Kottakkal Wood Complex, Kottakkal V. DCIT, Calicut

ITA 129/COCH/2011

• Counselvise Citation: [2012] 140 COUNSELVISE.COM (IT) 64813 (ITAT-COCHIN)
• Duration Of Justice: 1 year(s) 6 month(s) 18 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 07-09-2012
• Appeal Filed By: Assessee
• Bench Allotted: DB
• Next Hearing Date: 26-07-2012
• Assessment Year: 2004-2005
• Appeal Filed On: 18-02-2011
• Court: TRIBUNAL
• Department Lawyers: A S BINDHU
• Keywords: Business income; Search and seizure

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN BEFORE S/SHRI N.R.S.GANESAN, JM AND B.R.BASKAR AN, AM I.T.A NOS. 127-133/COCH/2011 ASSESSMENT YEARS: 2002-03 TO 2008-09 M/S. KOTTAKKAL WOOD COMPLEX, MAIN ROAD, KOTTAKKAL. [PAN: AACFK 6874A] VS. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOZHIKODE. (ASSESSEE-APPELLANT) (REVENUE- RESPONDENT) ASSESSEE BY SHRI ANIL D. NAIR, ADV. REVENUE BY SMT. A.S. BINDHU, SR. DR DATE OF HEARING 26/07/2012 DATE OF PRONOUNCEMENT 07/09/2012 O R D E R PER B.R.BASKARAN, ACCOUNTANT MEMBER: ALL THESE APPEALS FILED BY THE ASSESSEE ARE DIRECT ED AGAINST THE ORDERS PASSED BY LD CIT(A)-I, KOCHI AND THEY RELATE TO THE ASSESSMEN T YEARS 2002-03 TO 2008-09. SINCE IDENTICAL ISSUES ARE URGED IN THESE APPEALS, THEY W ERE HEARD TOGETHER AND ARE BEING DISPOSED OF BY THIS COMMON ORDER, FOR THE SAKE OF C ONVENIENCE. 2. THE ASSESSEE IS ASSAILING THE DECISION OF LD CIT(A) IN CONFIRMING THE ADDITIONS RELATING TO THE SUPPRESSION OF SALES, DISALLOWANCE OF PART OF MOTORCAR AND TELEPHONE EXPENSES IN ALL THESE YEARS. 3. THE FACTS RELATING TO THE ISSUES ARE STATED IN BRIEF. THE DEPARTMENT CARRIED OUT SEARCH AND SEIZURE OPERATIONS IN THE HANDS OF SHRI ADATTIL MOHAMMED AND IN THE PREMISES OF M/S CLASSY THE ANTIQUE DESIGNED FURNITU RE. DURING THE COURSE OF SEARCH, THE CERTAIN DOCUMENTS PERTAINING TO THE ASSESSEE HEREIN WERE SEIZED. ACCORDINGLY I.T.A. NOS. 127-133/COCH/2011 2 ASSESSMENT PROCEEDINGS WERE INITIATED IN THE HANDS OF THE ASSESSEE U/S 153C OF THE ACT. THE ASSESSEE HEREIN IS A PARTNERSHIP FIRM CON STITUTED BY ITS PARTNERS SHRI A.MUHAMMED AND SHRI K.MOIDEEN KUTTY. SHRI A.MUHAMM ED IS THE MANAGING PARTNER OF THE FIRM. SHRI A.JABIR IS THE SON OF SHRI A.MUHAMM ED AND THE SAID SHRI A.JABIR IS ONE OF THE PARTNERS OF THE FIRM NAMED M/S CLASSY THE ANTIQ UE DESIGNED FURNITURE. SHRI V.AHAMED IS THE SALES MAN OF THE ASSESSEE HEREIN. 