M/s. Hindusthan National Glass & Industries Ltd., , Kolkata V. D.C.I.T, Circle - 5(2), , Kolkata

ITA 515/KOL/2019

• Counselvise Citation: [2019] 112 COUNSELVISE.COM (IT) 0145 (ITAT-KOLKATA)
• Duration Of Justice: 9 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-12-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2013-2014
• Appeal Filed On: 15-03-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: RANU BISWAS
• Assessee Lawyers: D S DAMLE
• Keywords: Earning of tax free income; Rule 8D
• Section: 143(3); 14A; 143(2)

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL B, BENC H KOLKATA BEFORE SHRI S.S.GODARA, JM &DR. A.L.SAINI, AM ./ITA NO.515/KOL/2019 ( / ASSESSMENT YEAR: 2013-14) HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. 2, RED CROSS PLACE, BBD BAG, KOLKATA-700001 VS. DCIT, CIRCLE-5(2), KOLKATA ./ ./PAN/GIR NO.: AAACH 7557 G (APPELLANT) .. (RESPONDENT) APPELLANT BY : SHRI D.S. DAMLE, FCA RESPONDENT BY : SMT. RANU BISWAS, ADDL. CIT / DATE OF HEARING : 31/10/2019 /DATE OF PRONOUNCEMENT : 31/12/2019 / O R D E R PER BENCH: THE CAPTIONED APPEAL FILED BY THE ASSESSEE , PE RTAINING TO ASSESSMENT YEAR 2013-14, IS DIRECTED AGAINST THE ORDER PASSED BY TH E COMMISSIONER OF INCOME TAX (APPEAL)-2, KOLKATA IN APPEAL NO. 10081/CIT(A)-2/16 -17, WHICH IN TURN ARISES OUT OF AN ASSESSMENT ORDER PASSED BY THE ASSESSING OFFI CER U/S 143(3) OF THE INCOME TAX ACT, 1961 (IN SHORT THE ACT) DATED 17/03/2016 . 2. THE GROUNDS OF APPEAL RAISED BY THE ASSESSEE ARE AS FOLLOWS: 1. FOR THAT ON THE FACTS AND IN THE CIRCUMSTANCES O F THE CASE, THE LD. CIT(A) WAS UNJUSTIFIED IN LAW AND ON FACTS IN SETTING ASID E THE DISALLOWANCE AS PER RULE 8D(2)(II) TO THE FILE OF ASSESSING OFFICER EVE N THOUGH IT WAS DEMONSTRATED BEFORE THE LOWER AUTHORITIES THAT THE APPELLANTS NET OWN FUNDS IN THE FORM OF CAPITAL & FREE RESERVES WERE M UCH HIGHER THAN THE INVESTMENTS IN SHARES. 2. FOR THAT ON THE FACTS AND IN THE CIRCUMSTANCES OUGHT NOT TO HAVE RESTORED THE ISSUE OF QUANTIFICAT ION OF DISALLOWANCE UNDER RULE 8D(2)(II) IN RESPECT OF INTEREST PAID TO THE A .OS FILE WHEN IN THE PRECEDING AND SUBSEQUENT ASSESSMENT YEARS THE APPEL LATE AUTHORITIES, FOLLOWIN G THE BINDING DECISION OF THE CALCUTTA HIGH COURT I N THE CASE OF RASOI LIMITED, HAD HELD THAT NO INTEREST WAS DISALL OWABLE U/S 14A SINCE APPELLANTS OWN FUNDS WERE MORE THAN SUFFICIENT TO MEET THE COST OF INVESTMENT. 3. FOR THAT THE APPELLANT CRAVES LEAVE AMEND OR ALTER THE GROUNDS ALREADY TAKEN EITHER AT THE TIME OF HEARING OF THE APPEAL OR BEFORE. 