The Income Tax Officer Ward -2 (1) Erode Income Tax Office v. Aa.226 Modakurichi Primary Agricultrual Cooperative Credit Society Rep.by Its President P.v. Saravanan M/52

IN THE HIGH COURT OF JUDICATURE AT MADRAS THE HONOURABLE MR. JUSTICE R. MAHADEVANandTHE HONOURABLE MR. JUSTICE J.SATHYA NARAYANA PRASAD Writ Appeal Nos. 2396, 2759, 2847, 2851, 2868 and 2884 of 2021 and 138, 165, 243, 252, 281, 314 and 491 of 2022 andCMP Nos. 15277, 15280, 18116, 18947, 18974, 19346 & 19694 of2021 and 1028, 1105, 1774, 1836, 1997, 2390 & 3545 of 2022 1.THE INCOME TAX OFFICER WARD - 2 (1) ERODE, INCOME TAX OFFICE NO.15 GANDHIJI ROAD, ERODE, ERODE DT....APPELLANT/RESPONDENT in WA No.2396 of 2021 2.THE INCOME TAX OFFICER WARD 1(2) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR 641602....APPELLANT/RESPONDENT in WA No.2759 of 2021 3.THE INCOME TAX OFFICER WARD 2(3) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR 641602....APPELLANT/RESPONDENT in WA No.2847 of 2021 4.THE INCOME TAX OFFICER WARD-I(4) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR 641 602....APPELLANT/RESPONDENT in WA No.2851 of 2021 5.THE INCOME TAX OFFICER WARD 2(3) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR 641 602....APPELLANT/RESPONDENT in WA No.2868 of 2021 6.THE INCOME TAX OFFICER WARD - 2 (3) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR - 641 602....APPELLANT/RESPONDENT in WA No.2884 of 2021 7.THE INCOME TAX OFFICER NO.121 ADAM BUILDING SIXTY FEET ROAD TIRUPUR-641602https://hcservices.ecourts.gov.in/hcservices/...APPELLANT/RESPONDENT in WA No.138 of 2022 8.THE INCOME TAX OFFICER WARD 2(4) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR 641 602....APPELLANT/RESPONDENT in WA No.165 of 2022 9.THE INCOME TAX OFFICER WARD-2(3) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR-641602...APPELLANT/RESPONDENT in WA No.243 of 2022 10.THE INCOME TAX OFFICER WARD-2 (4) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR 641 302....APPELLANT/RESPONDENT in WA No.252 of 2022 11.THE INCOME TAX OFFICER NON CORP WARD 4(2) CBE NO.63 RACE COURSE ROAD COIMBATORE 641 018....APPELLANT/RESPONDENT in WA No.281, 314 of 2022 12.THE INCOME TAX OFFICER WARD -2 (1) ERODE INCOME TAX OFFICE NO.15 GANDHIJI ROAD ERODE ERODE DISTRICT...APPELLANT/RESPONDENT in WA No.491 of 2022 Vs 1.AA.226 MODAKURICHI PRIMARY AGRICULTRUAL COOPERATIVE CREDIT SOCIETY REP.BY ITS PRESIDENT P.V. SARAVANAN M/52 S/O. VENKATACHALAM PERUMAPALAYAM MODAKURUCHI POST ERODE DT....RESPONDENT/PETITIONER in WA No.2396 of 2021 2.K 2092 CHETTIPALAYAM PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY S.SUNDARRAJ M/47 S/O.K.SADAYAN NO.37 SUSAIYAPURAM T M C COLONY TIRUPPUR...RESPONDENT/PETITIONER in WA No.2759 of 20213.K-2043 ANDIPALAYAM PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY N.VISVESWARAN S/O.M. NACHIMUTHU NO.1/94 A.VELAYUDHAMPALAYAM ALAGUMALAI POST TIRUPPUR DISTRICT....RESPONDENT/PETITIONER in WA No.2847 of 2021 4.K 1594 PERUMANALLUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY A.BALAMANI W/O.G.D. SENTHIL GANESU NO.3/45 MAIN ROAD PERUMANALLUR TIRUPPUR DISTRICT....RESPONDENT/PETITIONER in WA No.2851 of 2021 https://hcservices.ecourts.gov.in/hcservices/ 5.K-2051 VIJAYAPURAM URBAN COOP CREDIT SOC CO-OPERATIVE CREDIT SOCIETY REP. BY ITS SECRETARY REP. BY ITS SECRETARY N.MUTHUNAGAI F/47 W/O.M.SHANMUGASUNDARAM NO.42 THENDRAL NAGAR, VIJAYAPURAM, TIRUPPUR - 641606...RESPONDENT/PETITIONER in WA No.2868 of 20216.K-2038 MANGALAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP BY ITS SECRETARY A.RENUKA W/O. GURUSAMY NO. 12/4 OM SAKTHI NAGAR KRISHNAPURAM SOMANUR SALUR TALUK, COIMBATORE DISTRICT....RESPONDENT/PETITIONER in WA No.2884 of 2021 https://hcservices.ecourts.gov.in/hcservices/ 5.K-2051 VIJAYAPURAM URBAN COOP CREDIT SOC CO-OPERATIVE CREDIT SOCIETY REP. BY ITS SECRETARY REP. BY ITS SECRETARY N.MUTHUNAGAI F/47 W/O.M.SHANMUGASUNDARAM NO.42 THENDRAL NAGAR, VIJAYAPURAM, TIRUPPUR - 641606...RESPONDENT/PETITIONER in WA No.2868 of 20216.K-2038 MANGALAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP BY ITS SECRETARY A.RENUKA W/O. GURUSAMY NO. 12/4 OM SAKTHI NAGAR KRISHNAPURAM