Nabakishore Dash, Jagatsinghpur V. ITO, Paradeep

ITA 56/CTK/2014

• Counselvise Citation: [2017] 130 COUNSELVISE.COM (IT) 7186 (ITAT-CUTTACK)
• Duration Of Justice: 3 year(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 15-03-2017
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Next Hearing Date: 15-03-2017
• Assessment Year: 2008-2009
• Appeal Filed On: 18-02-2014
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: D K PRADHAN
• Assessee Lawyers: SIDHANT DWIVEDI
• Keywords: Principle of natural justice
• Section: 68

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK SMC BENCH, CUTTACK BEFORE SHRI N.S SAINI, ACCOUNTANT MEMBER ITA NO. 56/CTK/2014 ASSESSMENT YEAR : 2008 - 09 NABA KISHORE DASH, ISWARPUR, PO: BALIKUDA, DIST: JAGATSINGHPUR VS. ITO, WARD - 1, PARADEEP. PAN/GIR NO. AGPPD 2607 K (APPELLANT ) .. ( RESPONDENT ) ASSESSEE BY : SHRI SIDHANT DWIVEDI REVENUE BY : SHRI D.K.PRADHAN , DR DATE OF HEARING : 15 /03 / 2017 DATE OF PRONOUNCEMENT : 15 /03 / 2017 O R D E R THIS IS AN APPEAL FILED BY THE ASSESSEE AGAINST THE ORDER OF CIT(A) - CUTTACK , DATED 28.11.2013 , FOR THE ASSESSMENT YEAR 2008 - 09 . 2. GROUND NOS. 1 & 7 OF THE APPEAL ARE GENERAL IN NATURE AND HENCE, REQUIRES NO SEPARATE ADJUDICATION BY ME. 3. IN GROUND NO.2 OF THE APPEAL, THE GRIEVANCE OF THE ASSESSEE IS THAT THE CIT(A) ERRED IN CONFIRMING THE ORDER OF THE ASSESSING OFFICER MAKING ADHOC DISALLOWANCE OF RS.20, 000/ - ON ESTIMATE BASIS TOWARDS FUEL EXPENDITURE. 2 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 4. I HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF LOWER AUTHORITIES AND MATERIALS AVAILABLE ON RECORD. IN THE INSTANT CASE, THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAS CLAIMED EXPENSES OF RS.80,134/ - TOWARDS PURCHASE OF FUEL. THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE ONLY PRODUCED A LIST SHOWING THE FU EL PURCHASES ON DIFFERENT DATE S, WHICH DID NOT INDICATE THE DETAILS OF QUANTITY OF FUEL PURCHASED AND THE CONCERNS FROM WHERE PURCHASES WERE MADE ON DIFFERENT DATES. HE NOTED THAT THE ASSESSEE IS A WHOLESALE DISTRI BUTOR OF PHARMACEUTICALS AND THE GROSS TURNOVER WAS RS.1,21,74,018/ - . THE ASSESSEE POSSESSES MOTOR - CYCLE/CAR, ET C , WHICH MAY NOT HAVE BEEN USED BY THE ASSESSEE FOR THE BUSINESS OF THE ASSESSEE. SINCE, THE ASSESSEE COULD NOT PRODUCE THE BILLS AND VOUCHERS OF FUEL, THE ASSESSING OFFICER, THEREFORE, DISALLOWED FUEL EXPENSES O F RS.20,000/ - OUT OF THE TOTAL CLAIM OF RS.80,134/ - . 5. ON APPEAL, THE CIT(A) CONFIRMED THE ACTION OF THE ASSESSING OFFICER. 