Writ petitions challenging notices under Section 153A of the Income Tax Act were dismissed as infructuous after counsel sought withdrawal with liberty to file fresh petitions if needed.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40119 OF 2023
PETITIONER:
M/S AAYANA CHARITABLE TRUST
REPRESENTED BY ITS MANAGING TRUSTEE
MR. SINY PUNNOOSE 1, MANJADI THIRUVALLA,
THIRUVALLA., PIN – 689101
BY ADVS.
N.KRISHNA PRASAD
P.SHANES METHAR
GAYATHRI POTI
PUSHPARAJ.K.P
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF REVENUE
MINISTRY OF FINANCE,
3RD FLOOR, JEEVAN DEEP BUILDING,
SANSAD MARG,NEW DELHI,PIN – 110001
2INTERIM BOARD FOR SETTLEMENT-II
REPRESENTED BY ITS SECRETARY 9TH FLOOR,
LOK NAYAK BHAVAN,
KHAN MARKET,
NEW DELHI, PIN – 110003
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE -
MINISTRY OF FINANCE,
GOVERNMENT OF INDIA NEW DELHI,PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE - 2 M.G. ROAD,
KOCHI, PIN – 682011
SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40120/2023, 40122/2023 AND CONNECTED CASES,
THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
2
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40120 OF 2023
PETITIONER:
M/S GROWTH IN FRATERNITY TRUST
REPRESENTED BY ITS MANAGING TRUSTEE MR. THOMAS
N.S NO. 106, 2ND STREET, 'E' CROSS, OMBR LAYOUT,
CHIKKABANASWADI,
BANGALORE, PIN – 560033
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY MINISTRY OF
FINANCE,3RD FLOOR,
JEEVAN DEEP BUILDING, SANSAD MARG
NEW DELHI., PIN – 110001
2INTERIM BOARD FOR SETTLEMENT-II
REPRESENTED BY ITS SECRETARY,
9TH FLOOR, LOK NAYAK BHAVAN,
KHAN MARKET NEW DELHI., PIN – 110003
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON,
MINISTRY OF FINANCE,
GOVERNMENT OF INDIA,
NEW DELHI., PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE - 2, M.G. ROAD,
KOCHI, PIN – 682011
BY ADV.
SRI. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
3
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40122 OF 2023
PETITIONER:
M/S SHEKINA PROPHETIC MISSION TRUST;
REPRESENTED BY ITS MANAGING TRUSTEE MR. PRABHUDAS J
SIRUMUGAI ROAD,
1ST STREET, ANNUR,
COIMBATORE, PIN – 641653
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF
REVENUE MINISTRY OF FINANCE,
3RD FLOOR, JEEVAN DEEP BUILDING,
SANSAD MARG,NEW DELHI, PIN – 110001
2INTERIM BOARD FOR SETTLEMENT-II
REPRESENTED BY ITS SECRETARY 9TH FLOOR,
LOK NAYAK BHAVAN,
KHAN MARKET NEW DELHI., PIN – 110003
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE -
MINISTRY OF FINANCE GOVERNMENT OF INDIA,
NEW DELHI, PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE - 2 M.G. ROAD,
KOCHI., PIN – 682011
BY ADV.
SMT. SUSIE B. VARGHESE - SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
4
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40125 OF 2023
PETITIONER:
M/S HOLY SPIRIT MINISTRIES
M/S HOLY SPIRIT MINISTRIES REPRESENTED BY ITS MANAGING
TRUSTEE MR. RAJU N RR NO. 7, WEEH 2779,
OPP TO DIYA ACDEMIC SCHOOL, KODIGEHALLI MAIN ROAD,
AYYAPPAN NAGAR, K.R.PURAM POST,
BENGALURU, PIN – 560036
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY
MINISTRY OF FINANCE, 3RD FLOOR,
JEEVAN DEEP BUILDING, SANSAD MARG,
NEW DELHI, PIN – 110001
2INTERIM BOARD FOR SETTLEMENT-II
9TH FLOOR, LOK NAYAK BHAVAN,
KHAN MARKET,
NEW DELHI, PIN – 110003
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE -
MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
NEW DELHI., PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE - 2, M.G. ROAD,
KOCHI, PIN – 682011
BY ADV.
