Harsh Bhuwalka, Kolkata V. I.T.O. Ward 43(2)/KoL, Kolkata

ITA 1159/KOL/2009

• Counselvise Citation: [2013] 140 COUNSELVISE.COM (IT) 70430 (ITAT-KOLKATA)
• Duration Of Justice: 4 year(s) 5 month(s) 6 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 12-12-2013
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Next Hearing Date: 16-08-2011
• Assessment Year: 2005-2006
• Appeal Filed On: 06-07-2009
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: VARINDER MEHT A P
• Assessee Lawyers: M G PATEL
• Keywords: Charitable institution
• Section: 12A; 12AA; 12; 11

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH: KOL KATA [ BEFORE SHRI R.C.SHARMA, HONBLE A.M. & SHRI MAHAVIR SINGH, HONBLE J.M. ] I.T.A. NO.1579/KOL/2012 ASSESSMENT YEAR :2012-13 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) (PAN:AAFAS 7597C).. ( APPELLANT ) -VS- DIRECTOR OF INCOME TAX(EXEM PTION), KOLKATA.. ( RESPONDENT ) DATE OF CONCLUDING THE HEARING : 04.12.2013 DATE OF PRONOUNCING THE ORDER : 12.12.2013 APPEARANCES : FOR THE APPELLANT : SHRI MR. M . G. PATEL, CA : FOR THE RESPONDENT : SHRI VARINDER MEHT A, CIT(DR) O R D E R PER SHRI R. C. SHARMA, A.M. THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER OF THE DIRECTOR OF INCOME-TAX (EXEMPTION), KOLKATA DATED 05.09.2012 FO R THE ASSESSMENT YEAR 2012- 13, IN THE MATTER OF ORDER PASSED UNDER SECTION 12A A OF THE INCOME-TAX ACT. THE FOLLOWING FOUR GROUNDS HAVE BEEN TAKEN BY THE ASSES SEE. 1. THE LEARNED DIRECTOR OF INCOME TAX (EXEMPTION), KOLKATA HAS ERRED IN LAW AS WELL AS ON FACTS IN NOT GRANTING RE GISTRATION U/S.12AA OF THE INCOME TAX ACT, 1961. 2. THE LEARNED DIRECTOR OF INCOME TAX (EXEMPTION), KOLKATA HAS ERRED IN HOLDING THAT IN ABSENCE OF DOCUMENT EVIDEN CING CREATION OF LEGAL ENTITY, WAQF CANNOT BE REGISTERED U/S.12AA TH OUGH INDENTURE DATED 09.07.1920 WAS SUBMITTED DURING THE PROCEEDIN GS. 3. WITHOUT PREJUDICE TO THE ABOVE GROUND, EVEN IF IT IS HELD THAT INDENTURE DATED 09.07.1920 WAS NOT RELEVANT DOCUMEN T, THE EXISTENCE OF WAQF CAN BE PROVED FROM OTHER EVIDENCES. 4. THE LEARNED DIRECTOR OF INCOME TAX (EXEMPTION), KOLKATA HAS ERRED IN HOLDING THAT THE APPELLANT WAS NOT ENTITLE D TO EXEMPTION U/S.11 OF I.T. ACT, 1961 AS THE APPELLANT WAS NOT B ROUGHT INTO EXISTENCE EITHER AS A TRUST OR A SOCIETY THOUGH THE APPELLANT IS A DULY CONSTITUTED WAQF UNDER WAQF ACT, 1995. ITA NO.1579/KOL/2012 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) ASSESSMENT YEAR: 2012-13 2 2. MR. M.G.PATEL, CA APPEARED ON BEHALF OF THE ASSE SSEE AND CONTENDED THAT THE DIRECTOR OF INCOME-TAX (EXEMPTIONS) HAS WRONGLY