Wp/17/2020 Of K 2058, Saravanampatti Primary v. The Income Tax Officer

IN THE HIGH COURT OF JUDICATURE AT MADRAS CORAM THE HONOURABLE DR. JUSTICE ANITA SUMANTH K.2058, SARAVANAMPATTI PRIMARYAGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD.,NOW NAME CHANGED ASK.2058, SARAVANMPATTI URBAN CO-OPERATIVE CREDIT SOCIETY LTD.,REP. BY ITS SECRETARY ...PETITIONER IN W.P.NO.17 OF 2020 1 K.1788 NARASEEPURAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY K.NATARAJ M/49, S/O. KALISAMY, NO.9/56, NAGAR KOIL STREET, PULLAGOUNDENPUDUR. ... PETITIONER in WP No.20 of 2020 1 K.758 IKKARAI BOLUVAMPATTI PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY G.NAGAMANI F/49 W/O.JOTHIKANNAN, NO.33 RAJAJI STREET, IKKARAI, BOLUVAMPATTI POST, COIMBATORE.... PETITIONER in WP No.22 of 2020 1 C.C.2343 NANJUNDAPURAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY R. RAMESHKUMAR M/49 S/O.K.RANGASAMY, NO.2/133, SOMAYANUR, THADAGAM POST, COIMBATORE. ... PETITIONER in WP No.23 of 2020 1 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. ... PETITIONER in WP No.26 of 2020 1 K.2065 KALIKKANAICKEN PALAYAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY S.SIVASWAMY M/56 S/O.S.SUBRAMANIAM, NO. 1/136 VINAYAGAR NAGAR, COIMBATORE. ... PETITIONER in WP No.29 of 2020 1 K.1594 PERUMANALLUR PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY A. BALAMANI W/O. G.D.SENTHIL GANESU NO 3/45 MAIN ROAD, PERUMANALLUR, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1107 of 2020 1 3145 THORAVALUR PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY M.S.RAVICHANDRAN S/O. SIVALINGAM THORAVALUR, MERKUPATHI POST- 638103, KUNNATHUR VIA, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1118 of 2020 1 AA516 MORATTUPALAYAM PRIM ARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY K.THIROWPATHI S/O. C.GOVINDASAMY, NO 1/142 KAVUDAMPALAYAM, MORATTUPALAYAM POST, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1121 of 2020 1 NO. 3386 KATTUMADHAPPUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY G. LATHADEVI F/44 W/O GOVINDASAMY, NO. 7/469-29 ALR NAGAR, PONGALUR AND POST, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1123 of 2020 1 AA 189 INGUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY N.KUMARASAMY S/O.NACHIMUTHU GOUNDER, INGUR POST 638 058, PERUNDURAI TALUK, ERODE DISTRICT. ... PETITIONER in WP No.1124 of 2020 1 K-2051 VIJAYAPURAM URBAN CO OPERATIVE CREDIT SOCIETY LTD REP BY ITS SECRETARY A.MUTHUNAGAI W/O. M. SHANMUGASUNDARAM NO 42 THENDRAL NAGAR, VIJAYAPURAM, TIRUPPUR-641606. ... PETITIONER in WP No.1125 of 2020 1 9481 KARADIVAI PRIMARY AGRIC ULTURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY M.BOOMA F/53 W/O. P.SHANMUGAM, NO. 2/96, NORTH STREET, KARADIVAVI POST, PALLADAM TALUK, TIRUPPUR. ... PETITIONER in WP No.1127 of 2020 1 K-2040 MANICKAURAMPUDUR PRIMARY AGRICULTURAL CO OPERATIVE CREDITSOCIETY LTD., REP BY ITS SECRETARY A. KUMARESAN, S/O. K.ARUMUGAM NO. 2730, HOUSING UNIT MUDALIPALAYAM VILLAGE, TIRUPPUR. ... PETITIONER