Sukumar Mondal, Howrah V. I.T.O.,Ward-47(4), Kolkata

ITA 2605/KOL/2019

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 8737 (ITAT-KOLKATA)
• Duration Of Justice: 7 month(s) 4 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 22-07-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2014-2015
• Appeal Filed On: 18-12-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SUPRIYA PAL CIT SR D R RESPON
• Assessee Lawyers: S M SURANA
• Keywords: Business income; Bonafide mistake; Set aside
• Section: 143(3); 22

Judgement Text

ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 1 IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA B BENCH, KOLKATA [VIRTUAL COURT HEARING] BEFORE SHRI P.M. JAGTAP, VICE-PRESIDENT & SHRI A.T. VARKEY, JUDICIAL MEMBER I.T.A. NO. 2605/KOL/2019 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL,.................................... ....................................APPELLANT GOBINDAPUR, VILL. & P.O. GOBINDAPUR, HOWRAH-711314 [PAN: AEUPM4095D] -VS.- INCOME TAX OFFICER,................................ .....................................RESPONDENT WARD-47(4), KOLKATA, 3, GOVERNMENT PLACE (WEST), KOLKATA-700001 APPEARANCES BY: SHRI S.M. SURANA, ADVOCATE, FOR THE APPELLANT SHRI SUPRIYA PAL, ADDL. CIT, SR. D.R., FOR THE RESP ONDE NT DATE OF CONCLUDING THE HEARING : JULY 14, 2020 DATE OF PRONOUNCING THE ORDER : JULY 22, 2020 O R D E R PER SHRI P.M. JAGTAP, VICE-PRESIDENT :- THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAI NST THE ORDER OF LD. COMMISSIONER OF INCOME TAX (APPEALS)-14, KOLKATA DA TED 21.11.2019 AND THE SOLITARY ISSUE INVOLVED THEREIN RELATES TO THE ADDITION OF RS.51,63,531/- MADE BY THE ASSESSING OFFICER AND CO NFIRMED BY THE LD. CIT(APPEALS) ON ACCOUNT OF THE PROFIT ALLEGEDLY EAR NED BY THE ASSESSEE ON UNDISCLOSED TURNOVER. ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 2 2. THE ASSESSEE IN THE PRESENT CASE IS AN INDIVIDUA L, WHO IS ENGAGED IN THE BUSINESS OF DISTRIBUTION OF FOOD AND SUPPLY OF RATION GOODS AND DEALING IN LAFARGE AND ACC CEMENT. THE RETURN OF IN COME FOR THE YEAR UNDER CONSIDERATION WAS FILED BY HIM ON 17.09.2014 DECLARING TOTAL INCOME OF RS.5,54,330/-. THE SAID RETURN WAS SELECT ED FOR LIMITED SCRUTINY ON THE GROUND THAT THE CASH DEPOSITS FOUND TO BE MA DE IN THE SAVINGS BANK ACCOUNTS OF THE ASSESSEE WERE MORE THAN THE TU RNOVER. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSING OFF ICER FOUND THAT THE ASSESSEE HAS MAINTAINED THREE BANK ACCOUNTS NAMELY ACCOUNT NO. 10380100001206 WITH PASCHIM BANGA GRAMIN BANK, ACCO UNT NO. 08160510000298 WITH UCO BANK, SHYAMPUR AND ACCOUNT NO. 11245243909 WITH STATE BANK OF INDIA. HE ALSO FOUND THAT OUT OF THE SAID THREE BANK ACCOUNTS, THE BALANCE OF ONLY ONE BANK ACCOUNT WITH STATE BANK OF INDIA WAS REFLECTED IN THE AUDITED BALANCE- SHEET FILED BY THE ASSESSEE, WHEREAS THE BALANCES OF THE REMAINING TWO BANK ACCOUNTS MAINTAINED WITH PASCHIM BANGA GRAMIN BANK AND UCO B ANK WERE NOT REFLECTED IN THE BALANCE-SHEET. HE ALSO NOTICED THA T INTEREST CHARGED IN ONE ACCOUNT AND INTEREST CREDITED IN THE OTHER ACCO UNTS HAD ALSO NOT BEEN REFLECTED IN THE ACCOUNTS OF THE ASSESSEE. KEEPING IN VIEW THESE SERIOUS DISCREPANCIES IN THE ACCOUNTS OF THE ASSESSEE, THE ASSESSING OFFICER TREATED THE TOTAL DEPOSITS FOUND TO BE MADE IN THE TWO BANK ACCOUNTS MAINTAINED BY THE ASSESSEE WITH PASCHIM BANGA GRAMI N BANK AND UCO BANK AGGREGATING TO RS.5,42,38,779/- AS THE UNDISCL OSED TURNOVER OF THE ASSESSEES BUSINESS AND APPLYING A GROSS PROFIT RAT E OF 9.52% AS REFLECTED IN THE AUDITED ACCOUNTS OF THE ASSESSEE, HE MADE AN ADDITION OF RS.51,63,531/- TO THE TOTAL INCOME OF THE ASSESSEE IN THE ASSESSMENT COMPLETED UNDER SECTION 143(3) OF THE ACT VIDE AN O RDER DATED 23.11.2016. 3. AGAINST THE ORDER PASSED BY THE ASSESSING OFFICE R UNDER SECTION 143(3), AN APPEAL WAS PREFERRED BY THE ASSESSEE BEF ORE THE LD. CIT(APPEALS) AND THE FOLLOWING SUBMISSIONS WERE MAD E ON BEHALF OF THE ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 3 ASSESSEE BEFORE THE LD. CIT(APPEALS) IN SUPPORT OF HIS CASE THAT THE ADDITION OF RS.51,63,531/- MADE BY THE ASSESSING OF FICER ON ACCOUNT OF PROFIT ALLEGEDLY EARNED ON UNDISCLOSED TURNOVER WAS NOT SUSTAINABLE:- THE ASSESSEE HHAS THREE BANK ACCOUNTS VIZ. (I) PASCHIMBANGA GRAMIN BANK, (II) CC ACCOUNT WITH UCO BANK, SHYAMPUR AND (III) STATE BANK OF INDIA, ULUBE RIA. ALL THE CASH RECEIVED FROM THE RATION SHOP IS DEPOSITED IN PASCHIMBANGA GRAMIN BANK ACCOUNT AND FROM THE SAME, THE DEMAND DRAFTS ARE PREPARED FOR PAYMENT TO FCI. IT IS SUBMITTED THAT THE TOTAL SALES ON ACCOUNT OF THIS B USINESS AS DISCLOSED IN MY BOOKS OF ACCOUNTS IS RS.3,29,61, 654/- WHEREAS THE TOTAL DEPOSITS IN THE PASCHIMBANGA GRAM IN BANK ACCOUNT IS RS.2,91,40,029/-. THEREFORE, THE TO TAL AMOUNT DEPOSITED IN PASCHIMBANGA GRAMIN BANK ACCOUN T IS LESS THAN THE TOTAL SALES DISCLOSED BY THE ASSES SEE IN HIS PROFIT AND LOSS ACCOUNT FROM RATION SHOP. HENCE ALL THE DEPOSITS MADE IN THIS BANK ACCOUNT IS FORMING PART OF SALES AND ALREADY DISCLOSED IN THE PROFIT AND LOSS ACCOUN T. THIS IS FURTHER PROVED FROM THE FACT STATED ABOVE THAT THE PAYMENT FOR PURCHASE IS MADE FROM THE VERY SAME ACCOUNT AND ALL PURCHASES ARE ALSO FORMING PART OF THE ACCOUNTS FOR WHICH THE PAYMENT IS MADE