HELD THAT WAQF CANNOT BE REGISTERED THOUGH AN INDENTURE DATED 09.07.1920 WAS SUBMITTED DURING THE PROCEEDINGS. HE FURTHER CONTENDED THAT DIRECTOR OF INCOME-TAX (EXEMPTION) WAS NOT CORRECT IN HOLDING THAT THE ASSESSEE WAS NOT BR OUGHT INTO EXISTENCE EITHER AS TRUST OR A SOCIETY, THOUGH THE ASSESSEE IS DULY CON STITUTED WAQF UNDER WAQF ACT, 1995. THE LD. A.R. ALSO PLACED ON RECORD ORDER OF T HE COORDINATE BENCH IN CASE OF SHIYA DAWOODI BOHRA JAMAT AMJHERA IN ITA NO.208/IND /2011 ORDER DATED 29.02.2012, ORDER IN CASE OF SHIYA DAWOODI BOHRA JA MAT, NEEMUCH & OTHERS IN ITA NO.464/IND/2005 DATED 08.02.2007 AND CONTENDED THAT THE PROPOSITION LAID DOWN IN THESE DECISIONS SQUARELY APPLY TO THE ASSES SEES CASE, ACCORDINGLY DIRECTOR OF INCOME TAX (EXEMPTIONS) SHOULD BE DIRECTED TO GR ANT REGISTRATION UNDER SECTION 12AA OF THE I.T. ACT. 3. ON THE OTHER HAND, THE LD. CIT(DR), SHRI VARINDE R MEHTA RELIED ON THE ORDER OF THE DIRECTOR OF INCOME-TAX (EXEMPTIONS) AND CONT ENDED THAT THE ASSESSEE IS NEITHER A TRUST NOR A SOCIETY, THEREFORE, THE DIT(E XEMPTIONS) HAS CORRECTLY DECLINED THE CLAIM OF REGISTRATION UNDER SECTION 12AA OF THE I.T. ACT READ WITH SECTION 11 OF THE I.T. ACT. 4. WE HAVE CONSIDERED RIVAL CONTENTIONS AND CAREFUL LY GONE THROUGH THE ORDERS OF THE AUTHORITIES BELOW. WE HAVE ALSO DELIBERATED ON THE JUDICIAL PRONOUNCEMENTS CITED BY THE LD. A.R., IN THE CONTEXT OF FACTUAL MA TRIX OF THE INSTANT CASE. FROM THE RECORDS, WE FOUND THAT THE ASSESSEE HAD APPLIED FOR REGISTRATION UNDER SECTION 12A. ALONGWITH THE APPLICATION, THE ASSESSEE HAD FILED ( I) CERTIFIED COPY OF THE INSTRUMENT UNDER WHICH THE TRUST/INSTITUTION WAS CR EATED/ ESTABLISHED, (II) CERTIFIED COPY OF DOCUMENT EVIDENCING THE CREATION OF THE TRU ST OR THE ESTABLISHMENT OF THE INSTITUTION, (III) THREE COPIES OF AUDITED ACCOUNTS OF THE TRUST/INSTITUTION FOR THE LATEST THREE YEARS. THE OBJECTS OF THE TRUST WERE A S UNDER: 1. TO ADVANCE, PROMOTE, PROPAGATE AND PREACH THE R ELIGION OF ISLAM ITA NO.1579/KOL/2012 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) ASSESSMENT YEAR: 2012-13 3 AMONGST THE DAWOOD BOHRAS IN CONFORMITY WITH AL-QUR AN, SHARIAT MOHAMMEDIYAH AND THE TENETS OF DAWAT-E HADIYAH. 2. TO CELEBRATE, ARRANGE, PARTICIPATE AND TAKE AN A CTIVE INTEREST IN ALL RELIGIOUS AND CEREMONIAL FUNCTIONS, GATHERINGS, MAJ ALIS OF DAWAT-E- HADIYAH AND THE BIRTH AND DEATH ANNIVERSARIES OF DO AT KIRAM AND HUDUD IZAM RECOGNIZED BY AL-DAI AL-MUTLAQ. 3. TO SUPPORT MADRASAHS AND ADVANCE RELIGIOUS EDUCATIO N AND LEARNING. 