Ita.36 Of 2020 v. Cit[(1978) 3 Scc 414].5. At The Outset; We Cannot Accept The Groundtaken By The First Appellate Authority That The Assesseewould Be Dis-Entitled To Claim The Ex

IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE K.VINOD CHANDRAN & THE HONOURABLE MR.JUSTICE T.R.RAVI FRIDAY, THE 13TH DAY OF NOVEMBER 2020 / 22ND KARTHIKA, 1942 I.T.A.No.36 OF 2020 AGAINST THE ORDER IN I.T.A.No.590/Coch/2019 DATED 08-01-2020OF INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN APPELLANT/ APPELLANT/ASSESSEE: M/S. BHARATHAKSHEMAM,BHARATHAKSHEMAM BUILDING, ST.THOMAS COLLEGE ROAD, THRISSUR-680 005, REPRESENTEDBY ITS CHAIRMAN SHRI.P.M.THOMAS. BY ADVS.SRI.T.M.SREEDHARAN (SR.)SMT.NISHA JOHNSRI.V.P.NARAYANANSMT.DIVYA RAVINDRANSRI.R.BHASKARA KRISHNAN RESPONDENT/ RESPONDENT/REVENUE: THE PRINCIPAL COMMISSIONER OF INCOME TAX,AAYAKAR BHAWAN, M.O.ROAD, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001. BY ADV. SRI.P.K.RAVINDRANATHA MENON (SR.)BY SRI.JOSE JOSEPH, SC, FOR INCOME TAX. THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON13-11-2020, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: “C.R.” K. Vinod Chandran & T.R.Ravi, JJ. ------------------------------------- I.T.A.No.36 of 2020 ------------------------------------ Dated, this the 13[th] day of November, 2020 JUDGMENT Vinod Chandran, J. The question of law arising in the above appeal isre-framed as follows: Whether the Tribunal was correct in havingdenied exemption to the income generated by theassessee, who is registered under Section 12A ofthe Income Tax Act, 1961 ['Act' for brevity], fromthe business of Chitty/Kuri which was fullyutilized for the purpose of 'medical relief', whichis the main object of the assessee-Trust, fallingunder the definition of 'charitable purpose'? 2. The facts need not be elaborated. Suffice it tonotice that the assessee is constituted as a Trust with itsmain object, as declared in its Memorandum of Association['MoA' for brevity], for establishing, maintaining andrunning a hospital for philanthropic purposes and notfor the purpose of profit. One of its objects whichhas been declared in the MoA, as incidental or ancillaryto the attainment of the main object is 'To run Chitties ITA.36 of 2020 (Kuries)'. The learned Counsel for the assesseespecifically pointed out the ancillary object from the MoAand submitted that the assessee had been granted theexemption in the years prior and subsequent to the relevantassessment year. The entire income from the business ofChitties was applied for the main object, the philanthropicpurpose and in any event, the income generated is less thanRs.25 lakhs, making the first proviso to Section 2(15)inapplicable to the assessee. The assessee's Counsel relieson Commissioner of Income Taxv. Dharmodayam Company & Ors.[ (1977) 4 SCC 75]and Assistant Commissioner of Income Taxv. Thanthi Trust Etc. [(2001) 2 SCC 707]to claim theexemption. 3. The learned Standing Counsel appearing for theRevenue draws a distinction between a business 'held underTrust' and that 'carried on by a Trust'. According to theRevenue, Thanthi Trustwas a decision with respect to abusiness held under Trust; whereas in the present case itis a business carried on by a Trust. It is also pointed outthat a Division Bench of the Delhi High Court in CIT v.Mehta Charitable Pranalay Trust [(2013) 357 ITR 560(Delhi)] distinguished the decision in Thanthi Trust; thefacts and law declared therein being applicable here. 3. The learned Standing Counsel appearing for theRevenue draws a distinction between a business 'held underTrust' and that 'carried on by a Trust'. According to theRevenue, Thanthi Trustwas a decision with respect to abusiness held under Trust; whereas in the present case itis a business carried on by a Trust. It is also pointed outthat a Division Bench of the Delhi High Court in CIT v.Mehta Charitable Pranalay Trust [(2013) 357 ITR 560(Delhi)] distinguished the decision in Thanthi Trust; thefacts and law declared therein being applicable here. 4. The first appellate authority found that theactivity carried on by the assessee of conducting Chittybusiness, in its outcome, had mutual benefit to thesubscribers and assessee. Substantial profit earned waspassed on to the subscribers and there was only a minorprofit shown by the assessee. Even if the said profit isapplied fully to the main object of the assessee, it wouldnot be an incidental activity for the attainment of themain objectives. The Tribunal agreed with the finding ofthe first appellate authority and specifically referred