Citation Codes

Equivalent Citations

citation codes

Case Number

ITA 419/KOL/2020

Disposition

in part

Attorney(S)

Acts

section 36(1)(iii) of the I.T. Act.

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Smart Summary

Summary of Opinion: ITA No.419/Kol/2020 (Assessment Year 2015-16)

Factual and Procedural Background

The assessee, Kaushalya Dealers Pvt. Ltd., filed its return of income for AY 2015-16 on 28.09.2015 declaring total income of Rs. 69,040/-. The return was processed under section 143(1) and the case was selected for scrutiny through CASS. The Assessing Officer (AO) framed assessment under section 143(3) on 05.09.2017 after taking into account contentions and replies filed by the assessee.

The Principal Commissioner of Income Tax (PCIT) issued a show cause notice under section 263 on 12.03.2020 proposing revision on four issues: (1) alleged lack of inquiry/verification regarding loss from trading in penny stocks set off against house property income; (2) non-communication to the vendor's AO regarding applicability of section 50C in respect of a purchased immovable property whose stamp duty valuation exceeded the purchase consideration; (3) claim of interest deduction under business when funds appear to have been used to acquire immovable property and hence interest not allowable under section 36(1)(iii); and (4) non-verification of loans taken from two companies.

The assessee responded with written submissions and documentary evidence asserting that the AO had examined these issues during assessment proceedings and had taken a plausible view after detailed examination. The PCIT, after considering submissions, passed an order under section 263 dated 23.03.2020 directing the AO to verify the issues and frame the assessment afresh after giving the assessee an opportunity.

In the set-aside proceedings before the AO, an addition was made only in respect of the first issue (loss from penny stocks), while the other three issues (sub-paras 2–4) were accepted by the AO and no additions were made. The assessee challenged the PCIT's exercise of revisionary jurisdiction and the consequent order before the Income Tax Appellate Tribunal (ITAT).

Legal Issues Presented

Whether the PCIT validly exercised revisionary jurisdiction under section 263 of the Income-tax Act in respect of the assessment framed under section 143(3), in particular whether the AO's order was "erroneous and prejudicial to the interests of revenue" as required by section 263.
Whether, in the facts of this case, the AO had carried out adequate enquiry and applied his mind to the documents and explanations furnished by the assessee (especially in relation to the loss on sale of penny stocks), such that the PCIT's revision under section 263 was impermissible.

Arguments of the Parties

Appellant's (Assessee's) Arguments

The revisionary jurisdiction under section 263 was wrongly invoked because the necessary conditions under that provision were not satisfied.
The AO had called for details (notices under section 142(1) dated 9.3.2017 and 2.08.2017) and the assessee furnished detailed documentary evidence regarding penny-stock transactions — sales/purchases, contract notes, D-mat statements, bank statements, STT payment proofs — and plausible explanations; therefore the AO had examined the issue and taken a possible/plausible view when framing assessment under section 143(3).
Since the AO had taken a plausible view after examining the records, this was not a case of lack of enquiry, wrong assumption of facts, or incorrect application of law; accordingly section 263 could not be invoked. The assessee relied on a series of coordinate-bench decisions supporting that principle.
The assessee confined its challenge before the Tribunal to the first issue (loss from penny stock) because in the set-aside proceedings addition was made only on that issue; the other three issues had become academic for purposes of this appeal as no additions were made by the AO on those points.

Respondent's (Revenue / PCIT) Arguments

The PCIT's order under section 263 did not cause prejudice to the assessee because in the set-aside proceedings the assessee was given full opportunity to present its case before the AO.
Although the assessee filed evidences and the AO raised the issues during assessment, the AO did not examine them sufficiently — in particular, the AO disregarded the investigation wing's report that the scrips were penny stocks — and therefore the PCIT was justified in directing a de novo examination under section 263 since the AO's order was alleged to be erroneous and prejudicial to the revenue's interest.
It was premature to decide the matter before the AO re-examined the issues as directed by the PCIT.

