M/S. Raiganj R.C.C. Spun Pipe Industries Pvt. Ltd., Uttar Dinajpur v. D.C.I.T., Circle-2, Jalpaiguri, Jalpaiguri

ITA 2163/KOL/2014 | 2010-2011
Pronouncement Date: 19-10-2016

Appeal Details

RSA Number 216323514 RSA 2014
Assessee PAN AABCR6097A
Bench Kolkata
Appeal Number ITA 2163/KOL/2014
Duration Of Justice 1 year(s) 10 month(s) 16 day(s)
Appellant M/S. Raiganj R.C.C. Spun Pipe Industries Pvt. Ltd., Uttar Dinajpur
Respondent D.C.I.T., Circle-2, Jalpaiguri, Jalpaiguri
Appeal Type Income Tax Appeal
Pronouncement Date 19-10-2016
Appeal Filed By Assessee
Bench Allotted SMC
Tribunal Order Date 19-10-2016
Date Of Final Hearing 01-09-2016
Next Hearing Date 01-09-2016
Assessment Year 2010-2011
Appeal Filed On 03-12-2014
Judgment Text
1 ITA NO.2163/KOL/2014- M/S. RANIGANJ R.C.C. SPUN PIP E INDUSTRIES PVT. LTD. A.Y.2010-11 IN THE INCOME TAX APPELLATE TRIBUNAL BENCH SMC K OLKATA [BEFORE HONBLE SHRI N.V.VASUDEVAN JM ] ITA NO.2163/KOL/2014 ASSESSMENT YEAR : 2010-11 M/S. RANIGANJ R.C.C.SPUN PIPE -VERSUS- D.C.I.T. C IRCLE-2 INDUSTRIES PVT.LTD. UTTAR DINAJPUR JALPAIGURI (PAN:AABCR 6097 A) (APPELLANT) (RESPONDENT) FOR THE APPELLANT: SHRI SUBASH AGARWAL ADVOCAT E FOR THE RESPONDENT: SHRI DIVAKAR CHAKRABORTY JCIT DATE OF HEARING : 01.09.2016. DATE OF PRONOUNCEMENT : 19.10.2016. ORDER THIS IS AN APPEAL BY THE ASSESSEE AGAINST THE ORDER DATED 07.11.2014 OF CIT(A)-JALPAIGURI RELATING TO A.Y.2010-11. 2. GROUNDS OF APPEAL RAISED BY THE ASSESSEE READ AS FOLLOWS :- 1. FOR THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASES LD. CIT(A) WAS MOT JUSTIFIED IN CONFIRMING THE ACTION OF THE LD. A.O. IN MAKING THE ADDITION OF RS.6 00 845 ON ACCOUNT OF ALLEGED DIFFERENCE IN VALUE OF STOCK. 3. THE ASSESSEE IS A COMPANY. IT IS ENGAGED IN THE BUSINESS OF MANUFACTURING OF RCC SPUN PIPE AND ACCESSORIES. THERE WAS A SURVEY U/S 1 33A OF THE INCOME TAX ACT 1961 (ACT) CONDUCTED IN THE FACTORY PREMISES OF THE ASSE SSEE AT DURGAPUR ON 17.03.2010. IN THE COURSE OF SURVEY PHYSICAL VERIFICATION OF THE S TOCK WAS TAKEN AND THE STOCK WAS VALUED AT RS.31 88 815/-. THE VALUE OF THE STOCK AS PER THE BOOKS OF ACCOUNT OF THE ASSESSEE WAS RS.11.88 723/-. THERE WAS A DIFFERENCE OF RS.20 00 092/- BETWEEN THE VALUE OF STOCK AS PHYSICALLY FOUND AND AS PER THE B OOKS OF ACCOUNTS. THE STATEMENT U/S 131 OF THE ACT OF ONE SHRI J.N.DUTTA MANAGING DIRE CTOR OF THE ASSESSEE WAS RECORDED 2 ITA NO.2163/KOL/2014- M/S. RANIGANJ R.C.C. SPUN PIP E INDUSTRIES PVT. LTD. A.Y.2010-11 ON 19.03.2010 BY A.C.I.T. CIRCLE-11 JALPAIGURI. THE FOLLOWING IS THE QUESTION AND ANSWER RELEVANT FOR THE PRESENT APPEAL :- Q.2 DO YOU AGREE TO MAKE ANY DISCLOSURE WITH RESPE CT TO THE DISCREPANCY OF RS.20 00 092/- FOUND IN PHYSICAL STOCK IN COMPARISO N TO THE STOCK AS PER BOOKS OF ACCOUNTS ? ANS: YES I HEREBY MAKE A DISCLOSURE OF RS.15 00 00 0/- INVESTED IN UNACCOUNTED STOCK/SALES ON WHICH I AGREE TO PAY THE TAXES AS AP PLICABLE. 