tothe first proviso to Section 2(15) to find that the Chittybusiness cannot be considered as incidental to the primaryobject of the assessee-Trust and hence, they are dis-entitled from claiming exemption under Section 11. Thereliance placed on the judgment of the Hon'ble SupremeCourt in Dharmodayam Company was negated. The Tribunal wasof the opinion that the said decision applies only to itsfacts and the same has been distinguished by the Hon'bleSupreme Court itself in Dharmaposhanam Company v. CIT[(1978) 3 SCC 414].5. At the outset; we cannot accept the groundtaken by the first appellate authority that the assesseewould be dis-entitled to claim the exemption since the subscribers to the chitties profited from the businesscarried on. If the subscribers profited they would be taxedfor the income in their hands and that would not result indenial of exemption, if the assessee is otherwise eligible. 6. We also have to notice that the Tribunal erredin brushing aside the dictum of the two judge Bench inDharmodayam Company, since that decision was upheld by aConstitution Bench inAddl.CITv.Surat Art SilkManufacturers' Association[(1980) 2 SCC 31], which islater in time to the three judge Bench decision inDharmaposhanam Company. Further these are decisions whichconsidered the impact of the words 'the advancement of anyother object of general public utility not involving thecarrying out of any activity of profit' which does not haveany relevance to the subject Trust which has as its primaryobject 'provision of medical relief'. In DharmodayamCompany, the Court looked at the objects to which theprofits were to be applied. After first applying it to theCompany's stability and creating a reserve for bad debtsthe balance was to be applied to 'charity, education,industry and other purpose of public interest'. On facts itwas found that the Company had never undertaken anyindustry nor any other activity of public interest other than conducting kuri business. The decision in IndianChamber of Commerce v. CIT(1976) 1 SCC 324 whichcriticized the judgment of the Kerala High Court impugnedin Dharmodayam Company, was held to have done so withoutlooking at the facts and on the assumption that the Companyhad been carrying on an 'industry'. than conducting kuri business. The decision in IndianChamber of Commerce v. CIT(1976) 1 SCC 324 whichcriticized the judgment of the Kerala High Court impugnedin Dharmodayam Company, was held to have done so withoutlooking at the facts and on the assumption that the Companyhad been carrying on an 'industry'. 7. In the case of Dharmaposhanam Company,intiallythe objects were inter alia to raise funds by conduct ofkuries, accept donations and subscriptions, lend money forinterest as also promote 'charity, education industriesetc: and public good'. The profits left after meeting theexpenses of the company were to be utilised for promoting'education, industry, social welfare and such otherpurposes of common good as are resolved by the generalmeeting'. The objects were later amended as 'for thepromotion of charity, education, medical relief and othermatters of public good'. The application of profits werealso amended as 'The profit left after meeting the expensesof the Company will be utilised for purposes of common goodlike charity, education and medical relief as are resolvedby the general meeting'. It was held that the employment ofthe words 'industries, 'public good' and 'common good' inthe Articles, evidently makes it referable to the residual clause in Section 2(15) ie: 'the advancement of any otherobject of public utility', which is qualified by therestrictive words 'not involving the carrying on of anyactivity for profit'. It was held that 'Whether a trust isfor charitable purpose falls to be determined by referenceto all the objects for which the trust has been broughtinto existence' and there the exemption was declined. Here,in the instant case the main object is only provision ofmedical relief. 8. In Surat Art Silk Manufacturers' AssociationaConstitution Bench, again considered the effect of thewords 'not involving the carrying on of any activity forprofit'. It was categorically held in Para 8 that: 'This question arises on the terms of Section 2clause (15) which gives an inclusive definitionof “charitable purpose”. It provides that“charitable purpose” includes “relief of thepoor, education, medical relief and theadvancement of any other object of general publicutility not involving the carrying on of any-activity for profit”. It is now wellsettled as aresult of the decision of this Court in(1978) 3 SCC 499Dharmadeepti v. CIT that thewords “not involving the carrying on of anyactivity for profit” qualify or govern only the last head of charitable purpose and not theearlier three heads'. 