4. DURING THE COURSE OF SEARCH, A STATEMENT WAS RECORDED FROM SHRI A.JABIR U/S 132(4) OF THE ACT, WHEREIN HE CONFESSED THAT THE SA LES INVOICES ARE RAISED AT HALF THE AMOUNT OF THE SELLING RATE. THE DEPARTMENT ALSO CA RRIED OUR SURVEY OPERATION IN THE PREMISES OF THE ASSESSEE HEREIN AND A STATEMENT WAS TAKEN FROM THE SALES MAN NAMED SHRI V.AHAMED. IN THE SAID STATEMENT, SHRI V.AHAMED STATED THAT MR.JABIR FIXES THE PRICE OF GOODS AND THE ACTUAL SALES PRICE IS DOUBLE THE RATE MENTIONED IN THE RATE CARD ATTACHED TO EACH OF THE FURNITURE. BASED ON THE SA ID STATEMENTS, THE AO CAME TO THE CONCLUSION THAT THERE IS SUPPRESSION OF SALES. THE ASSESSEE WAS ALSO SELLING BRANDED ITEMS, IN RESPECT OF WHICH THERE WAS NO SCOPE FOR S UPPRESSION OF SALES PRICE. ACCORDINGLY, WHILE WORKING OUT THE SUPPRESSED SALES , THE AO ESTIMATED THE SALE OF BRANDED ITEMS AT 20% OF THE SALES SHOWN IN THE PROF IT AND LOSS ACCOUNT AND FURTHER GAVE A DEDUCTION TOWARDS DISCOUNT OFFERED TO THE CU STOMERS AT 20% OF THE SALES RATE. ACCORDINGLY, THE AO ARRIVED AT THE SUPPRESSED SALES FOR EACH OF THE YEARS UNDER CONSIDERATION AND ADDED THE SAME TO THE TOTAL INCOM E OF THE ASSESSEE. THE LD CIT(A) ALSO CONFIRMED THE SAID ADDITIONS AND HENCE THE ASS ESSEE IS IN APPEAL BEFORE US. 5. THE LD COUNSEL FOR THE ASSESSEE SUBMITTED TH AT THE AO SHOULD NOT HAVE PLACED RELIANCE ON THE STATEMENT GIVEN BY SHRI A.JABIR, AS HE WAS A STRANGER IN SO FAR AS THE ASSESSEE FIRM IS CONCERNED. HE FURTHER SUBMITTED T HAT THE ASSESSEE FIRM DID NOT EFFECT ANY SALES TO THE SISTER CONCERNS AND HENCE THE METH ODOLOGY, IF ANY, ADOPTED IN THE SISTER CONCERNS CANNOT BE AUTOMATICALLY APPLIED HER E. HE FURTHER SUBMITTED THAT THE AO SHOULD NOT HAVE TAKEN SUPPORT FROM THE STATEMENT TA KEN FROM THE SALES MAN NAMED SHRI V.AHAMED DURING THE COURSE OF SURVEY OPERATION S, AS HE WAS RECENTLY EMPLOYED AND HE CANNOT BE CONSIDERED AS HAVING FULL KNOWLEDG E ABOUT THE BUSINESS. HE FURTHER I.T.A. NOS. 127-133/COCH/2011 3 SUBMITTED THAT THE SEARCH OFFICIALS DID NOT UNEARTH ANY MATERIAL TO SUGGEST THAT THERE WAS SUPPRESSION OF SALES AND HENCE THE ADDITIONS MA DE IN ALL THESE YEARS ON THIS ACCOUNT IS LIABLE TO BE DELETED. 6. ON THE CONTRARY, THE LD D.R SUBMITTED THAT S HRI A.JABIR IS THE SON OF THE MANAGING PARTNER OF THE FIRM AND IT IS EVIDENT THAT HE WAS A LSO MANAGING THE AFFAIRS OF THE ASSESSEE FIRM. THE SALESMAN OF THE ASSESSEE FIRM S HRI V.AHAMED HAS CONFIRMED THIS FACT IN THE STATEMENT TAKEN FROM HIM. FURTHER THE MODUS OPERANDI FOLLOWED FOR SUPPRESSION OF SALES IS ALSO CORROBORATED BY THE PR ICE TAG ATTACHED TO THE FURNITURE ITEMS AND HENCE THE PATTERN OF SUPPRESSION FOLLOWED BY THE ASSESSEE OVER THE YEARS HAS CLEARLY BEEN PROVED. ACCORDING THE LD D.R SUBMITTE D THAT THE LD CIT(A) WAS JUSTIFIED IN CONFIRMING THE ADDITIONS MADE TOWARDS SUPPRESSION O F SALES IN ALL THESE YEARS. 