SMT. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
5
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40141 OF 2023
PETITIONER:
M/S NEW LIFELINE CHARITABLE MINISTRIES
REPRESENTED BY ITS MANAGING TRUSTEE MR. MARTIN K E H NO.
10991/1, SECTOR 29D,
CHANDIGARH., PIN – 160062
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF
REVENUE MINISTRY OF FINANCE, 3RD FLOOR,
JEEVAN DEEP BUILDING, SANSAD MARG,
NEW DELHI., PIN – 110001
2 INTERIM BOARD FOR SETTLEMENT-II 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET NEW DELHI, PIN – 1100033 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE GOVERNMENT OF INDIA, NEW DELHI., PIN – 1100014 DEPUTY COMMISSIONER OF INCOME TAX DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 M.G. ROAD, KOCHI, PIN – 682011.BY ADV.
SMT. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
6
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40154 OF 2023
PETITIONER:
M/S LOVE INDIA MINISTRIES
REPRESENTED BY ITS MANAGING TRUSTEE
MR. OOMMEN MATHEW VII/37
POOTHICOTE, MANJADI THIRUVALLA,
THIRUVALLA., PIN – 689105
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF
REVENUE - MINISTRY OF FINANCE,
3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG,
NEW DELHI., PIN – 110001
2INTERIM BOARD FOR SETTLEMENT-II
REPRESENTED BY ITS SECRETARY 9TH FLOOR,
LOK NAYAK BHAVAN, KHAN MARKET,
NEW DELHI., PIN – 110003
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE -
MINISTRY OF FINANCE GOVERNMENT OF INDIA,
NEW DELHI., PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE - 2 M.G. ROAD,
KOCHI., PIN – 682011.
BY ADV.
SMT. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
7
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40176 OF 2023
PETITIONER:
M/S REHABOTH INDIAN GYPSY NEW LIFE TRUST
REPRESENTED BY ITS MANAGING TRUSTEE MR. RAJI JOHN
SIRUMUGAI ROAD, 1ST STREET, ANNUR,
COIMBATORE., PIN – 641653
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF
REVENUE MINISTRY OF FINANCE, 3RD FLOOR,
JEEVAN DEEP BUILDING,
SANSAD MARG,NEW DELHI, PIN – 110001
2INTERIM BOARD FOR SETTLEMENT -II
9TH FLOOR, LOK NAYAK BHAVAN,
KHAN MARKET,
NEW DELHI., PIN – 110003
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE -
MINISTRY OF FINANCE,
GOVERNMENT OF INDIA
NEW DELHI., PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE - 2 M.G. ROAD,
KOCHI, PIN – 682011.
BY ADV.
SMT. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION
ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
8
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40177 OF 2023
PETITIONER:
M/S BELIEVERS EASTERN CHURCH
REPRESENTED BY ITS MANAGING TRUSTEE
MR. SAMUEL MATHEW XXVI/219, IYERS BUILDING,
RAMANCHIRA, TIRUVALLA, PIN – 689101
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF
REVENUE MINISTRY OF FINANCE,
3RD FLOOR, JEEVAN DEEP BUILDING,
SANSAD MARG,
NEW DELHI, PIN – 110001
2INTERIM BOARD FOR SETTLEMENT-II
INTERIM BOARD FOR SETTLEMENT-II, NEW 9TH FLOOR,
LOK NAYAK BHAVAN, KHAN MARKET,
NEW DELHI., PIN – 110003
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE -
MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
NEW DELHI., PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE - 2 M.G. ROAD,
KOCHI., PIN – 682011.
BY ADV.
