M.K.RAJENDRAN PILLAI, vs. ASSISTANT COMMISSIONER OF INCOME TAX,

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WP(C)/17640/2019HC KeralaKLHC01043035201928 June 2019Author: HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE18 pages
AI SummaryRemanded

What did the High Court hold?

The High Court of Kerala directed the 3rd respondent, the Principal Commissioner of Income Tax (Central), to take an appropriate decision on Ext.P7 within a period of one month. This decision is to be made after issuing notice to the petitioners and affording them an opportunity of being heard. The Court did not rule on the legality of the attachment orders themselves but rather on the procedural step of ensuring the petitioners' representation is addressed. The operative direction is for the Principal Commissioner to adjudicate the matter expeditiously. No specific findings were made on the merits of the petitioners' claim of illegality or hardship, as the primary focus was on directing the authority to decide on the representation.

What were the facts?

The petitioners, Arun Raj Pillai, Valsala Raj, Varun Raj, and M.K. Rajendran Pillai, are assessees under the Income Tax Act. They are aggrieved by provisional attachment orders issued under Section 281B of the Income Tax Act, 1961. The petitioners allege that the attachments are illegal and are hindering their ability to conduct business. To address this, they submitted Ext.P7 to the Principal Commissioner of Income Tax (Central) seeking to lift or modify the attachment orders. These writ petitions were filed challenging the said attachment orders and seeking relief.

What were the issues?

1. Whether the provisional attachment orders issued under Section 281B of the Income Tax Act, 1961, are illegal and causing undue hardship to the assessees, preventing them from conducting business. Assessee's Contention: The petitioners argued that the attachment orders are illegal and are causing them significant financial hardship by preventing them from carrying out their business activities. They have approached the Principal Commissioner of Income Tax with a representation (Ext.P7) to resolve the issue. Revenue's Contention: The judgment does not record any specific contentions from the revenue regarding the legality of the attachment orders or the hardship faced by the assessees. The revenue is represented by the Assistant Commissioner of Income Tax, Deputy Director of Income Tax (Inv), and the Principal Commissioner of Income Tax (Central).

Which sections of the Income-tax Act were involved?

Section 281B

AI-generated summary — verify with the full judgment below

Heard together (4 matters)