7. WE HAVE HEARD THE RIVAL CONTENTIONS AND CARE FULLY PERUSED THE RECORD. ADMITTEDLY, THE ASSESSING OFFICER HAS PLACED STRONG RELIANCE ON THE SWORN STATEMENT RECORDED FROM SHRI A.JABIR DURING THE COURSE OF SEARCH OPERATIONS IN THE HANDS OF M/S CLASSY THE ANTIQUE DESIGNED FURNITURE AND ALSO THE STATEMENT TAKEN FROM THE SALES MAN OF THE ASSESSEE FIRM. WE FURTHER NOTICE THAT THE AO HAS A LSO CORROBORATED THE FACT OF SUPPRESSION OF SALES WITH OTHER AVAILABLE EVIDENCES . FOR THE SAKE OF CONVENIENCE, WE EXTRACT BELOW THE OBSERVATIONS MADE BY THE AO IN TH E ASSESSMENT ORDER PASSED FOR THE ASSESSMENT YEAR 2002-03 THE CONTENTION OF THE ASSESSEE IS NOT ACCEPTED. ASSESSEE IS A SISTER CONCERN OF CLASSY GROUP WHICH IS A FAMILY CONCERN OF ADATTIL MOHAMMED. THE MODUS OPERANDI REGARDING THE SUPPRESSION OF SALE B Y UNDERSTATING THE SALE IS COMMON IN ALL THE FIRMS AS IT IS EVIDENT FROM THE STATEMENT OF SRI ADATTIL JABIR AND SRI V. AHAMMAD AS MENTIONED ABOVE. THERE WAS AN INSPECTION BY THE INTELLIGENCE OFFICER OF COMMERCIAL TAXES OF TIRUR IN THE CASE OF KOTTAKKAL WOOD COMPLEX ON 17.8.06 AND EXCESS OF STOCK OF 14,38,78 5/- WAS FOUND AND THE DEPARTMENT OF COMMERCIAL TAXES HAS ISSUED A SHOW C AUSE NOTICE BEARING NO. TRL-08/06-07 DATED 16.10.2007 FOR IMPOSING PENALTY U/S. 67(6) OF THE KVAT ACT. IN RESPONSE TO THE SAID SHOW CAUSE NOTICE ASSESSEE VIDE LETTER DATED 10.4.07 REPLIED THAT THE STOCK DIFFERENCE EXISTED ONLY IN THE CASE OF 12 ITEMS OUT OF 31 ITEMS. THIS SHOWS THAT THE ASSESSEE IS REGULARLY SUPPRESSING THE SALE OF GOODS WHILE COMPUTING THE UNDERSATED SALE, BRANDED ITEMS , SALES TO BANKS ETC. ARE EXCLUDED. FURTHER, THE SHARP FALL IN GP COULD NOT BE SATISFACTORILY EXPLAINED FROM I.T.A. NOS. 127-133/COCH/2011 4 WHICH IT IS VERY CLEAR THAT THE ASSESSEE HAS SUPPR ESSED THE SALES. THEREFORE THE SUPPRESSION OF SALE WORKED OUT AS ABOVE AT RS. 17, 81,971/- IS ADDED TO THE TOTAL INCOME AS UNDISCLOSED BUSINESS INCOME. PENALTY PR OCEEDINGS U/S. 271(1)(C) IS INITIATED FOR CONCEALMENT OF INCOME. 8. THE LD CIT(A) HAS CONSIDERED THE ISSUE IN DE TAIL BY MAKING PARTICULAR REFERENCE TO THE RELEVANT QUESTION ANSWERS FROM THE STATEMENT RE CORDED FROM SHRI V.AHAMED, THE SALES MAN OF THE ASSESSEE FIRM. THE LD CIT(A) FURT HER NOTICED THAT THE MODALITIES OF SUPPRESSION WAS FOUND CORROBORATED BY THE AO. THE LD CIT(A) HAS ALSO ANALYSED THE PATTERN OF GROSS PROFIT RATE DECLARED BY THE ASSESS EE OVER THE YEARS FOUND THEM TO BE ERRATIC. UNDER THESE CIRCUMSTANCES, THE LD CIT(A) CAME TO THE CONCLUSION THAT THERE WAS SUPPRESSION OF SALES IN A SYSTEMATIC MANNER IN THE ASSESSEE FIRM AND ACCORDINGLY CONFIRMED THE ADDITIONS IN ALL THE YEARS. FOR THE SAKE OF CONVENIENCE, WE EXTRACT BELOW THE RELEVANT OBSERVATIONS MADE BY THE LD CIT(A) ON THIS ISSUE IN THE ORDER PASSED FOR THE ASSESSMENT YEAR 2002-03. 