9. Hence the question whether the incidentalactivity carried on can be termed as one for profit doesnot arise here, since the main object for which the Trusthere is constituted, is a charitable purpose for reason ofit being 'provision of medical relief'. Here, the questionfalls for consideration on the basis of the provisions asapplicable to the relevant year, being Section 2(15) andSection 11(4A). But before extracting the above provisions,we refer to the judgment of the Hon'ble Supreme Court inThanthi Trust. Therein, a Daily newspaper, called 'DhinaThanthi', was founded in 1942 and the same was settled on atrust called 'Thanthi Trust' created in 1954. The Hon'bleSupreme Court considered the issue for various years on thebasis of the relevant provisions. The first of suchcontroversy arose prior to 01.04.1984 when Section 13(1)(bb) was in the statute book. By Section 11(4) a propertyheld under trust included a business undertaking so held onthe basis of which the assessee drew a distinction insofaras 'a business held under Trust' and that 'carried on by aTrust'. It was the case of Thanthi Trust that the newspaperbusiness being the property settled upon the Trust, it was one held under Trust as a part of its corpus; thus creatinga legal obligation to use the income generated from thebusiness held under Trust for the public charitable purposefor which the Trust itself is created. The corollary wasthat a business carried on by the Trust would not have suchan obligation. 10. The Hon'ble Supreme Court found that thedistinction attempted would have no consequence as far assection 13(1)(bb) is concerned. Here we extract Section13(1)(bb): "13. (1) Nothing contained in Section 11 orSection 12 shall operate so as to exclude from thetotal income of the previous year of the person inreceipt thereof — xxxxxxxxx (bb) in the case of a charitable trust orinstitution for the relief of the poor, educationor medical relief, which carries on any business,any income derived from such business, unless thebusiness is carried on in the course of the actualcarrying out of a primary purpose of the trust orinstitution;” It was held so in paragraph 12: "12. A public charitable trust may hold abusiness as part of its corpus. It may carry on abusiness which it does not hold as a part of itscorpus. But it seems to us that the distinction hasno consequence insofar as Section 13(1)(bb) isconcerned. Section 13(1)(bb) provides, so far as it is relevant to this case, that the provisions ofSection 11 shall not operate so as to include inthe total income of the previous year of a publiccharitable trust for the relief of the poor,education or medical relief which carries on anybusiness, any income derived from such businessunless the business is carried on in the course ofthe actual carrying out of a primary purpose of thetrust. Section 13(1)(bb), therefore, will apply toa public charitable trust for the relief of thepoor, education or medical relief that carries on abusiness, regardless of whether or not thatbusiness is held by the trust in trust, that is, asa part of its corpus. Even a business that is heldby such a trust as a part of its corpus is carriedon by the trust and, therefore, Section 13(1)(bb)will apply to such trust". 11. The exemption prior to 01.04.1984 in ThanthiTrustwas considered on the basis of Section 13(1)(bb) andit was held that whether it be a business held under Trustor carried on by it unless the same is carried on in thecourse of the actual carrying out of the object of theTrust or institution, there could be no exemption claimed.We pertinently have to notice that even in Surat Art SilkManufacturers' Association the distinction as to a businessheld under Trust or carried on by it was noticed in theminority judgment without any clarification as to what would be the consequence of the distinction in the laterinstance. All the decisions cited, wherein business inkuries was mentioned as an object in the Memorandum ofAssociation, were held to be business held under trust. Thekuri business here too, has to be hence found to be abusiness held under trust. Sub-section (4) of Section 11makes any business held under trust to be property heldunder trust for the purposes of this section. 