Total Income Taxable Income of STP 8,44,721 Assessed Income of Non-STP 2,33,96 Assessed Income 2,42,41,187 Computation of Tax Assessed Income 2,42,41,187 Tax thereon @30% 72,72,356 Surcharge @10% 7,27,235 Education Cess @2% 1,59,992 Net Tax 81,59,583 Less:TDS 22,80,801 Balance Payable 58,78,782 Add: Interest u/s 234B 10,00,000 Total 48,78,782 Add: Refund issued u/s 143(1) 11,20,000 Add: Interest u/s 234B 1,73,600 Total Balance Payable 82,21,470 Ld.AR further submitted that assessing officer while passin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on facts available in the public domain. The Appellant humbly prays that the additional ground be admitted and adjudicated along with the other grounds of appeal in the course of hearing of the appeal. It has been submitted that assessee missed to allege certain comparables under software development service segment and ITES segment for exclusion, while filing the appeal before this Tribunal. It has been submitted that these comparables were agitated before DRP however DRP failed to appreciate contentions raised by assessee. Placing reliance upon decision of Hon'ble Supreme Court in case of NTPC Ltd vs CIT reported in 229 ITR 383 and Jute Corporation of India vs CIT reported in 53 taxman 85, submitted that comparables specified in additional grounds may be admitted. Ld.CIT DR, though opposed admission of additional ground, could not controvert submissions advance by Ld.AR. 6. We have perused details relied upon by both sides In our considered opinion the comparables alleged in additional ground arises out of the records and was objected before DRP for its exclusion/inclusion. Considering inadvertent mistake on behalf of assessee in raising these grounds before this Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eged comparables for exclusion by assessee. 8. Apollo Healthstreet Ltd., Asit C Mehta Financial Services Ltd., and Informed Technologies Ltd. It has been submitted by Ld.AR that, these comparables fail RPT filter, being less than 15%. In support of his contention placed reliance on following decisions of this Tribunal: * M/s Poll to Win India Pvt.Ltd. vs DCIT reported in IT(TP)A No. 1053/Bang/2011; * M/s Tesco Hindustan Services Centers Pvt.Ltd. vs DCIT in ITA No. 1285/Bang/2011; * M/s Magma Design Automation India Pvt.Ltd. vs ACIT in ITA No.1241/Bang/2011; * First Advantage Offshore Services Pvt.Ltd. vs DCIT in ITA No. 1086/Bang/2011; On the contrary, Ld.CIT DR relying upon Rule 10 B (4) of Income tax Rules, submitted that in; * Microelectronics Ltd., reported in 87 Taxmann.com 262; * Triology E-business Software, reported in 29 Taxmann.com 310 * Sendute India Ltd., In ITA (TP) A 59/Bang/2016 vide order dated 07/07/17; this Tribunal held that, merely because in decisions passed by this Tribunal in various cases, excludes certain comparables alleged by assessee, does not mean that it is excludable in present case too. 9. We have perused submissions advanced by bo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d also be excluded from the list of comparable companies. DRP rejected assessee's contentions without assigning any reason. Ld.AR placed reliance on decision of co-ordinate bench of this Tribunal in the case of Genisys Integrating Systems (India) (P.) Ltd. (supra), wherein it was held that when there is a limit for the lower end for identifying the comparable companies, there is no reason why there should not be an upper turnover limit also, as size matters in business. Ld.AR submitted that co-ordinate bench of this Tribunal in the case of Dell International Services India (P.) Ltd. v. Dy. CIT reported in [2018] 89 taxmann.com 44 for Assessment Year 2005-06 considered various aspects of application of turnover filter for excluding companies and observed that first decision rendered on application of this filter was in case of Genisys Integrating Systems (India) (P.) Ltd. (supra). Further, in case of Dell International Services India Pvt. Ltd. (supra), co-ordinate bench of this Tribunal discussed apparent divergent view of two non-jurisdictional High Courts and also decision of this Tribunal in the case of Sysarris Software (P.) Ltd. v. Dy. CIT reported in [2016] 67 taxmann.com 243 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Now coming to comparables alleged to be functionally not similar with assessee. We shall analyse each of them, having regards to annual reports of comparables placed before us. a) Accentia Technologies Ltd., This company has been selected by Ld.TPO into the list of comparables. Ld.Counsel submitted that during the year under consideration Geo-Soft Technologies (Trivandrum) Ltd. and Iridium Technologies India Pvt. Ltd amalgamated with Accentia resulting in abnormal rise in profits. It has been submitted that Delhi benches in case of Ciena India Pvt.Ltd vs. DCIT reported in (2015) 57 Taxmann.com 329 and ICC India Pvt.Ltd versus DCIT reported in (2016) 71 Taxmann.com 164 as well as Mumbai bench in Petro Araldite Pvt.Ltd vs DCIT reported in 31 Taxmann.com 281, has held that a company cannot be considered as comparable because of financial results become distorted due to mergers, demergers etc. It has been submitted that similar view has also been taken by Delhi bench in case of Toluna India Pvt.Ltd vs. ACIT reported in (2014) 50 Taxmann.com 24. Due to the amalgamation of companies into Accentia during the year in question it may not be comparable with assessee. Ld.DR on the contra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... network management are BPO services using technology but these services are not categorized as KPO. He held that a call centre may offer support services, like telemarketing to high end services like technical support services, where not only the level of knowledge, skill required would be high, but the technical knowledge as well would be high. According to him, back office transaction process services may he as remarkable and as complicated as insurance/market transaction processing services. He, therefore, rejected the contention of the assessee and treated the 131 'O as equivalent to KPO services. 