IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.73 OF 2018 AGAINST ORDER IN ITA 324/2017 DATED 10-08-2018 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: ENANALLOOR SERVICE CO-OPERATIVE BANK LIMITED NO. 1147 REP BY ITS SECRETARY, AYAVANA PO, MUVATTUPUZHA, ERNAKULAM DIST - 686668 BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 INCOME TAX OFFICER (1 AND C) 5TH FLOOR, KANDAMKULATHY TOWERS, M.G. ROAD, KOCHI - 11 2 JOINT DIRECTOR DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G. ROAD, KOCHI-11 , 682016 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA KOCHI 682020 R1-3 BY ADV. SRI.P.K.RAVINDRANATHA MENON (SR.) R1-3 BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX OTHER PRESENT: SC,IT- SRI.P.K.RAVINDRANATHA MENON (SR) THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.265/2019 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.265 OF 2019 AGAINST ORDER IN ITA 454/COCH/2019 DATED 07-08-2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: KANMANAM SERVICE CO-OPERATIVE BANK LIMITED NO.10555, REPRESENTED BY ITS SECRETARY, KANMANAM P. O., MALAPPURAM DISTRICT - 676556. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE) AYAKAR BHAVAN, MANANCHIRA, KOZHIKODE - 673001. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI KANDAMKULATHY TOWERS, M. G. ROAD, KOCHI - 11 3 COMMISSIONER OF INCOME TAX (APPEAL) KADAVANTHRA, KOCHI - 682020. 4 INCOME TAX OFFICER WARD - 1, TARIFF BAZAR, TIRUR - 676101. R1-4 BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX SRI.P.K.RAVINDRANATHA MENON (SR.) THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.270 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 392/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: UZHUVA SERVICE CO-OPERATIVE BANK LIMITED NO. 305, REPRESENTED BY ITS SECRETARY, PATTANAKKAD P.O. ALAPPUZHA DISTRICT. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE) VELLAKINAR, ALAPPUZHA 688 001. 2 JOINT DIRECTOR DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI KANDAMKULATHY TOWERS, M.G. ROAD KOCHI-11 3 COMMISSIONER OF INCOME TAX (APPEALS), KADAVANTHRA. KOCHI 682 020 SRI.P.K.RAVINDRANATHA MENON (SR.) R1-3 BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.271 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 235/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: MANAKKAD SERVICE CO-OPERATIVE BANK LIMITED NO.1796, REPRESENTED BY ITS SECRETARY, MANAKKAD P. O., THODUPPUZHA IDUKKI DISTRICT. BY ADVS. C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH SWATHY S RESPONDENT/S: 1 INCOME TAX OFFICER (I AND CI) 5TH FLOOR, KANDAMKULATHY TOWERS, M. G. ROAD, KOCHI - 682 011. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M. G. ROAD, KOCHI - 682 011. 3 COMMISSIONER OF INCOME TAX (APPEAL) KADAVANTHRA, KOCHI - 682 020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.272 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 216/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: MULAKKUZHA SERVICE CO-OPERATIVE BANK LIMITED, NO.1224, REPRESENTED BY ITS SECRETARY, MULAKKUZHA P.O., CHENGANNUR, ALAPPUZHA DISTRICT - 689 505. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE) NAVARATNAM, VELLAKINAR, ALAPPUZHA - 688 001. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI - 11. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI - 682 020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.273 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 442/2017 DATED 01-08-2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: VETTAKKAL SERVICE CO-OPERATIVE BANK LIMITED NO.1812 REPRESENTED BY ITS SECRETARY, VETTAKKAL,P.O, CHERTHALA, ALAPPUZHA DISTRICT BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE) NAVARATNAM VELLAKINAR, ALAPPUZHA-688001 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-20 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.274 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 214/2017 DATED 20-06-2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: KARIKODE SERVICE CO-OPERATIVE LTD NO.4009 BANK REPRESENTED BY ITS SECRETARY, KEERIKODE P.O., THODUPUZHA EAST IDUKKI DISTRICT-685 620. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C) 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 3 COMMISSIONER OF INCOME TAX (APPEAL) KADAVANTHRA, KOCHI-20. 4 INCOME TAX OFFICER WARD-1 AND TPS, THODUPUZHA P.O., PIN-685 585. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.275 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 441/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: ARTHINKAL VILLAGE SERVICE CO-OPERATIVE BANK LIMITED NO.3772 REPRESENTED BY ITS SECRETARY, ARTHINKAL.P.O, ALAPPUZHA DISTRICT-688530 BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH KUM.S.SWATHY RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE) NAVARATNAM NAVARATNAM, VELLAKINAR, ALAPPUZHA-688001 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWER,M.G.ROAD, KOCHI-682011 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-682020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.276 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 405/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: NEENDOOR SERVICE CO-OPERATIVE BANK LIMITED NO. 2641 REPRESENTED BY ITS SECRETARY, NENDOOR P.O. KOTTAYAM DISTRICT . BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH S.SWATHY RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE) VELLAKINAR, ALAPPUZHA 688 001. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI. KANDAMKULATHY TOWER M.G. ROAD KOCHI 11. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI -20. 4 INCOME TAX OFFICER, (INTELLIGENCE), VELLAKINAR, ALLEPPEY 688 001. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.279 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 418/2019 DATED 08-07-2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: MEKKADAMPU SERVICE CO-OPERATIVE BANK LTD NO.4073 BANK REPRESENTED BY ITS SECRETARY, MEKKADAMPU.P.O,ERNAKULAM DISTRICT. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I&C) 5TH FLOOR,KANDAMKULATHY TOWERS, M.G.ROAD,KOCHI-11. 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE), KOCHI.11 3 COMMISSIONER OF INCOME TAX(APPEAL), KADAVANTHRA,KOCHI-682019. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.280 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 260/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: THYCATTUSSERRY SERVICE CO-OPERATIVE BANK LIMITED NO.275 REPRESENTED BY ITS SECRETARY, THYCATTUSSERRY.P.O., ALAPPUZHA DISTRICT. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), VELLAKINAR, ALAPPUZHA-688001. 2 JOINT DIRECTOR DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-20. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.287 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 230/2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: POONITHARA SERVICE CO-OPERATIVE BANK LIMITED, E-840 REPRESENTED BY ITS SECRETARY, VAEGHESE K.Y., AGED 57, S/O.JACOB POONITHARA P.O., ERNAKULAM DISTRICT- 682038. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI- 682011. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI- 682011. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI- 682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.289 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 473/2015 DATED 23-08-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: KAKKOOR SERVICE CO-OPERATIVE BANK LIMITED NO 163, REPRESENTED BY ITS SECRETARY, GRACY CHERIAN, AGED 58, W/O. GEORGE, KAKKOOR P.O, ERNAKULAM DISTRICT, PIN 686 662 BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER(I AND C) 5TH FLOOR, KANDAMKULATHY TOWERS, M.G ROAD, KOCHI 682 011 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE ) KOCHI, KANDAMKULATHY TOWERS, M.G ROAD, KOCHI 682 011 3 COMMISSIONER OF INCOME TAX(APPEAL), KADAVANTHRA, KOCHI 682 020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.290 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 158/2017 DATED 27-10-2017 OF AGRL.I.T.ADDITIONAL .BENCH,ERNAKULAM APPELLANT/S: ELAVALLY SERVICE CO-OPERATIVE BANK LIMITED, NO.F-1456, REPRESENTED BY ITS SECRETARY, ELAVALLY P.O., MATTAM, THRISSUR DISTRICT- 680602. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND CI), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR- 680001. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI- 682011. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI- 682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.291 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 169/2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: ALANGAD SERVICE CO-OPERATIVE BANK LIMITED NO.E-661, REPRESENTED BY ITS SECRETARY, ALANGAD P.O., ERNKAULAM DISTRICT, PIN-683 511. BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER (I AND CI) 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682 011. 