M/s Urma C. S. Shop, Purulia v. ITO, WD-3(4), PURULIA, Purulia

ITA 716/KOL/2016 | 2011-2012
Pronouncement Date: 19-10-2016

Appeal Details

RSA Number 71623514 RSA 2016
Assessee PAN AABFU3173H
Bench Kolkata
Appeal Number ITA 716/KOL/2016
Duration Of Justice 6 month(s)
Appellant M/s Urma C. S. Shop, Purulia
Respondent ITO, WD-3(4), PURULIA, Purulia
Appeal Type Income Tax Appeal
Pronouncement Date 19-10-2016
Appeal Filed By Assessee
Bench Allotted SMC
Tribunal Order Date 19-10-2016
Assessment Year 2011-2012
Appeal Filed On 18-04-2016
Judgment Text
IN THE INCOME TAX APPELLATE TRIBUNAL BENCH A KOL KATA [BEFORE HONBLE SHRI N.V.VASUDEVAN JM & DR.ARJUN LAL SAINI AM ] ITA NO.716/KOL/2016 ASSESSMENT YEAR : 2011-12 M/S. URMA C.S.SHOP -VERSUS- I.T.O. WARD-3(4) PURULIA PURULIA [PAN: AABFU 3173 H] (APPELLANT) (RESPONDENT) FOR THE APPELLANT : SHRI R.N.RAM AR FOR THE RESPONDENT : SHRI A.K.PANDA ADDL. CIT DATE OF HEA RING : 22.09.2016 DATE OF PRONOUNCEMENT : 19.10.2016. ORDER PER DR.ARJUN LAL SAINI AM THE CAPTIONED APPEAL FILED BY THE ASSESSEE PERTAINING TO A.Y.2011-12 IS DIRECTED AGAINST THE ORDER PASSED BY THE COMMISSION ER OF INCOME TAX (A)-ASANSOL IN APPEAL NO.30/C.I.T.(A)/ASL/W-3(4)/PURULIA/14-15 DATED 28.01.2016 WHICH IN TURN ARISES OUT OF AN ORDER PASSED BY THE LD. ASSESSING OFFICER U/S 143(3) OF INCOME TAX ACT 1961 (IN SHORT THE ACT) DATED 07.03.2014. 2. THE FACTS OF THE CASE ARE AS STATED IN BRIEF. THE RETURN OF INCOME FOR A.Y.2011-12 WAS FILED BY THE ASSESSEE DECLARING THE TAXABLE IN COME OF RS.22 432/-. LATER ON THE CASE WAS SELECTED FOR SCRUTINY U/S 143(3) OF THE AC T AND THE AO HAS COMPLETED THE ASSESSMENT BY MAKING ADDITION OF RS. 20 68 357/- F OR VIOLATION OF THE PROVISION OF SECTION 40A(3) OF THE I. T. ACT AND OTHER SMALL AD DITIONS BECAUSE THE ASSESSEE DID NOT FURNISH THE DOCUMENTS AND EVIDENCES. 3. AGGRIEVED FROM THE ORDER OF THE LD. AO THE A SSESSEE FILED AN APPEAL BEFORE THE LD. CIT(A) WHO HAS ALSO CONFIRMED THE ACTION OF THE AO BY OBSERVING THE FOLLOWINGS :- . ITA NO. 716/KOL/2016 M/S. URMA C.S.SHOP A..Y.2011-12 2 12. THE BENGAL EXCISE (SUPPLY OF COUNTRY SPIRIT ON PAYMENT OF DUTY) RULES 2005 DOES NOT MAKE ANY EXPRESS PROVISION MANDATING THE NECESS ITY OF EFFECTING PAYMENT IN CASH BY THE VENDOR IN RELATION TO PURCHASES EFFECTED EITHER FROM GOVERNMENT OR ITS AUTHORIZED BOTTLING AGENTS. IN VIEW OF THE ABOVE I UPHOLD THE ADDITION OF RS 20 68 357/- MADE BY ASSESSING OFFICER. THE GROUNDS AGAINST ADDITIONS AR E DISMISSED. 13. IN THE GROUND OF APPEAL THE OTHER DISALLOWANCE ARE ALSO AGITATED. NO DETAILS AS TO WHY THE DISALLOWANCE ARE OBJECTED ARE AVAILABLE OR PREF ERRED. HENCE I DECIDE THE SAME ON BASIS OF CONTENTS IN ASSESSMENT ORDER. 