Srinidhi Karti Chidambaram v. The Principal Chief Commissioner Of Income Tax, (Tamil Nadu And Puducherry) Main Building

IN THE HIGH COURT OF JUDICATURE AT MADRAS The Hon'ble Mr.Justice T.S.Sivagnanam Writ Petition Nos.8832 to 8835, 8840 and 8841 of 2018 andW.M.P.Nos.10701, 10702 and 10706 of 2018 Srinidhi Karti Chidambaram...PetitionerVs. 1. The Principal Chief Commissioner of Income Tax, (Tamil Nadu and Puducherry) Main Building, No.121, Nungambakkam High Road, Chennai - 600 034. 2. The Director General of Income Tax (Investigation) New Building, 2nd Floor, Investigation Wing, New. No.45, Old No.108, Nungambakkam High Road, Chennai - 600 034. 3. The Deputy Director of Income Tax (Investigation) Unit - 3 (3) Room No.120, First Floor, Investigation Wing Building, No.45, Uthamar Gandhi Road, Nungambakkam High Road, Chennai - 600 034. 4. The Deputy Director of Income Tax(Investigation) Unit -3(2), Room.No.120, 1[st] Floor, Investigation Wind Building, No.45, Uthamar Gandhi Road, Nungambakkam, Chennai 600 034. ..WP.No.8834/2018 Writ Petition, filed under Article 226 of the Constitutionof India, for issuance of Writ of Prohibition, prohibiting thefirst respondent from sanctioning any prosecution against thepetitioner and the respondent No.2 and 3 from instituting anyprosecution against the petitioner, under Chapter V of the Act,(Act 22 of 2015) before the Special Court for Economic Offencesor any other appropriate Court having jurisdiction over thesubject matter. https://hcservices.ecourts.gov.in/hcservices/ For Petitioner in W.P.Nos. 8832 to 8835 of 2018 Mr.N.Venkataraman, Senior Counsel for M/s. C.Uma For Petitioner in W.P.Nos. 8840 to 8841 of 2018 Mr. Sathish Parasaran, Senior Counsel for M/s. C.Uma For Respondents in all W.P.Nos. Mr. A.P.Srinivas, Senior Standing Counsel andMr. A.N.R.Jayaprathap. COMMON ORDER These Writ Petitions can be segregated into two categories.In the first category of Writ Petitions, i.e., in Writ PetitionNos.8832, 8834 and 8840 of 2018, the petitioners seek for aissuance of Writ of Prohibition, prohibiting the firstrespondent from sanctioning any prosecution against them and therespondent No.2 and 3 from instituting any prosecution againstthe petitioners, under Chapter V of the Black Money (UndisclosedForeign Income and Assets) and Imposition of Tax Act, 2015, (Act22 of 2015, for brevity) before the Special Court for EconomicOffences, or any other appropriate Court, having jurisdictionover the subject matter. 2.In the second category, i.e., Writ Petition Nos.8833,8835 and 8841 of 2018, the petitioners have sought for adirection upon the third respondent, Deputy Director of IncomeTax (Investigation), Unit - 3 (3) to pass an order forthwithunder Section 10 (3) of the Act 22 of 2015, pursuant to thenotices issued under Section 10 (1) of the Act, 22 of 2015,dated 04.08.2017, 08.08.2017, 01.11.2017 and 30.01.2018, andalso pursuant to the enquiry conducted. 3.At the request of the learned Senior Counsel appearingfor the petitioners, W.P.Nos.8834 and 8835 of 2018 are taken aslead cases, for, the learned Senior Counsel would submit that,any decision rendered in these Writ Petitions, would apply tothe other Writ Petitions as well, since the facts are identical.4.W.P.No.8834 of 2018, falls under the first category ofWrit Petitions, i.e, Writ of Prohibition, and W.P.No.8835 of2018, falls under the second category, i.e., Writ of Mandamus. 5.The third respondent issued a notice to thepetitioner/assessee, dated 04.08.2017, under Section 10 (1) ofthe Act, stating that, pursuant to the receipt of information to https://hcservices.ecourts.gov.in/hcservices/ 3.At the request of the learned Senior Counsel appearingfor the petitioners, W.P.Nos.8834 and 8835 of 2018 are taken aslead cases, for, the learned Senior Counsel would submit that,any decision rendered in these Writ Petitions, would apply tothe other Writ Petitions as well, since the facts are identical.4.W.P.No.8834 of 2018, falls under the first category ofWrit Petitions, i.e, Writ of Prohibition, and W.P.No.8835 of2018, falls under the second category, i.e., Writ of Mandamus. 