Income Tax Appellate Tribunal - Kolkata
Dcit, Circle - 7(1), Kolkata, Kolkata vs M/S. Ganesh Realty & Mall Development ... on 22 July, 2019
IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH : KOLKATA
[Before Hon'bleShri J. Sudhakar Reddy, AM &Shri S.S. Godara, JM]
I.T.A No. 1621/Kol/2017 A.Y 2010-11
I.T.A No. 1622/Kol/2017 A.Y 2011-12
D.C.I.T, Cir-7(1), Kolkata Vs. M/s. Ganesh Realty & Mall
Development Pvt. Ltd.
PAN: AACCG 7821N
(Appellant) (Respondent)
Shri A.K. Naik, CIT/DR
For the Appellant/Department : Shri C.J. Singh, JCIT/.DR
For the Respondent /Assessee :Mrs. Nilima Joshi, FCA/AR
Date of Hearing : 17-05-2019
Date of Pronouncement :- 22.07-2019
ORDER
Shri S.S. Godara, JM:
1. These two Revenue's appeals for assessment years 2010-11 and 2011-12 arise against the CIT(A), 15, Kolkata' separate orders, both dated 28-04-2017, passed in case nos.
238/CIT(A)-15/15-16/Cir-7/R&T/Kol and 239/CIT(A)-15/15-16/Cir-7/R&T/Kol; respectively involving proceedings u/s 143(3) of the Act.
Heard both the parties. Case files perused.
2.The Revenue's identical former substantive grounds in both the impugned assessment years challenges correctness of the CIT(A)'s action treating the assessee'sLicence Fee receipts of Rs.45,63,699/- and Rs. 2,36,36,658/-, utility charges on renting of various facilities involving sums of Rs. 1,17,76,064/- and Rs. 5,86,46,193/- as well as allowing depreciation claims of Rs.8,04,49,959/- and Rs.6,89,49,057/- (assessment year-wise); as business income than income from house property and other sources; respectively.
2ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
3. The Revenue's during the course of hearing caseis that the Assessing Officer had rightly assessed the above first head of 'Licence Fee' received as 'House Property Income' than 'Business Income' in the two assessment years in issue. It pleads on the same analogythat utilities services receipts had also been correctly assessed as income from "other sources". We deem it appropriate to extract the CIT(A)'s detailed discussion for deciding the main issue of taxpayer's licence fee receipts as business income as follows:-
"3.1 Grounds of appeal No. 1, 2 & 4The assessee is a developer and it is running a mall. It has earned income from license fee, utility charges and profit on sale of commercial properties. During the year it has earned income of Rs. 1,63,39,733/- from license fees and utility charges. This includes, of Rs. 45,63,669/- from rent and Rs. 1,17,76,064/- from utility charges. Assessee has also earned profit of Rs. 1,07,03,030/- on sale of commercial space. Assessee had declared its receipts under the head 'Income from Business'. Assessee had also claimed depreciation of Rs. 8,04,49,959/- on its buildings. However, AO has not accepted assessee's submissions. He has assessed rental income of Rs. 45,63,669/- under the head 'Income from House Property'. Utility charges of Rs. 1,17,76,064/- has been assessed under the head 'Income from Other Sources'. Depreciation of Rs. 8,04,49,959/- has been disallowed. Only the profit on sale of commercial space has been assessed under the head income from business.
Appellant has made the following submissions/objections against the action of the AO:-
(i) It is submitted that appellant is engaged in the business of letting out of units for commercial purposes after acquisition of these properties. AO has arbitrarily changed the heads of assessability of rent and utility charges.2
ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
3ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
(ii) Assessee company is engaged in the business of letting out of units for commercial purposes after acquisition of property. These activities have been mentioned in the objects in memorandum of association (AO has mentioned the main objects in the assessment order). Along with letting out of units, assessee provides services (Utilities) which are essential for maintenance and functioning of these units. Some of the main utilities provided include, HVAC system for Air conditioning, DG sets for power back up, fire fighting system, security etc. Hence, assessee feels that it is involved in business activities.
(iii) Assessee has relied on the judgment of Hon'ble Supreme Court in Chennai Properties and Investment Ltd. vs. CIT(2015) 56 Taxmann.com 456. AO had relied on the judgment of Madras High Court in the same case. However, Hon'ble Supreme Court has reversed the judgment of the Hon'ble Madras High Court. Judgment of Hon'ble Supreme Court is in favour of assessee's case.
