Case Law Details
Kumar Suman Singh Vs ACIT (ITAT Patna)
ITAT Patna held that addition towards unexplained income upheld since assessee failed to prove genuineness of transaction and creditworthiness. Accordingly, appeal dismissed and addition upheld.
Facts- The assessee is an individual. A search and seizure operation u/s 132(1) of the Act was conducted on 19.02.2004 in the case of the assessee as well as his associates/relatives. In this search operation, substantial investments in form of movable and immoveable properties were discovered which was alleged to have been unaccounted income of the assessee. The investigation revealed significant undisclosed income from activities related to examinations and recruitment process such as pre-medical exams, Bank P.O exams etc.
Accordingly, AO initiated proceedings u/s 153A of the Act and due notices were issued to the assessee requiring to file returns. Thereafter, AO completed the assessment for the relevant year by determining substantial undisclosed income. Subsequent to the assessment, it was found that the assessee had used multiple alias names such as Indrajeet Kumar (Singh) and Ranjit Singh. Later on, income was assessed in the name of Indrajeet Kumar and merged with the assessed income of the assessee which was ultimately brought to tax by AO as there was no separate existence for different proceedings were found by AO.
CIT(A) granted certain relief but major additions were upheld. Being aggrieved, the present appeal is filed.
Conclusion- Held that in the instant issue, the Assessing Officer has not brought on record any material or valid proof in order to validate the existence or continuation of onion business of the assessee. Therefore, the alleged addition made by the Assessing Officer of Rs.80,000/- in the hands of the assessee was not correct and accordingly the instant ground taken by the assessee is allowed. Accordingly, we delete the entire addition of Rs.80,000/- in the hands of the assessee.
Held that in the assessment year 2003-04 in appeal no.CIT(A), Patna-3/10262/2007-08 has elaborately discussed the issue and the assessee could not controvert the facts before the ld. CIT(A) during the appellate proceedings and the ld. CIT(A) upheld the addition of Rs.54,000/-. We find no infirmity in the order of the ld. CIT(A) in this respect. Accordingly, this ground challenged by the assessee is hereby dismissed.
FULL TEXT OF THE ORDER OF ITAT PATNA
These appeals have been preferred by the assessee for different assessment years i.e 1998-99 & 2001-02 to 2004-05 against separate orders of the Commissioner of Income Tax (Appeals)-3, Patna [hereinafter referred to as ‘CIT(A)’] passed u/s 250 of the Income Tax Act (hereinafter referred to as the ‘Act’) respectively. Since, the issues involved in these appeals are mostly common and relate to the same assessee, therefore, these appeals have been heard together and are being disposed of by this consolidated order.
2. At the outset, we find that there is a delay of 132 days in filing the instant appeals. The assessee has submitted applications for condonation of delay citing reasonable grounds. After considering the averments made in the applications, we condone the delay.
3. We also find that no one has appeared on behalf of the assessee. On perusal of records, we notice that multiple dates of hearing were scheduled but the assessee failed to appear despite issuance of consecutive notices. Due to absence of the ld. AR or lack of representations, the Tribunal proceeds to decide the appeals based on the materials available on record and also with the assistance of the ld. DR to evaluate the merits of the case.