5.The third respondent issued a notice to thepetitioner/assessee, dated 04.08.2017, under Section 10 (1) ofthe Act, stating that, pursuant to the receipt of information to https://hcservices.ecourts.gov.in/hcservices/ the effect that, the assessee have made certain investments inacquiring assets abroad, particularly, in respect of theproperty, in Cambridge and the sale consideration was effectedby the assessee for the financial year 2014-15, relating to theAY 2015-16, and that, the assessee has not disclosed the saidForeign assets/Foreign interests fully in Schedule FA of thereturn of income filed by him for the AY 2016-17 on 30.07.2016,and for the purpose of making an assessment in the assessee'sown case under Act 22 of 2015, the assessee was directed tofurnish certain informations/documents. 6. The petitioner, through his Authorized Representative,sent a reply, dated 17.08.2017, questioning the validity of thenotice, dated 04.08.2017, and stated that, foreign remittancefor purchase of the said foreign asset was through normalbanking channels, as per RBI guidelines, enclosed documents inthe form of annexures, and prayed for withdrawal of the noticeissued under Section 10 (1) of the Act. Subsequently, anothernotice was issued to the petitioner, dated 08.08.2017, for theAY 2016-17, in which, copies of documents in respect ofinvestments made by M/s. Chess Global Advisory Services PrivateLimited were called for. This was followed by another notice,dated 21.08.2017, calling for further information in respect ofcertain investments made in Foreign Countries. After theissuance of the aforesaid three notices, the third respondentissued summons under Section 8 (1) of the Act, dated 01.11.2017,calling upon the assessee to appear on 06.11.2017, for givingevidence. 7. Mr.N.Venkataraman, the learned Senior Counsel for M/s.C.Uma, learned counsel for the petitioners/assessees submittedthat the documents sought for by the third respondent have beenfurnished and in spite of the receipt of the documents, thethird respondent is yet to pass orders under Section 10 (3) ofthe Act. Whileso, the Deputy Director of Income Tax(Investigation), Unit - 3 (2) (fourth respondent in W.P.Nos.8834and 8834 of 2018) issued summons to the assessee, dated09.04.2018, directing the petitioner to appear in person beforethe Officer and produce copies of details, listed as 1) to 6)thereunder, under the heading ''Details/Documents to beproduced", which are extracted hereinbelow: 1) The copy of affidavit filed before the Supreme Court stated in the reply filed by your Advocate, dated 07.02.2018; 2) The copy of the Bank Statement of Metro Bank account 20113723 and 21689491; 3) The copies of the KYC documents submitted during opening of account in Metro Bank; 4) Details of funds transferred to the said Metro Bank Accounts through LRs (if any); 5) Details of immovable assets owned by you in abroad, in your name or anyone else name belonging to you either wholly or partly; belonging to you either wholly or partly; 6) List of Bank accounts, including operative / inoperative / closed accounts along with copies of statements maintained by you in abroad 1) The copy of affidavit filed before the Supreme Court stated in the reply filed by your Advocate, dated 07.02.2018; 2) The copy of the Bank Statement of Metro Bank account 20113723 and 21689491; 3) The copies of the KYC documents submitted during opening of account in Metro Bank; 4) Details of funds transferred to the said Metro Bank Accounts through LRs (if any); 5) Details of immovable assets owned by you in abroad, in your name or anyone else name belonging to you either wholly or partly; belonging to you either wholly or partly; 6) List of Bank accounts, including operative / inoperative / closed accounts along with copies of statements maintained by you in abroad 8.The learned Senior Counsel further contended that, interms of Section 3 of the Act, 22 of 2015, there shall be chargeon every assessee for every assessment year, commencing on orafter the first day of April, 2016, subject to the provisions ofthe said Act, and tax, in respect of his total undisclosedforeign income and asset of the previous year at the rate ofthirty percent on such undisclosed income and asset. It issubmitted that, there are three conditions, which are requiredto be satisfied by the Officer to invoke such provisions of theAct, 22 of 2015, viz., i) Undisclosed income; ii) Undisclosedinvestments; and iii) Non-disclosures in the Income Tax Returns (ITRs). 