Smt Sheila Sen.(L/H - OF LATE Bimalendu Sen), Kolkata V. I.T.O Wd - 2(1),kolkata, Kolkata

ITA 1764/KOL/2013

• Counselvise Citation: [2017] 127 COUNSELVISE.COM (IT) 1527 (ITAT-KOLKATA)
• Duration Of Justice: 4 year(s) 3 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-09-2017
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 26-04-2017
• Assessment Year: 2006-2007
• Appeal Filed On: 06-06-2013
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Keywords: Unexplained investment; Source of fund
• Section: 143(3); 142(1); 234B; 12A

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH : KOLKATA [BEFORE HONBLE SRI P.M.JAGTAP, AM & SRI N.V.VASU DEVAN, JM] I.T.A NO. 1764/KOL/2 013 ASSESSMENT YEAR : 2 006-07 SMT. SHEILA SEN -VS.- I.T.O., WARD-2(1) L/H LATE BIMALENDU SEN, KOLKATA. KOLKATA [PAN : ALPPS 5849 B] (APPELLANT) (RESPONDENT) FOR THE APPELLANT : SHRI SOUMITRA CHOU DHURY, ADVOCATE FOR THE RESPONDENT : SHRI.SALLONG YADEN, ADDL . CIT DATE OF HEARING : 05.09.2017. DATE OF PRONOUNCEMENT : 13.09.2017. ORDER PER N.V.VASUDEVAN, JM THIS IS AN APPEL FILED BY THE ASSESSEE AGAINST TH E ORDER DATED 14.02.2013 OF CIT(A)-XX, KOLKATA RELATING TO A.Y.2006-07. 2. THOUGH THE ASSESSEE HAS RAISED SIX GROUNDS OF APPEAL, AT THE TIME OF HEARING OF THE APPEAL, THE LD. COUNSEL FOR THE SUBMITTED THAT GROU NDS NO. 2 AND 3 ALONE ARE PRESSED FOR ADJUDICATION. GROUND NO.4 WAS NOT PRESSED. GROUND N O.1 IS GENERAL IN NATURE AND CALLS FOR NO SPECIFIC ADJUDICATION AND GROUND NO.5 IS WIT H REGARD TO CHARGING OF INTEREST U/S 234A, 234B AND 234C OF THE INCOME TAX ACT, 1961 (AC T) WHICH IS PURELY CONSEQUENTIAL AND GROUND NO.6 IS AGAIN GENERAL IN N ATURE AND DOES NOT REQUIRE ANY SPECIFIC ADJUDICATION. 3. GROUNDS NO. 2 AND 3 RAISED BY THE ASSESSEE CA N BE ADJUDICATED TOGETHER. THESE GROUNDS READ AS FOLLOWS: 2. FOR THAT ON THE FACTS OF THE CASE THE LD. CIT(A ) WAS WRONG IN DITTOING THE ORDER OF THE A.O. AND CONFIRMING THE ADDITON OF RS.10,50, 000/- ON ACCOUNT OF UNDISCLOSED 2 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 2 INVESTMENT FROM UNDISCLOSED INCOME WHICH IS COMPLET ELY ARBITRARY UNJUSTIFIED AND ILLEGAL. 3. FOR THAT ON THE FACTS OF THE CASE THE LD. CIT(A) WAS WRONG IN DITTOING THE ORDER OF THE A.O. AND CONFIRMING THE ADDITON OF RS.74,72, 735/- ON ACCOUNT OF INCOME FROM FIRM AND SALE PROCEEDS WHICH IS COMPLETELY AR BITRARY UNJUSTIFIED AND ILLEGAL. 