WP(C).No.17597 of 2019
WP(C).17594/2019
WP(C).17602/2019
WP(C).17640/2019

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 A.MUHAMED MUSTAQUE FRIDAY, THE 28TH DAY OF JUNE 2019 / 7TH ASHADHA, 1941 WP(C).No.17597 of 2019 PETITIONER: ARUN RAJ PILLAI AGED 30 YEARS S/O.M.K.RAJENDRAN PILLAI, RESIDING AT RAJAVALSOM, PANANGADU P.O., KULANADA, PANDALAM, PATHANAMTHITTA- 689 503. BY ADVS. SRI.S.MUHAMMED HANEEFF SRI.M.H.ASIF ALI SMT.SHAIMA VAHAB RESPONDENTS: 1 ASSISTANT COMMISIONER OF INCOME TAX CENTRAL CIRCLE, KOLLAM, KARBALA JUNCTION, KOLLAM-691 001. 2 DEPUTY DIRECTOR OF INCOME TAX (INV), KOLLAM, KARABALA JUNCTION, KOLLAM-691 001. 3 THE PRINCIPAL COMMISSIONER OF INCOME TAX(CENTRAL), I.S.PRESS ROAD, KOCHI-682 031. BY ADV.THUSHARA JAMES, GOVT. PLEADER THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 28.06.2019, ALONG WITH WP(C).17594/2019, WP(C).17602/2019, WP(C).17640/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 2 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE FRIDAY, THE 28TH DAY OF JUNE 2019 / 7TH ASHADHA, 1941 WP(C).No.17594 of 2019 PETITIONER: VALSALA RAJ AGED 57 YEARS W/O. M.K. RAJENDRAN PILLAI, RESIDING AT RAJAVALSOM, PANANGADU P.O, KULANADA, PANDALAM, PATHANAMTHITTA-689 503 BY ADVS. SRI.S.MUHAMMED HANEEFF SRI.M.H.ASIF ALI RESPONDENTS: 1 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, KOLLAM, KARBALA JUNCTION, KOLLAM-691 001 2 DEPUTY DIRECTOR OF INCOME TAX (INV) KOLLAM, KARABALA JUNCTION, KOLLAM-691 001 3 THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), I.S. PRESS ROAD, KOCHI-682 031 BY ADV.THUSHARA JAMES, GOVT. PLEADER THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 28.06.2019, ALONG WITH WP(C).17640/2019, WP(C).17602/2019, WP(C).17597/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 3 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE FRIDAY, THE 28TH DAY OF JUNE 2019 / 7TH ASHADHA, 1941 WP(C).No.17602 of 2019 PETITIONER: 1 VARUN RAJ AGED 32 YEARS S/O.M.K.RAJENDRAN PILLAI, RESIDNG AT 'RAJAVALSOM, PANANGADU.P.O, KULANADA, PANDALAM PATHANAMTHITTA-689503 2 DEPUTY DIRECTOR OF INCOME TAX (INV), KOLLAM KARABALA JUNCTION, KOLLAM-691001 BY ADVS. SRI.S.MUHAMMED HANEEFF SRI.M.H.ASIF ALI RESPONDENTS: 1 ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, KOLLAM, KARBALA JUNCTION, KOLLAM- 691001 2 DEPUTY DIRECTOR OF INCOME TAX(INV), KOLLAM KARABALA JUNCTION, KOLLAM-691001 3 THE PRINCIPAL COMMISSIONER OF INCOME TAX(CENTRAL), I.S.PRESS ROAD, KOCHI-682031 BY ADV.THUSHARA JAMES, GOVT. PLEADER THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 28.06.2019, ALONG WITH WP(C).17640/2019, WP(C).17594/2019, WP(C).17597/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 4 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE FRIDAY, THE 28TH DAY OF JUNE 2019 / 7TH ASHADHA, 1941 WP(C).No.17640 of 2019 PETITIONER: M.K.RAJENDRAN PILLAI, AGED 67 YEARS S/O.PILLAI, RESIDING AT RAJAVALSOM, PANANGADU P.O., KULANADA, PANDALAM, PATHANAMTHITTA -689 503. BY ADVS. SRI.S.MUHAMMED HANEEFF SRI.M.H.ASIF ALI RESPONDENTS: 1 ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOLLAM, KARBALA JUNCTION, KOLLAM - 691001. 2 DEPUTY DIRECTOR OF INCOME TAX (INV), KOLLAM KARABALA JUNCTION, KOLLAM - 691 001. 3 THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), I.S.PRESS ROAD,KOCHI - 682 031. BY ADV.THUSHARA JAMES, GOVT. PLEADER THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 28.06.2019, ALONG WITH WP(C).17602/2019, WP(C).17594/2019, WP(C).17597/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 5

JUDGMENT The petitioners, the assessees under the Income Tax Act, aggrieved by the provisional attachment order under Section 281(B) of Income Tax Act, 1961, approached the Principal Commissioner of Income Tax (General) with Ext.P7 to lift the attachment order or to modify the order of attachment. Petitioners' allegation is that on account of the attachment, they are unable to do any business. Petitioners also submit that attachment order is illegal. In the light of Ext.P7, there shall be a direction to the 3rd respondent to take appropriate decision on Ext.P7, within a period of one month, after issuing notice to the petitioners and after affording an opportunity of being heard. These writ petitions are disposed of as above. A.MUHAMED MUSTAQUE jv JUDGE APPENDIX OF WP(C) 17597/2019 EXHIBIT P1 AOF THE COMMON ORDER DATED 29.03.2019 IN WP(C)NO.35(K)/2019 AND CONNECTED CASES ON THE FILES OF THE HON'BLE GAUHATI HIGH COURT, KOHIMA BENCH. EXHIBIT P2 AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P2 B AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P2 C AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P2 D AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT P2 E AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P3 AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1564/2011. EXHIBIT P3 A AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.463/2016 & OTHER. EXHIBIT P3 B AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.194/1/10 & OTHER.

AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2425/2006-07. EXHIBIT P3 D AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1585/2014. EXHIBIT P3 E AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.362/2015. EXHIBIT P3 F AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.692/2014. EXHIBIT P3 G AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2979/2015 & OTHER. EXHIBIT P3 H AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2778/2015 & OTHER. EXHIBIT P3 I AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.57/92 & OTHER. EXHIBIT P3 J AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2423/2015 & OTHER. EXHIBIT P3 K AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.586/2016. EXHIBIT P3 L AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.3387/12 & OTHER. EXHIBIT P3 M AOF THE ORDER BEARING NO.AHCPR2712F/281B/AIT/CC/KLM/18-19 DATED 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.944/15 & OTHER. EXHIBIT P4 AOF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/18-18 DATED 03.10.2017 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.3826/2013-14. EXHIBIT P4 A AOF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/18-18 DATED 03.10.2017 PERTAINING TO THE PROPERTIES AT BANGALORE 25807/2006-07. EXHIBIT P4 B AOF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/18-18 DATED 03.10.2017 PERTAINING TO THE PROPERTIES AT BANGALORE 1445/2009-10. EXHIBIT P5 THE ACKNOWLEDGMENT OF DECLARATION UNDER SECTION 183 OF THE FINANCE ACT, 2016 WHICH INCLUDE THE DESCRIPTION OF THE PROPERTIES. EXHIBIT P6 THE DETAILS OF THE PAYMENT EFFECTED ON VARIOUS DATES, BY THE PETITIONER AND OTHER FAMILY MEMBERS. EXHIBIT P7 AOF THE PETITION DATED 22.05.2019 SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT.

APPENDIX OF WP(C) 17594/2019 EXHIBIT P1 AOF THE COMMON ORDER DT. 29.03.2019 IN W.P.(C) NO. 35(K)/2019 AND CONNECTED CASES ON THE FILES OF THE HON'BLE GAUHATI HIGH COURT, KOHIMA BENCH. EXHIBIT P2 AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P2 B AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P2 C AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2 D AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17 EXHIBIT P2 E AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P3 AOF THE ORDER BEARING NO. ACAPR8941B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 587/16 EXHIBIT P3 A AOF THE ORDER BEARING NO. ACAPR8941B/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. N.DL- 24269163089024M. EXHIBIT P3 B AOF THE ORDER BEARING NO. ACAPR8941B/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 182/2014 AND OTHER.

AOF THE ORDER BEARING NO. ACAPR8941B/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 1593/2012 EXHIBIT P3 D AOF THE ORDER BEARING NO. ACAPR8941B/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 2483/2008 AND OTHER. EXHIBIT P3 E AOF THE ORDER BEARING NO. ACAPR8941B/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 302/13 AND OTHER. EXHIBIT P3 F AOF THE ORDER BEARING NO. ACAPR8941B/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 2122/88 AND OTHER. EXHIBIT P3 G AOF THE ORDER BEARING NO. ACAPR8941B/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 1445/2009 AND OTHER. EXHIBIT P4 AOF THE ORDER BEARING NO. DDIT/INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO. 3826/2013-14. EXHIBIT P4 A AOF THE ORDER BEARING NO. DDIT/INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO. 2425/2006-07 AND 25807/2006-07 EXHIBIT P4 B AOF THE ORDER BEARING NO. DDIT/INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO. 6036/2008-09 AND 1445 /2009-10 EXHIBIT P5 THE ACKNOWLEDGMENT OF DECLARATION U/S 183 OF FINANCE ACT, 2016 WHICH INCLUDES THE DESCRIPTION OF THE PROPERTIES. EXHIBIT P6 THE DETAILS OF THE PAYMENT EFFECTED ON VARIOUS DATES, BY THE PETITIONER AND OTHER FAMILY MEMBERES. EXHIBIT P7 AOF THE PETITION DT. 22.05.2019 SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT.

