Income Tax Appellate Tribunal - Kolkata
M/S. Acetylene Trexim Pvt. Ltd., ... vs Acit, Cc - 3(4), Kolkata, Kolkata on 17 July, 2019
I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8
Assessment year: 2009-2010
&
C . O. N o. 7 5 / KO L / 2 0 1 8
[ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ]
A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0
M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d
Page 1 of 11
IN THE INCOME TAX APPELLATE TRIBUNAL,
KOLKATA 'B' BENCH, KOLKATA
Before Shri P.M. Jagtap, Vice-President (KZ) &
Shri A.T. Varkey, Judicial Member
I.T .(SS)A. No. 39/KOL/2018
Assessment Year: 2009-2010
Assistant Commissioner of Income Tax,.... .......................................Appellant
Central Ci rcle-3 (4), Kolkata,
Aayakar Bhawan,
110, Shanti Pally, 5 t h Floor,
Kolkata-700 107
-Vs.-
M/s. Acetylene Trexi m Pvt. Limited..................................................Respondent
14, Netaji Subhas Ro ad, 4 t h Floor,
Kolkata-700 001
[PAN: AACCA 4045 J]
&
C.O. No. 75/KOL/2018
[arising out of I.T.(SS)A. No. 39/KOL/2018]
Assessment Year: 2009-2010
M/s. Acetylene Trexi m Pvt. Limited..............................................Cross Objec tor
14, Netaji Subhas Ro ad, 4 t h Floor,
Kolkata-700 001
[PAN: AACCA 4045 J]
-Vs.-
Assistant Commissioner of Income Tax,.... ........................................Respondent
Central Ci rcle-3 (4), Kolkata,
Aayakar Bhawan,
110, Shanti Pally, 5 t h Floor,
Kolkata-700 107
Appearances by:
Shri Radhey Shyam. CIT, D.R. , for the Department
Shri R.Choudhury, A.R., for the Assessee
Date of concluding th e hearing : Ju ly 09, 2019
Date of pronouncing the order : Ju ly 17, 2019
O R D E R
Per Shri P.M. Jagtap, Vice-President (KZ):-
This appeal is preferred by the Revenue against the order of ld. Commissioner of Income Tax (Appeals)-21, Kolkata dated 16.02.2018 and I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 2 of 11 the same is being disposed of along with the Cross Objection filed by the assessee being C.O. No. 75/KOL/2018.
2. The assessee in the present case is a Non-Banking Finance Company, which filed its return of income for the year under consideration regularly on 25.09.2009 declaring total income of Rs.8,04,560/-. In the assessment originally completed under section 143(3) vide an order dated 07.09.2011, the total income of the assessee was determined by the Assessing Officer at Rs.1,28,40,560/- after making two additions of Rs.1,05,36,000/- and Rs.15,00,000/- on account of expenditure on purchase of shares and Keyman Insurance respectively. Against the said order passed by the Assessing Officer under section 143(3), an appeal was preferred by the assessee before the ld. CIT(Appeals), who vide his appellate order dated 06.07.2012 deleted both the additions made by the Assessing Officer on account of disallowance of expenditure on purchase of shares and Keyman Insurance. Against the said order of the ld. CIT(Appeals), an appeal was preferred by the assessee before the Tribunal. Meanwhile a search and seizure action was conducted in the business premises of the assessee-company on 18.09.2012, which concluded on 19.09.2012. Pursuant to the said action, notice under section 153A was issued by the Assessing Officer on 27.11.2013, in response to which the return of income was filed by the assessee on 28.01.2014 declaring the same income of Rs.8,04,560/- as declared in the return of income originally filed. Thereafter assessment was completed by the Assessing Officer under section 153A /143(3) of the Act vide an order dated 30.03.2015, wherein he repeated both the additions made in the original assessment completed under section 143(3) on account of disallowance of purchase of shares and Keyman Insurance on the ground that both these issues were pending in appeal I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 3 of 11 before the ITAT and in order to maintain judicial consistency, both the additions were repeated.
