Vodafone Cellular Limited v. The Commissioner of Income-tax (Appeals)-II, Coimbatore / The Deputy Commissioner of Income-tax TDS Circle, Coimbatore
[Citation -2014-LL-1126]

Citation 2014-LL-1126
Appellant Name Vodafone Cellular Limited
Respondent Name The Commissioner of Income-tax (Appeals)-II, Coimbatore / The Deputy Commissioner of Income-tax TDS Circle, Coimbatore
Court HIGH COURT OF MADRAS
Relevant Act Income-tax
Date of Order 26/11/2014
Judgment View Judgment
Keyword Tags deduction of tax at source • discounted price • recovery of tax • speaking order • payment of tax • cash discount • stay petition • demand notice • interim stay • tax evasion • sales tax • deduct tax at source
Bot Summary: 2(a)The petitioner in these writ petitions seeks for issuance of writ of certiorari to quash the order passed by the first respondent dated 17.10.2014, rejecting the Stay Petition filed by the petitioner, praying for grant of stay of the demands payable pursuant to the orders of assessment under the Income Tax Act, 1961 for the assessment years 2012-13, 2013-14 2014-15. The petitioner filed a Stay Petition before the second respondent under section 220(6) of the Act on 31.01.2014, in respect of the demands made pursuant to the assessment orders dated 30.12.2013, for the assessment years 2013-14 2014-15. On 30.4.2014, the petitioner filed a Stay Petition under section 220(6) of the Act in respect of the demand made in terms of the assessment order for the assessment year 2012-13. The Stay Petition filed by the petitioner for the three assessment years were considered 5 by the first respondent and by order dated 17.10.2014, the same came to be rejected. 12.The question which falls for consideration in these Writ Petitions is as to whether the first respondent ignoring its earlier order in respect of the assessment years 2009-10 to 2011-12 is required to pass an order on the Stay Petition to stay the demand pursuant to the assessment orders relevant to these Writ Petitions. The petitioner did not produce the same and even after expiry of two weeks, the petitioner did not produce the cash position so as to examine the matter regarding their financial constraint claimed by the petitioner for non-payment TDS. The first respondent appears to have drawn an adverse inference and in my view, rightly so. 18.So far as the balance of convenience and hardship is concerned, despite opportunity, the petitioner did not produce the records nor there was any attempt made by the assessee to seek for further time to produce the records and it appears that there was no specific pleading in the Stay Petition about the financial capacity, even before the second respondent when the first petition for stay was presented on 31.12.2014.


1 IN HIGH COURT OF JUDICATURE AT MADRAS DATED: 26.11.2014 Date of Reserving Judgment Date of Pronouncing Judgment 24.11.2014 26.11.2014 Coram Hon'ble Mr. Justice T.S. SIVAGNANAM W.P. Nos.30650 to 30652 of 2014 & Connected Mps. Vodafone Cellular Limited .. Petitioner in all W.Ps. Vs 1.The Commissioner of Income Tax (Appeals) II 63-A, Race Course Road, Coimbatore. 2.The Deputy Commissioner of Income Tax TDS Circle, 46, 63, Race Course Road Coimbatore. .. Respondents in all Wps. Common Prayer :-Petitions filed under Article 226 of Constitution of India praying to issue writ of certiorarified Mandamus to call for records comprised in order bearing Ref.C.No.CIT (A)(II)/PDL/6/CMBB03049E/14-15 dated 17.10.2014, passed by Respondent No.1, and quash same and consequently direct respondents to forbear from acting in pursuance or in furtherance of assessment orders dated 29.03.2014 & 3012.2013 & made in TAN No.CMBB03049E under section 201(1) and 201(A) of Act by Respondent No.2, for Assessment years 2012-13, 2014-15 & 2013-14, pending disposal of Appeal filed before Respondent No.1 against said assessment order. 2 For petitioner .. Mr.Arvind (P) Datar,Sr.Counsel for Mr.Satish Parasaran For Respondents .. Mr.T.Pramod Kumar Chopda ************* COMMON ORDER Since prayer sought for in all these Writ Petitions are identical these Writ Petitions were heard together and are disposed of by this common order. 