4. SHRI BIMALENDU SEN, AN INDIVIDUAL FILED HIS RET URN OF INCOME FOR A.Y.2006-07 ON 27.03.2007 DECLARING TOTAL INCOME OF RS.5,12,419/-. THE AO ISSUED NOTICES U/S 143(2) AND 142(1) OF THE ACT CALLING UPON THE ASSESSEE TO FURNISH CERTAIN PARTICULARS FOR THE PURPOSE OF FRAMING THE ASSESSMENT U/S 143(3) OF THE ACT. UNFORTUNATELY BIMALENDU SEN DIED ON 02.11.2008 AND HIS WIFE SMT. SHEILA SEN AND THE AUTHORISED REPRESENTATIVE OF THE ASSESSEE PARTICIPATED IN THE ASSESSMENT PROCEED INGS. ACCORDING TO THE AO THERE WAS AN ANNUAL INFORMATION REPORT (AIR) RECEIVED BY THE AO WHICH WAS TO THE EFFECT THAT THE ASSESSEE HAD MADE AN INVESTMENT OF RS.10,50,000 /- IN MUTUAL FUND OF STANDARD CHARTERED BANK AS ON 31.03.2006. THE LEGAL REPRESEN TATIVE OF THE ASSESSEE COULD NOT EXPLAIN THE SOURCE OF THE FUNDS OUT OF WHICH THESE INVESTMENTS WERE MADE AND THEREFORE A SUM OF RS.10,50,000/- WAS ADDED TO THE TOTAL INCO ME OF THE ASSESSEE AS UNEXPLAINED INVESTMENT MADE FROM UNDISCLOSED SOURCE OF INCOME. 5. THE AO ALSO NOTICED FROM VARIOUS BANK STATE MENTS OF THE ASSESSEE THAT CASH AND CHEQUE DEPOSITS WERE MADE IN THREE BANK ACCOUNTS MA INTAINED BY THE ASSESSEE, TWO BANK ACCOUNTS WITH STANDARD CHARTERED BANK AND THE OTHER WITH HSBC BANK. THE DETAILS OF THE CASH AND CHEQUE DEPOSITS MADE IN THE AFORESAID BANK ACCOUNTS WERE AS FOLLOWS :- STANDARD CHARTERED BANK : KOLKATA MAIN BRANCH A/C N O. 322-1-0419397 CHEQUE DEPOSITS : CASH DEPOSITS 01.06.2005 RS.2,56,846/- 01.02.2006 RS.3,00,000/- RS.13,00,000/- 27.02.2006 RS.5,00,000/- 3 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 3 16.06.2005 RS.7,93,222/- 08.03.2006 RS.1,50,000/- 12.09.2005 RS.4,34,430/- 21.03.2006 RS.1,00,000/- 12.01.2006 RS.3,29,015/- 24.03.2006 RS.4,43,754/- RS.35,57,267/- RS.10,50,000/-TOTAL RS.46,07,267 /- STATE BANK INDIA : CONVENT ROAD CHEQUE DEPOSITS 17. 05.2005 RS.10,00,000/- 20.08.2005 RS. 4,00,000/- RS.14,00,000/- TOTAL RS.14,00,000/- HSBC : GARIAHAT BRANCH A/C NO. 023-636962 CHEQUE DEPOSITS : CASH DEPOSITS 03.06.2005 RS.7,90,468/- 28.01.2006 RS.4,00,000/- 16.02.2006 RS. 40,000/- 22.02.2006 RS. 35,000/- 27.02.2006 RS.1,00,000/- 21.03.2006 RS.1,00,000/- RS.7,90,468/- RS.6,75,000/-TOTAL RS.14,65,468/ - GRAND TOTAL RS.74,72,735/- 6. AS CAN BE SEEN FROM THE ABOVE DETAILS, THE TOT AL DEPOSITS MADE IN THE AFORESAID BANK ACCOUNT WAS A SUM OF RS.74,72,735/-. THE EXPLANATIO N OF THE ASSESSEE WITH REGARD TO THE SOURCE OF FUNDS WITH REGARD TO VARIOUS DEPOSITS IN THE BANK ACCOUNT WAS AS FOLLOWS :- A) THE LATE BIMALENDU SEN AND HIS BROTHER NIRMALENDU S EN OWNED A LAND AT TOPSIA ROAD, KOLKATA. THEY ENTERED INTO A PARTNERSHIP ON 0 5.03.2002 WITH THREE OTHER PARTIES NAMELY SRI JUGAL KISHORE KHETWAT, SHRI VISH AL KHETWAT AND M/S. KHETWAT TOWERS PVT. LTD. THE PARTNERSHIP WAS ENTERE D INTO ON 