9. It is submitted that, unless, these aforementionedthree conditions are fulfilled, the question of invoking theprovision of Act 22 of 2015 does not arise. To buttress hissubmission that the petitioners/assessees have disclosed theirincome, investments/source and also the ITRs, the learned SeniorCounsel referred to the ITRs filed for the AYs 2015-16 and 2016-17, in particular, the details of Foreign assets and income fromany source outside India, in Schedule FA. The learned SeniorCounsel took great pains to compare the figures to show that theentire investment has been fully disclosed in the ITRs and thefigures tally and there is no discrepancies in the same. 10.Further, it is submitted that, with regard to thesource and the manner of investment, reference was made to theappointment of M/s.Hewitson, as their Legal Specialist, for thepurchase of the said asset. In this regard, the agreemententered into between the assessee and M/s.Hewitson and the taxinvoices were referred to. The learned Senior Counsel alsoreferred to the financial statement and completion statementgiven by M/s. Hewitson. It is submitted that, the monies weretransferred through proper banking channels to the nominee'sBank and after transactions were over, bank account has beenclosed. The learned Senior Counsel also referred to theofficial copy of register of title standing in the name of theassessee. 10.Further, it is submitted that, with regard to thesource and the manner of investment, reference was made to theappointment of M/s.Hewitson, as their Legal Specialist, for thepurchase of the said asset. In this regard, the agreemententered into between the assessee and M/s.Hewitson and the taxinvoices were referred to. The learned Senior Counsel alsoreferred to the financial statement and completion statementgiven by M/s. Hewitson. It is submitted that, the monies weretransferred through proper banking channels to the nominee'sBank and after transactions were over, bank account has beenclosed. The learned Senior Counsel also referred to theofficial copy of register of title standing in the name of theassessee. 11. Thus, it is submitted that, there is absolutely nomaterial available in the hands of the third respondent forinitiating proceeding under the provisions of Act 22 of 2015.In any event, the petitioners, having furnished all the relevantdetails to the third respondent, though nine months had elapsed,till date, no orders have been passed under Section 10 (3) ofthe Act. It is further submitted that, while factual situationremain thus, a new Officer, viz., the the Deputy Director ofIncome Tax (Investigation), Unit - 3 (2), who is the fourthrespondent in W.P.Nos.8834 and 8835 of 2018 has issued summonsto the petitioners under Section 8 (1) of the Act, and thiswould clearly shows that two Authorities are examining the samematter, and it is sheer harassment on the assessees. Further,it is submitted that, the way the matter has proceeded, willclearly show that there is no intention for the Authorities tofinalize the matter, but, only to harass the assesses. In thisregard, it is stated that the fourth respondent is attempting toinitiate parallel proceedings, as apart from the CambridgeProperty, there is no property owned by the assessee outsideIndia. 