2(a)The petitioner in these writ petitions seeks for issuance of writ of certiorari to quash order passed by first respondent dated 17.10.2014, rejecting Stay Petition filed by petitioner, praying for grant of stay of demands payable pursuant to orders of assessment under Income Tax Act, 1961 for assessment years 2012-13, 2013-14 & 2014-15. (b)Pursuant to survey conducted under section 133 of Income Tax Act, 1961 ('Act'), on 17.09.2013, petitioner was issued notice by second respondent stating that there was omission on their part to deduct tax at source in respect of 3 Commission payments on pre-paid charges and it is proposed to raise demands in respect of such commission payments as in previous years. It was further stated that as proposed order under sections 201(1) and 201(1A) of Act will be in respect of default under section 194H of Act, petitioner was directed to submit their objections to said notice dated 21.10.2013, pertaining to financial years 2012-13 & 2013-14. (c)By communication dated 16.12.2013, petitioner submitted certain details which information was sought for by second respondent during course of personal hearing on 10.11.2013. Thereafter, assessment orders were passed for assessment years 2012-13, 2013-14 & 2014-15 on 30.12.2013. petitioner filed Stay Petition before second respondent under section 220(6) of Act on 31.01.2014, in respect of demands made pursuant to assessment orders dated 30.12.2013, for assessment years 2013-14 & 2014-15. petitioner preferred Appeals to first respondent against assessment orders dated 30.12.2013, passed by second respondent in respect of assessment years 2013-14 & 2014-15 on 03.02.2014. 4 (d)The second respondent passed order rejecting Stay Petition by order dated 07.02.2014. Thereupon petitioner filed Petition before first respondent praying for stay of demand till disposal of Appeals, which were pending as Appeal Nos. 305/13-14 and 308/13-14, for financial years 2012-13 and 2013-14. (e)With regard to assessment year 2012-13, second respondent passed order of assessment on 29.03.2014, confirming proposal and notice of demand was issued on 29.3.2014, demanding sum of Rs.10,05,75,866/- for assessment year 2012-13. petitioner preferred appeal to first respondent against said order of assessment dated 29.03.2014 for assessment year 2012-13. On 30.4.2014, petitioner filed Stay Petition under section 220(6) of Act in respect of demand made in terms of assessment order for assessment year 2012-13. second respondent by order dated 20.6.2014, following its earlier order dated 07.02.2014, for assessments years 2013-14 and 2014-15, rejected Stay Petition. Thereupon, petitioner filed Stay Petition before first respondent on 01.07.2014. Stay Petition filed by petitioner for three assessment years were considered 5 by first respondent and by order dated 17.10.2014, same came to be rejected. Challenging said order, these Writ Petitions have been filed. 3.Mr.Arvind P Datar, learned Senior counsel appearing for petitioner made elaborate reference to nature of transaction done by petitioner with its customers in matter of sale of prepaid sim cards and distinction between transaction in respect of prepaid sim cards and post-paid sim cards were placed for consideration of this Court. 4.It is submitted that authority without considering Stay Petition in proper perspective and without assigning any reason, much less proper reasons, has rejected Stay Petition. It is submitted by way of illustration that if cost of pre-paid sim card is Rs.100/-, petitioner would sell same to his Wholesale Distributor at Rs.80/- and Distributor further distributes same to his Sub-Distributors, which could contain discounts and Distributor does not ipso facto earn income just by purchasing coupons from petitioner and only if he is able to distribute them will it be treated as income earned by Distributor. Hence there is 6 no fixed amount of income from distribution agreement. Further it is submitted that transaction between petitioner and its pre- paid Distributor as being on principal to principal basis, question of deducting TDS does not arise. Further, it is submitted with regard to decision of Income Tax Appellate Tribunal on TDS liability for assessment years 2007-2008 and 2008-09, same is pending before this Court in T.C.Appeal Nos. 308 & 309 of 2011 and conditional interim order has been granted and 50% of demand has been paid. 5.Learned Senior Counsel after inviting attention of this Court to averments in Stay Petition, submitted that petitioner placed reliance on decisions of Kerala High Court in case of M/S HAMEED AND OTHERS v. DIRECTOR OF STATE LOTTERIES 7 OTHERES [249 ITR 186]; decision of Gujarat High Court in case of AHMEDABAD STAMP VENDORS ASSN. v. UNION OF INDIA [(2002) 257 ITR 202]; decision of Allahadbad High Court in case of JAGRAN PRAKASHAN LIMITED [345 ITR 288] and decision of Kerala High Court in case of KERALA STATE STAMP VENDORS ASSOCIATION v. OFFICE OF ACCOUNTANT GENERAL AND ORS [ 282 ITR 7], however, without reference to those 7 decisions, first respondent mechanically rejected Stay Petition, without considering three essential requirements viz. prima facie case, balance of convenience and irreparable hardship. 