Income Tax Appellate Tribunal - Kolkata
Champalall Rajkumar Textile Pvt. Ltd. , ... vs Ito, Ward- 12(1), Kolkata. , Kolkata on 17 January, 2024
IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH KOLKATA
BEFORE SHRI SONJOY SARMA, JUDICIAL MEMBER
AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER
ITA No.1178/Kol/2023
Assessment Year: 2012-13
Champalall Rajkumar Textile Pvt. Income Tax Officer, Ward-
Ltd. 12(1), Kolkata.
6, Garsatin Place, Ashoka Vs.
Chamber, Dalhousie, Kolkata-
700001.
(PAN: AABCC0476A)
(Appellant) (Respondent)
Present for:
Appellant by : Shri S. M. Surana, Advocate
Respondent by : Shri Abhijit Kundu, CIT DR
Date of Hearing : 04.01.2024
Date of Pronouncement : 17.01.2024
ORDER
PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:
This appeal filed by the assessee is against the order of Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi vide order No. ITBA/NFAC/S/250/2023-24/1057319424(1) dated 25.10.2023 passed against the assessment order by Tax Recovery Officer-2, Kolkata u/s.144 of the Income-tax Act, 1961 (hereinafter referred to as the "Act"), dated 17.03.2015 for AY 2012-13.
2. Grounds taken by the assessee are as under:
"1 For that the Ld CIT (A) erred in holding that the transfer of a case by the Ld CIT cannot be disputed in appeal before CIT(A) when the same was not in accordance with law and valid jurisdiction under the provisions of the Income Tax Act 1961.
2. For that the Ld. CIT(A) erred in holding that under the provisions of the I T Act 1961, the Tax Recovery Officer can act as Assessing Officer thereby 2 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 confirming the order of the Ld. ITO without properly appreciating the relevant provisions of law and should have held that the assessment was without jurisdiction.
3. For that the Ld. CIT(A) erred in confirming the order passed by Ld TRO who cannot act as an Assessing Officer, thus the assessment was ab initio void and was not maintainable.
4. For that the Ld CIT(A) erred in relying on the decision of the ITAT in the case of United Traders company which was per incuriam.
5. For that the Ld. CIT(a) erred in confirming the order of the TRO when the assessee duly discharged its onus to prove the genuineness of the share capital, filed all necessary evidences which were not controverted by the Ld TRO and even after asking for remand report with all evidences on record, again filed before the Ld CIT(A) the Ld AO failed to controvert the same.
6. For that the Ld CIT(A) erred in confirming the order of Ld AO simply because the directors did not appear when no fault was pointed out m respect of the evidence produced and for that matter the non-appearance of directors cannot be considered as factor to disprove the evidences filed.
7. For that the Ld CIT(A) should have held that the issue of shares at a premium cannot be a ground for making the addition.
8. For that on the facts and in the circumstances of the case, the addition u/s 68 made by the TRO and confirmed by the Ld CIT(A) is not in accordance with law."
3. From the above stated grounds of appeal it is noted that assessee has raised jurisdictional issue relating to whether Tax Recovery Officer (TRO) can act as an Assessing Officer (AO) and the second issue on merits in respect of addition made towards share capital raised by the assessee during the year.
4. Brief facts of the case as culled out from records are that assessee is a Non-banking Finance Company (NBFC) and had filed its return of income on 25.09.2012 reporting total income at nil. Notice u/s. 143(2) of the Act was issued on 08.08.2013 and served on the assessee on 20.08.2013. Subsequently, Ld. CIT passed orders directing the TRO-2, Kolkata to exercise powers and functions of the AO. The orders passed by Ld. CIT were vide order No. 30 F. No. CIT/Kol-II/u/s. 2(44)/120/6/2014-15 dated 04.08.2014, Order No. 07/2014-15 dated 08.08.2014 and order No. 19/2014-15 dated 24.11.2014. Notice u/s. 142(1) with detailed questionnaire were 3 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 issued and served on the assessee. Ld. AO also issued summons u/s. 131 of the Act to the directors of the assessee.