Table of Precedents Cited

Precedent	Rule or Principle Cited For	Application by the Court
M/s. Sethia Finance Trading Co. vs ACIT, Circle-45, Kolkata (ITA No. 783/Kol/2013)	Coordinate-bench authority holding that PCIT cannot invoke section 263 where the AO has taken a plausible view after considering evidence furnished by the assessee.	The Tribunal noted this decision among several coordinate-bench rulings supporting the proposition that s.263 cannot be invoked when AO has taken a plausible view; this line of authority was relied upon in quashing the PCIT's exercise of s.263 as to penny-stock loss.
M/s. Rupayan Udyog vs CIT, Kol-XVII (ITA No. 1073/Kol/2012)	Coordinate-bench authority cited for the same principle that revision under s.263 is not warranted where AO has considered evidence and taken a plausible view.	The Tribunal included this decision in the series relied upon to support the conclusion that the AO's decision was not erroneous/prejudicial and that s.263 was improperly exercised.
Shri Manish Chirania vs Pr. CIT-15, Kolkata (ITA No. 1161/Kol/2019)	Coordinate-bench authority on the limits of s.263 where AO's view is plausible and based on evidence.	The Tribunal treated this decision as reinforcing the principle that a mere lack of elaborate discussion in the AO's order does not imply lack of enquiry and does not justify s.263 revision.
M/s. Sinhotia Metals & Minerals Pvt. Ltd. vs PCIT, Durgapur (ITA No. 889/Kol/2017)	Coordinate-bench authority invoked to show that PCIT cannot set aside an assessment where the AO has examined records and taken a plausible view.	Counted among the decisions the Tribunal followed to conclude that the AO's view on penny-stock loss was plausible and therefore not susceptible to s.263 revision.
M/s. Patron Ninimay Pvt. Ltd. vs ITO, Ward-10(4), Kolkata (ITA No. 1614/Kol/2019)	Coordinate-bench authority supporting the limitation on PCIT's s.263 powers where AO has considered evidence and adopted a possible view.	The Tribunal relied on this decision as part of the series establishing that s.263 could not be invoked in the present facts.
M/s. Ganapati Tradewings Pvt. Ltd. vs ITO, Ward-1(4), Kolkata (ITA No. 2651/Kol/2019)	Coordinate-bench authority cited to demonstrate that s.263 is not available where the AO's decision is a plausible one based on material on record.	Included in the body of coordinate-bench precedents the Tribunal considered persuasive in quashing the PCIT's order insofar as it related to penny-stock loss.
M/s. Khetawat Properties Ltd. vs PCIT, Kolkata (ITA No. 578/Kol/2019)	Coordinate-bench authority on the proper scope of revisionary powers under section 263.	The Tribunal cited this decision as further support for the proposition that PCIT cannot set aside assessments where the AO reached a plausible conclusion after considering evidence.
M/s. Kaushalya Dealers Pvt. Ltd. (listed among the series of decisions)	Listed by the assessee among coordinate-bench authorities; principle same as other coordinate-bench rulings.	The Tribunal noted this listing by the assessee as part of the series of coordinate-bench rulings relied upon, and applied the same controlling principle in the present appeal.
CIT vs J.L. Morrison (India) Ltd., 366 ITR 593 (Kolkata)	Jurisdictional High Court authority holding that where requisite evidence is on record and was duly examined by the AO, the AO's order is not "erroneous and prejudicial" merely because the order lacks elaborate discussion; the Commissioner cannot set aside the assessment without first concluding that the AO's finding was erroneous and prejudicial to revenue.	The Tribunal relied on this decision as directly supportive: since the AO had the evidences on record and had framed the assessment after considering them, PCIT's exercise of s.263 was impermissible; the Tribunal followed J.L. Morrison in quashing the PCIT's revision insofar as it related to penny-stock loss.
CIT vs Gabriel India Ltd., 203 ITR 108 (Bom)	Bombay High Court authority referenced in J.L. Morrison — principle that the Commissioner's power to set aside is available only where AO's earlier finding is shown to be erroneous and prejudicial; mere desire for further inquiry does not suffice.	The Tribunal noted this authority (as followed by the Jurisdictional High Court) and applied its operative principle to hold that the PCIT could not set aside the AO's assessment in the absence of a finding of error prejudicial to revenue.

