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56 results for “bogus purchases”+ Penaltyclear

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Key Topics

Section 14855 Section 14747 Addition to Income40 Section 25035 Section 143(3)33 Section 143(2)29 Section 6828 Section 271(1)(c)26 Section 69C22

M/S. OM STEEL INDIA,HOWRAH vs. ACIT/ITO, NFAC, DELHI

In the result, the appeal of the assessee is allowed

ITA 1288/KOL/2024[2011-2012]Status: DisposedITAT Kolkata04 Dec 2024AY 2011-2012

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2011-12

For Appellant: Shri Arya Das, ARFor Respondent: Shri P. P. Barman, CIT DR

Section 143(3)Section 147Section 250Section 271(1)(C)Section 271(1)(c)

bogus purchases, thereby the penalty proceedings became infructuous as the penalty proceeding was initiated on the ground of alleged bogus

Showing 1–20 of 56 · Page 1 of 3

Reopening of Assessment15

Unexplained Cash Credit14

Limitation/Time-bar13

DCIT, CENTRAL CIRCLE-1(4), KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LTD., KOLKATA

In the result, the appeals of the Revenue are dismissed and the\nCOs of the assessee are partly allowed

ITA 2178/KOL/2024[2013-14]Status: DisposedITAT Kolkata28 Oct 2025AY 2013-14

Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

bogus purchases. Accordingly, we uphold the order of Id.\nCIT (A) by dismissing the appeal of the Revenue on this issue. Ground\nno.3 of Revenue's appeal is dismissed.\n025. The issue raised by Revenue in Ground no.4 and 5, is against\nthe deletion of addition of ₹2,57,72,500/-, by the Id. CIT (A) as made

MINA PRADHAN,KOLKATA vs. I.T.O., WARD - 42(4), KOLKATA, KOLKATA

In the result, the appeal filed by the assessee for AY 2017-18 is allowed

ITA 1587/KOL/2024[2017-2018]Status: DisposedITAT Kolkata27 Nov 2024AY 2017-2018

Bench: Sri Sanjay Garg & Sri Rakesh Mishra

Section 143(3)Section 148Section 69C

purchase transactions amounting to Rs. 34,59,840/- should be treated as unexplained expenditure u/s 69C and added back to your income.” 3.2. The Assessing Officer (hereinafter referred to as ‘the ld. AO’) in para 7.2 has held that since the assessee has herself accepted that she had indulged in bogus transactions whose sole purpose was to evade taxes, therefore

MINA PRADHAN,KOLKATA vs. I.T.O., WARD - 42(4), KOLKATA, KOLKATA

In the result, the appeal filed by the assessee for AY 2017-18 is allowed

ITA 1588/KOL/2024[2018-2019]Status: DisposedITAT Kolkata27 Nov 2024AY 2018-2019

Bench: Sri Sanjay Garg & Sri Rakesh Mishra

Section 143(3)Section 148Section 69C

purchase transactions amounting to Rs. 34,59,840/- should be treated as unexplained expenditure u/s 69C and added back to your income.” 3.2. The Assessing Officer (hereinafter referred to as ‘the ld. AO’) in para 7.2 has held that since the assessee has herself accepted that she had indulged in bogus transactions whose sole purpose was to evade taxes, therefore

DCIT, CENTRAL CIRCLE-1(4), KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LIMITED, KOLKATA

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2179/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR

Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

bogus purchases. Accordingly, we uphold the order of ld. CIT (A) by dismissing the appeal of the Revenue on this issue. Ground no.3 of Revenue’s appeal is dismissed. 025. The issue raised by Revenue in Ground no.4 and 5, is against the deletion of addition of ₹2,57,72,500/-, by the ld. CIT (A) as made

DCIT, CENTRAL CIRCLE-1(4), KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LIMITED, KOLKATA

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2187/KOL/2024[2015-16]Status: DisposedITAT Kolkata28 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR

Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

bogus purchases. Accordingly, we uphold the order of ld. CIT (A) by dismissing the appeal of the Revenue on this issue. Ground no.3 of Revenue’s appeal is dismissed. 025. The issue raised by Revenue in Ground no.4 and 5, is against the deletion of addition of ₹2,57,72,500/-, by the ld. CIT (A) as made

DCIT, CENTRAL CIRCLE-1(4), KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LIMITED, KOLKATA

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2196/KOL/2024[2018-19]Status: DisposedITAT Kolkata28 Oct 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR

Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

bogus purchases. Accordingly, we uphold the order of ld. CIT (A) by dismissing the appeal of the Revenue on this issue. Ground no.3 of Revenue’s appeal is dismissed. 025. The issue raised by Revenue in Ground no.4 and 5, is against the deletion of addition of ₹2,57,72,500/-, by the ld. CIT (A) as made

DCIT CENTRAL CIRCLE 1 4 KOLKATA, KOLKATA vs. MURLIDHAR RATANLAL EXPORTS LIMITED, KOLKATA

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2245/KOL/2024[2016-17]Status: DisposedITAT Kolkata28 Oct 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR

Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

bogus purchases. Accordingly, we uphold the order of ld. CIT (A) by dismissing the appeal of the Revenue on this issue. Ground no.3 of Revenue’s appeal is dismissed. 025. The issue raised by Revenue in Ground no.4 and 5, is against the deletion of addition of ₹2,57,72,500/-, by the ld. CIT (A) as made

M D DIESEL SPARES,HOWRAH vs. ITO, WARD-47, KOLKATA

In the result, the appeal of the assessee stands allowed

ITA 1430/KOL/2023[2012-2013]Status: DisposedITAT Kolkata03 May 2024AY 2012-2013

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.1430/Kol/2023 Assessment Year: 2012-13 M D Diesel Spares………..………………………… ........................……Appellant 7/12, Kings Road, Howrah-711101. [Pan: Aakfm7649F] Vs. Ito, Ward-47(2), Kolkata..................…................…........……...…..…..Respondent Appearances By: Shri A. K. Tibrewal & Saurabh Gupta, Ar, Appeared On Behalf Of The Appellant. Shri Prabir Gupta Choudhury, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 26, 2024 Date Of Pronouncing The Order : May 03, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 28.10.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Addition Of Rs.18,85,520/- Made By The Assessing Officer U/S 69C Of The Act On Account Of Bogus Purchases. 3. The Brief Facts Of The Case Are That The Assessee Firm Is Involved In The Business Of Spare Parts Of The Machinery. The Assessee Firm For The Year Under Consideration Filed Its Return Of Income Declaring A Total Income Of Rs.45,150/-. The Said Return Was Processed U/S 143(1) Of The

Section 143(1)Section 147Section 250Section 271(1)(c)Section 69C

bogus purchase claim of the assessee and added with the returned income of the assessee on account of unexplained expenditure u/s 69C of the I.T. Act, 1961. Therefore, the said sum of Rs. 18,85,520/- is considered as undisclosed income of the assessee and assessment is made accordingly. Penalty

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(1), KOLKATA, KOLKATA vs. AXIS OVERSEAS LIMITED, KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2425/KOL/2024[2013-14]Status: DisposedITAT Kolkata03 Dec 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Tax, Cc 1(1), Kolkata Axis Overseas Limited Aaykar Bhawan Poorva, 21A, Shakespeare Sarani, Vs. 3Rd Floor, Kolkata-700107, Kolkata-700107, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aagca7497L Assessee By : Shri Siddharth Agarwal, Ar Revenue By : Shri P.N. Barnwal, Dr Date Of Hearing: 13.11.2025 Date Of Pronouncement: 03.12.2025

For Appellant: Shri Siddharth Agarwal, ARFor Respondent: Shri P.N. Barnwal, DR

Section 133(6)Section 68

bogus. Further, the AO has also stated that in the post survey enquiry the statement of director of M/s Axis Overseas Ltd. Mr. Aditya Sharda was recorded on 05.02.2013 where he also could not explain the said incriminating documents. The AO disallowed the amount of Rs. 82,00,861/- calculated on the basis of cash vouchers impoundedand marked as AOL/08

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 4(1), KOLKATA vs. SENDOZ COMMERCIALS PRIVATE LIMITED, KOLKATA

The appeal of the revenue is hereby dismissed

ITA 28/KOL/2025[2017]Status: DisposedITAT Kolkata30 Apr 2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.28/Kol/2025 Assessment Year: 2017-18 Acit, Central Circle-4(1), Kolkata ………………………………….…..……Appellant Vs. Sendoz Commercials Pvt. Ltd…………..……...........……........……...…..…..Respondent 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] C.O. No.12/Kol/2025 (Arising Out Of I.T.A. No.28/Kol/2025) Assessment Year: 2017-18 Sendoz Commercials Pvt. Ltd …………..………….………………..….…..Cross-Objector 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] Vs. Acit, Central Circle-4(1), Kolkata.............................……........……...…..…..Respondent Appearances By: Shri A. K. Tulsyan, Fca & Deepak Mudhra, Aca, Appeared On Behalf Of The Assessee. Shri Prabhakar Prakash Ranjan, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 30, 2025 Date Of Pronouncing The Order : April 30, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal & The Assessee Has Filed The Corresponding Cross-Objection Against The Same Order Dated 27.08.2024 By The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Relating To Assessment Year 2017-18. 2. At The Outset, The Registry Has Informed That There Is A Delay Of 37 Days In Filing The Present Appeal. The Revenue Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case.