12. The second controversy which arose in ThanthiTrustwas the position of law between 1984 and 1992 in thecontext of Sub-section (4A) of Section 11 as it stood then;with which we are not concerned. For our purpose, what isrelevant is sub-section (4A) of Section 11 as substitutedwith effect from 01.04.1992, which was the thirdcontroversy dealt with in the case of Thanthi Trust. Forthe said years the business of news paper held under Trustwas found to be entitled to exemption on the followinginterpretation of sub-section (4A), in para 25: “25. The substituted sub-section (4A) statesthat the income derived from a business heldunder trust wholly for charitable or religiouspurposes shall not be included in the totalincome of the previous year of the trust orinstitution if “the business is incidental to the “25. The substituted sub-section (4A) statesthat the income derived from a business heldunder trust wholly for charitable or religiouspurposes shall not be included in the totalincome of the previous year of the trust orinstitution if “the business is incidental to the attainment of the objective of the trust or, asthe case may be, institution” and separate booksof accounts are maintained in respect of suchbusiness. Clearly, the scope of sub-section (4A)is more beneficial to a trust or institution thanwas the scope of sub-section (4A) as originallyenacted. In fact, it seems to us that the-substituted subsection (4A) gives a trust orinstitution a greater benefit than was given bySection 13(1)(bb). If the object of Parliamentwas to give trusts and institutions no morebenefit than that given by Section 13(1)(bb), thelanguage of Section 13(1)(bb) would have beenemployed in the substituted sub-section (4A). Asit stands, all that it requires for the businessincome of a trust or institution to be exempt isthat the business should be incidental to theattainment of the objectives of the trust orinstitution. A business whose income is utilisedby the trust or the institution for the purposesof achieving the objectives of the trust or theinstitution is, surely, a business which isincidental to the attainment of the objectives ofthe trust. In any event, if there be anyambiguity in the language employed, the provisionmust be construed in a manner that benefits theassessee. The Trust, therefore, is entitled tothe benefit of Section 11 for Assessment Year-199293 and thereafter. It is, we should add, notin dispute that the income of its newspaper business has been employed to achieve itsobjectives of education and relief to the poorand that it has maintained separate books ofaccounts in respect thereof. [underlining by us for emphasis] 13. We now look at the decision of the Delhi HighCourt in Mehta Charitable Pranalay Trust.Therein a Trustwas created settling an amount of Rs.2,200/- for the objectof establishing and maintaining of schools, colleges andstudy circles, advancing education and research on themodern and ancient Indian thought, providing for mental,moral and spiritual development, inculcating the spirit ofnationalism and patriotism, preparing and publishing textbooks, providing food, clothing, shelter and medicines tothe needy persons, running of dispensaries, hospitals etc.As in the present case, the Trust Deed enabled carrying onof a business for and on behalf of the Trust for the soleobject of applying the income and profits to the mainobjects of the Trust. The Trust then commenced a businessfor the manufacture and sale of Katha (Catechu), the fundsfor which came from sister concerns of the Trustees,borrowing from Banks and other agencies. The Division Benchof the High Court relied on the distinction of a business held under a Trust and carried on by Trust as recognized inSurat Art Silk Manufacturers' Association; which as wenoticed does not regulate the dictum, since it is referredin the minority decision and that too without anyconsequence arising therefrom. It was held that the testto find a business as a property held under Trust shouldhave been either acquired with the help of the fundoriginally settled upon Trust or the same having asubstantial and real connection with the commencement ofthe business by the Trustees. It was also held that theapplication of the income generated from the business isnot the relevant consideration and what is relevant iswhether the activity is so inextricably connected or linkedwith the object of the trust that it could be considered asincidental to those objectives. Examples as quoted by thefirst appellate authority was also referred to; which aretwo instances of a charitable trust established forproviding medical relief running a