Hillman Hosiery Mills Pvt. Ltd., Kolkata V. D.C.I.T.,Circle-11(1), Kolkata

ITA 2634/KOL/2019

• Counselvise Citation: [2021] 109 COUNSELVISE.COM (IT) 7754 (ITAT-KOLKATA)
• Duration Of Justice: 1 year(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 12-01-2021
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Next Hearing Date: 09-12-2020
• Assessment Year: 2013-2014
• Appeal Filed On: 24-12-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: DHRUBAJYOTI RAY
• Assessee Lawyers: MIRAJ D. SHAH
• Keywords: Unexplained cash credit; Period of limitation; Source of fund; Question of law; Time period of passing order; TDS
• Section: 143(3); 142(1); 5(2); 133(6); 250; 292BB; 143(2); 9(1); 9(1); 9(1); 13; 22; 131; 68

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA B BENCH, KOLKATA VIRTUAL COURT HEARING (BEFORE SRI J. SUDHAKAR REDDY, HONBLE ACCOUNTANT MEMBER & SRI S.S. GODARA, HONBLE JUDICIAL MEMBER) ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD.........................................APPELLANT 26/1G, P K TAGORE STREET JORABAGAN KOLKATA 700 006 [PAN : AABCH 4530 Q] VS. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA.............................RESPONDENT APPEARANCES BY: SHRI MIRAJ D. SHAH, ADVOCATE, APPEARED ON BEHALF OF THE ASSESSEE. SHRI DHRUBAJYOTI RAY, JCIT D/R, APPEARING ON BEHALF OF THE REVENUE. DATE OF CONCLUDING THE HEARING : DECEMBER 9 TH , 2020 DATE OF PRONOUNCING THE ORDER : JANUARY 12 TH , 2021 ORDER PER J. SUDHAKAR REDDY, AM :- THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER OF THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) 5, KOLKATA, (HEREINAFTER THE LD. CIT(A)), PASSED U/S. 250 OF THE INCOME TAX ACT, 1961 (THE ACT), DT. 02/12/2019, FOR THE ASSESSMENT YEAR 2013-14. 2. THE ASSESSEE IS A COMPANY AND E-FILED ITS RETURN OF INCOME FOR THE ASSESSMENT YEAR 2013-14 ON 25/09/2015, DECLARING TOTAL INCOME OF RS.39,41,690/-. THE ASSESSEE WAS ENGAGED IN THE BUSINESS OF MANUFACTURING AND TRADING OF HOSIERY GOODS AND MATERIAL. THE ASSESSING OFFICER PASSED ORDER U/S 143(3) OF THE ACT ON 14/03/2016 ASSESSING THE TOTAL INCOME OF THE ASSESSEE AT RS.6,24,19,470/- INTERALIA MAKING AN ADDITION OF RS.5,40,00,000/- BEING LOANS RECEIVED BY THE ASSESSEE FROM 32 PARTIES AS UNEXPLAINED CASH CREDITS U/S 68 OF THE ACT INCLUDING DISALLOWANCE OF INTEREST OF RS.44,65,805/- ON THESE CASH CREDITS, U/S 68 OF THE ACT. AGGRIEVED, THE ASSESSEE CARRIED THE MATTER IN APPEAL WITHOUT SUCCESS. 3. FURTHER AGGRIEVED, THE ASSESSEE IS IN APPEAL BEFORE US ON THE FOLLOWING GROUNDS:- 1. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) ERRED IN TREATING UNSECURED LOANS OF RS.5,40,00,000/- AS BOGUS. 2. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) ERRED IN CONFIRMING THE ADDITION OF RS.5,40,00,000/- ON ACCOUNT OF UNSECURED LOANS BY INVOKING THE PROVISIONS OF SECTION 68 OF THE INCOME TAX ACT, 1961. 3. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) ERRED IN CONFIRMING THE DISALLOWANCE OF RS.44,65,805/- ON ACCOUNT OF INTEREST ON UNSECURED LOANS BY TREATING THE LOANS AS BOGUS. 4. THE APPELLANT CRAVES LEAVE TO ADD/OR AMEND ANY GROUNDS OF THIS APPEAL. 4. THE ASSESSEE FILED THE FOLLOWING ADDITIONAL GROUNDS OF APPEAL: 1. FOR THAT THE ASSESSING OFFICER ISSUING THE NOTICE U/S 143(2) OF THE IT ACT 1961 DID NOT HAVE JURISDICTION OVER THE CASE OF THE ASSESSEE HENCE THE SAID AND THE CONSEQUENTIAL A SSESSMENT ORDER IS BAD IN LAW AND HENCE THE SAME QUASHED. 2. FOR THAT THE ASSESSING OFFICER PASSING THE ASSESSMENT ORDER U/S 143(3) OF THE IT ACT 1961 DID NOT ISSUE ANY NOTICE U/S 143(2) OF THE IT ACT 1961 AND HENCE THE CONSEQUENTIAL ASSESSMENT ORDER IS B AD IN LAW AND HENCE THE SAME BE QUASHED. 5. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THESE ADDITIONAL GROUNDS ARE LEGAL GROUNDS CHALLENGING THE JURISDICTION AND THAT THE FACTS ARE ON RECORD AND HENCE, IN TERMS OF THE JUDGEMENT OF THE HONBLE SUPRE POWER CO. LTD. VS COMMISSIONER O MAY BE ADMITTED. THE LD. D/R, OPPOSED THE SAME. 5.1. AS THE ADDITIONAL GROUNDS IN QUESTION ARE LEGAL GROUNDS, NOT REQUIRING INTO FACTS, WE ADMIT THE SAME. 6. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE NOTICE U/S 143(2) OF THE ACT WAS ISSUED BY THE ASSESSING OFFICER I.E., ITO WARD OBJECTIONS AND CONSEQUENTLY THE FILE WAS TRA OFFICER I.E., DCIT, CRICLE- 11(1), KOLKATA, WHO HAD PASSED THE IMPUGNED ASSESSMENT ORDER ON 14/03/2016. HE SUBMITTED THAT THE JURISDICTIONAL ASSESSING OFFICER (11)(1), KOLKATA, DID NOT ISSUE ANY ASSESSMENT ORDER PASSED U/S 143(3) OF THE ACT, IS BAD IN LAW. ALTERNATIVELY, HE SUBMITTED THAT IN CASE ITO,WARD ASSESSMENT ORDER PASSED BY THE DCIT, CIRCLE HENCE BAD IN LAW. 7. ON MERITS, HE SUBMITTED THAT AS ON 01/04/2012, THE ASSESSEE HAD OPENING BALANCE OF UNSECURED LOANS INCLUDING INTEREST OF RS. OPENING BALANCE AMOUNT OF RS.2,69,00,00 BALANCE SHEET. HE SUBMITTED THAT AS ON 31/03/2013, UNSECURED LOANS OF RS.5,89,62,908/- (INCLUDING INTEREST) AND RS.5,54,00,000/ OUTSTANDING FROM 28 PARTIES AND THAT THE ASSESSEE HAD OBTAIN FROM THESE EXISTING CREDITORS AS WELL AS NEW PARTIES. 2 THE ASSESSEE FILED THE FOLLOWING ADDITIONAL GROUNDS OF APPEAL: - FOR THAT THE ASSESSING OFFICER ISSUING THE NOTICE U/S 143(2) OF THE IT ACT 1961 DID NOT HAVE JURISDICTION OVER THE CASE OF THE ASSESSEE HENCE THE SAID AND THE CONSEQUENTIAL SSESSMENT ORDER IS BAD IN LAW AND HENCE THE SAME QUASHED. FOR THAT THE ASSESSING OFFICER PASSING THE ASSESSMENT ORDER U/S 143(3) OF THE IT ACT 1961 DID NOT ISSUE ANY NOTICE U/S 143(2) OF THE IT ACT 1961 AND HENCE THE CONSEQUENTIAL AD IN LAW AND HENCE THE SAME BE QUASHED. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THESE ADDITIONAL GROUNDS ARE LEGAL GROUNDS CHALLENGING THE JURISDICTION AND THAT THE FACTS ARE ON RECORD AND HENCE, IN TERMS OF THE JUDGEMENT OF THE HONBLE SUPRE ME COURT IN THE CASE OF POWER CO. LTD. VS COMMISSIONER O F INCOME TAX REPORTED IN 1998 229 ITR 383 THE LD. D/R, OPPOSED THE SAME. AS THE ADDITIONAL GROUNDS IN QUESTION ARE LEGAL GROUNDS, NOT REQUIRING INTO FACTS, WE ADMIT THE SAME. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE NOTICE U/S 143(2) OF THE ACT WAS ISSUED BY THE ASSESSING OFFICER I.E., ITO WARD - 3(3) AND THAT THE ASSESSEE HAS RAISED OBJECTIONS AND CONSEQUENTLY THE FILE WAS TRA NSFERRED TO THE JURISDICTIONAL ASSESSING 11(1), KOLKATA, WHO HAD PASSED THE IMPUGNED ASSESSMENT ORDER ON 14/03/2016. HE SUBMITTED THAT THE JURISDICTIONAL ASSESSING OFFICER (11)(1), KOLKATA, DID NOT ISSUE ANY NOTICE U/S 143(2) OF THE ACT AND HENCE THE ASSESSMENT ORDER PASSED U/S 143(3) OF THE ACT, IS BAD IN LAW. ALTERNATIVELY, HE SUBMITTED THAT IN CASE ITO,WARD - 3(3), KOLKATA IS THE JURISDICTIONAL OFFICER, THEN THE ASSESSMENT ORDER PASSED BY THE DCIT, CIRCLE -11( 1), KOLKATA, IS WITHOUT JURISDICTION AND ON MERITS, HE SUBMITTED THAT AS ON 01/04/2012, THE ASSESSEE HAD OPENING BALANCE OF UNSECURED LOANS INCLUDING INTEREST OF RS. 2,80,85,410/ - AMOUNT OF RS.2,69,00,00 0/- WITHOUT INTEREST, WHICH APPEARED BALANCE SHEET. HE SUBMITTED THAT AS ON 31/03/2013, UNSECURED LOANS OF (INCLUDING INTEREST) AND RS.5,54,00,000/ - (WITHOUT INTEREST), IS OUTSTANDING FROM 28 PARTIES AND THAT THE ASSESSEE HAD OBTAIN ED ADDITIONAL EXISTING CREDITORS AS WELL AS NEW PARTIES. ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. FOR THAT THE ASSESSING OFFICER ISSUING THE NOTICE U/S 143(2) OF THE IT ACT 1961 DID NOT HAVE JURISDICTION OVER THE CASE OF THE ASSESSEE HENCE THE SAID AND THE CONSEQUENTIAL FOR THAT THE ASSESSING OFFICER PASSING THE ASSESSMENT ORDER U/S 143(3) OF THE IT ACT 1961 DID NOT ISSUE ANY NOTICE U/S 143(2) OF THE IT ACT 1961 AND HENCE THE CONSEQUENTIAL THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THESE ADDITIONAL GROUNDS ARE LEGAL GROUNDS CHALLENGING THE JURISDICTION AND THAT THE FACTS ARE ON RECORD AND HENCE, IN ME COURT IN THE CASE OF NATIONAL THERMAL 1998 229 ITR 383 SC, THE SAME AS THE ADDITIONAL GROUNDS IN QUESTION ARE LEGAL GROUNDS, NOT REQUIRING ENQUIRY THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE NOTICE U/S 143(2) OF THE ACT 3(3) AND THAT THE ASSESSEE HAS RAISED NSFERRED TO THE JURISDICTIONAL ASSESSING 11(1), KOLKATA, WHO HAD PASSED THE IMPUGNED ASSESSMENT ORDER ON 14/03/2016. HE SUBMITTED THAT THE JURISDICTIONAL ASSESSING OFFICER I.E., DCIT, CIRCLE - U/S 143(2) OF THE ACT AND HENCE THE ASSESSMENT ORDER PASSED U/S 143(3) OF THE ACT, IS BAD IN LAW. ALTERNATIVELY, HE 3(3), KOLKATA IS THE JURISDICTIONAL OFFICER, THEN THE 1), KOLKATA, IS WITHOUT JURISDICTION AND ON MERITS, HE SUBMITTED THAT AS ON 01/04/2012, THE ASSESSEE HAD OPENING - AND FURTHER AN WHICH APPEARED IN THE BALANCE SHEET. HE SUBMITTED THAT AS ON 31/03/2013, UNSECURED LOANS OF (WITHOUT INTEREST), IS ED ADDITIONAL AMOUNTS HE SUBMITTED THAT THE COMPANY HAS REPAID WELL AS LOANS TAKEN DURING THE YEAR AND SUBMITTED DETAILS O CONTENTION THAT THE IDENTITY AND CREDITWORTHINESS OF THE LOAN CREDITORS GENUINENESS OF THE TRANSACTION FOLLOWING DOCUMENTS FILED:- A) CERTIFICATE OF INCORPORA B) INCOME TAX RETURN FILED FOR THE ASSESSMENT YEAR 2013 C) AUDITED STATEMENT OF ACCOUNTS FOR THE ASSESSMENT YEAR 2013 D) TAX AUDIT REPORTS OF EACH OF THESE LOAN CREDITORS. E) COPY OF BANK STATEMENTS CHANNELS F) C ONFIRMATION OF LOANS FROM THE CREDITOR WHEREVER APPLICABLE 7.1. HE SUBMITS THAT ON THE FACE OF SUCH VOLUMINOUS OF THE LOAN CREDITORS, THE ASSESSING OFFICER HAS NO EVIDENCE WHATSOEVER TO SUPPORT H CONCLUSION THAT THESE ARE UNEXPLAINED CASH CREDITS. HE FURTHER SUBMITTED THAT NOTICE U/S 133(6) OF THE ACT, WAS ISSUED THESE NOTICES WERE DULY SERVED AND REPLIES WERE LD. COUNSEL FOR THE ASSESSEE SUBMITS THAT THE ADDITION IS BAD IN LAW. HE RELIED ON A NUMBER OF CASE- LAW FOR THIS PROPOSITION AND FILED A PAPER BOOK RUNNING INTO 1013 PAGES CONTAINING COPIES OF ALL THE DOCUMENTS FILED BY THE LOWER AUTHORITIE 8. THE LD. D/R, ON THE OTHER HAND, SUBMITTED THAT THE NOTICE U/S 143(2) OF THE ACT WAS GIVEN ON 04/09/2014, A COPY OF WHICH IS PLACED AT PAGE 7 OF THE PAPER BOOK AND THAT THE LEGAL REQUIREMENTS PR OCEEDING TO SCRUTINISE THE CASE OF THE ASSESSEE IS FULFILLED. HE SUBMITTED THAT THE ASSESSING OFFICER IN WHOSE RECORDS THE PAN OF THE ASSESSEE LIES, IS AUTHORISED TO ISSUE NOTICE U/S 143(2) OF THE ACT AND THAT THERE IS NO LEGAL REQUIREMENTS FOR THE DCIT, C 11(1) TO ISSUE NOTICE ONCE AGAIN COMMISSIONER OF INCOME TAX 8.1. ON MERITS, HE SUBMITTED THAT THE ASSESSING OFFICER HAS CLEARLY STATED THE REASONS WHY THE DOCUMENTATION FURNISHED BY THE ASSESSEE COULD NOT B 3 HE SUBMITTED THAT THE COMPANY HAS REPAID MANY OF THE LOANS TAKEN EARLIER AS WELL AS LOANS TAKEN DURING THE YEAR AND SUBMITTED DETAILS O F THE SAME. IN SUPPORT OF THE CONTENTION THAT THE IDENTITY AND CREDITWORTHINESS OF THE LOAN CREDITORS GENUINENESS OF THE TRANSACTION IS PROVED BEFORE THE ASSESSING OFFICER, HE REFERRED TO THE CERTIFICATE OF INCORPORA TION INCOME TAX RETURN FILED FOR THE ASSESSMENT YEAR 2013 - 14 AUDITED STATEMENT OF ACCOUNTS FOR THE ASSESSMENT YEAR 2013 TAX AUDIT REPORTS OF EACH OF THESE LOAN CREDITORS. COPY OF BANK STATEMENTS TO PROVE THAT THE LOAN IS GIVEN ONFIRMATION OF LOANS FROM THE CREDITOR AND EVIDENCE OF REPAYMENT WHEREVER APPLICABLE . HE SUBMITS THAT ON THE FACE OF SUCH VOLUMINOUS EVIDENCE FILED IN SUPPORT OF EACH OF THE LOAN CREDITORS, THE ASSESSING OFFICER HAS NO EVIDENCE WHATSOEVER TO SUPPORT H CONCLUSION THAT THESE ARE UNEXPLAINED CASH CREDITS. HE FURTHER SUBMITTED THAT NOTICE U/S WAS ISSUED BY T HE ASSESSING OFFICER TO VARIOUS LOAN CREDITORS AND THAT THESE NOTICES WERE DULY SERVED AND REPLIES WERE ALSO DIRECTLY RECEIVED IN ASSESSEE SUBMITS THAT THE ADDITION IS BAD IN LAW. HE RELIED ON A LAW FOR THIS PROPOSITION AND FILED A PAPER BOOK RUNNING INTO 1013 PAGES CONTAINING COPIES OF ALL THE DOCUMENTS FILED BY THE LOWER AUTHORITIE S. THE LD. D/R, ON THE OTHER HAND, SUBMITTED THAT THE NOTICE U/S 143(2) OF THE ACT WAS GIVEN ON 04/09/2014, A COPY OF WHICH IS PLACED AT PAGE 7 OF THE PAPER BOOK AND THAT THE LEGAL REQUIREMENTS OF HAVING SERVED THE NOTICE U/S 143(2) OF THE ACT BEFORE OCEEDING TO SCRUTINISE THE CASE OF THE ASSESSEE IS FULFILLED. HE SUBMITTED THAT THE ASSESSING OFFICER IN WHOSE RECORDS THE PAN OF THE ASSESSEE LIES, IS AUTHORISED TO ISSUE NOTICE U/S 143(2) OF THE ACT AND THAT THERE IS NO LEGAL REQUIREMENTS FOR THE DCIT, C 11(1) TO ISSUE NOTICE ONCE AGAIN AS BOTH THESE OFFICERS ARE UNDER THE SAME COMMISSIONER OF INCOME TAX . ON MERITS, HE SUBMITTED THAT THE ASSESSING OFFICER HAS CLEARLY STATED THE REASONS WHY THE DOCUMENTATION FURNISHED BY THE ASSESSEE COULD NOT B E ACCEPTED. ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. OF THE LOANS TAKEN EARLIER AS THE SAME. IN SUPPORT OF THE CONTENTION THAT THE IDENTITY AND CREDITWORTHINESS OF THE LOAN CREDITORS AND THAT THE IS PROVED BEFORE THE ASSESSING OFFICER, HE REFERRED TO THE 14 AUDITED STATEMENT OF ACCOUNTS FOR THE ASSESSMENT YEAR 2013 -14 THE LOAN IS GIVEN THROUGH BANKING AND EVIDENCE OF REPAYMENT FILED IN SUPPORT OF EACH OF THE LOAN CREDITORS, THE ASSESSING OFFICER HAS NO EVIDENCE WHATSOEVER TO SUPPORT H IS CONCLUSION THAT THESE ARE UNEXPLAINED CASH CREDITS. HE FURTHER SUBMITTED THAT NOTICE U/S HE ASSESSING OFFICER TO VARIOUS LOAN CREDITORS AND THAT RECEIVED IN HIS OFFICE. THE ASSESSEE SUBMITS THAT THE ADDITION IS BAD IN LAW. HE RELIED ON A LAW FOR THIS PROPOSITION AND FILED A PAPER BOOK RUNNING INTO 1013 PAGES THE LD. D/R, ON THE OTHER HAND, SUBMITTED THAT THE NOTICE U/S 143(2) OF THE ACT WAS GIVEN ON 04/09/2014, A COPY OF WHICH IS PLACED AT PAGE 7 OF THE PAPER BOOK AND OF HAVING SERVED THE NOTICE U/S 143(2) OF THE ACT BEFORE OCEEDING TO SCRUTINISE THE CASE OF THE ASSESSEE IS FULFILLED. HE SUBMITTED THAT THE ASSESSING OFFICER IN WHOSE RECORDS THE PAN OF THE ASSESSEE LIES, IS AUTHORISED TO ISSUE NOTICE U/S 143(2) OF THE ACT AND THAT THERE IS NO LEGAL REQUIREMENTS FOR THE DCIT, C IRCLE- AS BOTH THESE OFFICERS ARE UNDER THE SAME ON MERITS, HE SUBMITTED THAT THE ASSESSING OFFICER HAS CLEARLY STATED THE REASONS E ACCEPTED. HE RELIED ON THESE FINDINGS. HE SUBMITTED THAT THE COMPANIES WHICH GAVE THE LOANS, COULD NOT BE FOUND AT THE ADDRESS STATED IN THE DOCUMENTS AND SUBMITTED THAT O 22 PARTIES REPLIED TO THE NOTICES. HE RELIED ON THE ORDER OF THAT MOST OF THE COMPANIES WHICH HAD GIVEN THE LOANS, HAD MEAGRE INCOME, AND THAT THIS SHOWS THAT THE CREDITWORTHINESS OF THESE COMPANIES IS SUSPICIOUS. HE RELIED ON THE ORDER OF THE ASSESSING OFFICER AS WELL AS THE FINDINGS THE FINDINGS OF THE LD. CIT(A) ON THIS ISSUE MAY BE UPHELD. 9. WE HAVE HEARD RIVAL CONTENTIONS. ON CAREFUL CONSIDERATION OF THE FACTS AND CIRCUMSTANCES OF THE CASE, PERUSAL OF THE PAPERS ON RECORD, ORDERS OF THE AUTHORI BELOW AS WELL AS CASE LAW CITED, WE HOLD AS FOLLOWS: 10. IN THIS CASE, THE ITO WARD 04/09/2014. IN REPLY, ON 22/09/2014, THE ASSESSEE WROTE TO THE ITO, WARD KOLKATA, STATING THAT HE HAS NO 31/07/2015, THE DCIT, CIRCLE THE ASSESSEE. THE DCIT, CIRCLE ACT ON 14/03/2016. THE ISSUE IS WHET 11(1), KOLKATA, IS VALID AS ADMITTEDLY, HE DID NOT ISSUE A THE ASSESSEE . THIS ISSUE IS NO MORE SOMA ROY VS. ACIT IN ITA N JANUARY, 2020 , UNDER IDENTICAL CIRCUMSTANCES, HELD AS UNDER: 5. AFTER HEARING RIVAL CONTENTIONS, I ADMIT THIS ADDITIONAL GROUND AS IT IS A LEGAL GROUND, RAISING A JURISDICTIONAL ISSUE AND DOES NOT REQUIRE ANY INVESTIGATION INTO THE FACTS. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT AS PER BOARD INSTRUCTION NO. 1/2011 [F 187/12/2010-IT(A- I)], DT. 31/01/2011, THE JURISDICTION OF THE ASSESSEE IS WITH THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE AND THE INCOME RETURNED IS ABOVE RS.15,00,000/ 143(2) OF THE ACT, WAS ISSUED ON 29/09/2016, BY THE INCOME TAX OFFICER, WARD DURGAPUR, WHO HAD NO JURISDICTION OF THE CASE. HE SUBMITTED THAT THE ASSESSMENT ORDER WAS PASSED BY THE ACIT, CIRCLE - HAD NOT ISSUED THE NOTICE U/S 143(2) OF THE ACT, WITHIN THE STATUTORY PERIOD PRESCRIBED UNDER THE ACT. THUS, HE SUBMITS THAT THE ASSESSMENT IS BAD IN LAW. 5.1. ON MERITS, HE REBUTTED THE FINDINGS OF THE LOWER AUTHORITIES. T ASSESSEE RELIED ON CERTAIN CASE 6. THE LD. D/R, ON THE OTHER HAND, SUBMITTED THAT THE CONCURRENT JURISDICTION VESTS WITH THE ITO AS WELL AS THE ACIT AND HENCE THE ASSESSMENT C BECAUSE THE STATUTORY NOTICE U/S 143(2) OF THE ACT, WAS ISSUED BY THE ITO AND THE ASSESSMENT WAS COMPLETED BY THE ACIT. HE FURTHER SUBMITTED THAT THE ASSESSEE DID NOT OBJECT TO THE ISSUE OF NOTICE BEFORE THE JURISDICTIONAL ASSESSIN OF THE ACT, COMES INTO PLAY AND THE ASSESSMENT CANNOT BE ANNULLED. ON MERITS, HE RELIED ON THE ORDERS OF THE LOWER AUTHORITIES. 4 HE SUBMITTED THAT THE COMPANIES WHICH GAVE THE LOANS, COULD NOT BE STATED IN THE DOCUMENTS AND SUBMITTED THAT O UT OF 32 PARTIES ONLY 22 PARTIES REPLIED TO THE NOTICES. HE RELIED ON THE ORDER OF THE LD. CIT(A) AND POINTED OUT THAT MOST OF THE COMPANIES WHICH HAD GIVEN THE LOANS, HAD MEAGRE INCOME, AND THAT THIS SHOWS THAT THE CREDITWORTHINESS OF THESE COMPANIES IS SUSPICIOUS. HE RELIED ON THE ORDER OF THE ASSESSING OFFICER AS WELL AS THE FINDINGS OF THE LD. CIT(A) AND SUBMITTED THAT THE FINDINGS OF THE LD. CIT(A) ON THIS ISSUE MAY BE UPHELD. WE HAVE HEARD RIVAL CONTENTIONS. ON CAREFUL CONSIDERATION OF THE FACTS AND CIRCUMSTANCES OF THE CASE, PERUSAL OF THE PAPERS ON RECORD, ORDERS OF THE AUTHORI BELOW AS WELL AS CASE LAW CITED, WE HOLD AS FOLLOWS: - IN THIS CASE, THE ITO WARD - 3(3), KOLKATA, ISSUED NOTICE U/S 143(2) OF THE ACT ON ON 22/09/2014, THE ASSESSEE WROTE TO THE ITO, WARD KOLKATA, STATING THAT HE HAS NO JURISDICTION OVER THE ASSESSEE. THEREAFTER ON 31/07/2015, THE DCIT, CIRCLE -11(1), KOLKATA, HAD ISSUED NOTICE U/S 142(1) OF THE ACT THE DCIT, CIRCLE - 11(1), KOLKATA, COMPLETED ASSESSMENT U/S 143(3) OF THE ACT ON 14/03/2016. THE ISSUE IS WHET HER AN ASSESSMENT ORDER PASSED BY DCIT, CIRCLE AS ADMITTEDLY, HE DID NOT ISSUE A NOTICE U/S 143(2) OF THE ACT . THIS ISSUE IS NO MORE RES-INTEGRA. THIS BENCH OF THE TRIBUNAL IN THE CASE OF VS. ACIT IN ITA N O. 462/KOL/2019; ASSESSMENT YEAR 2015 , UNDER IDENTICAL CIRCUMSTANCES, HELD AS UNDER: - HEARING RIVAL CONTENTIONS, I ADMIT THIS ADDITIONAL GROUND AS IT IS A LEGAL GROUND, RAISING A JURISDICTIONAL ISSUE AND DOES NOT REQUIRE ANY INVESTIGATION INTO THE FACTS. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT AS PER BOARD INSTRUCTION NO. 1/2011 [F I)], DT. 31/01/2011, THE JURISDICTION OF THE ASSESSEE IS WITH THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1, DURGAPUR, AS THE ASSESSEE IS A NON- CORPORATE ASSESSEE AND THE INCOME RETURNED IS ABOVE RS.15,00,000/ - AND WHEREAS, THE STATUTORY NOTICE U/S 143(2) OF THE ACT, WAS ISSUED ON 29/09/2016, BY THE INCOME TAX OFFICER, WARD DURGAPUR, WHO HAD NO JURISDICTION OF THE CASE. HE SUBMITTED THAT THE ASSESSMENT ORDER WAS - 1(1), DURGAPUR, WHO HAD THE JURISDI CTION OVER THE ASSESSEE, BUT HE HAD NOT ISSUED THE NOTICE U/S 143(2) OF THE ACT, WITHIN THE STATUTORY PERIOD PRESCRIBED UNDER THE ACT. THUS, HE SUBMITS THAT THE ASSESSMENT IS BAD IN LAW. ON MERITS, HE REBUTTED THE FINDINGS OF THE LOWER AUTHORITIES. T HE LD. COUNSEL FOR THE ASSESSEE RELIED ON CERTAIN CASE - LAW, WHICH I WOULD BE REFERRING TO AS AND WHEN NECESSARY. THE LD. D/R, ON THE OTHER HAND, SUBMITTED THAT THE CONCURRENT JURISDICTION VESTS WITH THE ITO AS WELL AS THE ACIT AND HENCE THE ASSESSMENT C ANNOT BE ANNULLED SIMPLY BECAUSE THE STATUTORY NOTICE U/S 143(2) OF THE ACT, WAS ISSUED BY THE ITO AND THE ASSESSMENT WAS COMPLETED BY THE ACIT. HE FURTHER SUBMITTED THAT THE ASSESSEE DID NOT OBJECT TO THE ISSUE OF NOTICE BEFORE THE JURISDICTIONAL ASSESSIN G OFFICER AND EVEN OTHERWISE, SECTION 292BB OF THE ACT, COMES INTO PLAY AND THE ASSESSMENT CANNOT BE ANNULLED. ON MERITS, HE RELIED ON THE ORDERS OF THE LOWER AUTHORITIES. ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. HE SUBMITTED THAT THE COMPANIES WHICH GAVE THE LOANS, COULD NOT BE UT OF 32 PARTIES ONLY THE LD. CIT(A) AND POINTED OUT THAT MOST OF THE COMPANIES WHICH HAD GIVEN THE LOANS, HAD MEAGRE INCOME, AND THAT THIS SHOWS THAT THE CREDITWORTHINESS OF THESE COMPANIES IS SUSPICIOUS. HE RELIED ON THE OF THE LD. CIT(A) AND SUBMITTED THAT WE HAVE HEARD RIVAL CONTENTIONS. ON CAREFUL CONSIDERATION OF THE FACTS AND CIRCUMSTANCES OF THE CASE, PERUSAL OF THE PAPERS ON RECORD, ORDERS OF THE AUTHORI TIES 3(3), KOLKATA, ISSUED NOTICE U/S 143(2) OF THE ACT ON ON 22/09/2014, THE ASSESSEE WROTE TO THE ITO, WARD -3(3), JURISDICTION OVER THE ASSESSEE. THEREAFTER ON U/S 142(1) OF THE ACT TO 11(1), KOLKATA, COMPLETED ASSESSMENT U/S 143(3) OF THE HER AN ASSESSMENT ORDER PASSED BY DCIT, CIRCLE - NOTICE U/S 143(2) OF THE ACT , TO THIS BENCH OF THE TRIBUNAL IN THE CASE OF O. 462/KOL/2019; ASSESSMENT YEAR 2015 -16, ORDER DT. 8 TH HEARING RIVAL CONTENTIONS, I ADMIT THIS ADDITIONAL GROUND AS IT IS A LEGAL GROUND, RAISING A JURISDICTIONAL ISSUE AND DOES NOT REQUIRE ANY INVESTIGATION INTO THE FACTS. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED THAT AS PER BOARD INSTRUCTION NO. 1/2011 [F . NO. I)], DT. 31/01/2011, THE JURISDICTION OF THE ASSESSEE IS WITH THE ASSISTANT CORPORATE ASSESSEE STATUTORY NOTICE U/S 143(2) OF THE ACT, WAS ISSUED ON 29/09/2016, BY THE INCOME TAX OFFICER, WARD -1(1), DURGAPUR, WHO HAD NO JURISDICTION OF THE CASE. HE SUBMITTED THAT THE ASSESSMENT ORDER WAS CTION OVER THE ASSESSEE, BUT HE HAD NOT ISSUED THE NOTICE U/S 143(2) OF THE ACT, WITHIN THE STATUTORY PERIOD PRESCRIBED UNDER HE LD. COUNSEL FOR THE LAW, WHICH I WOULD BE REFERRING TO AS AND WHEN NECESSARY. THE LD. D/R, ON THE OTHER HAND, SUBMITTED THAT THE CONCURRENT JURISDICTION VESTS ANNOT BE ANNULLED SIMPLY BECAUSE THE STATUTORY NOTICE U/S 143(2) OF THE ACT, WAS ISSUED BY THE ITO AND THE ASSESSMENT WAS COMPLETED BY THE ACIT. HE FURTHER SUBMITTED THAT THE ASSESSEE DID NOT OBJECT TO THE G OFFICER AND EVEN OTHERWISE, SECTION 292BB OF THE ACT, COMES INTO PLAY AND THE ASSESSMENT CANNOT BE ANNULLED. ON MERITS, HE RELIED ON 7. I HAVE HEARD RIVAL CONTENTIONS. ON CAREFUL CONSIDERATION OF THE FACTS AND CIRCUMS TANCES OF THE CASE, PERUSAL OF THE PAPERS ON RECORD, ORDERS OF THE AUTHORITIES BELOW AS WELL AS CASE LAW CITED, I HOLD AS FOLLOWS: 8. I FIND THAT THERE IS NO DISPUTE IN THE FACT THAT THE NOTICE U/S 143(2) OF THE ACT DT. 29/09/2016 HAS BEEN ISSUED BY THE TO THE JURISDICTION OF THE ACIT ON 11/08/2017. THEREAFTER, NO NOTICE U/S 143(2) OF THE ACT WAS ISSUED BY THE ASSESSING OFFICER HAVING JURISDICTION OF THIS CASE AND WHO HAD COMPLETED THE ASSESSMENT ON 26/12/2017 I.E., ACIT, CIRCLE THE QUESTION IS WHETHER THE ASSESSMENT IS BAD IN LAW FOR WANT OF ISSUAL OF NOTICE U/S 143(2) OF THE ACT. 9. THIS BENCH OF THE TRIBUNAL IN THE CASE OF SHRI SUKUMAR CH. SAHOO VS. ACIT 2073/KOL/2016 ORDER DT. 27.09.2017, HELD AS FOLLOWS: 5. FROM A PERUSAL OF THE ABOVE INSTRUCTION OF THE CBDT IT IS EVIDENT THAT THE PECUNIARY JURISDICTION CONFERRED BY THE CBDT ON ITOS IS IN RESPECT TO THE 'NON CORPORATE RETURNS' FILED WHERE I NCOME DECLARED IS ONLY UPTO RS.15 LACS ; AND THE ITO DOESN'T HAVE THE JURISDICTION TO CONDUCT ASSESSMENT IF IT IS ABOVE RS 15 LAKHS. ABOVE RS. 15 LACS INCOME DECLARED BY A NON CORPORATE PERSON I.E. LIKE ASSESSEE, THE PECUNIARY JURISDICTION LIES BEFORE AC/ ADMITTEDLY, THE ASSESSEE AN INDIVIDUAL (NON CORPORATE PERSON) WHO UNDISPUTEDLY DECLARED INCOME OF RS.50,28,040/ CBDT CIRCULAR (SUPRA). FROM A PERUSAL OF THE ASSESSMENT ORDE NOTICE U/S. 143(2) OF THE ACT WAS ISSUED BY THE THEN ITO, WARD THE SAME WAS SERVED ON THE ASSESSEE ON 19.09.2013 AS NOTED BY THE AO. THE AO NOTED THAT SINCE THE RETURNED INCOME IS MORE THAN RS. 1 WARD- 1, HALDIA TO ACIT, CIRCLE 27, HALDIA ON 24.09.2014 AND IMMEDIATELY ACIT ISSUED NOTICE U/S. 142(1) OF THE ACT ON THE SAME DAY. FROM THE AFORESA I) THE ASSESSEE HAD FILED RETURN OF INCOME DECLARING RS.50,28,040/ UNDER SECTION 143(2) II) THE ITO, WARD - TRANSFERRED THE CASE TO ACIT, CIRCLE III) ON 24.09.2014 STATUTORY NOTICES FOR SCRUTINY WERE ISSUED BY ACIT, CIRCLE 6. WE NOTE THAT THE CBDT INSTRUCTION IS D RETURN OF INCOME ON 29.03.2013 DECLARING TOTAL INCOME OF RS.50,28,040/ INSTRUCTION THE MONETARY LIMITS IN RESPECT TO AN ASSESSEE WHO IS AN INDIVIDUAL WHICH FALLS UNDER THE CATEGORY OF 'NON CO RS.15 LACS; AND IF THE RETURNED INCOME IS ABOVE RS. 15 LACS IT WAS THE AC/DC. SO, SINCE THE RETURNED INCOME BY ASSESSEE AN INDIVIDUAL IS ABOVE RS.15 LAKH, THEN THE JURISDICTION TO ASSESS THE ASSE SSEE LIES ONLY BY AC/DC AND NOT ITO. SO, THEREFORE, ONLY THE AC/DC HAD THE JURISDICTION TO ASSESS THE ASSESSEE. IT IS SETTLED LAW THAT SERVING OF NOTICE U/S. 143(2) OF THE ACT IS A SINE QUA NON FOR AN ASSESSMENT TO BE MADE U/S. 143(3) OF THE ACT. IN THIS C U/S. 143(2) OF THE ACT WAS ISSUED ON 06.09.2013 BY ITO, WARD THE PECUNIARY JURISDICTION TO ASSUME JURISDICTION AND ISSUE NOTICE. ADMITTEDLY, WHEN THE ITO REALIZED THAT HE DID NOT HAD THE PECUNIARY JURISDICTION TO FILE TO THE ACIT, CIRCLE WAS BEYOND THE TIME LIMIT PRESCRIBED FOR ISSUANCE OF NOTICE U/S. 143(2) OF THE ACT. WE NOTE THAT THE ACIT BY ASSUMING THE JU U/S. 143(2) OF THE ACT NOTICE BECAME QOARUM NON JUDICE AFTER THE LIMITATION PRESCRIBED BY THE STATUTE WAS CROSSED BY HIM. THEREFORE, THE ISSUANCE OF NOTICE BY THE ACIT, CIRCLE HALDIA AFTER THE LIMITATION PERIOD FOR ISSUANCE OF STATUTORY NOTICE U/S. 143(2) OF THE ACT HAS SET IN, GOES TO THE ROOT OF THE CASE AND MAKES THE NOTICE BAD IN THE EYES OF LAW AND CONSEQUENTIAL ASSESSMENT ORDER PASSED U/S. 143(3) OF THE ACT IS NOT VALID IN THE EYES OF LAW AND, THEREFORE, IS NULL AND VOID IN THE EYES OF LAW. THEREFORE, THE LEGAL ISSUE RAISED BY THE ASSESSEE IS ALLOWED. SINCE WE HAVE QUASHED THE ASSESSMENT AND THE APPEAL OF ASSESSEE IS ALLOWED ON THE LEGAL ISSUE, THE OTHER GROUNDS RAISED BY THE ASSESSEE NEED ADJUDICATED BECAUSE IT IS ONLY ACADEMIC. THEREFORE, THE ADDITIONAL GROUND RAISED BY THE ASSESSEE IS ALLOWED. 