DCIT, CIRCLE-48, KOLKATA, KOLKATA vs. M/S. 3 GUYS, HOWRAH

आदेश /O R D E R

PER Waseem Ahmed, Accountant Member:-

This appeal by the Revenue is arising out of order of Commissioner of Income Tax (Appeals)-XXX, Kolkata dated 30.05.2014. Assessment was framed by DCIT, Circle-48, Kolkata u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) vide his order dated 30.12.2010 for assessment year 2008-09. Grounds raised by Revenue per its appeal are as under:- “1. That on the facts and circumstances of the case the Ld. CIT(A)-XXX, Kolkata erred in deleting the addition of Rs.4,50,60,116/- in violation of Rule 46A of Income Tax Rules, 1962, by accepting the installation works acceptance certificate which was not submitted before the AO either at the assessment stage or at the remand proceedings stage.

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 2 2. That on the facts and circumstances of the case the Ld. CIT(A)-XXX, Kolkata erred in deleting the addition of Rs.4,50,60,116/- as the CIT(A) neither properly matched the returned turnover with installation works acceptance certificates nor gave the AO an opportunity to tally the returned turnover with installation works acceptance certificate. 3. That on the facts and circumstances of the case the Ld. CIT(A)-XXX, Kolkata erred in deleting the addition of Rs.4,50,60,116/- without establishing fact that the assessee has undertaken regularly employed accounting policy in raising invoices for installation works done. 4. That on the facts and circumstances of the case the Ld. CIT(A)-XXX, Kolkata erred in directing the allowance of TDS amounting to Rs.26,36,220/- in violation of Rule 37BA(3) of the Income Tax Rule, 1962. 5. That the order of Ld. CIT(A)-XX, Kolkata is contrary to law and facts of the case. 6. That the appellant craves leave to add, alter and/or amend, modify, substitute, all or any of the grounds of appeal during the course of hearing.” Shri Rajendra Prasad, Ld. Departmental Representative represented on behalf of Revenue and Shri Miraj D. Shah Ld. Advocate appeared on behalf of assessee. 2. Ground No. 1 to 3 are inter-related and therefore being taken up together. The issue raised by Revenue is that Ld. CIT(A) erred in deleting the addition made by Assessing Officer for ₹4,50,60,116/-. 3. Briefly stated facts are that assessee is a partnership firm and engaged in telecommunication works. The assessee has shown gross turnover in its profit and loss a/c as detailed under:- Nokia Siemens Networks (P) Ltd Rs.9,04,21,679/- Other Rs. 33,49,943/- Total Rs.9,37,71,622/- However, AO on perusal of the Tax Deducted at Source (TDS) certificate issued by M/s Nokia Siemens Networks (P) Ltd. (NSNP for short) observed that the assessee has executed the contracts for ₹14,23,09,064/- only. Thus, the difference of ₹5,18,87,385/- (14,23,09,064 – 9,,04,21,679/-) was observed by the AO. Accordingly, an explanation was sought from the assessee. In compliance thereto, the assessee submitted that there is a mistake on the part

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 3 of NSNP for deducting the tax on higher amount and the additional income in the form of TDS credit is a windfall in the hands of assessee. 4. From the above reply AO assumed that the difference in the income of ₹5,18,87,385/- has accrued to the assessee during the year and accordingly AO made the addition of the aforesaid sum to the total income of assessee. 5. Aggrieved, assessee preferred an appeal before Ld. CIT(A) who after considering the submission of assessee, remand report and the correspondence of NSNP Ld. observed the following facts which are elaborated as under:- i) Two TDS certificates were issued by NSNP as detailed under:- S.No. Name of party amount of income amount of TDS 1. NSNP 5,88,61,623 66,69,044 2. NSNP 8,26,53,675 91,91,815 ii) The assessee has not received any payment from NSNP in respect of TDS certificate of ₹66,71,455/-. Therefore, the amount of TDS certificate alone was to be treated as the income in the hands of assessee. iii) To verify the veracity of the claim of remand report was sought for from the AO who after a serious reminder has just supported the order of AO passed u/s. 143(3) of the Act. However, Ld. CIT(A) observed that the NSNP has made detailed reply which was running into 100 of pages and 20 sets of paper book were also filed but the AO failed to make any finding from the aforesaid details. Therefore, the necessary papers, ledger, remand report folder and assessment folder were called upon by the Ld. CIT(A) for his own examination. iv) The assessee has credited NSNP for ₹7,97,48,817/- during the year along with TDS amount. Further, assessee has shown TDS amount of ₹81,30,301/- showing the net amount receivable for ₹7,09,03,670/-. v) In the immediate preceding Assessment Year 2007-08 the assessee has shown gross revenue of ₹5,00,50,670/- only including the revenue from NSNP for ₹4,12,31,324/- only though the TDS was deducted for