nursing home or a trustfor advancement of education running a publishing house ora news paper.14. The declaration of the Hon'ble Supreme Courtin Thanthi Trust as extracted herein above (paragraph 25)was distinguished on the following reasoning: “25. In our opinion these observations have tobe understood in the light of the facts before theSupreme Court. Thanthi Trust carried on the businessof a newspaper and that business itself was heldunder trust. The charitable object of the trust wasthe imparting of education which falls under Section2(15) of the Act. The newspaper business wascertainly incidental to the attainment of the objectof the trust, namely that of imparting education.The observations were thus made having regard to thefact that the profits of the newspaper business wereutilised by the trust for achieving the object,namely education. The type of nexus or connectionwhich existed between the imparting of education andthe carrying on of the business of a newspaper doesnot exist in the present case. There is no suchnexus between the Katha business and the objects ofthe assessee-trust that can constitute the carryingon of the katha business an activity incidental tothe attainment of the objects, namely advancing ofeducation, patriotism, Indian culture, running ofhospitals and dispensaries, etc. It would in ouropinion be disastrous to extend the sweep of theobservations made by the Supreme Court (quotedabove) in the case of Thanthi Trust (supra), on thefacts of that case, to all cases where the trustcarries on business which is not held under trustand whose income is utilised to feed the charitableobjects of the trust. We are, therefore, of therespectful opinion that the observations of the Supreme Court must be understood and appreciated inthe background of the facts in that case and shouldnot be extended indiscriminately to all cases”. 15. With all the respect at our command, we areunable to agree with the Delhi High Court insofar as thedistinction drawn from Thanthi Trust. As to whether thebusiness commenced by the Trust was from the funds settledon the Trust, we do not think it applies in the presentcase. The Delhi High Court was concerned with thecommencement of a manufacturing business, which requiresconsiderable capital whereas here we are concerned with aChitty/Kuri business wherein no such initial investment isrequired. On the distinction drawn, we have to notice thatthe Hon'ble Supreme Court while considering the assessmentprior to 01.04.1984 with specific reference to Section13(1)(bb) held so in paragraph 18 to decline claim forexemption. "18. The business that the Trust carries on isthat of running a newspaper. That business, thoughit is held by the Trust as a part of its corpus,and, therefore, in trust, does not directlyaccomplish, wholly or in part, the Trust’s objectsof relief of the poor and education. Its income onlyfeeds such activity. It cannot be held to be carried "18. The business that the Trust carries on isthat of running a newspaper. That business, thoughit is held by the Trust as a part of its corpus,and, therefore, in trust, does not directlyaccomplish, wholly or in part, the Trust’s objectsof relief of the poor and education. Its income onlyfeeds such activity. It cannot be held to be carried on in the course of the actual accomplishment of theTrust’s objects of education and relief of the poor.It is, therefore, not possible to accept theargument on behalf of the Trust that it is entitledto the exemption under Section 11". This is the specific example pointed out by the Delhi HighCourt after the amendment of Sub-section (4A) of Section 11in 1992; to distinguish the decision in Thanthi Trustwhichdenied the exemption in the earlier years when Section13(1)(bb) was in the statute. Thanthi Trustcited almostidentical examples while denying the exemption when Section13(1)(bb) was available in the statute. After deletion ofSection 13(1)(bb) and introduction of the new sub-section(4A) under Section 11 in the year 1992, the Hon'ble SupremeCourt in Thanthi Trustheld that if the income from thebusiness is utilized for achieving the objectives of thetrust or institution, then it is incidental to theattainment of the objectives of the Trust. We have tofollow the above dictum of the Hon'ble Supreme Court whichis binding on us under Article 141 of the Constitution ofIndia. The observation of the Delhi High Court:It would inour opinion be disastrous to extend the sweep of theobservations made by the Supreme Court (quoted above) in the case of Thanthi Trust (supra), on the facts of thatcase, to all cases where the trust carries on businesswhich is not held under trust and whose income is utilisedto feed the charitable objects of the trust'; according tous, does not subserve judicial discipline. 