DCIT,(Central), Cir-4(3), Kolkata , Kolkata V. M/s. Anil R. Chordia (HUF) , Kolkata

ITA 1810/KOL/2017

• Counselvise Citation: [2019] 117 COUNSELVISE.COM (IT) 2108 (ITAT-KOLKATA)
• Duration Of Justice: 1 year(s) 10 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 19-06-2019
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2014-2015
• Appeal Filed On: 04-08-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: A K NAYAK
• Assessee Lawyers: S L PODDAR
• Keywords: Rejection of books of accounts; Set aside
• Section: 143(3); 250; 145

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH, KOLKATA BEFORE SRI J. SUDHAKAR REDDY, ACCOUNTANT MEMBER & SRI S.S. GODARA, JUDICIAL MEMBER I.T.A. NO.1810/KOL/2017 (ASSESSMENT YEAR: 2014-15) DCIT(CENTRAL), CIRCLE-4(3), KOLKATA...... APPELLANT VS. M/S ANIL R. CHORDIA(HUF)................. ..........................................RESPONDENT [PAN : AAFHA6145K ] APPEARANCES BY: SHRI A. K. NAYAK, CIT, DR, APPEARING ON BEHALF OF THE APPELLANT. SHRI S.L. PODDAR, ADVOCATE, APPEARING ON BEHALF OF THE RESPONDENT. DATE OF CONCLUDING THE HEARING : MAY 15 TH , 2019 DATE OF PRONOUNCING THE ORDER : JUNE 19 TH ,2019 O R D E R PER J. SUDHAKAR REDDY :- THIS APPEAL FILED BY THE REVENUE IS DIRECTED AGAINST THE ORDER OF THE LD. COMMISSIONER OF INCOME TAX (APPEALS) - 21, KOLKATA (HEREINAFTER THE LD. CIT (A)), PASSED U/S 250 OF THE INCOME TAX ACT, 1961 (THE ACT), DATED 24.05.2017. 2. THE ASSESSEE IS A HUF AND IS A PROPRIETOR OF M/S SHREEJI CORPORATION AND IS ENGAGED IN THE BUSINESS OF IMPORTING, EXPORTING, MANUFACTURING OF CUT AND POLISHED DIAMONDS. THE ASSESSEE FILED HIS RETURN OF INCOME ON 25.09.2014 DECLARING INCOME OF RS.6,54,320/-. THE ASSESSMENT WAS COMPLETED U/S 143(3) OF THE ACT ON 29.12.2016 DETERMINING THE TOTAL INCOME AT RS.9,16,49,750/-, INTER ALIA, MAKING AN ADDITION OF RS.2,96,65,276/- ON ACCOUNT OF MANIPULATION OF THE RATE OF YIELD OF FINISHED PRODUCT AND AN AMOUNT OF RS.6,13,28,333/- ON THE GROUND THAT THE ASSESSEE HAS UNDERSTATED THE SALE OF FINISHED DIAMONDS BY WAY OF MANIPULATION OF THEIR TRADING SEGMENT IN THE ACCOUNTS. FOR MAKING THE ADDITION ON THE GROUND THAT THE ASSESSEE HAS SUPPRESSED THE YIELD OF FINISHED DIAMONDS, THE ASSESSING OFFICER RELIED ON A COPY OF SNAPSHOT OF THE RELEVANT 2 I.T.A. NO.1810/KOL/2017 M/S ANIL R. CHORDIA(HUF) WEBSITE WHICH CATEGORICALLY EXPRESS THAT THE PERCENTAGE OF YIELD OF FINISHED DIAMONDS FROM ROUGH DIAMOND CANNOT BE LESS THAN 45%. AS THE YIELD OF THE ASSESSEE WAS 30.60%, IT WAS CONCLUDED THAT THE ASSESSEE HAS SUPPRESSED PRODUCTION. 