Disposed

Mullankolly Service Co-Operative Bank v. Income Tax Officer

Kerala HC11 Oct 2019WP(C)/6970/2019

Case brief

AI extract

What is this about?

The Court disposed of six connected writ petitions challenging penalty orders under Sections 271D and 271E of the Income Tax Act. Noting pending appeals and an operating interim stay, the Court directed the Commissioner of Income Tax (Appeals) to dispose of the appeals expeditiously within three months while maintaining the stay on recovery.

What did the court decide?

Writ petitions disposed; Petitioners directed to file appeals with CIT(A); CIT(A) directed to dispose appeals within 3 months; Existing stay on recovery continues.

Mullankolly Service Co-Operative Bank Vs Income Tax Officer — Income Tax | Kerala HC (2019)

¶1

IN THE HIGH COURT OF KERALA AT ERNAKULAM

¶2

PRESENT

¶3

THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

¶4

FRIDAY, THE 11TH DAY OF OCTOBER 2019 / 19TH ASWINA, 1941

¶5

WP(C).No.6907 OF 2019(K)

¶6

PETITIONER/S:

¶7

SULTHAN BATHERY SERVICE CO-OPERATIVE BANK REP. BY ITS SECRETARY, SULTHAN BATHERY, WAYANAD DISTRICT.

¶8

BY ADVS. SRI.M.P.ASHOK KUMAR SMT.BINDU SREEDHAR SHRI.ASIF N

¶9

RESPONDENT/S:

¶10

1 INCOME TAX OFFICER, AAYAKAR BHAVAN, KOZHIKODE- 673001.

¶11

2 JOINT COMMISSIONER OF INCOME TAX, OFFICE OF THE INCOME TAX DEPARTMENT, RANGE-2, KOZHIKODE- 673001.

¶12

3 COMMISSIONER OF INCOME TAX (APPEALS), AYAKAR BHAVAN, KOZHIKODE- 673001.

¶13

R1-3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT

¶14

THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 11.10.2019, ALONG WITH WP(C).12007/2019(A), WP(C).6970/2019(U), WP(C).7259/2019(F), WP(C).7931/2019(N), WP(C).7959/2019(T), WP(C).7963/2019(U), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

¶15

WP(C).No.6907/19 & conn cases

¶16

¶17

IN THE HIGH COURT OF KERALA AT ERNAKULAM

¶18

PRESENT

¶19

THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

¶20

FRIDAY, THE 11TH DAY OF OCTOBER 2019 / 19TH ASWINA, 1941

¶21

WP(C).No.12007 OF 2019(A)

¶22

PETITIONER/S:

¶23

THIRUNELLY SERVICE CO-OPERATIVE BANK LTD KARTIKULAM, MANANTHAVADY, WAYANAD - 673 646, REPRESENTED BY ITS SECRETARY

¶24

BY ADVS. SRI.P.R.VENKETESH SRI.G.KEERTHIVAS

¶25

RESPONDENT/S:

¶26

1 THE INCOME TAX OFFICER AAYAKAR BHAVAN, KOZHIKODE - 673 001

¶27

2 THE JOINT COMMISSIONER OF INCPME TAX OFFICE OF THE INCOME TAX DEPARTMENT, RANGE - 2, KOZHIKODE-673001

¶28

3 THE COMMISSIONER OF INCOME TAX (APPEALS) AAYAKAR BHAVAN, KOZHIKODE- 673001

¶29

THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 11.10.2019, ALONG WITH WP(C).6907/2019(K), WP(C).6970/2019(U), WP(C).7259/2019(F), WP(C).7931/2019(N), WP(C).7959/2019(T), WP(C).7963/2019(U), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

¶30

WP(C).No.6907/19 & conn cases

¶31

¶32

IN THE HIGH COURT OF KERALA AT ERNAKULAM

¶33

PRESENT

¶34

THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

¶35

FRIDAY, THE 11TH DAY OF OCTOBER 2019 / 19TH ASWINA, 1941

¶36

WP(C).No.6970 OF 2019(U)

¶37

PETITIONER/S:

¶38

MULLANKOLLY SERVICE CO-OPERATIVE BANK REP. BY ITS SECRETARY, MULLANKOLLY, WAYANAD DISTRICT.