in WP No.1129 of 2020 1 A.A.531 KESARIMANGALAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY KANNAYAL W/O.K.MADHAPPAN KUPPUCHIPALAYAM, KESARIMANGALAM POST 638 311, BHAVNI TALUK, ERODE DISTRICT. ... PETITIONER in WP No.1125 of 2020 1 9481 KARADIVAI PRIMARY AGRIC ULTURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY M.BOOMA F/53 W/O. P.SHANMUGAM, NO. 2/96, NORTH STREET, KARADIVAVI POST, PALLADAM TALUK, TIRUPPUR. ... PETITIONER in WP No.1127 of 2020 1 K-2040 MANICKAURAMPUDUR PRIMARY AGRICULTURAL CO OPERATIVE CREDITSOCIETY LTD., REP BY ITS SECRETARY A. KUMARESAN, S/O. K.ARUMUGAM NO. 2730, HOUSING UNIT MUDALIPALAYAM VILLAGE, TIRUPPUR. ... PETITIONER in WP No.1129 of 2020 1 A.A.531 KESARIMANGALAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY KANNAYAL W/O.K.MADHAPPAN KUPPUCHIPALAYAM, KESARIMANGALAM POST 638 311, BHAVNI TALUK, ERODE DISTRICT. ... PETITIONER in WP No.1131 of 2020 1 K.1755 GOUNDAMPALAYAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY A.GOVINDASAMY M/48 S/O. ARUNACHALA GOUNDER, NO. 7/469-29 ALR NAGAR, PONGALUR,TIRUPPUR. ... PETITIONER in WP No.1133 of 2020 1 A.A 508 SINGAMPETTAI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY (INCHARGE) VIJAYA F/ 51 W/O. GOPAL, SINGAMPETTAI POST 638 311, BHAVANI TALUK, ERODE DISTRICT. ... PETITIONER in WP No.1136 of 2020 1 A.A.82 VILAKKETHI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY O.S.SUBRAMANIAN S/O.SENGODA GOUNDER, NO.2/25, FOURT ROAD, SIVAGIRI VIA, VILAKKETHI, ERODE DISTRICT. ... PETITIONER in WP No.1138 of 2020 1 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, SULUR TALUK, COIMBATORE. ... PETITIONER in WP No.1139 of 2020 1 AA 300 BARGUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY R. DEVENDRAN M/49 S/O. RAJI REDDY, BARGUR AND POST, ANTHIYUR TALUK, ERODE DISTRICT. ... PETITIONER in WP No.1141 of 2020 1 K.1571 KARATTUPALAYAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY T.XAVIOUR PAUL VINCENT, S/O.A.THANGAMUTHU NO.1/176-A , ALAGUMALAI AND POST, TIRUPPUR. ... PETITIONER in WP No.1143 of 2020 1 NO. 8729 KEELVANI PRIMARY AGRICULATURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY A.MOHAN M/50 S/O. AZHAGUSAMY, NO. 471, ANDAL NAGAR, KULLAMPALAYAM POST, ANTHIYUR TALUK, ERODE DISTRICT. ... PETITIONER in WP No.1145 of 2020 1 K-1621 PONGALUR PRIMARY AGRICUTLTURAL CO OPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY, V.SRINIVASAN S/O. VENKATARAMAN NO 11-B, ANTHERI GOUNDER THOTTAM, MANGALAM ROAD, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1146 of 2020 1 K.1759 VELAMPATTI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY P.SELLAMUTHU S/O. PALANISAMY GOUNDER NO.3/149 R.PUDUPALAYAM POLLIKALIPALAYAM POST, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1149 of 2020 1 K. 2049 PERIYANAICKENPALAYAM, PRIMARY AGRIULTURAL COOPERATIVE CREDIT SOCIETY LTD. REP. BY ITS SECRETARY INCHARGE D. VANAJA F/52 W/O. DURAISAMY, NO. 53/3 OOR GOUNDER THOTTAM, COIMBATORE. ... PETITIONER in WP No.1150 of 2020 1 K-2043 ANDIPALAYAM PRIMARY