TMI Blog2019 (2) TMI 2062X X X X Extracts X X X X X X X X Extracts X X X X ..... findings, since the operating margins of the assessee are in excess of the selected comparable companies, no adjustment is warranted. TP adjustment - Arm s Length rate for international transaction of payment of royalty at 3.5% as against royalty paid @ 5% by the assessee - HELD THAT:- As decided in assessee own case [ 2019 (1) TMI 1567 - ITAT DELHI ] we direct the TPO to determine the Arm s length royalty @ 4.05%. Ground No. 5 is partly allowed. International transaction of allocation of Asia Regional Head Quarters expenses allegedly holding that no specific services were received by the assessee in consideration for such payments - HELD THAT:- As decided own case [ 2019 (1) TMI 1567 - ITAT DELHI ] the adjustment computed by the TPO/DRP on account of allocation of RHQ expenses is uncalled for and deserves to be deleted. TP adjustment in respect of service warrantee charges received by the assessee by applying margin of 26% on such reimbursement - HELD THAT:- The assessee is not acting as an agent or a service provider for the associated enterprise but is seeking reimbursement of the actual cost incurred by it. While making payment for third-party costs for se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... we direct the Assessing Officer to treat royalty payment as revenue expenditure. Deduction claimed by the assessee u/s 80JJAA - HELD THAT:- An identical issue was considered and decided by the Tribunal in assessee s own case in [ 2019 (1) TMI 1567 - ITAT DELHI ] direct the Assessing Officer to allow claim of deduction u/s 80JJAA of the Act as claimed by the assessee. Charging of interest u/s 234B, 234C and 234D - HELD THAT:- Levy of interest is mandatory, though consequential to our decision. The Assessing Officer is directed to levy interest as per the provisions of the law. Interest u/s 234C to be charged on the returned income. Error in granting benefit of advance tax / self assessment tax/TDS credited - HELD THAT:- We find that there is some error in granting tax credit to the assessee in respect of advance tax, self assessment tax and TDS. We direct the Assessing Officer to give credit to the assessee after verifying the tax challan /TDS certificates. Grounds are allowed for statistical purposes. - ITA No.953/DEL/2014 - - - Dated:- 15-2-2019 - SHRI N. K. BILLAIYA, ACCOUNTANT MEMBER, AND MS. SUCHITRA KAMBLE, JUDICIAL MEMBER Appellant by: Sh. Ajay Voh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itably compensated by the associated enterprise. The TPO, accordingly, compared the AMP expenditure incurred by the assessee as percentage of turnover at 9.21% with average AMP expenditure/sales ratio of 2.98% of the following comparable companies: Name of company AMP/sales Allied Photographics India Ltd 0.49% HCL Info Systems Ltd. 0.48% Home Solutions Retail (India) Ltd 5.30% Infinity Retail Ltd 4.71% Vivek Ltd 3.96% Arithmetic Mean 2.98% 6. The TPO further charged mark up of 15.46% and, accordingly, made adjustment of Rs. 5,37,59,29,670/- on account of the alleged brand building activity undertaken by the assessee for the AE, as under: Computation of TP adjustment Rs. Value of sales 9246,37,05,303 AMP / Sales of the comparables 2.98% Amount that represents b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at para 120 held as under: 120. Notwithstanding the above position, the argument of the Revenue goes beyond adequate and fair compensation and the ratio of the majority decision mandates that in each case where an Indian subsidiary of a foreign AE incurs AMP expenditure should be subjected to the bright line test on the basis of comparables mentioned in paragraph 17.4. Any excess expenditure beyond the bright line should be regarded as a separate international transaction of brand building. Such a broad-brush universal approach is unwarranted and would amount to judicial legislation. During the course of arguments, it was accepted by the Revenue that the TPOs/Assessing Officers have universally applied bright line test to decipher and compute value of international transaction and thereafter applied Cost Plus Method or Cost Method to compute the arm s length price. The said approach is not mandated and stipulated in the Act or the Rules. The list of parameters for ascertaining the comparables for applying bright line test in paragraph 17.4 and, thereafter, the assertion in paragraph 17.6 that comparison can be only made by choosing comparable of domestic cases not using any ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed that with the decision in Sony Ericsson having disapproved of BLT as a legitimate means of determining the ALP of an international transaction involving AMP expenses, the very basis of the Revenue's case is negated. XXX 51. The result of the above discussion is that in the considered view of the Court the Revenue has failed to demonstrate the existence of an international transaction only on account of the quantum of AMP expenditure by MSIL. Secondly, the