¶39

BY ADVS. SRI.M.P.ASHOK KUMAR SMT.BINDU SREEDHAR SMT.R.S.MANJULA SHRI.ASIF N

¶40

RESPONDENT/S:

¶41

1 INCOME TAX OFFICER

¶42

AAYAKAR BHAAVAN, KOZHIKODE-673001.

¶43

2 JOINT COMMISSIONER OF INCOME TAX OFFICE OF THE THE INCOME TAX DEPARTMENT, RANGE-2, KOZHIKODE-673001.

¶44

3 COMMISSIONER OF INCOME TAX (APPEALS), AYAKAR BHAVAN, KOZHIKODE-673001

¶45

R1-3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT

¶46

THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 11.10.2019, ALONG WITH WP(C).12007/2019(A), WP(C).6907/2019(K), WP(C).7259/2019(F), WP(C).7931/2019(N), WP(C).7959/2019(T), WP(C).7963/2019(U), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

¶47

WP(C).No.6907/19 & conn cases

¶48

¶49

IN THE HIGH COURT OF KERALA AT ERNAKULAM

¶50

PRESENT

¶51

THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

¶52

FRIDAY, THE 11TH DAY OF OCTOBER 2019 / 19TH ASWINA, 1941

¶53

WP(C).No.7259 OF 2019(F)

¶54

PETITIONER/S:

¶55

POOTHADY SERVICE CO-OPERATIVE BANK

¶56

REP. BY ITS SECRETARY, KENICHIRA, WAYANAD DISTRICT.

¶57

BY ADVS. SRI.M.P.ASHOK KUMAR SMT.BINDU SREEDHAR SHRI.ASIF N

¶58

RESPONDENT/S:

¶59

1 INCOME TAX OFFICER

¶60

AAYAKAR BHAVAN, KOZHIKODE-673 001

¶61

2 JOINT COMMISSIONER OF INCOME TAX OFFICE OF THE INCOME TAX DEPARTMENT, RANGE-2, KOZHIKODE-673 001

¶62

3 COMMISSIONER OF INCOME TAX (APPEALS), AYAKAR BHAVAN, KOZHIKOE-673 001

¶63

R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT

¶64

THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 11.10.2019, ALONG WITH WP(C).12007/2019(A), WP(C).6907/2019(K), WP(C).6970/2019(U), WP(C).7931/2019(N), WP(C).7959/2019(T), WP(C).7963/2019(U), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

¶65

WP(C).No.6907/19 & conn cases

¶66

¶67

IN THE HIGH COURT OF KERALA AT ERNAKULAM

¶68

PRESENT

¶69

THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

¶70

FRIDAY, THE 11TH DAY OF OCTOBER 2019 / 19TH ASWINA, 1941

¶71

WP(C).No.7931 OF 2019(N)

¶72

PETITIONER/S:

¶73

KALPETTA SERVICE CO-OEPRATIVE BANK LTD.,

¶74

REP. BY ITS SECRETARY, KALPETTA, WAYANAD DISTRICT,673 121

¶75

BY ADVS. SRI.M.P.ASHOK KUMAR SMT.BINDU SREEDHAR SHRI.ASIF N

¶76

RESPONDENT/S:

¶77

1 THE INCOME TAX OFFICER AAYAKAR BHAAVAN, KOZHIKODE-673 001

¶78

2 JOINT COMMISSIONER OF INCOME TAX OFFICE OF THE INCOME TAX DEPARTMENT, RANGE-2, KOZHIKODE-673 001

¶79

3 COMMISSIONER OF INCOME TAX (APPEALS) AYAKAR BHAVAN, KOZHIKODE-673 001

¶80

BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT

¶81

THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 11.10.2019, ALONG WITH WP(C).12007/2019(A), WP(C).6907/2019(K), WP(C).6970/2019(U), WP(C).7259/2019(F), WP(C).7959/2019(T), WP(C).7963/2019(U), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

