ITO,Ward-1, Malda, Malda V. M/s. Afsana Enterprise, Malda

ITA 781/KOL/2012

• Counselvise Citation: [2016] 133 COUNSELVISE.COM (IT) 5071 (ITAT-KOLKATA)
• Duration Of Justice: 3 year(s) 9 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 29-02-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2008-2009
• Appeal Filed On: 16-05-2012
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SATYANDRA MOHAN DAS J
• Assessee Lawyers: MANISH TIWRI
• Keywords: Tax effect
• Section: 144

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH C KOLKATA BEFORE SHRI MAHAVIR SINGH, JUDICIAL MEMBER AND SHRI WASEEM AHMED, ACCOUNTANT MEMBER ITA NO. 1304 & 781 / KOL / 2012 ASSESSMENT YEAR :2008-09 AFSANA ENTERPRISES M/S AFSANA ENTERPRISE, N.S. ROAD, MALDA 732101 [ PAN NO.AAEFA 5376 K ] ITO, WARD-1, N.S. ROAD, MALDA V/S . V/S . ITO WARD-1, MALDA, N.S. ROAD, MALDA- 732101 M/S AFSANA ENTERPRISE, N.S. ROAD, MALDA /APPELLANT .. / RESPONDENT /BY ASSESSEE SHRI MANISH TIWRI, FCA /BY REVENUE SHRI SATYANDRA MOHAN DAS, JCIT-DR /DATE OF HEARING 21-01-2016 ! /DATE OF PRONOUNCEMENT 29-02-2016 / O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER:- THESE TWO APPEALS FILED BY ASSESSEE AND REVENUE AR E ARISING OUT COMMON ORDER OF COMMISSIONER OF INCOME TAX (APPEALS ), JALPAIGURI IN APPEAL NO.18/MLD/CIT(A)/JAL/10-11 DATED 21.03.2012. ASSESS MENT WAS FRAMED BY ITO WARD-I, MALDA U/S 143(3)/145(3) OF THE INCOME T AX ACT, 1961 (HEREINAFTER REFERRED TO AS THE ACT) VIDE HIS ORDER DATED 06.1 2.2010 FOR ASSESSMENT YEAR 2008-09. SHRI MANISH TIWARI, LD. AUTHORIZED REPRESENTATIVE A PPEARING ON BEHALF OF ASSESSEE AND SHRI SATYANDRA MOHAN DAS, LD. DEPARTME NTAL REPRESENTATIVE APPEARING ON BEHALF OF DEPARTMENT. ITA NO.1304 & 781/KOL/2012 A.Y 2008-09 M/S AFSANA ENTERPRISE V. ITO WD-1, MLD. PAGE 2 FIRST WE TAKE UP ASSESSEES APPEAL ITA NO.1304/KOL/ 2012. 2. FIRST OF ALL, AT THE OUTSET, LD. AR FOR ASSESSEE FILED A CONDONATION PETITION TOGETHER WITH AN AFFIDAVIT FOR DELAYING TH E PRESENT APPEAL AS MANY AS 91 DAYS STATING AS UNDER:- 1) THAT THE ORDER OF CIT(A) WAS RECEIVED BY THE PA RTNERSHIP FIRM ON 13.04.2012 AND AS SUCH APPEAL BEFORE HON'BLE ITAT K OLKATA WAS DUE TO BE FILED WITHIN 60 DAYS WHICH EXPIRES ON 12.06.2012 . 