The Honourable Mr. Justice S.m.subramaniamwp Nos.38884 Of 2015 And 1143 Of 2016Andmp Nos.1 Of 2015 And 875 Of 2016 v. Dispute Resolution Panel-2 (Drp-2),Room

IN THE HIGH COURT OF JUDICATURE AT MADRASDATED : 29-07-2021CORAM THE HONOURABLE MR. JUSTICE S.M.SUBRAMANIAMWP Nos.38884 of 2015 and 1143 of 2016AndMP Nos.1 of 2015 and 875 of 2016 M/s.Sesa Sterlite Limited,(Old name Sterlite Industries (India) Ltd.),Now known as 'M/s.Vedanta Limited',Represented by its Manager-Finance,Sri Rajkumar Basak, S/o.Krishna Chandra Basak,Sterlite Copper, SIPCOT Industrial Complex,Madurai Bypass Road,T.V.Puram P.O.,Thoothukudi,Tamil Nadu – 628 002. ..Petitioner in WP 38884/2015 M/s.Sesa Sterlite Limited,(Previously known as Sterlite Industries (India) Ltd.),Then known as M/s.Sesa Goa Ltd.,Then known as M/s.Sesa Sterlite Ltd., andnow known as 'M/s.Vedanta Limited',Represented by its Manager-Finance,Sri Rajkumar Basak, S/o.Krishna Chandra Basak,Sterlite Copper, SIPCOT Industrial Complex,Madurai Bypass Road, T.V.Puram P.O.,Thoothukudi,Tamil Nadu – 628 002... Petitioner in WP 1143 of 2016 vs. Dispute Resolution Panel-2 (DRP-2),Room No.714, 7[th] Floor,Income Tax Office,BMTC Building,80 Feet Road,Koramangala,Bangalore – 560 095...R-1 in both WPs Deputy Commissioner of income Tax,Corporate Circle-6(2),7[th] Floor, Room No.705,Wanaparthy Block,121, Mahatma Gandhi Road,Nungambakkam,Chennai - 600 034...R-2 in both WPs Assistant Commissioner of Income Tax,Circle I (1),Aayakar Bhavan,Plot No.5, EDC Complex,Patto Plaza,Panaji,Goa – 403 001...R-3 in WP 1143/2016 WP 38884 of 2015 is filed under Article 226 of theConstitution of India, praying for the issuance of a Writ ofCertiorari, calling for the records in F.No.139/DRP-2-BNG/2015-16 dated 24.11.2015 relating to Assessment Year 2011-2012 on thefile of the first respondent herein and quash the same. WP 1143 of 2016 is filed under Article 226 of theConstitution of India, praying for the issuance of a Writ ofCertiorari, calling for the records in PAN:AABS4955Q dated29.12.2015 relating to Assessment Year 2011-2012 on the file ofthe third respondent and quash the same. WP 38884 of 2015 is filed questioning the directionsissued under Section 144-C(5) of the Act dated 24.11.2015. 2. WP 1143 of 2016 is filed challenging the finalassessment order dated 29.12.2015 passed under Section 143(3)read with Section 92CA and Section 144-C(13) of the Act https://hcservices.ecourts.gov.in/hcservices/ 3. Both the above two writ petitions are filedpertaining to the assessment year 2011-2012. 4. WP No.38884 of 2015 is taken as a lead case as theorder passed by the Dispute Resolution Panel under Section 144-C(5) of the Income Tax Act, is challenged. 5. Elaborate discussion regarding the disputed factsbecame unnecessary as the first respondent passed the finalassessment order, which is appealable. However, it is brought tothe notice of this Court that there is a blatant violation ofthe provisions of the Income Tax Act, with reference to theorder passed by the Dispute Resolution Panel under Section 144-C(5) of the Income Tax Act, affecting the rights of the Assesseeand therefore, if the legal issues, hitting the rights of theAssessee, are adjudicated, the same would be sufficient for thepurpose of disposing of the other writ petition also. 6. The facts in general are not in dispute. The issueraised is that whether the Dispute Resolution Panel is competentto reject the objections on account of non-appearance of theAssessee on the hearing date. 6. The facts in general are not in dispute. The issueraised is that whether the Dispute Resolution Panel is competentto reject the objections on account of non-appearance of theAssessee on the hearing date. 7. The learned Senior Counsel, appearing on behalf ofthe writ petitioner, drawn the attention of this Court withreference to the order impugned passed by the Dispute ResolutionPanel [herein after referred to as the 'DRP', in short]. Thesaid order impugned would reveal that “the case was fixed forhearing on 20.11.2015 at 11.30 A.M. before the DisputeResolution Panel (DRP-2). On the date of hearing nobody appearedon behalf of the Assessee. No request for adjournment wasreceived. This shows the Assessee is not interested in pursuingthe objections filed before DRP. Therefore, the objections filedby the Assessee deserve to be rejected. Accordingly, theobjections are being rejected. The directions of this Panel, asabove, are hereby communicated to the Assessee and theDepartmental Authorities concerned as per the provisions ofSection 144-C(5) of the Income Tax Act.” 8. It is not in dispute that the DRP consists of threeCommissioners of Income Tax Department and perusal of the orderwould reveal that the Assessee had not appeared on the date ofhearing, i.e., on 20.11.2011 at 11.30 A.M. However, the DRP hasnot considered the objections already on file and there was nodiscussion or finding in respect of the objections raised by theAssessee on merits. 