Court is of the view that the decision in Sony Ericsson holding that there is an international transaction as a result of the AMP expenses cannot be held to have answered the issue as far as the present Assessee MSIL is concerned since finding in Sony Ericsson to the above effect is in the context of those Assessees whose cases have been disposed of by that judgment and who did not dispute the existence of an international transaction regarding AMP expenses. XXX 60. As far as clause (a) is concerned, SMC is a non-resident. It has, since 2002, a substantial share holding in MSIL and can, therefore, be construed to be a non-resident AE of MSIL. While it does have a number of 'transactions' with M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s that where the price is something other than what would be paid or charged by one entity from another in uncontrolled situations then that would be the ALP. The Court does not see this as a machinery provision particularly in light of the fact that the BLT has been expressly negatived by the Court in Sony Ericsson. Therefore, the existence of an international transaction will have to be established de hors the BLT. 14. In the light of the aforesaid finding of the Hon'ble High Court, before embarking upon a benchmarking analysis, the Revenue needs to demonstrate on the basis of tangible material or evidence that there exists an international transaction between the assessee and the AE. Needless to mention, that the existence of such a transaction cannot be a matter of inference. 15. The Hon'ble Delhi High Court in case of Whirlpool of India Ltd vs DCIT 381 ITR 154 has held that there should be some tangible evidence on record to demonstrate that there exists an international transaction in relation with incurring of AMP expenses for development of brand owned by the AE. In our considered opinion, in the absence of such demonstration, there is no question of un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on in the Act to bring an international transaction involving AMP expense under the tax radar. In the absence of any clear statutory provision giving guidance as to how the existence of an international transaction involving AMP expense, in the absence of an express agreement in that behalf, should be ascertained and further how the ALP of such a transaction should be ascertained, it cannot be left entirely to surmises and conjectures of the TPO. XXX 47. For the aforementioned reasons, the Court is of the view that as far as the present appeals are concerned, the Revenue has been unable to demonstrate by some tangible material that there is an international transaction involving AMP expenses between WOIL and Whirlpool USA. In the absence of that first step, the question of determining the ALP of such a transaction does not arise. In any event, in the absence of a machinery provision it would be hazardous for any TPO to proceed to determine the ALP of such a transaction since BLT has been negatived by this Court as a valid method of determining the existence of an international transaction and thereafter its ALP. 16. The case of the Revenue is that Indian subsidiar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ompensation for rendering these services not provided unilaterally by the assessee. 19. We do not find any force in the aforesaid contentions of the ld. DR. As mentioned elsewhere, the Revenue needs to establish on the basis of some tangible material or evidence that there exists an international transaction of provisions of brand building service between the assessee and the AE. We find support from the decision of the Hon ble Delhi High Court in the case of Honda Seil Power Products Ltd vs DCIT ITA No 346/2015. 20. The Hon ble Delhi Court in its recent decision in the case of CIT vs Mary Kay Cosmetic Pvt Ltd (ITA No.1010/2018), too, dismissed the Revenue s appeal, following the law laid down in its earlier decision (supra) and held as under: We have examined the assessment order and do not find any good ground and reason given therein to treat advertisement and sales promotion expenses as a separate and independent international transaction and not to regard and treat the said activity as a function performed by the respondent-assessee, who was engaged in marketing and distribution. Further, while segregating / debundling and treating advertisement and sales pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee but for the group as a whole. 