SHRI PRAMOD KUMAR TEKRIWAL,KOLKATA vs. INCOME TAX OFFICER, WARD - 30(4), KOLKATA, KOLKATA

Per Shri S.S. Viswanethra Ravi :-

This appeal filed by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-XIV, Kolkata dated 08- 08-2013 for the assessment year 2009-10 on the following grounds:- ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal1

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exception insofar as the payment made in the month of March of the previous year. The tax deducted on payments made in the month of March of the previous year can be paid on or before the due date for filing the return of income. Since tax deducted on the aforesaid payment was not deposited to the credit of the Government before 31.03.2009, the Assessing Officer disallowed the claim of the assessee for deduction of Rs.13,99,171. On appeal by the assessee, the CIT(Appeals) upheld the order of the AO. Before the CIT(A), the assessee had submitted that since tax deducted has been paid on 22.7.2009, i.e., on or before the due date for filing the return of income u/s.139(1) of the Act, deduction has to be allowed in the A.Y. 2009-10. The CIT(A) rejected the plea raised by the assesse.

“40. Notwithstanding anything to the contrary in sections 30 to 38, the following amounts shall not be deducted in computed the income chargeable under the head `Profits and gains of business or profession’—.

…..

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(ia) any interest, commission or brokerage, fees for professional services or fees for technical services payable to a resident, or amounts payable to a contractor or sub-contractor, being resident, for carrying out any work (including supply of labour for carrying out any work), on or, after deduction, has not been paid during the previous year, or in the subsequent year before the expiry of the time prescribed under sub-section (1) of section 200 :

Provided that where in respect of any such sum, tax has been deducted in any subsequent year or, has been deducted in the previous year but paid in any subsequent year after the expiry of the time prescribed under sub-section (1) of section 200, such sum shall be allowed as a deduction in computing the income of the previous year in which such tax has been paid.

Explanation. – For the purposes of this sub-clause, -

(i)“commission or brokerage” shall have the same meaning as in clause (i) of the Explanation to section 194H;

(ii)“fees for technical services” shall have the same meaning as in Explanation 2 to clause (vii) of sub-section (1) of section 9;

(iii)“professional services” shall have the same meaning as in clause (a) of the Explanation to section 194J;

(iv)“work” shall have the same meaning as in Explanation III to section 194C; ” 5. The Memorandum explaining the provisions in the Finance Bill explained the rationale of the insertion of the new provision in following words :-

“With a view to augment compliance of TDS provisions, it is proposed to extend the provisions of section 40(a)(i) to payments of interest, commission or brokerage, fees for professional services or fees for technical services to residents, and payments to a resident contractor or sub-contractor for carrying out any work (including supply of labour for carrying out any work), on which tax has not been ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal4

deducted or after deduction, has not been paid before the expiry of the time prescribed under sub-section (1) of section 200 and in accordance with the other provisions of Chapter XVII-B. It is also proposed to provide that where in respect of payment of any sum, tax has been deducted under Chapter XVII-B or paid in any subsequent year, the sum of payment shall be allowed in computing the income of the previous year in which such tax has been paid.

The proposed amendment will take effect from 1st day of April, 2005 and will, accordingly, apply in relation to the assessment year 2005- 2006 and subsequent years. [Clause 11]”

“(ia) any interest, commission or brokerage, rent, royalty, fees for professional services or fees for technical services payable to a resident, or amounts payable to a contractor or sub-contractor, being resident, for carrying out any work (including supply of labour for carrying out any work), on which tax is deductible at source under Chapter XVII-B and such tax has not been paid,-

(A) in a case where the tax was deductible and was so deducted during the last month of the previous year, on or before the due date specified in sub-section (1) of section 139 ; or

(B) in any other case, on or before the last day of the previous year.

Provided that where in respect of any such sum, tax has been deducted in any subsequent year, or has been deducted-

(A) during the last month of the previous year but paid after the said due date ; or

(B) during any other month of the previous year but paid after the end of the said previous year, such sum shall be allowed as a deduction

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in computing the income of the previous year in which such tax has been paid.” ;

“(ia) any interest, commission or brokerage, rent, royalty, fees for professional services or fees for technical services payable to a resident, or amounts payable to a contractor or sub-contractor, being resident, for carrying out any work (including supply of labour for carrying out any work), on which tax is deductible at source under Chapter XVII-B and such tax has not been deducted or; after deduction, has not been paid on or before the due date specified in sub- section (1) of section 139.