4. THE ASSESSEE FILED RETURN OF INCOME ON 25.09.2 010 DECLARING A TOTAL INCOME OF RS.10 04 030/-. THIS DECLARATION WAS NOT IN ACCORDA NCE WITH THE STATEMENT OF THE MANAGING DIRECTOR OF THE ASSESSEE GIVEN ON 19.03.20 10 AFTER THE CONCLUSION OF THE SURVEY U/S 133A OF THE ACT AND THE ASSESSEE HAD OFF ERED TO DECLARE A SUM OF RS.15 00 000/- ON ACCOUNT OF UNACCOUNTED INVESTMENT IN STOCK. THE AO THEREFORE CALLED UPON THE ASSESSEE TO EXPLAIN AS TO WHY THE A SSESSEE HAD NOT DECLARED THE INCOME AS PER THE UNDERTAKING AT THE TIME OF SURVEY. 5. IN REPLY THE ASSESSEE POINTED OUT THAT THE METH OD OF DETERMINATION OF THE VALUE OF STOCK PHYSICALLY FOUND AND AS PER THE BOOKS OF ACCO UNTS OF THE ASSESSEE AT THE TIME OF SURVEY U/S.133A OF THE ACT WAS ERRONEOUS. THE ASSE SSEE PRODUCED THE SALE BILLS AT WHICH THE PRODUCTS WERE ACTUALLY SOLD AND FROM THE SAID SALE BILLS THE VALUE WAS ARRIVED AT BY THE ASSESSEE OF THE STOCK VALUE FOUND AT THE TIME OF SURVEY. THE ASSESSEE POINTED OUT THAT IT USED TO SELL ITS PRODU CTS AT A PRICE WHICH IS FAR BELOW OF OUR PRICE LIST VALUE BASED ON WHICH THE VALUE OF ST OCK WAS VALUED AT THE TIME OF SURVEY. THIS PRACTICE HAS BEEN FOLLOWED BY MANY MANUFACTURI NG HOUSES TO ATTRACT CUSTOMERS. THE SALE VALUE OF THE PRODUCTS FOUND BY THE SURVEY TEAM AS PER OUR SALE BILLS WAS ONLY FOR RS.30 34 317/- AS AGAINST ITS PRICE LIST V ALUE OF RS.31.88 723/- ADOPTED BY THE SURVEY TEAM. A DETAIL SHEET OF PRICE LIST VALUE AN D ACTUAL SALE VALUE OF THE STOCK LYING WITH US AS ON 17.03.2010 WAS FILED BY THE ASSESSEE BEFORE THE AO. THE ASSESSEE ALSO SUBMITTED THAT THE SURVEY TEAM HAD ALSO COMMITTED A MISTAKE IN CONSIDERING OUR OPENING STOCK AS ON 01.04.2009 FOR RS.11 88 723/- I NSTEAD OF OPENING STOCK AS ON 17.03.2.010 IN DETERMINING THE VALUE OF EXCESS STOC K OF RS.20 00 092/-. THE ASSESSEE 3 ITA NO.2163/KOL/2014- M/S. RANIGANJ R.C.C. SPUN PIP E INDUSTRIES PVT. LTD. A.Y.2010-11 CLAIMED THAT THE ACTUAL VALUE OF EXCESS STOCK WAS O NLY FOR RS.2 58 353/- AS ON THE DATE OF SURVEY AND GAVE THE FOLLOWING DETAILS: THE SURVEY TEAM HAD VALUED OUR STOCKS AS ON 17.03.2 010 AS PER PRICE LIST VALUE AT RS.31 88 815/- LESS: VALVE OF OPENING STOCK AS ON 1.04.2009(AS PER OUR LIST BALANCE SHEET) RS.11 88 723 WRONG EXCESS STOCKS DETERMINED BY SURVEY TEAM RS. 20.00.092/- ACTUAL VALUE OF EXCESS