3. BRIEF FACTS QUA THE ISSUE ARE THAT THE ASSESSEE COMPANY FILED ITS RETURN OF INCOME ON 29.09.2013 DECLARING TOTAL LOSS FINANCIAL YEAR, THE ASSESSEE COMPANY ENGAGED IN THE BUSINESS OF MANUFACTURING AND SELLING OF GLASS BOTTLES & CONTAINERS, PRINTING OF BOTTLES, MANUFACTURING OF CASTING AND POWER GENERATION. THE ASSESSEES CASE 143(2) OF THE ACT AND THE ASSESSING OFFICER COMPUTE D THE ADDITION U/S 143(3) OF THE ACT BY MAKING DISALLOWANCE U/S 14A READ WITH RU LE 8D AS FOLLOWS: 3. AGGRIEVED BY THE ADDITION MADE BY THE ASSESSING OFFICER THE ASSE SSEE CARRIED THE MATTER IN APPEAL BEFORE THE LD. CIT(A) WHO HAS ALLOWED THE APPEAL ASSESSEE FOR STATISTICAL PURPOSES OBSERVING THE FOL LOWING: I HAVE CONSIDERED THE GROUNDS OF APPEAL, STATEMENT OF THE AUTHORIZED REPRESENTATIVE OF THE APPELLATE COMP ANY AS WELL AS THE ORDER OF THE ASSESSING OFFICER FRAMED IN THE LIGHT OF THE MATERI ALS AVAILABLE ON RECORD BEFORE THE ASSESSING OFFICER DURING THE ASSESSMENT PROCEED INGS. HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. ITA NO. ASSESSMENT YEAR: FUNDS IN THE FORM OF CAPITAL & FREE RESERVES WERE M UCH HIGHER THAN THE INVESTMENTS IN SHARES. 2. FOR THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD. CIT(A) OUGHT NOT TO HAVE RESTORED THE ISSUE OF QUANTIFICAT ION OF DISALLOWANCE UNDER RULE 8D(2)(II) IN RESPECT OF INTEREST PAID TO THE A .OS FILE WHEN IN THE PRECEDING AND SUBSEQUENT ASSESSMENT YEARS THE APPEL LATE AUTHORITIES, G THE BINDING DECISION OF THE CALCUTTA HIGH COURT I N THE CASE OF RASOI LIMITED, HAD HELD THAT NO INTEREST WAS DISALL OWABLE U/S 14A SINCE APPELLANTS OWN FUNDS WERE MORE THAN SUFFICIENT TO MEET THE COST OF 3. FOR THAT THE APPELLANT CRAVES LEAVE TO SUBMIT ADDITIONAL GROUNDS AND/OR AMEND OR ALTER THE GROUNDS ALREADY TAKEN EITHER AT THE TIME OF HEARING OF THE APPEAL OR BEFORE. 3. BRIEF FACTS QUA THE ISSUE ARE THAT THE ASSESSEE COMPANY FILED ITS RETURN OF INCOME ON 29.09.2013 DECLARING TOTAL LOSS TO THE TUNE OF RS. 663,99,40,209/ FINANCIAL YEAR, THE ASSESSEE COMPANY ENGAGED IN THE BUSINESS OF MANUFACTURING AND SELLING OF GLASS BOTTLES & CONTAINERS, PRINTING OF BOTTLES, MANUFACTURING OF CASTING AND POWER GENERATION. THE ASSESSEES CASE WAS SELECTED FOR SCRUTINY U/S 143(2) OF THE ACT AND THE ASSESSING OFFICER COMPUTE D THE ADDITION U/S 143(3) OF THE ACT BY MAKING DISALLOWANCE U/S 14A READ WITH RU LE 8D AS FOLLOWS: THE ADDITION MADE BY THE ASSESSING OFFICER THE ASSE SSEE CARRIED THE MATTER IN APPEAL BEFORE THE LD. CIT(A) WHO HAS ALLOWED THE APPEAL ASSESSEE FOR STATISTICAL PURPOSES OBSERVING THE FOL LOWING: I HAVE CONSIDERED THE GROUNDS OF APPEAL, STATEMENT OF FACTS AND CIRCUMSTANCES OF THE AUTHORIZED REPRESENTATIVE OF THE APPELLATE COMP ANY