SMT. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
9
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40186 OF 2023
PETITIONER:
M/S NEW HOPE FOUNDATION,
REPRESENTED BY ITS MANAGING TRUSTEE MR. JOHN AUXON,
KEELPADAPPAI, KANCHIPURAM,
CHENNAI., PIN – 601301.
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA,
REPRESENTED BY THE FINANCE SECRETARY,
DEPARTMENT OF REVENUE MINISTRY OF FINANCE,
3RD FLOOR, JEEVAN DEEP BUILDING,
SANSAD MARG, NEW DELHI, PIN – 110001.
2INTERIM BOARD FOR SETTLEMENT-II,
REPRESENTED BY ITS SECRETARY 9TH FLOOR,
LOK NAYAK BHAVAN, KHAN MARKET,
NEW DELHI, PIN – 110003.
3THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA,
NEW DELHI, PIN – 110001.
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE – 2
M.G. ROAD KOCHI, PIN – 682011.
BY ADV.
SMT. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
10
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945
WP(C) NO. 40211 OF 2023
PETITIONER:
M/S HOLY BERACHAH MINISTRIES
REPRESENTED BY ITS M
CENTRAL CIRCLE – 2,A
CENTRAL CIRCLE – 2,NAGING TRUSTEE MR. JESUPRASAD S D
DOOR NO. 18, G.C COLONY,QUEENS ROAD,
BANGALORE., PIN – 560051
BY ADVS.
SRI. N. KRISHNA PRASAD
SRI. P. SHANES METHAR
SMT. GAYATHRI POTI
SRI. PUSHPARAJ K. P.
RESPONDENTS:
1UNION OF INDIA
REPRESENTED BY THE FINANCE SECRETARY MINISTRY OF
FINANCE, 3RD FLOOR,JEEVAN DEEP BUILDING,
SANSAD MARG, NEW DELHI., PIN – 110001.
2INTERIM BOARD FOR SETTLEMENT-II
REPRESENTED BY ITS SECRETARY,
9TH FLOOR, LOK NAYAK BHAVAN,
KHAN MARKET, NEW DELHI, PIN – 110003.
3THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE -
MINISTRY OF FINANCE GOVERNMENT OF INDIA,
NEW DELHI., PIN – 110001
4DEPUTY COMMISSIONER OF INCOME TAX
CENTRAL CIRCLE – 2, M.G. ROAD KOCHI, PIN – 682011.
BY ADV.
SMT. SUSIE B. VARGHESE-SC
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WP(C) NO. 40119 OF 2023 & Connected Cases
11
DINESH KUMAR SINGH, J.
WP(C) Nos.40119, 40120, 40122, 40125, 40141, 40154, 40176, 40177, 40186 & 40211 of 2023
Dated this the 6th day of December, 2023
JUDGMENT
Sd/-
DINESH KUMAR SINGH JUDGE
Svn
WP(C) NO. 40119 OF 2023 & Connected Cases
12
APPENDIX OF WP(C) 40119/2023
PETITIONER’S EXHIBITS
Exhibit |
P1TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 INWP(C) NO. 4299/2021 |
|---|---|
Exhibit |
P2TRUE COPY OFTHE INTERIM ORDER 13.4.2021 IN WP(C) NO.9076 /2021 |
Exhibit |
P3TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FORTHE ASSESSMENT YEARS 2015-16 DATED 12.7.2021 |
Exhibit |
P3(a)TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FORTHE ASSESSMENT YEARS 2016-17 DATED 12.7.2021 |
Exhibit |
P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FORTHE ASSESSMENT YEARS 2017-18 DATED 12.7.2021 |
Exhibit |
P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FORTHE ASSESSMENT YEARS 2018-19 DATED 12.7.2021 |
Exhibit |
P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FORTHE ASSESSMENT YEARS 2019-20 DATED 12.7.2021 |
Exhibit |
P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FORTHE ASSESSMENT YEARS 2020-21 DATED 12.7.2021 |
Exhibit |
P4TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RDRESPONDENT DATED 07.09.2021 |
Exhibit |
P5TRUE COPY OF THE ORDER U/S.119(2)(B) OF THE ACTDATED 28.09.2021 |
Exhibit |
P6TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEOPTDATED 25.9.2021 |
Exhibit |