3. Against the order passed by the Assessing Officer under section 153A/143(3) of the Act, an appeal was preferred by the assessee before the ld. CIT(Appeals). Meanwhile the appeal filed by the Department against the order of the ld. CIT(Appeals) dated 06.07.2012 challenging the deletion of both the additions made in the original assessment came to be disposed of by the ITAT vide its order dated 03.08.2016 passed in ITA No. 1429/KOL/2012, whereby the order of the ld. CIT(Appeals) giving relief to the assessee on both these issues were upheld by the Tribunal. Taking note of the said decision of the Tribunal, the ld. CIT(Appeals) vide his appellate order dated 16.02.2018 deleted the said two additions made by the Assessing Officer in the assessment completed under section 153A/143(3) to maintain judicial consistency. Aggrieved by the order of the ld. CIT(Appeals), the Revenue has preferred this appeal before the Tribunal, while the assessee-company has also filed its Cross Objection.
4. Grounds raised by the Revenue in its appeal read as under:-
"(1) The ld. CIT(A) erred in law as well as on facts in deleting the disallowance of Rs.15,02,247/- on account of payment made for Keymans Insurance Policy for the Directors, without appreciating the fact that the person for whom the policy was taken is not a key person of the company and is only an authorized signatory.
(2) The ld. CIT(A) erred in law as well as on facts in deleting the disallowance of Rs.1,05,36,000/- incurred in relation to purchase of shares without appreciating the fact that the purchase of shares were not on the contract date being 29.08.2008 as alleged by the assessee, and the sale consideration was received by M/s. Puskar Banijya only as late as on 17.03.2009, and the shares were transferred to de mat account immediately thereafter on 20.03.2009, and that the loss incurred thereon is not I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 4 of 11 adjustable with income as laid down in the decision of Hon'ble Supreme Court in the case of Maddi Venkataraman & Co. Pvt. Ltd. reported in 229 ITR 534 (SC)".
5. Grounds raised by the assessee in its Cross Objection read as under:-
"(1) That on the fact and circumstances in the case of assessee for the same assessment year simil ar additions was made in regular assessment u/s 143(3) on 30/03/2015 by Assessing Officer 9(1 ) Kolkata, which was deleted and decided in favo ur of assessee by C IT(A)(VIII) Kolkat a, vide o rder dated 05/07/2012.
2. That on the fact and circumstances of the case the appeal filed by th e Assessing Officer 9(1) Kolkata, against the order of CIT(A)(VIII) befo re Hon'ble ITAT was h eard and decided of under IT AT No.1429/Ko1/2012, dated 03/08/2018. Wherein the Hon'ble ITAT 'C' Bench Kolkata, and uphold the orde r of CIT(A)(VIII) and dismissed the Revenue appeal against the order dated 30.03 .2015 u/s 143(3).
3. That on the facts and circumstances of the case the addition of Rs.15,02,247/- on account of Key Insurance Premi um and expenditure in relat ion to purch ase of shares amounting to Rs.1 ,05,36,000/- are covered by the order of Hon'ble ITAT 'C' Bench Kolkat a, and uphold the order of Ld.CIT(A) and gro unds raised for addit ion made by revenue was dismissed.
4. That on the fact and circumstances of the case the addition u/s 153A/143(3) made by DCIT is stated only to maint ain consistency is bad in l aw as well as on fact of the case.
5. That on the fact and circumstances of t he case there was no proceeding pending o n the last-day of aut horization of search and attended final ity befo re th e date of search no incriminating material or assets found in course of search and the assessment attended finalit y should not have been disturbed. A co mpleted assessment can be interfered by Assessing Officer by making assessment under section 153A only on the basis of incriminating material unearthed during the course of search or not disclosed and hence assessment under sectio n 153A is bad in law.
