Income Tax Appellate Tribunal - Kolkata
Chandra Bhan Agarwal, Kolkata vs Assessee on 2 February, 2012
आयकर अपीलीय अधीकरण, Ûयायपीठ - "A", कोलकाता,
IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH- A, KOLKATA
[सम¢ ौी महाबीर िसंह, Ûयायीक सदःय एवं ौी सी.
सी डȣ.
डȣ राव,
राव लेखा सदःय]
Before Shri Mahavir Singh, Judicial Member & Sri C.D. Rao, Accountant Member
आयकर
आयकर अपील संÉया / ITA Nos. 1778/Kol/2009
िनधॉरण वषॅ/Assessment Year 2006-07
Chandra Bhan Agarwal -वनाम- Addl.Commissioner of Income-tax
Kolkata, (PAN-ACUPA5677R) Versus Range-31, Kolkata.
(अपीलाथȸ/APPELLANT) (ू×यथȸ/RESPONDENT)
अपीलाथȸ कȧ ओर से/ For the Appellant: ौी/Sri S.M. Surana
ू×यथȸ कȧ ओर से/For the Respondent: ौी/Sri S.K. Roy, Sr. D.R. &
Sri S.B. Dey, Valuation Officer
सुनवाई कȧ तारȣख/Date of Hearing : 02/02/2012
घोषणा कȧ तारȣख/Date of Pronouncement : 14/03/2012
आदे श/ORDER
ौी महाबीर िसंह,) Ûयायीक सदःय (Mahavir Singh), Judicial Member :
(ौी This appeal by assessee is arising out of the order of CIT(A)-XIX, Kolkata in Appeal No 352/CIT(A)-XIX/Addl.CIT-Range-31/Kol/08-09 dated 2/7/09. Assessment was framed by Add C.I.T., Range-31, Kolkata u/s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') for assessment years 2006-07 vide order dated 30/12/2008.
2. At the out set, it is to be narrated that Hon'ble Calcutta High Court in ITAT No.199 of 2010 (GA No.2879 of 2010) in assessee's case has formulated following substantial question of law:-
"Whether the Learned Tribunal is justified in accepting the valuation made by the assessing officer as confirmed by the Commissioner of Income Tax (Appeal) without considering the materials produced by the assessee ?"
The Hon'ble High Court has set aside this appeal to Tribunal to decide afresh after considering the material placed before it earlier, by holding as under:-
1"This matter is taken up after admitting for final hearing itself. It appears from the impugned judgment and order of the Learned Tribunal that though the assessee argued with the materials, that the valuation arrived at by the assessing officer was not proper and justified, Learned Tribunal, it appears to us has not considered this aspect of the matter. Wherefore, are of the view that this matter needs to be reconsidered.
Accordingly, the operation of judgment and order is kept in abeyance and the same is remanded for fresh hearing by the Learned Tribunal, who will hear afresh considering the materials placed before it earlier, and will take a fresh decision. If it is found that the present judgment is required to be changed or varied the same may be done with an open mind and without being influenced and/or swayed by the earlier observation.
After considering all the aspects if it is found that this judgment does not require any change, in that event stay granted by this Court will stand automatically vacated."
