ITO, Ward-4(2), Bhubaneswar, Bhubaneswar V. Runu Kar, Bhubaneswar

ITA 19/CTK/2015

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 7574 (ITAT-CUTTACK)
• Duration Of Justice: 1 year(s) 10 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 08-11-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: SMC
• Next Hearing Date: 08-11-2016
• Assessment Year: 2011-2012
• Appeal Filed On: 08-01-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: D K PRADHAN
• Assessee Lawyers: BIRAJA PRASAD KAR
• Keywords: Principle of natural justice; Peak credit
• Section: 142(1); 68; 144

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK SMC BENCH, CUTTACK BEFORE SHRI N.S SAINI, ACCOUNTANT MEMBER ITA NO.19 /CTK/2015 ASSESSMENT YEAR : 2011 - 2012 INCOME TAX OFFICER, WARD 4(2), BHUBANESWAR VS. SMT. RUNU KAR, PLOT NO.772, 2 ND FLOOR, MAHARSHI DAYANANDA MARG, SAHID NAGAR, BHUBANESWAR,. PAN/GIR NO. BABPK 8187 Q (APPELLANT ) .. ( RESPONDENT ) ASSESSEE BY : SHRI BIRAJA PRASAD KAR REVENUE BY : SHRI D.K.PRADHAN, DR DATE OF HEARING : 8 /11 / 2016 DATE OF PRONOUNCEMENT : 8 /11 / 2016 O R D E R THIS IS AN APPEAL FILED BY THE REVENUE AGA INST THE ORDER OF CIT(A) - II, BHUBANESWAR , DATED 10 TH OCTOBER, 2014 , FOR THE ASSESSMENT YEAR 2011 - 2012 . 2. THE SOLE ISSUE INVOLVED IN THIS APPEAL IS THAT THE LD CIT(A) IS NOT JUSTIFIED IN DELETING THE ADDITION OF RS.24,88,000/ - UNDER THE HEAD UNEXPLAINED CASH DEPOSIT. 2 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 3. I HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE MATERIALS AVAILABLE ON RECORD. IN THE INSTANT CASE, THE ASSESSEE FILED RETURN OF INCOME FOR THE ASSESSMENT YEAR 2011 - 12 ON 16.5.2011 SHOWING INCOME OF RS.2,42,800/ - AFTER CLAIMING DEDUCTION OF RS.7,200/ - UNDER CHAPTER VIA OF THE INCOME TAX ACT. THE ASSESSEE FAILED TO APPEAR BEFORE TH E ASSESSING OFFICER ON THE DATES FIXED FOR HEARING AND DID NOT FILE THE DETAILS AND PARTICULARS CALLED FOR BY THE ASSESSING OFFICER. THEREFORE, THE ASSESSING OFFICER ASSESSED THE INCOME OF THE ASSESSEE AT RS.39,16,024/ - BY MAKING ADDITION UNDER THE HEAD UNEXPLAINED SOURCES U/S.68 OF THE ACT FOR DEPOSITS IN CASH IN UCO BANK, ASHOK MARKET BRANCH, BHUBANESWAR ACCOUNT OF RS.10,35,800/ - AND RS. 28,02,000/ - UNDER THE HEAD UNEXPLAINED SOURCES U/S.68 OF THE ACT FOR CASH DEPOSITS IN UCO BANK CRP HQ. NAYAPALLI, B HUBANESWAR, DISALLOWING DEDUCTION CLAIMED OF RS.7,200/ - UNDER CHAPTER VIA OF THE ACT FOR WANT OF DOCUMENTARY EVIDENCE, ADDING INTEREST INCOME OF RS.55,032/ - AND RS.11,992/ - CREDITED IN TWO BANK ACCOUNTS UNDER THE HEAD INCOME FROM OTHER SOURCES. 