Ita/6/2017 Of Kerala State Co-Operative Agricultural & Rural Development Bank Ltd v. Commissioner Of Income Tax

IN THE HIGH COURT OF KERALA AT ERNAKULAMPRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE VIJU ABRAHAM FRIDAY, THE 24 DAY OF SEPTEMBER 2021 / 2ND ASWINA, 1943 ITA NO. 30 OF 2017 AGAINST THE ORDER IN ITA 101/2015 OF I.T.A.TRIBUNAL,COCHIN BENCH,ERNAKULAM APPELLANT/S: THE COMMISSIONER OF INCOME TAXTHIRUVANANTHAPURAM. BY ADVS.SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPTSRI.K.M.V.PANDALAI INCOME TAX DEPARTMENT RESPONDENT/S: KERALA STATE CO-OPERATIVE AGRICULTURAL & RURAL DEVELOPMENT BANK LTDSTATUE, THIRUVANANTHAPURAM-695001(AAAAK4391F) BY ADVS. JOSE JACOBJAZIL DEV FERDINANTO THIS INCOME TAX APPEAL HAVING COME UP FOR HEARING ON 24.09.2021,ALONG WITH ITA.2/2017, 6/2017 AND CONNECTED CASES, THE COURT ON THESAME DAY DELIVERED THE FOLLOWING: -2- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE VIJU ABRAHAM FRIDAY, THE 24 DAY OF SEPTEMBER 2021 / 2ND ASWINA, 1943 ITA NO. 2 OF 2017 AGAINST THE ORDER/JUDGMENT IN ITA 182/2015 OF I.T.A.TRIBUNAL,COCHINBENCH, ERNAKULAM APPELLANT/S: M/S. KERALA STATE CO-OP.AGRICULTURAL & RURAL DEVELOPMENT BANK LTD., TRIVANDRUM, REPRESENTED BY ITS GENERAL MANAGER &AUTHORISED SIGNATORY APARNA PRATHAP BY ADV SRI.JOSE JACOB RESPONDENT/S: COMMISSIONER OF INCOME TAX, AAYAKAR BHAVAN, KOWDIAR, TRIVANDRUM 695 001 OTHER PRESENT: SC CHRISTOPHER ABRAHAM THIS INCOME TAX APPEAL HAVING COME UP FOR HEARING ON 24.09.2021,ALONG WITH ITA.30/2017 AND CONNECTED CASES, THE COURT ON THE SAME DAYDELIVERED THE FOLLOWING: -3- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE VIJU ABRAHAM FRIDAY, THE 24 DAY OF SEPTEMBER 2021 / 2ND ASWINA, 1943 ITA NO. 6 OF 2017 AGAINST THE ORDER IN ITA 26/2015 OF I.T.A.TRIBUNAL,COCHIN BENCH,ERNAKULAM APPELLANT/S: KERALA STATE CO-OPERATIVE AGRICULTURAL & RURAL DEVELOPMENT BANK LTDTRIVANDRUM, REPRESENTED BY ITS MANAGING DIRECTOR & AUTHORISED SIGNATORY DR. P.SURESH BABU IAS. BY ADV SRI.JOSE JACOB RESPONDENT/S: COMMISSIONER OF INCOME TAXAAYAKAR BHAVAN, KOWDIAR, TRIVANDRUM-695001. SC CHRISTOPHER ABRAHAM THIS INCOME TAX APPEAL HAVING COME UP FOR HEARING ON 24.09.2021,ALONG WITH ITA.30/2017 AND CONNECTED CASES, THE COURT ON THE SAME DAYDELIVERED THE FOLLOWING: ITA Nos.2, 6, 30 & 31/2017 -4- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE VIJU ABRAHAM FRIDAY, THE 24 DAY OF SEPTEMBER 2021 / 2ND ASWINA, 1943 ITA NO. 31 OF 2017 AGAINST THE ORDER IN ITA 236/2015 OF I.T.A.TRIBUNAL,COCHIN BENCH, ERNAKULAM APPELLANT/S: THE COMMISSIONER OF INCOME TAXTHIRUVANANTHAPURAM BY ADVS.SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPTSRI.K.M.V.PANDALAI INCOME TAX DEPARTMENT RESPONDENT/S: M/S. KERALA STATE CO-OPERATIVE AGRICULTURAL AND RURAL DEVELOPMENT BANK LTD. STATUE, THIRUVANANTHAPURAM-695001.(AAAAK4391F) BY ADVS.JOSE JACOBJAZIL DEV FERDINANTO THIS INCOME TAX APPEAL HAVING COME UP FOR HEARING ON 24.09.2021, ALONG WITH ITA.30/2017 AND CONNECTED CASES, THE COURT ON THE SAME DAYDELIVERED THE FOLLOWING: J U D G M E N T [ITA Nos.30/2017, 2/2017, 6/2017, 31/2017] S.V. Bhatti, J. Heard learned Advocates Mr Jose Jacob and MrChristopher Abraham for parties. 2.The assessee and the Revenue being aggrieved by the orders of the Income Tax Appellate Tribunal on the issuesarsing in the returns filed for the Assessment Years 2010-11 and2011-12, have filed the four appeals. The details of theAssessment Years, appeals etc are stated in the followingtabular form: Appeals filed by the assessee -6- Appeals filed by the Revenue 3.ITA No.2/2017 and ITA No.30/2017 are treated as representative appeals for disposing of the four appeals. The questions of law raised in these appeals are excerpted ITA Nos.2, 6, 30 & 31/2017 hereunder: J U D G M E N T [ITA Nos.30/2017, 2/2017, 6/2017, 31/2017] S.V. Bhatti, J. Heard learned Advocates Mr Jose Jacob and MrChristopher Abraham for parties. 