DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. N C SHAW AND CO BEVERAGES PRIVATE LIMITED , KOLKATA

IN THE INCOMETAXAPPELLATE TRIBUNAL “C” BENCH, KOLKATA Before ShriRajesh Kumar, Accountant Member and ShriPradip Kumar Choubey, Judicial Member ITA No./1798KOL/2025 Assessment Year: 2022-23 / DCIT, CENTRAL CIRCLE-4(3),............................................................................Appellant Aayakar Bhawan Poorva, 110. Shantipally, Kolkata-= 700107 [PAN No. AABCN8699N] Vs. NC SHAW AND CO BEVERGES,..…………..…………………....……….Respondent PRIVATE LIMITED, Kolkata P-45 Goragache Road, Goragacha Road Taratala Koklata 700053 Appearances by: Shri Miraj D. Shah, Advocate, appeared on behalf of the Appellant. Shri Soumitra Ghosh, Addl. CIT, Sr. DR ,appeared on behalf of the Respondent. Date of concluding the hearing :April 2, 2026 Date of pronouncing theorder : April 21 ,2026 ORDER Per Pradip Kumar Choubey, Judicial Member: This appeal filed by the Revenue is directed against the order dated 13.04.2025 of the office of The Commissioner of Income Tax Appeal passed under Section 143(3)r.w.s260 of the Assessment Year 2022-23 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”).

At the very outset, it appears from the report of the registry that appeal of the revenue has been filed after a delay of eight days and for this a petition to condone the delay has been filed by the revenue. Going over the contention made in the petition, we find the reasons are bona fide and genuine and accordingly, we condoned the delay.

ITA No.1798/Kol/2025 Assessment Year- 2022-23 2. The facts of the case are that a search and seizure operation u/s 132(1) of the Act was conducted in respect of 'Golden Goenka group of assessee’s on 18.12.2021 by the directorate of Income Tax (Investigation), UP & Uttarakhand. The assessee was also covered in the said search & seizure operation. Subsequent to the search operation, the case of the assessee was centralized to the Central Circle 4(3), Kolkata and jurisdiction of the assessee was also transferred to the Central Circle 4(3), Kolkata by order u/s 127 of the higher authority. Further, the assessee filed its original return of income u/s 139 of the Act on 20.10.2022 declaring total income of Rs. 13,29,750/-. The return was processed u/s 143(1) of the Act on 04.11.2022 at total income of Rs. 13,29,750/-. Being the year of the search, return of the instant year was selected for compulsory scrutiny and notice u/s 143(2) of the Act was issued on 31.05.2023. Thereafter, notice u/s 142(1) of the Act along with detailed questionnaire was also issued on 29.08. 2023. The assessee complied these notices and submitted documents/details & explanation which were perused by the AO and placed in record. In consideration to the assessee reply and available materials, the AO passed the assessment order u/s 143(3) of the Act on 22.03.2024 at assessed total income of Rs. 54,62,996/-. In this assessment order total addition of Rs. 41,33,246/- was made wherein Rs. 20,00,000/- was added as unexplained cash credit u/s 68 of the Act for in-genuine unsecured loan and relatable interest paid to the amount of Rs. 21,33,246/- was disallowed u/s 36(1)(ⅲ) of the Act. Further, the assessee challenged the said assessment order u/s 143(3) of the Act dated 22.03.2024 before the Hon'ble Calcutta High Court vide Writ Petition No. 292/2024 on the ground of 'principle of natural justice. The Hon'ble Court has pronounced the judgment on 08.04.2024 wherein the impugned assessment order was set aside and

ITA No.1798/Kol/2025 Assessment Year- 2022-23 remanded back to the assessing officer concerned to pass the fresh assessment order.

In pursuance to the order of Hon'ble High Court Calcutta, fresh assessment proceeding was initiated and the assessee has filed a letter of objection on 08.05.2024. In the course of fresh assessment proceeding, the assessee was allowed with opportunity of being heard vide letter dated 16.05.2024 and objections raised by them are disposed thereof. In consideration to the fact and circumstances of the case, the AO passed the assessment order u/s 143(3) r.w.s 260 the Act on 26.06.2024 assessing the total income to Rs. 71,62,996/-, It is observed from the assessment order that the AO has made following additions in the assessment order dated 26.06.2024: -

SI NO. Addition made u/s Addition amount Details (Rs.)

