ACIT, Circle-43, Kolkata, Kolkata v. M/S. Jewel India Jewellers, Kolkata

ITA 202/KOL/2015 | 2011-2012
Pronouncement Date: 04-10-2016

Appeal Details

RSA Number 20223514 RSA 2015
Assessee PAN AACFJ4832H
Bench Kolkata
Appeal Number ITA 202/KOL/2015
Duration Of Justice 1 year(s) 7 month(s) 7 day(s)
Appellant ACIT, Circle-43, Kolkata, Kolkata
Respondent M/S. Jewel India Jewellers, Kolkata
Appeal Type Income Tax Appeal
Pronouncement Date 04-10-2016
Appeal Filed By Department
Bench Allotted B
Tribunal Order Date 04-10-2016
Date Of Final Hearing 18-07-2016
Next Hearing Date 18-07-2016
Assessment Year 2011-2012
Appeal Filed On 25-02-2015
Judgment Text
ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 1 IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH KOLKATA BEFORE SHRI P.M.JAGTAP ACCOUNTANT MEMBER AND SHRI S.S.VISWANETHRA RAVI JUDICIAL MEMBER I.T.A. NO. 202/KOL/2015 A.Y: 2011-12 ASSTT. COMMISSIONER OF VS. JEWEL INDIA JEWELLER S INCOME-TAX CIR-43 KOLKATA PAN:AACFJ 4832H (APPELLANT) (RESPONDENT) APPEARANCES BY: SHRI NIRAJ KUMAR CIT LD. SR.DR FOR THE REVENUE SHRI S.M SURANA ADVOCATE LD.AR OF THE ASSESSEE DATE OF HEARING : 18-07- 2016 DATE OF PRONOUNCEMENT : 04 -10-2016 O R D E R SHRI S.S. VISWANETHRA RAVI JM :- THIS APPEAL BY THE REVENUE IS DIRECTED AGAINST THE ORDER DATED 13-11-2014 OF THE COMMISSIONER OF INCOME TAX(APPEALS) XXX KOLKATA FOR THE ASSESSMENT YEAR 2011-12. 2. IN THIS APPEAL THE REVENUE HAS RAISED THE FOLLO WING EFFECTIVE GROUNDS:- (I) THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF T HE CASE LD. CIT(A) HAS ERRED IN DELETING THE ADDITION ON UNDERV ALUATION OF CLOSING STOCK FOR RS.8 73 46 711/- WITHOUT CONSIDER ING THE FACT THAT THE ASSESSEE HAS NEVER CLAIMED THE VALUE OF ST OCK OF GOLD FOR THE F. YR. 2004-05 2005-06 IN THE VALUATION OF CLOSING STOCK FOR THE A. YR. 2009-10 DURING THE COURSE OF ASSESSM ENT PROCEEDINGS FOR THE A. YR. 2009-10. BUT THE SAME WA S CLAIMED ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 2 IN THE COURSE OF ASSESSMENT PROCEEDINGS FOR THE A. YR. 2011-12 IN THE VALUATION OF CLOSING STOCK. THIS DISCREPANCY IS OF A VERY SERIOUS NATURE AND CONTRADICTS THE CLAIM MADE BY TH E ASSESSEE THAT IT HAS CONSISTENTLY FOLLOWED THE UFO METHOD OF CLOSING STOCK. (II) THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE LD. CIT(A) HAS ERRED IN NOT CONSIDERING THE FACT THAT T HE ASSESSEE HAS ATTRIBUTED THE ENTIRE VALUE ADDITION TO THE STO CK OF FINANCIAL YEAR 2010-11 BUT THE ASSESSEE HAS NOT GIVEN ANY CON CLUSIVE PROOF THAT NO VALUE ADDITION WAS MADE TO THE STOCK OF FINANCIAL YEAR 2004-05 2005-06 AND 2006-07. (III) THAT THE PETITIONER CRAVES LEAVE TO ADD AMEN D AND WITHDRAW ANY GROUND OF APPEAL AT THE TIME OF HEARIN G. 3. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE IS A FIRM AND MANUFACTURER OF JEWELLERY OF GOLD DIAMOND AND OTHE R PRECIOUS AND SEMIPRECIOUS STONES. THE ASSESSEE FILED ITS RET URN DECLARING TOTAL INCOME OF RS.87 80 980/-FOR THE ASSESSMENT YE AR 2011-12 ON 31-08-2011. UNDER SCRUTINY NOTICE U/S 143(2) AND THEREAFTER NOTICE U/S. 142(1) WERE ISSUED IN RESP ONSE TO WHICH THE ASSESSE FILED WRITTEN SUBMISSIONS AND DOCUMENTS . 4. DURING SUCH PROCEEDINGS THE AO FOUND FROM THE T AX AUDIT REPORT THE VALUE OF CLOSING STOCK WAS DISCLOSED AT RS.14 26 62 442/- AND FURTHER NOTICED THAT THE RAW MATERIAL WAS VALUED AT LOWER OF COST OR MARKET PRICE AND FIN ISHED GOODS WAS VALUED AT LOWER OF ESTIMATED COST OR MARKET PRI CE. THE AO WAS OF THE VIEW THAT THE ASSESSEE UNDER VALUED CLOS ING STOCK AND IN THIS REGARD THE ASSESSEE FURNISHED THE CORRE SPONDING VALUATION OF CLOSING STOCK AS ON 31-03-2011 IS AS U NDER: PARTICULARS QUANTITY AMOUNT (IN RS.) GOLD 68084.120 GRAMS 65 694 587.00 DIAMOND 5660.298 CT. 69 936 269.00 ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 3 RUBY 9722.480 CT 3 100 822.00 EMERALD 4498.475 CT. 1 966 376.00 PEARLS 8039.979 GRAMS 606 345.00 BLUE SAPPHIRE 3190.980 CT. 546 735.00 MULTI SAPPHIRE 3340.580 CT 291 518.00 SEMI PRECIOUS 11372.620 278 995.00 IMITATION STONE 5086.449 CT. 202 795.00 TOTAL 142 624 442.00 5. BASING ON ABOVE INFORMATION AS PROVIDED BY THE A SSESSEE THE AO SUMMARIZED THE VALUATION OF STOCK AS UNDER: TOTAL VALUE OF STONE & OTHER ITEMS RS. 7 69 29 855/ - ADD: GOLD VALUE RS. 6 56 94 587/- TOTAL VALUE OF STOCK RS.14 26 24 442/ TOTAL GOLD STO CK IN TERMS OF PURE GOLD 107167.19 GRAMS LESS : GOLD DEPOSIT AS CLAIMED BY THE ASSESSEE 39083.07 GRAMS NET GOLD STOCK IN TERMS OF PURE GOLD 68084.12 GRAMS 6. THE AO WAS OF THE VIEW THAT THE ASSESSEE DELIBE RATELY UNDERVALUING STOCK BY FOLLOWING LIFO METHOD OF VALU ATION OF GOLD STOCK AND PROPOSED FIFO METHOD OF VALUATION OF STOCK OF GOLD TO BE APPROPRIATE FOR VALUATION OF GOLD STOCK. ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 4 7. IN REPLY TO PROPOSITION AS MADE BY THE AO THE A SSESSEE SUBMITTED THAT IT PURCHASES GOLD AND STONES MANUFA CTURES JEWELLERY FROM SUCH GOLD ALSO DISMANTLES JEWELLERY ALREADY MANUFACTURED AND MANUFACTURES FRESH JEWELLERY OUT O F THE SAME SINCE DESIGNS GOES OUT OF MARKET WITHIN VERY SHORT TIME. 8. THE ASSESSEE ALSO SUBMITTED THAT IT CONSISTENTLY FOLLOWING LIFO METHOD FOR VALUATION OF CLOSING STOCK SINCE IT S INCEPTION. THIS SYSTEM IS CONSISTENTLY FOLLOWED AND ACCEPTED I N ALL EARLIER YEARS INCLUDING IN THE SCRUTINY ASSESSMENT FOR THE EARLIER YEARS INCLUDING THE ASSESSMENT YEAR 2006-2007 IN WHICH SU RVEY WAS CONDUCTED. 