4. TO PROMOTE, PROPAGATE, FOSTER AND IMPLEMENT THE CON CEPT OF QARDAN HASANA AMONG THE DAWOODI BOHRAS, IN ACCORDANCE WITH THE TENETS AND PRINCIPLES OF DAWAT-E-HADIYAH. 5. TO HOST AND ASSIST IN ARRANGING NIYAZ (RELIGIOUS MEALS) ON SOLEMN OCCASIONS. 6. TO DEVELOP, EXPAND, RENOVATE AND MAINTAIN MASJIDS, MADRESAHS, JAMATKHANAS, DARUL EMARAT (OFFICIAL RESIDENCE OF TH E AMIL) AND QABRASTANS (BURIAL GROUNDS) AND SUCH OTHER RELIGIOU S PROPERTIES. 7. TO CARRY OUT ANY OTHER PIOUS OR RELIGIOUS ACTIVITIE S AS PER THE DIRECTIONS OF THE SOLE TRUSTEE. 5. FROM THE RECORDS, WE FOUND THAT THE ASSESSEE WAQ F WAS CARRYING OUT THE FOLLOWING ACTIVITIES:- 1. MAINTENANCE/DEVELOPMENT OF MOSQUE, KABRASTAN & OTHER PROPERTIES. 2. PAYMENTS OF VAZIFA SALARIES TO AAMIL SAHAB/ VA LI MULLA & OTHER STAFF. 3. PERFORMANCE OF NIYAZ (RELIGIOUS MEALS) ON SOLEMN OCCASIONS & MAJALIS OF DAWAT-E-HADIYAH AND THE BIRTH AND DEATH ANNIVERSARIES OF DOAT KIRAM AND HUDUD IZAM RECOGNIZ ED BY AL-DAI AL-MUTLAQ. 4. CHARITY TO THE NEEDY PEOPLE . 6. VIDE LETTER DATED 16.08.2012, DIRECTOR OF INCOME -TAX (EXEMPTIONS) HAD ASKED FOR CERTAIN QUERIES, WHICH WERE PROPERLY REPL IED BY THE ASSESSEE, VIDE LETTER DATED 05.09.2012, AS UNDER: 1. SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA), EARLIER K NOWN AS DAWOODI BOHRA COMMUNITY WAKF, WAS CREATED VIDE INDE NTURE ITA NO.1579/KOL/2012 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) ASSESSMENT YEAR: 2012-13 4 DATED 9 TH JULY, 1920. IT WAS SUBSEQUENTLY ENROLLED WITH THE OFFICE OF THE COMMISSIONER OF WAKFS, WEST BENGAL, KOLKATA ON 21-11- 1979. THE NAME OF THE WAKF WAS AMENDED TO SHIA DAWO ODI BOHRA JAMAAT WAQF (KOLKATA) WHICH WAS NOTED IN THE RECORD S OF THE WAKF REGISTER MAINTAINED BY THE BOARD OF WAKFS, WES T BENGAL. THE COPIES OF THE INDENTURE DATED 9-7-1920, ENROLME NT CERTIFICATE DATED 18-12-1979 AND THE LETTER DATED 5-1-2011 FROM THE BOARD OF WAKFS, WEST BENGAL ARE ALREADY FI1ED ALONG WITH THE APPLICATION. THE ORIGINAL OF THE INDENTURE DATED 9-7-1920 IS PRO DUCED HEREWITH FOR YOUR KIND VERIFICATION. 2. A NOTE ON THE OBJECTS OF THE WAKF AND THE ACTIVITIES CARRIED ON BY IT WAS SUBMITTED ALONG WITH THE APPLICATION. . 3. THE AUDITED ACCOUNTS FOR THE YEARS 2008-09 1 2009-10 AND 2010-11 WERE SUBMITTED ALONG WITH THE APPLICATION. 4. COPIES OF THE LATEST STATEMENT FROM IDBI BANK AND T HE PANCARD OF THE WAKF IS ENCLOSED HEREWITH. 5. THE PRESENT APPLICATION IS U/S 12 A OF THE INCOME T AX ACT, 1961 AND THEREFORE NO COURT FEE STAMP IS REQUIRED TO BE AFFIXED. 6. THE DECLARATION U/S 11(5) AND 13 (1)(C) OF THE INCO ME TAX ACT, 1961,SIGNED BY ALL THE MANAGERS WILL BE SUBMITTED I N DUE COURSE. 