2) THAT MD. AFJAL HOSSAIN (PARTNER) AFTER RECEIPT O F CIT(A)S ORDER DISCUSSED THE ISSUES WITH TAX EXPERT STATIONED AT K OLKATA IN THE MONTH OF MAY 2012 FOR LEGAL REMEDY AND ENTRUSTED HIM WITH RESPONSIBILITIES OF PREPARING BRIEF ETC., FOR FILING APPEAL TO ITAT. 3) THAT THE SAID PARTNER MR. AFJAL HOSSAIN AGED ABO UT 53 YEARS FELT CHEST PAIN AND WAS TAKEN TO DR. G.N. CHOWDHURY, MBBS AT H IS CHAMBER AT JHALJHALIA STATION ROAD, MALDA ON 09.06.2012 WHO EX AMINED HIM, PRESCRIBED MEDICINES AND ADVISED BED REST FOR ONE M ONTH. 4) THAT DUE TO THE SAID COMPELLING REASON THE SAID PARTNER COULD NOT ATTEND TAX EXPERTS CHAMBER AT KOLKATA FOR FINALIZA TION, SIGNATURE ETC. ON MEMO OF APPEAL GROUNDS ETC., AS SUCH APPEAL TO ITAT COULD NOT BE FILED WITHIN 12.06.2012. 5) THAT THE SAID PARTNERS BEING PHYSICALLY FIT ULTI MATELY MET THE TAX EXPERT OFFICE AT KOLKATA ON 7 TH SEPTEMBER 2012 AND FINALIZED THE MATTER. ACCORDINGLY THE APPEAL TO ITAT WAS FILED ON 11.09.2 012 RESULTING IN DELAY OF 91 DAYS. CONSIDERING THE CIRCUMSTANCES OF ASSESSEE AND TOTAL ITY OF THE CASE REGARDING ITS INABILITY FOR FILING THE APPEAL IN DUE TIME, LD . DR FAIRLY CONCEDED THAT IN VIEW OF THE REASONS GIVEN IN AFFIDAVIT SUPPORTED WITH ME DICAL CERTIFICATE, DELAY CAN BE CONDONED. IN VIEW OF CONCESSION GIVEN BY LD. DR, WE CONDONE THE DELAY AND ADMIT THE APPEAL OF ASSESSEE FOR HEARING. GROUNDS RAISED BY ASSESSEE ARE REPRODUCED BELOW:- 1) THAT ON THE FACTS AS WELL AS ON LAW THE LD. CIT( APPEAL) HAS ERRED IN CONFIRMING THE ADDITION MADE BY A.O FOR RS.7,16,500 .00 THE AMOUNT WHICH WAS DEPOSITED THROUGH VOYAZAR ENTERPRISE, THROUGH C OMPENSATING ENTRIES. ITA NO.1304 & 781/KOL/2012 A.Y 2008-09 M/S AFSANA ENTERPRISE V. ITO WD-1, MLD. PAGE 3 2) THAT ON FACTS, AS WELL AS ON LAW, THE LD. CIT(AP PEAL) HAS ERRED IN CONFIRMING THE ADDITION MADE BY AO FOR RS.1,51,490. 00 THOUGH EXPLAINED BY THE ASSESSEE. 3) THAT THE AMOUNT OF RS.1,80,000.00 DEPOSITED BY T HE ASSESSEE WHICH WAS RECEIVED FROM MR AFJAL HOSSAIN & MR ANWAR HOSSAIN, (THE PARTNERS OF THE FIRM) OF RS.1,00,000.00 AND RS.80,000.00 RESPECTIVELY. TH EREFORE THE ASSESSEE BEGS AN APPEAL FOR DEDUCTION OF RS.1,80,000.00 AS H AS BEEN ADDED BY THE LD. AO TO THE TOTAL INCOME. 4) THAT ON FACTS AND CIRCUMSTANCES OF THE CASE, IT WAS SEEN THAT THE ASSESSEE HAS RECEIVED COMMISSION FROM BSNL RS.34,43,325.00. BUT THE ASSESSEE HAS CREDITED COMMISSION AMOUNTING TO RS.36,68,783.00 IN HIS BOOKS OF A/C THUS THE ASSESSEE HAS SHOWN EXCESS COMMISSION OF (RS.36, 68,783.00 RS.34,43,325.00) RS2,25,458.00 IN HIS BOOKS OF A/C. 5) THE AMOUNT OF RS.2,94,769.00 IS CONTRA IN NATURE AND STILL THE LD. CIT(APPEAL) HAS ERRED IN CONFIRMING THE ADDITION MA DE BY A.O. 6) THAT ON FACTS AS WELL AS ON LAW THE LD. CIT(APPE AL) HAS ERRED IN CONFIRMING THE DISALLOWANCE MADE BY THE AO OF RS.87,000.FOR S HOP RENT PAID. 3. ISSUE RAISED BY ASSESSEE IN THE GROUNDS NO. 1 TO 5 IS COMMON, SO ALL THE GROUNDS ARE CLUBBED TOGETHER FOR THE SAKE OF CO NVENIENCE AND TO PASS A CONSOLIDATED ORDER. ISSUES RAISED BY ASSESSEE ARE T HAT LD. CIT(A) ERRED IN CONFIRMING THE ACTION OF ASSESSING OFFICER BY SUSTA INING THE ADDITION OF RS.16,30,440/- AS UNEXPLAINED MONEY. 