Cheminvest Ltd. v. CIT

378 ITR 33High Court2015#24 most cited

What is Cheminvest Ltd. v. CIT authority for?

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

1,569

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

Cheminvest Ltd. v. CIT · Section 14A disallowance · no exempt income · exempt dividend income · expenditure related to exempt income · Section 8D · Section 115JB · Income-tax Act 1961 · Delhi High Court

Also reported as

61 Taxmann.com 118234 Taxmann 761317 ITD 33281 CTR 447

Sections most often in play

Section 14ASection 143(3)Section 8DSection 115JBSection 250Section 1961Section 37(1)Section 143(2)
Read the full judgment

Issues it is cited on

disallowance u/s 14adisallowance under section 14asection 14asection 36(1)(iii)section 115jbrevenue expendituresection 37(1)section 37section 36previous yearscrutiny assessmentsection 115

Judgments citing Cheminvest Ltd. v. CIT

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

ITA 4250/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai17 Oct 2024

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Ble

For Appellant: Shri Ajit Kumar Jain, A/RFor Respondent: Mr. R.A. Dhyani, CIT D/R & Shri Krishna Kumar, Sr. D/R
Section 14A

…aspect has observed: " 4. Having heard both the sides and perused the relevant material on record, we find that the legal position is no more res integra in view of the judgment of the Hon'ble jurisdictional High Court in the case Cheminvest Ltd v. CIT (2015) 378 ITR 33 (Del), wherein it has been held that if there is no exempt income, there can be no question of making any disallowance u/s 14A. Similar view has been taken by the Hon'ble jurisdictional High Court in CIT v. Holcim India P. Ltd. (2014) 90CCH 081-Del-HC. In view of these binding precedents providing for not making any disallowance u/s 14A in the abs…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

ITA 4249/MUM/2024[AY 2015-16]Status: DisposedITAT Mumbai17 Oct 2024

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Ble

For Appellant: Shri Ajit Kumar Jain, A/RFor Respondent: Mr. R.A. Dhyani, CIT D/R & Shri Krishna Kumar, Sr. D/R
Section 14A

…aspect has observed: " 4. Having heard both the sides and perused the relevant material on record, we find that the legal position is no more res integra in view of the judgment of the Hon'ble jurisdictional High Court in the case Cheminvest Ltd v. CIT (2015) 378 ITR 33 (Del), wherein it has been held that if there is no exempt income, there can be no question of making any disallowance u/s 14A. Similar view has been taken by the Hon'ble jurisdictional High Court in CIT v. Holcim India P. Ltd. (2014) 90CCH 081-Del-HC. In view of these binding precedents providing for not making any disallowance u/s 14A in the abs…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

ITA 4248/MUM/2024[AY 2014-15]Status: DisposedITAT Mumbai17 Oct 2024

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Ble

For Appellant: Shri Ajit Kumar Jain, A/RFor Respondent: Mr. R.A. Dhyani, CIT D/R & Shri Krishna Kumar, Sr. D/R
Section 14A

…aspect has observed: " 4. Having heard both the sides and perused the relevant material on record, we find that the legal position is no more res integra in view of the judgment of the Hon'ble jurisdictional High Court in the case Cheminvest Ltd v. CIT (2015) 378 ITR 33 (Del), wherein it has been held that if there is no exempt income, there can be no question of making any disallowance u/s 14A. Similar view has been taken by the Hon'ble jurisdictional High Court in CIT v. Holcim India P. Ltd. (2014) 90CCH 081-Del-HC. In view of these binding precedents providing for not making any disallowance u/s 14A in the abs…

Incred Holdings Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 6(3)(2), Mumbai

In the result, appeals filed by the assessee in I

ITA 4246/MUM/2024[AY 2013-14]Status: DisposedITAT Mumbai17 Oct 2024

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Ajit Kumar Jain, A/RFor Respondent: Mr. R.A. Dhyani, CIT D/R & Shri Krishna Kumar, Sr. D/R
Section 14A

…aspect has observed: " 4. Having heard both the sides and perused the relevant material on record, we find that the legal position is no more res integra in view of the judgment of the Hon'ble jurisdictional High Court in the case Cheminvest Ltd v. CIT (2015) 378 ITR 33 (Del), wherein it has been held that if there is no exempt income, there can be no question of making any disallowance u/s 14A. Similar view has been taken by the Hon'ble jurisdictional High Court in CIT v. Holcim India P. Ltd. (2014) 90CCH 081-Del-HC. In view of these binding precedents providing for not making any disallowance u/s 14A in the abs…

