w w w . L a w y e r S e r v i c e s . i n



M/s. S. Subrahmanyan Constructions Company Private Limited, Rep., by its Director, R. Sankar v/s Assistant Commissioner of Income Tax, Corporate Circle 6(2), Nungambakkam


Company & Directors' Information:- C & C CONSTRUCTIONS LIMITED [Active] CIN = L45201DL1996PLC080401

Company & Directors' Information:- U G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400TN2010PTC074921

Company & Directors' Information:- A G R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG1997PTC028180

Company & Directors' Information:- N J R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209TG2009PTC065101

Company & Directors' Information:- C P R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2008PTC057937

Company & Directors' Information:- S T CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC127181

Company & Directors' Information:- J P G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC124763

Company & Directors' Information:- B O CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U00000DL2000PTC103440

Company & Directors' Information:- V R G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45208TN2013PTC090378

Company & Directors' Information:- G N R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70200KA2004PTC034839

Company & Directors' Information:- E C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL1998PTC092928

Company & Directors' Information:- I P CONSTRUCTIONS PVT LTD [Active] CIN = U45201DL2005PTC141372

Company & Directors' Information:- A R R S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45202TZ2008PTC014926

Company & Directors' Information:- S K CONSTRUCTIONS LIMITED [Amalgamated] CIN = U45200DL1972PLC006224

Company & Directors' Information:- D N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2011PTC074563

Company & Directors' Information:- D A P CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201WB1997PTC086056

Company & Directors' Information:- M R CONSTRUCTIONS PVT LTD [Active] CIN = U45202WB1987PTC041958

Company & Directors' Information:- E AND A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2007PTC052569

Company & Directors' Information:- J N C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1998PTC093071

Company & Directors' Information:- P R D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL2005PTC132422

Company & Directors' Information:- R A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74120DL1999PTC101132

Company & Directors' Information:- S V P CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U15100KA2013PTC072347

Company & Directors' Information:- V G V CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TZ2003PTC010825

Company & Directors' Information:- C K CONSTRUCTIONS INDIA PRIVATE LIMITED [Active] CIN = U45309DL2021PTC382589

Company & Directors' Information:- C L S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC074067

Company & Directors' Information:- R M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2005PTC136640

Company & Directors' Information:- CORPORATE INDIA PRIVATE LIMITED [Active] CIN = U74110DL1999PTC099505

Company & Directors' Information:- R K CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U45400UP2009PTC039089

Company & Directors' Information:- H M R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U27209WB1944PTC011901

Company & Directors' Information:- H A M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2005PTC140214

Company & Directors' Information:- B M R C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC126958

Company & Directors' Information:- A V A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200DL2006PTC154123

Company & Directors' Information:- N B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U70109DL2006PTC153179

Company & Directors' Information:- V P V CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202TZ2002PTC010021

Company & Directors' Information:- P K CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45202WB1990PTC048623

Company & Directors' Information:- D B S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201BR1990PTC003954

Company & Directors' Information:- P R P CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TN1995PTC032833

Company & Directors' Information:- N S CONSTRUCTIONS (INDIA) LIMITED [Active] CIN = U70101DL1997PLC088867

Company & Directors' Information:- B B CONSTRUCTIONS LTD [Active] CIN = U70101WB1988PLC045084

Company & Directors' Information:- S V P CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45203KA2013PTC072347

Company & Directors' Information:- S. C. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400AS2012PTC010876

Company & Directors' Information:- K & R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201AS2011PTC010822

Company & Directors' Information:- M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MH2004PTC148776

Company & Directors' Information:- V Y CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201UP2014PTC062964

Company & Directors' Information:- G V B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U70100TG1998PTC028935

Company & Directors' Information:- P K D CONSTRUCTIONS PVT LTD [Strike Off] CIN = U74999WB1980PTC032820

Company & Directors' Information:- H K P CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202OR2001PTC006458

Company & Directors' Information:- G S S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201TZ1992PTC003665

Company & Directors' Information:- C AND M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC130723

Company & Directors' Information:- A G P CONSTRUCTIONS COMPANY PRIVATE LIMITED [Active] CIN = U45201AN2006PTC000078

Company & Directors' Information:- S I A CONSTRUCTIONS PVT LTD [Active] CIN = U45202WB1993PTC061189