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE), KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682 011. 3 COMMISSIONER OF INCOME TAX(APPEAL), KADAVANTHRA, KOCHI-682 020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.292 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 297/2017 DATED 03-10-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: KAVALANGAD SERVICE CO-OPERATIVE BANK LIMITED, NO.1348 REPRESENTED BY ITS SECRETARY MADHUSOODHANA NAIR P.K., AGED 52 YEARS, S/O.KARUNAKARAN NAIR, NELLIAMATTOM P.O., KOTHAMANGALAM, ERNAKULAM DISTRICT- 686693. BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.293 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 211/2017 DATED 03-10-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: VATANAPALLY SERVICE CO-OPERATIVE BANK LIMITED NO.F 211, REPRESENTED BY ITS SECRETARY, THRITHALLUR P.O., THRISSUR DISTRICT. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFCIER (I AND C) AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001. 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE), KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682 011. 3 COMMISSIONER OF INCOME TAX(APPEAL), KADAVANTHRA, KOCHI-682 020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.294 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 232/2017 DATED 08-11-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: PALAKKUZHA SERVICE CO-OPERATIVE BANK LIMITED NO.E 81 REPRESENTED BY ITS SECRETARY BABU JOHN, AGED 54 , S/O. JOHN,PALAKKUZHA P.O, ERNAKULAM DISTRICT-682 316 BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA,KOCHI R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.295 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 225/2019 DATED 08-07-2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: THOTTIPPAL SERVICE CO-OPERATIVE BANK LIMITED NO.634 REPRESENTED BY ITS SECRETARY, THOTTIPPAL P.O, THRISSUR DISTRICT. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER(INTELLIGENCE) THRISSUR, AYAKAR BHAVAN, THRISSUR- 680001 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI KANDAMKULATHY TOWERS, M.G.ROAD,KOCHI - 11 3 COMMISSIONER OF INCOME TAX (APPEAL) KADAVANTHRA , KOCHI -20 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.296 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 449/2019 DATED 01-10-2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: THRIKKAKARA SERVICE CO-OPERATIVE BANK LIMITED NO.E.148,REPRESENTED BY ITS SECRETARY, GIBI.I, AGED 57, W/O.ASOKAN.T.S., VADDACODE P.O., KANGARAPPADY, ERNAKULAM DISTRICT, PIN-682 021 BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C) 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682 011 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI,KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682 011 3 COMMISSIONER OF INCOME TAX (APPEAL) KADAVANTHRA, KOCHI-682 020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.297 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 544/2015 DATED 23-08-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: MUHAMMA SERVICE CO-OPERATIVE BANK LIMITED NO. 1670 REPRESENTED BY ITS SECRETARY, C.S. SUNILKUMAR, AGED 46 YEARS, S/O. SUMITHRAN, MUHAMMA, P.O. CHERTHALA, ALAPPUZHA DISTRICT. 688 525. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C) NAVARATNAM , VELLAKKINAR, ALAPPUZHA 688 001. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI, KANDAMKULATHY TOWERS, M.G. ROAD, KOCHI 682 011. 3 COMMISSIONER OF INCOME TAX, (APPEALS), KADAVANTHRA, KOCHI 682 020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.298 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 217/2017 DATED 23-08-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: EDATHALA SERVICE CO-OPERATIVE BANK LIMITED REPRESENTED BY ITS SECRETARY, EDATHALA NORTH P.O., ALUVA, ERNAKULAM DISTRICT-683 564. BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C) 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE), KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 3 COMMISSIONER OF INCOME TAX(APPEAL), KADAVANTHRA, KOCHI. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.299 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 453/2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: PANAVALLY SERVICE CO-OPERATIVE BANK LIMITED NO.E.901, REPRESENTED BY ITS SECRETARY, POOCHACKAL P.O., ALAPPUZHA DISTRICT. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE), NAVARATNAM, VELLAKINAR, ALAPPUZHA - 688 001. 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI - 11. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI.682 020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.300 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 224/2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: UDUMBANNOOR SERVICE CO-OPERATIVE BANK LIMITED, NO.E.93, REPRESENTED BY ITS SECRETARY, UDUMBANNOOR.P.O., THODUPUZHA IDUKKI DISTRICT- 685595. BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682011. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682011. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.302 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 146/2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: ORUMANAYUR SERVICE CO-OPERATIVE BANK LIMITED NO.F.1456, REPRESENTED BY ITS SECRETARY, ORUMANAYUR P O, THRISSUR DISTRICT. BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER (I AND CI) AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGANCE) KOCHI, KANDAMKULATHY TOWER, M.G. ROAD, KOCHI-682011. 3 COMMISSIONER OF INCOME TAX(APPEAL) KADAVANTHRA , KOCHI-682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.303 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 243/2017 DATED 23-08-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: PANANGAD SERVICE CO-OPERATIVE BANK LIMITED NO. 655 REPRESENTED BY ITS SECRETARY, ASHA P.R, W/O SURESH BABU, AGED 51 YEARS,PANANGAD P.O.ERNAKULAM DISTRICT, PIN-682 506. BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER (1 AND C1), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-11. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.304 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 190/2016 DATED 23-08-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: UDAYAMPEROOR SERVICE CO-OPERATIVE BANK LIMITED NO.747 REPRESENTED BY ITS SECRETARY, UDAYAMPEROOR P.O, ERNAKULAM DISTRICT 682 307 BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), 5TH FLOOR, KANDAMKULATHY TOWER, M.G ROD, KOCHI 682 011 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI. KANDAMKULATHY TOWERS, M.G ROAD, KOCHI 682 011 3 COMMISSIONER OF INCOME TAX(APPEAL), KADAVANTHRA, KOCHI 682 020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.305 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 284/2017 DATED 15-11-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: CHERANALLUR SERVICE CO-OPERATIVE BANK LIMITED NO.62 REPRESENTED BY ITS SECRETARY, CHERANALLUR.P.O., ERNAKULAM DISTRICT-680307. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND CI), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682011. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI, KANDAMKULATY TOWERS, M.G.ROAD, KOCHI-682011. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.306 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 471/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: MUVATTUPUZHA SERVICE CO-OPERATIVE BANK LIMITED NO.E.781, REPRESENTED BY ITS SECRETARY, SUDHEER.K., AGED 46, S/O.KRISHNAN NAIR, MUVATTUPUZHA.P.O., ERNAKULAM DISTRICT, PIN-686661. BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER ( I AND C), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682011. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI, KANDAMKULATY TOWERS, M.G.ROAD, KOCHI-682011. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.307 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 250/2017 DATED 09-11-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: KUNNUKARA SERVICE CO-OPERATIVE BANK LIMITED NO.827, REPRESENTED BY ITS SECRETARY, SHIYAS.K.S., AGED 41 YEARS, S/O.SHAMSU, KUNNUKARA.P.O., ERNAKULAM DISTRICT-683524 BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682011. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI, KANDAMKULATY TOWERS, M.G.ROAD, KOCHI-682011. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.308 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 152/2017 DATED 23-08-2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: CHAVAKKAD SERVICE CO-OPERATIVE BANK LIMITED NO.F-9991, REPRESENTED BY ITS SECRETARY, SAJU.M.J., AGED 52, S/O.JACOB, CHAVAKKAD.P.O., THRISSUR DISTRICT-680506. BY ADVS. SRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND CI), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682011. 