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Income Tax Appellate Tribunal, KOLKATA ‘A’ BENCH, KOLKATA
Before: Shri P.M. Jagtap, Hon’ble Vice-, KZ & Shri Aby T. Varkey, Hon’ble
Date of concluding the hearing : November 29th, 2021 Date of pronouncing the order : December 15th, 2021 ORDER Per P.M. Jagtap, Vice-President, KZ :- This appeal filed by the assessee is directed against the order of the ld. Commissioner of Income Tax (Appeals) – 5, Kolkata, (hereinafter the ‘ld. CIT(A)’), dt. 28/09/2018 and the solitary issue involved therein relates to the addition of Rs.20,00,000/- made by the Assessing Officer and confirmed by the ld. CIT(A) being the difference between the fair market value (FMV) of the shares and the value actually received by the assessee company u/s 56(2)(viib) of the Income Tax Act, 1961 (hereinafter ‘the Act’) read with Rule 11UA of the Income Tax Rules, 1962 (hereinafter ‘the Rules’).
The assessee in the present case is a company which is engaged in the business of manufacturing and sale of laminated rolls and tarpaulin. The return of income for the year under consideration was filed by the assessee on 21/11/2014 declaring a loss of Rs.59,56,603/-. During the year under consideration, the assessee company had issued 10,00,000 equity shares (having face value of Re. 1/- per shares) @ Rs.10/- per share. The value of each share so sold was worked out by the Assessing Officer by applying Rule 11UA of the Rules @ Rs.8/- per share and difference between the sale consideration of 10,00,000 shares received by the assessee and the FMV determined by him by applying Rule 11UA amounting to Rs.20,00,000/- was added by the Assessing Officer to the total income of the assessee u/s 56(2)(viib) of the Act in the assessment completed u/s 143(3) of the Act vide order dt. 27/12/2016.
Assessment Year: 2014-15 Chamundi Extrusions Pvt. Ltd. Chamundi Extrusions Pvt. Ltd 3. The addition of Rs.20,00,000/ The addition of Rs.20,00,000/- made by the Assessing Officer u/s 56(2)(viib) made by the Assessing Officer u/s 56(2)(viib) r.w.r. 11UA was challenged by the assessee in t r.w.r. 11UA was challenged by the assessee in the appeal filed before the ld. CIT(A) and he appeal filed before the ld. CIT(A) and the following contention was mainly raised on behalf of the assessee during the course the following contention was mainly raised on behalf of the assessee during the course the following contention was mainly raised on behalf of the assessee during the course of appellate proceedings before the of appellate proceedings before the ld. CIT(A) in support of its contentions: contentions:- “Thus as per Rule 11UA , the valuation is to be Thus as per Rule 11UA , the valuation is to be based on last Audited Balance sheet. The based on last Audited Balance sheet. The shares were allotted on 15.07.2013. The audited balance sheet for the year March, 2013 shares were allotted on 15.07.2013. The audited balance sheet for the year March, 2013 shares were allotted on 15.07.2013. The audited balance sheet for the year March, 2013 was prepared on 25.07.2013.The last available Balance Sheet as on the date of was prepared on 25.07.2013.The last available Balance Sheet as on the date of was prepared on 25.07.2013.The last available Balance Sheet as on the date of allotment was for the year ended 31.03.2012 and as allotment was for the year ended 31.03.2012 and as such going by the provisions of Rule such going by the provisions of Rule 11UA the balance sheet as at 31.03.2012should have been the basis of calculation of the 11UA the balance sheet as at 31.03.2012should have been the basis of calculation of the 11UA the balance sheet as at 31.03.2012should have been the basis of calculation of the Fair Value. However, the Assessing Officer drew up the valuation based on the Balance Fair Value. However, the Assessing Officer drew up the valuation based on the Balance Fair Value. However, the Assessing Officer drew up the valuation based on the Balance Sheet as on 31.03.2013, which on the date of Sheet as on 31.03.2013, which on the date of allotment was not available or prepared. allotment was not available or prepared. The Assessing Officer was wrong in taking a valuation not allowable in law only with the The Assessing Officer was wrong in taking a valuation not allowable in law only with the The Assessing Officer was wrong in taking a valuation not allowable in law only with the intension of rejecting the valuation as provided by the assessee and making an addition intension of rejecting the valuation as provided by the assessee and making an addition intension of rejecting the valuation as provided by the assessee and making an addition based on the deeming provision and th based on the deeming provision and the same is based on incorrect i e same is based on incorrect interpretation of section 56(2)(viib) read along with Rule iib) read along with Rule11UA and as such the addition made may kindly UA and as such the addition made may kindly be deleted.”