2.The assessee and the Revenue being aggrieved by the orders of the Income Tax Appellate Tribunal on the issuesarsing in the returns filed for the Assessment Years 2010-11 and2011-12, have filed the four appeals. The details of theAssessment Years, appeals etc are stated in the followingtabular form: Appeals filed by the assessee -6- Appeals filed by the Revenue 3.ITA No.2/2017 and ITA No.30/2017 are treated as representative appeals for disposing of the four appeals. The questions of law raised in these appeals are excerpted ITA Nos.2, 6, 30 & 31/2017 hereunder: ITA No.2/2017 a.Whether on the facts and in the circumstances of the case,and in law the Appellate Tribunal was justified in treating theAppellant as a co-operative bank' and denying the benefitunder Section 80P(2)(a)(i) of the Act, without considering thefact that the Appellant does not fall within the definition ofmeaning assigned to 'co-operative bank' in Part V of theBanking Regulation Act, 1949 (10 of 1949)? b. Whether the Appellate Tribunal has failed to appreciate thatthe Appellant, not being a primary cooperative bank, centralcooperative bank or a state cooperative bank, is not a co-operative bank and accordingly cannot be denied the benefitconferred on a cooperative society under Section 80P of theAct? c. Whether on the facts and in the circumstances of the case,and in law the Appellate Tribunal was justified in treating theAppellant as a 'co-operative bank' and denying the benefitunder Section 80P(2)(a)(i) of the Act, without considering theInformation received under RTI from the Registrar of Co-operative Societies and NABARD stating that the Appellant isnot a 'co-operative bank' and instead is a 'State LandDevelopment Bank' in accordance with Section 2(v) of NABARD Act, 1981 or a 'Co-operative Credit Society' in accordance withSection 5(ccii) of Part V of Banking Regulations Act, 1949? d. Whether the Appellate Tribunal committed an error infailing to appreciate that the Appellant is a 'State LandDevelopment Bank' as defined under NABARD Act, 1981 whichis distinct from the "Co operative Bank"? e. Whether on the facts and in the circumstances of the case,and in law the Appellate Tribunal was justified in not allowingdeduction of contributions made to Staff Retirement BenefitFund under Section 37 of the Act which is a special fund set uppurely as a welfare measure for the benefit of employees whichis also approved by the Registrar of Cooperative Societies? f. Whether on the facts and in the circumstances of the case,and in law the Appellate Tribunal was justified in not allowingdeduction of the contributions made to Staff RetirementBenefit Fund to the extent of actual withdrawals made by theemployees from the Staff Retirement Benefit Fund solely forthe reason that the same was not raised before any income taxauthorities before? g. Whether a disallowance under Section 40A(9) of the Act,leading to additions in the "profits of business" is susceptible totaxation independently, if the Appellant would be entitled to acomplete deduction of income from "Profit of business"available to a cooperative society under Section 80P of the Act? ITA Nos.2, 6, 30 & 31/2017 ITA No.30/2017 (i) After having held in the appeal filed by the assessee that theassessee is not entitled for the deduction under section 80P(2)(a)(i), is not the Tribunal contradicting itself when it holds thatthe assessee is entitled for deduction under section 80P(2)(a)(i)as a State Development Bank. Is not such an order perverse? g. Whether a disallowance under Section 40A(9) of the Act,leading to additions in the "profits of business" is susceptible totaxation independently, if the Appellant would be entitled to acomplete deduction of income from "Profit of business"available to a cooperative society under Section 80P of the Act? ITA Nos.2, 6, 30 & 31/2017 ITA No.30/2017 (i) After having held in the appeal filed by the assessee that theassessee is not entitled for the deduction under section 80P(2)(a)(i), is not the Tribunal contradicting itself when it holds thatthe assessee is entitled for deduction under section 80P(2)(a)(i)as a State