ARUN MAJEED, vs. THE INCOME TAX OFFICER,

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WP(C)/35986/2023HC KeralaKLHC01081298202329 July 2024Author: HONOURABLE MR. JUSTICE GOPINATH P.17 pages
AI SummaryRemanded

What did the High Court hold?

The High Court disposed of the writ petitions with a direction to the petitioner. The court held that if the petitioner approaches the jurisdictional assessing authority with specific details of refunds that have been sanctioned but not yet paid, the assessing authority must decide on these claims. This decision is to be made in accordance with the law, after providing the petitioner an opportunity of hearing. The assessing authority is directed to take a decision within a period of three months from the date of receipt of a certified copy of the judgment. The court did not delve into the merits of specific refund claims but provided a procedural path for resolution.

What were the facts?

The petitioner, Arun Majeed, acting as the Managing Partner for several Partnership Firms, filed three writ petitions before the High Court of Kerala. These petitions were filed due to the non-payment of refunds due to these firms for various assessment years, despite requests made by the petitioner. The respondents are various Income Tax Officers and Principal Commissioners of Income Tax across different wards and circles in Kerala. The cases were heard together, and the court considered the submissions from both the petitioner and the department.

What were the issues?

1. Whether the petitioner has a subsisting grievance regarding the non-payment of refunds due to the Partnership Firms for various assessment years, which warrants intervention by the High Court under its writ jurisdiction? Assessee's Contention: The petitioner argues that refunds due to the Partnership Firms have not been paid despite requests, indicating a failure on the part of the revenue authorities to discharge their statutory obligation. Revenue's Contention: The learned Standing Counsel for the department submitted that several refunds have already been sanctioned and paid. They further contended that if the petitioner has any specific grievance regarding any unpaid refund, the petitioner should approach the assessing authority for resolution.

AI-generated summary — verify with the full judgment below

Heard together (4 matters)

WP(C) NO. 35946 OF 2023
TC NO. 34/71
WP(C).35955/2023
WP(C) NO. 35986 OF 2023

Read from the judgment's own cause title. This page is filed under one of them.