¶82

WP(C).No.6907/19 & conn cases

¶83

¶84

IN THE HIGH COURT OF KERALA AT ERNAKULAM

¶85

PRESENT

¶86

THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

¶87

FRIDAY, THE 11TH DAY OF OCTOBER 2019 / 19TH ASWINA, 1941

¶88

WP(C).No.7959 OF 2019(T)

¶89

PETITIONER/S:

¶90

KANIYAMBETTA SERVICE CO-OPERATIVE BANK LIMITED REP. BY ITS SECRETARY, KANIYAMBETTA, WAYANAD DISTRICT, 673 121

¶91

BY ADVS. SRI.M.P.ASHOK KUMAR SMT.BINDU SREEDHAR SHRI.ASIF N

¶92

RESPONDENT/S:

¶93

1 THE INCOME TAX OFFICER AAYAKAR BHAAVAN, KOZHIKODE-673 001

¶94

2 JOINT COMMISSIONER OF INCOME TAX, OFFICE OF THE INCOME TAX DEPARTMENT, RANGE-2, KOZHIKODE-673 001

¶95

3 COMMISSIONER OF INCOME TAX (APPEALS) AYAKAR BHAVAN, KOZHIKODE-673 001

¶96

R1-3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT

¶97

THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 11.10.2019, ALONG WITH WP(C).12007/2019(A), WP(C).6907/2019(K), WP(C).6970/2019(U), WP(C).7259/2019(F), WP(C).7931/2019(N), WP(C).7963/2019(U), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

¶98

WP(C).No.6907/19 & conn cases

¶99

¶100

IN THE HIGH COURT OF KERALA AT ERNAKULAM

¶101

PRESENT

¶102

THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

¶103

FRIDAY, THE 11TH DAY OF OCTOBER 2019 / 19TH ASWINA, 1941

¶104

WP(C).No.7963 OF 2019(U)

¶105

PETITIONER/S:

¶106

MADIKKAMALA SERVICE CO-OPERATIVE BANK LTD., REP. BY ITS SECRETARY, MADIKKAMALA, WAYANAD DISTRICT.

¶107

BY ADVS. SRI.M.P.ASHOK KUMAR SMT.BINDU SREEDHAR SHRI.ASIF N

¶108

RESPONDENT/S:

¶109

1 INCOME TAX OFFICER AAYAKAR BHAAVAN, KOZHIKODE-673 001

¶110

2 JOINT COMMISSIONER OF INCOME TAX OFFICE OF THE INCOME TAX DEPARTMENT, RANGE-2, KOZHIKODE 673 001.

¶111

3 COMMISSIONER OF INCOME TAX (APPEALS) AYAKAR BHAVAN, KOZHIKODE-673 001

¶112

BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT

¶113

THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 11.10.2019, ALONG WITH WP(C).12007/2019(A), WP(C).6907/2019(K), WP(C).6970/2019(U), WP(C).7259/2019(F), WP(C).7931/2019(N), WP(C).7959/2019(T), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

¶114

WP(C).No.6907/19 & conn cases

¶115

¶116

JUDGMENT

¶117

[ WP(C).6907/2019, WP(C).12007/2019, WP(C).6970/2019, WP(C).7259/2019, WP(C).7931/2019, WP(C).7959/2019, WP(C).7963/2019 ]

¶118

Dated this the 11th day of October 2019

¶119

In all these writ petitions the petitioners, who are Primary Agricultural Credit Societies, are aggrieved by the penalty orders passed under the Income Tax Act against them during the assessment year 2015-16, in terms of Sections 271D and 271E of the Income Tax Act. The facts stated in the writ petitions would reveal that the petitioner societies had not complied with the requirements of Sections 269 SS and had accepted deposits from their members in excess of Rs.20,000/-, in cash. A penalty for the said action was imposed under Sections 271D and 271E of the Income Tax Act. The penalty amounts imposed on the petitioners range from approximately Rs.36 Crores to Rs.218 Crores.

