ACIT, C.C. XXII, Kolkata V. Smt. Manju Poddar, Kolkata

ITSSA 119/KOL/2008

• Counselvise Citation: [2012] 121 COUNSELVISE.COM (IT) 8547 (ITAT-KOLKATA)
• Duration Of Justice: 4 year(s) 1 month(s) 8 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 25-10-2012
• Appeal Filed By: Department
• Bench Allotted: A
• Next Hearing Date: 04-10-2010
• Assessment Year: misc
• Appeal Filed On: 16-09-2008
• Court: TRIBUNAL
• Department Lawyers: A K MOHAPATRA
• Assessee Lawyers: A K TIBREWAL
• Keywords: Opportunity of being heard; Assessment record; Block assessment
• Section: 132

Judgement Text

, A , IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH: KOL KATA () BEFORE , /AND , . . !' ) [BEFORE SHRI MAHAVIR SINGH, JM & SHRI C. D. RAO, AM ] # # # # / I.T.(SS).A NO. 119/KOL/2008 $% &' $% &' $% &' $% &'/ // / BLOCK PERIOD : 01.04.1988 TO 21.12.1998 ASSISTANT COMMISSIONER OF INCOM-TAX, VS. SMT. MAN JU PODDAR C.C. XXII, KOLKATA. ()* /APPELLANT ) (+,)*/ RESPONDENT ) DATE OF HEARING: 11.10.2012 DATE OF PRONOUNCEMENT: 25.10.2012 FOR THE APPELLANT: SHRI A. K. MOHAPATRA FOR THE RESPONDENT: SHRI A. K. TIBREWAL !- / ORDER PER MAHAVIR SINGH, JM ( , , , , ) THIS APPEAL BY REVENUE IS ARISING OUT OF ORDER OF C IT(A), CENTRAL-III, KOLKATA IN APPEAL NO. 309/CC-XXIII/CIT(A)C-III/01-02 DATED 01.07.2008 . ASSESSMENT WAS FRAMED BY DCIT, CENTRAL CIRCLE-XIII U/S. 158BC OF THE INCOME-TAX AC T, 1961 (HEREINAFTER REFERRED TO AS THE ACT) FOR BLOCK PERIOD 01.04. 1988 TO 21.12.1998 VI DE HIS ORDER DATED 31.01.2001. 2. AT THE OUTSET, IT IS NOTICED THAT THIS APPEAL IS TIME BARRED BY 17 DAYS AND REVENUE HAS NOT FILED ANY CONDONATION PETITION BUT DURING THE HEARI NG IT WAS POINTED OUT THAT THE DATE OF COMMUNICATION OF ORDER APPEALED AGAINST IN FORM NO. 36 IS WRITTEN AS 1 ST JULY, 2008, WHICH WAS CORRECTED BY LD. CIT, DR. ACCORDING TO HIM, TH E DATE OF COMMUNICATION OF ORDER APPEALED AGAINST IS 1 ST AUGUST, 2008 AS AGAINST THE DATE MENTIONED IN FORM NO. 36 AS 1 ST JULY, 2008. IT MEANS THAT THE APPEAL IS WITHIN THE TIME AND THERE IS NO DELAY. WHEN THIS WAS POINTED OUT, LD. COUNSEL FOR THE ASSESSEE FAIRLY CONCEDED THE POSITI ON AND HENCE, WE ADMIT THE APPEAL AND ADJUDICATE THE SAME. 3. THE FIRST ISSUE IN THIS APPEAL OF REVENUE IS AGA INST THE ORDER OF CIT(A) CANCELLING BLOCK ASSESSMENT AND FOR THAT RAISED FOLLOWING TWO GROUND S: 1. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE THE LD. CIT(A),C-III, HAS FAILED TO ADJUDICATE THE ISSUES RESTORED TO HIS FILE BY TH E HONBLE ITAT IN ITS ORDER DATED 2 ITSSA 119/K/2008 SMT. MANJU PODDAR B.P.1.4.1988 TO 21.12.1998 03.01.2007 IN ITA NO.132 AND 171(KOL) OF 2005 BY SI MPLY PUTTING THE SAME ORDER IN VERBATIM PASSED BY HIS PREDECESSOR IN OFFICE DATED 06.05.2005. 