24. It is the say of the ld. DR that pricing regulations are to applied keeping in mind the overall scheme of the tax payer s business arrangement. The contention of the ld. DR can be summarized as under: a) The assessee being part of a group is not completely independent in its pricing policies including price of raw material purchased from AE, payments in respect of copyrights and patents payable to the AE. Even their product pricing is not completely independent. Linder such circumstances, the benefits emanating from the AMP function cannot be enjoyed by the assessee alone. The assessee is not an independent manufacturer who takes all the risks and enjoys all the benefits of the functions performed by them. b) The assessee is not engaged only in manufacture. It is also engaged in distribution of goods by its own admission. In fact, the assessee has a dual function of manufacturer and distributor. In any case, given its distribution function, the assessee is covered by the judgement of Hon ble Delhi High Court in M/s Sony Ericsson. c) The benefits to the AE from AMP function continue to be the same as in the case of di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for the owner to reimburse the expenditures), the issue is the extent to which the distributor is able to share in the potential benefits from those activities. In general, in arm s length transactions the ability of a party that is not the legal owner of a marketing intangible to obtain the future benefits of marketing activities that increase the value of that intangible will depend principally on the substance of the rights of that party. For example, a distributor may have the ability to obtain benefits from its investments in developing the value of a trademark from its turnover and market share where it has a long-term contract of sole distribution rights for the trademarked product. In such cases, the distributor s share of benefits should be determined based on what an independent distributor would obtain in comparable circumstances. In some cases, a distributor may bear extraordinary marketing expenditures beyond what an independent distributor with similar rights might incur for the benefit of its own distribution activities. An independent distributor in such a case might obtain an additional return from the owner of the trademark, perhaps through a decrease in the purc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was accepted and agreed that the contract would be renewed. 153. Economic ownership of a brand is an intangible asset, just as legal ownership. Undifferentiated, economic ownership brand valuation is not done from moment to moment but would be mandated and required if the assessed is deprived, denied or transfers economic ownership. This can happen upon termination of the distribution-cummarketing agreement or when economic ownership gets transferred to a third party. Transfer Pricing valuation, therefore, would be mandated at that time. The international transaction could then be made a subject matter of transfer pricing and subjected to tax. 154. Brand or trademark value is paid for, in case of sale of the brand or otherwise by way of merger or acquisition with third parties. . .. .. Re-organisation, sale and transfer of a brand as a result of merger and acquisition or sale is not directly a subject matter of these appeals. As noted above, in a given case where the Indian AE claims economic ownership of the brand and is deprived or transfers the said economic ownership, consequences would flow and it may require transfer pricing assessment. (emphasis suppli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an the operating margins of comparable companies, no further separate compensation for AMP expenses is warranted. The Hon ble Court held as under: 101. However, once the Assessing Officer/TPO accepts and adopts TNM Method, but then chooses to treat a particular expenditure like AMP as a separate international transaction without bifurcation/segregation, it would as noticed above, lead to unusual and incongruous results as AMP expenses is the cost or expense and is not diverse. It is factored in the net profit of the inter-linked transaction. This would be also in consonance with Rule 10B(1)(e), which mandates only arriving at the net profit margin by comparing the profits and loss account of the tested party with the comparable. The TNM Method proceeds on the assumption that functions, assets and risk being broadly similar and once suitable adjustments have been made, all things get taken into account and stand reconciled when computing the net profit margin. Once the comparables pass the functional analysis test and adjustments have been made, then the profit margin as declared when matches with the comparables would result in affirmation of the transfer price as the arm s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nasmuch as there is no precedent available on this point. We find that the TPO determined comparable average rate of 3.5% of the companies having fixed term agreements. Considering the fact that the assessee had a perpetual license, he discounted the uncontrolled royalty rate by 2%, thereby calculating the arm's length royalty rate at 1.5%. The DRP computed average rate of royalty of three comparable companies at 4.5% and, thereafter, reduced 1% on account of limited period of license used by the comparables vis-a-vis the assessee using the perpetual license. 