AS WELL AS THE ORDER OF THE ASSESSING OFFICER FRAMED IN THE LIGHT OF THE MATERI ALS AVAILABLE ON RECORD BEFORE THE ASSESSING OFFICER DURING THE ASSESSMENT PROCEED INGS. THE AR HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. ITA NO. 515/KOL/2019 ASSESSMENT YEAR: 2013-14 P PP PA AA AG GG GE EE E | || | 2 22 2 FUNDS IN THE FORM OF CAPITAL & FREE RESERVES WERE M UCH HIGHER THAN THE OF THE CASE, THE LD. CIT(A) OUGHT NOT TO HAVE RESTORED THE ISSUE OF QUANTIFICAT ION OF DISALLOWANCE UNDER RULE 8D(2)(II) IN RESPECT OF INTEREST PAID TO THE A .OS FILE WHEN IN THE PRECEDING AND SUBSEQUENT ASSESSMENT YEARS THE APPEL LATE AUTHORITIES, G THE BINDING DECISION OF THE CALCUTTA HIGH COURT I N THE CASE OF RASOI LIMITED, HAD HELD THAT NO INTEREST WAS DISALL OWABLE U/S 14A SINCE APPELLANTS OWN FUNDS WERE MORE THAN SUFFICIENT TO MEET THE COST OF TO SUBMIT ADDITIONAL GROUNDS AND/OR AMEND OR ALTER THE GROUNDS ALREADY TAKEN EITHER AT THE TIME OF HEARING OF 3. BRIEF FACTS QUA THE ISSUE ARE THAT THE ASSESSEE COMPANY FILED ITS RETURN OF INCOME TO THE TUNE OF RS. 663,99,40,209/ -. DURING THE FINANCIAL YEAR, THE ASSESSEE COMPANY ENGAGED IN THE BUSINESS OF MANUFACTURING AND SELLING OF GLASS BOTTLES & CONTAINERS, PRINTING OF BOTTLES, MANUFACTURING OF WAS SELECTED FOR SCRUTINY U/S 143(2) OF THE ACT AND THE ASSESSING OFFICER COMPUTE D THE ADDITION U/S 143(3) OF THE ACT BY MAKING DISALLOWANCE U/S 14A READ WITH RU LE 8D AS FOLLOWS: THE ADDITION MADE BY THE ASSESSING OFFICER THE ASSE SSEE CARRIED THE MATTER IN APPEAL BEFORE THE LD. CIT(A) WHO HAS ALLOWED THE APPEAL OF THE FACTS AND CIRCUMSTANCES OF THE AUTHORIZED REPRESENTATIVE OF THE APPELLATE COMP ANY AS WELL AS THE ORDER OF THE ASSESSING OFFICER FRAMED IN THE LIGHT OF THE MATERI ALS AVAILABLE ON RECORD BEFORE THE AR OF THE APPELLATE HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. ITA NO.515/KOL/2019 ASSESSMENT YEAR:2013-14 P PP PA AA AG GG GE EE E | || | 3 33 3 HAS SUBMITTED THAT THE ENTIRE INVESTMENTS HAVE BEEN MADE OUT OF OWN INTEREST FREE FUNDS AND NO INTEREST-BEARING BORROWINGS WHATSOEVER HAS BEEN UTILIZED FOR MAKING SUCH INVESTMENTS. THE INTEREST: EXPENDITURE WAS DIRECTLY ATTRIBUTABLE TO THE BUSINESS ACTIVITIES OF THE APPELLANT AND THEREF ORE NO PORTION OF INTEREST ATTRIBUTABLE TO INVESTMENTS/ SECURITIES. THE APPELL ANT FURTHER SUBMITS THAT THE INTEREST EXPENSES OF RS.20066.77 LACS PERTAINS TO I NTEREST PAID TO BANKS & FINANCIAL INSTITUTIONS FOR OBTAINING TERM LOANS, CA SH CREDIT FACILITIES, WORKING CAPITAL LIMITS, PACKING OTHER RELATED EXPORT CREDIT S ETC. IT IS SUBMITTED THAT ALL THESE LOANS WERE SECURED AGAINST THE FIXED