6. BEFORE ME, THE CONTENTION OF THE LD AUTHORISED REPRESENTATIVE OF THE ASSESSEE IS THAT THE ASSESSING OFFICER WAS NOT JUSTIFIED I N MAKING ADHOC DISALLOWANCE OF RS.20,000/ - OUT OF FUEL EXPENSES OF RS.80,134/ - CLAIMED BY THE ASSESSEE. 7. ON THE OTHER HAND, LD DEPARTMENTAL REPRESENTATIVE VEHEMENTLY OPPOSED THE SUBMISSION OF THE LD AUTHORISED REPRESENTATIVE OF THE ASSESSEE AND ARGUED TH AT THE ASSESSEE FAILED TO PRODUCE BILLS AND VOUCHERS FOR 3 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 PURCHASE OF FUEL AND, THEREFORE, THE DISALLOWANCE MADE BY THE ASSESSING OFFICER WAS FULLY JUSTIFIED. 8. IN THE ABOVE FACTS AND CIRCUMSTANCES OF THE CASE, IN MY CONSIDERED OPINION, THE ASSESSEE WAS RE QUIRED BY THE ASSESSING OFFICER TO PRODUCE BILLS AND VOUCHERS FOR PURCHASE OF FUEL. THE ASSESSEE FAILED TO PRODUCE THE SAME. WHEN ASKED BY THE BENCH WHETHER THE BILLS COULD BE PRODUCED BY THE ASSES SEE BEFORE THE TRIBUNAL, THE AUTHORISED REPRESENTATIVE OF THE ASSESSEE EXPRESSED HIS INABILITY TO DO SO. IN THE ABSENCE OF BILLS FOR PURCHASE OF FUEL, IN MY CONSIDERED OPINION, THE DISALLOWANCE MADE BY THE ASSESSING OFFICER WAS JUSTIFIED. THEREFORE, I FIND NO INFIRMITY IN THE ORDER OF THE CIT(A) , WHICH IS HEREBY CONFIRMED AND THE GROUND OF APPEAL OF THE ASSESSEE IS DISMISSED. 9. IN GROUND NO.3 OF THE APPEAL, THE GRIEVANCE OF THE ASSESSEE IS THAT THE CIT(A) ERRED IN CONFIRMING THE DISALLOWANCE OF RS.40,710/ - TOWARDS PAYMENT OF FREIGHT CHARGES. 10. I HAVE HEA RD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF LOWER AUTHORITIES AND MATERIALS AVAILABLE ON RECORD. IN THE INSTANT CASE, THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAS CLAIMED RS.3,19,110/ - TOWARDS PAYMENT OF FREIGHT CHARGES. HE OBSERVED THAT T HE ASSESSEE COULD NOT PRODUCE ANY EVIDENCE IN SUPPORT OF FREIGHT CHARGES OF RS.40,710/ - . IN ABSENCE OF EVIDENCE, HE DISALLOWED RS.40,710/ - . 11. ON APPEAL, THE CIT(A) CONFIRMED THE ACTION OF THE ASSESSING OFFICER. 4 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 12. BEFORE US, LD AUTHORISED REPRESENTATIV E OF THE ASSESSEE SUBMITTED THAT ADHOC DISALLOWANCE WAS NOT JUSTIFIED BY THE ASSESSING OFFICER AND THE CIT(A) ERRED IN CONFIRMING THE ACTION OF THE ASSESSING OFFICER. 13. ON THE OTHER HAND, LD DEPARTMENTAL REPRESENTATIVE VEHEMENTLY OPPOSED THE SUBMISSION O F LD A.R. OF THE ASSESSEE AND SUBMITTED THAT THE DISALLOWANCE WAS MADE IN ABSENCE OF ANY EVIDENCE FOR MAKING PAYMENTS. 