P7TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 INWP NO.20746 OF 2021 AND CONNECTED CASES |
Exhibit |
P8TRUE COPY OF THE RELEVANT EXTRACT AMENDMENT MADE BYTHE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM01.02.2021 |
Exhibit |
P9TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 |
WP(C) NO. 40119 OF 2023 & Connected Cases
13
APPENDIX OF WP(C) 40120/2023
PETITIONER’S EXHIBITS
Exhibit P1 |
TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 INWP(C) NO. 4299/2021 |
|---|---|
Exhibit P2 |
TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 INWP(C) NO. 9076 /2021 |
Exhibit P3 |
TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2015-16 ISSUED BY THE 4TH RESPONDENT DATED23.08.2021 |
Exhibit P3(a) |
TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2016-17 ISSUED BY THE 4TH RESPONDENT DATED23.08.2021 |
Exhibit P3(b) |
TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2017-18 ISSUED BY THE 4TH RESPONDENT DATED23.08.2021 |
Exhibit P3(c) |
TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2018-19 ISSUED BY THE 4TH RESPONDENT DATED23.08.2021 |
ExhibitP3(d) |
TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2019-20 ISSUED BY THE 4TH RESPONDENT DATED23.08.2021 |
Exhibit P3(e) |
TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2020-21 ISSUED BY THE 4TH RESPONDENT DATED23.08.2021 |
Exhibit P4 |
TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RDRESPONDENT DATED 07.09.2021 |
Exhibit P5 |
TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACTDATED 28.09.2021 |
Exhibit P6 |
TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPTDATED 25.9.2021 |
Exhibit P7 |
TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 INW.P.(C) NO.20746 OF 2021 AND CONNECTED CASES |
Exhibit P8 |
TRUE COPY OF THE RELEVANT EXTRACT OF AMENDMENT MADEBY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECTFROM 01.02.2021 |
Exhibit P9 |
TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 |
WP(C) NO. 40119 OF 2023 & Connected Cases
14
APPENDIX OF WP(C) 40122/2023
PETITIONER’S EXHIBITS
Exhibit P1 |
TRUE COPY OF THE INTERIM ORDER DATED18.2.2021 IN WP(C) NO. 4299/2021 |
|---|---|
Exhibit P2 |
TRUE COPY OF THE INTERIM ORDER DATED13.4.2021 IN WP(C) NO. 9076 /2021 |
Exhibit P3 |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2015-16 |
Exhibit P3(a) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2016-17 |
Exhibit 3(b) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2017-18 |
Exhibit P3(c) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2018-19 |
Exhibit P3(d) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2019-20 |
Exhibit P3(e) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2020-21 |
Exhibit P4 |
TRUE COPY OF THE PRESS RELEASE ISSUED BY THE3RD RESPONDENT DATED 07.09.2021 |
Exhibit P5 |
TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THEACT DATED 28.09.2021 |
Exhibit P6 |
TRUE COPY OF THE SETTLEMENT APPLICATION FEERECEIPT DATED 25.9.2021 |
Exhibit P7 |
TRUE COPY OF THE INTERIM ORDER DATED30.09.2021 IN WP (C) NO.20746 OF 2021 ANDCONNECTED CASES |
Exhibit P8 |
TRUE COPY OF THE RELEVANT EXTRACT OF THEAMENDMENT MADE BY THE FINANCE ACT, 2021 WITHRETROSPECTIVE EFFECT FROM 01.02.2021 |
Exhibit P9 |
TRUE COPY OF THE NOTICE OF HEARING DATED21.11.2023 |
WP(C) NO. 40119 OF 2023 & Connected Cases
15
APPENDIX OF WP(C) 40125/2023
PETITIONER’S EXHIBITS
Exhibit P1 |
TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 INW.P (C) NO.4299 OF 2021 |
|---|---|
Exhibit P2 |
TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 INW.P.(C) NO.9076 OF 2021 |
Exhibit P3 |
TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FORTHE ASSESSMENT YEARS 2015-16 |
Exhibit P3(a) |
TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FORTHE ASSESSMENT YEARS 2016-17 DATED 23.08.2021 |
Exhibit P3(b) |
TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FORTHE ASSESSMENT YEARS 2017-18 DATED 23.08.2021 |
Exhibit P3(c) |
TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FORTHE ASSESSMENT YEARS 2018-19 DATED 23.08.2021 |
Exhibit P3(d) |
TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FORTHE ASSESSMENT YEARS 2019-20 DATED 23.08.2021 |
ExhibitP3(e) |
TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FORTHE ASSESSMENT YEARS 2020-21 DATED 23.08.2021 |
Exhibit P4 |
TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RDRESPONDENT DATED 07.09.2021 |
Exhibit P5 |
TRUE COPY OF THE ORDER U/S.119(2)(B) OF THE ACTDATED 28.09.2021 |
Exhibit P6 |
TRUE COPY OF THE SETTLEMENT APPLICATION FEERECEIPT DATED 25.9.2021 |
Exhibit P7 |
TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 INW.P (C) NO. 20746 OF 2021 AND CONNECTED CASES |
Exhibit P8 |
TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENTMADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVEEFFECT FROM 01.02.2021 |
Exhibit P9 |
TRUE COPY OF THE NOTICE OF HEARING DATED21.11.2023 |
WP(C) NO. 40119 OF 2023 & Connected Cases
16
APPENDIX OF WP(C) 40141/2023
PETITIONER’S EXHIBITS
Exhibit P1TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021
IN W.P (C) NO.4299 OF 2021
Exhibit P2TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021
IN W.P (C) NO.9076 OF 2021
Exhibit P3TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021
FOR THE ASSESSMENT YEARS 2015-16
Exhibit P3(a)TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021
FOR THE ASSESSMENT YEARS 2016-17
Exhibit P3(b)TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021
FOR THE ASSESSMENT YEARS 2017-18
Exhibit P3(c)TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021
FOR THE ASSESSMENT YEARS 2018-19
Exhibit P3(d)TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021
FOR THE ASSESSMENT YEARS 2019-20
Exhibit P3(e)TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021
FOR THE ASSESSMENT YEARS 2020-21
Exhibit P4TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD
RESPONDENT DATED 07.09.2021
Exhibit P5TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT
DATED 28.09.2021
Exhibit P6TRUE COPY OF THE SETTLEMENT APPLICATION FEE
RECEIPT DATED 25.9.2021
Exhibit P7TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021
IN W.P (C) NO.20746 OF 2021 AND CONNECTED CASES
Exhibit P8TRUE COPY OF THE RELEVANT EXTRACT OF THE
AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH
RETROSPECTIVE EFFECT FROM 01.02.2021
Exhibit P9TRUE COPY OF THE NOTICE OF HEARING DATED
21.11.2023
WP(C) NO. 40119 OF 2023 & Connected Cases
17
APPENDIX OF WP(C) 40154/2023
PETITIONER’S EXHIBITS
Exhibit P1 |
TRUE COPY OF THE INTERIM ORDER DATED18.2.2021 IN WP(C) NO. 4299/2021 |
|---|---|
Exhibit P2 |
TRUE COPY OF THE INTERIM ORDER DATED13.4.2021 IN WP(C) NO. 9076 /2021 |
Exhibit P3 |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2015-16 |