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 4 ₹1,381/- only. Thus, there was no match between gross revenue shown by the assessee vis-à-vis amount of TDS shown by the assessee but the Revenue accepted the gross income shown by the assessee. It is also undisputed fact that the proceedings was carried out for the immediate preceding assessment year 2007-08 u/s 147 of the Act. But the AO accepted the proposition for the gross revenue as well as TDS as shown by the assessee. However, the year under consideration, the AO has taken a different view and held that assessee has suppressed its gross revenue. vi) The AO for the assessment year 2006-07 has held that the amount of ₹,1,52,31,504/- and ₹ 10 lakh pertains to assessment year 2007-08 though the TDS was issued for the year ending 31.03.2006. It is also undisputed that TDS certificate was issued by NSNP in the financial year 2005-06 and credit was also given in the same financial year. But the correspondence income was taxed in the subsequent financial year i.e. 2006-07. vii) The assessee has also given a chart depicting the TDS deducted by the party vis-à-vis gross revenue shown by the assessee. This certificate pertains to the assessment years 2002-03, 2003-04, 2005-06, 2007-08, 2008-09 and 2009-10 respectively. viii) The assessee also furnished the break-up of income offered to tax in respect of TDS certificate issued by NSNP for ₹5,88,87,385/- in the financial year 2007-08 as detailed under:- “ Amt.(Rs) AY 2008-09 1,79,53,417.00 AY 2009-10 3,21,53,913.00 AY 2010-11 3,62,000.00 AY 2011-12 1,11,165.00 PO’s not found/never been executed 30,24,546.00 Remaining jobs in PO not performed 52,56,631.00 Total 5,88,61,673.00

In view of the above, Ld. CIT(A) partly granted relief to assessee by observing as under:-