14. IN THE ABOVE FACTS AND CIRCUMSTANCES OF THE CASE, I FIND THAT THE DISALLOWANCE OF RS.40,710/ - OUT OF FREIGHT CHARGES WAS MADE IN ABSE NCE OF ANY EVIDENCE FOR PAYMENT. ON A QUERY BY THE BENCH, WHETHER EVIDENCE FOR THE PAYMENTS COULD BE PRODUCED BEFORE THE TRIBUNAL, LD A.R. EXPRESSED HIS INABILITY TO DO SO. IN VIEW OF ABOVE, I FIND THAT THE DISALLOWANCE MADE BY THE ASSESSING OFFICER IS FULLY JUSTIFIED AND THERE IS NO ERROR IN THE ORDER OF THE CIT(A) IN CONFIRMING THE SAME. HENCE, I CONFIRM THE ORDER OF THE CIT(A) AND DISMISS THE GROUND OF APPEAL OF THE ASSESSEE. 15. GROUND NO.4 OF THE APPEAL READS AS UNDER: FOR THAT THE ALLEGED ADDITION ON ACCOUNT OF SUNDRY CREDITORS AMOUNTING TO RS.2,30,331/ - BY THE AO WITHOUT GIVING THE ASSESSEE A CHANCE OF CROSS - EXAMINATION TO THE PERSON CONCERN AND FAILURE OF THE CIT(A) TO SEEK A REMAND REPORT TO THIS EFFECT EVEN THOUGH REMAND REPORT WAS SOUG HT ON ACCOUNT OF OTHER HEAD OF ADDITION IS ILLEGAL AND ARBITRARY AND COMPLETE DENIAL OF NATURAL JUSTICE. 16. AT THE TIME OF HEARING, LD AUTHORISED REPRESENTATIVE OF THE ASSESSEE DID NOT PRESS THIS GROUND OF APPEAL AND, THEREFORE, SAME IS DISMISSED AS NOT PRESSED. 5 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 17. IN GROUND NO.5 OF THE APPEAL, THE GRIEVANCE OF THE ASSESSEE IS THAT THE CIT(A) ERRED IN CONFIRMING THE ADDITION OF RS.5,18,500/ - U/S.68 OF THE ACT. 18. I HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF LOWER AUTHORITIES AND MATERIAL S AVAILABLE ON RECORD. THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAS RECEIVED UNSECURED LOAN OF RS.8,19,500/ - FROM HIS FATHER SHRI NATABAR DASH IN CASH. ON OATH, SHRI NATABAR DASH, FATHER OF THE ASSESSEE ADMITTED THE FACT OF ADVANCING RS.8,19,500/ - IN CASH BY DRAWING FROM HIS BANK ACCOUNT. ON VERIFICATION OF BANK ACCOUNT, THE ASSESSING OFFICER FOUND THAT THERE WAS WITHDRAWAL OF RS.4,20,500/ - ON 17.12.2007, 30,000/ - ON 31.7.2007, RS.76,000/ - ON 14.11.2007 AND RS.62,000/ - ON 1.12.2007 A ND THAT REST OF THE WITH DRAWALS MADE DURING THE PERIOD UNDER CONSIDE RATION WERE VERY NOMINAL AND CONSIDERED THE SAME TOWARDS PERSONAL EXPENSES OF SHRI NATABAR DASH. THUS, THE ASSESSING OFFICER FOUND THAT THE FATHER OF THE ASSESSEE COULD EXPLAIN THE SOURCE OF LOAN OF RS.5,88,500/ - BY WITHDRAWING FROM HIS BANK ACCOUNT. HE, THEREFORE, CONFIRMED THE BA LANCE AMOUNT OF ADDITION OF RS.2,31,000/ - UNDER SECTION 68 OF THE ACT AS NOT EXPLAINED 19. SIMILARLY, THE ASSESSING OFFICER FOUND THAT THE ASSESSEE RECEIVED LOAN OF RS.2,59,500/ - FROM SMT. ASHALATA ACHARYA, MOTHER OF THE ASSESSEE, WHO IS A RETIRED TEACHER. SHE ADMITTED ON OATH OF HAVING ADVANCING RS.2,59,500/ - IN CASH FROM HER BANK ACCOUNT. ON A PERUSAL OF BANK 6 