VALSALA RAJ vs. ASSISTANT COMMISSIONER OF INCOME TAX

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WP(C)/17594/2019HC KeralaKLHC01043047201928 June 2019Bench: HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE18 pages
AI SummaryRemanded

What did the High Court hold?

The High Court directed the third respondent, the Principal Commissioner of Income Tax (Central), to take an appropriate decision on Ext.P7 (the petitioners' representation) within a period of one month. This decision was to be made after issuing notice to the petitioners and affording them an opportunity of being heard. The Court did not make a determination on the legality of the attachment orders themselves but rather directed the appropriate authority to consider the petitioners' grievance. The writ petitions were disposed of in terms of this direction. No specific amount in dispute was mentioned, and the assessment years were not recorded.

What were the facts?

The petitioners, identified as assessees under the Income Tax Act, filed four writ petitions before the High Court of Kerala. They were aggrieved by provisional attachment orders issued under Section 281B of the Income Tax Act, 1961. The petitioners alleged that these attachments were illegal and were hindering their ability to conduct business. To address this, they had submitted a representation (Ext.P7) to the Principal Commissioner of Income Tax (General) seeking to lift or modify the attachment orders. The petitions were filed by Arun Raj Pillai, Valsala Raj, Varun Raj, and M.K. Rajendran Pillai, with the Assistant Commissioner of Income Tax, Deputy Director of Income Tax (Inv), and the Principal Commissioner of Income Tax (Central) as respondents.

What were the issues?

The primary question before the High Court was whether the provisional attachment orders issued under Section 281B of the Income Tax Act, 1961, were illegal and causing undue hardship to the assessees, thereby warranting intervention. The assessees contended that the attachment orders were illegal and were preventing them from carrying out their business activities. They sought relief by way of lifting or modifying these orders. The revenue's contentions are not explicitly recorded in the judgment, beyond their role as respondents to the writ petitions challenging the attachment orders.

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.

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. Sd/- A.MUHAMED MUSTAQUE jv JUDGE

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 6 APPENDIX OF WP(C) 17597/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF 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 A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P2 B A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P2 C A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P2 D A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT P2 E A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P3 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 7 & OTHER. EXHIBIT P3 C A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF THE ORDER BEARING

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 8 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/18-18 DATED 03.10.2017 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.2425/2006-07 & 25807/2006-07. EXHIBIT P4 B A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/18-18 DATED 03.10.2017 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.6036/2008-09 & 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 A TRUE COPY OF THE PETITION DATED 22.05.2019 SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT.

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 9 APPENDIX OF WP(C) 17594/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF 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 A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P2 B A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P2 C A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2 D A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17 EXHIBIT P2 E A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P3 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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.

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 10 EXHIBIT P3 C A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 11 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 A TRUE COPY OF THE PETITION DT. 22.05.2019 SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT.

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 12 APPENDIX OF WP(C) 17602/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF 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 A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13 EXHIBIT P2 A A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14 EXHIBIT P2 B A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15 EXHIBIT P2 C A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2 D A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2 E A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR ASSESSMENT YEAR 2017-18 EXHIBIT P3 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 13 EXHIBIT P3 C A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/AIT/CC/KLM/18-19

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 14 DT.17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1635/14 EXHIBIT P3 M A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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 A TRUE COPY OF 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

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 15 SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 16 APPENDIX OF WP(C) 17640/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF 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 A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P2 B A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P2 C A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P2 D A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT P2 E A TRUE COPY OF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P3 A TRUE COPY OF 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 A TRUE COPY OF THE ORDER BEARING NO.AGJPR7612L/2281B/ACIT/CC/KLM/18-19 DT.20/08/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.130/14 & OTHER. EXHIBIT P3 B A TRUE COPY OF THE ORDER BEARING NO.AGJPR7612L/281B/ACIT/CC/KLM/18-19

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 17 DT.20/08/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.495/09 & ANOTHER. EXHIBIT P3 C A TRUE COPY OF 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.3167/13. EXHIBIT P3 D A TRUE COPY OF 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.132/2015. EXHIBIT P3 E A TRUE COPY OF 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.1925/15 & ANOTHER. EXHIBIT P3 F A TRUE COPY OF 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.498/14. EXHIBIT P3 G A TRUE COPY OF 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.1712/13 & OTHER. EXHIBIT P3 H A TRUE COPY OF 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.584/16. EXHIBIT P3 I A TRUE COPY OF 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.312/14. EXHIBIT P4 A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED IN DOCUMENT NO.3826/2013-14. EXHIBIT P4 A A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE

WP(C) 17597/2019 ,WP(C).17594/2019 ,WP(C).17602/2019 ,WP(C).17640/2019 18 COVERED BY DOCUMENT NO.2425/2006-07 & 25807/2006-07. EXHIBIT P4 B A TRUE COPY OF 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 & 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 A TRUE COPY OF THE PETITION DT. 22/05/2019 SUBMITTED BY THE PETITIONER BEFORE THE 3RD RESPONDENT.

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