14. UPON GOING THROUGH ASSESSMENT ORDER I FIND THAT A.O. HAS MADE ADDITIONS OF RS 7 695/- RS 4 26 320/- RS 12 228/- RS1 000/- R S 89 347/- AND RS.9 031/-. HE HAS ALSO RECORDED REASONS. NO MATERIAL TO OVERTURN THE SAME IS BEFORE ME. HENCE I DISMISS THE GROUNDS AGAINST THE ADDITIONS. 15. THE APPEAL IS DISMISSED. ALL GROUNDS OF APPEAL STAND DISPOSED OF ACCORDINGLY. 4. NOT BEING SATISFIED WITH THE ORDER OF THE LD. CIT(A) THE ASSESSEE IS IN FURTHER APPEAL BEFORE US AND HAS TAKEN THE FOLLOWING GROUND S OF APPEAL :- 01. THAT ON THE FACTS AND CIRCUMSTANCES OF THE CAS E ID. AO. ERRED IN TREATING THE ASSESSEE AS RETAIL TRADER OF COUNTRY SPIRIT WHEREAS THE APPELLANT IS A LICENSEE OF COUNTRY SPIRIT UNDER SUPERVISION AND CONTROL OF STA TE EXCISE AUTHORITY UNDER GOVT. OF WEST BENGAL. 02. THAT ON THE FACTS AND CIRCUMSTANCES OF THE CASE ID. A.O. ERRED IN MAKING A DISALLOWANCE OF RS.20 68 357/- BEING TOTAL PURCHASE OF COUNTRY SPIRIT INCLUDING EXCISE DUTY SALES TAX T.D.S. AND BOTTLING CHARGES U/S 40 A(3) ON THE GROUND THAT PURCHASE AMOUNT EXCEEDED THE THRESHOLD LIMIT OF RS.20 000/- DISREGARDING THE FACT THAT ENTIRE PURCHASE WAS MADE FROM GOVERNMENT BOND(WAREHOUSE) U NDER CONTROL OF STATE EXCISE DEPARTMENT AND SUCH PURCHASE FROM GOVERNMENT FALLS WITHIN EXCEPTIONS OF RULE 6DD(A). 03. THAT ON THE FACTS AND CIRCUMSTANCES OF THE CASE ID. A.O. ERRED IN DISREGARDING THE NOTIFICATION OF GOVT. OF W.B. EXCISE DEPARTMENT NOT IFICATION NO.1208 EX DT. 29/08/2005 THAT RETAIL VENDORS WILL NOT DEPOSIT MONEY FOR PURC HASE OF C.S. EXCISE DUTY AND OTHER TAXES TO THE GOVT. TREASURY. THEY WILL DEPOSIT THE COST OF C.S. EXCISE DUTY AND OTHER IMPOSITIONS BY LAW DIRECT TO WHOLESALERS AND ACCORD INGLY THE APPELLANT HAS MADE THE PAYMENTS TO THE WHOLESALERS FOLLOWING THE DIRECTION S OF THE GOVT. AND SUCH PAYMENTS AS PER DIRECTIONS AND RULE FRAMED THEREIN FALLS UNDER RULE 6DD(A) AND RULE 6DD(B) AND ACCORDINGLY THE APPELLANT IS FREE FROM ANY DISALLOW ANCE U/S 40A(3). 04. THAT ON THE FACTS AND CIRCUMSTANCES OF THE CASE ID. A.O. ERRED IN MAKING A DISALLOWANCE U/S 40A(3) WHEREAS THE COST OF C.S. PU RCHASE FROM GOVT. BONDS FALLS WITHIN EXCEPTION PROVIDED UNDER RULE 6DD(A) AND EXC ISE DUTY AND SALES TAX FALLS WITHIN EXCEPTION PROVIDED UNDER RULE 6DD(B) AND ACCORDINGL Y DESERVES TOTAL DELETION. 