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.309 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 261/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: PALLIPPURAM VILLAGE SESRVICE CO-OPERATIVE BANK LIMITED NO.335, REPRESENTED BY ITS SECRETARY, PALLIPPURAM P.O, ALAPPUZHA DISTRICT. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 INCOME TAX OFFICER (INTELLIGENCE) VELLAKINAR, ALAPPUZHA-688001. 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE)KOCHI. KANDAMKULATHY TOWERS,M.G.ROAD, KOCHI-11. 3 COMMISSIONER OF INCOME TAX(APPEAL), KADAVANTHRA, KOCHI,PIN -682020. R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.311 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 217/2019 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: THODUPUZHA TOWN SERVICE CO-OPERATIVE BANK LTD. NO.I-233 BANK, REPRESENTED BY ITS SECRETARY, P.O.THODUPUZHA, IDUKKI DISTRICT-685584. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH SMT.SWATHY S. RESPONDENT/S: 1 INCOME TAX OFFICER (I AND C), 5TH FLOOR, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682 011 2 JOINT DIRECTOR OF INCOME TAX (INTELLIGENCE) KOCHI, KANDAMKULATHY TOWERS, M.G.ROAD, KOCHI-682 011 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-682 020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: IN HIGH COURT OF KERALA AT ERNAKULAM PRESENT HONOURABLE MR.JUSTICE C.K.ABDUL REHIM & HONOURABLE MR. JUSTICE AMIT RAWAL WEDNESDAY, 19TH DAY OF FEBRUARY 2020 / 30TH MAGHA, 1941 ITA.No.312 OF 2019 AGAINST ORDER/JUDGMENT IN ITA 159/2017 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/S: MULLASSERY SERVICE CO-OPERATIVE BANK LIMITED NO.R 280 REPRESENTED BY ITS SECRETARY, MULLASSERY.P.O, THRISSUR DISTRICT, PIN-680509 BY ADV. SRI.C.A.JOJO RESPONDENT/S: 1 INCOME TAX OFFICER (I AND CI), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001 2 JOINT DIRECTOR OF INCOME TAX(INTELLIGENCE) KOCHI KADAMKULATHY TOWERS, M.G.ROAD, KOCHI-682011 3 COMMISSIONER OF INCOME TAX (APPEAL), KADAVANTHRA, KOCHI-682020 R1-R3 SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 19-11-2019, ALONG WITH ITA.73/2018 AND CONNECTED CASES, COURT ON 19-02-2020 DELIVERED FOLLOWING: ITA.73/18 & con. cases 35 C.K. ABDUL REHIM & AMIT RAWAL, JJ. ------------------------------------------------- I.T.A.No.73 of 2018 & Nos.265, 270, 271, 272, 273, 274, 275, 276, 279, 280, 287, 289, 290, 291, 292, 293, 294, 295, 296, 297, 298, 299, 300, 302, 303, 304, 305, 306, 307, 308, 309, 311 & 312 of 2019 ------------------------------------------------- Dated this 19th day of February, 2020 JUDGMENT Amit Rawal, J. 1. This order shall decide 34 appeals preferred by various Co- operative Banks impugning action of Income Tax Officer (Intelligence), asking for furnishing information under Section 133(6) of Income Tax Act, 1961, hereinafter 'the Act', for short, for financial years 2010-11, 2011-12 and 2012-13. All banks, after availing statutory remedy and remained unsuccessful before Commissioner of Appeals as well as Income Tax Appellate Tribunal, have preferred these appeals, 34 in number. Tribunal decided matters on different dates; orders impugned in ITA.Nos.289/19, 290/19, 297/19, 298/19, 302/19, 303/19, 304/19, 308/19 & 312/19 on 23.8.2017; in ITA.Nos.291/19, ITA.73/18 & con. cases 36 292/19, 293/19 & 305/19 on 3.10.2017; ITA.Nos.287/19 & 294/19 on 8.11.2017; ITA No.307/19 on 9.11.2017; ITA No.73/18 on 7.6.2018; ITA No.311/19 on 20.6.2019; ITA Nos.270/19, 271/19, 273/19, 275/19, 276/19, 279/19, 280/19, 295/19, 200/19 & 309/19 on 8.7.2019; ITA No.274/19 on 20.7.2019; ITA No.272/19 on 1.8.2019; ITA Nos.299/19 and 265/19 on 7.8.2019; ITA No.306/19 on 4.9.2019 and ITA No.296/19 on 1.10.2019. 2. facts have been taken from ITA.No.73/2018, which, according to learned counsel, is lead case for adjudication of questions of law raised in all appeals. questions of law raised for consideration are as following: (1) Whether Income Tax Officer (Intelligence) is authority to issue notice U/S 133(6) of Income Tax Act to appellant prior to Notification No.77 of 2014 of CBDT dated 10.12.2014? (2)Whether notice U/S 133(6) issued by Income Tax Officer (Intelligence) is valid prior to Notification No.77 of 2014 of CBDT on delegation of power dated 10.12.2014? (3)Whether Inquiry u/s 133(6) in absence of enquiry under any of provisions of Act, conducted by Income Tax Officer ITA.73/18 & con. cases 37 (Intelligence) is right in eye of law? (4)Whether notice U/S 133(6) issued by Income Tax Officer (Intelligence) is valid in absence of formation of opinion as to whether it will be useful for or relevant to any enquiry or proceeding under Act? (5)Whether notice u/s 133(6) can be issued on appellant which is not person as per Income Tax Act? (6)Whether order passed by Joint Director of Income Tax (Intelligence) U/S 272A(2)(c) is right in eye of law? 3. learned counsel Sri.C.A.Jojo appearing on behalf of various Co-operative Banks, in support of aforementioned questions of law, raised following submissions:- i. Section 133(6) of Act empowers Assessing Officer, Deputy Commissioner (Appeals), Joint Commissioner or Commissioner (Appeals) to require firms, Hindu undivided families, trustees, any dealer, broker or agents and any person including banking company (relevant in instant case) to furnish information relating to such points or matters, statements of accounts and affairs verified in ITA.73/18 & con. cases 38 manner specified by set of officers referred to above, for giving information in relation to such points or matters, as in opinion of officers, would be useful for or relevant for purpose of enquiry or proceeding under Act. As per second proviso to aforesaid provision of law, where no proceedings are pending, power in respect of inquiry shall not be exercised by any Income-tax authority below rank of Principal Director or Director or Principal Commissioner or Commissioner other than Joint Director or Deputy Director or Assistant Director without prior approval, of Principal Director or Director or as case may be, Principal Commissioner or Commissioner. ii. Income-tax Officer (Intelligence), Kochi did not have jurisdiction to seek information vide notice dated 10.9.2013 (Annexure A) as he derives power only by notification No.77/2014 dated 10.12.2014 issued by Central Board of Direct Taxes (Annexure ITA.73/18 & con. cases 39 G). There is no delegation of power to notification placed on record empowering Income-tax Officer (Intelligence) to initiate proceedings under sub-section (6) of Section 133 nor is there any material on record justifying opinion which would be useful and relevant for purpose of proceedings. iii. expressions 'enquiry' and 'inquiry' have different connotation and cannot be read in same manner. power to hold enquiry under section 133(6) of Act vests only with Assessing Officer (emphasis supplied), Deputy Commissioner (Appeals), Joint Commissioner or Commissioner (Appeals) as case may be. proviso does not authorize Income-tax Officer (Intelligence) to make such inquiry. iv.Section 120 of Act do not envisage any power of delegation in absence of any direction of Central Board of Direct Taxes. 'enquiry' under Section 133(6) has no nexus with any 'inquiry' under Act. ITA.73/18 & con. cases 40 'Enquiry' is request for information. whereas 'inquiry' is investigation because as per statement of facts of respondents, Income-tax Officer (Intelligence) is not Assessing Officer. v. As per 'Manual of Office Procedure', responsibility for collection, collation and dissemination of information was with Central Information Branch. But vide notification dated 6.9.2013 (Annexure G attached to statement of respondents in ITA.265/19), aforementioned powers vested with Income-tax Officer (Intelligence), Kochi, to collect information, thus, role of Income-tax Officer (Intelligence) and that of Assessing Officer as per Manual of Office Procedure is totally different, but Tribunal did not address such issues, though, specifically raised in memorandum of appeals. vi. In support of aforementioned contention, counsel relied upon judgment of Hon'ble Supreme Court in Kathiroor Service Co-operative ITA.73/18 & con. cases 41 Bank Ltd. v. Commissioner of Income-Tax (CIB) and Others [(2014) 360 ITR 243 (SC)] wherein, while challenging jurisdiction of Assessing Officer under 133(6) of Act, it was specifically held that domain of holding enquiry, including issuance of notice, vested only with 'Assessing authority'. 