AGRICULTRUAL CO OPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY N.VISVESWARAN S/O.M.NACHIMUTHU, NO 1/94 A. VELAYUDHAMPALAYAM, ALAGUMALAI POST, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1152 of 2020 1 K.2080 P. KARIAMPALAYAM PRIMRY AGRIULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY K. SHANMUGASUNDARAM M/54 S/O. KRISHNAN NO. 6/129 BHARATHI NAGAR, KOVARI ROAD, COIMBATORE. ... PETITIONER in WP No.1155 of 2020 1 K-2043 ANDIPALAYAM PRIMARY AGRICULTRUAL CO OPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY N.VISVESWARAN S/O.M.NACHIMUTHU, NO 1/94 A. VELAYUDHAMPALAYAM, ALAGUMALAI POST, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1152 of 2020 1 K.2080 P. KARIAMPALAYAM PRIMRY AGRIULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY K. SHANMUGASUNDARAM M/54 S/O. KRISHNAN NO. 6/129 BHARATHI NAGAR, KOVARI ROAD, COIMBATORE. ... PETITIONER in WP No.1155 of 2020 1 K.2069 VEERAKERALAM PRIMARY AGRIULTURAL COOPERATIVE CREDIT SOCIETY LTD., NOW NAME CHANGED AS K. 2069 VEERAKERALAM URBAN COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY. ... PETITIONER in WP No.1161 of 2020 1 K.343 ONDIPUDUR PRIMARY AGRIULTURAL COOPERATIVE CREDIT SOCIETY LTD., NOW NAME CHANGED AS K. 343 ONDIPUDUR URBAN COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY R. INDIRANI F/56, W/O PALANISAMY. ... PETITIONER in WP No.1166 of 2020 1 K.1006 SINGANALLUR PRIMARY AGRIULTURAL COOPERATIVE CREDIT SOCIETY LTD. NOW NAME CHANGED AS K. 1006 SINGANALLUR URBAN COOPERATIVE CREDIT SOCIETY LTD. REP BY ITS SECRETARY T.KANNAN M/53, S/O S.U.THIRUPATHI. ... PETITIONER in WP No.1169 of 2020 1 K 1603 PULIAMPATTY PRIMARY AGRIULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP BY ITS SECRETARY M. DURAISAMY M/48 S/O. V. MANDHIRIYAPPAN, PULIAMPATTI POST 641 658, PALLADAM TALUK, TIRUPPUR DISTRICT. ... PETITIONER in WP No.1171 of 2020 1 THE CHITHODE FARMERS SERVICES COOPERATIVE SOCIETY LTD., NADUPALAYA, CHITHODE, ERODE DISTRICT, PRESENTLY CALLED AS K 11279 CHITHODE PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY, REP BY ITS SECRETARY ... PETITIONER in WP No.1293 of 2020 1 THE CHITHODE FARMERS SERVICES COOPERATIVE SOCIETY LTD., NADUPALAYAM, CHITHODE, ERODE DISTRICT, PRESENTLY CALLED AS K 11279 CHITHODE PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY, REP BY ITS SECRETARY ... PETITIONER in WP No.1299 of 2020 1 NO.3324 NERINJIPETTAI PRIMARY AGRICULTURAL COPPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY S. MURUGESAN NERINJIPETTAI, ANTHIYUR TALUK, ERODE DISTRICT. ... PETITIONER in WP No.1420 of 2020 Vs THE INCOME TAX OFFICER,NON CORP WARD -2 (5), CBE,NO.63, RACE COURSE ROAD,COIMBATORE - 641 018. ... RESPONDENT IN W.P.NO.17 OF 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (2) CBE NO.63 RACE COURSE ROAD, COIMBATORE 641018. NON CORP WARD - 4 (2) CBE NO.63 RACE COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.20 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (2) CBE, NO.63 RACE COURSE ROAD, COIMBATORE 641018. NON