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 5 “13.1.4 To sum up, the AO has committed an error in solely relying on TDS certificate of current AY 08-09 ignoring other facts relevant to the accrual of income. TDS certificate alone does not evidence the amount of income chargeable to tax in the relevant Assessment Year. Similarly, the AO has committed an error in concluding that the AR of the Appellant accepted that the sum of Rs.5,18,87,385/- had accrued as income to the Assessee for the year ended 31.03.2008. In the Order Sheet dated 28.12.2010, the extracts of which have been included in the Assessment Order, there is no recording of the acceptance by the Art ha the income as per the TDS Certificate dated 10.06.2008 had accrued to the Assessee for the year ended 31.03.2008. The nothing only talks of credit of TDS which has been treated as windfall income. Examination of relevant facts indicates that the TDS amount was deducted by M/s Nokia Siemens Network Pvt. Ltd. from other payments and deposited to the Central Government and thus TDS amount deposited does not represented any income to the Appellant. It was a mere out-go from dues payable to the Appellant and so it is factually incorrect to equate TDS amount to income of the Assessee. Similarly, as there is no income terming that as windfall is doubly wrong. This only indicates that the AR representing the case could not appreciate the relevant facts. Signing the Order Sheet by the AR especially when the facts are so different does not make the sums or the TDS amounts as windfall income. As regards Mercantile System of Accounting the AO has failed to even explain as to how that System gives rise to chargeability to tax of additional sum of Rs.5,18,87,385/-. The AO seems to have used the term Mercantile System without applying his mind to the relevant issues and has thus erred in holding so. In view of the facts discussed above it becomes clear that the said amounts in TDS Certificate did not accrue to the Appellant in terms of the works contract/agreement and accounting standard 9 which is applicable in the case as some of the works were not executed or the acceptance of the installation was awaited. Thus on all the counts forwarded as reasons for making addition by the A.O. the A.O. seems to have gone wrong and his decision therefore cannot be sustained. Thus the addition made of Rs.5.18 crores cannot be sustained as these amounts are claimed to have been offered as turnover in the following Financial Year 2008-09 or other years. As a result, the addition made is deleted, subject to the estimation of the income contained in the gross amounts mentioned in the TDS Certificates or offered turnover as discussed or estimated hereinafter. 13.1.5 Estimating of Income: Though addition of Rs.5,18,87,385/- cannot be sustained it appears after the examination of relevant details that the income of the A.Y.08-09 as offered in the return is not correct as the Appellant has failed to evaluate the work-in-progress in respect of installation works executed in the current F.Y.07-08 but for which invoicing was done in the following F.Y.08-09 as detailed later. The Appellant has not been able to follow the matching principle, which requires that to compute income only those expenses have to be deducted from the revenue which are incurred for earning the said revenue. It is seen that Rs.3,21,53,913/- worth of installations were carried out for which billing or invoicing were done in A.Y.09-10 but a good part of that work was carried out in the F.Y.07-08 relevant for current A.Y.08-09. To carry out the work direct expenses were incurred which were not balanced out from the revenue offered and to that extent the income offered by the Appellant in the current A.Y.08-09 is lower. For the purpose of assessing the income of A.Y.08-09 the valuation of work- in-progress of the installations which were carried out in F.Y.07-08 but Invoicing for which was done in F.Y.08-09, has to be worked out. It appears that the date of raising of invoices and the completion of relevant installation works are spread over a few months. The delay seems to have arisen because of the agreement between the appellant and Nokia wherein the appellant is

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 6 required to raise invoice only on the acceptance of the service by Nokia. A large number of sites have been installed in F.Y. 2007-08 relevant to Assessment Year 2008-09 completion for which has been conveyed to Nokia during the F.Y. 2007-08 itself. But the invoicing of this installation works have been postponed to F.Y. 2008- 09, for reason that the appellant awaited for the inspection and issuance of acceptance certificate or for confirmation from Nokia for raising the bills. The Appellant has not maintained, it appears, the detailed accounts of various installations specially regarding the expenses of various sites which have been completed and are awaiting inspection or for which invoices have not been raised even though the installation might have been completed to the complete satisfaction of both Nokia and the appellant. The expenses incurred appear to have been recorded in the books as and when it has been incurred. In some cases the invoicing delay is of even about 5 months. Estimation of work-in-progress against installation completed but awaiting acceptance is a must to estimate reasonable profit earned by the Appellant. There are no details made available by the Appellant on expenses incurred for the installations where the Appellant is waiting for acceptance of Nokia. Discussion with technical personnel of the Appellant leads to the observation that in some cases, inspection results in re-working or rectification of some of the work already done and similarly, inspection itself involves costs because personnel have to be sent to the sites where joint inspection is carried out. Keeping this in mind that inspection has to be done in all cases and in some cases follow-up action in the form of rectification or modification is required to be done, the work-in-progress to be associated to installations for which invoicing has been done in F.Y. 2008-09 but for which work was done in F.Y. 2007-08 can be done as under: The audited P & L A/c shows the direct cost for installations booked in the FY 2007- 08 Labour charges and site expenses are respectively Rs.1,39,47,734/- and Rs.2,79,09,342/-. These two add up to Rs.4,18,57,076/- of direct expenses for all the installations carried out in FY 207-08. To apportion a part of such expenses towards installations awaiting inspection or acceptance the following formula may be adopted. TEAM INSTALLATION INSIPECTION RECTIFICTION STRENGTH (INITIAL) /REWORK (1) (2) (3) (4) TECHNICIAL 3 2 2 ENGINEER 1 1 1 RIGGER 1 0 0 A TOTAL 5 3 3 B No of Days 2 1 1 C=A*B MAN DAYS 10 3 3 COST/WAGE/SALARY RATE TEHNICIAL 8,000.00 8,000.00 8,000.00 ENGINEER 13,000.00 13,000.00 13,000.00 RIGGER 6,000.00 6,000.00 TEHNICIAL 24,000.00 16,000.00 16,000.00 ENGINEER 13,000.00 13,000.00 13,000.00 RIGGER 6,000.00 00 43,000.00 29,000.00 29,000.00 No of Days 2 1 1 86,000.00 29,000.00 29,000.00