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Provided that where in respect of any such sum, tax has been deducted in any subsequent year, or has been deducted during the previous year but paid after the due date specified in sub-section (1) of section 139, such sum shall be allowed as a deduction in computing the income of the previous year in which such tax has been paid.” 9. From the above provision as amended by the Finance Act, 2010 with retrospective effect from 1st April, 2010 it can be seen that the only difference which this amendment has made is dispensing with the earlier two categories of defaults as per the Finance Act, 2008, as discussed in the earlier para, causing disallowance on the basis of the period of the previous year during which tax was deductible. The first category of disallowances included the cases in which tax was deductible and was so deducted during the last month of the previous year but there was failure to pay such tax on or before the due date specified in sub-section (1) of section 139. The Finance Act, 2010 has not tinkered with this position. The second category of the Finance Act, 2008 which required the deposit of tax before the close of the previous year in case of deduction during the first eleven months, as a pre-condition for the grant of deduction in the year of incurring expenditure, has been altered. The hitherto requirement of the assessee deducting tax at source during the first eleven months of the previous year and paying it before the close of the previous year up to 3 1st March of the previous year as a requirement for grant of deduction in the year of incurring such expenditure, has been eased to extend such time for payment of tax up to due date u/s 139(1) of the Act. As per the new amendment, the disallowance will be made if after deducting tax at source, the assessee fails to pay the amount of tax on or before the due date specified in sub-section (1) of section 139 of the Act. The effect of this amendment is that now the assessee deducting tax either in the last month of the previous year or first eleven months of the previous year shall be entitled to deduction of the expenditure in the year of

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incurring it, if the tax so deducted at source is paid on or before the due date u/s 139(1). This is the only difference which has been made by the Finance Act, 2010.

on loans were credited to the creditors account on 31.3.2005 to the extent they were paid after the due date for filing return of income u/s.139(1) of the Act, the disallowance was made u/s.40(a)(ia) of the Act. Before the Tribunal, the Assessee contented that the amendment by the Finance Act, 2010 with retrospective effect from 1st April, 2010 whereby amount of tax deducted at the time of making payment in respect of expenditure referred to in Sec.40(a)(ia) of the Act, if paid to the Government on or before the due date for filing the return of income due date u/s 139(1) of the Act should be allowed as a deduction. In other words it was argued that the amendment by the Finance Act, 2010 to the provisions of Sec.40(a)(ia) has to be held to be retrospective w.e.f. 1-4-2005. The ITAT Kolkata Bench by its order dated 15.12.2010, held as follows:

“8. After hearing the rival submissions and on careful perusal of the materials available on record, keeping in view of the fact that though the Ld.D.R. submitted that the decisions of the Coordinate Benches are not binding and the Kolkata benches may take a different view, since Mumbai Bench after analyzing the provisions of Sec.40(a)9ia) since its inception and various amendments made to the same including the suggestion made by the Industry in the form of representation in their pre-budget memorandum to the Hon’ble Finance Minister and by applying the decision of the Hon’ble Apex Court in the case of Alom Extrusions Ltd., has observed that “The provisions of Section 40(a)(ia) as stood prior to the amendments made by the Finance Act 2010 thus were resulting into unintended consequences and causing grave and genuine hardships to the assesses who had substantially complied with the relevant TDS provisions by deducting the taxes at source and by paying the same to the credit of the Government before the due date of filing of their returns u/s.139(1). In order to remedy this position and to remove the hardships which was being caused to the assessee belonging to such category, amendments have been made in the provisions of Section 40(a)(ia) by the Finance Act, 2010. The said amendments, in our opinion, thus are clearly remedial/curative in nature as held by the Hon’ble Supreme Court in the case of Allied Motors Pvt.Ltd. (supra) and Mom Extrusions Ltd. (supra) and the same therefore would apply ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal9