The ld. CIT(A) did not find merit in the submission made on behalf of the The ld. CIT(A) did not find merit in the submission made on behalf of the The ld. CIT(A) did not find merit in the submission made on behalf of the 4. assessee and proceeded to assessee and proceeded to confirm the addition of Rs.20,00,000/ confirm the addition of Rs.20,00,000/- made by the Assessing Officer for the following reasons given in his impugned order: Assessing Officer for the following reasons given in his impugned order: Assessing Officer for the following reasons given in his impugned order:-
I have considered the submission of the appellant and perused the relevant assessment I have considered the submission of the appellant and perused the relevant assessment I have considered the submission of the appellant and perused the relevant assessment records. The only issue in this appeal is t records. The only issue in this appeal is the valuation of share under Rule 11UA of the I T he valuation of share under Rule 11UA of the I T Rule, 1962. The AO had valued the shares on the basis of the balance sheet as on Rule, 1962. The AO had valued the shares on the basis of the balance sheet as on Rule, 1962. The AO had valued the shares on the basis of the balance sheet as on 31.03.2013. The A/R of the appellant in his submission has submitted that the shares were 31.03.2013. The A/R of the appellant in his submission has submitted that the shares were 31.03.2013. The A/R of the appellant in his submission has submitted that the shares were allotted on 15.07.2013. The audited allotted on 15.07.2013. The audited balance sheet for the year March, 2013 was prepared balance sheet for the year March, 2013 was prepared on 25.07.2013. However, the Assessing Officer drew up the valuation based on the Balance on 25.07.2013. However, the Assessing Officer drew up the valuation based on the Balance on 25.07.2013. However, the Assessing Officer drew up the valuation based on the Balance Sheet as on 31.03.2013, which on the date of allotment was not available or prepared. The Sheet as on 31.03.2013, which on the date of allotment was not available or prepared. The Sheet as on 31.03.2013, which on the date of allotment was not available or prepared. The assessee valued the share assessee valued the shares on the basis of Balance Sheet as on However he claims that However he claims that Assessing Officer did not take cognizance of the valuation report provided by the assessee Assessing Officer did not take cognizance of the valuation report provided by the assessee Assessing Officer did not take cognizance of the valuation report provided by the assessee and calculated the value as on and calculated the value as on despite of the fact that such Balance Sheet was not available despite of the fact that such Balance Sheet was not available as on the date of allotment and as such could not have been considered. There is no merit as on the date of allotment and as such could not have been considered. There is no merit as on the date of allotment and as such could not have been considered. There is no merit in the submission of the appellant. The method of valuation of unquoted shares is laid in the submission of the appellant. The method of valuation of unquoted shares is laid in the submission of the appellant. The method of valuation of unquoted shares is laid down in Rule 11UA(1)(c) which reads as follows: )(c) which reads as follows: the fair market value of unquoted shares and securities other than equity shares "the fair market value of unquoted shares and securities other than equity shares "the fair market value of unquoted shares and securities other than equity shares in a company which are not listed in any recognized stock exchange shall be in a company which are not listed in any recognized stock exchange shall be in a company which are not listed in any recognized stock exchange shall be estimated to be price it would fetch if sold in the open market on estimated to be price it would fetch if sold in the open market on estimated to be price it would fetch if sold in the open market on the valuation date and he assessee may be obtain a report from a merchant banker or an accountant and he assessee may be obtain a report from a merchant banker or an accountant and he assessee may be obtain a report from a merchant banker or an accountant in respect of such valuation." in respect of such valuation." Reference may be made to definition of valuation date as per Rule 11U(j) as under: Reference may be made to definition of valuation date as per Rule 11U(j) as under: Reference may be made to definition of valuation date as per Rule 11U(j) as under:- “’Valuation date’ means the date on which “’Valuation date’ means the date on which the property or consideration, as the the property or consideration, as the case may be, is received by the assessee.” case may be, is received by the assessee.”
