TaxTMI 
TaxTMI 
2017 (11) TMI 1541
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....ith the appeal in ITA No. 5856/Del/2011 for the assessment year 2007-08. Following grounds have been raised in this appeal: "1. The Learned Commissioner of Income Tax (Appeals) - II, Dehradun ("Ld. CIT(A)") has erred on facts and in law in disallowing the claim of the appellant for deduction u/s 80-IC of the Income Tax Act, 1961 ("the Act") and confirming the assessment at income of INR 1,66,45,050 as made by the Learned Deputy Commissioner of Income Tax, Circle-2, Dehradun, ("Ld. AO"). 2. The Ld. CIT(A) has erred in law and on facts in admitting the additional evidence submitted by the ld. AO holding that the ld. AO has not exceeded the mandate of the remand made by the Ld. CIT(A). 3. The Ld. CIT(A) has erred on facts in not appreciating the business model of the appellant and holding the appellant is engaged in the business of manpower recruitment and supply. 4. The Ld. CIT(A) has erred on facts and law in holding that the appellant is not rendering services in the field of Information and Communication Technology (ICT) industry as required for claiming deduction u/s 80-IC. 5. The Ld. CIT(A) has erred in law and on facts in holding tha....
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....before April 2012; Thus provisions of 80IC (2)(b)(ii) stand complied with; 3. Our works/operations are covered under point 13 of Annexure II as Thrust industries as per letter No. 1(10)/2001 - NER of Ministry of Commerce & Industry dated 07.01.2003; 4. Our unit is located at Majra, Subhash Nagar (Opp. Transport Nagar), Dehradun; 5. Building map has been approved by MDDA as Cyber City IT; 6. The unit is registered with District Industries Centre, Dehra Dun and Software Technology Parks of India, Dehradun. 7. Audit Report u/s 80IC on Form 10CCB, has already been submitted. As regards the assessee's claim that its activities are covered under point 13 of Part-C of the Fourteenth Schedule as mentioned in sub section 2(b) of section 801C, it is noticed that the above category envisages the category of eligible activity or article or thing or operation to be "Information and Communication Technology Industry, Computer Hardware, Call Centre." 6. The assessee also summarized the process of acquiring the work contract as under: RESPONSE TO POINT No. 18 Note on the process of getting contracts "The process of solicit....
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....tware testing, system quality assurance, documentation, systems development, training, systems maintenance and systems and as per the contract, the assessee had to make the payment of salaries and all related taxes for the contractor would be responsibility of the assessee. It was also agreed upon by the assessee's client that on selection of a contractor for an onsite assignment, the relevant work permit/visa will be applied for by the assessee and that the charges for professional services payable to the assessee by the client were payable on monthly basis, on time and material basis. The AO discussed the payment schedule in the case of Tech Mahendra Ltd. as under: Jr. Programmer Exp. (0 to 2 yrs) Programmer (exp. 2 to 4 yrs) Analyst (exp. 4 to 6 yrs) Project Leader (exp 6 to 8 yrs) Rs. 35,000/- + Service Tax as applicable Rs. 45,000/- + Service Tax as applicable. Rs. 60,000/- + Service Tax as applicable. Rs. 70,000/- + Service Tax as applicable. Premium Skill. Programmer (Exp. 3 to 5 yrs. Analyst (exp. 5 to 8 yrs.) Project Manager (Exp. 8+) Rs. 50,000/- + Service Tax ....
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....o be an industry in the sense it has been used in category 13 of Part C of the Fourteenth Schedule of the Act. He further observed that the language used in Section 80IC of the Act, more particularly in clause (b) of Section 80IC of the Act clearly mandates that manufacture/production or commencement of operation as specified therein has to be in the State of Himachal Pradesh or the State of Uttaranchal which means that Information and Communication Technology Industry has to be commenced in the State of Uttaranchal, whereas the assessee's operations , if that can be called to so by the stretch of wild imagination, are taking place at various sites of the clients which are not only outside the State of Uttaranchal but also it can be outside India and most of the operations which were conducted in the State of Uttaranchal were the ground operations like raising invoices and running assessee's establishment in connection with the operations conducted by the assessee's employees on the locations directed by the assessee's client and moreover, the charging of service tax in the invoices raised by the assessee on its clients further confirmed that the assessee is only providing services....