2. THAT THE LD. CIT(A) ERRED ON FACT AS WELL AS LAW IN CANCELLING THE BLOCK ASSESSMENT. 4. BRIEF FACTS LEADING TO THE ABOVE ISSUE ARE THAT A SEARCH U/S. 132 OF THE ACT WAS CARRIED OUT BY THE I. T. DEPARTMENT ON RESIDENTIAL PREMISES OF THE ASSESSEE AT FLAT NO. 8B/1, SATTYAM TOWERS, 3, ALIPORE ROAD, KOLKATA-700 027. IN CONSE QUENCE TO THE SEARCH A NOTICE U/S. 158BC OF THE ACT WAS ISSUED TO THE ASSESSEE ON 17.09.1999 AND ASSESSEE FILED HER BLOCK RETURN ON 29.10.1999 IN FORM NO. 2B DECLARING NIL UNDISCLOSED INCOME. THE AO FRAMED BLOCK ASSESSMENT ORDER U/S. 158BC OF THE ACT VIDE HIS ORD ER DATED 31.01.2001 COMPUTING THE UNDISCLOSED INCOME AT RS.16,74,600/-. AGGRIEVED AS SESSEE PREFERRED APPEAL BEFORE CIT(A), CENTRAL-III, KOLKATA, WHO DISMISSED THE APPEAL FOR NON-PROSECUTION ON 22.04.2004. THE ASSESSEE FILED MA BEFORE CIT(A) PRAYING FOR RECALLI NG OF THE ORDER AND CIT(A) RECALLED HIS ORDER DATED 22.04.2004 ON 06.05.2005. AGAINST ORDE R OF 06.05.2005, AO RAISED A PLEA THAT NO PROPER HEARING WAS ALLOWED TO HIM AND NO NOTICE WAS SERVED ON HIM FIXING THE APPEAL FOR HEARING. THE CIT(A) RE-FIXED THE APPEAL AND ISSUED NOTICE TO THE AO BUT AO CHOSE NOT TO APPEAR AND IN SUCH CIRCUMSTANCES, HE PASSED THE ORD ER DATED 12.08.2005 REPEATING THAT THE ORDER DATED 06.05.2005 STANDS AS IT IS. AGGRIEVED, REVEN UE WENT IN APPEAL BEFORE ITAT AND ITAT DIRECTED THE CIT(A) TO PASS A FRESH ORDER AFTER GIV ING OPPORTUNITY OF BEING HEARD TO BOTH THE PARTIES. PURSUANT TO THE TRIBUNALS ORDER, CIT(A) ISSUED FRESH NOTICES U/S. 250 OF THE ACT TO THE AO AS WELL AS TO ASSESSEE. THIS TIME ALSO THERE WA S NO COMPLIANCE FROM THE AO AND A LETTER DATED 12.10.2007 WAS SENT BY CIT(A) TO THE AO REQUE STING HIM TO COMPLY WITH THE AFORESAID NOTICES. COPY OF THIS LETTER WAS ALSO FORWARDED TO ADDL. CIT, RANGE-6 AS WELL AS CIT, CENTRAL- III, KOLKATA. DESPITE THESE NOTICES, NOBODY APPEAR ED BEFORE CIT(A) ON BEHALF OF REVENUE. IN SUCH CIRCUMSTANCES, CIT(A) CONFIRMED ORDER PASSED BY CIT DATED 06.05.2005 VIDE HIS ORDER DATED 01.07.2008. WE HAVE GONE THROUGH THE ORDER O F CIT DATED 06.05.2005 WHEREIN FOLLOWING OBSERVATIONS (AS NOTED BY HIM) ARE AS UNDER: A) THERE WAS NO SEARCH WARRANT IN THE NAME OF THE ASSESSEE FOR CONDUCTING A SEARCH IN THE CASE OF THE ASSESSEE U/S 132 OF THE INCOME TAX ACT, 1961 ON OR BEFORE 21 ST DECEMBER 1998. THERE IS NO MENTION IN THE IMPUGNED ASSESSMEN T ORDER ABOUT ANY SEARCH WARRANT IN THE NAME OF THE ASSESSEE. THE NAME OF THE ASSESSEE DID NOT APPEAR IN THE PANCHANAMA DRAWN ON 21ST DECEMBER 1998. HE ALSO HELD THAT IN T HESE CIRCUMSTANCES, SO FAR AS THE ASSESSEE MANJU PODDAR IS CONCERNED, NO PROCEEDINGS U/S 158BC COULD HAVE BEEN INITIATED. PLEASE SEE 1ST AND 2ND NEW PARA AT PAGE 16 OF THE ORDER DATED 06TH MAY 2005 PASSED BY LD. CIT(A) AND ALSO 1ST AND 2ND NEW PARA AT PAGE 13 OF IMPUGNED ORDER DATED 1ST JULY 2008 PASSED BY LEARNED CIT(A). 