SOMANUR SALUR TALUK, COIMBATORE DISTRICT....RESPONDENT/PETITIONER in WA No.2884 of 2021 7.M/S.UTTUKULI AND AVINASI UNION PUBLIC SERVANTS CO-OP THRIFT AND CREDIT SOCIETY LTD. REP. BY ITS SECRETARY 1 T.M.P JAYALAKSHMI COMPLEX VIJAYAMANGALAM UTHUKULI POST THIRUPUR DISTRICT - 638751...RESPONDENT/PETITIONER in WA No.138 of 2022 8.K.1140 JALLIPATTI PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY S.BADRUDEEN M/51 S/O.S.SIRAJUDEEN NO.18 SARASWATHI LAYOUT DHARAPURAM ROAD, UDUMALPET, TIRUPPUR DISTRICT....RESPONDENT/PETITIONER in WA No.165 of 20229.K 1621 PONGALUR PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LTD. REP BY ITS SECRETARY G.LATHADEVI F/43 W/O. GOVINDASAMY NO.7/469-29 ALR NAGAR PONGALUR AND POST TIRUPPUR...RESPONDENT/PETITIONER in WA No.243 of 2022 10.K.1104 ELAYAMUTHUR PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY P.CHINNASAMY M/55 S/O.PERIYASAMY NO.1/358 P.V.LAYOUOT S.V.MILLS POST S.V.PURAM, UDUMALPET & TALUK, TIRUPPUR DISTRICT....RESPONDENT/PETITIONER in WA No.252 of 2022 11.K.758 IKKARAI BOLUVAMPATTI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY S.SUSEELA F/49 W/O.MARUTHACHALAM NO.4/4A BOLUVAMPATTI STREET RAMANATHAPURAM, POOLUVAPATTI, COIMBATORE – 641101. ...RESPONDENT/PETITIONER in WA No.281 of 2022 12.C.C.2341 PERUR CHETTIPALAYAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY R.ANANTHAN M/51 S/O.K.RANGASAMY ARUMUGA GOUNDANUR PERUR CHETTIPALAYAM POST, COIMBATORE – 641010. CO-OPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY R.ANANTHAN M/51 S/O.K.RANGASAMY ARUMUGA GOUNDANUR PERUR CHETTIPALAYAM POST, COIMBATORE – 641010. https://hcservices.ecourts.gov.in/hcservices/ ...RESPONDENT/PETITIONER in WA No.314 of 2022 13.THE CHITHODE FARMERS SERVICE COOPERATIVE SOCIETY LTD NADUPALAYAM CHITHODE ERODE DISTRICT PRESENTLY CALLED AS K.11279 CHITHODE PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD REP.BY ITS SECRETARY M.ESWARAMOORTHY, RANGAPURAM CHITHODE-638102, ERODE TALUK AND DISTRICT. ...RESPONDENT/PETITIONER in WA No.491 of 2022 Prayer in WA No.2396 of 2021: Appeal filed under Clause 15 of the Letters Patent againstthe order dated 06.09.2019 and made in WP No. 769 of 2019 onthe file of this court. Common Prayer in WA Nos.2759, 2847, 2851, 2868 and 2884 of2021, 138, 165, 243, 252, 281, 314 and 491/2022 Appeal are filed under Clause 15 of the Letters Patentagainst the order dated 27.06.2019 and made in WP.Nos.3721,3718, 3712, 3720, 3714, 4477, 4540, 4389, 4535, 4100, 5238 and5006 of 2019 respectively on the file of this court. Prayer in WP No.769 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in order No.ITBA /AST / S / 143 (3) / 2018 - 19 / 1014648589 (1) dated 28.12.2018and quash the same. Prater in WP No.3721 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No.ITBA /AST / S / 143 (3) / 2018-19 / 1014606291 (1) dated 27.12.2018and quash the same. Prayer in WP No.769 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in order No.ITBA /AST / S / 143 (3) / 2018 - 19 / 1014648589 (1) dated 28.12.2018and quash the same. Prater in WP No.3721 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No.ITBA /AST / S / 143 (3) / 2018-19 / 1014606291 (1) dated 27.12.2018and quash the same. Prayer in WP No.3718 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No. ITBA/ AST/S/ 143 (3)/ 2018-19/ 1014594606 (1) dated 26.12.2018 and quashthe same Prayer in WP No.3712 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No.ITBA /AST / S / 143 (3) / 2018-19 / 1014429866 (1) dated 20.12.2018and quash the same. Prayer in WP No.3720 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No. ITBA/ AST/https://hcservices.ecourts.gov.in/hcservices/S/ 143 (3)/ 2018-19/ 1014594884 (1) dated 26.12.2018 and quash the same. Prayer in WP No.3714 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No.ITBA /AST / S / 143 (3) / 2018-19 / 1014593051 (1) dated 26.12.2018and quash the same. Prayer in WP No.4477 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in orderNo.ITBA/AST/S/143(3)/2018-19/1014608013 (1) passed by therespondent for the Assessment Year 2016-17 and quash the orderdated 27/12/2018. Prayer