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 STATEMENT, THE ASSESSING OFFICER FOUND THAT SHE HAD WITHDRAWN RS.50,000/ - ON 22.6.2007, RS.27,000/ - ON 18.7.2007, RS.1,00,000/ - ON 16.11.2007 AND RS.30,000/ - ON 31.3.2008 AGGREGATING TO RS.2,07,000/ - . HE OBSERVED THAT DURING THE WHOLE YEAR, THE TOTAL WITHDRAWAL FROM BANK ACCOUNT BY SMT. ACHARYA WAS RS.2,24,000/ - AGAINST WHICH SHE CLAIMED OF ADVANCING RS.2,59,500/ - . THEREFORE, HE CONSIDERED THE LOA N OF RS.2,07,000/ - AS EXPLAINED AN MADE ADDITION OF RS.52,500/ - U/S.68 OF THE ACT. 20. SIMILARLY, HE OBSERVED THAT THE ASSESSEE HAS RECEIVED LOAN OF RS.66,000/ - FROM BAPUJI MAITI IN CASH, WHO IS A RETAIL TRADER . THE LOAN CREDITOR ADMITTED ON OATH OF ADVAN CING THE MONEY WITHDRAWING FROM HIS CASH CREDIT ACCOUNT. ON EXAMINATION OF THE BANK ACCOUNT, THE ASSESSING OFFICER FOUND THAT SHRI MAITI HAD NOT DRAWN ANY AMOUNT IN CASH OF RS.66,000/ - FROM HIS BANK. THE AMOUNTS WERE WITHDRAWN BY CHEQUES FOR SPECIFIC PUR POSES AND HENCE, HE TREATED THE LOAN OF RS.66,000/ - AS NOT GENUINE AND ADDED THE SAME TO THE INCOME OF THE ASSESSEE. 21. SIMILARLY, THE ASSESSING OFFICER FOUND THAT THE ASSESSEE HAS CLAIMED TO HAVE RECEIVED RS.1,29,000/ - FROM SHRI RAMA CHANDRA DAS, A RETIRED TEACHER WHO WAS UNCLE OF THE ASSESSEE. SHRI RAM CHANDRA DAS ADMITTED THAT HE HAD ADVANCED RS.1,29,000/ - FROM HIS BANK ACCOUNT . ON VERIFICATION OF THE SAID BANK ACCOUNT, THE ASSESSING OFFICER FOUND THAT TOTAL WITHDRAWAL DURING THE WHOLE PERIOD WAS RS.85,100/ - WHICH WAS MUCH LESS THAN THE AMOUNTS SAID TO HAVE BEEN ADVANCED TO THE ASSESSEE. MOREOVER, HE FOUND 7 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 THAT DRAWAL S OF RS.85,000/ - CONSTITUTES NOMINAL AMOUNTS DRAWN ON DIFFERENT DATES OF THE WHOLE PERIOD AND CONSIDERED THE SAME TO BE FOR PERSONAL EXPENSES OF SHRI RAM CHANDRA DAS. HENCE, THE ASSESSING OFFICER CONSIDERED THE SAME TO BE NOT GENUINE AND MADE THE ADDITION U/S.68 OF THE ACT. 22. SIMILARLY, THE ASSESSEE CLAIMED TO HAVE RECEIVED RS.40,000/ - IN CASH FROM SHRI ASISH KUMAR MOHAPATRA, WHO IS WORKING AS A MEDICINE REPRESENTATIVE. SHRI MOHAPATRA FILED AN AFFIDAVIT ALONGWITH HIS BANK ACCOUNT. ON VERIFICATION OF T HE BANK ACCOUNT, IT WAS FOUND THAT THE TOTAL WITHDRAWAL DURING THE WHOLE PERIOD WAS ONLY RS.38,965/ - . THE ASSESSING OFFICER, THEREFORE, HELD THAT THE MEDICINE REPRESENTATIVE IS REQUIRED BY PROFESSION TO MOVE FROM ONE PLACE TO ANOTHER TO DEVELOP THE SALE O F THE MEDICINES OF THE COMPANY FOR WHICH IS WORKING. SO, HE HELD THAT THE WITHDRAWAL OF RS.38,965/ - AFTER MEETING HIS PERSONAL EXPENSES, WAS NOT SUFFICIENT TO ADVANCE RS.40,000/ - TO THE ASSESSEE. HENCE, HE CONSIDERED THE SAME AS NOT GENUINE AND ADDED U/S .68 OF THE ACT. 23. IN THIS WAY, THE ASSESSING OFFICER MADE ADDITION RS.5,18,500/ - U/S.68 OF THE ACT TO THE TOTAL INCOME OF THE ASSESSEE. 