3.1 THE FACTS OF THE CASE IN THE PRESENT APPEAL ARE THAT ASSESSEE IS A PARTNERSHIP FIRM ENGAGED IN BUSINESS OF TRADING OF SIM CARDS, CASH CARDS, MOBILE PHONES AND ALSO PROVIDING TECHNICAL SERVICES . DURING THE COURSE OF ASSESSMENT PROCEEDINGS, AO WAS NOT SATISFIED ABOUT THE CORRECTNESS AND COMPLETENESS OF THE BOOKS OF ACCOUNT DUE TO THE FOL LOWING REASONS:- (A) ASSESSEE-FIRM HAS INFLATED PURCHASE AMOUNT OF R S.7,02,880/- FROM M.S. JASHODA COMMUNICATION, (B) ASSESSEE-FIRM HAS INFLATED PURCHASE OF RS.5,50, 451/- FROM BSNL, (C) ASSESSEE DEPOSITED CHEQUES IN ITS TWO BANK ACCO UNTS WITH SBI & ICICI BANK, BURDWAN BUT SHOWED IN ITS BOOKS OF ACCOUNT AS CASH DEPOSIT. ITA NO.1304 & 781/KOL/2012 A.Y 2008-09 M/S AFSANA ENTERPRISE V. ITO WD-1, MLD. PAGE 4 ON THE FINDING OF ABOVE FACTS THE AO REJECTED THE B OOKS OF ACCOUNTS OF ASSESSEE U/S 145(3) OF THE ACT AND PROCEEDED TO FRA ME THE ASSESSMENT U/S. 144 OF THE ACT. DURING THE COURSE OF ASSESSMENT PRO CEEDINGS, AO FOUND THAT ASSESSEE HAS DEPOSITED CHEQUES IN ITS BANK ACCOUNT FOR A VALUE OF RS.21,87,440/- BUT THE CHEQUES DEPOSITED WERE SHOWN AS CASH DEPOSIT IN ITS BOOKS OF ACCOUNT. ON QUESTION BY AO ASSESSEE FAILED TO REPLY FOR SHOWING THE DEPOSITS OF CHEQUES AS CASH-IN-HAND. THEREFORE, AO MADE THE ADDITION OF RS.21,87,440/- AS UNEXPLAINED MONEY. 4. AGGRIEVED, ASSESSEE PREFERRED AN APPEAL BEFORE L D. CIT(A). DURING THE APPELLATE STAGE, ASSESSEE DEMONSTRATED THAT THERE W AS NO INVOLVEMENT UNEXPLAINED/ UNDISCLOSED MONEY IN THE BUSINESS OF A SSESSEE. THE CONCERN BANK USED TO LEVY CHARGES FOR DEPOSITING OF CASH IN ASSESSEES BANK ACCOUNT. SO ASSESSEE USED TO DEPOSIT THE CASH IN THE BANK AC COUNTS OF ITS PARTNER AND OTHER ASSOCIATES IN ORDER TO ESCAPE FROM THE BANK C HARGES. THE ASSESSEE USED TO COLLECT CHEQUES FOR THE SAME AMOUNT ON THE SAME DAY FROM THE PARTNER AND/OR CLOSE ASSOCIATE OF THE ASSESSEE IN W HOSE ACCOUNT THE CASH WAS DEPOSITED. IN SUPPORT OF ITS CLAIM ASSESSEE SUB MITTED A STATEMENT CO- RELATING THE ENTRIES REFLECTED IN THE BANK STATEMEN T OF ASSESSEE AND PARTNER OF FIRM ALONG WITH THE ASSOCIATE. HOWEVER, LD.CIT(A) O BSERVED THAT CERTAIN AMOUNTS HAVE NOT BEEN RECONCILED AS DEPICTED IN THE RECONCILIATION STATEMENT FURNISHED BY ASSESSEE. THE