Blue Star Civil Engineering Company Pvt. Ltd., Purba Medinipur V. ACIT, CIR-27, HALDIA, Purba Medinipur

ITA 1434/KOL/2015

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 6107 (ITAT-KOLKATA)
• Duration Of Justice: 2 year(s) 7 month(s) 2 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 06-07-2018
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: B
• Assessment Year: 2011-2012
• Appeal Filed On: 04-12-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: A BHATTACHARJEE
• Assessee Lawyers: M GHOSH
• Keywords: Assessment record
• Section: 143(3)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL D BENCH : KOLKATA [BEFORE HONBLE SHRI M.BALAGANESH, AM & HONBLE SHR I S.S.VISWANETHRA RAVI, JM] I.T.A NO. 1434/KOL/2015 ASSESSMENT YEAR : 2011-1 2 BLUE STAR CIVIL ENGINEERING COMPANY -VS- ACIT, CIRCLE-HALDIA [PAN: AACCB 2247 B] (APPELLANT) (RESPONDEN T) FOR THE APPELLANT : SHRI M. GHOSH, ADV OCATE FOR THE RESPONDENT : SHRI A. BHATTACHARJE E, ADDL. CIT DATE OF HEARING : 26.06.2018 DATE OF PRONOUNCEMENT : 06.07.2018 ORDER PER M.BALAGANESH, AM 1. THIS APPEAL BY THE ASSESSEE ARISES OUT OF THE O RDER OF THE LEARNED COMMISSIONER OF INCOME TAX(APPEALS)-7, KOLKATA [IN SHORT THE LD CIT (A)] IN APPEAL NO.537/CIT(A)- 7/CIR-27/14-15 DATED 16.09.2015 AGAINST THE ORDER P ASSED BY ACIT, CIRCLE- HALDIA, [ IN SHORT THE LD AO] UNDER SECTION 143(3) OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT) DATED 12.03.2014 FOR THE ASSESSMENT YEAR 2011-12. 2. AT THE OUTSET WE FIND THAT THERE IS A DELAY IN F ILING THE APPEAL FOR 5 DAYS. WE HAVE GONE THROUGH THE CONDONATION PETITION FILED BY THE ASSESSEE, WE ARE CONVINCED WITH THE REASONING GIVEN THEREON FOR THE DELAY. ACCORDINGLY, WE CONDONE THE DELAY IN FILING THE APPEAL BY THE ASSESSEE AND ADMIT THE APPEAL FOR AD JUDICATION. 2 ITA NO.1434/KOL/2015 BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD. A.YR. 2011-12 2 3. THE FIRST PRELIMINARY GROUND RAISED BY THE ASSE SSEE IS AS TO WHETHER THE CASE WAS PROPERLY SELECTED FOR SCRUTINY IN ACCORDANCE WITH T HE SCRUTINY GUIDELINES PRESCRIBED BY THE CBDT VIS--VIS BY OBTAINING PROPER APPROVAL THE REON. 3.1. THE BRIEF FACTS OF THIS ISSUE IS THAT THE ASSE SSEE HAD FILED ITS RETURN OF INCOME FOR THE ASSESSMENT YEAR 2011-12 ON 29.09.2011 DECLARING TOT AL INCOME OF RS. 38,34,845/-. THE RETURN WAS PROCESSED U/S 143(1) OF THE ACT. LATER T HE CASE WAS SELECTED FOR SCRUTINY. THE ASSESSEE RAISED PRELIMINARY OBJECTION BEFORE THE LD . CIT(A) THAT THE RETURN FOR THE ASSESSMENT YEAR 2011-12 FILED BY THE ASSESSEE COMP ANY WAS ILLEGALLY MANUALLY SELECTED FOR SCRUTINY AND BY NOT