STOCK AS ON 17.03.2010 SALE VALUE OF STOCKS FOUND BY THE SURVEY TEAM AS PE R DETAIL SHEET ENCLOSED RS.30 34 317/- COST OF GOODS FOR SALE VALUE OF RS.30 34 317/- BY A PPLYING LAST YEAR'S G.P. RATE OF 18.16% I.E. COST OF STOCK AS ON 17.03.2010 (81.84/100X30 34 317) RS.24 83 785/- LESS: STOCK AS PER BOOKS AS ON 17.03.2010 SALE VALUE OF GOODS FROM 17.03.2010 TO 31.03.2010 R S.3.01 045/- SO COST OF GOODS SOLD FROM 17.03.2010 TO 31.03.201 0 IS 81.84/100X3 01 045= RS.2 46 375/- ADD: STOCK AS ON 31.03.2010 AS PER BOOKS RS.19 78 5 57/- RS.22 24 932/- EXCESS STOCK FOUND BY THE SURVEY TEAM AS ON 17.03.2 010 RS.2 58 353/- 6. THE ASSESSEE ALSO POINTED OUT THAT ITS GROSS PROFIT (G.P.) RATE DURING THE YEAR WAS CONSIDERATION IS 44.20% INCLUDING THE EXCESS STOCK AS ABOVE AND THE SAME WAS FAIR AND REASONABLE. THERE ASSESSEE ALSO TOOK A POSITION TH AT THERE WAS NO EXCESS STOCK AS ON 17.03.2010 ATTRACTING PROVISIONS OF SECTION 69 AS PER FOLLOWING DETAILS. COST OF GOODS SALE VALUE 01 RS.30 34 317/- BY APPLY ING CURRENT YEAR'S G.P. RATE 0144.20% I.E. COST OF STOCK AS ON 17.03.2010 (55.8/100X30 34 317) RS.16 93 149/- LESS: STOCK AS PER BOOKS AS ON 17.03.2010 SALE VALUE OF GOODS FROM 17.03.2010 TO 31.03.2010 RS.3 01 045/- SO COST OF GOODS SOLD FROM 17.03.2010 TO 31.03.201 0 IS 55.8/100X3 01.045/- = RS.1 67 983/- ADD: STOCK AS ON 31.03.2010 AS PER BOOKS.. RS.19 78 557/- RS.21 46 540/ EXCESS STOCK FOUND BY THE SURVEY TEAM AS ON 17.03. 2010 RS4 53.391/ 7 . THE ASSESSEE THUS SUBMITTED THAT IT HAD CREDITED A VALUE OF EXCESS STOCK OF RS.4.53 391 / - IN ITS BOOKS OF ACCOUNTS AS AGAINST EXCESS STOCK OF RS.2 58 353/ - FOUND BY THE SURVEY TEAM TO PAY MORE TAX AS PER ITS COMMI TMENT TO THE DEPARTMENT. THE ASSESSEE ALSO SUBMITTED THAT A READING OF SECTION 6 9 OF THE ACT WOULD MAKE IT CLEAR THAT THE BASIC CONDITION FOR ATTRACTING THE PROVISI ONS OF SEC. 69 OF THE ACT WAS THAT THE INVESTMENTS SHOULD HAVE BEEN MADE DURING THE FINANC IAL YEAR CONCERNED AND SUCH 4 ITA NO.2163/KOL/2014- M/S. RANIGANJ R.C.C. SPUN PIP E INDUSTRIES PVT. LTD. A.Y.2010-11 INVESTMENTS SHOULD NOT HAVE BEEN RECORDED IN THE BO OKS OF ACCOUNT MAINTAINED BY THE ASSESSEE. THE ASSESSEE POINTED OUT THAT IN ITS CASE EXCESS STOCK HAD BEEN DULY ACCOUNTED FOR AND AFTER SO ACCOUNTING FOR AN EXCES S INCOME HAD BEEN-DECLARED BY YOUR ASSESSEE IN ITS RETURN OF INCOME. HENCE FURT HER ADDITION U/S. 69 OF THE I.T. ACT SHOULD NOT BE MADE IN VIEW OF THE DECISION OF RAJAS THAN HIGH COURT IN THE CASE OF CIT VS. MEHTA GWAR GUM 8. COMPANY (2008) 219 CTR (RAJ) 58. THE ASSESSEE ALSO POINTED OUT THAT ITS NET PROFIT RATE FOR THE YEAR E NDING AS ON 31.03.2009 WAS 2.66% ONLY BUT IN ORDER TO PAY MORE TAX ON ITS INCOME INCLUDING ON ITS UNDISCLOSED INCOMES/INVESTMENTS THE ASSESSEE HAD DECLARED A NE T PROFIT OF 29% DURING THE YEAR UNDER CONSIDERATION AND PAID DUE TAXES THEREON. 