Court's Reasoning and Analysis

The Tribunal examined the record and parties' submissions and proceeded in stages:

Scope of PCIT's action: The PCIT invoked section 263 to revise the AO's assessment on four specified issues. The Tribunal noted that after the PCIT's direction, the AO (in set-aside proceedings) made an addition only on the penny-stock loss issue and accepted the other three issues (no additions). On that basis the Tribunal treated the PCIT's order as academic with respect to the three accepted issues and declined to adjudicate the validity of PCIT's jurisdiction on those three points.
Analysis of penny-stock loss issue: The Tribunal reviewed whether the AO had examined the assessee's submissions and documents concerning the loss from penny-stock transactions. The record showed that the AO had specifically called for transaction details and the assessee had furnished sales/purchase details, D-mat statements, contract notes, bank statements, and STT payment proofs. The AO framed the assessment after taking these documents into account.
Legal standard for invoking section 263: Applying the jurisprudence of the Jurisdictional High Court in CIT vs J.L. Morrison (which follows CIT vs Gabriel India Ltd.), the Tribunal noted that the Commissioner may set aside an assessment only after concluding that the AO's earlier finding was erroneous and prejudicial to the interests of revenue. Mere absence of a detailed discussion in the AO's order does not by itself establish error or lack of enquiry where evidence and explanations are on file and were considered.
Application of the legal standard to facts: The Tribunal concluded that the AO had applied his mind and taken a plausible view after considering the assessee's evidences. There was no demonstration that the AO's conclusion was perverse, founded on incorrect application of law, or based on a wrong assumption of fact that would render the assessment "erroneous and prejudicial" under section 263. The PCIT therefore lacked power to revise the assessment on the ground of alleged lack of enquiry.
Reliance on prior decisions: The Tribunal relied on the cited Jurisdictional High Court authority (J.L. Morrison) and a series of coordinate-bench decisions to support its conclusion that section 263 was improperly invoked in respect of the penny-stock loss.

Holding and Implications

Holding: The appeal is allowed. The Tribunal quashed the exercise of revisionary jurisdiction by the PCIT under section 263 in so far as it relates to the loss on sale of penny stocks.

Implications and direct consequences:

The Tribunal set aside the PCIT's revision insofar as it pertained to the penny-stock loss; the AO's assessment on that issue (which had been framed after considering the assessee's documentary submissions) was upheld against the s.263 challenge.
The PCIT's order was treated as academic in respect of the other three issues (stamp duty/section 50C communication, treatment of interest under section 36(1)(iii), and verification of certain loans) because, in the set-aside proceedings, the AO made no additions on those points; accordingly the Tribunal did not adjudicate the validity of the PCIT's jurisdiction on those three issues.
No new legal precedent was set by this decision; the Tribunal expressly followed the Jurisdictional High Court decision in CIT vs J.L. Morrison (and the Bombay High Court in CIT vs Gabriel India Ltd.) and several coordinate-bench decisions applying the established principle that s.263 cannot be invoked where the AO has taken a plausible view after considering the evidence on record.

Order pronounced in open court on 10.12.2021. Members: Sanjay Garg (Judicial Member) and Rajesh Kumar (Accountant Member). The appeal was allowed in favour of the assessee.

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Kaushalya Dealers (P) Ltd, Kolkata v. ITO, Ward-4(4) , Kolkata

IN THE INCOME TAX APPELLATE TRIBUNAL,

KOLKATA BENCH "B", KOLKATA

BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER

AND SHRI RAJESH KUMAR, ACCOUNTANT MEMBER

ITA No.419/Kol/2020

Assessment Year: 2015-16

Kaushalya Dealers Pvt. Ltd. 498/H/4, Karl Mark Sarani, Kolkata – 700 023. PAN: AADCK8028Q	Vs.	ITO, Ward-4(4), Kolkata
(Appellant) (Respondent)

Present for:

Appellant by : Shri S.M. Surana, Advocate

Respondent by : Shri Sudipta Guha, CIT (DR).

Date of Hearing : 08.12.2021

Date of Pronouncement : 10.12.2021

O R D E R

PER RAJESH KUMAR, ACCOUNTANT MEMBER:

The present appeal has been preferred by the assessee against the revisionary order passed u/s 263 of the Act dated 29.05.2020 of the Commissioner of Income Tax (Appeals) [hereinafter referred to as the PCIT] relevant to AY 2015-16.

