Income Tax Appellate Tribunal - Kolkata
India Housing, Kolkata vs Acit, Cir-54, Kolkata. , Kolkata on 15 March, 2024
आयकर अपीलीय अधिकरण
कोलकाता 'बी' पीठ, कोलकाता में
IN THE INCOME TAX APPELLATE TRIBUNAL
KOLKATA 'B' BENCH, KOLKATA
श्री राजेश कुमार, लेखा सदस्य
एवं
श्री अधिकेश बिजी, न्याधयक सदस्य
के समक्ष
Before
SRI RAJESH KUMAR, ACCOUNTANT MEMBER
&
SRI ANIKESH BANERJEE, JUDICIAL MEMBER
I.T.A. Nos.: 1218 & 1219/KOL/2023
Assessment Years: 2013-14 & 2014-15
M/s. India Housing...................................................................Appellant
[PAN: AABFI 8377 B]
Vs.
DCIT, Circle-54, Kolkata.......................................................Respondent
Appearances:
Assessee represented by: Sh. P.K. Bansal, A/R.
Department represented by: Sh. Abhijit Kundu, CIT D/R.
Date of concluding the hearing : March 6th, 2024
Date of pronouncing the order : March 15th, 2024
ORDER
Per Bench:
Both the appeals of the assessee were filed against separate orders of the Commissioner of Income-tax (Appeals)-NFAC, Delhi [in brevity ld. 'CIT(A)'] dated 27.09.2023 passed u/s 250 of the Income Tax Act, 1961 (in brevity the 'Act') for assessment years 2013-14 & 2014-15. The impugned orders were emanated from the orders of the DCIT, Circle-54, Kolkata (in brevity the 'AO') passed u/s 143(3) of the Act dated 24.03.2016 & 19.12.2016 respectively.
2. Both the appeals are filed with a delay of 669 days. The ld. A/R explained that the delay is covered by the decision of Hon'ble Supreme Court in the case of Suo Motu writ petition (c) no. 3 of 2020 date of order 10/01/2022 and part of the delay was due to change of consultant. Ld. D/R I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
had not made any objection against the request for condonation of delay. Accordingly, the delay of 669 days is condoned.
3. At the outset, both the appeals have same nature of fact and have a common issue. With the request of both the parties, ITA No. 1218/KOL/2023 for AY 2013-14 is taken as the lead case.
4. The assessee has taken the following grounds of appeal:
"1. That the Ld. CIT(A), National Faceless Appeal Centre (NFAC) has erred in law and on facts and circumstances of the case in ignoring/ not considering and not deciding the additional ground of appeal filed by the appellant in light of the ratio diescendi laid down by the Hon'ble Supreme Court in the case of "M/s Chennai Properties and Investments Ltd." 373 ITR 673(SC)"
2. That the Ld. CIT(A), NFAC has erred in law and on facts and circumstances of the case in confirming the disallowance of Rs. 19202515/- out of "Repair and Maintenance expenses" relatable to common area maintenance in spite of the fact that the receipts in respect thereof stood offered for assessment and have been subjected to tax.
3. That the Ld. CIT(A), NFAC has erred in law and on facts and circumstances of the case in confirming the disallowance of Rs. 7,50,00,000/- on account of Supervision charges paid by the appellant firm during the year which were incidental to the carrying on the business of appellant firm and were incurred in the course thereof and due deduction of tax at source was also made in respect thereto.
4. (a) That the Ld. CIT(A), NFAC is not justified in confirming the disallowance of Rs. 34057046/- out of interest paid by the appellant firm.
(b) That the Ld. CIT(A), NFAC is not justified in confirming the addition of Rs. 34057046/- by way of imputing interest on partners' capital/current account having a debit balance as the overall balance capital/current of the partners was not negative and there was no stipulation in the partnership deed for charging/paying of interest income on the capital/current account balance of partners.
5. That the order passed by the Ld. CIT(Appeals), NFAC in respect of grounds of appeal no. 3 & 4 is against the principles of judicial discipline as the issues stood decided by order of Hon'ble Tribunal/ Hon'ble High Court which is higher in a hierarchy and was binding on the CIT(Appeals).