Company & Directors' Information:- P H CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45201DL2004PTC125388

Company & Directors' Information:- G G CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1987PTC028772

Company & Directors' Information:- N S V CONSTRUCTIONS PRIVATE LIMITED [Converted to LLP and Dissolved] CIN = U70101WB1997PTC084753

Company & Directors' Information:- S M C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201MH2000PTC123619

Company & Directors' Information:- T AND P CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45309PN2020PTC191603

Company & Directors' Information:- R K CONSTRUCTIONS PVT LTD [Strike Off] CIN = U24248UP1984PTC006613

Company & Directors' Information:- H V CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400MH2008PTC183930

Company & Directors' Information:- K M S CONSTRUCTIONS PVT LTD [Active] CIN = U26931TG1983PTC004119

Company & Directors' Information:- M S R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201TG2000PTC035352

Company & Directors' Information:- K P C CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45204DL2012PTC233771

Company & Directors' Information:- A G M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202KL2002PTC015340

Company & Directors' Information:- A N CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400UP2008PTC035171

Company & Directors' Information:- D N CONSTRUCTIONS PVT LTD [Active] CIN = U45203AS1983PTC002024

Company & Directors' Information:- P S V CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209TG2009PTC064768

Company & Directors' Information:- K B C CONSTRUCTIONS LIMITED [Strike Off] CIN = U45209CH2011PLC032890

Company & Directors' Information:- T T S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45403KL2020PTC064299

Company & Directors' Information:- V B R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG1997PTC027406

Company & Directors' Information:- M R Y CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400DL2008PTC172953

Company & Directors' Information:- V S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201KA1980PTC003939

Company & Directors' Information:- J B CONSTRUCTIONS LTD [Strike Off] CIN = U45201WB1981PLC034263

Company & Directors' Information:- S D R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201OR2010PTC012083

Company & Directors' Information:- M. G. B. CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45400DL2015PTC281859

Company & Directors' Information:- V N CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U45200KA2015PTC083425

Company & Directors' Information:- R D S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45202PN2001PTC016041

Company & Directors' Information:- T R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400DL2007PTC161605

Company & Directors' Information:- J B J CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2004PTC130303

Company & Directors' Information:- A I B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45309KA2021PTC146378

Company & Directors' Information:- A AND V CONSTRUCTIONS PVT LTD [Strike Off] CIN = U65992TG1987PTC007890

Company & Directors' Information:- M R G CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201MP1994PTC008620

Company & Directors' Information:- P D R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U72100KA1986PTC007383

Company & Directors' Information:- A P CONSTRUCTIONS PVT LTD [Strike Off] CIN = U74210WB1979PTC032397

Company & Directors' Information:- J N D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL1997PTC088802

Company & Directors' Information:- P. R. CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45202MP1982PTC002078

Company & Directors' Information:- M AND M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL1992PTC051503

Company & Directors' Information:- J AND T CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG1999PTC031067

Company & Directors' Information:- CONSTRUCTIONS CO OF INDIA PRIVATE LIMITED [Strike Off] CIN = U29248UP1946PTC001471

Company & Directors' Information:- K S CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U29248UP1982PTC005640

Company & Directors' Information:- J. P. CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45202CT2007PTC020304

Company & Directors' Information:- I M CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL2003PTC122889

Company & Directors' Information:- J V R INDIA CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL2004PTC129898

Company & Directors' Information:- S J M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70101KA1997PTC023146

Company & Directors' Information:- L S CONSTRUCTIONS INDIA PRIVATE LIMITED [Active] CIN = U45202KA2012PTC063895

Company & Directors' Information:- G D CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201WB1985PTC039687

Company & Directors' Information:- B G CONSTRUCTIONS PVT LTD [Active] CIN = U70109WB1989PTC046859

Company & Directors' Information:- J & J CONSTRUCTIONS PVT LTD [Not available for efiling] CIN = U70109WB1991PTC052664

Company & Directors' Information:- M C CONSTRUCTIONS PVT LTD [Strike Off] CIN = U70101WB1985PTC039150

Company & Directors' Information:- N C CONSTRUCTIONS PVT LTD [Strike Off] CIN = U70101WB1987PTC042382

Company & Directors' Information:- M R B CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201CH1995PTC017071

