ITO, Ward-48(4), Kolkata, Kolkata V. M/S. Hazi Heritage, Howrah

ITA 2150/KOL/2014

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 1509 (ITAT-KOLKATA)
• Duration Of Justice: 2 year(s) 8 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-07-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2010-2011
• Appeal Filed On: 27-11-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: DAVID Z CHOWNGTHU
• Assessee Lawyers: V N PUROHIT
• Keywords: Wrong claim

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH A, KOLKATA [BEFORE SHRI P.M. JAGTAP, AM & SHRI S.S. VISWANETHRA RAVI, JM] I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 ITO, WARD-48(4), KOLKATA.............................APPELLANT INCOME TAX OFFICE, 3, GOVT. PLACE (WEST), KOLKATA - 700001 M/S. HAZI HERITAGE.....................RESPONDENT JALAN INDUSTRIAL COMPLEX, BIPRANNAPARA, P.S. DOMJUR, JANGALPUR HOWRAH 711411 [PAN: AAEFH7606P] APPEARANCES BY: SHRI DAVID Z. CHOWNGTHU, ADDL. CIT APPEARING ON BEHALF OF THE REVENUE. SHRI V.N. PUROHIT, FCA APPEARING ON BEHALF OF THE ASSESSEE. DATE OF CONCLUDING THE HEARING : JULY 24, 2017 DATE OF PRONOUNCING THE ORDER : JULY 31, 2017 ORDER PER P.M. JAGTAP, AM THIS APPEAL IS PREFERRED BY THE REVENUE AGAINST THE ORDER OF LEARNED CIT (APPEALS) XXX, KOLKATA DATED 18.09.2014 AND THE SOLITARY ISSUE RAISED THEREIN RELATES TO THE DELETION BY THE LD. CIT (A) OF THE DISALLOWANCE MADE BY THE AO ON ACCOUNT OF CONSUMABLE EXPENSES TO THE EXTENT OF RS. 76,74,165/-. 2. THE ASSESSEE IN THE PRESENT CASE IS A PARTNERSHIP FIRM WHICH IS ENGAGED IN THE BUSINESS OF GALVANIZING IRON GOODS ON LABOUR JOB BASIS. THE RETURN OF INCOME FOR THE YEAR UNDER CONSIDERATION WAS FILED BY IT ON 29.09.201 DECLARING A TOTAL INCOME OF RS. 9,62,727/-. IN THE PROFIT & LOSS ACCOUNT FILED ALONG WITH THE SAID RETURN, A SUM OF RS. 3,15,44,707/- WAS DEBITED BY THE ASSESSEE ON ACCOUNT OF CONSUMABLE 2 I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 M/S. HAZI HERITAGE STORES. DURING THE COURSE OF ASSESSMENT PROCEEDING, THE CLAIM OF THE ASSESSEE FOR EXPENSES ON CONSUMABLE STORES WAS EXAMINED BY THE AO. ON SUCH EXAMINATION, HE FOUND THAT THE EXPENSES CLAIMED BY THE ASSESSEE ON CONSUMABLE STORES WERE ABOUT 69% OF THE TOTAL JOB CHARGES WHILE IN THE TWO COMPARABLE CASES SITUATED IN THE SAME LOCALITY NAMELY M/S. SHREE KRISHNA ENGG. & GALVANIZING WORK AND MD. MOHIUDDIN, THE PERCENTAGE OF CONSUMABLE JOB CHARGES WAS 40% TO 21% RESPECTIVELY. HE, THEREFORE, REQUIRED THE ASSESSEE TO EXPLAIN THE HIGHER EXPENSES CLAIMED BY IT ON ACCOUNT OF