INCOME TAX OFFICER, WARD 44 2, KOLKATA vs. RAJESH KUMAR JALAN, HOOGHLY

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA Before Shri Rajesh Kumar, Accountant Member and Shri Pradip Kumar Choubey, Judicial Member ITA No.2048/2049/2050/2051/Kol/2024 Assessment Year: 2013-14& 2014-15, 2015-16& 2016-17 INCOME TAX OFFICER ………………………….………………………….Appellant WARD 44-2 3, GOVT. PLACE (WEST), KOLKATA- 700001 [PAN No. AMKPJ4084B] Vs. Rajesh Kumar Jalan…………..……………………..…………….………... Respondent, 161/1, M.G. Road, Burrabazar, Kolkata- 700007 Appearances by: Shri S.K. Tulsiyan, Advocate, and Puja Somani CAappeared on behalf of the Appellant. Smt Monalisa Pal Mukherjee, Sr. DR ,appeared on behalf of the Respondent. Date of concluding the hearing : June10, 2026 Date of pronouncing the order : June 26 ,2026 ORDER Per Pradip Kumar Choubey, Judicial Member: These are the appeals filed by the Revenue is directed against the order dated 02.08.2024 of the National Faceless Appeal Centre (NFAC) passed under Section 147/144 of the Assessment Year 2013-14 to 2016-17 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”).

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 sarees. The assessee also received rental income from leased hotel in AY 2016-17.The assessee is furnishing income under presumptive taxation scheme under section 44AD of the Act. Therefore, no books of accounts were maintained by the assessee.On 01.04.2016 the Assessee randomly received certain information from Commercial Tax Authorities that he had by the fraudulent act of opening seven bank accounts under five alleged proprietary concerns received total amount of Rs. 1,12,41,47,898/- over the years tabulated below:-

Financial Year Assessment Year Amounts received (Rs.) 2012-13 2013-14 Rs. 7,77,42,891/- 2013-14 2014-15 Rs. 31,96,40,21/- 2014-15 2015-16 Rs. 30,03,78,690/- 2015-16 2016-17 Rs. 42,63,85,896/- TOTAL Rs. 1,12,41,47,898/-

The impugned 7 Bank A/cs are as follows: S.No Name of Branch A/c No Name of the the Bank organization 1. IDBI Bank Brabourne 0060102000139274 M/s KL Road Enterprised

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 2. Federal Rabindra 16230200007883 Bank Sarani 3. Indusind Burrabazar 200999284782 M/s. Bank Sampurna Traders 4. Canara Birrabazar 1392201980153 M/s. Naina Bank International 5. Indusind Burrabazar 200999296494 M/s. Keswani Ban Enterprises 6. Indusind Burrabazar 200004740517 M/s. Gobinda Bank Trading 7. HDFC Bank India 02192000029922 M/s. Eastern Exchange Engineering Place Corporation

Thus, the sum of Rs. 1,12,41,47,898/- for these four assessment

years was held to be Suppressed Sales of the Assessee by the

Commercial Tax Authorities of State of West Bengal.

located the suppressed sales as turnover of the assessee and

applied a profit rate of 8% and estimated the income. The net

addition was made after allowing the reduction towards the

income already declared by the assessee.

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 Aggrieved by the said order, assessee preferred appeal before the CIT(A) wherein all the appeal of the assessee has been allowed.

(i) Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made by AO to the tune of Rs.57,20,959/- as shortfall of Profit for the A.Y. 2013-14 ignoring the circumstantial evidence brought on record by the A.O. that the entire amount credited to the bank account of the assessee is actual turnover of the assessee for the A.Y. 2013-14.

(ii) Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made by AO based on the submission of the assessee ignoring the report of the Commercial Tax Authorities and in absence of any enquiry report of Police Authority in support of the claim of the assessee.