¶120

It would appear that, against the penalty orders, the petitioners preferred appeals before the First Appellate Authority, and simultaneously moved the Joint Commissioner of Income tax, through petitions under Section 226 of the Income Tax Act for considering them as assessees not in default pending the disposal of the appeals by the appellate authority. The Joint Commissioner, after considering the case of the petitioners, directed them to pay 10% of the penalty amounts confirmed against them by the assessing authority in two equal monthly instalments, as a condition for stay of the recovery of the balance amounts confirmed against them. It is citing their poor financial condition, and inability to pay even the reduced amount directed by the 2^nd respondent - the Joint

¶121

WP(C).No.6907/19 & conn cases

¶122

¶123

Commissioner of Income Tax, that they have approached this Court through the present writ petitions, impugning the orders of the Joint Commissioner of Income Tax.

¶124

I have heard Sri.,Ashok Kumar and Sri.P.R.Venkatesh, the learned counsel for the petitioners and also the learned Standing Counsel for the respondents.

¶125

On a consideration of the facts and circumstances of the case and the submissions made across the Bar, while under normal circumstances, the orders of the Joint Commissioner of Income Tax impugned in these writ petitions cannot be seen as unreasonable or arbitrary and hence liable for interference by this Court in these proceedings under Article 226 of the Constitution of India, I take note of the submissions of the learned counsel for the petitioners, that the appeals preferred by them against the penalty orders have since been heard by the appellate authority, and orders are not passed in the appeals only because of the pendency of these writ petitions. I also note that when these writ petitions were admitted by this Court, this Court had by an interim order passed in March 2019, stayed the recovery of the penalty amounts from the petitioners during the pendency of the writ petitions. The writ petitions have been pending before this Court for over six months and a stay has also been operating in favour of the petitioners, in the meanwhile. Under the said circumstances, and taking note of the fact that the statutory appeals can now be disposed by the First Appellate Authority, I dispose these writ petitions by directing the Commissioner of Income Tax (Appeals) before whom the appeals preferred by the petitioners, against the orders of penalty passed against them under the Income Tax Act, are pending, to consider and pass orders on the same, expeditiously after hearing the petitioners, at any rate, within three months from the date of receipt of a copy of this judgment. It is made clear that pending disposal of the appeals by the

¶126

WP(C).No.6907/19 & conn cases

¶127

¶128

Commissioner of Income Tax (Appeals), and communication of the appellate orders to the petitioners, the stay granted by this Court against recovery of penalty amounts from the petitioners shall continue to operate.

¶129

Sd/- A.K.JAYASANKARAN NAMBIAR JUDGE

¶130

¶131

WP(C).No.6907/19 & conn cases

¶132

¶133

APPENDIX OF WP(C) 6907/2019

¶134

PETITIONER'S/S EXHIBITS:

¶135

EXHIBIT P1 PENALTY ORDER DATED 26.07.2018. EXHIBIT P2 PENALTY ORDER DATED 26.07.2018. EXHIBIT P3 PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT. EXHIBIT P4 PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT. EXHIBIT P5 PHOTOCOPY OF THE STAY PETITION DATED 23.01.2019. EXHIBIT P6 PHOTOCOPY OF THE STAY PETITION DATED 23.01.2019. EXHIBIT P7 PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019. EXHIBIT P8 PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019. EXHIBIT P9 PHOTOCOPY OF THE RELEVANT PAGE OF THE BALANCE SHEET DATED 31.03.2015.

¶136

WP(C).No.6907/19 & conn cases

¶137

¶138

APPENDIX OF WP(C) 12007/2019

¶139

PETITIONER'S/S EXHIBITS:

¶140

EXHIBIT P1	TRUE COPY OF THE NOTICE DATED 25.6.2018 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER
EXHIBIT P2	TRUE COPY OF THE NOTICE DATED 25.1.2018 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER
EXHIBIT P3	TRUE COPY CO THE REPLY SUBMITTED BY THE PETITIONER TO THE 2ND RESPONDENT DATED 14.2.2018
EXHIBIT P4	THE TRUE COPY OF THE BALANCE SHEET AS ON 31.3.2015 DATED 15.2.2016 OF THE PETITIONER SOCIETY
EXHIBIT P5	TRUE COPY OF THE TRADE, PROFIT AND LOSS ACCOUNT FOR THE YEAR ENDED 31.3.2015 OF THE PETITIONER BANK DATED 15.2.2016
EXHIBIT P6	TRUE COPY OF PROFIT & LOSS ACCOUNT FOR THE YEAR ENDED 31.3.2015 OF THE PETITIONER SOCIETY DATED 15.2.2016
EXHIBIT P7	TRUE COPY OF THE PROFIT & LOSS APPROPRIATION ACCOUNT FOR THE YEAR ENDED 31.3.2015 OF THE PETITIONER SOCIETY
EXHIBIT P8	TRUE COPY OF THE DEMAND NOTICE DATED 26.7.2018 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER SOCIETY
EXHIBIT P9	TRUE COPY OF ASSESSMENT YEAR UNDER SECTION 271D R/W SECTION 269 SS ISSUED BY THE 2ND RESPONDENT DATED 26.7.2018 FOR THE ASSESSMENT YEAR 2015-16
EXHIBIT P10	TRUE COPY OF THE APPEAL FILED BEFORE THE 3RD RESPONDENT BY THE PETITIONER AGAINST DEMAND NOTICE UNDER SEC.271D DATED 28.8.2018
EXHIBIT P11	TRUE COPY OF THE STAY APPLICATION FILED BY THE PETITIONER BEFORE THE 2ND RESPONDENT DATED 23.1.2019

¶141

WP(C).No.6907/19 & conn cases

¶142

¶143

EXHIBIT P12	TRUE COPY OF THE STAY ORDER DATED 31.1.2019 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER
EXHIBIT P13	TRUE COPY OF THE DEMAND NOTICE DATED 26.7.2018 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER
EXHIBIT P14	TRUE COPY OF THE ASSESSMENT ORDER FOR THE YEAR 2015-16 DATED 26.7.2018 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER
EXHIBIT P15	TRUE COPY OF THE WRITTEN SUBMISSIONS FILED BY THE PETITIONER SOCIETY AGAINST THE NOTICE UNDER SECTION 274 R/W SECTION 271E OF THE INCOME TAX ACT DATED 14.2.2018
EXHIBIT P16	TRUE COPY OF THE STAY APPLICATION FILED BY THE PETITIONER DATED 23.1.2019 AGAINST RECOVERY OF DEMAND LEVIED UNDER SECTION 271E
EXHIBIT P17	TRUE COPY OF THE ORDER DATED 31.1.2019 ISSUED BY THE 2ND RESPONDENT UNDER SECTION 271E IN RESPONSE TO THE STAY APPLICATION
EXHIBIT P18	TRUE COPY OF THE INTERIM ORDER DATED 11/03/2019 IN WP(C) 6907 OF 2019
EXHIBIT P19	TRUE COPY OF THE APPEAL FILED BEFORE THE 3RD RESPONDENT AGAINST DEMAND NOTICE UNDER SEC.271E BY THE PETITIONER DATED 28.8.2018

¶144

WP(C).No.6907/19 & conn cases

¶145

¶146

APPENDIX OF WP(C) 6970/2019

¶147

PETITIONER'S/S EXHIBITS:

¶148

EXHIBIT P1	PENALTY ORDER DAT	ED 26/07/2018.
EXHIBIT P2	PENALTY ORDER DAT	ED 26/07/2018.
EXHIBIT P3	PHOTOCOPY OF THE 3RD RESPONDENT.	APPEAL PENDING BEFORE THE
EXHIBIT P4	PHOTOCOPY OF THE 3RD RESPONDENT.	APPEAL PENDING BEFORE THE
EXHIBIT P5	PHOTOCOPY OF THE 23/01/2019.	STAY PETITION DATED
EXHIBIT P6	PHOTOCOPY OF THE 23/01/2019.	STAY PETITION DATED
EXHIBIT P7	PHOTOCOPY OF THE THE STAY PETITION	INTERIM ORDER PASSED IN 31/01/2019
EXHIBIT P8	PHOTOCOPY OF THE THE STAY PETITION	INTERIM ORDER PASSED IN 31/01/2019.
EXHIBIT P9	PHOTOCOPY OF THE BALANCE SHEET DAT	RELEVANT PAGE OF THE ED 31/03/2015.