CONSUMABLE STORES. IN REPLY, IT WAS SUBMITTED BY THE ASSESSEE THAT THERE CANNOT BE ANY STANDARD NORM IN THE TRADE AS REGARDS THE CONSUMPTION OF STORES IN RELATION TO THE JOB CHARGES, SINCE THERE ARE SO MANY REASONS FOR FLUCTUATION OF STORES CONSUMPTION FROM ONE MANUFACTURER TO OTHERS AS PER TECHNICAL NORMS OF THE INDUSTRY. IT WAS ALSO SUBMITTED THAT BOTH THE COMPARABLE CASES CITED BY THE AO USED VERY SMALL COAL FIRE VATS FOR WHICH CONSUMABLE STORES REQUIRED WAS MUCH LESS THAN THE OIL FIRE VATS. IT WAS POINTED OUT THAT THE VAT USED BY THE ASSESSEE WAS BIG IN SIZE HAVING A VOLUME OF 198 CU.FT. WHEREAS THE VAT USED IN THE COMPARABLE CASES WAS HAVING A VOLUME OF 33.75 CU.FT. A COMPARABLE CASE OF M/S. A.M. INDUSTRIES WAS ALSO CITED BY THE ASSESSEE WHEREIN THE EXPENSES CLAIMED ON CONSUMABLE STORES WERE NEARLY 65% OF THE JOB CHARGES. A CERTIFICATE FROM A PLANT ENGINEER WAS ALSO FILED BY THE ASSESSEE CONFIRMING THAT PERCENTAGE OF EXPENSES OF CONSUMABLE IN THE TRADE WAS ABOUT 75 TO 80%. 3 I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 M/S. HAZI HERITAGE 3. THE EXPLANATION OFFERED BY THE ASSESSEE AS REGARDS THE HIGHER EXPENSES CLAIMED ON CONSUMABLE STORES WAS NOT FOUND ACCEPTABLE BY THE AO FOR THE FOLLOWING REASONS. 1. AS REGARDS TO THE CASE OF M/S. A.M. INDUSTRIES PAN AALFA4757B AS RELIED UPON BY THE ASSESSEE, IT IS SEEN THAT THE FURNACE OF THIS CASE IS RUN BY COAL & NOT BY OIL. WHEREAS THE FURNACE OF THE ASSESSEE AND THE OTHER TWO CASES RELIED UPON BY ME IS RUN BY OIL. SO, THE RATIO OF THE CASES AS RELIED UPON BY THE ASSESSEE IS NOT ACCEPTABLE. THE ASSESSEE COULD NOT POINT OUT ANY CASE WHERE FURNACE IS RUN BY OIL AND PERCENTAGE OF CONSUMABLE IS NEARLY 69% ON JOB CHARGES. THUS ASSESSEE HAS FAILED TO SUBSTANTIATE HIS HUGE CLAIM OF ABOUT 69% ON JOB CHARGES EXPENSES IN FORM OF CONSUMABLE BY REFERRING TO A SINGLE CASE. 2. AS REGARDS TO ENGINEERS CERTIFICATE AS DISCUSSED EARLIER IT IS TO BE NOTED THAT SUCH ENGINEER IS NOT A PRODUCTION EXPERT ENGINEER. HE HAS NO EXPERTISE KNOWLEDGE IN PRODUCTION. HE IS AN EXPERT SETTING UP OF A PLANT ONLY. 3. THE CASE REFERRED TO BY THE ASSESSEE IS ALSO A GROUP RELATED CONCERN OF THE ASSESSEE. IN ADDITION TO THAT THE FURNACE OF THIS COMPANY (AS RELIED UPON BY THE ASSESSEE) IS RUN BY COAL WHICH IS DIFFERENT TO THE CASE OF THE ASSESSEE AS WELL AS OTHER TWO CASES AS RELIED UPON BY ME. THE ISSUE HERE IS WHETHER THE EXPENSES CLAIMED BY WAY OF CONSUMABLE IS JUSTIFIED AND REASONABLE. IT IS NOT THAT ISSUE THAT THE ASSESSEE HAS NOT PURCHASED THE CONSUMABLE. THE ASSESSEE MIGHT HAVE