6.Further it is submitted that issue with regard to liability to effect TDS on discount on prepaid coupons is pending before Hon'ble Supreme Court in case of other telecom operators and Hon'ble Supreme Court has also granted interim relief in those cases. 7.Further decision of Gujarat High Court in case of AHMEDABAD STAMP VENDORS ASSN.(supra), has been confimed by Hon'ble Supreme Court in case of COMMISSIONER OF INCOME TAX AND ORS. v. AHMEDABAD STAMP VENDORS ASSOCIATION [(2012) 348 ITR 378 (SC)], which was delivered by Hon'ble Supreme Court on 06.0.2012 and that should have been taken note by authority while considering Stay Petition. Further, it is submitted that in respect of Stamp Vendors Association, in respect of Milk Vendors Association and transactions relating to Soft Drinks, Hon'ble Supreme Court has taken view that there is no requirement of deduction of TDs in identical type of transactions and therefore petitioner having established prima facie case and balance of 8 convenience being in their favour, first respondent ought to have stayed demand till disposal of Appeals. 8.Per contra, Mr. T.Pramod Kumar Chopda, assisted by Mr.S.Rajkumar, appearing for Revenue, submitted that order passed in respect of earlier assessment orders of petitioner/ assessee, is now pending before this Court in T.C.Nos. 308 & 309 of 2011 and tax case has been admitted on 09.09.2009 and interim order has been granted subject to deposit of 50% of demand. It is submitted that effect of decision in case of AHMEDABAD STAMP VENDORS ASSN.(supra), and types of transaction done by petitioner/assessee has to be decided by Hon'ble Supreme Court and as on date, first respondent was fully justified in following earlier order passed in respect of assessment years 2007-08 and 2008-09, which has been decided in favour of Revenue. 9.Further, respondent cannot ignore its earlier orders. It is submitted that though hearing notice was given to petitioner and they were directed to produce required details, they have not produced same and at present they cannot contend that accounts are on 9 all India basis, etc. and having not produced accounts as called for, petitioner cannot claim that matter should be remanded for fresh consideration before authority. 10.Heard learned counsel appearing on either side and perused materials placed on record. 11.So far as assessment years 2009-10, 2010-11 and 2011- 12, Commissioner of Income Tax (Appeals), has upheld orders of Assessing Officer, wherein identical issue has arisen for consideration. In so far as assessment years 2007-08 and 2008-09, Commissioner of Income Tax (Appeals) has confirmed order of Assessing Officer and Income Tax Appellate Tribunal has rejected petitioner's appeal and petitioner has filed Tax Case (Appeals) before this Court and it is pending consideration and conditional order of stay has been granted. 12.The question which falls for consideration in these Writ Petitions is as to whether first respondent ignoring its earlier order in respect of assessment years 2009-10 to 2011-12 is required to pass order on Stay Petition to stay demand pursuant to assessment orders relevant to these Writ Petitions. 10 13.Before considering this issue, it has to be noted that notice was issued to petitioner on 19.9.2014, calling upon petitioner to produce copies of Books of Accounts maintained by them, to verify balances/fund available as on date. petitioner did not produce same and even after expiry of two weeks, petitioner did not produce cash position so as to examine matter regarding their financial constraint claimed by petitioner for non-payment TDS. first respondent appears to have drawn adverse inference and in my view, rightly so. Learned Senior counsel appearing for petitioner also states that all was not well as to manner in which petitioner seeks to justify non production of Accounts. 14.Be that as it may, unless and until petitioner places materials before first respondent, pleading financial incapacity or inability to pay demand, pending decision of Appeal, authority who is consider Stay Petition cannot be faulted for having taken decision that petitioner/applicant has not established prima facie case. 15.The sheet anchor of contentions raised by learned Senior Counsel appearing for petitioner is that decision in 11 case of AHMEDABAD STAMP VENDORS ASSN.(supra), has been upheld by Hon'ble Supreme Court and that transaction is akin to that of sale of prepaid sim cards and Hon'ble Supreme Court has held that there was no error in discount given to Stamp Vendors for purchasing stamps in bulk quantity and same is in nature of cash discount and in circumstances transaction is sale and consequently, section 194 H of Income Tax Act, 1961, has no application. By placing reliance on decision, it is submitted that Officer should have considered this issue when petitioner has relied on decision of Gujarat High Court. 