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 iii) Whether on the facts and circumstances of the case and in law the order of the Ld. CIT(A) suffers from perversity as it ignores the facts brought on record by the Assessing Officer establishing the fact that the assessee has not discharged the burden of proof lies on him with the aim to evade tax.

(iv) Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made by AO by following the decision of Hon'ble ITAT in the assessees case for the A.Y. 2015-16 & 2016-17 where the judgement was not rendered through analysis and adjudication of the factual issues involved in this case.

(v) The appellant craves leave to add further grounds or alter the grounds at the time of hearing.

ITA No: - 2048 & 2049For the assessment year 2013-14 4. & 2014-15

For both the assessment year, appeal of the assessee has been allowed by the CIT(A) on the ground that the notice u/s 143(2) was not issued by the Ld. AO,and revenue has preferred appeal, so we have decided to adjudicate the issue by taking both

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 cases together. The ld. CIT(A) in allowing the appeal has held thus: -

9.1 The AO issued notice u/s 148 of the IT Act on 31-03-2021 for the AY 2013-14. The appellant submitted detailed facts claiming that he has neither received notice u/s 148 of the IT Act dated 31.03.2021 in his e-mail address nor any SMS in his registered Mobile. The remand report submitted by the AO on 25.01.2024 was totally silent on his contention. The appellant claimed that only on 30.09.2021, from the new E-filing Portal, he came to know about the notice issued u/s 148 of the IT Act and hence he has filed his return of income on 27-12-2021.

9.2 Once the appellant filed the return of income in response to the notice issued w/s 148 of the IT Act, the AO has to issue the notice u/s 143(2) of the IT Act. Not issuing notice u/s 143(2) of the IT Act in spite of receipt of return of income filed in response to notice issue u/s 148 of the IT Act would vitiate entire reassessment proceedings invalid. Hon'ble Supreme Court in the case of ACIT vs Hotel Blue Moon 321 ITR 362 (2010) has ruled the same and it has been followed in plethora of decisions.

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 9.3 In the present case no notice u/s 143(2) of the IT Act was issued. As the assumption of jurisdiction itself was not valid the assessment order passed w/s 147 rws 144B of the IT Act on 30- 03-2022 is not at all maintainable. The jurisdictional High Court in the case of Pr. Commissioner of Income Tax Vs Oberoi Hotels (P) Ltd [2018] in 96 taxmann.com 104 held the same by following the decision of Hon'ble SC supra The appellant has relied upon this decision in his written submission.

9.4 As the assessment order was passed without issuing of notice w/s 143(2) of the IT Act, the grounds raised by the appellant on assumption of jurisdiction is allowed.

In AY 2014-15the learned CIT(A) has allowed the appeal by holding thus: - Decision:

9.1 The AO issued notice u/s 148 of the IT Act on 31-03-2021 for the AY 2013-14. The appellant submitted detailed facts claiming that he has neither received notice u/s 148 of the IT Act dated 31.03.2021 in his e-mail address nor any SMS in his registered Mobile. The remand report submitted by the AO on 25.01.2024 was

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 totally silent on his contention. The appellant claimed that only on 30.09.2021, from the new E-filing Portal, he came to know about the notice issued u/s 148 of the IT Act and hence he has filed his return of income on 16-10-2021.

9.2 Once the appellant filed the return of income in response to the notice issued u/s 148 of the IT Act, the AO has to issue the notice u/s 143(2) of the IT Act. Not issuing notice u/s 143(2) of the IT Act in spite of receipt of return of income filed in response to notice issue w/s 148 of the IT Act would vitiate entire reassessment proceedings invalid. Hon'ble Supreme Court in the case of ACIT vs Hotel Blue Moon 321 ITR 362 (2010) has ruled the same and it has been followed in plethora of decisions.