9. The DRP has rejected the objections merely on theground that the Assessee had not appeared. Rejection of the https://hcservices.ecourts.gov.in/hcservices/ objections due to non-appearance resulted denial of anopportunity of adjudication before the DRP to the Assessee.Under these circumstances, the question raised is, whether theDRP has got powers/competency under Section 144-C of the IncomeTax Act, to reject the objections merely on the ground that theAssessee has not appeared on the date of hearing. 10. Sub-section (2) of Section 144-C of the Income TaxAct, contemplates that “On receipt of the draft order, theeligible assessee shall, within thirty days of the receipt byhim of the draft order,—(a) file his acceptance of the variations to the AssessingOfficer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer.” 11. Therefore, on receipt of the draft order, theAssessee gets a right to file his objections, if any to suchvariations with the DRP and the Assessing Officer. Thus, theobjections, if any, to be raised must be filed before the DRP aswell as the Assessing Officer concerned. If no objections arefiled under sub-section (3) of Section 144-C of the Act, theAssessing Officer shall complete the assessment on the basis ofthe draft order. However, if an objection is filed by theAssessee, then sub-section (5) of Section 144-C of the IncomeTax Act, would come into operation. Sub-section (5) of Section144-C of the Income Tax Act, denotes “The Dispute ResolutionPanel shall, in a case where any objection is received undersub-section (2), issue such directions, as it thinks fit, forthe guidance of the Assessing Officer to enable him to completethe assessment”. Therefore, it is duty mandatory on the part ofthe DRP to decide the objections on merits. 12. The DRP is undoubtedly having certain Expertise inthe Tax Regime. Thus, adjudication before the DRP is a valuableopportunity provided both to the Assessee as well as to theAssessing Officer. Either of the parties may get guidance forthe purpose of completion of the assessment proceedings. Thus,the importance attached to the DRP under the Income Tax Act, atno circumstances, be undermined. 12. The DRP is undoubtedly having certain Expertise inthe Tax Regime. Thus, adjudication before the DRP is a valuableopportunity provided both to the Assessee as well as to theAssessing Officer. Either of the parties may get guidance forthe purpose of completion of the assessment proceedings. Thus,the importance attached to the DRP under the Income Tax Act, atno circumstances, be undermined. 13. The Statute contemplates, on receipt of objectionsfrom the Assessee, the DRP has to issue certain directions as itthinks fit for the guidance of the Assessing Officer. Thus, anadjudication before the DRP is a valuable opportunity to theAssessee, provided under the Income Tax Act and such a rightcannot be taken away without complying with the provisions ofthe Act, in its letter and spirit. 14. The Courts are not empowered to add any languageto the Statute and the language adopted is to be interpretedconstructively, keeping in mind the purpose and object of theIncome Tax Act. When the Income Tax Act contemplates a right toan Assessee, then such a right must be allowed to be exercisedin the manner prescribed under the Income Tax Act. Thus, if anobjection is filed under Section 144-C(2)(b) of the Act, thesaid objection is to be dealt with in the manner prescribed inthe other provisions and in the event of any failure, it is tobe construed that the right conferred to an Assessee is takenaway. 15. Let us now consider sub-section (6) of Section144-C of the Income Tax Act, which stipulates “The DisputeResolution Panel shall issue the directions referred to in sub-section (5), after considering the following, namely:— (a) draft order; (b) objections filed by the assessee; (c) evidence furnished by the assessee; (d) report, if any, of the Assessing Officer, ValuationOfficer or Transfer Pricing Officer or any other authority; (e) records relating to the draft order; (f) evidence collected by, or caused to be collected by,it; and (g) result of any enquiry made by, or caused to be madeby, it.” 16. Sub-section (6) of Section 144-C of the Income TaxAct, would indicate that DRP shall issue directions. Thequestion arises whether issuing direction is mandatory ordiscretionary. The language employed is 'shall' both under sub-sections (5) and (6) of Section 144-C of the Income Tax Act.Therefore, the DRP has no option but to strictly follow sub-sections (5) and (6) of Section 144-C of the Income Tax Act. 17. Under sub-section (5) of Section 144-C of the Act,the DRP is bound to issue directions as it thinks fit for theguidance of the Assessing Officer and under sub-section (6), theDRP shall issue directions referred to in sub-section (5) afterconsidering the issues contemplated from sub-clauses (a) to (g)under sub-section (6) of Section 144-C of the Income Tax Act. 18. Sub-section (6) of Section 144-C of the Act,unambiguously states that the DRP is bound to consider thematerials denoted as the case may be and issue suitabledirections as it thinks fit. Therefore, the DRP has no optionbut to deal with objections, if any, filed by an eligibleAssessee on merits and, in the event of non-consideration, it isto be construed that the right conferred under the Act, to an Assessee has not been complied with. 19. Sub-section (7) of Section 144-C of the Act,states that “The Dispute Resolution Panel may, before issuingany directions referred to in sub-section (5),—(a) make such further enquiry, as it thinks fit; or(b) cause any further enquiry to be made by anyincome-tax authority and report the result of the same to it.” 20. Sub-section (8) of Section 144-C of the Act, alsostates that “The Dispute Resolution Panel may confirm, reduce orenhance the variations proposed in the draft order so, however,that it shall not set aside any proposed variation or issue anydirection under sub-section (5) for further enquiry and passingof the assessment order. Assessee has not been complied with. 19. Sub-section (7) of Section 144-C of the Act,states that “The Dispute Resolution Panel may, before issuingany directions referred to in sub-section (5),—(a) make such further enquiry, as it thinks fit; or(b) cause any further enquiry to be made by anyincome-tax authority and report the result of the same to it.” 20. Sub-section (8) of Section 144-C of the Act, alsostates that “The Dispute Resolution Panel may confirm, reduce orenhance the variations proposed in the draft order so, however,that it shall not set aside any proposed variation or issue anydirection under sub-section (5) for further enquiry and passingof the assessment order. Explanation.—For the removal of doubts, it is herebydeclared that the power of the Dispute Resolution Panel toenhance the variation shall include and shall be deemed alwaysto have included the power to consider any matter arising out ofthe assessment proceedings relating to the draft order,notwithstanding that such matter was raised or not by theeligible assessee”. 21. Sub-section (10) of Section 144-C of the Act,makes it clear that “every direction issued by the DisputeResolution Panel shall be binding on the Assessing Officer”.Therefore, sub-section (7) of Section 144-C of the Act, providesdiscretion to the DRP to make such further enquiry as it thinksfit. The term, makes it further clear that the enquiry isdiscretionary and may be done on need basis. If the DRP is of anopinion that further enquiry is required, then the DRP may atits discretion to conduct such enquiry and if no such furtherenquiry is required, then the DRP may comply with sub-sections(5) and (6) of Section 144-C of the Act, and issue suitabledirections as it thinks fit to the Assessing Officer, which isbinding on the Assessing Officer as per sub-section (10) ofSection 144-C of the Income Tax Act. 22. Sub-section (8) of Section 144-C of the Act, isalso discretionary. Cogent reading of the sub-sections wouldmake it crystal clear that the right of an Assessee is conferredfor filing objections before the DRP and the Assessing Officerand in the event of no such objections, the Assessing Officershall complete the assessment. If any objection is received,then sub-section (5) of Section 144-C of the Act, would comeinto operation. Once the objections are before the DRP, then theDRP is bound to issue directions as it thinks fit for theguidance of the Assessing Officer and such directions must be incompliance with sub-section (6) of Section 144-C of the Income Tax Act. 23. Thus, sub-sections (5) and (6) to Section 144-C ofthe Income Tax Act, are mandatory provisions as far as the DRPis concerned and sub-sections (7) and (8) of Section 144-C ofthe Act, are discretionary powers provided under the saidprovisions. In the event of any violation of sub-sections (5)and (6) of Section 144-C of the Act, it is to be construed thatthe right of an Assessee is taken away, resulting violation ofthe provisions of the Act. However, if sub-sections (7) and (8)are violated, the same would not infringe the right of anAssessee as the powers conferred on the DRP is onlydiscretionary and not mandatory. 