Income Tax Appellate Tribunal - Kolkata
Millennium Stock Broking Pvt. Ltd., ... vs Department Of Income Tax on 29 September, 2015
IN THE INCOME TAX APPELLATE TRIBUNAL
KOLKATA BENCH "A" KOLKATA
Before Shri, S.V. Mehrotra, Accountant Member and
Shri Mahavir Singh, Judicial Member
IT A No.670/Kol/2011 &
IT A No.677/Kol/2011
Assessment Year :2006-07
IT A No. 676/Kol/2011
Assessment Year: 2007-08
M/s Millennium Stock V/s. DCIT Circle-6, P-7,
Broking (P) Ltd., 1, R.N. Chowringhee Square
Mukherjee Road, 1 s t Fl. Kolkata - 01
Room No. 9 Kolkata 01
[PAN No. AACCM 2853 Q]
ITO, W ard-4(2), 8 t h Floor, M/s Millennium Stock
P-7, Chowringhee Square, V/s. Broking Pvt.4 t h Floor,
Kol-69 1, R.N.Mukherjee
Road, Kolkata-01
M/s Millennium Stock DCIT, Circle-6, P-7,
Broking (P) Ltd., R.N. V/s. Chowringhee Squar,
Mukherjee Road, 1 s t Fl. Kolkata-01
Room No. 9, Kolkata-01
अपीलाथ /Appellant .. यथ /Respondent
आवेदक क ओर से/ By Assessee Shri J.P.Khaitan, Senior Advocate
Shri Anirban Ghosh, Advocate
राज व क ओर से/By Revenue Shri Pinaki Mukherjee, JCIT-SR-DR
सन
ु वाई क तार ख/Date of Hearing 13-08-2015
घोषणा क तार ख/Date of Pronouncement 29-09-2015
आदे श /O R D E R
ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08
M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 2
PER S.V.Mehrotra, Accountant Member:-
These three appeals - two by assessee and one by Revenue are against the different orders of Ld. Commissioner of Income Tax (Appeals)-VI Kolkata dated 28.02.2011 for the assessment years 2006-07 and 2007-08 respectively.
2. Brief facts of the case are that in the relevant assessment year 2006-07, the assessee derived income from share trading, jobbing, arbitrage, derivative and brokerage etc. It filed its return of income of Rs.4,97,56,692/-. Assessee had claimed rebate u/s 8E on 30% (averae rate) on ST income of Rs.4,91,73,037/- or STT paid i.e. 1,80,13,120/-, which ever was less. The non STT income was Rs.5,5,68,876/-.
2.1 Thereafter, the case was reopened u/s 148 of the Income Tax Act, for allowing inaccurate rebate of claim u/s 88E. The AO in the assessment order u/s. 147/143(3) dated 31-12-09 of the Act has observed that the STT paid income of Rs.4,91,73,037/- was computed by assessee by debiting expenses of Rs.65,15,839/- from STT income of Rs.5,56,88,876/- (as per assessee). He noted that assessee had allocated total expenses of Rs.1,66,63,904/- in the ratio of 25% / 75% basis between STT income of Rs.55,688,876/- and non- STT income of Rs.1,07,31,720/-. He observed that assessee failed to explain logic of such expense allocation to arrive at the STT income for the purpose of rebate u/s. 88E calculation and, therefore, reopening was made.
2.2. Brief facts leading to reopening are like this: The original assessment was completed as under:-
Rs. Rs.