05. THAT ON THE FACTS AND CIRCUMSTANCES OF THE CASE ID. AO. ERRED IN MAKING ADDITION OF RS.4 26 302/- ON ACCOUNT OF LOSS OF F.L (FOREIGN L IQUOR) IN COURSE OF DESTRUCTION BY ITA NO. 716/KOL/2016 M/S. URMA C.S.SHOP A..Y.2011-12 3 CROWED OF LOCAL VILLAGERS COMPRISING OF HUNDREDS OF WOMEN WHICH CAME IN THE PRINT MEDIA AND ALSO IN ELECTRONIC MEDIA AND WHEREAS SUCH LOSS WAS INCURRED IN COURSE OF CARRYING OUT THE BUSINESS OF THE APPELLANT. 06. THAT ON THE FACTS AND CIRCUMSTANCES OF THE CASE ID. A.O. ERRED IN MAKING AN ADDITION OF RS. 89 347/- ON ACCOUNT OF NET DEBIT BALANCE COM PUTED BY THE AO IN RESPECT OF A.N. ENTERPRISE AND KISAN F.L BOND. 5. GROUND NOS.1 2 3 AND 4 RELATE TO ONE SOLITARY GRIEVANCE OF THE ASSESSEE IN RESPECT OF CASH PAYMENT MADE BY THE ASSESSEE IN EXCESS OF R S.20 000/- U/S 40A(3) OF THE ACT VIDE RULE 6DD(A) AND 6DD(B) OF THE IT RULES. THEREF ORE FIRST WE ARE GOING TO DEAL WITH THE SOLITARY GRIEVANCE OF THE ASSESSEE WHICH H AS BEEN REFLECTED BY WAY OF MULTIPLE GROUNDS RAISED BY THE ASSESSEE (GROUND NOS . 1 TO 4). 6. THE LD. AR FOR THE ASSESSEE HAS SUBMITTED (IN RESPECT OF GROUND NOS. 1 TO 4) THAT THE ASSESSEE IS A RETAIL VENDOR OF COUNTRY LIQUOR A ND POCHAI. THE COUNTRY LIQUOR IS AN EXCISABLE COMMODITY. ITS PURCHASE AND SALE ARE STRI CTLY CONTROLLED BY THE STATE GOVERNMENT. PREVIOUSLY THE RETAIL DEALERS LIKE THE ASSESSEE USED TO DEPOSIT THE COST PRICE EXCISE DUTY BOTTLING CHARGES ETC IN THE TREA SURY AGAINST FORM TR-7 IN CASH FOR GETTING SUPPLIES FROM WHOLESALE LICENSEE. SUBSEQUEN TLY THE EXCISE DEPARTMENT BY A NOTIFICATION DATED 29/08/2005 CHANGED THE PROCEDURE . AS PER REVISED PROCEDURE PRESCRIBED BY THE EXCISE DEPARTMENT FOR LIFTING COU NTRY SPIRIT THE RETAIL VENDOR LIKE THE ASSESSEE WAS REQUIRED TO MAKE THE ENTIRE PAYMENT CO NSISTING OF COST OF THE STOCK IN TRADE EXCISE DUTY AND BOTTLING CHARGES ETC ONLY T O THE WHOLESALE LICENSEE APPOINTED BY THE STATE GOVERNMENT . FOLLOWING THE REVISED PRO CEDURE THE ASSESSEE MADE THE PAYMENTS BY CASH DEPOSITS IN THE BANK ACCOUNT OF TH E SUPPLIER NAMELY M/S IFB AGRO AND INDUSTRIES.LTD DURGAPUR IN THE STATE BANK OF INDIA AT PURULIA. WHILE COMPLETING THE ASSESSMENT THE ASSESSING OFFIC ER DISALLOWED A SUM OF RS.20 68 357/- U/S 40A (3) ON THE GROUND THAT EACH PAYMEN T EXCEEDED A SUM OF RS.20000/- AS THE PAYMENT WAS MADE IN CASH TO THE BANK ACCOUNT OF THE SELLER. HE NOTED HIS OBSERVATION ON PAGE 5 AND 6 OF HIS ASSESSMENT ORDER AND MENTIONED THAT THE ENTIRE PAYMENT WAS MADE IN THE BANK ACCOUNT OF IFB AGRO IN DUSTRIES LTD IN THE STATE BANK OF INDIA PURULIA. ITA NO. 716/KOL/2016 M/S. URMA C.S.SHOP A..Y.2011-12 4 THE ASSESSEE FILED AN APPEAL AGAINST AFORESAID DISA LLOWANCE AND CLAIMED THAT THE ASSESSEE CASE IS COVERED UNDER RULE-6 DD(B) AND RUL E 6 DD(K) BUT THE CIT APPEAL PASSED AN ORDER WITHOUT CARING THE