3. Brief facts relating to this case are that the assessee filed his return of income for the relevant assessment year 2006-07 on 31/8/2006 and assessment was framed after issuing notice u/s 143(2) of the Act and completed vide order dated 30/12/2008 u/s143(3) of the Act. The Assessee during the year under consideration sold one property with land and building situated at Holding No.1472 (Part) Basudevpur, HPL Link Road, P.S. Durga chak, Haldia to Smt. Yogini B. Chotai for a total sale consideration of Rs.65,00,101/- and paid stamp duty of Rs.71,591/- and stamp charges at Rs.5,20,100/-. The AO during the course of assessment proceedings issued letter to Registrar, Sutahata, Dist. Midnapur (East), West Bengal vide letter No.388 dated 28/8/2008 to ascertain the valuation of property as per stamp valuation rates fixed by the State Government. Registrar, Sutahata replied vide letter No. 92 dated 04/9/2008 that the relevant sale deed No. P-5722/05 was not registered with the Registrar, Sutahata ADSR Office. The AO made reference to Registrar of Assurance, 5, Govt. Place (North), Kolkata, who vide letter dated 26/9/2008 informed that this property was assessed at Rs.1,24,14,400/- only. In view of these facts, the AO required the assessee to explain as to why long-term capital gain (LTCG) should not be computed by adopting deemed full value of consideration at Rs.1,24,14,400/- u/s 50C of the Act. The assessee objected to the valuation made by Registrar of Assurance. Hence AO referred the matter to Valuation Officer of Income-tax Department u/s 50C(2)(b) of the Act. The Valuation Officer valued the property at Rs.1,24,13,670/- and valuation report received vide letter dated 29/12/2008. The AO 2 assessed the deemed full value of consideration at Rs.1,24,13,670/- and computed LTCG accordingly. Aggrieved, assessee preferred appeal before CIT(A), who confirmed the action of the A.O. by giving following finding in paras 6 to 8 of his appellate order:-
"(6) I have considered the submission of the appellant and also gone through the assessment made by the A.O. The section 50C of the I.T, Act, which was introduced, by the Finance Act, 2002 w.e.f. 01.04.2003, contains for a special provision for valuation of consideration in certain cases. Section 50C(1) provides that where consideration received or accruing as a result of transfer by an assessee of a capital asset, consisting of land or building or both, is less than the value adopted or assessed by any authority of a State Government (referred to as Stamp Valuation Authority) for the purpose of payment of stamp duty for such transfer, the value so adopted or assessed shall, for the purpose of section 48, be deemed to be the full value of consideration received or accruing as a result of such transfer. In other words, when the stated sale consideration of a land or house property is less than stamp duty valuation for the said property, it is the stamp duty valuation which shall prevail for the purposes of computation of capital gain u/s. 48 of the Act.
(7) The provision is, however, subject to an important exception scheme of which is set out in sub-section (2) & (3) of Section 50C. Section 50C(2) provides that where assessee claims before the A.O. that the value adopted by the Stamp Valuation Authority, u/s. 50C(l), exceeds fair market value of the property as on the date of transfer, and unless such valuation is subject matter of litigation before any. Authority or Court, the A.O. may refer the matter for determination of fair market value of the property in question to the D.V.O. and the same shall be taken into account for computation of capital gain. Section 50C(3), however, provides that when fair market valuation so determined by the D.V.O. is higher than the valuation or assessment as per the Stamp Valuation Authority, the computation of capital gain is to be done with reference to the valuation or assessment as per the stamp Valuation Authority. In other words, valuation of property by D.V.O. cannot act to detriment to the assessee; the assessee cannot be put to any disadvantage in case the matter is referred to the D.V.O. The scheme of Section 50C can be summarized as follows. The normal rules thus is that where Stamp duty Valuation is higher than the stated consideration on transfer, the same is to be adopted for the purposes of computing the capital gain. The exemption is that in case the assesee can demonstrate that the fair market valuation is less than the stamp Duty Valuation, the fair market value is to be adopted. In the case of appellant, the Stamp Valuation Authority has adopted the value for the purposes of stamp duty at Rs.1,24,14,400/-. On the other hand, on a reference made by the A.O. to the D.V.O., the fair market value of the property was determined by him at Rs.l,24,13,670/-. In view of provisions of Section 50C(2), the A.O. has adopted the value of the property at Rs.1,24,13,670/- for the purposes of computation of capital gain u/s. 48 of the I.T. Act as against the value of Rs.
1,24,14,400/- adopted by the Stamp Valuation Authority.
3(8) Under the circumstances, I am of the opinion that the A.O. has acted as per the provisions of Section 50C of the I.T. Act and accordingly he was justified in adopting the sale consideration of the property at Rs,1,24,13,670/- as against the sale consideration shown by the appellant at Rs.65,00,101/-. The action of the A.O. is upheld in this regard. The ground no. 1 is dismissed."
Aggrieved, assessee preferred appeal before Tribunal and Tribunal vide order dated 07/5/2010 dismissed the appeal of the assessee and upheld the orders of lower authorities, against which assessee preferred appeal before the Hon'ble Calcutta High Court u/s. 260A of the Act and Hon'ble High Court has set aside the matter to the file of Tribunal to reconsider in the light of the direction reproduced as above.