Section 115BSection 133(6)Section 143(2)Section 143(3)Section 148Section 69C

bogus purchases by citing the reason that the suppliers were not traceable during assessment proceedings. Nevertheless, the assessee was in possession of vital evidences in his possession to prima facie substantiate his purchases to some extent particularly when the payments were though banking channels, Merely because the suppliers could not be traced at the given address would not automatically lead

M/S. BLACKSTONE OVERSEAS PVT. LTD.,KOLKATA vs. I.T.O., WARD-5(1),, KOLKATA

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

ITA 2026/KOL/2025[2016-2017]Status: DisposedITAT Kolkata18 Dec 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pradeep Dung Dung, DR

Section 143(1)Section 143(2)Section 148Section 148ASection 151

bogus purchases to the tune of ₹54,94,151/- from shell company M/s Ranisati Metal Industries, M/s Ranisati Industries Ltd and TIF Castings Limited. Accordingly, notice u/s 148A(b) of the Act was issued on 30.03.2023. The ld. AR submitted before us that the second notice u/s 148A(b) of the Act dated 25.04.2023 was invalid since, the time period

BLACKSTONE OVERSEAS PVT. LTD.,KOLKATA vs. I.T.O., WARD - 5(1),, KOLKATA

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

ITA 2027/KOL/2025[2018-2019]Status: DisposedITAT Kolkata18 Dec 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pradeep Dung Dung, DR

Section 143(1)Section 143(2)Section 148Section 148ASection 151

bogus purchases to the tune of ₹54,94,151/- from shell company M/s Ranisati Metal Industries, M/s Ranisati Industries Ltd and TIF Castings Limited. Accordingly, notice u/s 148A(b) of the Act was issued on 30.03.2023. The ld. AR submitted before us that the second notice u/s 148A(b) of the Act dated 25.04.2023 was invalid since, the time period

RAMESHWAR SHAW,HOWRAH vs. ITO, 48(3),KOLKATA. , KOLKATA

In the result, the appeal filed by the assessee bearing

ITA 841/KOL/2023[2013-14]Status: DisposedITAT Kolkata12 Feb 2024AY 2013-14

Bench: Shri Rajesh Kumar & Shri Anikesh Banerjeei.T.A. No. 841/Kol/2023 Assessment Year: 2013-2014 Rameshwar Shaw,....................................Appellant 12/5, Musalmanpara Lane, Banta, Howrah-711101 [Pan: Amaps0893D] -Vs.- Income Tax Officer,.................................Respondent Ward-48(3), Kolkata, 3, Government Place (West), Kolkata-700001 Appearances By: Shri Debabrata Ghosh, A.R., Appeared On Behalf Of The Assessee Shrip.P. Barman, Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : February 12, 2024 Date Of Pronouncing The Order : February 12, 2024

Section 133(6)Section 143(2)Section 144Section 250

bogus sundry creditors, Penalty proceedings u/s 271(1)(c) & u/s 271(1)(b) initiated separately. The ld. D.R. further argued that in any case there was no verification was done. The entire sundry creditors are non- 6 Rameshwar Shaw verified from the end of the Revenue. So, further investigation should be required in relation to the sundry creditors

MITUL PRAVINCHANDRA MALANI, ,KOLKATA vs. ACIT, CIR. 33, KOLKATA

In the result, the appeal of the assessee is partly allowed while the penalty of ₹9,560/- imposed is hereby cancelled

ITA 931/KOL/2024[2014-15]Status: DisposedITAT Kolkata17 Oct 2024AY 2014-15

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2014-15

For Appellant: Anil Kochar, AdvocateFor Respondent: Subhendu Datta, CIT DR

Section 143(3)Section 250Section 271(1)(c)Section 274

Bogus’. Penalty proceedings under section 271(1)(c) of the Act were also initiated by the Ld. AO for furnishing inaccurate particulars of income and penalty show cause notice was issued to the appellant. Consequently, penalty order u/s 271(1)(c) of the Act was passed on 28.06.2017 levying a penalty of Rs. 9,560/- against the assessee for furnishing