4. ITA No.213/Pat/2023 for assessment year 2001-02 – First, we take up the issue in respect of ITA No.212/Pat/2023.
5. Brief facts of the case are that the assessee is an individual. A search and seizure operation u/s 132(1) of the Act was conducted on 19.02.2004 in the case of the assessee as well as his associates/relatives. In this search operation, substantial investments in form of movable and immoveable properties were discovered which was alleged to have been unaccounted income of the assessee. The investigation revealed significant undisclosed income from activities related to examinations and recruitment process such as pre-medical exams, Bank P.O exams etc. Accordingly, the Assessing Officer initiated proceedings u/s 153A of the Act and due notices were issued to the assessee requiring to file returns. Thereafter, the Assessing Officer completed the assessment for the relevant year by determining substantial undisclosed income. Subsequent to the assessment, it was found that the assessee had used multiple alias names such as Indrajeet Kumar (Singh) and Ranjit Singh. Later on, income was assessed in the name of Indrajeet Kumar and merged with the assessed income of the assessee which was ultimately brought to tax by the Assessing Officer as there was no separate existence for different proceedings were found by the Assessing Officer. While passing the assessment order, the Assessing Officer clearly stated the facts in his assessment order at page 4 and assessed the income of the present assessee in respect of bail petition filed before the Hon’ble Patna High Court in Criminal Misc. No.879 of 2006, the contents of which are as under:
“Later on, it was detected that Shri Indrajeet Kumar(Singh) is actually the other name of Shri Kumar Suman Singh, as was evident from the bail petition filed before the Hon’ble Patna High Court by Shri Kumar Suman Singh in Criminal Misc. No. 879 of 2006, which shows that it was Kumar Suman Singh who was also known as Ranjit Singh/Indrajit Singh. Also, on perusal of the copy of L.I.C. policy no. 512001452 and policy no. 512001422, it was found that the policy holder is Shri Indrajeet Kumar and nominee/assignee is Shri Shyam Sundar Prasad and column for relative with the policy holder bears the term ‘father’. Family chart of the assessee shows that Shri Kumar Suman Singh, S/o Shri Shyam Sundar Prasad has no any brother with the name ‘Indrajeet Kumar’. Thus, it is amply clear that the person with the name Indrajeet Kumar/Prasad is none else, but Shri Kumar Suman Singh himself.
On the belief that there was no separate existence of Indrajeet Kumar, a proposal u/s 263 of the Act was submitted to the commissioner of Income Tax (Central), Patna by the A.O on 22.11.2006, to merge the income assessed in the hands of Shri Indrajeet Kumar in the assessed income of Shri Kumar Suman Singh.
The matter was examined by the Commissioner of Income Tax(Central), Patna, before whom it was pleaded on behalf of the assessee that the matter of non-existence of Shri Indrajeet Kumar was pending before the District Judge Nalanda. The CIT(Central), Patna held, ‘on careful consideration, I am of the opinion that despite request the A/R has failed to show the separate existence of any such Indrajeet Kumar / Prasad / Singh. In fact A/R has avoided any submission on this issue’. Yet on the basis of documents presented before the Hon’ble High Court, Patna and other related papers, the Commissioner of Income Tax (Central), Patna observed that there was no existence of Indrajeet Kumar separately and the assessment made in his hands (even without the filing of return by him) was erroneous and prejudicially to the interest of revenue. Accordingly, the A.O. was directed by him to assess the income of the nonexistent Shri Indrajeet Kumar in the hands of Shri Kumar Suman Singh and to modify the assessment order passed in the case of Shri Kumar Suman Singh to that extent.
An appeal before the Hon’ble ITAT, Patna, against this order of the Commissioner of Income of Income Tax (Central), Patna passed u/s 263 of the income Tax Act was quashed by the Hon’ble Bench by its order pronounced on 01.02.2008.”
5.1 Ultimately, the Assessing Officer completed the assessment by assessing total income of Rs.9,21,810/- by making certain additions.
6. Aggrieved by the above order, the assessee went in appeal before the ld. CIT(A) but the assessee could not succeed there and the ld. CIT(A) considering the submissions of the assessee granted certain relief but major additions were upheld by the ld. CIT(A).
7. Dissatisfied, the assessee has come in appeal before this Tribunal raising the following grounds:
“1. For that the proceeding initiated u/s 153A pursuant to search u/s 132(1) was illegal and void ab initio.
2. For that the CIT(A) has erred in confirming the addition of Rs.1,00,000/- on account of household expenses including payment of insurance premium.
3 For that the CIT(A) has wrongly included the income of Rs.7,59,520/- assessed in the hands of one Shri Indrajeet Kumar/Prasad Singh as the income of the appellant.
4. For that the assessment order in otherwise bad in fact and law and fit to be modified.
5 For that the appellant may be allowed to urge additional grounds, if any.”
8. Ground No.1 – In respect of ground no.1 which is relating to legality of proceedings initiated u/s 153A, the ld. DR stated that the search operation was conducted based on credible information and substantial unaccounted income was discovered during the search operation. Therefore, the initiation of proceedings u/s 153A was correct and proper and he prayed for dismissal of the ground.