Net Profit as per P & L A/c paid 3,17,75,642/-
Add; 1] STT 1,80,13,120/-
2] Depreciation [to be considered separately] 4,86,205/-
ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 3 3] Preliminary Exp. 10,702/-
4] Donation 3,000/-
Add: As discussed above:
A] u/s 14A 1,500/-
B] Expenses 27,892/- 29,392/-
5,03,18,061
Less: Dividend [Exempt] 29,974/-
Depreciation [As per I.T. Rules] 5,02,003/- 5,31,977/-
Total Income 4,97,86,084/-
R.O. Rs.4,97,86,080/-
CALCULATIN OF TAX
Income Tax thereon 1,49,35,824/-
Less: Rebate u/s. 8E @ 30% of Rs.4,91,73,037/- 1,47,51,911/-
[Actual paid Rs.1,80,13,120/-]
Tax on Non-STT Income of Rs.6,13,047/- @ 30% 1,83,914/-
Add: S.C @ 10% 18,391/-
Add: Education 2% 4,046/-
2,06,351/-
Less : T.D.S. 2,02,900/-
Payable 3,451/-
2.3 He observed that out of total income of Rs.5,85,71,389/- following was the break up of non-STT and STT income:-
Brokerage Rs. 98,45,114 Share Derivative 47809695 Interest Rs. 9,16,580 STT 47809695 Non-STT Rs. 1,07,61,694 2.4 He further pointed out that out of total expenses debited to the profit and loss account of Rs.3,46,74,928/-, expenses related to STT income were at Rs.3,26,07,206/- and Rs.20,67,722/- related to both STT income and non-STT income. The Assessing Officer determined the common expenses attributable to non-STT income as under:-
Rs.(1,07,61,694) x Rs.20,67,722 Rs.5,85,71,389/-
Rs.98,45,114 + Rs.9,16,580 - Rs.3,79,916 ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 4 2.5 Therefore, net non-STT income was arrived at Rs.1,03,81,778/- as under:-
(Rs.98,45,114 + Rs.9,16,580) - Rs.3,79,516 = Rs.1,03,81,778/-
2.6 He, accordingly determined non-STT at Rs.1,03,81,778/- and STT income at Rs.1,03,81,778/-, out of total assessed income of Rs.4,98,04,282/-.
Rebate u/s.88E was allowed at Rs.11826751 being 30% of Rs.3,94,22,505/-. Aggrieved, assessee went in appeal before Ld. CIT(A).
3. Before Ld. CIT(A) the assess had assailed the reopening on the ground that objections of the assessee had not been disposed off. Ld. CIT(A) did not accept the assessee's plea, inter alia, observing that Assessing Officer had disposed off the objection by pointing out defect in original assessment. On merits, assessee explained the calculation u/s. 88E as under:-
"The detail of appellant returned income is as below:
Business Amount
Share Trading 4605962
Jobbing, arbitrage dealings 2856925
F/O profit 53939839
Brokerage/others 10731720
Expenses as per Returned of Income (16663904)
Returned income 49756692
The expenses were bifurcated on overall business and actual in the under mentioned basis Particulars Own Client Total Remarks Transactions charges 7464182 2488061 99522443 75:25 Terminal operating 1095649 365216 1460865 75:25 chgs.
Depository charges 184060 61353 245413 75:25
Electricity charges 64857 21619 86476 75:25
Fees & subscription 283391 94464 377855 75:25
Depreciation 276102 225901 502003 55:45
Others (as per P/L & 4523 4034526 4039049 Actual
computation etc.)
ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 5 9372764 7291140 16663904 The appellant brought to the notice of AO the circulars of CBDT, provisions of Act, ITR 6 and furnished the followings:
a) STT income 58545801
Less: Expenses etc. 9372764
49173037
b) Non STT income 10731720
Less: Expenses etc. 7291140
Less: Set off u/s 70 2856925
583655
3.1 The first contention of the assessee was that out of the expenses debited to the profit and loss account under head "others", of Rs.40,39,049/-, the sum pertaining to client's account was at Rs.40,34,526/- and on own account was only Rs.4,523/-. The assessee had given the justification in the following manner "We have to state that our basic work is carrying of brokerage business in the National Stock Exchange. If our intention had been to do business on own account we could have approached various brokerage houses and that would have been easy proposition as well comfortable for us in all fronts. It may not be out of place to mention that in order to do brokerage business basic minimum establishment / office / infrastructure has to be maintained together with the paraphernalia's unique to carrying on the business in the on line environment in which it works. The various expenses of Vsat & lease line charges, repair & maintenance, printing & stationary, stamp expenses on brokerage, bank charges, Salary & Bonus etc., Books & Periodicals, Rent & Maintenance charges, rates & taxes, insurance, telephone, Misc. expenses, audit fees etc., are very much part and parcel of carrying on brokerage business. The same have to be incurred irrespective of the business generated on account of brokerage and is directly attributable to brokerage business. The clients can be catered in the aforesaid environment only who conducts business through us as well as who seeks regular advice / meeting with us. The same is on going process which lasts through out the financial year. We categorically state that substantial expenditures under various aforesaid heads are to be incurred for maintaining the structure of stock broking business as well as carrying of brokerage business and the aforesaid facts cannot be disputed in the scenario of technological ad systemic development in stock markets. In a nutshell maintaining of structure of business as well as carrying of brokerage business thus entails substantial expenditures. Expenses are allocate done the basis of overall business and actual for rebate u/s. 88E."
ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 6
4. The second dispute was in regard to loss of Rs.28,56,925/- from jobbing and arbitrage dealings which had been set off by assessee against non-STT income on the ground that it was non STT income. Ld. CIT(A) did not accept this plea observing as under:-
However, it is seen that the jobbing and arbitrage transactions of the assessee very much involve payment of SIT by the assessee. Therefore, there is no doubt that the income/ loss from jobbing and arbitrage dealing is a part of the SIT related transactions. Therefore, the loss of Rs.28,56,925/- from these dealings have to be considered in the calculation of STT related income.
4.1. Thus, Ld. CIT(A) observed that allocation as done in an arbitrary manner. During appeal proceedings assessee was required to provide details about the volume of transactions done by the assessee on its own account and on account of its client's from which it transpired as under:-
Own transactions Rs.249141541578.47
Client transactions Rs.51113102336.90
4.2. He, accordingly, observed that 83% of the transactions were assessee's own transactions and only 17% were transactions belonging to the clients.
Thus, he observed that the substantial portion of the transactions were assessee's own transaction and it was wrong for the ae to claim that it mainly maintain its establishment for its clients. He pointed out that out of te total expenses, other than the STT charges debited in the profit and loss account only the expenses for stamp duty charges amounting to Rs.22,31,939/- could be said to be fully related to client's transactions. All remaining expenses had been incurred both for assessee's own transactions as well as the transactions of the clients. Therefore, out of total expenses of Rs.1,66,63,904/-, the common expenses were at Rs.1,44,31,965/- (1,66,63,904 - 22,31,939) and these had to be apportioned between the STT and non-STT income which he allocated in the ratio 83% to 17% of the common expenses amounting to Rs.24,53,434/- related to non-STT income. He computed net STT and non-STT income as under:-
STT Income Rs.5,85,45,801 ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 7 Less: Jobbing & arbitrage loss Rs.28,56,925 Less: Related Exp. Rs. 1,19,78,531 Net STT Income Rs.4,37,10,343 Non STT Income Rs.1,07,31,720 Less: Related Exp. Rs.24,53,434 Direct Non STT Exp. Rs.22,31,939 Net Non STT Income Rs.60,46,347 4.3 Thus, Ld. CIT(A) computed the rebate u/s 88E at Rs.1,31,13,103/- as against Rs.1,18,26,751/- allowed by AO in reassessment proceedings.
5. Being aggrieved, assessee is in appeal before us against the order of Ld. CIT(A) not allowing set off of arbitrage / jobbing loss of Rs.28,56,925/- against non-STT income and Revenue is in appeal before us as Ld. CIT(A) allowed excess rebate of Rs.12,86,352/- u/s.88E of the Act.
6. First we take up assessee's appeal raising the following grounds of appeal:-
"1) That on the facts and circumstances of the case the CIT(A) erred in concluding that proceedings u/s. 147 initiated by the AO, recorded reason as well as completing the assessment was as per law.
2) That on the facts and circumstances of the case the CIT(A) erred in not setting off the arbitrage/jobbing loss of Rs.2856925/- from non STT business income as claimed and as per option exercised by the appellant.