In the order u/s 143(3) of the Act dated 22.03.2024, the AO made the total addition of Rs. 41,33,246/- however in the order u/s 143(3) r.w.s 260 of the Act dated 26.06.2024 the AO made total addition of Rs. 58,33,246/-. As a result, the assessed income was also enhanced by Rs. 17,00,000/- (From Rs. 54,62,996/- to Rs. 71,62,996/-) due to the addition of unreported in-genuine unsecured loan of Rs. 17,00,000/-

ITA No.1798/Kol/2025 Assessment Year- 2022-23 CIT(A), the relevant portion of the order of CIT(A) is essential to reproduce here in below: -

6.2.5 The AO has added Rs. 17,00,000/- as disallowance of loan by stating that this credit is not available in loan confirmation. During the course of appellate proceeding, the director of the assessee company Smt. Raj Goenka filed a letter stating that the assessing officer did not make any enquiry from the assessee company and thus he had failed to appreciate that the said sum of Rs. 17,00,000/- was received by another group entity viz. N.C. Shaw and Co. (PAN: AACFN2348E) duly reported in the books of the said entity. The said alleged unreported credits of Rs. 17,00,000/- does not pertain to the assessee company (PAN: AABCN8699N; M/s N.C Shaw & CO. Beverages Private Limited). The necessary documents viz, bank statements, ledger copy of the said Mis N.C.Shaw and Co. (PAN: AACFN2348E) supports the said contention is attached herewith. Hence, the addition of Rs. 17,00,000/- on account of unreported credit does not belong to the assessee. Therefore, the addition of Rs. 17,00,000/- is deleted.

6.2.6. Further the AO has referred to certain historical transactions pertaining to the Loan unrelated transactions have no connection whatsoever with the legitimate and disclosed transactions executed by the assessee in AY 2022-2023 set principle of law that each assessment year is an independent unit, and allegations or findings pertaining to a deterrent period cannot be automatically extended to subsequent assessment years w independent verification and substantiation. The AO has neither established any direct or Indirect link between the assessee's transaction and the alleged irregularities concerning the creditors nor provided any tangible evidence to support the claim that the transaction in question is dubious. Moreover, the AO has failed to controvert the following critical established aspects:

ITA No.1798/Kol/2025 Assessment Year- 2022-23 Identity of the Creditor: The identity of the lender companies is established through statutory documentation and transaction records.

Genuineness of the Transaction: The transaction in question is duly supported by proper documentation, banking channels, and confirmations from the creditors and most important factor is the refund of the loans.

Creditworthiness of the Creditor: The Creditors has sufficient own capital and bee reserves/net worth and thus there is no reason to doubt their creditworthiness. No evidence has been provided to dispute the financial capacity of the creditors during the relevant period

6.2.12. During the course of assessment proceedings, the appellant produced the evidences of loan repayment in respect of all the four concerns. The appellant has produced/filled copies of bank statements to establish that the loans were repaid through banking channels in the same and subsequent years.

6.2.13. All the above discussions established the fact that the loans from the said two companies were given from the creditors disclosed bank accounts, and were received in the disclosed bank account of the Appellant. These loans were duly reflected in the assessee's books of account and the said loans were also repaid through banking channels which were duly recorded and reflected. These facts have not been disputed by the AO. With respect to the repayment the AO has raised a doubt in the assessment order that the assessee did not show the source of the repayment of loan. In this regard I find that the entire books of accounts and bank statement etc were before the AO in the assessment proceedings, further the AO has not raised any query or conducted any inquiry with respect to source of repayment of loan. I have examined the statutory notices issued by the AO under section 143(2) and 142(1) of the Act and I find that nowhere in 5