9. We, after examining the facts of the case and submission made by the ld. DR, find that the search operation was carried out based on valid information gathered against the assessee along with associates/relatives and large scale investments were also found by the department during the relevant year. Accordingly, the Assessing Officer initiated proceedings u/s 153A of the Act and the assessment was completed making some additions on the basis of substantial unaccounted income after giving due opportunity to the assessee. Moreover, we note that the order passed u/s 263 of the Act passed by the ld. CIT(Central), Patna had already upheld by the ITAT in its order dated 01.02.2008 and the order passed by the Tribunal attained finality as it was not challenged before any higher forum. Therefore, this ground taken by the assessee is hereby dismissed.
10. Ground No.2 – In respect of ground no.2 which is relating to confirmation of addition of Rs.1,00,000/- on account of household expenses including payment of insurance premium, the ld. DR stated that the assessee has used multiple alias names including Indrajeet Singh which is evident from the documents such as LIC policy and bail petition filed by the Hon’ble Patna High Court. He also stated that the Assessing Officer after making detailed enquiries concluded that Indrajeet Singh was not a separate individual but another alias name used by the assessee and accordingly, the income assessed in the name of Indrajeet Singh was assessed in the hands of the assessee.
11. We find that the Assessing Officer made an addition of Rs.1,00,000/- on account of low withdrawal for the assessment year in question. However, the ld. CIT(A) after considering the present issue granted partial relief to the assessee to the extent of Rs.64,000/-observing as under:
“The AO has discussed the rationale of addition of Rs. 1,00,000/- on account of low withdrawal for the AY in question. I find that similar addition has been made by the AO for A.Y 2002-03 as well wherein he has added Rs. 65,000/- on account of low withdrawal. Considering the requirement of consistency, the AO should have taken consistence view regarding the low withdrawal for AY 2001-02 & 2002-03.
For AY 2002-03, it is observed that the appellant had shown withdrawal of Rs.35,000/-. The AO found the evidence of expenses of Rs. 59,575/- on account of payment to LIC and Rs. 7,500/-on account of payment to ULIP aggregating to Rs. 67,075/-. With these background facts, the AO made addition of Rs. 65,000/-. Under these background fact, the total withdrawal has been taken at Rs. 1,00,000/- (35,000+65000) against which the proof of expenses of approx. Rs. 67,000/- was available on account of payment to LIC/ULIP. Therefore, balance Rs. 33,000/(1,00,000-67,000) was left for personal expenses spread over 12 month. Meaning thereby, that AO has accepted the personal expenses @2750/-per month (33,000/12).
The AO should have taken consistent view while computing addition on account of low withdrawal for AY 2001-02 as well. The AO found that the appellant has shown withdrawal of Rs. 25,000/-. The AO had the evidence of expenses of Rs. 31,243/- on account of payment to LIC and Rs. 24,520/- on account of payment to ULIP aggregating to Rs. 55,763/-. Against this background, the AO made addition of Rs. 1,00,000/2 on account of low withdrawal. I find that this addition is inconsistent against his view for AY 2002-03 on the same issue. Admittedly, in this case, the AO had the evidence of expenses of Rs. 56,000/- approx. The AO has allowed personal expenses to the appellant @2750/- per month i.e. 33,000/- per annum for A.Y. 2002-03 which appears to be quite reasonable and therefore taking a consistent view, the total withdrawal should have been pegged at Rs. 89,000/- (33,000+56,000). The appellant has disclosed withdrawal of Rs. 25,000/-. Taking a consistent view, the AO should have at best made addition of Rs. 64,000/- (89,000-25,000). In view of the above discussion, the addition of Rs. 64,000/- only can be sustained for A.Y. 2001-02. In absence of any evidence from the appellant to the contrary, I direct the A.O to restrict the disallowance of Rs. 64,000/-on account of low withdrawal for A.Y. 2001-02. The ground is partly allowed.”
11.1 We, after examining the facts of the case and submission made by the ld. DR, find that the ld. CIT(A) while passing the impugned order discussed the facts of the issue at length and allowed partial relief to the assessee @ Rs.2750 per month i.e. Rs.33000/- per annum for the assessment year 2002-03 and the ld. CIT(A) by applying the same analogy for the relevant assessment year i.e. 2001-02 restricted the addition to the extent of Rs.64000/-. We do not find any interference in the order of the ld. CIT(A) and deem it correct since no contrary evidence was filed by the assessee before the Assessing Officer as well as the ld. CIT(A) during the proceedings. Therefore, we sustain the addition made by the ld. CIT(A) and dismiss this ground taken by the assessee.