3) That on the facts and circumstances of the case the CIT(A) erred in ignoring the provision of section 70 and settled law and facts and appellant/s contentions while calculating STT business income/non STT business income and rebate u/s 88E."
7. Vide ground No.1 assessee challenges the validity of initiation of proceedings u/s. 147 of the Act Ld. Counsel referred to page 21 of paper book wherein reasons for reopening dated 12-11-2009 are contained and pointed out that the same does no refer to any escapement of income but allowing of excess rebate. Ld. Counsel submitted that rebate u/s 88E depends on income determined. He submitted that assessee's income remains unaltered and, therefore, there was no 4escapement of income. He referred pages 29 and 30 ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 8 of the Paper Book filed by assessee wherein the Form No. 10DB is contained to demonstrate that STT was paid on assessee's own transactions. He relied the following case laws:-
a) Baijnath Saboo And Others v. ITO And Others 113 ITR 303 (Cal)
b) CIT v. Birla Jan Kalyan Trust 190 ITR 351 (Cal)
c) CIT v. Bombay Gas Co. Ltd 120 ITR 822 (Bom) 7.1 Ld. Counsel further pointed out that it is a case of clear change of opinion.
8. Ld. DR referred to Explanation-2 clause(e) of (iii) / (iv) to Section 147 and pointed out that assessee has been allowed excessive relief and, therefore, it is clearly covered by the deeming provision of Section 147 of the Act. He pointed out that no opinion was formed by AO in original assessment on various aspect in regard to determination of STT income and non-STT income as per the provision of u/s 88E.
9. We have considered the submission of both the parties and have perused the record of the case. As far as the first proposition advanced by Ld. Counsel for the assessee that there is no escapement of income, is concerned, we do not find any merit in the same. As per the deeming provisions contained in Explanation to section 147, if the income has been subjected to excessive relief under Act then also it is deemed that the income chargeable to tax has escaped assessment. In the original proceedings, AO merely accepted assessee's claim without examining the relevant details whether any income comes under STT income or non STT income and, further, details regarding allocation of expense between STT and non-STT, were not available before the AO. He had only accepted the computation without examining the correct legal position u/s. 88E. If a claim is not legally sustainable and reassessment proceedings have been initiated in ordered to arrive at the correct taxable income on which the rebate is admissible, then it cannot be said to a case of change of opinion because if the law has not ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 9 correctly been applied then the same cannot be equated with a situation where two views are possible. For allowing proper rebate u/s 88E, total income arising from taxable security transaction had to be computed. The AO recorded these reasons after arriving at a conclusion that STT related income was calculated excessively with regard to allocation of expenses leading to excessive rebate u/s.8E. We are of the opinion that it is not a case of change of opinion but a case where legal position with regard to rebate u/s. 88E had not correctly been applied to the acts of the case, which resulted in granting excessive rebate of income tax. We, accordingly, uphold the order of Ld. CIT(A) in sustaining the initiation of reassessment proceedings. This ground of assessee is dismissed.
10. Now coming to the merits of the case. The first dispute raised by ld.
Counsel in course of hearing is regarding allocation of establishment expenses incurred by assessee. Before, we proceed to consider this aspect, we may point out that assessee has not taken any ground on this issue, but in course of hearing ld. Senior counsel raised this issue. Since the issue arises from ld. CIT(A)'s order and all facts are there on record, we proceed to decide this issu9e under rule 27 of the ITAT Rules. The assessee's claim was that establishment expenses were mainly incurred on behalf of clients from whom the non-STT income was earned and, therefore, the expenses had been allocated towards non-STT income whereas Ld. CIT(A) has allocated 83% of expenses towards STT transactions, which were on assessee's own account, after considering the ratio of turnover of STT transactions to non-STT transactions. Ld. Sr. Counsel for the assessee pointed out that in subsequent year the AO himself has allocated only 15% of the establishment expenses towards own transactions resulting into STT income.