05.03.2002 AND THE NAME OF THE PARTNERSHIP WAS EAST END DEVELOPER S.. AS PER THE DEED OF PARTNERSHIP THE ASSESSEE AND HIS BROTHER GAVE THE L AND OWNED BY THEM AT TOPSIA ROAD, KOLKATA AS THEIR SHARE OF CAPITAL CONTRIBUTIO N TO THE PARTNERSHIP. THE FIRM 4 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 4 WANTED TO CONSTRUCT APARTMENTS OVER THE LAND THAT W AS BROUGHT INTO THE FIRM AS CAPITAL. THERE WERE DISPUTE BETWEEN THE PARTNERS A ND ULTIMATELY THE DISPUTE WAS SETTLED. ARBITRATORS PASSED AN AWARD DATED 27.01.2 006 WHICH WAS LATER CONFIRMED BY THE HONBLE CALCUTTA HIGH COURT IN AN ORDER DATED 16.03.2006. AS PER THE ARBITRATION AWARD THE PROPERTIES STOOD TRAN SFERRED AND BECAME THE PARTNERSHIP BUSINESS W.E.F. 01.03.2002 I.E. DATE O F THE COMMENCEMENT OF THE PARTNERSHIP BUSINESS. THE VALUE OF THE PROPERTY I.E . LAND AT TOPSIA ROAD,KOLKATA WAS VALUED AT RS.7,10,00,000/-AS ON 01.03.2002 AND THE CAPITAL ACCOUNT OF THE ASSESSEE AND HIS BROTHER WERE TO BE CREDITED BY A S UM OF RS.3,55.00,000/- EACH. THE ASSESSEE EXPLAINED THAT IT HAD WITHDRAWN A SUM OF RS.1,48,50,000/- FROM HIS CAPITAL ACCOUNT IN THE FIRM TILL 31.03.2006 AND THA T A SUM OF RS.30,00,000/-WAS BEEN WITHDRAWN FROM THE CAPITAL DURING THE PREVIOUS YEAR RELEVANT TO A.Y.2006- 07. B) THE ASSESSEE WAS ALSO ALLOTTED A FLAT IN THE PROJEC T WHICH WAS DEVELOPED BY THE FIRM OVER THE LANDS OWNED BY THE ASSESSEE AND HIS B ROTHER. THE ASSESSEE HAD AGREED TO SELL ONE SUCH FLAT TO SHRI SWADESH RANJAN SAMANTA AND SMT. KABERI SAMANTA. THE ADVANCE RECEIVED FROM THE AFORESAID PA RTIES WAS ALSO EXPLAINED AS THE SOURCE OF FUNDS FOR VARIOUS DEPOSITS IN THE BAN K ACCOUNT OF THE ASSESEE. C) BESIDES THE ABOVE THE ASSESSEE ALSO RECEIVED COMPEN SATION FOR COMPULSORY ACQUISITION OF LAND OWNED BY THE ASSESSEE FROM THE GOVERNMENT. THE ASSESSEE ALSO RECEIVED REDEMPTION PROCEEDS OF MUTUAL FUND. D) AS FAR AS THE CASH PORTION OF THE MONEYS DEPOSITED IN THE BANK ACCOUNT IS CONCERNED THE ASSESSEE EXPLAINED THAT THEY WERE ALS O ADVANCES AND WITHDRAWALS FROM THE CAPITAL ACCOUNT. E) THE ASSESSEE CONTENDED THAT SINCE THE AMOUNTS IN QU ESTION REPRESENTED WITHDRAWAL OF CAPITAL AND ADVANCES FOR SALE OF FLAT S, THEY CANNOT BE REGARDED AS ASSESSEES INCOME. 5 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 5 7. THE AO, HOWEVER DID NOT AGREE WITH THE SUBMI SSIONS MADE BY THE ASSESSEE. HE HELD THAT THE ENTIRE ARRANGEMENT BETWEEN THE ASSESS EE AND EAST END DEVELOPERS WAS A BUSINESS ARRANGEMENT AND WHATEVER MONEY WAS RECEIVE D BY THE ASSESSEE AS WITHDRAWAL FROM THE CAPITAL ACCOUNT OF THE FIRM WAS INCOME FRO M BUSINESS VENTURE. SINCE THE ASSESSEE DID NOT OFFER INCOME FROM THE SAID BUSINES S VENTURE, THE SAME CANNOT BE EXPLAINED AS SOURCE OF FUNDS FOR VARIOUS DEPOSITS M ADE IN THE BANK ACCOUNT. THE AO THEREFORE ADDED A SUM OF RS.74,72,735/- TO THE TOTA L INCOME OF THE ASSESSEE. 