By Advs.sri.harisankar v. Menonsmt.meera V.menon

IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.209 OF 2019 AGAINST THE ORDER IN ITA 329/COCH/2018 DATED 18-02-2019 OF INCOMETAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN APPELLANT/APPELLANT/ASSESSEE: M/S.POPULAR DEALERSPOPULAR TOWERS, VAKAYAR P.O, KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER(TDS), ALAPPUZHA-688 011 SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.210/2019 AND CONNECTED CASES, THE COURTON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20192 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.210 OF 2019 AGAINST THE ORDER IN ITA 321/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S. POPULAR TRADERSPOPULAR TOWERS, VAKAYAR P. O., KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. REPRESENTED BY ITS MANAGING PARTNER, BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICERTDS, ALAPPUZHA - 688 011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20193 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.212 OF 2019 AGAINST THE ORDER IN ITA 325/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S.POPULAR PRINTERS,POPULAR TOWERS, VAKAYAR P.O., KONNI, PATHANAMTHITTAREPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER (TDS),ALAPPUZHA- 688011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20194 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.220 OF 2019 AGAINST THE ORDER IN ITA 324/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S POPULAR TRADERSPOPULAR TOWERS, VAKAYAR P.O, KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER, TDS, ALAPPUZHA - 688 011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.No.220 OF 2019 AGAINST THE ORDER IN ITA 324/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S POPULAR TRADERSPOPULAR TOWERS, VAKAYAR P.O, KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER, TDS, ALAPPUZHA - 688 011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20195 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.221 OF 2019 AGAINST THE ORDER IN ITA 328/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: POPULAR PRINTERSPOPULAR TOWERS, VAKAYAR P.O., KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER (TDS)OPPOSITE GENERAL HOSPITAL, ALAPPUZHA - 688 011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20196 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.222 OF 2019 AGAINST THE ORDER IN ITA 323/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S POPULAR TRADERSPOPULAR TOWERS, VAKAYAR P.O., KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. REPRESENTED BY ITS MANAGING PARTNER, BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER ALAPPUZHA - 688 011. TDS, OPPOSITE GENERAL HOSPITAL, SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20197 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.224 OF 2019 AGAINST THE ORDER IN ITA 331/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S.POPULAR DEALERSPOPULAR TOWERS, VAKAYAR P.O, KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER, (TDS), ALAPPUZHA-688 011 SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20198 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI APPELLANT/APPELLANT/ASSESSEE: M/S.POPULAR DEALERSPOPULAR TOWERS, VAKAYAR P.O, KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER, (TDS), ALAPPUZHA-688 011 SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20198 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.226 OF 2019 AGAINST THE ORDER/JUDGMENT IN ITA 322/COCH/2018 DATED 18-02-2019OF INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S.POPULAR TRADERSPOPULAR TOWERS, VAKAYAR P.O, KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICERTDS, OPP.GENERAL HOSPITAL,ALAPPUZHA, 688011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/20199 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.227 OF 2019 AGAINST THE ORDER IN ITA 326/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S.POPULAR PRINTERS,POPULAR TOWERS, VAKAYAR P.O., KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER (TDS),ALAPPUZHA - 688 011 SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201910 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.230 OF 2019 AGAINST THE ORDER IN ITA 330/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S.POPULAR DEALERSPOPULAR TOWERS, VAKAYAR.P.O,KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER,THOMAS DANIEL. BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER,(TDS)ALAPPUZHA-688011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201911 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.233 OF 2019 AGAINST THE ORDER IN ITA 327/COCH/2018 DATED 18.02.2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER,(TDS)ALAPPUZHA-688011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201911 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.233 OF 2019 AGAINST THE ORDER IN ITA 327/COCH/2018 DATED 18.02.2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: POPULAR PRINTERSPOPULAR TOWERS, VAKAYAR.P.O., KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. REPRESENTED BY ITS MANAGING PARTNER, BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER (TDS)ALAPPUZHA - 688011 SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201912 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR. JUSTICE T.R.RAVI TUESDAY, THE 09TH DAY OF JUNE 2020 / 19TH JYAISHTA, 1942 ITA.No.234 OF 2019 AGAINST THE ORDER IN ITA 332/COCH/2018 DATED 18-02-2019 OFINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH APPELLANT/APPELLANT/ASSESSEE: M/S. POPULAR DEALERS,POPULAR TOWERS, VAKAYAR P.O., KONNI, PATHANAMTHITTA, REPRESENTED BY ITS MANAGING PARTNER, THOMAS DANIEL. REPRESENTED BY ITS MANAGING PARTNER, BY ADVS.SRI.HARISANKAR V. MENONSMT.MEERA V.MENON RESPONDENT/RESPONDENT/REVENUE: THE INCOME TAX OFFICER (TDS),ALAPPUZHA - 688 011. SRI.CHRISTOPHER ABRAHAM, SC, IT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON09.06.2020, ALONG WITH ITA.209/2019 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 13 JUDGMENT Dated this the 9[th] day of June, 2020 T.R.RAVI, J. Three different assessees, which are partnership firms, have filed the appeals against a common order of the Income-tax AppellateTribunal, Cochin Bench. The orders relate to the assessment years2013-14 to 2016-17. A common question is raised in all theseappeals and hence they are heard and disposed of together. 2.The assessees have been accepting loans in the form ofdeposits and paying interest on such borrowings. Even though theassesses were required to deduct tax on the interest paid underSection 194A of the Income-tax Act, they have failed to do so. TheAssessing Officer proceeded to assess the appellants treating them asassessees in default under Section 201 of the Income-tax Act. Eventhough the appellants challenged the assessment orders before theAppellate Authority, the same were dismissed and further appealsbefore the Income-Tax Appellate Tribunal have also been dismissed asper the orders impugned in these appeals. 3.Heard Sri Harisankar V.Menon on behalf of the appellants ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 and Sri Christopher Abraham on behalf of the respondents. 3.Heard Sri Harisankar V.Menon on behalf of the appellants ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 and Sri Christopher Abraham on behalf of the respondents. 4.The main contention of the counsel for the appellants isthat the Assessing Authority ought to have confirmed the failure ofthe 'payee-assessee' to pay the tax directly as per Section 191 of theIncome-tax Act, before declaring the 'deductor-assessee' as anassessee-in-default under Section 201. It was also contended thatthe authorities have failed to fix the liability on the correct personwho is responsible for deduction of tax at source, as the firms havemany Managers, who were actually responsible for the same.According to the counsel, the fixing of liability on the assessee and itspartners as assessee-in-default was hence not in accordance with law.The counsel for the Department on the other hand contended thatSection 194A obliges the person who is paying the interest to deductincome-tax thereon at the rates in force and a failure to do so willimmediately lead, to the said person who is liable to deduct, beingdeemed to be an assessee-in-default in respect of such tax. 5. The following questions of law arise for consideration inthese appeals: (a) Whether on the facts and in the circumstances of the case, has not the Tribunal erred in holding that ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201915 burden of proof lies on the appellant in terms of the first proviso to Section 201(1) of the Income Tax Act, 1961? (b)Whether on the facts and circumstances of thecase the assessment impugned herein is against theprinciples laid down in Jagran Prakash Ltd. v. DCIT(TDS) 345 ITR 288? (c)Ought not the learned Tribunal have held thatSection 201 is found on the instance when thedeductee/payee fails to pay the tax on the paymentmade by the deductor or fails to show the same in thereturn filed? (d)Ought not the learned Tribunal have held that theassessing authority passed a vague order in respect ofliability of the appellant along with Principal Officer,partner and Managing Partner to deduct tax U/s.194A?(e)Are not the findings of the learned Tribunalperverse and against the provisions of the Income TaxAct, 1961? 6.The relevant portions of Sections 194A and 201 areextracted below: ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 “194A. Interest other than “Interest on securities”. (1) Any person, not being an individual or a Hindu undividedfamily, who is responsible for paying to a resident any incomeby way of interest other than income by way of interest onsecurities, shall, at the time of credit of such income to theaccount of the payee or at the time of payment thereof incash or by issue of a cheque or draft or by any other mode,whichever is earlier, deduct income-tax thereon at the ratesin force . (2) Omitted by the Finance Act, 1992 w.e.f. 1.6.1992. (3) The provisions of sub-section (1) shall not apply— (i) where the amount of such income or, as the case may be,the aggregate of the amounts of such income credited or paidor likely to be credited or paid during the financial year by theperson referred to in sub-section (1) to the account of, or to,the payee, does not exceed— (a) forty thousand rupees, where the payer is a bankingcompany to which the Banking Regulation Act, 1949 (10 of1949) applies (including any bank or banking institution,referred to in section 51 of that Act); (b) forty thousand rupees, where the payer is a co-operativesociety engaged in carrying on the business of banking; (2) Omitted by the Finance Act, 1992 w.e.f. 1.6.1992. (3) The provisions of sub-section (1) shall not apply— (i) where the amount of such income or, as the case may be,the aggregate of the amounts of such income credited or paidor likely to be credited or paid during the financial year by theperson