FOLLOWING THE GUIDELINES PR ESCRIBED UNDER THE CENTRAL ACTION PLAN OF CBDT FIXING THE CRITERION FOR SELECTION OF CASES FOR SCRUTINY THEREON. ACCORDINGLY, IT PLEADED BEFORE THE LD. CIT(A) THAT THE ENTIRE ASSESSMENT FRAMED BY THE LD. AO IS TO BE TREATED IS VOID AB INITIO AND LIABL E TO BE QUASHED. THE ASSESSEE IN SUPPORT OF THIS ARGUMENT PLACED RELIANCE ON THE ORDER SHEET ENTRY OF THE LD. AO WHEREIN IT WAS MENTIONED BY THE AO THAT THE CASE HAS BEEN SELECTED FOR THE PURPOSE OF SCRUTINY BY OBTAINING PREVIOUS APPROVAL OF ADDITIONAL CIT, RANG E-HALDIA AS PER CENTRAL ACTION PLAN GUIDELINE FOR FINANCIAL YEAR 2012-13. NOTICE I SSUED U/S 143(2) OF THE IT ACT FIXING THE DATE OF HEARING ON 04.02.2013. THE LD. CIT(A) O BSERVED THAT AS PER THE CENTRAL ACTION PLAN ISSUED BY THE CBDT, IN CASE OF MOFUSSIL AREAS, THE ASSESSING OFFICER COULD SELECT THE CASES FOR SCRUTINY AFTER RECORDING THE R EASONS FOR THE SELECTION AND APPROVAL OF THE CONCERNED RANGE HEAD WHO HAPPENED TO BE THE SEN IOR MOST OFFICER IN THAT STATION. THE LD. CIT(A) OBSERVED THAT THE ACCORDINGLY THE AP PROVAL GIVEN BY THE ADDITIONAL CIT-HALDIA IS IN ORDER AND IN ACCORDANCE WITH THE C ENTRAL ACTION GUIDELINE WHICH CANNOT BE QUESTIONED BY THE ASSESSEE. HE ALSO OBSE RVED THAT DURING THE APPEAL THIS GROUND WAS NOT PRESSED BY THE ASSESSEE AND ACCORDI NGLY DISMISSED THE GROUND OF THE ASSESSEE AS NOT PRESSED. AGGRIEVED, THE ASSESSEE IS IN APPEAL BEFORE US. 3 ITA NO.1434/KOL/2015 BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD. A.YR. 2011-12 3 3.2. WE HAVE HEARD RIVAL SUBMISSIONS. THE LD. AR BE FORE US PLACED RELIANCE ON COPIES OF VARIOUS ORDER SHEET NOTINGS TO ARGUE THAT THE LD. A O PLACED RELIANCE ON CENTRAL ACTION PLAN GUIDELINES OF CBDT ISSUED FOR FINANCIAL YEAR 2 012-13 AND SELECTED THE CASE FOR SCRUTINY FOR ASSESSMENT YEAR 2011-12 MANUALLY, WHI CH ACCORDING TO HIM, WAS ILLEGAL AND HENCE THE ENTIRE ASSESSMENT FRAMED PURSUANT TO SUCH MANUAL SELECTION OF CASE FOR SCRUTINY IS LIABLE TO BE QUASHED. WE HAVE GONE THRO UGH THE ENTIRE ASSESSMENT RECORDS. FROM THE SAME, WE FIND THAT THE LD. AO HAD DULY OBT AINED PERMISSION/APPROVAL FROM THE RANGE HEAD OF HALDIA I.E. ADDITIONAL CIT-HALDIA BEF ORE SELECTING THE CASE FOR SCRUTINY MANUALLY. WE HAVE GONE THROUGH THE GUIDELINES ISSUE D UNDER CENTRAL ACTION PLAN BY CBDT IN F. NO. 225/93/2009/ ITA-II DATED 08.09.2010 ON THE SUBJECT OF IDENTIFICATION OF CASES FOR SCRUTINY THROUGH MANUAL SELECTION FOR THE FINANCIAL YEAR 2010-11 AS UNDER: REFERENCE IS INVITED TO BOARD'S-LETTER OF EVEN NUM BER DATED 28.07.2010 ON THE SUBJECT ABOVE. 