The Pr. Commissioner of Income Tax -Central -1 vs. Sahara India Financial Corporation Ltd

ITA - 527 / 2024HC Delhi16 Oct 2024
Section 14A

…Section 14A of the Act if the assessee’s income for the relevant assessment year did not include any income that was exempt from the limited tax. This issue is covered by the decision of this Court in Cheminvest Limited v. Commissioner of Income Tax : 2015 378 ITR 33 (Delhi) as well as the recent decision in Principal Commissioner of Income Tax, Central-3, New Delhi v. Alchemist Ltd.: Neutral Citation 2024:DHC:6439-DB. 8. The learned counsel appearing for Revenue has also drawn the attention of this Court to the explanation to Section 14A of the Act, which was inserted by virtue of the Finance Act, 2022.…

M/S. Bhumi Nirman Pvt. Ltd., Kolkata vs. I.T.O., Ward - 10(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1166/KOL/2024[2015-2016]Status: DisposedITAT Kolkata16 Oct 2024AY 2015-2016

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 14ASection 271(1)(c)

…ment Year: 2015-16 M/s. Bhumi Nirman Pvt. Ltd. section 14A if no exempt income was earned by assessee - Held, yes [Paras 9 and 10] [The Hon’ble High Court relied on the order in the case of IL & FS Energy Development Co. Ltd. and Cheminvest Ltd. v. CIT [2015] 378 ITR 33 (Delhi).] 3.1. Accordingly, the appellant gets relief on this point and the addition of Rs. 9,647/- is directed to be deleted.” Considering the findings in the extract above, this issue is decided in favour of the appellant since there is no exempt income earned during the year. 5. In the result, the appeal of the assessee is allowed. Order pronou…

Alluum Conclave Pvt. Ltd., Kolkata vs. ITO, Ward - 5(4), Kolkata

In the result, the appeal filed by the assessee stands allowed

ITA 1042/KOL/2024[2017-2018]Status: DisposedITAT Kolkata16 Oct 2024AY 2017-2018

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 142(1)Section 144Section 14A

…dend income out of the investments made. Therefore, as per the law laid down by various Courts of the country, no disallowance u/s 14A of the Act is attracted. Reliance was placed in the cases of Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi), CIT v. Shivam Motors (P.) Ltd. [2015] 55 taxmann.com 262/230 Taxman 63 (All.), CIT v. Corrtech Energy (P.) Ltd. [2014] 45 taxmann.com 116/223 Taxman 130/[2015] 372 ITR 97 (Guj.), CIT v. Ashika Global Securities Ltd. [GA No. 2122 of 2014, dated 11-6-2018], Redington India Ltd. v. Addl. CIT [2017] 77 taxmann.com 257/392 ITR 633 (Mad.) where…

DCIT, New Delhi vs. M/S. Mahatta Towers Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1137/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Oct 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year : 2012-13] Dcit, Vs M/S. Mahatta Towers Pvt.Ltd., Circle-16(1), 614, Plot No.54, Mahatta Towers, New Delhi. B Block, Community Center, Janakpuri, New Delhi-110058. Pan-Aaacm2109F Appellant Respondent Appellant By Shri Koushlender Tiwari, Cit Dr Respondent By Shri Ved Jain, Adv. Date Of Hearing 13.08.2024 Date Of Pronouncement 10.10.2024

Section 14Section 142(1)Section 143(2)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “E” BENCH: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER & SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER [Assessment Year : 2012-13] DCIT, vs M/s. Mahatta Towers Pvt.Ltd., Circle-16(1), 614, Plot No.54, Mahatta Towers, New Delhi. B Block, Community Center, Janakpuri, New Delhi-110058. PAN-AAACM2109F APPELLANT RESPONDENT Appellant by Shri Koushlender Tiwari, CIT DR Respondent by Shri Ved Jain, Adv. Date of Hearing 13.08.2024 Date of Pronouncement 10.10.2024 ORDER PER KUL BHARAT, JM : The present appeal filed by the Revenue is directed against the order passed by Ld.…