9. ACCORDING TO AO THE ASSESSEE HAS SHOWN THE VALU E ADDITION TO THE STOCK OF F.Y. 2010-11 BUT THE ASSE SSEE HAS NOT PROVIDED ANY CONCLUSIVE PROOF THAT NO VALUE ADDITIO N WAS MADE TO THE STOCK OF F.YS 2004-05 2005-06 AND 2006-07. THE AO OPINED THAT THE OLD RECEIPT OF GOLD OR GOLD ORNAMEN TS WAS NOT SUBJECTED TO THE ABOVE VALUE ADDITION. BUT DURING THE ENTIRE COURSE OF ASSESSMENT PROCEEDI NGS THE ASSESSEE HAS FAILED TO SUBMIT ANY SUCH REGISTER BY WHICH THE ASSESSEE CAN ESTABLISH THAT THE VALUE OF GOLD STOCK OF THE F. YS. 2004-05 2005-06 7006-07 AND SO ON WAS LYING AS CLOSING STOCK. HE ALSO FAILED TO PROVIDE SUFFICIENT EVIDENCE AND PROOF REGARDING AS TO HOW THE RATES FOR F.YS 2004- 05 2005- 06 AND 2006-07 WERE DERIVED BY THE ASSESSEE. IN THE ABSENCE OF ANY DOCUMENTARY PROOF IT IS NOT POSSIBLE TO ACCE PT THE RATES PERTAINING TO F.YS 2004-05 2005-06 AND 2006-07 AS CLAIMED BY THE ASSESSEE. FURTHER IT IS SEEN DURING THE COURSE OF ASSESSMENT PROCEEDING FOR THE A.YR. 2009-10 THE ASSESSEE HAS CLAIMED THE VALUE OF CLOSING STOCK COMPRISING ONLY OF CLOSING STOCK OF R ATE OF F.Y.- 2006-07 AND F.Y.- 2007-08 AND NOT OF F.Y. - 2004-05 AND 2005-06. THE SAME WAS DULY REFLECTED IN PARA NO. 11 OF ASSESSMENT ORDER U/S.143(3) DATED 27/12/2011 THE S AME IS REPRODUCED AS BELOW. THE SCANNED COPY OF THE RELEVA NT PAGE OF THE ASSESSMENT ORDER AS WELL AS THE SCANNED COPY OF ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 5 ANNEXURE PAGE 3 ON WHICH PARA 11 OF ASSTT. ORDER OF A.YR. 2009-10. HENCE IT IS CRYSTAL CLEAR THAT THE ASSESSEE HAS NO T CONSISTENTLY FOLLOWED THE LIFO METHOD OF VALUATION OF CLOSING STOCK AS 'IS CLAIMED BY THE ASSESSEE. FROM THE ABOV E SUBMISSION IT IS SEEN HAT THE ASSESSEE HAS NEVER CL AIMED THE VALUE OF STOCK OF GOLD FOR THE F. YR. 2004-05 2005 -06 DURING THE ASSESSMENT PROCEEDINGS RELATING TO ASSESSMENT Y EAR 2009-10 BUT IN THE F.YR. 2010-11 THE ASSESSEE CONSI DERED THE VALUE OF STOCK OF GOLD FOR F. YR. 200:4-05 & 2005-0 6. THIS DISCREPANCY IS OF A VERY SERIOUS NATURE AND CONTRAD ICTS THE CLAIM MADE BY THE ASSESSEE THAT HE HAS CONSISTENTLY FOLLOWED THE LIFO METHOD OF CLOSING STOCK. 10. THE AO DID NOT ACCEPT THE SUBMISSION OF THE ASS ESSEE REGARDING APPLICATION OF LIFO METHOD FOR VALUATION OF STOCK OF GOLD. THE AO APPLIED GOLD RATE AS IT WAS EXISTING I N F.Y 2010-11 RS.1993.50 PER GRAM AND MODIFIED THE VALUE OF GOLD STOCK AT RS.8 73 46 711/- AND ADDED THE SAME TO THE TOTAL IN COME OF THE ASSESSEE ON ACCOUNT OF UNDER VALUATION OF STOCK . 