3. THE SECOND ADDITION WAS MADE ON THE GROUND THAT THE ASSESSEE HAS UNDERSTATED THE SALE OF FINISHED DIAMONDS. THIS WAS MADE ON THE GROUND THAT ROUGH DIAMONDS WERE PURCHASED DURING THE YEAR AT THE RATE OF 1767.34/- PER CARAT AND WHEREAS IT WAS SOLD AT THE RATE OF 1671/- PER CARAT, WHICH IS NOT JUSTIFIED. AT PAGE 3 THE ASSESSING OFFICER HELD AS FOLLOWS: FROM THE ABOVE ANALYSIS IT IS SEEN THAT YOUR MANUFACTURING COST PER CARAT WAS RS.10,325/-, MOREOVER YOU HAVE VALUED THE CLOSING STOCK OF FINISHED DIAMOND AT RS.15,460/- PER CARAT. IN SUCH SITUATION, YOU HAVE SHOWN SALE @RS.9.328/- PER CARAT WHICH APPEARS TO BE NOT BELIEVABLE. HENCE, YOU ARE DIRECTED TO EXPLAIN THE REASONS OF SALE AT SUCH A LOWER RATE AND ALSO EXPLAIN WHY SUCH RATE OF SALE SHALL NOT BE CONSIDERED AT AVERAGE RATE OF RS.12,394/- I.E.[(9,328+15,460)/2] PER CARAT WHICH REASONABLY EXCEEDED MANUFACTURING COST BY REJECTING YOUR BOOK VALUE U/S 145 OF THE ACT. IN VIEW OF THE FACT, SALE PRICE OF 1248.93 CARAT OF FINISHED DIAMOND IS TO BE TAKEN AS RS.24,79,55,231/- I.E.(20006.07*1248.93). HENCE UNDERSTATEMENT OF FINISHED DIAMOND SALE APPEAR AS RS.6,13,28,333/- [RS.24,79,55,231 RS.18,66,26,898]. 3.1 THE EXPLANATION OF THE ASSESSEE WAS FOUND NOT SATISFACTORY BY THE ASSESSING OFFICER AND HENCE THE ADDITIONS. 4. AGGRIEVED THE ASSESSEE CARRIED THE MATTER IN APPEAL. THE FIRST APPELLATE AUTHORITY GRANTED RELIEF. HE DELETED BOTH THE ADDITIONS FOR THE DETAILED REASONS GIVEN IN HIS ORDER. 5. AGGRIEVED THE REVENUE IS IN APPEAL ON THE FOLLOWING GROUNDS: 1. THAT, ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) WAS NOT JUSTIFIED IN LAW IN CONCURRING THE ASSESSEE'S DECLARED YIELD OF POLISHED DIAMOND AT 30.60 PERCENT, WITHOUT ASSIGNING ANY REASONS AND IN TOTAL DISREGARD OF MATERIAL AVAILABLE WHICH UPON APPRAISAL THEY WERE FOUND AGAINST THE ASSESSEE AND THEREBY ERRED IN DELETING THE ADDITION OF RS.2,96,65,276/- MADE IN THE ASSESSMENT ORDER. 2. THAT, ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) WAS NOT JUSTIFIED IN ACCEPTING THE PERCENTAGE OF YIELD SHOWN BY THE ASSESSEE MERELY ON THE BASIS OF DECISIONS IN CERTAIN CASES, HAVING DISTINGUISHABLE FACTS AND WITHOUT CONSIDERING AND APPRECIATING THE FACTS 3 I.T.A. NO.1810/KOL/2017 M/S ANIL R. CHORDIA(HUF) BROUGHT ON RECORD TO JUSTIFY GROSS MANIPULATION IN THE BOOKS OF ACCOUNT LEADING TO LOSS IN DIAMOND BUSINESS. 3. THAT, ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD.CIT(A) ERRED IN NOT SUSTAINING THE REJECTION OF BOOKS OF ACCOUNT WHEN THE ASSESSEE FAILED TO EXPLAIN THE LOSS IN ROUGH DIAMOND TRADING WHICH WAS SOLD AT AN AVERAGE PRICE LOWER THAN THE AVERAGE PURCHASE PRICE AND WHEN ASSESSEE ITSELF ADMITTED THAT ONE TO ONE LINKING IS NOT POSSIBLE. 