7. THE NAMES, ADDRESSES, PAN AND OCCUPATION OF ALL THE MANAGERS IS CLOSED HEREWITH. THE COPIES OF THEIR PHOTO IDENTITY WERE SUBMITTED ALONG WITH THE APPLICATION. 8. THE WAKF HAS NOT RECEIVED DONATION, EITHER VOLUNTA RY OR CORPUS. ITS INCOME IS BY WAY OF RENT AMOUNTING TO RS.31,719 /- DURING THE YEAR 2010-11. 9. THE WAKF HAS NOT MADE ANY COUNTER DONATIONS. 10. AS EXPLAINED TO YOUR HONOUR, THE WAKF WAS CREATED MANY DECADES AGO ON 9-7-1920 AND THEREFORE THERE ARE NO SPECIFIC PROVISIONS. RELATING TO ITS IRREVOCABILITY, AREA OF OPERATION, SAFE CUSTODY OF TRUST PROPERTY AND DISSOLUTION CLAUSE. THE MANAGERS OF' THE TRUST HAVE HOWEVER, IN THE APPLICATION FOR REGISTRATION U/S 12A, CERTIFIED AND CONFIRMED THAT THE 'WAQF SHA1I BE GOVERNED IN A CCORDANCE WITH THE PROVISIONS OF THE WAQF ACT, 1996 AND THE I NCOME TAX ACT, 1961 AND ANY OTHER RELEVANT ACT FOR THE TIME BEING IN FORCE'. WE MAY ALSO POINT OUT THAT ANY PROPERTY (MOVABL OR IMM OVEABLE) THAT ITA NO.1579/KOL/2012 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) ASSESSMENT YEAR: 2012-13 5 COMES INTO THE POSSESSION OF THE WAKF IS PERMANENTL Y DEDICATED IN TO ALLAH ARID IS.THUS IRREVOCABLE. 11. THE WAKF IS NOT REGISTERED UNDER FCRA. 12. THE WAKF HAS NOT RECEIVED ANY FOREIGN CONTRIBUTION . 13. THE WAKF IS NOT RUNNING ANY BUSINESS ACTIVITIES. 14. THE WAKF IS PURELY AND SOLELY A RELIGIOUS INSTITUTI ON AND ALL ITS EXPENDITURE ARE ON RELIGIOUS ACTIVITIES ONLY. 7. AFTER CAREFULLY GOING THROUGH THE DOCUMENTS ATTA CHED WITH APPLICATION FILED U/S.12AA, REPLY FILED ON 5.9.2012 AND THE OTHER MAT ERIALS PLACED ON RECORD, WE FOUND THAT THE ASSESSEE, SHIA DAWOODI BOHRA JAMAT W AQF (KOLKATA), WHICH WAS EARLIER KNOWN AS DAWOODI BOHRA COMMUNITY WAKF WAS C REATED VIDE INDENTURE DATED 09.07.1920. IT WAS ENROLLED WITH THE OFFICE O F THE COMMISSIONER OF WAKFS (KOLKATA) ON 21.11.1979. THE NAME OF THE WAKF WAS A MENDED TO SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) WHICH WAS DULY NOTED IN THE RECORDS OF THE WAKF REGISTER MAINTAINED BY THE BOARD OF WAKFS, WEST BEN GAL. WE HAVE ALSO PERUSED THE COPIES OF THE INDENTURE DATED 09.07.1920, ENROLMENT CERTIFICATE DATED 18.12.1979 AND THE LETTER DATED 05.01.2011 FROM THE BOARD OF W AKFS, WEST BENGAL, WHICH WERE ALREADY FILED BY THE ASSESSEE ALONG WITH THE R EGISTRATION APPLICATION. WE ALSO FOUND THAT ORIGINAL OF THE INDENTURE DATED 09.07.19 20 WAS PRODUCED BEFORE THE DIRECTOR OF INCOME-TAX(EXEMPTIONS) FOR HIS VERIFICA TION. AS PER THE OBJECTS OF THE WAQF, IT WAS ENGAGED IN CHARITABLE AND RELIGIOUS AC TIVITIES. THE OBJECT WAS TO ADVANCE, PROMOTE, PROPAGATE AND PREACH THE RELIGION OF ISLAM AMONGST THE