Income Tax Appellate Tribunal - Kolkata
Soumendra Prasad Dash, Kolkata vs Department Of Income Tax
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IN THE INCOME TAX APP ELLATE TRIBUNAL,
KOLKATA 'C' BENCH, KOLKATA
Before Shri Shamim Yahya (Accountant Member),
and Shri George Mathan (Judicial Member)
I.T .A. No. 12 18/Kol. / 2010
Assessment year : 2006- 07
Income Tax Office r,............ ...... .............................. ..... ............. ...Ap pellant
Wa rd-27(4) , Kolkata,
169, AJC Bose Road,
Kolkata-700 014
-Vs.-
Shri Soumendra Prasa d Dash ,............................ .............. ....Respondent
The Condovilla Bengal Ambuja ,
New Town,
Kolkata-700 156
[PAN : ACMPD 2845 G]
&
C.O . No. 111/Kol/2013
(a ri sing out of ITA N o. 1218/Kol/2010)
Asse ssment Ye ar : 2006-2007
Shri Soumendra Prasa d Dash ,............................ .............. ....C ros s Objecto r
The Condovilla Bengal Ambuja ,
New Town,
Kolkata-700 156
-Vs._
Income Tax Office r,............ ...... .............................. ..... ............. ...Respondent
Wa rd-27(4) , Kolkata
169, AJC Bose Road,
Kolkata-700 014
&
I.T.A. No. 1216/Kol/2010
Asse ssment Ye ar : 2006-2007
Income Tax Office r,............ ...... .............................. ..... ............. ...Ap pellant
Wa rd-27(4) , Kolkata,
169, AJC Bose Road,
Kolkata-700 014
-Vs.-
Shri Soumen S amanta,.........................................................Respondent
3/2, Ramlal Dutta L ane,
Bhadrakali ,
Hooghly-712 232
[PAN : AKKPS 8993A]
&
I.T.A. No. 1219/Kol/2010
Asse ssment Ye ar : 2006-2007
I .T.A . N o . 1 2 1 8/ Kol. / 2 0 1 0
C. O. No . 1 1 1 -Ko l- 2 0 1 3( in I TA 1 2 1 8 -Kol- 2 0 1 0 )
I TA No s . 1 2 1 6, 1 2 1 9, 1 2 2 4 -Kol- 2 0 1 0 &
C.O. N o . 1 1 2 - Ko l- 2 0 1 3 ( i n I TA No . 1 22 4 - Ko l- 2 0 1 0 )
A s s es s m en t ye ar : 2 0 0 6 - 0 7
Page 2 of 11
Income Tax Office r,............ ...... .............................. ..... ............. ...Ap pellant
Wa rd-27(4) , Kolkata,
169, AJC Bose Road,
Kolkata-700 014
-Vs.-
Smt. Su darsh ana Thakurta,............................................... ....Resp ondent
1, Avenue East,
Modern Pa rk,
Kolkata-700 075
[PAN : ADGP T 1801 R]
&
I.T.A. No. 1224/Kol/2010
Asse ssment Ye ar : 2006-2007
Income Tax Office r,............ ...... .............................. ..... ............. ...Ap pellant
Wa rd-27(4) , Kolkata,
169, AJC Bose Road,
Kolkata-700 014
-Vs.-
Shri Souvik Chatte rj ee,.......................... ..................... ..........Respo ndent
46/11-1, Be charam Chatte rjee Road ,
Behala ,
Kolkata-700 034
[PAN : ACHPC 4467 E ]
&
C.O . No. 112/Kol/2013
(a ri sing out of ITA N o. 1224/Kol/2010)
Asse ssment Ye ar : 2006-2007
Shri Souvik Chatte rj ee,.......................... ..................... ..........Cross Objector
46/11-1, Be charam Chatte rjee Road ,
Behala ,
Kolkata-700 034
-Vs._
Income Tax Office r,............ ...... .............................. ..... ............. ...Respondent
Wa rd-27(4) , Kolkata
169, AJC Bose Road,
Kolkata-700 014
Appearances by:
Shri Rajendra Prasad, JCIT, Sr. D.R., for the Department
Shri P. Dey, FCA, for t he assessee
Date of co ncluding the hearing : Apri l 30, 2014
Date of pronouncing the orde r : Ma y 2 n d , 2014
O R D E R
Per Bench :
All these appeals relate to different assessees, who are employees of M/s. TCS Limited. During the previous year under consideration, the I .T.A . N o . 1 2 1 8/ Kol. / 2 0 1 0 C. O. No . 1 1 1 -Ko l- 2 0 1 3( in I TA 1 2 1 8 -Kol- 2 0 1 0 ) I TA No s . 1 2 1 6, 1 2 1 9, 1 2 2 4 -Kol- 2 0 1 0 & C.O. N o . 1 1 2 - Ko l- 2 0 1 3 ( i n I TA No . 1 22 4 - Ko l- 2 0 1 0 ) A s s es s m en t ye ar : 2 0 0 6 - 0 7 Page 3 of 11 assessees have rendered their services in U.S.A . for certain period of time. During their period of stay in U.S .A ., they were paid living allowances. The assessees had claimed the sums as exempt under section 10(14) of the Act. This being the fact on which the appeals have been disposed of by this common order.