6. a. That the Ld. CIT(A), NFAC has not justified in confirming the addition of Rs. 56,83,756/- made by the Assessing Officer u/s 40a(ia) of the Act on Page 2 of 12 I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
the facts and circumstances of the case as well as submissions filed by the appellant in the statement of facts.
b. That the Ld. CIT(A), NFAC has erred in law and on facts and circumstances of the case in holding that the appellant has not made any submission in respect of this ground. Although, in the Statement of Facts complete details item-wise in respect of disallowance was given by the appellant and therefore there is no justification of CIT(A) in confirming the addition u/s 40a(ia) of the Act.
7. That the Ld. CIT(A), NFAC has not considered the detailed submissions filed by the appellant before the Assessing Officer as well as during the course of appellate proceedings and there is no whisper in the appellate order regarding the same which renders the order passed by the CIT(Appeals), NFAC contrary to the principles of jurisprudence and natural justice.
8. That the Appellant craves leave to add, alter, amend and withdraw any `of grounds of appeal before or during the course of appellate proceedings."
5. The brief fact of the case is that the assessee is a partnership firm having three partners viz M/s. Sahara India Commercial Corporation Ltd., M/s. Carlton Hotel Pvt. Ltd. and Shri I. Ahmed. The profit-sharing ratio is 90:5:5. The object of the firm was build a mall in the name and style of 'Sahara Ganj Mall' located at Shah Najaf Road, Lucknow, Uttar Pradesh. The mall was constructed during previous year relevant to AY 2006-07. The sale of property in the mall started taking place with effect from FY 2005-06 and the sale continued up to FY 2007-08. In all these years the stock in the form of built- up area in the mall was being disclosed by the firm under head 'work-in- progress/stock-in-trade'. However, in FY 2008-09 relevant to AY 2009-10 the assessee decided to convert the unsold shop from 'stock-in-trade' to fixed assets as investment and the shops/kiosks of the mall were let out. The ld. AO had made a show cause related to impugned assessment year and asked for a detailed calculation related to assessee's computation of income. The assessee declared the part of revenue in the head of 'house property' and part in the 'business income'. In explanation, the assessee placed that the unsold stock of the shops which are converted from 'stock-in-trade' to investment for AY 2009-10 due to the financial set back was duly treated as house property income. The rest of the shops which are sold was only related to business income for collecting the maintenance charge, repairing charge and other Page 3 of 12 I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
charge. During the assessment proceedings the ld. AO added back in the head of supervision charge, amounting of Rs. 7.50 Crore, repair and maintenance, amounting of Rs. 1,92,02,515/- and disallowed the interest by way of interest of partners' capital which was added back with the total income of the assessee. Further, a disallowance u/s 40(a)(ia) of the Act amounting to Rs. 58,63,756/- was added back for contravening of Section 40(a)(ia) of the Act. Aggrieved assessee filed an appeal before ld. CIT(A). The ld. CIT(A) upheld the assessment order and allowed the appeal by a partial relief. Being aggrieved the assessee filed an appeal before us.
6. The ld. A/R further proceed and placed that the additional ground is also submitted before the Bench which is reproduced as below:
"In this ground of appeal the appellant has withdrawn its claim which was accepted by the Department for subjecting to tax the Income from letting out Property as 'Property Income and has offered to tax the same as 'Business Income' in light of the judgment of the Hon'ble Supreme Court in the case of Chennai Properties and Investments Ltd.' reported in 373 ITR 673 (SC)."
7. The ld. A/R argued and filed a written submission which are kept in the record. The ld. A/R has started his argument ground-wise. Accordingly, ground nos. 2, 3, 4 & 5 are taken together for hearing.