Exhibit P3(a) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2016-17 |
Exhibit P3(b) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2017-18 |
Exhibit P3(c) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2018-19 |
Exhibit P3(d) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2019-20 |
Exhibit P3(e) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2020-21 |
Exhibit P4 |
TRUE COPY OF THE PRESS RELEASE ISSUED BY THE3RD RESPONDENT DATED 07.09.2021 |
Exhibit P5 |
TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THEACT DATED 28.09.2021 |
Exhibit P6 |
TRUE COPY OF THE SETTLEMENT APPLICATION FEERECEIPT DATED 25.9.2021 |
Exhibit P7 |
TRUE COPY OF THE INTERIM ORDER DATED30.09.2021 IN WP NO.20746 OF 2021 ANDCONNECTED CASES |
Exhibit P8 |
TRUE COPY OF THE RELEVANT EXTRACT OF THEAMENDMENT MADE BY THE FINANCE ACT, 2021 WITHRETROSPECTIVE EFFECT FROM 01.02.2021 |
WP(C) NO. 40119 OF 2023 & Connected Cases
18
APPENDIX OF WP(C) 40176/2023
PETITIONER’S EXHIBITS
Exhibit P1 |
TRUE COPY OF THE INTERIM ORDER DATED18.2.2021 IN W.P.(C) NO.4299 OF 2021 |
|---|---|
Exhibit P2 |
TRUE COPY OF THE INTERIM ORDER DATED13.4.2021 IN W.P(C) NO.9076 OF 2021 |
Exhibit P3 |
TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022FOR THE ASSESSMENT YEARS 2015-16 |
Exhibit P3(a) |
TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022FOR THE ASSESSMENT YEARS 2016-17 |
Exhibit P3(b) |
TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022FOR THE ASSESSMENT YEARS 2017-18 |
Exhibit P3(c) |
TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022FOR THE ASSESSMENT YEARS 2018-19 |
Exhibit P3(d) |
TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022FOR THE ASSESSMENT YEARS 2019-20 |
Exhibit P3(e) |
TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022FOR THE ASSESSMENT YEARS 20120-21 |
Exhibit P4 |
TRUE COPY OF THE PRESS RELEASE ISSUED BY THE3RD RESPONDENT DATED 07.09.2021 |
Exhibit P5 |
TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THEACT DATED 28.09.2021 |
Exhibit P6 |
TRUE COPY OF THE SETTLEMENT APPLICATION FEERECEIPT DATED 25.9.2021 |
Exhibit P7 |
TRUE COPY OF THE INTERIM ORDER DATED04.10.2021 IN W.P (C) NO.21062 OF 2021 |
Exhibit P8 |
TRUE COPY OF THE RELEVANT EXTRACT OF THEAMENDMENT MADE BY THE FINANCE ACT, 2021 WITHRETROSPECTIVE EFFECT FROM 01.02.2021 |
Exhibit P9 |
TRUE COPY OF THE NOTICE OF HEARING DATED21.11.2023 |
WP(C) NO. 40119 OF 2023 & Connected Cases
19
APPENDIX OF WP(C) 40177/2023
PETITIONER’S EXHIBITS
Exhibit P1 |
TRUE COPY OF THE INTERIM ORDER DATED18.2.2021 IN WP(C) NO. 4299/2021 |
|---|---|
Exhibit P2 |
TRUE COPY OF THE INTERIM ORDER DATED13.4.2021 IN WP(C) NO. 9076 /2021 |
Exhibit P3 |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2015-16 |
Exhibit P3(a) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2016-17 |
Exhibit P3(b) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2017-18 |
Exhibit P3(c) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2018-19 |
Exhibit 3(d) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2019-20 |
Exhibit P3(e) |
TRUE COPY OF NOTICE U/S. 153A DATED23.03.2021 FOR THE ASSESSMENT YEARS 2020-21 |
Exhibit P4 |
TRUE COPY OF THE PRESS RELEASE ISSUED BY THE3RD RESPONDENT DATED 07.09.2021 |
Exhibit P5 |
TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THEACT DATED 28.09.2021 |
Exhibit P6 |
TRUE COPY OF THE SETTLEMENT APPLICATION FEERECEIPT DATED 25.9.2021 |
