P.K.PRASAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - IV, ALLEPPEY

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WP(C)/7509/2013HC KeralaKLHC01050706201318 March 2013Author: HONOURABLE MR.JUSTICE ANTONY DOMINIC28 pages
AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the criminal miscellaneous cases. The court rejected the petitioners' contention that they cannot be prosecuted because they relied on agents for filing returns, stating that the responsibility for filing proper returns lies with the assessee, not the agent. The petitioners were the beneficiaries of the false claims, and the agents were paid a small percentage of the refund. The court found that the argument regarding the requirement of prior administrative approval for prosecution under Section 276C was irrelevant because the crime was investigated by the CBI, and the charge sheet filed by the CBI only incorporated offences punishable under Section 420 IPC read with Section 120B IPC. The court also held that the fact that the Income Tax Department treated the refund claim as a mistake, issued notices, and the petitioners repaid the amount with penalty, does not absolve them from prosecution, as submitting false returns and accepting ineligible refunds are crucial factors. The court emphasized that proceedings for realization of escaped assessment, imposition of penalty, and prosecution for filing false returns are distinct, and realization of escaped assessment or imposition of penalty does not absolve a person from prosecution. Therefore, the prayer for quashing the proceedings was rejected. The petitioners were granted liberty to move the trial court for discharge.

What were the facts?

The petitioners are accused in a crime registered by the CBI based on a letter from the Principal Chief Commissioner of Income Tax, Kochi. The complaint alleged that numerous salaried assessees in Ward-3, Kannur, received substantial income tax refunds by claiming bogus deductions under various sections of the Income Tax Act. The petitioners, who are Lieutenant Commanders in the Indian Navy, are among those accused. They filed criminal miscellaneous cases seeking to quash the FIR and subsequent proceedings. The alleged offences include conspiracy (Section 120B IPC), cheating (Section 420 IPC), and offences under the Income Tax Act (Section 276C). The petitioners claim they relied on agents for filing returns and that the tax department initially treated the refund claims as mistakes, which were rectified, and the ineligible refunds were repaid.

What were the issues?

1. Whether the petitioners can be prosecuted for offences under Section 120B read with Section 420 of the Indian Penal Code and Section 276C of the Income Tax Act, given that they relied on agents for filing their returns and subsequently rectified the claims and repaid the ineligible refunds. Assessee's Contention: The petitioners argued that the allegations in the communication from the Income Tax Department were against agents, not the assessees. They contended that they were dependent on agents for filing returns and that the prosecution lacked evidence of the bogus claims being made at their instance. They further submitted that the Income Tax Department treated the refund claims as mistakes, issued notices under Sections 148, 154, and 155, and the petitioners rectified these and repaid the amounts, demonstrating no intention to cheat. Additionally, they argued that prosecution under Section 276C requires prior administrative approval from a collegium of two CCIT/DGIT rank officers, as per a specific circular. Revenue's Contention (Income Tax Department): The Income Tax Department argued that filing returns is the individual taxpayer's responsibility, even if assisted by an agent, and electronic verification requires the taxpayer's own action. They stated that the escaped assessment was discovered during subsequent verification, and the petitioners' replies were unsatisfactory, leading to penalty imposition. They asserted that refunding excess amounts and paying penalties do not absolve criminal liability for cheating by filing false returns with intent to deceive. They also contended that the circular regarding Section 276C approval is irrelevant as the prosecution is not under that section, and the CBI is investigating based on departmental information. Revenue's Contention (CBI): The CBI stated that the crime was registered based on the Income Tax Department's complaint, and during investigation, sufficient incriminating evidence for cheating was obtained, leading to a charge sheet for Section 420 IPC. They argued that the intention to commit the offence persists even if the loss is compensated, and the petitioners failed to produce documents substantiating their refund claims. They also noted that the petitioners were not able to prove their innocence.

Which sections of the Income-tax Act were involved?