FROM THIS BANK. FURTHER, IN RELATION TO THE SECOND BUSINESS OF THE ASSESSOR AS CEMENT DEALER OF LAFARGE, ACC, IT IS SUBMITTED T HAT THE SAME PROCESS WHICH IS FOLLOWED IN THE RATION SUPPLY BUSINESS IS FOLLOWED IN THIS BUSINESS I.E. THE SALE S ARE MADE IN CASH AND THE PROCEEDS ARE DEPOSITED IN THE CC AC COUNT OF UCO BANK. THE PAYMENT FOR PURCHASE OF CEMENT IS MAD E IN CHEQUES OR DEMAND DRAFTS FROM THE CC ACCOUNT OF UCO BANK ITSELF. THE TOTAL AMOUNT DEPOSITED IN THIS ACCOUNT IS RS.2,50,98,750/- WHEREAS THE SALES ON THIS BUSINESS AS DISCLOSED IN PROFIT AND LOSS ACCOUNT FILED BEFORE T HE DEPARTMENT IS RS.2,60,60,841/-. THEREFORE, THE TOTA L AMOUNT OF DEPOSITS IN UCO BANK ACCOUNT IS LESS THAN THE TOTAL SALES DISCLOSED BY THE ASSESSEE IN HIS PROFIT AND LOSS ACCOUNT. HENCE, ALL THE DEPOSITS MADE IN THIS BANK ACCOUNT IS FORMING PART SALES AND ALREADY DISCLOSED IN THE PROFIT AND LOSS ACCOUNT. THE FACT HOWEVER REMAINS THAT DUE TO OVERSIGHT THES E TWO BANK ACCOUNTS WERE OMITTED TO BE TAKEN IN THE BALAN CE SHEET THOUGH THE PURCHASE CONTAINED AND PAYMENT MAD E FOR THE SAME IS PART OF THE PROFIT AND LOSS ACCOUNT AND BOOKS OF ACCOUNTS. THE NON-MENTION OF THE ACCOUNT I N THE BALANCE SHEET IS A SHEER BONAFIDE MISTAKE WHICH IS FURTHER ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 4 PROVED FROM THE FACT THAT THE GENUINE INTEREST PAID ON THE OVERDRAFT CC ACCOUNT WAS ALSO NOT DEBITED TO THE PR OFIT AND LOSS ACCOUNT. THEREFORE, IN SUCH CIRCUMSTANCES THE AO COULD HAVE ADDED THE CLOSING BALANCE IN THE BANK AC COUNT AS INCOME. HOWEVER, ON THE FACTS THIS ADDITION WAS NOT CALLED FOR SINCE IN UCO BANK THERE WAS OD OF RS.17,38,565/- AS ON 31.03.2014 AND IN PASCHIMBANGA GRAMIN BANK, THERE WAS BALANCE OF RS.77,158/- ONLY. THE BANK BALANCE ON THE OPENING DAY I.E. 1.4.2013 WAS RS.1,37,752/-. HENCE, THE BALANCE WAS NOT MORE THAN THE OPENING BALANCE AND NO ADDITION CAN BE MADE. THESE EXPLANATIONS WERE SUBMITTED TO THE AO AT THE TIME OF ASSESSMENT PROCEEDINGS, BUT THE AO REJECTED THE SAM E AND ADDED RS.51,63,531/- AS GROSS PROFIT ON ACCOUNT OF THESE ALLEGED UNDISCLOSED SALES ON AN ESTIMATE BASIS. THE REFORE, THE ACTION OF THE AO IN ADDING BACK THE GROSS PROFI T ON THIS SALE IS NOT CORRECT AS IT IS ALREADY INCLUDED IN TH E GROSS PROFIT ALREADY DISCLOSED AND IF THE SAME IS ADDED A GAIN, THEN IT WILL BE DOUBLE ADDITION. IT IS SUBMITTED TH AT THE ADDITION CANNOT BE MADE SOLELY ON THE BASIS OF TWO BANK ACCOUNTS WHICH INADVERTENTLY WERE MISSED TO BE INCORPORATED IN THE BALANCE SHEET OF THE ASSESSEE. THE COPY OF THE BANK STATEMENT FOR BOTH BANKS IS AT TACHED HEREWITH. THE FACTS STATED ABOVE ARE FULLY VERIFIAB LE FROM THE BANK ACCOUNTS WHERE FOR PURCHASE PAYMENTS EVEN THE NAMES OF THE SELLERS ARE MENTIONED. HENCE, THE ADDI TION WAS NOT CALLED FOR AND MAY BE DELETED. 