6. We have heard the arguments of both the sides and also perused the relevant material available on record. It is observed that both the I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 5 of 11 additions made on account of disallowance of expenditure on purchase of shares and Keyman Insurance in the original assessment completed under section 143(3) for the year under consideration were simply repeated by the Assessing Officer in the assessment completed under section 153A/143(3) vide an order dated 30.03.2015 just to maintain judicial consistency since the issues relating to the said additions made in the assessment originally completed under section 143(3) were pending before the Tribunal in the appeal filed by the Department. Against the order passed by the Assessing Officer under section 153A/143(3), an appeal was preferred by the assessee before the ld. CIT(Appeals) disputing the said two additions and before the said appeal could be heard by the ld. CIT(Appeals), the appeal filed by the Department against the order of the ld. CIT(Appeals) deleting the similar additions made in the assessment originally completed under section 143(3) came to be disposed of by the Tribunal and the relief allowed by the ld. CIT(Appeals) on these two issues was upheld by the Tribunal vide its order dated 03.08.2016 passed in ITA No. 1429/KOL/2012 for the following reasons given in page nos. 10 & 11 as well as on page nos. 16 to 19 of the impugned order of the ld. CIT(Appeals):-
From page nos. 10 & 11 "11. We h ave heard rival content ions and perused the materials available o n reco rd. We find th at AO disallowed th e payment of KIP premium on th e ground th at the directo rs of assessee-co mpany are not actively engaged in the day-to-day affairs. At this juncture, we would like to reproduce the meaning of KIP as per Explanation-1 to Sect ion 10(10D) of the Act which reads as under: -
"[Explanatio n 1] -Fo r the purposes of this clause, "Keyman insurance policy" means a life insurance policy tak en by a person o n the life of another person who is or was the employee of the first- mentio ned person o r is or was connected in any manner whatsoever with the business of the first - mentio ned perso n [and includes such policy which has been assigned to a person, at an time during the term of the policy, with or with out any consideration]; ] I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 6 of 11 On a bare reading, we find th at said Section requires the connection between the assessee and person to be covered under insurance. It is not necessary that h e should be aware of all the affairs of business of assessee. In view of above, we find no reason to interfere in the order of Ld. CIT(A). We uphold accordingl y. Ground raised by Revenue is dismissed" .
From page nos. 16 to 19 "6. We have h eard rival parties and perused the materials available on record. Ld. DR filed written submissio n which is placed on record. On the other h and, Ld. AR submitted paper book which is running from pages 1 to 155 pages and cited case laws.
6.1. From the fo regoing discussion, we find that as sessee has purchased sh are of the GHCL on 29.08.2008 but made the payment fo r the purchase of share in the month of March'09 and also shares were transferred to the demat account of assessee in the mont h of March '09. The value of sh are came down drast ically on t he balance-sheet date as on 31.03.2009 as a result due to decline in the value of shares a loss of RS.1,05,36,000/- was booked in its books of account . We find that AO t reat ed this l oss claimed by assessee as illegal loss and it was creat ed with the sole purpo se o f avoiding the t ax liability against the income from the genuine source of the assessee's business, However, Ld. CIT (A) deleted the addition made by AO. Now the question befo re us is as to whether the loss arising as a result of valuation of closing stock of share is genuine business loss in the aforesaid fact s and ci rcumst ances, At the outset, we find that sh ares were purchased on 29,08,2008 from MPB and on the date of purchase stock of share was very much available in the demat account of MPB as evidenced in the demat account of MPB which is placed on page 45 of the paper book, We also find th at a notice was issued to MPB u/s 133(6) of the Act for confirming the aforesaid transactions in its books of acco unt , We find that MPB h as dul y reflected the transactions with the assessee in its books of account and in support of its claim, th e balance-sheet along with other document s and bank e/c are pl aced on pages 42 to 64 of the paper boo k, We further find t hat aforesaid shares were sold subsequent ly in the financial year 2009-10 and the details of th e same is placed on pages 68 to 81 of the paper book, We also find th at in the similar fact s, co-o rdinat e Bench decided the same issue in favo ur of assessee in ITA No, 1595/Kol/2012 dated 30-01-2015 in the case of ITO v , Kiran Consortium T rade CP) Ltd, The relevant extract is reproduced below:-