8. THE ASSESSEE ALSO POINTED OUT THAT AS PER THE CBDT INSTRUCTION NO.286/2/2003(INV) DATED 10.03.2003 IT HAS BEEN SPE CIFICALLY INSTRUCTED THAT NO ADDITION CAN BE MADE MERELY ON THE BASIS OF STATEME NT RECORDED AT THE TIME OF SURVEY. 9. THE AO HOWEVER DID NOT AGREE WITH THE SUBMISSIO NS MADE BY THE ASSESSEE. ACCORDING TO THE AO AT THE TIME OF SURVEY CPU MARKE D AS RCC-CPU-1 WAS IMPOUNDED ON 17.03.2010 ON THE DATE OF SURVEY. AFT ER DECLARATION OF INCOME ON 19.03.2010 IN THE STATEMENT RECORDED U/S 131 OF TH E ACT THE ORDER IMPOUNDING CPU AND THE BOOKS OF ACCOUNT WAS VACATED. ACCORDING TO THE AO DESPITE REQUEST MADE FOR PRODUCTION OF CPU WHICH HAD BEEN IMPOUNDED THE ASS ESSEE DID NOT PRODUCE THE SAME. ACCORDING TO THE AO THE CPU WOULD HAVE BEEN W IPED FROM ITS ORIGINAL FORM AT THE TIME OF SURVEY AND IT WAS NOT POSSIBLE TO RETRI EVE THE DATA FROM THE CPU AS IT EXISTED ON THE DATE OF SURVEY. THE AO WAS THEREFORE OF THE VIEW THAT THE ASSESSEE OUGHT TO HAVE GIVEN A DECLARATION OF INCOME AS PER THE DISCLOSURE MADE AT THE TIME OF SURVEY. HE THEREFORE MADE AN ADDITION OF RS.6 00 84 5/- FOR THE FOLLOWING REASONS :- 5.5 THE ASSESSEE FAILED TO PRODUCE THE INVENTORISE D CPU THE ASSESSEE COULD NOT CONFIRM WHETHER IT IS IN ORIGINAL FORM TILL DATE OR NOT? SO APPLICABILITY OF SECTION 292C CANNOT BE DENIED AND FOR WANT OF ASSESSEE'S CO-OPER ATION THE APPLICABILITY OF SECTION 292C IS NOT TESTED. AS THE SAID CPU LIES WITH THE ASSESSEE SO THE ASSESSEE CANNOT DENY ITS RESPONSIBILITY WHEN THE DIRECTOR RETRACTED FROM THE DISCLOSURE. SO THE EXPLANATION AS FILED BY THE ASSESSEE IS NOT APPLICABLE HERE FOR AS SESSEE'S OWN FAILURE TO PRODUCE ALL 5 ITA NO.2163/KOL/2014- M/S. RANIGANJ R.C.C. SPUN PIP E INDUSTRIES PVT. LTD. A.Y.2010-11 BOOKS OF ACCOUNTS WHICH WERE TO BE TESTED UNDER THE LENS OF SECTION 292C OF THE INCOME TAX ACT 1961. SO THE ASSESSEE'S EXPLANATION IS NOT ACCEPTABLE HERE FOR ASSESSEE'S OWN FOLLY. IT IS ALREADY STATED THAT THE UNDERSIGNED APPRECIAT ED THE ASSESSEE FOR SHOWING PROFIT @ 21% WHICH IS TEN FOLD MORE THAN THE NORMAL PROFIT(2 .2%) AS RETURNED BY THE ASSESSEE. THE UNDERSIGNED BEING JUDICIOUS CONSIDERED THE EXCE SS PROFIT WITHIN DISCLOSURE BUT THE SAID AMOUNT COMPUTED TO RS. 8 99 155/ -ONLY. 5.6. SO IT IS PRESUMED THAT THE ASSESSEE HAS FAILE D TO CONSIDER REMAINING SUM OF RS.6 00 845/- AS DISCLOSURE IN HIS HAND WITHOUT FUR NISHING FULL