DCIT, CC-XI, KOLKATA, Kolkata V. Saurabh Mittal, New Delhi

ITA 810/KOL/2014

• Counselvise Citation: [2017] 128 COUNSELVISE.COM (IT) 1532 (ITAT-KOLKATA)
• Duration Of Justice: 3 year(s) 2 month(s) 13 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-07-2017
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: C
• Next Hearing Date: 25-05-2017
• Assessment Year: 2010-2011
• Appeal Filed On: 01-05-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: G MALLIKARJUNA
• Assessee Lawyers: A K TULSYAN
• Keywords: Income from undisclosed sources; Document seized; Documents seized
• Section: 143(3); 153A; 132

Judgement Text

1 ITA NOS.809-811/KOL/2014 SAURABH MITTAL, AYS.2009-10-2011-12 IN THE INCOME TAX APPELLATE TRIBUNAL C BENCH: KOL KATA [BEFORE SHRI A. T. VARKEY, JM & SHRI M. BALAGANESH , AM] I.TA NO.809,810 & 811/KOL/2014 A.Y 2009-10, 2010-11 & 2011-12 D.C.I.T, CENTRAL CIRCLE XI, KOLKATA VS. SAURABH MITTAL (PAN:AEAPM5901Q) APPELLANT/REVENUE RESPONDENT/ASSESSEE DATE OF HEARING 25.05.2017 DATE OF PRONOUNCEMENT 14.07.2017 FOR THE REVENUE SHRI , G. MALLIKARJUNA, CIT. DR FOR THE ASSESSEE SHRI A. K. TULSYAN, AR ORDER PER SHRI A.T.VARKEY, JM THESE ARE REVENUE APPEALS AGAINST THE COMMON ORDER OF THE CIT(A) CENTRAL-1, KOLKATA DATED 25.02.2014 FOR AYS 2009-10 TO 2011-12 . SINCE GROUNDS ARE COMMON AND FACTS ARE IDENTICAL, WE DISPOSE OF ALL THE APPEALS BY THIS COMMON ORDER FOR THE SAKE OF CONVENIENCE. 2. THE GROUNDS OF APPEAL ARE COMMON FOR ALL THE THR EE ASSESSMENT YEARS. THEREFORE, THE ASSESSMENT YEAR 2009-10 IS TAKEN AS THE LEAD CASE A ND THE RESULT OF IT WILL BE FOLLOWED IN THE OTHER TWO ASSESSMENT YEARS. 3. THE MAIN GRIEVANCE OF THE REVENUE IS AGAINST TH E ACTION LD. CIT(A) DELETING THE ADDITION OF RS.1,93,04,470/- WHICH WAS MADE BY THE A.O ON ACCOUNT OF DOUBLE DIGIT SUPPRESSION. 4. THE BRIEF FACTS OF THE CASE AS NOTED BY THE LD. CIT(A) AND WHICH IS NOT DISPUTED BY THE LD. D.R ARE THAT IN ALL THE 3 APPEALS, THE ASSE SSEE HAS CONTESTED THE FINDING OF THE AO THAT THE SEIZED DOCUMENT AT PAGE 4 OF SPM/ 1 CONTAI NS FIGURES WHEREIN TWO ZEROS HAVE BEEN SUPPRESSED. AS THE 3 APPEALS INVOLVE IDENTICAL ISSU ES, THEY ARE BEING DISPOSED BY A SINGLE 2 ITA NOS.809-811/KOL/2014 SAURABH MITTAL, AYS.2009-10-2011-12 COMBINED ORDER. THE BRIEF FACTS AS THEY APPEAR FROM THE MATERIAL PLACED ON RECORD ARE THAT SEARCH U/S 132 WAS CONDUCTED ON 28-09-2010 AT THE R ESIDENTIAL AND BUSINESS PREMISES OF THE ASSESSEE GROUP. IN RESPONSE TO THE NOTICES U/S 153A , THE ASSESSEE FILED HIS RETURNS FOR THE ASSESSMENT YEARS 2009-10 AND 2010-11 DECLARING TOTA L INCOME OF RS.27,59,350/- AND RS.1,02,93,300/-. THE RETURN FOR THE ASSESSMENT YEA R 2O1L-12 WAS FILED AT TOTAL INCOME OF RS.2,30,69,374/-. THE ASSESSMENT FOR THE ASSESSMENT YEARS 2009-10, 2010-11 AND 2O11-12 WAS MADE U/S 153A / 143(3) ON 25-03-2013 AT TOTAL I NCOME OF RS.2,20,63,820/-, RS.2,39,44,410/- AND RS.2,73,70,9301- RESPECTIVELY. 