Silverlake Traders Pvt. Ltd., Kolkata vs. ITO, Ward-5(1), Kolkata

In the result, the appeal filed by the assessee is partly allowed

ITA 379/KOL/2024[2009-10]Status: DisposedITAT Kolkata23 Sept 2024AY 2009-10

Bench: Sri Rajpal Yadav, Vice- & Sri Sanjay Awasthi

Section 14ASection 263Section 68

…आयकर अपीलीय अधिकरण कोलकाता 'ए' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘A’ BENCH, KOLKATA श्री राजपाल यादव, उपाध्यक्ष (कोलकाता क्षेत्र) एवं श्री संजय अवस्थी, लेखा सदस्य के समक्ष Before SRI RAJPAL YADAV, VICE-PRESIDENT & SRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A. No.: 379/KOL/2024 Assessment Year: 2009-10 Silverlake Traders Pvt. Ltd……….............................................Appellant [PAN: AAMCS 3292 F] Vs. ITO, Ward-5(1), Kolkata…………………………………………………Respondent Appearances: Assessee represented by: None. Department represented by: Subhendu Datta, CIT DR. Date of concluding the hearing :…

Safal Properties Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(2), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1334/KOL/2024[2016-2017]Status: DisposedITAT Kolkata23 Sept 2024AY 2016-2017

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2016-17

For Appellant: Saurabh Bagaria, ARFor Respondent: P.P Barman, Addl. CIT, Sr. DR
Section 115JSection 143(3)Section 14ASection 250Section 263Section 40Section 57

…n of the High Court of Delhi in Pr. CIT (Central) v. Era Infrastructure (India) Ltd. [2022] 141 taxmann.com 289/288 Taxman 384/448 ITR 674, which had taken note of the decision in the case of Cheminvest Ltd. v. CIT-IV [2015] 61 taxmann.com 118/234, Taxman 761/378 ITR 33 (Delhi), wherein it was held that amendment by the Finance Act, 2022 of Section 14A by inserting a non-obstante clause and explanation would take effect from 01.04.22 and could not be presumed to have retrospective effect and, therefore, on facts the amendment could not be applied to the assessment year under consideration. There was found no erro…

M/S. Salarpuria Homes Pvt. Ltd., Kolkata vs. A.C.I.T., Circle - 1(2), Kolkata

In the result, appeal filed by the assessee is allowed

ITA 1360/KOL/2024[2014-2015]Status: DisposedITAT Kolkata13 Sept 2024AY 2014-2015

Bench: Shri Sonjoy Sarma, Judicial Member Shri Rakesh Mishra (Accountant Member)

Section 143(3)Section 14ASection 250

…expressed by the High Courts at Calcutta, Delhi, Gujarat, Madras& Allahabad. The relevant citations are as follows: - CIT v. Ashika Global Securities Ltd. [GA No. 2122 of 2014, dated 11-6-2018] - Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi) - Pr. CIT v. IL & FS Energy Development Co. (P.) Ltd. [2017] 84 taxmann.com 186/250 Taxman 174/399 ITR 483 (Delhi) - CIT v. Corrtech Energy (P.) Ltd. [2014] 45 taxmann.com 116/223 Taxman 130/[2015] 372 ITR 97 (Guj.) - CIT v. Shivam Motors (P.) Ltd. [2015] 55 taxmann.com 262/230 Taxman 63 (All.) - Redington India Ltd. v. Addl. CIT [2017] 77…

Miranda Tools Private Limited, Mumbai vs. DCIT-7(3)(2), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1599/MUM/2023[2014-15]Status: DisposedITAT Mumbai13 Sept 2024AY 2014-15

Bench: Shri Om Prakash Kant & Shri Sunil Kumar Singh

For Appellant: Shri Anuj KisnadwalaFor Respondent: Smt. Mahita Nair, Sr.DR
Section 14Section 143(3)Section 14A

…st Association [1992] 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in IL & FS Energy Development Company Ltd (supra) and Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi).” 7. Further, the Tribunal in the case of M/s. PMP Auto Components Pvt. Ltd., vs. DCIT in ITA(TP) No. 587/Mum/2017, AY. 2012-13 has restricted the disallowance to the extent of dividend income observing as under: “25. Issue no.5 is in connection with the disallowance of u/s 14A of Act. The assessee has earned the dividend income of Rs.1,1…

