VALSALA RAJ vs. ASSISTANT COMMISSIONER OF INCOME TAX

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WP(C)/35913/2019HC KeralaKLHC01093379201906 January 2020Author: HONOURABLE MR. JUSTICE ALEXANDER THOMAS19 pages
AI SummaryDismissed

What did the High Court hold?

The High Court observed that the matters raised in the writ petitions had practically become infructuous because assessment orders had been duly passed by the competent assessing officer. The court noted that the petitioners' remedy, if they had any legally justiceable grievance, was to file a statutory appeal against these assessment orders. The learned counsel for the petitioners indicated that they intended to challenge the assessment orders through the appropriate legal channels. Consequently, the High Court, with these observations, directed that the writ petitions would stand dismissed as infructuous, while according liberty to the petitioners to work out their remedies strictly in the manner known to law.

What were the facts?

These four writ petitions (WP(C) Nos. 35913, 35914, 35915, and 35916 of 2019) were filed before the High Court of Kerala by Valsala Raj, M.K. Rajendran Pillai, Arun Raj Pillai, and Varun Raj, respectively. The petitioners are challenging actions or orders passed by the Assistant Commissioner of Income Tax, Central Circle, Kollam, the Deputy Director of Income Tax (Inv), Kollam, and the Principal Commissioner of Income Tax (Central), Kochi. The specific assessment year(s) and the nature of the orders or actions under challenge are not detailed in the provided text. The procedural history indicates that these petitions were heard on January 6, 2020.

What were the issues?

The primary issue before the High Court was whether the writ petitions were maintainable or had become infructuous. The revenue, through its Standing Counsel, submitted that the assessment orders had been passed, rendering the writ petitions practically infructuous and that the petitioners' remedy lay in filing a statutory appeal. The petitioners' counsel stated that they had been advised to challenge the impugned assessment orders in the manner known to law. The court needed to decide whether to dismiss the petitions as infructuous based on the revenue's submission and the availability of an alternative statutory remedy.

AI-generated summary — verify with the full judgment below

Heard together (4 matters)

WP(C).No.35913 OF 2019
WP(C).35914/2019
WP(C).35915/2019
WP(C).35916/2019

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 ALEXANDER THOMAS MONDAY, THE 06TH DAY OF JANUARY 2020 / 16TH POUSHA, 1941 WP(C).No.35913 OF 2019(L) PETITIONER/S: 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 RESPONDENT/S: 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 OTHER PRESENT: SRI.JOSE JOSEPH, SC FOR INCOME TAX THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 06.01.2020, ALONG WITH WP(C).35914/2019(L), WP(C).35915/2019(L), WP(C).35916/2019(L), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE ALEXANDER THOMAS MONDAY, THE 06TH DAY OF JANUARY 2020 / 16TH POUSHA, 1941 WP(C).No.35914 OF 2019(L) PETITIONER/S: 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 RESPONDENT/S: 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 OTHER PRESENT: SRI.JOSE JOESPH, SC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 06.01.2020, ALONG WITH WP(C).35913/2019(L), WP(C).35915/2019(L), WP(C).35916/2019(L), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE ALEXANDER THOMAS MONDAY, THE 06TH DAY OF JANUARY 2020 / 16TH POUSHA, 1941 WP(C).No.35915 OF 2019(L) PETITIONER/S: 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 RESPONDENT/S: 1 ASSISTANT COMMISSIONER OF INCOE 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 OTHER PRESENT: SRI.JOSE JOSEPH, SC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 06.01.2020, ALONG WITH WP(C).35913/2019(L), WP(C).35914/2019(L), WP(C).35916/2019(L), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE ALEXANDER THOMAS MONDAY, THE 06TH DAY OF JANUARY 2020 / 16TH POUSHA, 1941 WP(C).No.35916 OF 2019(L) PETITIONER/S: VARUN RAJ AGED 32 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 RESPONDENT/S: 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 OTHER PRESENT: SRI.JOSE JOSEPH, SC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 06.01.2020, ALONG WITH WP(C).35913/2019(L), WP(C).35914/2019(L), WP(C).35915/2019(L), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ALEXANDER THOMAS, J. ================== W.P.(C).Nos.35913, 35914, 35915 & 35916 of 2019 ================== Dated this the 6th day of January, 2020