2. THE BOARD HAS DECIDED TO MODIFY THE AFORESAID GU IDELINES REGARDING SELECTION OF CASES FOR SCRUTINY AS UNDER: A) IN PARAGRAPH (C) OF THE AFORESAID INSTRUCTION, THE WORDS 'RUPEES TEN OR MORE' WERE INADVERTENTLY MENTIONED, WHICH MAY BE READ AS 'RUPE ES 10 CRORE OR MORE'. B) THE FOLLOWING ADDITIONAL CATEGORY OF CASES MAY ALSO BE SELECTED MANUALLY FOR SCRUTINY: 'RETURNS OF INCOME OF TRUSTS/ AOPS ETC, F ILED IN RETURN FORM ITR-7 WHERE GROSS RECEIPTS EXCEED RS.5 CRORE' C) IN PARTIAL MODIFICATION OF THE CATEGORY (G) OF GUID ELINES DATED 28.07.2010, WHEREIN CCIT/DGIT WERE AUTHORIZED TO APPROVE SELECTION OF C ASES, THE FOLLOWING DECISION HAS BEEN TAKEN: I. THE ASSESSING OFFICERS IN MOFUSSIL STATIONS MAY SELECT A MAXIMUM NUMBER OF TWENTY FIVE CASES PER A.O AFTER RECORDING REASONS FOR THE SELECTION AND WITH THE APPROVAL OF THE ADDL. CIT/JCIT IN CHARGE OF THE RANGE* IF THE ADDI. CIT/JCIT HAPPENS TO BE THE SENIOR MOST OFFICER IN THE STATION. HOWEVER IF THE SENIOR MOST OFFICER AT THE STATION IS OF THE RANK OF COMMISSIONER, APPROVAL IN THIS REGARD SHALL BE G IVEN BY THE COMMISSIONER. FROM THE ABOVE IT IS VERY CLEAR THAT THE ASSESSEE S ITUATED IN MOFUSSIL STATION AND ASSESSED THEREON WOULD FALL UNDER THE CONTROL OF THE RANGE H EAD OF THAT STATION. IT IS NOT IN DISPUTE THAT THE ADDITIONAL CIT-HALDIA IS THE RANGE HEAD OF HALDIA AND ACCORDINGLY THE APPROVAL FOR MANUAL SELECTION OF CASE FOR SCRUTINY GIVEN BY ACIT-HALDIA ON 29.09.2012 4 ITA NO.1434/KOL/2015 BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD. A.YR. 2011-12 4 IS IN ORDER AND CONSEQUENTIALLY THE ASSESSMENT FRAM ED THEREON IS NOT LIABLE TO BE QUASHED AS VOID AB INITIO. WE ALSO FIND THAT THE FINANCIAL YEAR 2012-13 MENTIONED BY THE LD. AO IN THE ORDER SHEET APPEARS TO BE ONLY TYPOGRAPHICAL ERROR AS ADMITTEDLY THE PAPERS WERE INDEED MOVED BY HIM THROUGH PROPER CHANNEL FOR OBTA INING APPROVAL FOR MANUAL SELECTION OF CASE FOR SCRUTINY BEFORE THE LD. ADDIT IONAL CIT -HALDIA FOR THE ASSESSMENT YEAR 2011-12 ONLY, WHICH IS EVIDENT AND APPARENT FR OM THE ASSESSMENT RECORDS. HENCE THIS ERROR COMMITTED BY THE LD. AO IN THE ORDER SHE ET IS CONSTRUED AS TYPOGRAPHICAL ERROR AND IS HEREBY CONDONED. IN VIEW OF THE AFORESAID OB SERVATIONS THE GROUND NO.1 RAISED BY THE ASSESSEE IS DISMISSED. 