Company & Directors' Information:- B A CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201PB2002PTC024960

Company & Directors' Information:- B AND W CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U17291DL2007PTC170930

Company & Directors' Information:- A S D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201DL2004PTC125030

Company & Directors' Information:- P K CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45200AP1987PTC008025

Company & Directors' Information:- G K CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201AS1988PTC003035

Company & Directors' Information:- H H CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MH1980PTC022610

Company & Directors' Information:- S D C CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209AP2011PTC074468

Company & Directors' Information:- C J CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U70101DL1996PTC082457

Company & Directors' Information:- R R CONSTRUCTIONS PVT LTD [Strike Off] CIN = U74210OR1989PTC002234

Company & Directors' Information:- N D F C CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201MH2004PTC144493

Company & Directors' Information:- J H CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MH1998PTC115057

Company & Directors' Information:- S. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70101MH2003PTC139538

Company & Directors' Information:- L D F CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400UP2009PTC037275

Company & Directors' Information:- K P N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200TG2014PTC092096

Company & Directors' Information:- J D CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Active] CIN = U45209TG2010PTC071441

Company & Directors' Information:- R . C . S . CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U36911UP1999PTC024964

Company & Directors' Information:- U R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400WB2007PTC120032

Company & Directors' Information:- H M K CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400WB2012PTC184485

Company & Directors' Information:- O P B K CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1992PTC047760

Company & Directors' Information:- G A CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL2001PTC109333

Company & Directors' Information:- A J N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL2005PTC142336

Company & Directors' Information:- J. N. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200BR2011PTC017019

Company & Directors' Information:- J. L. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45500AP2016PTC104385

Company & Directors' Information:- U E CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201KA2002PTC030635

Company & Directors' Information:- U D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201OR1990PTC002649

Company & Directors' Information:- C & A CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TN1989PTC017300

Company & Directors' Information:- R S S CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45202JH1990PTC003927

Company & Directors' Information:- P AND P CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45200TG1992PTC015113

Company & Directors' Information:- I. A. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100TG1998PTC029569

Company & Directors' Information:- B J CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200MH1972PTC015731

Company & Directors' Information:- S A K CONSTRUCTIONS (INDIA) PRIVATE LIMITED [Strike Off] CIN = U45400TG2007PTC055386

Company & Directors' Information:- L & I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201UR2006PTC032334

Company & Directors' Information:- A.T. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201UP1990PTC011951

Company & Directors' Information:- P B R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201AP1998PTC028800

Company & Directors' Information:- I R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201DL1996PTC084160

Company & Directors' Information:- M A M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TZ2003PTC010667

Company & Directors' Information:- V. M. R. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202AP1996PTC023724

Company & Directors' Information:- Y P S CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201CH1993PTC013953

Company & Directors' Information:- A. W. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200MP2009PTC022110

Company & Directors' Information:- S B R CONSTRUCTIONS PVT LTD [Active] CIN = U70100MH1982PTC027337

Company & Directors' Information:- G V K CONSTRUCTIONS P LTD [Strike Off] CIN = U45201TN1985PTC011867

Company & Directors' Information:- G T CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U51101UP1980PTC004982

Company & Directors' Information:- I. N. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400JK2013PTC003931

Company & Directors' Information:- B. R. B. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74899DL1990PTC039632

Company & Directors' Information:- N. M. CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U74899DL1995PTC067227

Company & Directors' Information:- B N CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201OR1981PTC001015

Company & Directors' Information:- D F CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201CH1991PTC011820

Company & Directors' Information:- J AND J CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201KL1980PTC003192

Company & Directors' Information:- L AND S CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400PB2009PTC032554

Company & Directors' Information:- M T M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TZ2005PTC011626

Company & Directors' Information:- I S K CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45202TN2006PTC059103

Company & Directors' Information:- K R V CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400TN2010PTC075836

Company & Directors' Information:- R S I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400TN2010PTC078562

Company & Directors' Information:- D & Y CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200PN2009PTC134889

Company & Directors' Information:- K & Y CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200PN2014PTC150194

Company & Directors' Information:- L. K. M. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45201MH2006PTC164835

Company & Directors' Information:- K & H CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400MH2011PTC218327

Company & Directors' Information:- J J K CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45400MH2013PTC244977