10.1 Ld. DR has submitted that merely because in subsequent year the AO has accepted 15% expenses towards STT transactions that can not automatically be applied for current year. After considering submissions of ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 10 both the parties and taking into consideration the explanation reproduced earlier, we are of the opinion that there is considerable force in the argument of Ld. Counsel of assessee that assessee could enter into own transactions even without having such huge infrastructure. However, it cannot be ignored that considering the volume of assessee's transaction, some infrastructure was very much required. In our opinion, ends of justice would be met if 25% of the establishment expenses are allocated towards assessee's own transactions and 75% are allocated towards client's transaction (non-STT income) in respect of establishment expenses. On other expenses there is no dispute.
11. Now the second issue is regarding the set off being claimed u/s 70 of the Act in regard to loss incurred by assessee on account of arbitrage and jobbing transactions on which admittedly STT was paid. Assessee's contention is that it is entitled to set off the loss from jobbing / arbitrage transaction against the non-STT transaction for computing rebate u/s 88E. In this regard, Ld. Counsel for assessee relied on the case law in the case of CIT v. K.L. Varadarajan 75 ITR 23 (Mad) and in the case of CIT v. B.K. Birla 174 ITR 361 (Cal).
12. We have considered the submissions of both the parties at length. The contention of Ld. DR is that section 88E is a specific provision and, therefore, it has to be given preference over other provisions and the computation had to be made as contemplated under that section. In order to appreciate the controversy, we reproduce section 88E:
[Rebate in respect of securities transaction tax. 88E.(1) Where the total income of an assessee in a previous year includes any income, chargeable under the head "Profits and gains of business or profession", arising from table securities transactions, he shall be entitled to a deduction, from the amount of income-tax on such income arising from such transactions, computed in the manner provided in sub-section (2), of an amount equal to the securities transaction tax paid by him in respect of the taxable securities transactions entered into in the course of his business during that previous year:
ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 11 Provided that no deduction under this sub-section shall be allowed unless the assessee furnished along with the return of income, evidence of payment of securities transaction tax in the prescribed form :
Provided further that the amount of deduction under this sub-section shall not exceed the amount of income-tax on such income computed in the manner provided in sub-section (2).
(2) For the purposes of sub-section (1), the amount of income-tax on the income arising from the taxable securities transactions, referred to in that sub-section, shall be equal to the amount calculated by applying the average rate of income- tax on such income.
[(3) No deduction under this section shall be allowed in, or after, the assessment year beginning on the 1st day of April, 2009.] Explanation.-For the purposes of this section, the expressions, "taxable securities transaction" and "securities transaction tax" shall have the same meanings respectively assigned to them under Chapter VII of the Finance (No 2) Act, 2004.] 12.1. A bare perusal makes it clear that the Section has following ingredients
(a) total income of assessee includes the income chargeable under the head profit and gains of business (b) such income is arising from taxable securities transactions; (c) deduction under the section is allowable from the amount of income tax on such income arising from such transaction. Thus, the total income used in this section cannot be given a general meaning and has to be ascribed the meaning as contemplated in the context in which Section 88E has been inserted by the Finance Act 2004 with effect from 1.4.2005. The object of Section 88E clearly is to protect the assessee from double taxation. Firstly, by way of payment of STT and secondly by way of income tax on the income earned from STT transaction. The concept of total income as contemplated under Section 2 sub-section (45) cannot be imputed here. The opening words of section 2 dealing with the definition are that unless the context otherwise requires. Therefore, the total income as contemplated u/s 88E is not same as contemplated u/s 2(45). It has been considered in entirely different context in section 88E. The term "total income" as interpreted by ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 12 various decisions relied upon by ld. Counsel cannot be made applicable to the facts of the case which is in context to Section 88E. Therefore, we do not find any reason to interfere with the order of Ld. CIT(A) in holding that business loss occurred on arbitrage and job which were STT paid transactions could not be adjusted against the non-STT transaction belonging to clients. It had to be deducted from STT paid transactions only on assessee's own account. There is one more reason. The rebate u/s. 88E is allowable from the tax paid. However, in case of arbitrage loss assessee had admittedly not paid any income tax. Therefore, if assessee's plea is accepted then it would lead to double relief to assessee - firstly, by allowing set off u/s 70 against STT income and then allowing rebate from income-tax. This is definitely not the intention of legislature. We accordingly do not find any reason to interfere with the order of Ld. CIT(A) and ground taken by assessee is dismissed.