4. THAT, ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD.CIT(A) WAS NOT JUSTIFIED IN DELETING THE ADDITION OF RS.6,13,28,333/- MADE ON ACCOUNT OF SUPPRESSION OF SALE PROCEEDS, WITHOUT GIVING ANY REASONS AS TO HOW THE DISALLOWANCE MADE BY THE ASSESSING OFFICER WAS NOT REASONABLE AND WITHOUT CONSIDERING THE FULL FACTS OF THE CASE PARTICULARLY THE FACTS RELATING TO THE AVERAGE SALE PRICE OF POLISHED DIAMOND WHICH IS LOWER THAN THE AVERAGE COST OF PRODUCTION AND COST OF VALUATION OF CLOSING STOCK PER UNIT. 6. THE LD. DEPARTMENTAL REPRESENTATIVE SUBMITTED THAT THE ASSESSING OFFICER HAD VERIFIED FROM VARIOUS WEBSITES AND AFTER GIVING COPY OF THE SNAPSHOTS OF THE SAME TO THE ASSESSEE AND OBTAINING EXPLANATION HAS COME TO THE CONCLUSION THAT THE ASSESSEE HAS SUPPRESSED PRODUCTION. HE SUBMITTED THAT THE ASSESSEE HAS SHOWN ONLY 30.60% YIELD AND WHEREAS SNAPSHOT FROM THE WEBSITES STATE THAT THE YIELD CANNOT BE LESS THAN 45%. HE SUBMITTED THAT THE ASSESSEE WAS NOT MAINTAINING PROPER STOCK REGISTER AND THAT ONE TO ONE LINKAGE COULD NOT BE MADE. HE SUBMITTED THAT THE DIAMONDS PURCHASED OR MANUFACTURED COULD NOT BE TRACED TO ITS ULTIMATE SALE, SO AS TO UNABLE THE ASSESSING OFFICER TO FIND OUT AS TO WHETHER THE ASSESSEE HAS DECLARED THE CORRECT YIELD AND THE CORRECT RATE. HE RELIED ON THE DECISION OF HONBLE PUNJAB AND HARYANA HIGH COURT IN THE CASE OF PRAMOD KUMAR, PROP. LAJJA RICE & OILS MILLS V. CIT, PANCHKULA; [2015] 58 TAXMANN.COM 41(PUNJAB & HARYANA) FOR THE PROPOSITION THAT WHEN THE DEFICIENCIES AND DISCREPANCIES ARE NOTICED IN THE RECORDS MAINTAINED BY THE ASSESSEE, THE ASSESSING OFFICER WAS JUSTIFIED IN REJECTING THE BOOKS OF ACCOUNTS. HE ALSO RELIED ON THE JUDGMENT OF HONBLE ALLAHABAD HIGH COURT IN THE CASE OF AWADHESH PRATAP SINGH ABDUL REHMAN & BROS. V. CIT; [1994] 210 ITR 406 (ALLAHABAD) FOR THE PROPOSITION THAT, WHEN THE BOOKS OF ACCOUNTS OF THE ASSESSEE WERE DEFECTIVE AND WHEN STOCK REGISTER WAS NOT MAINTAINED AND THE SALES ARE NOT VERIFIABLE IN THE ABSENCE OF SUCH STOCK REGISTER, BOOK RESULTS CAN BE REJECTED AND PROFIT ESTIMATED. HE TOOK THIS BENCH THROUGH THE ANALYSIS MADE BY THE 4 I.T.A. NO.1810/KOL/2017 M/S ANIL R. CHORDIA(HUF) ASSESSING OFFICER ON THE RATE OF SALE AND SUBMITTED THAT THE ASSESSEES EXPLANATION WAS RIGHTLY REJECTED BY THE ASSESSING OFFICER. HE ARGUED THAT THE LD. CIT(A) HAS NOT CONSIDERED THE ISSUES IN THE RIGHT PERSPECTIVE AND THAT THE ASSESSING OFFICER HAS NOT BEEN GIVEN ADEQUATE OPPORTUNITY TO EXPLAIN THE MATTER AND TO CONSIDER THE SUBMISSIONS OF THE ASSESSEE. 6.1 HE PLEADED THAT THE ISSUED SHOULD BE SET ASIDE TO THE FILE OF ASSESSING OFFICER FOR FRESH ADJUDICATION, IN CASE, THE TRIBUNAL IS OF THE VIEW THAT THE ASSESSING OFFICER HAS NOT PROVIDED ALL THE NECESSARY MATERIAL TO THE ASSESSEE TO COME TO THE CONCLUSION OR IF IT FINDS MERITS IN THE ORDER OF THE LD. CIT(A) AS OPPORTUNITY IS TO BE GIVEN TO THE ASSESSING OFFICER. 