NECESSARY DETAILS OF UNR ECONCILED ENTRIES STAND AS UNDER:- 1 DEPOSITED THROUGH AN ACCOUNT OF VOYAZAR ENTERPRISES, WHO IS SEPARATE ASSESSEE AND THE TRANSACTION WAS NOT FOUND IN THE LEDGER OF VOYAZAR RS.7,16,500/- 2 NOT EXPLAIN BY THE ASSESSEE RS.1,51,490/- 3 DEPOSITED BY ASSESSEE THROUGH CASH BUT THE BANK SHOW IT DEPOSITED BY CREDIT RS.1,80,000/- 4 RELATED TO AMC, BUT NOT SHOWN BY THE ASSESSEE RS. 1,11,849/- 5 RELATED TO COMMISSION FRO BSNL, BUT NOT FOUND REFLECTED RS.1,75,832/- ITA NO.1304 & 781/KOL/2012 A.Y 2008-09 M/S AFSANA ENTERPRISE V. ITO WD-1, MLD. PAGE 5 6 RELATED TO CONTRA ENTRY, BUT THE ASSESSEE SHOW IT DEPOSITED BY CASH AND FOR THIS MISTAKE CASH-IN- HAND SUPPRESSED FOR THE AMOUNT OF RS.2,94,769/- RS.2,94,769/- TOTAL RS.16,30,446/- ACCORDINGLY, LD. CIT(A) SUSTAINED THE ADDITION OF R S.16,30,446/- OF THOSE ENTRIES WHICH WERE NOT RECONCILED BY THE ASSESSEE. BEING AGGRIEVED BY THIS ORDER OF LD. CIT(A) ASSESSE E PREFERRED SECOND APPEAL BEFORE US. 5. WE HAVE HEARD THE RIVAL PARTIES AND PERUSED THE MATERIALS AVAILABLE ON RECORD. BEFORE US LD. AR FILED A WRITTEN SUBMISSION WITH SEVERAL ANNEXURE NO. A TO M. THE ASSESSEE ALSO SUBMITTED A TABLE RECONCI LING ALL THE DEPOSITS ENTERED IN THE BANK WITH THOSE REFLECTED IN THE BAN K STATEMENT OF THE PARTNERS AND ITS ASSOCIATES. THE TABLE IS MARKED AS ANNEXUR E E WHICH IS PLACED ON RECORD AND SAME IS ENCLOSED WITH THIS ORDER (AS SEP ARATE ENCLOSURE-SHEET AS PART OF ORDER ). LD. AR FURTHER SUBMITTED THE BANK STATEMENT OF F IVE PARTIES FROM WHOM CHEQUES WERE RECEIVED IN THE EXCHANGE OF CASH IN SUPPORT OF ITS CLAIM WHICH IS ALSO PLACED ON RECORD. THE LD. AR ALSO SUB MITTED THAT THE ASSESSEE HAS SHOWN COMMISSION INCOME FROM BSNL OF RS. 36,68, 783/- THOUGH THE ACTUAL COMMISSION RECEIVED IS OF RS. 34,43,325/-, T HEREFORE THE EXCESS INCOME DECLARED BY THE ASSESSEE IS OF RS. 2,25,458/-. ACCO RDINGLY THE ASSESSEE REQUESTED FOR THE RELIEF OF THE EXCESS INCOME DECLA RED TO THE EXTENT OF RS. 2,25,458/-. FINALLY THE LD. AR REQUESTED THE BENCH TO REVERSE THE ORDERS OF AUTHORITIES BELOW. 5.1. ON THE OTHER HAND, LD DR VEHEMENTLY RELIED ON THE ORDERS OF AUTHORITIES BELOW. 6. FROM THE AFORESAID DISCUSSION, WE FIND THAT THE ASSESSEE HAS MADE WRONG BOOK ENTRIES BY SHOWING CASH RECEIPT IN PLACE OF CHEQUE RECEIPT IN ITS ITA NO.1304 & 781/KOL/2012 A.Y 2008-09 M/S AFSANA ENTERPRISE V. ITO WD-1, MLD. PAGE 6 CASH BOOK. THE ASSESSEE USED TO DEPOSIT CASH IN THE BANK ACCOUNTS OF THE PARTNERS AND ITS ASSOCIATES. IN EXCHANGE OF THE CAS H DEPOSITS, THE ASSESSEE USED TO