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 7 Ratio 86 29 29 Converted 100 33.7 33.7 Taking cost or site as “x” Cost site on an average x 0.337 x 0.337x i) Inspection is carried for all installation. Reworks/rectifications in most of the sites, it is observed, are completed on the date of inspection itself but in about 25% of the cases, it is claimed that rework or rectification requires another day of work, which results in additional costs. ii) Factoring-in the rectification or rework costs in about x+.337x+.25*.337x 25% of the sites, the total costs of the sites invoiced is iii) Similarly for sites in respect of which no invoices have been raised, the cost will be only of installation cost of x iv) The revenue offered by the appellant against Nokia (after considering 147 proceeding for AY 2007-08) is 8.12 crore [9-0.88 cr.]. v) Potential Revenue in respects of sites uninvoiced (in crores) = 2.247 0.70 [Anx-A]*3.21 vi) Thus the ratio of the sites invoiced and the sites uninvoiced is 1:.277(8.12 cr: 2.247 cr) vii) Thus the following equation may be written for costs of sites n(1.43225) x + (.277) nx = 41,857.076.00 1.69825nx = 1,857,076.00 nx = 24,647,181.51 nx *(.277) = 6,827,269.28 viii) The above is the cost allocable to the sites for which installation has been doe but invoice has not been raised and so this can be taken as work in progress for services rendered in the AY 2008-09 in respect of which revenue has been booked in AY 2009-10. ix) a) The figure of 0.70 (or 70%) is received from the sheet of total No of sites completed in F.Y 2007-08 and F.Y 2008-09 in respect of bills raised in FY 2008-09 with respect to A.Y 2009-10. (Refer Annexure-A) b) Total cost of Rs.4,18,57,076/- includes Labour charges of Rs.1,39,47,735/- and site expenses of Rs.2,79,09,343/-. The formula gives rise to WIP of Rs.68,27,269/- which may be added to the income returned in the current year. The WIP figure is subject to rectification u/s. 154 of any error in observation or otherwise in the formula adopted above. The appellant or AO is free to seek rectification, if required. This addition towards WIP of Rs.68,27,269.28 has to be adjusted in later years. This addition has been made on the basis of matching principles which requires that the revenue and cost have to be matched to estimate revenue income. The matching principles thus also require that this WIP should be given consideration in the following year and this WIP becomes cost for the revenue in later years. Thus, this is directed to be allowed as cost to be deducted from the revenue booked in the FY 2008-09 in respect of installations which were executed in FY 2007-08. As a result, addition out of Rs.5,18,87,385/- is confirmed only upto Rs.68,27,269/- and the

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 8 balance of Rs.4,50,60,116/- is deleted. The ground [original no.d (last sentence)/revised no.5] is thus partly allowed.” The Revenue, being aggrieved, is in appeal before us. 6. Before us Ld. DR submitted that Ld. CIT(A) has granted partly relief to assessee after accepting the additional evidence which is in contravention to the provision of Rule 46A of the IT Rules. He vehemently relied on the order of AO. On the other hand, Ld. AR for the assessee submitted that remand report was duly called for by Ld. CIT(A) from the AO before passing the order. Besides, the remand report Ld. CIT(A) also verified the enquiry report which conducted from NSNP, ledger, remand folder and assessment folder. All these documents were duly examined by Ld. CIT(A). He relied on the order of Ld. CIT(A). 7. We have heard the rival contentions of both the parties and perused the material available on record. From the foregoing discussion, we find that the addition was made by the AO on the ground that there was mismatch between gross revenue shown in the TDS certificate and recorded in the books by the assessee. However, Ld. CIT(A) granted partly relief to assessee by observing that there was regular mismatch between the gross revenue shown by the assessee vis-à-vis TDS certificate issued by NSNP in the earlier years. The major reason for the difference was that the contracts undertaken by assessee were spreading for several years though NSNP has deducted TDS on the basis of purchase orders i.e. when the contract was awarded to the assessee. From the above facts, it was observed that there was an agreement between assessee and NSNP for installation of telecommunication network towers as per Article 7 of the agreement. The assessee can raise the invoice once work is completed by it and accepted by NSNP. In this process, sometime it used to take considerable time for getting acceptance certificate from NSNP. Thus, in many occasions, NSNP has deducted TDS on behalf of assessee for which the bill was not raised by assessee for the want of acceptance certificate. In