11. THE CIT-A OBSERVED THAT THE AO DID NOT GIVE ANY REASON FOR REJECTION OF LIFO METHOD FOR VALUATION OF GOLD STOCK AND ALSO FOUND FAULT WITH THE APPLICATION OF RATE OF GO LD PER GRAM IN F.Y.2010-11 TO FYS 2004-05 2005-06 2006-07 AND 2 010-11 AND FOUND THE ASSESSMENT ORDER MADE WITHOUT ANY BAS IS. THE CIT-A DELETED THE ADDITION OF RS.8 73 46 711/-AS MA DE BY THE AO BY FOLLOWING THE FIRST APPELLATE ORDER DT:08-02 -2013 FOR A.Y.2009-10. 12. HAVING AGGRIEVED BY THE ORDER OF CIT-A THE RE VENUE BEFORE THIS TRIBUNAL BY RAISING AFOREMENTIONED GROU NDS. THE LD. DR RELIED ON THE ORDER OF AO. ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 6 13. AT THE TIME OF HEARING THE LD.AR SUBMITS THAT THE APPELLANT REVENUE CHALLENGED THE ORDER OF CIT-A PAS SED FOR A.Y 2009-10 BEFORE THIS TRIBUNAL AND SUBMITTED THAT THE TRIBUNAL UPHELD THE ORDER OF CIT-A. 14. HEARD RIVAL SUBMISSIONS AND PERUSED THE MATERIA L EVIDENCE ON RECORD. WE FIND THAT THE OBSERVATION OF THE COOR DINATE BENCH THAT THE AO DID NOT GIVE ANY JUSTIFIABLE REAS ON FOR REJECTION OF LIFO METHOD WHICH HAS BEEN FOLLOWED CO NSISTENTLY BY THE ASSESSEE AND WHICH METHOD THE REVENUE HAS BE EN ACCEPTING FOR EARLIER YEARS. THE RELEVANT PORTION O F WHICH IS REPRODUCED HEREIN BELOW: 7.2. IT IS QUITE NATURAL THAT JEWELLERY BEING A F ASHION INDUSTRY THE OLD STOCKS WOULD MOST OF THE TIMES REMAIN WITH THE ASSE SSEE AND THE REVENUE CANNOT EXPECT THE OLD STOCKS TO BE SOLD OUT FIRST T HOUGH IT WOULD REMAIN IN THE WISH LIST OF THE JEWELLER. WE FIND THAT THE AFO RESAID VALUATION EXACTLY FITS INTO THE ACCEPTED METHOD OF VALUATION FOR A JE WELLER AS APPROVED IN THE CASE OF COCHIN TRIBUNAL SUPRA. WE ALSO FIND THAT TH E DECISION OF THE CHANDIGARH TRIBUNAL IN THE CASE OF DCIT VS VIPIN AG GARWAL IN ITA NO. 450/CHD/2010 DATED 23.7.2010 WHEREIN IT WAS HELD THAT :- 6. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSE D THE RECORDS. THE ISSUE ARISING IN THE PRESENT APPEAL IS WITH REGARD TO THE VALUATION OF CLOSING STOCK. THE ASSESSEE IS A JEWELER AND HAD DECLARED CLOSING STOCK OF RS. 3 79 84 232/- AS ON 31.3.2007. THE CONTENTION OF THE ASSESSEE WAS THAT IT WAS VALUING THE CLOSING STOCK AT COST. OUT OF THE TOTAL CLOSING STO CK OF 54 756 GMS THE ASSESSEE CLAIMS THAT GOLD WEIGHING 31 905 GMS WAS I TS OPENING STOCK VALUED @ RS. 482/- PER GRAM. THE BALANCE STOCK AVAILABLE O UT OF THE PURCHASES MADE DURING THE YEAR WAS 22850 GMS WHICH WAS VALUED AT COST PRICE OF RS. 905/- PER GRAM. THE CONTENTION OF THE ASSESSEE WAS REJECTED BY THE ASSESSING OFFICER AS ACCORDING TO THE ASSESSING OFF ICER THE ASSESSEE WAS NOT FOLLOWING ONE