40. We have to now consider whether a BPO and a KPO are functionally similar and are comparable to each, other. BPO is a subset if, outscoring arid involves the contracting of the operations and responsibilities of specific business functions or process to a third party services provider. Often business processes outsourcing are information technology based and referred to as ITES-BPO, KPO is one of the sub-segment of the BPO industry. It involves outsourcing of core information related business activities which are competitively important or form an integral part of a company&# ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by both sides and observed that it is into software development and data cleansing segment. It has been categorised to have only one segment being software development and is engaged in providing open and end- to-end web solutions, software consultancy, design and development of solutions using the latest technologies. We therefore do not find this company to be comparable with that of assessee and direct Ld.TPO to exclude this from list of comparables. d).Eclerx services Ltd., This comparable was included by Ld.TPO, as it is providing knowledge-based specialised services. It has been submitted by Ld.Counsel that Hon'ble Delhi High Court in the case of Rampgreen Solutions Pvt. Ltd., vs. CIT reported in (2015) 377 ITR 533 has held that KPO segment cannot be compared with ITES segment. Hon'ble Court has held Eclerx to be a KPO, whereas present assessee is a captive service provider. Ld.DR submitted that functions performed by assessee is also KPO and therefore is a fit comparable. We have perused submissions advanced by both sides in light of records placed before us. It is observed this company is engaged in providing high-level services involving specialised knowledge and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ufacturing. It is claimed to be engaged in providing solutions that do not just reduce cost, but help the clients increase sales and reduce risk by enhancing efficiencies and by providing valuable insights that empower better decisions. M/s eClerx Services Pvt. Ltd. is also claimed to have a scalable delivery model and solutions offered that include data analytics, operations management, audits and reconciliation, metrics management and reporting services. It also provides tailored process outsourcing and management services along with a multitude of data aggregation, mining and maintenance services. It is claimed that the company has a team dedicated to developing automation tools to support service delivery. These software automation tools increase productivity, allowing customers to benefit from further cost saving and output gains with better control over quality. Keeping in view the nature of services rendered by M/s eClerx Services Pvt. Ltd. and its functional profile, we are of the view that this company is also mainly engaged in providing high-end services involving specialized knowledge and domain expertise in the field and the same cannot be compared with the assessee c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 taxman.com 164. Respectfully following the same, we direct this comparable to be excluded from the list of comparables. f) Caliber Point Business Solutions Ltd., Regarding Caliber Pint Business Solutions Ltd., co-ordinate bench (Mumbai) of Tribunal in case of Stream International Services (P.) Ltd. v. Asstt. CIT reported in [2015] 53 taxmann.com 19 held: " (x) Caliber Point Business Solutions Ltd.:- At the outset, the ld. Counsel for the assessee stated that this company deserves to be rejected as the related party transaction is more than 25% which is a filter adopted by the TPO himself. We find that the DRP has not considered this objection because it was of the opinion that related party transaction is mainly for reimbursements and recoveries and therefore would not affect the company. We find that an identical issue came up before the Tribunal in assessee's own case in A.Y. 2006-07 in ITA No. 8997/Mum/2010 wherein the Tribunal has rejected this contention of the Department. The Tribunal at para 13 of its order has observed that "A pure reimbursement of expenses by one AE to another AE is very much a 'transaction' as per section 92F(v) and consequently is equa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns India (P.) Ltd. (supra). Therefore, we direct the AO/TPO to exclude these companies form the list of comparables. Before us nothing contrary to the above findings has been brought on record by revenue. Ld. DR do not have any objection in exclusion of this comparable. Respectfully following the same, we therefore direct Ld.TPO to exclude these comparables from final list. h) I