16.It is to be pointed out that in respect of petitioner, for assessment year 2004-05 to 2007-08, identical issues arose for consideration before Kerala High Court. One of issue which fell for consideration in those cases is regarding payments made for services rendered by Distributors under pre-paid scheme. appellant therein took stand that supply of sim cards, recharge coupons etc., under prepaid scheme is sale of goods at discounted price by Assessee and besides discount given at time of sale of these items, Assessee is not paying any commission or crediting any commission in account of distributors and so 12 much so, Assessee is not liable to deduct and remit tax at source in terms of Section 194H of Act. Considering said submission, Division Bench of Kerla High Court held as follows: "6. Senior counsel appearing for assessee has relied on several judgments, particularly two decisions of this court in M.S.HAMEED V. DIRECTOR OF STATE LOTTERIES reported in (2001) 114 TAXMAN 394 (KER.) and KERALA STATE STAMP VENDORS ASSOCIATION V. OFFICE OF ACCOUNTANT GENERAL reported in (2006) 150 TAXMAN 30(KER.), decision of Gujarat High Court in AHMEDABAD STAMP VENDORS ASSOCIATION V. UNION OF INDIA reported in (2002) 124 TAXMAN 628 (GUJ.), and decision of Bombay High Court in COMMISSIONER OF INCOME TAX V. QUTAR AIRWAYS in I.T.A. No.99 of 2009 dated 26.3.2009. first decision of this court pertains to sale of lottery tickets wherein this court held that commission given by way of discount at time of sale of lottery tickets is not commission on which tax is deductible under Section 194G of Act. second decision of this court pertains to sale of stamp paper by licensed stamp vendors wherein also finding of this court following decision of Gujarat High Court in AHMEDABAD STAMP VENDORS' case is that transaction is sale of goods and so much so, no deduction of tax is called for under Section 194G of Act. So far as lottery ticket is concerned, transaction is different and Supreme Court has held that transaction is sale of goods and so much so, decision rendered by this court has no application in regard to commission paid by assessee to distributors in form of discount which we have found to be in essence and substance for rendering services. next judgment relied on by petitioner which is in KERALA STAMP VENDORS ASSOCIATION case rendered by one of us (C.N.Ramachandran Nair, J.), relates to sale of stamp paper by licensed vendors. Here again, this court by relying on decision of Gujarat High Court in AHMEDABAD STAMP VENDORS case held that transaction is sale. On reconsideration of this judgment, we feel this court's judgment may require reconsideration because consideration received by stamp vendors for stamp paper does not really represent it's value but is nothing but stamp duty. Value of each stamp paper may be fifty paise or even rupee, whatever be it's quality, but what is collected depends on amount stamped thereon which is nothing but 13 stamp duty recovered by State from ultimate user in terms of Stamp Act. Rightly or wrongly this court held that transaction is sale because loss of stamp paper is to account of stamp vendors, if it is lost in their custody. Government also treats transaction as sale of goods and specific exemption is granted from payment of sales tax in terms of provisions of Sales Tax Act. Therefore, finding that Section 194H is not applicable is on specific finding in that case that transaction is sale of goods, whereas in this case following Division Bench judgment of this court we have found that distributor is paid commission in form of discount for services rendered to assessee. Therefore, none of these decisions relied on by assessee applies to facts of this case which is payment of commission by way of discount for services rendered by distributor. Senior counsel for assessee has in support of his contentions relied on following decisions of Supreme Court also, ADDITIONAL COMMISSIOENR OF INCOME TAX V. SURAT ART SILK CLOTH MANUFACTURERS ASSOCIATION reported in (1980) 121 ITR 1, KEDARNATH JUTE MANUFACTURING CO. V. COMMISSIONER OF INCOME TAX reported in 82 ITR 363, COMMISSIONER OF INCOME TAX V. MOTORS 7 GENERAL STORES (P) LTD. (1967) 66 ITR 692, COMMISSIONER OF INCOME TAX V. AJAX PRODUCTS LTD. (1965) 55 ITR 741, COMMISSIONER OF INCOME TAX V. B.C.SRINIVASA SETTY (1981) 128 ITR 294, TUTICORIN ALKALI CHEMICALS & FERTILIZERS LTD. V. COMMISSIONER OF INCOME TAX (1997) 227 ITR 172 and decisions of House of Lords in INLAND REVNUE COMMISSIONERS V. WESLEYAN GENERAL ASSURANCE SOCIETY reported in (1948) 16 ITR 101 and another decision in REVENUE COMMISSIONERS V. DUKE OF WESTMINSTER reported in (1936) A.C. 1. However, on going through