Corporation Bank,Rep. By Its Authorised Officer/Assistant General Manager,Old v. The Commissioner,Income Tax Department,Investigation Building

IN THE HIGH COURT OF JUDICATURE AT MADRASReserved on : 01.04.2021 Pronounced on: 21.04.2021 CORAM THE HONOURABLE DR. JUSTICE ANITA SUMANTHW.P. Nos.27409 & 27411 of 2019 and 1251 of 2018 and WMP.Nos.1559 of 2018& 3342 of 2020 W.P. No.27409 of 2019: Corporation Bank,Rep. by its Authorised Officer/Assistant General Manager,Old No.37, New no.77, First Avenue,Indira Nagar, Adayar,Chennai – 600 020. ... Petitioner Vs. 1.The Commissioner,Income Tax department,Investigation Building,46, MG Road, Nungambakkam,Chennai – 600 034. 2.The Sub Registrar,Office of the Sub-Registrar,Uraiyur. 3.M/s.Vasan Health Care Pvt. Ltd.,Rep. by its Managing Director,No.70, West Minister Complex,4[th] floor, Dr.R.K.Salai,Mylapore, Chennai – 600 004. 4.A.M.Arun 5.Meera Arun 6.Dwarakanathan 7.D.Nirmala 8.Beena Veiraiah9.A.M.Rajeswari10.K.Karunanidhi .... Respondents Prayer: Writ Petition filed under Article 226 of theConstitution of India praying to Writ of declaration, declaringthe Order of Attachment bearing PAN /CC-2(1)/CHE/2016-17 dated 18.01.2017 and PAN /Cc-2(1)/CHE/2016-17 dated14/7/17 passed by the 1[st] respondent subject to mortgage of thePetitioner Bank and consequently direct the 2[nd] respondent toregister the sale certificate issued by the Petitioner bank. W.P. No.27411 of 2019: Corporation Bank,Rep. by its Authorised Officer/Assistant General Manager,Old No.37, New no.77, First Avenue,Indira Nagar, Adayar,Chennai – 600 020. .... PetitionerVs. 1.The Commissioner,Income Tax department,Investigation Building,46, MG Road, Nungambakkam,Chennai – 600 034. 2.The Sub Registrar,Office of the Sub-Registrar,Sathanur. 3.M/s.Vasan Health Care Pvt. Ltd.,Rep. by its Managing Director,No.70, West Minister Complex,4[th] floor, Dr.R.K.Salai,Mylapore, Chennai – 600 004. 4.A.M.Arun5.Meera Arun6.Dwarakanathan7.D.Nirmala8.Beena Veiraiah9.A.M.Rajeswari10.K.Karunanidhi.... Respondents Prayer: Writ Petition filed under Article 226 of theConstitution of India praying to Writ of declaration, declaringthe Order of Attachment bearing No.CNo.2771/C-2/2016-17/2 Dated13.07.2017 passed by the 1[st] respondent subject to mortgage ofthe Petitioner Bank and consequently direct the 2[nd] respondent toregister the sale certificate issued by the Petitioner bank. W.P. No.1251 of 2018: Union Bank of India,Regional Office, Represented by Chief Manager,649/650, Oppanakara Street,Coimbatore – 641 001. .... Petitioner Vs. 1.Sub-Registrar,Tirupur, Tirupur District. 2.Tax Recovery Officer,Income Tax Department,Room No.35, 1[st] Floor,Main Building,63, Race Course Road,Coimbatore – 641 018. 3.M/s.Beetle ExportsNo.17, SRP Nagar,2[nd] Cross, Bharathi Park,Saibaba Colony,Coimbatore – 641 011. 4.V.Balasubramaniam 5.J.Swetha .... Respondents Prayer: Writ Petition filed under Article 226 of theConstitution of India praying to Writ of CertiorarifiedMandamus, to call for the records of the 2[nd] Respondentpertaining to the attachment Notice dated 27.03.2017 in FormITCP-16 and quash the same and lift the attachment andconsequently direct the 1[st] Respondent to register the SaleCertificate. For Petitioners : Mr.S.Sethuraman Mr.SrinathSridevan (In WP.1251/2018) For Respondents : Mr.A.P.Srinivas, Senior Standing Counsel for R1 in WP.Nos.23409 & 27411 of 2019)(for R2 in WP.No.1251 of 2018) Mr.B.Murugavel (In WP.23409 & 27411/2019) (for R10) No Appearance (In WP.23409 & 27411/2019)(for R2 , R3 to R9) No Appearance In all these cases, the petitioners are Banks and challengeorders encumbering properties that, according to them, have beenoffered to them as collateral by persons who have availedfinancial assistance. Memoranda of Deposit of Title Deeds (MOD)have been executed, under which the property in question wasoffered as security to the Bank by the borrowers/loanees. For Petitioners : Mr.S.Sethuraman Mr.SrinathSridevan (In WP.1251/2018) For Respondents : Mr.A.P.Srinivas, Senior Standing Counsel for R1 in WP.Nos.23409 & 27411 of 2019)(for R2 in WP.No.1251 of 2018) Mr.B.Murugavel (In WP.23409 & 27411/2019) (for R10) No Appearance (In WP.23409 & 27411/2019)(for R2 , R3 to R9) No Appearance In all these cases, the petitioners are Banks and challengeorders encumbering properties that, according to them, have beenoffered to them as collateral by persons who have availedfinancial assistance. Memoranda of Deposit of Title Deeds (MOD)have been executed, under which the property in question wasoffered as security to the Bank by the borrowers/loanees. 