PURCHASED THE CONSUMABLE BUT THAT DOES NOT MEAN THAT HUGE PERCENTAGE OF EXPENSES BY WAY OF CONSUMABLE IS JUSTIFIED AND REASONABLE HAS ACTUALLY BEEN USED FOR THAT EXTENT AS CLAIMED. ON THE BASIS OF THE REASON GIVEN ABOVE, THE AO ARRIVED AT THE CONCLUSION THAT THE EXPENSES CLAIMED BY THE ASSESSEE ON CONSUMABLE STORES WERE EXCESSIVE AND UNREASONABLE. HE HOWEVER NOTED THAT THE JOB CHARGES OF THE ASSESSEE WERE AROUND 3.66 PER KG AS AGAINST THE TWO COMPARABLE CASES TAKEN BY HIM WHEREIN IT WAS ABOUT 3 PER KG. GIVING SOME WEIGHTAGE TO THIS ASPECT, THE AO ALLOWED EXPENSES CLAIMED BY THE ASSESSEE ON CONSUMABLE STORES TO THE EXTENT OF 50% 4 I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 M/S. HAZI HERITAGE AND MADE A DISALLOWANCE OF RS. 85,77,008/- BEING 19% OF THE JOB CHARGES OF RS. 4,51,42,147/- EARNED BY THE ASSESSEE. 5. THE DISALLOWANCE OF RS. 85,77,008/- MADE BY THE AO ON ACCOUNT OF CONSUMABLE EXPENSES WAS CHALLENGED BY THE ASSESSEE IN THE APPEAL FILED BEFORE THE LD. CIT (A) THEN AFTER CONSIDERING THE SUBMISSIONS MADE BY THE ASSESSEE AS WELL AS THE MATERIAL AVAILABLE ON RECORD, THE LD. CIT (A) RESTRICTED THE DISALLOWANCE OF RS. 85,77,008/- MADE BY THE AO TO RS. 9,02,843/- FOR THE FOLLOWING REASONS GIVEN IN HIS IMPUGNED ORDER. I HAVE GONE THROUGH THE SUBMISSION MADE BY THE APPELLANT VIDE LETTER DATED 25.08.2014. IT IS SEEN THAT THE A.O. HAS NOT POINTED OUT ANY FAULT IN THE BOOKS OF ACCOUNTS. THE A.O. ALSO NOT POINTED OUT ANY BOGUS CLAIMS OF EXPENSES AGAINST ANY ITEM. IN FACT, HE HAS NOT CONDUCTED ANY ENQUIRY TO ASCERTAIN THE GENUINENESS OF EXPENSES CONTAINED IN CONSUMPTION OF CONSUMABLES OR OTHER ITEMS OF EXPENSES. IF HE THOUGHT THAT THE EXCESS CLAIM OR UNREASONABLE EXPENSES OR BOGUS EXPENSES HAVE BEEN CLAIMED THEN THERE WAS A NEED TO ENQUIRE INTO AND DECISION SHOULD HAVE BEEN BASES ON THE FINDINGS OF THE RELEVANT ENQUIRIES. BUT THE A.O. HAS MADE NO SUCH ENQUIRIES CONNECTED TO ANY ITEM OF EXPENSES CLAIMED BY THE APPELLANT. HE SIMPLY SEEMS TO HAVE SUSPICION THAT THE CONSUMPTION OF CONSUMABLES IS EXCESSIVE. HE HAS PULLED UP CASES OF SHRIKRISHNA ENGINEERING AND MD. MOHIUDDIN WHEREIN 40% AND 21% RESPECTIVELY OF CONSUMABLES ARE SHOWN. COMPARING THESE TWO FIGURES TO THE APPELLANTS CLAIM OF 69%, HE HAS MADE A HIGH PITCHED ADDITION. IN MY VIEW, THIS ACTION IS UNREASONABLE, ILLEGAL AND HAS NO BASIS. IT IS NOT CLEAR THAT IF THE A.O. IS GUIDED BY THE CONSUMPTION DATA OF MD. MOHIUDDIN AND SHRIKRISHNA ENGINEERING THEN WHAT THE BASIS IS FOR HIM FOR TREATING 50% CONSUMPTION AS REASONABLE. EXAMINATION OF CONSUMPTION