4. This appeal was fixed for hearing before us, in view of the direction of Hon'ble Calcutta High Court, first time on 11/01/2012 and on that date, the matter was partly heard. On 20/1/2012, the matter was further taken up for hearing and during the course of hearing, learned counsel for the assessee, Sri S.M. Surana, first of all desired to produce the copy of valuation report made by the Office of ADSR, Sutahata, dated 08/9/2008, which reads as under :-
GOVERNMENT OF WEST BENGAL Office of the A.D.S.R. SUTAHATA Market Value/Chargeability Assessment Slip Query No./Year 007552 / 2008 Date 08/09/2008 Applicant Name Lakshmi Kanta Maity Applicant Status Others Type of Deed [0101] Sale Document Market Value Rs. 76,18,872/-
Stampduty Payable Rs. 5,33,321/- Stamp Duty: Schedule 1A, Article-23 Registration Fee payable Rs. 83,798/-
Sch Plot No. Proposed Area Set Forth Market Depreciation/
No. Land use Value(Rs.) Value(Rs.) Appreciation
Dist. Purba Medinapaore, P.S.-Durgachak, Mini.-HALDIA, Mouza- Basudevpur
1 1472 Bastu 17 Dec. 5,00,000/- 19,73,624/- AR OPT.
Sch Str. Floor Use Type Area Floor Age Roof Set Forth Market Depr/
No. No. No. Sq.Ft. Type (Yrs) Type Aprc.
1 1 Gr Residential 3250 Cemented 12 Pucca 45,50,000 56,45,248 CA-0
Sq.ft.
1 1 1 Residential 3250 Cemented 12 Pucca
1 1 2 Residential 3250 Cemented 12 Pucca
4
1 1 3 Residential 3250 Cemented 12 Pucca
GOVERNMENT OF WEST BENGAL
Office of the A.D.S.R. SUTAHATA
Market Value/Chargeability Assessment Slip
Query No./Year 007552 / 2008 Date 08/09/2008
N.B 1. AR-Approach Road, BD-Bargadar, Dec-Decimal, Kth-Katha, Fl No-Floor No, Dist-District, P.S-Police Station , Crop-Crop. Depr/Appr-Depreciation/Appreciation, Str-Structure, Apt-Apartment, Sch-Schedule, Muni-Munacipality, CA-Car Parking Area
2. S.D.& Regn. Fees are calculated on the basis of information and transaction Description/code provided in the Requisition Form. If those information are found to be given isncorrect, the assessment made stands invalid.
3. Assessed market value is valid for one month.
4. Standard User charges of Rs.175/- (rupees one hundred seventy five) only inclusive of all taxes per transaction upto 15 (fifteen) pages and Rs.6/- (Rupees six) only for each additional page will be applicable.
Sd/-
Registering Office A.D.S.R. SUTAHATA"
Further, learned counsel for the assessee took us to Valuation Officer's report vide No F.No.1911/DVO/ITD/KOL/07-08-09/654 dated 29/12/2008, whereby the value was determined at Rs.1,24,13,670/- in respect to this property sold by assessee. The relevant abstract of the report reads as under:-
"Abstract of Cost Determination of fair market value of property at 1472 Basudevpur, HPL Link Road, Haldia.
The building is G+3 RCC framed structure. The property is located on main HPL Link Road and has huge commercial potential value.
The property under consideration is commercial good and considering the factors such as commercial area, frontage of building, location transportation facilities and other amenities being very good.
The rate of building under consideration as Rs.10751 per sqm (plinth area) Plinth area 1154.76 sqm. @ Rs.10750/- sqm. = Rs.1,24,13,670/-.
Plinth area - GF = 310.59 sqm.
1st to 3rd floor 3 x 323.83` = 971.49 sqm.
1282.08 sqm
Less already sold (-) 127.32 sqm
1154.76 sqm.
Valuation for property at 1472, Basudevpur HPL Link Road, Haldia The property is located on mail HPL Link Road PS Durgachak. Considering the factors such as good commercial area, frontage of building, location, transport facilities and other amenities being very good the rate adopted is Rs.10750 per sqm.
Sd/-5
Valuation Officer-VI Income Tax Department 54/1, Rafi Ahmed Kidwai Road, KOLKATA-700016."