4.1. Ld. AO had noted that assessee has raised share capital including share premium, totalling to Rs.7,12,00,000/-, having face value of Rs.10/- each and share premium of Rs.990/- each. To verify the genuineness of the said transaction and to verify the identity and creditworthiness of the shareholders, ld. AO issued summons u/s. 131 to the directors of the assessee namely, Shri Radheshyam Saraf and Shri Laxman Saraf on 23.01.2015. Summons remained uncomplied after which Ld. AO issued a show cause letter on 04.03.2015. In response to this show cause letter, Ld. AO has noted that assessee has submitted sheaves of paper documents without providing explanation and thus, treated the reply as non-complied. Ld. AO had analysed the bank statement of the share subscribing companies to observe that every single credit to the account was correspondingly followed by the matching debit either on the same day or near about days, thus, held that neither the source of all such credits nor the identities of subscribers is ascertainable. Ld. AO being not satisfied with the submissions made by the assessee, completed the assessment by holding that assessee and the share subscribing companies are paper/shell companies and made the addition of Rs.7,12,00,000/- u/s. 68 of the Act as unexplained cash credits. Ld. AO completed the assessment by referring to provisions of Sec. 144 i.e. passing the order ex parte based on material available on record. Aggrieved, assessee went in appeal before the Ld. CIT(A).
5. Before the Ld. CIT(A), assessee took additional grounds on the jurisdictional issue of assessment having been completed by TRO which was rejected and was dismissed by observing that power to transfer cases by the Ld. CIT cannot be challenged before the Ld. CIT(A). While dealing with the grounds of appeal on merit, Ld. CIT(A) 4 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 observed that assessee had submitted details of share applications along with relevant corroborative documents which included copies of confirmation of share application money, bank statements, ITR Acknowledgment, audited financial statements, Company Master Data from MCA Portal, PAN. Ld. CIT(A) had also called for a remand report from the AO on the submissions made by the assessee vide e-mail communication made on 06.10.2023 to the Ld. AO who did not respond. He thus, disposed of the appeal by taking into consideration submissions made by the assessee.
5.1. From the details filed by the assessee in the course of first appellate proceeding, ld. CIT(A) analysed and tabulated certain observations. In the first set of observations, on source of source, he noted that certain subscribers have sourced their fund for making investment into the share capital of assessee from certain common sources. In another set of observations, he noted that return of share subscriber companies have been uploaded from single IP address. In yet another set of observations, on analysis of the bank statement of the share subscribing companies, he noted certain discrepancies in respect of appearance of name of the account holder, statement period, statement page no., bank branch address, account type mentioned or absent in the bank account statements. Based on these observations, he upheld the adverse view taken by the Ld. AO for making the addition. The Ld. CIT(A) thus dismissed the appeal of the assessee upholding the addition made by the Ld. AO. Aggrieved, assessee is in appeal before the Tribunal.
6. Before us, Ld. Counsel for the assessee has placed on record a written submission on both the aspects of the appeal i.e. on the jurisdictional issue as well as on the merits of the case. Ld. Counsel also placed on record a paper book containing 498 pages in support of corroborating the transaction of share capital including share 5 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 premium raised during the year. Ld. Counsel for the assessee has made a detailed and elaborate submission on the jurisdictional issue. He also took the Bench through the merits of the case to demonstrate the onus discharged by the assessee in terms of section 68 of the Act. He categorically pointed out that Ld. AO himself has noted in the assessment proceeding that assessee has furnished sheaves of paper documents in response to the summon issue. Ld. Counsel also pointed out that Ld. AO has analysed the bank statement of the share subscribing companies which evidently demonstrates that all the relevant documentary evidences were before the Ld. AO though adverse view was taken. Ld. Counsel also submitted that summons were issued u/s. 131 on the directors of the assessee which even though were not complied in terms of personal attendance but were responded to by making all the necessary details and documents which have been acknowledged by the Ld. AO.