2. ITA No. 1218/Kol./2010 & C.O. No. 111/Kol./2013 ITA No. 1218/Kol/2010 is an appeal filed by the revenue against the order of l d. Commissioner of Income Tax (Appeals)-XIV, Kolkata in Appeal No. 441/CIT(A)-XIV/08-09 dated 22.03.2010 for the assessment year 2006-07.
C.O. No. 111/Kol./2013 is a Cross Objection filed by the assessee in the Revenue's appeal in ITA No. 1218/Kol/2010.
4. Shri Rajendra Prasad, JCIT, Sr. D.R. represented on behalf of the Revenue and Shri P. Dey, FCA , represented on behalf of the assessees.
5. In the Revenue's appeal, the Revenue has challenged the action of the ld. CIT(A ppeals) in deleting the interest levied under section 234B in respect of the disallowance of the living allowance under section 10(14) of the Act.
In the Cross Objection filed by the assessee, the assessee has challenged the action of the ld. CIT(Appeals) in confirming the denial of exemption under section 10(14)(i) of the Income Tax Act, 1961 read with Rule 2BB(1) of the Income Tax Rules, 1962.
6. At the time of hearing, it was submitted by the ld. A.R. that the issue of exemption under section 10(14)(i) in respect of living allowance was squarely covered by the decision of the Coordinate Bench of this Tribunal in the case of other TCS employees, most specifically in the case of ITO -vs.- S ri Saptarshi Ghosh & Others in ITA No. 915/Kol/2010 & I .T.A . N o . 1 2 1 8/ Kol. / 2 0 1 0 C. O. No . 1 1 1 -Ko l- 2 0 1 3( in I TA 1 2 1 8 -Kol- 2 0 1 0 ) I TA No s . 1 2 1 6, 1 2 1 9, 1 2 2 4 -Kol- 2 0 1 0 & C.O. N o . 1 1 2 - Ko l- 2 0 1 3 ( i n I TA No . 1 22 4 - Ko l- 2 0 1 0 ) A s s es s m en t ye ar : 2 0 0 6 - 0 7 Page 4 of 11 others dated 30.09.2011, wherein the Coordinate Bench of this Tribunal has held as under :-
"22. Now, we proceed to examine the facts of the present case in the context of principles discussed above. In order to appreciate the correct position in this regard, we reproduce hereunder certain contents from various documents. Before us, the details in regard to Saptarshi Ghosh have been filed. In the deputation letter dated 19.05.2005, it has been, inter alia, stated as under :-
"Your deputation is expected to last for a period of approximately 3 months. However, various factors could necessitate your being in the USA for a shorter or longer duration, and could result in a change of location or a transfer to a TCS project for a different client in the USA. If there are any such changes with respect to your deputation, we will give you as much advance notice as is practicable under the circumstances.
In order to prepare you for this deputation, I enclose a copy of the Overseas Deputation Manual for the USA. This Manual contains important information on the customers and practices in the USA as well as other information that will be helpful to you on your deputation. You should review the Manual carefully. Remember, while you are in the USA, you will be a representative of TCS, and are expected to maintain a professional image at all times.
After you have reviewed the enclosed materials, or if you have any questions while you are reviewing them, you should contact the personnel Department. It is essential that you fully understand all aspects and conditions of your deputation before choosing to proceed on this assignment and singing your Deputation Agreement and Service Agreement Addendum. Your signature below on the additional copy of this letter will confirm your understanding of this obligation and your agreement to fulfill it.