3 ITSSA 119/K/2008 SMT. MANJU PODDAR B.P.1.4.1988 TO 21.12.1998 B) IT WAS FURTHER HELD THAT NO NOTICE HAS BEEN ISSU ED U/S 158BC OF THE INCOME TAX ACT, 1961 IN THE CASE OF THE ASSESSEE CALLING FOR RETURN ON INCOME FOR THE BLOCK PERIOD ENDING ON 5TH JANUARY 1999, THE DATE ON WHICH A PANCHANAMA WAS DRAWN IN THE JOINT NAMES OF THE ASSESSEE WITH THREE OTHERS. HE FURTHER HELD THA T AS FAR AS THE ASSESSEE IS CONCERNED NO SEARCH TOOK PLACE ON 21.12.1998. IN THE ASSESSMENT ORDER ALSO, THE AO DOES NOT INDICATE THAT HE FOUND ANY EVIDENCE THAT INDICATED THAT APPE LLANT HAD UNDISCLOSED INCOME. AGGRIEVED, REVENUE IS NOW IN APPEAL BEFORE US. 5. WE HAVE HEARD RIVAL SUBMISSIONS AND GONE THROUGH FACTS AND CIRCUMSTANCES OF THE CASE. AT THE OUTSET, IT IS TO BE NOTICED THAT TRIBUNAL VI DE ORDER SHEET ENTRY DATED 12.07.2011 HAS REQUIRED THE REVENUE TO PRODUCE COPY OF WARRANT OF AUTHORISATION IN THE CASE OF THE ASSESSEE. THE FOLLOWING IS THE ORDER DATED 12.07.2011: 12.07.2011: ARGUMENTS CONCLUDED. LD. BOTH OF THE REPRESENTATIVES ARE DIRECTED TO FILE WRITTEN SUBMISSION WITHIN 10 DAYS. THE LD. DR IS A LSO TO PRODUCE COPY OF WARRANT OF AUTHORISATION FOR OUR PERUSAL. ADJD. TO 26.07.2011 . BOTH PARTIES ARE INFORMED. SUBSEQUENTLY, THE SAME ENTRY WAS REPEATED ON 26.07. 2011, 06.09.2011, 04.01.2012, 13.01.2012 AND FINALLY ON 08.05.2012. THE RELEVANT ENTRY DATE D 08.05.2012 READS AS UNDER: 8.5.2012: LD. CIT (DR) STATED AT BAR THAT HE HAS R ECEIVED COMMUNICATION FROM CIT STATING THAT THE DEPTT. COULD NOT TRACE THE SEARCH WARRANT AS OF NOW. ON THIS, BENCH REQUIRED LD. CIT(DR) TO CATEGORICALLY STATE WHETHER THERE IS SEARCH WARRANT IN THE CASE OF SMT. MANJU PODDAR AND WHEN HE WILL PRODUCE THE SAME. LD. CIT(DR) ASKED ONE MORE OPPORTUNITY AND REQUESTED THE CASE TO BE ADJD. ON R EGULAR DATE. TO BE FAIR TO REVENUE, WE WANT TO PROVIDE ONE MORE OPPORTUNITY FOR PRODUCTION OF SEARCH WARRANT IN THE CASE OF SMT. MANJU PODDAR. LD. CIT(DR) IS DIRECTED ACCORDI NGLY. ADJD TO 9.10.2012. BOTH PARTIES ARE INFORMED. ON 11.10.2012 FINALLY REVENUE ADMITTED THAT THERE I S NO SEARCH WARRANT IN THE NAME OF THE ASSESSEE AND THE RELEVANT FIRST PARA OF LETTER DATE D 10.10.2012 OF CIT-DR, ITAT, KOLKATA BENCHES READS AS UNDER: IN ADDITION TO