APPENDIX OF WP(C) 17602/2019 EXHIBIT P1 AOF THE COMMON ORDER DATED 29.03.2019 IN WP(C)NO.35/2019 AND CONNECTED CASES ON THE FILES OF THE HON'BLE GAUHATI HIGH COURT, KOHIMA BENCH EXHIBIT P2 AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13 EXHIBIT P2 A AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14 EXHIBIT P2 B AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15 EXHIBIT P2 C AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2 D AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2 E AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR ASSESSMENT YEAR 2017-18 EXHIBIT P3 AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT 17.09.2018 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.685/06 AND OTHER. EXHIBIT P3 A AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.361/15 EXHIBIT P3 B AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1040/16 AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.IN-DL- 26345648582334M. EXHIBIT P3 D AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2918/16 EXHIBIT P3 E AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT 2320/11 AND OTHER. EXHIBIT P3 F AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.93/13. EXHIBIT P3 G AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.949/10. EXHIBIT P3 H AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.853/12 EXHIBIT P3 I AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.889/10. EXHIBIT P3 J AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.693/14 EXHIBIT P3 K AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2069/16 EXHIBIT P3 L AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1635/14 EXHIBIT P3 M AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1060/10 EXHIBIT P3 N AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.193/04 EXHIBIT P3 O AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.585/16 EXHIBIT P3 P AOF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.977/16 AND OTHER EXHIBIT P4 AOF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT.03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.3826/2013-14 EXHIBIT P4 A AOF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT 2425/2006-07 AND 25807/2006-07 EXHIBIT P4 B AOF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.6036/2005-09 AND 1445/2009-10 EXHIBIT P5 THE ACKNOWLEDGMENT OF DECLARATION U/S 183 OF THE FINANCE ACT, 2016 WHICH INCLUDES THE DESCRIPTION OF THE PROPERTIES EXHIBIT P6 THE DETAILS OF THE PAYMENT EFFECTED ON VARIOUS DATED, BY THE PETITIONER AND OTHER FAMILY MEMBERS SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT APPENDIX OF WP(C) 17640/2019 EXHIBIT P1 AOF THE COMMON ORDER DT. 29/3/2019 IN WP(C) NO.35(K)/2019 & CONNECTED CASES ON THE FILES OF THE HON'BLE GAUHATI HIGH COURT, KOHIMA BENCH. EXHIBIT P2 AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P2 B AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P2 C AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P2 D AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT P2 E AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P3 AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 DT. 20/08/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.698/15 & OTHER. EXHIBIT P3 A AOF THE ORDER BEARING NO.AGJPR7612L/2281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.130/14 & OTHER. EXHIBIT P3 B AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.495/09 & ANOTHER.

AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.3167/13. EXHIBIT P3 D AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.132/2015. EXHIBIT P3 E AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.1925/15 & ANOTHER. EXHIBIT P3 F AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.498/14. EXHIBIT P3 G AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.1712/13 & OTHER. EXHIBIT P3 H AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.584/16. EXHIBIT P3 I AOF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19 PETITIONER COVERED BY DOCUMENT NO.312/14. EXHIBIT P4 AOF THE ORDER BEARING PERTAINING TO THE PROPERTIES AT BANGALORE COVERED IN DOCUMENT NO.3826/2013-14. EXHIBIT P4 A AOF THE ORDER BEARING PERTAINING TO THE PROPERTIES AT BANGALORE 25807/2006-07. EXHIBIT P4 B AOF THE ORDER BEARING PERTAINING TO THE PROPERTIES AT BANGALORE 1445/2009-10. EXHIBIT P5 THE ACKNOWLEDGMENT OF DECLARATION U/S 183 OF THE FINANCE ACT, 2016 WHICH INCLUDES THE DESCRIPTION OF THE PROPERTIES. EXHIBIT P6 THE DETAILS OF THE PAYMENT EFFECTED ON VARIOUS DATES, BY THE PETITIONER AND OTHER FAMILY MEMBERS. EXHIBIT P7 AOF THE PETITION DT. 22/05/2019 SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT.

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