2. The assessee has challenged the revisionary jurisdiction exercised by Ld. PCIT u/s 263 of the Act and also the consequent order passed u/s 263 of the Act on the ground that revisionary jurisdiction as well as the consequent order is invalid and nullity as necessary conditions envisaged in section 263 of the Act have not been satisfied before invoking the revisionary jurisdiction. The fact in brief are that the assessee filed a return of income on 28.09.2015 declaring total income of Rs. 69,040/- which was processed u/s

143(1) of the Act. Thereafter, the case of the assessee was selected for scrutiny through CASS and assessment was framed vide order dated 05.09.2017 passed u/s 143(3) of the Act assessing the income at Rs. 69,040/- after taking into account the various contentions/replies of the assessee filed during the course of assessment proceedings.

3. Thereafter, the Ld. PCIT upon examination of assessment records came to the conclusion that the AO has not examined certain issues during the course of assessment proceedings and, therefore, the order so framed is erroneous and prejudicial to the interest of the revenue and accordingly issued a show cause notice u/s 263 of the Act vide letter dated 12.03.2020 proposing to revise the assessment on the following issues:

"1. No inquiry/verification has been done on the issue of suspicious transactions in penny stock (one of the reasons for selection of scrutiny). It is noteworthy that the assessee made a major loss in penny scrip and the same was set off with income from house property.

2. The assessee had purchased an immovable house property during the previous year. The purchase cost is shown at Rs. 4,28,13,810/- whereas the Stamp Duty valuation of the said property is at Rs. 5,05,27,200/-. The officer did not pass on the information in regard to applicability of section 50C to the jurisdictional AO of the vendor.

3. It is apparent from the financial statements that a part of interest bearing loan borrowed by the assessee was advanced to Millennia Infrastructure (P) Ltd. on interest till 2014-15. In the year under consideration, the loan given to M/s. Millennia Infrastructure (P) Ltd. was converted into purchase cost of immovable property from the said company by the assessee. The assessee earned house property income from the said immovable property and offered the income under the head 'income from House Property', which means the interest bearing loan taken by the assessee was infused into immovable property purchased by the assessee. Yet the assessee claimed interest payment made to loan creditor under the head of income from business which is not allowable. However, the officer

allowed the interest on loan in violation to section 36(1)(iii) of the I.T. Act.

4. In the previous year, the assessee had taken loan of Rs. 50 lakhs & 30 lakhs from two companies viz. Lily Vintrade (P) Ltd. and Mountview Dealmark (P) Ltd. But no verification was made".

4. In reply to the show notice, the assessee filed written submissions alongwith details/evidences explaining that the issues proposed to be raised in the show cause notice have been examined by the AO during assessment proceedings and only after carrying out a detailed examination and verification, a plausible and possible view was taken and accordingly the assessment was framed u/s 143(3) of the Act. The Ld. PCIT after taking into account, the written submissions and arguments of the Ld. AR revised the assessment framed u/s 143(3) by the AO vide order passed u/s 263 dated 23.03.2020 by directing the AO to verify these issues and frame the assessment afresh after giving a reasonable opportunity to the assessee.

5. At the outset, the learned counsel of the assessee, submitted that the revisionary jurisdiction u/s 263 was exercised by ld PCIT in respect of four issues stated in the show cause notice which are also extracted by the ld CIT(A) in para 3 of the impugned order passed u/s 263 of the Act. The Ld. AR, by referring to the assessment framed u/s 143(3) r.w.s. 263 of the Act dated 27.09.2021, submitted in the set aside proceedings, the AO has made addition only in relation to first issue of loss from penny stock as mentioned by the Ld. PCIT in para 3 sub para 1 while no addition was made in respect of remaining issues mentioned in sub paras no. 2 to 4 after taking into consideration the contentions made by the assessee. The Ld. AR, therefore, submitted that the assessee is pressing its appeal only inspect of the first issue on which the addition has been made by the AO in the set aside proceedings. The Ld. AR, therefore, submitted

that the order of Ld. PCIT has become academic in respect pf the remaining three issues as no addition has been made by the AO in the assessment framed in th4e set aside proceedings and, therefore, are not being pressed.