12.With these submissions, the learned Senior Counselstressed that the petitioners have no intention to stall theproceedings initiated under Section 10 (1) of the Act, but whatthey seek is for earlier conclusion of the issue, and therefore,the learned counsel prays for an appropriate direction,directing the third respondent to forthwith pass an order underSection 10 (3) of the Act 22 of 2015. Further, it is submittedthat, the fourth respondent is attempting to initiateproceedings under Section 8 (1) of the Act, insisting uponpersonal appearance of the petitioner, when the third respondenthad initiated the proceedings under Section 10 (1) of the Act. 13.Mr.Sathish Parasaran, the learned Senior Counsel forM/s. C.Uma, in W.P.Nos.8840 and 8841 of 2018, submitted that,when the petitioners have reasonable apprehension that therespondent/Income Tax Department will initiate prosecution andconsidering the peculiarity of Act 22 of 2015 and the wordings,the manner, in which, Section 48 has been worded, thepetitioners apprehends that prosecution will be initiated, andsince the petitioner is cooperating with the assessmentproceedings, a Writ of prohibition should be issued, prohibitingthe respondent/Department from initiating prosecution, in termsof Section 48 of the Act. 14. Mr. A.P.Srinivas, the learned Senior Standing Counselfor the respondents submitted that, it is no doubt true that, inresponse to the notice under Section 10 (1) of the Act, dated04.08.2017, initially, the assessee submitted part of the https://hcservices.ecourts.gov.in/hcservices/ 14. Mr. A.P.Srinivas, the learned Senior Standing Counselfor the respondents submitted that, it is no doubt true that, inresponse to the notice under Section 10 (1) of the Act, dated04.08.2017, initially, the assessee submitted part of the https://hcservices.ecourts.gov.in/hcservices/ informations on 17.08.2017 along with annexures, andsubsequently, notices were issued, calling upon the petitionerto furnish further details and these proceedings are now dealtwith by the third respondent, Deputy Director of Income Tax(Investigation) Unit - 3 (3), and after receiving requisitedetails, the third respondent has issued summons under Section 8(1) of the Act, dated 01.11.2017. So far as the summons by theDeputy Director of Income Tax (Investigation) Unit - 3 (2), thefourth respondent is concerned, it is incorrect to state that hehas straightaway issued summons under Section 8 (1) of the Act,but, he has done so, only after issuing notice under Section 10(1) of the Act. In response to the same, the assessee, throughtheir counsel, sent a reply, dated 17.08.2017, stating that theDeputy Director of Income Tax (Investigation) Unit - 3 (2)should not insist upon appearance of the assessee, eitherpersonally or through their representative, and this being thereason, the summons under Section 8 (1) of the Act was issuedfor personal appearance to produce the information called for.Further, it is submitted that, the question of issuing writ ofprohibition, prohibiting the respondents from initiatingprosecution against the petitioners does not arise and such aprayer is not maintainable in law. In this regard, referencewas made to the decision rendered by this Court, in KrishnaswamiVijayakumar Vs. The Principal Director of Income Tax, inW.P.No.29464 of 2017, dated 17.11.2017. 15.Heard Mr.N.Venkataraman, the learned Senior Counsel forM/s. C.Uma, the learned counsel for petitioners in W.P.Nos. 8832to 8835 of 2018, Mr. Sathish Parasaran, the learned SeniorCounsel for M/s. C.Uma for petitioners in W.P.Nos. 8840 and 8841of 2018, and Mr. A.P.Srinivas, the learned Senior StandingCounsel for the respondent/Income Tax Department, and carefullyperused the materials. 16.In the second category of Writ Petitions, thepetitioners seek for a direction upon the third respondent, topass final orders under Section 10 (3) of Act 22 of 2015. Thestatute prescribes an outer time limit, within which, theAuthority is entitled to pass final orders. Therefore, tocompel the Authority to pass final orders well before the timestipulated in the statute is not feasible of consideration.When the statute prescribe an outer time limit, the Court, whileexercising its power under Article 226 of the Constitutionshould not interfere with the said power, i.e., either byreducing the time limit prescribed under the statute or byincreasing the time limit. While considering the power of theStatutory Authorities to condone delay, in filing the AppealPetition before them, the Courts have held that, when thestatute prescribes an outer time limit, as limitation period,then, the Court, exercising its power under Article 226 of the Constitution cannot extend the time limit prescribed under thestatute. Constitution cannot extend the time limit prescribed under thestatute. 