IT/ILT: Where in original assessment, taxability of income from Bangkok branch of assessee was considered by Assessing Officer in detail, reopening of assessment to include income of assessee from said branch could not be sustained
IT/ILT: Where assessee had income from Bangkok branch, Double taxation relief is allowable only at lower rate of Bangkok income taxed in India or taxed at Bangkok
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[2013] 39 taxmann.com 193 (Chennai - Trib.)
IN THE ITAT CHENNAI BENCH 'A'
Bharat Overseas Bank Ltd.
v.
Assistant Commissioner of Income-tax, Company Circle -I (2), Chennai*
ABRAHAM P. GEORGE, ACCOUNTANT MEMBER
AND S.S. GODARA, JUDICIAL MEMBER
AND S.S. GODARA, JUDICIAL MEMBER
IT APPEAL NOS. 830, 831, 1183 & 1184 (MDS.) OF 2010
[ASSESSMENT YEARS 2002-03 AND 2007-08]
[ASSESSMENT YEARS 2002-03 AND 2007-08]
SEPTEMBER 26, 2013
I. Section 9 of the Income-tax Act, 1961, read with Article 23 of the DTAA between India and Thailand - Income - Deemed to accrue or arise in India [Method of elimination of Double taxation] - Assessment year 2002-03 - In original assessment order, Assessing Officer held that income of assessee from Bangkok branch in Thailand was not taxable in India and, accordingly, assessee was given benefit - After four years, Assessing Officer reopened assessment giving reason that income of assessee earned in Thailand was required to be taxed in India with allowance of tax credit on actual tax paid by assessee in Thailand subject to provisions of DTAA - Whether since in original assessment completed under section 143(3), Assessing Officer had dealt with issue and revenue had no case that assessee had failed to disclose truly and fully any particulars necessary for its assessment, reopening based on change of opinion could not be held valid - Held, yes [Para 9] [In favour of assessee]
II. Section 90 of the Income-tax Act, 1961 read with article 23 of the DTAA between India and Thailand - Double taxation relief - Where agreement exists [Method of elimination of double taxation] - Assessment year 2007-08 - Assessee, banking company, claimed double taxation relief (DTR) in respect of income from Bangkok branch taxed in India at rate of tax in India - Assessing Officer, however, held that DTR would be allowed only at lower rate of Bangkok income taxed in India or taxed at Bangkok - He, accordingly, gave benefit of a sum being 30 per cent tax payable on Bangkok income - Whether order of Assessing Officer was justified - Held, yes [Paras 35 & 36][In favour of revenue]
CASE REVIEW-I
CIT v. Kelvinator of India Ltd. [2010] 320 ITR 561/187 Taxman 312 (SC) (para 9) followed.
CASES REFERRED TO
CIT v. P.V.A.L. Kulandagan Chettiar [2004] 267 ITR 654/137 Taxman 460 (SC) (para 6), CIT v. Kelvinator of India Ltd. [2010] 320 ITR 561/187 Taxman 312 (SC) (para 9), Indian Overseas Bank v. Dy. CIT [IT Appeal No. 818 (Mds.) of 2010, dated 19-3-2013] (para 15), CCI Ltd.v. Jt. CIT [2012] 206 Taxman 563/20 taxmann.com 196 (Kar.) (para 18), MSA Securities Services (P.) Ltd. v. Asstt. CIT [2013] 33 taxmann.com 508/58 SOT 44 (Chennai) (URO) (para 18), Godrej & Boyce Mfg. Co. Ltd. v. Dy. CIT [2010] 328 ITR 81/194 Taxman 203 (Bom.) (para 20), Dy. CIT v. Bharat Overseas Income Tax [IT Appeal No. 215 (Mds.) of 2010, dated 30-10-2012] (para 30) and Catholic Syrian Bank Ltd. v. CIT[2012] 343 ITR 270/206 Taxman 182/18 taxmann.com 282 (SC) (para 31).
C. Naresh for the Appellant. Shaji P. Jacob for the Respondent.
ORDER
Abraham P. George, Accountant Member - These are appeals filed by the assessee and Revenue respectively, directed against orders dated 7-4-2010 of Commissioner of Income Tax (Appeals)-III, Chennai, for the impugned assessment years.