referred to in sub-section (1) to the account of, or to,the payee, does not exceed— (a) forty thousand rupees, where the payer is a bankingcompany to which the Banking Regulation Act, 1949 (10 of1949) applies (including any bank or banking institution,referred to in section 51 of that Act); (b) forty thousand rupees, where the payer is a co-operativesociety engaged in carrying on the business of banking; (c) forty thousand rupees, on any deposit with post officeunder any scheme framed by the Central Government andnotified by it in this behalf; and (d) five thousand rupees in any other case.” xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 201. Consequences of failure to deduct or pay. (1)Where any person, including the principal officer of a ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, company,— (a) who is required to deduct any sum inaccordance with the provisions of this Act; or accordance with the provisions of this Act; or (b) referred to in sub-section (1A) of section 192, being an employer, does not deduct, or does not pay, or after so deducting fails to pay, the whole or any part of the tax, as required by orunder this Act, then, such person, shall, without prejudice toany other consequences which he may incur, be deemed tobe an assessee-in-default in respect of such tax. Provided that any person, including the principal officer of a company, who fails to deduct the whole or any part of the taxin accordance with the provisions of this Chapter on the sumpaid to a payee or on the sum credited to the account of apayee shall not be deemed to be an assessee-in-default inrespect of such tax if such payee- (i)has furnished his return of income undersection 139section 139 (ii) has taken into account such sum forcomputing income in such return of income; andcomputing income in such return of income; and (iii)has paid the tax due on the income declaredby him in such return of income,by him in such return of income, and the person furnishes a certificate to this effect from an accountant in such form as may be prescribed.” 7.Section 194A is categoric when it says that any person who is responsible for paying to a resident any income by way of interestother than income by way of interest on securities, shall deductincome-tax thereon at the rates in force, at the time of credit of such ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, (ii) has taken into account such sum forcomputing income in such return of income; andcomputing income in such return of income; and (iii)has paid the tax due on the income declaredby him in such return of income,by him in such return of income, and the person furnishes a certificate to this effect from an accountant in such form as may be prescribed.” 7.Section 194A is categoric when it says that any person who is responsible for paying to a resident any income by way of interestother than income by way of interest on securities, shall deductincome-tax thereon at the rates in force, at the time of credit of such ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, income to the account of the payee. It can be seen from sub-section(3) of Section 194A that the Legislature has carved out the cases inwhich such deduction need not be made. Admittedly, the case of theappellants does not come under any of the categories identified insub-section (3). As such, the appellants cannot contend that they arenot liable to deduct the tax at the time of payment of the interestincome to its customers. A reading of Section 201, again, clearlyshows that the failure to deduct such tax will entail the consequenceof such person being deemed to be an assessee-in-default in respectof such tax. The first proviso to Section 201 was added by theFinance Act, 2012 with effect from 01.07.2012. As per the proviso, aperson who fails to deduct such tax shall not be deemed to be anassessee-in-default, if it satisfies the conditions stated in the proviso.As per the proviso, the payee in such cases ought to have furnishedhis return of income under Section 139, takinginto account such sumfor computing income in such return of income, and, paid the tax dueon the income declared by him in such return of income. It is alsoprovided that the assessee(deductor) should furnish a certificate tothis effect from an Accountant in such form, as may be prescribed.Admittedly, the appellants have not furnished any such certificate as ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201919 required by the Statute. Having not complied with the conditions laid down in Section 201, the appellants are not entitled to contend thatthey should not be treated as assessee-in-default under Section 201. 8.The appellantshavea contention that the AssessingAuthority ought to have confirmed the failure of the payee-assesseeto pay tax directly as per Section 191 before declaring the appellantsas assessee-in-default. Section 191 of the Act is extracted below: “191. Direct payment. In the case of income in respect ofwhich provision is not made under this Chapter for deductingincome-tax at the time of payment, and in any case whereincome-tax has not been deducted in accordance with theprovisions of this Chapter, income-tax shall be payable by theassessee direct. Explanation.