NOTICE OF HEARIN G HAVING BEEN SERVED TO THE APPELLANT ON THE GROUND THAT HER PREDECESSOR HAS CO NFIRMED THE DISALLOWANCES U/S 40A(3) IN RESPECT OF EARLIER ASSESSMENT YEARS. THE LD AR FOR THE ASSESSEE ALSO DREW OUR ATTENTION TO THE VERY RECENT CONSOLIDATED JUDGMENT PASSED BY HON`ABLE INCOME TAX APPELLATE TR IBUNAL A-BENCH KOLKATA IN I.T.A NO 148/KOL/2015 ASSESSMENT YEAR 2007-08 I. T .A. NO. 185/KOL/2014 ASSESSMENT YEAR 2008-09 & I.T.A NO 1186/KOL/2014 A SSESSMENT YEAR 2010-11 IN THE CASE OF RAMNAGAR PACHWAI & C.S.(S) SHOP VS. INC OME TAX OFFICER WARD-2(3) ASANSOL. IT IS IMPORTANT TO NOTE THAT IN HIS ORDER DATED 05/08/2016 RULED THAT THE CASE OF THE APPELLANT FALLS UNDER THE EXCEPTIONS PROVIDE D IN RULE 6DD(B) AND RULE 6DD(K) OF THE IT RULES AND ACCORDINGLY ALLOWED THE APPEAL OF THE ASSESSEE. THE PRESENT APPEAL OF THE ASSESSEE( OF M/S URMA C.S .SHOP ) UNDER CONSIDERATION IS SQUARELY COVERED BY THE ABOVE JUDGMENT AS BOTH THE ASSESSEES M/S RAMNAGAR PACHWAI & C.S.(S) SHOP AND M/S URMA C.S. SHOP ARE R ETAIL VENDOR OF COUNTRY LIQUOR AND PACHWAI SHOP AND ARE CONTROLLED BY THE EXCISE D EPARTMENT OF THE STATE GOVERNMENT. BOTH HAVE DEPOSITED THE CASH IN THE BAN K ACCOUNT OF THE SELLER AND LIFTED THE GOODS FROM THE WAREHOUSE UNDER THE CONTROL THE EXCISE DEPARTMENT. 7. ON THE OTHER HAND THE LD. DEPARTMENTAL REPRE SENTATIVE FOR THE REVENUE HAS PRIMARILY REITERATED THE STAND TAKEN BY THE AO WHIC H WE HAVE ALREADY NOTED IN OUR EARLIER PARA AND IS NOT BEING REPEATED FOR THE SAK E OF BREVITY. 8. HAVING HEARD THE RIVAL SUBMISSIONS PERUSED THE MATERIAL AVAILABLE ON RECORD WE ARE OF THE VIEW THAT THERE IS MERIT IN THE SUBMISSI ONS OF THE ASSESSEE AS THE PROPOSITIONS CANVASSED BY THE LD. AR FOR THE ASSESS EE ARE SUPPORTED BY THE JUDGMENT OF THE HONBLE ITAT KOLKATA ( CITED SUPRA) AND FA CTS NARRATED BY HIM. THE LD. AR HAS POINTED OUT THAT AS PER THE REVISED PROCEDURE P RESCRIBED BY THE EXCISE DEPARTMENT FOR LIFTING COUNTRY SPIRIT THE RETAIL VENDOR LIKE T HE ASSESSEE WAS REQUIRED TO MAKE THE ITA NO. 716/KOL/2016 M/S. URMA C.S.SHOP A..Y.2011-12 5 ENTIRE PAYMENT CONSISTING OF COST OF THE STOCK IN T RADE EXCISE DUTY AND BOTTLING CHARGES ETC ONLY TO WHOLESALE LICENCEE APPOINTED BY THE STATE GOVERNMENT. THEREFORE FOLLOWING THE REVISED PROCEDURE THE ASSESSEE MADE T HE PAYMENT BY CASH DEPOSITED IN THE BANK ACCOUNT OF THE SUPPLIER NAMELY M/S. IFB AG RO AND INDUSTRIES LTD. DURGAPUR IN THE STATE BANK OF INDIA PURULIA. THEREFORE CON SIDERING THE ABOVE FACTUAL POSITION THE ADDITION MADE BY THE LD. CIT(A) NEEDS TO BE DEL ETED. ACCORDINGLY WE DELETE THE ADDITION MADE BY THE LD. CIT(A). 