4. THE LD. CIT(APPEALS) DID NOT FIND MERIT IN THE S UBMISSIONS MADE ON BEHALF OF THE ASSESSEE AND REJECTING THE SAME, HE C ONFIRMED THE ADDITION OF RS.51,63,531/- ON THE ISSUE UNDER CONSIDERATION FOR THE FOLLOWING REASONS GIVEN IN PARAGRAPH NO. 3.3 OF HIS IMPUGNED ORDER:- 3.3. I HAVE GONE THROUGH THE SUBMISSION OF THE APP ELLANT AND PERUSED THE RELEVANT RECORDS. THE APPELLANT HAS THREE ACCOUNTS WITH THE FOLLOWING BANKS:- (I) PASCHIMBANGA GRAMIN BANK (A/C. NO.10380100001206); (II) CC ACCOUNT WITH UCO BANK, SHYAMPUR (A/C. NO. 08160510000298) & (III) STATE BANK OF INDIA, ULUBERIA (A/C. NO. 11245243909 ). ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 5 THE APPELLANT HAD REFLECTED ONLY ACCOUNT WITH STATE BANK OF INDIA, ULUBERIA, A/C. NO. 11245243909 IN ITS AUDITE D BALANCE SHEET. THE REMAINING TWO BANK ACCOUNTS WERE NOT REF LECTED IN THE AUDITED BALANCE SHEET OF THE APPELLANT. THE AO HAD ESTIMATED UNDISCLOSED INCOME EARNED FROM THESE TWO UNDISCLOSE D BANK ACCOUNTS @ GP RATE OF 9.52% ON TOTAL DEPOSITS AMOUN TING TO RS.5,42,38,779/-. THE A/R OF THE APPELLANT IN HIS S UBMISSION HAD STATED THAT THE OMISSION TO INCLUDE THESE TWO BANK ACCOUNTS IN THE AUDITED BALANCE SHEET IS DUE TO OVERSIGHT AND THAT ALL THE PURCHASES AND SALES MADE FROM THESE TWO BANK ACCOUN TS HAVE BEEN REFLECTED IN THE AUDITED ACCOUNTS OF THE APPELLANT. ON EXAMINATION OF THESE TWO BANK ACCOUNTS, IT IS FOUND THAT HUGE A MOUNTS WERE DEPOSITED IN CASH. THE AR OF THE APPELLANT COULD NO T CORRELATE BETWEEN THESE CASH DEPOSITS AND SALES MADE IN THE B OOKS. IT IS TRUE THAT THESE UNDISCLOSED BANK ACCOUNTS ALSO REFLECT P URCHASES BY RTGS/CHEQUE MADE FROM LAFARGE INDIA LIMITED AND ACC LTD. BUT AS MENTIONED EARLIER THE AR OF THE APPELLANT COULD NOT PROVIDE EVIDENCE THAT THE SALES WERE REFLECTED IN THE BOOKS . THE AO HAD NOT ADDED BACK THE TOTAL DEPOSITS IN THESE TWO BANK ACCOUNTS BUT COMPUTED INCOME FROM THESE ACCOUNTS ON THE BASIS OF GROSS PROFIT OF 9.52%. I FIND NO MERIT THEREFORE, TO INTERFERE I N THE ORDER OF THE AO. THE ADDITION OF RS.51,63,531/- IS CONFIRMED. TH IS GROUND OF APPEAL FAILS AND IS THEREFORE NOT ALLOWED. AGGRIEVED BY THE ORDER OF THE LD. CIT(APPEALS), THE ASSESSEE HAS PREFERRED THIS APPEAL BEFORE THE TRIBUNAL. 