Services India Pvt. Ltd, Assessee seeks exclusion of I Services India Pvt. Ltd, on ground that complete data is not available. Reliance was placed on decision in case of e4e Business Solutions India (P.) Ltd. (supra) wherein it has been held: "30. The assessee has not raised any specific ground on adopting this company as a comparable before the DRP. Before us, the learned counsel for the assessee has submitted that the TPO did not furnish the information obtained from this company in exercise of his powers u/s. 133(6) of the Act. It was further pointed out that even as per the TPO, the annual report of this company for F. Y. 2006-07 was not available. The TPO has gone by the data available on capita line data base. The learned counsel for the assessee therefore made a prayer that the question of con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the facts of present assessee before us, services are rendered to group concerns, strictly on the basis of contract and requirement of its AE. And therefore this company cannot be comparable with the functions performed by present assessee before us. Accordingly we direct this company to be excluded from the list of comparables. j) Accurate Data Converters Ltd Assessee objected for exclusion of this comparable for the reason that it is functionally with that of assessee and financial data are not available in the database. It is also been submitted that it this company fails employee cost filter applied by Ld. TPO. It has been submitted that this comparable has reported employee cost at 1.61% which shows a different business model. Ld.ARfurther submitted that this company outsources its business and provides software development services. On the other hand Ld. DR placed reliance upon orders of authorities below. We have perused submissions advanced by both sides in the light of records placed before us. Ld.AR placed reliance upon decision of coordinate bench of this Tribunal in case of Siemens information processing services (P) Ltd vs DCIT reported in (2016) 71 Taxmann.com ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d that assessee is engaged in business of selling licenses for use of software applications developed by its parent and group companies. Under software development segment assessee renders services in the domain of requirement management, business process management and enterprise architecture. Global service agreement entered into by assessee with its AE dated 15/02/06 placed at page 409 of paper book reveals that assessee under software development service segment has to support its AE by developing, testing, supporting, maintaining of internal Telelogic tools like MOVEX,AXAPTA, TST etc. it has been submitted that assessee is remunerated on a cost plus basis for its software development services and the cost incurred by assessee is also compensated on any rework on deliverables. b) Risks assumed from TP study it is observed that assessee do not bear any contract risk, credit risk, market risk, quality risk. Only risk assumed by assessee is in respect of foreign exchange fluctuation risk as the invoicing is done in foreign currency and employee risk as assessee is responsible for recruitment and retention of personal in its organisation. c) Assets employed: Assessee does not ow ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed that reasons given by authorities below for exclusion of companies with low turnover was that, such companies do not reflect industry trends, as their low cost to sales ratio made their results unreliable. Contention of assessee was that there would be effect on profitability whenever there is high or low turnover and therefore companies with high turnover should also be excluded from the list of comparable companies. DRP rejected assessee's contentions without assigning any reason. Ld.AR placed reliance on decision of co-ordinate bench of this Tribunal in the case of Genisys Integrating Systems (India) (P.) Ltd. (supra), wherein it was held that when there is a limit for the lower end for identifying the comparable companies, there is no reason why there should not be an upper turnover limit also, as size matters in business. Ld.AR submitted that co-ordinate bench of this Tribunal in the case of Dell International Services India (P.) Ltd. v. Dy. CIT reported in [2018] 89 taxmann.com 44 for Assessment Year 2005-06 considered various aspects of application of turnover filter for excluding companies and observed that first decision rendered on application of this filter was in ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lude identical comparables by applying turnover filter, wherein all the decisions relied upon by Ld. CIT DR has been considered and dealt with. Therefore, respectfully following above decisions, we direct Ld.TPO to exclude Flextronics Software Systems Ltd., iGate Global Solutions Ltd., Infosys Technologies., Mindtree Ltd.,Persistent Systems Ltd., Sasken Communications Technologies Ltd (seg.)., Tata Elxsi Ltd., Wipro Ltd (seg.) from final list as they fail turnover filter of 1-200 Crores. B. Ld.AR submitted that Geometric Ltd (seg) is to be excluded as related party transaction of this comparable is more than 15%. Geometric Ltd (seg): It has been alledged by Ld.AR that this company fail in RPT filter of less that 15%, as applied by Ld.TPO. It has been submitted that the range of RPT filter generally accepted by coordinate benches of this tribunal is 5% to 25%. Ld.AR placed reliance upon decision of coordinate bench of this tribunal in case of M/s novel software development (India) private limited vs DCIT in ITA (TP) A No. 1287/Bang/2011 for assessment year 2007-08 for exclusion of this comparable. C. Ld. DR placed reliance upon orders of authorities below. 