Assessment Year: 2014-15 Chamundi Extrusions Pvt. Ltd. Chamundi Extrusions Pvt. Ltd The definition of property under explanation (d) to section 56(1) includes shares and The definition of property under explanation (d) to section 56(1) includes shares and The definition of property under explanation (d) to section 56(1) includes shares and securities. Therefore, the date of valuation of shares for which fair market value has t securities. Therefore, the date of valuation of shares for which fair market value has t securities. Therefore, the date of valuation of shares for which fair market value has to be computed as per on date of transfer or allotment of the shares. This view is fortified by Rule computed as per on date of transfer or allotment of the shares. This view is fortified by Rule computed as per on date of transfer or allotment of the shares. This view is fortified by Rule 11UAA which was introduced by the Income 11UAA which was introduced by the Income-tax (20th Amendment) Rules, 2017 tax (20th Amendment) Rules, 2017 - CBDT Notification G.S.R. 865(E) dated 12th July, 2017 Notification G.S.R. 865(E) dated 12th July, 2017 - w.e.f. the 1st day of Ap w.e.f. the 1st day of April, 2018 which clearly states that "for the purpose of section 50CAFMV of unquoted shares shall be clearly states that "for the purpose of section 50CAFMV of unquoted shares shall be clearly states that "for the purpose of section 50CAFMV of unquoted shares shall be determined in the manner provided in Rule determined in the manner provided in Rule 11UA(1)(c)(b) or Rule 11UA(1 11UA(1)(c)(c) as the case may be. Valuation date for the purpose of Rule 11U & 11UA shall case may be. Valuation date for the purpose of Rule 11U & 11UA shall case may be. Valuation date for the purpose of Rule 11U & 11UA shall mean the date on which the capital asset, being shares of a company other than unquoted shares referred in which the capital asset, being shares of a company other than unquoted shares referred in which the capital asset, being shares of a company other than unquoted shares referred in section 50CA is transferred." Though the amendment came to effect from 01.04.2018, from section 50CA is transferred." Though the amendment came to effect from 01.04.2018, from section 50CA is transferred." Though the amendment came to effect from 01.04.2018, from the definition of valuation date, it is the clear that the in the definition of valuation date, it is the clear that the intention of the legislature was to tention of the legislature was to take the date of transfer as the valuation date. take the date of transfer as the valuation date. As discussed above, it is clear that the date of valuation of unquoted shares would be date As discussed above, it is clear that the date of valuation of unquoted shares would be date As discussed above, it is clear that the date of valuation of unquoted shares would be date the shares transferred or allotted. In this case, the shares were allotted on 15/ the shares transferred or allotted. In this case, the shares were allotted on 15/ the shares transferred or allotted. In this case, the shares were allotted on 15/07/2013. Therefore, it would be reasonable to assume that fair market value as calculated by the AO Therefore, it would be reasonable to assume that fair market value as calculated by the AO Therefore, it would be reasonable to assume that fair market value as calculated by the AO on 31.03.2013 can be safely taken to be fair market value of unquoted shares instead of the on 31.03.2013 can be safely taken to be fair market value of unquoted shares instead of the on 31.03.2013 can be safely taken to be fair market value of unquoted shares instead of the fair market value as on 31.03.2012 taken by the appellant. The a fair market value as on 31.03.2012 taken by the appellant. The addition ddition of Rs.20,00,000/- is confirmed.”
Aggrieved by the order of the ld. CIT(A) the assessee has preferred this appeal Aggrieved by the order of the ld. CIT(A) the assessee has preferred this appeal Aggrieved by the order of the ld. CIT(A) the assessee has preferred this appeal before the Tribunal.