4. THE NEXT GROUND RAISED BY THE ASSESSEE IS AS TO WHETHER THE LD. CIT(A) WAS JUSTIFIED IN UPHOLDING THE DISALLOWANCE MADE TOWARDS PRIOR PE RIOD EXPENSES IN THE SUM OF RS. 3,04,500/-, IN THE FACTS AND CIRCUMSTANCES OF THE C ASE. 4.1. THE BRIEF FACTS OF THIS ISSUE IS THAT THE ASSE SSEE HAD INCURRED CERTAIN EXPENDITURE TO THE TUNE OF RS. 3,04,500/- AND HAD PAID VAT THEREON IN THE SUM OF RS. 12,180/-. THE TOTAL BILL AMOUNT FROM M/S J & M CONSTRUCTION WAS R S. 3,16,680/-. THIS BILL DATED 24.12.2009 FROM M/S J & M CONSTRUCTION AFTER SEVERA L NEGOTIATIONS WAS BROUGHT DOWN TO THE TUNE OF RS. 3,16,680/- AND ULTIMATELY THE SA ME WAS ENTERED AND ACCOUNTED BY THE ASSESSEE ON 10.04.2010 I.E. FINANCIAL YEAR 2010-11 RELEVANT TO ASSESSMENT YEAR 2011-12. THE ASSESSEE EXPLAINED BEFORE THE LD. AO THE REASON S FOR THE DELAYED ACCOUNTING OF THIS PARTICULAR BILL DURING THE YEAR UNDER CONSIDERATION . THE ASSESSEE STATED THAT THERE WAS DISPUTE IN THE RATE AND THE SAID DISPUTE GOT SETTLE D WITH THE SAID PARTY ON 10.04.2010 AND ACCORDINGLY, THE ASSESSEE DECIDED TO ACCOUNT THE EX PENDITURE TOGETHER WITH THE VAT PORTION THEREON IN FINANCIAL YEAR 2010-11 RELEVANT TO ASSESSMENT YEAR 2011-12. THE LD. AO HOWEVER DID NOT AGREE TO THIS CONTENTION AND DIS ALLOWED THE SAME AS EXPLAINED NOT RELATABLE TO THE YEAR UNDER CONSIDERATION. THIS ACT ION OF THE LD. AO WAS UPHELD BY THE LD. CIT(A) FOR THE SAME REASON. AGGRIEVED THE ASSES SEE IS IN APPEAL BEFORE US. 5 ITA NO.1434/KOL/2015 BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD. A.YR. 2011-12 5 4.2. WE HAVE HEARD RIVAL SUBMISSIONS. AT THE OUTSET WE FIND THAT THERE IS NO DISPUTE THAT THE ASSESSEE HAD INCURRED THIS EXPENDITURE FOR THE PURPOSE OF ITS BUSINESS. IT IS NOT IN DISPUTE THAT THE SAID EXPENDITURE TOGETHER WITH THE BILL OF M/S J & M CONSTRUCTION IS NOT GENUINE. THE ONLY POINT THAT ARISES FOR CONSIDERATI ON IS THAT THE SAID BILLS OF M/S J & M CONSTRUCTION DATED 24.12.2009 WHICH FALLS IN FINAN CIAL YEAR 2009-10, WHEREAS THE SAME HAS BEEN ACCOUNTED BY THE ASSESSEE AS EXPLAINED IN FINANCIAL YEAR 2010-11. WE FIND THAT THE ASSESSEE HAD GIVEN PROPER EXPLANATION FOR THE S AID DELAYED ACCOUNTING OF THE BILL. WE ALSO FIND THOUGH THE TOTAL BILL AMOUNT OF M/S J & M CONSTRUCTION IS RS. 3,16,680/- COMPRISING OF EXPENDITURE PORTION OF RS. 3,04,500/- AND VAT PORTION OF RS. 12,180/-, THE LD. AO HAD DISALLOWED ONLY THE EXPENDITURE PORT ION OF RS. 3,04,500/-, MEANING THEREBY THE VAT PORTION OF RS. 12,180/- HAS BEEN AC CEPTED BY THE LD. AO AS EXPENDITURE INCURRED DURING THE ASSESSMENT YEAR 2011-12. WE FIN D THAT THERE IS NO MALA FIDE INTENTION ON THE PART OF THE ASSESSEE IN RESPECT O F THIS BILL AND NOT ACCOUNTING THE SAME IN THE EARLIER YEAR. WE FIND THAT THE CO-ORDINATE B ENCH OF THIS TRIBUNAL IN THE CASE OF HINDUSTHAN GUM AND CHEMICALS LTD. VS. ITO REPORTED IN 23 SOT143 HAD ALLOWED THE CLAIM OF PRIOR PERIOD EXPENSES IN SIMILAR CIRCUMSTA NCES. OUR VIEW IS FURTHER ENDORSED BY THE FOLLOWING DECISIONS OF HONBLE