5. WE HAVE HEARD THE ARGUMENTS OF BOTH THE SIDES AN D ALSO PERUSED THE RELEVANT MATERIAL AVAILABLE ON RECORD. THE FIRST CO NTENTION RAISED BY THE LD. COUNSEL FOR THE ASSESSEE IS THAT THE CASE OF TH E ASSESSEE HAVING BEEN SELECTED FOR LIMITED SCRUTINY ON THE ISSUE OF CASH DEPOSITS IN THE BANK ACCOUNTS BEING MORE THAN THE TURNOVER, THE SCOPE OF THE ASSESSMENT WAS LIMITED AND THE ASSESSING OFFICER WAS NOT JUSTIFIED TO MAKE THE ADDITION ON ACCOUNT OF PROFIT ALLEGEDLY EARNED BY THE ASSESS EE ON UNDISCLOSED TURNOVER, WHICH WAS AN ALTOGETHER DIFFERENT ISSUE. WE ARE UNABLE TO ACCEPT THIS CONTENTION OF THE LD. COUNSEL FOR THE A SSESSEE. WHILE EXAMINING THE ISSUE OF CASH DEPOSITS IN THE BANK AC COUNTS OF THE ASSESSEE BEING MORE THAN THE TURNOVER, IT WAS FOUND BY THE A SSESSING OFFICER THAT TWO BANK ACCOUNTS MAINTAINED BY THE ASSESSEE WITH P ASCHIM BANGA ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 6 GRAMIN BANK AND UCO BANK WERE NOT REFLECTED IN THE ACCOUNTS OF THE ASSESSEE. HE ALSO NOTICED THAT HUGE DEPOSITS AGGREG ATING TO RS.5,42,38,779/- WERE MADE IN THE SAID BANK ACCOUNT S AND SINCE THE SAID BANK ACCOUNTS WERE FOUND TO BE NOT REFLECTED IN THE ACCOUNTS OF THE ASSESSEE, THE SAME WERE TREATED BY HIM AS THE UNDIS CLOSED TURNOVER OF THE ASSESSEES BUSINESS AND ESTIMATED PROFIT THEREON WA S ADDED BY HIM TO THE TOTAL INCOME OF THE ASSESSEE. IT IS THUS CLEAR THAT THE IMPUGNED ADDITION MADE BY THE ASSESSING OFFICER ON ACCOUNT OF PROFIT ALLEGEDLY EARNED BY THE ASSESSEE ON UNDISCLOSED TURNOVER WAS DIRECTLY RELAT ED TO THE GROUND ON WHICH THE CASE OF THE ASSESSEE WAS SELECTED FOR LIM ITED SCRUTINY AND THE SAME BEING FALL-OUT OF THE VERIFICATION MADE BY THE ASSESSING OFFICER ON THE ISSUE ON WHICH THE CASE OF THE ASSESSEE WAS SEL ECTED FOR LIMITED SCRUTINY, WE DO NOT FIND MERIT IN THE CONTENTION RA ISED BY THE LD. COUNSEL FOR THE ASSESSEE THAT THE IMPUGNED ADDITION MADE BY THE ASSESSING OFFICER IS BEYOND THE SCOPE OF LIMITED SCRUTINY. 6. THE SECOND CONTENTION RAISED BY THE LD. COUNSEL FOR THE ASSESSEE IS THAT THE DEPOSITS FOUND TO BE MADE IN THE TWO BANK ACCOUNTS MAINTAINED WITH PASCHIM BANGA GRAMIN BANK AND UCO BANK AGGREGA TING TO RS.5,42,38,779/- REPRESENTED THE SALE PROCEEDS OF T HE REGULAR BUSINESS OF THE ASSESSEE AND THE SAME HAVING BEEN INCLUDED IN T HE TURNOVER OF RS.5,65,50,985/- AS DECLARED BY THE ASSESSEE IN HIS RETURN OF INCOME FOR THE YEAR UNDER CONSIDERATION (COPY AT PAGE NO. 15 O F THE PAPER BOOK), IT WAS NOT A CASE OF UNDISCLOSED TURNOVER AND THE ADDI TION MADE BY THE ASSESSING OFFICER AND CONFIRMED BY THE LD. CIT(APPE ALS) ON ACCOUNT OF PROFIT ALLEGEDLY EARNED BY THE ASSESSEE ON SUCH UND ISCLOSED TURNOVER IS NOT SUSTAINABLE. IN THIS REGARD, IT IS OBSERVED THA T A SIMILAR CONTENTION WAS RAISED BY THE ASSESSEE EVEN DURING THE COURSE O F APPELLATE PROCEEDINGS BEFORE THE LD. CIT(APPEALS) BUT THE SAM E WAS REJECTED BY THE