5. THE SEIZED DOCUMENTS MARKED SPM/ 1 WAS RECOVERED FROM THE RESIDENTIAL PREMISE OF ASSESSEE'S FATHER SRI SHIV PRAKASH MITTAL IN KOL KATA WHEREAS THE ASSESSEE RESIDES AT NEW DELHI. THE AO NOTED IN HIS ASSESSMENT ORDER THAT IT WAS ADMITTED BY SRI SHIV PRAKASH MITTAL IN HIS STATEMENT U/S 132(4) THAT THE DOCUMEN T AT PAGE 4 OF SPM/ 1 IS THE ACCOUNT OF THE ASSESSEE FOR THE ASSESSMENT YEARS 2009-10, 2010 -11 AND 2011-12 IN AS MUCH AS IT CONTAINS UNACCOUNTED INCOME CREDITED TO THE ACCOUNT S OF THE ASSESSEE AND ALSO THE WITHDRAWALS MADE BY HIM. SRI SHIV PRAKASH MITTAL (F ATHER OF ASSESSEE) IN HIS DISCLOSURE PETITION ALSO OFFERED THE HIGHER OF THE CREDITS OR WITHDRAWALS AS THE UNDISCLOSED INCOME OF THE ASSESSEE FOR THE SAID ASSESSMENT YEARS 2009-10, 2010-11 AND 2011-12. IN OTHER WORDS, SRI SHIV PRAKASH MITTAL IN HIS DISCLOSURE PETITION OFFERED SUM OF RS.1,94,994.64; RS.1,37,890.00 AND RS.43,450.00 AS THE UNDISCLOSED INCOME OF THE ASSESSEE FOR THE ASSESSMENT YEARS 2009-10, 2010-11 AND 2011-12 (WHIC H WAS ALSO INCLUDED BY THE ASSESSEE IN HIS RETURNS FOR THE RESPECTIVE YEARS). THE AO SU MMARISED THE DISCLOSURE IN HIS ASSESSMENT ORDER AS UNDER: PARTICULARS OF DISCLOSURE SEIZED DOCUMENT A Y APPEARING IN SEIZED DOCUMENT TOTAL OPENING BALANCE (RS.6488.08) PLUS TOTAL OF WITHDRAWALS BEING GREATER THAN CREDITS IS TREATED AS INCOME PAGE 4 OF SPM/ I 2009-10 6,488.09 1,88,505.56 1,94,994.64 TOTAL OF CREDITS BEING LARGER THAN WITHDRAWALS IS TREATED AS INCOME PAGE 4 OF SPM/ 1 2010-11 99,960.00 3,930.00 34,000.00 1,37,890.00 TOTAL OF CREDITS BEING LARGER THAN WITHDRAWALS IS TREATED AS INCOME PAGE 4 OF SPM/ 1 2011-12 41,650.00 1,800.00 43,450.00 3 ITA NOS.809-811/KOL/2014 SAURABH MITTAL, AYS.2009-10-2011-12 6. THE AO NOTED IN THE ASSESSMENT ORDER THAT THERE WAS APPARENTLY DOUBLE-DIGIT SUPPRESSION IN THE SEIZED DOCUMENT AT PAGE 4 OF SPM / 1 WHICH REFLECTED CERTAIN TRANSACTION OF ASSESSEE. THE AO DERIVED STRENGTH FROM THE FACT THAT DOUBLE-DIGIT SUPPRESSION WAS ADMITTED BY FATHER OF ASSESSEE WITH REFERENCE TO CE RTAIN OTHER DOCUMENTS SEIZED IN COURSE OF THE SEARCH. FOR, ACCOUNTS RELATED TO ASSESSEE'S BRO THER SRI SHOBHAN MITTAL WAS FOUND IN