2. There were defaults by the loanees, as a result that theBanks had initiated action under Section 13 of theSecuritisation and Reconstruction of Financial Assets andEnforcement of Security Interest Act, 2002 (in short ‘SARFAESIAct’) and taken possession of the property thereafter underSection 13(4) thereof. Public notice for auction of theproperties was issued and in all the cases sales have beenconcluded to successful bidders and certificates have beenissued. The sales have been registered and sale certificatesissued in all cases. 3. The loanees are assesses under the provisions of theIncome Tax Act, 1961 (in short ‘Act’) and have defaulted in thepayment of income tax arrears. It is the case of the Income taxdepartment that, as result of the defaults, proceedings havebeen taken to attach the properties of the defaulters. It is thecreation of conflicting charges upon the properties that has ledto the lis in the present matters. 4. The above facts are common to all the Writ Petitionersexcept for specifics of the petitioner/financial institutions,the details of the loans extended, the dates of MOD andregistration of same with the Sub-Registrar, the dates ofcreation of charge by the Income Tax Authorities, if any, andthe details of sale by public auction. However, such differencesdo not change the overall fact pattern as is relevant fordeciding the present issue, the issue being whether the bankswould hold a priority of charge over that of the Income TaxDepartment qua the security interest created in the propertyheld as collateral. 5. Let me refer to the specifics of the facts inW.P.No.1251 of 2018 for clarity in, and completion of narration. https://hcservices.ecourts.gov.in/hcservices/ W.P.No.1251 of 2018 has been filed by the Union Bank of Indiaarraying Sub-Registrar, Tiruppur as R1/SRO, the Tax RecoveryOfficer (TRO) as R2, Beetle Exports (company), the income taxassessee, as R3 and two individuals, who were erstwhileDirectors in the R3 company, as R4 and R5. The directors of R3company had executed a MOD in regard to the property at No.17,SRP Nagar, 2[nd] Street, Bharathi Park Road, Saibaba Colony,Coimbatore (property/property in question) in favour of UnionBank of India of 10.02.2014, registered on the same day. 6. On account of defaults in the repayment of financialaccommodation, a demand notice was issued on 17.03.2016 andpossession of the property was taken by the Bank on 12.07.2017.Public notice was issued on 18.07.2017 and the property broughtto auction under notice dated 17.07.2017.The auction wasconducted and the bid confirmed in favour of one Mr.Charles,successful purchaser, on 23.08.2017. 7. In the meanwhile, it appears that the company hadsuffered orders of assessment for Assessment Years (AY) 2012-13and 2013-14 and an order of attachment of immovable property inForm No.I.T.C.P-16 under Rule 48 of the 2[nd] Schedule to theIncome Tax Rules (in short Rules) was issued by the TRO on27.03.2017 and duly communicated to the SRO. According to thelearned Senior Standing Counsel for the Department, this wouldsuffice to create a charge and an enforceable right over theproperty. 7. In the meanwhile, it appears that the company hadsuffered orders of assessment for Assessment Years (AY) 2012-13and 2013-14 and an order of attachment of immovable property inForm No.I.T.C.P-16 under Rule 48 of the 2[nd] Schedule to theIncome Tax Rules (in short Rules) was issued by the TRO on27.03.2017 and duly communicated to the SRO. According to thelearned Senior Standing Counsel for the Department, this wouldsuffice to create a charge and an enforceable right over theproperty. 8. This has given rise to the conflicting claims betweenthe bank and the Income Tax Department over the scheduleproperty. Upon publication of auction notice, there has beenexchange of correspondences between the TRO and the Bank inregard to the title to the property in question and while thecorrespondences continued, the auction came to be conducted asscheduled, resulting in the registration of the sale on25.10.2017 and issuance of sales certificate in favour of thesuccessful bidder on the same day. 9. On 06.11.2017, R1, the Sub-Registrar communicated withthe Bank informing it of the Tax recovery certificate issued bythe Income Tax Department in regard to the same property. Therequests of the Bank for lifting of the attachment and theobjections for registering the sale certificate came to berefused by the TRO, who relied on Rule 12, Part I to the 2[nd]Schedule of the Act, stating that the attachment would continuetill such time the arrears to the Department was remitted. 