J U D G M E N T Sri.Jose Joseph, learned Standing Counsel for the Income Tax Department of the Government of India appearing for the respondents submits on the basis of the instructions that the matters raised in these Writ Petitions have practically become infructuous inasmuch as, assessment orders have been duly passed by the competent assessing officer and that the remedy of the petitioners is to file statutory appeal thereto, if they have any legally justiceable grievance. The learned counsel for the petitioners would submit that the petitioners have been advised to challenge the impugned assessment orders in the manner known to law. Liberty is accorded to the petitioners to work out their remedies strictly in the manner known to law. With these observations and directions, the above Writ Petitions (Civil) will stand dismissed as infructuous. sdk+ ALEXANDER THOMAS, JUDGE - : 6 :- APPENDIX OF WP(C) 35913/2019 PETITIONER'S/S EXHIBITS: 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/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 587/16 EXHIBIT P3A AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. N.-DL- 24269163089024M.

- : 7 :- EXHIBIT P3B AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 182/2014 AND OTHER. EXHIBIT P3C AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 1593/2012 EXHIBIT P3D AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 2483/2008 AND OTHER. EXHIBIT P3E AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT 302/13 AND OTHER. EXHIBIT P3F AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 2111/88 AND OTHER. EXHIBIT P3G AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/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. EXHIBIT P4A 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.

- : 8 :- EXHIBIT P4B 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. 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. EXHIBIT P8 AOF THE JUDGMENT DT. 28.06.2019 IN HON'BLE COURT. EXHIBIT P9 AOF THE ORDER BEARING F.NO. VALSALA RAJ/ 281B/PCIT(C) CHN/2019-20 DT. 26.07.2019 ISSUED BY THE 3RD RESPONDENT. EXHIBIT P10 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2008-09 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P11 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2009-10 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P12 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2010-2011 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P13 AOF THE NOTICE DT. 19.12.2019 FOR FOR THE ASSESSEMENT YEAR 2011-12 ISSUED BY THE 1ST RESPONDENT.

APPENDIX OF WP(C) 35914/2019 PETITIONER'S/S EXHIBITS: 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 P2A AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14 EXHIBIT P2B AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15 EXHIBIT P2C AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2D AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17 EXHIBIT P2E 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. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.698/15 AND OTHER. EXHIBIT P3A 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. 130/14 AND OTHER. EXHIBIT P3B 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. 495/08 AND ANOTHER. EXHIBIT P3C 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. 3167/13

EXHIBIT P3D 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. 132/2015 EXHIBIT P3E 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. 1925/15 AND OTHER. EXHIBIT P3F 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. 498/14 EXHIBIT P3G 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. 1712/13 AND OTHER. EXHIBIT P3H 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. 584/16 EXHIBIT P3I 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. 312/14 EXHIBIT P4 AOF THE ORDER BEARING NO. DDIT /INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE EXHIBIT P4A AOF THE ORDER BEARING NO. DDIT /INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE EXHIBIT P4B AOF THE ORDER BEARING NO. DDIT /INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE 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. EXHIBIT P8 AOF THE JUDGMENT DT. 28.06.2019 IN HON'BLE COURT. EXHIBIT P9 AOF THE ORDER BEARING F.NO. VALSALA RAJ/ 281B/PCIT(C) CHN/2019-20 DT. 26.07.2019 ISSUED BY THE 3RD RESPONDENT. EXHIBIT P10 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2008-09 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P11 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2009-10 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P12 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2010-2011 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P13 AOF THE NOTICE DT. 19.12.2019 FOR FOR THE ASSESSEMENT YEAR 2011-12 ISSUED BY THE 1ST RESPONDENT.