Exhibit P7 |
TRUE COPY OF THE INTERIM ORDER DATED30.09.2021 IN WP NO. 20746 OF 2021 ANDCONNECTED CASES |
Exhibit P8 |
TRUE COPY OF THE RELEVANT EXTRACT OF THEAMENDMENT MADE BY THE FINANCE ACT, 2021 WITHRETROSPECTIVE EFFECT FROM 01.02.2021 |
WP(C) NO. 40119 OF 2023 & Connected Cases
20
APPENDIX OF WP(C) 40186/2023
PETITIONER’S EXHIBITS
Exhibit P1 |
TRUE COPY OF THE INTERIM ORDER DATED18.2.2021 IN WP(C) NO. 4299/2021 |
|---|---|
Exhibit P2 |
TRUE COPY OF THE INTERIM ORDER DATED13.4.2021 IN WP(C) NO. 9076 /2021 |
Exhibit P3 |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2015-16 |
Exhibit P3(a) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2016-17 |
Exhibit P3(b) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2017-18 |
Exhibit P3(c) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2018-19 |
Exhibit P3(d) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2019-20 |
Exhibit P3(e) |
TRUE COPY OF NOTICE U/S. 153A DATED23.08.2021 FOR THE ASSESSMENT YEARS 2020-21 |
Exhibit P4 |
TRUE COPY OF THE PRESS RELEASE ISSUED BY THE3RD RESPONDENT DATED 07.09.2021 |
Exhibit P5 |
TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THEACT DATED 28.09.2021 |
Exhibit P6 |
TRUE COPY OF THE SETTLEMENT APPLICATION FEERECEIPT DATED 25.9.2021 |
Exhibit P7 |
TRUE COPY OF THE INTERIM ORDER DATED30.09.2021 IN W.P (C) NO.20746 AND CONNECTEDCASES |
Exhibit P8 |
TRUE COPY OF THE RELEVANT EXTRACT OF THEAMENDMENT MADE Y THE FINANCE ACT, 2021 WITHRETROSPECTIVE EFFECT FROM 01.02.2021 |
Exhibit P9 |
TRUE COPY OF THE NOTICE OF HEARING DATED21.11.2023 |
WP(C) NO. 40119 OF 2023 & Connected Cases
21
APPENDIX OF WP(C) 40211/2023
PETITIONER’S EXHIBITS
Exhibit |
P1TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 INW.P (C) NO.4299/2021 |
|---|---|
Exhibit |
P2TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 INW.P (C) NO.9076/2021 |
Exhibit |
P3TRUE COPY OF NOTICE U/S. 153A DATED 22.09.2021 FORTHE ASSESSMENT YEARS 2015-16 |
Exhibit |
P3(a)TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2016-17 DATED 22.09.2021 |
Exhibit |
P3(b)TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2017-18 DATED 22.09.2021 |
Exhibit |
P3(c)TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2018-19 DATED 22.09.2021 |
Exhibit |
P3(d)TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2019-20 DATED 22.09.2021 |
Exhibit |
P3(e)TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FORTHE AY. 2020-21 DATED 22.09.2021 |
Exhibit |
P4TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RDRESPONDENT DATED 07.09.2021 |
Exhibit |
P5TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACTDATED 28.09.2021 |
Exhibit |
P6TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPTDATED 25.09.2021 |
Exhibit |
P7TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 INW.P (C) NO.20746 OF 2021 AND CONNECTED CASES |
Exhibit |
P8TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENTMADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVEEFFECT FROM 01.02.2021 |
Exhibit |
P9TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 |
M/S AAYANA CHARITABLE TRUST
M/S GROWTH IN FRATERNITY TRUST
M/S SHEKINA PROPHETIC MISSION TRUST
M/S HOLY SPIRIT MINISTRIES
M/S NEW LIFELINE CHARITABLE MINISTRIES
UNION OF INDIA
Dinesh Kumar Singh
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court