23. Deputation Agreement- United States ("Agreement") dated 17.10.2004 between assessees and Tata Consultancy Limited is as under :-
A. In order to qualify the Employee for overseas assignment, or deputation ('Deputation"), the Employer has provided the Employee with extensive specialized training and experience in Information Technology and its application, including trade secrets and the Employer's proprietary information, for which the Employer incurs considerable costs and expenses.
B. The Employer has selected the Employee for Deputation to the United States and, by reading and signing this Deputation Agreement, and the annexed Deputation Terms Agreement the Employee agrees to go on Deputation where the Employee will be assigned to use his/her training and experience on one or more projects of the Employer for its clients in the United States.
C. The Employee shall acquire commercially useful experience, knowledge and skills white on Deputation in the United States, and such experience, knowledge and skills are of substantial value to the Employer for dissemination by the Employee to the 32 Employer's employees in India upon the Employee's return to India after the conclusion of the Deputation.
D. The Employer is willing to send the Employee on Deputation only if the Employee agrees, and as provided below the Employee does agree and commit, to complete his/her Deputation I .T.A . N o . 1 2 1 8/ Kol. / 2 0 1 0 C. O. No . 1 1 1 -Ko l- 2 0 1 3( in I TA 1 2 1 8 -Kol- 2 0 1 0 ) I TA No s . 1 2 1 6, 1 2 1 9, 1 2 2 4 -Kol- 2 0 1 0 & C.O. N o . 1 1 2 - Ko l- 2 0 1 3 ( i n I TA No . 1 22 4 - Ko l- 2 0 1 0 ) A s s es s m en t ye ar : 2 0 0 6 - 0 7 Page 5 of 11 in the United States, and to return to India at the conclusion of a Deputation in order to impart the experience, knowledge and skills acquired on the Deputation to employees of the Employer in India.
Therefore, in consideration of the mutual covenants and conditions set forth below and other good and valuable consideration, the receipt and sufficiency of which are acknowledged by both parties, the parties agree as follows:
I. OVERSEAS DEPUTATION 1.1. General Provision. The Employee is an employee of the Employer pursuant to a Service Agreement entered into in India upon commencement of the Employee's employment The Service Agreement, and all other current agreements between the Employee and the Employer regarding the employment relationship in India, remain in full force and effect This Agreement governs the terms of the Employee's Deputation to the United States.
A "Deputation" is defined as an overseas assignment to the United Slates when, for this Deputation Agreement, unless otherwise terminated or amended according to its terms, shall govern and apply to each and every Deputation of the Employee to the United States, and it shall remain in effect during the Employees employment by the Employer. With respect to each separate Deputation of Employee to the United States a separately executed DTA SHALL GOVERN THE PARTICULAR TERMS OF THAT DEPUTATION and shall be in effect only during the Deputation to which it applies.
1.2. Period of Deputation. The Deputation will begin on the date the Employee leaves India for the United States following execution of a DTA, and shall continue until the stated term of the Deputation, or extension thereof, has expired,. The initial term of the Deputation is set forth in the applicable DTA. However, the Employer reserves the right to shorten or end the period of a Deputation at any time, with or without advance notice, and the Deputation may be extended by mutual agreement between the parties.
Place of Deputation- The Employee will be assigned to work an one of the Employer's projects for a client identified in the DTA and at a location in the United States as stated in the DTA. However, the Employer reserves the right to change the location of the Deputation assignment in the United States, and to transfer the Employee to an Employer project for a different employer clilent in the United States. Upon any such change location or assignment, the provisions of this Agreement will continue to apply and remain in full force and effect, and Employer shall confirm to Employee in writing the details concerning the new location or assignment.
COMPENSATION AND BENEFITS In connection with the Deputation, the Employee will receive compensation and benefits in India and in the United States, for services rendered by the Employee during the Deputation in the United States. The gross amount of the total compensation in India and the United States is set forth in the applicable DTA, and this total gross 33 amount of compensation shall be includable as earnings in the United States and reported on U.S. Internal Revenue Service form W-2. More specifically, the compensation and benefits on the Deputation will be as follows:
Initial Payments- Before the Employee embarks on his/her Deputation, the Employer will make the following payments to the Employee:
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(a) The Employer will compensate to the Employee an amount in rupees that is designed to enable the Employee to purchase any usual and necessary outfits for the Deputation, and to cover initial incidental travel-related expenses in embarking on this overseas assignment.