We have heard the arguments of both the sides and also perused the relevant We have heard the arguments of both the sides and also perused the relevant We have heard the arguments of both the sides and also perused the relevant material available on record. material available on record. Before us, the ld. Counsel for the assessee the ld. Counsel for the assessee has mainly reiterated the contention raised before the ld. CIT(A) that the balance sheet of the reiterated the contention raised before the ld. CIT(A) that the balance sheet of the reiterated the contention raised before the ld. CIT(A) that the balance sheet of the assessee company as on 31/03/2013 having been assessee company as on 31/03/2013 having been audited only on 25/07/2013 i.e., after only on 25/07/2013 i.e., after the allotment of shares on 15/0 the allotment of shares on 15/07/2013, the valuation of shares by applying Rule 11UA 7/2013, the valuation of shares by applying Rule 11UA should have been made on the basis of the last balance sheet of the assessee company as should have been made on the basis of the last balance sheet of the assessee company as should have been made on the basis of the last balance sheet of the assessee company as on 31/03/2012 being the last balance sheet availa on 31/03/2012 being the last balance sheet available as on the date of allotment ble as on the date of allotment. He has contended that the Assessing Officer as well as the ld. CIT(A), however, made the ing Officer as well as the ld. CIT(A), however, made the ing Officer as well as the ld. CIT(A), however, made the valuation of shares on the basis of balance sheet of the assessee as on 31/03/2013 valuation of shares on the basis of balance sheet of the assessee as on 31/03/2013 valuation of shares on the basis of balance sheet of the assessee as on 31/03/2013 which was audited on 25/07/2013 and was not available on the date of allotment of which was audited on 25/07/2013 and was not available on the date of allotment of which was audited on 25/07/2013 and was not available on the date of allotment of shares i.e., on 15/07/2013. In sup shares i.e., on 15/07/2013. In support of this contention, he has relied on the definition port of this contention, he has relied on the definition of ‘balance sheet’ given for the purpose of Rule 11UA in Clause (b) of Rule 11U which of ‘balance sheet’ given for the purpose of Rule 11UA in Clause (b) of Rule 11U which of ‘balance sheet’ given for the purpose of Rule 11UA in Clause (b) of Rule 11U which reads as under:-
“11U. For the purposes of this rule and rule 11UA, For the purposes of this rule and rule 11UA,— (a) ………….. (b) “balance-sheet”, in relation sheet”, in relation to any company, means,— (i) for the purposes of sub (i) for the purposes of sub-rule (2) of rule 11UA, the balance-sheet of such company sheet of such company (including the notes annexed thereto and forming part of the accounts) as drawn up on the (including the notes annexed thereto and forming part of the accounts) as drawn up on the (including the notes annexed thereto and forming part of the accounts) as drawn up on the Assessment Year: 2014-15 Chamundi Extrusions Pvt. Ltd. Chamundi Extrusions Pvt. Ltd valuation date which has been audited by the auditor of valuation date which has been audited by the auditor of the company appointed under the company appointed under section 224 of the Companies Act, 1956 (1 of 1956) and where the balance section 224 of the Companies Act, 1956 (1 of 1956) and where the balance section 224 of the Companies Act, 1956 (1 of 1956) and where the balance-sheet on the valuation date is not drawn up, the balance valuation date is not drawn up, the balance-sheet (including the notes annexed thereto and sheet (including the notes annexed thereto and forming part of the accounts) drawn up as on a date forming part of the accounts) drawn up as on a date immediately preceding the valuation immediately preceding the valuation date which has been approved and adopted in the annual gene date which has been approved and adopted in the annual gene date which has been approved and adopted in the annual general meeting of the shareholders of the company; shareholders of the company; and (ii) in any other case, the balance (ii) in any other case, the balance-sheet of such company (including the notes annexed sheet of such company (including the notes annexed thereto and forming part of the accounts) as drawn up on the valuation date which has part of the accounts) as drawn up on the valuation date which has part of the accounts) as drawn up on the valuation date which has been audited by the auditor appointed under section 224 of the Companies Act, 1956 (1 of been audited by the auditor appointed under section 224 of the Companies Act, 1956 (1 of been audited by the auditor appointed under section 224 of the Companies Act, 1956 (1 of 1956);]”
The ld. Counsel for the assessee The ld. Counsel for the assessee has contended that the balance sheet of the contended that the balance sheet of the assessee company as on the date of valuation date i.e., 15/07/2013 when the shares pany as on the date of valuation date i.e., 15/07/2013 when the shares pany as on the date of valuation date i.e., 15/07/2013 when the shares were allotted had not been drawn up and since the balance sheet as on 31/03/2013 been drawn up and since the balance sheet as on 31/03/2013 been drawn up and since the balance sheet as on 31/03/2013 was not been approved and adopted in the Annual General Meeting (AGM) of the not been approved and adopted in the Annual General Meeting (AGM) of the not been approved and adopted in the Annual General Meeting (AGM) of the shareholders of the company shareholders of the company up to the date of valuation, the balance sheet as drawn up up to the date of valuation, the balance sheet as drawn up on 31/03/2012 was available as the balance sheet drawn up as on a date immediately on 31/03/2012 was available as the balance sheet drawn up as on a date immediately on 31/03/2012 was available as the balance sheet drawn up as on a date immediately preceding the valuation date and the valuation of shares should have been done on the preceding the valuation date and the valuation of shares should have been done on the preceding the valuation date and the valuation of shares should have been done on the basis of the said balance sheet and not on the balance sheet as on 31/03/2012. heet and not on the balance sheet as on 31/03/2012. heet and not on the balance sheet as on 31/03/2012.