(iv) Assessee submits that object of the company should be kept in mind while deciding the nature of receipts in its hand. Rent and utility charges are business income. In support of this proposition assessee has relied on the decision of ITAT order dated 29/04/2015 in Mangalam Fashion Ltd. Kolkata vs. CIT -7, Kolkata, wherein it has been held that receipts from utility services are intimately connected with the property itself and part and parcel of the income derived from these tenants .
(v) Appellant had made two separate agreements with the tenants. One was for lease of the commercial properties and the other was for providing utility services. Appellant has submitted that utility period mentioned in the agreement coincides with license period for which lease is given. Thus, utility services are inseparable part of license fees/rent agreement.
(vi) Appellant submits that it has used its assets for commercial purposes along with the services rendered to licensees. Hence, both the activities are in the nature of business activities. In support of this proposition, appellant has relied on the following judgments/ decisions:-
3ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.4
ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
(a)CIT vs. National Storage Pvt. Ltd, (1967) 66 ITR 596 (SC)-
Supreme Court observed that In cases where the Income received is not from the bare letting of the tenement or from the letting accompanied by incidental services or facilities, but the subject hired out is a complex one and the income obtained is not so much because of bare letting of tenement but because of the facilities and services rendered, the operations involved in such letting of the property may be of the nature of business or trading operations and income derived may be of nature' of Business or trading operation."
(b) Karni Properties Ltd. vs CIT, (1971) 82 ITR 547 (SC) Where Supreme Court held that if the services rendered by the assessee are the results of its activities carried on continuously in an organized manner, with a set purpose and with a view to earn profits, those activities would constitute business activities and the income arising therefrom would be assessable under section 10 (of the 1922 Act) i.e, as Business income under section 28 of the I.T. act, 1961)
(c) PFH Mall and Retail Management Ltd. vs. ITO, (2007) 112 TTJ (Kol) 523: Mere fact that income is attached to immovable property cannot be sole criterion for assessment of such income as income from House property. As the main intention was to exploit the immovable property by way of complex commercial activities, it was held as business income. Further, no tenancy rights were given.
(vii) Entire receipt from 2 agreements constitute a composite business and there is no scope for artificial segregation.
(viii) Assessee is entitled for depreciation on the let out buildings, as letting out activity is business in nature.
I have considered the facts of the case and submissions of the assessee. In assessment order, AO has discussed various judgments. However, after the judgment of Hon'ble Supreme Court in Chennai Properties & Investment Ltd. (Supra), Judgments discussed by the Ld. AO are not relevant to the facts of 4 ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
5ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
this case. Hon'ble Supreme Court has held that if one of the main objects of company is letting out of properties, then this activity would be considered as business activity. This judgment clearly supports the stand of the assessee. Hence, there is no need for any contrary interpretation of this issue. In assessee's case letting out of property along with sale of commercial property, is included in the main objects of the company. Hence, AO is directed to assess the receipts from letting out of property under the head 'Income from Business'. Further, appellant has mentioned that letting out of property and providing utility services are complementary to each other. Hence, both these activities are business activities. This view is also supported by the decision of Kolkata ITAT in Mangalam Fashion Ltd. (Supra). In view of the judgment of the Hon'ble Supreme Court and the decision of Kolkata ITAT, as mentioned in above, AO is directed to assess license fees and utility charges as income under the head business and profession. As letting of the buildings are held as business activity, consequentially, AO is also directed to allow depreciation of Rs. 8,04,49,959/- on these buildings. These grounds are allowed."
4. We have heard the rival contentions. The assessee's detailed paper book ( pages 1 to 101) comprising of written submissions dt. 21-03-2017 before the CIT(A) in lower appellate proceedings, sample copy of licence and utility services agreements dated 19- 09-2009, audited accounts for the two A.Y(s), computation(s) of income and processing u/s. 143(1) for the A/ys 2014-15 to 2016-17 accepting its receipts derived from licence fees and utility service in issue as business income; respectively,stands perused.
5. We now come to the basic relevant facts regarding the above former issue of assessment of assessee's licence fee income derived from renting out of unsold shops in the shopping mall in question. This taxpayer is a company engaged in property(ies) development business. It claimed the impugned rental and utilitiesincome received as business income followed by consequential depreciation raised in both the impugned assessment years. Relevant assessment order in former assessment year suggests that 5 ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
6ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
the taxpayer had purchased 92 units of commercial space comprising varying measurements from its holding company M/s. Bengal Ambuja Housing Development Ltd. " BAHDL" for Rs.86,39,45,273/-. It sold a portion thereof for Rs.82,8022,050/- to various parties. Coming to unsold stock, the assessee gave it on rent by way of license agreement to various parties for 108 months subject to a 18 months lock-in period commencing on or from expiry of 60 days from the date of possession. The assessee, its above stated holding company &its tenants (supra) acted as lincesor/ confirming party & licencee(s); respectively. It further executed various agreements with the said licensees for providing them utility services as well.