Miranda Tools Private Limited, Mumbai vs. DCIT RG 7(3)(2), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1598/MUM/2023[2013-14]Status: DisposedITAT Mumbai13 Sept 2024AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sunil Kumar Singh

For Appellant: Shri Anuj KisnadwalaFor Respondent: Smt. Mahita Nair, Sr.DR
Section 14Section 143(3)Section 14A

…st Association [1992] 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in IL & FS Energy Development Company Ltd (supra) and Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi).” 7. Further, the Tribunal in the case of M/s. PMP Auto Components Pvt. Ltd., vs. DCIT in ITA(TP) No. 587/Mum/2017, AY. 2012-13 has restricted the disallowance to the extent of dividend income observing as under: “25. Issue no.5 is in connection with the disallowance of u/s 14A of Act. The assessee has earned the dividend income of Rs.1,1…

New India Retailing & Investment Ltd., Kolkata vs. D.C.I.T., Circle - 5(1), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1285/KOL/2024[2018-2019]Status: DisposedITAT Kolkata11 Sept 2024AY 2018-2019

Bench: Sri Sonjoy Sarma & Sri Sanjay Awasthi

Section 14A

…ment year, no disallowance could be made under section 14A if no exempt income was earned by assessee - Held, yes [Paras 9 and 10] [The Hon’ble High Court relied on the order in the case of IL & FS Energy Development Co. Ltd. and Cheminvest Ltd. v. CIT [2015] 378 ITR 33 (Delhi).] 3.1. Accordingly, the appellant gets relief on this point and the addition of Rs. 9,647/- is directed to be deleted.” It also deserves to be mentioned that in the case of Era Infrastructure (supra) it has been held that the insertion of Explanation to Section 14A of the Act shall not apply retrospectively. Apart from this, a recent judgm…

Artline Financial Management Pvt. Ltd., Kolkata vs. I.T.O., Ward - 14(3), Kolkata

In the result, appeal filed by the assessee is allowed

ITA 1297/KOL/2024[2013-2014]Status: DisposedITAT Kolkata10 Sept 2024AY 2013-2014

Bench: Sri Sonjoy Sarma & Sri Sanjay Awasthi

Section 14Section 14ASection 37

…ment year, no disallowance could be made under section 14A if no exempt income was earned by assessee - Held, yes [Paras 9 and 10] [The Hon’ble High Court relied on the order in the case of IL & FS Energy Development Co. Ltd. and Cheminvest Ltd. v. CIT [2015] 378 ITR 33 (Delhi).] 3.1. Accordingly, the appellant gets relief on this point and the addition of Rs. 9,647/- is directed to be deleted.” 3.1. Furthermore, the prospective operation of the clarificatory amendment vide Finance Act, 2022 has been dealt with in the case of Pr. CIT vs. Avantha Realty Ltd. reported in [2024] 164 taxmann.com 376 (Calcutta). Some…

DCIT CC 1(1), Mumbai vs. Edel Finance Company Ltd., Mumbai

In the result, appeal of the revenue is partly allowed, and cross objection of the assessee is dismissed as withdrawn

ITA 3025/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Sept 2024AY 2018-19

Bench: Shri Anikesh Banerjee () & Shri Girish Agrawal ()

Section 10(34)Section 143(3)Section 144BSection 14ASection 250Section 94(7)

…Trust Association [1992] 3 SCC 1, the present appeal is dismissed being covered by the judgment passed by the learned predecessor Division Bench in IL & FS Energy Development Co. Ltd. (supra) and Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi). 10. Accordingly, the appeal and application are dismissed. However, it is clarified that the order passed in the present appeal shall abide by the final decision of the Supreme Court in the SLP filed in the case of IL & FS Energy Development Co. Ltd. (supra).” Considering the above discussion, we are not interferingin the impugned appeal…

Multiple Concrete Pvt. Ltd., Kolkata vs. ITO, Ward-10(3), Kolkata

The appeal of the assessee is allowed

ITA 341/KOL/2024[2012-13]Status: DisposedITAT Kolkata30 Aug 2024AY 2012-13

Bench: Shri Sonjoy Sarma, Jm & Shri Rakesh Mishra, Am Income Tax Officer, Ward 10(3), Multiple Concrete Pvt. Ltd. 13, Dum Dum Road, Aaykar Bhavan, Vs. Kolkata-700 074 P-7, Chowringhee Square, Kolkata (Appellant) (Respondent) Pan No. Aabcm7885R Assessee By : Shri S.K. Tulsiyan & Ms. Puja Somani, Ars Revenue By : Shri Rakesh Kumar Das, Dr Date Of Hearing: 06.08.2024 Date Of Pronouncement : 30.08.2024