Section 120B,Section 276C,Section 148,Section 154,Section 155,Section 80DDB,Section 80E,Section 80EE,Section 80GG,Section 80GGC

AI-generated summary — verify with the full judgment below

CRL.MC NO. 1003 OF 2023 CRIME NO.RC 0342023E0002/2023 OF CBCID, THIRUVANANTHAPURAM, Thiruvananthapuram

RAJAN KOYOTH VEETTIL SIDHARTH, S/O. K.V. RAJAN,LIEUTENANT COMMANDER, NAVAL PAY

NISHANT SINGH POSWAL, S/O. LATE KANWAR PAL VERMA,LIEUTENANT

SUMIT SINGH, AGED 31 YEARS S/O. NAIB SINGH,LIEUTENANT COMMANDER,NAVAL PAY

ROSHAN KUMAR SINGH, S/O. BINOD KUMAR SINGH,LIEUTENANT COMMANDER,NAVAL PAY OFFICE, MUMBAI,INDIAN NAVAL ACADAMY, EZHIMALA, KANNUR, PIN - 670310

. RAJKUMAR SHARMA, AGED 31 YEARS S/O. PARSHOTAM DAS,LIEUTENANT COMMANDER,NAVAL PAY

PAWAN SINGH RATHORE, AGED 30 YEARS S/O. DARWAN SINGH RATHOUR,LIEUTENANT

MADATHIL VALAPPIL RAHUL RAMAN, SON OF M.V. KUNHI RAMAN,LIEUTENANT K.P.SANTHI M.C.BINDUMOL TARA PREM

STATE OF KERALA, REPRESENTED BY THE PUBLIC PROSECUTOR, HIGH COURT OF KERALA, ERNAKULAM., PIN - 682031

JOINT COMMISSIONER OF INCOME TAX (HQ),(TECH OFFICE OF PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,KERALA, 2ND FLOOR, C.R. BUILDING, I.S.PRESS ROAD, KOCHI, PIN - 682018

CENTRAL BUREU OF INVESTIGATION, SPECIAL CRIME BRANCH, THIRUVANANTHAPURAM, PIN - 695024 BY ADV SREELAL N.WARRIER, SPL.PUBLIC PROSECUTOR, CENTRAL BUREAU OF INVESTIGATION (CBI) OTHER PRESENT: SRI. M.C. ASHI, PP. SRI. SREELAL. N. WARRIER SPL. PP FOR CBI. SRI. JOSE JOSEPH SC, FOR INCOME TAX DEPARTMENT. THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON 13.03.2025, ALONG WITH Crl.MC.67/2025, 2003/2023 AND CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:

CRL.MC NO. 67 OF 2025 CRIME NO.RC 0342023E0002/2023 OF CENTRAL BUREAU OF INVESTIGATION, THIRUVANANTHAPURAM, Thiruvananthapuram AGAINST THE ORDER/JUDGMENT DATED IN CC NO.123 OF 2024 OF CHIEF JUDICIAL MAGISTRATE, ERNAKULAM

CHANDRAN GANAPATHIYADAN, AGED 59 YEARS S/O. KUNJIRAMAN, KALATHIL HOUSE, KARA PERAVOOR P.O., KEEZHALLUR,THALASSERY, KANNUR, PIN - 670702

VINOD KUMAR K., AGED 48 YEARS S/O. BAMBU B, KIZHAKKEKKARA HOUSE, BERIAM, KARADKA, KASARAGOD, PIN - 671542

SHABU SREEDHARAN JAYACHANDRAN NAIR G. ARCHANA U. REENU S. BABU RATHEESH.V.R. LEKSHMI J. BIJU JACOB B.O. KARISHMA JOHN

UNION OF INDIA, REPRESENTED BY THE ASST. SOLICITOR GENERAL, OFFICE OF THE ASST. SOLICITOR GENERAL, HIGH COURT OF KERALA, ERNAKULAM, PIN - 682031

CENTRAL BUREAU OF INVESTIGATION, REPRESENTED BY ITS DEPUTY SUPERINTENDENT OF POLICE, CBI, SCB, TC 1757/5, "CBI OCR COMPLEX", MUTTATHARA, VALLAKADAVU P.O., THIRUVANANTHAPURAM, PIN - 695008 THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON 13.03.2025, ALONG WITH Crl.MC.1003/2023 AND CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:

CRL.MC NO. 2003 OF 2023 CRIME NO.RC 0342023E0002/2023 OF CENTRAL BUREAU OF INVESTIGATION, THIRUVANANTHAPURAM, Thiruvananthapuram PETITIONER: AKSHAY KISHOR SALI S/O K.V.RAJAN, LIEUTENANT COMMANDER, NAVAL PAY OFFICE, MUMBAI, INDIAN NAVAL ACADAMY, EZHIMALA,KANNUR, PIN - 670310 K.P.SANTHI TARA PREM