these judgments we do not find any of judgment has any direct application to facts of this case. very scheme of deduction of tax at source under Income Tax Act is to trace recipients of income and their accountability to department for payment of tax on various transactions. In fact, major portion of income tax collection is through recovery of tax at source and but for mechanism, there would have been massive evasion of tax by recipients of various kinds of income. trend in legislation is to increase coverage for recovery of tax at source and on steady basis various services are brought under TDS scheme so that tax evasion is avoided. We have already taken note of provision under Section 197 of Act which mitigates against hardship if any in recovery of tax in as much as payee is entitled to approach department and apply for certificate to receive any amount which would be otherwise subject to deduction of tax at source without recovery of any tax or on 14 recovery at lesser rates. We are of view that grievance if any against recovery of tax by assessee is on distributors, and they are already on roles of department because assessee is making deduction of tax at source for payment of commission made under post paid scheme. As already pointed out, if distributors have any grievance against assessee recovering tax for commission paid in form of discount in respect of prepaid services, any such distributor is free to approach department for getting his grievance redressed by filing application under Section 197 of Income Tax Act. However, we make it clear that this is not ground on which we have held assessee liable for recovery of tax at source under Section 194H which is only because we have clearly found that discount paid to distributors is for service rendered by them and same amounts to "commission" within meaning of that term contained under Explanation (i) to Section 194H of Act. impugned orders issued under Section 201(1) and 201(1A) of Act are only consequential orders passed on account of default committed by assessee under Section 194H and, therefore, those orders were rightly upheld by Tribunal. We, therefore, dismiss all appeals filed by assessee. " It is submitted that as against Judgment of Kerala High Court, petitioner has preferred Appeal and matter is now pending before Hon'ble Supreme Court. 17.It is to be stated that decision of Kerala High Court in case of petitioner/assessee referred supra was followed by Delhi High Court and Calcutta High Court. Learned Senior counsel submits that Karnataka High Court has taken different view. However, as on date in assessee's own case, decision of Kerala High Court supports stand of Revenue. In such circumstances, first respondent while considering Petition for 15 Stay, took note of earlier orders for assessment years 2009-10 to 2011-12, which was on same issue and pending as Appeal before Tribunal and in respect of assessment years 2007-08 and 2008-09, it has been affirmedby Tribunal and in absence of production of Bank Accounts and fund availability, etc., rejected Stay Petition. Thus, while applying three cardinal principles while considering Stay Petition, decision in assesses own case as on date stands concluded in favour of Revenue. Therefore, to that extent petitioner has not been able to establish prima facie case. 18.So far as balance of convenience and hardship is concerned, despite opportunity, petitioner did not produce records nor there was any attempt made by assessee to seek for further time to produce records and it appears that there was no specific pleading in Stay Petition about financial capacity, even before second respondent when first petition for stay was presented on 31.12.2014. 19.Section 220 of act would treat assessee to be assessee in default when he does not meet tax liability in respect of demand raised by demand notice under section 156 of Act. discretion conferred on Assessing Officer under sub section (6) 16 of Section 220 of Act, is not arbitrary power, but power coupled with responsibility and assessing officer concerned should take all circumstances into account and all considerations that could be urged by assessee as to why he should not be treated as "not being in default" and then make order as is provided to facts of case. [see Mahalingam Chettiyar (MLM) vs. ITO [(1967) 66 ITR (Madras)]. 20.The other principle which has to be borne in mind is with regard to fair chance of success of assessee in its appeal, apart from hardship which assessee will be put to or financial soundness of assessee. Further more, when demand in dispute relates to issues which was decided in favour of Revenue by Appellate Authority and Tribunal in assessee's own case, then it would have direct bearing on case of assessee in respect of subsequent demand against which appeal has been preferred. However, underlying principle is that grant of stay is matter of discretion, mere pendency of appeal before appellate authority will not amount to automatic stay of demand. 