9.3 In the present case no notice u/s 143(2) of the IT Act was issued. As the assumption of jurisdiction itself was not valid the assessment order passed w/s 147 rws 144B of the IT Act on 30- 03-2022 is not at all maintainable. The jurisdictional High Court in the case of Pr. Commissioner of Income Tax Vs Oberoi Hotels (P) Ltd [2018] in 96 taxmann.com 104 held the same by following the decision of Hon'ble SC supra. The appellant has relied upon this decision in his written submission.

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 9.4 As the assessment order was passed without issuing of notice u/s 143(2) of the IT Act, the grounds raised by the appellant on assumption of jurisdiction is allowed.

ITA NO,-2050&2051/KOL/2025 for the AY 2015-16 and 6. 2016-17

In both the assessment year, issues are common hence taken up together for disposal by taking a lead case of 2050/25.For the present assessment year, Ld. AO has passed an order which is as follows: -

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 “8. As discussed, the total payment of Rs. 43,08,96,425/- (Rs. 42,63,85,896 + Rs. 45,10,529) received during the financial year 2015-16 is taken as total turnover of the assessee. The assessee has filed return u/s. 44AD shown net profit @ 8% in the return. Therefore, net profit is computed @ 8% on total turnover which comes to Rs. 3,44,71,714/-. Since the assessee already showed net profit of Rs. 4,81,690/- in his return of income, remaining income of Rs. 3.,39,90,024- (Rs. 3,44,71,714 (-) Rs. 4,81,690? Is brought to tax as shortfall profit.” 7. Aggrieved by the said order, assessee preferred appeal before the CIT(A) wherein appeal of the assessee has been allowed by the CIT(A) by observing thus:- 10.4 It is to be mentioned here that, decision of Hon'ble ITAT dated: 12.06.2024 was informed by the AO in his letter dated: 23.07.2024 only. However, much before this decision, notice was issued to the AO on 01.04.2024, 20.04.2024, 22.04.2024 & 21.05.2024 by directing to carry out the enquiries on the veracity of the claim. However, the AO submitted a cryptic Remand Report on 30.05.2024 stating that the appellant did not comply to the notice issued by the

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 AO and hence he could not verify his claim. That Remand Report is already reproduced in para 8 of this order. 10.5 It is to be mentioned here that on the basis of Commercial Tax Department advice the appellant filed the complaint with local police station. This fact is recorded in the assessment order. Hence, the AO was also asked to obtain the status of Investigation carried out by the Commercial tax department who have shared the information to the Income Tax Department. To this letter also, the AO replied that he has issued some letters to Commercial Tax Department whereas they have not responded to his notice. 10.6. In view of the detailed discussion made above, it is concluded that the AO blindly followed the report of Commercial Tax Department and treated that the appellant suppressed turnover of nearly Rs.112,41,47,898/- in all the 4 assessment years without carrying out any independent verification. As per the records, the Commercial Tax Department has shared this information with the Investigation Wing of the Department in the year 2018 and the assessment was reopened much later. In all these years, no independent verification has been carried out by any

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 officer on the claim of the appellant filed before them. Hon'ble ITAT, Kolkata in its order dated: 12.06.2024, has also rightly held that the AO failed to carry out any such independent verification on the claim of the appellant by deputing his Inspector or on his own motion. The decision of Hon'ble ITAT is rendered only on 12.06.2024. Much before this decision the appeal proceedings are commenced in the case of the for the AY 2013-14 to 2016-17. The AO was given several opportunities to verify the veracity of his claim. However, no such verification was carried out by the AO. On the other hand, the appellant submitted sufficient material evidences including copies of FIR and claimed that, the sales turnover informed by the Commercial Tax Department to the Income Tax Department was not pertaining to him. When the appellant placed all these evidences, the AO ought to have verified such claim by conducting necessary enquiries. In the present case, no such attempt was made by the AO. 10.7 By respectfully following the decision of Hon'ble ITAT, Kolkata and the material evidences placed by the appellant, it is noticed that the claim of the appellant could not be disproved otherwise. Hence, attributing the sales turnover of