9. I HAVE CAREFULLY CONSIDERED THE RELEVANT FACTS AND PROVISIONS OF LAW WITH REGARD TO THE ISSUE INVOLVED. I FIND THAT DURING THE COURSE OF SEARCH ACTION THERE WAS A CLEAR ADMISSION BY SALES MAN OF THE APPELLAN T FIRM MR. V. AHAMED THAT SALE PRICE WAS DECIDED BY MR. JABIR WHO WAS A PART NER IN M/S. CLASSY THE ANTIQUE DESIGNED FURNITURE A SISTER CONCERN OF THE APPELLA NT FIRM. MR. JABIR WHO WAS SON OF THE MANAGING PARTNER IN TURN MADE A CLEAR ADMIS SION THAT INVOICE WAS PREPARED ONLY FOR HALF OF THE AMOUNT FOR WHICH AN ITEM WAS SOLD. THE STATEMENT WAS DULY CORROBORATED BY THE CODED TAG ATTACHED TO THE FURNITURE WHICH HAS BEEN DULY ELABORATED BY MR. JABIR AND HAS BEEN ALSO REF ERRED TO IN THE BODY OF THE ASSESSMENT ORDER. THIS MODUS OPERANDI WAS ALSO EL ABORATED BY SALES MAN MR. V. AHAMED IN THE DEPOSITION GIVEN DURING THE COURS E OF SEARCH ACTION AS PER THE FOLLOWING QUESTION AND ANSWER: QUESTION: WHO IS FIXING THE RATE OF THE FURNITUR E BEING SOLD HERE? HOW IS THE CODE RATE IN THE TAG HUNG ON THE FURNITURE DECIDED? ANSWER: JABIR IS DECIDING THE PRICE OF THE STOCK HERE. HE IS DECIDING THE CODE. THE PRICE IS DECIDED ON PERUS ING THE TAG AS FOLLOWS: DINING TABLE 6/4 FOR RS. 4,500/- FOR THIS IN THE TAG IT IS WRITTEN AS DD 22/50. BY MULTIPLY ING WITH 2 WE GET RS. 4,500/- ACCORDING TO THIS THE SEL LING PRICE MARKED IN THE TAG IS DECIDED. IN THE ABOVE DEPOSITION GIVEN ON THE DAY OF SEARCH , MR. V. AHAMED SALES MAN OF THE APPELLANT FIRM, CLEARLY STATED THAT BILLING OF THE FURNITURE SOLD WAS DONE BY MR. JABIR AND THE COMPUTER FOR ISSUING THE BILL WAS US ED BY MR. JABIR AND THEIR I.T.A. NOS. 127-133/COCH/2011 5 ACCOUNTANT. INVOLVEMENT OF MR. JABIR IN THE MATTER WAS THEREFORE FULLY ESTABLISHED IRRESPECTIVE OF THE FACT THAT HE HIMSE LF WAS NOT A PARTNER IN THE APPELLANT FIRM, BUT BEING A CONCERN OF THE GROUP, HE WAS HANDLING THE REAL AFFAIRS OF THE APPELLANT FIRM. THE CLAIM OF THE APPELLANT THAT MR. JABIR WAS A BOY OF 22 YEARS, DOES NOT HAVE MUCH BEARING ON THE ISSUE BEC AUSE HE WAS MAJOR AND WAS ALSO ACTIVELY HANDLING THE AFFAIRS OF THE APPELLAN T GROUP. ANOTHER CLAIM OF THE APPELLANT THAT STATEMENT WAS NOT VOLUNTARY IS ALSO FAR FROM TRUTH FOR THE REASON THAT THE ISSUE WAS CLEARED BY MR. JABIR HIMSELF WH ILE ANSWERING TO QUESTION NO. 19 & 20, WHEREIN HE AFFIRMED THAT THE STATEMENT WA S MADE STATING THE TRUTH AND THE ABSENCE