8. ON APPEAL BY THE ASSESSEE CIT(A) CONFIRMED TH E ORDER OF AO. HENCE THIS APPEAL FILED BY THE ASSESSEE BEFORE THE TRIBUNAL. 9. WE HAVE HEARD THE RIVAL SUBMISSIONS. AS FAR A S ADDITION OF RS.10,50,000/- WHICH IS THE SUBJECT MATTER OF CHALLENGE IN GR.NO.2 RAISED B Y THE ASSESSEE IS CONCERNED, THE LD. COUNSEL FOR THE ASSESSEE BROUGHT TO OUR NOTICE THAT THE AIR INFORMATION RECEIVED BY THE AO WAS THAT THERE WAS A DEPOSIT OF CASH OF RS.10,50 ,000/- IN THE BANK ACCOUNT OF THE ASSESSEE WITH STANDARD CHARTERED BANK, KOLKATA, 14 N.S.ROAD. WE HAVE ALREADY SEEN THAT THERE WAS A CASH DEPOSIT OF RS.,10,50,000/- IN STANDARD CHARTERED BANK A/C. ( SET OUT IN PARA-5 OF THIS ORDER). THIS SUM OF RS.10,50 ,000 IS PART AND PARCEL OF THE SUM OF RS.74,72,735/- WHICH WAS ADDED BY THE AO AS UNEXPLA INED INVESTMENT WHICH IS SUBJECT MATTER OF CHALLENGE IN GR.NO.3 IN THIS APPEAL. THE LD. COUNSEL FOR THE ASSESSEE BROUGHT TO OUR NOTICE THAT THE AO UNDER AN ERRONEOUS BELIEF THAT RS.10,50,000/-HAD BEEN INVESTED BY THE ASSESSEE IN MUTUAL FUND OF STANDARD CHARTERED BANK AS ON 31.03.2006 HAS MADE THE IMPUGNED ADDITION WHICH IS CHALLENGED IN GR.NO.2. IT WAS SUBMITTED THAT SINCE THE SUM OF RS.10,50,000/- WHICH IS THE SUBJEC T MATTER OF CHALLENGE IN GROUND NO.2 IS ALREADY PART OF THE CASH DEPOSITS WHICH IS THE S UBJECT MATTER OF CHALLENGE IN GROUND NO.3, THE ADDITION MADE ON THE PRESUMPTION THAT THE ASSESSEE MADE INVESTMENTS IN MUTUAL FUND SHOULD BE DELETED. IN THIS REGARD OUR A TTENTION WAS DRAWN TO PAGE 22 OF 6 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 6 THE ASSESSEES PAPER BOOK WHICH CONTAINS THE AIR WH ICH AO RECEIVED BASED ON WHICH THE AO MADE ADDITION OF RS.10,50,000/-. THE LD. DR RELIED ON THE ORDER OF AO. 10. WE HAVE PERUSED PAGE 22 OF THE ASSESSEES PA PER BOOK AND FIND FROM A PERUSAL OF THE SAME THAT THE INFORMATION RECEIVED BY THE AO WA S ONLY WITH REGARD TO CASH DEPOSIT IN THE STANDARD CHARTERED BANK, KOLKATA-14. THERE I S NO INFORMATION THAT THE ASSESSEE INVESTED A SUM OF RS.10,50,000/- IN MUTUAL FUND OF STANDARD CHARTERED BANK AS ON 31.03.2006. THIS CASH DEPOSIT OF RS.10,50,000/- IS ALREADY PART OF THE SUM OF RS.74,72,735/- ADDED BY THE AO AS UNEXPLAINED INVES TMENT AND THIS IS A SUBJECT MATTER OF CHALLENGE IN GROUND NO.3 BY THE ASSESSEE. THUS I T IS CLEAR THAT THE SUM OF RS.10,50,000/- HAS BEEN TAXED TWICE. THE EXPLANATIO N WITH REGARD TO THE CASH DEPOSIT OF RS.10,50,000/- IN STANDARD CHARTERED BANK WILL BE D EALT WITH WHILE DEALING WITH GROUND NO.3 RAISED BY THE ASSESEE AND THEREFORE SEPARATE A DDITION OF RS.10,50,000/- CHALLENGED IN GROUND NO.2 IS DELETED. 