6.1. Ld. Counsel also submitted that mere non-appearance of directors is no basis for invoking provisions of section 68 of the act for which he placed reliance on the decision of Hon'ble Supreme Court in the case of CIT v. Orissa Corpor ation (P) Ltd. (1986) 159 ITR 78 (SC) wherein it was held as under:
"In this c ase the as sessee had given the n ames and add resses of the allege d creditor s. It was in the kn owledge of the rev enue that the s aid cred itors were the in co me - tax assessees. T he ir index number was in the f ile of the revenue. The revenue, apar t f rom issuing no tices under s ection 131 at the ins tance of the asse ssee, d id no t pursue the ma tter f ur ther. Th e revenue d id no t examine the source of inco me of the said al leged cred itors to f ind out whe the r they were credit- wor thy or we re such who could adv an ce the alleged lo ans. There was no effor t made to pursue the so- c alled alleged cre ditors. In those circums tan ces, the assessee could no t do any f ur ther. In the pre mises, if the T r ib unal came to the conc lus ion th a t the assessee had discharged the bur den that lay on him, then it could no t be s aid that such a con clus ion was unreasonab le or perverse or based on no ev ide nc e. If the 6 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 conc lus ion was based on so me evide nce on wh ich a co nc lus io n could be arr ived a t, no question of law as such could ar is e.
The High Cour t was, th eref ore, right in ref using to r ef er the ques tions sough t f or. Decis io n of the H igh Cour t af f irme d."
6.2. It was also submitted that audited Balance Sheet of each of the share applicant companies reflected the amount of investment made by them in the assessee as against their respective net worth. He thus, contended that Ld. AO has made the addition with a predete rmined mind set. Further, according to him, they are all re gistered companies under the Companies Act, 1956.
6.3. According to him, Ld. AO has not made any attempt to enquire into the details and documents placed on record in the assessment proceeding. He submitted that Ld. AO has casually remarked that merely dumping the papers and documents on the table of the assessing authority does not in any way mean compliance. The burden of proof cannot be shifted on the revenue by cart loads of documents. On this observation of the Ld. AO, he strongly submitted that no attempt has been made by the Ld. AO to enquire into the veracity of the documents and details furnished by the assessee. According to him, no notice u/s. 133(6) or section 131 were issued to the share subscribing companies to disprove the documents and evidence filed by the assessee. Thus, the burden was on the Ld. AO as no adverse material has been brought on record to substantiate the addition made in the hands of the assessee.
6.4. Ld. Counsel for the assessee submitted that to establish the identity and creditworthiness of the shareholders and genuineness of the transactions, assessee has submitted all the relevant details and documents in the course of assessment as well as appellate 7 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 proceedings, details of which are tabulated and is extracted below from the index of the paper book for ease of reference:
8 ITA No.1178/Kol/2023Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 9 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 10 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 11 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 6.5. Ld. Counsel reiterated that the share subscribers are body corporate, registered with ROC and are assessed to income tax. He further stated that these subscribers had confirmed the transactions, filed relevant papers and documents and also explained the source of funds in their hands for making investment in the assessee. He thus, emphasized that assessee had discharged its primary onus casted 12 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 upon it u/s. 68 of the Act. According to him, the onus thus shifted to the Ld. AO to disprove the material placed before him. Without doing so, the addition made by the Ld. AO is based on conjectures and surmises and, therefore, cannot be sustained. He pointed that Ld. AO for reasons known to him alone, did not chose to issue notices/summons u/s. 133(6)/131 to the share subscribers.
6.6. Ld. Counsel submitted that instead of pointing out any de fe ct or discrepancy in the evidence and the details furnished by the assessee , Ld. AO proce eded to take adverse inference only on the ground that the directors of the assessee did not appear personally before him. In this respect he placed reliance on the de cision of Hon'ble Jurisdictional High Court of Calcutta in the case of Crystal Networks Pvt. Ltd. v. CIT in ITA 158 of 2002 dated 29.07.2010.