7. THE LD. COUNSEL FOR THE ASSESSEE, ON THE OTHER HAND, SUBMITTED THAT DURING THE YEAR THE ASSESSEE PURCHASED ROUGH DIAMONDS OF 37564.2 CARATS OUT OF WHICH 22087.2 CARATS WERE CONSUMED FOR PRODUCTION OF FINISHED DIAMONDS AND THE OUTPUT OF FINISHED GOODS WAS 6757.64 CARATS WHICH COMES YIELD OF 30.60%. HE SUBMITTED THAT THE ASSESSING OFFICER HAS NOT MENTIONED NAME OF ANY WEBSITES AND FROM WHERE HE HAS GOT THE SNAPSHOT. THE SUBMISSIONS OF THE ASSESSEE BASED ON STATEMENT GIVEN BY GEMS AND JEWELLERY EXPORT PROMOTION COUNCIL THAT THE YIELD IN DIAMONDS WOULD BE RANGING BETWEEN 10% TO 55% WAS DISREGARDED AND MISQUOTED. HE FURTHER SUBMITTED THAT THE ASSESSEES TRACK RECORD IN THE EARLIER ASSESSMENT YEARS DISCLOSED YIELD OF 31.61% AND THIS WAS ACCEPTED IN THE SCRUTINY ASSESSMENT U/S 143(3) OF THE ACT ON 30.10.2013 FOR THE ASSESSMENT YEAR 2011-12. HE SUBMITTED THAT DETAILED BOOKS OF ACCOUNT INCLUDING STOCK REGISTER WERE MAINTAINED AND THEY ARE AUDITED U/S 44AB OF THE ACT. HE SUBMITTED THAT THE ASSESSING OFFICER HAS NOT POINTED OUT ANY DEFECTS IN THE BOOKS OF ACCOUNTS AND REJECTED THE SAME ONLY ON CONJECTURES AND SURMISES. HE SUBMITTED THAT QUANTITATIVE DETAILS HAVE BEEN MAINTAINED AND THAT THE ASSESSING OFFICER HAS NOT COMMENTED ON THE SAME. IN SUPPORT OF THE PERCENTAGE OF YIELD BEING AROUND 30%, HE RELIED ON THE FOLLOWING CASE LAWS: 5 I.T.A. NO.1810/KOL/2017 M/S ANIL R. CHORDIA(HUF) (I) DCIT VS. NEVIL GEMS(ITAT, AHMEDABAD TRIBUNAL IN (2015) 45 CCH 0268 (AHD.TRIB); (II) M/S. PANKAJ DIAMOND, ITA NO.1975/AD/2009; ASSESSMENT YEAR 2006-07 8. ON THE ISSUE OF ADDITION MADE ON THE GROUND THAT THERE WAS SUPPRESSION OF YIELD, HE SUBMITTED THAT THE ASSESSING OFFICER DID NOT DISPUTE THE SALE PRICE NOR HAS HE MADE ANY ENQUIRY WHATSOEVER WITH ANY OF THE PURCHASERS OR SELLERS. HE ARGUED THAT THE ASSESSING OFFICER ADOPTED A FICTIONAL RATE OF 12,394.61 PER CARAT AGAINST THE SALE PRICE DISCLOSED BY THE ASSESSEE OF RS.9328.51/-. HE VEHEMENTLY CONTENDED THAT THE ACTION OF THE ASSESSING OFFICER WAS IMAGINARY, UNREASONABLE AND UNLAWFUL AND UNJUSTIFIED. HE SUBMITTED THAT THE ASSESSEE HAD VALUED CLOSING STOCK AT A HIGHER RATE I.E. 15460.70/- PER CARAT IN COMPARISON TO THE AVERAGE SALE PRICE OF RS.9328.51 PER CARAT, BECAUSE THE INVENTORY QUALITY OF DIAMONDS/SALE OF BETTER QUALITY WAS LEFT IN THE STOCK. HE POINTED OUT THAT THE ASSESSING OFFICER HAS NOT FOUND FAULT THAT THE VALUATION OF CLOSING STOCK NOR HAS HE DISPUTED THE COST OF PRODUCTION, NOR IS IT THE CASE OF THE ASSESSING OFFICER THAT THE ASSESSEE HAS INDULGED IN UNACCOUNTED SALES. HE RELIED ON THE ORDER OF THE LD. CIT(A) AND SUBMITTED THAT THE SAME BE UPHELD. HE FILED A PAPER BOOK RUNNING INTO 46 PAGES IN SUPPORT OF HIS CASE AND REFERRED TO THE SAME DURING THE COURSE OF HIS ARGUMENTS. 