4. BEING AGGRIEVED, THE ASSESSEE FILED APPEAL BEFORE THE LD CIT(A) AND SUBMITTED AS UNDER: (A) THE AO IN HIS ASSESSMENT ORDER HAD UNJUSTIFIABLY LOOKED AT ONLY THE DEPOSIT SIDE OF THE BANK ACCOUNTS WHILE IGNORING THE WITHDRAWALS MADE BY THE APPELLANT FROM THE SAME BANK ACCOUNTS. THE APPELLANT ADMITTED TO HAVE REPEATEDLY INDULGED IN THE PRACT ICE OF 3 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 WITHDRAWING CASH FROM ONE BANK ACCOUNT AND DEPOSITING IN CASH THE WITHDRAWN ACCOUNTS OR PARTS THEREOF IN ANOTHER BANK ACCOUNT. (B) THE APPELLANT PROVIDED DETAILS OF THE MATCHING OF WITHDRAWALS AND CORRESPONDING DEPOSITS IN THE FORM OF A MERGED BANK CASH TRANSACTIONS STATEMENT, AND SUBMITTED THAT THESE TRANSACTIONS WERE MADE FROM ONE BANK TO ANOTHER ON SHORT TERM BASIS TOWARDS WHAT SHE TERMED AS 'ADJUSTMENTS FOR SOCIAL NEEDS', WHATEVER THAT MAY MEAN TO HER MIND. (C) THE APPELLANT ALSO SUBMI TTED THAT SHE HAD NOT RECEIVED THE NOTICES, LETTERS AND OTHER CORRESPONDENCES ISSUED BY THE AO AS THE ADDRESS STATED IN THEM WAS THE RESIDENTIAL PREMISES OF HER IN - LAWS FROM WHOM SHE WAS SEPARATED (PHYSICALLY AND BY IMPLICATION, EMOTIONALLY) OWING TO FAMIL Y PROBLEMS, AND IN CONSEQUENCE TO WHICH, SHE WAS NOT RESIDING AT THE RESIDENTIAL ADDRESS OCCUPIED BY HER IN - LAWS. (D) THE APPELLANT SUBMITTED THE COPY OF RECEIPT OF SCHOOL FEES PAID ON BEHALF OF HER CHILD TO SUBSTANTIATE HER CLAIM OF DEDUCTION MADE UN DER CHAPTER VI - A. (E) THE APPELLANT REQUESTED FOR A LENIENT VIEW BASED ON THE FACTS AND CIRCUMSTANCES - OF THE CASE AND TO GRANT FULL RELIEF. 5. LD CIT(A) AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESSEE HELD AS UNDER: 6. I HAVE CONSIDERED THE SUBSTANCE AND CONTENT OF THE ASSESSMENT ORDER AND AFTER EXAMINING THE GROUNDS OF APPEAL PREFERRED AND THE ADDITIONAL SUBMISSIONS MADE BY THE APPELLANT CONTESTING THE SAME, ARRIVE AT THE FOLLOWING FINDINGS AND DECISION. A) THE CLAIM OF DEDUCTION OF RS. 7,200/ - MADE UNDER CHAPTER VIA IS ALLOWED IN VIEW OF THE EVIDENCE SUBMITTED IN THE FORM OF THE COPY OF THE RECEIPT OF SCHOOL FEES PAID, AND THE ATTENDANT FAC T THAT THE APPELLANT WAS PREVENTED FROM APPEARING BEFORE THE AO DURING THE SCRUTINY PROCEEDINGS AND SUBMITTING THE SAID DOCUMENTS OWING TO FAMILY PROBLEMS AND POSSIBLE EMOTIONAL TURMOIL. THEREFORE DUE OPPORTUNITY CAN BE HELD TO HAVE BEEN NOT OBTAINED BY HE R (ALTHOUGH SUCH OPPORTUNITY' WAS INTENDED TO BE ACCORDED BY THE AO) DUE TO NON - RE CEIPT OF NOTICES OWING TO HER NON - PRESENCE AT THE STATED 4 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 ADDRESS. BESIDES, THE AMOUNT OF DEDUCTIO N CLAIMED IS NOT LARGE AND IS OF THE NATURE OF A CLAM PRIMA FACIE SHOWN TO BE ALLOWABLE FROM THE MATERIAL AVAILABLE ON RECORD. MORE