2. Appeals for assessment year 2002-03 are taken up first.
3. Assessee in its appeal assails the validity of reassessment proceedings, which was upheld by the CIT(Appeals).
4. Facts apropos are that assessee had filed its return for the impugned assessment year on 31.10.2002 declaring income of Rs. 40,65,11,720/-. Assessment was completed under Section 143(3) of Income-tax Act, 1961 (in short 'the Act') on 18.2.2005. Thereafter notice under Section 148 was issued on 24.3.2009 and reassessment was completed on 17.12.2009. Reason for reopening was stated as under:—
'The income of the assessee earned in Thailand is required to be taxed in India with the allowance of tax credit on the actual tax paid by the assessee in Thailand subject to the provisions of DTAA.
Article 23(2) of the DTAA with Thailand read as under.
"The amount of that tax payable, under the laws of Thailand and in accordance with the provisions of this Convention, whether directly or by deduction, by a resident of India, in respect of profits or income arising in Thailand, which has been subjected to tax both in India and in Thailand, shall be allowed as a credit against the Indian tax payable in respect of such profits or income provided that such credit shall not exceed the Indian tax (as computed before allowing any such credit) which is appropriate to the profits or income arising in Thailand." According to Article 23(3) of the DTAA, "For the purposes of the credit referred to in Paragraph (2), the term "That tax payable" shall be deemed to include any amount which would have been payable as Thai tax for any year...."
It is clear from the above, where the profits or income has been subjected to tax both in India and in Thailand, there shall be allowed as a credit in the form of "DITR Relief" against the Indian tax payable in respect of such profit or income earned in Thailand. It is simply made clear vide article 23(3) of DTAA that the quantum of credit to be allowed is that "any amount which would have been payable as Thai tax for any year".
The above stand is also strengthened by the Gazette Notification Extraordinary Part II Section 3 Sub-section (ii) dated 28.8.2008. This clarificatory notification implies that such income of resident shall not be exempt from tax in India and the tax, if any, paid in the other country may be given credit in accordance with DTAA.
The assessee had filed to disclose all the details relevant to the Thailand Income like, Head Office expenses, Travel expenses, etc while claiming relief under Exclusion method whereas the relief under credit method needs to be computed with reference to provisions of Section 23(2) of DTAA with Thailand. As the assessee had failed to disclose these details in full, I am of the opinion that the income has escaped assessment within the meaning of section 147 and the amount of escaped income is also likely to exceed Rs. 1 lakh.
I therefore request the Commissioner to kindly accord approval for issue of notice u/s 148.'
5. Reassessment was completed on 17.12.2009 whereby the income of the assessee from Bangkok Branch was included in its income chargeable to tax in India.
6. Assessee moved in appeal before CIT(Appeals), wherein it assailed the reopening as well as the merits of the addition. As per assessee, in view of the decision of Hon'ble Apex Court in the case of CIT v. P.V.A.L. Kulandagan Chettiar [2004] 267 ITR 654/137 Taxman 460, income of its Bangkok Branch could not be included in its total income for the purpose of taxation in India. Further, as per assessee, in the original assessment, taxability of the income from Bangkok Branch was considered by the Assessing Officer in detail. Therefore, as per the assessee, reopening was based on a change of opinion. Though CIT(Appeals) allowed the claim of the assessee on merits, he did not specifically adjudicate on its ground regarding validity of the reopening.
7. Now before us, learned A.R. submitted that the reassessment notice was issued after four years from the end of the relevant assessment year. According to him, in the original assessment completed on 18.2.2005, Assessing Officer had in detail considered the claim of the assessee that Bangkok income was not taxable in India.
8. Per contra, learned D.R. supported the orders of authorities below.
9. We have perused the orders and heard the rival submissions. We find that in the original assessment completed under Section 143(3) on 18.2.2005, Assessing Officer had dealt with the issue regarding claim of the assessee with regard to its Bangkok income. Relevant para in the assessment order appearing on page 5 is reproduced hereunder:—
"DIT relief under Double Taxation Agreement
The assessee has claimed a sum of Rs. 4,50,23,152/- being 35.70% tax on its Bangkok income of Rs. 12,61,15,270/-. As held by the Supreme Court of India, in the case of P.V.A.L. Kulandagan Chettiar (supra), the income from Bangkok amounting to Rs. 12,61,15,270/-is not taxable in India and hence reduced from the total income. The above Supreme Court judgment was referred to the Sr. Standing Counsel for proper interpretation and as advised by her necessary reworking has been done in earlier years also."