6. The ld AR vehemently submitted before the bench that during the original assessment proceeding the AO called for the details and explanation of the assessee in respect of loss on sale of penny stocks and justification of setting off the same against the house property income which were duly furnished before the AO by referring to the notices issued u/s 142(1) dated 9.3.2017 and 2.08.2017. The ld AR stated that in the first notice on page no 2 vide para 9 the AP specifically called for the details of sales and purchases of shares along with evidences which was replied by the assessee was replied by written submission on 10.11.2018.the ld AR submitted that the assessee has furnished the details of purchase and sale of shares in respect of which the Ld. PCIT has proposed to exercise jurisdiction u/s 263 of the Act. The assessee also filed the copies of bank account, ledger accounts, D-mat account, contract notes and bank statement evidencing the payment for purchase of shares, payment proof of STT payments and receipt of sales consideration through banking channels and only after taking into consideration the reply of the assessee, the AO has taken a plausible view on this issue. The Ld. AR, therefore, stated that the issue has been examined by the AO during the course of assessment proceedings and a plausible view has been taken. The Ld. AR submitted that this is not a case of lack of enquiry and, therefore, the assessment already framed by the assessee after taking into account all the evidences and explanations offered during the course of assessment proceedings cannot disturbed by exercising jurisdiction u/s 263 of the Act. The Ld. AR

relied on the series of decisions of coordinate benches which are as under:

"1. M/s. Sethia Finance Trading Co. vs ACIT, Circle-45, Kolkata vide ITA No. 783/Kol/2013.

2. M/s. Rupayan Udyog vs CIT, Kol-XVII vide ITA No. 1073/Kol/2012.

3. Shri Manish Chirania vs Pr. CIT-15, Kolkata vide ITA No. 1161/Kol/2019.

4. M/s. Sinhotia Metals & Minerals Pvt. Ltd. vs PCIT, Durgapur vide ITA No. 889/Kol/2017.

5. M/s. Patron Ninimay Pvt. Ltd. vs ITO, Ward-10(4), Kolkata vide ITA No. 1614/Kol/2019.

6. M/s. Ganapati Tradewings Pvt. Ltd. vs ITO, Ward-1(4), Kolkata vide ITA No. 2651/Kol/2019.

7. M/s. Khetawat Properties Ltd. vs PCIT, Kolkata vide ITA No. 578/Kol/2019.

8. M/s. Kaushalya Dealers Pvt. Ltd."

7. The Ld. AR therefore, submitted that in view of the various decisions of the coordinate benches wherein it has been held that invoking jurisdiction u/s 263 in case the AO has taken a plausible view after taking into consideration the reply/evidences furnished by the assessee. The Ld. AR submitted that it is not a case of lack of enquiry or incorrect assumption of facts or incorrect application of law by the AO and submitted that the revisionary proceedings and consequent order may kindly be quashed.

8. Per contra, the Ld. DR relied heavily on the order of Ld. PCIT by submitting that no prejudice is caused to the assessee by the revisionary proceedings u/s 263 of the Act by the by the PCIT as the assessee was given full opportunity to present his case before the AO in set aside proceedings. Besides the Ld. AR argued that though admittedly the issues, which are proposed to be raised in the show

cause notice issue du/s 263 of the Act , have been raised by the AO during the course of assessment proceedings and has been replied by the assessee by filing details of purchase and sale of shares, payment proofs of STT, contract notes, D-Mat statement, bank statement evidencing the payments for purchase of shares and receipt of sale consideration but the AO has not examined the issues further and so much so that he ignored the report of investigation Wing, Kolkata that the scrips involved are penny stock and, therefore, this is fit for revisionary jurisdiction u/s 263 of the Act as the PCIT is conferred with power u/s 263 to revise the assessment order if it is prejudicial and erroneous to the interest of justice. The Ld. DR also submitted that the fact that certain items in their show cause notice have been accepted by the AO during the course of set aside proceedings but it would be premature to decide the same at this stage as the PCIT has only directed the AO to examine the issues denovo.