6.7. Ld. Counsel also emphasized on the fact that in the submissions including ITRs, audit reports, share application details etc. as listed above, the Ld. AO has not found fault in any of the details submitted and simply proceeded to make addition in respect of the amount of share capital and premium. The documents furnished are to be prima facie considered as correct unless evidence is brought on record to falsify the claim made therein.
6.8. On the three basic ingredients for any cash credit viz., identity, creditworthiness of the subscribers and the genuineness of the transactions, Ld. Counsel submitted that all of these are fulfilled. In this respect he submitted as under:13 ITA No.1178/Kol/2023
Champalal Rajkumar Textile Pvt. ltd., AY 2012-13
(i) On identity : - All the shareholders are regular income tax assessees and have filed their income tax returns. Ld. Counsel thus emphasized that identity of all the share subscribers is well established and cannot be doubted. Further, he submitted that company subscribers are body corporate registered under the Companies Act, 1956.
ii) On creditworthiness: To establish the creditworthiness of the subscribers, details relating to source of fund in the hands of these shareholders represented by their respective net worth were furnished along with their respective bank statements and audited financial statements. The details furnished by the assessee in this respect are reproduced in the table below:14 ITA No.1178/Kol/2023
Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 15 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 16 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 It was thus, submitted that the above table containing details on "source of source" unequivocally testifies and proves that the subscribers had sufficient fund for making investment in the share capital of the assessee.
iii) On genuineness of the transaction: It was submitted that the amounts were invested by the subscribers through proper banking channel which is duly reflected in the respective financial statements of the subscribers. Since the investments reflected in their respective financial statements have been duly reported in their respective returns with the Department are thus genuine and transaction cannot be doubted.
7. Per contra, ld. Sr. DR placed reliance on the orde r of the authorities below and submitted that assessee's own income has been infused in the guise of share capital through the allottee companies by layering the transactions to make appear a non-genuine transaction as a genuine one
8. We have heard the rival contentions and gone through the material placed on record. We note that Ld. AO without even going through and discussing the details submitte d by the subscriber companies, insisted for personal appearance of the directors of the asse ssee to prove the identity, creditworthiness of the subscribers and the genuine ness of the transactions. To our mind, Ld. AO could have taken an adve rse view only if he could point out the discrepancies or insufficiency in the evidence and details furnished in his office and also as to what further investigation was needed by him by way of recording of statement of the directors of the assessee. We draw our force from the de cision of the 17 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 Hon'ble Bombay High court in the case of PCIT v. Par adise Inl and Shipping Pvt. Ltd. [2017] 84 taxmann.com 58 (Pan) wherein it was held that once the assessee has produced documentary evidence to establish the existe nce of the subscriber companies, the burden would shift on the re venue to establish their case. We also draw our force from the de cision of Hon'ble Jurisdictional High Court of Calcutta in the case of Crystal Network Pvt. Ltd. v. CIT (supra) which held as under:
"We f ind consider able f orce of the submiss ions of the le arned counsel f or the appellan t th at the Tr ibun al h as mere ly no tic ed that s ince the s u mmons issued bef ore as sessme nt re turned unserved and no one came f or ward to prove. T heref ore it shall be assumed tha t the assessee f ailed to prove the ex is tence of the creditors or f or th a t matter cred it wo r th iness. As r igh tl y po inted out by the le arned counsel th at the CIT( Appe als) has taken the tro uble of examin ing of all other ma ter ials and docu ments v iz., conf ir mator y s ta te men ts, inv oices, challans and voucher s sho wing supp ly of bid i as ag ainst the advance. Theref ore, the attendan ce of the witnesses p ursuant to the summons issued in ou r v ie w is no t imp or tan t. The impor tant is to pr ove as to whe ther the said c ash credit was rece ived as agains t the f uture s ale of the produce of the assessee or not. When it was f ound by the CIT (A ppe al) on f act h av ing examined the docu men ts th at the adv ance given by the cred itors h ave been established the Tr ibun al shou ld no t h ave ignored this f ac t f inding."