THE SEIZED DOCUMENT AT PAGE 5 OF SPM/ 1 WHEREIN DOUBLE- DIGIT SUPPRESSION WAS ADMITTED AND UNDISCLOSED INCOME WAS ALSO SURRENDERED ACCORDINGLY . FURTHERMORE, SRI SHIV PRAKASH MITTAL ALSO ADMITTED DOUBLE-DIGIT SUPPRESSION IN HI S ACCOUNTS FOUND IN THE SEIZED DOCUMENT AT PAGE 6 & 7 OF SPM/1. THE AO ALSO REFERRED TO THE SEIZED DOCUMENT JV/3 WHEREIN DOUBLE-DIGIT SUPPRESSION WAS ADMITTED BY THE CFO SR I VENKATRAMANI IN HIS STATEMENT U/S 132(4). THE AO, THEREFORE, WAS OF THE VIEW THAT THE MODUS OPERANDI OF DOUBLE-DIGIT SUPPRESSION WAS BEING FOLLOWED BY THE ASSESSEE GROU P AND THEREFORE THE SEIZED DOCUMENT AT PAGE 4 OF SPM/ I SHOULD ALSO INVOICE DOUBLE-DIGIT S UPPRESSION. THE ASSESSEE HOWEVER DENIED AT THE ASSESSMENT STAGE THAT THERE WAS ANY D OUBLE-DIGIT SUPPRESSION IN THE SEIZED DOCUMENT AT PAGE 4 OF SPM/1. IT WAS CONTENDED THAT THE SEIZED DOCUMENT CONTAINS ACTUAL FIGURES OF INCOME AND WITHDRAWAL; AND, THAT THE UND ISCLOSED INCOME BEING THE HIGHER OF INCOME OR WITHDRAWAL HAS BEEN DULY SURRENDERED BY T HE ASSESSEE. 7. THE AO REJECTED THE CONTENTIONS OF THE ASSESSEE MAINLY ON TWO GROUNDS : FIRST, THAT DOUBLE-DIGIT SUPPRESSION WAS ADMITTED BY FATHER OF ASSESSEE IN RESPECT OF CERTAIN OTHER SEIZED DOCUMENTS, NAMELY, PAGE 5, 6 & 7 OF SPM/ 1 A ND IN RESPECT OF JV/3 BY CFO OF THE GROUP ADMITTED OF DOUBLE DIGIT SUPPRESSION; AND SEC ONDLY, THAT THE OPENING BALANCE AND THE TOTAL WITHDRAWALS DURING THE FINANCIAL YEAR 2008-09 WAS SHOWN AT RS.6,488.08 AND RS.1,88,505.56 RESPECTIVELY IN PAGE 4 OF SPM/ 1 WHI CH WAS NOT POSSIBLE, AS THE COINS OF SUCH DENOMINATION (1,2, 3 & 5 PAISA) HAD LONG BEEN WITHDRAWN BY THE RBI. THE AO ALSO REJECTED THE JUDICIAL DECISIONS RELIED BY THE ASSES SEE ON THE GROUND THAT THE UNDISCLOSED INCOME WAS BEING COMPUTED ON THE BASIS OF THE SEIZE D MATERIAL AND NOT BY PRESUMPTION OR GUESS WORK. SINCE THE FATHER AND BROTHER OF ASSESSE E INDULGED IN DOUBLE DIGIT SUPPRESSION, THE AO CONCLUDED THAT THERE WAS DOUBLE-DIGIT SUPPRE SSION IN THE SEIZED DOCUMENT PERTAINING TO ASSESSEE TRANSACTION NOTED AT PAGE 4 OF SPM/1. THE AO THEN COMPUTED ON THE 4 ITA NOS.809-811/KOL/2014 SAURABH MITTAL, AYS.2009-10-2011-12 BASIS OF SUCH SEIZED DOCUMENT THE UNDISCLOSED INCOM E OF THE ASSESSEE FOR THE ASSESSMENT YEARS 2009-10, 2010-11 AND 2011-12 AT RS. 1,94,99,4 64/- RS. 1,37,89,000/- AND RS.43,45,000/- RESPECTIVELY. AGGRIEVED BY THE AFOR ESAID ADDITIONS MADE BY THE AO THE ASSESSEE PREFERRED AN APPEAL BEFORE THE LD. CIT(A), WHO WAS PLEASED TO DELETE THE ADDITIONS. AGGRIEVED BY THE SAID ACTION OF THE