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 various concerns to the appellant and estimating profit on those sales by the AO in the reassessment order is not maintainable. Hence, even on merit the appeal is allowed. 8. The Ld. DR challenged the very impugned order thereby submitting that Ld. CIT(A) erred in holding the addition made by the AO to the tune of Rs. 2,39,49,389/- as shortfall profit for the assessment year 2015-16 ignoring the circumstantial evidence brought on the record by the AO that the entire amount credited to the bank account of the assessee is actual turnover of the assessee for the assessment year 2015-16. The Ld. DR further submits that Ld. CIT(A) erred in deleting the addition made by the AO by following the decision of the Hon’ble ITAT in the assessee’s case for the assessment year 2015-16 and 2016-17 where the judgment was not rendered through analysis and adjudication of the factual issue involved in this case. 9. Contrary to that Ld. AR supports the impugned order thereby submitting that the Ld. CIT(A) has passed order on the basis of the order passed by the Tribunal in ITA No. 254 & 255/KOL/2024 as the assessee preferred appeal before the Hon’ble ITAT KOL against the order passed by the

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 Hon’ble PCIT u/s 263 of the Act for the same assessment year that is for the assessment year 2015-16 & 2016-17. The Ld. AR submits that the Hon’ble ITAT vide its judgment dated 12.06.2024 passed in ITA No. 254 and 255/KOL/24 has quashed the order passed u/s 263 of the IT Act in assessee’s own case. The Ld. AR further submits that the order passed by the ITAT in ITA No. 254 & 255/24 has been placed by the Revenue before the Hon’ble High Court Kolkata and Hon’ble High Court of Kolkata vide its judgment dated 03.07.2025 dismissed the appeal of the revenue. It has further been submitted that CIT(A) after following the decision of the Hon’ble ITAT Kol. passed the order in favour of the assessee and there is no infirmity in the impugned order. 10. Upon hearing the submission of the counsel of the respective parties and on perusal of the impugned order, we find that assessee received information from commercial tax authorities that he had by the fraudulent act of opening seven bank accounts.The assessee denied the opening of any of the bank accounts and he provided documentary evidences before the commercial/sales tax authorities and

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 also filed a pools complaint to the officers In-charge of the local PS with a request to investigate the matter. We further find that Assessing Officer ignoring the fact as well as documents filed by the assessee passed an assessment order and assessee preferred appeal before the CIT(A). Meanwhile the assessee preferred appeal before the Hon’ble ITAT Kol. against the order passed by the Hon’ble PCIT u/s 263 of the Act for AY 2015-16 and 2016-17 dated 14-12- 2023 and 15-12-2023 respectively on the sole ground that the learned AO erred in adding only 8% of the total receipts as per the information of the Sales Tax Authorities instead of adding the entire receipts credited in the impugned bank accounts which has made the assessment order erroneous and prejudicial to the interest of the revenue. The Hon'ble ITAT vide its judgment dated 12-06-2024 held thus:- 20. It is pertinent to observe that at the first instance, the assessee submitted that he has not opened any bank accounts, rather somebody has personated him. His case is based on the issue that his IDs have been misused and some unknown person has carried out these transactions in his name. He could only know

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 about this when he received information from Sale Tax Authorities, Bureau of Investigation, Commercial Taxes. He pleaded this stand before those agencies also, but none of the agencies has culminated the inquiry into a positive finding. Nobody has recorded a specific finding that this plea of the assessee is false. We have taken note of the show-cause notice issued by the ld. Commissioner in paragraph no. 4.2 reproduced (supra) and after the show-cause notice, the finding of the ld. Commissioner is that the assessee was asked to submit his audited balance-sheet, books of account for A.Ys. 2014-15 and 2015-16 along with proof of vouchers/invoices in original, purchases and sales. He further observed that the assessee was asked to appraise about the status of the complaint lodged by him in Konnagar Police Station. Thereafter he recorded the finding that the assessee failed to give anything. To our mind, this cannot be expected from a Senior Officer of the Income Tax Department to put somebody under the Tax liability without concluding the finding. He ought to have issued notice to the Police Authorities as well as