in WP No.4540 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the records relating to the impugnedorder passed by the respondent in Order No. ITBA/ AST/ S/ 143(3)/ 2018-19/ 1014601316(1), dated 25.12.2018 and quash thesame. Prayer in WP No.4389 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in orderNo.ITBA/AST/S/143(3)/2018-19/1014595977(1), dated 26.12.2018and quash the same. Prayer in WP No.4535 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the records relating to the impugnedorder passed by the respondent in Order No. ITBA/ AST/ S/ 143(3)/ 2018-19/ 1014568833(1), dated 25.12.2018 and quash thesame. Prayer in WP No.4100 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No.ITBA /AST / S / 143 (3) / 2018-19/ 1014279348 (1) dated 14.12.2018and quash the same. Prayer in WP No.5238 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No. ITBA/ AST/S/ 143(3)/ 2018-19/ 1014180907(1), dated 11.12.2018. Prayer in WP No.4100 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No.ITBA /AST / S / 143 (3) / 2018-19/ 1014279348 (1) dated 14.12.2018and quash the same. Prayer in WP No.5238 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in Order No. ITBA/ AST/S/ 143(3)/ 2018-19/ 1014180907(1), dated 11.12.2018. Prayer in WP No.5006 of 2019: Petition filed under Article 226of the Constitution of India pleased to issue a Writ ofCertiorari to calling for the entire records relating to theimpugned order passed by the respondent in order No.ITBA / ASThttps://hcservices.ecourts.gov.in/hcservices//S / 143(3) / 2018-19/ 1014657015(1) dated 29.12.2018 and quashthe same. For Appellant : Mr.A.P.SrinivasSenior Standing counsel for Income Taxin all the Writ Appeals For Respondent : Mr. C. Prakasamin all the Writ Appeals COMMON JUDGMENT (Judgment of the court was delivered by R. MAHADEVAN, J.) These writ appeals are filed by the Revenue, questioningthe validity of the orders passed by the learned Judge in thewrit petitions filed by the respondents / co-operativesocieties. 2. The writ petitions have been filed by the respondents/co-operative societies questioning the orders of assessmentpassed by the Assessing Officer and demanding payment of tax. 3. For the purpose of appreciating the factual matrix ofthe case, the averments made in WP No. 769 of 2019,corresponding to W.A. No. 2396 of 2021, are taken as the leadcase. 4. According to the respondent/writ petitioner in WP No.769 of 2019, they are the Agricultural Cooperative CreditSociety registered under the Tamil Nadu Cooperative SocietiesAct, 1983. They filed its return of income for the assessmentyear 2016-2017 on 12.10.2016 declaring 'nil' income and claimeddeduction under Section 80-P of the Income-tax Act (in short,'the Act'). Such return filed by the respondent/writ petitionerwas processed under Section 143 (1) of the Act and theassessment was completed under section 143(3) of the Act on28.12.2018, determining a total income of Rs.26,66,374/- anddemanded Rs.10,71,103/- towards tax, while disallowing theclaim made under Section 80P of the Act. Aggrieved by theorder of assessment dated 28.12.2018, the respondent / writpetitioner has filed WP No. 769 of 2019. 5. The learned Judge, on consideration of thesubmissions made by both sides, disposed of the said writpetition No. 769 of 2019 on 06.09.2019 along with other writpetition, after having found that the issue involved in thewrit petitions is covered by the judgment dated 02.08.2016passed by the Division Bench of this Court in Tax Case AppealNumbers 484 to 487 and 490 of 2016 wherein it was held that theexemption spelt out in section 80P(4) of the Income Tax Act,1961, is applicable to the credit society. However, it wasbrought to the notice of the learned Judge by the counsel forthe revenue that as against the said order passed by thehttps://hcservices.ecourts.gov.in/hcservices/Division Bench of this Court, an appeal in SLP(C) No.11745 of2019 has been filed before the Honourable Supreme Court and itis pending. Having regard to the same, the learned Judge directed the appellant herein not to give effect to the ordersof assessment, which are impugned in the writ petitions and tokeep them in abeyance and further proceedings shall be taken upsubject to the outcome of the Special Leave Petition pendingbefore the Honourable Supreme Court. 