ASSETS A ND WORKING CAPITAL COMPRISING OF STOCK, SUNDRY DEBTORS ETC. THE APPELLANT SUBMITS THAT THESE SECURED LOANS WAS OBTAINED FOR SPECIFIC BUSINESS PURPOSES AND ALSO UT ILIZED THEREOF ONLY. IN THE CIRCUMSTANCES IT WOULD BE APPRECIATED THAT NONE OF THE INTEREST COSTS INCURRED ON THESE LOAN FUNDS WERE IN CONNECTION WITH THE INVEST MENTS OR PURCHASE OF SHARES MADE BY THE APPELLANT. AS REGARDS TO DISALLOWANCE U NDER RULE 8D (III), THE AR OF THE APPELLATE HAS SUBMITTED THAT THE DISALLOWANCE U NDER SECTION 14A IN TERMS OF FORMULA LAID DOWN IN RULE 8D SHOULD BE COMPUTED WIT H REFERENCE TO THE DIVIDEND YIELDING' INVESTMENTS. AS REGARDS TO DISALLOWANCE OF THE INTEREST UNDER RU LE 8D(II) THE AR OF THE APPELLATE BEFORE THE AO AS WELL AS ME HAD STATED TH AT THE SECURED LOANS WERE OBTAINED BY THE APPELLANT FOR SPECIFIED BUSINESS PU RPOSES. 1 FIND THAT THE INTEREST EXPENSES PERTAIN TO INTEREST PAID TO BANKS & FINANCIAL INSTITUTIONS FOR OBTAINING TERM LOANS, CASH CREDIT FACILITIES, WORKING CAPITAL LIMITS, PACKING OTHER RELATED EXPORT CREDITS ETC. THE ALL THESE LOANS WERE SECURE D AGAINST THE FIXED ASSETS AND WORKING CAPITAL COMPRISING OF STOCK, SUNDRY DEBTORS ETC. THESE SECURED LOANS WERE OBTAINED FOR SPECIFIC BUSINESS PURPOSES AND AL SO UTILIZED THEREOF ONLY AND NONE OF THE INTEREST COSTS INCURRED ON THESE LOAN F UNDS WERE IN CONNECTION WITH THE INVESTMENTS OR PURCHASE OF SHARES MADE BY THE APPEL LANT. ATTENTION IN THIS REGARD IS MADE TO THE DECISION OF THE KOLKATA BENCH OF INCOME- TAX APPELLATE TRIBUNAL IN THE CASE OF ITO VS NARAIN PRASAD DALMIA (ITA NO. 1180/KOL/2011) DATED 27.01.2014. IN THE DECIDED CAS E THE ITAT HELD THAT RULE 8D(2)(II) IS VERY CLEAR THAT THE EXPENDITURE ON ACC OUNT OF PAYMENT OF INTEREST WOULD BE COVERED IN THE SAID RULE ONLY IF IT IS NOT DIRECTLY ATTRIBUTABLE TO ANY PARTICULAR INCOME OR RECEIPT. THE ITAT THEREFORE HE LD THAT IF THE ASSESSEE IS ABLE TO DEMONSTRATE THAT THE PAYMENT OF INTEREST IS DIRE CTLY ATTRIBUTABLE TO THE ASSESSEE'S BUSINESS THEN IT CANNOT BE CONSIDERED UN DER RULE 8D (2) (II) OF THE I.T. RULES. SIMILAR VIEW WAS ALSO EXPRESSED BY THE CHENNAI BENC H OF INCOME-TAX APPELLATE TRIBUNAL IN THE CASE OF ACIT VS BEST & CROMPTON ENGINEERING LTD (ITA NO. 1603/MDS/2012) DATED 16.07.2013 WHEREIN THE TRIBUNA L CATEGORICALLY HELD THAT IF LOANS HAVE BEEN SANCTIONED FOR SPECIFIC PROJECTS/ B USINESS PURPOSES AND HAVE BEEN UTILIZED TOWARDS THE SAME, THEN OBVIOUSLY THEY COUL D NOT HAVE BEEN UTILIZED FOR MAKING ANY INVESTMENTS CAPABLE OF YIELDING TAX-FREE INCOME AND IT THEREFORE HAS TO BE EXCLUDED FROM THE CALCULATION TO DETERMINE TH E DISALLOWANCE UNDER RULE 8D(2)(II). IN BOTH THE ABOVE DECISIONS THE COORDINATE BENCHES REFERRED TO THE DECISION OF KOLKATA BENCH OF ITAT IN THE CASE OF ACIT VS CHAMPI ON COMMERCIAL LIMITED (139 ITD 108) WHEREIN IT WAS OBSERVED THAT SECTION 14A OF THE INCOME-TAX ACT, 1961 RECOGNIZES TWO CATEGORIES OF INCOME WHICH ARE MUTUALLY EXCLUSIVE VIZ. 