DETAILS OF THE APPELLANT INDICATES THAT ABOUT 87% OF THE CONSUMPTION RELATES TO FURNACE OIL AND COAL AND THE BALANCE RELATE TO CONSUMABLES BEING ACID, GLOVES, BRICKS, SODIUM, DICHROMATE, ETC. THUS, THE BREAK UP OF THE CONSUMABLES INDICATES THAT UNDER THIS ITEM THE ENERGY CONSUMPTION IN THE FORM OF OIL AND COAL UP TO THE AMOUNT OF 87% HAS BEEN INCLUDED. THE A.O. HAS GIVEN NO FINDING OR OBSERVATION ON ACTUAL CONSUMPTION AS CLAIMED OF OIL AND COAL. 5 I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 M/S. HAZI HERITAGE FROM THE PROFIT AND LOSS ACCOUNT, IT IS SEEN THAT THE APPELLANT HAS OFFERED RS. 30,43,631/- OF NET PROFIT IN THE P&L ACCOUNT ON TURNOVER OF RS. 4,51,42,147/- WHICH IS ABOUT 6.74% OF TURNOVER BEING LABOUR CHARGES. THE GROSS PROFIT IS RS. 42,19,819/- WHICH IS 9.35% OF LABOUR CHARGES SHOWN IN THE TRADING OR MANUFACTURING ACCOUNT. THE ASSESSED INCOME OF RS. 1,14,07,080/- (EXCLUDING PARTNERS SALARY) IS 25.27% OF THE TURNOVER, WHICH IN MY VIEW IS EXTREMELY HIGH. IN MY VIEW, THE A.O. HAS NO MATERIAL TO REJECT THE BOOK PROFIT SHOWN BY THE APPELLANT. CONSUMPTION OF OIL OR COAL MAY DEPEND ON VARIOUS FACTORS LIKE TECHNICAL, OPERATIONAL OR COMMERCIAL. WITHOUT REJECTING THE BOOKS OF ACCOUNTS, IT IS NOT PERMISSIBLE FOR THE A.O. TO BE GUIDED BY NET PROFIT OR GROSS PROFIT MARGIN OF SOME OTHER BUSINESSMEN. IT IS ONLY WHEN THE BOOKS ARE REJECTED THAT THE A.O. GETS THE AUTHORITY OR HAS THE OPTION OF USING G.P. OR N.P. FROM SOME OTHER SOURCE IN SIMILAR CIRCUMSTANCES. THE A.O. HAS NOT BEEN ABLE TO DEMONSTRATE. IF SHRIKRISHNA ENGINEERING AND MD. MOHIUDDIN ARE IDENTICALLY PLACED. THEREFORE, THIS ADDITION CANNOT BE SUSTAINED. HOWEVER, THE APPELLANT HAS CITED THE CASE OF M/S. A.M. INDUSTRIES WHERE CONSUMPTION IS SHOWN AT 65%. GROSS PROFIT OF THE APPELLANT IS 9.6% AND THE N.P. IS 6.74% OF TURNOVER, WHICH CANNOT BE SAID UNREASONABLY LOW. HAVING REGARD TO THE A.OS OBSERVATIONS AND THE APPELLANTS SUBMISSION BEFORE THE ASSESSING OFFICER AND IN THE APPEAL STAGE I CONSIDER IT REASONABLE TO VARY THE ASSESSMENT TO NET PROFIT PERCENTAGE IN EXCESS OF 2% OVER THE FIGURE DISCLOSED AS PER THE AUDITED P & L ACCOUNT. THUS, THE ADDITION IS SUSTAINED ONLY OF ABOUT 2% OF TURNOVER OF RS. 4,51,42,147/- BEING RS. 9.02,843/-. THE BALANCE ADDITION OF RS. 85,77,008/- (-) RS. 9,02,843/- = RS. 76,74,165/- IS DELETED. AGGRIEVED BY THE ORDER OF THE LD. CIT (A), THE REVENUE HAS PREFERRED THIS APPEAL BEFORE THE TRIBUNAL. 