retrospectively w.e.f. 1st April, 2005. In the case of R.B.Jodha Mal Kuthiala 82 ITR 570, it was held by the Hon’ble Supreme Court that a proviso which is inserted to remedy unintended consequences and to make the provision workable, requires to be treated as retrospective in operation so that a reasonable interpretation can be given to the section as a whole. In the present case, the amount of tax deducted at source from the freight charges during the period 01/04/2005 to 28/02/2006 was paid by the Assessee in the month of July and August 2006 i.e., well before the due date of filing of its return of income for the year under consideration. This being the undisputed position, we hold that the disallowance made by the A.O. and confirmed by the learned CIT(A) on account of freight charges by invoking the provisions of Section 40(a)(ia) is not sustainable as per the amendments made in the said provisions by the Finance Act, 2010 which, being remedial/curative in nature, have retrospective application”, we find no reason to deviate from the decisions of the ITAT’s Mumbai Bench and Ahmedabad Bench, in the absence of a contrary view, except the other benches decisions or any other High Court. Therefore, respectfully following the decision of the Coordinate Benches (supra), we allow the ground nos. I to 3 of the assessee’s appeal.

“We have heard Mr. Nizamuddin and gone through the impugned judgment and order. We have also examined the point formulated for which the present appeal is sought to be admitted. It is argued by Mr. Nizamuddin that this court needs to take decision as to whether section 40(A)(ia) is having retrospective operation or not.

The learned Tribunal on fact found that the assessee had deducted tax at source from the paid charges between the period April 1, 2005 and April 28, 2006 and the same were paid by the assessee in July and August 2006, i.e. well before the due date of filing of the return of income for the year under consideration. This factual position was undisputed. Moreover, the Supreme Court, as has been recorded by ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal10

the learned Tribunal, in the case of Allied Motors Pvt. Ltd. and also in the case of Alom Extrusions Ltd., has already decided that the aforesaid provision has retrospective application. Again, in the case reported in 82 ITR 570, the Supreme Court held that the provision, which has inserted the remedy to make the provision workable, requires to be treated with retrospective operation so that reasonable deduction can be given to the section as well. In view of the authoritative pronouncement of the Supreme Court, this court cannot decide otherwise. Hence we dismiss the appeal without any order as to costs.” 13. It can be seen from the above decision of the Hon’ble Calcutta High Court that Amendment to the provisions of Sec.40(a)(ia) of the Act, by the Finance Act, 2010 as aforesaid was held to be retrospective from 1.4.2005. If the amendment is considered as retrospective from 1.4.2005, the effect will be that payments of TDS to the credit of the Government on or before the last date for filing return of income u/s.139(1) of the Act for the relevant AY have to be allowed as deduction. Admittedly in the case of the Assessee payments were so made before the said due date and in terms of the decision of the Hon’ble Calcutta High Court no disallowance could be made by the AO u/s. 40(a)(ia) of the Act.

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therefore the impugned disallowance deserves to be deleted. We order accordingly and allow Gr.No.1 of the appeal by the Assessee.

Sl.No. Name of the party Amount (Rs.) 01. E.K Enterprise 6,00,000/- 02. Jai Ambe Multi Trade Ltd 1,50,000/- 03. Riddhi Siddhi Enterprise 1,26,400/- Total 8,76,400

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and from Riddhi Siddhi Enterprise for Rs. 1,26,440/- and the same were credited in the party ledger besides purchase as against payment made to the party was debited in the party ledger. The assessee was asked to clarify the reason of such credit entries of amount received from the parties. In the course of assessment the A/Rs of the assessee were failed to clarify the same by producing relevant documents, party ledger etc. So, a show cause letter was issued to the assessee requesting to clarify as to why the same would not be considered as income earned by you otherwise which was not routed through P & L A/c. In response, the assessee had submitted that in first two cases, cheques were issued in earlier year. As the said cheques were not cleared the same had been reversed during the year and in the case of Riddhi Siddhi Enterprise the amount was received on behalf of sister concern, M/s. Ayush Steel. This contention of the assessee was not acceptable on the ground that the assessee merely stated in its submission dated 29-11-11 that cheques were issued but not cleared and the same had been reversed back, but in support of his contention, the assessee did not produce any supporting evidence to prove that cheques were issued earlier and the same had been reversed back. Moreover, if the same had been reversed, then a contra entry should have been passed in the party ledger instead of amount receipt. Moreover, in the course of assessment, the ld.AR of the assessee also failed to reconcile the same clearly. A further opportunity was given to the assessee requesting to clarify as to why such amount credited in party ledger should not be treated as purchase discount in nature. In response to the same the ld.AR of the assessee in her submission dated 15-12-2011 deposited in the office counter some unsigned party ledger of the sundry creditors of earlier year along with her submission claiming that these were unclear cheques and the same has been reversed during the year. The assessee's contention is not acceptable on the ground that the assessee made her submission in the office counter, but did not get the ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal13