Cause title — parties, addresses and appearances
IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. MONDAY, THE 29TH DAY OF JULY 2024 / 7TH SRAVANA, 1946 WP(C) NO. 35946 OF 2023 PETITIONER: ARUN MAJEED, AGED 42 YEARS TC NO. 34/711, VELIYANNUR TEMPLE LANE, THRISSUR, PIN - 680021 BY ADVS. MEERA V.MENON R.SREEJITH K.KRISHNA PARVATHY MENON RESPONDENTS: 1 THE INCOME TAX OFFICER, NON-CORP WARD 1 (1), INCOME TAX DEPARTMENT, C.R. BUILDINGS, I.S.PRESS ROAD, KOCHI, PIN - 682018 2 THE PRINCIPAL COMMISSIONER OF INCOME TAX, INCOME TAX DEPARTMENT, C.ER. BUILDINGS, I.S. PRESS ROAD,KOCHI, PIN - 682018 OTHER PRESENT: SRI. CHRISTOPHER ABRAHAM (SC) THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 29.07.2024, ALONG WITH WP(C).35955/2023, 35986/2023, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) Nos. 35946, 35955, 35986 of 2023 2 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. MONDAY, THE 29TH DAY OF JULY 2024 / 7TH SRAVANA, 1946 WP(C) NO. 35955 OF 2023 PETITIONER: ARUN MAJEED, AGED 42 YEARS TC NO. 34/711, VELIYANNUR TEMPLE LANE, THRISSUR, PIN - 680021 BY ADVS. MEERA V.MENON R.SREEJITH K.KRISHNA PARVATHY MENON RESPONDENTS: 1 THE INCOME TAX OFFICER, WARD 1 (3), INCOME TAX DEPARTMENT, AAYAKAR BHAVAN, THIRUVANANTHAPURAM, PIN - 695003 2 THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1 (1), INCOME TAX DEPARTMENT, AAYAKAR BHAVAN, THIRUVANANTHAPURAM, PIN - 695003 3 THE INCOME TAX OFFICER, WARD -1, INCOME TAX DEPARTMENT, AAYAKAR BHAVAN, KOLLAM, PIN - 691001 4 THE PRINCIPAL COMMISSIONER OF INCOME TAX, INCOME TAX DEPARTMENT, AYAKAR BHAVAN, THIRUVANANTHAPURAM, PIN - 695003 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 29.07.2024, ALONG WITH WP(C).35946/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) Nos. 35946, 35955, 35986 of 2023 3 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. MONDAY, THE 29TH DAY OF JULY 2024 / 7TH SRAVANA, 1946 WP(C) NO. 35986 OF 2023 PETITIONER: ARUN MAJEED, AGED 42 YEARS TC NO. 34/711, "PALAK", VELIYANNUR TEMPLE LANE, THRISSUR, PIN - 680021 BY ADVS. MEERA V.MENON K.KRISHNA R.SREEJITH PARVATHY MENON RESPONDENTS: 1 THE INCOME TAX OFFICER, WARD 1 & TPS, INCOME TAX DEPARTMENT, GURUVAUYUR ,THRISSUR DISTRICT, PIN - 680101 2 THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE (1) & TPS, INCOME TAX DEPARTMENT, AAYAKAR BHAVAN, S.T. NAGAR, THRISSUR, PIN - 680001 3 THE INCOME TAX OFFICER, WARD 1 (1), INCOME TAX DEPARTMENT, AAYAKAR BHAVAN, MANANCHIRRA, KOZHIKODE, PIN - 673001 4 THE INCOME TAX OFFICER, WARD 2 (1), INCOME TAX DEPARTMENT,AAYAKAR BHAVAN, S.T. NAGAR, THRISSUR, PIN - 680001 5 THE PRINCIPAL COMMISSIONER OF INCOME TAX, INCOME TAX DEPARTMENT, AYAKAR BHAVAN, MANACHIRRA, KOZHIKODE, PIN - 673001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 29.07.2024, ALONG WITH WP(C).35946/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) Nos. 35946, 35955, 35986 of 2023 4 GOPINATH P., J. - - - - - - - - - - - - - - - - - - - - - WP(C) Nos.35946, 35955 & 35986 of 2023 - - - - - - - - - - - - - - - - - - - - - - - - - - - Dated this the 29th day of July, 2024

JUDGMENT The petitioner is common in all these cases, though he represents different Partnership Firms as its Managing Partner in each writ petition.

2.

The petitioner has approached this Court being aggrieved by the fact that certain amount of refund due to the Partnership Firms in question in respect of various assessment years has not been paid despite request.

3.

The learned Standing Counsel appearing for the department would submit that several of the refunds due to petitioner have been sanctioned and paid and if the petitioner has any subsisting grievance regarding any particular amount that has not been received, the petitioner may approach the assessing authority, who will consider the claim of the petitioner and take a decision, in accordance with the law.

4.

Having heard the learned counsel appearing for the petitioner and the learned Standing Counsel appearing for the department, these writ petitions will stand disposed of directing that if the petitioner approaches the jurisdictional assessing authority with details of the refunds which have been sanctioned but not been paid so far, the jurisdictional assessing authority shall take a decision regarding the claims put forward by the petitioner, in accordance with the law, after affording an opportunity of hearing to the petitioner, within a period of three months from the date of receipt of a certified copy of this judgment. These writ petitions are disposed of accordingly. GOPINATH P. JUDGE bng