24. ON APPEAL, THE CIT( A ) CONFIRMED THE ACTION OF THE ASSESSING OFFICER ON THE GROUND THAT THE ASSESSING OFFICER HAD MADE SUFFICIENT EFFORTS TO GO INTO THE DETAILS OF THE CASE TO FIND OUT THE GENUINENESS, CREDITWORTHINESS AND IDENTITY OF EACH OF THE LOAN CREDITORS CAREFULLY. TH EREFORE, THE CIT(A) 8 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 UPHELD THE ACTION OF THE ASSESSING OFFICER IN ADDING RS.5,18,500/ - U/S.68 OF THE ACT FOR THE ABOVE FIVE LOAN CRE DITORS . 25. BEFORE ME, LD AUTHORISED REPRESENTATIVE OF THE ASSESSEE REITERATED THE SUBMISSIONS MADE BEFORE THE LOWER AUTHOR ITIES. 26. ON THE OTHER HAND, LD DEPARTMENTAL REPRESENTATIVE RELIED ON THE ORDERS OF LOWER AUTHORITIES. 27. I FIND THAT THE ADDITION OF RS.5,18,500/ - OUT OF LOANS RECEIVED FROM FIVE PERSONS WAS MADE BY THE ASSESSING OFFICER ON THE GROUND THAT THE CREDITWOR THINESS OF THE LOAN CREDITORS COULD NOT BE PROVED BY THE ASSESSEE. BEFORE ME, LD A.R. COULD NOT BRING ANY MATERIAL ON RECORD TO CONTROVERT THE FINDINGS OF THE ASSESSING OFFICER AS WELL AS THE CIT(A) THAT THE LOAN CREDITORS DID NOT HAVE CREDITWORTHINESS TO ADVANCE THE AMOUNT TO TH E ASSESSEE . IN ABSENCE OF THE SAME, I FIND NO GOOD REASON TO INTERFERE WITH THE ORDER OF THE CIT(A), WHICH IS HEREBY CONFIRMED AND THE GROUND OF APPEAL OF THE ASSESSEE IS DISMISSED. 28. IN GROUND NO.6 OF THE APPEAL, THE GRIEVANCE OF THE ASSESSEE IS THAT THE CIT(A) ERRED IN CONFIRMING THE ADDITION OF RS.2,50,000 / - MADE BY THE ASSESSING OFFICER UNDER THE HEAD LOANS FROM 25 PERSONS. 29. I HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE ORDERS OF LOWER AUTHORITIES AND MATERIALS AVAILABLE ON RECORD. THE ASSESSING OFFICER OBSERVED THAT THE ASSESSEE HAS CLAIMED TO HAVE RECEIVED LOAN OF 9 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 RS.10,000/ - EACH FROM 27 PERSONS AMOUNTING TO RS.2,70,000/ - . THE ASSESSEE WAS REQUIRED TO FILE CONFIRMATIONS IN SUPPORT OF ADVANCEMENT OF LOAN. THE ASSESSEE DID NOT FILE ANY CONFIRMATION LETTERS FROM LOAN CREDITORS. THEREFORE, THE ASSESSING OFFICER MADE ADDITION OF RS.2,70,000/ - U/S.68 OF THE ACT CONSIDERING THE LOAN TO BE NON - GENUINE. 