APPENDIX OF WP(C) 35915/2019 PETITIONER'S/S EXHIBITS: 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 P2A AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14 EXHIBIT P2B AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15 EXHIBIT P2C AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2D AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17 EXHIBIT P2E AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18 EXHIBIT P3 AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1564/2011 EXHIBIT P3A AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.463/2016 AND OTHER. EXHIBIT P3B AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.194/1/10 AND OTHER.

EXHIBIT P3C AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2425/2006-07 EXHIBIT P3D AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1585/2014 EXHIBIT P3E AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.362/15 EXHIBIT P3F AOF THE ORDER BEARING NO. AHCPR2712F/281B/AIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.692/14 EXHIBIT P3G AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2979/2015 AND OTHER. EXHIBIT P3H AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2778/15 AND OTHER. EXHIBIT P3I AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.57/92 AND OTHER. EXHIBIT P3J AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE AND OTHER. EXHIBIT P3K AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE AND OTHER.

EXHIBIT P3K AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.586/16 EXHIBIT P3I AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.3387/12 AND OTHER. EXHIBIT P3M AOF THE ORDER BEARING NO. AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.944/15 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 P4A 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 P4B 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 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. EXHIBIT P8 AOF THE JUDGMENT DT. 28.06.2019 IN WP(C) NO. 17597/2019 ON THE FILES OF THIS HON'BLE COURT. EXHIBIT P9 AOF THE ORDER BEARING F.NO. VALSALA RAJ/ 281B/PCIT(C) CHN/2019-20 DT. 26.07.2019 ISSUED BY THE 3RD RESPONDENT.

EXHIBIT P10 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2008-09 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P11 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2009-10 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P12 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2010-2011 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P13 AOF THE NOTICE DT. 19.12.2019 FOR FOR THE ASSESSEMENT YEAR 2011-12 ISSUED BY THE 1ST RESPONDENT.

APPENDIX OF WP(C) 35916/2019 PETITIONER'S/S EXHIBITS: 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 P2A AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2013-14 EXHIBIT P2B AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2014-15 EXHIBIT P2C AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 EXHIBIT P2D AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2016-17 EXHIBIT P2E AOF THE IT RETURN ACKNOWLEDGMENT ISSUED TO THE PETITIONER FOR THE ASSESSMENT YEAR 2017-18 EXHIBIT P3 AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 685/06 AND OTHER. EXHIBIT P3A 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 P3B AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 1040/16

EXHIBIT P3C AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. IN-DL- 26345648582334M. EXHIBIT P3D 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 P3E AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 2320/11 AND OTHER. EXHIBIT P3F 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 P3G AOF THE ORDER BEARING NO. ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.853/12 EXHIBIT P3(H) AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 853/12 EXHIBIT P3I AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 889/10 EXHIBIT P3J AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.693/14 EXHIBIT P3K AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE 2069/16 EXHIBIT P3L AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1635/14

EXHIBIT P3M AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1060/10 EXHIBIT P3N AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 193/04 EXHIBIT P3O AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/CC/KLM/18-19 DT. 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO. 585/16 EXHIBIT P3P AOF THE ORDER BEARING NO. ACAPR8839E/281B/ACIT/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 EXHIBIT P4A AOF THE ORDER BEARING NO. DDIT /INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE EXHIBIT P4B AOF THE ORDER BEARING NO. DDIT /INV/KLM/MKR/17-18 DT. 03.10.17 PERTAINING TO THE PROPERTIES AT BANGALORE 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. EXHIBIT P8 AOF THE JUDGMENT DT. 28.06.2019 IN WP(C) NO. 17602/2019 ON THE FILES OF THIS HON'BLE COURT. EXHIBIT P9 AOF THE ORDER BEARING F.NO. VALSALA RAJ/ 281B/PCIT(C) CHN/2019-20 DT. 26.07.2019 ISSUED BY THE 3RD RESPONDENT.

EXHIBIT P10 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2008-09 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P11 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2009-10 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P12 AOF THE NOTICE DT. 19.12.2019 FOR THE ASSESSMENT YEAR 2010-2011 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P13 AOF THE NOTICE DT. 19.12.2019 FOR FOR THE ASSESSEMENT YEAR 2011-12 ISSUED BY THE 1ST RESPONDENT.

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