Company & Directors' Information:- M K CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200MH2000PTC127425

Company & Directors' Information:- S R R CONSTRUCTIONS PVT LTD [Active] CIN = U45202MH1982PTC027359

Company & Directors' Information:- 4 F CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400TG2012PTC081501

Company & Directors' Information:- N N C CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45400TG2015PTC099840

Company & Directors' Information:- J S J CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74900TN2016PTC103860

Company & Directors' Information:- Q AND Q CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG2004PTC043373

Company & Directors' Information:- V M N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45209TG2013PTC087032

Company & Directors' Information:- S I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45209CH2014PTC035188

Company & Directors' Information:- R S A CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2009PTC193200

Company & Directors' Information:- B B R L CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2011PTC217588

Company & Directors' Information:- M AND R CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2012PTC243738

Company & Directors' Information:- A M T CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400DL2014PTC268935

Company & Directors' Information:- K. D. CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74120DL2009PTC190268

Company & Directors' Information:- G T B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100DL2009PTC193204

Company & Directors' Information:- G N D CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100DL2009PTC193472

Company & Directors' Information:- R P T CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200AP2007PTC055960

Company & Directors' Information:- M N R CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U45200AP2014PTC094893

Company & Directors' Information:- C B N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400HR2010PTC040454

Company & Directors' Information:- Y & M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45400HR2011PTC044664

Company & Directors' Information:- M P K CONSTRUCTIONS PRIVATE LIMITED [Under Process of Striking Off] CIN = U45201KA2001PTC029100

Company & Directors' Information:- H K G N CONSTRUCTIONS PRIVATE LIMITED [Active] CIN = U74210KA2003PTC032055

Company & Directors' Information:- M Y S CONSTRUCTIONS PVT LTD [Active] CIN = U45201KL1995PTC008623

Company & Directors' Information:- R B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70102AP1989PTC010527

Company & Directors' Information:- A P N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201HP1995PTC017344

Company & Directors' Information:- CORPORATE CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100TG1996PTC024719

Company & Directors' Information:- M T J CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201KA1991PTC011684

Company & Directors' Information:- V N V CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70101DL1992PTC050037

Company & Directors' Information:- SANKAR CORPORATION PRIVATE LIMITED [Not available for efiling] CIN = U74999PY1959PTC000034

Company & Directors' Information:- U AND I CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U99999MH2000PTC129703

Company & Directors' Information:- H B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U70100MH1974PTC017866

Company & Directors' Information:- D B CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG2007PTC053917

Company & Directors' Information:- T V L S CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200TG2008PTC057723

Company & Directors' Information:- N N CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45201TG2006PTC050240

Company & Directors' Information:- R S CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201CT1983PTC002128

Company & Directors' Information:- A R H CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200DL2006PTC155870

Company & Directors' Information:- E M CONSTRUCTIONS PRIVATE LIMITED [Strike Off] CIN = U45200DL2008PTC185365

Company & Directors' Information:- K V S CONSTRUCTIONS PVT LTD [Strike Off] CIN = U45201RJ1983PTC002720

    W.P.No. 34632 of 2018 & W.M.P.Nos. 40151 & 40153 of 2018

    Decided On, 26 April 2021

    At, High Court of Judicature at Madras

    By, THE HONOURABLE MR. JUSTICE S.M. SUBRAMANIAM

    For the Petitioner: R. Sivaraman, Advocate. For the Respondent: A.P. Srinivas, Senior Standing Counsel.