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....R objects to the AO's contention that the appellant activities cannot be termed as an "industry". He has relied on the cases of National Union of Commercial Employees vs. M.R. Meher and Bangalore Water Supply & Sewerage Board vs. A. Rajappa reported in 38 CT 207 (SC). The Id. AR has also distinguished the case of MSCO (P) Ltd. vs. UOI reported in AIR 1985 SC 76, 79, relied upon by the AO. The Id. AR has also relied upon a document issued by the Department of Information Technology (IT.), Govt. of India to canvass the view that for the IT. Sector 'industry' would include all the services envisaged for this sector and that the term 'industry' cannot be confined to production or manufacture of goods. It has also been mentioned that NASSCOM also tends to use the term 'industry' for activities peculiar to the I.T. Industry. Thereafter extracts from KPMG's paper on the I.T. Industry prepared for CII in 2008 have also been mentioned for claiming that the activities associated with the I.T. Industry are 'industry'. In similar vein several other papers from reputed organizations have also been cited. (iii) The Id. AR has cited the Notification No....
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.... the report of the Id. AO was also handed over to the Id, AR for his comments. The Id, AR has utilized the opportunity provided to file detailed submissions on the same on two occasions on 25.08.2011 and 22.09.2011. Thus, nothing has been done behind the appellant's back and all findings by Id, AO have been shared with the appellant. (ii) The Id. AR has also contended that fresh material has been unearthed by the AO which was not before the AO while passing the assessment order, thus, this new material should not be relied upon in appellate proceedings. The Id. AR has relied upon the following cases in support of his contention which may be discussed:- (a) CIT vs. Buildwell Assam (P) Ltd. 133 ITR 736 (Gauh): In this case, the Court had observed that the directions by the superior authority to subordinate authorities must be firm and clear and the subordinate authorities must carry out the directions. From this case law, no infirmity on the part of the AO can be inferred and the Id. AR's contention that the AO exceeded her brief through a more rigorous approach than what was allegedly warranted, is hard to accept since this case law does not intend to fette....
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....n para 4.4 of the impugned order, for the cost of repetition, the same is not reproduced herein. On merit of the case, the assessee furnished the written submission which has been incorporated by the ld. CIT(A) in para 5 of the impugned order which read as under: "4.THE APPELLANT IS ENGAGED IN INFORMATION & COMMUNICATION TECHNOLOGY INDUSTRY OPERATIONS /ACTIVITIES 4.1 The Assessing Officer has contended that the appellant is providing services in the nature of 'Manpower Recruitment and Supplier' relying upon the data available gathered from a variety of sources such as website of the appellant company, Form No. 3CD of the Audit Report of the relevant financial year, website of the Ministry of Corporate Affairs and service tax registration of the appellant company. 4.2 It is respectfully submitted that the appellant company is engaged in the business of providing 'information and communication technology services' and services related thereto which consist of inter alia, application development and support services, technical help desk support services, on call support services etc. The target clients of the appellant are telecom and softwar....
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....ertaking various projects in the field of ICT. The employees of the appellant meeting the specifications provided by the clients are assigned to various ICT related projects. The remuneration for the services provided by the appellant company is charged not in terms of per man hours or man days spent but on a fixed fee basis per month based upon level of personnel working on the project. Attention in this regard is invited to page 4 of the Assessment Order where the Assessing Officer has reproduced the details of professional services charges. 4.5 The Assessing Officer's finding that the appellant company is engaged in supply of computer skilled personnel is based on a misreading of the services provided by the appellant company to their clients. It is respectfully submitted that merely because specific employees are assigned to work on a particular project, it cannot be concluded that the appellant is engaged in the business of supplying personnel. It would be appreciated that the personnel working on the projects are employees of the appellant company, and not of the clients of the appellant. As already submitted, the appellant is recognized as the employer of such e....
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....e information and communication technology services cannot be interpreted to mean that the appellant is engaged in the business of 'body shopping' or is acting merely as a 'staffing agency'. 4.9 The fact that such skilled personnel are required to work on-site at the clients' premises can by no means be taken to imply that the company is 'supplying' such personnel to its clients. ICT services by their very nature have to be rendered through deployment of personnel possessing requisite skills. The fact that such personnel are often required to work onsite at the clients ' premises does not change the nature of the services provided by the appellant company Such services remain ICT services regardless of whether they are rendered through personnel working from the appellants' premises, or through personnel deployed at the clients site. 4.10 The Assessing Officer has in paragraph 5.1.2 of the remand report relied upon the website of the appellant company and concluded that the appellant merely acts as a 'Master Staffing Supplier'. It is most respectfully submitted that in order to derive the true intent and colour of any do....