10. According to the Bank, the provisions of Section 26E ofthe SARFAESI Act would protect it in full, since, after https://hcservices.ecourts.gov.in/hcservices/ introduction and notification of the aforesaid provision,security interest created in favour of a secured creditor wasparamount and would have priority over charges of all othercreditors, including crown debts. The petitioner relies on thefollowing judgments in support of this proposition: i. The Assistant Commissioner (CT) v Indian Overseas Bank(2016 SCC Online Mad 10030) ii. Canara Bank v The Recovery Officer (UnreportedJudgment dated 25.01.2018 in W.P. No.25867 of 2017) iii. State Bank of India v State of Maharashtra (2020 SCCOnline Bom 4190) iv. Bank of Baroda v State of Kerala (2020 SCC Online Ker7152) v.Pridhvi Asset Reconstruction and Securitisation CompanyLtd v State of AP (2020 SCC Online AP 1936) vii.Solidaire India Ltd v Fairgrowth Financial ServicesLtd &Ors((2001) 3 SCC 71) 11. The respondent would rely on the provisions of Section281 itself that render transfer of property certain transfers tobe void, relying on the following decisions of the Courts: (i) Department of Income-tax v. Vodafone Essar GujaratLtd ((2016) 66 taxmann.com 374 (SC)) (ii) Sri Sivalaya Advances v. Tax Recovery Officer,Madurai ((2018) 93 taxmann.com 143 (Madras)) (iii) D.S.Senthilvel v. Tax Recovery Officer, Madurai((2018) 92 taxmann.com 354 (Madras)) (iv) Karnail Singh v. Union of India ((2011) 11taxmann.com 323 (Punjab Haryana) (v) Abdul Jamil v. Secretary, Income Tax Department((1998) 101 Taxmann 332 (MAD) (vi) Master Aditya Kumar Kedia v. Tax Recovery Officer((2002) 120 Taxman 291 (Bombay) https://hcservices.ecourts.gov.in/hcservices/ (vii) JaymacLasetron (P.) Ltd. v. Commissioner of IncomeTax ((2001) 116 Taxman 231 (CAL.)) (viii) Agasthiya Holdings (P.) Ltd. v. Commissioner ofIncome-tax, Madurai (2018) 93 taxmann.com 81 (Madras)) (i) Department of Income-tax v. Vodafone Essar GujaratLtd ((2016) 66 taxmann.com 374 (SC)) (ii) Sri Sivalaya Advances v. Tax Recovery Officer,Madurai ((2018) 93 taxmann.com 143 (Madras)) (iii) D.S.Senthilvel v. Tax Recovery Officer, Madurai((2018) 92 taxmann.com 354 (Madras)) (iv) Karnail Singh v. Union of India ((2011) 11taxmann.com 323 (Punjab Haryana) (v) Abdul Jamil v. Secretary, Income Tax Department((1998) 101 Taxmann 332 (MAD) (vi) Master Aditya Kumar Kedia v. Tax Recovery Officer((2002) 120 Taxman 291 (Bombay) https://hcservices.ecourts.gov.in/hcservices/ (vii) JaymacLasetron (P.) Ltd. v. Commissioner of IncomeTax ((2001) 116 Taxman 231 (CAL.)) (viii) Agasthiya Holdings (P.) Ltd. v. Commissioner ofIncome-tax, Madurai (2018) 93 taxmann.com 81 (Madras)) 12. As regards the argument of the Revenue that Section281 of the Act would protect its interests, the petitionerwould state that protection under Section 281 is not envisagedin cases where there was a valid subsisting mortgage by asecured creditor and the latter would prevail over all otherdebts. Reliance is placed on the following three judgments todrive home the point that Section 281 only provides aprotection to the revenue in cases where an assessee tries tocircumvent recovery proceedings by alienating property andthat no declaration of title is contemplated thereunder. (i) Tax Recovery Officer v Gangadhar Vishwanath Ranade((1998) 6 SCC 658) (ii) Sancheti Leasing Company Ltd v Income Tax Officer((2000) 246 ITR 814) (iii) ICICI Bank Ltd v Tax Recovery Officer (2018 SCCOnline Hyd 441) 13. Having heard learned counsel and perused the WritPetitions as well as case law carefully, I believe that theseWrit Petitions are liable to be allowed and my reasoning is asfollows. 