7. IN THE RESULT, APPEAL OF ASSESSEE IS ALLOWED. 5 I HAVE HEARD RIVAL CONTENTIONS. ON CAREFUL CONSIDERATION OF THE FACTS AND TANCES OF THE CASE, PERUSAL OF THE PAPERS ON RECORD, ORDERS OF THE AUTHORITIES BELOW AS WELL AS CASE LAW CITED, I HOLD AS FOLLOWS: - I FIND THAT THERE IS NO DISPUTE IN THE FACT THAT THE NOTICE U/S 143(2) OF THE ACT DT. 29/09/2016 HAS BEEN ISSUED BY THE ITO, WD- 1(1), DURGAPUR. LATER, THE CASE WAS TRANSFERRED TO THE JURISDICTION OF THE ACIT ON 11/08/2017. THEREAFTER, NO NOTICE U/S 143(2) OF THE ACT WAS ISSUED BY THE ASSESSING OFFICER HAVING JURISDICTION OF THIS CASE AND WHO HAD COMPLETED 26/12/2017 I.E., ACIT, CIRCLE - 1(1), DURGAPUR. UNDER THESE CIRCUMSTANCES, THE QUESTION IS WHETHER THE ASSESSMENT IS BAD IN LAW FOR WANT OF ISSUAL OF NOTICE U/S 143(2) THIS BENCH OF THE TRIBUNAL IN THE CASE OF SHRI SUKUMAR CH. SAHOO VS. ACIT 2073/KOL/2016 ORDER DT. 27.09.2017, HELD AS FOLLOWS: - 5. FROM A PERUSAL OF THE ABOVE INSTRUCTION OF THE CBDT IT IS EVIDENT THAT THE PECUNIARY JURISDICTION CONFERRED BY THE CBDT ON ITOS IS IN RESPECT TO THE 'NON CORPORATE RETURNS' FILED NCOME DECLARED IS ONLY UPTO RS.15 LACS ; AND THE ITO DOESN'T HAVE THE JURISDICTION TO CONDUCT ASSESSMENT IF IT IS ABOVE RS 15 LAKHS. ABOVE RS. 15 LACS INCOME DECLARED BY A NON CORPORATE PERSON I.E. LIKE ASSESSEE, THE PECUNIARY JURISDICTION LIES BEFORE AC/ ADMITTEDLY, THE ASSESSEE AN INDIVIDUAL (NON CORPORATE PERSON) WHO UNDISPUTEDLY DECLARED INCOME OF RS.50,28,040/ - IN HIS RETURN OF INCOME CANNOT BE ASSESSED BY THE ITO AS PER THE CBDT CIRCULAR (SUPRA). FROM A PERUSAL OF THE ASSESSMENT ORDE R, IT REVEALS THAT THE STATUTORY NOTICE U/S. 143(2) OF THE ACT WAS ISSUED BY THE THEN ITO, WARD - 1, HALDIA ON 06.09.2013 AND THE SAME WAS SERVED ON THE ASSESSEE ON 19.09.2013 AS NOTED BY THE AO. THE AO NOTED THAT SINCE THE RETURNED INCOME IS MORE THAN RS. 1 5 LACS THE CASE WAS TRANSFERRED FROM THE ITO, 1, HALDIA TO ACIT, CIRCLE - 27 AND THE SAME WAS RECEIVED BY THE OFFICE OF THE ACIT, CIRCLE 27, HALDIA ON 24.09.2014 AND IMMEDIATELY ACIT ISSUED NOTICE U/S. 142(1) OF THE ACT ON THE SAME DAY. FROM THE AFORESA ID FACTS THE FOLLOWING FACTS EMERGED: I) THE ASSESSEE HAD FILED RETURN OF INCOME DECLARING RS.50,28,040/ - . THE ITO ISSUED NOTICE SECTION 143(2) OF THE ACT ON 06.09.2013. - 1, HALDIA TAKING NOTE THAT THE INCOME RETURNED WAS ABOVE RS. 15 LACS TRANSFERRED THE CASE TO ACIT, CIRCLE -27, HALDIA ON 24.09.2014. III) ON 24.09.2014 STATUTORY NOTICES FOR SCRUTINY WERE ISSUED BY ACIT, CIRCLE - 27, HALDIA. 6. WE NOTE THAT THE CBDT INSTRUCTION IS D ATED 31.01.2011 AND THE ASSESSEE HAS FILED THE RETURN OF INCOME ON 29.03.2013 DECLARING TOTAL INCOME OF RS.50,28,040/ - . AS PER THE CBDT INSTRUCTION THE MONETARY LIMITS IN RESPECT TO AN ASSESSEE WHO IS AN INDIVIDUAL WHICH FALLS UNDER THE CATEGORY OF 'NON CO RPORATE RETURNS' THE ITO'S INCREASED MONETARY LIMIT WAS UPTO RS.15 LACS; AND IF THE RETURNED INCOME IS ABOVE RS. 15 LACS IT WAS THE AC/DC. SO, SINCE THE RETURNED INCOME BY ASSESSEE AN INDIVIDUAL IS ABOVE RS.15 LAKH, THEN THE JURISDICTION TO ASSESS SSEE LIES ONLY BY AC/DC AND NOT ITO. SO, THEREFORE, ONLY THE AC/DC HAD THE JURISDICTION TO ASSESS THE ASSESSEE. IT IS SETTLED LAW THAT SERVING OF NOTICE U/S. 143(2) OF THE ACT IS A SINE QUA NON FOR AN ASSESSMENT TO BE MADE U/S. 143(3) OF THE ACT. IN THIS C U/S. 143(2) OF THE ACT WAS ISSUED ON 06.09.2013 BY ITO, WARD - 1, HALDIA WHEN HE DID NOT HAVE THE PECUNIARY JURISDICTION TO ASSUME JURISDICTION AND ISSUE NOTICE. ADMITTEDLY, WHEN THE ITO REALIZED THAT HE DID NOT HAD THE PECUNIARY JURISDICTION TO ISSUE NOTICE HE DULY TRANSFERRED THE FILE TO THE ACIT, CIRCLE - 27, HALDIA ON 24.09. 2014 WHEN THE ACIT ISSUED STATUTORY NOTICE WHICH WAS BEYOND THE TIME LIMIT PRESCRIBED FOR ISSUANCE OF NOTICE U/S. 143(2) OF THE ACT. WE NOTE THAT THE ACIT BY ASSUMING THE JU RISDICTION AFTER THE TIME PRESCRIBED FOR ISSUANCE OF NOTICE U/S. 143(2) OF THE ACT NOTICE BECAME QOARUM NON JUDICE AFTER THE LIMITATION PRESCRIBED BY THE STATUTE WAS CROSSED BY HIM. THEREFORE, THE ISSUANCE OF NOTICE BY THE ACIT, CIRCLE LIMITATION PERIOD FOR ISSUANCE OF STATUTORY NOTICE U/S. 143(2) OF THE ACT HAS SET IN, GOES TO THE ROOT OF THE CASE AND MAKES THE NOTICE BAD IN THE EYES OF LAW AND CONSEQUENTIAL ASSESSMENT ORDER PASSED U/S. 143(3) OF THE ACT IS NOT VALID IN THE EYES OF LAW AND, THEREFORE, IS NULL AND VOID IN THE EYES OF LAW. THEREFORE, THE LEGAL ISSUE RAISED BY THE ASSESSEE IS ALLOWED. SINCE WE HAVE QUASHED THE ASSESSMENT AND THE APPEAL OF ASSESSEE IS ALLOWED ON THE LEGAL ISSUE, THE OTHER GROUNDS RAISED BY THE ASSESSEE NEED ADJUDICATED BECAUSE IT IS ONLY ACADEMIC. THEREFORE, THE ADDITIONAL GROUND RAISED BY THE ASSESSEE IS ALLOWED. 7. IN THE RESULT, APPEAL OF ASSESSEE IS ALLOWED. ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. I HAVE HEARD RIVAL CONTENTIONS. ON CAREFUL CONSIDERATION OF THE FACTS AND TANCES OF THE CASE, PERUSAL OF THE PAPERS ON RECORD, ORDERS OF THE AUTHORITIES BELOW AS I FIND THAT THERE IS NO DISPUTE IN THE FACT THAT THE NOTICE U/S 143(2) OF THE ACT DT. 1(1), DURGAPUR. LATER, THE CASE WAS TRANSFERRED TO THE JURISDICTION OF THE ACIT ON 11/08/2017. THEREAFTER, NO NOTICE U/S 143(2) OF THE ACT WAS ISSUED BY THE ASSESSING OFFICER HAVING JURISDICTION OF THIS CASE AND WHO HAD COMPLETED 1(1), DURGAPUR. UNDER THESE CIRCUMSTANCES, THE QUESTION IS WHETHER THE ASSESSMENT IS BAD IN LAW FOR WANT OF ISSUAL OF NOTICE U/S 143(2) THIS BENCH OF THE TRIBUNAL IN THE CASE OF SHRI SUKUMAR CH. SAHOO VS. ACIT IN ITA NO. 5. FROM A PERUSAL OF THE ABOVE INSTRUCTION OF THE CBDT IT IS EVIDENT THAT THE PECUNIARY JURISDICTION CONFERRED BY THE CBDT ON ITOS IS IN RESPECT TO THE 'NON CORPORATE RETURNS' FILED NCOME DECLARED IS ONLY UPTO RS.15 LACS ; AND THE ITO DOESN'T HAVE THE JURISDICTION TO CONDUCT ASSESSMENT IF IT IS ABOVE RS 15 LAKHS. ABOVE RS. 15 LACS INCOME DECLARED BY A NON - CORPORATE PERSON I.E. LIKE ASSESSEE, THE PECUNIARY JURISDICTION LIES BEFORE AC/ DC. IN THIS CASE, ADMITTEDLY, THE ASSESSEE AN INDIVIDUAL (NON CORPORATE PERSON) WHO UNDISPUTEDLY DECLARED IN HIS RETURN OF INCOME CANNOT BE ASSESSED BY THE ITO AS PER THE R, IT REVEALS THAT THE STATUTORY 1, HALDIA ON 06.09.2013 AND THE SAME WAS SERVED ON THE ASSESSEE ON 19.09.2013 AS NOTED BY THE AO. THE AO NOTED THAT 5 LACS THE CASE WAS TRANSFERRED FROM THE ITO, 27 AND THE SAME WAS RECEIVED BY THE OFFICE OF THE ACIT, CIRCLE - 27, HALDIA ON 24.09.2014 AND IMMEDIATELY ACIT ISSUED NOTICE U/S. 142(1) OF THE ACT ON THE . THE ITO ISSUED NOTICE TAKING NOTE THAT THE INCOME RETURNED WAS ABOVE RS. 15 LACS 27, HALDIA. ATED 31.01.2011 AND THE ASSESSEE HAS FILED THE . AS PER THE CBDT INSTRUCTION THE MONETARY LIMITS IN RESPECT TO AN ASSESSEE WHO IS AN INDIVIDUAL WHICH FALLS RPORATE RETURNS' THE ITO'S INCREASED MONETARY LIMIT WAS UPTO RS.15 LACS; AND IF THE RETURNED INCOME IS ABOVE RS. 15 LACS IT WAS THE AC/DC. SO, SINCE THE RETURNED INCOME BY ASSESSEE AN INDIVIDUAL IS ABOVE RS.15 LAKH, THEN THE JURISDICTION TO ASSESS SSEE LIES ONLY BY AC/DC AND NOT ITO. SO, THEREFORE, ONLY THE AC/DC HAD THE JURISDICTION TO ASSESS THE ASSESSEE. IT IS SETTLED LAW THAT SERVING OF NOTICE U/S. 143(2) OF THE ACT IS A SINE QUA NON FOR AN ASSESSMENT TO BE MADE U/S. 143(3) OF THE ACT. IN THIS C ASE, NOTICE 1, HALDIA WHEN HE DID NOT HAVE THE PECUNIARY JURISDICTION TO ASSUME JURISDICTION AND ISSUE NOTICE. ADMITTEDLY, WHEN THE ITO ISSUE NOTICE HE DULY TRANSFERRED THE 27, HALDIA ON 24.09. 2014 WHEN THE ACIT ISSUED STATUTORY NOTICE WHICH WAS BEYOND THE TIME LIMIT PRESCRIBED FOR ISSUANCE OF NOTICE U/S. 143(2) OF THE ACT. WE NOTE RISDICTION AFTER THE TIME PRESCRIBED FOR ISSUANCE OF NOTICE U/S. 143(2) OF THE ACT NOTICE BECAME QOARUM NON JUDICE AFTER THE LIMITATION PRESCRIBED BY THE STATUTE WAS CROSSED BY HIM. THEREFORE, THE ISSUANCE OF NOTICE BY THE ACIT, CIRCLE -27, LIMITATION PERIOD FOR ISSUANCE OF STATUTORY NOTICE U/S. 143(2) OF THE ACT HAS SET IN, GOES TO THE ROOT OF THE CASE AND MAKES THE NOTICE BAD IN THE EYES OF LAW AND CONSEQUENTIAL ASSESSMENT ORDER PASSED U/S. 143(3) OF THE ACT IS NOT VALID IN THE EYES OF LAW AND, THEREFORE, IS NULL AND VOID IN THE EYES OF LAW. THEREFORE, THE LEGAL ISSUE RAISED BY THE ASSESSEE IS ALLOWED. SINCE WE HAVE QUASHED THE ASSESSMENT AND THE APPEAL OF ASSESSEE IS ALLOWED ON THE LEGAL ISSUE, THE OTHER GROUNDS RAISED BY THE ASSESSEE NEED NOT TO BE ADJUDICATED BECAUSE IT IS ONLY ACADEMIC. THEREFORE, THE ADDITIONAL GROUND RAISED BY THE 9.1. THIS BENCH OF THE TRIBUNAL IN THE CASE OF KRISHNENDU CHOWDHURY VS. ITO REPORTED [2017] 78 TAXMANN.COM 89 (KOLKATA RETURN OF INCOME OF ASSESSEE WAS RS. 12 LAKHS FOR SCRUTINY ASSESSMENT VESTED IN INCOME MUST BE ISSUED BY INCOME ISSUED BY ASSTT. COMMISSIONER, CIRCLE HALDIA KNOWING FULLY WELL THAT HE HAD NO JURISDICTION OVER ASSESSEE NOTICE ISSUED BY ASSTT. COMMISSIONER WAS INVALID AND CONSEQUENTLY ASSESSMENT FRAMED BY INCOME WAS NOT DONE BY INCOME 9.2. THE HONBLE HIGH COURT OF CALCUTTA IN THE CASE OF WEST BENGAL STATE ELECTRICITY BOARD VS. DEPUTY COMMISSIONER OF INCOME TAX, SPECIAL RANGE ITR 218 (CAL.) HAS HELD AS FOLLOWS: SECTION 254 OF THE INCOME 1983-84 TO 1987- 88 WHICH WEN T TO ROOT OF JURISDICTION CAN BE RAISED FOR FIRST TIME BEFORE TRIBUNAL JURISDICTION OF ASSESSING AUTHORITY IS NOT DEPENDENT ON DATE OF ACCRUAL OF CAUSE OF ACTION BUT ON DATE WHEN IT IS INITIATED BE PROSPECTIVE AND CANNOT BE RETROSPECTIVE AND IT HAS TO BE INTERPRETED HAVING REGARD TO MANNER IN WHICH IT HAS BEEN SOUGHT TO BE CREATED 9.3. THE HONBLE SUPREME COURT IN THE CASE OF CIT VS. LAXMAN 108 TAXMANN.COM 183 (SC), HELD AS FOLLOWS: 7. A CLOSER LOOK AT SECTION 292BB SHOWS THAT IF THE ASSESSEE HAS PARTICIPATED IN THE PROCEEDINGS IT SHALL BE DEEMED THAT ANY NOTICE WHICH IS REQUIRED TO BE SERVED UPON WAS DULY SERVED AND BE PRECLUDED FROM TAKING ANY OBJECTIONS THAT THE NOTICE WAS (A) NOT SERVED UPON HIM; OR (B) NOT SERVED UPON HIM IN TIME; OR (C) SERVED UPON HIM IN AN IMPROPER MANNER. ACCORDING TO MR. MAHABIR SINGH, LEARNED SENIOR ADVOCATE, SINCE THE RES SECTION 292BB WOULD BE A COMPLETE ANSWER. ON THE OTHER HAND, MR. ANKIT VIJAYWARGIA, LEARNED ADVOCATE, APPEARING FOR THE RESPONDENT SUBMITTED THAT THE NOTICE UNDER SECTION 143(2) OF THE ACT WAS PASSED ON RECORD AS WELL AS THE STAND TAKEN BY THE APPELLANT IN THE MEMO OF APPEAL. IT WAS FURTHER SUBMITTED THAT ISSUANCE OF NOTICE UNDER SECTION 143(2) OF THE ACT BEING PREREQUISITE, IN THE ABSENCE OF SUCH N OTICE, THE ENTIRE PROCEEDINGS WOULD BE INVALID. 8. THE LAW ON THE POINT AS REGARDS APPLICABILITY OF THE REQUIREMENT OF NOTICE UNDER SECTION 143(2) OF THE ACT IS QUITE CLEAR FROM THE DECISION IN HOTEL BLUE MOON'S CASE (SUPRA). THE ISSUE THAT HOWEVER NEEDS TO BE CONSIDERED IS THE IMPACT OF SECTION 292BB OF 9. ACCORDING TO SECTION 292BB OF THE ACT, IF THE ASSESSEE HAD PARTICIPATED IN THE PROCEEDINGS, BY WAY OF LEGAL FICTION, NOTICE WOULD BE DEEMED TO BE VALID EVEN IF THERE BE INFRACTIONS AS DETAILED IN SAID SECTION. THE SCOPE OF THE PROVISION IS TO M THERE WAS REQUISITE PARTICIPATION ON PART OF THE ASSESSEE. IT IS, HOWEVER, TO BE NOTED THAT THE SECTION DOES NOT SAVE COMPLETE ABSENCE OF NOTICE. FOR SECTION 292BB TO APPLY, THE NOT THE DEPARTMENT. IT IS ONLY THE INFIRMITIES IN THE MANNER OF SERVICE OF NOTICE THAT THE SECTION SEEKS TO CURE. THE SECTION IS NOT INTENDED TO CURE COMPLETE ABSENCE OF NOTICE ITSELF. 