Judgment Text

(Petition filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records on the file of the respondent in PAN: AAFCS3911A in issuing the impugned notice in ITBA/AST/S/148/2017-18/1009544069(2) dated 29.03.2018 under Section 148 of the Income Tax Act, 1961 and the consequential proceedings in Corp. Circle – 6(2)/Reasons/2018-19 dated 18.12.2018 and quash the same as illegal, arbitrary and without jurisdiction.)The notice issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as €œthe IT Act€œ) for reopening of the assessment in proceedings dated 29.03.2018, and the proceedings dated 18.12.2018 furnishing reasons for reopening of the case of the petitioner/assessee are under challenge in the present writ petition.2. The petitioner is a Private Limited Company engaged in the field of construction. The petitioner is assessed to the files of the respondent in PAN: AASCS3911A. With respect to the impugned assessment year 2011-12, the petitioner had duly filed their income on 29.09.2011 declaring total income of Rs.38,47,535/-. The return of income was processed under Section 143(1) of the IT Act. Subsequently, the case was selected for scrutiny under Computer Aided Scrutiny Selection (CASS) and notice under Section 143(3) of the IT Act was issued on 10.08.2012. In response to the same, the authorized representative of the petitioner had duly provided all the details called for by the Deputy Commissioner of Income Tax, Company Circle-VI(1), the predecessor of the respondent. The petitioner, vide letter dated 22.05.2014, had duly submitted the details pertaining to retention money more specifically, with respect to the change in Accounting Policy, which was further substantiated by Schedule XIII to the Notes of Account forming part of the computation of total income for the assessment year 2011-12. The petitioner had filed all the details called for by the respondent from time to time. It is only after considering the submissions along with the evidences placed on record, the respondent passed the scrutiny assessment order under Section 143(3) of the IT Act dated 30.03.2014.3. The Assistant Commissioner of Income Tax, Corporate Circle 6(1), Chennai (for brevity “the ACIT”) vide letter dated 17.01.2018, had requested certain clarification pertaining to the retention money amounting to Rs.5,87,61,168/-, which was required to be added back to the assessed income. The ACIT further stated that since the petitioner was following percentage completion methods, the income as per percentage completion method to the tune of Rs.1,45,31,751/- is required to be assessed for the Assessment Year 2011-12. The petitioner preferred their reply to the said clarification by letter dated 12.02.2018 stating that the petitioner had incomplete projects worth Rs.2,92,00,91,516/-, out of which, the total expected retention money at the end of the project is Rs.11,14,43,711/-. These projects were completed on percentage completion method and a sum of Rs.5,87,61,167/- was deducted by the customer as retention money. This money would be paid by the customer only after the project is completed and defect curing period is completed. In other words, the amount will become due to the petitioner only after completion of warranty period. The amount of retention money has been accrued at the completion of project in the subsequent years. Moreover, the retention money has already been offered to tax in the subsequent period thereby vitiating the taxation of the same income during the impugned assessment year 2011-12.4. After a period of four years, the respondent by notice dated 29.03.2018 issued under Section 148 of the IT Act, sought to reopen the concluded assessment under Section 143(3), without any tangible materials and without giving a finding that there is a failure on the part of the petitioner to disclose fully and truly all the materials at the time of completion of the original assessment. The petitioner requested the respondent to provide for the reasons for reopening of the assessment for the assessment year 2011-12, which is beyond four years.5. The petitioner has stated that the reasons for reopening the assessment issued by the respondent were identical to the clarifications raised by the ACIT vide letter dated 17.01.2018. Identical information was requested by the Assessing Officer during the course of the scrutiny proceedings under Section 143(3) of the IT Act relating to the retention money and the change in Accounting Policy by the petitioner for the relevant previous year.6. Despite providing their detailed explanations to the clarifications of the ACIT, the petitioner reiterated their stand by means of a detailed objections dated 17.12.2018 before the respondent stating their objections for reopening the assessment proceedings under Section 147 of the IT Act. With respect to the reasons for reopening, the petitioner had duly submitted and provided their detailed explanations during the course of the scrutiny assessment proceedings. The petitioner submitted that the retention money amounting to Rs.5,87,61,168/-was not in the nature of income till such time the contractual obligations are fully performed to the satisfaction of the customer by the petitioner. Therefore, charging the same to tax as work in progress is not correct as per law. These facts were duly discussed and explained during the course of the original scrutiny assessment under Section 143(3) of the IT Act by the petitioner and subsequently, accepted by the respondent. Additionally, the petitioner objected that they had provided all the documents and evidences during the course of the scrutiny assessment proceedings as well as while filing their response to the clarifications to the ACIT.7. On going through the aforesaid objections, it is crystal clear that there is neither any jurisdiction of the authority, nor there are any merits to show that the income has escaped assessment on the part of the respondent herein warranting reopening of the concluded assessment, since there are no tangible materials warranting reopening of the completed assessment and there is no finding given by the respondent that there is failure on the part of the petitioner to disclose fully and truly all material facts necessary for the assessment. The respondent herein without dealing with the jurisdiction issue and without even dealing with the case laws, which are binding upon him, by impugned proceedings dated 18.12.2018, had held that the proceedings under Section 147 of the IT Act have been initiated correctly and rejected the objections of the petitioner. The proceeding passed by the respondent dated 18.12.2018 is devoid of merit and is not a speaking order as stipulated under law.8. The learned counsel for the petitioner solicited the attention of this Court with reference to the Significant Accounting Policies, that is, Basis of Accounting. It is contended that as per Schedule XIIIA1(c) of the