OF THE METHODS SPECIFIED IN ACCOUNTIN G STANDARD AS-2 ISSUED BY THE INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA FOR DETERMINING THE COST OF INVENTORIES. THE EXPLANATION OF THE ASSESSEE IN THI S REGARD WAS THAT THE OPENING STOCK OF 31950 GMS WAS VALUED AT RS. 482/- PER GRAM AND SIMILAR VALUE BE ADOPTED TO WORK OUT THE VALUE OF CLOSING S TOCK. IT AS FURTHER EXPLAINED THAT THE SAID JEWELLERY BEING OLD CONVENT IONAL JEWELLERY WAS NOT SOLD DURING THE YEAR AND WAS AVAILABLE AT THE CLOSE OF THE YEAR. THE BALANCE STOCK WAS OUT OF THE PURCHASES MADE DURING THE YEAR LESS SALES MADE BY THE ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 7 ASSESSEE. THE ASSESSING OFFICER WHILE RE-COMPUTING THE VALUE OF STOCK HAS ACCEPTED THE WEIGHTS IN GRAMS OF STOCKS BUT HAD ONL Y REVALUED THE STOCK BY ADOPTING A FIGURE HIGHER THAN RATE DISCLOSED BY THE ASSESSEE. WE FIND NO MERIT IN THE SAID ADDITION BEING MADE BY THE ASSESS ING OFFICER WHERE THE VALUATION OF CLOSING STOCK HAS BEEN CHANGED VIS-A-V IS ITS VALUE AND NOT BECAUSE OF ANY DIFFERENCE IN THE QUANTITY OF STOCK. THE ASSESSEE WAS CONSISTENTLY FOLLOWING A PARTICULAR METHOD OF ACCOU NTING WHICH IS BEING ACCEPTED FROM YEAR TO YEAR AND IN THE ABSENCE OF AN Y CONTRARY FINDINGS BY THE ASSESSING OFFICER THERE IS NO MERIT IN NOT ADO PTING THE METHOD OF VALUATION OF STOCK BEING CONSISTENTLY FOLLOWED BY T HE ASSESSEE. FURTHER WE FIND SUPPORT FROM THE RATIO LAID DOWN BY THE HON'BL E SUPREME COURT IN CHAINRUP SAMPAT RAM VS. CIT 24 ITR 481 (SC) (SUPRA) WHEREIN IT HAS BEEN HELD THAT THE VALUE OF STOCK CANNOT BE APPRECIATED HIGHER THAN THE COST BECAUSE THE CLOSING STOCK IS NOT THE SOURCE OF PROF IT FOR THE ASSESSEE. IT HAS ALSO BEEN HELD BY THE HONBLE SUPREME COURT THAT TH E CLOSING STOCK IS TO BE VALUED EITHER AT COST OR MARKET VALUE WHICHEVER IS LOW. IN THE FACTS AND CIRCUMSTANCES OF THE PRESENT CASE WE ARE IN CONFOR MITY WITH THE ORDER OF CIT(A) AND UPHOLD THE SAME. THERE IS NO MERIT ILL A DOPTING THE WEIGHTED AVERAGE COST METHOD FOR VALUATION OF INVENTORY OF S TOCK IN THE CIRCUMSTANCES OF THE CASE. WE CONFIRM THE DELETION OF ADDITION M ADE BY THE ASSESSING OFFICER TOTALING RS.52 23 753/-. THE GROUND OF APP EAL RAISED BY THE REVENUE IS THUS DISMISSED. 7.3. IN ANY EVENT WE HOLD THAT NO ADDITION COULD BE MADE TOWARDS VALUE OF STOCK BECAUSE THE CLOSING STOCK CANNOT BE CONSTR UED AS A SOURCE OF PROFIT FOR THE ASSESSEE. WE PLACE RELIANCE ON THE D ECISION OF THE HONBLE SUPREME COURT IN THE CASE OF CHAINRUP SAMPAT RAM VS CIT REPORTED IN 24 ITR 481 (SC) IN SUPPORT OF THIS PROPOSITION. 