STATE OF KERALA REPRESENTED BY THE PUBLIC PROCECUTOR, HIGH COURT OF KERALA, ERNAKULAM, PIN - 682031

JOINT COMMISSIONER OF INCOME TAX(HQ) (TECH), OFFICE OF PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA, 2ND FLOOR, C.R.BUILDING, I.S.PRESS ROAD, KOCHI, PIN - 682018

CENTRAL BUREAU OF INVESTIGATION SPECIAL CRIME BRANCH, THIRUVANANTHAPURAM, REPRESENTED BY THE SUPRENTENDENT OF POLICE, PIN - 695024 BY ADV Sreelal Warriar THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON 13.03.2025, ALONG WITH Crl.MC.1003/2023 AND CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:

CRL.MC NO. 10877 OF 2024 CRIME NO.36/2007 OF CRIME BRANCH, MALAPPURAM, Malappuram AGAINST THE ORDER/JUDGMENT DATED IN CC NO.194 OF 2024 OF CHIEF JUDICIAL MAGISTRATE ,MANJERI

GOLDEN FOREX PVT.LTD @ GOLDEN FOREX CENTER LTD@ GOLDENFOREX AND FINANCE SERVICES, ZEENATH PLAZA, EZHUR ROAD, THIRUR, MALAPPURAM (REPRESENTED BY NASIM P.K, MANAGING DIRECTOR ), PIN - 676101

NASIM P.K, AGED 48 YEARS S/O. HAMZA HAJI,PANNIKANDATHIL HOUSE, ANNARA, THIRUR, MALAPPURAM, PIN - 676101

ZEENATH, AGED 68 YEARS W/O. HAMZA HAJI, PANNIKANDATHIL HOUSE, ANNARA, THIRUR, MALAPPURAM, PIN - 676101

R.ANIL B.RAMAN PILLAI (SR.) SUJESH MENON V.B. THOMAS SABU VADAKEKUT MAHESH BHANU S. RESSIL LONAN JOEL GEORGE KAMPIYIL ANANTH KRISHNA K.S. RESPONDENT:

STATE OF KERALA, REPRESENTED BY PUBLIC PROSECUTOR,HIGH COURT OF KERALA, PIN - 682031

MOIDEEN ( SOUGHT TO BE IMPLEADED ) S/O. BEERAN, EZHOOR, THIROOR, ( SOUGHT TO BE IMPLEADED ) THIS CRIMINAL MISC. CASE HAVINGHAVING BEEN FINALLY HEARD ON 13.03.2025, ALONG WITH Crl.MC.1003/2023 AND CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:

V.G.ARUN, J = = = = = = = = = = = = = = = = = Crl.M.C.Nos.1003 & 2003 of 2023, 10887 of 2024 & 67 of 2025 = = = = = = = = = = = = = = = = = = Dated this the 17th day of March, 2025 ORDER Petitioners are some of the accused in Crime No.RC0342023E0002

registered

the

CBI/SCB/ Thiruvananthapuram for offences punishable under Sections 120B read with 420 of IPC and Section 276C of the Income Tax Act. The crime was registered on the basis of a letter received from the Principal Chief Commissioner of Income Tax, Kochi alleging that many salaried assessees in Ward-3 Kannur had received huge refund of income tax, by claiming bogus deductions under Sections 80DDB, 80E, 80EE, 80GG, 80GGC etc.

2.

These Crl.M.Cs are filed seeking to get the FIR and further proceedings against the petitioners quashed on various grounds. 3. Heard, Advs.K.P.Santhi and Shabu Sreedharan for the petitioners, Adv.Jose Joseph for the Income Tax Department and Adv.Sreelal N Warrier for the Central Bureau of Investigation. 4. Learned counsel for the petitioners contended that in the communication issued by the Principal Chief Commissioner of Income Tax, which led to registration of the crimes, the allegations were raised against agents who had indulged in malpractices while submitting returns on behalf of the assessees. Assessees like the petitioners are completely dependent on the agents for filing income tax returns. The prosecution does not have a case that the bogus claims were raised at the instance of the petitioners. According to the counsel, the Income Tax Department had treated the claim for refund as a mistake and notices were issued under Sections