Development Bank. Is not such an order perverse? (ii) Is not the decision of the Tribunal contrary to law andperverse, especially in view of the observation of the MadrasHigh Court in CIT Vs Madras Autorickshaw Drivers' Co-operative Society Ltd. [1983] 143 ITR 981 (MAD) which isaffirmed by the Apex Court in [2001] 249 ITR 330(SC): "The tax relief under section 80P(2)(a)(i) is a grant by Parliament notto a category of income but to a category of assessee, namely a co-operative society answering the description of a society engaged incarrying on the business of providing credit facilities to its members.If the society in question does not answer this description, it is notentitled to relief. For invoking or applying this provision, it is notpermissible to make a break-up of the income of the society as somuch derived from the provision of credit facilities and so much fromother income." (iii) In view of the finding of this Hon'ble High Court in itsdecision in the case of very same assessee in respect of AY2007-08 reported in 383 ITR 610 (Kerala) that the assessee is neither a primary agricultural credit society or a Primary Cooperative agricultural and rural development bank, has not theITAT erred in upholding the order of the CIT(A) grantingdeduction u/s 80P(2)(a)(i) treating it as a 'State DevelopmentBank?” 3.1The assessee claims deduction under Section 80P(2) of the Income Tax Act, 1961 (for short 'the Act') and the claim was disallowed both by the Tribunal and the authorities as wellin the orders referred to in the tabular statement. Hence, theappeals at the instance of the assessee. 3.2The Tribunal while rejecting the deduction underSection 80P(2) remanded the matter to the Assessing Officer forconsideration of assessee's entitlement for deduction as a ruralland development bank. Hence, the appeals at the instance ofthe Revenue. 3.3 The counsel appearing for the parties agreed that the principal claim for deduction of assessee, i.e., entitlement ofdeduction under Section 80P(2) of the Act, would have bearing ITA Nos.2, 6, 30 & 31/2017 on the outcome of the appeals filed by the Revenue. ITA No.2 & 6/2017 4.It is matter of record that the assessee claimeddeduction under Section 80P(2) of the Act for the AssessmentYear 2007-08 and the said claim of assessee was finallyconsidered by this Court in ITA No.103/2011, vide judgmentdated 26.11.2015, the appeal of the assessee was dismissed. Theassessee filed appeal before the Supreme Court and the matteris pending before the Supreme Court. 4.1The Supreme Court in Mavilayi Service Co-operativeBank Ltd. v. Commissioner of Income Tax[1] considered the scope,extent and applicability of Section 80P of the Act to co-operative societies registered under the Co-operative SocietiesAct. The dictum laid down by the Apex Court in Mavilayi ServiceCo-operative Bank Ltd. case is relied on by the assessee with ITA Nos.2, 6, 30 & 31/2017 4.It is matter of record that the assessee claimeddeduction under Section 80P(2) of the Act for the AssessmentYear 2007-08 and the said claim of assessee was finallyconsidered by this Court in ITA No.103/2011, vide judgmentdated 26.11.2015, the appeal of the assessee was dismissed. Theassessee filed appeal before the Supreme Court and the matteris pending before the Supreme Court. 4.1The Supreme Court in Mavilayi Service Co-operativeBank Ltd. v. Commissioner of Income Tax[1] considered the scope,extent and applicability of Section 80P of the Act to co-operative societies registered under the Co-operative SocietiesAct. The dictum laid down by the Apex Court in Mavilayi ServiceCo-operative Bank Ltd. case is relied on by the assessee with ITA Nos.2, 6, 30 & 31/2017 considerable force to claim the deduction under Section 80P(2)of the Act notwithstanding the judgment in assessee's own case.The assessee invites our attention to a few details received fromthe Reserve Bank of India under Right to Information Act andthe assessee's standing or status under the National Bank forAgricultural and Rural Development Act, 1981 (for short 'Act1981'). The judgment of this Court in ITA No.103/2011, it isargued, does not come in the way of this Court following thebinding precedent of the Supreme Court in Mavilayi Service Co-operative Bank Ltd. and allow the deduction claimed underSection 80P(2) of the Act. Therefore, the assessee prays forsetting aside the orders under appeal and extend the benefit ofdeduction claimed under Section 80P(2) of the Act to theassessee. 