COLLECT CHEQUES OF THE SAME AMOUNT ON THE S AME DAY DRAWN IN THE NAME OF THE FIRM. THE ASSESSEE WAS FOLLOWING THIS P RACTICE TO AVOID THE BANK CHARGES LEVIED BY THE BANK ON THE DEPOSIT OF THE CA SH. HOWEVER THE AO TREATED THE SAME AS UNEXPLAINED MONEY. HOWEVER, WE FIND FROM THE CO- RELATIVE TABLE THAT THE SALE PROCEEDS RECEIVED IN C ASH WAS INITIALLY DEPOSITED IN THE SAVING BANKS ACCOUNTS OF THE PARTNER AND ITS AS SOCIATES. THEREAFTER THE PARTNERS AND ASSOCIATES USED TO ISSUE CHEQUES IN TH E NAME OF THE FIRM FOR THE SAME AMOUNT. FROM THE ABOVE WE FIND THAT THE ACT O F SHOWING THE CHEQUE DEPOSIT IN PLACE OF CASH DEPOSIT DO NOT ALTER THE A CTUAL INCOME OF ASSESSEE. LD. AR HAS GIVEN THE DETAILS OF THE TRANSACTION IN THE FORM OF COMPARATIVE CHART WHICH IS MARKED AS ANNEXURE E AND PLACED ON R ECORD. THE CHART RECONCILES ALL THE FIGURES OF THE CASH DEPOSIT AND CHEQUE DEPOSIT WITH THE BANK STATEMENT OF THE PARTNERS AND ITS ASSOCIATES. THE L D. DR HAS NOT BROUGHT ANYTHING CONTRARY TO THE ARGUMENT OF THE ASSESSEE. THEREFORE IN OUR CONSIDERED VIEW, ASSESSEE HAS NOT UNDERSTATED ITS I NCOME IN FILING OF ITS RETURN. ACCORDINGLY, MONEY DEPOSITED IN THE ACCOUNT S OF PARTNERS AND TAKING CHEQUES FROM THOSE PARTNERS DO NOT AMOUNT TO UNEXPL AINED MONEY. IN THIS VIEW OF THIS MATTER, THE INCOME OF ASSESSEE HAS NOT BEEN UNDERSTATED AND THERE WAS NO MOVEMENT OF ADDITIONAL CASH. HOWEVER, WE ARE INCLINED TO RESTORE THIS MATTER BEFORE ASSESSING OFFICER WITH T HE DIRECTION TO VERIFY THE CASH DEPOSITS WITH THE PARTNERS AND CHEQUES RECEIVE D FROM THOSE PARTNERS AND DEPOSITED IN ASSESSEES BANK ACCOUNT AND ADJUDI CATE THE MATTER ACCORDINGLY AS PER LAW. HENCE, THIS ISSUE OF ASSESS EES APPEAL IS ALLOWED FOR STATISTICAL PURPOSE. 7. ISSUE NO. 2 RAISED IN THIS APPEAL OF ASSESSEE IS THAT LD. CIT(A) ERRED IN CONFIRMING THE DISALLOWANCE MADE BY AO OF RS.87,000 /- ON ACCOUNT OF SHOP RENT. ITA NO.1304 & 781/KOL/2012 A.Y 2008-09 M/S AFSANA ENTERPRISE V. ITO WD-1, MLD. PAGE 7 7.1 DURING THE COURSE OF ASSESSMENT PROCEEDINGS, AO MADE THE ADDITION IN THE ABSENCE OF SUPPORTING PAPERS IN RESPECT OF RENT EXPENSES CLAIMED BY THE ASSESSEE. 8. AGGRIEVED, ASSESSEE PREFERRED AN APPEAL BEFORE L D. CIT(A) WHO HAS UPHELD THE ORDER OF THE AO. 9. WE HAVE HEARD RIVAL CONTENTIONS OF BOTH THE PART IES. BEFORE US LD. AR SUBMITTED RENT RECEIPTS WHICH ARE PLACED ON RECORD IN SUPPORT OF ITS CLAIM FOR THE RENT EXPENSES. ON THE OTHER HAND THE LD. DR SIM PLY RELIED ON THE ORDERS OF AUTHORITIES BELOW. FROM THE AFORESAID DISCUSSION , WE FIND THAT THE ASSESSEE