I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 7 of 11 "5. We have heard rival content ions and go ne thro ugh facts and circumst ances of the case. We find fro m the facts that th e assessee purch ased these shares fro m Beejay Investments and Financial Consult ants P. Ltd (in short BIFC) and consequently, the said part y issued the sale bill to assessee, copy of which was filed before the assessing officer and the same is not disputed. The assessing officer has raised the issue th at BIFC did not have the adequat e number of shares in their stock as on the date sale. However, th e fact s are contrary to the findings of the assessing officer, as wo uld appear from the co py of account enclosed h erewith, that the said BFIC had the required number of sh ares in thei r stock and in respo nse to the query of the assessing officer, an explanat ion was filed vide letter dated 30- 11- 2011 (copy is enclosed in assessee's paper book). Further, the assessing officer also made enquiry under section 133(6) fro m t he seller BIFC , who also replied and admitted the factum of the sale of share. Therefo re simply because the shares amount transferred to the Demat account of the assessee or that the payments were made in th e subsequent year, the transactio n cannot be taken to be not genuine. The assessing officer noted that the transactio n is bogus and further the purch ase was inflated. However, there is no basis for the same but it is only the presumptions of the assessing officer. Moreo ver, as info rmed during the course of this appeal hearing befo re us by learned Counsel that aft er completio n of the assessment of the assessee, scrutiny assessment of the seller was t aken up and in such scrut iny assessment , the sale of the have been t reated to be genuine. This fact was also not examined by the assessing officer from the assessment records of the seller, as the PAN was given. We are of the view t hat in case the transaction have been treated as genuine in the hands of the seller, the same very t ransact ion cannot be non-genuine in the hands of the purch aser. Apart fro m this, learned Counsel also relied on the judgement of Hon'ble Gujarat High Court in th e case of CH v. Prudent Finance (P.) Ltd. (2 014) 225 Taxman 0 125 (Gu)), wherein exactl y ident ical issue was taken up and the facts discussed by Hon'ble High Court as under: -
"Respondent of T ax Appeal No . 1003/2013 and other connected appeals is one Prudent Finance Pvt . Lt d. a co mpany regist ered under the Companies Act . One Nitin B. Parikh and I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 8 of 11 other members of h is family referred to as Nttin B. Parikh group of assessee who h ad control over others, was subjected to search action under sectio n 132 of the Act . It was found th at large number of sh ares were traded between th e Company and the said group of persons at off-mark et transactio ns. Such off market transactions were entered by the company with ot her unrelated assesses also. The assessing officer carried a bel ief that such transactio ns were not genuine, in the sense that th e same would have t ak en place with anterio r dates in the opinion of the assessing officer, this was do ne to contrive loss in the hands of some of the assessee who in turn transferring the profits in the hands of oth er assessees. This was done to ensure that the assessees who had sizable profits from sale of shares could claim such losses as set off. Th e assessing officer questioned the assessee company in detail . The assessing officer in the order of assessment formed a belief th at full det ails were not made available with respect to such transactions. The sal es were not at mark et price. Th e amount s were not paid, but o nly account ent ries were made. The shares were also not transferred in th e name of t he purchasers. On such basis, the assessing officer co ncluded th at the transactions were not genuine and applying the ratio of the judgment of the Supreme Court in the case of McDowell Co. Lt d v. Commercial Tax. Officer (1985) 154 ITR 148/22 Taxman 11, held th at such loss cannot be allowed. The assessing officer observed that whenever sales were made to other ent ities, they were not followed by cheque receipt s. Simil arly wh en purchases were made from other entities, they were also not followed by cheque payments. He concluded th at th e assessee carried off market transactions by simple purchase bills or sales bills ignoring mark et rates. This was done t o avoid t ax. "
And finally held as under:
"8. Additionally, we also note that necessary entries were made in the account books of both sides, i.e. purchaser and seller and delivery receipt s were also passed demo nst rating I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 9 of 11 contemporaneous sale and purchase of the shares. It is not even the ease of the Revenue that such off mark et transactions were not permissible. When we find that off market transactions were permitted in law, that there was no evidence to suggest that artificiall y they were sold at rat es lower than the prevailing market rat es and we further find that the assessing officer coul d not bring on reco rd any material to show th at the transactions were sh own to be deliberat ely back-dated, the findings of the Co mmissioner (Appeals) as well as that of the Tribunal , in our opinion, call fo r no int erference."
In view of the abo ve fact s and identical issue t aken up by Hon'ble Gujarat High Court in the case of Prudent Finance (P.) Ltd., supra, we are of the view that the t ransactio n to unrelated parties i.e. off mark et transaction, there was no e vidence in th e present case also which suggest s that the shares were artificially sold at a lower rate than the prevailing market rt e. Even the assessing office co uld not bring anyth ing on reco rd, which suggests that the sell ing rate was lower t han the market rate. Respectfully following Hon'b/e Gujarat High Court, we confirm the order of Commissioner (Appeals) and t he issue of revenue' s appeal is dismissed."