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....o. 4.12 The Assessing Officer has in paragraph 5.1.3 of the remand report placed reliance upon the website of the Ministry of Corporate Affairs and the Memorandum Association of the company wherein the object of the company is 'to establish, provide, perform and render technical and consultancy services relating to information technology enabled services of multidisciplinary character in all areas including human activities in or outside India and to act as advisors or consultants on all matters, aspects and to provide all types of services consequential or incidental thereto'. On the basis of the said clause, the Assessing Officer has concluded that the assessee company 'itself is not engaged in IT services, it is merely providing consultancy services to others'. In this regard, it is humbly submitted by the appellant that a conjunctive reading of the entire 'Object Clause' as cited by the Assessing Officer clearly shows that the appellant is providing 'technical and consultancy services of a multidisciplinary character relating to information technology'. It is respectfully submitted that the conclusion reached by the Assessing Officer is ....
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.... (xi) Payroll; (xii) Remote Maintenance; (xiii)Revenue Accounting; (xiv) Support Centres, and (xv) Web-site Services. In view of the above, it is respectfully submitted that the appellant is engaged in the business of providing ICT services for manufacture of computer software. (Please refer to paragraph 2.15 to 2.17.3 of our submissions, dated 14.12.2010 wherein detailed submissions have been made in this regard). 4.14 Without prejudice to the submission of the appellant that the appellant is engaged in the business of providing ICT services, it is respectfully submitted that even if it is assumed that the appellant is engaged in the business of providing 'Human Resource Services' for its clients in the ICT Industry, the appellant would still be eligible to claim deduction under Section 80IC of the Act. It would be appreciated that 'human resource services' is one of the categories of services which have been expressly included within the definition of 'computer software' given in Section 10A of the Act vide Notification No. SO 890(E) dated 26.09.2000 issued by the Central Board of Direct Taxes (CBDT)." ....
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....cer has misconstrued this to mean shifting of the accounting operations to Dehradun in order to claim tax benefits under Section 80IC. 5.3 The Assessing Officer has, at paragraph 6.2 & 6.2.1 of the remand report, also contended that the appellant is in effect providing rented floor area to other information technology companies. In this regard it is also humbly submitted by the appellant that it has obtained license from the appropriate authorities in order to be registered as a STPU and is adequately carrying out the services in the nature of 'Information and Communication Technology Industry'. The appellant does not dispute the fact that in the STPU setup by it, a proportion of the area has been rented out to other IT companies and the income derived there from is in the nature of 'Income from House Property'. However, as is evident from the Assessment Order dated 23.12.2009, the appellant has not claimed deduction in respect of such income, and the same has been adequately offered for tax under the appropriate head. It is also submitted that a proportion of the area in the STPU is also being used by the appellant for rendering its services to the clients....
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....e not absolute and unfettered, and cannot be exercised without having regard to the form, manner and restrictions prescribed in regard to exercise of these powers. The Assessing Officer has not disclosed the specific provisions of the Act under which the visit was made, or under which the so-called information / evidence was gathered. Hence, both the visit and the 'evidence' gathered during such visit are vitiated by reason of not being in accordance with law. 5.7 The Assessing Officer has not mentioned the name or status of the 'employees' to whom questions were put during the visit. Further, the statements or answers of such 'employees' have not been formally recorded under the relevant provisions of the Act. In fact, such statements or answers have not even been reduced to writing. Hence, the appellant is not in a position to rebut or challenge these 'statements' Even if it is assumed for the sake of argument that the visit of the Assessing Officer was in accordance with law, no opportunity to cross examine was given to the appellant. For that reason also, the allegations made on the basis of the purported 'statements' of the witn....
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....the projects and the requirements of the client. The projects on which the appellant and its employees work are in the nature of intellectual property and therefore require confidentiality and protection. It is also submitted that detailed perusal of the service agreements between the assessee and its clients would also reveal that there are a variety of services which are rendered by the assessee to its clients both on-line and on-site, all of which are in the nature of IT services. 5.10 Reference is invited in this regard on Circular No. 694 dated 22-11-1994, wherein the CBDT has clarified that, for the-purpose of tax holiday under sections 80HHE, 10A and 10B of the Act, on-site performance of software operations would be deemed to be manufacture/production of computer software by the unit. Attention in this regard is also invited to Explanation 3 to Section 10A wherein it is provided that profits from onsite development of software outside India would be deemed to be profits from export of computer software outside India. From the aforesaid it can be inferred that the onsite development of software and provision of IT services is covered within the activity /operation "....