17. Insofar as Act 22 of 2015 is concerned, time given forcompletion of assessment and reassessment is only in terms ofSection 11 of the Act. Section 11 (1) of the Act states that,no order of assessment or reassessment shall be made underSection 10, after the expiry of two years from the end of thefinancial year, in which, the notice under sub-section (1) ofSection 10 was issued by the Assessing Officer. Sub-section (2)commences with a non obstante clause, stating that,notwithstanding anything contained in Section (1) of the Act, anorder of fresh assessment in pursuance of an order passed underSection 18 setting aside or cancelling an assessment, may bemade at any time before the expiry of the period of two yearsfrom the end of the financial year, in which, the order underSection 18 is received by the Principal Commissioner or theCommissioner. 18.Thus, the prayer sought for by the petitioners in thesecond category of Writ Petitions, i.e. to direct the thirdrespondent to forthwith pass orders under Section 10 (3) of theAct, if acceded to, it would be contrary to the statutoryprovisions under Section 11 (1) of the Act. Therefore, such apositive direction cannot be issued. 19.With regard to the first category of cases, praying forissuance of a writ of prohibition, the submission of the learnedSenior Counsel for the petitioners is that, the Deputy Directorof Income Tax (Investigation) Unit - 3 (2), viz., the fourthrespondent in W.P.Nos.8834 and 8835 of 2018, is dealing with thevery same subject matter, which is seized of and dealt by thethird respondent, in which, notices have been issued and thefourth respondent cannot proceed parallely. Second limb of thesubmission is that, Deputy Director of Income Tax(Investigation) Unit - 3 (2) straightaway issued summons underSection 8 (1) of the Act. However, I find that, it is factuallyincorrect statement made by the assessees, as the DeputyDirector of Income Tax (Investigation) Unit - 3 (2) has notstraightaway issued summons under Section 8 (1) of the Act, butwas preceded with notice under Section 10 (1), dated 30.01.2018,and to the said notice, the assessee through their counsel, senta reply, stating that the Deputy Director of Income Tax(Investigation) Unit - 3 (2) should not insist upon appearanceof the assessee, either personally or through theirrepresentative, and this appears to be the reason, whichtriggered of the summons under Section 8 (1) of the Act. 20. With regard to the first limb of the submission thatthe Deputy Director of Income Tax (Investigation) Unit - 3 (2) https://hcservices.ecourts.gov.in/hcservices/ is also dealing with the same matter pending before the thirdrespondent, is a question of fact, which should be adjudicatedbefore appropriate Authority and not in a Writ Petition, underArticle 226 of the Constitution, however, this Court, primafacie, is of the view that, what is being dealt with by thethird respondent is pertaining to the Cambridge property andcertain investments in Nano Holdings LLC, USA made by M/s. ChessGlobal Advisory Services Private Limited and the summons issuedby the Deputy Director of Income Tax (Investigation) Unit - 3(2), dated 09.04.2018, callings for i) Copies of the affidavitfiled before the Hon'ble Supreme Court; ii) Copy of the bankstatement of Metro Bank account; iii) Copies of the KYCdocuments; iv) Details of funds transferred to the said MetroBank accounts thorugh their LrS (if any); v) Details ofimmovable assets owned by the assessee in abroad, in his name orany one else name belonging to the assessee either wholly orpartly; and vi) List of bank accounts, includingoperative/inoperative/closed accounts along with copies ofstatements maintained by the assessee in abroad. 