Significant Accounting Policies, the company, during the year, has changed the Accounting Policy on recognition of retention money on completed projects. It has accounted retention money on completed projects on accrual basis, where the company is confident of receiving the retention money in full as compared to cash basis followed in preceding years. This apart, the Chartered Accountants, of the petitioner in letter dated 25.02.2014, categorically stated with reference to the assessment year 2011-12 regarding the change in Accounting Policy relating to retention money. The said Chartered Accountants have stated as under:-In the preceding years, the assessee used to account retention money on receipt basis. During the year, the assessee changed the accounting policy of retention money where there is a reasonable certainty of receiving the retention money the same has been offered to tax. During the year, a sum of Rs.4,91,73,327.51 has been offered to tax even though the same has not been received. The change in accounting policy has been carried out to ensure that the revenue is recognised earlier than receipt. Hence compared to preceding year, the profit is higher by Rs.4,91,73,327.51.”9. It is contended by the learned counsel for the petitioner that these aspects were considered by the Assessing Officer during the original assessment and the clarifications as well as the letter of the Chartered Accountants dated 25.02.2014 and the details given by the petitioner regarding change in Accounting Policy relating to retention money were all provided before the Assessing Officer at the time of original assessment and the Assessing Officer passed an assessment order under Section 143(3) of the IT Act on 31.03.2014. Thus, there is no other reason whatsoever to reopen the assessment, which is perverse and without jurisdiction.10. The learned counsel for the petitioner is of an opinion that once the change in Accounting Policy relating to retention money has been placed before the Assessing Officer, who in turn, considered the same and passed assessment order, the reopening based on the same informations or materials, is nothing but change of opinion and cannot be construed as reason to believe. Thus, the respondent has no jurisdiction to invoke Section 147 of the IT Act and the writ petition is to be allowed.11. The respondent filed a counter affidavit by stating that there was a scrutiny of the assessment order issued under Section 143(3) of the IT Act dated 31.03.2014 and certain clarifications were sought for by the ACIT in his proceedings dated 17.01.2018 well after the assessment order was passed by the Assessing Officer in the year 2014.12. The Assessing Officer has recorded reasons for reopening on two issues; one in respect of retention money; and the other in respect of difference in profits admitted in the P & L account. In respect of retention money, the petitioner is not following a consistent policy in accounting the retention money, the assessee is offering retention money on some completed projects and has not offered retention money on on-going projects. The Assessing Officer has worked out the gross profit at Rs.1,15,65,348/- as against which, it was observed that the petitioner has admitted loss of Rs.29,66,403/- in the P & L account. Thus, the Assessing Officer found that income of Rs.1,45,31,751/- (11565348 + 2966403) is required to be brought to tax. Though the petitioner was given an opportunity to reconcile the difference in profit by letter dated 17.01.2018, the petitioner has not reconciled the profit admitted in the P & L account. Thus, there is failure on the part of the assessee in disclosing the full facts. The Assessing Officer has applied his mind, drawn reasons to form an inference and recorded the reasons. The Assessing Officer was in possession of tangible material in the form of audited balance sheet, computation of total income etc. The Assessing Officer has verified the information available on record, analysed the provisions of the IT Act and arrived at the conclusion that the assessee has made incorrect claim and reduced income. The said assessment has been reopened as there is an escapement of income.13. The Assessing Officer has opined that from the information available on record, there is escapement of income. Accordingly, the Assessing Officer has reopened the case by issuing notice under Section 148, after recording reasons for reopening and taking statutory approvals from the authorities concerned. During the course of assessment proceedings, no details in respect of retention money were called for. If the petitioner had followed mercantile system of accounting and also claimed expenses relating to the retention money, then the assessee should have offered the retention money as income. The Authorised Representative of the assessee, during the course of assessment proceedings, vide letter dated 13.05.2013, has stated that the company continues to follow percentage completion methods during the previous year. There is no change in the method of accounting during the assessment year 2011-12. However, as per Schedule-XIIIA1(c) of the Significant Accounting Policies in the Basis of Accounting, it is mentioned that the company during the year has changed the Accounting Policy on recognition of retention money on completed projects. It has accounted retention money on completed projects on accrual basis, where the company is confident of receiving the retention money in full as compared to cash basis followed in previous year. Thus, there is failure on the part of the assessee in disclosing full facts. There has been recording of reasons for reopening based on tangible material to come to the conclusion that there is escapement of income.14. As per explanation 2(c) to Section 147 of the IT Act, the following shall also be deemed to be the case where income chargeable to tax has escaped assessment, viz.,where an assessment has been made, but -(i) income chargeable to tax has been under assessed; or(ii) such income has been assessed at too low a rate; or(iii) such income has been made the subject of excessive relief under this Act; or(iv) excessive loss or depreciation allowance or any other allowance under this Act has been computed;15. Since in this case there is escapement of income, this case falls within the ambit of the provision of Section 147. The Assessing Officer has applied his mind, drawn reasons to form an inference and recorded the reasons. The said assessment has been reopened, as there is an escapement of income. A letter dated 14.12.2018 was issued by the respondent communicating the reasons for reopening the assessment informing how the Assessing Officer has jurisdiction over the case. Since in this case, excess deduction of retention money on work in progress has been claimed and allowed, this case falls within the ambit of Explanation 2(c) to Section 147 of the IT Act. The Assessing Officer