8.1. Ld. AO has not bothered to discuss or point out any de fe ct or deficiency in the documents furnished by the assessee of the share subscribing companie s. These evidences furnishe d have bee n neither controverted by the Ld. AO during the assessment proceedings nor anything substantive brought on record to justify the addition made by him. Ld. AO has simply adde d the amount of share capital and share premium on the ground that assessee has not produced its directors. Thus, going by the records placed by the assessee of all the share subscribing companies, it can 18 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 be safely held that the assessee has discharged its initial burden and the burden shifted on the Ld. AO to enquire further into the matter which he failed to do so. It is also note d from their audited financial statement and chart extracted above that all the investing companies have sufficient own funds available with them to make investment in the assessee.
8.2. From the perusal of the paper book and the documents place d therein, it is vivid that all the share applicants are (i) income tax assessees, (ii) they are filing their income tax returns, (iii) share application form and allotment letter is available on record, (iv) share application money was made by account payee cheques, (v) details of the bank accounts be longing to share applicants and their bank statements, (vi) in none of the transactions there are any deposit of cash be fore issuing cheques to the assessee, (vii) all the share applicants are having substantial creditworthiness represented by their capital and reserves, (viii) details relating to 'source of source' also placed on record by the subscribers.
9. Before concluding, to give our finding, we place reliance on the following judicial precedents to buttress our observations and conclusions :
i) The decision of Hon'ble Jurisdictional High Court of Calcutta in the case of CIT v. Dataware Pvt. Ltd. in ITAT No. 263 of 2011 dated 21.09.2011 wherein Hon'ble jurisdictional High Court held that 19 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 "After getting the PAN number and getting the information that the creditor is assessed under the Act, the Assessing officer should enquire from the Assessing Officer of the creditor as to the genuineness" of the transaction and whether such transaction has been accepted by the Assessing officer of the creditor but instead of adopting such course, the Assessing officer himself could not enter into the return of the creditor and brand the same as unworthy of credence."
ii) Decision of Hon'ble jurisdiction High Court of Calcutta in the case of CIT Vs. Sagun Commercial P. Ltd. (ITA No. 54 of 2001 dated 17.021.2011) wherein it was held as under:
"After hearing the learned advocate for the appellant and after going through the materials on record, we are at one with the Tribunal below as well as the Commissioner of Income-tax (Appeals) that the approach of the Assessing Officer cannot be supported. Merely because those applicants were not placed before the Assessing Officer, such fact could not justify disbelief of the explanation offered by the assessee when details of Permanent Account Nos. payment details of shareholding and other bank transactions relating to those payments were placed before the Assessing Officer. It appears that the Tribunal below has recorded specifically that the Assessing Officer totally failed to consider those documentary evidence produced by the assessee in arriving at such conclusion.
We, therefore, find no reason to interfere with the decision passed by the Commissioner of Income-tax (Appeals) and the Tribunal below and answer the questions formulated by the Division Bench in the affirmative and against the Revenue. The appeal is, thus, dismissed."
iii) Decision of Hon'ble Bombay High Court in the case of CIT v. Creative World Telefilms P. Ltd. (2011) 333 ITR 100 (Bom) wherein it was held as under:
"In the case in hand, it was not disputed that the assessee had given the details of name and address of the shareholder, their PAN/GIR number and had also given the cheque number, name of the bank. It was expected on the part of the Assessing Officer to make proper investigation and reach the shareholders. The Assessing Officer did nothing except issuing summons which were ultimately returned back with an endorsement "not traceable". The Assessing Officer ought to have found out their details through PAN cards, bank account details or from their bankers so as to reach the shareholders since all the relevant material details and particulars were given by the assessee to the Assessing Officer. In the above circumstances, the view taken by the Tribunal could not be faulted. No substantial question of law was involved in the appeal.'' 20 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13
iv) Decision of Hon'ble Madras High Court in the case of Pranav foundations Ltd. (2015) 229 Taxman 58 (Mad) is also referred wherein it was held as under:
"In view of the fact that all the four parties, who are subscribers of the shares, are limited companies and enquiries were made and received from the four companies and all the companies accepted their investment. Thus, the assessee has categorically established the nature and source of the said sum and discharged the onus that lies on it in terms of section 68. When the nature and source of the amount so invested is known, it cannot be said to undisclosed income. Therefore, the addition of such subscriptions as unexplained credit under section 68 is unwarranted."