6. The Assessing Officer came across the assessee's P & L account stating business income under the above two heads of licence fee and utility service charges as well as profit on sale of building (commercial space) amounting to Rs.1,63,39,733/- and Rs.1,07,03,030/-; respectively. He issued a show cause dt. 5-1-13 proposing to assess the rental and utility services income(supra) as income from "house property" and from "other sources"; respectively than business income. The assessee pleaded to have been acting as a company engaged in letting out its commercial space/units for business purposes. And that the utility service charges income very much formed part and parcel of the said rental income only. The Assessing Officer's assessment order dated 12-03-2013 indicates that it had also placed on record the relevant memorandum of association as under:
"a) The objects of the assessee company as mentioned in the Memorandum of Association of the company are as follows:
• To acquire by purchase, lease, exchange, hire or otherwise, lands and property of any tenure or any interest in the same and to erect and construct houses, buildings .... and to sell, lease, let mortgage or otherwise dispose of the lands, houses, buildings and other property of the company or others and framing and execution of infrastructure development schemes.6
ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.7
ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
• To construct, execute, carryout, equip, improve, alter, develop, decorate, maintain, furnish, administer, take/give on rent / lease, manage or control public and private works and convenience of all kinds including Malls, market, commercial complexes, shops, offices, and flats.
• To manage land, building and other property whether belonging to the company or not, and to collect rents and income and to provide or supply to tenants, occupiers and others all or anyof the services that may be needed in a commercial, business or other organization either with or without consideration.
7. The assessee next explained that it had exploited the commercial potential of the units held/purchased in the "City Centre Mall" by letting out the same to licencee parties followed by utility charges receipts realized to ensure better amenities to the licensed commercial space. It averred that the said utility services were in the nature of provision of "high voltage air conditioning system for facilitating air-conditioning of the licenced space, provision for 100% DG set power backup and provision of firefighting system/sprinkler system and fire alarm system etc. It lastlyquoted judicial precedents in support of the contention seeking to treat its rental as well as utility service income to be assessable as business income.
8. Case files suggest that the Assessing Officer declined the assessee's entire foregoing explanation in his identical assessment order(s) in issue. He observed first of all thatassessee's rental and utility service income were very much separable since involving different sets of agreement. He was thereafter of the view that composite charges received for letting out of various services rendered could be split up as well. He held that assessee's utility charges income received separately followed by a portion thereof being passed over to its holding company (supra); could not be taken as part and parcel of rental income. He accordingly treated the said utility income Rs.11,77,064/- (supra) in former assessment year as income from "other" sources.
7ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
8ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
9. Coming to rental income of Rs.45,64,669/- in former assessment year,the Assessing Officer's view was that the license period of 108 months was subject to an 18 months'lock-in-period. It sufficiently indicated assessee's intention to earn rental income onlythan any adventure in commercial space as business. He acted accordingly to treat the impugned rental income as house property income. Suffice to say, the Assessing Officer proceeded on the same line in the latter assessment year as well. The CIT(A) has reversed the Assessing Officer's action(s) vide above extracted detailed reasoning.
10. Learned CIT/DR's first and foremost vehement contention is that the impugned CIT(A)'s orders under challenge are totally not speaking since he has neither framed any points of the determination nor has he adjudicated the issue(s) involved in the instant case regarding assessment of rental and utility service income as prescribed u/s. 250(6) of the Act. We find no merit in the Revenue's instant first argument alleging violation of the above statutory provision. The fact remains that although the CIT(A) 's findings under challenge are in a single para, he has decided the issue against the department in the light of hon'ble apex court's decision in Chennai Properties & Investment V/s. CIT reported in (2015) 56 taxmann. Com 456(SC).He has thereafter concluded that assessee's twin incomes deserve to be assessed under the head business income only. We therefore decline first identical ground raised at Revenue's behest.