5. We find that by Finance Act, 2002, a new section 50C has been inserted in the Act to make a special provision for determining deemed full value of consideration in case of transfer of immovable property. Sub-sec. (1) of sec. 50C of the Act provides that where the sale consideration declared to be received or accruing as a result of transfer of capital asset being land or building or both is less than the value adopted or assessed or assessable by any authority of Sate Govt. for the purpose of payment of stamp duty in respect of such transfer, the value so adopted or assessed shall be the deemed full value of consideration and capital gain shall be computed accordingly u/s. 48 of the Act. Further, sub-sec (2) of sec 50C of the Act provides that where the assessee claims that the value so adopted or assessed for stamp duty purposes exceeds the fair market value so adopted or assessed has not been disputed in any appeal or revision or reference before any authority or court, on the objection of the assessee, the AO may refer the matter to DVO to determine the fair market value in accordance with sub-sec (2) of this section. If the fair market value determined by the DVO is less than the value adopted for stamp duty purposes, the AO has to take such fair market value to be the full value of consideration for the purpose of computation of capital gains u/s 48 of the Act. However, if the fair market value, so determined by the DVO, is more than the value adopted or assessed for stamp duty purposes, the AO shall not adopt such fair market value and shall take the full value of consideration to be the value adopted or assessed for stamp duty purposes. In view of the provisions of sub-sec. (2) of sec. 50C of the Act, the AO may refer the capital asset, i.e. the land and building or both, for valuation to DVO and where any such reference is made, following provisions will apply:-
- sub-sections (2), (3), (4), (5) and (6) of section 16A,
- clause (i) of sub-section (1) and sub-sections (6) and (7) of section 23A,
- sub-section (5) of section 24,
- section 34AA,
- section 35 and
- section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, apply-
- in relation to such reference as they apply in relation to a reference made by the Assessing Officer under section 16A(1) of that Act 27 of 1957.6
6. In the present case before us, the property with land and building was sold for total consideration of Rs.65,00,101/- and stamp duty at Rs.5,20,100/- and Rs.71,591/- were paid. This property was sold as on 29/07/2005 and sale deed was executed on this very date 29/07/2005. The AO proposed to take full value of consideration at Rs.1,24,14,400/- in view of property assessed by A.D.S.R., Sutahata being deemed sale consideration of the property and accordingly computed LTCG on the same. The assessee objected and on that basis, and on objection of assessee AO referred the matter to DVO, who vide report dated 29/12/2008 assessed the property by applying plinth area rates @ Rs.10,750/- per sq.mt. and ascertained the fair market value of this property as on the date of sale dated 29/7/2005 at Rs.1,24,13,620/-. The AO assessed the deemed sale consideration, as assessed by DVO at Rs.1,24,13,670/- and computed LTCG accordingly. The assessee before appellate authorities made argument that there is no fixed rate or there is no circle rate fixed by West Bengal Government for assessing the fair market value for the purpose of stamp duty during the relevant period when property was sold by assessee for the area where assessee's property . He referred the matter to Govt. of West Bengal, who assessed the fair market value of this property as on 08/9/2008, whereas the sale was made as on 29/7/2005, at Rs.76,18,872/- referring the same property. The relevant fair market value assessed by A.D.S.R., Sutahata has been reproduced above in para 4 page 4 & 5 of this order.