THE SYNOPSIS OF THE CASE SUBMITTED BY EARLIER CIT (ITAT) (COPY ENCLOSED). I AM SUBMITTING THE FOLLOWING CASES FOR SUPPORTING THE PROPOSITION THAT IF THE ASSESSMENT IS HELD TO BE INVALID U/S. 158BC OF THE INCOME TAX ACT FOR NOT ISSUING WARRANT IN THE NAME OF THE ASSESSEE, THEN THE ALTERNATIVE PLEA OF THE ASSESSMENT HAVING BEEN MADE AS PER SECTION 158BD MAY BE ACCEPTED. I AM SUBMITTING THE FOLLOWING CASES FOR SUPPORTING THE ABOVE PROPOSITION. 6. WE HAVE GONE THROUGH THE SYNOPSIS OF CIT, ITAT, KOLKATA BENCHES DATED 22.07.2011 NO. CIT(ITAT)-III/DRS/IT(SS)/119/K/08/MANJU PODDAR/ 2011-12/794 WHICH CLEARLY ADMITS THAT A SEARCH WAS CARRIED OVER ON 19.12.1998 U/S. 132 OF THE ACT IN THE CASE OF ASHOK KR. GROUP OF CASES AT THE RESIDENTIAL PREMISES OF THE ASSESSEE A T FLAT NO. 8B/1, SATYAM TOWER, 3, ALIPORE ROAD, KOLKATA-27 WHEREIN ASSESSEE SMT. MANJU PODDAR RESIDES ALONG WITH HER HUSBAND SHRI 4 ITSSA 119/K/2008 SMT. MANJU PODDAR B.P.1.4.1988 TO 21.12.1998 RAJ KUMAR PODDAR. ACCORDING TO REVENUE, PANCHNAMA REVEALS THAT THE WARRANT WAS IN THE NAME OF FOLLOWING PERSONS: I) SHRI ASHOK KUMAR PODDAR II) SMT. PREMA PODDAR III) AKP SECURITIES P. LTD. WE FIND THAT THE FIRST PANCHNAMA WAS DRAWN ON 20.12 .1998 IN PURSUANCE OF WARRANT OF AUTHORISATION DATED 18.12.1998 (PAGE 2 OF ASSESSEE S PAPER BOOK). THE PANCHNAMA WAS DRAWN IN THE NAMES OF SHRI ASHOK KR. PODDAR, SMT. PREMA P ODDAR AND AKP SECURITIES PVT. LTD. AND PANCHNAMA CONTAINS THESE NAMES WHICH ALSO CONTAINED IN THE WARRANT DATED 18.12.1998. THE NAME OF THE ASSESSEE DOES NOT APPEAR AT ALL. IT ME ANS THAT THERE IS NO WARRANT OF AUTHORISATION IN THE NAME OF ASSESSEE AS IS EVIDENT FROM THE ABOVE P ANCHNAMA. SUBSEQUENTLY, SECOND PANCHNAMA WAS DRAWN ON 21.12.1998 IN PURSUANCE OF A NOTHER SEARCH WARRANT DATED 21.12.1998 IN THE NAME OF SHRI ASHOK KR. PODDAR (PAGES 36 AND 37 OF ASSESSEES PAPER BOOK). ACCORDING TO ASSESSEE, SEARCH WAS AN INDEPENDENT AND SEPARATE SEARCH AND WAS NOT IN CONTINUATION OF SEARCH DATED 19.12.1998. HERE ALSO, THE ASSESSEES NAME DOES NOT APPEAR IN COLUMN A OF PANCHNAMA (PAGE 36 OF ASSESSEES PAPER BOOK) WHERE THE NAME OF THE PERSON IN RESPECT OF WHOM WARRANT ISSUED IS MENTIONED. SIMILARLY, 3 RD AND 4 TH PANCHNAMAS WERE DRAWN ON 01.01.1999 WAS IN THE JOINT NAMES OF SHRI ASHOK KR. PODDAR AND SMT. PREMA PODDAR (AT PAGE 40 OF ASSESSEES PAPER BOOK) AND ASHOK KR. PODDAR, SMT. MANJU PODDAR, RAJ KR. PODDAR AND SMT. PREMA PODDAR (PANCHNAMA AT PAGE 53 OF ASSESSEE S PAPER BOOK), WHICH, CLAIMED BY REVENUE, ISSUED IN PURSUANCE OF WARRANT OF AUTHORIS ATION DATED 21.12.1998 AND WAS IN CONTINUATION OF SEARCH DATED 