6.Challenging the orders so passed by the learned Judgein the writ petitions, the Revenue has come up with these writappeals. directed the appellant herein not to give effect to the ordersof assessment, which are impugned in the writ petitions and tokeep them in abeyance and further proceedings shall be taken upsubject to the outcome of the Special Leave Petition pendingbefore the Honourable Supreme Court. 6.Challenging the orders so passed by the learned Judgein the writ petitions, the Revenue has come up with these writappeals. 7. When these appeals are taken up for hearing today,the learned Senior Standing Counsel appearing for the appellantcontended that once the orders of assessment are passed, theassessees ought to have filed statutory appeals before theappellate authority, whereas in this case, the respondents/ co-operative societies filed both the writ petitions under Article226 of the Constitution of India and the statutory appealsbefore the CIT (Appeals) simultaneously and hence, the learnedJudge ought not to have entertained the writ petitions.However, he fairly submitted that the Division Bench of thisCourt, in the Judgment dated 02.08.2016 passed in Tax CaseAppeal Numbers 484 to 487 and 490 of 2016 has held that interms of Section 80P of the Act, which was inserted under theFinance Act, 2006 with effect from 01.04.2007, the assessees,which are the cooperative credit societies, would be entitledto the benefit of Section 80P of the Act. It is further statedthat assailing the said order passed by the Division Bench ofthis Court, the Revenue has carried the matter on appeal beforethe Honourable Supreme Court in Special Leave to Appeal (c) No(s).17745/2019 [Prl. Commissioner of Income Tax Vs. M/s.S.1308Ammapet Primary Agricultural Cooperative Bank Ltd] and theHonourable Supreme Court, by judgment dated 17.01.2020permitted the Department to withdraw the appeal while keepingthe question of law open for consideration. The order dated17.01.2020 passed by the Honourable Supreme Court reads asfollows: “Permission granted, subject to just exceptions.” The special leave petition and pendingapplications are dismissed as withdrawn,leaving questions(s) of law open.” The learned Senior Standing Counsel therefore submitted that theappeals filed by the respondents / co-operative societies beforethe appellate authority have to be examined in the light of thedecision of the Division Bench of this Court mentioned supra. 8. On the other hand, the learned counsel appearing forthe respondents/co-operative societies fairly submitted that asagainst the orders of assessment, the respondents herein havealso filed statutory appeals and they are pending before theAppellate Authority. The learned counsel also brought to thenotice of this Court the judgment of the Honourable Supremehttps://hcservices.ecourts.gov.in/hcservices/Court in the case of Mavilayi Service Co-operative Bank Ltd. v.Commissioner of Income Tax, Calicut (2021) 123 taxmann.com 161(SC), wherein, in paragraph 45, it was observed as follows: 8. On the other hand, the learned counsel appearing forthe respondents/co-operative societies fairly submitted that asagainst the orders of assessment, the respondents herein havealso filed statutory appeals and they are pending before theAppellate Authority. The learned counsel also brought to thenotice of this Court the judgment of the Honourable Supremehttps://hcservices.ecourts.gov.in/hcservices/Court in the case of Mavilayi Service Co-operative Bank Ltd. v.Commissioner of Income Tax, Calicut (2021) 123 taxmann.com 161(SC), wherein, in paragraph 45, it was observed as follows: “ 45. To sum up, therefore, the ratio decidendiof Citizen Cooperative Society Ltd. (supra), must begiven effect to.Section 80Pof the IT Act, being abenevolent provision enacted by Parliament toencourage and promote the credit of the co-operativesector in general