OVER, THIS ALLOWANCE IS MADE IN EXERCISE OF CO - TERMIN US AND CONCURRENT POWERS OF ASSESS MENT AND THE AUTHORITY TO RECEIVE, EXAMINE AND ACCEPT ADDITIONAL MATERIAL SUBMITTED BY AN APPELLANT VES TED IN ME AND SANCTIFIED BY THE DECISION OF THE HON'BLE SUPREME COURT IN THE CASE OF JUTE CORPORATION OF INDIA LTD VS CIT (1991) 187 1TR 688 (SC). MOREOVER, THE PROVISIONS OF RULE 46A NEED TO BE READ IN CONSONANCE WITH THE FACT THAT EFFECTIVE OPPORTUNITY W AS NOT PROVIDED TO THE APPELLANT IN THE INSTANT CASE TO SUBSTANTIATE HER END OF THE NARRATIVE. (B) IN RESPECT OF THE CLAIMS OF THE APPELLANT THAT MANY OF THE DEPOSITS IN THE BANK ACCOUNTS WERE SOURCED FROM CORRESPONDING WITHDRAWALS IN CASH FROM THE BANK ACCOUNT, THE MERGED STATEMENTS 'OF BANK ACCOUNTS SUBMITTED HAVE BEEN EXAMINED. IT IS FOUND THAT IN MA NY CASES, THE DEPOSITS MADE IN CASH ARE SIMILAR IN MAGNITUDE (OR OF THE SAME ORDER) TO THE WITHDRAWALS MADE IN CASH ON PROXIMATE (IN THE TEMPORAL NEIGHBORHOOD ) DATES WHICH CAN BE CONSIDERED TO BE QUASI - CONTRA ENTRIES. IT IS ONE OF THE TENETS OF JUST AND FA IR ACCOUNTING AND COMPUTING OF TAXABLE INCOME THAT BOTH SOURCES AND MANIFESTATIONS OF INCOME CANNOT BE TAXED. THE BENEFIT OF TELESCOPING OF THE IDENTIFIED SOURCES INTO THE MANIFESTED DESTINATIONS NEEDS TO BE PROVIDED IN THE INTERESTS OF FAIRNESS AND JUSTIC E. IN THIS CASE, IT WOULD APPEAR THAT THE AO HAS, BY ADDING ONLY THE CREDITS BEING THE CASH DEPOSITS MADE IN ACCOUNTS WHILE STUDIOUSLY IGNORING THE CORRESPONDING WITHDRAWALS MADE, HAS ACTED ILLOGICALLY INCONSISTENTLY AND INJUDICIOUSLY. IT IS THEREFORE THOU GHT FIT TO CARRY OUT A 'PEAK CREDIT EXERCISE' TO DETERMINE THE TOTAL TAXABLE INCOME OF THE APPELLANT BEING INCOMES FROM UNEXPLAINED SOURCES TAXABLE U/S 68 OF THE ACT. THE EXERCISE CARRIED OUT USING THE DATA EXTRACTED FROM THE MERGED STATEMENTS OF THE TWO B ANK ACCOUNTS (AS SUBMITTED BY THE APPELLANT) IS REPRODUCED BELOW: DATE CASH WITHDRAWAL AMOUNT (RS.) CASH DEPOSIT AMOUNT (RS.) DATE - WISE PEAK VALUE (RS.) 08 - 04 - 2010 24000 24000 15 - 04 - 2010 20000 4000 15 - 04 - 2010 2000 2000 5 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 29 - 04 - 2010 3000 5000 03 - 05 - 2010 800 4200 21 - 05 - 2010 1300 5500 24 - 05 - 2010 200000 - 194500 25 - 05 - 2010 1300 - 193200 26 - 05 - 2010 138000 - 331200 26 - 05 - 2010 6000 - 337200 31 - 05 - 2010 10000 - 347200 31 - 05 - 2010 3000 - 350200 04 - 06 - 2010 2000 - 352200 15 - 06 - 2010 1500 - 353700 25 - 06 - 2010 49000 - 304700 06 - 07 - 2010 24000 - 328700 10 - 07 - 2010 1300 - 327400 12 - 07 - 2010 3000 50000 - 280400 16 - 07 - 2010 6000 - 286400 31 - 07 - 2010 1300 - 285100 09 - 08 - 2010 800000 514900 