21.12.1998. HERE, THE NAME OF THE ASSESSEE DOES APPEAR. BUT WHETHER THE ASSESSEES NAME APPEARS IN THE PANCHANA MA DRAWN ON 05.01.1998, WHICH WAS IN CONTINUATION OF SEARCH ON 21.12.1998 AND IN RESPECT OF THE SAME WARRANT OF AUTHORISATION DATED 21.12.1998, WHICH WAS IN THE NAME OF SHRI ASHOK KR. PODDAR ONLY. IN SUCH CIRCUMSTANCES, THERE IS NO WARRANT OF AUTHORISATION IN THE NAME OF ASSESSEE ON 21.12.1998 AND IN THE PANCHNAMA DATED 05.01.1999 THE ASSESSEES NAME WAS INCLUDED WITHOUT WARRANT OF AUTHORISATION. IN SUCH CIRCUMSTANCES, WE ARE OF TH E VIEW THAT THE AO WAS NO JUSTIFIED IN FRAMING OF THE BLOCK ASSESSMENT U/S. 158BC OF THE A CT IN THE CASE OF THE ASSESSEE. AS REGARDS THE ALTERNATIVE PLEA OF THE REVENUE THAT BLOCK ASSE SSMENT, IF AT ALL, COULD HAVE BEEN MADE U/S. 158BD OF THE ACT AND THIS BLOCK ASSESSMENT CAN BE C ONVERTED U/S. 158BD OF THE ACT. AS REGARDS TO ALTERNATIVE PLEA OF THE ASSESSEE, IF AT ALL, ANY ASSESSMENT COULD BE MADE IN RESPECT OF 5 ITSSA 119/K/2008 SMT. MANJU PODDAR B.P.1.4.1988 TO 21.12.1998 UNDISCLOSED INCOME THAT COULD BE MADE ONLY U/S. 158 BD OF THE ACT AFTER SATISFYING CONDITIONS AS LAID DOWN IN SECTION 158BD OF THE ACT. ANY BLOC K ASSESSMENT IN ABSENCE OF SATISFACTION RECORDED, AS MENTIONED IN SECTION 158BD OF THE ACT IS A NULLITY IN VIEW OF THE DECISION OF HONBLE SUPREME COURT IN THE CASE OF MANISH MAHESWA RI VS. ACIT 289 ITR 324 (SC) WHEREIN HONBLE SUPREME COURT HAS HELD AS UNDER: THE CONDITION PRECEDENT FOR INVOKING A BLOCK ASSES SMENT IS THAT A SEARCH HAS BEEN CONDUCTED UNDER SECTION 132, OR DOCUMENTS OR ASSETS HAVE BEEN REQUISITIONED UNDER SECTION 132A. THE SAID PROVISION WOULD APPLY IN TH E CASE OF ANY PERSON IN RESPECT OF WHOM SEARCH HAS BEEN CARRIED OUT UNDER SECTION 132A OR DOCUMENTS OR ASSETS HAVE BEEN REQUISITIONED UNDER SECTION 132A. SECTION 158BD, H OWEVER, PROVIDES FOR TAKING RECOURSE TO A BLOCK ASSESSMENT IN TERMS OF SECTION 158BC IN RESPECT OF ANY OTHER PERSON, THE CONDITIONS PRECEDENT WHEREFOR ARE: (I) SATISFACTION MUST BE RECORDED BY THE ASSESSING OFFICER THAT ANY UNDISCLOSED INCOME BELONGS TO ANY PERSON, OTHER THAN THE PERSON WITH RESPECT TO WHOM SEARCH WAS MADE UNDER SECTION 132 O F THE ACT; (II) THE BOOKS OF ACCOUNT OR OTHER DOCUMENTS OR ASSETS SEIZED OR REQUISITIONE D HAD BEEN HANDED OVER TO THE ASSESSING OFFICER HAVING JURISDICTION OVER SUCH OTH ER PERSON; AND (III) THE ASSESSING OFFICER HAS PROCEEDED UNDER SECTION 158BC AGAINST S UCH OTHER PERSON. THE CONDITIONS PRECEDENT FOR INVOKING THE PROVISION S OF SECTION 158BD. THUS, ARE REQUIRED TO BE SATISFIED BEFORE THE PROVISIONS OF T HE SAID CHAPTER ARE APPLIED IN