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 9 this connection, NSNP has replied to AO vide letter dated 03.05.2013 and relevant extract of the reply by NSNP reproduced below:- “We refer to the captioned letter issued by your office (copy enclosed as Annexure 1) received by the assessee on April 23,2013. In this regard, we, on behalf of and under the instructions of our subject client, wish to submit as follows: NSN India has issued Form 16A No.2/NSNI AACL/2007-08 C subject TDS certificate) to Mis 3 Guys wherein credit of Rs.6,669.044 on payments I accruals amounting to Rs.68.861.623 was specified copy of From 16A is enclosed as Annexure 2. A notice under section 133(6) of the Income-tax Act, 1961 C Act’) was issued by our office dated October 10, 2012 asking NSN India to furnish requisite information as Mis 3 Guys had claimed before your office that no payments amounting to Rs. 58.861.623 as specified in the subject TDS certificate were received by it. In response to the aforesaid notice and during the course of our discussions with your office. NSN India had stated that taxes, as specified in the subject TDS certificate were deducted at source by NSN India on the basis of accruals made on March 31 2008 in accordance with Generally Accepted Accounting Principles in respect of services procured from Mis 3 Guys for which no invoices were received.”

From the above, it is clear that NSNP has deducted the TDS in a particular year and assessee in that particular year has not shown income in its books of account. The assessee was following Accounting Standard 9 for Revenue Recognition. Accordingly, it used to recognize revenue in its books of account, once the installation work is accepted by the client. In view of the above, the difference between TDS amount and correspondence gross revenue arose. It was also observed that the Ld. DR has not brought anything contrary to the finding of Ld. CIT(A). In this view, we find that Ld. CIT(A) has passed a detailed order covering all the facts of the case. We also find support and guidance from the judgment of Hon'ble Supreme Court in the case of CIT vs. K.Y. Pilliah & Sons reported in 63 ITR 411 wherein it was held as under:- “The Tribunal is the final fact-finding authority and normally it should record its conclusion on every disputed question raised before it, setting out its reasons in support of its conclusion. But, in failing to record reasons, when the Tribunal fully agrees with the view expressed by AAC and has no other ground to record in support of its conclusion, it does not act illegally or irregularly, merely because it does not repeat the grounds of the AAC on which the decision was given against the assessee or the Department.”

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 10 Respectively following the principle laid down by the Hon'ble Supreme Court in the above case, we find no reason to interfere in the order of Ld. CIT(A).

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 11 I.T. Authority [Form 26AS] came into existence only much later. Thus it is held that the credit for TDS of Rs.20,18,902/- corresponding to the income of Rs.1,78,19,084/- not be allowed in Assessment Year 2007-08 as the corresponding return of the Appellant and the information furnished to the Income Tax Authority in 26AS does not support the view that. the credit of the corresponding amount be given in A.Y.2007-08. But since the tax of Rs.20,18,902/- has been withheld from the Appellant's revenue and deposited to the Central Government as tax on behalf of the Appellant it is the demand of justice that the said credit be allowed in the current Assessment Year 2008- 09 as Form 26AS and Form 16A supports the claim in the Assessment Year 2008-09 and the return of income filed by the Appellant makes claim for the credit of the said TDS in Assessment Year 2008-09. Not allowing the credit here in A.Y.2008-09 would go against the provision of section 205 of I.T. Act which puts bar on collection of tax from the Appellant to the extent of the tax of Rs.20,18,902/- deducted and paid from income of the Appellant. As a result, TDS of Rs.20,18,902/- corresponding to the said sum of Rs.1,78,19,084/- is directed to be allowed as credit in the Assessment Year 2008-09.