PRAMOD KUMAR SARAF,KOLKATA vs. ITO, WARD-22(2), KOLKATA

In the result, the appeal of the assessee stands allowed

ITA 683/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Aug 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.683/Kol/2024 Assessment Year: 2014-15 Pramod Kumar Saraf...…………….....……………………....………....Appellant 24, R. N Mukherjee Road, Mission Row, Kol-1. [Pan: Apkps6814F] Vs. Ito, Ward-22(2), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Sunil Surana, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 26, 2024 Date Of Pronouncing The Order : August 28, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.03.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Levy/Confirmation Of Penalty U/S 271(1)(C) Of The Act. 3. The Brief Facts Of The Case Are That The Assessee Had Claimed Long- Term Capital Gains On Account Of Sale Of Shares At Rs.7,10,447/-. During The Assessment Proceedings, The Assessee Produced Relevant Documents To Substantiate His Claim, However, The Assessing Officer Held That As Per The Report Received From The Investigation Wing, There Was Large Scale Price Rigging Of Certain Scrips, Whereby, The Bogus Long-Term

Section 250Section 271(1)(c)

purchaser of the shares and the assessee has earned only small amount of long-term capital gains of Rs.7,10,447/-. Had the assessee any prior information I.T.A. No.683/Kol/2024 Assessment Year: 2014-15 or intention to claim bogus long-term capital gains, the assessee would have claimed higher amount in this respect. He has further submitted that the revenue could

RAM AWATAR DHOOT,KOLKATA vs. WARD 22(4) KOLKATA, KOLKATA

In the result, the appeal of the assessee stands allowed

ITA 91/KOL/2024[2015-16]Status: DisposedITAT Kolkata29 Aug 2024AY 2015-16

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.91/Kol/2024 Assessment Year: 2015-16 Ram Awatar Dhoot…...…………….....……………………....………....Appellant 29B, Rabindra Sarani Floor, Room No.10E, Kolkata-700073. [Pan: Adepd7419F] Vs. Ito, Ward-22(4), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Ram Awatar Dhoot, Self, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 27, 2024 Date Of Pronouncing The Order : August 29, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Levy/Confirmation Of Penalty U/S 271(1)(C) Of The Act. 3. The Brief Facts Of The Case Are That The Assessee Had Claimed Long- Term Capital Gains On Account Of Sale Of Shares At Rs.14,94,407/-. During The Assessment Proceedings, The Assessee Produced Relevant Documents To Substantiate His Claim, However, The Assessing Officer Held That As Per The Report Received From The Investigation Wing, There

Section 250Section 271(1)(c)

purchaser of the I.T.A. No.91/Kol/2024 Assessment Year: 2015-16 Ram Awatar Dhoot shares and the assessee has earned only small amount of long-term capital gains of Rs.4,61,771/-. Had the assessee any prior information or intention to claim bogus long-term capital gains, the assessee would have claimed higher amount in this respect. He has further submitted that

RAJPAL GUPTA,HOWRAH vs. I.T.O., WARD - 47(1),, KOLKATA

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1276/KOL/2025[2019-2020]Status: DisposedITAT Kolkata30 Oct 2025AY 2019-2020

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1276/Kol/2025 Assessment Year: 2019-2020 Rajpal Gupta,…………………………………..……Appellant 103/25, Foreshore Road, Shibpur, Howrah-711102, West Bengal [Pan:Adtpg4725E] -Vs.- Income Tax Officer,……………………………..Respondent Ward-47(1), Kolkata, 3, Government Place (West), Kolkata-700001 Appearances By: Shri Avijit Ghosal, Advocate, Appeared On Behalf Of The Assessee Shri Mrinmay Basak, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: October 14, 2025 Date Of Pronouncing The Order: October 30, 2025 O R D E R

Section 271ASection 69C

bogus purchases as unexplained expenditure and the same was brought to tax under section 69C of the Act and penalty

PRAMOD LAKRA DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. URVASHI SAREES PVT. LTD, KOLKATA

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 222/KOL/2025[2015-16]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-16

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

penalties and writ petition filed by the various assessee in the Calcutta High Court against the order U/s 148A(d) and notice U/s148, as well as collecting and arranging the required documents/files for the 2nd appeal. Therefore, it is requested to kindly condone the delay of 101 days in filing appeal before the Hon'ble ITAT, Kolkata for the sake

URVASHI SAREES PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1946/KOL/2024[2015-2016]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-2016

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

penalties and writ petition filed by the various assessee in the Calcutta High Court against the order U/s 148A(d) and notice U/s148, as well as collecting and arranging the required documents/files for the 2nd appeal. Therefore, it is requested to kindly condone the delay of 101 days in filing appeal before the Hon'ble ITAT, Kolkata for the sake