11. AS FAR AS ADDITION OF RS.74,72,735/- WHICH I S THE SUBJECT MATTER OF CHALLENGE IN GROUND NO.3 IS CONCERNED, THE LD. COUNSEL FOR THE A SSESEE, AT THE OUTSET, CONCEDED THAT THE ASSESSEE IS UNABLE TO EXPLAIN THE SOURCE OF FUN DS FOR THE CASH DEPOSIT OF RS.10,50,000/- IN STANDARD CHARTERED BANK, KOLKATA MAIN BRANCH AND A SUM OF RS.6,75,000/- IN HSBC, GARIAHAT BRANCH. THESE ADDIT IONS MADE BY THE AO AND SUSTAINED BY CIT(A) ARE THEREFORE CONFIRMED. 12. AS FAR AS THE SOURCE OF FUNDS FOR THE OTHER CHEQUE DEPOSIT IN THE THREE ACCOUNTS ARE CONCERNED, IT IS CLEAR FROM THE MATERIAL ON RECORD THAT THE FACTS WITH REGARD TO THE FORMATION OF THE PARTNERSHIP EAST END DEVELOPERS, DISPUTE BETWEEN THE PARTNERS OF SUCH PARTNERSHIP, ULTIMATE SETTLEMENT OF THE DISPU TES BY THE ARBITRATORS AND FACTUM OF CREDIT OF A SUM OF RS.3.55 CRORES AS CAPITAL CONTRI BUTION BY THE ASSESSEE IN THE FIRM PURSUANT TO THE ARBITRATION AWARD ARE CORRECT AND A RE NOT DISPUTED EVEN BY THE AO. IT 7 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 7 IS ALSO NOT IN DISPUTE THAT THE ASSESSEE WITHDREW A SUM OF RS.1,48,50,000/- TILL 31.03.2006 FROM HIS CAPITAL ACCOUNT OUT OF WHICH A SUM OF RS.30,00,000/- HAS BEEN WITHDRAWN FROM THE CAPITAL ACCOUNT DURING THE PREVI OUS YEAR RELEVANT TO A.Y.2006-07. THE DETAILS OF THE AMOUNTS WITHDRAWN FROM HIS CAPIT AL ACCOUNT FROM EAST END DEVELOPERS IS AS FOLLOWS :- DATE CHEQUE# AMOUNT BENEFICIARY BANK 13/05/2005 229231 RS.10,00,000.00 STANDARD CHARTERE D BANK 13/05/2005 229232 RS.10,00,000.00 STANDARD CHARTERE D BANK 13/05/2005 229233 RS.10,00,000.00 STATE BANK OF IND IA 13. IT IS ALSO NOT DISPUTED BY THE AO THAT THE ASS ESSEE RECEIVED A SUM OF RS.24,61,874/- FROM THE PURCHASERS OF THE FLAT WHICH HE GOT IN THE PROJECT DEVELOPED BY EAST END DEVELOPERS. THE DETAILS IN THIS REGARD ARE AS FOLLO WS :- DETAILS OF PAYMENTS FROM KABERI SAMANTA AGAINST ADV ANCE FOR FLAT 12A : DATE PAYMENT RECEIVED (RS.) DEPOSIT ON BANK 16.06.2005 7,93,222.00 STANDARD CHARTERED (9397) 12.09.2005 4,34,430.00 STANDARD CHARTERED (9397) 24.03.2006 4,43,754.00 STANDARD CHARTERED (9397) 03.06.2005 7,90,468.00 HSBC (023636962) 24,61,874.00 14. IT IS CLEAR FROM THE AFORESAID DETAILS THAT TH E ASSESSEE HAD RECEIVED THESE AMOUNTS EITHER DIRECTLY IN HIS BANK ACCOUNT OR THROUGH TRAN SFER FROM ANOTHER ACCOUNT OF THE ASSESSEE WITH STANDARD CHARTERED BANK. THESE RECEIP TS ARE PRIOR TO THE DATES OF DEPOSITS AND IT SUFFICIENTLY EXPLAINS THE SOURCE FOR VARIOUS DEPOSITS SET OUT BY THE AO IN THE ORDER OF ASSESSMENT. 