Thus, Assessing Officer, during the course of original assessment, was very well aware of the decision of Hon'ble Apex Court in the case of P.V.A.L. Kulandagan Chettiar (supra). When we look at the reason given for reopening reproduced at para 4 above, we find that the reopening has been resorted to for the same issue. There is no new material or tangible evidence in the hands of the Revenue. It was only based on a change of opinion that reopening was resorted to. That a reopening cannot be done based on a change of opinion has been laid down by Hon'ble Apex Court in the case ofCIT v. Kelvinator of India Ltd. [2010] 320 ITR 561/187 Taxman 312 (SC). Revenue has no case that assessee had failed to disclose truly and fully any particulars necessary for its assessment. In other words, proviso to Section 147 is squarely applicable. Reopening done based on change of opinion after four years from the end of the impugned assessment year could not be held as valid. The reopening and resultant reassessment are quashed.
10. Appeal of the assessee is allowed.
11. Since assessee's appeal has been allowed, cross appeal of the Revenue for the impugned assessment year has become infructuous and is dismissed.
12. Now we take up cross appeals of the assessee and Revenue for assessment year 2007-08.
13. Appeal of the assessee is taken up first for disposal.
14. In its ground No.1, assessee is aggrieved that CIT(Appeals) remitted the issue regarding allowance of rural bad debts of Rs. 17,89,732/- back to the file of the Assessing Officer. As per assessee, claim had to be allowed since there was no credit balance in the provision computed under Section 36(1)(vii) of the Act.
15. We find that similar issue had come up before this Tribunal in assessee's appeal for assessment year 2007-08. This Tribunal in its order Indian Overseas Bank v. Dy. CIT [I.T. Appeal No. 818 (Mds.) of 2012, dated 19-3-2013], held at para 14 & 15, as under:—
'14. In the third ground of appeal, the assessee has assailed the impugned order on the ground that the CIT(A) has erred in restricting the claim in respect of deduction under section 36(1)(viia) to the extent of provision made in the books instead of allowing the same based on the eligible amount as per the provisions of the said section. The A.R. fairly conceded that the issue has been decided against the assessee by the Tribunal inBharat Overseas Bank Ltd. v. CIT [2012] 139 ITD 154/26 taxmann.com 330 (Chennai). The relevant extract of the order of the Tribunal in the said appeal is reproduced herein below:—
7. We have perused the orders and heard the rival submissions. The original claim, which was allowed by the Assessing Officer under Section 36(1)(viia) of the Act, was as follows:—
| 7.5% of Gross Total Income | : Rs. 5,74,07,362 | |
| 10% of Rural Advances | : Rs. 2,72,65,099 | |
| (Rs. 27,26,50,990/-) | ||
| Rs. 8,46,72,461 |
Thereafter, assessee had moved in appeal against some of the additions made by the Assessing Officer on other issues and pursuant to the relief granted in such appeal, the gross total income which earlier stood at Rs. 76,54,31,493/- came down to Rs. 35,38,65,546/-. As a result of the reduction in gross total income, deduction under Section 36(1)(viia) was also scaled down from Rs. 5,74,07,362/- to Rs. 2,65,39,916/-. This sum when aggregated with 10% of rural advances coming to Rs. 2,72,65,099/-, resulted in the sum of Rs. 5,38,05,015/- being eventually allowed as deduction under Section 36(1)(viia) of the Act. In the books of the assessee, actual provision for bad and doubtful debts was only Rs. 4,01,44,027/-. Assessee had also made a provision of Rs. 2.23 Crores on its standard assets. If the provision for bad and doubtful debts alone was considered, then the total allowance under Section 36(1)(viia) was in excess of such provision. However, if the provision for standard assets was also considered as provision for bad and doubtful debts, then the total provision could go up to Rs. 6,24,44,027/-. Then of course, assessee's claim as finally allowed was well within the limits specified under Section 36(1)(viia) of the Act. At this juncture, a look at Section 36(1)(viia) is necessary and this is reproduced hereunder, for brevity:—
"36(1)(viia) a scheduled bank [not being a bank incorporated by or under the laws of a country outside India] or a non-scheduled bank [or a co-operative bank other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank], an amount [not exceeding seven and one-half per cent] of the total income (computed before making any deduction under this clause and Chapter VIA) and an amount not exceeding [ten] per cent of the aggregate average advances made by the rural branches of such bank computed in the prescribed manner."