16. We also notice that the definition clause under Section 2(15) for the relevant year stood as below: “2(15) “charitable purpose” includes relief ofthe poor, education, medical relief, preservation ofenvironment (including watersheds, forests andwildlife) and preservation of monuments or places orobjects of artistic or historic interest, and theadvancement of any other object of general publicutility: Provided that the advancement of any otherobject of general public utility shall not be acharitable purpose, if it involves the carrying onof any activity in the nature of trade, commerce orbusiness, or any activity of rendering any servicein relation to any trade, commerce or business, fora cess or fee or any other consideration,irrespective of the nature of use or application, orretention, of the income from such activity: Provided further that the first proviso shall not apply if the aggregate value of the receipts from the activities referred totherein is twenty-five lakh rupees or less in theprevious year”. We are of the opinion that the first Proviso brought in thesame effect as spoken of in Dharmaposhanam, on exemptionwhich respect to carrying on a public utility. But 'medicalrelief' is not qualified with those words; as has beenfound in Dharmadeepti as affirmed in Surat Art Silk'Manufacturers Association. On the above reasoning weanswer the question of law in the negative and in favour ofthe assessee and against the Revenue.The appeal would stand allowed. Parties are leftto suffer their respective costs. Sd/-K.VINOD CHANDRANJUDGE Vku/- Sd/-T.R.RAVIJUDGE APPENDIX APPELLANT'S ANNEXURES: ANNEXURE ATRUE COPY OF THE REGISTRATION CERTIFICATE DATED 20.04.2001 ISSUED BY THE COMMISSIONER OF INCOME TAX, COCHIN.DATED 20.04.2001 ISSUED BY THE COMMISSIONER OF INCOME TAX, COCHIN. ANNEXURE BTRUE COPY OF THE ASSESSMENT ORDER DATED 14.11.2014 FOR AY 2012-13 ISSUED BY THE INCOME TAX OFFICER WARD 1(1), THRISSUR.DATED 14.11.2014 FOR AY 2012-13 ISSUED BY THE INCOME TAX OFFICER WARD 1(1), THRISSUR. Sd/-K.VINOD CHANDRANJUDGE Vku/- Sd/-T.R.RAVIJUDGE APPENDIX APPELLANT'S ANNEXURES: ANNEXURE ATRUE COPY OF THE REGISTRATION CERTIFICATE DATED 20.04.2001 ISSUED BY THE COMMISSIONER OF INCOME TAX, COCHIN.DATED 20.04.2001 ISSUED BY THE COMMISSIONER OF INCOME TAX, COCHIN. ANNEXURE BTRUE COPY OF THE ASSESSMENT ORDER DATED 14.11.2014 FOR AY 2012-13 ISSUED BY THE INCOME TAX OFFICER WARD 1(1), THRISSUR.DATED 14.11.2014 FOR AY 2012-13 ISSUED BY THE INCOME TAX OFFICER WARD 1(1), THRISSUR. ANNEXURE CTRUE COPY OF THE CIRCULAR NO.11/2008 DATED 19.12.2008 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES.DATED 19.12.2008 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. ANNEXURE DTRUE COPY OF THE APPELLATE ORDER IN ITA NO.221/TCR/CIT(A)/14-15 DATED 18.07.2019 ISSUED BY THE CIT(A), THRISSUR.ITA NO.221/TCR/CIT(A)/14-15 DATED 18.07.2019 ISSUED BY THE CIT(A), THRISSUR. ANNEXURE ECERTIFIED COPY OF THE APPELLATE TRIBUNAL'S ORDER IN ITA NO.590/COCH/2019 DATED 08.01.2020 ISSUED BY THE ITAT, COCHIN BENCH, COCHIN.ORDER IN ITA NO.590/COCH/2019 DATED 08.01.2020 ISSUED BY THE ITAT, COCHIN BENCH, COCHIN. ANNEXURE FTRUE COPY OF THE ASSESSMENT ORDER DATED 19.03.1996 FOR AY 1993-94 ISSUED BY THE ASST.COMMISSIONER OF INCOME TAX, THRISSUR.DATED 19.03.1996 FOR AY 1993-94 ISSUED BY THE ASST.COMMISSIONER OF INCOME TAX, THRISSUR. ANNEXURE GTRUE COPY OF THE ASSESSMENT ORDER DATED 28/03/2015 ISSUED BY THE CONTRALISED PROCESSING CENTRE, BANGALORE, FOR THE ASSESSMENT YEAR 2013-14.DATED 28/03/2015 ISSUED BY THE CONTRALISED PROCESSING CENTRE, BANGALORE, FOR THE ASSESSMENT YEAR 2013-14. ANNEXURE HTRUE COPY OF THE ASSESSMENT ORDER DATED 0/2/03/2018 ISSUED BY THE DATED 0/2/03/2018 ISSUED BY THE CONTRALISED PROCESSING CENTRE, BANGALORE, FOR THE ASSESSMENT YEAR 2014-15.FOR THE ASSESSMENT YEAR 2014-15. ANNEXURE ITRUE COPY OF THE ASSESSMENT ORDER DATED 29/01/2018 ISSUED BY THE CONTRALISED PROCESSING CENTRE, BANGALORE, FOR THE ASSESSMENT YEAR 2016-17.DATED 29/01/2018 ISSUED BY THE CONTRALISED PROCESSING CENTRE, BANGALORE, FOR THE ASSESSMENT YEAR 2016-17. ANNEXURE JTRUE COPY OF THE ASSESSMENT ORDER DATED 09/03/2018 ISSUED BY THE CONTRALISED PROCESSING CENTRE, BANGALORE, FOR THE ASSESSMENT YEAR 2017-18.DATED 09/03/2018 ISSUED BY THE CONTRALISED PROCESSING CENTRE, BANGALORE, FOR THE ASSESSMENT YEAR 2017-18.