4. Per contra, learned counsel Sri.P.K.Ravindranatha Menon appearing for Revenue relied on notification dated 19.8.2011, annexed along with statement of respondents in ITA.265/19 as (Annexure A) and contended that it envisages clause for empowering Director or Director General of Income-tax (Intelligence and Criminal Investigation) for initiation of proceedings specified under Section 120 of Act for issuance of order and directions to Income-tax authorities. 5. He buttressed his arguments, supporting action of authorities, in raising demand of penalty, as, appellants did not comply with requirement envisaged under section 133. Section 120 confers jurisdiction upon 'Income- ITA.73/18 & con. cases 42 tax Authorities' to exercise all or any of powers and perform all or any of functions, or as case may be, assigned to such authorities in accordance with directions of Board. By Clause 2 of notification dated 19.8.2011, Directors of Income-tax specified in column (2) of Schedule 2 was empowered to issue orders in writing to income-tax authorities subordinate to them for exercise of such powers under Act. 6. expression 'Income-tax Authority' is of wide amplitude and would also include 'Assessing Officer'. Notification dated 10.12.2014 empowered Director to issue orders in writing to Income-tax Officer (Intelligence) for purpose of verification only. 7. provisions of sub-section 6 of section 133 and proviso thereto cannot be read in isolation but in conjunction with section 120, particularly sub-section 2 thereof. 8. Almost identical question has been deliberated upon by Division Bench of this Court in Kodur Service Co-operative Bank Ltd. And Others v. Director of Income Tax ITA.73/18 & con. cases 43 (Intelligence) and Another [(2014) 367 ITR 22 (Ker)]. In aforementioned case, issue relating to legality of notice, was challenged, by relying upon judgment in Kathiroor Service Co-operative Bank Ltd. (supra) and it was held that as per notification dated 19.8.2011 which was in vogue, Directors of Income-tax had all powers to issue orders in writing in relation to and in connection with collection, collation, verification and dissemination of information. validity of notices under challenge and jurisdiction of Income-tax Officer (Intelligence) to issue notices, were upheld. 9. Vide order/notification dated 1.11.2011, Income-tax Officer, Thiruvananthapuram, Alappuzha, Kochi and Thrissur were authorised to function as Income-tax Officer (Intelligence) and by subsequent letter dated 2.9.2013, handed over during course of hearing, Director of Income-tax (Intelligence) authorised Income-tax Officers (Intelligence) to issue notices to Co-operative Banks/Urban Co-operative Banks/Credit Co-operative Societies, calling for ITA.73/18 & con. cases 44 information. scope of enquiry was in respect of survey. 10. It was further argued that there is no merit in appeals nor any questions of law arises for determination and prayed for dismissal of appeals. 11. We have heard counsel on both sides, perused records, appraised paper book and of view that there is no force in submissions and reasons are not one but many. 12. Before adverting to reasons, it would be in fitness of things to extract provisions of Sections 120 and 133 of Act. Jurisdiction of income-tax authorities 120. (1) Income-tax authorities shall exercise all or any of powers and perform all or any of functions conferred on, or, as case may be, assigned to such authorities by or under this Act in accordance with such directions as Board may issue for exercise of powers and performance of functions by all or any of those authorities. Explanation- For removal of doubts, it is hereby declared that any Income-tax authority, being authority higher in rank, may,if so directed by Board, exercise ITA.73/18 & con. cases 45 powers and perform functions of income tax authority lower in rank and any such direction issued by Board shall be deemed to be direction issued under sub-section (1). (2) directions of Board under sub-section (1) may authorise any other income-tax authority to issue orders in writing for exercise of powers and performance of Functions by all or any of other income-tax authorities who are subordinate to it. (3) In issuing directions or orders referred to in sub- sections (1) and (2), Board or other income-tax authority authorised by it may have regard to any one or more of following criteria, namely:- (a) territorial area; (b)persons or classes of persons; (c) incomes or classes of income; and (d) cases or classes of cases. (4) Without prejudice to provisions of sub-sections (1) and (2), Board may by general or special order, and subject to such conditions, restrictions or limitations as may be specified therein,- (a) authorise any Principal Director General or Director General or other income-tax authority as may be assigned to him by Board; (b) empower Principal Director General or Director General or Principal Director or Director to perform such functions of any "Principal Chief Commissioner or Chief ITA.73/18 & con. cases 46 Commissioner or Principal Commissioner or Commissioner to issue orders in writing that powers and functions conferred on, or as case may be, assigned to, Assessing Officer by or under this Act in respect of any specified area or persons or classes of persons or incomes or classes of income or cases or classes of cases, shall be exercised or performed by Additional Commissioner or Additional Director or Joint Commissioner or Joint Director and, where any order is made under this clause, references in any other provision of this Act or in any rule made thereunder to Assessing Officer shall be deemed to be references to such Additional Commissioner or Additional Director or Joint Commissioner or Joint Director by whom powers and functions are to be exercised or performed under such order, and any provision of this Act requiring approval or sanction of Joint Commissioner shall not apply. (5) directions and orders referred to in sub-sections (I) and (2) may wherever considered necessary or appropriate for proper management of work, require two or more Assessing Officers (whether or not of same class) to exercise and perform, concurrently, powers and functions in respect of any area or persons or classes of persons or incomes or classes of income or cases or classes of cases; and, where such powers and functions are exercised and performed concurrently by Assessing Officers of different classes, any authority lower in rank amongst them shall exercise powers and perform functions as any higher authority amongst them may direct, and, further, references in any other provision of this Act or in any rule made thereunder to Assessing Officer shall be deemed to be references to such higher authority and any provision of this Act ITA.73/18 & con. cases 47 requiring approval or sanction of any such authority shall not apply. (6) Notwithstanding anything contained in any direction or order issued this section, or in section 124, Board may, by notification in Official Gazette, direct that for purpose of furnishing of return of income or doing of any other act or thing under this Act or any rule made thereunder by any person or class of persons, income- tax authority exercising and performing powers and functions in relation to said person or class of persons shall be such authority as may be specified in notification. Power to call for information.