opportunity to produce the documents before the Assessing Officer so that her claim could be reconciled and verified with the last years purchase/sundry Creditors balance, etc., as well as, through verification of Books of Accounts. Moreover, in the course of assessment the A/R of the assessee appeared to represent the case and had accepted her failure to reconcile the same. So, mere filing of unsigned ledger copies of the parties is not acceptable until and unless the same are verified with other Books of accounts and Bank statements, etc. Since the assessee had failed to do the same, so, no cognizance is given to such unsigned documents produced by the assessee. Moreover, it is also seen from the submitted documents that in the case of Jai Ambe Multi Trade (P) Ltd., in the last financial year 2007-08, a cheque was issued for Rs. 1,50,000/- on 12.06.2007. The assessee claims that such cheque amount was reversed in the ledger account of the financial Year 2008- 09 on 01.04.2008 i.e. near about after one year; the same was credited. The contention of the assessee is not acceptable as nowhere it is mentioned as reverse entry on the contrary. In the confirmation submitted by the party in response to notice issued u/s. 133(6) of the I. T. Act the same has been shown as payment and duly reflected in the Bank Account and for that reason the A/R of the assessee admitted their failure to substantiate their , claim of reversal entry. As regard Jai Ambe Multi Trade (P) Ltd. mere entries shown in unsigned party ledger, not reconciled with Books of accounts, bank statements, are not acceptable as in the course of assessment in spite of several opportunities given, the; A/R of the assessee failed to substantiate the facts. So, it is considered that the assessee had received such income in the nature of Purchase discount from the parties that had not been reflected in the P& L A/c. Considering the above, Rs. 8,76,400/- is treated as income of the assessee for the relevant assessment year and the same is added back to the total income of the assessee. "

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"The assessee would like to humbly submit that the contention of the AO to treat the amounts credited in the ledger of creditors on account of cheque issued but not presented for payment as purchase discount and subsequently treat the same is erroneous and without application of mind. The same is nothing but result of imaginary .thinking from fertile brain. Firstly, even if the unreasonable contention of AO is accepted for a moment that the assessee had received purchase discount in that case, as per elementary accounting principles, the amounts would not have been credited in the books of sundry creditors but debited in their ledger. Thus, the contention of the AO to treat credit entries as purchase discounts is prima facie incorrect and without any logical reasoning. From the show cause dated 24-11-2011, Your Honour will kindly observe that there is no purchase from Riddhi Siddhi Enterprises and the AO has treated entire amount of Rs.1,26,440/- as purchase discount without any purchase . Further, in the present case, the assessee had duly submitted the party ledger of earlier years to show that the credit balances as shown in the ledgers were on account of purchases. The ledger account of the creditor was debited when the cheques were issued but since those cheques were not presented for payment by the creditors to the bank, they were reversed. It is normal trade practice that as and when cheques are issued to the party, the same are debited in the ledger accounts of the party. The AO also stated in the assessment order that since the assessee has failed to substantiate the claim with the help of bank statements in the course of assessment the contention of the assessee to treat the amounts as contra entries are not accepted. In this regard, it is humbly submitted that since the cheques were not presented to banks for payments by the creditors, no debits have been made at the bank account of the assessee. Therefore, the bank statements are not reflecting any debits for cheques which have not been presented for payment. Moreover, the assessee had duly presented party ledger which can be reconciled with books of accounts of the assessee. However, disregarding the submission of the assessee, the AO has simply worked on suspicion and ignoring the basic