ITA No.1798/Kol/2025 Assessment Year- 2022-23 the said notices the AO has sought details in respect of the source of repayment of loan though details were sought about the repayment of loan. It is a matter of record that an Assessment Order dated 22/03/2024 was initially passed, in the case of the Assessee Company, under section 143(3) of the Act wherein the loan credits received from one loan creditors, and related interest expenses, were added as unexplained cash credit under Section 68 of the Income Tax Act, 1961. The said Assessment Order was challenged before the Hon'ble Calcutta High Court in Writ Jurisdiction and the Hon'ble High Court remanded the matter back to AO with a direction to pass fresh assessment order after considering the reply to be filed by the petitioner against the impugned assessment order by treating the said Assessment Order dated 22/03/2024 as show cause notice. I have examined the said show cause notice/Assessment Order dated 22/03/2024 and I find that no query was ever raised in respect of the source of repayment of loan. Thus, the AO clearly travelled beyond the scope of Show Cause Notice/Assessment Order dated 22/03/2024 which stands in clear violation of the direction of Hon'ble Calcutta High Court. Even otherwise, it is a settled legal principle that if an allegation or ground is not made at the stage of show cause itself, it is not permitted for the authorities to create a new ground. In support of its contention, reference is made to the judgments of the Hon'ble Supreme Court in the case of Birla Corporation Ltd. v. CCE 2005 (186) E.L.T. 266/2005 taxmann.com 1293, Indian Oil Corporation Ltd. v. Collector of Central Ex. 2006 (202) E.L.T. 37/2006 taxmann.com1514 (SC) and Boving Fouress Ltd. v. CCE 2006 (202) E.L.T. 389 (SC). I fail to appreciate that in absence of any query or inquiry by the AO from the assessee, how is the assessee expected to reply to the same. it is well settled in law that in absence of inquiry the AO cannot invoke Section 68 of the Act.

ITA No.1798/Kol/2025 Assessment Year- 2022-23 6.2.14. Furthermore, the fact remains that no addition has been made by AO in respect of the said admitted claim of repayment of loan and thus his attempt to negate the argument of repayment of loan is perverse. I refer to the binding judgment dated 17.12.2024 of the Hon'ble Calcutta High Court rendered in the case of PCIT vs Alom Extrusions Limited [ ITAT/268/2024] wherein the Hon'ble High Court has deleted the addition made of loan credits u/s. 68 of the Act by taking note of the fact of repayment of loan. I am supported in the said view by the judgment of Gujrat High Court in PCIT vs. Merrygold Gems (P.) Ltd.[2024] 164 taxmann.com 764 (Gujarat).

The CIT(A) has deleted that addition of Rs. 37,00,000 and also an amount of Rs. 21,33,246 by observing thus:-

6.2.21 I find that the facts of the instant case at hand is quite similar to the facts discussed by the Hon'ble jurisdictional High Court in the case of Principal Commissioner of Income-tax vs. Sreeleathers in [2022] 143 taxmann.com 435 (Calcutta) The its of t said case were:

a) The assessee-firm was engaged in business of trading/retaling of footwear and leather and non-leather accessories. It had filed its retum of income and same was selected for scrutiny. Subsequently, notices under sections 143(2) and 142(2) were issued on it.

b) The Assessing Officer noted that the assessee had received certain amount of unsecured loans from various companies out of which 13 companies were allegedly claimed to be paper companies. He thus made addition of amount of unsecured loans in the assessee's total income

c) The Commissioner noted that the assessee had furnished various documents to prove genuineness and creditworthiness of alleged paper companies however same was rejected by the Assessing Officer.

ITA No.1798/Kol/2025 Assessment Year- 2022-23 He thus held that it was not enough for the Assessing Officer to dismiss documents furnished by the assessee without consideration but rather should have recorded reasons in writing as to why these documents filed by the assessee did not go to establish the identity of the lender or prove the genuineness of the transaction. In the absence of any such finding, order passed by the Assessing Officer was held to be utterly perverse The Hon'ble High Court of Calcutta gave the following judgement:

This provision of sections deals with cash credits. It states that where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by hen is not in the opinion of the Assessing Officer, satisfactory, the sum so credited may be charged to income tax as the income of the assessee of that previous year. The crucial words in the said provision are 'assessee offers no explanation. This would mean where the assessee offers no proper, reasonable and acceptable explanation as regard the amount credited in the books maintained by the assessee. No doubt the burden of proof is on the taxpayer. However, this is only the initial burden. in cases where the assessee offers an explanation to the credit by placing evidence regarding the identity ofthe investor or lender along with their conformations, it has been held that the assessee has discharged the initial burden and, therefore, the burden shifts on the Assessing Officer to examine the source of the credit so as to be justified in referring to section 68. After the Assessing Officer puts the assessee on notice and the assessee submits the explanation with regard to the cash credit, the Assessing Officer should consider the same objectively before he takes a decision to accept or reject it. If the explanation given by the assessee shows that the receipt is not of income nature, the 8

