IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER Assessment Year : 2012-13 Assistant Commissioner of Income Tax, Central Circle-1(2), Kolkata, R. No. 310, 3rd Floor, Aayakar Bhawan Poorva, 110, Shanti Pally, Kolkata – 700107 ……..…...…………….... Appellant vs.

Somani Services Private Limited, 16C, Synagouge Street, Kolkata, Kolkata – 700001, West Bengal [PAN : AAICS2046K] ................................ Respondent Appearances by:

Assessee represented by : Rakesh Jain, AR Department represented by : Dheeraj, Sr. DR Date of concluding the hearing : 25.08.2025 Date of pronouncing the order : 16.10.2025

O R D E R

PER SANJAY AWASTHI, ACCOUNTANT MEMBER:

1. These are a batch of two appeals filed by the Revenue for the same Assessment Year (2012-13). Both of the appeals have interconnected facts and hence they are being disposed off through a single order.

1.1 Both the appeals have been belatedly filed and for the sake of convenience the application for condonation of delay in ITA No. 2219/Kol/2024 is being reproduced for consideration of condonation of said delay:

“With due respect, this is to inform you that in the