14. The rival claims at play emanate from the operation ofSection 281 of the Income Tax Act, vis-a-vis Section 26E of theSARFAESI Act. Both provisions are extracted below: Section 281 of the Income Tax Act: Certain Transfers to be void '281. (1) Where, during the pendency of anyproceeding under this Act or after the completionthereof, but before the service of notice under rule2 of the Second Schedule, any assessee creates acharge on, or parts with the possession (by way ofsale, mortgage, gift, exchange or any other mode oftransfer whatsoever) of, any of his assets in favourof any other person, such charge or transfer shall bevoid as against any claim in respect of any tax or any other sum payable by the assessee as a result ofthe completion of the said proceeding or otherwise : Provided that such charge or transfer shall not bevoid if it is made— (i) for adequate consideration and without notice ofthe pendency of such proceeding or, as the case maybe, without notice of such tax or other sum payableby the assessee ; or (ii) with the previous permission of the AssessingOfficer. (2) This section applies to cases where the amount oftax or other sum payable or likely to be payableexceeds five thousand rupees and the assets chargedor transferred exceed ten thousand rupees in value. Explanation.—In this section, "assets" means land,building, machinery, plant, shares, securities andfixed deposits in banks, to the extent to which anyof the assets aforesaid does not form part of thestock-in-trade of the business of the assessee.Section 26E of the SARFAESI Act: "26E. Priority to Secured Creditors- Notwithstandinganything contained in any other law for the timebeing in force, after the registration of securityinterest, the debts due to any Secured Creditor shallbe paid in priority over all other debts and allrevenues, taxes, cesses and other rates payable tothe Central Government of State Government or localauthority. Explanation.—In this section, "assets" means land,building, machinery, plant, shares, securities andfixed deposits in banks, to the extent to which anyof the assets aforesaid does not form part of thestock-in-trade of the business of the assessee.Section 26E of the SARFAESI Act: "26E. Priority to Secured Creditors- Notwithstandinganything contained in any other law for the timebeing in force, after the registration of securityinterest, the debts due to any Secured Creditor shallbe paid in priority over all other debts and allrevenues, taxes, cesses and other rates payable tothe Central Government of State Government or localauthority. Explanation: For the purposes of this Section, it ishereby clarified that on or after the commencement ofthe Insolvency and Bankruptcy Code, 2016 (31 of2016), in cases where insolvency or bankruptcyproceedings are pending in respect of secured assetsof the Borrower, priority to secured creditors inpayment of debt shall be subject to the provisions ofthat Code.' 15. Let us first analyze the provisions of Section 281 readwith the proviso thereunder, and the umbrella of protection itoffers, as well as the case law on point. Section 281 has beenenacted to protect the interests of a bonafide purchaser lured https://hcservices.ecourts.gov.in/hcservices/ into the purchase of the property in question without theknowledge of recovery proceedings pending as against the vendor.Thus, Section 281 may be invoked only in cases where thetransfer was a devise or an arrangement to circumvent asubsisting or anticipated demand by the Income Tax Departmentand to protect the interests of an unsuspecting purchaser whohas paid valuable consideration for the purchase of the propertyin question. 16. Since Section 281 would apply in cases where thetransfer of the property has been made during the pendency ofproceedings or after the completion thereof, one has to examinewhether there were any proceedings pending in the case of thecompany for AY 2012-13 at the time when the MOD was registered,which is 10.02.2014. 17. The counter filed by the TRO refers to a notice issuedin terms of Section 143(2) of the Act without setting out anydetails thereof. It is also silent as to when the returns ofincome were filed by the petitioners or when notices were issuedthereafter to indicate commencement of proceedings. However,Mr.Srinivas states that he is in possession of the assessmentfiles and produces a notice under Section 143(2) of the Actdated 08.08.2013 relating to AY 2012- 2013, that has been issuedto the company in August 2013, prior to registration ofmortgage. There is no reference to any notice issued as far asAY 2013-14 is concerned. 18. According to the revenue, the issuance of notice underSection 143(2) would create an automatic charge over theproperty by the petitioner and any subsequent alienation of theproperty by the petitioner would be liable to be set aside inlight of the protection under Section 281. 