8. The ld. A/R first argued the addition of repair and maintenance expenses related to ground no. 2. The relevant part of the submission is reproduced as below:
"Ground No.2-Disallowancc out of Repair and Maintenance Expenses. (for both years) Submission is prepared taking A.Y. 2013-14 as lead year
a) That the assessee firm constructed "Sahara Ganj Mall" at Lucknow, Uttar Pradesh during F.Y 2005-06, i.e., A.Y. 2006-07 and started selling commercial space in said Mall. Sales of commercial space continued till F.Y. 2007-08. However, due to acute recession in real estate market, the assessee could not sell the commercial space in entirety. As a matter of business prudence, the commercial spaces in Mall were leased out to several tenants and due to continued inability to sell; the assessee firm during F.Y. 2008-09, i.e., A.Y. 2009-10 recategorized the inventory of shops from 'Stock-in-trade' to fixed assets as investment.Page 4 of 12
I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
b) The assessee derived rental income of Rs.32,50,02,678/- (for A.Y.2014- 15 Rs.32,42,22,813/-) from leasing out the commercial space in mall and declared the said income as income from House Property and claimed statutory deduction of Rs.9,28,37,138/- (for A.Y.2014-1 5 Rs.9,26,03,1 79/- ) u/s 24(a) of the Act being 30% of the lease rentals.
Apart from lease rentals the assessee Firm derived income in the nature of Common Area Maintenance charges to the tune of Rs.9,93,93,007/- (for A.Y.2014-15 Rs.9,71,58,778/-), Vehicle Parking of Rs. 1,49,95,081/- (for A.Y.2014-15 Rs. 1,28,20,145/-) and Signage Space charges of Rs. 91,31,734/- (for A.Y.2014-15 Rs.66,03,188/-).
c) The assessee incurred several Mall Management Expenses comprising of Repair and Maintenance expenses of Rs. 1,92,02,515/- (for A.Y.2014-15 Rs.2,08,47,060/-). The Ed. AO on perusal of facts of the case opined that repair and maintenance expenses incurred by the assessee arc not allowable as the assessee has availed statutory deduction of 30% of rental income u/s 24(a) of the Act and proposed disallowance of said expenses.
d) The assessee firm during the course of assessment proceedings submitted that it was engaged in 2 activities (a) Letting out the property on hire and (b) Maintenance of property and claimed that the maintenance charges incurred by the assessee are related to common area maintenance and vehicle parking space maintenance.
Further, the law nowhere lays down the presumption that the deduction u/s 24(a) oi the Act relates to repair and maintenance etc. It is merely a statutory deduction allowed while computing taxable income under the head "Income from House Property".
e) The assessee during appellate proceedings reiterated the submissions that the repair and maintenance expenses pertained to common area maintenance and vehicle parking space maintenance and it was also submitted that in case the additional ground of appeal of the assessee is allowed, the very basis of alleging disallowance of repair and maintenance expenses will be demolished. It was also categorically stated that all the expenses are properly vouched and verifiable.
f) The Ld. CIT(A) in Para 4.2 of the appellate order held that the assessee was unable to bring evidence on record to counter findings of AO and also held that the assessee has claimed both repair and maintenance expenses as well as deduction u/s 24 of the Act and in the absence of evidences the claim of assessee cannot be allowed.
g) In this regard it is pertinent to mention here that the assessee has derived revenue from Common Area Maintenance, Vehicle Parking Space maintenance and Signage Spaces. The repair and maintenance expenses arc incurred in these areas only.
Page 5 of 12I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
In commercial leased properties, the maintenance agencies incur maintenance expenses only w.r.t. to common area, parking spaces and signage spaces. The areas inside the sold or leased shops arc maintained by shop owners or tenants themselves. A builder or maintenance agency never incurs maintenance expenses w.r.t. to areas inside the shops. Such maintenance is to be borne by occupants themselves whether they are shop owners or tenants. A landlord or maintenance agency will never change even a faulty light inside the shop sold or given on rent.
Thus, it is evident that the repair and maintenance expenses incurred by the assessee relates only to common area maintenance vehicle parking space and signage spaces and in no way related to maintenance of shops sold or given on lease.
Since the repair and maintenance expenses incurred by the assessee are no way related to rental income accrued to it, the same cannot be disallowed on the pretext that the assessee has availed statutory deduction u/s 24(a) of the Act."