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....npower to I.T. companies/clients since 1995. So, it was not a new unit which commenced operations from January, 2006. 16. The assessee had taken a strong objection to the said observation of the learned CIT(A) and stated that the Software Technology Park Unit (STPU) of the assessee commenced operations from January, 2006. However, the ld. CIT(A) relied upon the following inferences drawn by the AO: "a) The appellant did not begin or began producing article or thing necessary for claiming deduction u/s 80-IC of the Act in 2006 as claimed. The STPU has been leased out to the extent of 90% of usable space (10% is used by appellant) and the income from such leasing is shown as income from house property for which no deduction u/s 80IC of the Act has been claimed for obvious reasons. If the date of commencement of operations to the extent of recruitment and deployment of manpower is actually linked with the date of shifting the registered office to Dehradun on 18.12.2008 then that date would decide the actual commencement of operations for the purposes of satisfying the conditions laid down in Sec. 80-IC of the Act. b) The words "has begun" or "begins" are not new a....
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....ntract documents, the said address was mentioned. He further observed that the assessee's case was obviously not a case of splitting up but may be a case of reconstruction of business already in existence. The reliance was placed on the following case laws: * JCIT Vs Thirani Chemicals Ltd. (2010) 40 SOT 530 (Del.) (SB) * Nagardas Bechardas & Brothers (P.) Ltd. Vs CIT (1976) 104 ITR 255 (Guj.) * CIT Vs Gaekwar Foam and Rubber Co. Ltd.(1959) 35 ITR 662 (Bom.) * Textile Machinery Corporation Ltd. Vs CIT 107 ITR 195 (SC) 18. The ld. CIT(A) also observed that the assessee had been recruiting and supplying manpower to various companies for engagement in Information Technology functions, this activity had continued unchanged between the old and new avatars of the assessee and the construction of STPU had been only a reconstruction of business and not being part of business eligible for claiming deduction u/s 80IC of the Act, and that it would bring the assessee within the ambit of Section 80IC(4) of the Act since the assessee's activity in the State of Uttarakhand were as a result of construction of an already existing business which would deny the b....
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.... Nil TOTAL 5,20,28,467 23,02,858 On the basis of aforesaid details, the ld. CIT(A) observed that the percentage of revenue generated by manpower deployed in the State of Uttarakhand came to only 4.24% of the total revenue generated at Rs. 5,43,31,325/- (Rs.5,20,28,467/- + Rs. 23,02,858/-). He further observed that even if for a moment for the sake of argument, we subscribe to the view that the assessee was covered under Schedule 14 then too a very significant percentage of 95.76% was done outside the State of Uttarakhand and that the findings of the AO in the remand report that back office functions only were being performed by a few staff posted at the address of the assessee at Dehradun, leads to the inevitable conclusion that even if the activities of the assessee as eligible under Schedule 14 then too all such eligible (u/s 80IC) activities were being carried out outside the State of Uttarakhand and only non-eligible (u/s 80IC of the Act) activities were being carried out in the State of Uttarakhand. He also observed that the assessee though vehemently claimed that all its managerial/supervisory/control functions were being carried out from Dehradun, it was still ....
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.... geographical regions of the country. Thus the appellant's business cannot be said to fall within the purview of Schedule 14 of the Act. (C) The appellant's business claimed to be eligible for the purposes of section 80IC of the Act has been formed by reconstruction of an already existing business. Thus the claim of appellant is hit by section 80-IC(4) of the Act. (D) It has been demonstrated on the basis of appellant's own admission that merely 4.24% of the revenues from deploying manpower with various companies is attributable to the State of Uttarakhand. This implies that revenue generation is taking place outside the State but benefit u/s 80IC of the Act is sought to be availed by having a token presence at Dehradun. (E) From a perusal of documents filed during appellate proceedings and the facts gathered by the Id. AO, it is seen that the appellant has presence in terms of infrastructure etc. outside Uttarakhand at places like Gurgaon and Bangalore, but instead of apportioning revenues and expenses between all such units, all receipts/profits have been shown at the Dehradun unit as claim eligible for deduction u/s 80IC of the Act." In ....