OF HIS FATHER AT THE TIME OF SEARCH WA S RELEVANT ONLY TO THE EXTENT THAT HE COULD NOT ANSWER ALL THE QUESTIONS PUT TO HIM. THE ARGUMENT OF THE LEARNED COUNSEL FOR THE APPELLANT THAT THE STATEME NT MADE BY MR. JABIR CAN AT BEST BE RELIED UPON FOR THE YEAR 2007-08 AND THAT TOO TILL THE DATE OF SEARCH I.E., 12.09.2007 DOES NOT HAVE MUCH MERIT. THIS IS FOR THE REASON THAT MR. JABIR ELABORATED UPON THE MODUS OPERANDI OF THE APPELLAN T ALONG WITH THE REASONING THAT ATTEMPT WAS TO REDUCE THE INCIDENCE OF SALES TAX. A PERUSAL OF BOOK RESULTS, OF THE APPELLANT FOR VARIOUS YEARS REVEAL AS UNDER : SL. NO. A.Y. TURNOVER SHOWN (RS.) GP RATE DECLARED (%) 1. 2002-03 37,12,442 29.94 2. 2003-04 61,26,928 18.21 3. 2004-05 52,24,895 17.06 4. 2005-06 34,82,459 19.93 5. 2006-07 17,50,930 20.08 6. 2007-08 12,22,695 5.79 7. 2008-09 13,06,703 9 A PERUSAL OF ABOVE BOOK RESULTS, REVEAL ERRATIC T REND OF TURNOVER AND GP DECLARED BY THE APPELLANT. IT CAN BE SEEN THAT TH E VARIATION IN GPO RATE IS VERY WIDE RANGING FROM 5.9% TO 29.94% WHICH IS TOTALLY UNREASONABLE IN THE LINE OF BUSINESS. IN A SIMILAR MANNER, THE TURNOVER SHOWN BY THE APPELLANT HAS GONE DOWN TO RS. 13,06,703 IN A.Y. 2008-09 FROM A TURNO VER OF RS. 37,12,442 IN A.Y. 2002-03 ALONG WITH STEEP FALL IN GP RATE. THIS IS HIGHLY ABNORMAL FOR THE REASON THAT IN A NORMAL COURSE AND WITH INFLATIONARY TREN D THE TURNOVER SHOULD HAVE GRADUALLY INCREASED INSTEAD OF A SHARP FALL. THES E FACTS FORM STRONG CIRCUMSTANTIAL EVIDENCES TO ESTABLISH THAT THE APP ELLANT WAS NOT DISCLOSING THE BUSINESS TRANSACTIONS IN THE BOOKS OF ACCOUNTS IN A TRUTHFUL MANNER AND THERE WAS AN APPARENT EVIDENCE THAT THE APPELLANT WAS IN DULGING IN SUPPRESSION OF TURNOVER AND PROFIT THERE FROM IN A REGULAR MANNER AND FOR ALL THE ASSESSMENT YEARS. THE DEPOSITION OF SALESMAN OF THE APPELLAN T FIRM, AND MR. JABIR WHO WAS MANAGING THE AFFAIRS OF THE FIRM IN FACT, DESCRIBE D THE MODUS OPERANDI OF THE APPELLANT AS A REGULAR PRACTICE AND NOT FOR ANY SP ECIFIC PERIOD. THE SAME THEREFORE HAS TO HAVE CONSEQUENCE FOR ALL ASSESSME NT YEARS. THE STATEMENT MADE BY MR. JABIR WAS INSTANT AND EXPLAINED THE MO DUS OPERANDI OF THE I.T.A. NOS. 127-133/COCH/2011 6 APPELLANT FIRM. THE SAME WAS ALASO DULY CORROBORA TED BY EXPLICIT EVIDENCES IN THE FORM OF TAG WITH THE FURNITURE IN A CODED LANG UAGE AND CORRESPONDING SALE INVOICES WHEREIN ONLY HALF OF THE ACTUAL SALE PRIC E WAS RECORDED. THIS MODUS OPERANDI OF THE GROUP CONCERNS WAS DULY AND SIMULT ANEOUSLY CONFIRMED IN AN INDEPENDENT MANNER BOTH BY MR. JABIR, PARTNER OF M /S. CLASSY THE ANTIQUE DESIGNED FURNITURE, A