11. Learned CIT/DR's next argument is that the Assessing Officer had rightly assessed the assessee's rental income as income from house property and not business income. Mr. Nayakreiterates that the taxpayer had rented its unsold stock for on long term basis which sufficiently indicates its intention of earning stable rental income not involving any adventure in the nature of trade or business.He seeks to distinguish the hon'ble apex court's above stated decision (supra)holding thatthe concerned taxpayer had duly proved its business activities of renting out of properties only. Mr. Nayak, continues his challenge to correctness of the CIT(A)'s findings under challenge 8 ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
9ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
accepting assessee's claim that assessee had acquired possession of unsold commercial space and gave the same on rent/lease to licensee on long term basis thereby creating a right in their favour. His case is that the assessee had not performed any activity on its own at all. He urged us to lift the corporate veil employed at assessee's behest. Hon'ble apex court's decisions in Mysore Minerals Ltd. vs. CIT in (1995) 239 ITR 775, CIT v. Podar Cement (P.) Ltd [1997] 226 ITR625/92 Taxman 541 (SC), Raj Dadarkar& Associates v. ACIT (2017) 394 ITR 592/ 248 Taxman 1 (SC) are quoted in support. Mr. Nayak accordingly seeks to restore the Assessing Officer's findings treating assessee's licence fee as well as utility services income under the head 'income from house property' and from 'other sources'; respectively.
12. Learned authorized representative first of all takes us through the assessee's detailed paper book (pages 1 to 101)comprising of its written submissions dt. 21-03- 2017 submitted before the learned CIT(A), sample copy of license agreement dt. 19-09- 2009, sample copy of utilities agreement dt. 19-09-2009, copies of audited accounts for both the A/ys, copies of computation(s) &intimation(s)for assessmentyears 2014-15 to 2016-17. She submits that the department has not raised any dispute qua the very issue in all these succeeding assessment years. She avers that the CIT(A) has rightly assessed the impugned receipts as business income in the lower appellate proceedings. She strongly supports the impugned lower appellate reasoning deleting the impugned addition which stands extracted in the preceding paragraphs of this order.
13. We have given our thoughtful consideration to rival contentions. There is hardly any dispute that the issue between the partiesin above assessment of taxpayer's licence fee and utility services income as to whether the same is liable to be assessed as business income or not. The assessee had admittedly purchased the commercial space in issue from its holding company and thereafter, it executed licence deed(s) with the 9 ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
10ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
various parties. It also charged for utility services by way of separate agreements. We wish to reiterate that it has already on record that this taxpayer's "Memorandum of Association" containing main clause(a) makes it clear that acquisition of land and properties by way of lease, exchange, hire or otherwise and management thereofthrough the various modes formingits main business activity.
14. We now proceed to examine the assessee's objects/activities in the light of various judicial precedents. First of all comes the hon'ble apex court's decision in Chennai Properties & Investment Ltd (supra) holding that letting out of properties was business activity of the concerned taxpayer. Their lordships have adjudicated the issue against the Revenue therefore. We find in this backdrop that the taxpayer before us has also satisfied the very test since its main activity is that of acquiring and managing land and buildings as well as to provide for various ancillary services. Their lordships next decision in Keyaram Hotels (P) Ltd V/s. DCIT (2015) 63 taxmann.com 301(SC) dealt with an assessee who was not engaged in renting business activity but derived rental income which was held as not in the nature of business income. We re-emphasize here that this taxpayer has indeed carried out its business activity of renting of commercial space as per its Memorandum of Association as is evident from the books of accounts not disputed at Revenue's instance.
15. We next notice that their lordships decision in "Rayala case" (supra) also supports the assessee since the concerned taxpayer only derived rental incomeas per the corresponding clauses in Memorandum of Association. We find no merit in Revenue'sarguments placing reliance on the hon'ble apex court's decision in Raj Dadarkar & Associates(supra) as well. The lordships make it clear that assessee's objects do not form the sole/conclusive criteria and each case is to be decided as per the facts involved in the lis. Their lordships then observe that the decisive factor in such a 10 ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
11ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
case is as to whether the assessee in issue is engaged in a systematic activity is the nature of business or not. We notice that the said taxpayer had failed to prove renting out its properties as the main systematic business activity whereas the facts before us speak otherwise. This assessee has placed on record all its evidence suggesting adventure in the nature of business in acquiring of profits followed by sale and licensee(s) deriving business income. The Revenue fails to rebut this crucial element. We therefore decline Revenue's arguments seek to revive the Assessing Officer's action that this taxpayer's licence fee and utility services income are to be treated as income from house property and from other sources; respectively. So is the outcome of the Revenue's plea is that the CIT(A) findings give double depreciation claim to assessee as well as its licensees. We find no merit in the instant arguments of the Revenue in view of our foregoing discussion based on facts analysed in light of various judicial precedents. We further wish to make it clear that the Revenue itself has accepted the assessee's treatment of the very receipts as business income in the succeeding assessment years as well (supra). We thus uphold the CIT(A)'s impugned findings under challenge. The Revenue's identical former substantive ground raised in both the appeals fails. The CIT(A) is held to have rightly treated assessee's rented and utilities service income as business income therefore.