9. RIVAL CONTENTIONS HEARD. ON A CAREFUL CONSIDERATION ON THE FACTS AND CIRCUMSTANCES OF THE CASE, PERUSING THE PAPERS ON RECORD AND ORDERS OF THE AUTHORITIES BELOW AS WELL AS CASE LAWS CITED, WE HOLD AS FOLLOWS . 10. THE ASSESSING OFFICER IN THIS CASE HAS MADE HUGE ADDITIONS BASED ON SURMISES AND CONJECTURES, WITHOUT CONDUCTING ANY INVESTIGATION OR BRINGING ON RECORD ANY EVIDENCE IN SUPPORT OF HIS CONTENTIONS AND WITHOUT MAKING THIRD PARTY ENQUIRES. THE YIELD FROM MANUFACTURING OF DIAMONDS IS ARRIVED AT ON THE BASIS OF SNAPSHOTS FROM WEBSITES, NAMES OF WHICH ARE NOT DISCLOSED EVEN TO US, AND BY IGNORING THE PAST RECORD OF THE ASSESSEE AND THE STATEMENT MADE BY GEMS AND JEWELLERY EXPORT PROMOTION COUNCIL PERCENTAGE OF YIELD. SUCH ADDITIONS MADE ON 6 I.T.A. NO.1810/KOL/2017 M/S ANIL R. CHORDIA(HUF) SURMISES AND CONJECTURES HAVE BEEN RIGHTLY DELETED BY THE LD. CIT(A). THE LD. CIT(A) RELIED ON THE DECISION OF THE TRIBUNAL IN THE CASE OF KHANDELWAL GEMS TRADING CORPORATION VS ASSTT. CIT (1996) 54 TTJ (JP) 479 AND IN THE CASE OF M/S DHAMI BROTHERS VS. ACIT IN ITA NO.2309/AHD/2008 AND THE DECISION IN THE CASE OF M/S. PANKAJ DIAMOND (SUPRA) WHILE COMING TO THE CONCLUSION THAT THE YIELD OF 30.60% DECLARED BY THE ASSESSEE IS REASONABLE. NO COMPARABLE CASES HAVE BROUGHT ON RECORD BY THE ASSESSING OFFICER IN SUPPORT OF HIS CONCLUSIONS THAT THE YIELD SHOULD BE 45%. THE BOOKS OF ACCOUNTS OF THE ASSESSEE HAVE BEEN REJECTED ON THE BASIS OF CONCLUSION DRAWN BY THE ASSESSING OFFICER THAT THE ASSESSEE HAS UNDERSTATED THE YIELD OF DIAMONDS. NO DEFECTS WERE POINTED OUT IN THE BOOKS OF ACCOUNTS. NO ENQUIRY HAS BEEN MADE EITHER WITH THE PURCHASERS OF THE GOODS NOR WITH THE SELLERS OF THE GOODS. THE VALUE OF CLOSING STOCK HAS BEEN ACCEPTED BY THE ASSESSING OFFICER. THE PURCHASED PRICE AND THE COST OF PRODUCTION WAS NOT DISPUTED. THE ENTIRE ALLEGATION IS BASED ON THE GROUND THAT THE ASSESSEE HAS DECLARED LOW YIELD AND THE GROUND THAT THE ASSESSEE HAS CONSEQUENTLY SUPPRESSED SALES. THESE CONCLUSIONS OF THE ASSESSING OFFICER ARE TOTALLY IMAGINARY AND WITHOUT ANY BASIS. PAST HISTORY OF THE ASSESSEE SHOWS THE FOLLOWING PERCENTAGE OF YIELD FROM ROUGH DIAMONDS TO POLISH DIAMONDS: SR NO. F.Y % OF YIELD 1 2008-09 33.71 2 2009-10 33.65 3 2010-11 31.61 4 2011-12 37.42 5 2012-13 35.24 6 2013-14 30.60 THE CURRENT YEAR YIELD DECLARED BY THE ASSESSEE IS CONSISTENT WITH THE ABOVE FIGURES. 