'TAX EXEMPT INCOME' AND 'TAXABLE INCOME'. ACCORDINGLY, W HILE ALLOCATING INTEREST HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. ITA NO.515/KOL/2019 ASSESSMENT YEAR:2013-14 P PP PA AA AG GG GE EE E | || | 4 44 4 AMONGST THESE TWO CATEGORIES, INTEREST WHICH IS DIR ECTLY RELATABLE TO 'TAXABLE INCOME' IS TO BE EXCLUDED FROM THE PURVIEW OF THE D ISALLOWANCE & INTEREST WHICH IS DIRECTLY RELATABLE TO EXEMPT INCOME' HAS TO BE ENT IRELY DISALLOWED UNDER SECTION 14A. IT IS ONLY THE REMAINING COMMON INTEREST WHICH DOES NOT RELATE TO ANY SPECIFIC CATEGORY OF INCOME CAN ONLY BE APPORTIONED AND ACCORDINGLY BE DISALLOWED UNDER SECTION 14A READ WITH RULE 8D(2)(I I). THE TRIBUNAL WHILE ARRIVING AT THIS CONCLUSION REFERRED TO THE BOMBAY HIGH COURT IN THE CASE OF GODREJ & BOYCE MFG CO LTD (SUPRA) WHEREIN IT WAS IN PRINCIPLE ACCEPTED THAT ONLY THE REMAINING INTEREST/EXPENDITURE WHICH CANNO T BE IDENTIFIED OR ALLOCATED TO ANY SPECIFIC ASSET/PURPOSE SHALL BE DISALLOWED UNDE R RULE 8D(2)(II) & (III). IN VIEW OF ABOVE, THE APPELLANT SHALL FURNISH BEFOR E THE AO THE DETAILS IN THE MATTER. THE AO IS ALSO DIRECTED TO VERIFY THE SAME AND ACCORDINGLY RE-COMPUTE THE DISALLOWANCE U/S 14A R.W. RULE 8D. THE AO SHALL ALL OW THE APPELLANT AN OPPORTUNITY OF HEARING BEFORE PASSING ANY ORDER IN THIS REGARD. THIS GROUND IS THEREFORE ALLOWED FOR STATISTICAL PURPOSES. AS REGARDS TO DISALLOWANCE OF IHE EXPENSES UNDER RU LE 8D (III) HON'BLE JURISDICTIONAL ITAT IN THE CASE OF RE1 AGRO LTD. VS . DC1T (144 ITD 141) HAS HELD THAT ONLY THE INVESTMENTS WHICH ACTUALLY YIELD EXEM PT INCOME HAS TO BE CONSIDERED FOR THE PURPOSES OF APPLICATION OF RULE 8D(2)(III). THE ITAT HELD THAT THE INVESTMENTS WHICH DID NOT YIELD ANY TAX-FREE INCOME IN THE RELEVANT YEAR WERE NOT REQUIRED TO BE CONSIDERED FOR THE PURPOSES OF APPLI CATION OF RULE 8D. KEEPING IN VIEW, OF ABOVE AND BY FOLLOWING THE JUDGEMENT OF HO N'BLE JURISDICTIONAL ITAT, THE AO IS DIRECTED TO RECALCULATE THE DISALLOWANCE OF T HOSE SHARES, WHICH HAS YIELDED DIVIDEND INCOME WHILE TAKING THE INVESTMENT. IN VIEW OF ABOVE, THE APPELLANT SHALL FURNISH BEFOR E THE AO THE DETAILS IN THE MATTER. THE AO IS ALSO DIRECTED TO VERIFY THE SAME AND ACCORDINGLY RE-COMPUTE THE DISALLOWANCE U/S 14A R.W. RULE 8D. THE AO SHALL ALL OW THE APPELLANT AN OPPORTUNITY OF HEARING BEFORE PASSING ANY ORDER IN THIS REGARD. THIS GROUND IS THEREFORE ALLOWED FOR STATISTICAL PURPOSES. 