21.A contention was raised by learned Senior Counsel for petitioner stating that impugned order is not speaking order and 17 devoid of reasons. assessing officer or that matter, appellate authority should take into consideration facts placed by assessee and factors and circumstances pleaded by them. In instant case, it is not in dispute that in assess's own case for earlier assessment years, order of assessment has been upheld by Commissioner of Income Tax (Appeals). However, in respect of anterior period i.e. for 2007-08 and 2008-09, Tribunal confirmed order passed by Commissioner of Income Tax (Appeals), against which petitioner has preferred Tax Case Appeal Nos.308 & 309 of 2011, which has been admitted by Hon'ble Division Bench of this Court on 09.09.2011 and order of interim stay has been granted, subject to condition petitioner pays 50% of demand. 22.Therefore, in my view though reasoning of first respondent while rejecting Stay Petition cannot be faulted in its entirety, but fact that on date when order was passed, Commissioner of Income Tax (Appeals) ought to have noted that appeal arising out of assessment orders for years 2007-08 and 2008-09, has been entertained by Hon'ble Division Bench of this Court in TCA No. 308 & 309 of 2011 and appeals have been admitted 18 on 09.09.2011 and interim order has also been granted. 23.This undoubtedly would be very relevant factor to consider two of cardinal tests viz. prima facie case and balance of convenience. If legal issue is now pending before Hon'ble Division Bench of this Court and order of interim stay has been granted, subject to certain conditions, that should have been considered by first respondent while passing impugned order dated 17.10.2014. 24.In light of above discussion, this Court is not inclined to interfere with impugned order on grounds raised by petitioner stating that decision of Gujarat High Court ought to have been taken note of by Commissioner of Income Tax (Appeals), despite fact that in assessee's own case, Division Bench of Kerala High Court has held against assessee. However, considering fact that in respect of earlier assessment year 2007-08 and 2008-09, in respect of identical transaction TCA Nos. 308 & 309 of 2011 are pending before Hon'ble Division Bench of this Court and have been admitted on following questions of law viz. 19 "1.Whether Tribunal was right in holding that transaction between appellant and distributors of its prepaid SIM cards and recharge coupons was contract of agency and not on principal-to- principal basis ? 2.Whether Tribunal was right in holding that discount offered on provision of Prepaid SIM cards and pre-paid recharge coupons (refill/recharge slip, refill/recharge cards, e-topup) i.e. pre-paid talk-time is commission envisaged under section 194H of Income Tax Act ? 3.Whether Tribunal was right in holding that tax deduction provisions can be applied to unascertained or indeterminable amounts in view of unworkability of computation provisions in such cases ? 4.Whether Tribunal was right in holding that Section 194H will apply to cases where person neither makes payment nor credits any sum to account to another person ?" and conditional order of stay has been granted, this Court is of view that petitioner has made out case for grant of interim order subject to certain conditions. 25.Accordingly, Writ Petitions are partly allowed by directing petitioner to deposit 50% of entire demand in respect of all three assessment years viz. 2012-13, 2013-14 and 2014-15, within 20 period of four weeks from date of receipt of copy of this order and if such direction is complied with, remaining amount demanded shall remain stayed till disposal of appeal by first respondent. If direction is not complied with, within time permitted, benefit of this order will not enure to petitioner and Writ Petition would stand dismissed without further reference to this Court. No costs. Consequently, connected Miscellaneous Petitions are closed. 26.11.2014 rpa Index :Yes/No Internet:Yes/No To 1.The Commissioner of Income Tax (Appeals) II 63-A, Race Course Road, Coimbatore. 2.The Deputy Commissioner of Income Tax TDS Circle, 46, 63, Race Course Road Coimbatore. 21 T.S. SIVAGNANAM, J. rpa Pre-delivery O r d e r in W.P. Nos.30650 to 30652 of 2014 26.11.2014 Vodafone Cellular Limited v. Commissioner of Income-tax (Appeals)-II, Coimbatore / Deputy Commissioner of Income-tax TDS Circle, Coimbatore
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