ITA No.1798/Kol/2025 Assessment Year- 2022-23 department cannot convert good proof into no proof or otherwise unreasonably reject it. On the other hand, if the explanation is unconvincing, the same can be rejected and an inference shows that the amount represents undisclosed income either from a disclosed or an undisclosed source. The explanation given by the assessee cannot be rejected arbitrarily or capriciously, without sufficient ground on suspicion or on imaginary or irrelevant grounds

Further to be noted that where the assessee furnishes full details regarding the creditors, it is up to the department to pursue the matter further to locate those creditors and examine their creditworthiness. While drawing the inference, it cannot be assumed in the absence of any material that there have been some illegalities in the assessee's transaction. Thus, more importantly, the onus of proving that the appellant was not the real was on the party wha claims it to be so. Bearing the above legal principles in mind, in the instant case, it is clear that the Assessing Officer issued show cause notice only in respect of one of the lenders FGD. The assessee responded to the show cause notice and submitted the reply. The documents annexed to the reply were classified under 3 categories namely: to establish the identity of the lender, to prove the genuineness of the transactions and to establish the creditworthiness of the lender. The Assessing Officer has brushed aside these documents and in a very casual manner has stated that mere filing PAN details, balance sheet does not absolve the assessee from his responsibility of proving the nature of transaction. There is no discussion by the Assessing Officer on the correctness of the stand taken by the assessee. Thus, going by the records placed by the assessee, it could be safely held that the assessee has discharged his initial burden and the burden shifts on the Assessing Officer to enquire further into the matter which he failed to do. In more than one place the Assessing Officer used the expression 'money laundering. Such usage is

ITA No.1798/Kol/2025 Assessment Year- 2022-23 uncalled for as the allegations of money laundering is a very serious allegations and the effect of a case of money laundering under the relevant Act is markedly different. Therefore, the Assessing Officer should havedesisted from using such expression when it was never the case that there were any allegations of money laundering. Much reliance was placed on the statement of AKA which statement has been extracted in full in the assessment order and it cannot be disputed that there is no allegation against the assessee company in the said statement. There is no evidence brought on record by the Assessing Officer to connect the said entry operator with the loan transaction done by the assessee. Therefore, the statement is of little avail and could not have been the basis for making allegations.

The Assessing Officer ignored the settled legal principle and in spite of the assessee having offered the explanation with regard to the loan transaction, no finding has been recorded as regards the satisfaction on the explanation offered by the assessee. Therefore, the Assessing Officer ignored the basic tenets of law before invoking his power under section 68 Fortunately, for the assessee, the Commissioner (Appeals) has done an elaborate factual exercise, took into consideration, the creditworthiness of the 13 companies the details of which were furnished by the assessee. More importantly, the Commissioner noted that all these companies responded to the notices issued under section 133(6) which fact has not been denied by the Assessing Officer. On going through the records and the net worth of the lender companies, the Commissioner (Appeals) has recorded the factual findings that the net worth of those companies is in crores of rupees and they have declared income to the tune of Rs 45,00,000/- Therefore, the Assessing Officer if in his opinion found the explanation offered by the assessee to be not satisfactory, he should have recorded so with reasons. However, there is no discussion on the explanation offered by

ITA No.1798/Kol/2025 Assessment Year- 2022-23 the assessee qua, one of the lenders. Admittedly, the assessee was not issued any show cause notice in respect of other lenders. However, they are able to produce the details before the Commissioner (Appeals) who had rightly appreciated the facts and circumstances of the case. As pointed out earlier, the Assessing Officer brushed aside the explanation offered by the assessee by stating that merely filing PAN details, balance sheet does not absolve the assessee from his responsibilities of proving the nature of transactions. It is not enough for the Assessing Officer to say so but he should record reasons in writing as to why the documents which were filed by the assessee along with the reply does not go to establish the identity of the lender or prove the genuineness of the transaction or establish the creditworthiness of the lender.