- 133. Assessing Officer, Deputy Commissioner (Appeals), Joint Commissioner or Commissioner (Appeals) may, for purposes of this Act,- (1) require any firm to furnish him with return of names and addresses of partners of firm and their respective shares; (2) require any Hindu undivided family to furnish him with return of names and addresses of manager and members of family; (3) require any person whom he has reason to believe to be trustee, guardian or agent, to furnish him with return of names of persons for or of whom he is trustee, guardian or agent, and of their addresses; (4) require any assessee to furnish statement of names and addresses of all persons to whom he has paid in any previous year rent, interest, commission, royalty or brokerage, or any annuity, not being any annuity taxable under head Salaries amounting to more than one thousand rupees, or such higher amount as may ITA.73/18 & con. cases 48 be prescribed, together with particulars of all such payments made; (5) require any dealer, broker or agent or any person concerned in management of stock or commodity exchange to furnish statement of names and addresses of all persons to whom he or exchange has paid any sum in connection with transfer, whether by way of sale, exchange or otherwise, of assets, or on whose behalf or from whom he or exchange has received any such sum, together with particulars of all such payments and receipts; (6) require any person including banking company or any officer thereof, to furnish information in relation to such points or matters, or to furnish statements of accounts and affairs verified in manner specified by Assessing Officer, Deputy Commissioner (Appeals), Joint Commissioner or Commissioner (Appeals), giving information in relation to such points or matters as, in opinion of Assessing Officer, Deputy Commissioner (Appeals), Joint Commissioner or Commissioner (Appeals), will be useful for, or relevant to, any enquiry or proceeding under this Act: Provided that powers referred to in clause (6), may also be exercised by Principal Director General or Director General, Principal Chief Commissioner or Chief Commissioner, Principal Director or Director or Principal Commissioner or Commissioner or Joint Director or Deputy Director or Assistant Director: Provided further that power in respect of inquiry, in case where no proceeding is pending, shall not be ITA.73/18 & con. cases 49 exercised by any income-tax authority below rank of Principal Director or Director or Principal Commissioner or Commissioner, other than Joint Director or Deputy Director or Assistant Director, without prior approval of Principal Director or Director or, as case may be, Principal Commissioner or Commissioner: Provided also that for purposes of agreement referred to in section 90 or section 90A, income-tax authority notified under sub-section (2) of section 131 may exercise all powers conferred under this section, notwithstanding that no proceedings are pending before it or any other income-tax authority." (i) cumulative reading of aforesaid, particularly section 120, would reveal that Income-tax Officers are vested with powers to exercise all functions conferred upon from time to time, including Directors to issue orders in writing for exercise of powers and performance of their duties. From plain and simple perusal of sub section 2 of section 120 (emphasis supplied), it is discerned that senior officers of Income-tax authorities have power to further issue directions or orders in writing for undertaking task as per provisions of Act. Notification dated 19.8.2011 which was already in vogue prior to issuance of ITA.73/18 & con. cases 50 impugned notices, authorised Directors of Income-tax to issue orders in writing to Income-tax authorities subordinate to them, for exercise of such powers under Act. relevant portion of notification and its applicability to Kochi at Sl.No.18 reads thus: SECTION 120(1) AND (2) OF INCOME TAX ACT, 1961 - INCOME TAX AUTHORITIES - JURISDICTION OF DIRECTOR GENERAL/DIRECTOR (INTELLIGENCE & CRIMINAL INVESTIGATION) - SUPERSESSION OF NOTIFICATION NOS. S.0, 883(E), DATED 14-9-2001: S.0. 494(E), DATED 13-3-2008; S.0.855(E) AND S.O.856(E), BOTH DATED 31-5-2007 NOTIFICATION NO.42/2011 DATED 19.8-2011 In exercise of powers conferred by sub-sections (1) and (2) of section 120 of Income tax Act, 1961 [43 of 1961], and in supersession of notifications of Government of India, Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, Number(s) S.0. 883(E), dated 14 September, 2001, S.O. 494(1), dated 13th March, 2008, 8.O. 855(E), dated 31 st May, 2007 and S.O,856(E), dated 31st May, 2007, Central Board of Direct Taxes hereby directs that:- (i) Director General of Income-tax specified in column (2) of Schedule -1 annexed to this notification, having his headquarters at place specified in corresponding entries in column (3) of said Schedule ITA.73/18 & con. cases 51 shall exercise powers and perform functions in respect of such territorial area or of such persons or classes of persons or of such incomes or classes of incomes or of such cases or classes of cases, in respect of which Directors of Income-tax specified in corresponding entries in column (4) of said Schedule are having jurisdiction; (ii) Directors of Income-tax specified in column (2) annexed to this notification, having their headquarters at places specified in corresponding entries in column (3) of said Schedule-2, shall exercise powers and perform functions specified in column (5) of aforesaid Schedule in respect of territorial areas specified in column (4) of aforesaid Schedule; 2. Directors of Income-tax specified in column (2) of said Schedule-2 shall issue orders in writing to income-tax authorities subordinate to them for exercise of such powers under income-tax Act by them, which may be specified therein, in respect of territorial areas under their jurisdiction. Schedule-1 Sl. Designation of Income- Headquarters Directors of Income-tax No. tax Authorities 1 2 3 4 1 Director General of New Delhi I) Director of Income-tax (Intelligence Income-tax and Criminal Investigation, (Intelligence and Administration), Delhi Criminal Investigation), ii) Directors of Income-tax Delhi (Intelligence and Criminal Investigation) iii) Directors of Income-tax (Intelligence) ITA.73/18 & con. cases 52 Schedule-2 Sl. Designation of Headquarter Jurisdiction Powers and functions No. Income-tax s Authorities 1 2 3 4 5 1. .. .. .. .. .. 17 18 Director of Kochi, Kerala Area within All powers conferred under Income-tax State of Kerala Income-tax Act, 1961 (Intelligence), and Union related to and in connection Kochi Territory of with collection, collation, lakshadweep and verification and Minicoy dissemination of information in respect of territorial are mentioned in column(4) (ii) Though in first blush, argument of Sri.C.A.Jojo looked attractive, but on conjoint reading of contents of notifications dated 10.12.2014 and 19.8.2011, there is hardly any substance in submission that 'Income-tax Assessing Officer' would exclusively have jurisdiction to call for verification vide notices, impugned and not fall within ITA.73/18 & con. cases 53 purview of 'Income tax Authorities'. expression 'Income- tax authorities' is of wide amplitude and also include Assessing Officer as defined under Section 133 of Act. role of both authorities, besides verification, is also for collection, dissemination as well as enquiry. It is matter of record that appellants did not provide any information on receipt of impugned notice resulting into imposition of penalty. (iii) There is nothing in notification dated 19.8.2011, which would arrest power of Director of Income-tax to authorise Income-tax authorities to initiate actions. By specifying section 133, in notification dated 10.12.2014, would not mean that Income-tax authorities did not have any jurisdiction to issue impugned notice in year 2013. procedure prescribed under sub-section 6 of section 133 is akin to survey in order to ascertain whether Co-operative Banks failed to divulge information with regard to receipts of more than 5 lakhs within three immediate assessment years. ITA.73/18 & con. cases 54 (iv) Reliance on manual, it is only with regard to procedure which would not partake powers and functions of authorities enumerated in Principal Act. (v) In Kathiroor Service Bank (supra), question which came to be pondered was that it pertained to challenge of notices, issued under section 133(6) by various Income- tax authorities. In none of paras, distinction has been drawn that 'Assessing Officer' would not mean 'Income-tax Authorities'. powers under section 133(6) for repetition are in nature of survey and general enquiry to identify persons who are likely to have taxable income or whether they complied with provisions of Act. (vi) On contrary, issue raised in present appeals have, almost, been answered in Kodur Service Co- operative Bank (supra). In aforementioned judgment, no dispute was raised questioning legality of notices, whereby similarly situated cooperative banks were called upon to furnish details of entire deposits of more than Rs.5 lakhs in year for last three previous years in ITA.73/18 & con. cases 55 saving bank account, on premise, that said notice was not issued by authority specified in section 133(6) of Act. While considering aforementioned argument, Division Bench in paragraphs 6 and 7 held as follows: 6. Coming to first issue whether authority which signed exhibit P1 had power to issue such notice to various co-operative societies, we have orders and notification referred to above issued by Director of Income-tax indicating who are authorities who could discharge various