We are unable to accept th We are unable to accept the contention of the ld. Counsel for the assessee. The contention of the ld. Counsel for the assessee. The shares having been allotted by the assessee company on 15/07/2013, the valuation date shares having been allotted by the assessee company on 15/07/2013, the valuation date shares having been allotted by the assessee company on 15/07/2013, the valuation date was 15/07/2013 and since the 5/07/2013 and since the balance sheet of the assessee company was not drawn balance sheet of the assessee company was not drawn up on the said valuation date, the balance sheet drawn up as on a date immediately up on the said valuation date, the balance sheet drawn up as on a date immediately up on the said valuation date, the balance sheet drawn up as on a date immediately preceding the valuation date preceding the valuation date, which has been approved and adopted in the AGM of the which has been approved and adopted in the AGM of the shareholders of the company shareholders of the company, was to be taken as the balance sheet for the purpose of e taken as the balance sheet for the purpose of valuation as per Rule 11UA read with Clause (b) of Rule 11U. In the present case, the last valuation as per Rule 11UA read with Clause (b) of Rule 11U. In the present case, the last valuation as per Rule 11UA read with Clause (b) of Rule 11U. In the present case, the last balance sheet of the assessee company was drawn as on 31/03/2013 balance sheet of the assessee company was drawn as on 31/03/2013 balance sheet of the assessee company was drawn as on 31/03/2013 being a date immediately preceding the valuation dat immediately preceding the valuation date but since the same was audited on e but since the same was audited on 25/07/2013 i.e., after the date of valuation i.e., 15/07/2013 and had been approved and 25/07/2013 i.e., after the date of valuation i.e., 15/07/2013 and had been approved and 25/07/2013 i.e., after the date of valuation i.e., 15/07/2013 and had been approved and adopted in the AGM of the shareholders of the company held after the date of valuation, adopted in the AGM of the shareholders of the company held after the date of valuation, adopted in the AGM of the shareholders of the company held after the date of valuation, the ld. Counsel for the assessee has contend the ld. Counsel for the assessee has contended that the same cannot be taken for the ed that the same cannot be taken for the purpose of valuation of shares under Rule 11UA and the balance sheet as on purpose of valuation of shares under Rule 11UA and the balance sheet as on purpose of valuation of shares under Rule 11UA and the balance sheet as on 31/03/2012 should be taken into consideration. It is 31/03/2012 should be taken into consideration. It is however observed that there is observed that there is nothing either in Rule 11UA or even nothing either in Rule 11UA or even in the definition of ‘balance sheet’ given in Clause ‘balance sheet’ given in Clause (b)(i) of Rule 11UA to show that the balance sheet drawn as on the date immediately (b)(i) of Rule 11UA to show that the balance sheet drawn as on the date immediately (b)(i) of Rule 11UA to show that the balance sheet drawn as on the date immediately preceding the valuation date should have been approved and adopted in the AGM of preceding the valuation date should have been approved and adopted in the AGM of preceding the valuation date should have been approved and adopted in the AGM of shareholders of the company before the date of valuation. shareholders of the company before the date of valuation. It, therefore, follows that even It, therefore, follows that even Assessment Year: 2014-15 Chamundi Extrusions Pvt. Ltd. Chamundi Extrusions Pvt. Ltd if the balance sheet as drawn up on 31/03/2013 if the balance sheet as drawn up on 31/03/2013 had been audited, approved and had been audited, approved and adopted in the AGM of the shareholders of the company after the date of valuation, the adopted in the AGM of the shareholders of the company after the date of valuation, the adopted in the AGM of the shareholders of the company after the date of valuation, the same being the balance sheet drawn up as on the date immed same being the balance sheet drawn up as on the date immediately preceding the iately preceding the valuation date should be taken into consideration for the purpose of determining