Appendix — schedule of exhibits
APPENDIX OF WP(C) 35955/2023 PETITIONER EXHIBITS EXHIBIT P1 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KESAVADASAPURAM SEVENA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P2 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KILLIPPALAM SEVENA MEDICINES FOR THE YEAR 2009-10 DTD. 07-05-2018 EXHIBIT P3 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KILLIPPALAM SEVENA MEDICINES FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P4 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KILLIPPALAM SEVENA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P5 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KILLIPPALAM SEVENA MEDICINES FOR THE YEAR 2012-103DTD. 07-05-2018 EXHIBIT P6 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KILLIPPALAM SEVENA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P7 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KILLIPPALAM SEVENA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P8 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOLLAM SEVENA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P9 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, WP(C) Nos. 35946, 35955, 35986 of 2023 7 CENTRAL CIRCLE, THRISSUR TO M/S. KOLLAM SEVENA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P10 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOLLAM SEVENA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P11 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOLLAM SEVENA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P12 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGASRDS M/S. KESAVADASAPURAM SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P13 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 2ND RESPONDENT AS REGASRDS M/S. KILLIPPALAM SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P14 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 4TH RESPONDENT DTD. 22-08-2023 WP(C) Nos. 35946, 35955, 35986 of 2023 8 APPENDIX OF WP(C) 35986/2023 PETITIONER EXHIBITS EXHIBIT P1 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M./S. EDAPPAL KARUNYA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P2 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M./S. EDAPPAL KARUNYA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P3 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. EDAPPAL KARUNYA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P4 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M./S. EDAPPAL KARUNYA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P5 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. A.M. PHARMACEUTICALS INDIA PVT. LTD. FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P6 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. A.M. PHARMACEUTICALS INDIA PVT. LTD. FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P7 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. A.M. PHARMACEUTICALS INDIA PVT. LTD. FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P8 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. NEW BUS STAND SEVANA MEDICINES FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P9 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, WP(C) Nos. 35946, 35955, 35986 of 2023 9 CENTRAL CIRCLE, THRISSUR TO M/S. NEW BUS STAND SEVANA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P10 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. NEW BUS STAND SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P11 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. NEW BUS STAND SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P12 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. NEW BUS STAND SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P13 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALAYAM SEVANA MEDICINES FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P14 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALAYAM SEVANA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P15 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALAYAM SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P16 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALAYAM SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P17 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALAYAM SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P18 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. WP(C) Nos. 35946, 35955, 35986 of 2023 10 SEVANA MEDICINES , KALOOR FOR THE YEAR 2008-09 DTD. 07-05-2018 EXHIBIT P19 OPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES , KALOOR FOR THE YEAR 2009-10 DTD. 07-05-2018 EXHIBIT P20 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES , KALOOR FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P21 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES , KALOOR FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT 22 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES , KALOOR FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P23 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES , KALOOR FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P24 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES , KALOOR FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P25 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOTTAYAM SEVANA MEDICINES FOR THE YEAR 2009-10 DTD. 07-05-2018 EXHIBIT P26 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOTTAYAM SEVANA MEDICINES FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P27 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOTTAYAM SEVANA MEDICINES FOR THE YEAR WP(C) Nos. 35946, 35955, 35986 of 2023 11 2011-12 DTD. 07-05-2018 EXHIBIT P28 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOTTAYAM SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P29 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOTTAYAM SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P30 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KOTTAYAM SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P31 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES, CHALAKUDY FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P32 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES , CHALAKUDY FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P33 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES, CHALAKUDY FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P34 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES, CHALAKUDY FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P35 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. SEVANA MEDICINES, CHALAKUDY FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P36 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ROUND