6. THE LEARNED DR INVITED OUR ATTENTION TO THE RELEVANT PORTION OF THE ASSESSMENT ORDER TO POINT OUT THE REASONS GIVEN BY THE AO FOR TREATING THE CLAIM OF THE ASSESSEE FOR EXPENSES ON CONSUMABLE STORES AS EXCESSIVE AND UNREASONABLE. HE SUBMITTED THAT THE EXPENSES CLAIMED ON ACCOUNT OF CONSUMABLE STORES IN COMPARABLE CASES CITED BY THE AO WERE ONLY 40% AND 21% AS AGAINST 69% CLAIMED BY THE ASSESSEE AND THIS SUBSTANTIAL DIFFERENCE COULD NOT BE SATISFACTORILY 6 I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 M/S. HAZI HERITAGE EXPLAINED BY THE ASSESSEE IN SPITE OF SUFFICIENT OPPORTUNITY AFFORDED BY THE AO. HE CONTENDED THAT THE LD. CIT (A) HOWEVER ALLOWED A SUBSTANTIAL RELIEF TO THE ASSESSEE ON THIS ISSUE BY RESTRICTING THE DISALLOWANCE BY 19% MADE BY THE AO TO 2% WITHOUT APPRECIATING THE SPECIFIC ADVERSE FINDINGS RECORDED BY THE AO IN THE ASSESSMENT ORDER. HE ALSO CONTENDED THAT NO BASIS WHATSOEVER HAS BEEN GIVEN BY THE LD. CIT (A) FOR THE DISALLOWANCE TO THE EXTENT OF 2% SUSTAINED BY HIM ON ACCOUNT OF CONSUMABLE STORES. 7. THE LEARNED COUNSEL FOR THE ASSESSEE ON THE OTHER HAND SUBMITTED THAT THE BOOKS OF ACCOUNTS REGULARLY MAINTAINED BY THE ASSESSEE WERE NEITHER REJECTED BY THE AO NOR ANY MATERIAL OR SPECIFIC DEFECTS WERE POINTED OUT BY HIM IN THE BILLS AND VOUCHERS MAINTAINED BY THE ASSESSEE IN SUPPORT OF ITS CLAIM FOR EXPENSES ON ACCOUNT OF CONSUMABLE STORES. HE INVITED OUR ATTENTION TO THE COMPARATIVE DETAILS GIVEN AT PAGE 21 OF HIS PAPER BOOK TO SHOW THAT THE EXPENSES CLAIMED BY THE ASSESSEE ON CONSUMABLE STORES WERE ALWAYS IN THE RANGE OF 68% TO 70% IN THE IMMEDIATELY PRECEDING TWO YEARS AS WELL AS IN THE IMMEDIATELY SUCCEEDING TWO YEARS. HE CONTENDED THAT EVEN THE GROSS PROFIT SHOWN BY THE ASSESSEE DURING THIS YEAR WAS QUITE COMPARABLE TO THAT OF THE YEAR UNDER CONSIDERATION. HE ALSO CONTENDED THAT DISTINGUISHING FEATURES BETWEEN THE CASE OF THE ASSESSEE AND THE COMPARABLE CASES CITED BY THE AO WERE SPECIFICALLY POINTED OUT BY THE ASSESSEE TO SHOW THAT THE COMPARISON SOUGHT TO BE MADE BY THE AO WAS NOT FAIR AND PROPER. HE CONTENDED THAT THE LD. CIT (A) HOWEVER APPRECIATED THESE RELEVANT FACTS OF THE MATTER IN 7 I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 M/S. HAZI HERITAGE RIGHT PERSPECTIVE WHILE DELETING SUBSTANTIALLY THE DISALLOWANCE MADE BY THE AO ON ACCOUNT OF CONSUMABLE STORES. 8. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS AND ALSO PERUSED THE RELEVANT MATERIAL AVAILABLE ON RECORD. IT IS OBSERVED THAT THE DISALLOWANCE ON ACCOUNT OF CONSUMABLE EXPENSES WAS MADE BY THE AO TO THE EXTENT OF 19% OF THE JOB CHARGES EARNED BY THE ASSESSEE BY MAINLY RELYING ON THE TWO COMPARABLE CASES WHERE THE CONSUMABLE EXPENSES CLAIMED WERE RELATIVELY ON THE LOWER SIDE. DURING THE COURSE OF ASSESSMENT PROCEEDING, IT WAS POINTED OUT ON BEHALF OF THE ASSESSEE THAT THE SAID CASES CITED BY THE AO WERE ACTUALLY NOT COMPARABLE IN AS MUCH AS THE VATS USED BY THEM WERE SMALL IN SIZES HAVING VOLUME OF 33.75 CU.FT. AS COMPARED THE VAT OF 198 CU.FT. USED BY THE ASSESSEE. A COMPARABLE CASE OF M/S. A.M. INDUSTRIES WAS ALSO CITED BY THE ASSESSEE WHEREIN THE EXPENSES CLAIMED ON CONSUMABLES WERE NEARLY 65% OF THE JOB CHARGES EARNED. A CERTIFICATE ISSUED BY A PLANT ENGINEER WAS ALSO FILED BY THE ASSESSEE TO SHOW THAT THE PERCENTAGE OF CONSUMABLE EXPENSES IN THE INDUSTRY OF ASSESSEES TYPE WAS 75 TO 80%. AS RIGHTLY CONTENDED BY THE LEARNED COUNSEL FOR THE ASSESSEE, IT APPEARS THAT THE ASSESSING OFFICER HOWEVER BRUSHED ASIDE ALL THESE SUBMISSIONS MADE BY THE ASSESSEE TO JUSTIFY THE CONSUMABLE EXPENSES OF 69% CLAIMED BY IT AND DISALLOWED THE SAME TO THE EXTENT OF 19% POINT. THE LD. CIT(A) HOWEVER APPRECIATED ALL THESE RELEVANT ASPECTS OF THE CASE IN THE RIGHT PERSPECTIVE AND ALSO CONSIDERED THE PAST RESULT OF THE ASSESSEES CASE FOR THE IMMEDIATELY SUCCEEDING TWO YEARS WHEREIN THE CONSUMABLE EXPENSES CLAIMED BY THE ASSESSEE WERE 67.63% AND 67.75% AS AGAINST THE CONSUMABLE EXPENSES OF 69.98% 8 I.T.A. NO. 2150/KOL/2014 ASSESSMENT YEAR: 2010-11 M/S. HAZI HERITAGE CLAIMED BY THE ASSESSEE FOR THE YEAR UNDER CONSIDERATION. HE ACCORDINGLY FOUND THAT THE CLAIM OF THE ASSESSEE FOR THE CONSUMABLE EXPENSES AS MADE IN THE YEAR UNDER CONSIDERATION WAS SLIGHTLY HIGHER BY 2% THAN THAT OF THE IMMEDIATELY PRECEDING TWO YEARS AND ACCORDINGLY RESTRICTED THE DISALLOWANCE OF 19% MADE BY THE AO TO THE EXTENT OF 2% OF THE JOB CHARGES EARNED. HAVING REGARD TO ALL THE FACTS OF THE CASE, WE FIND NO INFIRMITY IN THE IMPUGNED ORDER OF THE LD. CIT (JA) RESTRICTING THE DISALLOWANCE OF 19% MADE BY THE AO TO THE EXTENT OF 2% AND UPHOLDING THE SAME, WE DISMISS THE APPEAL FILED BY THE REVENUE. 9. IN THE RESULT, THE APPEAL OF THE REVENUE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 31 ST JULY, 2017. SD/- SD/- (S.S. VISWANETHRA RAVI) (P.M. JAGTAP) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 31/07/2017 BISWAJIT, SR. P.S. COPY OF ORDER FORWARDED TO: 1. M/S. HAZI HERITAGE, JALAN INDUSTRIAL COMPLEX, BIPRANNAPARA, P.S. DOMJUR, JANGALPUR, HOWRAH 711411. 2. ITO, WARD 48(4), KOLKATA, INCOME TAX OFFICE, 3, GOVT. PLACE (WEST), KOLKATA - 700001 3. THE CIT(A) 4. THE CIT 5. DR TRUE COPY, BY ORDER, SR. P.S. / H.O.O. ITAT, KOLKATA