FAILED TO PRODUCE THE SUPPORTING DOCUMENTS IN RESPE CT OF THE RENT EXPENSES. THEREFORE IT WAS DISALLOWED. BEFORE US THE LD. AR H AS SUBMITTED THE RENT RECEIPTS IN SUPPORT OF THE RENT EXPENSES. THEREFORE , WE ARE INCLINED TO RESTORE THIS MATTER BEFORE ASSESSING OFFICER WITH THE DIREC TION TO VERIFY THE RENT RECEIPTS AND ADJUDICATE THE MATTER ACCORDINGLY AS P ER LAW. HENCE, THIS ISSUE OF ASSESSEES APPEAL IS ALLOWED FOR STATISTICAL PURPOS E. COMING TO REVENUES APPEAL IN ITA NO.781/KOL/2012 A .Y. 08-09 . 10. THIS APPEAL IS PREFERRED BY THE REVENUE AGAINST THE ORDER OF LD. COMMISSIONER OF INCOME TAX (APPEALS)-JALPAIGURI DAT ED 21.03.2012 FOR THE ASSESSMENT YEAR 2008-09. 11 AS POINTED OUT BY THE LD. COUNSEL FOR THE ASSESS EE, AT THE OUTSET, THE TAX EFFECT INVOLVED IN THIS APPEAL OF T HE REVENUE IS LESS THAN THE REVISED MONETARY LIMIT RECENTLY FIXED BY T HE CBDT VIDE CIRCULAR NO. 21/2015 DATED 10 TH DECEMBER, 2015 AT RS.10 LACS. FOR FILING THE APPEAL BY THE REVENUE BEFORE THE TRI BUNAL AND THIS POSITION CLEARLY EVIDENT FROM THE GROUNDS RAISED BY THE REVENUE IN THIS APPEAL IS NOT DISPUTED EVEN BY THE LD. D.R. IN CIRCULAR NO. 21/2015 (SUPRA) RECENTLY ISSUED BY THE CBDT, THE MO NETARY LIMIT ITA NO.1304 & 781/KOL/2012 A.Y 2008-09 M/S AFSANA ENTERPRISE V. ITO WD-1, MLD. PAGE 8 FOR FILING THE APPEALS BY THE REVENUE BEFORE THE TR IBUNAL HAS BEEN INCREASED TO RS.10,00,000/- AND AS CLARIFIED IN THE SAID CIRCULAR, THE SAID MONETARY LIMIT IS APPLICABLE RETROSPECTIVE LY EVEN TO THE APPEALS PENDING BEFORE THE TRIBUNAL. THE CBDT HAS A LSO INSTRUCTED THAT SUCH PENDING APPEALS BELOW THIS SPE CIFIED TAX LIMIT OF RS.10 LACS. MAY BE WITHDRAWN/ NOT PRESSED. KEEPI NG IN VIEW THE INSTRUCTION GIVEN BY THE CBDT VIDE CIRCULAR NO. 21/ 2015 DATED 10.12.2015, WHICH IS SQUARELY APPLICABLE IN THE PRE SENT CASE, THE APPEAL FILED BY THE REVENUE IN THIS CASE IS TREATED AS WITHDRAWN/NOT PRESSED AND DISMISSED ACCORDINGLY. 13. IN THE RESULT, APPEAL OF ASSESSEE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES AND THAT OF REVENUE IS DISMISSED IN LIMINI . ORDER PRONOUNCED IN THE OPEN COURT 29/ 02/2016 SD/- SD/- (MAHAVIR SINGH) (WASEEM AHMED) (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) KOLKATA, *DKP '#$- 29 / 02 /201 6 / COPY OF ORDER FORWARDED TO:- 1. /ASSESSEE-AFSANA ENTERPRISES, N.S. ROAD, MALDA-7321 01 2. /REVENUE-ITO WARD-1, NETAJI MARKET, MALDA-732101 3.#,#-. / / CONCERNED CIT JALPAIGURI 4. /- / CIT (A) JALPAIGURI 5.2 3455-., -.!, / DR, ITAT, KOLKATA 6.489:; / GUARD FILE. BY ORDER/ , /TRUE COPY/ /# -.!,