9. After hearing both the parties and perusing the material available on record, we note that the revisionary jurisdiction was exercised by the Ld. PCIT u/s 263 of the Act in order to revise the assessment on four issues. In the set aside proceedings, the AO has made rejected the loss on sale of penny whereas the other three issues proposed by the PCIT were accepted and no addition were made. Therefore, we find merit in the contentions of the Ld. AR that the order of PCIT becomes academic to the extent of these three issues on which no additions were made by the AO assessment framed u/s 263 r.w.s. 143(3) of the Act. Accordingly we are not adjudicating the validity of jurisdiction of PCIT on these three issues. The issue raised in respect of loss of penny stock, we observe on perusal of records produced before us that the AO has specifically called for details of purchase and sale of shares during the original

assessment proceedings and the assessee has furnished the details of sale and purchase of shares, proofs payment of STT, copy of D- Mat statement, copy of bank statement evidencing the payment for purchase of shares and receipt of sale consideration into the assessee's bank account through banking channels. We note that the AO has framed the assessment only after taking into account the above aforesaid details. Therefore, simply because the order does not speak or discuss about the loss on sale of shares should not be taken to mean that AO has not examined the details by the assessee or has not applied his mind to the details and there was complete lack of enquiry. In opinion the AO has take a possible view after taking into account the evidences filed by the assessee which are part of records and therefore the Ld. PCIT has no power to revise the assessment on the ground of lack of enquiry. In our considered view this is not a case of wrong assumption of facts or incorrect application of law and therefore the revisionary powers have been invalidly exercised. The case of the assessee finds support from the decision of jurisdiction High Court in the case of CIT vs J.L. Morrison (India) Ltd. 366 ITR 593 (Kolkata) wherein the Hon'ble Jurisdictional High Court has held that where all the requisite evidences are on records and same were duly examined by the AO, then the order of the AO was not erroneous and prejudicial to the interest of the revenue after following the decision of Hon'ble Bombay High Court in the case of CIT vs Gabriel India Ltd. 203 ITR 108(Bom) the operative part whereof is as under:

15. We may now examine the facts of the present case in the light of the powers of the Commissioner set out above. The Income-tax Officer in this case had made enquiries in regard to the nature of the expenditure incurred by the assessee. The assessee had given detailed explanation in that regard by a letter in writing. All these are part of the record of the case. Evidently, the claim was allowed by the Income-tax Officer on being satisfied with the explanation of the

assessee. Such decision of the Income-tax Officer cannot be held to be

"erroneous" simply because in his order he did not make an elaborate discussion in that regard. Moreover, in the instant case, the Commissioner himself, even after initiating proceedings for revision and hearing the assessee, could not say that the allowance of the claim of the assessee was erroneous and that the expenditure was not revenue expenditure but an expenditure of capital nature. He simply asked the Income-tax Officer to re-examine the matter. That, in our opinion, is not permissible. Further inquiry and/or fresh determination can be directed by the Commissioner only after coming to the conclusion that the earlier finding of the Income-tax Officer was erroneous and prejudicial to the interests of the Revenue. Without doing so, he does not get the power to set aside the assessment. In the instant case, the Commissioner did so and it is for that reason that the Tribunal did not approve his action and set aside his order. We do not find any infirmity in the above conclusion of the Tribunal.

10. The assessee has also filed a series of decisions of Kolkata benches as stated hereinabove deciding the similar issue in favour of the assessee by holding that PCIT cannot exercise the jurisdiction u/s 263 of the Act where the AO has taken a plausible view on the basis evidences filed by the assessee which is not contrary to law and facts. Accordingly respectfully following the decision of the jurisdiction High Court and various other decisions, we are inclined quash the revisionary jurisdiction exercised by ld PCIT in so far as it relates to loss on penny stocks.

11. In the result, the appeal of the assessee is allowed. Order pronounced in the open court on 10.12.2021. Sd/- Sd/-

(SANJAY GARG) (RAJESH KUMAR)

JUDICIAL MEMBER ACCOUNTANT MEMBER

Kolkata, Dated:10.12.2021. Biswajit, Sr. P.S.

Copy to: The Appellant The Respondent

The CIT, Concerned, Kolkata The CIT (A) Concerned, Kolkata The DR Concerned Bench / / T r u e C o p y / / [ By Order

Sr. Private Secretary/DDO ITAT, Kolkata Benches, Kolkata

Kaushalya Dealers (P) Ltd, Kolkata v. ITO, Ward-4(4) , Kolkata

Summary of Opinion: ITA No.419/Kol/2020 (Assessment Year 2015-16)

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Appellant's (Assessee's) Arguments

Respondent's (Revenue / PCIT) Arguments

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

Kaushalya Dealers (P) Ltd, Kolkata v. ITO, Ward-4(4) , Kolkata

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