the valuation date should be taken into consideration for the purpose of determining the valuation date should be taken into consideration for the purpose of determining the FMV of the shares sold by the assessee on 15/07/2013. Even otherwise, the contention FMV of the shares sold by the assessee on 15/07/2013. Even otherwise, the contention FMV of the shares sold by the assessee on 15/07/2013. Even otherwise, the contention of the ld. Counsel for the assessee that the FMV of the shares as of the ld. Counsel for the assessee that the FMV of the shares as on 15/07/2013 should on 15/07/2013 should have been determined on the basis of balance sheet drawn up have been determined on the basis of balance sheet drawn up on 31/03/2012 instead of 31/03/2012 instead of 31/03/2013 cannot be accepted not being either fair or proper. Moreover, the definition 31/03/2013 cannot be accepted not being either fair or proper. Moreover, the definition 31/03/2013 cannot be accepted not being either fair or proper. Moreover, the definition of ‘balance sheet’ given in Clause (b) of Rule11U for the pur of ‘balance sheet’ given in Clause (b) of Rule11U for the purpose of sub pose of sub-rule (2) of Rule 11UA contemplates the balance sheet of the company as drawn up on the valuation date 11UA contemplates the balance sheet of the company as drawn up on the valuation date 11UA contemplates the balance sheet of the company as drawn up on the valuation date which has been audited by the auditor of the company clearly suggests or indicates that by the auditor of the company clearly suggests or indicates that by the auditor of the company clearly suggests or indicates that the balance sheet referred to therein need not be avai the balance sheet referred to therein need not be available on the date of valuation lable on the date of valuation simply because the balance sheet as drawn up on the valuation date and audited by the simply because the balance sheet as drawn up on the valuation date and audited by the simply because the balance sheet as drawn up on the valuation date and audited by the auditor of the company cannot be practically available as on the date of valuation itself. auditor of the company cannot be practically available as on the date of valuation itself. auditor of the company cannot be practically available as on the date of valuation itself. We are, therefore, of the considered view that t We are, therefore, of the considered view that the balance sheet drawn up as on he balance sheet drawn up as on 31/03/2013 was rightly taken by the Assessing Officer as well as the ld. CIT(A) for the 31/03/2013 was rightly taken by the Assessing Officer as well as the ld. CIT(A) for the 31/03/2013 was rightly taken by the Assessing Officer as well as the ld. CIT(A) for the determination of the FMV of the shares sold by the assessee on 15/07/2013 as per determination of the FMV of the shares sold by the assessee on 15/07/2013 as per determination of the FMV of the shares sold by the assessee on 15/07/2013 as per Clause (b) of Rule11U for the purpose of sub Clause (b) of Rule11U for the purpose of sub-rule (2) of Rule 11UA being the balance f Rule 11UA being the balance sheet drawn up immediately preceding the valuation date sheet drawn up immediately preceding the valuation date. In that view of the matter, we . In that view of the matter, we uphold the impugned order of the ld. CIT(A) on this issue and dismiss this appeal of the uphold the impugned order of the ld. CIT(A) on this issue and dismiss this appeal of the uphold the impugned order of the ld. CIT(A) on this issue and dismiss this appeal of the assessee.
In the result, appeal of the assess In the result, appeal of the assessee is dismissed.
Order pronounce in the Court on Order pronounce in the Court on the 15th day of December ember, 2021. Sd/- Sd/- [P.M. Jagtap] [Aby T. Varkey] Judicial Member Judicial Member Vice-President Dated: 15.12.2021 {SC SPS} Assessment Year: 2014-15 Chamundi Extrusions Pvt. Ltd. Chamundi Extrusions Pvt. Ltd Copy of the order forwarded to: 1. Chamundi Extrusions Pvt. Ltd Chamundi Extrusions Pvt. Ltd Village – Vyer Chak Ranihati Amta Road P.O. – Jala Biswanathpur Near Gabberia Hospital Howrah – 711 322
2. Asstt. Commissioner of Income Tax, Circle Asstt. Commissioner of Income Tax, Circle-36, Kolkata 3. CIT(A)- 4. CIT- , 5. CIT(DR), Kolkata Benches, Kolkata. . CIT(DR), Kolkata Benches, Kolkata.