09 - 08 - 2010 1300 516200 18 - 08 - 2010 500 515700 18 - 08 - 2010 1000 514700 20 - 08 - 2010 3000 511700 20 - 08 - 2010 1000 512700 23.8.2010 300000 812700 23.8.2010 5000 807700 23.8.2010 300000 507700 26 - 08 - 2010 300000 807700 26 - 08 - 2010 300000 4000 511700 30 - 08 - 2010 3000 508700 30 - 08 - 2010 1000 507700 09 - 09 - 2010 20000 527700 13 - 09 - 2010 3000 524700 23 - 09 - 2010 200000 724700 23 - 09 - 2010 225000 499700 6 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 28 - 09 - 2010 5000 99000 593700 13 - 10 - 2010 1300 595000 20 - 10 - 2010 2000 593000 25 - 10 - 2000 2000 591000 28 - 10 - 2010 1000 . 590000 11 - 11 - 2010 5000 585000 12 - 11 - 2010 5000 580000 15 - 11 - 2010 4000 576000 06 - 12 - 2010 25000 551000 08 - 12 - 2010 1000000 - 449000 09 - 12 - 2010 2000 - 451000 09 - 12 - 2010 1000000 549000 10 - 12 - 2010 600000 1149000 10 - 12 - 2010 200000 1349000 10 - 12 - 2010 400000 949000 10 - 12 - 2010 1000000 - 51000 27 - 12 - 2010 73000 22000 30 - 12 - 2010 25000 47000 03 - 01 - 2011 2000 45000 03 - 01 - 2011 1500 43500 10 - 01 - 2011 2000 41500 10 - 01 - 2011 1000 40500 14 - 01 - 2011 1000 39500 7 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 14 - 01 - 2011 1000 38500 14 - 01 - 2011 2000 36500 22 - 01 - 2011 2000 34500 24 - 01 - 2011 13000 21500 25 - 01 - 2011 2500 19000 28 - 01 - 2011 500 18500 31 - 01 - 2011 500 18000 01 - 02 - 2011 1000 17000 07 - 02 - 2011 3000 14000 08 - 02 - 2011 2000 12000 14 - 02 - 2011 44000 56000 16.2.2011 10000 46000 18.2.2011 10000 36000 23 - 02 - 2011 3000 33000 25.2.2011 2000 31000 28.2.2011 500 30500 28.2.2011 2000 28500 9.3.2011 1500 27000 11.3.2011 1000 26000 15.3.2011 38000 64000 16.3.2011 5000 59000 16.3.2011 1000 58000 31.3.2011 1000 57000 37,80,000 38,37,000 B) FROM THE ABOVE, IT IS CLEAR THAT THE MAXIMUM OR PEAK CREDIT DEPOSITED IN CASH BY THE APPELLANT IN HER BANK ACCOUNT IS RS. 13,49,000 (SHOWN IN BOLD ITALICIZED RELIEF IN WHITE AGAINST A BLACK BACKGROUND). IT MAY BE NOTED THAT THIS VALUE IS PRIMARILY THE RESULT OF THE CASH DEPOSITS OF RS. 10,00,000 AND RS. 2,00,000 MADE RESPECTIVELY ON 09.12.2010 AND 10.12.2010 THAT DO NOT APPEAR TO POSSESS ANY TEMPORALLY PRECEDING EXPLAIN ED OR ACCOUNTED SOURCES AND ALSO HAVE NOT BEEN BALANCED OUT BY CORRESPONDING LATER WITHDRAWALS. THE WRITTEN STATEMENT OF THE APPELLANT 8 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 ON 27.08.2014 THAT 'ALL DEPOSITS AND WITHDRAWALS ARE FULLY MATCHING EACH OTHER' IS CLEARLY A WRONG DEPICTION OF THE STATE OF AFFAIRS AND IS REJECTED. ACCORDINGLY, THIS AMOUNT OF RS. 13,49,000 IS ACCEPTED AND TREATED AND CHARGED TO TAX U/S 68 OF THE ACT AS THE INCOME OF