30. ON APPEAL, THE CIT(A) OBSERVED THAT THE ASSESSEE C LAIMED TO HAVE RECEIVED LOAN FROM 27 PERSONS OF RS.10,000/ - EACH. THE ASSESSEE COULD PRODUCE FOUR PERSONS FOR VERIFICATION BY THE ASSESSING OFFICER REGARDING PAYMENT OF RS.10,000/ - EACH IN CASH. ONE PERSON CONFIRMED HAVING ADVANCING RS.10,000/ - IN FINAN CIAL YEAR 2007 - 08, WHICH WAS ADJUSTED IN IN THE FINANCIAL YEAR 2007 - 08 AGAINST PURCHASE. TWO PERSONS STATED TH A T THEY HAD ADVANCED RS.10,000/ - EACH DURING THE FINANCIAL YEAR 2007 - 08 AND SAME AMOUNT WERE ADJUSTED AGAINST PURCHASE IN THE FINANCIAL YEAR 2008 - 09. ONE PERSON STATED THAT HE HAD ADVANCED RS.10,000/ - DURING THE YEAR 2011 - 12 AND SAME WAS ADJUSTED AGAINST PURCHASE OF MEDICINES IN THE YEAR 2011 - 12.. THEREFORE, THE CIT(A) CONCLUDED THAT THE VERACITY OF THE CLAM OF RECEIPT OF RS.2,70,000/ - AS ADVANCE IN THE YEAR 2007 - 08 HAS BOILED DOWN TO TWO PERSONS ADVANCING RS.10,000/ - ONLY. THEREFORE, HE CONFIRMED THE ADDITION OF RS.2,50,000/ - OUT OF TOTAL ADDITION OF RS.2,70,000/ - MADE BY THE ASSESSING OFFICER. 31. LD AUTHORISED REPRESENTATIVE OF THE ASSESSEE REI TERATED THE SUBMISSIONS MADE BEFORE THE LOWER AUTHORITIES. 10 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 32. LD DEPARTMENTAL REPRESENTATIVE SUPPORTED THE ORDER OF THE CIT(A). 33. I FIND THAT THE ASSESSEE CLAIMED TO HAVE RECEIVED LOAN OF RS.10,000/ - EACH FROM 27 PERSONS. THE ASSESSEE FAILED TO PRODUCE ANY CONFIRMATION LETTERS FROM THE LOAN CREDITORS. THEREFORE, THE ASSESSING OFFICER ADDED RS.2,70,000/ - U/S.68 OF THE ACT FOR CONSIDERING THE LOAN BEING NOT GENUINE. 34. BEFORE THE CIT(A), ASSESSEE COULD PRODUCE FOUR PERSONS AND ON EXAMINATION OF THE FOUR PERSONS, HE FOUND THAT TWO PERSONS HAD ADVANCED LOAN OF RS.10,000/ - EACH DURING THE FINANCIAL YEAR 2007 - 08. THEREFORE, HE ALLOWED CREDIT OF RS.20,000/ - AND CONFIRMED THE BALANCE ADDITION OF RS.2,50,000/ - . 35. BEFORE ME ALSO, NO MATERIAL HAS BEEN PRODUCE D BY THE ASSESSEE TO CONTROVERT THE FINDINGS OF THE CIT(A). IN ABSENCE OF THE SAME, I FIND NO GOOD AND JUSTIFIABLE REASON TO INTERFERE WITH THE ORDER OF THE CIT(A), WHICH IS HEREBY CONFIRMED AND GROUND OF APPEAL OF THE ASSESSEE IS DISMISSED. 36. IN THE RE SULT, THE APPEAL FILED BY THE ASSESSEE IS DISMISSED . ORDER PRO NOUNCED IN THE OPEN COURT ON 15 /03 /2017 IN THE PRESENCE OF PARTIES. SD/ - ( N.S SAINI) A CCOUNTANT MEMBER CUTTACK; DATED 15 /03 /2017 B.K.PARIDA, SPS 11 ITA NO. 56/CTK/2014 ASSESSMENT YEAR :2008 - 09 COPY OF THE ORDER FORWARDED TO : BY ORDER, SR.PRIVATE SECRETARY ITAT, CUTTACK 1. THE APPELLANT : NABA KISHORE DASH,ISWARPUR, PO: BALIKUDA, DIST: JAGATSINGHPUR 2. THE RESPONDENT. ITO, WARD - 1, PARADEEP 3. THE CIT(A) CUTTACK 4. PR.CIT , CUTTACK 5. DR, ITAT, CUTTACK 6. GUARD FILE. //TRUE COPY//