21.Thus, I am not inclined to agree with the second limbof the submission of the learned Senior Counsel for thepetitioners that both the third respondent and the DeputyDirector of Income Tax (Investigation) Unit - 3 (2) areexamining the same issue. However, this Court refrains fromexpressing any findings on this aspect, and it is for theassessee to establish the same before appropriate forum. In theconnection, the learned Senior Counsel for petitioners wouldcontend that the petitioners are not challenging the noticesissued against them under Act, 22 of 2015 or the proceedingsinitiated the under the Section 8 (1) of the Act, but what theyseek is for earlier conclusion of the matter, as the proceedingsare hanging like Damocles' Sword over the head of the assessees. 22. Under normal circumstances, this Court would directthe Statutory Authorities to perform their functionsexpeditiously when no time lines are fixed under the relevantstatute, and if there is slackness, the Court would fix aperemptory time limit. However, the Court cannot exercise suchpower in the instant case, on the account of the time limitfixed under Section 11 (1) of the Act. Since the petitionershave agreed to cooperate in the assessment proceedings beforethe respondents, both the Deputy Director of Income Tax(Investigation) Unit - 3 (3) and Deputy Director of IncomeTax (Investigation) Unit - 3 (2) are directed to proceed withthe matter, as it is represented that certain documents wereplaced by the assessee before the Officer today (12.04.2018). 23. The next issue to be considered is as to whether therespondents should be restrained by issuing writ of prohibition https://hcservices.ecourts.gov.in/hcservices/ from initiating any prosecution or instituting prosecutionagainst the petitioner, under Chapter V of the Act, (Act 22 of2015) before the Special Court for Economic Offences or anyother Court. 24.The learned Senior Counsels for the petitioners wouldsubmit that Section 48 of Act, 22 of 2015 is uniquely worded, incontradistinction with other penal statutes. It is submittedthat, in terms of sub-section 1 of Section 48 falling underChapter V of the Act, dealing with the offences and prosecution,shall be in addition to and not in derogation of, the provisionsof any other law, providing for prosecution for offencesthereunder. Sub-section 2 of Section 48, states that, theprovisions of this Chapter shall be independent of any orderunder the Act 22 of 2015, that may be made, or has not beenmade, on any person, and it shall be no defence that the orderhas not been made on account of time limitation or for any otherreason. 25.In the light of the above mentioned statutoryprovisions, it is submitted that, without even waiting for theassessment to be completed, the statute permits the Authority,who is the highest Authority in the Department to grant sanctionto prosecute, and if such an order is passed by the PrincipalChief Commissioner or the Chief Commissioner or the PrincipalCommissioner, exercising his power under Section 55, theAssessing Officer, who is a lower level Authority in theOfficial hierarchy will definitely not take a decision contraryto the opinion of the Head of the Department, in grantingsanction to prosecute. 25.In the light of the above mentioned statutoryprovisions, it is submitted that, without even waiting for theassessment to be completed, the statute permits the Authority,who is the highest Authority in the Department to grant sanctionto prosecute, and if such an order is passed by the PrincipalChief Commissioner or the Chief Commissioner or the PrincipalCommissioner, exercising his power under Section 55, theAssessing Officer, who is a lower level Authority in theOfficial hierarchy will definitely not take a decision contraryto the opinion of the Head of the Department, in grantingsanction to prosecute. 