Exhibit P8The True Copy Of The Judgment Of This Hon'ble Court In W.a v. Income Tax Officerhon'ble Court In W.a

IN THE HIGH COURT OF KERALA AT ERNAKULAM THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGHFRIDAY, THE 1 DAY OF DECEMBER 2023 / 10TH AGRAHAYANA, 1945 WP(C) NO. 39862 OF 2023 PETITIONER: VALLAPUZHA SERVICE CO-OPERATIVE BANK LTD 9/283, NELLAYA, CHERUPULASSERY, PALAKKAD, KERALA REPRESENTED BY ITS SECRETARY, SRI. ASHRAFALI. P, PIN – 679335 BY ADV. V.P.NARAYANAN RESPONDENTS: 1THE INCOME TAX OFFICER WARD-3, AAYAKAR BHAVAN, INCOME TAX OFFICE, ENGLISH CHURCH ROAD, PALAKKAD-, PIN – 678014WARD-3, AAYAKAR BHAVAN, INCOME TAX OFFICE, ENGLISH CHURCH ROAD, PALAKKAD-, PIN – 678014 2THE NATIONAL FACELESS APPELLATE CENTRE MAYUR BHAWAN, CONNAUGHT LANE, BARAKHAMBA ROAD, NEW DELHI REPRESENTED BY COMMISSIONER OF INCOME TAX APPEALS(NFAC), PIN – 110001MAYUR BHAWAN, CONNAUGHT LANE, BARAKHAMBA ROAD, NEW DELHI REPRESENTED BY COMMISSIONER OF INCOME TAX APPEALS(NFAC), PIN – 110001 3THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX (KERALA) CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, KOCHI, PIN – 682018 BY SRI. JOSE JOSEPH, SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 01.12.2023, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: JUDGMENT The present writ petition has been filed impugning the orders in Exts.P5, P6 and P7 passed by the secondrespondent under Section 250 of the Income Tax Act,1961 for the assessment years 2014-15 & 2015-16. Thelearned counsel for the petitioner submits that the firstappellate authority has not considered all the groundStaken by the petitioner assessee and therefore, this Courtmay remand back the matter to the first appellateauthority to re-consider the grounds taken by thepetitioner assessee against the assessment orders inExts.P1 to P3. 2.If the appellate authority has not consideredone or more grounds taken by the assessee, the orderpassed by the first appellate authority does not becomebad in law. The petitioner has a remedy to file appealagainst the orders and may take all the grounds takenbefore the first appellate authority as well as additional If the appellate authority has not considered 3 grounds. However, for non-consideration of one or more grounds by the first appellate authority, this Court couldnot exercise its judicial review jurisdiction under Article 226 of the Constitution of India. I find this writ petition wholly misconceive andaccordingly, it is dismissed. DCS/01.12.2023 Sd/- DINESH KUMAR SINGH JUDGE W.P.(C.) No.39862/2023 APPENDIX PETITIONER EXHIBITS EXHIBIT P1THE TRUE COPY OF THE ASSESSMENT ORDER ALONG WITH THE DEMAND NOTICE ISSUED IN CASE OF THE PETITIONER FOR AY 2014-15 PASSED BY THE 1ST RESPONDENT UNDER SECTION 143(3) OF THE ACT DATED 20.12.2016 EXHIBIT P2THE TRUE COPY OF THE RECTIFICATION ORDER ISSUED UNDER SECTION 154 OF THE ACT BY THE 1ST RESPONDENT FOR AY 2014-15ISSUED UNDER SECTION 154 OF THE ACT BY THE 1ST RESPONDENT FOR AY 2014-15 EXHIBIT P3THE TRUE COPY OF THE ASSESSMENT ORDER ISSUED BY THE 1ST RESPONDENT FOR AY 2015-16 UNDER SECTION 143(3) OF THE DATED 29.11.2017ISSUED BY THE 1ST RESPONDENT FOR AY 2015-16 UNDER SECTION 143(3) OF THE DATED 29.11.2017 EXHIBIT P4A TRUE COPY OF THE NOTE SUBMITTED BY THE PETITIONER DATED 25.09.2023 IN REPLY TO THE NOTICE ISSUED UNDER SECTION 250 OF THE ACT FOR AY 2014-15PETITIONER DATED 25.09.2023 IN REPLY TO THE NOTICE ISSUED UNDER SECTION 250 OF THE ACT FOR AY 2014-15 EXHIBIT P5THE TRUE COPY OF THE APPELLATE ORDER PASSED BY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15, DATED 31.10.2023PASSED BY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15, DATED 31.10.2023 EXHIBIT P6A TRUE COPY OF THE APPELLATE ORDER ISSUEDBY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15 DATED 10.10.2023 AGAINST THE ORDER PASSED UNDERSECTION 154 OF THE ACTBY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15 DATED 10.10.2023 AGAINST THE ORDER PASSED UNDERSECTION 154 OF THE ACT EXHIBIT P4A TRUE COPY OF THE NOTE SUBMITTED BY THE PETITIONER DATED 25.09.2023 IN REPLY TO THE NOTICE ISSUED UNDER SECTION 250 OF THE ACT FOR AY 2014-15PETITIONER DATED 25.09.2023 IN REPLY TO THE NOTICE ISSUED UNDER SECTION 250 OF THE ACT FOR AY 2014-15 EXHIBIT P5THE TRUE COPY OF THE APPELLATE ORDER PASSED BY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15, DATED 31.10.2023PASSED BY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15, DATED 31.10.2023 EXHIBIT P6A TRUE COPY OF THE APPELLATE ORDER ISSUEDBY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15 DATED 10.10.2023 AGAINST THE ORDER PASSED UNDERSECTION 154 OF THE ACTBY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2014-15 DATED 10.10.2023 AGAINST THE ORDER PASSED UNDERSECTION 154 OF THE ACT EXHIBIT P7A TRUE COPY OF THE APPELLATE ORDER PASSEDBY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2015-16, DATED 31.10.2023BY THE 2ND RESPONDENT UNDER SECTION 250 OF THE ACT FOR AY 2015-16, DATED 31.10.2023 EXHIBIT P8THE TRUE COPY OF THE JUDGMENT OF THIS HON'BLE COURT IN W.A NO. 753/2021 DATED 28.06.2021 IN THE CASE OF M/S POONJAR SERVICE CO-OPERATIVE BANK LTD VS INCOME TAX OFFICERHON'BLE COURT IN W.A NO. 753/2021 DATED 28.06.2021 IN THE CASE OF M/S POONJAR SERVICE CO-OPERATIVE BANK LTD VS INCOME TAX OFFICER EXHIBIT P9 THE TRUE COPY OF THE JUDGMENT IN THE CASEOF KARUVANNUR SERVICE CO-OPERATIVE BANK LTD VS ITO IN W.P (C ) NO. 16614/2022 DATED 25.05.2022