DAWOOD BOHRAS IN CONFORMITY WITH THE AL-QURAN, SHARIAT MOH AMMEDIYAH AND THE TENETS OF DAWAT-E-HADIYAY, TO DEVELOP, EXPAND, RENOVATE AND M AINTAIN MASJIDS, MADRESAHS, JAMATKHANAS, ETC. IT CARRIED OUT CHARITY TO THE NEE DY PEOPLE. THE DIT (EXEMPTION) HAS DENIED EXEMPTION ON THE PLEA THAT THE ASSESSEE IS NEITHER A TRUST NOR A SOCIETY, THEREFORE, EXEMPTION UNDER SECTION 11 CANNOT BE GRA NTED. THE ISSUE HAS BEEN CONSIDERED IN DETAIL BY THE COORDINATE BENCH IN CAS E OF SHIA DAWOODI BOHRA JAMAT, AMJHERA ( SUPRA ), WHEREIN IT WAS OBSERVED THAT WAQF IS AN ORAL WAQ F. COPY ITA NO.1579/KOL/2012 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) ASSESSMENT YEAR: 2012-13 6 OF WAQF DEED WAS NOT AVAILABLE. WAQF WAS CREATED BY CUSTOMS AND TENANTS OF DAWOODI BOHRA COMMUNITY WELL BEFORE THE ENACTMENT O F THE INCOME TAX ACT, 1961. AS THE WAQF IS EXISTING PRIOR TO INCOME-TAX A CT, 1961, THE OBJECT BENEFICIAL TO A SECTION OF THE PUBLIC IS AN OBJECT OF GENERAL PUBLIC UTILITY. TO SERVE AS A CHARITABLE PURPOSE, IT IS NOT NECESSARY THAT THE OB JECT MUST BE TO SERVE THE WHOLE MANKIND OR ALL PERSONS LIVING IN A COUNTRY OR PROVI NCE. IT IS REQUIRED TO BE NOTED THAT EVEN IF A SECTION OF THE PUBLIC IS GIVEN BENEF IT, IT CANNOT BE SAID THAT IT IS NOT A TRUST FOR CHARITABLE PURPOSE IN THE INTEREST OF PUB LIC. IT IS NOT NECESSARY THAT THE PUBLIC AT LARGE MUST GET THE BENEFIT. LOOKING TO TH E SCHEME OF THE TRUST AND APPLYING THE PROPOSITION OF LAW AS LAID DOWN BY THE HONBLE SUPREME COURT IN CASE OF AHMEDABAD RANA CASTE ASSOCIATION 82 ITR 704 , WE HOLD THAT THE OBJECTS OF THE ASSESSEE WAS TO BENEFIT A SECTION OF THE PUB LIC, WHICH CERTAINLY CAN BE DISTINGUISHED. THE HONBLE SUPREME COURT IN CASE OF AHMEDABAD RANA CASTE ASSOCIATION ( SUPRA ) ALSO HELD THAT AN OBJECT BENEFICIAL TO A SECTION OF THE PUBLIC IS AN OBJECT OF GENERAL PUBLIC UTILITY. TO SERVE A CHA RITABLE PURPOSE, IT IS NOT NECESSARY THAT THE OBJECT SHOULD BE BENEFICIAL TO THE WHOLE M ANKIND OR ALL PERSONS IN A PARTICULAR COUNTRY OR A STATE. AN OBJECT BENEFICIAL TO A PARTICULAR COMMUNITY OF A PARTICULAR DOMICILE AT LARGE ALONG WITH IMMIGRATES OF THE SAME COMMUNITY AS ACCEPTED BY THE NATIVES ACCORDING TO THE CUSTOM AND USAGE AMOUNTS TO A BENEFIT TO A SECTION OF THE PUBLIC WITHOUT PERSONAL TOUCH, HEN CE AN OBJECT OF GENERAL PUBLIC UTILITY. THUS, AN OBJECT BENEFICIAL TO A SECTION OF PUBLIC IS AN OBJECT OF GENERAL PUBLIC UTILITY. APPLYING THE PROPOSITION OF LAW AS LAID DOWN BY THE HONBLE SUPREME COURT TO THE FACTS OF THE INSTANT CASE, AS DISCUSSED ABOVE, WE FOUND THAT THE ASSESSEE, SHIA DAWOODI BOHRA JAMAT WAQF (KOLKAT