has issued the notice after recording the reasons and taking necessary statutory approvals from the higher authorities concerned. The Assessing Officer has jurisdiction to issue the notice under Section 148 of the IT Act. The objections raised by the petitioner were duly considered and the letter dated 18.12.2018 was issued rejecting the objections raised by the petitioner.16. The petitioner do have other alternatives such as appeals before the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal. This Court in the case of JCIT & Ors. vs. Kalanithi Maran & Ors. reported in (2014) 107 DTR 1 (Mad.) dismissed the writ petition regarding reopening under Section 147 and held as under:-A challenged made to an order passed on the objections of the assessee would in effect is a challenge made to a notice under Section 148 of the Act. Such an order passed by the Assessing Officer is only at the stage of process of determination and not a determination by itself. The process of assessment is not required to be challenged before Court of law, as it is a still born child. Therefore, the petitioner cannot have a legal right as there is no legal injury suffered by them at that stage.”17. During the course of original assessment proceedings, the Assessing Officer has not examined the issue of retention money. The principle, that a mere change of opinion cannot be a basis for reopening completed assessments, would be applicable only to situations where the Assessing Officer has applied his mind and taken a conscious decision on a particular matter. In this case, the Assessing Officer has recorded reasons for reopening on two issues one in respect of retention money and the other in respect of difference in profits admitted in the P & L account. In respect of retention money, the petitioner is not following a consistent policy in accounting the retention money. The assessee is offering retention money on some completed projects and has not offered retention money on on-going projects. In respect of difference in the profit admitted, the petitioner could not reconcile the loss worked out as per the profit and loss account and the revenue recognised on completed projects and ongoing projects as per percentage completion method.18. In the reasons recorded by the Assessing Officer, it is clearly brought on record that there is failure on the part of the petitioner to disclose fully and truly all material facts necessary for assessment. While recording reasons, all the replies of petitioner in response to various notices were considered and it was noted that the petitioner has failed to disclose material facts necessary for assessment. As there is finding of failure on the part of the petitioner and also income chargeable to tax has escaped assessment, the reassessment proceedings are valid.19. As there was no opinion formed on the issues on the basis of which reasons for reopening was done, there is no change of opinion. There is tangible material in the form of financial documents, replies of the petitioner etc., on record to come to a conclusion that there is escapement of income. The objections filed for reasons were disposed by way of a speaking order. After considering all the submissions of the petitioner, the objections were rejected. The petitioner is not following a consistent policy in accounting the retention money. Hence, the ratio of case laws relied on by the petitioner were not applicable to the facts of the present case. Hence, the respondent after considering all these facts and circumstances rejected the objections raised by the petitioner. There is a clear finding that there is failure on the part of the petitioner to disclose all material facts. There is no change of opinion in the instant case. The petitioner has not furnished all the material facts necessary for assessment.20. The primary facts of reconciliation of difference in gross profit and the reason for not following a consistent policy in accounting the retention money were not available before the Assessing Officer.21. In the original assessment, there is no opinion formed on the issues raised recorded in the reasons for reopening the assessment. The petitioner claimed that the Accounting Policy for retention money for recognition of retention money on completed projects is that it has accounted retention money on completed projects on accrual basis where the company is confident of receiving the retention money. The petitioner is offering only a part of the income and not offering the other part. In the relevant year, the petitioner chose to offer part of the retention money on completed projects and has not offered retention money on on-going projects. Thus, the petitioner is offering only part of the retention money accrued during the year. There is inconsistency in the accounting treatment followed by the assessee. As there is no consistent policy in accounting the retention money, the ratio of the case laws relied upon by the petitioner cannot be applied to the facts of the present case.22. Relying on the contentions raised in the counter affidavit filed by the respondent, the learned Senior Standing Counsel reiterated that the clarifications sought for from the assessee in proceedings dated 17.01.2018 itself would reveal that in view of the discrepancies and the new materials found by the authorities competent, they have instituted action under Section 147 of the IT Act. The reasons for reopening of the case of the writ petitioner were communicated in proceedings dated 14.12.2018 wherein, it is categorically stated that €œthere are new materials made available, which were not adjudicated by the Assessing Officer during the course of assessment and at the time of passing the assessment order under Section 143(3) of the IT Act€œ. The informations collected by the Income Tax Department were analysed and based on the analysis, the reasons are furnished to the petitioner/assessee. The reasons communicated in the impugned proceedings dated 18.12.2018 would reveal that “the Assessing Officer was in possession of material in the form of audited balance sheet, computation of total income etc.,” but the Assessing Officer has verified the information available on record, analysed the provision of the IT Act and arrived at the conclusion that the assessee has made incorrect claim and reduced income. The Assessing Officer has applied his mind, drawn reasons to form an inference and recorded reasons. In the assessment order or during the course of the assessment proceedings, the Assessing Officer has not formed any opinion on the issue of retention money of Rs.5,87,61,168/-. Hence there is no change of opinion by the Assessing Officer.23. This Court is of the considered opinion that the reasons furnished for reopening of the assessment dated 18.12.2018 would clearly reveal that incorrect claim and reduced income were identified. Further, it is stated that the issue of retention mone