13.1.6.3 It has been claimed by the Appellant that Rs.30,24,546/- of revenue noted in the TDS certificate 16A, dated 10.06.200S corresponds to purchase Orders which were not communicated to the Appellant and so there was no work carried out. No revenue can be said to have arisen out of such POs. Hence, setting aside a part of the dues to the Appellant by M/s. Nokia Siemens Network Pvt. Ltd. towards TDS deduction in respect of the said non-existent revenue is not correct. However, since the said amount has been deposited by M/s. Nokia Siemens Network Pvt. Ltd to the Central Government Account and has been adjusted against the appellant's receivables amount, this credit must be allowed to the Appellant, it is claimed. Following the decision of Hon'ble ITAT Chennai Bench 'C' in the cases of Supreme Renewable Energy Ltd.[(2010) 124 ITD 394 (Chennai)] the A.O. is directed to allow the credit of the .TDS corresponding to this amount, i.e.Rs.3,42,681. Likewise, the Appellant further claims that Rs.52,56,631/- out of the amounts shown as credit/payment in TDS certificate dated 10.06.2008 relates to PO's/sites where works were never executed and Nokia might have carried out the said work through other vendors or the site/work might have been abandoned by Nokia. In any case as no work was ever executed, it is claimed that the corresponding amount of Rs.52,56,631/- does not represent any revenue that may accrue to the Appellant in this year or later years. As the sum has been adjusted by Nokia against payables to the Appellant, it is claimed, the tax thus paid to the Central Government and termed as TDS [Rs.5,94,529/-] corresponding to the said amount of Rs.52,56,631/- must be allowed against the credits to be given towards tax paid by the Appellant of this Assessment Year. Consequently following the Hon'ble ITAT Chennai Bench's decision (supra), it is directed that the credit of Rs.5,94,529/- be allowed.”

The Revenue, being aggrieved, is in appeal before us.

ITA No.1670/Kol/2014 A.Y.2008-09 DCIT, Cir-48 Kol. Vs. M/s 3 Guys Page 12 11. Before us both parties relied on the order of Authorities Below as favourable to them. 12. We have heard the rival contentions of both the parties and perused the material available on record. At the outset, it was observed that the instant issue is squarely covered in favour of assessee and against the Revenue by the order of Hon'ble ITAT Chennai Bench in the case of Supreme Renewable Energy Ltd. (2010) 124 ITD 394 (Chennai) wherein it was held as under:- “when a particular income is received by the assessee after deduction of tax at source and the said TDS has been duly deposited with the Government and the assessee has received the requisite certificate to this effect, then on production of the said certificate the assessee becomes entitled for the credit of TDS even if the assessee has not directly offered the said income for tax as the assessee considered the same was not liable to tax.”

Respectfully following the decision of Chennai Bench in the case of Supreme Renewable Energy Ltd. (supra) we uphold the order of Ld. CIT(A). This ground of Revenue’s appeal is dismissed. 13. In the result, Revenue’s appeal stands dismissed. Order pronounced in the open court 15/09/2017

Sd/- Sd/- (Aby. T. Varkey) (Waseem Ahmed) (Judicial Member) (Accountant Member) Kolkata, *Dkp �दनांकः- 15/09/2017 कोलकाता । आदेश क� ��त�ल�प अ�े�षत / Copy of Order Forwarded to:- 1. अपीलाथ�/Appellant-DCIT, Cir-48, 3, Govt. Place (West), Kokata-001 2. ��यथ�/Respondent-M/s 3 Guys J.C. Chakraborty Road, Duillya, Howrah-711302 3. संबं�धत आयकर आयु�त / Concerned CIT Kolkata 4. आयकर आयु�त- अपील / CIT (A) Kolkata 5. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, कोलकाता / DR, ITAT, Kolkata 6. गाड� फाइल / Guard file. By order/आदेश से, /True Copy/ Sr. Private Secretary, Head of Office/DDO आयकर अपील�य अ�धकरण, कोलकाता ।