24. Sub-section (11) to Section 144-C of the Act,denotes that “no direction under sub-section (5) shall be issuedunless an opportunity of being heard is given to the assesseeand the Assessing Officer on such directions which areprejudicial to the interest of the assessee or the interest ofthe revenue, respectively”. 25. The above sub-section unambiguously clarifies thatDRP shall not issue any directions under sub-section (5) unlessan opportunity of hearing is given to an Assessee and theAssessing officer. 26. Sub-section (11) to be linked with sub-section (2)(b)(i) and (ii) of Section 144-C of the Act, because anopportunity is bound to be given to the Assessee as well as tothe Assessing Officer. 24. Sub-section (11) to Section 144-C of the Act,denotes that “no direction under sub-section (5) shall be issuedunless an opportunity of being heard is given to the assesseeand the Assessing Officer on such directions which areprejudicial to the interest of the assessee or the interest ofthe revenue, respectively”. 25. The above sub-section unambiguously clarifies thatDRP shall not issue any directions under sub-section (5) unlessan opportunity of hearing is given to an Assessee and theAssessing officer. 26. Sub-section (11) to be linked with sub-section (2)(b)(i) and (ii) of Section 144-C of the Act, because anopportunity is bound to be given to the Assessee as well as tothe Assessing Officer. 27. Before the DRP, both the Assessee as well as theAssessing Officer are getting an opportunity to adjudicatecertain issues for the purpose of solution and the correctnessof the decisions. Therefore, the opportunity contemplated underthe Act for the Assessee as well as the Assessing Officer mustbe allowed to be exercised in complete form, so as to reach thepurpose and object for which the DRP is constituted under theAct itself. It is a valuable right provided both to the Assesseeas well as to the Assessing Officer. Thus, the DRP, being aQuasi Judicial Authority, is bound to pass orders as it thinksfit only on merits and such Quasi Judicial Authorities are notempowered to reject the objections merely by stating that theAssessee had not appeared before the DRP. Even in case of non-appearance, the matters are to be decided on merits, as theobjections in writing filed by the petitioner is very muchavailable on record before the DRP. Rejecting the objections onthe ground of non-appearance may be an easy way out for thedisposal of the objections, however, the spirit and theintention of Legislation, at no circumstances, be diluted and this apart, the Quasi Judicial Functionaries are not empoweredto pass any such orders, rejecting the objections merely on theground of non-appearance. Further, the Assessee may not get anopportunity by filing a petition for restoration to restore theobjections for the purpose of complete objection. This being theimplications, the DRP is legally bound to adjudicate theobjections and pass orders on merits, even in case of theAssessee or the Assessing Officer failed to appear for personalhearing. 28. The very purpose of filing an objection before theAssessing Officer is to ensure that the Assessing Officer mayalso raise an objection against the objections filed by theAssessee. Thus, the Act contemplates a balanced procedure inorder to comply with the principles of natural justice byproviding an opportunity to all the parties, who all areentitled to put forth their respective cases before the DRP. 29. Coming to sub-section (11) of Section 144-C of theAct, the Assessing Officer is entitled to defend the revenue andthe Assessee is entitled to put forth his case based on theobjections or otherwise. Thus, sub-section (11) is alsosignificant with reference to the opportunities to be granted tothe parties before the DRP. The DRP is a Quasi JudicialAuthority. Therefore, on receipt of any objections, the DRPcannot reject the same due to non-appearance of parties. Even incase of absence of either of the parties (Assessee and AssessingOfficer), the DRP is bound to decide the objections on meritsand issue suitable directions as it thinks fit. 29. Coming to sub-section (11) of Section 144-C of theAct, the Assessing Officer is entitled to defend the revenue andthe Assessee is entitled to put forth his case based on theobjections or otherwise. Thus, sub-section (11) is alsosignificant with reference to the opportunities to be granted tothe parties before the DRP. The DRP is a Quasi JudicialAuthority. Therefore, on receipt of any objections, the DRPcannot reject the same due to non-appearance of parties. Even incase of absence of either of the parties (Assessee and AssessingOfficer), the DRP is bound to decide the objections on meritsand issue suitable directions as it thinks fit. 30. In the present case, admittedly, the Assesseefiled an objection both