5.Per contra, Mr Christopher Abraham contends thatthe assessee relies on a few details, now furnished by either ITA Nos.2, 6, 30 & 31/2017 Reserve Bank of India or with reference to Act 1981 and apply the dictum of Mavilayi Service Co-operative Bank Ltd., to thecircumstances already considered by the Tribunal and theauthorities. He contends that while the Department is notdisputing the principle laid down in Mavilayi Service Co-operativeBank Ltd., its applicability to the case on hand with reference tobasic circumstances established by the assessee ought to beconsidered by either the Tribunal or authorities under the Act. 5.1It is contextual to refer to the following paragraphsfrom Mavilayi Service Co-operative Bank Ltd. on which substantialreliance has been made by the assessee. “39. The above material would clearly indicate that the limitedobject of section 80P(4) is to exclude co-operative banks thatfunction at par with other commercial banks i.e. which lendmoney to members of the public. Thus, if the BankingRegulation Act, 1949 is now to be seen, what is clear fromsection 3 read with section 56 is that a primary co-operativebank cannot be a primary agricultural credit society as such co- operative bank must be engaged in the business of banking asdefined by section 5(b) of the Banking Regulation Act, 1949,which means the accepting, for the purpose of lending orinvestment, of deposits of money from the public. Likewise,under section 22(1)(b) of the Banking Regulation Act, 1949 asapplicable to co-operative societies, no co-operative societyshall carry on banking business in India, unless it is a co-operative bank and holds a licence issued in that behalf by theRBI. As opposed to this, a primary agricultural credit society isa co-operative society, the primary object of which is to providefinancial accommodation to its members for agriculturalpurposes or for purposes connected with agricultural activities. …..... …..... operative bank must be engaged in the business of banking asdefined by section 5(b) of the Banking Regulation Act, 1949,which means the accepting, for the purpose of lending orinvestment, of deposits of money from the public. Likewise,under section 22(1)(b) of the Banking Regulation Act, 1949 asapplicable to co-operative societies, no co-operative societyshall carry on banking business in India, unless it is a co-operative bank and holds a licence issued in that behalf by theRBI. As opposed to this, a primary agricultural credit society isa co-operative society, the primary object of which is to providefinancial accommodation to its members for agriculturalpurposes or for purposes connected with agricultural activities. …..... …..... 45. To sum up, therefore, the ratio decidendi of Citizen Co-operative Society Ltd. (supra), must be given effect to. Section80P of the IT Act, being a benevolent provision enacted byParliament to encourage and promote the credit of the co-operative sector in general must be read liberally andreasonably, and if there is ambiguity, in favour of the assessee.A deduction that is given without any reference to anyrestriction or limitation cannot be restricted or limited byimplication, as is sought to be done by the Revenue in thepresent case by adding the word "agriculture" into section 80P(2)(a)(i) when it is not there. Further, section 80P(4) is to beread as a proviso, which proviso now specifically excludes co-operative banks which are co-operative societies engaged inbanking business i.e. engaged in lending money to members