Coming to Revenue's appeal in ITA No. 677/Kol/2011
13. The Revenue has taken following ground of appeal:-
"1. That on the facts and circumstances of the case, Ld. CIT(A)-VI, Kolkata has erred in law as well as on the facts by allowing excess rebate of Rs.12,86,352/- u/s.88E of the Act to the assessee though the AO has calculated the same in a correct manner."
14. We find that AO had computed STT income of Rs.4,78,09,695/- which was rectified by Ld. CIT(A) by observing as under:-
" As regards the calculation done by the AO I find that it is erroneous because while taking STT income of Rs.4,78,09,695/-. From the GP calculation sheet the AO forgot to add the value of closing stock of Rs.78,79,181/-. Though in the direct expenses he included the value of opening stock of Rs.99,52,243/-. Even in respect of allocation of expenses between ST and non-STT income I am of the view that except for few direct expenses as discussed above the best way to allocate the remaining common expenses sis to do so n the ratio of the volume of transactions for STT income (own transaction) and non-STT income (client's transaction). Therefore I do not agree with the method of calculation adopted by the AO.
Thus with net STT income of Rs.4,37,10,345/- the rebate allowable u/s 88E will be 0.30 x 4,37,10,345 = Rs.1,31,13,103/- as against the rebate ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 13 of Rs.1,18,26,751/- allowed by the AO in the reassessment proceedings."
14.1. Ld. DR has not been able to point out any mistake in the computation made by Ld. CIT(A) and, therefore, we do not find any reason to interfere with the order of Ld. CIT(A). This ground of Revenue's appeal is dismissed.
Coming to assessee's appeal in ITA No.676/Kol/2011.
15. The assessee has taken following ground:-
"1) That on the facts and circumstances of the case the CIT(A) erred in not setting off the arbitrage/jobbing loss of Rs.4520558/- from non STT business income as claimed and as per option exercised by the appellant.
2) That on the facts and circumstances of the case the CIT(A) erred in ignoring the provision of section 70 and settled law and facts and appellant's contentions while calculating STT business income/non STT business income and rebate u/s 88E."
16. We have considered the issue involved in assessee's own case in ITA No.670/Kol/2011 for AY 2006-07 and, therefore, for the reasons given therein, confirm the order of Ld. CIT(A) and this issue of assessee's appeal is dismissed.
17. In the result, appeals of both assessee as well as Revenue are dismissed.
Order pronounced in the open court 29/09/2015
Sd/- Sd/-
(Mahavir Singh) (S.V.Mehrotra)
(Judicial Member) (Accountant Member)
Kolkata,
Order pronounced in open court 29/0915
Sd/- Sd/-
M.S. W.A
(J.M. (A.M)
*Dkp
"दनांकः- 29/09/2015 कोलकाता ।
ITA No.670, 676, 677/Kol/2011 A.Ys. 2006-07 & 2007-08 M/s Millennium Stock Broking (P) v, DCUT Cir-6 Kol. Page 14 आदे श क त ल प अ े षत / Copy of Order Forwarded to:-
1. आवेदक/Assessee- M/s Millennium Stock Broking (P) 1, R.N.Mukherjee Road 1st Floor, Room No. 9 Kolkata-01
2. राज व Revenue- ITO, Wd-4(2) / DCIT Circle-6 8th Floor, P-7, Chowringhee Square Kolkata - 700 069
3. संबं/धत आयकर आयु1त / Concerned CIT Kolkata
4. आयकर आयु1त- अपील / CIT (A) Kolkata
5. 3वभागीय 6त6न/ध, आयकर अपील य अ/धकरण, कोलकाता / DR, ITAT, Kolkata
6. गाड: फाइल / Guard file.
By order/आदे श से, उप/सहायक पंजीकार आयकर अपील य अ/धकरण, कोलकाता ।