(b) The Employer will compensate the Employee an amount in US. dollars or travelers cheques for the Employee's use in his/her discretion for expenses such as housing and transportation expenses incurred on arrival in the United States and for the purpose of settling down.
(c) The amounts and details of these payments may be specified in the DTA and/or other documents furnished to the Employee prior to the commencement of a Deputation.
2.2. Airfare- Before the Employee embarks on his/her Deputation, the Employer will obtain a round trip airline ticket for the Employee's travel between India and the United States. The Employer will bear the cost of this airfare, and this amount will not be included in gross compensation. The Employer shall also bear the cost of transportation within the United States between the place of arrival and the site where Employee shall report to work.
Compensation and Benefits in India - During the period of the Deputation, the Employee will continue to receive his/her salary and benefits in India, as if the Employee had continued to work for the Employer in India, subject to any tax requirements under the laws of the United States and its states. Moreover, the period of the Deputation will be treated as approved service with the employer and counted for all of the following purposes in India, based on the salary the employee continues to receive in India while on Deputation, Privilege Leave, Promotion, Annual Increment and payment of Housing Subsidy, performance reward, Provident Fund contributions and Superannuation Fund contributions.
Compensation in the United States- During the period of the Deputation the Employee will receive additional compensation in U.S. dollars, in the amount stated in the DTA. This compensation shall be for living and other expenses in the United States. It shall be part of Employee's total compensation for purposes of U.S. Department of Labor 'prevailing wage' determinations.
Total Gross Compensation- Amounts of salary paid by the Employer in India (under Paragraph 2.3) and compensation paid for living expenses in the United States (under Paragraph 2.4) shall be aggregated and thus shall be treated as the Employees total gross compensation under U.S. law with respect to the Employee's employment in the United States.
Your Deputation shall begin on or about 17th October, 2004, you shall initially be assigned to perform IT consulting services on behalf of TCS for GE Healthcare at Milwankee.
3. Your Deputation in the United States is scheduled for a period of 12 months. However, various factors could require you to render services to TCS for its clients in the United States for a shorter or longer duration, and could result in a change of location or transfer to a TCS project for a different client in the United States. If there are any changes with respect to the period of your deputation or the location of your assignment, we will give you as much advance notice as is practicable under the circumstances. It is understood that you have no right to serve any particular fixed period of deputation or to serve at any particular location or clilent project. However, if the period of your deputation is extended beyond the scheduled 12 month period, the extension shall be reflected in a mutual written agreement.
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4. The following specific provisions shall govern your deputation :-
(A) OverseasTravel and Reimbursement TCS shall be used travelers cheques, which is designed for your use in meting initial expenses for transportation and housing when you arrive in the United States.
(B) Salary and benefits in India :- As stated in the Deputation Agreement, you will continue to receive your salary and benefits in India during the period of the Deputation, subject to any tax requirements of the United States and its states.
(C) Compensation in the United States.. In addition to the compensation and benefits you currently receive and will continue to receive in India who on Deputation, you shall receive additional compensation in the United States in the gross amount of US$50000 less deductions required by law or otherwise voluntarily authorized by you. This compensation shall be for living and other expenses in the United States.
(D) Total Gross Compensation Amounts of salary paid by TCS in India (under Paragraph 4
(b) above) and the additional compensation in the United States (under Paragraph 4(c) above) shall be aggregated and thus shall be treated as your total gross compensation for purposes of U.S. law with respect to your employment in the United States.