148, 154, 155 etc. of the Income Tax Act. On receipt of the notices, mistakes were rectified and the ineligible refund, remitted back. This shows that the petitioners had no intention to cheat. Moreover, the petitioners cannot be prosecuted for the offence under Section 276C of the Income Tax Act without previous administrative approval of the Collegium of two CCIT/DGIT rank officers, as evident from Annexure XIX circular produced in Crl.M.C.No.1003 of 2023. 5. Learned Standing Counsel for the Income Tax Department made the following submissions; From 2014-2015 onwards, many of the assessees in Ward 3, Kannur had raised bogus claims for refund by under- reporting their salary and making ineligible deductions. Filing of return of income is the responsibility of individual tax payers even if it is prepared with the help of an agent. Electronic verification of the return of income has to be done by the tax payer himself, either through Aadhar OTP or net banking. The

returns are processed by the Central Processing Centre without any manual intervention. Therefore, the escaped assessment was noticed only during subsequent verification. Immediately, notices were sent to the petitioners and other assessees. The reply received from the petitioners being unsatisfactory, penalty was imposed on them. Refund of the excess amount claimed and payment of penalty will not absolve the petitioners from criminal liability, as they had committed cheating by filing false returns with intention to deceive the department. The contention based on Annexure XIX circular cannot also be countenanced, since the Department has not initiated prosecution under Section 276C. Instead, the CBI is conducting investigation based on the information given from the Department. 6. Learned Standing Counsel for the CBI submitted that, crime was registered against 31 persons, including the petitioners, based on a complaint received from the Income Tax

Department. During investigation, sufficient incriminating evidence to prove the commission of the offence of cheating was obtained. Hence, charge sheet was filed against the petitioners and others for the offence of cheating under Section 420 of the Indian Penal Code. The intention to commit the offence will continue to exist even if the loss caused to the Government is compensated by repaying the ineligible refund received. Investigation had revealed that some of the accused had claimed exemption towards housing loan interest, whilst others had claimed unmerited deductions under Sections 80DDB, 80E, 80EE, 80GG,80GGC etc. of the Income Tax Act. On receipt of complaint from the Income Tax Department, the documents were verified meticulously and information was gathered from officers at various levels and opportunity was given to the petitioners to prove their innocence. The petitioners were not able to produce any document to substantiate their claim for refund.

7.

The contention that false claims were raised by the agents and not the petitioners is liable to be rejected outright as the responsibility of filing proper returns is that of the assessee and not the agent. The petitioners themselves are the beneficiaries of such false claims and the agents are paid only a small percentage of the refunded amount. The argument that prosecution under Section 276C can be initiated only with the permission of the Collegium has no relevance, since the crime against the petitioners was investigated by the CBI. Pertinently, in the charge sheet filed by the CBI, only the offence punishable under Section 420 of IPC read with 120-B IPC, is incorporated. The submission that the Income Tax Department had treated the claim for refund as a mistake and issued notices to the petitioners, and the petitioners repaid the amount with penalty, is of no avail, as submission of false returns and acceptance of ineligible refunds are the crucial factors. Going by the scheme of the Income Tax Act, proceedings for

realisation of escaped assessment, imposition of penalty and prosecution for filing false returns are entirely different aspects and realisation of escaped assessment or imposition of penalty will not absolve a person from prosecution. For the reasons aforementioned, the prayer for quashing the proceedings is liable to be rejected. Needless to say, it will still be open for the petitioners to move the trial court for discharge. The Crl.M.Cs are hence dismissed leaving it for the trial court to pass appropriate orders if applications for discharge are filed by the petitioners. sd/-

V.G.ARUN, JUDGE

APPENDIX OF CRL.MC 67/2025 Annexure-1 THE TRUE COPY OF THE LETTER FORWARDED BY THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOZHIKODE TO THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KOCHI DATED 4.2.2020 Annexure-2 THE TRUE COPY OF THE LETTER FORWARDED BY THE JOINT COMMISSIONER OF INCOME TAX, OFFICE OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KOCHI TO THE RESPONDENT CBI DATED 11.3.2020 Annexure-3 THE TRUE COPY OF THE FIR IN RC 0342023E0002 OF CBI/SCB/THIRUVANANTHAPURAM DATED 17.1.2023 Annexure-4 ASSESSMENT YEAR 2017 – 2018 DATED 1.4.2017 Annexure-5 THE TRUE COPY OF THE TAX PAYER COUNTERFOILS DATED 27.11.2021 Annexure-6 ASSESSMENT YEAR 2018 – 2019 DATED 1.4.2018