AND PROPER EVIDENCES WHICH WAS WITH THE ASSESSEE AFTER THE SURVEY AS INV ENTORIED BOOKS OF ACCOUNTS .. EACH ASSESSMENT IS A SEPARATE PROCEEDING AND ALL FACT AN D CIRCUMSTANCES OF THE PRESENT CASE IS NOT SIMILAR TO THOSE CASE LAWS AS CITED BY THE ASSE SSEE. ALL CASE LAWS AS CITED BY THE ASSESSEE ARE NOT SQUARELY APPLICABLE IN THIS CASE. 10. ON APPEAL BY THE ASSESSEE THE CIT(A) CONFIRM ED THE ORDER OF AO BY OBSERVING AS FOLLOWS :- 4. SUBMISSIONS OF ASSESSEE- THE ASSESSEE DID NOT P RESS THE ADDITIONS ON ACCOUNT OF APPLYING SECTION 44 AE FOR INCOME FROM PLYING OF TR UCKS AND THE DISALLOWANCE OF RS. 5 455 AS BEING OF CAPITAL NATURE. THE ASSESSEE SUBM ITTED THAT THE DISCLOSURE MADE DURING THE TIME OF SURVEY CANNOT BE BASIS FOR ADDITION IF IT IS ESTABLISHED THAT THE DISCLOSURE WAS NOT CORRECT. THE ASSESSEE CITED VARIOUS JUDGEMENTS OF COURTS IN SUPPORT OF HIS ARGUMENTS. 5. CONCLUSION- IT IS SEEN THAT BOOKS OF ACCOUNT WE RE NOT IMPOUNDED BY THE SURVEY TEAM BECAUSE THE ASSESSEE HAD VOLUNTARILY ACCEPTED THE D ISCREPANCY IN HIS STOCK AND OFFERED RS. 15 00 000 AS INCOME ON THIS ACCOUNT. DURING COU RSE OF ASSESSMENT PROCEEDINGS THE ASSESSEE DID NOT PRODUCE THE CPU OF THE COMPUTER AN D COULD NOT CONFIRM WHETHER THE CPU IS IN THE SAME FORM OR NOT. THUS IT IS SEEN TH AT THE ASSESSEE HAS FAILED TO ESTABLISH THAT THE INCOME DECLARED DURING COURSE OF SURVEY WA S NOT CORRECT. IN VIEW OF THIS THE JUDGEMENTS CITED BY THE ASSESSEE ARE NOT APPLICABLE TO THE FACTS OF THE CASE OF THE ASSESSEE. THE APPEAL OF THE ASSESSEE IS DISMISSED. 11. AGGRIEVED BY THE ORDER OF CIT(A) THE ASSESS EE HAS FILED THE PRESENT APPEAL BEFORE THE TRIBUNAL. 12. I HAVE HEARD THE SUBMISSIONS OF THE LD. COUN SEL FOR THE ASSESSEE. THE LD. COUNSEL FOR THE ASSESSEE REITERATED THE SUBMISSIONS AS WERE MADE BEFORE THE REVENUE AUTHORITIES. HE FURTHER PLACED RELIANCE ON THE DECI SION OF THE HONBLE MADRAS HIGH COURT IN THE CASE OF CIT VS KHADER KHAN SON 300 ITR 157 (MAD) WHEREIN THE HONBLE MADRAS HIGH COURT HAS HELD THAT THERE CAN B E EVIDENTIARY VALUE ATTACHED TO THE STATEMENT RECORDED AT THE TIME OF SURVEY. THE L D. COUNSEL FOR THE ASSESSEE POINTED 6 ITA NO.2163/KOL/2014- M/S. RANIGANJ R.C.C. SPUN PIP E INDUSTRIES PVT. LTD. A.Y.2010-11 OUT THAT THE DECISION OF THE HONBLE MADRAS HIGH CO URT HAS BEEN CONFIRMED BY THE HONBLE SUPREME COURT IN THE CASE OF CIT VS S.KHADE R KHAN SON 352 ITR 480 (SC). THE LD. DR PLACED RELIANCE ON THE ORDER OF AO/.CIT( A). 