9. IN THE RESULT THE APPEAL FILED BY THE ASSES SEE ON THIS ISSUE IS ALLOWED. 10. GROUND NO.5 RAISED BY THE ASSESSEE RELATES T O THE ADDITION OF RS.4 26 302/- ON ACCOUNT OF LOSS/ DESTRUCTION BY CROWD OF LOCAL VILL AGERS. THE LD. AO HAS DISALLOWED RS.4 26 302/- BY OBSERVING THE FOLLOWINGS :- 3. FURTHER EXPLANATION REGARDING THE LOSS IN TRAN SIT TO THE TUNE OF RS. 2 76 302/ - AND DEBIT AMOUNT OF RS. 1 50 000/ - UNDER THE HEAD 'DRU M & BOTTLES DESTROYED IN THE TRADING P& L ACCOUNT IN THE YEAR ENDED ON 31/03/20 11 WAS FOUND NOT SATISFACTORY. HENCE THE AMOUNT AGGREGATING TO THE TUNE OF RS. 4 26 302/- IS DISALLOWED AND ADDED BACK TO THE TOTAL INCOME OF THE ASSESSEE AS THE A/R OF THE ASSESSEE FIRM HAD FAILED TO ESTABLISH THE LOSS IN TRANSIT TO THE TUNE OF RS. 2 76 302/- AND 'THE DESTRUCTION OF DRUMS AND BOTTLES AMOUNTING TO RS. 1 50 000/- BY ADDUCING STRONG AND COGENT DOCUMENTARY EVIDENCE IN SUPPORT OF THE CLAIM MADE UNDER ABOVE S AID HEADS. 11. AGGRIEVED FROM THE ADDITION OF THE LD. ASSE SSING OFFICER THE ASSESSEE FILED AN APPEAL BEFORE THE LD. CIT(A) WHO HAS ALSO CONFIRME D THE ORDER OF ASSESSING OFFICER OBSERVING THAT NO MATERIAL OR EVIDENCES WERE FILED BEFORE HIM BY THE ASSESSEE. 12. NOT BEING SATISFIED WITH THE ORDER OF THE LD . CIT(A) THE ASSESSEE IS IN FURTHER APPEAL BEFORE US ON THIS ISSUE AND SUBMITTED THAT T HE AO DISALLOWED A SUM OF RS.4 26 302/- ON ACCOUNT OF LOSS OF F.L. IN COURSE OF DESTRUCTION BY CROWD OF LOCAL VILLAGERS. 13. ON THE OTHER HAND THE LD. DEPARTMENTAL REPR ESENTATIVE FOR THE REVENUE HAS STRONGLY DEFENDED THE ORDER MADE BY THE LD. AO AND THE ORDER MADE BY THE LD. CIT(A) AND EXPLAINED THAT NO EVIDENCE OR DOCUMENTS WERE FI LED BY THE ASSESSEE EITHER BEFORE ITA NO. 716/KOL/2016 M/S. URMA C.S.SHOP A..Y.2011-12 6 AO OR BEFORE THE LD. CIT(A). THEREFORE THE ASSESSE E IS NOT ELIGIBLE TO CLAIM ANY BENEFIT ON ACCOUNT OF DESTRUCTION BY CROWD OF LOCAL VILLAGERS. 14. HAVING HEARD THE RIVAL SUBMISSIONS PERUSE D THE MATERIAL AVAILABLE ON RECORD WE ARE OF THE VIEW THAT THERE IS MERIT IN THE SUBMI SSIONS OF THE LD. DR FOR THE REVENUE AS THE PROPOSITIONS CANVASSED BY THE LD. DR FOR THE REVENUE ARE SUPPORTED BY THE FACTS NARRATED BY HIM. HE HAS MENTIONED THAT NO EVIDENCE WERE SUBMITTED BY THE ASSESSEE BEFORE THE AO. THERE IS NO FIR FILED BY THE ASSESSE E STATING THAT THE BOTTLES WERE DESTROYED BY THE CROWD OF LOCAL VILLAGERS. THEREFOR E IN VIEW OF THE ABOVE FACTUAL POSITION WE CONFIRM THE ORDER PASSED BY THE LD. CIT (A). 15. IN THE RESULT THE APPEAL FILED BY THE ASSESS EE ON THIS GROUND IS DISMISSED. 