It is clear from the above that it is not a standard allowance which is given, but, the allowance is subject to the actual provision made by the assessee, which in no case shall exceed 7.5% of the gross total income. Therefore, the argument of the assessee that whatever the provision it had actually made in its books, a provision of 7.5% of the gross total income had to be allowed, is not in accordance with law. Now considering the second aspect, whether provision for standard assets could be considered as provision for bad and doubtful debts, admittedly a provision on standard assets is not against any debts which had become doubtful. Standard assets are always considered recoverable, in the sense, bank has no doubt of recoverability. When the bank itself has treated such assets as good and recoverable, any provision made on such assets cannot be considered as a provision for bad and doubtful debts. The debt itself being good, a provision made on good debt cannot be considered as a provision for bad and doubtful debts. May be, the RBI has made a regulation for 10% provision for standard assets also a prudential norm. This can however be considered as a measure prescribed in abundant caution, to deal with a situation where banks are not to suffer shock of sudden delinquency that could happen in future. There is always a possibility that an asset, which is fully recoverable, may not be so at future date. Nevertheless, possibility of happening of such a contingency cannot be a sufficient reason to consider a provision made on standard assets also as a provision for bad and doubtful debts. Therefore, claim of the assessee that provision for standard assets also has to be considered for applying the condition set out under Section 36(1)(viia) is not in accordance with law. If the provision for standard assets is not considered as provision for bad and doubtful debts, the actual provision for bad and doubtful debts made by the assessee in its books Rs. 4,01,44,027/- fall much below the sum of Rs. 5,38,05,015/- allowed by the Assessing Officer. In any case, a look into the original assessment order clearly show that but for the deduction allowed to the assessee as claimed by it in its return, there was no discussion as to how Section 36(1)(viia) was applied and whether the limits were corrected worked out. Admittedly, no question was asked to the assessee during the course of assessment proceedings also with regard to the claim made by it under Section 36(1)(viia), insofar as it concerns the quantum of such claim. This obviously show that there was no application of mind by the Assessing Officer at the time of assessment. Assessing Officer had not come to any conclusion at all having not considered the claim in the light of the conditions set out in Section 36(1)(viia) of the Act. We cannot say that he had taken a view which was in accordance with law. It is not a case where the Assessing Officer had adopted one of the courses possible in law. Of course, a cryptic order of the Assessing Officer by itself may not show that there was no thought given by him on a claim of the assessee. However, here there was no enquiry made during the course of assessment proceedings. Therefore, the order which was silent on the claim made by the assessee, and allowing such claim, without any discussion, will definitely render it erroneous and prejudicial to the interests of Revenue. As held by Hon'ble Apex Court in the case of Malabar Industrial Co. Ltd. v. CIT [2000] 243 ITR 83/109 Taxman 66, "prejudicial to the interests of the Revenue" is a term of wide import and not confined to loss of tax. An order without application of mind is definitely prejudicial to the interests of the revenue. We are in agreement with ld. CIT that the order of Assessing Officer was erroneous insofar as it was prejudicial to the interests of Revenue. No interference is required.
8. In the result, appeal filed by the assessee is dismissed."
15. The Tribunal has upheld the order of CIT u/s.263 in assessee's own case for the same assessment year on the issue in hand. Since, the matter has been remitted back to Assessing Officer, this ground of appeal of the assessee is dismissed.'
For the impugned assessment year also, the issue regarding allowance of rural bad debts has only been remitted back by the CIT(Appeals) to the Assessing Officer. We find no reason to interfere with the order of CIT(Appeals).
16. Ground No.1 of the assessee is dismissed.
17. Vide its ground No.2, grievance raised by the assessee is that disallowance made under Section 14A of the Act, for the impugned assessment year, was confirmed by the ld. CIT(Appeals). As per assessee, the A.O. had made the disallowance relying on Rule 8D of Income-tax Rules, 1962, whereas, the said rule was not applicable for impugned assessment year.