must be read liberally andreasonably, and if there is ambiguity, in favour ofthe assessee. A deduction that is given without anyreference to any restriction or limitation cannot berestricted or limited by implication, as is soughtto be done by the Revenue in the present case byadding the word “agriculture” intoSection 80P(2)(a)(i)when it is not there. Further, section 80P(4) isto be read as a proviso, which proviso nowspecifically excludes co-operative banks which areco-operative societies engaged in banking businessi.e. engaged in lending money to members of thepublic, which have a licence in this behalf from theRBI. Judged by this touchstone, it is clear that theimpugned Full Bench judgment is wholly incorrect inits reading of Citizen Cooperative Society Ltd.(supra). Clearly, therefore, oncesection 80P(4)isout of harm’s way, all the assessees in the presentcase are entitled to the benefit of the deductioncontained insection 80P(2)(a)(i), notwithstandingthat they may also be giving loans to their memberswhich are not related to agriculture. Also, in caseit is found that there are instances of loans beinggiven to non-members, profits attributable to suchloans obviously cannot be deducted.” Relying upon the above decision of the Honourable Supreme Court,the learned counsel for the respondents / co-operative societiessubmitted that appropriate direction may be issued to theAppellate Authority to take note of the aforesaid decision ofthe Honourable Supreme Court as well, at the time of disposal ofthe statutory appeals filed by the respondents herein. 9. Heard the learned Senior Standing Counsel appearingfor the appellant and the learned counsel for the respondents. 10. Admittedly, in all these cases, the Assessing Officerhas passed orders of assessment determining the income of therespective respondent/ Cooperative Society and demanded tax.Challenging the said orders of assessment, the respondents havealready filed appeals before the appellate authority and theyare pending. Therefore, it would be appropriate to direct therespondents herein to raise all the contentions including theeligibility of their claim under section 80P of the Act, in theappeals pending before the appellate authority. The appellateauthority is also directed to consider the claim of therespondents/co-operative societies and pass orders, on meritsand in accordance with law and also in the light of the decisionhttps://hcservices.ecourts.gov.in/hcservices/rendered by the Honourable Supreme Court, mentioned supra.Accordingly, the orders impugned herein, shall stand modified. 11. All the writ appeals stand disposed of in the aboveterms. No costs. Consequently, the connected miscellaneouspetitions are closed. Sd/-Assistant Registrar (CS-III)//True Copy// msr/rsh Sub Assistant Registrar To 1.THE INCOME TAX OFFICER, WARD -2 (1), ERODE, INCOME TAX OFFICE NO.15, GANDHIJI ROAD, ERODE ERODE DISTRICT. 2.THE INCOME TAX OFFICER, WARD 1(2) TPR INCOME TAX OFFICE, NO.121, 60 FEET ROAD, TIRUPPUR 641602. 11. All the writ appeals stand disposed of in the aboveterms. No costs. Consequently, the connected miscellaneouspetitions are closed. Sd/-Assistant Registrar (CS-III)//True Copy// msr/rsh Sub Assistant Registrar To 1.THE INCOME TAX OFFICER, WARD -2 (1), ERODE, INCOME TAX OFFICE NO.15, GANDHIJI ROAD, ERODE ERODE DISTRICT. 2.THE INCOME TAX OFFICER, WARD 1(2) TPR INCOME TAX OFFICE, NO.121, 60 FEET ROAD, TIRUPPUR 641602. 3.THE INCOME TAX OFFICER, WARD 2(3) TPR INCOME TAX OFFICE, NO.121, 60 FEET ROAD, TIRUPPUR 641602. 4.THE INCOME TAX OFFICER, WARD-I(4) TPR INCOME TAX OFFICE, NO.121, 60 FEET ROAD, TIRUPPUR 641 602. 5.THE INCOME TAX OFFICER, NO.121, ADAM BUILDING, SIXTY FEET ROAD, TIRUPUR-641602. 6.THE INCOME TAX OFFICER WARD 2(4) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD TIRUPPUR 641 602. 7.THE INCOME TAX OFFICER NON CORP WARD 4(2) CBE NO.63 RACE COURSE ROAD COIMBATORE 641 018.+13ccs to Mr.A.P.Srinivas, Senior Standing Counsel for IncomeTax, SR. No. 16739 +5ccs to Mr.C.Prakasam, Advocate SR. Nos.16634 to 16638 NRJK (CO)https://hcservices.ecourts.gov.in/hcservices/PR (05/04/2022)