24. From the above noted contents of deputation letter and agreement, etc. it is clear that the place of posting did not change to USA and the employees were sent there with reference to the specific projects though the projects could change at the instance of employer. The employees were to report back to the employer and serve the employer after acquiring skill from USA projects. The salary structure of employees remained same and the additional amounts were paid only for the purposes of additional routine expenses in USA. This is evident from deputation agreement, which deals with compensation and benefits noted above. It is specifically mentioned in para 2.3 that during the period of deputation, the employee will continue to receive his salary and benefits in India. This clearly shows that place of posting had not changed, which is basic ingredient for deciding whether a person had been transferred or was on tour. Ld. CIT(Appeals) has wrongly concluded that headquarters had been shifted from Kolkata to USA. Ld. CIT(Appeals) has also pointed out that employees had a choice to say no also. In the present case, the employees were to be sent to USA and, therefore, their choice had to be taken before sending them abroad. Since the assessees were to be sent abroad, they had to obtain Visa also for that purpose. In that regard, all the specific requirements had to be fulfilled by the employer. But that should not detract us from examining the true import of the term 'tour'. Ld. CIT(Appeals) has also pointed out that as per the deputation agreement, the assessees were entitled to take their families but that also cannot be a basis for deciding whether the assessees were to be treated on tour in terms of Rule 2BB(1)(b) or not because that Rule does not prohibit taking the family on tour. We are, therefore, of the considered opinion that keeping in view the entirety of the facts and circumstances of the case, assessees were to be treated on tour and, therefore, eligible for claiming deduction under section 10(14)(i) read with Rule 2BB(1)b). Further, we find that the issue relating to living allowance has been considered by various decisions relied upon by the ld senior counsel for the assessees with reference to non-residents. Ld. CIT(Appeals) has distinguished all such case laws on the ground that they relate to non- residents and not with reference to the employees being sent abroad. We do not find any rationale in distinguishing the case laws noted in ld. Senior counsel's submissions merely on the ground that they related to non-residents. Non-residents coming to India and Indian going abroad, are to be considered on same footing as far as the issue is in respect of exemption I .T.A . N o . 1 2 1 8/ Kol. / 2 0 1 0 C. O. No . 1 1 1 -Ko l- 2 0 1 3( in I TA 1 2 1 8 -Kol- 2 0 1 0 ) I TA No s . 1 2 1 6, 1 2 1 9, 1 2 2 4 -Kol- 2 0 1 0 & C.O. N o . 1 1 2 - Ko l- 2 0 1 3 ( i n I TA No . 1 22 4 - Ko l- 2 0 1 0 ) A s s es s m en t ye ar : 2 0 0 6 - 0 7 Page 8 of 11 under section 10(14)(i) read with Rule 2BB(1). It does not lay down separate consideration for non-residents vis-à-vis residents.
25. Further, one more aspect which is to be considered is with regard to actual incurring of expenditure. In this regard, we find that the issue is squarely covered by he decision of ITAT, Mumbai dated 21.04.2006 in ITA Nos. 5561 & 5570/Mum./2002 for the assessment years 1997-98 and 1998-99 in the case of Madanlal Mohanlal Narang -vs.- ACIT(supra), wherein it has been held that "it is not open to the revenue to call for the details of expenses actually incurred unless the specific allowance are disproportionately high compared to the salary received by him or unreasonable with reference to the nature of the duties performed by the assessee".
Further, the assessees had submitted that FBT must have been paid by the employer. However, as noted earlier, employer has not paid FBT. In our opinion, the considerations for eligibility of exemption under section 10(14)(1) are entirely different and nothing turns around on the applicability or non-applicability of the provisions of FBT.
In view of above discussions, the appeals of the assessees as well as the Cross Objections are allowed.
26. With regard to the Departmental appeals, we have already held that living allowance is not taxable. Therefore, interest levied under section 234B cannot be sustained. Even otherwise, we find that the issue is covered by the decision of ITAT, Special Bench in the case of Sumit Bhattacharya -vs.- ACIT reported in [2008] 300 ITR page 347 (Mumbai)(SB).
In view of the above, the Departmental appeals are dismissed.
27. Before parting, we may further observe that, in any view of the matter, the entire controversy is almost revenue neutral because even if it is held that assessees were not eligible for exemption under section 10(14)(i) in respect of living allowance, then in view of DTAA with USA, the assessees would become entitled to get tax credit in respect tax paid on living allowance in USA. However, as we have already held that living allowance is not taxable in India, therefore, assessees are entitled for exemption under section 10(14(i). Therefore, they cannot claim tax credit in respect of tax paid in USA on living allowance because as very fairly pointed out by the ld. senior counsel for the assessees, DTAA would come into play only when a particular receipt is taxable in both the countries.
28. In the result, the appeals as well as the Cross Objections filed by the assessees are allowed and the appeals filed by the Department are dismissed".
7. As it is noticed that the issue in the Cross Objection is squarel y covered by the decision of the Coordinate Bench of this Tribunal. Respectfully following the decision of the Coordinate Bench of this Tribunal , the Cross Objection filed by the assessee is allowed.