16. GROUND NO.6 RAISED BY THE ASSESSEE RELATES T O THE ADDITION OF RS.89 347/- ON ACCOUNT OF NET DEBIT BALANCE COMPUTED BY THE AO IN RESPECT OF A.N.ENTERPRISE AND KISAN F.L. BOND. THE AO HAS DISALLOWED THE SAID SUM OBSERVING THAT THE LD. AR FOR THE ASSESSEE FIRM COULD NOT PRODUCE ANY DOCUMENTARY EVIDENCE REGARDING THE CREDIT BALANCE OF RS.86 917/- AGAINST A.N.ENTERPRISE. THE CREDIT BALANCE AMOUNTING TO RS.13 735/- AGAINST KISHAN F.L.BOND IS ACCEPTED. TH US THE NET DEBIT BALANCE BECOMES EQUAL TO RS.1 00 669/- (RS.86934 + RS.13735). HENCE THE AMOUNT OF RS.89 347/- (RS.1 90 016 MINUS RS.1 00 669) IS ADDED TO THE TOT AL INCOME OF THE ASSESSEE. 17. NOT BEING SATISFIED WITH THE ORDER OF THE AO THE ASSESSEE FILED AN APPEAL BEFORE THE LD. CIT(A) WHO HAS ALSO CONFIRMED THE ACTION O F THE LD. AO AS THE ASSESSEE HAD NOT FURNISHED ANY EVIDENCE OR DOCUMENTARY PROOF BEF ORE THE LD. CIT(A). NOT BEING SATISFIED WITH THE ORDER OF THE LD. CIT(A) THE ASS ESSEE IS IN FURTHER APPEAL BEFORE US ON THIS ISSUE. 18. THE LD. AR FOR THE ASSESSEE HAS SUBMITTED TH AT THIS IS AN ADDITION MADE BY THE LD. AO U/S 68 OF THE ACT AND ADDITION MADE BY HIM IS N OT VALID. ITA NO. 716/KOL/2016 M/S. URMA C.S.SHOP A..Y.2011-12 7 19. ON THE OTHER HAND THE LD. DEPARTMENTAL REPR ESENTATIVE FOR THE REVENUE HAS PRIMARILY REITERATED THE STAND TAKEN BY THE LD. AO . HE ARGUED THAT THE ASSESSEE HAD NEITHER SUBMITTED ANY DOCUMENTARY EVIDENCE BEFORE T HE AO NOR BEFORE THE LD. CIT(A) THEREFORE IT IS A GENUINE ADDITION MADE BY AO. 20. HAVING HEARD THE RIVAL SUBMISSIONS PERUSED THE MATERIAL AVAILABLE ON RECORD WE ARE OF THE VIEW THAT THERE IS MERIT IN THE SUBMI SSIONS OF THE LD. DR FOR THE REVENUE AS HE HAS RIGHTLY POINTED OUT THAT THE ASSESSEE HAS NEITHER SUBMITTED ANY DOCUMENTARY EVIDENCE BEFORE THE LD. AO NOR BEFORE THE LD. CIT( A) TO PROVE THE GENUINENESS OF THE TRANSACTION. THEREFORE THE ADDITION MADE BY THE LD. AO IS VALID. THEREFORE BASED ON THE ABOVE FACTUAL POSITION WE CONFIRM THE ORDER PAS SED BY THE LD. CIT(A) ON THIS ISSUE. 21. IN THE RESULT THE APPEAL FILED BY THE ASSES SEE ON THIS IS DISMISSED. 22. IN THE RESULT THE APPEAL FILED BY THE ASSE SSEE IS PARTLY ALLOWED. ORDER PRONOUNCED IN THE COURT ON 19.10.2016. SD/- SD/- [N.V.VASUDEVAN] [DR.ARJUN LAL SAINI] JUDICIAL MEMBER ACCOUNTANT MEMBER DATE: 19.10.2016. R.G.(.P.S.) COPY OF THE ORDER FORWARDED TO: 1 . M/S URMA C.S.SHOP BARA URMA HATTALA PURULIA-72315 4. 2 I.T.O. WD-3(4) PURULIA. 3 . CIT(A)-ASANSOL 4. CIT-ASANSOL 5. CIT(DR) KOLKATA BENCHES KOLKATA. TRUE COPY BY ORDER DEPUTY /ASST. REGISTRAR ITAT KOLKATA BENCHES ITA NO. 716/KOL/2016 M/S. URMA C.S.SHOP A..Y.2011-12 8