9. For ground no. 3 the ld. A/R argued that the disallowance of supervision charge of Rs. 7.50 Crore for AY 2013-14 & AY 2014-15 was duly covered by the decision of ITAT, Kolkata Bench in aasessee's own case, ITA No. 125/KOL/2015 for AY 2011-12 dated 11.12.2019. The relevant paragraph 15 is duly inserted as below:
"15. We note that the supervision charges have been paid by assessee as per an agreement. The assessee has deducted tax at source while making payment. The payment was made through banking channel. The ld. Assessing Officer was aware about the assessee`s agreement. The assessee has paid service tax on the mall management expenses and, therefore, there arises no occasion of doubting genuineness of the expenses. The ld. Assessing Officer has not demonstrated as to how the expenditure incurred by the assessee for giving overall mall management supervision work to M/s. Sahara Prime City Ltd. was in excess of the fair market value of service or facility or was not as per legitimate needs of the business of the assessee. The maintenance of huge mall having area of 2,50,000 sq. ft., the assessee has to incur management supervision charges. Moreover, AO has not rejected books of accounts of the assessee and assessment is framed by AO under section 143(3) of the Act. Based on the factual position narrated above, we are of the view that there is no infirmity in the order of ld. CIT(A). We note that for eligibility of an allowance u/s 37(1) of the Act, there should be a nexus between the expenditure and the purpose of the business and the expenditure should have been wholly and exclusively laid out for that purpose. Once these facts are established, the revenue cannot justifiably claim to put itself in the arm chair of business man or in a position of the Board of Directors and assumed the role of ascertaining how much is Page 6 of 12 I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
reasonable expenditure having regard to the circumstances of the case. We note that the assessee has incurred management supervision charges for the purpose of business and if the expenditure is incurred Cross Objection No.16/Kol/2015 & M/s India Housing bona fide in relation to business activity then it would be an allowable expenditure. That being so, we decline to interfere in the order passed by ld. CIT(A), his order on this issue is hereby accepted and grounds of appeal raised by the Revenue is dismissed."
10. The ld. A/R in argument in ground no. 4 placed that the assessee is allowed the interest on capital amounting to Rs. 3,40,57,046/-. During this impugned assessment year both the partners are continuing capital and current account. The capital account has a credit balance but whereas the current account has a debit balance. Accordingly, the ld. AO has rejected the calculation of intertest of the partners and rejected the deduction. The ld. A/R placed that the issue is squarely covered by the order of ITAT, Kolkata Bench in assessee's own case in ITA No. 125/KOL/2015 for AY 2011-12 dated 11.12.2019. The relevant paragraph is duly inserted as below:
"We note that it is a well settled legal position that factual matters which permeate through more than one assessment year, if the Revenue has accepted a particular's view or proposition in the past, it is not open for the Revenue to take an entirely contrary or different stand in a later year on the same issue, involving identical facts unless and until a cogent case is made out by the Assessing Officer on the basis of change in facts. For that we rely on the order of the Hon'ble Supreme Court in Radhasoami Satsang vs. CIT 193 ITR 321 (SC), wherein it was held as follows:
"We are aware of the fact that, strictly speaking, res judicata does not apply to income tax proceedings. Again, each assessment year being a unit, what is decided in one year may not apply in the following year but where a fundamental aspect permeating through the different assessment years has been found as a fact one way or the other and parties have allowed that position to be sustained by not challenging the order, it would not be at all appropriate to allow the position to be changed in a subsequent year. On these reasoning, in the absence of any material change justifying the Revenue to take a different view of the matter - and, if there was no change, it was in support of the assessee - we do not think the question should have been reopened and contrary to what had been decided by the Commissioner of Income-tax in the earlier proceedings, a different and contradictory stand should have been taken."
We are of the view that the above cited precedents on principle of consistency are squarely applicable to the assessee under consideration."
Page 7 of 12I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
11. The ld. A/R further argued about the ground no. 6 related to disallowance amount of Rs. 56,83,756/- u/s 40(a)(ia) of the Act for AY 2013-
14. In this order the ld. A/R has submitted a written summary which is reproduced as below:
"Ground No. 6 - Disallowance of Rs. 56,83,756/- u/s 40(a)(ia) (for A.Y. 2013-
14) That in Para 5 of the assessment order the Ld. AO has made disallowance of Rs. 56,83,756/- u/s 40(a)(ia) of the Act. The said amount comprised of the following:
a) Rs. 2,94,053/- paid to M s Delhi ACB Service Centre
b) Rs. 42,59,998/- paid to Federal Security Pvt. Ltd.
c) Rs. 4,82,531/- paid to M/s Otis Elevator Co. (I) Ltd.
d) Rs. 6,47,174/- paid to Runway International Express.