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8. In respect of the Revenue's appeal regarding the levy of interest under section 234B, it was submitted by the ld. A.R. that the issue was squarely covered by the decision dated 19.08.2010 of Coordinate Bench of this Tribunal in the case of ITO -vs.- Shri Atish Sreemany & Others in ITA No. 1172/Kol/2010, wherein the Coordinate Bench of this Tribunal has held in para 6 as follows:-
"6. Before ld. CIT(Appeals), the assessees had also assailed the finding of Assessing Officer in respect of charging of interest under section 234B relying on the decision of ITAT, Special Bench, Mumbai in the case of Sumit Bhattacharya -vs.- ACIT [300 ITR (AT) 347(Mum.)(SB)".
9. In reply, ld. D.R. vehementl y supported the order of Assessing Officer and pleaded that the order of ld. CIT(A ppeals) was liable to be reversed.
10. We have considered the rival submissions. As it is noticed that the issue in respect of the Revenue's appeal is squarel y covered by the decision of the Coordinate Bench of this Tribunal in the case of Shri Atish Sreemany referred to supra, the finding of the ld. CIT(Appeals) in cancelling the levy of interest under section 234B stands upheld. Consequently the appeal filed by the Revenue stands dismissed and the Cross Objection filed by the assessee stands allowed.
11. ITA No. 1216/Kol/2010 (Revenue's appeal) ITA No. 1216/Kol/2010 is an appeal filed by the revenue against the order of l d. Commissioner of Income Tax (Appeals)-XIV, Kolkata in respect of levy of interest under section 234B in Appeal No. 418/CIT(A)- XIV/08-09 dated 22.03.2010 for the assessment year 2006-07.
12. The issue in this appeal is squarely covered by the decision in ITA No. 1218/Kol/2010 (supra). Consequentl y our finding therein applies to this appeal also.
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13. In the result, the appeal of the Revenue stands dismissed.
14. ITA No. 1219/Kol/2010 (Revenue's appeal) ITA No. 1219/Kol/2010 is an appeal filed by the revenue against the order of l d. Commissioner of Income Tax (Appeals)-XIV, Kolkata in respect of levy of interest under section 234B in Appeal No. 488/CIT(A)- XIV/08-09 dated 18.03.2010 for the assessment year 2006-07.
15. The issue in this appeal is squarely covered by the decision in ITA No. 1218/Kol/2010 (supra). Consequentl y our finding therein applies to this appeal also.
16. In the result, the appeal of the Revenue stands dismissed.
17. ITA No. 1224/Kol/2010 & C.O. No. 112/Kol/2013 ITA No. 1224/Kol/2010 is an appeal filed by the revenue against the order of l d. Commissioner of Income Tax (Appeals)-XIV, Kolkata in Appeal No. 472/CIT(A)-XIV/08-09 dated 18.03.2010 in respect of levy of interest under section 234B for the assessment year 2006-07.
18. The issue in this appeal is identical to Revenue's appeal in ITA No. 1218/Kol./2010(supra). Our finding therein applies to this appeal . Consequently the Revenue's appeal stands dismissed.
19. Cross Objection No. 112/Kol/2013 is identical to the Cross Objection filed by the assessee in C.O. No. 111/Kol/2013 referred to supra. Consequentl y our finding therein applies to this Cross Objection also. Consequently the Cross Objection filed by the assessee stands allowed.
20. In the result, the appeals filed by the Revenue stand dismissed and the Cross Objections filed by the assessees stand allowed.
Sd/- Sd/-
Shamim Yahya George M athan
(Accountant Member) (Judicial Member)
Kolkata, the 2 n d day of May, 2014
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Page 11 of 11
Copies to : (1) Income Tax Office r,
Wa rd-27(4) , Kolkata,
169, AJC Bose Road,
Kolkata-700 014
(2)(i) Shri Soumendra Prasa d Dash ,
The Condovilla Bengal Ambuja ,
New Town,
Kolkata-700 156,
( ii) Shri Soumen S amanta,
3/2, Ramlal Dutta L ane,
Bhadrakali ,
Hooghly-712 232
(iii) Smt. Su darsh ana Thakurta,
1, Avenue East,
Modern Pa rk,
Kolkata-700 075
(iv ) Shri Souvik Chatte rj ee,
46/11-1, Be charam Chatte rjee Road ,
Behala ,
Kolkata-700 034
(3) Commissioner of Inco me-tax (Appeals)
(4) Commissioner of Income Tax
(5) The Departmental Representative
(6) Guard File
By o rder
Assistant Registrar
Income Tax Appellate Tribunal
Kolkata benches, Ko lkata
Laha/Sr. P.S.