16. Next comes Revenue's latter substantive ground/grievance seeking to revive section 36(1)(iii) interest disallowance in both assessments involving figures of Rs.37,85,520/- and Rs.35,74,320/- on account of interest free loans given to above the assessee's holding company (supra). The CIT(A) identical detailed discussed qua this latter issue reads as follow:-
"3.2 Assessee had given interest free security deposit of Rs.3,15,46,000/- to its holding company M/s. Bengal Ambuja Housing Development Ltd. Assessee had also received interest free security deposit of Rs.2,95,31,149/- from its lessees. AO has mentioned that by giving interest free deposits 11 ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.12
ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
assessee has hurt its commercial interest. It has been giving interest on loans taken but has given interest free deposits to its holding company. Hence, relying on the judgments of Kerala High Court in CIT vs. Accelerated Freeze Drying Co. Ltd. (2010) 324 ITR 316 and decision of Mumbai ITAT in Aditya Birla Pvt. Ltd. company Ltd. vs. ITO (2010) 4 ITR (T) 658, AO has computed interest @ 12% on interest free deposit given, which come to Rs. 37,85,520/- and disallowed this amounts] s. 36(iii).
Appellant has submitted that it has given interest free deposits to Bengal Ambuja Housing Developing Ltd. for business purpose. Assessee had taken loans of 74 crores (approx) to purchase various commercial units but has given only 3.15 crores as interest free deposits. At the same time, it has also received Rs.2,95,31,149/- as interest free deposits from its lessees. Bengal Ambuja Housing Development Ltd. is a joint sector company with West Bengal Housing Board (owned by Govt. of West Bengal), which made its mandatory to all the lessees to give deposits. As per the agreement, assessee had to deposit some amount in term of certain percentage of per unit saleable space of their respective units to Bengal Ambuja Housing Development Ltd. or its nominees, to cover for any delay in timely payment of maintenance bills and other charges. In case of default this deposit may be utilized to recover the arrears.
I have considered the facts of the case and submissions of the assessee. While making the disallowance, AO has mentioned that interest free deposits received by it is different from interest free deposits. Secondly, interest free deposits have not been given for any business purposes. I do not agree with the view of the AO. All receipts of the assessee go in a common fund and it is not possible to distinguish which receipt is utilized for a particular expenditure/investment. Interest free deposits given and those received are of approximately same amount. Interest free deposits have been given as per the written stipulation of the holding company and the purpose is also explained. It is apparent that interest free deposits have been given for commercial reasons to cover for any default in payments by lesses. Hence, it is definitely for business purposes. Besides difference in amounts of interest free deposits given and those received are not much. Hence, it cannot be said that assessee, in any way, compromised its commercial interest.
In view of the above, disallowance of Rs.37,85,520/- is deleted."
12ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
13ITA Nos. 1621 & 1622/Kol/17 M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.
17. Mr. Nayak's vehement contention is that the Assessing Officer had rightly proceeded to disallow the impugned interest sum in view of assessee's interest free loans given to its holding company. He fails to dispute the clinching fact that the assessee had nowhere given interest free loan to the said holding entity since it had proceeded to deposit the amount in question in terms of a fixed percentage going by commercial space units. We make it clear that the Revenue has failed to dispute or controvert the fact the impugned sum was to recover for maintenance & other charges. We therefore conclude this backdrop of facts that the CIT(A) has rightly deleted the impugned disallowance as there is no interest free loan involved in facts of the instant case. Revenue's identical arguments qua the instant latter issue are also rejected.
18. These two Revenue's appeals are dismissed.
Order pronounced in the Court on 22-07-2019
Sd/- Sd/-
[ J. Sudhkar Reddy ] [ S.S.Godara ]
Accountant Member Judicial Member
Dated : 22-07-2019
**PRADIP, Sr. PS/Dkp
Copy of the order forwarded to:
1. Appellant/Revenue: Deputy Commissioner of Income Tax, Circle-7(1), Kolkata, 5th Floor, Aaykar Bhawan, P-7 Chowringhee Sq., Kolkata-69.
2. Respondent/Assessee: M/s. Ganesh Realty & Mall Development Pvt. Ltd 216, A.J.C Bose Road, Kolkata-17.
3..C.I.T(A).- 4. C.I.T.- Kolkata.
5. CIT(DR), Kolkata Benches, Kolkata.
True copy By Order
Assistant Registrar
H.O.O/D.D.O Kolkata
13
ITA Nos. 1621 & 1622/Kol/17
M/s. Ganesh Realty & Mall Dev.Pvt. Ltd.