10.8. There can be no quarrel on the fact that, other things being equal, a landlord intending to have a tenant for a long-term may compromise some amount of rent, in comparison with a landlord finding a tenant requiring the premises for a short-term. The rate of rent in a former case will be lower for a variety of reasons, such as, not undergoing the process of finding a tenant every now and then, fear of the property remaining vacant for some time after the exit of the first tenant and incurring costs at the time of each let out. Difference between the rent charged by the landlord or paid by the tenants in the afor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d decided by the Tribunal in assessee s own case in ITA No. 6253/DEL/2012 for assessment year 2008-09 vide Ground Nos. 5 to 5.5 of that appeal. The relevant findings of the co-ordinate bench read as under: 47. In our considered opinion, for the purpose of determination of ALP of intra group services, the following issues have to be taken into consideration: i) Whether the services were required? ii) Whether the services were rendered? iii) Whether the services benefitted the assessee? iv) Whether the price paid for such services is at arm s length? 48. We find that the lower authorities have not disputed the factum of rendering of services but have held that the services rendered by RHQ are duplicative and hence were not required by the assessee. Further, the Revenue has also alleged that these were share holder services. 49. In our humble opinion, it is the prerogative of the assessee to decide as to whether or not the services are required. Documentary evidences brought on record show that significant services were rendered by RHQ benefitting the assessee to name a few such services, brand analysis, product analysis, market analysis, etc. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d or the case of the Revenue that the technology or know-how was hopeless and useless. The finding of the Assessing Officer/TPO, that the assessee had not derived any commercial benefit as technology and know-how had not resulted in any substantial profit increase, has been rightly rejected as totally unsustainable. Profitability of the assessed could have been lower or varied due to various reasons and lower profitability in one or more years cannot lead to the conclusion that no benefits were derived or technology was unproductive. The justification given by the assessee for lower profits on account of bad debts, high rent, increase in legal cost stand highlighted and accepted by the Tribunal. 184. Transfer pricing provisions, as noted above, recognise separate entity principle. Therefore, as a sequitur, it follows that the AE is a separate entity and when it avails and secures advantage of technical know-how, it should pay arm s length price for the right to use. The arm s length price would be the fair market price of the technical know-how, which is licensed. ****** ****** ****** 185. Royalty payable for availing the right to use would depend upon corresponding pric ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as made clear by the ITAT in Dresser-Rand India Pvt. Ltd. v. Additional Commissioner of Income Tax, 2012 (13) ITR (Trib) 422. 35. The TPO s Report is, subsequent to the Finance Act, 2007, binding on the AO. Thus, it becomes all the more important to clarify the extent of the TPO s authority in this case, which is to determining the ALP for international transactions referred to him or her by the AO, rather than determining whether such services exist or benefits have accrued. That exercise of factual verification is retained by the AO under Section 37 in this case. Indeed, this is not to say that the TPO cannot after a consideration of the facts state that the ALP is nil given that an independent entity in a comparable transaction would not pay any amount. However, this is different from the TPO stating that the assessee did not benefit from these services, which amounts to disallowing expenditure. That decision is outside the authority of the TPO . 56. Considering this issue from another angle in the light of the decision of the Hon ble Delhi high Court in the case of CIT vs Lumax Industries Limited ITA No 102/2014 we are of the opinion that once the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of Rs. 10,43,12,616/- which includes TP adjustment of Rs. 3,52,34,484/-. 19. The assessee has filed an application u/r 29 of the ITAT Rules for admission of additional evidence in support of payment of export commission to AEs. Similar application was filed in assessment year 2008-09 and the Tribunal, after considering the same, has remanded the matter to the file of the Assessing Officer to decide the issue after considering the additional evidence placed on record by the assessee. Relevant findings of the co-ordinate bench read as under: 91. It is not in dispute that in A.Y 2007-08 this issue was decided against the assessee by the Tribunal. The assessee has filed application u/r 29 of the ITAT Rules for admission of additional evidence in support of payment of export commission to its AE. In our considered opinion, such additional evidences need to be verified before deciding this