—For the removal of doubts, it is herebydeclared that if any person including the principal officer of acompany,— (a) who is required to deduct any sum inaccordance with the provisions of this Act; or accordance with the provisions of this Act; or (b) referred to in sub-section (1A) of section 192, being an employer, does not deduct, or after so deducting fails to pay, or doesnot pay, the whole or any part of the tax, as required by orunder this Act, and where the assessee has also failed topay such tax directly, then, such person shall, withoutprejudice to any other consequences which he may incur, bedeemed to be an assessee-in-default within the meaning of ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 (a) who is required to deduct any sum inaccordance with the provisions of this Act; or accordance with the provisions of this Act; or (b) referred to in sub-section (1A) of section 192, being an employer, does not deduct, or after so deducting fails to pay, or doesnot pay, the whole or any part of the tax, as required by orunder this Act, and where the assessee has also failed topay such tax directly, then, such person shall, withoutprejudice to any other consequences which he may incur, bedeemed to be an assessee-in-default within the meaning of ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 sub-section (1) of section 201, in respect of such tax.” Section 191 only says that in case of failure to deduct income-tax atthe time of payment, income-tax shall be payable by the assesseedirect. The Explanation to the Section says that if a person does notdeduct the tax as required under the Act and where the assessee hasalso failed to pay such tax directly, then such person shall withoutprejudice to any other consequences which he may incur, be deemedto be an assessee-in-default within the meaning of sub-section (1) ofSection 201. It can thus be seen that there is no requirement underthe Statute that the Assessing Officer should ensure whether thepayee has directly paid tax before declaring the appellants asassessee-in-default. As a matter of fact, the appellants by operationof Section 201 will be deemed to be assessee-in-default, even withoutany such declaration by the Assessing Officer. 9.The counsel for the appellants places reliance on thejudgment of the High Court of Allahabad in Jagran Prakashan Ltd.v. Deputy Commissioner of Income-tax (TDS) reported in [2012(21) Taxman.com.489 (Allahabad) in support of his contention.It can be seen that the judgment was rendered in a case whichrelates to the assessment years 2009-10 and 2010-11. The provisoto Section 201 came into force only in 2012. As such, no reliance can ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201921 be placed on the above judgment, since the statutory provision itself has undergone a change in the relevant assessment yearand theSection as it stood at the time action was taken against theappellants, created a fiction by deeming such persons who defaultedin deducting tax at the time of payment of interest, as assessee-in-default. The burden to prove that the payee-assessee had paid thetax, which the assessee-deductor failed to deduct was placed on thelatter; by production of a certificate from the Accountant. Thequestions (a) to (c) are thus answered against the assessee and infavour of the Revenue. 10.The appellants have a further contention that the orders ofthe authorities are vague in the sense that it does not fix the liabilityto pay the tax on the correct person. According to the appellants, theauthorities ought not to have fixed the liability on the assessee and itspartners and thereafter issued demand only against the ManagingDirector. We do not find anything illegal or inappropriate in suchdirection. In CIT v. R.M. Chidambaram Pillai reported in (1977) 1SCC 431, the Hon'ble Supreme Court observed as follows:- “5. First principles plus the bare text of the statute furnishthe best guidelight to understanding the message and-meaning of the provisions of law. Thereafter, the ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201922 sophisticated exercises in precedents and booklore. Here “5. First principles plus the bare text of the statute furnishthe best guidelight to understanding the message and-meaning of the provisions of law. Thereafter, the ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201922 sophisticated exercises in precedents and booklore. Here the first thing that we must grasp is that a firm is not alegal person even though it has some attributes ofpersonality. Partnership is a certain relation betweenpersons, the product of agreement to share the profits ofa business. “Firm” is a collective noun, a compendiousexpression to designate an entity, not a person. In incometax law a firm is a unit of assessment, by specialprovisions, but is not a full person; which leads to the nextstep that since a contract of employment requires twodistinct persons viz. the employer and the employee,there cannot be a contract of service, in strict law,between a firm and one of its partners.” It is settled law that a partnership is neither a natural person nor a juristic person. It has no separate existence than its partners. The liability of a partnership firm is the liability of its partners. As such,fixing the liability of the firm on its partners can never be held to beillegal. In fact, it necessarily has to be fixed on the partners. In thelight of the legal nature of a partnership firm, a demand raised on the Managing Partner can never be visualised as a wrong fixation ofliability. It can only be seen as a demand made on the person who ismanaging the affairs of the firm, for and on behalf of all its partners.Such a demand does not in any way amount to