Annexure-7 ASSESSMENT YEAR 2019 – 2020 Annexure-8 THE TRUE COPIES OF THE COMPUTERIZED RECEIPTS OF SBI, KANNUR DATED 3.2.2023 ISSUED TO THE 1ST PETITIONER Annexure-9 BY THE 2ND PETITIONER FOR THE ASSESSMENT YEAR 2018 – 2019 DATED 1.4.2018 Annexure-10 BY THE 2ND PETITIONER FOR THE ASSESSMENT YEAR 2019 – 2020 DATED 1.4.2019 Annexure-11 THE TRUE COPIES OF THE COMPUTERIZED RECEIPTS OF SBI, KANNUR DATED 3.2.2023 ISSUED TO THE 2ND PETITIONER Annexure-12 THE TRUE COPY OF THE INTERIM ORDER OF THIS HON’BLE COURT IN CRL MC NO. 1661/2023 DATED 26.9.2023 Annexure-13 THE TRUE COPY OF THE ORDER OF THIS HON’BLE COURT IN CRL MC NO. 1661/2023 DATED 9.10.2024. Annexure-14 THE CERTIFIED COPY OF THE CHARGE SHEET FILED BY THE RESPONDENT CBI IN RC 0342023E002 OF CBI/SCB/THIRUVANANTHAPURAM BEFORE THE CJM COURT, ERNAKULAM DATED 29.6.2024

APPENDIX OF CRL.MC 2003/2023 Annexure I TRUE COPY OF THE FIR NO. RC 0342023E0002 DATED 17-1-2023 Annexure II TRUE COPY OF THE CIRCULAR DATED 9-9- Annexure III TRUE COPY OF THE LETTER DATED 4-2-2020 OF THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOZHIKODE Annexure IV TRUE COPY OF THE COMPLAINANT DATED 11- 3-2020 OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX

APPENDIX OF CRL.MC 10877/2024 Annexure 1 THE CERTIFIED COPY OF THE FIR NO. 348/2006 OF THIRUR POLICE STATION Annexure 2 THE CERTIFIED COPY OF THE FINAL REPORT IN CRIME NO. 348 OF 2006 OF THIRUR POLICE STATION, WHICH IS RE-REGISTERED AS CRIME NO.36/CB/MPM/2007 OF CRIME BRANCH , MALAPPURAM AND PENDING AS C.C. NO. 194 OF 2024 BEFORE THE HON’BLE COURT OF THE CHIEF JUDICIAL MAGISTRATE, MANJERI Annexure 3 TRUE COPY OF THE MEDICAL CERTIFICATE DATED 18-9-2024 ISSUED FROM LOURDE HOSPITAL Annexure 4 A TRUE COPY OF THE DISCHARGE SUMMARY DATED 20-2-2023 AFTER ADMITTED ON 16-2- 2024

APPENDIX OF CRL.MC 1003/2023 Annexure I TRUE COPY OF FIR NO. RC 0342023E0002 DATED 17-1-2023 OF THE CHIEF JUDICIAL MAGISTRATE COURT, ERNAKULAM Annexure II ASSESSMENT YEAR 2016-2017 DATED 10-5- Annexure II(a) ASSESSMENT YEAR 2014-2015 DATED 30-3- Annexure II(b) ASSESSMENT YEAR 2014-2015 DATED 12-3- Annexure III 22-4-2021 FOR THE ASSESSMENT YEAR 2017- Annexure III(a) 2-2022 FOR THE ASSESSMENT YEAR 2014- 2015 Annexure III(b) 4-2022 FOR THE ASSESSMENT YEAR 2014- 2015

Annexure IV Annexure IV(a) ASSESSMENT YEAR 2017-2018 DATED 26-3- Annexure IV(b) ASSESSMENT YEAR 2017-2018 DATED 21-9- Annexure V TRUE COPY OF THE COUNTERFOIL DATED 15- Annexure V(a) TRUE COPY OF THE COUNTERFOIL DATED 20- Annexure VI TRUE COPY OF THE ORDER DATED 19-12-2022 OF THE 2ND RESPONDENT Annexure VII ASSESSMENT YEAR 2015-2016 DATED 30-3- Annexure VII(a)