15. A CREDIT/DEPOSIT IN THE BANK ACCOUNT OF THE AS SESSEE OF RS.3,29,015 ON 12.1.2006 IS ON ACCOUNT OF REDEMPTION PROCEEDS OF RELIANCE MUTUA L FUND GFGP (PAGE-84 OF THE PAPER BOOK LETTER OF STANDARD CHARTERED BANK). SIM ILAR A DEPOSIT/CREDIT OF RS.4,00,000 8 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 8 AS ON 17.5.2005 IS COMPENSATION RECEIVED FROM ACQUI SITION OF LAND OF THE ASSESSEE (PAGE-65 OF THE PAPER BOOK). 16. THUS THE SOURCE OF ALL THE CASH DEPOSITS STAND S SUFFICIENTLY EXPLAINED BY THE ASSESSEE. 17. APART FROM THE ABOVE IT WAS ALSO BROUGHT TO OUR NOTICE BY THE LD. COUNSEL FOR THE ASSESSEE THAT AFTER THE SETTLEMENT OF DISPUTE IN TH E PARTNERSHIP, THE REVENUE REOPENED THE ASSESSMENT OF THE ASSESSEE FOR A.Y.2006-07 U/S.147 OF THE ACT AND BROUGHT TO TAX THE CAPITAL GAIN ON TRANSFER OF THE LAND BY THE ASSESSE E TO THE PARTNERSHIP FIRM AND ADDED A SUM OF RS.5,24,06,587/- BY ORDER OF ASSESSMENT DATE D 29.03.2014 PASSED U/S 143(3) R.W.S.147 OF THE ACT FOR A.Y.2006-07. A COPY OF TH E SAID ORDER WAS ALSO FILED BEFORE US. IT IS THUS CLEAR THAT WHATEVER WAS THE RECEIPTS BY THE ASSESSEE FROM EAST END DEVELOPERS AS WELL AS FROM SHRI SWADESH RANJAN SAMANTA AND SMT . KABERI SAMANTA , THE PERSONS WHO PURCHASED ONE FLAT FROM THE ASSESSEE WERE ALL C APITAL RECEIPTS AND THEY ARE NOT IN THE NATURE OF INCOME. THESE RECEIPTS SUFFICIENTLY EXPLA IN THE SOURCE OF FUNDS FOR VARIOUS DEPOSITS IN THE THREE BANK ACCOUNTS REFERRED TO IN THE ORDER OF AO. THE ADDITIONS MADE BY THE AO AND CONFIRMED BY CIT(A) IN SO FAR AS IT R ELATES TO THE DEPOSITS IN THE FORM OF CHEQUES IN THE THREE BANK ACCOUNTS AND THEREFORE HE LD TO BE EXPLAINED AND NOT CHARGEABLE TO TAX. TO THIS EXTENT GROUND NO.3 IS PA RTLY ALLOWED. 18. IN THE RESULT THE APPEAL BY THE ASSESSEE IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE COURT ON 13.09.2017. SD/- SD/- [P.M.JAGTAP] [ N.V.VASUDEVAN ] ACCOUNTANT MEMBER JUDICIAL MEMBER DATED : 13.09.2017. [RG PS] 9 ITA NO.1764/KOL/2013 SMT.SHEILA SEN, L/H LATE BIMALENDU SEN A.YR..2-006-07 9 COPY OF THE ORDER FORWARDED TO: 1.SMT. SHEILA SEN, L/H OF LATE BIMALENDU SEN, 16, C ONVENT ROAD, KOLKATA-700014. 2. I.T.O., WARD-2(1), KOLKATA. 3. C.I.T. (A)-XX, KOLKATA 4. C.I.T.-1, KOLKATA. 5. CIT(DR), KOLKATA BENCHES, KOLKATA. TRUE COPY BY ORDER SENIOR PR IVATE SECRETARY HEAD OF OFFICE/D.D.O., I.T.A.T., KOLKATA BENCHE S