10. RESPECTFULLY FOLLOWING THE PROPOSITIONS OF APPLYING THE SAME TO THE FACTS OF THE CASE, WE HOLD THAT THE ASSESSMENT ORDER IS BAD IN LAW FOR THE REASON THAT THE ASSESSING OFFICER HAVING JURISDICTION OVER THE ASSESSEE, HAS NOT ISSUED A NOTICE U/S 143(2) OF THE NO JURISDICTION OF THE ASSESSEE IS NULL AND VOID. WHEN A NOTICE IS ISSUED BY AN OFFICER HAVING NO JURISDICTION, SECTION 292BB OF THE ACT, DOES NOT COMES INTO PLAY. COMING TO THE ARGUMENT OF THE LD. D/R THAT OBJECTION U/S 124(3) OF THE ACT HAS TO BE TAKEN BY THE ASSESSEE ON RECTIFYING NOTICE U/S 143(2) OF THE ACT FROM A NON VIEW THAT I NEED NOT ADJUDICATE THIS ISSUE, AS I HAVE HELD THAT NON 143(2) OF THE ACT BY THE JURISDICTIONAL ASSESSING OFFICER MAKES THE ASSESSMENT BAD IN LAW. UNDER THESE CIRCUMSTANCES, WE ALLOW THIS APPEAL OF THE ASSESSEE. 11. RESPECTFULLY FOLLOWING THE SAME, WE HAVE TO HOLD THAT THE ASSESSMENT ORDER PASSED BY THE DCIT, CIRCLE- 11(1), KOLKATA, WITHOUT ISSUANCE OF NOTICE U/S 143(2) OF THE 6 THIS BENCH OF THE TRIBUNAL IN THE CASE OF KRISHNENDU CHOWDHURY VS. ITO REPORTED [2017] 78 TAXMANN.COM 89 (KOLKATA -TRIB.) HELD AS FOLLOWS:- RETURN OF INCOME OF ASSESSEE WAS RS. 12 LAKHS - AS PER CBDT INSTRUCTION, JURISDICTION FOR SCRUTINY ASSESSMENT VESTED IN INCOME - TAX OFFICER AND NOTICE UNDER SECTION 143(2) MUST BE ISSUED BY INCOME -TAX OFFICER, WARD-I, HALDIA AND NONE OTHER - BUT, NOTICE WAS ISSUED BY ASSTT. COMMISSIONER, CIRCLE HALDIA MUCH AFTER CBDT'S INSTRUCTION AND KNOWING FULLY WELL THAT HE HAD NO JURISDICTION OVER ASSESSEE - WHETHER, THEREFORE, NOTICE ISSUED BY ASSTT. COMMISSIONER WAS INVALID AND CONSEQUENTLY ASSESSMENT FRAMED BY INCOME -TAX OFFICERS BECOMES VOID SINCE ISSUE OF NOT ICE UNDER SECTION 143(2) WAS NOT DONE BY INCOME - TAX OFFICERS AS SPECIFIED IN CBDT INSTRUCTION NO. 1/2011. THE HONBLE HIGH COURT OF CALCUTTA IN THE CASE OF WEST BENGAL STATE ELECTRICITY BOARD VS. DEPUTY COMMISSIONER OF INCOME TAX, SPECIAL RANGE I, REPORTED IN [2005] 278 ITR 218 (CAL.) HAS HELD AS FOLLOWS: - SECTION 254 OF THE INCOME -TAX ACT, 1961 - APPELLATE TRIBUNAL - POWERS OF - ASSESSMENT YEARS 88 - WHETHER A QUESTION OF LAW ARISING OUT OF FACTS FOUND BY AUTHORITIES AND T TO ROOT OF JURISDICTION CAN BE RAISED FOR FIRST TIME BEFORE TRIBUNAL - HELD, YESWHETHER JURISDICTION OF ASSESSING AUTHORITY IS NOT DEPENDENT ON DATE OF ACCRUAL OF CAUSE OF ACTION BUT ON DATE WHEN IT IS INITIATED - HELD, YES - WHETHER ONCE A PARTICULAR JU RISDICTION IS CREATED, SAME MUST BE PROSPECTIVE AND CANNOT BE RETROSPECTIVE AND IT HAS TO BE INTERPRETED HAVING REGARD TO MANNER IN WHICH IT HAS BEEN SOUGHT TO BE CREATED - HELD, YES ASSESSEE THE HONBLE SUPREME COURT IN THE CASE OF CIT VS. LAXMAN DAS KHANDELWAL [2019] 108 TAXMANN.COM 183 (SC), HELD AS FOLLOWS: - A CLOSER LOOK AT SECTION 292BB SHOWS THAT IF THE ASSESSEE HAS PARTICIPATED IN THE PROCEEDINGS IT SHALL BE DEEMED THAT ANY NOTICE WHICH IS REQUIRED TO BE SERVED UPON WAS DULY SERVED AND THE ASSESSEE WOULD BE PRECLUDED FROM TAKING ANY OBJECTIONS THAT THE NOTICE WAS (A) NOT SERVED UPON HIM; OR (B) NOT SERVED UPON HIM IN TIME; OR (C) SERVED UPON HIM IN AN IMPROPER MANNER. ACCORDING TO MR. MAHABIR SINGH, LEARNED SENIOR ADVOCATE, SINCE THE RES PONDENT HAD PARTICIPATED IN THE PROCEEDINGS, THE PROVISIONS OF SECTION 292BB WOULD BE A COMPLETE ANSWER. ON THE OTHER HAND, MR. ANKIT VIJAYWARGIA, LEARNED ADVOCATE, APPEARING FOR THE RESPONDENT SUBMITTED THAT THE NOTICE UNDER SECTION 143(2) OF THE ACT WAS NEVER ISSUED WHICH WAS EVIDENT FROM THE ORDERS PASSED ON RECORD AS WELL AS THE STAND TAKEN BY THE APPELLANT IN THE MEMO OF APPEAL. IT WAS FURTHER SUBMITTED THAT ISSUANCE OF NOTICE UNDER SECTION 143(2) OF THE ACT BEING PREREQUISITE, IN THE ABSENCE OF OTICE, THE ENTIRE PROCEEDINGS WOULD BE INVALID. THE LAW ON THE POINT AS REGARDS APPLICABILITY OF THE REQUIREMENT OF NOTICE UNDER SECTION 143(2) OF THE ACT IS QUITE CLEAR FROM THE DECISION IN HOTEL BLUE MOON'S CASE (SUPRA). THE ISSUE THAT HOWEVER NEEDS TO BE CONSIDERED IS THE IMPACT OF SECTION 292BB OF THE ACT. ACCORDING TO SECTION 292BB OF THE ACT, IF THE ASSESSEE HAD PARTICIPATED IN THE PROCEEDINGS, BY WAY OF LEGAL FICTION, NOTICE WOULD BE DEEMED TO BE VALID EVEN IF THERE BE INFRACTIONS AS DETAILED IN SAID SECTION. THE SCOPE OF THE PROVISION IS TO M AKE SERVICE OF NOTICE HAVING CERTAIN INFIRMITIES TO BE PROPER AND VALID IF THERE WAS REQUISITE PARTICIPATION ON PART OF THE ASSESSEE. IT IS, HOWEVER, TO BE NOTED THAT THE SECTION DOES NOT SAVE COMPLETE ABSENCE OF NOTICE. FOR SECTION 292BB TO APPLY, THE NOT ICE MUST HAVE EMANATED FROM THE DEPARTMENT. IT IS ONLY THE INFIRMITIES IN THE MANNER OF SERVICE OF NOTICE THAT THE SECTION SEEKS TO CURE. THE SECTION IS NOT INTENDED TO CURE COMPLETE ABSENCE OF NOTICE ITSELF. RESPECTFULLY FOLLOWING THE PROPOSITIONS OF LAW LAID DOWN IN ALL THESE CASE APPLYING THE SAME TO THE FACTS OF THE CASE, WE HOLD THAT THE ASSESSMENT ORDER IS BAD IN LAW FOR THE REASON THAT THE ASSESSING OFFICER HAVING JURISDICTION OVER THE ASSESSEE, HAS NOT ISSUED A NOTICE U/S 143(2) OF THE ACT AS REQUIRED BY THE STATUTE. NOTICE ISSUE BY THE OFFICER HAVING NO JURISDICTION OF THE ASSESSEE IS NULL AND VOID. WHEN A NOTICE IS ISSUED BY AN OFFICER HAVING NO JURISDICTION, SECTION 292BB OF THE ACT, DOES NOT COMES INTO PLAY. COMING TO THE ARGUMENT THE LD. D/R THAT OBJECTION U/S 124(3) OF THE ACT HAS TO BE TAKEN BY THE ASSESSEE ON RECTIFYING NOTICE U/S 143(2) OF THE ACT FROM A NON - JURISDICTIONAL ASSESSING OFFICER, VIEW THAT I NEED NOT ADJUDICATE THIS ISSUE, AS I HAVE HELD THAT NON -ISSUAL OF STATUTORY NOTICE/S 143(2) OF THE ACT BY THE JURISDICTIONAL ASSESSING OFFICER MAKES THE ASSESSMENT BAD IN LAW. UNDER THESE CIRCUMSTANCES, WE ALLOW THIS APPEAL OF THE ASSESSEE. RESPECTFULLY FOLLOWING THE SAME, WE HAVE TO HOLD THAT THE ASSESSMENT ORDER 11(1), KOLKATA, WITHOUT ISSUANCE OF NOTICE U/S 143(2) OF THE ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. THIS BENCH OF THE TRIBUNAL IN THE CASE OF KRISHNENDU CHOWDHURY VS. ITO REPORTED IN AS PER CBDT INSTRUCTION, JURISDICTION TAX OFFICER AND NOTICE UNDER SECTION 143(2) BUT, NOTICE WAS MUCH AFTER CBDT'S INSTRUCTION AND WHETHER, THEREFORE, NOTICE ISSUED BY ASSTT. COMMISSIONER WAS INVALID AND CONSEQUENTLY ASSESSMENT ICE UNDER SECTION 143(2) TAX OFFICERS AS SPECIFIED IN CBDT INSTRUCTION NO. 1/2011. THE HONBLE HIGH COURT OF CALCUTTA IN THE CASE OF WEST BENGAL STATE ELECTRICITY REPORTED IN [2005] 278 ASSESSMENT YEARS WHETHER A QUESTION OF LAW ARISING OUT OF FACTS FOUND BY AUTHORITIES AND HELD, YESWHETHER JURISDICTION OF ASSESSING AUTHORITY IS NOT DEPENDENT ON DATE OF ACCRUAL OF CAUSE OF ACTION BUT ON RISDICTION IS CREATED, SAME MUST BE PROSPECTIVE AND CANNOT BE RETROSPECTIVE AND IT HAS TO BE INTERPRETED HAVING REGARD TO MANNER DAS KHANDELWAL [2019] A CLOSER LOOK AT SECTION 292BB SHOWS THAT IF THE ASSESSEE HAS PARTICIPATED IN THE PROCEEDINGS IT SHALL THE ASSESSEE WOULD BE PRECLUDED FROM TAKING ANY OBJECTIONS THAT THE NOTICE WAS (A) NOT SERVED UPON HIM; OR (B) NOT SERVED UPON HIM IN TIME; OR (C) SERVED UPON HIM IN AN IMPROPER MANNER. ACCORDING TO MR. MAHABIR SINGH, PONDENT HAD PARTICIPATED IN THE PROCEEDINGS, THE PROVISIONS OF ON THE OTHER HAND, MR. ANKIT VIJAYWARGIA, LEARNED ADVOCATE, APPEARING FOR THE RESPONDENT SUBMITTED NEVER ISSUED WHICH WAS EVIDENT FROM THE ORDERS PASSED ON RECORD AS WELL AS THE STAND TAKEN BY THE APPELLANT IN THE MEMO OF APPEAL. IT WAS FURTHER SUBMITTED THAT ISSUANCE OF NOTICE UNDER SECTION 143(2) OF THE ACT BEING PREREQUISITE, IN THE ABSENCE OF THE LAW ON THE POINT AS REGARDS APPLICABILITY OF THE REQUIREMENT OF NOTICE UNDER SECTION 143(2) OF THE ACT IS QUITE CLEAR FROM THE DECISION IN HOTEL BLUE MOON'S CASE (SUPRA). THE ISSUE THAT HOWEVER NEEDS TO BE ACCORDING TO SECTION 292BB OF THE ACT, IF THE ASSESSEE HAD PARTICIPATED IN THE PROCEEDINGS, BY WAY OF LEGAL FICTION, NOTICE WOULD BE DEEMED TO BE VALID EVEN IF THERE BE INFRACTIONS AS DETAILED IN SAID SECTION. AKE SERVICE OF NOTICE HAVING CERTAIN INFIRMITIES TO BE PROPER AND VALID IF THERE WAS REQUISITE PARTICIPATION ON PART OF THE ASSESSEE. IT IS, HOWEVER, TO BE NOTED THAT THE SECTION DOES ICE MUST HAVE EMANATED FROM THE DEPARTMENT. IT IS ONLY THE INFIRMITIES IN THE MANNER OF SERVICE OF NOTICE THAT THE SECTION SEEKS TO CURE. LAW LAID DOWN IN ALL THESE CASE -LAW AND APPLYING THE SAME TO THE FACTS OF THE CASE, WE HOLD THAT THE ASSESSMENT ORDER IS BAD IN LAW FOR THE REASON THAT THE ASSESSING OFFICER HAVING JURISDICTION OVER THE ASSESSEE, HAS NOT ISSUED ACT AS REQUIRED BY THE STATUTE. NOTICE ISSUE BY THE OFFICER HAVING NO JURISDICTION OF THE ASSESSEE IS NULL AND VOID. WHEN A NOTICE IS ISSUED BY AN OFFICER HAVING NO JURISDICTION, SECTION 292BB OF THE ACT, DOES NOT COMES INTO PLAY. COMING TO THE ARGUMENT THE LD. D/R THAT OBJECTION U/S 124(3) OF THE ACT HAS TO BE TAKEN BY THE ASSESSEE ON JURISDICTIONAL ASSESSING OFFICER, I AM OF THE OF STATUTORY NOTICE/S 143(2) OF THE ACT BY THE JURISDICTIONAL ASSESSING OFFICER MAKES THE ASSESSMENT BAD IN LAW. RESPECTFULLY FOLLOWING THE SAME, WE HAVE TO HOLD THAT THE ASSESSMENT ORDER 11(1), KOLKATA, WITHOUT ISSUANCE OF NOTICE U/S 143(2) OF THE ACT, IS BAD IN LAW. IF IT IS HELD THAT THE ITO WARD ASSESSEE, THEN THE ASSESSMENT ORDER PASSED BY THE DCIT, CIRCLE BECOME BAD IN LAW AS IT WOULD BE LOOKING AT IT EITHER WAY, WE FIND THAT THE ASSESSMENT IS BAD IN LAW. 12. COMING TO THE MERITS OF THE CASE, WE FIND THAT THE ASSESSEE HAS FILED ALL THE NECESSARY DOCUMENTS TO PROVE THE IDENTITY AND CREDITWORTHINESS OF THE LOAN CREDITOR COMPANIES. EACH OF THESE COMPANIES ARE ASSESSED TO INCOME TAX AND HAVE CONFIRMED HAVING GIVEN LOAN TO TH E ASSESSEE. INTEREST HAS BEEN PAID ON THESE LOANS INTEREST . THE ASSESSEE HAS PROVIDED REPAID. THIS PROVES THE GENUINENESS 12.1. WE WOULD NOW CONSIDER THE EVIDENCES FILED PARTY WISE : 1) M/S. ALPS SALES PRIVATE LIMITED THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 02/08/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 19/03/1996 U51909WB1996PTC078213 ITO WARD 9(1) , KOLKATA AND WAS HAVING PAN HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF 31/03/2013 AND RS.1,60,75,700/ INCLUDING INTEREST WAS REPAID ON ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK-2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS CO ARE AVAILABLE ON PAGES 347 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 298-299 OF THE PAPER BOOK 2) M/S. AYUSH BUSINESS PRIVATE LIMITED RS.10,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 22/05/2012 7 ACT, IS BAD IN LAW. IF IT IS HELD THAT THE ITO WARD - 3(3), KOLKATA, HAS JURISDICTION OVER THE ASSESSEE, THEN THE ASSESSMENT ORDER PASSED BY THE DCIT, CIRCLE - 11(1), KOLKATA, WOULD BECOME BAD IN LAW AS IT WOULD BE AN ORDER PASSED BY AN OFFICER WHO HAS NO LOOKING AT IT EITHER WAY, WE FIND THAT THE ASSESSMENT IS BAD IN LAW. THE MERITS OF THE CASE, WE FIND THAT THE ASSESSEE HAS FILED ALL THE NECESSARY DOCUMENTS TO PROVE THE IDENTITY AND CREDITWORTHINESS OF THE LOAN CREDITOR COMPANIES. EACH OF THESE COMPANIES ARE ASSESSED TO INCOME TAX AND HAVE CONFIRMED E ASSESSEE. THE TRANSACTIONS ARE THROUGH BANKING CHANNELS. ON THESE LOANS AND TAX HAS BEEN DEDUCTED AT SOURCE . THE ASSESSEE HAS PROVIDED EVIDENCES IN CASES WHERE THE LOANS HAVE BEEN THIS PROVES THE GENUINENESS OF THE TRANSACTIONS. WE WOULD NOW CONSIDER THE EVIDENCES FILED PARTY WISE : - M/S. ALPS SALES PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN RS.15,00,000/ THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS 19/03/1996 AND WAS HAVING COMPANY IDENTIFICATION NUMBER U51909WB1996PTC078213 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE , KOLKATA AND WAS HAVING PAN AAACA3914A . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.1,60,75,700/ RS.1,60,75,700/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 03/11/2012 . THE COPY OF THE CONFIRM ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS CO 347 -360 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. OF THE PAPER BOOK -1. M/S. AYUSH BUSINESS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 22/05/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 3(3), KOLKATA, HAS JURISDICTION OVER THE 11(1), KOLKATA, WOULD AN ORDER PASSED BY AN OFFICER WHO HAS NO JURISDICTION. THE MERITS OF THE CASE, WE FIND THAT THE ASSESSEE HAS FILED ALL THE NECESSARY DOCUMENTS TO PROVE THE IDENTITY AND CREDITWORTHINESS OF THE LOAN CREDITOR COMPANIES. EACH OF THESE COMPANIES ARE ASSESSED TO INCOME TAX AND HAVE CONFIRMED THE TRANSACTIONS ARE THROUGH BANKING CHANNELS. AND TAX HAS BEEN DEDUCTED AT SOURCE ON THE THE LOANS HAVE BEEN RS.15,00,000/ - TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE . THIS COMPANY WAS RS.1,60,75,700/ - AS ON AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN . THE COPY OF THE CONFIRM ATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS CO MPANY 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATIO N NUMBER FILED ITS RETURN OF INCOME BEFORE AAECA3205A . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.10,74,01,884/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 10,26,630/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 378 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 3) M/S. BABA METALICS PRIVATE LIMITED INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR AND A FURTHER LOAN OF RS.10,00,000/ RECEIVED DURING THE FINANCIAL YEAR ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON WAS HAVING COMPANY IDENTIFICATION NUMBER COMPANY DULY FILED ITS RETURN OF INCOME BEFORE HAVING PAN AABCB0711D RESERVES AND SURPLUS OF RS.11 AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 33,17,490/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILA SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 8 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 07/03/1995 N NUMBER U74140WB1995PTC068936 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 4(3) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.10,74,01,884/ - AS ON 31/03/2013 AND RS. 10,76,40,122/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 05/01/2016 . COPY OF CONFIRMATION OF REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK - SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 300-301 OF THE PAPER BOOK M/S. BABA METALICS PRIVATE LIMITED : THERE WAS A OPENING BALANCE OF INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR RS.10,00,000/ - WAS PAID TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 23/04/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON WAS HAVING COMPANY IDENTIFICATION NUMBER U26939WB1995PTC074383 COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 5(4) , KOLKATA AND WAS AABCB0711D . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.11 ,40,55,919/- AS ON 31/03/2013 AND RS.11,43,10,410/ AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 29/03/2016 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILA BLE IN THE PAPER BOOK - SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 07/03/1995 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND 10,76,40,122/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 361- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX OF THE PAPER BOOK -1. : THERE WAS A OPENING BALANCE OF 22,16,000/- INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR WAS PAID TO THE ASSESSEE COMPANY, WHICH WAS . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 20/09/1995 AND U26939WB1995PTC074383 . THIS , KOLKATA AND WAS . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.11,43,10,410/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 379- 393 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 4) M/S. BALASARIA HOLDINGS PRIVATE LIMITED RS.5,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED D 2012-2013 ON 27/07/2012 THIS COMPANY WAS INCORPORATED ON IDENTIFICATION NUMBER U67120WB1995PTC074216 RETURN OF INCOME BEFORE ITO WARD 5(4) THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.66,41,05,705/- AS ON 31/03/2013 AND RESPECTIVELY. AT THE END OF THE YEAR THERE WAS PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 25/02/2016 IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN T SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 418 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 5) M/S. BASUKINATH DEVELOPERS PRIVATE LIMITED RS.50,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURIN YEAR 2012-2013 ON 25/05/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFOR AADCB1940J . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.5,10,11,242/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 21/08/2012 & 25/02/2013 IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 9 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 302-303 OF THE PAPER BOOK M/S. BALASARIA HOLDINGS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED D URING THE FINANCIAL YEAR 27/07/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 12/09/1995 AND WAS HAVING COMPANY U67120WB1995PTC074216 . THIS COMPANY DULY FILED ITS ITO WARD 5(4) , KOLKATA AND WAS HAVING PAN THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2013 AND RS.66,46,33,490/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST 25/02/2016 . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN T HE PAPER BOOK - SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U /S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 304-307 OF THE PAPER BOOK M/S. BASUKINATH DEVELOPERS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURIN 25/05/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 06/08/2007 COMPANY IDENTIFICATION NUMBER U70101WB2007PTC117656 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFOR E ITO WARD 5(3) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.5,10,11,242/ - AS ON 31/03/2013 AND RS.5,00,31,390/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 21/08/2012 & 25/02/2013 . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK - FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. REPLY U/S. 133(6) OF THE INCOME TAX OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN URING THE FINANCIAL YEAR . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. AND WAS HAVING COMPANY . THIS COMPANY DULY FILED ITS , KOLKATA AND WAS HAVING PAN AABCB1322L . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2012 A CLOSING BALANCE OF RS. 5,36,690/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 394- /S. 133(6) OF THE INCOME TAX OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURIN G THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 06/08/2007 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.5,00,31,390/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 419- 434 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEF ORE THE LD. AO IS AVAILABLE ON PAGE NO. 6) M/S. CHOKHANI REALTORS PRIVATE LIMITED RS.25,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 18/10/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE HAVING PAN AADCC3004E RESERVES AND SURPLUS OF RS.6,33,29,638/ ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 24/01/2013 . THE COPY OF THE RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 7) M/S. DEORA FINANCE PRIVATE LIMITED RS.27,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 22/09/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIF ICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AABCD1811E . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.29,81,72,293/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 29/01/2013 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 10 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ORE THE LD. AO IS AVAILABLE ON PAGE NO. 308 OF THE PAPER BOOK M/S. CHOKHANI REALTORS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 18/10/2012 . THE LOAN W AS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 11/03/2008 COMPANY IDENTIFICATION NUMBER U45400WB2008PTC124015 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE DCIT-CENTRAL CIRCLE- 4(XVIII)/CAL AADCC3004E . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.6,33,29,638/ - AS ON 31/03/2013 AND RS.6,51,19,238/ ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 309-310 OF THE PAPER BOOK M/S. DEORA FINANCE PRIVATE LIMITED : THIS C OMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 22/09/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 18/03/1988 ICATION NUMBER U65993WB1988PTC043976 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 6(1) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.29,81,72,293/ - AS ON 31/03/2013 AND RS.29,77,14,280/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL AS MADE BY ACCOUNT PAYEE 11/03/2008 AND WAS HAVING . THIS COMPANY DULY 4(XVIII)/CAL , KOLKATA AND WAS . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.6,51,19,238/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER THIS COMPANY ARE AVAILABLE ON PAGES 435-460 OF 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, OF THE PAPER BOOK -1. OMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 18/03/1988 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.29,77,14,280/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 461-477 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 8) M/S. GARG BROTHERS PRIVATE LIMITED TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 25/04/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 18/08/1984 U27109WB1984PTC . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE CENTRAL CIRCLE- 4(XIX)/CAL COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.54,86,02,090/- AS ON 31/03/2013 AND RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 9) M/S. IMPERIAL RETAILS PRIVATE LIMITED RS.15,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 30/08/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AACCI5938C . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.5,01,25,355/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 15,39,946/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. T HE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT 517 OF THE PAPER BOOK-2. 11 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 311 OF THE PAPER BOOK M/S. GARG BROTHERS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS 18/08/1984 AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE 4(XIX)/CAL , KOLKATA AND WAS HAVING PAN AAACG9775F COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2013 AND RS.52,32,00,539/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 10/0 7/2012 THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 478-498 OF THE PAPER BOOK M/S. IMPERIAL RETAILS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 30/08/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 04/05/2011 COMPANY IDENTIFICATION NUMBER U52190WB2011PTC162273 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 10(1) , KOLKATA AND WAS . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.5,01,25,355/ - AS ON 31/03/2013 AND RS.5,01,12,660,/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 17/01/2015 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE HE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK - SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN RS.50,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE DCIT- AAACG9775F . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2012 7/2012 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT OF THE PAPER BOOK -2. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 04/05/2011 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.5,01,12,660,/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE HE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 499- 10) M/S. INDRALOKE TIE- UP PRIVATE LIMITED 10,00,000/- INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR AND A FURTHER LOAN OF WAS RECEIVED DURING THE FINANCIAL YEAR MADE BY ACCOUNT PAYEE CHEQUE 24/12/2008 AND WAS HAVING COMPANY IDENTIFICATION NUMBER U51909WB2008PTC131451 ITO WARD 6(1) , KOLKATA AND WAS HAVING PAN A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF 31/03/2013 AND RS.1,51,08,860/ YEAR THERE WAS A CLOSING BALANCE OF RS. COMPANY TO ABOVE PARTY AN 02/01/2016 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED AC AVAILABLE IN THE PAPER BOOK HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 312-313 OF THE PAPER BOOK 11) M/S. JIT FINANCE PRIVATE LIMITED THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 15/06/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 04/01/1995 U65921WB1995PTC . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE 1(4) , KOLKATA AND WAS HAVING PAN CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.77,29,33,828/ - AS ON 31/03/201 CLOSING BALANCE OF RS. 10,85,808/ PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON CONFIRMATION OF ACCOUNT, TDS, AUDITED 12 UP PRIVATE LIMITED : THERE WAS A OPENING BALANCE OF INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR AND A FURTHER LOAN OF RS.5,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 25/05/2012 MADE BY ACCOUNT PAYEE CHEQUE /RTGS. THIS COMPANY WAS INCORPORATED ON AND WAS HAVING COMPANY IDENTIFICATION NUMBER U51909WB2008PTC131451 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE , KOLKATA AND WAS HAVING PAN AACCI0038F . THIS COMPANY WAS HAVING UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.1,51,20,483/ RS.1,51,08,860/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 15,39,946/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AN D THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED AC COUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 518-532 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE OF THE PAPER BOOK -1. M/S. JIT FINANCE PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN RS.10,00,000/ THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS 04/01/1995 AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE , KOLKATA AND WAS HAVING PAN AAACJ6647H . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.77,29,73647,/- AS ON 31/03/2013 AND AS ON 31/03/201 2 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A 10,85,808/ - TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 25/02/2016 CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. : THERE WAS A OPENING BALANCE OF INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE TO THE ASSESSEE COMPANY, WHICH 25/05/2012 . THE LOAN WAS /RTGS. THIS COMPANY WAS INCORPORATED ON AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE . THIS COMPANY WAS HAVING RS.1,51,20,483/ - AS ON AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE TO BE PAYABLE BY THE ASSESSEE D THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE COUNTS, IT RETURN AND OTHER DOCUMENTS ARE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE RS.10,00,000/ - TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD . THIS COMPANY WAS HAVING A PAID UP AS ON 31/03/2013 AND 2 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE 25/02/2016 . THE COPY OF THE ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 314-315 OF THE PAPER BOOK 12) M/S. JULEX DISTRIBUTORS PRIVATE LIMITED RS.25,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 01/08/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AAACJ6457F . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.19,99,64,373/ 31/03 /2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 08/11/2012 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS COPY OF THEIR STATEMENT RECORDED U/S. 131 OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 13) M/S. KR INFRA PROJECTS PRIVATE LIMITED RS.50,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 11/09/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICA TION NUMBER FILED ITS RETURN OF INCOME BEFORE AADCK4696A . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.3,17,95,972/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 13 AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 533-556 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE OF THE PAPER BOOK -1. M/S. JULEX DISTRIBUTORS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 01/08/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 29/01/1996 COMPANY IDENTIFICATION NUMBER U51109WB1996PTC076826 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 12(3) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.19,99,64,373/ - AS ON 31/03/2013 AND RS.19,96,81,622/ /2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 316 OF THE PAPER BOOK COPY OF THEIR STATEMENT RECORDED U/S. 131 OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 341-343 OF THE PAPER BOOK-1. M/S. KR INFRA PROJECTS PRIVATE LIMITED : THIS COMP ANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 11/09/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 11/08/2008 TION NUMBER U67190WB2008PTC128374 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 11(4) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.3,17,95,972/ - AS ON 31/03/2013 AND RS.3,15,63,314/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 29/01/1996 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.19,96,81,622/ - AS ON /2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 557-586 OF 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, OF THE PAPER BOOK -1. CERTIFIED COPY OF THEIR STATEMENT RECORDED U/S. 131 OF THE INCOME TAX ACT, 1961 FILED BEFORE THE ANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 11/08/2008 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.3,15,63,314/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 15/12/2012 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEV ANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES THE PAPER BOOK-2. 14) M/S. LAKSHMIRAMAN INVESTMENT & FINANCE LIMITED LOAN RS.50,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012- 2013 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AABCL3182E . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.11,39,27,224/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 50,00,000/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE CO PY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 15) M/S. LINKLINE CONSTRUCTION PRIVATE LIMITE RS.20,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 29/06/2012 & 05/09/2012 PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON HAVING COMPANY IDENTIFICATION NUMBER DULY FILED ITS RETURN OF INCOME BEFORE AACCL1073D . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.49,25,58,3 14 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER ANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES M/S. LAKSHMIRAMAN INVESTMENT & FINANCE LIMITED : THIS COMPANY HAD GIVEN A TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE 2013 ON 10/07/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 30/05/2007 COMPANY IDENTIFICATION NUMBER U65900WB2007PTC116238 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 1(2) , KOLKATA AND W . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.11,39,27,224/ - AS ON 31/03/2013 AND RS.11,26,44,526/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 05/03/2014 . COPY OF LEDGER ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN PY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 635 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 317-318 OF THE PAPER BOOK M/S. LINKLINE CONSTRUCTION PRIVATE LIMITE D : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 29/06/2012 & 05/09/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 27/09/2011 HAVING COMPANY IDENTIFICATION NUMBER U45400WB2011PTC168191 DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 49(1) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.49,25,58,3 64/- AS ON 31/03/2013 AND RS.49,24,99,296/ ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER ANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 587-611 OF : THIS COMPANY HAD GIVEN A TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE . THE LOAN WAS MADE BY ACCOUNT PAYEE 30/05/2007 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND W AS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.11,26,44,526/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . COPY OF LEDGER ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN PY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL 635 -656 OF THE PAPER 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT 27/09/2011 AND WAS U45400WB2011PTC168191 . THIS COMPANY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.49,24,99,296/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 21,43,212/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK-2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RE ARE AVAILABLE ON PAGES 612 16) M/S. MOJJIKA STEELS PRIVATE LIMITED INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR AND A FURTHER LOAN OF RS.20,00,000/ DURING THE FINANCIAL YEAR 2012 PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON HAVING COMPANY IDENTIFICATION DULY FILED ITS RETURN OF INCOME BEFORE AABCM7080Q . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.11,57,57,778/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 32,86,126/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK-2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS C ARE AVAILABLE ON PAGES 657 17) M/S. MONOLITHIC INVESTMENTS PRIVATE LIMITED RS.5,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 18/06/2012 THIS COMPANY WAS INCORPORATED ON IDENTIFICATION NUMBER U74899WB1995PTC073990 RETURN OF INCOME BEFORE ITO WARD 4(4) TH IS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.25,71,642,/- AS ON 31/03/2013 AND 15 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 03/11/2012 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RE LEVANT DOCUMENTS FOR THIS COMPANY 612 -634 OF THE PAPER BOOK-2. M/S. MOJJIKA STEELS PRIVATE LIMITED : THERE WAS A OPENING BALANCE OF INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR RS.20,00,000/ - TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED 2012 -2013 ON 04/06/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 25 /03/1992 HAVING COMPANY IDENTIFICATION NUMBER U51392WB1992PTC054923 DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 4(1) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.11,57,57,778/ - AS ON 31/03/2013 AND RS11.60,26,319/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 29/03/2016 . THE COPY OF THE CONFIR ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS C 657 -674 OF THE PAPER BOOK-2. M/S. MONOLITHIC INVESTMENTS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 18/06/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 20/11/1995 AND WAS HAVING COMPANY U74899WB1995PTC073990 . THIS COMPANY DULY FILED ITS ITO WARD 4(4) , KOLKATA AND WAS HAVING PAN IS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2013 AND RS.25,38,114/ - AS ON 31/03/2012 ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LEVANT DOCUMENTS FOR THIS COMPANY : THERE WAS A OPENING BALANCE OF 11,08,000/- INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED . THE LOAN WAS MADE BY ACCOUNT /03/1992 AND WAS U51392WB1992PTC054923 . THIS COMPANY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS11.60,26,319/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . THE COPY OF THE CONFIR MATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS C OMPANY : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR MADE BY ACCOUNT PAYEE CHEQUE/RTGS. AND WAS HAVING COMPANY . THIS COMPANY DULY FILED ITS , KOLKATA AND WAS HAVING PAN AABCM4179J . IS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON THE CONFIRMATION OF ACCOUNT, ARE AVAILABLE IN THE PAPER BOOK COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILAB CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 18) M/S. NARAYANI COMMODEAL PRIVATE LIMITED 20,00,000/- INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR AND A FURTHER LOAN OF WAS RECEIVED DURING THE FINANCIAL YEAR MADE BY AC COUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 30/12/2008 AND WAS HAVING COMPANY IDENTIFICATION NUMBER U51909WB2008PTC131563 ITO WARD 6(3) , KOLKATA AND WAS HAVING PAN HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF 31/03/2013 AND RS.7,20,09,431/ YEAR THERE WAS A CLOSING BALANCE OF RS. COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 20/11/2013 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUN T, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAIL ABLE ON PAGES 19) M/S. OLYMPIA CREDITS & MERCANTILES PRIVATE LIMITED LOAN RS.25,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012- 2013 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AAACO2805J . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND 16 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 17/11/2012 THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILAB LE ON PAGES 675-691 OF THE PAPER BOOK CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 319-321 OF THE PAPER BOOK-1. M/S. NARAYANI COMMODEAL PRIVATE LIMITED : THERE WAS A OPENING BALAN INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE PREVIOUS YEAR AND A FURTHER LOAN OF RS.20,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 22/05/2012 COUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON AND WAS HAVING COMPANY IDENTIFICATION NUMBER U51909WB2008PTC131563 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE , KOLKATA AND WAS HAVING PAN AACCN9212G . THIS COMPANY HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.7,14,86,411/ RS.7,20,09,431/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 42,15,408/- TO BE PAYABLE BY THE ASSESSEE TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE T, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR ABLE ON PAGES 692-708 OF THE PAPER BOOK-2. M/S. OLYMPIA CREDITS & MERCANTILES PRIVATE LIMITED : THIS COMPANY HAD GIVEN A TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE 2013 ON 09/07/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 14/06/1991 COMPANY IDENTIFICATION NUMBER U65921WB1991PTC052054 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 8(2) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 17/11/2012 . THE COPY OF TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT OF THE PAPER BOOK -2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE : THERE WAS A OPENING BALAN CE OF INCLUDING INTEREST WHICH WAS RECEIVED BY THE ASSESSEE COMPANY IN THE TO THE ASSESSEE COMPANY, WHICH 22/05/2012 . THE LOAN WAS COUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE . THIS COMPANY WAS RS.7,14,86,411/ - AS ON AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE TO BE PAYABLE BY THE ASSESSEE TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE T, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR : THIS COMPANY HAD GIVEN A TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE . THE LOAN WAS MADE BY ACCOUNT PAYEE 14/06/1991 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.5,85,44,658/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 12/11/2012 . THE COPY OF THE LEDGER OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 20) M/S. PANSARI ORGANOCHEM PRIVATE LIMITED RS.25,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 17/08/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUM FILED ITS RETURN OF INCOME BEFORE HAVING PAN AADCP5132A RESERVES AND SURPLUS OF RS.3,09,80,716/ ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 19/11/2012 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 21) M/S. POONAM MERCANTILES PRIVATE LIMITED RS.15,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 02/08/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AABCP5206F . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.3,63,88,041/ 17 RS.5,85,44,658/ - AS ON 31/03/2013 AND RS.5,84,29,552/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 709 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 322-323 OF THE PAPER BOOK M/S. PANSARI ORGANOCHEM PRIVATE LIMITED : THIS COMPANY HAD TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 17/08/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 02/01/1996 COMPANY IDENTIFICATION NUM BER U51909WB1996PTC076305 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE DCIT-CENTRAL CIRCLE- 5(XXV)/CAL AADCP5132A . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.3,09,80,716/ - AS ON 31/03/2013 AND RS.3,00,79,679/ ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 325-326 OF THE PAPER BOOK M/S. POONAM MERCANTILES PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 02/08/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 19/03/1996 COMPANY IDENTIFICATION NUMBER U51909WB1996PTC078213 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE DC-CIRCLE-XIII , KOLKATA AND WA . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.3,63,88,041/ - AS ON 31/03/2013 AND RS.3,63,61,025/ ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. RS.5,84,29,552/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL 709 -732 OF THE PAPER 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 02/01/1996 AND WAS HAVING . THIS COMPANY DULY 5(XXV)/CAL , KOLKATA AND WAS . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.3,00,79,679/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 733-756 OF 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 19/03/1996 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WA S HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.3,63,61,025/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 15,39,946/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 772 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 22) M/S. PRATEEK TRADERS PRIVATE LIMITED RS.20,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 09/05/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AADCP0140N . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.4,36,90,833/ 31/03/2012 RE SPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 21,93,513/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON REFLECTING THEREIN NIL BAL ANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK SOURCE OF FUNDS FROM WHICH THI PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 793 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO 23) M/S. REDLILY ENTERPRISES PRIVATE LIMITED RS.10,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 02/08/2012 18 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 02/01/2016 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK - SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 327-328 OF THE PAPER BOOK M/S. PRATEEK TRADERS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 09/05/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 02/03/1995 COMPANY IDENTIFICATION NUMBER U67120WB1995PTC068811 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 5(2) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.4,36,90,833/ - AS ON 31/03/2013 AND RS.4,37,69,928/ SPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 25/02/2016 . COPY OF CONFIRMATION OF ACCOUNT ANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK - SOURCE OF FUNDS FROM WHICH THI S COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 329-330 OF THE PAPER BOOK M/S. REDLILY ENTERPRISES PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 02/08/2012 . THE LOAN WAS MADE B Y ACCOUNT PAYEE ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 757- 133(6) OF THE INCOME TAX OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 02/03/1995 AND WAS HAVING THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.4,37,69,928/ - AS ON SPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . COPY OF CONFIRMATION OF ACCOUNT ANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF S COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 773- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL Y ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AABCR2177D . THIS COMP SURPLUS OF RS.12,19,31,643/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 10,43,200/- TO BE PAYABLE BY THE ASSESSEE C INCLUDING INTEREST WAS REPAID ON REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY AR 833 OF THE PAPER BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 24) M/S. SARAOGI VINIYOG PRIVATE LIMITED RS.50,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 22/05/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBE FILED ITS RETURN OF INCOME BEFORE AAECS0638R . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.10,57,62,583/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 26/09/2012 . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 19 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 03/09/1991 COMPANY IDENTIFICATION NUMBER U51109WB1991PTC052929 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 4(1) , KOLKATA AND WAS HAVING PAN . THIS COMP ANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.12,19,31,643/ - AS ON 31/03/2013 AND RS.12,22,14,691/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE C OMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 26/02/2016 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK - SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY AR E AVAILABLE ON PAGES 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 331-332 OF THE PAPER BOOK M/S. SARAOGI VINIYOG PRIVATE LIMITED : THIS COMPANY HAD GI TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 22/05/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 06/04/1995 COMPANY IDENTIFICATION NUMBE R U65999WB1995PTC070950 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 5(2) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.10,57,62,583/ - AS ON 31/03/2013 AND RS.10,22,58,693/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FU FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 834 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 333 OF THE PAPER BOOK-1. ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. 03/09/1991 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN ANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.12,22,14,691/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. OMPANY TO ABOVE PARTY AND THE SAID LOAN . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE E AVAILABLE ON PAGES 794- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX OF THE PAPER BOOK -1. : THIS COMPANY HAD GI VEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 06/04/1995 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.10,22,58,693/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND THE DETAILS OF SOURCE OF FU NDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL 834 -862 OF THE PAPER 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED 25) M/S. SEVEN STAR TRADES & SERVICES PRIVATE LIMITED RS.15,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 02/08/20 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE HAVING PAN AADCS7657R RESERVES AND SURPLUS OF RS.3,27,87,893/ ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 15,39,946/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. TH E COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 26) M/S. SIDHANT FINANCIAL CONSULTANTS PR LOAN RS.10,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012- 2013 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AALCS5338P . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.5,01,06,864/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. 10,43,496/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE P 20 M/S. SEVEN STAR TRADES & SERVICES PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 02/08/20 12 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 01/02/1996 COMPANY IDENTIFICATION NUMBER U51909WB1996PTC076969 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE DCIT CENTRAL CIRCLE- 3(XIII)/KOL AADCS7657R . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.3,27,87,893/ - AS ON 31/03/2013 AND RS.3,27,53,716/ ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 15/11/2014 . COPY OF LEDGER ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN E COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL FOR THIS COMPANY ARE AVAILABLE ON PAGES 863 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 334-335 OF THE PAPER BOOK M/S. SIDHANT FINANCIAL CONSULTANTS PR IVATE LIMITED : THIS COMPANY HAD GIVEN A TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE 2013 ON 05/11/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 23/01/2008 COMPANY IDENTIFICATION NUMBER U74120WB2008PTC122038 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 1(1) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.5,01,06,864/ - AS ON 31/03/2013 AND RS.5,00,89,791/ 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 22/03/2016 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE P APER BOOK - ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 01/02/1996 AND WAS HAVING . THIS COMPANY DULY 3(XIII)/KOL , KOLKATA AND WAS . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RS.3,27,53,716/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN . COPY OF LEDGER ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN E COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL 863 -879 OF THE PAPER 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TAX ACT, 1961 FILED OF THE PAPER BOOK -1. : THIS COMPANY HAD GIVEN A TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE . THE LOAN WAS MADE BY ACCOUNT PAYEE 23/01/2008 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.5,00,89,791/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRITTEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, - 2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 900 OF THE PAPER BOOK-2. 