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y of Rs.5,87,61,168/- was not considered by the Assessing Officer in the original assessment order. Thus, the reopening of assessment cannot be construed as change of opinion.24. This Court is of the considered opinion that once the Department could able to establish that reopening of assessment is made based on the new materials or with reference to the informations which were not truly and correctly provided by the assessee at the time of original assessment, then power under Section 147 of the IT Act can be invoked. Amended provision of Section 147 of the IT Act provides wider power to the Assessing Officer to reopen the assessment. Only when the adjudicated issues are sought to be reopened, then alone the Court can form an opinion that the case would fall under change of opinion and not otherwise.25. Regarding the sufficiency of material, the High Court would not substitute any opinion and it is for the competent authority to conduct an enquiry, adjudicate the issues by affording opportunity to the assessee and pass appropriate orders by following the procedures contemplated. Thus, the High Court is empowered to scrutinise the process through which the decision is taken and the validity of the reasons provided in the order impugned and certainly not the decision itself. Thus, the sufficiency of the reasons cannot be gone into by the High Court in writ proceedings. Once the High Court is able to form an opinion that the issues raised in the reopening proceedings are not adjudicated in the original assessment order, then it is sufficient to confer power on the Assessing Officer to reopen the assessment and the Department must be allowed to proceed with further action as contemplated under the statute.26. These being the principles to be followed in the present case, the non-adjudication of retention money of Rs.5,87,61,168/- is unable to be disputed by the petitioner/assessee in the present case. In other words, the petitioner could not be able to establish that the retention money stated above was adjudicated by the Assessing Officer during the original assessment. This being the factum established, there is no reason to consider the case of the writ petitioner and accordingly, the writ petition fails and stands dismissed. No costs. Consequently, connected miscellaneous petitions are closed.
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