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....of the assessee's paper book). It was emphasised that the activities of the assessee are duly covered under clause 13 of part (c) of Schedule XIV of the Income Tax Act as mentioned in Sub-Section 2(b) of Section 80IC of the Act, which provides that the activities of Information and Communication Technology Industry, Computer hardware, call centers to be eligible for deduction u/s 80IC of the Act. It was submitted that the assessee was engaged in the field of providing services of the Information and Communication Technology and its personnel were engaged to work with the clients at premises of their choice for efficiency and maintaining confidentiality, the personnel so engaged were employees of the assessee in every respect and they were deployed on the basis of contractual relationship between the assessee and the IT Company/clients and not due to any contract between the IT Company/client and the personnel deployed. It was stated that in the Information and Communication Technology Industry, specific work is often required to be remitted at the site of the client as per the later's requirements, the Software development and maintenance/repair of hardware are the examples of such....
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.... its member companies are stated to be broadly in the business of software development, software services, software products, consulting services, BPO services, e-commerce & web services, engineering services, off-shoring, animation & gaming, also tends to use the term "industry" for the activities peculiar to the I.T. Industry. It was also contended that the term "Industry" as understood in the world of Information and Communication Technology not limited to manufacture of goods only but also covers the rendering of services, a reference was made to page nos. 299 & 300 of the assessee's paper book. The ld. Counsel for the assessee also cited the Notification No. SO 890 (E) dated 26.09.2000 issued in respect of Sections 10A, 10B and 80HHE of the Act. vide which, the CBDT specified the following Information Technology enabled products or services for the purpose of above said sections: (i) Back-office Operations; (ii) Call Centres; (iii) Content Development or Animation; (iv) Data Processing; (v) Engineering and Design; (vi) Geographic Information System Services; (vii) Human Resource Services; (viii)Insurance C....
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....n Technology and IT enabled services including Software Development and maintenance". It was contended that the meaning of industry cannot be restricted to the manufacturing or production of articles because the rendering of services is also included for claiming the deduction u/s 80IC of the Act and that the service activities undertaken by the assessee fall in the definition of "industry". A reference was made to page nos. 201 to 298 of the assessee's paper book which are the copies of industrial profile of the assessee. It was further stated that the assessee recruited the personnel, paid them salary/wages and instruct them to work on behalf of the assessee, at the various sites of the clients. Therefore, the claim of the assessee was in accordance with law which has to be allowed and the ld. CIT(A) was not justified in confirming the order of the AO who had disallowed the claim of the assessee u/s 80IC of the Act. 26. In his rival submissions, the ld. DR reiterated the observations made by the AO and the ld. CIT(A) in their respective orders. It was further submitted that the assessee was not an industry but a service provider, therefore, it was not eligible for deduction u/....
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....Processing Zone or Integrated Infrastructure Development Centre or Industrial Growth Centre or Industrial Estate or Industrial Park or Software Technology Park or Industrial Area or Theme Park, as notified by the Board in accordance with the scheme framed and notified by the Central Government in this regard, in any of the North-Eastern States; (b) which has begun or begins to manufacture or produce any article or thing, specified in the Fourteenth Schedule or commences any operation specified in that Schedule, or which manufactures or produces any article or thing, specified in the Fourteenth Schedule or commences any operation specified in that Schedule and undertakes substantial expansion during the period beginning- (i) on the 23rd day of December, 2002 and ending before the 1st day of April, 2012, in the State of Himachal Pradesh or the State of Uttaranchal; or (ii) on the 7th day of January, 2003 and ending before the 1st day of April, 2012, in the State of Himachal Pradesh or the State of Uttaranchal; or (iii) on the 24th day of December, 1997 and ending before the 1st day of April, 2007, in any of the North-Eastern States. (3) Th....