In the absence of any such finding, it is held that the order passed by the Assessing Officer was utterly perverse and rightly interfered by the Commissioner (Appeais). The Tribunal re-appreciated the factual position and agreed with the Commissioner (Appeals). The tribunal apart from taking into consideration, the legal effect of the statement of AKA also took note of the fact that the notices which were issued by the Assessing Officer under section 133(6) to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal in the form of a paper book. These materials were available on the file of the Assessing Officer and there is no discussion on this aspect. Thus, the tribunal rightly dismissed the appeal filed by the revenue. (Para 5]

In the instant appeal also, the AO in spite of having all the requisite documents at his disposal failed to bring on record any reasons to justify his conclusion that the documents which were filed by the assessee along with the reply did not go to establish the identity of the lender or prove the genuineness of the transaction or establish the creditworthiness of the sander 11

ITA No.1798/Kol/2025 Assessment Year- 2022-23 Similarly, the decision of the Hon'ble Rajasthan High Court in the case of CITVs

AL Lalpuria Construction (P) Ltd (215 taxmann 12) is also found to be relevant to the present case where in also the addition made by the AO alleging unsecured loans to be in the nature of accommodation entry was held to untenable as it was based on unconfronted oral statement of third party which was obtained prior to the search conducted uls 132 of the Act upon the assessee. The Hon'ble Court observed that,

The assessee as alleged carried out construction activities and disclosed income from subcontract and investment in building construction. After the search U/s 132 of the Act, 1961 was carried out on 12-4-2005 in the case of another assessee M/s B. C. Purohit & Company at Jaipur & Kolkata, evidence was gathered and from the investigation if revealed that in the garb of tax consultation the owners and employees of this group were running the racket of providing accommodation entries of gifts, loans, share application money, share investment and long-term capital gains in shares. It will be relevant to record that the present assessee might have been in consultation with M/s B.C. Purohit & Company and a member of the group and has drawn inference regarding providing accommodation entries and the

ITA No.1798/Kol/2025 Assessment Year- 2022-23 assessing officer was of the view that details made available by the assessee as regarda unsecured loans and share application money, reference of which has been made in para-4 of its order, appears to be the accommodation entries and the present assessee was middle man and invoking Sec. 68 of the Act, it was considered to be part of the income in the hands of the assessee. However, on appeal preferred before the Commissioner(Appeals)by the assessee U/s 143(3) r/w 147 of the Act, 1961 all the factual statements were examined at length and the Commissioner (Appeals), after due appreciation of material which came on record, observed that from independent enquiry the copies of bank account were obtained by the assessing officer and found that for clearing of the cheques issued by these companies either cash was deposited in the same account or in another account of the group company in fact was M/s. B.C. Purohit of which the present assessee was considered to be one of the group member. However, it was further observed that summons issued U/s 131of the Act were served upon all such applicant/creditors and their confirmation letters were filed and the companies were assessed to tax being the private limited companies, the existence of their separate legal entity ordinarily could not have been doubted. However, on the basis of statement of Kripa Shanker Sharma which was recorded by the search authorities as regardsaccommodation entries, a sum of Rs. 5 Lacs was assessed in the hands of present assessee alone and as regards other income; it was not considered to be in the hands of the present assessee. Obviously, the department being aggrieved preferred appeal before the Tribunal and at the same time, the present assessee fled cross objection regarding part of the income, tothe extent of a sum of Rs. 5 Lacs, as being recorded in the hands of present assessee on the basis of statement of Kripa Shanker Sharma The Tribunal while appreciating the factual matrix came on record observed that after the summons were

ITA No.1798/Kol/2025 Assessment Year- 2022-23 issued U/s 131 of the Act, 1961 to the applicant/creditors and their confirmation letters were filed and the companies were assessed to tax being private limited companies the existence of their separate legal entity ordinarily could not have been challenged more so when the identity of existence of the investor is not disputed and accordingly upheld the view of Commissioner (Appeals), at the same time further observed that merely on the basis of oral statement of Kripa Shanker Sharma recorded before the search authorities thatthe assessee provided accommodation entries was not sufficient for the income to be assessed for a sum of Rs. 5 Lacs in the hands of the assessee and while allowing the cross objection filed by the assessee dismissed the appeal preferred by the revenue under order impugned.