RELATION TO ANY PERSON OTHER THAN THE PERSON WHOSE PREMISES HAD BEEN SEARCHED OR WHOSE DOCUMENTS AND OTHER ASSETS HAD BEEN REQUISITIONED U NDER SECTION 132A OF THE ACT. WE FIND THAT THE CIT(A) HAS CATEGORICALLY RECORDED A FINDING THAT NO SATISFACTION WAS EVER RECORDED FOR ISSUANCE OF NOTICE U/S. 158BD OF THE A CT AND BLOCK ASSESSMENT WAS FRAMED U/S. 158BC OF THE ACT. FURTHER, THE CIT(A) HAS ALSO RECO RDED THE FACT THAT AS FAR AS THE ASSESSEE MRS. MANJU PODDAR IS CONCERNED, PROCEEDINGS CAN BE INITI ATED U/S. 158BC OF THE ACT AS IF THERE WERE SEARCH U/S. 132 OF THE ACT AGAINST HER AS ON 05.01. 1999 IN RESPECT OF LOCKER NO. 1224 BUT THE BLOCK ASSESSMENT ORDER WITH THE BLOCK PERIOD ENDING AS ON 05.01.1999 CAN ONLY BE AT NIL BECAUSE THERE IS NO EVIDENCE FOUND DURING THE COURS E OF SEARCH AS THE LOCKER WAS EMPTY. THERE IS NO NOTICE U/S. 158BC OF THE ACT CALLING FOR BLOC K RETURN FOR THE BLOCK PERIOD ENDING AS ON 05.01.1999 WHEREAS THERE IS NO SEARCH TOOK PLACE AS ON 21.12.1998. IN THE BLOCK ASSESSMENT ORDER ALSO THE AO DOES NOT INDICATE THAT HE HAS FOU ND ANY EVIDENCE INDICATING THAT THE ASSESSEE HAD UNDISCLOSED INCOME SO THAT HE CAN INVOKE THE PR OVISIONS OF SECTION 158BD OF THE ACT. THE CIT(A) ALSO EXAMINED THE BLOCK ASSESSMENT RECORDS O F SHRI ASHOK KR. PODDAR AND SHRI RAJ KR. PODDAR AND FOUND THAT IN NONE OF THESE CASES PROVIS IONS OF SECTION 158BD OF THE ACT HAVE BEEN INVOKED AGAINST THE ASSESSEE MRS. MANJU PODDAR. WE FIND THAT IN ORDER TO USE MATERIAL FOUND DURING THE COURSE OF SEARCH IN THE CASE OF ANY OTHE R PERSON FOR DETERMINING UNDISCLOSED INCOME OF THAT ANOTHER PERSON WHO WAS NOT SEARCHED, IT IS NECESSARY TO INVOKE SECTION 158BD OF THE 6 ITSSA 119/K/2008 SMT. MANJU PODDAR B.P.1.4.1988 TO 21.12.1998 ACT, HERE IN THE PRESENT CASE IS TOTALLY ABSENT. I N SUCH CIRCUMSTANCES, WE ARE OF THE VIEW THAT THE CIT(A) HAS RIGHTLY ANNULLED THE ASSESSMENT AND WE CONFIRM THE SAME. APPEAL OF REVENUE IS DISMISSED. 7. IN THE RESULT, THE APPEAL OF REVENUE IS DISMISSE D. 8. ORDER PRONOUNCED IN THE OPEN COURT ON 25 TH OCT., 2012. SD/- SD/- . . !' , (C. D. RAO) (MAHAVIR SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER ( ' ' ' ') )) ) DATED : 25TH OCTOBER, 2012 ./ $01 2 JD.(SR.P.S.) 7 ITSSA 119/K/2008 SMT. MANJU PODDAR B.P.1.4.1988 TO 21.12.1998 !- 3 +4 5!4&6- COPY OF THE ORDER FORWARDED TO: 1 . )* / APPELLANT ACIT, CC-XXII, KOLKATA 2 +,)* / RESPONDENT SMT. MANJU PODDAR, 8B/1, SATYAM TOWE RS, 3, ALIPORE ROAD, KOLKATA-27. 3 . -$ ( )/ THE CIT(A), KOLKATA 4. 5. -$ / CIT KOLKATA 4<= +$ / DR, KOLKATA BENCHES, KOLKATA ,4 +/ TRUE COPY, !-$>/ BY ORDER, 1 /ASSTT. REGISTRAR .