As regards items mentioned at S. No. a) and c) i.e. Rs. 2,94,053/- to Delhi ACB Service Centre and Rs. 4,82,531/- paid to M/s Otis Elevator Co. (I) Ltd. pertained to purchase of parts from these suppliers. Both the suppliers are also doing maintenance work and due tax is deducted on said maintenance work. There is no requirement for deduction of tax on purchase of parts. Thus, the stated disallowance may please be deleted.
That Rs. 42,59,998/- paid to Federal Security Pvt. Ltd. pertained to services rendered by said party during F.Y. 2011-12. Said party didn't raised invoices during F.Y. 2011-12 and thus, the assessee made provision in its books of account and deducted TDS on the same and deposited it. Thus, there was no liability for further deduction of TDS during F.Y. 2012-13, i.e., the year under consideration.
As regard disallowances u/s 40a(i)(a) of Rs. 6,47,174/- (correct figure Rs. 6,74,194/-) on account of payment to Runway International Express, the Ld. Assessing Officer has inadvertently taken figure as per 26Q i.e. payment on which TDS is deducted at Rs. 80,38,234/- whereas the correct figure as per 26Q is Rs. 86,85,428/-. (relevant portion of 26Q is enclosed in PBF 134 for A.Y.2013-14). The balance of Rs. 6,47,194/- (correct figure Rs.6,74,194/-) is appearing because of incorrect figure taken by Ld. Assessing Officer. If correct figure is taken there will be no difference."
12. The ld. A/R prayed for remand back the matter to the file of the ld. AO for further verification.
Page 8 of 12I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
13. The ld. D/R vehemently argued and relied on the order of the Revenue authorities. The relevant paragraph of the appeal order is duly inserted as below:
"4.3 Ground No. 3 to the appellant is pertaining to disallowance of Rs.7.5 Crore under supervision charges. The Ld.AO in his order has made elaborate discussion on the issue which is given in para 3 of his order. The relevant part i.e. para 3.11 is reproduced as under:-
"3.11 It, therefore, appears that the so called Supervision by SPCL is confined to very little responsibility as stated in the agreement itself. It also appears that for efficient and proper utilization for a sum of Rs. 9,72,23,353/- the firm has further incurred Rs.7,50,00,000/-towards Supervision charges which amounts to 77.14% of the said mall management expenses. In other words, for Rs. 100/- spent towards Mall Management Expenses the assessee firm has paid another Rs.77/- extra so that the benefits of spending Rs. 100/- are made assured. Not only that, when mall management charges got lowered as compared to earlier year, surprisingly, the supervision charges got higher. On perusal of the list of vendors engaged in the maintenance works of the mall it is seen that most of the vendors are reputed companies and regarded as giants in their respective fields such as M/s. Otis Elevators, M/s. Pest Control India, M/s. Voltas Ltd., Ricoh India, M/s. Eureka Forbes etc who need little supervision of their own work. Whatever supervision Was required, it was provided by M/s. JLL Mand M/s. Runway International who had to take all responsibility if anything goes wrong. On the other hand, M/s SPCL, in spite of getting huge sum of Rs.7,50,00,000/-did not have to take any responsibility, as discussed earlier. Moreover, it can easily be said that M/s. SPCL must have, in turn, claimed expenses against such income in its account seven though service tax has been paid by the assessee firm on such supervision charge. The net result is the taxability on the income got reduced by siphoning of the amount in such a manner. The logic behind such claim cannot be appreciated by any such stretch of logical human imagination. The A/R of the assessee was asked to furnish the accounts of M/s. SPCL for the last two previous years. From the accounts of the company it is noticed that M/s. SPCL actually made huge operational business loss. Hence, the assessee could afford to transfer the supervision charge to compensate such loss thereby resulting in avoidance of tax liability. The sum claimed towards supervision charges are excessive, unreasonable without any legitimate need and has been made for a covert benefit of another member of Sahara India Parivar.
The appellant in his submitted has given general comments on the addition made by the AO. Whereas the Ld.AO as duly approved that the practice of paying supervision charges is not consistence from year to year. No such payment was made in the F.Y.2008-09 and 2010-11, however, the payment was made shown in F.Y.2009-10, 2011-12 & 2012-13. From the same it Page 9 of 12 I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
appears that such expenses were not necessary to run the business. Hence, the addition made by the AO is confirmed."