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principles of accounting proposed to treat the contra entries as purchase discounts. Vide submission dated 15-12-2011, the assessee had specifically requested the AO to make direct enquiry from both the parties as he has already done in case of so many other creditors. Copy of ledger from DK Enterprises and Jai Je Multi Trade Pvt. Ltd. from 01-04-2007 to 31- 03-2009 (i.e. 2 years) and further certificate from them that cheque of Rs.1,5O,OOO/- is reversal of cheque received in last year was submitted in original. The copy of ledger from both the parties are enclosed herewith as Annexure 8 and 9 and certificate from Jai Ambe Multi Trade Pvt. Ltd is enclosed as Annexure 10.both the parties are enclosed herewith as Annexure 8 and 9 and certificate from Jai Ambe Multi Trade Pvt. Ltd. is enclosed as Annexure 10. The assessee humbly submits that the Hon'ble Jurisdictional Calcutta High Court in the case of Smt. Protima Roy -Vs. CIT (1982) 138 ITR 536 (Cal) has held that what is apparent has to be taken as real unless contrary is proved and the onus to prove the contrary is on the party making allegation. Similar view has also been taken in the case of CIT -vs.- Daulat Ram Rawatmull (1973) 87 ITR 349 (Se) by the Hon'ble Apex Court. In the present case, the AO is making an allegation that credit entries made in the ledger of sundry creditor accounts are purchase discounts, without any evidence of the same. Moreover, the contention of the AO is also based on illogical reasoning which are evidently incorrect. If at all, the assessee would have received any discount, it would have not been credited but debited in the edger. Hence it is pleaded before your good self to reject the false and illogical reasoning as advanced by the AO and treating contra entries in relation to cheques not presented for payment as income of the assessee and delete the additions based on them in the interest of justice. "

“4.2 I have carefully examined and considered the written submissions made by the A.R of the appellant as well as observation of the AO. The contention of the appellant is not acceptable as nowhere it is mentioned ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal16

as reverse entry on the contrary. In the confirmation submitted by the party in response to notice issued u/s. 133(6) of the I.T Act, the same has been shown as payment and duly reflected in the Bank Account, and for that reason, the A/R of the appellant admitted their failure to substantiate their claim of reversal entry. As regard Jai Ambe Multi Trade (P) Ltd, mere entries shown in unsigned party ledger, not reconciled with Books of accounts, bank statements, are not acceptable as in the course of assessment, in spite of several opportunities given, the A/R of the appellant failed to substantiate the facts. So, it is considered that the appellant had received such income in the nature of Purchase discount from the parties that had not been reflected in the P & L A/c. I am of the view that I hold the above addition of Rs.8,76,400/- is treated as income of the appellant for the relevant assessment year and the same is added back to the total income of the appellant as made by the AO. This ground of appeal is dismissed.” 19. We have heard the rival submissions. It is seen from the ledger account of Jai Ambe Multi Trade Pvt. Ltd and & D.K Enterprises for 2 years i.e., 2007-08 and 2008-09 that the Assessee owed to the aforesaid parties a sum of Rs.1,50,000/- and Rs.6,00,000/- respectively. The Assessee issued cheques to the aforesaid parties but as these cheques were not cleared the same has been reversed during the previous year. Perusal of copy of Bank Statements and complete bank book shows that no payment has been received from these parties. There is no entry in bank statement for receipt of these said cheques. Further, the account balance of Jai Ambe Multi Trade Pvt. Ltd is same as per Assessee’s books of accounts. They have not accounted any amount as discount given to the Assessee. From the above one can infer that the assessee has not received any Purchase Discount. Further, when a cheque is reversed, the same can be accounted only by way of receipt voucher in bank book. Copy of Ledger account from both M/s. Jai Ambe Multi Trade (P) Ltd and D.K Enterprise from 01.04.2007 to 31.03.2008 and 01.04.2008 to 31.03.2009 were also perused in this regard. A confirmation letter from Jai Ambe Multi Trade (P) Ltd that cheque of Rs.1,50,000/- was reversed, as it was not cleared is ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal17

also on record. Therefore the assumption that it should be income being in the nature of discount is completely baseless.