11. ON THESE FACTS, THE LD. CIT(A) HAS HELD AS FOLLOWS: 7 I.T.A. NO.1810/KOL/2017 M/S ANIL R. CHORDIA(HUF) I HAVE CONSIDERED FINDINGS OF THE A.O IN THE ASSESSMENT ORDER AND THE WRITTEN SUBMISSION FILED BY THE AR ON THESE ISSUES. I FIND THAT THE A.O HAS ARRIVED AT THE CONCLUSION OF LOWER YIELD OF FINISHED DIAMONDS ON THE BASIS OF 1) SOME SNAPSHOTS FROM SOME WEBSITE. 2) IT IS NOT CLEAR WHETHER THE ANALYSIS OF PRODUCTION OF FINISHED DIAMONDS WAS MADE ON THE SAME QUALITY OF RAW DIAMOND OR SOME DIFFERENT QUALITY OF RAW DIAMONDS. 3) FROM THE ASSESSMENT ORDER IT IS NOT CLEAR WHETHER THE A.O HAS TAKEN INTO CONSIDERATION THE FINAL QUALITY OF FINISHED DIAMONDS OR NOT. 4) THE A.O HAS REJECTED THE BOOKS OF ACCOUNTS OF THE ASSESSEE ON THE BASIS OF SOME STUDY ON YIELDS OF DIAMONDS PUBLISHED ON INTERNET WITHOUT BRINING ON RECORD ANY SCIENTIFIC EVIDENCE OR FULL PROOF REASON OF ACCEPTING THE STUDY PUBLISHED ON SOME WEBSITE. THUS IT IS CLEAR THAT THE A.O HAS NOT FOUND ANYTHING WRONG IN THE ENTRIES MADE IN THE BOOKS OF ACCOUNTS/PURCHASE REGISTER/SALES BOOKS/INVENTORY REGISTER/LEDGER ETC. BUT THE A.O HAS REJECTED THE BOOKS OF ACCOUNTS ON THE BASIS OF SOME ARTICLES PUBLISHED ON INTERNET. I THINK, REJECTING BOOKS OF ACCOUNTS WITHOUT POINTING OUT ANY CLEAR MISTAKE IN IT. RATHER SIMPLY ON THE BASIS OF SOME ARTICLES PUBLISHED ON INTERNET IS NOT JUSTIFIED. 12. THESE FACTUAL FINDINGS OF THE LD. CIT(A) COULD NOT BE CONTROVERTED BY THE LD. DR. THE DECISION IN THE CASE OF PRAMOD KUMAR, PROP. LAJJA RICE & OILS MILLS (SUPRA) DOES NOT HOLD THE CASE OF THE REVENUE, AS IT WAS A CASE WHERE CERTAIN DEFECTS AND DEFICIENCIES WAS FOUND IN THE MAINTENANCE OF RECORDS. NO SUCH DEFICIENCIES ARE POINTED OUT BY THE ASSESSING OFFICER IN THIS CASE. SIMILARLY THE JUDGMENT IN THE CASE OF AWADHESH PRATAP SINGH ABDUL REHMAN & BROS.(SUPRA) IS NOT APPLICABLE AS IN THAT CASE THERE WAS NO STOCK REGISTER AND THE BOOKS OF ACCOUNTS WERE NOT MAINTAINED PROPERLY. THIS IS NOT THE FACT IN THE CASE ON HAND. THUS, WE UPHOLD THE ORDER OF THE FIRST APPELLATE AUTHORITY AND DISMISS THE APPEAL OF THE REVENUE. 13. IN THE RESULT, THE APPEAL OF THE REVENUE IS DISMISSED. KOLKATA, THE 19 TH JUNE, 2019. SD/- SD/- [ S.S. GODARA ] [J. SUDHAKAR REDDY] JUDICIAL MEMBER ACCOUNTANT MEMBER DATED : 19.06.2019 (RS, SR. PS) 8 I.T.A. NO.1810/KOL/2017 M/S ANIL R. CHORDIA(HUF) COPY OF THE ORDER FORWARDED TO: 1. DCIT(CENTRAL), CIRCLE-4(3), KOLKATA. 2. M/S ANIL R. CHORDIA(HUF), PROP. OF M/S SHREEJI CORPORATION, FLAT NO.1005/1006, THE BREEZY CORNER BLDG SUBMITTED-2, OPP. PANCHSHEEL MAHAVIR NAGAR KANDIVALI WEST, MUMBAI- 400067. 3. CIT(A)- 4. CIT- , 5. CIT(DR), KOLKATA BENCHES, KOLKATA. TRUE COPY BY ORDER ASSISTANT REGISTRAR ITAT, KOLKATA BENCHES