15. We have peruse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sis Ltd. vs.ACIT reported in (2017) 83 taxmann.com 362, First Advantage Offshore Services Pvt.Ltd. Vs DCIT in IT(TP) A No. 1086/Bang/2011. It is observed that this comparable has been excluded for aforastated reasons by this Tribunal in case of Capgemini India (F) Ltd. Vs ACIT reported in 12 taxman.com 51, where assessee was captive software developer. Accepting argument of Ld.AR, we hold that aforesaid company should be excluded as comparables. Respectfully following decisions of this Tribunal in similar set of facts, these companies are directed to be excluded from list of comparables. a) Avani Cimcon Technologies Ltd. It has been submitted that this company is functionally different from the assessee. Based on the information available in company's website, it has been submitted that this company developed a software product by name "DXchange". It was also submitted that this company has revenue from software product sales, apart from rendering of software services for which segmental information is not available. It has therefore been submitted that this company is functionally different from assessee. It was further submitted that Mumbai Bench of Tribunal in case of Telcord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Addl. CIT - ITA No.6623/Mum/2011 (for AY 2007-08) in which comparability of this company for clinical trial research segment. The Company has developed a drug design tool "CELSUITE" to find lead molecules for drug discovery and has patented the same. It has observed that this Company developed molecule to treat Leucoderma and multiple cancer which is also protected under IPR by filing patent. It is observed that this company is planning to set up biotechnology facility to manufacture industrial enzymes, which include research laboratories for carrying out further R & D activities to develop new drug molecules and license them to Interested Pharma and Bio Companies across the GLOBE. It is thus observed that this company is into diversified activities and therefore cannot be considered as functionally comparable with Assessee who is a captive service provider. It was thus submitted that, this company is not into software development activities, accordingly, this company should be rejected as comparable being functionally different. Ld.DR, on the other hand, relied on order of Ld.TPO. 18. We have considered submissions advanced by both sides and perused records placed before us. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m the website of the company to establish that it is engaged in providing of I T enabled services and that the said company is into development of software products, etc. All these aspects have not been factually rebutted and, in our view, the said concern is liable to be excluded from the final set of comparables, and thus on this aspect, assessee succeeds. Based on all the above, it was submitted on behalf of the assessee that KALS Information Systems Limited should be rejected as a comparable." Ld.DR, on the other hand, relied on order of Ld.TPO. 19. We have considered submissions advanced by both sides and perused records placed before us. We find that Ld.TPO concluded on basis of information obtained by issue of notice u/s.133(6) of the Act. This information which was not available in public domain could not have been used by Ld.TPO, when the same is contrary to annual report of this company as highlighted by Ld.AR. We also find that in the decision referred to by Ld.AR, of this Tribunal held that this company was developing software products and not purely or mainly software development service provider. We therefore accept the plea of the Assessee that this company is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... No. 5/2002 dated 08/08/95 wherein it has been very clearly mentioned that the rooms hired on regular basis are liable for TDS. Ld.AR submitted that in the present case the payments have been made for conducting seminars and companies annual Day celebrations and the hotels had not earmarked any room at a specific rate. He also submitted that the hotels were under no legal obligation to provide the rooms and the rooms were hired for a maximum period of 3 days on regular basis. On the contrary, Ld.DR, placed reliance upon orders passed by authorities below. 22. We have perused the submissions advanced by both sides in the light of the records placed before us. It is observed that the occupancy of the rooms in Golden Palm hotels was occasional and was taken on regular basis. Further the expenditure was incurred by assessee for the purposes of business on which TDS is not liable to be deducted. Accordingly we delete addition made by Ld.AO. In the result this ground raised by assessee stands allowed. 23. Ground No. 10 has been raised by assessee for shortfall in TDs credit granted. It has been submitted that assessee is eligible for credit of tax amounting to Rs. 23,24,487/-wherea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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