12 Ground No.3 – In respect of ground no.3 which is relating to inclusion of income by the ld. CIT(A) of Rs.7,59,520/- in the hands of Sri Indrajeet Singh as income of the assessee, the ld. DR stated that this fact emerged from the bail petition filed before the Hon’ble Patna High Court in Criminal Misc. No.879 of 2006, which shows that the assessee is known as Ranjit Singh/Indrajit Singh. The ld. DR also stated that on perusal of the copy of L.I.C. policy no. 512001452 and policy no. 512001422, it was found that the policy holder is Shri Indrajeet Kumar and nominee/assignee is Shri Shyam Sundar Prasad and column for relative with the policy holder bears the term ‘father’ and Family chart of the assessee shows that Shri Kumar Suman Singh, S/o Shri Shyam Sundar Prasad has no any brother with the name ‘Indrajeet Kumar’. Thus, it is amply clear that the person with the name Indrajeet Kumar/Prasad is none else, but Shri Kumar Suman Singh himself. The ld. DR concluded that the ld. CIT(A) in this respect has rightly upheld the addition of Rs.7,59,520/- in the hands of the assessee.
13. We, after examining the facts of the case and submission made by the ld. DR, find that the assessee had used multiple alias names such as Indrajeet Kumar (Singh) and Ranjit Singh which was clearly evident from the bail petition filed before Hon’ble Patna High Court. We also find that income assessed in the name of Indrajeet Kumar in the hands of the assessee as there was no separate existence found for different proceedings by the Assessing Officer. Therefore, we find that the ld. CIT(A) has rightly upheld the order of the ld. CIT(A) in respect of inclusion of income of Rs.7,59,520/- in the hands of Sri Indrajeet Singh as income of the assessee. We also dismiss this ground taken by the assessee.
14. Ground Nos.4 & 5 – These grounds taken by the assessee are general in nature and do not require any adjudication.
15. Therefore, ITA No.213/Pat/2023 is dismissed.
16. ITA No.214/Pat/2023 for assessment year 2002-03 – Since the facts and issues involved in the present appeal are identical to that has been discussed in ITA No.213/Pat/2023 for assessment year 2001-02 except difference in figures, our findings/directions given above will mutatis mutandis apply to ITA No.214/Pat/2023 also.
17. Hence, ITA No.214/Pat/2023 is also dismissed.
18. ITA No.215/Pat/2023 for assessment year 2003-04 – The assessee through this appeal has taken the following grounds:
“1. For that the proceeding initiated u/s 153A pursuant to search u/s 132(1) was illegal and void ab initio.
2. For that the CIT(A) has erred in confirming the addition of Rs.51,055/- as unexplained expenditure.
3 For that the CIT(A) has not justified in confirming the addition of Rs.3,00,000/- being gift received from Grandmother.
4. For that the CIT(A) has wrongly included the income of Rs.5,54,740/- assessed in the hands of one Shri Indrajeet Kumar/Prasad Singh as the income of the appellant.
5. For that the assessment order in otherwise bad in fact and law and fit to be modified.
6. For that the appellant may be allowed to urge additional grounds, if any.”
19. Since the facts and issues involved in the present appeal apart from difference in figures of amounts involved are identical to that has been discussed in ITA No.213/Pat/2023 for assessment year 2001-02 except Ground No.3, hence, our findings/directions given in the remaining grounds except ground no.3 will mutatis mutandis apply to the present appeal i.e. ITA No.215/Pat/2023 and we now proceed to adjudicate ground no.3 taken by the assessee in the instant appeal.
20. Ground No.3 – In respect of ground no.3 which is relating to confirmation of the addition of Rs.3,00,000/- being gift received from grandmother, the ld. DR stated that the assessee’s grandmother namely Smt. Pano Devi had no resource which can substantiate the gift given to the assessee at Rs.3,00,000/- for the assessment year 2003-04 and the ld. CIT(A) has rightly dismissed the ground of the assessee observing as under:
“I have considered the findings recorded by the A.O in the assessment order and written submission made by the ld. AR. The ld. AR has objected to the addition, however, he has failed to prove with reference to documentary evidence that grandmother Smt. Pano Devi had disclosed resources to substantiate the gift of Rs.3,00,000/- made for A.Y 2003-04. In view of the aforementioned discussion, I hold that the genuineness and creditworthiness has not been proved neither during the assessment proceedings nor during appellate proceedings. Accordingly, the ground is dismissed.”