THE APPELLANT FROM UNEXPLAINED SOURCES. THE ASSESSMENT IS MADE AT THIS FIGURE AS AGAINST THE ORIGINAL FIGUR E OF RS. 38,37,800 DETERMINED AND ASSESSED BY THE AO. D) THE SUBMISSIONS MADE BY THE APPELLANT DURING THE APPELLATE PROCEEDINGS ON 27.08.2014 RECORD 'THAT THE SAVINGS BANK INTEREST THAT HAS ACCRUED TO HER CREDIT OF RS. 67,024 HAVE NOT BEEN REPORTED TO TAX AS PART OF HER RETURNED INCOME. CONSEQUENTLY, THIS AMOUNT OF RS. 67,024/ - IS ASSESSED TO TAX SEPARATELY AS THE INCOME OF THE APPELLANT FROM 'OTHER SOURCES'. THE AO'S ACTION IN THIS 'REGARD IS UPHELD. E) THE GROUNDS OF APPEAL PREFERRED BY THE APPELL ANT DO NOT PROVIDE ANY OTHER FACTUAL INFORMATION THAT IS HELPFUL TO HER CASE. THEY ASSAIL AND HARANGUE THE ACTIONS OF THE AO AND THE IMPUGNED ORDER AS 'WRONG', 'WHOLLY UNJUSTIFIED' AS BEING 'ERRONEOUS IN LAW AS WELL AS ON FACTS IN MAKING ESTIMATING THE INC OME BY APPLYING BEST JUDGMENT ASSESSMENT' 'BAD IN LAW' AND 'FLAGRANTLY VIOLATING THE PRINCIPLES OF NATURAL JUSTICE '. THE ADDITIONAL GROUNDS OF APPEAL TOO ARE OF SIMILAR SYMBOLIC - HYPERBOLIC CONTENT AND ESSENCE AND REMAIN CONSPICUOUS BY THEIR TOTAL NON - RELI ANCE ON AND ABSENCE OF MATERIAL FACTS. SUCH TENDENTIOUS OBFUSCATION IMPLIES THAT THE APPELLANT DOES NOT HAVE ANY LEGITIMATE FACTUAL EVIDENCE IN HER ARSENAL TO S UPPORT HER CONTENTIONS AGAINST THE DECISIONS TAKEN BY THE AO. F) WHILE THE APPELLANT MAY BE FAC TUALLY RIGHT IN STATING THAT SHE DID NOT RECEIVE THE NOTICES ISSUED AND CORRESPONDENCES SENT BY THE AO, AND THAT SHE HAD PRESSING FAMILY PROBLEMS THAT RENDERED HER PHYSICALLY AND EMOTIONALLY INCAPABLE OF APPEARING AT THE ASSESSMENT (SCRUTINY) HEARINGS, SHE COULD NOT HAVE BEEN WHOLLY UNAWARE OF THE PROCEEDINGS ESPECIALLY SINCE HER BROTHER HAD CLEARLY RECEIVED THE NOTICE U/S. 142(1) (ALONG WITH A LETTER CONTAINING A QUESTIONNAIRE) ISSUED BY THE AO ON 16.07.213. STUDIED IGNORANCE OF STATUTORY REQUIREMENTS AND PROCEDURES AND OF THE INCUMBENT RESPONSIBILITY TO COMPLY WITH THEM AND PRESUMED OR PROCLAIMED INNOCENCE OF LAW AND DUE PROCESS, ESPECIALLY OVER A REASONABLY LONG PERIOD OF TIME AND IN THE FACE OF AWARENESS OF THE ASSESSMENT PROCEEDINGS AND IN THE FACE OF A T LEAST AN UNDENIABLE SPECULATIVE PRESUMPTION (FOR THE APPELLANT WOULD NEED TO BE NOT RATIONAL FOR SUCH PRESUMPTION TO NOT EMERGE) THAT THE AO CONCERNED WOULD BE OFFERING REPEATED OPPORTUNITIES (COMPOUNDED BY THE APPELLANT'S APPARENT ATTENDANT FAILURE TO A TTEST SUCH SPECULATION TO BE WRONG AND UNFOUNDED BY CONTACTING THE AO) CANNOT BE HELD AS VALID AND MAINTAINABLE EXCUSES. THE APPELLANT CLEARLY HAS RUN OUT OF EVIDENTIARY FIREPOWER AND HAS NOTHING ELSE TO STATE. ON ACCOUNT OF THESE