27) M/S. STB EXPORT PRIVATE LIMITED THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 02/08/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 13/07/1993 U27205WB1993PTC059440 ITO WARD 10(2) , KOLKATA AND WAS HAVING PAN HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF 31/03/2013 AND RS.43,60,895/ INCLUDING INTEREST WAS REPAID ON ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK-2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 901 28) M/S. SWATI ADVISORY SERVICES PRIVAT RS.25,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 03/04/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AAJCS7441R . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.1,44,14,972/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 08/01/2013 . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES BOOK- 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TA BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 21 SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES M/S. STB EXPORT PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN RS.25,00,000/ THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS 13/07/1993 AND WAS HAVING COMPANY IDENTIFICATION NUMBER U27205WB1993PTC059440 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE , KOLKATA AND WAS HAVING PAN AAHCS4813P . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.1 ,04,70,658/ RS.43,60,895/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 29/12/2012 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY 901 -917 OF THE PAPER BOOK-2. M/S. SWATI ADVISORY SERVICES PRIVAT E LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 03/04/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 20/03/2006 COMPANY IDENTIFICATION NUMBER U74140WB2006PTC108607 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 1(4) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.1,44,14,972/ - AS ON 31/03/2013 AND RS.1,43,68,969/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAI LS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 918 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TA BEFORE THE LD. AO IS AVAILABLE ON PAGE NO. 336-337 OF THE PAPER BOOK ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 880- RS.25,00,000/ - TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE . THIS COMPANY WAS ,04,70,658/ - AS ON AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 20/03/2006 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.1,43,68,969/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE LEDGER ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND LS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL 918 -938 OF THE PAPER 2. CERTIFIED COPY OF THEIR REPLY U/S. 133(6) OF THE INCOME TA X ACT, 1961 FILED OF THE PAPER BOOK -1. 29) M/S. VAISHALI FILMS PRIVATE LIMITED TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 26/07/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 06/03/2008 U92100WB2008PTC123768 DCIT CENTRAL CIRCLE- 4 (XVIII)/KOL COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.3,07,95,251/- AS ON 31/03/2013 AND RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 22/03/2016 THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRIT SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES THE PAPER BOOK-2. 30) M/S. VENKATESH REALCON PRIVATE LIMITED RS.25,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 13/07/23012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AADCV3688H . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.6,28,89,101/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 15/10/2012 . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVA NT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES THE PAPER BOOK-2. 22 M/S. VAISHALI FILMS PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS 06/03/2008 AND WAS HAVING COMPANY IDENTIFICATION NUMBER U92100WB2008PTC123768 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE 4 (XVIII)/KOL , KOLKATA AND WAS HAVING PAN AACCV6598B COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2013 AND RS.3,07,80,898/ - AS ON 31/03/2012 RESPECTIVELY. AT THE END OF THE YEAR THERE WAS A CLOSING BALANCE OF RS. BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING 22/03/2016 . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRIT SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES M/S. VENKATESH REALCON PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 13/07/23012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 30/07/2010 COMPANY IDENTIFICATION NUMBER U70100WB2010PTC151844 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 6(4) , KOL KATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.6,28,89,101/ - AS ON 31/03/2013 AND RS.1,13,81,369/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER NT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. : THIS COMPANY HAD GIVEN A LOAN RS.20,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS AND WAS HAVING COMPANY IDENTIFICATION NUMBER . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE AACCV6598B . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF AS ON 31/03/2012 RS. 21,47,353/- TO BE PAYABLE BY THE ASSESSEE COMPANY TO ABOVE PARTY AND THE SAID LOAN INCLUDING . COPY OF CONFIRMATION OF ACCOUNT REFLECTING THEREIN NIL BALANCE TO BE PAYABLE BY US IS ENCLOSED HEREWITH ALONG WITH THE WRIT TEN SUBMISSION. THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 939-961 OF : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 30/07/2010 AND WAS HAVING . THIS COMPANY DULY KATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.1,13,81,369/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER NT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES 962-980 OF 31) M/S. VRINDAVAN COMMOSALES PRIVATE LIMITED RS.25,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 15 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AACCV9560B . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.2,03,53,027/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 04/12/2012 . THE COPY OF THE RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THE PAPER BOOK-2. 32) M/S. WIZARD INVESTMENT ADVISORY PRIVATE LIMITED RS.15,00,000/- TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL YEAR 2012-2013 ON 07/11/2012 CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON COMPANY IDENTIFICATION NUMBER FILED ITS RETURN OF INCOME BEFORE AAACW8683J . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND SURPLUS OF RS.1,52,81,107/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON 14/03/2013 . THE COPY OF THE CONFIRMA RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COM OF THE PAPER BOOK-2. 13. ON EXAMINING THE ABOVE CREDITOR IN SUPPORT OF THE GENUINENESS OF THE TRANSACTION AND AS INTEREST HAS BEEN PAID 23 M/S. VRINDAVAN COMMOSALES PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 15 /06/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 09/03/2009 COMPANY IDENTIFICATION NUMBER U51909WB2009PTC133608 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 5(1) , KOLKATA AND WAS HAV . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.2,03,53,027/ - AS ON 31/03/2013 AND RS.2,03,08,435/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COMPANY ARE AVAILABLE ON PAGES M/S. WIZARD INVESTMENT ADVISORY PRIVATE LIMITED : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL 07/11/2012 . THE LOAN WAS MADE BY ACCOUNT PAYEE CHEQUE/RTGS. THIS COMPANY WAS INCORPORATED ON 25/03/2009 COMPANY IDENTIFICATION NUMBER U65990WB2009PTC124230 . THIS COMPANY DULY FILED ITS RETURN OF INCOME BEFORE ITO WARD 43(4) , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.1,52,81,107/ - AS ON 31/03/2013 AND RS.1,49,45,468/ 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON . THE COPY OF THE CONFIRMA TION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT RETURN AND OTHER DOCUMENTS ARE AVAILABLE IN THE PAPER BOOK -2. THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER BOOK. ALL THE RELEVANT DOCUMENTS FOR THIS COM PANY ARE AVAILABLE ON PAGES ON EXAMINING THE ABOVE VOLUMINOUS RECORDS AND DOCUMENTS PRODUCED BY EACH CREDITOR IN SUPPORT OF THE GENUINENESS OF THE TRANSACTION AND AS INTEREST HAS BEEN PAID ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL . THE LOAN WAS MADE BY ACCOUNT PAYEE 09/03/2009 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAV ING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.2,03,08,435/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON CONFIRMATION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER THIS COMPANY ARE AVAILABLE ON PAGES 981-999 OF : THIS COMPANY HAD GIVEN A LOAN TO THE ASSESSEE COMPANY, WHICH WAS RECEIVED DURING THE FINANCIAL THE LOAN WAS MADE BY ACCOUNT PAYEE 25/03/2009 AND WAS HAVING . THIS COMPANY DULY , KOLKATA AND WAS HAVING PAN . THIS COMPANY WAS HAVING A PAID UP CAPITAL WITH FREE RESERVES AND RS.1,49,45,468/ - AS ON 31/03/2012 RESPECTIVELY. THE SAID LOAN INCLUDING INTEREST WAS REPAID ON TION OF ACCOUNT, TDS, AUDITED ACCOUNTS, IT THE DETAILS OF SOURCE OF FUNDS FROM WHICH THIS COMPANY HAD MADE THE LOAN ARE ALSO AVAILABLE IN THE PAPER PANY ARE AVAILABLE ON PAGES 1000-1013 AND DOCUMENTS PRODUCED BY EACH CREDITOR IN SUPPORT OF THE GENUINENESS OF THE TRANSACTION AND AS INTEREST HAS BEEN PAID ON ALL THESE LOANS AND AS TDS ASSESSING OFFICER NOR THE LD. CIT(A) HAVE ANY ADVERSE MATERIAL TO CONTROVERT THE EVIDENCE FILED BY EACH OF THESE CREDITORS PARTIES ARE ASSESSED TO INCOME TO A CONCLUSION THAT THE ADDITION MADE U/S 68 OF THE ACT, ON THE GROUND THAT THESE ARE UNEXPLAINED CASH CREDITS, IS BAD IN LAW. THE LOAN CREDITORS IN THIS CASE HAVE ALSO EXPLAINED SOURCES OF SOURCES. DECISIONS ON CONJECTURES AND SURMISES. HEREBY DELETED. CONSEQUENTLY, THE INTEREST EXPENDITURE DISALLOWED ON TH IS ALSO DIRECTED TO BE DELETED. 14. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWED. KOLKATA, THE SD/- [ S. S. GODARA ] JUDICIAL MEMBER DATED : 12.01.2021 {SC SPS} COPY OF THE ORDER FORWARDED TO: 1. HILLMAN HOSIERY MILLS PVT. LTD 26/1G, P K TAGORE STREET JORABAGAN KOLKATA 700 006 2. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3. CIT(A)- 4. CIT- , 5. CIT(DR), KOLKATA BENCHES, KOLKATA. 24 ON ALL THESE LOANS AND AS TDS HAS BEEN DEDUCTED ON THESE INTEREST PAYMENTS AND AS THE ASSESSING OFFICER NOR THE LD. CIT(A) HAVE ANY ADVERSE MATERIAL TO CONTROVERT THE EVIDENCE FILED BY EACH OF THESE CREDITORS AND ALSO LOOKING AT THE FACT THAT EACH OF THE PARTIES ARE ASSESSED TO INCOME TAX AND AS MANY OF THE LOANS HAVE BEEN REPAID, WE COME TO A CONCLUSION THAT THE ADDITION MADE U/S 68 OF THE ACT, ON THE GROUND THAT THESE ARE UNEXPLAINED CASH CREDITS, IS BAD IN LAW. THE LOAN CREDITORS IN THIS CASE HAVE ALSO EXPLAINED SOURCES OF SOURCES. T HE ASSESSING OFFICER AS WELL AS THE LD. CIT(A) BASED THEIR DECISIONS ON CONJECTURES AND SURMISES. THUS, THIS ADDITION MADE U/S 68 OF THE ACT, IS HEREBY DELETED. CONSEQUENTLY, THE INTEREST EXPENDITURE DISALLOWED ON TH DELETED. HENCE ALL THESE GROUNDS ON MERITS ARE ALLOWED. IN THE RESULT, APPEAL OF THE ASSESSEE IS ALLOWED. KOLKATA, THE 12 TH DAY OF JANUARY, 2021. [ J. SUDHAKAR REDDY ACCOUNTANT MEMBER HILLMAN HOSIERY MILLS PVT. LTD DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -11(1), KOLKATA 5. CIT(DR), KOLKATA BENCHES, KOLKATA. ASSISTANT REGISTRAR ITAT, KOLKATA BENCHES ITA NO. 2634/KOL/2019 ASSESSMENT YEAR: 2013-14 HILLMAN HOSIERY MILLS PVT. LTD. HAS BEEN DEDUCTED ON THESE INTEREST PAYMENTS AND AS THE ASSESSING OFFICER NOR THE LD. CIT(A) HAVE ANY ADVERSE MATERIAL TO CONTROVERT THE AND ALSO LOOKING AT THE FACT THAT EACH OF THE TAX AND AS MANY OF THE LOANS HAVE BEEN REPAID, WE COME TO A CONCLUSION THAT THE ADDITION MADE U/S 68 OF THE ACT, ON THE GROUND THAT THESE ARE UNEXPLAINED CASH CREDITS, IS BAD IN LAW. THE LOAN CREDITORS IN THIS CASE HAVE ALSO HE ASSESSING OFFICER AS WELL AS THE LD. CIT(A) BASED THEIR THUS, THIS ADDITION MADE U/S 68 OF THE ACT, IS HEREBY DELETED. CONSEQUENTLY, THE INTEREST EXPENDITURE DISALLOWED ON TH ESE CASH CREDITS HENCE ALL THESE GROUNDS ON MERITS ARE ALLOWED. SD/- J. SUDHAKAR REDDY ] ACCOUNTANT MEMBER TRUE COPY BY ORDER ASSISTANT REGISTRAR ITAT, KOLKATA BENCHES