7. In view of the above facts, now the question arises as to why the fair market value assessed by DVO as per the provision of sec. 50C(2)(a) of the Act be adopted.. The expression "fair market value", in relation to any immovable property transferred, meant the price the immovable property ordinarily fetch on sale in the open market on the date of execution of the instrument of transfer of such property. The fair market value is the best price which vendor can reasonably obtain in the circumstances of a particular case and what is required to be done for the ascertainment of such market value is to ascertain the price which a willing, reasonable and prudent purchaser would pay for the property. In ascertaining that, all factors having any depressing or appreciative effect on the value of the property have to be taken into account or if irrelevant considerations have entered the enquiry, the finding becomes vitiated in law. There is no difference between the import of the terms "cost", "price" and "value". As a matter of fact, a price indicates a fact that has 7 already occurred in practice, a completed affair after a property has been, or agreed to be sold. On the other hand, "value" indicates the estimation of a probable price of the property concerned. The value of a property cannot be stated in an abstract form and it varies from time to time and can only be stated with reference to so many factors, i.e. the locality, situation, general appearance in the area, availability of shopping and marketing facilities, condition of public ways and transportation, availability of utilities, and many other things. As far as "cost" is concerned, it indicates cost to the purchaser for the purchase of the property after the purchase has been completed or agreed to. The provisions of sec. 50C of the Act, in the present context, state the fair market value and value is estimation of a probable price of the property, i.e. the deeming fiction. The deemed value is to be ascertained and for that, as discussed above, sec. 50C of the Act has postulated certain conditions. In the present case, the fair market value estimated by DVO has been challenged as DVO's report has no basis, because it has not discussed any of the factors, such as locality, situation, general appearance in the area, availability of shopping and marketing facilities, conditions of public ways and transportation, availability of utilities etc. and etc. We have gone through the DVO.'s report, which is a cryptic one, and the assessment is based on value as assessed by A.D.S.R., Sutahata and that also on the basis of additional stamp duty asked for. If such is the situation, there is no purpose for referring the matter to DVO reason being if the DVO is to adopt the value taken by stamp duty authority, then he has not applied his independent mind and that itself is based on irrelevant considerations and germane considerations have not been considered while assessing the value. Hon'ble Supreme Court has ruled for determining the fair market value, no doubt in the context of Land Acquisition Act, 1894, but the same holds the field even in the case of valuation to be made by the DVO. Hon'ble Apex Court has considered the issue in Chimanlal Hargovinddas V Special Land Acquisition Officer, AIR 1988 SC 1652, 1656-58, in Suresh Kumar V Town Improvement Trust, Bhopal, (1989) 2 SCC 329 (SC) and in Land Acquisition Collector v. Sukhdev Singh, AIR 1995 HP 150, 153-54 laid down following guiding factors:-
"(1) The market value of land under acquisition has to be determined as on the crucial date of publication of the notification under section 4 of the Land Acquisition Act (Dates of Notifications under sections 6 and 9 are irrelevant).
(2) The determination has to be made standing on the date line of valuation (date of publication of notification under section 4) as if the value is a hypothetical purchaser 8 willing to purchase land from the open market and is prepared to pay a reasonable price as on that day. It has also to be assumed that the vendor is willing to sell the land at a reasonable price.
(3) In doing so by the instances method, the Court has to correlate the market value reflected in the most comparable instance which provides the index of market value.
(4) Only genuine instances have to be taken into account. (Sometimes instances are rigged up in anticipation of acquisition of land.) (5) Even post-notification instances can be taken into account (1) if they are very proximate, (2) genuine and (3) the acquisition itself has not motivated the purchaser to pay a higher price on account of the resultant improvement in development prospects.
(6) The most comparable instances out of the genuine instances have to be identified on the following considerations:
(i) proximity from time angle
(ii) proximity from situation angle.
(7) Having identified the instances which provide the index of market value the price reflected therein may be taken as the norm and the market value of the land under acquisition may be deduced by making suitable adjustments for the plus and minus factors vis-a-vis land under acquisition by placing the two in juxtaposition.
(8) A balance-sheet of plus and minus factors may be drawn for this purpose and the relevant factors may be evaluated in terms of price variation as a prudent purchaser would do.
(9) The market value of the land under acquisition has thereafter to be deduced by loading the price reflected in the instance taken as norm for plus factors and unloading it for minus factors.
(10) The exercise indicated in clauses (7) to (9) has to be undertaken in a common sense manner as a prudent man of the world of business would so. We may illustrate some such illustrative (not exhaustive) factors:-
Plus factors Minus factors
1. Smallness of size. 1. Largeness of area
2. Proximity to a road. 2. Situation in the interior at a distance
from the road.
3. Frontage on a road. 3. Narrow strip of land with very small
frontage compared to depth.
4. Nearness to developed area. 4. Lower level requiring the depressed
portion to be filled up.
5. Regular shape. 5. Remoteness from developed locality.
6. Level vis-à-vis land under acquisition 6. Some special disadvantageous factor which would deter a purchaser.
7. Special value for an owner of an -
Adjoining property to which it may Have some very special advantage.