19. The power to initiate coercive recovery in terms of the2[nd]Schedule to the Act has been the subject matter of discussionin various decisions. In the case of Gangadhar Vishwanath Ranade(supra) the Supreme Court considered a challenge by the TRO to adecision of the Bombay High Court that had set aside anattachment under Rule 11 of the 2[nd] Schedule to the Act on theground that under Rule 11, the TRO had no power to declare atransfer void and one that had been effected with the intentionof defrauding the revenue. The provisions of Section 281 do notconfer the power of adjudication upon the authorities, butmerely the power to declare the law, qua the aspect ofattachment alone. 20. Section 281 states that any transaction of transferengaged in after the commencement of proceedings, with the https://hcservices.ecourts.gov.in/hcservices/ 20. Section 281 states that any transaction of transferengaged in after the commencement of proceedings, with the https://hcservices.ecourts.gov.in/hcservices/ intention of defrauding the revenue and circumventingproceedings for recovery, would be construed as void as againstany claim of tax or other sum payable by that assessee. However,bona fide transactions that have been entered into for adequateconsideration, with the parties being unaware of the pendency ofproceedings before the Income Tax authorities/without being putto notice, shall stand excluded from the rigour of theprovision. Transactions engaged in with the sanction of theAssessing Officer would also be excluded from the application ofthe provision. 21.The Supreme Court thus held that the TRO shall have thepower to examine the alternate charge created by the assesseeand attach the property if he came to the conclusion that thecharge had been created only to circumvent the attachment by theincome tax department. However, the power of the TRO shall notextend to declaration of title that may be made only by theCivil Courts in a Suit for declaration declaring the transactionvoid under Section 281 of the Act. This was for the reason thatthe TRO is himself an interested party and hence cannot sithimself in judgment in such a case. 22. Thus, while the attachment of the Income Tax Departmentover the subject property would be held to be valid, the powervested in the income tax authorities can extend no further thanto effect an attachment. This is as per Rule 11(6) of the 2[nd]Schedule to the Act, reading thus: Investigation by Tax Recovery Officer..... (6) Where a claim or an objection is preferred, theparty against whom an order is made may institute a suitin a civil court to establish the right which he claimsto the property in dispute; but, subject to the resultof such suit (if any), the order of the Tax RecoveryOfficer shall be conclusive. 23. In Sancheti Leasing Company Ltd (supra), JusticeR.Jayasimha Babu says: 6. Section 281(1) of the Act had been relied upon bythe Income-tax Officer. That section declares certaintransactions as void. The section, however, does notvest the authority in the Income-tax Officer to makesuch a declaration. 7. Before a transaction involving immovable propertycan be declared as void, all the requirements of lawmust necessarily be satisfied. The fact that a statuteprovides for such a declaration being made, if theconditions mentioned in the statute are satisfied, doesnot imply that an officer exercising powers under theprovisions of the statute can assume to himself thepower and jurisdiction to declare what is otherwise alegally valid transaction as void. Adjudication is thefunction of the courts. Any declaration of atransaction being void must be sought in the civilcourt. The Income-tax Officer moreover in this case isan interested party as it is in the interests of theRevenue to make such a declaration and proceed torecover the vendor's arrears of tax from such person. 