¶149

WP(C).No.6907/19 & conn cases

¶150

¶151

APPENDIX OF WP(C) 7259/2019

¶152

PETITIONER'S/S EXHIBITS:

¶153

EXHIBIT P1	PENALTY ORDER DAT	ED 26.07.2018
EXHIBIT P2	PENALTY ORDER DAT	ED 26/07/2018
EXHIBIT P3	PHOTOCOPY OF THE 3RD RESPONDENT.	APPEAL PENDING BEFORE THE
EXHIBIT P4	PHOTOCOPY OF THE 3RD RESPONDENT.	APPEAL PENDING BEFORE THE
EXHIBIT P5	PHOTOCOPY OF THE 23.01.2019	STAY PETITION DATED
EXHIBIT P6	PHOTOCOPY OF THE 23.01.2019	STAY PETITION DATED
EXHIBIT P7	PHOTOCOPY OF THE THE STAY PETITION	INTERIM ORDER PASSED IN 31.01.2019
EXHIBIT P8	PHOTOCOPY OF THE THE STAY PETITION	INTERIM ORDER PASSED IN 31.01.2019
EXHIBIT P9	PHOTOCOPY OF THE BALANCE SHEET DAT	RELEVANT PAGE OF THE ED 31.03.2015

¶154

WP(C).No.6907/19 & conn cases

¶155

¶156

APPENDIX OF WP(C) 7931/2019

¶157

PETITIONER'S/S EXHIBITS:

¶158

EXHIBIT P1 PENALTY ORDER DATED 26.07.2018. EXHIBIT P2 PENALTY ORDER DATED 26.07.2018 EXHIBIT P3 PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT. EXHIBIT P4 PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT. EXHIBIT P5 PHOTOCOPY OF THE STAY PETITION DATED 25.01.2019. EXHIBIT P6 PHOTOCOPY OF THE STAY PETITION DATED 25.01.2019 EXHIBIT P7 PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019 EXHIBIT P8 PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019

¶159

WP(C).No.6907/19 & conn cases

¶160

¶161

APPENDIX OF WP(C) 7959/2019

¶162

PETITIONER'S/S EXHIBITS:

¶163

EXHIBIT P1	PENALTY ORDER DATED 26.07.2018
EXHIBIT P2	PENALTY ORDER DATED 26.07.2018.
EXHIBIT P3	PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT.
EXHIBIT P4	PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT.
EXHIBIT P5	PHOTOCOPY OF THE STAY PETITION DATED 25.01.2019.
EXHIBIT P6	PHOTOCOPY OF THE STAY PETITION DATED 25.01.2019
EXHIBIT P7	PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019
EXHIBIT P8	PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019

¶164

WP(C).No.6907/19 & conn cases

¶165

¶166

APPENDIX OF WP(C) 7963/2019

¶167

PETITIONER'S/S EXHIBITS:

¶168

EXHIBIT P1	PENALTY ORDER DATED 26.07.2018
EXHIBIT P2	PENALTY ORDER DATED 26.07.2018
EXHIBIT P3	PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT.
EXHIBIT P4	PHOTOCOPY OF THE APPEAL PENDING BEFORE THE 3RD RESPONDENT.
EXHIBIT P5	PHOTOCOPY OF THE STAY PETITION DATED 25.01.2019
EXHIBIT P6	PHOTOCOPY OF THE STAY PETITION DATED 25.01.2019
EXHIBIT P7	PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019
EXHIBIT P8	PHOTOCOPY OF THE INTERIM ORDER PASSED IN THE STAY PETITION 31.01.2019

Mullankolly Service Co-Operative Bank v. Income Tax Officer

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Mullankolly Service Co-Operative Bank v. Income Tax Officer

Case brief

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