A) WAS FOUNDED FOR DEVELOPMENT OF MUSLIM RELIGION, CANNOT BE DENIED TH E BENEFIT OF REGISTRATION UNDER SECTION 12A OF THE ACT ON THE PLEA THAT IT WAS ONLY FOR THE PURPOSE OF MUSLIM RELIGION, AS IT WAS FOR THE PURPOSE OF A SECTION OF THE PUBLIC AMOUNTS TO AN OBJECT OF GENERAL PUBLIC UTILITY. AS PER OUR CONSIDERED VIEW FOR GRANTING REGISTRATION, IT IS NOT NECESSARY THAT THE OBJECTS SHOULD BE TO BENEFIT THE WHOLE MANKIND, IT WILL BE SUFFICIENT IF THE OBJECT IS BENEFICIAL TO A SECTION OF THE PUBLIC, WHICH, IN OUR CASE, IS ITA NO.1579/KOL/2012 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) ASSESSMENT YEAR: 2012-13 7 MUSLIM RELIGION. AFTER GOING THROUGH THE AUDITED BA LANCE-SHEET, AUDITED ACCOUNTS OF THE ASSESSEE FOR THE LAST THREE YEARS, WE FOUND THAT NO PART OF THE INCOME OR PROPERTY OF THE TRUST WAS USED OR APPLIED DIRECTLY FOR THE BENEFIT OF ANY PERSON, REFERRED IN SUBSECTION (3) OF SECTION 13. NO FUNDS OF THE TRUST WERE INVESTED OR DEPOSITED OTHERWISE THAN IN ANY ONE OR MORE OF THE FORMS OR MODES SPECIFIED IN SUB-SECTION (5) OF SECTION 11. 8. WE HAVE ALSO GONE THROUGH THE PROVISIONS OF SECT ION 6 AND 44 OF BENGAL WAQF ACT, 1934 AND ALSO VERIFIED COPIES OF ORDERS O F DIT(EXEMPTION), MUMBAI, GRANTING REGISTRATION UNDER SECTION 12AA IN CASE OF DAWOODI BOHRA MOSQUE AT MACHHI BAZAR WAKF DATED 20.09.2006, JAMALI MOHALLAH DAWOODI BOHRA WAQF MUMBAI DATED 06.10.2009 AND DAWOODI BOHRA JAMAT ANJ UMAN-E-NAJMI WAKF DATED 15.04.2008, AS PLACED ON RECORD, WHICH WERE A LSO HAVING VERY SAME OBJECTS AND INDENTURE. 9. IN VIEW OF THE ABOVE DISCUSSION, RESPECTFULLY FO LLOWING THE DECISION OF THE HONBLE SUPREME COURT AND THE COORDINATE BENCH, AS DISCUSSED ABOVE, WE DO NOT FIND ANY MERIT IN THE ORDER OF THE DIRECTOR OF INCO ME-TAX (EXEMPTIONS) FOR DENIAL OF REGISTRATION UNDER SECTION 12AA OF THE I.T. ACT. ACCORDINGLY, WE DIRECT THE DIT(EXEMPTIONS) TO GRANT REGISTRATION UNDER SECTION 12AA OF I.T. ACT. WE DIRECT ACCORDINGLY. 10. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS AL LOWED. THIS ORDER IS PRONOUNCED IN THE COURT ON 12 TH DECEMBER, 2013. SD/- SD/- (MAHAVIR SINGH) (R.C.SHARMA) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED : 12 TH DECEMBER, 2013 ITA NO.1579/KOL/2012 SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA) ASSESSMENT YEAR: 2012-13 8 COPY OF THE ORDER FORWARDED TO: 1. SHIA DAWOODI BOHRA JAMAAT WAQF (KOLKATA), C/O- AAMI L SAHEB, SAIFEE MASJID, 21, POLLOCK STREET, KOLKATA 700 00 1 2 DIRECTOR OF INCOME TAX (EXEMPTION), KOLKATA 3. THE CIT(A), 4. CIT, 5. DR, TRUE COPY, BY ORDER, ASSTT. REGISTRAR , ITAT, KOLKATA TALUKDAR(SR.P.S.)