21. We, after examining the facts of the case and submission made by the ld. DR, note that the assessee has failed to prove his claim before the Assessing Officer as well as before the ld. CIT(A) regarding the confirmation of the addition of Rs.3,00,000/- received as gift from grandmother i.e. Smt. Pano Devi during the relevant assessment year. Since, the donor Smt. Pano Devi, grandmother of the assessee, has no disclosed source to substantiate the claim of gift made to the assessee, we accordingly uphold the order of the ld. CIT(A). This ground of the assessee is dismissed.
22. ITA No.215/Pat/2023 is therefore dismissed.
23. ITA No.216/Pat/2023 for assessment year 2004-05 – The assessee through this appeal has taken the following grounds:
“1. For that the proceeding initiated u/s 153A pursuant to search u/s 132(1) was illegal and void ab initio.
2. For that the CIT(A) has erred in confirming the addition of Rs.40,000/- as income from business where the appellant was in jail in that period.
3 For that the CIT(A) has not justified in treating the deposit of Rs.54,000/- in bank account as unexplained.
4. For that the CIT(A) has wrongly included the income of Rs.1,32,710/- assessed in the hands of one Shri Indrajeet Kumar/Prasad Singh as the income of the appellant.
5. For that the assessment order in otherwise bad in fact and law and fit to be modified.
6. For that the appellant may be allowed to urge additional grounds, if any.”
24. Since the facts and issues involved in the present appeal apart from difference in figures of amounts involved are identical to that has been discussed in ITA No.213/Pat/2023 for assessment year 2001-02 except Ground No.2, hence, our findings/directions given in the remaining grounds except Ground No.2 & Ground No.3 will mutatis mutandis apply to the present appeal i.e. ITA No.216/Pat/2023 and we now proceed to adjudicate Ground nos.2 & 3 taken by the assessee in the present appeal.
25. Ground No.2 – Ground no.2 is relating to confirmation of the addition of Rs.40,000/- as income from business where the assessee was in jail in that period of time, therefore, the addition sustained by the ld. CIT(A) is not correct and liable to be dismissed. In respect of this ground, the ld. DR stated that while framing the assessment order, an addition of Rs.80,000/- was made on estimation basis in the hands of the assessee and the assessee did not come forward to submit necessary documents in the relevant assessment year. He further stated that the ld. CIT(A), after considering the facts, found that the Assessing Officer has failed to bring any positive material to prove existence or continuation of onion business and the ld. CIT(A) in the interest of justice granted partial relief to the assessee to the extent of Rs.40,000/-.
26. We, after examining the facts of the case and submission made by the ld. DR, find that in the instant issue, the Assessing Officer has not brought on record any material or valid proof in order to validate the existence or continuation of onion business of the assessee. Therefore, the alleged addition made by the Assessing Officer of Rs.80,000/- in the hands of the assessee was not correct and accordingly the instant ground taken by the assessee is allowed. Accordingly, we delete the entire addition of Rs.80,000/- in the hands of the assessee. This ground of the assessee is allowed.
27. Ground No.3 – Ground no.3 is relating to treating of Rs.54,000/- in bank account as unexplained income of the assessee. In this regard, the ld. DR stated that the issue of gift from grandmother has been discussed in detailed by the ld. CIT(A) in his order for the assessment year 2003-04 in appeal no.CIT(A), Patna-3/10262/2007-08 where the genuineness of the transaction and creditworthiness of the grandmother was not proved. Therefore, the gift of Rs.54,000/- as alleged by the assessee was not allowed and the ld. CIT(A) sustained the addition. Therefore, the ld. DR has not found any infirmity drawn in the order of the ld. CIT(A) in respect of this ground.
28. We, after examining the facts of the case and submission made by the ld. DR, find that in the assessment year 2003-04 in appeal no.CIT(A), Patna-3/10262/2007-08 has elaborately discussed the issue and the assessee could not controvert the facts before the ld. CIT(A) during the appellate proceedings and the ld. CIT(A) upheld the addition of Rs.54,000/-. We find no infirmity in the order of the ld. CIT(A) in this respect. Accordingly, this ground challenged by the assessee is hereby dismissed.