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 to the Commercial Tax Investigating Authorities for submission of their report. He ought to have first determined whether these accounts belong to the assessee, only thereafter taxability of the amounts available in those accounts would have fallen upon the assessee. 21. A perusal of the impugned orders would reveal that neither the ld. CIT has applied his mind analytically while assuming jurisdiction for taking cognizance under section 263. We have specifically noticed that details in paragraph no. 17 of this order and we find that after narrating the facts, Id. CIT just observed on verification of the record, it is found that the amount of Rs.42.14,37,039/- was to be added and taxed instead of 8%, hence underassessment occurred. which is adverse to the revenue. We failed to appreciate, which aspect was verified by him because he has just reproduced the proposal sent by the Additional CIT, Circle-43. There is no independent application of mind at his end for taking cognizance under section 263. 21.1. Apart from the above. while dealing with explanation of

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 assessee in paragraph no. 4.3 of the impugned order, we find that ld. CIT has not recorded any finding. He just put the blame on the assessee to prove a negative aspect. It is for the revenue to first determine that these accounts belong to the assessee. Once the assessee has been emphasizing that these accounts do not belong to him and he has lodged a FIR in such situation, there should be adjudication of this aspect but ld. CIT simply ignored this aspect under the garb that the assessee failed to substantiate this issue. It cannot be substantiated by the assessee. It is to be investigated by the ld. Assessing Officer or by the Id. CIT. The role of the id Assessing Officer is not only a prosecutor but he has to play a role of an adjudicator. That very role has to be played by the Id. Commissioner while exercising the powers under section 263. 22. We could have set aside to the issue to ld. CIT for recording a categorical finding on this fold of issue but for the reasons to be recorded by us in the subsequent paragraph, we do not deem it necessary to set aside this issue.

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 23. As observed earlier, we have construed the meaning of clause (c) of section 263(1). The Id. CIT in the present proceeding has treated the assessment orders as erroneous and prejudicial to the interest of the revenue, but failed to note that these assessment orders are challenged before the la. CIT(Appeals). The assessee has been disputing before the ld. Ist Appellate Authority that these accounts do not belong to him. It is yet to be decided whether these accounts belong to the assessee and additions made by the Id. Assessing Officer at 8% of the alleged gross turnover is sustainable or not. In other words, it is a subsequent stage whether the total amounts credited to the accounts deserve to be treated as cash credit of the assessee or not. This issue is pending before the Id. CIT(Appeals). It is directly linked to the issue taken up in 263 proceedings. The Id. Ist Appellate Authority has co-terminus powers of the Id. Assessing Officer if it is felt that the total amount deserves to be considered as an unexplained credit of the assessee, then, that aspect could be looked into by

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 the Id. Ist Appellate Authority and no revisionary power ought to have been exercised on that aspect. 24. It is also pertinent to note that a poor fellow, who has been returning income of Rs.4,33,403/-and Rs.5,01,272/-, all of a sudden assume as owner of more than Rs.1 12 crores, before drawing such type of inference, at least a local Commissioner or Inspector or could have been deputed to verify the level of living of the assessee. It ought to have been determined whether he owns such type of properties or his trading business of that magnitude. We hope all analysis would be looked into by the Id. 1st Appellate Authority while adjudicating the appeals of the assessee against the assessment orders. But we are of the view that these impugned orders are not sustainable because the same very issue is subject matter of appeal before the Id. CIT(Appeals). Before we part with this order, it is observed that Id. Commissioner has confirmed the additions on merit in the present orders. Since we have observed that this issue is pending in appeals before the ld. CIT(Appeals) and Id. CIT(Appeals) could consider all possible aspects,

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 therefore, this order would not impair or injure the explanation of the assessee and would not cause any prejudice to the interest of the ld. Assessing Officer. This finding is confined to the legality of orders passed under section 263 and we have not expressed our mind on the merits of the issue whether the alleged unexplained sales turnovers are to be treated as a cash credit or not. With the above observations, we allow both the appeals and quash both the orders passed under section 263 of the Income Tax Act in both the years.