Annexure VII(b) ). TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2017-2018 DATED 30- 3-2021 Annexure VII(c) 156 OF THE INCOME TAX ACT DATED 24-3- Annexure VIII Annexure VIII(a) 4-2022 FOR THE ASSESSMENT YEAR 2016- Annexure VIII(b) 4-2022 FOR THE ASSESSMENT YEAR 2015- Annexure VIII(c) Annexure VIII(d) 25-10-2022 FOR THE ASSESSMENT YEAR 2016-2017 Annexure VIII(e) 10-2022 FOR THE ASSESSMENT YEAR 2015-

Annexure VIII(f) 11-2022 FOR THE ASSESSMENT YEAR 2016- Annexure VIII(g) 11-2022 FOR THE ASSESSMENT YEAR 2015- Annexure VIII(h) 11-2022 FOR THE ASSESSMENT YEAR 2017- Annexure VIII(i) 12-2022 FOR THE ASSESSMENT YEAR 2015- Annexure VIII(j) 12-2022 FOR THE ASSESSMENT YEAR 2017- Annexure VIII(k) 12-2022 FOR THE ASSESSMENT YEAR 2016- Annexure IX . TRUE COPY OF THE NOTICE UNDER SECTION ASSESSMENT YEAR 2015-2016 DATED 30-3- Annexure IX(a)

Annexure IX(b) Annexure X 22-4-2022 FOR THE ASSESSMENT YEAR 2016- Annexure X(a) TRUE COPY OF THE COUNTERFOIL DATED 22- 4-2022 FOR THE ASSESSMENT YEAR 2015- Annexure X(b) Annexure XI ASSESSMENT YEAR 2016-2017 DATED 14-2- Annexure XI(a) ASSESSMENT YEAR 2016-2017 DATED 25-8- Annexure XI(b) ASSESSMENT YEAR 2017-2018 DATED 14-2-

Annexure XI(c) ASSESSMENT YEAR 2017-2018 DATED 25-8- Annexure XII 6-2022 FOR THE ASSESSMENT YEAR 2017- Annexure XII(a) TRUE COPY OF THE COUNTERFOIL DATED 15- 6-2022 FOR THE ASSESSMENT YEAR 2016- Annexure XII(b) 10-2022 FOR THE ASSESSMENT YEAR 2016- Annexure XII(c) Annexure XIII Annexure XIII(a) Annexure XIV ASSESSMENT YEAR 2017-2018 DATED 22-3-

Annexure XV TRUE COPY OF THE COUNTERFOIL DATED 4-4- 2022 FOR THE ASSESSMENT YEAR 2016-2017 Annexure XV(a) TRUE COPY OF THE COUNTERFOIL DATED 4-4- 2022 FOR THE ASSESSMENT YEAR 2017-2018 Annexure XVI ASSESSMENT YEAR 2017-2018 DATED 10-5- Annexure XVI(a) ASSESSMENT YEAR 2017-2018 DATED 26-02- Annexure XVI(b) ASSESSMENT YEAR 2017-2018 DATED 27-1- Annexure XVI(c) ASSESSMENT YEAR 2016-2017 DATED 21-9- Annexure XVI(d) 133(6) OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2018-2019 DATED 30-10- Annexure XVI(e) 133(6) OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2019-2020 DATED 30-10-

Annexure XVII TRUE COPY OF THE COUNTERFOIL DATED 28- 02-2021 FOR THE ASSESSMENT YEAR 2017- Annexure XVII(a) TRUE COPY OF THE COUNTERFOIL DATED 13- 08-2021 FOR THE ASSESSMENT YEAR 2016- Annexure XVIII TRUE COPY OF THE ORDER DATED 19-12-2022 OF THE 2ND RESPONDENT Annexure XIX TRUE COPY OF THE CIRCULAR DATED 9/9/2019 ISSUED BY THE GOVERNMENT OF INDIA Annexure XX TRUE COPY OF THE LETTER DATED 4/2/2020 OF THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOZHIKODE Annexure XXI TRUE COPY OF THE COMPLAINT DATED 11/3/2020 OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA Annexure XXII TRUE COPY OF THE FINAL REPORT IN C.C. NO. 104 OF 2024 OF THE CHIEF JUDICIAL MAGISTRATE COURT, ERNAKULAM

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