We have heard the parties at length and of the view that what has been observed by the Commissioner (Appeals) & the Tribunal appears to be based on factual matrix and there appears no substantial question of law arises which may require interference by this Court to be examined in the instant appeal

Consequently, the instant appeals are wholly devoid of merit and accordingly stand dismissed."

In addition to the aforesaid binding judgment of Hon'ble Calcutta High Court in the case of PCIT vs Sreeleathers [2022] 143 taxmann.com 435 (Calcutta), I am supported in my views by the following binding judgments of Hon'ble Jurisdcitional Calcutta High Court:

CIT vs. Mis. Dataware Private Limited reported in 2011 (9) TMI 175 (CAL)

PCIT vs Alom Extrusions Limited [ITACT/268/2024, judgment dated 17.12.20241

ITA No.1798/Kol/2025 Assessment Year- 2022-23 PCIT vs Parwati Lakh Udyog [ITAT/2/2024, judgment dated 19.02.2024)

CIT v. Mitul Krishna Kapoor (ITA No. 333 of 2009, judgment dated 09.06.2016)

PCIT vs Coal Sale Co. Ltd. [ITAT/71/2022, Judgment dt. 29.07.2022]

CIT vs. Eastern Commercial Enterprises [1994] 210 ITR 103 (Cal)

of CIT(E) -vs- Mayapur Dham Pilgrim & Visitors Trust (2022) 214 DTR 441/328 CTR 984 (Cal)

CIT(E)-vs-Sanskriti Sagar [ITAT/46/2018 (GA No. 631 of 2018 dated 26.04.2022 (Cal))

6.2.22. In view of the above discussions and various judicial pronouncements the addition of loan made by the AO to the tune of Rs. 20,00,000/- as unexplained cash credit U/s 65 of the Act and unreported cash credit of Rs. 17,00,000/- (total Rs. 37,00,000/-) is deleted. As a result, total interest of Rs. 21,33,246/- (Rs. 12,96,693/- paid to Siri Salasar Suppliers Pvt Ltd. and Rs. 8,36.553/- paid to Mis Jajodia Finance Limited) disallowed u/s 36(1)(i) of the Act is also deleted. Hence, these grounds of appeal raised by the assessee are allowed.

ITA No.1798/Kol/2025 Assessment Year- 2022-23

ITA No.1798/Kol/2025 Assessment Year- 2022-23 in the present case there is an addition of Rs. 37,00,000/- on account of loan received by the Assessee. The assessee has submitted that assessee has discharged its onus and creditors having responded to notices U/s 131 of the Act. It is pertinent to mention here that assessee has filed following documentary evidences before the Assessing Officers to prove the loan being genuine one and further than loan has already been repaid. (i) lendor’s letter confirming its transaction with source of Fund. (ii) Loan confirmation (iii) Bank statemnet of the lender (iv) Audited financial of the lender (v) NBFC certificate issued by RBI (vi) income tax acknowlwdgement of the lender We further find that summons was issued to all the loan creditors and replies were received from them all the lender companies.In response to notices U/s 131 they duly submitted copies of audit accounts, bank statement, ITR filed for the relevant financial year, loan confirmation statements and source of funds. The Assessing Officer has failed to show any defect shortcoming in the details furnished before him. The identity of lender companies has been established through statutory documentation and transaction records.Transaction in question is duly supported by proper documentation, banking channels, and confirm from the creditors and most important factor is that refund of the loans. The creditor has sufficient own capital and free reserves/net worth, the CIT(A) in its order has discussed the documentary evidences as well as consider the

ITA No.1798/Kol/2025 Assessment Year- 2022-23 judgment passed by the Kolkata High Court. We do not find any infirmity in the impugned order.

Accordingly, the appeal of the Revenue is hereby dismissed.

Kolkata, the 21st April , 2026.

Sd/- Sd/- [Rajesh Kumar] [Pradip Kumar Choubey] Accountant Member Judicial Member

DC Dated:. 21. 04.2026.

Copy of the order forwarded to: 1. Appellant - 2. Respondent - 3. CIT(A)- 4. CIT- 5. CIT(DR) 0

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

ITA No.1798/Kol/2025 Assessment Year- 2022-23