10. We note that authorities below have relied upon the decision in the case of M/s Bisakha Sales Pvt. Ltd. v CIT [2014] 52 taxmann.com 305 (Kolkata- Trib.). In this case, it was held that where assessee- company received share application money with huge and unjustified share premium from corporate entities, merely because said amount was received through banking channel, Assessing Officer was not justified in accepting said transactions as genuine without making proper enquiries. Apparently, the AO has not properly appreciated that decision of the Hon'ble ITAT. The Hon'ble ITAT has never held that share capital and share premium can be assessed as unexplained cash credit merely for high share premium even though the identities and creditworthiness of the share applicant and genuineness of the transactions have been established. What is held by the Hon'ble ITAT is that revision proceedings u/s 263 are valid where the transactions have been accepted as genuine without making proper enquiries.
11. Further, in the judgment of Hon'ble Supreme Court in the case of NRA Iron & Steel Pvt. Ltd. (412 ITR 161), Ld. AO has made extensive enquiries and some of investors were found to be non-existent. Upon going through the facts involved in that judgment, it is noted that, in the decided case, the AO had made extensive enquiries and from that 21 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 he had found that some of the investor companies were non-existent, which is certainly not the case before the undersigned. In the said decided case, certain investor companies also failed to produce their bank statements for proving the source for making investments in assessee company. In the facts of the present case however, not only have the shareholders furnished their bank statements and investment schedules to establish the source of funds but they have also furnished their respective sources of funds.
12. Considering the facts and circumstances of the case and the material placed on record, we find that assessee has discharged its onus to prove the identity and creditworthiness of the share subscribing companies and the genuine ness of the transactions towards sum of Rs.2,76,50,000/- received during the impugned year. Accordingly, considering the se facts and in the light of the judicial pre cedence referred above, we set aside the order of the ld. CIT(A) and delete the addition made towards share capital and share premium u/s. 68 of the Act. Accordingly, grounds taken by the assessee in this respect are allowed.
13. Since on the merits of the case, we have deleted the addition made by the Ld. AO in terms of our observations and findings recorded above, the legal issue raised by the assessee in this appeal on the jurisdiction of TRO to make the impugned assessment is rendered as a mere academic exercise. Accordingly, we desist ourselves from indulging into such an exercise. Ld. Counsel for the assessee has made a detailed written submission on the legal issue which is placed on record. Ld. CIT, DR in the course of hearing had also submitted that he be given an opportunity to make a submission on the legal 22 ITA No.1178/Kol/2023 Champalal Rajkumar Textile Pvt. ltd., AY 2012-13 issue in case it is being adjudicated upon which in the present case is not warranted. Accordingly, grounds taken by the assessee in this respect are not adjudicated upon.
14. In the result, appe al of the assessee is allowed.
Order is pronounced in the open court on 17th January, 2024 Sd/- Sd/-
(Sonjoy Sarma) (Girish Agrawal)
Judicial Member Accountant Member
Dated: 17th January, 2024
JD, Sr. P.S.
Copy to:
1. The Appellant:
2. The Respondent.
3. CIT(A), NFAC, Delhi
4. CIT
5. DR, ITAT, Kolkata Bench, Kolkata
//True Copy//
By Order
Assistant Registrar
ITAT, Kolkata Benches, Kolkata