LD. CIT(APPEALS) ON THE GROUND THAT THE ASSESSEE CO ULD NOT CO-RELATE BETWEEN THE CASH DEPOSITS FOUND TO BE MADE IN HIS T WO BANK ACCOUNTS AND THE SALES REFLECTED IN THE BOOKS. AS ALREADY NOTED BY US, SERIOUS ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 7 DISCREPANCIES WERE FOUND IN THE BOOKS OF ACCOUNT OF THE ASSESSEE, INASMUCH AS, THE SUBSTANTIAL BALANCES IN THE TWO AC COUNTS MAINTAINED BY THE ASSESSEE WITH PASCHIM BANGA GRAMIN BANK AND UCO BANK WERE NOT REFLECTED IN THE AUDITED BALANCE-SHEET OF THE ASSES SEE. SIMILARLY THE INTEREST EARNED BY THE ASSESSEE IN ONE BANK ACCOUNT AS WELL AS INTEREST CHARGED IN THE OTHER BANK ACCOUNT WAS ALSO NOT REFL ECTED IN THE ACCOUNTS OF THE ASSESSEE. KEEPING IN VIEW THESE SERIOUS DISC REPANCIES SERIOUSLY DOUBTING THE RELIABILITY OF THE AUDITED ACCOUNTS OF THE ASSESSEE, THE ONUS, IN OUR OPINION, WAS GREATER ON THE ASSESSEE TO ESTA BLISH BY FURNISHING CASH FLOW STATEMENT DULY SUPPORTED BY THE RELEVANT BOOKS OF ACCOUNT THAT THE DEPOSITS FOUND TO BE MADE IN THE BANK ACCOUNTS MAINTAINED WITH PASCHIM BANGA GRAMIN BANK AND UCO BANK REPRESENTED THE SALE PROCEEDS OF HIS BUSINESS, WHICH WERE DULY REFLECTED IN THE B OOKS OF ACCOUNT AND INCLUDED IN THE TOTAL TURNOVER FINALLY DECLARED IN THE RETURN OF INCOME. SINCE THIS EXERCISE WAS NOT SPECIFICALLY DONE BY TH E ASSESSEE EITHER DURING THE COURSE OF ASSESSMENT PROCEEDINGS BEFORE THE ASS ESSING OFFICER OR DURING THE COURSE OF APPELLATE PROCEEDINGS BEFORE T HE LD. CIT(APPEALS), WE CONSIDER IT FAIR AND PROPER AND IN THE INTEREST OF JUSTICE TO SET ASIDE THE IMPUGNED ORDER OF THE LD. CIT(APPEALS) ON THIS ISSUE AND RESTORE THE MATTER BACK TO THE FILE OF THE ASSESSING OFFICER FO R DECIDING THE SAME AFRESH AFTER GIVING THE ASSESSEE AN OPPORTUNITY TO SUPPORT AND SUBSTANTIATE HIS CASE ON THE ISSUE BY PREPARING AND FURNISHING A CASH FLOW STATEMENT DULY SUPPORTED BY THE RELEVANT BOOKS OF A CCOUNT. 7. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS TRE ATED AS ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON JULY 22, 2020 . SD/- SD/- (A.T. VARKEY) (P.M. JAGTAP) JUDICIAL MEMBER VIC E-PRESIDENT) KOLKATA, THE 22 ND DAY OF JULY, 2020 ITA NO. 2605/KOL/20 19 ASSESSMENT YEAR: 2014-2015 SUKUMAR MONDAL 8 COPIES TO : (1) SHRI SUKUMAR MONDAL, GOBINDAPUR, VILL. & P.O. GOBINDAPUR, HOWRAH-711314 (2) INCOME TAX OFFICER, WARD-47(4), KOLKATA, 3, GOVERNMENT PLACE (WEST), KOLKATA-700001 (3) COMMISSIONER OF INCOME TAX (APPEALS)-14, K OLKATA; (4) COMMISSIONER OF INCOME TAX- , KOLKATA (5) THE DEPARTMENTAL REPRESENTATIVE (6) GUARD FILE BY ORDER ASSISTANT REGISTRAR, INCOME TAX APPELLATE TRIBUNAL, KOLKATA BENCHES, KOLKATA LAHA/SR. P.S.