9(11) The evaluation of these factors of course depends on the facts of each case. There cannot be any hard and fast or rigid rule. Common sense is the best and most reliable guide. For instance, take the factor regarding the size. A building plot of land say 500 to 1000 sq. yds. cannot be compared with a large tract or block of land of say 10000 sq. yds. or more. Firstly while a smaller plot is within the reach of many, a large block of land will have to be developed by preparing a lay-out, carving out roads, leaving open space, plotting out smaller plots, waiting for purchasers (meanwhile the invested money will be blocked up) and the hazards of an entrepreneur. The factor can be discounted by making a deduction by way of an allowance at an appropriate rate ranging approximately between 20% to 50% to account for land required to be set apart for carrying out lands and plotting out small plots. The discounting will to some extent also depend on whether it is a rural area or urban area, whether building activity is picking up, and whether waiting period during which the capital of the entrepreneur would be locked up, will be longer or shorter and the attendant hazards.
(12) Every case must be dealt with on its own fact pattern bearing in mind all these factors as a prudent purchaser of land in which position the judge must place himself.
(13) These are general guidelines to be applied with understanding informed with common sense."
8. From the above, we can visualize that DVO has not discussed anything while determining fair market value, rather he has based his opinion on the basis of fair market value assessed by A.D.S.R., Sutahata for ascertaining value for stamp valuation purposes. Even the DVO without discussing anything has applied plinth area rate per sq. mt. He has not discussed the method of valuation, i.e. primarily land and building method, contractor's method of valuation, rental basis or yield basis method, municipal valuation method etc. In this case, the DVO has not ascertained any market value to which a willing, reasonable and prudent purchaser would pay for this property. Even the DVO has not considered the factors having any depressing or appreciative effect on the value of the property including guidelines laid down by Hon'ble Supreme Court, as noted above. Even DVO was asked to present to support his valuation report and in terms of proviso to section 24 of Wealth Tax Act, 1957, he was allowed opportunity. The DVO, Shri S.B.Dey was present but he fairly conceded that the valuation made is on the basis of value determined by Stamp Valuation Authority for charging stamp duty and his valuation is not based on any factors as enumerated by Hon'ble Supreme Court in the above-referred cases. These, above referred cases of Hon'ble Supreme Court, were confronted to DVO. Even Ld. Sr.DR, Shri S.K.Roy could not support the valuation report and fairly conceded that at the time of registration of sale deed of the assessee's property, there was no circle rates 10 for assessing the fair market value for the purposes of collection or levy of stamp duty is fixed. In such circumstances, now we have to determine what should be the fair market value. As argued by ld. Counsel for the assessee, Shri S.M.Surana and the valuation report as assessed by the stamp valuation authority, the same property vide report dated 08.09.2008 assessing the market value at Rs.76,18,872/- as filed before us can be considered. Hence, as directed by Hon'ble Calcutta High Court, considering the fair market value determined by A.D.S.R., Sutahata, Govt. of West Bengal, i.e. the valuation authority report dated 08/9/2008 assessing the fair market value of this property as on 08/9/2008 at Rs.76,18,872/- seems to be fair and reasonable for the purpose of computation of long-term capital gains because when assessee sold his property, in question, there was no circle rates fixed by stamp valuation authority of the concerned circle for the purpose of collection or levy of stamp duty as conceded by Ld. SR DR. We direct the AO accordingly.
9. The appeal of the assessee is partly allowed.
यह आदे श खुले Ûयायालय मɅ सुनाया गया है This order is pronounced in the open Court on 14.03.2012 Sd/- Sd/-
(सी.
सी डȣ.
डȣ राव) लेखा सदःय) महाबीर िसंह, Ûयायीक सदःय)
(महाबीर
(C.D. Rao) Accountant Member (Mahavir Singh) Judicial Member
(तारȣख)
तारȣख) Date: 14 -03-2012
आदे श कȧ ूितिलǒप अमेǒषतः-
Copy of the order forwarded to:
1. अपीलाथȸ / The Appellant : Chander Bhan Agrawal,
17, Ganesh Chandera Avenue,
Kolkata-700013
2 ू×यथȸ / The Respondent : Addl CIT, Range-31, Kolkata.
3. आयकर किमशनर (अपील) : The CIT(A)-XIX, Kolkata.
4. आयकर किमशनर/The C.I.T., Kol -
5 वभािगय ूितनीधी / DR, ITAT, Kolkata Benches, Kolkata 6 Guard file.
स×याǒपत ूित/True Copy, आदे शानुसार/ By order,
Asstt. Registrar.
11