“6.2 I have carefully examined and considered the written submission made by the A.R of the appellant as well as observation of the AO. The appellant has claimed that all the expenses were made for wholly and exclusively business purpose. But the appellant’s contention is not acceptable as per tax audit report where in clause 17, it is mentioned that personal nature of expenses is involved in telephone and Motor Car. So 20% of telephone & Motor Car Expenses debited in P & L a/c i.e 20% of [Rs.3,18,848/- + Rs.76,211/-] = Rs.79,011/- and Rs.3,910/- additionally claimed as Telephone Expenses, being treated as wholly personal expenses, i.e totalling to Rs.1,22,921/- is disallowed and added back to the total income of the appellant by the AO. In view of my observation, I uphold and confirm the addition made by the AO. The fails on this ground and I dismissed ground no.4 of the instant appeal. “

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“Regarding disallowance u/s. 24 of the Act of interest of Rs.52,771/- on the Housing Loan. The AO has observed in his assessment order as under:- “In the computation of total income, the assessee had claimed Loss on account of his self-occupied House Property where he had claimed interest on loan amounting to Rs.1,50,000/-. However, from the certificate of loan issued by ICICI Bank, it is seen that the House Property Loan was sanctioned jointly with Mrs. Sangeeta Tekriwal and interest component was Rs. 1,94,458/- for the relevant financial year. Since the assessee is entitled for loss claimed in respect of only one house as self-occupied property, as well as, the loan was granted in joint names, so the assessee was eligible for half of the interest i.e for Rs. ½ X 1,94,458/-=Rs.97,229/- instead of his claim of Rs.1,50,000/-. So, the additional claim of Rs. 52,771/- is disallowed and added back to the total income of the assesse.” 9.1 On the other hand, the A.R. of the appellant has submitted as under: "It is humbly submitted that assessee had taken the loan and the same has been accounted in his balance sheet The entire interest is being paid by assessee only and he has not recovered any interest from Mrs. Sangeeta Tekriwal. Therefore, assessee only is eligible for -deduction under section 24. Mrs. Sangeeta Tekriwal is not incurring any ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal19

interest on the housing loan for the said property and is therefore not eligible for any deduction under section 24. Section 24 of the Act nowhere states that deduction will be allowed only to an assessee who has applied loan without assigning any co-applicant. Actually Mrs. Sangeeta Tekriwal had obtained another loan from ICICI bank which was accounted in her return and she had also paid in her individual capacity Rs.94,483/- on account of principal and Rs.l,2~641/- on account of interest separately. Certificate from ICICI Bank is enclosed and marked as Annex. 11. Without prejudice to above, if the contention of AO is accepted that Mrs.Sangeeta Tekriwal is also a co-owner of the property, in that case also assessee would be entitled to claim 100% of interest as borne by him for the purposes of section 24. This is because, as per Section 26, if the property is owned by co- owners is self occupied by each of the co-owners. each co- owner will be entitled to a deduction of Rs. 150,000/- under section 24(b). The action of the AO to disallow 50% of interest is not in accordance per law. In terms of section 24(b) assessee is eligible to claim Rs. 1,50, 000/-. " 9.2 In view of the above submission made by the appellant as well as A.O observation I am of the view that the A.O. is correct in making 50% disallowed of interest paid on borrowed loan as the loan was sanction jointly and the said property is jointly own by appellant and his wife. Therefore, I hold the addition of Rs.51,771/- on this account. “

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24(b) of the Act on the ground even if the assessee is assumed to be a co- owner, yet u/s. 26 of the Act the claim of assessee for deduction ought to have been allowed. For the reason given above, we allow ground no.4 raised by the assessee.

ORDER PRONOUNCED IN OPEN COURT ON 27 /07 /2016

Sd/- Sd/- P.M Jagtap S.S. Viswanethra Ravi Accountant Member Judicial Member Dated 27 /07/2016

Copy of the order forwarded to 1.. The Appellant/Assessee : Shri Pramod Kumar Tekriwal C/o Shri Kishan Kandoi 15 Gangadhar Babu Lane, 2nd floor, Room No. 204, Kolkata-700012. The Respondent/Department: Income Tax Officer, 2 Ward-30-(3), Kolkata Aaykar Bhavan Dakshin, 2 Gariahat Road (South), Kolkata-700 068. (3) CIT (4) CIT(A) (5) The Departmental Representative (6) Guard File By order Assistant Registrar Income Tax Appellate Tribunal ** PRADIP SPS Kolkata benches, Kolkata ITA No. 2458/K/13 Shri Pramod Kumar Tekriwal21

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Shri Pramod Kumar Tekriwal22