26. Though, at the first blush, the argument appears to beconvincing, but on a close reading of the statutory provisions,it is otherwise. Sub-section 1 of Section 48 states that,Chapter V dealing with offence and prosecution, shall beindependent of any order under the Act, that may be, or has notbeen made, on any person and it shall be no defence that theorder has not been made on account of time limitation or for anyother reason. Thus, the language employed in the statute,includes 'offence and prosecution', as contained in Chapter V,as independent of other proceeding, which are enunciated underthe Act. Section 48 commences by stating that, Chapter V is notin derogation of any other law or any other provision of Act 22of 2015. In such circumstances, based on the apprehension of thepetitioner, the Court cannot issue writ of prohibition, toprevent the Authorities from initiating prosecution. If done,it would under Section 48 of the Act be inoperative. 27.That apart, the assessees have not placed any materialsbefore the Court to show that the order of sanction has been https://hcservices.ecourts.gov.in/hcservices/ passed under Section 55 or steps have been taken to initiateprosecution. Furthermore, the order of sanction to prosecutepassed under Section 55 of the Act is an administrative act.Therefore, the grant of sanction being an administrative act, asheld by the Hon'ble Supreme Court in Assistant Commissioner Vs.Velliapa Textiles Limited, reported in [(2003) 132 Taxmann.com165], the need to provide an opportunity of personal hearing tothe accused before according sanction does not arise. In anyevent, as on date, it appears that, no such order has beenpassed, and thus, the Court cannot issue writ of prohibition,prohibiting the respondent from initiating or exercising powersunder the statute. 28.Thus, for the above reasons, the prayer sought for inWrit Petition Nos.8833, 8835 and 8841 of 2018, seeking directionupon the third respondent, Deputy Director of Income Tax(Investigation) Unit - 3 (3) to forthwith pass orders underSection 10 (3) of the Act is rejected, as the Writ Petitions aredisposed of, directing both the Deputy Director of Income Tax(Investigation) Unit - 3 (3) and Deputy Director of Income Tax(Investigation) Unit - 3 (2) to pass orders in accordance withthe provisions of the Act 22 of 29.Insofar as the Writ Petition Nos.8832, 8834 and 8840 of2018, seeking for issuance of writ of prohibition is concerned,the prayer cannot be granted and the Writ Petitions aredismissed. 30. It is needless to state that, the petitioners areentitled to canvass all the factual and legal contentionsbefore the Deputy Director of Income Tax (Investigation) Unit -3 (3) and Deputy Director of Income Tax (Investigation) Unit - 3(2) in the proceedings initiated pursuant to the notices andsummons issued. 31.In the result, all the Writ Petitions are dismissed, asindicated above. No costs. Consequently, connected WritMiscellaneous Petitions are closed. //True Copy// Sub Assistant Registrar To 29.Insofar as the Writ Petition Nos.8832, 8834 and 8840 of2018, seeking for issuance of writ of prohibition is concerned,the prayer cannot be granted and the Writ Petitions aredismissed. 30. It is needless to state that, the petitioners areentitled to canvass all the factual and legal contentionsbefore the Deputy Director of Income Tax (Investigation) Unit -3 (3) and Deputy Director of Income Tax (Investigation) Unit - 3(2) in the proceedings initiated pursuant to the notices andsummons issued. 31.In the result, all the Writ Petitions are dismissed, asindicated above. No costs. Consequently, connected WritMiscellaneous Petitions are closed. //True Copy// Sub Assistant Registrar To 1. The Principal Chief Commissioner of Income Tax, (Tamil Nadu and Puducherry) Main Building, No.121, Nungambakkam High Road, Chennai - 600 034. 2. The Director General of Income Tax (Investigation) New Building, 2nd Floor, Investigation Wing, New. No.45, Old No.108, Nungambakkam High Road, Chennai - 600 034. 3. The Deputy Director of Income Tax (Investigation) Unit - 3 (3) Room No.120, First Floor, Investigation Wing Building, No.45, Uthamar Gandhi Road, Nungambakkam High Road, Chennai - 600 034. 4. The Deputy Director of Income Tax(Investigation) Unit -3(2), Room.No.120, 1[st] Floor, Investigation Wind Building, No.45, Uthamar Gandhi Road, Nungambakkam, Chennai 600 034. +3cc to M/s.A.P.Srinivas, Advocate Sr.No.27406 to 27408+3cc to M/s.C.Uma, Advocate Sr.No.27333 to 27335KAN(CO)sm:2.5.2018 Writ Petition Nos.8832 to 8835, 8840 and 8841 of 2018