a conclusion that theclaim against the other partners has been given up, since the liability ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 23 of the partners is joint and several. We do not find any perversity in the findings of the AppellateTribunal. The questions (d) and (e) raised in the appeal are answeredagainst the assessee and in favour of the Revenue. The appeals aredismissed, however, without any order as to costs. Sd/-K. VINOD CHANDRAN JUDGE Sd/- T.R. RAVI JUDGE dsn ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201924 APPENDIX OF ITA 209/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENTFOR THE YEAR 2013-14 DATED 17.05.2016. ANNEXURE BCOPY OF ORDER ISSUED BY THE COMMISSIONER OF INCOME TAX (APPEALS), KOTTAYAM DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA NO. 329/COCH/2018 FORTHE YEAR 2013-14 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 25 APPENDIX OF ITA 210/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2013-14 DATED 17.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA NO.321/COCH/2018 FOR THE YEAR 2013-14 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 APPENDIX OF ITA 212/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2013-14 DATED 17.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM, DATED 06.04.2018. ANNEXURE C COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2013-14 DATED 17.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA NO.321/COCH/2018 FOR THE YEAR 2013-14 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 APPENDIX OF ITA 212/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2013-14 DATED 17.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM, DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA.NO.325/COCH/2018 FOR THE YEAR 2013-14 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 27 APPENDIX OF ITA 220/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE IST RESPONDENT FOR THE YEAR 2016-17 DATED 12.8.2016 ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 6.4.2018. ANNEXURE C COPY OF ORDER IN ITA NO.324/COCH/2018 FOR THE YEAR 2016-17 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.2.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, APPENDIX OF ITA 221/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE IST RESPONDENT FOR THE YEAR 2016-17 DATED 31.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 6.4.2018. ANNEXURE C COPY OF ORDER IN ITA NO.328/COCH/2018 FOR THE YEAR 2016-17 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.2.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201929 APPENDIX OF ITA 222/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE IST RESPONDENT FOR THE YEAR 2015-16 DATED 31.5.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 6.4.2018. ANNEXURE C COPY OF ORDER IN ITA NO.323/COCH/2018 FOR THE YEAR 2015-16 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.2.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201930 APPENDIX OF ITA 224/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2015-16 DATED 31.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA NO.331/COCH/2018 FOR THE YEAR 2015-16 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 31 APPENDIX OF ITA 226/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2014-15 DATED 23.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX(APPEALS) KOTTAYAM DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA NO.322/COCH/2018, FOR THE YEAR 2014-15 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/2019 31 APPENDIX OF ITA 226/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2014-15 DATED 23.05.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX(APPEALS) KOTTAYAM DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA NO.322/COCH/2018, FOR THE YEAR 2014-15 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201932 APPENDIX OF ITA 227/2019 PETITIONER'S/S EXHIBITS: ANNEXURE-A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2014-15 DATED 23.05.2016 ANNEXURE-B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 06.04.2018 ANNEXURE-C COPY OF ORDER IN ITA NO. 326/COCH/2018 FOR THE YEAR 2014-15 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019 ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201933 APPENDIX OF ITA 230/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2014-15 DATED 23.05.2016 ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX(APPEALS), KOTTAYAM DATED 06.04.2018 ANNEXURE C COPY OF ORDER IN ITA NO.330/COCH/2018 FOR THE YEAR 2014-15 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019. ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201934 APPENDIX OF ITA 233/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT OF THE YEAR 2015-16 DATED 31.05.2016 ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX(APPEALS), KOTTAYAM DATED 06.04.2018 ANNEXURE C COPY OF ORDER IN ITA NO.327/COCH/2018 FOR THE YEAR 2015-16 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019 ITA.209/2019, ITA.210/2019, ITA.212/2019, ITA.220/2019, ITA.221/2019, ITA.222/2019, ITA.224/2019, ITA.226/2019, ITA.227/2019, ITA.230/2019, ITA.233/2019 & ITA.234/201935 APPENDIX OF ITA 234/2019 PETITIONER'S/S EXHIBITS: ANNEXURE A COPY OF ORDER ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2016-17 DATED 12.08.2016. ANNEXURE B COPY OF ORDER ISSUED BY THE COMMISSIONER OFINCOME TAX (APPEALS), KOTTAYAM DATED 06.04.2018. ANNEXURE C COPY OF ORDER IN ITA NO.332/COCH/2018 FOR THE YEAR 2016-17 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN DATED 18.02.2019.