DELHI HIGH COURT : A) CIT VS. JAGATJIT INDUSTRIES LTD. REPORTED IN 339 IT R 382 (DELHI) B) CIT VS. MODIPON LTD. REPORTED IN 334 ITR 102 RESPECTFULLY FOLLOWING THE AFORESAID DECISIONS AND APPLYING THE SAME TO THE FACTS OF THE INSTANT CASE, WE ALLOW THE CLAIM OF PRIOR PERIOD EX PENSES OF RS. 3,04,500/- FOR ASSESSMENT YEAR 2011-12 AND ACCORDINGLY, GROUND NO. 2 RAISED BY THE ASSESSEE IS ALLOWED. 5. THE LAST ISSUE TO BE DECIDED IN THIS APPEAL IS A S TO WHETHER THE LD. CIT(A) WAS JUSTIFIED IN UPHOLDING THE ADDITION MADE IN THE SUM OF RS. 15,18,652/-, IN THE FACTS AND CIRCUMSTANCES OF THE CASE. 6 ITA NO.1434/KOL/2015 BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD. A.YR. 2011-12 6 5.1. THE BRIEF FACTS OF THIS ISSUE IS THAT THE ASSE SSEE IS A CIVIL CONTRACTOR AND WAS ENGAGED IN THE BUSINESS OF CIVIL CONSTRUCTION INCLUDING EXC AVATION AND EVACUATION OF DRY FLY ASH FROM THE SITE OF WEST BENGAL POWER DEVELOPMENT CORP ORATION LTD. (WBPDCL) AND DURGAPUR PROJECTS LTD. (DPL). THE ASSESSEE COMPANY DID NOT POSSESS THE REQUISITE INFRASTRUCTURE TO EXCAVATE AND EVACUATE THE DRY FLY ASH FROM THE THERMAL POWER PLANT AND ACCORDINGLY SUB-CONTRACTED THE SAID WORK TO VAR IOUS SUB-CONTRACTORS INCLUDING M/S ELECON ENGINEERING COMPANY, M/S NOVEL ENGINEERING A ND M/S M CONSTRUCTION. THE ASSESSEE EXPLAINED BEFORE THE LD. AO THAT WEST BENG AL POWER DEVELOPMENT CORPORATION LTD./ KOLAGHAT THERMAL POWER STATION HAD ADJUSTED R S. 15,18,652/- DURING THE YEAR AGAINST THE BILL ON ACCOUNT OF ADMINISTRATIVE EXPEN SES FOR TAKING DELIVERY OF DRY FLY ASH FROM KOLAGHAT THERMAL POWER STATION. AS PER THE CO NTRACT WITH WBPDCL, THE ASSESSEE HAS TO PAY RS. 6 PER METRIC TONNE TOWARDS ADMINISTRATIVE CHARGES TO WBPDCL FOR EXCAVATING AND EVACUATING DRY FLY ASH FROM THE RMAL POWER STATION. THE ASSESSEE IN TURN SUB-CONTRACTED THIS WORK TO M/S NOVEL ENGINEER ING AND REALIZED THE ADMINISTRATIVE CHARGES AS AND WHEN THE BILLS ARE RAISED BY THEM. T HE LD. AO HOWEVER OBSERVED THAT THE ASSESSEE HAS NOT SHOWN ANY INCOME ON SALE OF DRY FL Y ASH AND GENUINENESS OF THE TRANSACTION OF THE ASSESSEE WITH THE SUB-CONTRACTOR HAS NOT BEEN CONCLUSIVELY PROVED BY THE ASSESSEE. IN VIEW OF THIS, THE AMOUNT OF ADJUST MENT OF ADMINISTRATION CHARGES IN THE SUM OF RS. 15,18,652/- AS ADJUSTED BY WBPDCL WAS AD DED AS INCOME OF THE ASSESSEE IN THE ASSESSMENT. THE ASSESSEE PLEADED THAT THOUGH IT HAD INCURRED THE EXPENDITURE IN THE FORM OF ADMINISTRATIVE CHARGES AT RS. 6 PER METRIC TONNE, HAD EVENTUALLY REALIZED THE SAME FROM ITS SUB-CONTRACTORS WHICH IS QUITE EVIDEN T FROM THE LEDGER DETAILS OF THE SUB- CONTRACTOR, IN SUPPORT OF WHICH HE PLACED THE RELEV ANT LEDGER ACCOUNT. 