LD. CIT(A) THE REVENUE IS BEFORE US. 8. WE HAVE HEARD RIVAL SUBMISSIONS AND PERUSED THE RECORDS CAREFULLY. WE NOTE THAT SPM-1 IS BUNCH OF LOOSE SHEETS CONTAINING MISCELLAN EOUS DOCUMENTS WHICH WERE SERIALLY MARKED FROM PAGES 1 TO 21 FOUND DURING THE COURSE O F SEARCH OPERATION CONDUCTED U/S. 132(1) OF THE ACT ON 28.09.2010 AND WERE SEIZED. S PM-4 RELATES TO THE ASSESSEE WHICH IS FOUND AT PAGE 15 OF THE PAPER BOOK AND WHICH IS REP RODUCED AS UNDER: A/C MR. SAURABH MITTAL DATE PARTICULARS DEBIT CREDIT BALANCE 4.1.2008 OPENING BALANCE 6488.08 DR. 2008-09 TOTAL CREDIT AS PER SYT SPM JI 99960.00 93471.92 2008-09 CREDIT AGAINST P. EXPAN FILES 3730.00 97201.92 2008-09 WITHDRAWALS 188505.56 91303.64 2009-10 TOTAL CREDIT AS PER SYT SPM JI 99960.00 8656.36 2009-10 CREDIT AGAINST EXPENSES 3930.00 12586.36 2009-10 CREDIT AGAINST MISC. 34000.00 46586.36 2009-10 WITHDRAWALS 99419.33 52832.97 2010-11 CREDIT AS PER SYT SPM JI 41650.00 11182.97 2010-11 CASH 1800.00 9382.97 2010-11 WITHDRAWLS UPTO 07.05.2010 25278.96 34661.93 DR. 9. FROM THE PERUSAL OF THE AFORESAID NOTING ON PAG E 4 OF SPM/1, THE LD. CIT(A) HAS RIGHTLY OBSERVED THAT IT IS APPARENT THAT THESE NOT INGS ARE ANNUAL SUMMARY OF ASSESSEE'S TRANSACTIONS IN THE RECORDS OF SOME THIRD PARTY WIT H WHOM HE HAD FINANCIAL TRANSACTIONS DURING THE FINANCIAL YEARS 2008-09 TO 2010-11. THE LD. CIT(A) HAS TAKEN NOTE OF THE FACT THAT THESE TRANSACTIONS WERE NOT RECORDED IN THE RE GULAR BOOKS OF THE ASSESSEE. THE LD. CIT(A) HAS ALSO TAKEN INTO CONSIDERATION FROM THE S UBMISSIONS OF THE ASSESSEE THAT THERE IS NO CLARITY AS TO IN WHOSE BOOKS OR RECORDS THIS ACC OUNT WAS MAINTAINED AND THAT WITH WHOMSOEVER SUCH ACCOUNT WAS MAINTAINED, BUT THE FAC T WAS THAT IT WAS NOT RECORDED IN THE ASSESSEE'S REGULAR BOOKS. THE LD. CIT(A) APPRECIATE D THE FACT THAT THE NOTING AT PAGE 4 OF SPM/ 1 DID NOT RECORD DETAILS OF TRANSACTIONS CONDU CTED ON DAY-TO-DAY BASIS WITH THE THIRD PARTY. WE NOTE THAT THE NATURE AND CHARACTER OF ENT RIES AT PAGE 4 OF SPM/1 IS DIFFERENT FROM 5 ITA NOS.809-811/KOL/2014 SAURABH MITTAL, AYS.2009-10-2011-12 THOSE FOUND AT PAGES 5, 6 & 7 OF SPM/I. THE LD. CIT (A) AFTER COMPARING THE PAGE 4 WITH PAGES 5, 6 & 7 OF SPM/1 HAS RIGHTLY OBSERVED THAT U NLIKE THE NOTINGS ON PAGE 4 WHICH CONTAINED ANNUALIZED SUMMARY OF ASSESSEE'S TRANSACT IONS; THE PAGES 5, 6 & 7 (WHICH PERTAINS TO ASSESSEES FATHER AND BROTHER) CONTAINE D RECEIPTS & PAYMENTS OF MONEY ON DAY- TO-DAY BASIS. THE NOTINGS ON PAGES 5, 6 & 7 PROVIDE D DESCRIPTION OF THE PAYMENTS RECEIVED OR PAYMENTS