SOUTH SEVANA PHARMA FOR THE YEAR 2008- 09 DTD. 07-05-2018 WP(C) Nos. 35946, 35955, 35986 of 2023 12 EXHIBIT P37 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ROUND SOUTH SEVANA PHARMA FOR THE YEAR 2009- 10 DTD. 07-05-2018 EXHIBIT P38 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ROUND SOUTH SEVANA PHARMA FOR THE YEAR 2010- 11 DTD. 07-05-2018 EXHIBIT P39 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ROUND SOUTH SEVANA PHARMA FOR THE YEAR 2011- 12 DTD. 07-05-2018 EXHIBIT P40 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ROUND SOUTH SEVANA PHARMA FOR THE YEAR 2012- 13 DTD. 07-05-2018 EXHIBIT P41 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ROUND SOUTH SEVANA PHARMA FOR THE YEAR 2013- 14 DTD. 07-05-2018 EXHIBIT P42 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ROUND SOUTH SEVANA PHARMA FOR THE YEAR 2014- 15 DTD. 07-05-2018 EXHIBIT P43 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. A M ALUMINIUM FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P44 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGARDS M/S. EDAPPAL KARUNYA MEDICINES DTD. 22-01-2022 EXHIBIT P45 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 2ND RESPONDENT AS REGARDS M/S. A.M. PHARMACEUTICALS INDIA POVT.LTD.DTD. 22-01-2022 EXHIBIT P46 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 3RD RESPONDENT AS REGARDS M/S. PALAYAM SEVANA WP(C) Nos. 35946, 35955, 35986 of 2023 13 MEDICINES DTD. 22-01-2022 EXHIBIT P47 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 4TH RESPONDENT AS REGARDS M/S. SEVANA MEDICINES, KALOOR DTD. 22-01-2022 EXHIBIT P48 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 4TH RESPONDENT AS REGARDS M/S. KOTTAYAM SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P49 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 4TH RESPONDENT AS REGARDS M/S. SEVANA MEDICINES, CHALAKUDY DTD. 22-01-2022 EXHIBIT P50 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 4TH RESPONDENT AS REGARDS M/S. ROUND SOUTH SEVANA MEDICINES, DTD. 22-01-2022 EXHIBIT P51 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 4TH RESPONDENT AS REGARDS M/S. AM ALUMINIUM DTD. 22- 01-2022 EXHIBIT P52 COPY OF APPLICATION FILED BY THE PETITIONER BEFORE THE 5TH RESPONDENT DTD. 22-08-2023 WP(C) Nos. 35946, 35955, 35986 of 2023 14 APPENDIX OF WP(C) 35946/2023 PETITIONER EXHIBITS EXHIBIT P1 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. THOPPUMPADY SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P2 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. EDAPPALLY TOLL SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P3 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KADAVANTHRA SEVANA MEDICINES FOR THE YEAR 2008-09 DTD. 07-05-2018 EXHIBIT P4 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KADAVANTHRA SEVANA MEDICINES FOR THE YEAR 2009-10 DTD. 07-05-2018 EXHIBIT P5 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KADAVANTHRA SEVANA MEDICINES FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P6 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KADAVANTHRA SEVANA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P7 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KADAVANTHRA SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P8 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. KADAVANTHRA SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P9 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, WP(C) Nos. 35946, 35955, 35986 of 2023 15 CENTRAL CIRCLE, THRISSUR TO M/S. KADAVANTHRA SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P10 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. HIGH COURT JUNCTION SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P11 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. HIGH COURT JUNCTION SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P12 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. HIGH COURT JUNCTION SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P13 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ANGAMALI SEVANA MEDICINES FOR THE YEAR 2010-11 DTD. 07-05-2018 EXHIBIT P14 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ANGAMALI SEVANA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P15 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ANGAMALI SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P16 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ANGAMALI SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P17 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. ANGAMALI SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P18 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. WP(C) Nos. 35946, 35955, 35986 of 2023 16 TRIPUNITHURA SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P19 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. TRIPUNITHURA SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P20 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. TRIPUNITHURA SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P21 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALARIVATTOM SEVANA MEDICINES FOR THE YEAR 2011-12 DTD. 07-05-2018 EXHIBIT P22 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALARIVATTOM SEVANA MEDICINES FOR THE YEAR 2012-13 DTD. 07-05-2018 EXHIBIT P23 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALARIVATTOM SEVANA MEDICINES FOR THE YEAR 2013-14 DTD. 07-05-2018 EXHIBIT P24 COPY OF ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, THRISSUR TO M/S. PALARIVATTOM SEVANA MEDICINES FOR THE YEAR 2014-15 DTD. 07-05-2018 EXHIBIT P25 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGARDS THE THOPPUMPADY SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P26 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGARDS THE EDAPPALLY TOLL SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P27 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGARDS THE KADAVANTHRA SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P28 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT WP(C) Nos. 35946, 35955, 35986 of 2023 17 AS REGARDS THE HIGH COURT JUNCTION SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P29 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGARDS THE ANGAMALI SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P30 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGARDS THE THRIPUNITHURA SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P31 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 1ST RESPONDENT AS REGARDS THE PALARIVATTOM SEVANA MEDICINES DTD. 22-01-2022 EXHIBIT P32 COPY OF APPLICATION SUBMITTED BY THE PETITIONER BEFORE THE 2ND RESPONDENT DTD. 22-08-2023

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