For Appellant: Shri S.K. Tulsiyan &For Respondent: Shri Rakesh Kumar Das, DR
Section 143(2)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI SONJOY SARMA, JM AND SHRI RAKESH MISHRA, AM Income Tax Officer, Ward 10(3), Multiple Concrete Pvt. Ltd. 13, Dum Dum Road, Aaykar Bhavan, Vs. Kolkata-700 074 P-7, Chowringhee Square, Kolkata (Appellant) (Respondent) PAN No. AABCM7885R Assessee by : Shri S.K. Tulsiyan & Ms. Puja Somani, ARs Revenue by : Shri Rakesh Kumar Das, DR Date of hearing: 06.08.2024 Date of pronouncement : 30.08.2024 O R D E R PER SONJOY SARMA, JM: 01. The caption appeal filed by the assessee is directed against the order passed by the National Faceless Appeal Centre, De…

Deputy Commissioner of Income Tax, Circle-7.1.1, Bangalore vs. Tally Solutions Private Limited, Bangalore

In the result, the appeal filed by the revenue is partly allowed for statistical purposes

ITA 177/BANG/2024[2017]Status: DisposedITAT Bangalore30 Aug 2024

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadavassessment Years: 2017-18

For Appellant: Ms. Tanmayee Rajkumar, AdvocateFor Respondent: Shri Subramanian S, JCIT
Section 14ASection 35

…d to calculate the disallowance based upon the investments made by the assessee. The CIT(A) and the Income Tax Appellate Tribunal (ITAT) allowed the assessee's appeals by following the ruling in 'Cheminvest Ltd. v. CIT [2015] 61 taxmann.com 118/234 Taxman 761/378 ITR 33 (Delhi); the Court had then held that in the absence of any exempt income disallowance was impermissible. For the relevant Assessment Year (2013-14), concededly, the assessee did not report any exempt income. Consequently, no substantial question of law arises; the appeal is therefore dismissed alongwith the pending application. 21.2 In view of t…

DCIT, 14(1)(2), Mumbai vs. Vedhas Realtors Private Limited, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 750/MUM/2024[2015-16]Status: DisposedITAT Mumbai22 Aug 2024AY 2015-16

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri Surendra Meena, Sr DR
Section 142(1)Section 143(2)Section 143(3)Section 14ASection 154Section 250Section 68Section 69C

…s exempt income by the AO is in fact the gains earned by the assessee from the investments. The Revenue could not bring any material to controvert the aforesaid factual position. 18. We find that the Hon’ble Delhi High Court in Cheminvest Ltd. v. CIT: [2015] 378 ITR 33 (Delhi) held that section 14A will not apply if no exempt income is received or receivable during the relevant previous year. We further find that the Hon’ble jurisdictional High Court in Pr.CIT v/s Kohinoor Project (P) Ltd., [2020] 121 taxmann.com 177 (Bom.), rendered similar findings and dismissed the Revenue’s appeal on a similar issue. Since,…

Elegant Dealmark Pvt. Ltd., Kolkata vs. ITO, Ward-5(3), Kolkata

In the result, the appeal filed by the assessee is partly allowed, with Ground No

ITA 51/KOL/2024[2012-13]Status: DisposedITAT Kolkata21 Aug 2024AY 2012-13

Bench: Sri Rajpal Yadav, Vice- & Sri Sanjay Awasthi

Section 131Section 14ASection 68

…आयकर अपीलीय अधिकरण कोलकाता 'ए' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘A’ BENCH, KOLKATA श्री राजपाल यादव, उपाध्यक्ष (कोलकाता क्षेत्र) एवं श्री संजय अवस्थी, लेखा सदस्य के समक्ष Before SRI RAJPAL YADAV, VICE-PRESIDENT & SRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A. No.: 51/KOL/2024 Assessment Year: 2012-13 Elegant Dealmark Pvt. Ltd......................................................Appellant [PAN: AACCE 7972 Q] Vs. ITO, Ward-5(3), Kolkata........................................................Respondent Appearances: Assessee represented by: None. Department represented by: B.K. Singh, Addl.…