before the DRP and before the AssessingOfficer. The DRP issued notice to the Assessee, fixing thehearing date. On certain personal grounds, as stated by thepetitioner, the Assessee could not able to appear on the date ofhearing. However, the DRP rejected the objections only on theground that the Assessee had not appeared before the DRP on thedate of hearing. Thus, this Court has no hesitation in formingan opinion that the mandatory provisions under sub-sections (5)and (6) of Section 144-C have not been complied with by the DRP,while dealing with the objections filed by the Assessee undersub-section (2)(b) of Section 144-C of the Act. 31. In this regard, the Income Tax (Dispute ResolutionPanel) Rules, 2009 also may be looked into. The said Rules wereframed in exercise of the powers conferred under sub-section(14) of Section 144-C of the Act. The Central Board of DirectTaxes make Rules to regulate the procedures of the DRP. Panel) Rules, 2009 provides hearing of objections. 33. Rule 10 of the Income Tax (Dispute ResolutionPanel) Rules, 2009 deals with issue of directions. Sub-clauses(1) to (3) of Rule 10 of the Income Tax (Dispute ResolutionPanel) Rules, 2009 enumerate that “(1) On the date fixed for hearing or on any other dateto which the hearing may be adjourned, if the eligible Assesseeor his authorized representative do not appear, or when theyappear, upon hearing the objections, the panel may, within thespecified time, issue such directions as it deems proper. (2) While hearing the objections, the panel shall not beconfined to the grounds set forth in the objections but shallhave power to consider any matter or grounds arising out of theproceedings. (3) On conclusion of hearing, the panel shall issuedirections within the specified period”. 34. Therefore, the manner in which the objections areto be considered by the DRP, are well defined both under theIncome Tax Act as well as under the Income Tax (DisputeResolution Panel) Rules, 2009. 35. The learned Senior Standing Counsel, appearing onbehalf of the respondents, while rebutting the contentionsraised on behalf of the petitioner, contended that in thepresent case, final assessment order has been passed and thedirections issued by the DRP had not been taken intoconsideration for the purpose of passing an assessment order bythe Assessing Authority and further, the grounds raised in theobjections before the DRP may be raised before the AppellateAuthority by preferring an appeal and therefore, the writpetition is liable to be rejected. 36. In other words, it is contended that the DRP hasrejected the objections and thereafter the assessment order hasbeen passed and the Assessee is not aggrieved from and out ofthe non-consideration of the objections by the DRP andtherefore, the Assessee has to prefer a statutory appeal for thepurpose of redressing his grievances in the manner known to law. 37. It is contended that once the final assessmentorder is passed, the earlier proceedings need not be interferedwith by the Courts and the Assessee has to prefer an appealbefore the competent Appellate Authority. 38. In this regard, this Court is of the considered 36. In other words, it is contended that the DRP hasrejected the objections and thereafter the assessment order hasbeen passed and the Assessee is not aggrieved from and out ofthe non-consideration of the objections by the DRP andtherefore, the Assessee has to prefer a statutory appeal for thepurpose of redressing his grievances in the manner known to law. 37. It is contended that once the final assessmentorder is passed, the earlier proceedings need not be interferedwith by the Courts and the Assessee has to prefer an appealbefore the competent Appellate Authority. 38. In this regard, this Court is of the considered https://hcservices.ecourts.gov.in/hcservices/ opinion that principles of natural justice and its violationwith regard to certain disputed issues need not be gone into bythe High Court in the writ proceedings, so also thejurisdictional issues, if relatable to the disputed facts, thenalso the aggrieved person may be granted liberty to prefer anappeal for effective adjudication of such disputes. However, ifthe principles of violation of natural justice or thejurisdiction directly hitting the provisions of the Statute isestablished, then the High Court has to look into theseriousness of such violations for the purpose of restoring theright of the aggrieved persons and issue suitable orders toprovide such opportunities as contemplated. 39. This apart, the DRP consists of three Senior mostCommissioners of Income Tax Department. It is a decision, whichis to be taken by the Panel having expertise in the income taxmatters. Thus the right conferred and the importance at nocircumstances be undermined. 