SISTER CONCERN OF THE APPELL ANT FIRM, AND BY MR. V. AHAMED SALESMAN OF APPELLANT FIRM. INSPECTION BY INTELLIG ENCE OFFICER OF COMMERCIAL TAXES AND DISCOVERY OF SUBSTANTIAL STOCK DISCREPAN CY AS REFERRED TO IN THE ASSESSMENT ORDER FURTHER CONFIRMED THAT THE APPELL ANT WAS NOT RECORDING THE BUSINESS TRANSACTIONS IN THE BOOKS OF ACCOUNTS IN A TRUTHFUL MANNER. I, THEREFORE, HOLD THAT ON THE BASIS OF MATERIAL AND EVIDENCES A VAILABLE ON RECORD, THE ASSESSING OFFICER WAS JUSTIFIED IN GIVING A FINDIN G THAT THE APPELLANT WAS INDULGING IN SUPPRESSION OF SALES. THE SAME IS ACCORDINGLY CONFIRMED. THE CONSEQUENTIAL ADDITION OF RS. 17,81,971 MADE BY THE ASSESSING OF FICER ON THIS ACCOUNT IS ALSO ACCORDINGLY CONFIRMED. THESE GROUNDS OF APPEAL AR E ACCORDINGLY REJECTED. 9. WE NOTICE THAT THE AO HAS CORROBORATED THE FACT OF SUPPRESSION OF SALES WITH THE PRICE TAG AVAILABLE WITH THE FURNITURE ITEMS. THE ASSESSEE HAS, HOWEVER, FAILED TO CONTROVERT THIS FINDING OF THE AO BY BRINGING ANY M ATERIAL ON RECORD. THOUGH THE LD COUNSEL FOR THE ASSESSEE HAS CONTENDED THAT SHRI A. JABIR IS A STRANGER TO THE ASSESSEE FIRM, YET WE ARE UNABLE TO ACCEPT THE SAID CONTENTI ON FOR THREE REASONS VIZ., (A) SHRI A.JABIR IS THE SON OF THE MANAGING PARTNER OF THE A SSESSEE FIRM, (B) THE SALES MAN OF THE ASSESSEE FIRM HAS CONFIRMED THAT SHRI A.JABIR O NLY FIXES THE SELLING RATE AND (C) MANAGEMENT OF BUSINESS AFFAIRS BY THE FAMILY MEMBER S WHO ARE NOT LEGAL OWNERS IS NOT UNCOMMON IN THE TRADE CIRCLES. HENCE, ON A CONSP ECTUS OF THE MATTER, WE FIND NO INFIRMITY IN THE ORDER OF LD CIT(A) ON THIS ISSUE. 10. THE OTHER TWO ADDITIONS RELATE TO THE PROPO RTIONATE DISALLOWANCE OF TELEPHONE AND CAR EXPENSES TOWARDS PERSONAL USE OF THE PARTNE RS. IN THE ABSENCE OF ANY EVIDENCE TO SHOW THAT THEY WERE NOT USED FOR PERSON AL PURPOSES, WE DO NOT FIND ANY INFIRMITY IN MAKING ESTIMATED DISALLOWANCE OF A POR TION OF THE TELEPHONE AND CAR EXPENSES. ACCORDINGLY, WE UPHOLD THE ORDER OF LD C IT(A) ON THIS ISSUE. I.T.A. NOS. 127-133/COCH/2011 7 11. IN THE RESULT, ALL THE APPEALS OF THE ASSES SEE ARE DISMISSED. PRONOUNCED ACCORDINGLY ON 07-09-2012 SD/- SD/- (N.R.S.GANESAN) (B.R.BASKARAN) JUDICIAL MEMBER ACCOUNTANT MEMBER PLACE: KOCHI DATED: 7TH SEPTEMBER, 2012 GJ COPY TO: 1. M/S. KOTTAKKAL WOOD COMPLEX, MAIN ROAD, KOTTAKKA L. 2. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL C IRCLE-2, KOZHIKODE. 3. THE COMMISSIONER OF INCOME-TAX (APPEALS)-I, KOCH I. 4. THE COMMISSIONER OF INCOME-TAX, CENTRAL, KOCHI. 5. D.R., I.T.A.T., COCHIN BENCH, COCHIN. 6. GUARD FILE. BY ORDER (A SSISTANT REGISTRAR) ITAT , COCHIN