29. Therefore, ITA No.216/Pat/2023 is partly allowed.
30. ITA No.212/Pat/2023 for assessment year 1998-99 – The assessee through this appeal has taken the following grounds:
“1. For that the CIT(A) has erred in treating the opening balance as on 01.04.1997 of Rs.2,68,385/- as income for A.Y 1998-99.
2. For that the assessment order in otherwise bad in fact and law and fit to be modified.
3. For that the appellant may be allowed to urge additional grounds, if any.”
31. In this appeal, the assessee has challenged one issued relating to addition made in respect of opening balance as on 01.04.1997 shown by the assessee at Rs.2,68,385/- as income of the assessee from undisclosed sources and the addition was added to the income of the assessee by the Assessing Officer and subsequently sustained by the ld. CIT(A), which was not correct. On this context, the ld. DR stated that the ld. CIT(A) in his order has already discussed the facts in details while passing the order at para no.6, which is as under:
During the course of assessment proceedings, the appellant filed the balance sheet of relevant previous year 1998-99, the opening capital was shown at Rs. 2,68,385/- with narration “as per last balance sheet”. The AO after in-depth analysis of the information available before him has held that there was Nil income of the appellant up to FY 1997-98. Accordingly, he was of the view that the appellant could not produce any supporting document to verify the opening balance. Accordingly, the same was treated as appellant’s own income for relevant previous year.
During the course of appellate proceedings, the AR Shri Suman Kumar Nayak could not produce any documentary evidence except xerox copy of affidavit dated 06.07.2006 which stated that the appellant had sold Bajaj 4-S, Champion Motor Cycle bearing registration no. BR-1E-6695, Chasis No. 31E94E40697 and Engine No. 31M94E39869 on 04.05.1997 amounting to Rs. 35,000/-. Undisputedly, the copy of affidavit submitted was dated 06.07.2006, however, the disputed assessment was passed on 10.02.2006. This affidavit was made subsequent to the date of assessment order. Had there been any genuineness in the claim made in the affidavit, the same should have been filed during the course of assessment proceedings as it has been claimed in the affidavit that the sale was made on 04.05.1997. Under the evident facts, as the reliability of affidavit being doubtful, the request of the Ld. AR that at least to the extent of the sale value of the motorcycle at Rs. 35,000/- should be accepted as proved capital in hands of the appellant as on 01.04.1997, cannot be accepted. In view of the aforesaid discussion, I hold that appellant has failed to bring on record any documentary evidence to prove the opening capital of Rs. 2,68,385/-. Accordingly, the addition is confirmed the ground nos. 1 to 5 taken on this issue are dismissed.”
32. The ld. DR stated that at the time of framing of the assessment order, the assessee could not furnish any credible documentary evidences in order to prove the opening capital balance of Rs.2,68,385/-. He also stated that the Assessing Officer therefore has rightly added the alleged amount as undisclosed income in the hands of the assessee. The assessee has furnished a copy of affidavit dated 06.07.2006 stating that the assessee had sold Bajaj 4-S, Champion Motor Cycle at Rs.35,000/-which was after the passing of assessment order dated 10.02.2006 and the assessee failed to bring relevant documents in order to prove the alleged opening capital of Rs.2,68,385/- on 01.04.1997 and accordingly, the ld. CIT(A) has rightly upheld the order of the Assessing Officer. He, therefore, prayed that this ground taken by the assessee needs to be dismissed.
33. We, after examining the facts of the case and submission made by the ld. DR, find that the assessee could not controvert the facts by producing documentary evidence in order to prove the instant issue of opening capital of Rs.2,68,385/-. We note that before the ld. CIT(A), the assessee simply submitted copy of an affidavit dated 06.07.2006 which was after the passing of assessment order dated 10.02.2006, therefore, the Assessing Officer did not consider the same. We further note that the view taken by the ld. CIT(A) is correct and we find no infirmity in the order of the ld. CIT(A) on this ground. Accordingly, we dismiss the present ground taken by the assessee.
34. Ground No.2 & 3 are consequential in nature and do not require any adjudication.
35. Therefore, ITA No.212/Pat/2023 is dismissed.
36. In the result, I.T.A. Nos.212 to 215/Pat/2023 are dismissed, whereas, ITA No.216/Pat/2023 is partly allowed.
Kolkata, the 9th January, 2025.
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