4. AGGRIEVED BY THE ORDER OF THE LD. CIT(A), THE AS SESSEE IS IN APPEAL BEFORE US. 5. THE LD. COUNSEL FOR THE ASSESSEE RELIED ON THE S UBMISSIONS MADE BEFORE THE AUTHORITIES BELOW ON THE OTHER HAND, THE LD. DR HAS PRIMARILY REITERATED THE STAND TAKEN BY THE ASSESSING OFFICER WHICH WE HAVE ALREAD Y NOTED IN OUR EARLIER PARA AND THE SAME IS NOT BEING REPEATED FOR THE SAKE OF BREVITY. 6. WE HEARD BOTH THE PARTIES AND CAREFULLY GONE THR OUGH THE SUBMISSION PUT FORTH ON BEHALF OF THE ASSESSEE ALONG WITH THE DOCUMENTS FURNISHED AND THE CASE LAWS RELIED UPON, AND PERUSED THE FACT OF THE CASE INCLU DING THE FINDINGS OF THE LD CIT(A) AND OTHER MATERIALS AVAILABLE ON RECORD. WE NOTE THAT THE ASSESSEE IS IN APPEAL BEFORE US AGAINST THE DISALLOWANCE UNDER RUL E 8D(2)(II) READ WITH SECTION HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. ITA NO.515/KOL/2019 ASSESSMENT YEAR:2013-14 P PP PA AA AG GG GE EE E | || | 5 55 5 14A OF THE ACT. THE LD. COUNSEL FOR THE ASSESSEE SU BMITTED BEFORE US THE BALANCE SHEET OF THE ASSESSEE COMPANY AS ON 31.03.2013. ON PERUSAL OF BALANCE SHEET, WE NOTICED THAT OWN FUNDS OF THE ASSESSEE COMPANY IS R S. 1,15,771/- LAKHS, WHICH IS MORE THAN THE INVESTMENTS IN SHARES AND SECURITIES TO THE TUNE OF RS. 18,089/- LAKHS. SINCE COMPANYS NET OWNED FUNDS IN THE FORM OF EQUITY CAPITAL AND FREE RESERVES WERE SUBSTANTIALLY MORE THAN THE COST OF S HARE INVESTMENT, YIELDING DIVIDEND INCOME, NO PART OF THE INTEREST PAID IS DI SALLOWABLE BECAUSE BORROWED FUNDS WERE NOT USED FOR ACQUIRING SHARES. FOR THAT WE RELY ON THE JUDGMENT OF THE HONBLE CALCUTTA HIGH COURT DECISION IN THE CASE OF CIT VS HDFC BANK LTD. [49 TAXMANN.COM 335). THEREFORE, THE DISALLOWANCE UNDER RULE 8D(2)(II) RE AD WITH SECTION 14A IS NOT ATTRACTED IN ASSESSEES CASE HENCE WE DIRECT THE AS SESSING OFFICER TO DELETE THE DISALLOWANCE UNDER RULE 8D(2)(II) OF THE IT RULES. 7. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALL OWED. ORDER PRONOUNCED IN THE COURT ON 31.12. 2019 SD/- ( S.S.GODARA ) SD/- (A.L.SAINI) / JUDICIAL MEMBER / ACCOUNTANT MEMBER /KOLKATA; / DATE: 31/12/2019 ( SB, SR.PS ) COPY OF THE ORDER FORWARDED TO: 1. HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. 2. DCIT, CIRCLE-5(2), KOLKATA 3. C.I.T(A)- 4. C.I.T.- KOLKATA. 5. CIT(DR), KOLKATA BENCHES, KOLKATA. 6. GUARD FILE. TRUE COPY BY ORDER ASSIST ANT REGISTRAR ITAT, KOLKA TA BENCHES HINDUSTHAN NATIONAL GLASS & INDUSTRIES LTD. ITA NO.515/KOL/2019 ASSESSMENT YEAR:2013-14 P PP PA AA AG GG GE EE E | || | 6 66 6