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.... (12) of section 80-IA shall, so far as may be, apply to the eligible undertaking or enterprise under this section." 28. From the above provisions, it is clear that the deduction u/s 80IC of the Act is available where the gross total income of an assessee includes any profits and gains derived by an undertaking or an enterprise from any business of manufacturing or production of any article or thing not being article or thing specified in Thirteenth Schedule or commenced any operation specified in Fourteenth Schedule and undertakes substantial expansion during the period beginning on the 7th day of January, 2003 and ending before 1st day of April, 2012 in the State of Himachal Pradesh or State of Uttaranchal. The claim of the assessee is that it was established during the period specified in Sub-Clause (ii) of Clause (a) of SubITA Section (2) to Section 80IC of the Act and it is providing the services specified in Fourteenth Schedule, therefore, it is eligible for deduction u/s 80IC of the Act. Now the controversy to be resolve before us as to whether the assessee was established in the State mentioned in Section 80IC(2)(a)(ii) and started the business in the specified period i.....
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....vices calculated to satisfy human wants and wishes (not spiritual or religious but inclusive of material things or services geared to celestial bliss, e.g., making on a large scale, prasad or food), prima facie there is an industry" in that enterprise. It was further observed that the true focus is functional and the decisive test is the nature of the activity with special emphasis on the employer-employee relations." From the ratio laid down by the Hon'ble Apex Court in the aforesaid referred to cases, it can safely be held that the word " industry" has a wide import and it is a systematic activity organized by co-operation between employer and employee for production and/or distribution of goods and services calculated to satisfy human wants and wishes. 29. In the present case, the assessee is a company incorporated at Dehradun, it is engaged in providing support services to IT companies like IBM, Nokia, Wipro Infotech, Tech Mahindra etc. The services provided are through various modes on-line, on-site or off-site depending on the nature of the clients. The various services provided by the assessee to its clients are Application Development & Support, Customer Care Services....
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....OW, Supplier will provide software support development activities, including but not limited to, software development, software resting, publication development, program maintenance, software development support and/or such other activities as may be defined by the Buyer to the Supplier in the relevant WA. Supplier will also provide to Buyer the Deliverables and Services described in Section 3.0 of this SOW." From the aforesaid agreements entered between the assessee and its clients, it is clear that assigned work was to be done by the employees of the assessee at the sites of the clients and there was no direct contract between the clients and employees. All the payments in lieu of the work done was the responsibility of the assessee and not of the clients. 30. In the present case, it is not in dispute that Part (c) of the Schedule Fourteenth of the Act relates to State of Himachal Pradesh and the State of Uttaranchal. The various activity or article or thing or operations are defined in the said Schedule which read as under: S. No. Activity or article or thing or operation 4/6 digit excise classification Sub-class under NIC classification on 1998 ITC(HS....
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....sed on atmospheric fraction) 17. Handicrafts 18. Non-timber forest product-based industries.] 31. From the aforesaid part (C) of Schedule Fourteenth, it is clear that the Information and Communication Technology Industry, Computer hardware, call centers are placed at item No. 13. The assessee is also engaged in the similar type of activities because it provides Software Support Development activities, programme maintenance services, software development support and software testing. Therefore, the activities undertaken by the assessee falls in category no. 13 of part C of Schedule Fourteenth of the Income Tax Act. In the present case, the AO while disallowing the claim of the assessee riled upon the decision of the Hon'ble Supreme Court in the case of MSCO Pvt. Ltd. Vs Union of India AIR 1985 SC 76. However, in the said decision, the Hon'ble Supreme court observed that the word "industry" has many meaning and that it is hazardous to interpret a word in accordance with its definition in another statute or statutory instr....
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....o. 13" of part C of the "Schedule Fourteenth" to the Income Tax Act, 1961. The assessee is situated at Dehradun which is the part of the State of Uttaranchal to which part C of "Schedule Fourteenth" applies. The SDE Telephones, Dehradun also issued a certificate copy of which is placed at Page No. 216 of the assessee's paper book which states that the assessee had been provided datacom links by them which was being used for transmission of data for development of Software for export purposes since 17th January 2006. The said certificate is placed at page no. 216 of the assessee's paper book and read as under: "CERTIFICATE BY DATACOM SERVICE PROVIDER Certified that M/s IMSI (India) Pvt. Ltd. have been provided datacom links by us referred in para "4" of Back-up Form. The link is being used by them for transmission of data for development of Software for export purposes since 17 Jan. 2006." Sd/- J.T.O. Telephones Clement Town Dehradun Sd/- S.D.E Telephones Clement Town Dehradun 33. The assessee situated at Dehradun is also having electricity meter in its name which is evident from page nos. 214 & 215 of the assessee's paper book which is the copy of the ele....