MADE FROM DAY-TO-DAY IN THE NAMES OF SH OBHAN MITTAL OR S P MITTAL (BROTHER AND FATHER RESPECTIVELY OF ASSESSEE). HAVING REGARD TO THE GRAPHIC DETAILS OF PAYMENTS MADE AND RECEIVED ON DAY-TO-DAY BASIS, SRI SHOBHAN MITTA L AND SRI S P MITTAL HAD ADMITTED IN THEIR INCOME TAX RETURNS THAT THE NOTINGS CONTAINED ON PAGES 5, 6 & 7 HAD TWO-DIGIT SUPPRESSION. WE NOTE THAT THE AO WAS INFLUENCED BY THE FACT THAT SINCE PAGES 5, 6 & 7 WERE ALSO SEIZED FROM SRI S P MITTAL AND WITH REGARD TO THESE PAGES 5, 6 & 7 THE ASSESSEE'S FATHER AND BROTHER HAD ADMITTED THE SUPPRESSION OF TWO DIG ITS, THE VERY SAME INFERENCE NEEDS TO BE DRAWN TO THE NOTINGS ON PAGE 4. MOREOVER ACCORDING TO AO, IN THE STATEMENT RECORDED U/S 132(4), SRI S P MITTAL HAD ADMITTED THE SUPPRESSION OF TWO DIGITS. AND THE ADMISSION WAS FOLLOWED BY THE DISCLOSURE MADE IN THE RETURNS FILE D BY SRI S P MITTAL AND SRI SHOBHAN MITTAL LED THE AO TO CONCLUDE THAT THERE WAS TWO-DI GIT SUPPRESSION IN RELATION TO PAGE 4 AS WELL. WE HAVE GONE THROUGH THE STATEMENT OF SRI S P MITTAL RECORDED U/S 132(4). WE NOTE THAT NOWHERE IN HIS STATEMENT SRI S P MITTAL HAD AD MITTED THAT THERE WAS TWO-DIGIT SUPPRESSION IN THE NOTINGS MADE ON PAGE 4 OF SPM/ 1 . IN THE STATEMENT OF SHRI SHIV PRAKASH MITTAL WHICH WAS RECORDED U/S. 132(4) OF TH E ACT WHEN ENQUIRED ABOUT PAGE NO. 4 OF SPM-1 IT WAS REPLIED BY SHRI SHV PRAKASH MITTAL (FATHER OF THE ASSESSEE) THAT THIS PERTAINS TO DAY TO DAY EXPENSES FOR PERSONAL USE WH ICH IS FOUND ANNEXED AT PAGE 20 OF PAPER BOOK. THE AO CONCLUDED THAT THE ASSESSEE HAS SUPPRESSED TWO ZEROS ON THE BASIS OF THE STATEMENT OF THE FATHER SHRI SHIV PRAKASH MITTA L AND THE STATEMENT OF MR. VISWANATH VENKATRAMANI THE CFO WHEN CONFRONTED WITH DOCUMENTS MARKED JV-3. THE AO NOTES THAT MR. SHIV PRAKASH MITTAL HAS DULY DISCLOSED THE SUPP RESSION OF TWO ZEROS VIDE HIS DISCLOSURE PETITION DATED 25.11.2010 WHICH HAS BEEN KEPT AT PA GES 35 TO 84 OF THE PAPER BOOK. WE NOTE THAT THE AO HAS MADE THE ASSUMPTION OF SUPPRES SION OF TWO ZEROS IN RESPECT TO THE ASSESSEE SHRI SAURABH MITTAL ONLY ON THE BASIS OF T HE STATEMENT OF THE FATHER IN RESPECT TO PAPERS WHICH WERE MAINTAINED AT PAGES 5, 6 AND 7 OF SPM-1 AND WHICH PERTAINS TO SHRI SHIV PRAKASH MITTAL, FATHER OF THE ASSESSEE AND SHR I SHOBHAN MITTAL (NOT THE ASSESSEE). IN 6 ITA NOS.809-811/KOL/2014 SAURABH MITTAL, AYS.2009-10-2011-12 THE DISCLOSURE PETITION FILED BY SHRI SHIV PRAKASH MITTAL DATD 25.11.2010, WE FIND AT PAGE 65 WHICH SHOWS THAT SHRI SHIV PRAKASH MITTAL HAS NO T COME OUT WITH THE THEORY