FACTS AND REASONS, THE AO'S ACTIONS ARE HELD AS CORRECT AND THE ONLY COURSE OF ACTION UNDER THE CIRCUMSTANCES CREATED BY THE APPELLANT. ACCORDINGLY, THE DECISION TO ASSESS THE TAXABLE INCOME OF THE 9 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 APPELLANT U/S 144 OF THE ACT IS UPHELD AS JUSTIFIED, CORRECT IN LAW AND FAIR AND NOT IN VIOLATION OF THE PRINCIPLES OF NATURAL JUSTICE. IT IS ONLY ON THE QUESTION OF ASSESSED INCOME THAT RELIEF AS ABOVE HAS BEEN PROVIDED TO THE APPELLANT. THE AO WAS DENIED ACCESS TO THE BASIS AND STATEMENTS OF COMPUTATION OF THE APPELLANT'S TAXABLE INC OME AND THEREFORE HAD TO RESORT TO BEST JUDGMENT IN ESTIMATING HER TAXABLE INCOME AND DUE TO HER PHYSICAL ABSENCE AND NON - COMPLIANCE, HAD TO PASS EX PARTE ORDERS. 7. IN SUM THE APPEAL IS PARTIALLY ALLOWED ON THE QUANTUM OF THE ASSESSMENT MADE. THE AO IS DIRECTED TO ASSESS THE APPELLANT'S TAXABLE INCOME COMPUTED AS UNDER: INCOME DECLARED IN THE RETURN OF INCOME FILED RS. 2,42,800/ - ADD INCOME FROM UNEXPLAINED SOURCES ASSESSED U/S 68 AS ABOVE RS.13,49,000/ ADD BANK INTEREST ASSESSED AS INCOME FROM OTHER SOURCES RS. 67,024/ - TOTAL TAXABLE INCOME ASSESSED IN THE HANDS OF THE APPELLANT RS. 16,58,824 6. LD D.R. RELIED ON THE ORDER OF THE ASSESSING OFFICER. 7. I FIND THAT THE LD CIT(A) AFTER APPRECIATING THE ENTIRE EVIDENCE ASSESSED THE INCOME OF THE ASSESSEE AT RS.16,58,824/ - IN PLACE OF RS.41,58,824/ - DETERMINED BY THE ASSESSING OFFICER THEREBY ALLOWING RELIEF OF RS.24,88,800/ - BY SUSTAINING THE ADDITION MADE UNDER THE HEAD UNEXPLAINED SOURCES U/S.68 OF THE ACT AT RS.13,49,000/ - IN PLACE OF RS.38,37,800/ - MADE BY THE ASSESSING OFFICER. BEING AGGRIEVED BY THE SAID ORDER OF THE LD CIT(A), THE REVENUE IS IN APPEAL BEFORE ME. LD D.R. SIMPLY RELIED ON THE ORDER OF THE ASSESSING OFFICER. HE COULD NOT POINT OUT ANY SPECIFIC ERROR IN THE ORDER OF THE LD CIT(A) QUOTED ABOVE. THEREFORE, I FIND 10 ITA NO.19/CTK/2015 ASSESSMENT YEAR : 2011 - 2012 NO GOOD REASON TO INTERFERE WITH THE ORDER OF THE LD CIT(A), WHICH IS HEREBY CONFIRMED AND GROUND OF REVENUE IS DISMISSED. 8 . IN THE RESULT, THE APPEAL FILED BY THE REVENUE IS DISMISSED. ORDER PRONOUNCE D IN THE OPEN COURT ON 8 /11 /2016 IN THE PRESENCE OF PARTIES. SD/ - ( N.S SAINI) A CCOUNTANT MEMBER CUTTACK; DATED 8 /11 /2016 B.K.PARIDA, SPS COPY OF THE ORDER FORWARDED TO : BY ORDER, ASST.REGISTRAR, ITAT, CUTTACK 1. THE APPELLANT : INCOME TAX OFFICER, WARD 4(2), BHUBANESWAR 2. THE RESPONDENT. SMT. RUNU KAR, PLOT NO.772, 2 ND FLOOR, MAHARSHI DAYANANDA MARG, SAHID NAGAR, BHUBANESWAR 3. THE CIT(A) - II, BHUBANESWAR 4. CIT , BHUBANESWAR. 5. DR, ITAT, CUTTACK 6. GUARD FILE. //TRUE COPY//