5.2. THE LD. CIT(A) OBSERVED THAT IN CASE THE ASSES SEE HIMSELF WAS TAKING THE DRY FLY ASH MINIMUM TO THE EXTENT OF CHARGES COLLECTED BY T HE PAYEE, THE SAME WOULD BE COST OF ASSET AND ACCORDINGLY CLOSING STOCK THEREON SHOULD HAVE BEEN DECLARED BY THE ASSESSEE. THE ASSESSEE NEITHER DECLARED THE ASSET NOR DECLARE D THE EXPENSES RECOVERABLE FROM THE 7 ITA NO.1434/KOL/2015 BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD. A.YR. 2011-12 7 SUB-CONTRACTORS. ACCORDINGLY, HE UPHELD THE ACTION OF THE LD. AO. AGGRIEVED, THE ASSESSEE IS IN APPEAL BEFORE US. 5.3. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSE D THE MATERIAL AVAILABLE ON RECORD. WE HAVE GONE THOUGH THE STATEMENT RAISED BY THE CON CERNED PARTIES TO THE TUNE OF RS. 15,18,662/- TOWARDS ADMINISTRATION CHARGES WHICH IS ENCLOSED IN PAGE 54 OF THE PAPER BOOK FILED BEFORE US. FROM THE PERUSAL OF THE SAID STATEMENT WE FIND THAT OPENING STOCK AS ON 01.04.2010 WAS RS. 2,06,70,213/- AND BILLS RA ISED DURING THE FINANCIAL YEAR 2010- 11 WAS RS. 6,32,538/- AND AMOUNT ADJUSTED AGAINST T HE TOTAL BILLS WAS RS. 15,18,662/-. THE CLOSING BALANCE AS ON 31.03.2011 WAS ACCORDINGL Y ARRIVED AT RS. 11,80,919/- WHICH WAS SHOWN AS LIABILITY IN THE BALANCE SHEET OF THE ASSESSEE. WE HAVE ALSO GONE THROUGH THE LEDGER ACCOUNT OF THE ASSESSEE AS APPEARING IN THE BOOKS OF NOVEL ENGINEERING (I.E. SUB-CONTRACTOR) WHEREIN IT IS EVIDENT THAT THE ASSE SSEE HAD INDEED REALIZED ADMINISTRATION CHARGES FROM THE SUB-CONTRACTOR. SO THESE FACTS CON CLUSIVELY PROVE THAT THERE IS ABSOLUTELY NO CASE MADE OUT BY THE REVENUE FOR MAKI NG AN ADDITION IN THE SUM OF RS. 15,18,662/- ON ACCOUNT OF ADMINISTRATIVE CHARGES. A CCORDINGLY, GROUND RAISED BY THE ASSESSEE IS ALLOWED. 6. THE GROUND NO. 4 IS GENERAL IN NATURE AND DOES N OT REQUIRE ANY SPECIFIC ADJUDICATION. 7. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PAR TLY ALLOWED. ORDER PRONOUNCED IN THE COURT ON 06.07.2018 SD/- SD/- [S.S. VISWANETHRA RAVI] [ M.BAL AGANESH ] JUDICIAL MEMBER ACCOUNTANT MEM BER DATED : 06.07.2018 SB, SR. PS 8 ITA NO.1434/KOL/2015 BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD. A.YR. 2011-12 8 COPY OF THE ORDER FORWARDED TO: 1. BLUE STAR CIVIL ENGINEERING COMPANY PVT. LTD., V ILLAGE-SANTIPUR, P.O.-MECHEDA, PURBA MEDINIPUR-721137, WEST BENGAL. 2. ACIT, CIRCLE-27, HALDIA, BASUDEVPUR, P.O.-KHANJA NCHAK, HALDIA, PURBA MEDICINE- 721602. 3..C.I.T.- 4. C.I.T.- KOLKATA. 5. CIT(DR), KOLKATA BENCHES, KOLKATA. TRUE COPY BY ORDER SENIOR PRIVAT E SECRETARY HEAD OF OFFICE/D.D.O., ITAT, KOLKATA BENCHE S