ofthe public, which have a licence in this behalf from the RBI.Judged by this touchstone, it is clear that the impugned FullBench judgment is wholly incorrect in its reading of CitizenCooperative Society Ltd. (supra). Clearly, therefore, oncesection 80P(4) is out of harm's way, all the assessees in thepresent case are entitled to the benefit of the deductioncontained in section 80P(2)(a)(i), notwithstanding that theymay also be giving loans to their members which are notrelated to agriculture. Also, in case it is found that there areinstances of loans being given to non-members, profitsattributable to such loans obviously cannot be deducted.” 5.2The assessee, by referring to the definition of “Co-operative Bank”; “Central Co-operative Bank”; “State Co-operative Bank”; and “Primary Co-operative Bank” as defined inthe Banking Regulation Act, 1949 read with State LandDevelopment Bank in Section 2(v) of the Act 1981, contends thatthe assessee was and is a Co-operative Society catering to the needs of its constituent members, who are none other than the District Level Land Development Banks and the assessee is notinto banking business, therefore, is entitled to the deduction ofSection 80P(2). 6.We have taken note of the circumstances adverted to above. Firstly, in assessee's own case in ITA No.103/2011, thisCourt has considered the standing of the assessee vis-a-visSection 80P(2) of the Act and denied the claim for deduction asa Co-operative Society. The said judgment is in appeal beforethe Supreme Court. In Mavilayi Service Co-operative Bank Ltd.case, from the paragraphs excerpted above, it is argued byrefering to additional details, brought on record that theassessee is entitled to the claim as Co-operative Societyregistered under the Kerala Co-operative Societies Act, 1969 andmerits acceptance of its claim for deduction under Section80P(2) of the Act. There is consensus in the arguments of both ITA Nos.2, 6, 30 & 31/2017 sides that even for applying the principle of Mavilayi Service Co- operative Bank Ltd. case, independent of the judgment in ITANo.103/2011, a few details are examined, a finding recorded andthen the principle laid down in Mavilayi Service Co-operative BankLtd. case could be applied. ITA Nos.2, 6, 30 & 31/2017 sides that even for applying the principle of Mavilayi Service Co- operative Bank Ltd. case, independent of the judgment in ITANo.103/2011, a few details are examined, a finding recorded andthen the principle laid down in Mavilayi Service Co-operative BankLtd. case could be applied. 6.1We are of the view that instead of following theassessee's own case in ITA No.103/2011 and dismissing theappeals of the assessee or alternatively follow Mavilayi ServiceCo-operative Bank Ltd. without examination of a few details andgrant the status of Society for enabling the assessee fordeduction under Section 80P(2), the matter requires to bereconsidered by the Tribunal. These questions could beanswered in favour of the assessee to the limited extent that thematter requires reconsideration by the Tribunal on the claim ofassessee as a Co-operative Society and the entitlement todeduction under Section 80P(2) of the Act. The assessee and the ITA Nos.2, 6, 30 & 31/2017 Department are given liberty to place additional materials, now brought on record in the appeals before the Tribunal fordecision and consideration. The questions are answered in favour of the assessee, against the Revenue, resulting in the order under appeal in ITANos.2 & 6/2017 being set aside, and remitted to Tribunal foradjudication afresh. ITA Nos.30 & 31/2017 7.The Revenue being aggrieved by the relief granted by the Tribunal, particularly after rejecting the claim of assesseefor deduction under Section 80P(2), the alternate prayer which,according to Revenue, is unavailable under the Act and shouldnot have been granted. It is not in dispute that the alternateprayer now granted is definitely dependent on the outcome ofentitlement of assessee for deduction under Section 