Further we also relying on th e judgment of Hon'ble Gujarat High Court in the case of CIT v. Prudent Finance CP) Lt d. (2014) taxman 125 where the head note as under:-
"Business loss - Allowability Genuineness of loss on off market transactio ns - Assessee-co mpany found to be treat ed in off mark et share transactio ns with it s related group of persons as well as with unrelated groups of perso ns. AO disallowed losses o n impugned transactions on the ground that transactio ns were not genuine as assessee carried off market transactio ns by simple purch ase bills or sales bills igno ring market rates. This was do ne to avoid tax. Moreover neither any amo unt was paid nor any sh ares were transferred in the name of purch asers, onl y account entries were made. Held-:Necessary ent ries were made in the account books of bot h sides, i.e, purch aser and seller and delivery receipts were also passed demonstrating contemporaneous sal e and purch ase of the shares. It was not even the case of the Revenue that such off market transactions were not permissible. When off market t ransact ions were permitt ed in law, and there was no evidence to suggest that artificiall y they were sold at rates lower t han the prevailing market rates and AO could not bring on record any material to show that the t ransactions were not genuine, the I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 10 of 11 findings of C IT(A) as well as Tribunal that impugned transactions were genuine, called for no int erference."
Fro m the above judgment s, we find th at th e transactions of sale- purchase was dul y recorded in the book s of account of the respective part ies, the allegation by the Assessing Officer that the off market transactions cannot be accepted under SCRA is factual incorrect rel ating in the aforesaid appellat e order. We also find th at the exception has been provided in the SCRA Act under section 14(2) of the SCRA Act as discussed above. Accordingly we uphold the order of Ld. C IT (A) and g round raised by Revenue is dismissed".
7. Keeping in view the decision of the Tribunal as rendered above on the similar issues, the ld. CIT(Appeals) deleted the similar additions made by the Assessing Officer in the assessment completed under section 153A/143(3) to maintain judicial consistency. At the time of hearing before the Tribunal, the ld. Counsel for the assessee has contended that both the issues involved in this appeal of the Revenue are squarely covered in favour of the assessee by the order of the Tribunal dated 03.08.2016 passed in ITA No 1429/KOL/2012, wherein the same additions made by the Assessing Officer were held to be not sustainable by the Tribunal by passing a well discussed and well reasoned order. The ld. D.R. has also not disputed this position. He, however, has contended that the aspect of colourable device adopted by the assessee to claim the expenditure on purchase of shares was not looked into by the Tribunal in its order dated 03.08.2016. We, however, find that this was not the case made out even by the Assessing Officer in the assessment completed passed under section 153A/143(3) and both the additions were repeated by him in order to maintain judicial consistency keeping in view that the issue relating to the same additions made in the regular assessment were pending before the Tribunal vide an appeal filed by the Department. We also note from the assessment order passed by the Assessing Officer under section 153A/143(3) that both these additions were repeated by the Assessing Officer just to maintain judicial consistency and there was I . T. ( S S ) A . N o 3 9 / KO L / 2 0 1 8 Assessment year: 2009-2010 & C . O. N o. 7 5 / KO L / 2 0 1 8 [ i n I T ( S S ) A N o. 3 9 / KO L / 2 0 1 8 ] A s s e s s m e n t Ye a r : 2 0 0 9 - 2 0 1 0 M / s . A c e t y le n e Tr ex i m P v t . Li m i t e d Page 11 of 11 no incriminating material found during the course of search to support and substantiate the same. We, therefore, find no infirmity in the impugned order of the ld. CIT(Appeals) deleting both the additions made by the Assessing Officer on account of disallowance of expenditure on purchase of shares and Keyman Insurance and upholding the same, we dismiss this appeal filed by the Revenue and allow the Cross Objection filed by the assessee.
8. In the result, the appeal of the Revenue is dismissed, while the Cross Objection filed by the assessee is allowed.
Order pronounced in the open Court on July 17, 2019.
Sd/- Sd/-
(A.T. Varkey) (P.M. Jagtap)
Judicial Member Vice-President (KZ)
Kolkata, the 17 t h day of July, 2019
Copies to : (1) Assistant Commissioner of Income Tax,
Central Ci rcle-3 (4), Kolkata,
Aayakar Bhawan,
110, Shanti Pally, 5 t h Floor,
Kolkata-700 107
(2) M/s. Acetylene Trexi m Pvt. Limited.
14, Netaji Subhas Ro ad, 4 t h Floor,
Kolkata-700 001
(3) Commissioner of Income Tax (Appeals)-21, Kolkata,
(4) Commissio ner of Income Tax- ,
(5) The Depart ment al Represent ative
(6) Guard File
By order
Assistant Registrar,
Income Tax Appellate Tribunal,
Kolkata Benches, Kolkata
Laha/Sr. P.S.