IN RESPECT TO THE ASSESSEE OF SUPPRESSING TWO ZEROS IN RESPECT OF DOCUMENT AT PAGE 4 OF SPM-1. MERELY BECAUSE THE ASSESSEES ACCOUNTS HAVE GOT .56 PAISE AND .08 PAISE RECORDED ON THE LOOSE SHEET MARKED AS PAGE 4 OF SPM-1, THE AO TAKI NG NOTE THAT .56PAISE AND .08PAISE (COINS) ARE NOT IN CIRCULATION AND THEREFORE IN THE LIGHT OF THE CLEAR ADMISSION MADE BY THE FATHER OF ASSESSEE, THE ASSESSEES TRANSACTION REF LECTED AT PAGE 4 OF SPM-1 ALSO SUPPRESSED THE TWO ZEROS AND THEN HE WENT AHEAD IN MAKING ADDI TION, WHICH ACTION OF THE AO WE CANNOT APPROVE FOR THE SIMPLE REASON THAT SHIV PRAK ASH MITTAL OR CFO DID NOT MAKE ANY SUCH ADMISSION THAT IN ASSESSEES PAGE NO. 4 THER E WAS DOUBLE DIGIT SUPPRESSION. WE NOTE THAT THE LD. CIT(A) HAS TAKEN INTO CONSIDERATION AL L THESE FACTS AND HAS PASSED A REASONED ORDER. WE NOTE THAT THE CFO MR. VISWANATH VENKATRA MANIS STATEMENT HAS GOT NO CONNECTION WITH PAGE 4 OF SPM-1 AND THE STATEMENT O F SHRI SHIV PRAKASH MITTAL IN NO WAY TOUCHES UPON THE CONTENTS OF PAGE NO.4 OF THE ASSES SEE IN ANY MANNER TO SUGGEST SUPPRESSION OF TWO ZEROS AND ON THE CONTRARY THE VE RY SAME SHRI SHIV PRAKASH MITTAL HAS FILED THE DISCLOSURE PETITION DATED 25.11.2010 ON T HE BASIS OF WHICH RETURN OF INCOME WAS FILED BY THE ASSESSEE WHICH GOES ON TO PROVE THAT T HERE IS NO SUPPRESSION OF DOUBLE DIGIT AS WRONGLY PRESUMED BY THE AO. THE LD. DR COULD NOT PO INT OUT FROM THE STATEMENT RECORDED U/S. 132(4) OF THE ACT OF SHRI SHIV PRAKASH MITTAL OR FROM MR. VISWANATH VENKATRAMANI IN ORDER TO THROW LIGHT OF THE FACT THAT THE TRANSACTI ON RECORDED AT PAGE 4 OF SPM-1 ALSO WAS DONE BY SUPPRESSING TWO DIGITS , WITHOUT DOING SO, THE AOS ADDITIONS WERE BASED ON NO EVIDENCE AND, THEREFORE, PERVERSE. THE LD. CIT(A) HAS CLEARLY ANALYSED THE MATERIAL ON RECORD AND HAS GIVEN A REASONED ORDER WHICH DOES NO T WARRANT OUR INTERFERENCE. THEREFORE, WE UPHOLD THE ORDER OF THE LD. CIT(A) AND DISMISS T HE GROUNDS OF APPEAL RAISED BY THE REVENUE IN ALL THE APPEALS. 10. IN THE RESULT, ALL THE APPEALS OF REVENUE ARE D ISMISSED. ORDER IS PRONOUNCED IN THE OPEN COURT ON 14.07.2017 SD/- SD/- (M. BALAGANESH) (ABY. T. VARKEY) ACCOUNTANT MEMBER JUDICIAL MEMBER DATED : JULY, 2017 JD.(SR.P.S.) 7 ITA NOS.809-811/KOL/2014 SAURABH MITTAL, AYS.2009-10-2011-12 COPY OF THE ORDER FORWARDED TO: 1. APPELLANT DCIT, CENTRAL CIRCLE-XI, KOLKATA. 2 RESPONDENT SHRI SAURABH MITTAL, 66, ANAND LOK, KHEL GAON ROAD, NEW DELHI-49. 3. THE CIT(A), KOLKATA 4. 5. CIT , KOLKATA DR, KOLKATA BENCHES, KOLKATA /TRUE COPY, BY ORDER, SR. PVT. SECY