18. Learned A.R. submitted that income was earned on securities held as stock-in-trade. According to him, when securities were held as stock-in-trade, income earned thereon were only incidental. Relying on the decision of Hon'ble Karnataka High Court in the case of CCI Ltd. v. Jt. CIT [2012] 206 Taxman 563/20 taxmann.com 196, learned A.R. submitted that where earnings of income were only incidental, Section 14A could not be applied. Reliance was also placed on the decision of co-ordinate Bench of this Tribunal in the case of MSA Securities Services (P.) Ltd. v. Asstt. CIT [2013] 33 taxmann.com 508/58 SOT 44 (Chennai) (URO).
19. Per contra, learned D.R. submitted that in assessee's own case for assessment year 2006-07, this Tribunal has remitted the issue back to the file of the Assessing Officer for consideration afresh.
20. We have perused the orders and heard the rival submissions. In view of the decision of Hon'ble Bombay High Court in the case of Godrej & Boyce Mfg. Co. Ltd. v. Dy. CIT [2010] 328 ITR 81/194 Taxman 203 (Bom.), there can be no dispute that Rule 8D could not be applied for impugned assessment year. However, Hon'ble Bombay High Court also held that even after the application of Rule 8D, disallowance under Section 14A could be made. No doubt, here assessee's submission is that securities were held by it as stock-in-trade and earning of income was incidental thereon. But, at the same time, we also find that co- ordinate Bench of this Tribunal in assessee's own case for assessment year 2006-07 in I.T.A. No. 96/Mds/2010 dated 3.1.2011 had remitted the said issue back to the file of the Assessing Officer. Therefore, in the interest of justice, we are of the opinion that for the impugned assessment year also, the matter can be looked into by the Assessing Officer once again. We set aside the orders of authorities below and remit the issue regarding disallowance under Section 14A back to the file of the A.O. for consideration afresh, in accordance with law.
21. Ground No.2 of the assessee is allowed for statistical purposes.
22. Vide its ground No.3, grievance of the assessee is that depreciation on UPS, which was claimed by it at 80% considering UPS to be an energy saving device, was disallowed by the A.O. and confirmed by the CIT(Appeals).
23. Learned A.R. submitted that the issue stood decided in favour of assessee by this Tribunal, on assessee's appeal for assessment year 2007-08 inIndian Overseas Bank (supra).
24. Learned D.R. fairly agreed that the matter as on date stood in favour of assessee.
25. We have perused the orders and heard the submissions. This Tribunal, on assessee's appeal for assessment year 2007-08, held at paras 27 & 28 in its order dated 19th March, 2013, as under:—
"27. The next ground of appeal relates to claim for depreciation on UPS at 80%. The AR submitted that the CIT(A) has failed to appreciate that UPS is an energy saving device, therefore, depreciation @ 80% should have been allowed. However, he also relied on the judgement of the Hon'ble Delhi High Court in the case of CIT v. Orient Ceramics & Industries Ltd. [2011] 11 taxmann.com 417/200 Taxman 64 (Delhi) (Mag.)reported as 56 DTR (Del) 397, wherein the Hon'ble High Court has allowed depreciation @ 60% on UPS treating it as part of computer hardware. On the other hand, learned DR relied on the order of the Delhi Bench of the Tribunal in the case of Nestle India Ltd. v. Dy. CIT [2009] 27 SOT 9 (Delhi) (URO) reported as 111 TTJ 498 wherein the Tribunal has held UPS at par with plant and machinery and rejected the contention of assessee to treat it as part of computer.
28. We do not agree with the submissions of the AR that the UPS is an energy saving device, therefore, depreciation @ 80% should be granted. However, we are in consonance with the decision of Hon'ble Delhi High Court in the case of Orient Ceramics & Industries Ltd. (supra), wherein the Hon'ble Court has granted depreciation @ 60% by treating UPS as part of computer hardware. Accordingly, we allow depreciation @ 60% on UPS and partly allow the ground of appeal of the assessee."
Following the order of co-ordinate Bench of this Tribunal, we hold that assessee was entitled for higher depreciation available to energy saving device.
26. Ground No.3 of the assessee is allowed.
27. In the result, appeal of the assessee for assessment year 2007-08 is partly allowed for statistical purposes.
28. Coming to the appeal of the Revenue, it has raised altogether five grounds, of which, Ground Nos.1 and 5 are general needing no adjudication.
29. Vide its ground No.2, grievance raised by the Revenue is that CIT(Appeals) allowed the claim of the assessee on bad debt relating to non-rural advances.