issue. We, accordingly, restore this matter to the file of the Assessing Officer. The assessee is directed to furnish relevant documentary evidences and the Assessing Officer is directed to consider the same and decide the same afresh after giving reasonable opportunity of being heard to th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ince the CBU are imported from its AEs, there is a 12 months back to back warranty. The warranty claim/services are performed by third party /independent service providers in India. Such service providers charge the assessee for servicing the warranty claims and the appellant in terms of the arrangement thereafter charges its associated enterprises and gets reimbursement of the same in respect of such warrantee cost/expenses paid to paid to third party service providers. With respect to certain service spares, the same are imported from its associated enterprises which are supplied to authorized service providers. In respect of such imports, the associated enterprises reimburses the assessee on actual cost basis. 27. The TPO, however, held that the assessee is providing a service to the associated enterprises by servicing the warranty claims and ought to have earned a mark up on cost incurred for provision of such services. The TPO, accordingly, selected the following companies engaged in provision of business support services for calculating the mark up: S No. Name of the company OP/TC 1. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... endent service providers. This is clearly mentioned in the TP documentation also. In our view, such external costs being in the nature of pass-through costs, are not to be recovered along with a mark-up and a cost to cost reimbursement satisfies the arm s length principle. 33. The Hon ble Delhi High Court in case of Johnson Matthey India Private Limited vs. DCIT 380 ITR 43 has directed to exclude the pass through cost while computing the operating margin. The Hon ble Delhi High Court held as follows: 37. The exclusion of pass through costs from the denominator of total costs where the financial ratio of OP to TC is used is acknowledged in para 2.93 and 2.94 of the OECD Guidelines. Para 2.93 states that the extent to which it would be acceptable at arm's length to treat a significant portion of the tax payer's costs as pass-through costs to which no profit element is attributed (i.e. costs which are potentially excludable from the denominator of the net profit indicator) would depend on the extent to which an independent party in comparable circumstances would agree not to earn a mark-up on part of the costs it incurs. Para 2.94 of the OECD Guidelines further ack ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... loyed or to be employed by the enterprise ... It thus contemplates a determination of ALP with reference to the relevant factors (cost, assets, sales etc.) of the enterprise in question, i.e. the assessee, as opposed to the AE or any third party. The textual mandate, thus, is unambiguously clear. 35. Moreover, the operating margin of the assessee in the distribution segment at 4.52% is higher than that of the comparable companies at 3.93% and the after sale warrantee is closely linked with distribution function of the assessee. Therefore, no adjustment on account of international transaction of reimbursement of warranty claims is warranted on the facts of the case. Our view is fortified by the decision of the Hon'ble Delhi High Court in the case of Sony Ericsson Mobile Communications (supra) wherein the Hon ble Court held that Clubbing of closely linked transactions is permissible in appropriate cases. The Hon ble High Court further held that once the Revenue accepts the TNMM as the most appropriate method, then it would be inappropriate for the Revenue to treat a particular expenditure as a separate international transaction. 36. The Hon ble Delhi High Court in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 for assessment year 2008-09 vide Ground No. 8 of that appeal. The relevant findings of the co-ordinate bench read as under: 78. We have given thoughtful consideration to the orders of the authorities below. We have also considered the orders of the coordinate bench in assessee s own case and the various judicial decisions relied upon by the ld. AR. In A.Y 2002-03, the coordinate bench in ITA No. 1404/DEL/2007 has held as under: 9. We have heard both the parties and gone through the material available on record. In this case the assessee had collected sales tax as a part of dealers' price. At the year end the sales tax portion, which formed the part of dealers' price had been bifurcated and has been claimed as capital subsidy. We have also gone through the Notification No. 1179 dated 31.03.1995 issued by the State Government of Uttar Pradesh. The State Govt. has provided sales tax exemption with an objective to promote the development of certain industries which have been set up or undertaken modernisation, diversification, backward integration by way of fixed capital investment of Rs.50 crores or more. The exemption of from sales tax or benefit of reduced rate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovided to the extent of 100 per cent, next three years 75 per cent, next two years 50 per cent and next two years 25 per cent. In all exemption from sales tax was provided for 10 years. 