functions. authority who issued exhibit P1 under section 120(2) of Income-tax Act by notification dated August 19, 2011, at SL No. 18 is Director of Income-tax, having head quarters at Kochi, Kerala, who has jurisdiction over area within State of Kerala, Union Territory of Lakshadweep and Minicoy. He has all powers envisaged under Income-tax Act related to and in connection with collection, collation, verification and dissemination of information in respect of area over which he has jurisdiction. By office order dated November 1, 2011, Income-tax Officer, Thiruvananthapuram, Alappuzha, Kochi and Thrissur were authorised to function as Income-tax Officer (Intelligence) of above three places. Letter dated September 2, 2013, is issued by Director of Income- tax (Intelligence) to above Income-tax Officers (Intelligence) authorising them to issue notices to co- operative banks/urban co-operative banks/credit co- operative societies coming under respective jurisdiction calling for information as contemplated under section 133(6) of Income-tax Act. By virtue of these ITA.73/18 & con. cases 56 documents, Income-tax Officer (Intelligence) is authorised person who could issue exhibit P1, therefore, allegation that officer who issued exhibit P1 had no authority has to be rejected. 7. Then coming to section 133(6) of Income-tax Act, in Kathiroor Service Co-operative Bank's case (supra), various co-operative societies registered under Kerala Co-operative Societies Act engaged in banking business were before this court when notices were issued to societies under section 133 (6) of Act calling for particulars of cash transaction above rupees one lakh with details of account holders/deposit holders in format prepared by authority issuing notices. societies challenged validity of notices. After referring to section 133(6) of Act, prior to introduction of second proviso and its effect and after introduction of second proviso to section 133(6), their Lordships opined that there was no scope for interfering with validity of notices. 13. From reliance on notification dated 1.11.2011, it is decipherable that power of collection, collation and dissemination which earlier vested with Central Information Branch was transferred to Income-tax officer (Intelligence), which would not mean that notices issued and imposition of penalty by Income-tax Officer (Intelligence) lacked jurisdiction. ITA.73/18 & con. cases 57 As upshot, we are of view that present appeals do not involve determination of any substantial questions. These appeals are accordingly dismissed upholding orders under challenge. There shall be no order as to costs. Sd/- C.K.Abdul Rehim, Judge Sd/- Amit Rawal, Judge kkb. APPENDIX OF ITA 73/2018 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133 (6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.09.2013 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 19.5.2014 ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 19.3.2015 ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 16.7.2014 ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 20.3.2017 ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 6.6.2017 ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO. 77/2014 CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE H TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANT ANNEXURE I CERTIFIED COPY OF ORDER OF HON'BLE ITAT DATED 7.6.2018 APPENDIX OF ITA 265/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 6.9.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 17.3.2015. ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 15.10.2015. ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 23.9.2015. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 14.5.2019. ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 16.5.2019. ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE H TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANT ON 5.8.2019. ANNEXURE I TRUE COPY OF ORDER OF HON'BLE ITAT DATED 7.8.2019. ANNEXURE J TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. ANNEXURE K TRUE COPY OF LETTER OF DEMAND ISSUED BY 4TH RESPONDENT DATED 9.10.2019. RESPONDENT'S ANNEXURES A: COPY OF NOTIFICATION S.O 1942(E) DATED 19.8.2011 B: COPY OF OFFICE ORDER DATED 1.11.2011 BY DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI C: COPY OF OFFICE ORDER DATED 1.11.2011 BY DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI D: COPY OF NOTIFICATION S.O 1942(E) DATED 19.8.2011, SUBSTITUTED ENTRIES E: COPY OF OFFICE ORDER DATED 19.2.2014 BY DIRECTOR OF INCOME TAX (INTELLIGENCE), KOCHI F: COPY OF PARAGRAPH 3, CHAPTER 8 MANUAL OF OFFICE PROCEDURE VOLUME -II G: COPY OF LETTER ISSUED BY INCOME TAX OFFICER (INTELLIGENCE) TO APPELLANT DATED 6.9.2013 APPENDIX OF ITA 270/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S. 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 02.09.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 23.03.2015. ANNEXURE C TRUE COPY OF REPLAY SUBMITTED TO 1ST RESPONDENT DATED 04.04.2015. ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S. 156, ISSUED BY 2ND RESPONDENT DATED 22.12.2015. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019. ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HONBLE ITAT COCHIN BENCH DATED 07.05.2019 ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO. 77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE H TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANTS. ANNEXURE I TRUE COPY OF ORDER OF HONBLE ITAT DATED 08.07.2019. ANNEXURE J TRUE COPY OF STAY ORDER OF THIS HONBLE COURT IN ITA NO. 73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 271/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 25.9.2014. ANNEXURE B TRUE COPY OF PENALTY ORDER ISSUED BY 2ND RESPONDENT DATED 25.8.2015. ANNEXURE C TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.2.2019. ANNEXURE D TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 8.3.2019. ANNEXURE E TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE F TRUE COPY OF ARGUMENT NOTE SUBMITTED BY APPELLANT. ANNEXURE G TRUE COPY OF ORDER OF HON'BLE ITAT DATED 8.7.2019. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 272/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 02/09/2013. ANNEXURE B TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 22/12/2015. ANNEXURE C TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26/02/2019. ANNEXURE D TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 20/03/2019. ANNEXURE E TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10/12/2014. ANNEXURE F TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANTS. ANNEXURE G ORIGINAL COPY OF ORDER OF HON'BLE ITAT DATED 01/08/2019. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29/11/2018. APPENDIX OF ITA 273/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE(INTELLIGENCE) DATED 02.09.2013 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 08.04.2015 ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 22.12.2015 ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019 ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 27.05.2019 ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE G TRUE COPY OF ARGUMENT NOTE SUBMITTED BY APPELLATE ANNEXURE H ORIGINAL COPY OF ORDER OF HON'BLE ITAT DATED 08.07.2019 ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73/2018 DATED 29.11.2018 APPENDIX OF ITA 274/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 18.9.2013 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY IST RESPONDENT DATED 5.2.2015. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 25.8.2015. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 30.1.2019. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 18.3.2019. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G TRUE COPY OF ARGUMENT NOTE DATED 20.5.2019 SUBMITTED BY APPELLANT. ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 20.7.2019. ANNEXURE I TRUE COPY OF LETTER OF DEMAND NO.ITBA/COM/F/17/2019-20/1019317244(1) DATED 23.10.2019. ANNEXURE J TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT INITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 275/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE(INTELLIGENCE) DATED 23.10.2013 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 23.03.2015 ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 22.12.2015 ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019 ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 27.05.2019 ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE G TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLATE ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 08.07.2019 ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73/2018 DATED 29.11.2018 APPENDIX OF ITA 276/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133 (6) ISSUED BY INCOME TAX OFFICE INTELLIGENCE DATED 02.09.2013. ANNEXURE B TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 27.10.2014. ANNEXURE C ORIGINAL COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019. ANNEXURE D TRUE COPY OF APPEAL FILED BEFORE HONBLE ITAT COCHIN BENCH DATED 07.03.2019. ANNEXURE E TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO. 77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE F TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANTS. ANNEXURE G TRUE COPY OF ORDER OF HONBLE ITAT DATED 08.07.2019. ANNEXURE H TRUE COPY OF LETTER OF DEMAND ISSUED BY 4TH RESPONDENT DATED 03.10.2019. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HONBLE COURT IN ITA NO. 73 OF 2018 DATED 29.11.2018 APPENDIX OF ITA 279/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.09.2013 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1st RESPONDENT DATED 19.5.2014 ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 05.02.2015 ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019 ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 10.5.2019 ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE G TRUE COPY OF ARGUMENT NOTE SUBMITTED BY APPELLANT DATED 08.07.2019 ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 08.07.2019 ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018 APPENDIX OF ITA 280/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S.133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 2.9.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 23.3.2015. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S.156, ISSUED BY 2ND RESPONDENT DATED 22.12.2015. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.2.2019. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 8.4.2019. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANT DATED 8.7.2019. ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 8.7.2019. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 287/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.09.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 20.05.2014. ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 28.05.2014. ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 27.10.2014. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 31.03.2017. ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 12.05.2017. ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 08.11.2017. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 289/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10-09-2013 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 19-05-2014 ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 24-09-2015 ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S. 156, ISSUED BY 2ND RESPONDENT DATED 19-09-2014 ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 30-06-2015 ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 20-07-2015 ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO. 77/2014 CBDT NOTIFICATION DATED 10-12-2014 ANNEXURE II TRUE COPY OF ARGUMENT NOTE DATED 17-08- 2017 ANNEXURE I true copy of order of hon'ble ITAT dated 23-08-2017 ANNEXURE j TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA N. 73 OF 2018 DATED 29-11-2018 APPENDIX OF ITA 290/2019 PETITIONER'S/S EXHIBITS: ANNEXURE TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 08.11.2013. ANNEXURE B TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 27.11.2014. ANNEXURE C TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 20.03.2017. ANNEXURE D TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 25.04.2017. ANNEXURE E TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE F TRUE COPY OF ORDER OF HON'BLE ITAT DATED 23.08.2017. ANNEXURE G TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 291/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE UNDER SECTION 133(6) ISSUED BY INCOME TAX OFFICE(INTELLIGENCE) DATED 05.09.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 19.05.2014. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND UNDER SECTION 156, ISSUED BY 2ND RESPONDENT DATED 15.09.2014. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 21.03.2017. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 23.04.2017. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G ORIGINAL COPY OF ORDER OF HON'BLE ITAT DATED 03.10.2017. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 292/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.09.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 20.05.2014. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 16.07.2014. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 31.03.2017. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 09.05.2017. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G TRUE COPY OF ORDER OF HON'BLE ITAT DATED 03.10.2017. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 293/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE UNDER SECTION 133(6) ISSUED BY INCOME TAX OFFICE(INTELLIGENCE) DATED 08.11.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 23.10.2014. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND UNDER SECTION 156, ISSUED BY 2ND RESPONDENT DATED 27.11. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 20.03.2017. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 12.05.2014. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G CERTIFIED COPY OF ORDER OF HON'BLE ITAT DATED 03.10.2017 IN ITA 2011/COCHIN/2017. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 294/2019 PETITIONER'S/S EXHIBITS: ANNEXURE-A TRUE COPY OF NOTICE U/S. 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 0.09.2013 ANNEXURE-B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 20.05.2014 ANNEXURE-C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 25.09.2013 ANNEXURE-D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S.156,ISSUED BY 2ND RESPONDENT DATED 16.07.2014 ANNEXURE-E TUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 20.03.2017 ANNEXURE-F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 19.05.2017 ANNEXURE-G TRUE COPY OF RELEVANT PAGE OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE-H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 08.11.2017 ANNEXURE-I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018 APPENDIX OF ITA 295/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 23.10.2013. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 10.04.2015 ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 21.03.2019. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G TRUE COPY OF HON'BLE ITAT DATED 08.07.2019. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 296/2019 PETITIONER'S/S EXHIBITS: ANNEXURE-A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.09.2013 ANNEXURE-B TRUE COPY F SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 19.05.2014 ANNEXURE-C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S.156,ISSUED BY 2ND RESPONDENT DATED 25.02.2015 ANNEXURE-D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019 ANNEXURE-E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 07.06.2019 ANNEXURE-F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014/CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE-G TRUE COPY OF ORDER OF HON'BLE ITAT DATED 01.10.019 ANNEXURE-H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018 APPENDIX OF ITA 297/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133 (6) ISSUED BY INCOME TAX OFFICE INTELLIGENCE DATED 02.09.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 19.06.2014. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S. 156, ISSUED BY 2ND RESPONDENT DATED 04.08.2014. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 06.11.2015. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HONBLE ITAT COCHIN BENCH DATED 15.12.2015. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO. 77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G ORIGINAL COPY OF ORDER OF HONBLE ITAT DATED 23.8.2017. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HONBLE COURT IN ITA NO. 73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 298/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE UNDER SECTION 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.09.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 19.05.2014. ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT BY APPELLANT DATED 27.01.2014. ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND UNDER SECTION 156, ISSUED BY 2ND RESPONDENT DATED 11.19.2014. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 25.04.2017. ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 16.05.2017. ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE H ORIGINAL COPY OF ORDER OF HON'BLE ITAT DATED 23.08.2017. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 299/2019 PETITIONER'S/S EXHIBITS: ANNEXURE TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE)DATED 02-09-2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 07-09-2015. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 15+6, ISSUED BY 2ND RESPONDENT DATED 23-09-2015. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 04-05-2019. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN COCHIN BENCH DATED 26- 06-2019. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO. 77/2014 CBDT NOTIFICATION DATED 10-12-2014. ANNEXURE G TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANT DATED 07-08-2019. ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 07-08-2019. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO. 73 OF 2018 DATED 29-11-2018. APPENDIX OF ITA 300/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S.133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 18.9.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 12.6.2015. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S.156, ISSUED BY 2ND RESPONDENT DATED 20.8.2015. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 29.1.2019. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 21.3.2019. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G TRUE COPY OF ARGUMENT NOT SUBMITTED BY APPELLANT DATED 27.6.2019. ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 8.7.2019. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 302/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S. 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 06.09.2013. ANNEXURE B TRUE COPY OF PENALTY ORDER WITH DEMAND U/S. 156, ISSUED BY 2ND RESPONDENT DATED 27.11.2014. ANNEXURE C TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 20.03.2017. ANNEXURE D TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COHIN BENCH DATED 22.04.2017. ANNEXURE E TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE F TRUE COPY OF ORDER OF HON'BLE ITAT DATED 23.08.2017. ANNEXURE G TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 303/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133 (6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.1.2014 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 20.5.2014 ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 27.5.2014 ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 27.11.2014 ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 4.3.2016 ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 23.5.2016 ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO 77/2014 CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 23.8.2017 ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO 73 OF 2018 DATED 29.11.2018 APPENDIX OF ITA 304/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 16-09-2014 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 20-05-2014 ANNEXURE TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 30-09-2014 ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S. 156, ISSUED BY 2ND RESPONDENT DATED 25-09-2014. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 29-01-2016 ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 13-04-2016 ANNEXURE TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO. 77/2014 CBDT NOTIFICATION DATED 10-12-2014 ANNEXURE H original COPY OF ORDER OF HON'BLE ITAT DATED 23-08--2017 ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO. 73 OF 2018 DATED 29-11-2018 APPENDIX OF ITA 305/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S.133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.9.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 19.5.2014. ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 25.1.2014. ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 15.9.2014. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 25.4.2017. ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 11.5.2017. ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE H ORIGINAL COPY OF ORDER OF HON'BLE ITAT DATED 3.10.2017. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 306/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S.133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.1.2014. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 1.7.2014. ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 28.5.2014. ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 16.7.2014. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.2.2019. ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 20.7.2019. ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE H TRUE COPY OF ORDER OF HON'BLE ITAT DATED 4.9.2019. ANNEXURE I TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 307/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S.133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 10.9.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 2ND RESPONDENT DATED 12.8.2014. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 19.9.2014. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 21.3.2017. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 9.5.2019. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G CERTIFIED COPY OF ORDER OF HON'BLE ITAT DATED 9.11.2017. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 308/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S.133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 6.9.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 23.10.2014. ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156, ISSUED BY 2ND RESPONDENT DATED 27.11.2014. ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 20.3.2017. ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 22.4.2017. ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE G TRUE COPY OF ORDER OF HON'BLE ITAT DATED 23.8.2017. ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 309/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE(INTELLIGENCE) DATED 02.09.2013 ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 17.03.2015 ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 09.10.2015 ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S 156,ISSUED BY 2ND RESPONDENT DATED 23.09.2015 ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 26.02.2019 ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 02.04.2019 ANNEXUREMG TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE H TRUE COPY OF ARGUMENT NOTE SUBMITTED BY APPELLANTS ANNEXURE I TRUE COPY OF ORDER OF HON'BLE ITAT DATED 08.07.2019 ANNEXURE J TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 311/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S.133(6) ISSUED BY INCOME TAX OFFICE (INTELLIGENCE) DATED 18.9.2013. ANNEXURE B TRUE COPY OF SHOW CAUSE NOTICE ISSUED BY 2ND RESPONDENT DATED 5.2.2015. ANNEXURE C TRUE COPY OF REPLY SUBMITTED TO 1ST RESPONDENT DATED 18.3.2015. ANNEXURE D TRUE COPY OF PENALTY ORDER WITH DEMAND U/S.156, ISSUED BY 2ND RESPONDENT DATED 25.8.2015. ANNEXURE E TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 29.1.2019. ANNEXURE F TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 22.3.2019. ANNEXURE G TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014. ANNEXURE H TRUE COPY OF ARGUMENT NOTE DATED 20.6.2019 SUBMITTED BY APPELLANT. ANNEXURE I CERTIFIED COPY OF ORDER OF HON'BLE ITAT DATED 20.6.2019. ANNEXURE J TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73 OF 2018 DATED 29.11.2018. APPENDIX OF ITA 312/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A TRUE COPY OF NOTICE U/S 133(6) ISSUED BY INCOME TAX OFFICE(INTELLIGENCE) DATED 06.09.2013 ANNEXURE B TRUE COPY OF TH SHOW CAUSE NOTICE ISSUED BY 1ST RESPONDENT DATED 23.10.2014 ANNEXURE C TRUE COPY OF PENALTY ORDER WITH DEMAND/S156, ISSUED BY 2ND RESPONDENT DATED 27.11.2014 ANNEXURE D TRUE COPY OF APPELLATE ORDER OF 3RD RESPONDENT DATED 20.03.2017 ANNEXURE E TRUE COPY OF APPEAL FILED BEFORE HON'BLE ITAT COCHIN BENCH DATED 22.04.2017 ANNEXURE F TRUE COPY OF RELEVANT PAGES OF CBDT NOTIFICATION NO.77/2014 CBDT NOTIFICATION DATED 10.12.2014 ANNEXURE G TRUE COPY OF ORDER OF HON'BLE ITAT DATED 23.08.2017 ANNEXURE H TRUE COPY OF STAY ORDER OF THIS HON'BLE COURT IN ITA NO.73/2018 DATED 29.11.2018 Enanalloor Service Co-Operative Bank Limited v. Income-tax Officer (1 and C), Kochi / Joint Director Director of Income-tax (Intelligence), Kochi / CIT(A), Kochi