80P(2) ofthe Act. The consideration of the questions of law now raised ITA Nos.2, 6, 30 & 31/2017 by the Revenue in these appeals would pre-empt consideration of the issue by the Tribunal. The Assessment Years are same inboth the appeals. For facilitating comprehensive adjudication,the portion by which the Revenue is aggrieved is also set aside,matter remitted to Tribunal for decision afresh in accordancewith law. The questions in ITA Nos.2, 6 30 and 31/2017 are answeredsetting aside the portion by which the assessee and the Revenueare aggrieved, and cases remanded to the Tribunal for decisionafresh. Sd/- S.V.BHATTIJUDGE Sd/- VIJU ABRAHAMJUDGE jjj APPENDIX OF ITA 31/2017 PETITIONER ANNEXURE ANNEXURE A TRUE COPY OF THE ORDER U/S 143(3) OF THE INCOME TAX ACT, 1961 OF THE ASSESSING OFFICER DATED 30.12.2013. ANNEXURE BTRUE COPY OF THE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS), THIRUVANANTHAPURAM DATED 28.11.2014. ANNEXURE C TRUE COPY OF THE ORDER OF THE ITAT, COCHIN BENCH, COCHIN IN ITA No. 236/COCH/2015, FOR THE ASST.YEAR 2011-12 DATED 03.11.2016. ITA Nos.2, 6, 30 & 31/2017 APPENDIX OF ITA 2/2017 PETITIONER ANNEXURE ANNEXURE ATRUE COPY OF THE ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(2), TRIVANDRUM FOR THE AY 2010-11 ANNEXURE BTRUE COPY OF THE ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(2), TRIVANDRUM FOR THE AY 2011-12DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(2), TRIVANDRUM FOR THE AY 2011-12 ANNEXURE CTRUE COPY OF THE CIT(A) ORDER ISSUED BY THE COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2010-11COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2010-11 ANNEXURE DTRUE COPY OF THE CIT(A) ORDER ISSUED BY THE COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2011-12COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2011-12 ANNEXURE ETRUE COPY OF THE ITAT ORDER ISSUED BDY THE INCOMETAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN FOR AY 2010-11 AND AY 2011-12TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN FOR AY 2010-11 AND AY 2011-12 ANNEXURE BTRUE COPY OF THE ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(2), TRIVANDRUM FOR THE AY 2011-12DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(2), TRIVANDRUM FOR THE AY 2011-12 ANNEXURE CTRUE COPY OF THE CIT(A) ORDER ISSUED BY THE COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2010-11COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2010-11 ANNEXURE DTRUE COPY OF THE CIT(A) ORDER ISSUED BY THE COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2011-12COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2011-12 ANNEXURE ETRUE COPY OF THE ITAT ORDER ISSUED BDY THE INCOMETAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN FOR AY 2010-11 AND AY 2011-12TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN FOR AY 2010-11 AND AY 2011-12 ANNEXURE FTRUE COPY OF THE INFORMATION RECEIVED ON ACCOUNT OF RTI APPLICATIONS MADE TO NABARD, REGISTRAR OF CO-OP SOCIETIESACCOUNT OF RTI APPLICATIONS MADE TO NABARD, REGISTRAR OF CO-OP SOCIETIES APPENDIX OF ITA 6/2017 PETITIONER ANNEXURE ANNEXURE ATRUE COPY OF THE ASSESSMENT ORDER ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(2), TRIVANDRUM FOR THE AY 2011-12 ANNEXURE BTRUE COPY OF THE CIT(A) ORDER ISSUED BY THE COMMISSIONER OF INCOME TAX (APPEALS) TRIVANDRUM FOR THE AY 2011-12 ANNEXURE CTRUE COPY OF THE ITAT ORDER ISSUED BDY THE INCOMETAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN FOR AY 2011-12 ANNEXURE DTRUE COPY OF THE INFORMATION RECEIVED ON ACCOUNT OF RTI APPLICATIONS MADE TO NABARD, REGISTRAR OF CO-OP SOCIETIES PETITIONER ANNEXURE ANNEXURE A ANNEXURE B ANNEXURE C APPENDIX OF ITA 30/2017 TRUE COPY OF THE ORDER U/S 143(3) OF THE INCOME TAX ACT, 1961 OF THE ASSESSING OFFICER DATED 19.03.2013. TRUE COPY OF THE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS), THIRUVANANTHAPURAM DATED 30.01.2015. TRUE COPY OF THE ORDER OF THE ITAT, COCHIN BENCH, COCHIN IN ITA No. 101/COCH/2015, FOR THE ASST.YEAR 2010-11 DATED 03.11.2016.