14. We heard the rival submission and considered the documents available in the record. From very beginning if we dissect the revenue income of the assessee we find that the assessee has an income from house property and from business. The assessee is availing the deduction u/s 24(a) of the Act at the rate of 30% on the house property income. Further all these properties were assessee's own property which the assessee was unable to sell in the market. In case of business income, the assessee is earning the maintenance, parking charge and other incidental charges from the parties and declared this amount as business income. So, the expenses which are related to this income is eligible for deduction. The Revenue has pointed out a pertinent question here that the entire expenses of supervision charge, repair & maintenance charge and other charge will not be eligible for house property income as the assessee already availed the deduction at the rate of 30% u/s 24(a) of the Act. Further, related to supervision charge the assessee was unable to submit the required documents before the AO during the time of assessment.
15. During the hearing before the ITAT, the ld. A/R pointed out the order of the Coordinate Bench in assessee's own case related to allowable expenses for supervision charge and repair charge and partners' interest. During hearing the assessee prayed for acceptance of additional ground and treating the entire income as the business income by covering the order of Hon'ble Supreme Court in the case of Chennai Properties & Investments Ltd. vs. CIT reported in [2015] 373 ITR 673 (SC). With the consent of the ld. D/R we accepted the assessee's prayer, so the additional ground of the assessee is accepted. Respectfully following the order of Hon'ble Apex Court, the entire revenue income is converted to business income. The issue was agitated first time before the Bench not even the appellate and assessing authorities. The calculation in relation to the change of nature of income from house property to business income is duly under consideration of the ld. assessing authority.
Page 10 of 12I.T.A. Nos.: 1218 & 1219/KOL/2023 Assessment Years: 2013-14 & 2014-15 M/s. India Housing.
16. the related ground no. 4(a) & 4(b) the issue is squarely covered by the order of the ITAT, Kolkata Bench in assessee's own case in ITA No. 125/KOL/2023 for AY 2011-12 dated 11.12.2019. In our considered view, we consider the order of the Coordinate Bench. The partners have both capital and current account and considering this the capital account has a credit balance. So, the expenses related to partners' interest on capital is duly accepted and ground no. 4 is allowed.
17. In relation to ground no. 6 the issue is question of verification and the ld. A/R himself prayed for further verification by the ld. AO. So, ground no. 6 is remit back to the file of ld. AO for further verification de novo related to this addition u/s 40(a)(ia) of the Act amounting to Rs. 56,83,756/-. In our considered view the matter is remit back to the file of the ld. AO after considering the additional ground of the assessee which is duly accepted by the Bench and ld. D/R had not made any objection related to acceptance of the additional ground.
18. Considering the above ground nos. 1, 2, 3 & 6 are allowed for statistical purposes, ground no. 4 is allowed and Ground nos. 5, 7 & 8 are general in nature which needs no adjudication.
19. As we adjudicated the ITA No. 1218/KOL/2023. Both the appeal have similar facts. So, the ITA No. 1218/KOL/2023 mutatis mutandis applied to ITA No. 1219/KOL/2023 and pass the order accordingly.
20. In the result, ITA Nos. 1218 & 1219/KOL/2023 are partly allowed for statistical purposes.
Order pronounced in the open Court on 15th March, 2024.
Sd/- Sd/-
[Rajesh Kumar] [Anikesh Banerjee]
Accountant Member Judicial Member
Dated: 15.03.2024
Bidhan (P.S.)
Page 11 of 12
I.T.A. Nos.: 1218 & 1219/KOL/2023
Assessment Years: 2013-14 & 2014-15
M/s. India Housing.
Copy of the order forwarded to:
1. M/s. India Housing, 2A, Sahara India Sadan, Shakespeare Sarani, Kolkata-700 071.
2. DCIT, Circle-54, Kolkata.
3. CIT(A)-NFAC, Delhi.
4. CIT-
5. CIT(DR), Kolkata Benches, Kolkata.
//True copy // By order Assistant Registrar ITAT, Kolkata Benches Kolkata Page 12 of 12