“The short issue which falls for consideration is whether the learned Tribunal was right in allowing the assessee's appeal and setting aside the order passed by the Commissioner under section 263 of the Act. The order passed by the learned Tribunal is an elaborate order wherein all the factual issues have been thoroughly dealt with apart from noting the legal position. The assessee's consistent case was that he had not opened any bank account 21

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 rather somebody else impersonated him by using his identity card and he came to know of it when he received information from the Sales Tax Authority, Bureau of Investigation, Commercial Taxes. Though such a stand was pleaded before those agencies none of the agencies has undertaken an inquiry or rendered any finding on the said aspect. The learned Tribunal faulted the department for not issuing the notice to the police authorities or to the Commercial Tax Investigating Authority and calling for a report. It was specifically noted that while dealing with the assessee's explanation to the show cause notice the Commissioner has not recorded any finding rather shifted the onus on the assessee to prove the negative. The learned Tribunal rightly held that the revenue has to first determine as to whether the bank account belonging to the assessee, more particularly when he has been emphasizing that the bank account do not belong to him and he has lodged an FIR with the police authorities. This aspect has been ignored by the Commissioner while exercising power under section 263 of the Act, more importantly, when the assessee filed the report to the show cause notice they had specifically pleaded that as against the assessment order appeal had been filed before the Commissioner of Income Tax (Appeals) andcopy of the appeal

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 memorandum was annexed to the reply. In such circumstances, the Commissioner could have Invoked the power under section 263 of the Act as there is a completewhen an appeal is pending against an order of assessment. That apart, we find that the department has not undertaken any exercise to determine as to whether who is the actual account holder and who else is the proprietor and who is conducting trading business of such magnitude. That apart, all the issues which were subject matter of the 263 proceeding, was pending at the relevant point of time before the Commissioner of Income Tax (Appeals). With these reasoning the assessee's appeal was allowed by the Tribunal. After the order was passed by the learned Tribunal the appeal filed by the assessee before the Commissioner of Income Tax (Appeals) has been allowed and the said order has become final. Apart from that the assessing officer reopened the assessment and an assessment order was passed under section 147 of the Act. which was appealed against and the said appeal has also been allowed in favour of the assessee and the department has not challenged the said order and the same attained finality. Copy of the order passed by the appellate authority has been placed before us for consideration.

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 12. It is important to mention here that assessee has taken a consistent stand that the impugned bank accounts are never opened by him nor did they belong to the assessee. The stand of the assessee was that said bank account were opened by some fraudulent person using his false Pan against which assessee has filed an FIR before the police authority.Considering the above facts and in view of the judgment of the Hon’ble High Court of Kolkata in the assessee’s own case, it is clear that Ld. Assessing Officer failed to undertake any inquiry to check whether the assessee had opened any bank account or somebody else has impersonated him by using his identity card. The Ld. CIT(A) in its order has discussed the issue at length and after following the verdict passed by the ITAT in the assessee own case u/s 263 allowed the appeal of the assessee.

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16 Kolkata, the 26th June, 2026.

Sd/- Sd/- [Rajesh Kumar] [Pradip Kumar Choubey] Accountant Member Judicial Member Dated:. 26.06.2026. DC, PS

Copy of the order forwarded to: 1. Appellant - 2. Respondent - 3. CIT(A)- 4. CIT- 5. CIT(DR)

//True copy// By order Assistant Registrar, Kolkata Benches

ITA No.2048& 2049 & 2050 & 2051/Kol/2024 Assessment Year- 2013-14/15/16