30. Learned A.R. submitted that the issue stood decided in favour of assessee by the decision of the Tribunal in assessee's own case for assessment year 2006-07 in Dy. CIT v. Bharat Overseas Income Tax IT Appeal No. 215 (Mds.) of 2010, dated 30-10-2012.
31. Learned D.R. fairly admitted that decision of Hon'ble Apex Court in the case of Catholic Syrian Bank Ltd. v. CIT [2012] 343 ITR 270/206 Taxman 182/18 taxmann.com 282 went in favour of assessee.
32. In view of the admitted position, ground No.2 of the Revenue stands dismissed.
33. Vide its ground No.3, grievance of the Revenue is that CIT(Appeals) directed the Assessing Officer to allow Double Income Taxation Relief (DITR).
34. Learned A.R. submitted that this issue stood covered against the assessee by the decision of Tribunal on its appeal for assessment year 2006-07 inBharat Overseas Income Tax (supra).
35. We find that the issue regarding double taxation relief raised by the Revenue had come up before this Tribunal in assessee's appeal for assessment year 2006-07, in Bharat Overseas Income Tax (supra). It was held by this Tribunal in the said order as under:—
"10. We have heard both the sides, perused the records and gone through the orders of the authorities below. In this case the assessee is a banking company and also having a branch office at Bangkok. The Assessing Officer in the original assessment order gave tax credit to the assessee on the tax paid at Bangkok at Rs. 1,08,25,780/- According to the assessee he is entitled for the tax rate payable in India and claimed at Rs. 1,86,74,470/-. The matter went to the CIT(A). The learned CIT(Appeals) allowed the claim of the assessee. The Revenue carried the matter before the Tribunal. The Tribunal vide order dated 30-11-2004 directed the Assessing Officer to enquire whether there is a DTAA between India and Bangkok. The Assessing Officer in accordance with the directions given by the ITAT enquired all the provisions of the DTAA between India and Thailand and as per Article 23(3) by following the tax credit method whatever tax was paid by the assessee in Thailand was given credit to the assessee. Aggrieved, the assessee carried the matter before the learned CIT(Appeals). The learned CIT(Appeals) hyper technically held that the only job of the Assessing Officer was to see whether there is a DTAA between India and Thailand. We are unable to understand the above conclusion made by the learned CIT(Appeals) that the job of the Assessing Officer is just to see whether there is a DTAA between India and Thailand. If there is a DTAA, the Assessing Officer has to allow the relief claimed by the assessee. That being so, in our opinion, the Tribunal need not refer it to the Assessing Officer as well just to see and pass an order. The Tribunal clearly directed the Assessing Officer to enquire into the existence of a DTAA between India and Bangkok. "Enquiry" means to investigate and apply the same. In our opinion, the Assessing Officer has rightly investigated and applied the same and decided the issue. We therefore hold that the finding given by the learned CIT(Appeals) is not correct. Accordingly, we reverse the order passed by the learned CIT(Appeals) on this count and uphold the order of the Assessing Officer."
36. Ground No.3 of the Revenue is allowed.
37. Vide its ground No.4, grievance raised by the Revenue is that CIT(Appeals) directed the Assessing Officer to allow loss on revaluation of investments of Rs. 34,98,10,600/-.
38. Learned A.R. submitted that the issue stood decided in favour of assessee by this Tribunal on assessee's appeal for assessment year 2006-07 inBharat Overseas Income Tax (supra). Reliance was also placed on the decision of co-ordinate Bench of this Tribunal in assessee's own case for assessment year 2007-08 in I.T.A. No. 861/Mds/2010. Learned D.R. fairly agreed with this.
39. In view of the admitted position that loss on revaluation of investments has been allowed by virtue of the decision of this Tribunal in assessee's own case for assessment year 2006-07 in Bharat Overseas Income Tax (supra), we do not find any merit in this ground raised by the Revenue.
40. Ground No.4 of the Revenue stands dismissed.
41. In the result, appeal of the Revenue is partly allowed.
42. To summarize the result, assessee's appeal for 2002-03 is allowed, whereas, its appeal for 2007-08 is partly allowed for statistical purposes, and, Revenue's appeal for assessment year 2002-03 is dismissed as infructuous, whereas, its appeal for assessment year 2007-08 is partly allowed.
USPRegards
Prarthana Jalan
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