40. The learned Senior Standing Counsel, appearing onbehalf of respondents, raised a pertinent point that theAssessee would get an opportunity to raise all the points raisedin the objections before the Assessing Officer as well as beforethe Appellate Authority. However, such a submission has no forceas the valuable right conferred under the Act to the Assesseecan never be taken away. In the event of glaring violation ofthe provisions of the Act, the High Court has to provide anappropriate relief to the aggrieved persons. In other words, ifthe point of jurisdiction or enforcement of right directlyhitting the provisions of the Income Tax Act, then the HighCourt has to entertain a writ petition. In the event of failure,the High Court would be failing in its constitutional duty torestore the valuable right of an Assessee conferred under theIncome Tax Act. The principles of natural justice being anintegral part of Article 14 of the Constitution of India, thedirect violation of the provisions in this regard is a groundfor entertaining a writ petition. Where the violation ofprinciples of natural justice is raised and interpretation ofthe provisions of the Income Tax Act is imminent, then it isnecessary to entertain the writ petition to ascertain the natureof rights conferred to an Assessee or the Assessing Officerunder the provisions of the Act. While doing so, if the rightsviolated are patent and caused infringement of right to eitherof the parties, then the aggrieved person is entitled for anappropriate relief. 41. Thus, the objections raised by the learned SeniorStanding Counsel appearing on behalf of respondents, standrejected. 42. As far as the grounds on merits are concerned, thelearned Senior Counsel, appearing on behalf of the petitioner,fairly made a submission that all such disputes are to beadjudicated before the Competent Authority as the point ofjurisdiction as well as the manner in which an order must bepassed by the Dispute Resolution Panel, which is under challengein the present writ petition. 41. Thus, the objections raised by the learned SeniorStanding Counsel appearing on behalf of respondents, standrejected. 42. As far as the grounds on merits are concerned, thelearned Senior Counsel, appearing on behalf of the petitioner,fairly made a submission that all such disputes are to beadjudicated before the Competent Authority as the point ofjurisdiction as well as the manner in which an order must bepassed by the Dispute Resolution Panel, which is under challengein the present writ petition. 43. This being the factum established, this Court isof the considered opinion that the DRP had failed to act in themanner as contemplated, more specifically, under sub-sections(5) and (6) of Section 144-C of the Income Tax Act andtherefore, the order passed, rejecting the objections submittedby the Assessee, merely on the ground that the Assessee has notappeared on the hearing date, is infirm and liable to be quashedand accordingly, the same is quashed. 44. In view of the fact that the proceedings beforethe DRP is quashed, the consequential assessment order passed bythe Assessing Authority is also quashed. The proceedings beforethe DRP stands restored and the DRP is directed to consider theobjections in the manner prescribed under sub-sections (5) and(6) of Section 144-C of the Income Tax Act and by following theother relevant provisions of the Act and Rules and pass an orderafresh by affording an opportunity to the Assessee as well as tothe Assessing Officer. The said exercise is directed to be doneas expeditiously as possible. Thereafter, the Assessing Officeris at liberty to pass further orders by following the proceduresas contemplated.Accordingly, WP No. 38884 of 2015 standsallowed. 45. In this view of the matter, WP No.1143 of 2016also stands allowed. 46. In the result, WP Nos.38884 of 2015 and 1143 of2016 stand allowed. However, there shall be no order as tocosts. Consequently, connected miscellaneous petitions areclosed. Sd/- Assistant Registrar(CS) // True Copy// Svn Sub Assistant Registrar To 1. The Dispute Resolution Panel-2 (DRP-2), Room No.714, 7[th] Floor, Income Tax Office, BMTC Building, 80 Feet Road, Koramangala, Bangalore – 560 095.2. The Deputy Commissioner of income Tax, Corporate Circle-6(2), 7[th] Floor, Room No.705, Wanaparthy Block, 121, Mahatma Gandhi Road, Nungambakkam, Chennai - 600 034.3. The Assistant Commissioner of Income Tax, Circle I (1), Aayakar Bhavan, Plot No.5, EDC Complex, Patto Plaza, Panaji,Goa – 403 001. +2ccs to Mr.A.Baskar, Advocate, S.R.No.36710,36711+1cc to Mr.A.P.Srinivas, Advocate, S.R.No.37028 WP Nos.38884 of 2015and1143 of 2016 GPL(CO)SU(19/08/2021) https://hcservices.ecourts.gov.in/hcservices/