7.4. WE FIND THAT THE ASSESSEE HAS BEEN CONSISTENT LY FOLLOWING LIFO METHOD OF ACCOUNTING FOR VALUATION OF ITS CLOSING S TOCK OF GOLD WHICH HAS BEEN ACCEPTED BY THE DEPARTMENT IN THE EARLIER YEAR S EVEN IN SCRUTINY ASSESSMENT PROCEEDINGS OF THE ASSESSEE. THEN THERE IS NO JUSTIFIABLE REASON TO REJECT THE SAME METHOD DURING THE YEAR UN DER APPEAL. IN THIS REGARD WE PLACE RELIANCE ON THE DECISION OF THE HO NBLE APEX COURT IN THE CASE OF UNITED COMMERCIAL BANK VS CIT REPORTED IN 2 40 ITR 355 (SC) WHEREIN THE PRINCIPLES WERE LAID DOWN FOR VALUATION OF ASSETS AT PAGE 366. WE FIND THAT THE FOLLOWING DECISIONS ALSO SUPPORT T HE CASE OF THE ASSESSEE:- CIT VS SANT RAM MANGAT RAM REPORTED IN (2005) 275 I TR 312 (P&H) CIT VS EMA INDIA LTD REPORTED IN (2006) 296 ITR 510 (ALL) CIT VS JAGATJIT INDUSTRIES LTD REPORTED IN (2011) 3 39 ITR 382 (DEL) CIT VS SHAH DOSHI & CO REPORTED IN (1982) 133 ITR 2 3 (GUJ) ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 8 7.5. IN VIEW OF THE AFORESAID FINDINGS IN THE FACT S AND CIRCUMSTANCES OF THE CASE AND RESPECTFULLY FOLLOWING THE VARIOUS JUD ICIAL PRECEDENTS RELIED UPON HEREINABOVE WE DO NOT FIND ANY REASON TO INTE RFERE WITH THE ORDER OF THE LEARNED CITA. ACCORDINGLY THE GROUNDS RAISED B Y THE REVENUE ARE DISMISSED. 15. THE COORDINATE WHILE DEALING WITH THE ISSUE ON HAND DISCUSSED THE DECISION OF COCHIN TRIBUNAL IN THE CASE OF JEWELLER IN ITO VS SREE PADMANABHA JEWELLERY MART REPORTED IN 19 ITD 816 AS RELIED BY THE ASSESSEE WHEREIN IT APPROVED THE LIF O METHOD. THE COORDINATE BENCH ALSO DISCUSSED THE DECISION OF THE CHANDIGARH TRIBUNAL IN THE CASE OF DCIT VS VIPIN AGGARWAL IN ITA NO. 450/CHD/2010 DATED 23.7.2010 WHICH FOUND NO MERIT IN NOT ADOPTING THE METHOD OF VALUATION OF STOCK BEING CONSISTENTLY FOLLOWED BY THE ASSESSE E WHICH IS BEING ACCEPTED FROM YEAR TO YEAR IN THE ABSENCE OF ANY CO NTRARY FINDINGS BY THE ASSESSING OFFICER. IN VIEW OF THE FINDING OF THE CO ORDINATE BENCH FOR A.Y 2009-10 WE HOLD THAT NO ADDITION IS MAINTAINABLE M ADE ON ACCOUNT OF VALUE OF CLOSING STOCK AND THE ORDER OF THE CIT-A I S JUSTIFIED AND THE GROUNDS RAISED ARE DISMISSED. 16. IN THE RESULT THE APPEAL FILED BY THE REVENUE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 4 TH OCTOBER 2016 SD/- SD/- P.M JAGTAP S.S.VISWANETHRA RAVI ACCOUNTANT MEMBER JUDICIAL MEMBER DATED: 04/10/2016 ITA NO. 202/KOL/15 M/S. JEWEL INDIA JEWELLERS 9 COPY OF THE ORDER FORWARDED TO: 1 . APPELLANT ACIT CIRCLE-43 3 GOVT PLACE (W) KOLK ATA-1. 2 RESPONDENT M/S. JEWELL INDIA JEWELLERS 41 MONOHA R DASS ST. KOLKATA-700 007 3 . THE CIT (A) KOLKATA 4. 5. CIT KOLKATA DR KOLKATA BENCHES KOLKATA / TRUE COPY BY ORDER ASSTT. REGISTRAR .