10. Neither the certificates issued by Greater Noida Industrial Development Authority nor the Notification issued by the State Govt. authorises the assessee to collect sales tax from its customers. The assessee has been exempted from collecting the sales tax from customers on the sales made with effect from 27th March, 1998. In fact, the ld. counsel for the assessee made a statement at the bar, during the course of hearing, that neither the Notification has authorized the assessee to collect sales tax nor the assessee had collected the sales tax as such. The assessee had included the element of sales tax in the dealers' price as a sale price of the product. In the States other than Uttar Pradesh, the sales tax so collected as a part of dealers' price has been paid to respective State Governments, whereas in the case of the assessee, since the assessee was not liable to pay sales tax, as exemption has been provided to the extent of 200 per cent of fixed capital investment, the sales ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eal. The relevant findings of the co-ordinate bench read as under: 88. We find that the Tribunal in assessee s own case for A.Y. 2007-08 has decided this issue in favour of the assessee and against the Revenue. Respectfully following the findings of the coordinate bench, we direct the Assessing Officer to treat royalty payment of Rs. 85.75 crores as revenue expenditure. Ground No. 10 is allowed. 45. Respectfully following the precedent, we direct the Assessing Officer/TPO to delete the impugned disallowance. Ground No. 10 is allowed. 46. Ground No. 12 relates to restricting the deduction claimed by the assessee u/s 80JJAA of the Act. 47. An identical issue was considered and decided by the Tribunal in assessee s own case in ITA No. 6253/DEL/2012 for assessment year 2008-09 vide Ground No. 12 of that appeal. The relevant findings of the co-ordinate bench read as under: 96. We have carefully considered the orders of the authorities below qua the issue. There is no dispute that he assessee satisfies all the conditions for claiming deduction u/s 80JJAA of the Act. For our convenience, section 80JJAA reads as under: 80JJAA. (1) Where the gross total income o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the minimum period in subsequent year. 99. In our considered opinion, this amendment i.e. second proviso is clarifactory in nature and is intended to remove the anomaly so as to advance legislative intention of providing incentive to new worker for more than 300 days and must be given retrospective effect. For this proposition, we draw support from the judgment of the Hon'ble Supreme Court in the case of Allied Motors Pvt. Ltd Vs. CIT 224 ITR 677 [SC]. The relevant finding of the Hon'ble Supreme Court reads as under: In the case of Goodyear India Ltd. v. State of Haryana and Anr. (188 ITR 402) this court said that he rule of reasonable construction must be applied while construing a statute. Literal construction should be avoided if it defeats the manifest object and purpose of the Act. Therefore, in the well known words of Judge learned Hand, one cannot make a fortress out of the dictionary; and should remember that statutes have some purpose and object to accomplish whose sympathetic and imaginative discovery is the surest guide to their meaning. In the case of R.B. Jodha Mal Kuthiala v. Commissioner of Income-tax, Punjab, Jammu Kashmir and Himacha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the case of CIT Vs. Alom Extrusions Ltd 319 ITR 306 wherein the Hon'ble Supreme Court held that where a proviso in section is inserted to remedy unintended consequences to make section workable the proviso which supplies obvious omission therein in required to be read retrospectively in operation particularly to give effect to section as a whole. 101. Same view was followed by the Hon'ble Supreme Court in the case of CIT Vs. Kolkata Export Company 404 ITR 654. 102. Respectfully following the ratio laid down by the Hon'ble Supreme Court [supra] we direct the Assessing Officer to allow claim of deduction u/s 80JJAA of the Act as claimed by the assessee. 48. Ground Nos. 13 and 14 relate to charging of interest u/s 234B, 234C and 234D of the Act. 49. Levy of interest is mandatory, though consequential to our decision. The Assessing Officer is directed to levy interest as per the provisions of the law. Interest u/s 234C to be charged on the returned income. 50. Ground Nos. 15 and 16 relate to error in granting benefit of advance tax / self assessment tax/TDS credited. 51. We find that there is some error in granting tax credit to the assessee in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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