8. The Supreme Court of India in its recent decisionrendered in the case of TRO v. Gangadhar ViswanathRanade (Decd.) [1998] 234 ITR 188 has held that if theDepartment finds that the assessee has transferred aproperty to a third party with the intention to defraudthe Revenue, the Revenue will have to file a suit underRule 11(6) of Schedule II to the Income-tax Act to havethe transfer declared void under Section 281 of theIncome-tax Act. 8. The Supreme Court of India in its recent decisionrendered in the case of TRO v. Gangadhar ViswanathRanade (Decd.) [1998] 234 ITR 188 has held that if theDepartment finds that the assessee has transferred aproperty to a third party with the intention to defraudthe Revenue, the Revenue will have to file a suit underRule 11(6) of Schedule II to the Income-tax Act to havethe transfer declared void under Section 281 of theIncome-tax Act. 24. I thus, find no merit in the submissions of therespondent to the effect that Section 281 constitutes adeclaration of charge much less, one which is preferential tothe revenue. The thrust of Section 281 is only a protection to abona fide purchaser in cases where an errant assessee may seekto alienate property to circumvent anticipated recovery ofoutstanding arrears payable by him to the Income Tax Department.Nothing in Section 281 would support the submission that it, byitself creates a positive charge of property. The charge inthis case was created by the Income Tax Department only after27.03.2017 when the property was attached in terms of Rule 48 ofthe 2[nd] Schedule and duly communicated to the SRO. 25. Moreover, the aforesaid cases however do not take noteof Section 26E of the SARFAESI that has been notified on24.01.2020. Section 26E commences with a non-obstante clause andstates that priority shall be accorded to the debts payable tosecured creditors, notwithstanding anything in any other law forthe time being in force, including the Income tax Act. The onlyexception, is as per the Explanation to Section 26E, casespending under the Insolvency and Bankruptcy Code 2016. In thecase of a secured creditor where a prior valid charge exists, asin the present case where the mortgage has been created on10.02.2014, the provisions of Section 281 would not serve todisturb the same. 26. A matter similar to the present one came up forconsideration before the Andhra Pradesh and Telangana High Court(prior to bifurcation) in the case of ICICI Bank Ltd (supra).Conflicting claims to the same property were set up by the ICICIBank and the Tax Recovery Officer. After considering theinterpretation of Section 281 and the power of recovery underthe 2[nd] Schedule to the Income Tax Act, the Bench states that theattachment in that case was prior to the attachment by theIncome Tax Department and thus, held priority over thesubsequent attachment. Following the ratio of the judgment ofthe Supreme Court in the case of Gangadhar Vishwanath Ranade(supra), the claim of the Bank was allowed. 27. In this case the mortgage by the Bank is on 10.02.2014and that by the Income tax Department, is post attachment, on27.03.2017 only. The subsequent attachment thus fails in thelight of Section 26E. 28. Incidentally, at the time when the above decision wasrendered, Section 26E of the SARFAESI Act had not been notified,prompting the Bench to state at paragraph 6 of that decision (ofthe SCC online report) that the issue before them could havebeen resolved in a trice, had only the provisions of Section 26Ebeen notified at the time when the decision was being rendered.The provisions of Section 26E have since been notified on24.01.2020 and the benefit of the same is available for thepresent Writ Petitioners. sl To 1.The Commissioner,Income Tax department,Investigation Building,46, MG Road, Nungambakkam,Chennai – 600 034. 2.The Sub Registrar,Office of the Sub-Registrar,Uraiyur. 3.The Sub Registrar,Office of the Sub-Registrar,Sathanur. 4.Sub-Registrar,Tirupur, Tirupur District. 5.Tax Recovery Officer,Income Tax Department,Room No.35, 1[st] Floor,Main Building,63, Race Course Road,Coimbatore – 641 018. +4cc to Mr.B.Murugavel, Advocate SR.24494, 24494+2cc to Mr.S.Sethuraman, Advocate SR.24563+3cc to Mr.A.P.Srinivas, Advocate SR.24771, 24770, 24772+1cc to Mr.Srinath Sridevan, Advocate, SR.24744W.P. Nos.27409 & 27411 of 2019 and 1251 of 2018and sl To 1.The Commissioner,Income Tax department,Investigation Building,46, MG Road, Nungambakkam,Chennai – 600 034. 2.The Sub Registrar,Office of the Sub-Registrar,Uraiyur. 3.The Sub Registrar,Office of the Sub-Registrar,Sathanur. 4.Sub-Registrar,Tirupur, Tirupur District. 5.Tax Recovery Officer,Income Tax Department,Room No.35, 1[st] Floor,Main Building,63, Race Course Road,Coimbatore – 641 018. +4cc to Mr.B.Murugavel, Advocate SR.24494, 24494+2cc to Mr.S.Sethuraman, Advocate SR.24563+3cc to Mr.A.P.Srinivas, Advocate SR.24771, 24770, 24772+1cc to Mr.Srinath Sridevan, Advocate, SR.24744W.P. Nos.27409 & 27411 of 2019 and 1251 of 2018and WMP.Nos.1559 of 2018& 3342 of 2020