13. I HAVE GIVEN A VERY CAREFUL CONSIDERATION TO THE RIVAL SUBMISSIONS. FROM A PERUSAL OF THE AO AS WELL AS CIT(A)M IT IS CLEAR TH AT THE BASIS OF MAKING THE IMPUGNED ADDITION IS ONLY A STATEMENT RECORDED ON 1 9.03.2010 U/S 131 OF THE ACT WHICH IS AFTER CONCLUSION OF THE SURVEY U/S 133A OF THE ACT. A PERUSAL OF THE RECORD SHOWS THAT THE AO HAS NOT DEALT WITH THE BASIS OF V ALUATION AT THE TIME OF SURVEY AND THE BASIS OF VALUE AS GIVEN BY THE ASSESSEE IN THE STATEMENT OF ACCOUNTS FILED ALONG WITH THE RETURN OF INCOME. IT IS CLEAR FROM THE STA ND TAKEN BY THE ASSESSEE BEFORE THE REVENUE AUTHORITIES THAT HE HAS DISPUTED THE MANNER OF VALUATION OF THE PHYSICAL STOCK AT THE TIME OF SURVEY AND THE VALUE OF STOCK AS PER THE BOOKS OF ACCOUNTS MAINTAINED BY THE ASSESSEE. THE BASIS ON WHICH THE ASSESSEE CL AIMS THAT THE VALUE OF THE STOCK AS PER THE BOOKS OF ACCOUNTS AS DETERMINED ON THE DATE OF SURVEY AS INCORRECT IS FURTHER SUPPORTED BY THE STATEMENT OF MANUFACTURING COST V ALUE OF FINISHED GOODS AND RAW MATERIAL AS ON 17.03.2010 WHICH IS PLACED IN PAGES 11 AND 12 OF THE ASSESSEES PAPER BOOK. THE FACT THAT THE ULTIMATE SALE OF THE FINISH ED PRODUCT BY THE ASSESSE DURING THE PREVIOUS YEAR YIELDED A SUM OF RS.30 34 317/- IS AL SO NOT DISPUTED BY THE REVENUE. IN SUCH CIRCUMSTANCES THE ACTION OF AO IN REJECTING TH E CLAIM OF THE ASSESSEE MERELY ON THE BASIS THAT THE INVENTORISED CPU WAS NOT PRODUCE D CANNOT BE SUSTAINED. IT IS CLEAR FROM THE RECORD THAT THE ASSESSEE HAD MADE DECLARAT ION OF INCOME TO THE TUNE OF RS.8 99 155/- ON ACCOUNT OF DISCREPANCY FOUND AT T HE TIME OF SURVEY AND SUCH DISCLOSURE HAS BEEN SHOWN TO BE ON AN ACCEPTABLE BA SIS BY THE ASSESSEE. THE AO HAS NOT BROUGHT ON RECORD ANY MATERIAL TO SHOW THAT THI S DECLARATION WAS NOT CORRECT. THE IMPUGNED ADDITION BY THE AO IS PURELY BASED ON THE STATEMENT RECORDED AT THE TIME OF SURVEY. IN THE LIGHT OF THE JUDICIAL PRONOUNCEMENTS BROUGHT TO MY NOTICE BY THE LD. COUNSEL FOR THE ASSESSEE AND IN THE LIGHT OF THE CB DTS INSTRUCTION THAT WAS BROUGHT TO THE NOTICE OF THE CIT(A) I AM OF THE VIEW THAT THE ADDITION MADE BY THE AO AND SUSTAINED BY CIT(A) DESERVES TO BE DELETED. THE SAM E IS HEREBY DIRECTED TO BE DELETED. 7 ITA NO.2163/KOL/2014- M/S. RANIGANJ R.C.C. SPUN PIP E INDUSTRIES PVT. LTD. A.Y.2010-11 14. IN THE RESULT THE APPEAL OF THE ASSESSEE IS ALLOWED. O RDER PRONOUNCED IN THE OPEN COURT ON 19.10.2016. SD/- [ N.V.VASUDEVAN ] JUDICIAL MEMBER DATED : 19.10.2016. [RG PS] COPY OF THE ORDER FORWARDED TO: 1.M/S. RANIGANJ R.C.C. SPUN PIPE INDUSTRIES PVT. LT D. DURGAPUR P.O.BHUPALPUR DIST. UTTAR DINAJPUR PIN 733143. 2.D.C.I.T. CIRCLE-2 JALPAIGURI. 3. CIT(A)-JALPAIGURI. 4. CIT-JALPAIGURI. 5. CIT(DR) KOLKATA BENCHES KOLKATA. TRUE COPY BY ORDER ASST. REGISTRAR ITAT KOLKATA BENCHES