CORP WARD - 4 (2) CBE, NO.63 RACE COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.22 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 2 (1) CBE NO.63 RACE COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.23 of 2020 COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.23 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (2) CBE, NO.63 RACE COURSE ROAD, COIMBATORE 641018. NO.63 RACE COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.26 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (2) CBE, NO.63 RACE COURSE ROAD, COIMBATORE 641018. NO.63 RACE COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.29 of 2020 1 THE INCOME TAX OFFICER, WARD- 1 (4) TPR INCOME TAX OFFICE, NO 121 60 FEET ROAD, TIRUPPUR- 641602. WARD- 1 (4) TPR INCOME TAX OFFICE, NO 121 60 FEET ROAD, TIRUPPUR- 641602. ... RESPONDENT in WP No.1107 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (2) CBE, NO.63 RACE COURSE ROAD, COIMBATORE 641018. NO.63 RACE COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.26 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (2) CBE, NO.63 RACE COURSE ROAD, COIMBATORE 641018. NO.63 RACE COURSE ROAD, COIMBATORE 641018. ... RESPONDENT in WP No.29 of 2020 1 THE INCOME TAX OFFICER, WARD- 1 (4) TPR INCOME TAX OFFICE, NO 121 60 FEET ROAD, TIRUPPUR- 641602. WARD- 1 (4) TPR INCOME TAX OFFICE, NO 121 60 FEET ROAD, TIRUPPUR- 641602. ... RESPONDENT in WP No.1107 of 2020 1 THE INCOME TAX OFFICER, WARD- 1 (4) TPR INCOME TAX OFFICE, NO 121 60 FEET ROAD, TIRUPPUR- 641602. ... RESPONDENT in WP No.1118 of 2020 WARD- 1 (4) TPR INCOME TAX OFFICE, NO 121 60 FEET ROAD, TIRUPPUR- 641602. ... RESPONDENT in WP No.1118 of 2020 1 THE INCOME TAX OFFICER, WARD- 1 (3) TPR INCOME TAX OFFICE, NO 121 60 FEET ROAD, TIRUPPUR- 641602. ... RESPONDENT in WP No.1121 of 20201 THE INCOME TAX OFFICER, WARD 2 (2) TPR INCOME TAX OFFICE, NO. 121 60 FEET ROAD, TIRUPPUR 641 602. ... RESPONDENT in WP No.1123 of 20201 THE INCOME TAX OFFICER WARD 2 (2) ERODE INCOME TAX OFFICE, NO.15 GANDHIJI ROAD, ERODE 638 001, ERODE DISTRICT. ... RESPONDENT in WP No.1124 of 2020 1 THE INCOME TAX OFFICER, WARD- 2 (3) TPR INCOME TAX OFFICE NBO 121 60 FEET ROAD, TIRUPPUR- 641602. ... RESPONDENT in WP No.1125 of 2020 1 THE INCOME TAX OFFICER, WARD 2 (2) TPR INCOME TAX OFFICE, NO. 121 60 FEET ROAD, TIRUPPUR 641 602. ... RESPONDENT in WP No.1127 of 20201 THE INCOME TAX OFFICER, WARD- 2 (3) TPR INCOME TAX OFFICE, NBO 121 60 FEET ROAD, TIRUPPUR- 641602. ... RESPONDENT in WP No.1129 of 20201 THE INCOME TAX OFFICER, WARD 2 (5) ERODE INCOME TAX OFFICE, NO.15 GANDHIJI ROAD ERODE 638 001. ... RESPONDENT in WP No.1131 of 2020 1 THE INCOME TAX OFFICER, WARD 2 (2) TPR INCOME TAX OFFICE, NO. 121 60 FEET ROAD, TIRUPPUR 641 602. ... RESPONDENT in WP No.1133 of 20201 THE INCOME TAX OFFICER, WARD 2 (5) ERODE INCOME TAX OFFICE, NO. 15 GANDHIJI ROAD, ERODE 638 001 ERODE DISTRICT. ... RESPONDENT in WP No.1136 of 2020 1 THE INCOME TAX OFFICER, WARD 2 (4) ERODE INCOME TAX OFFICE, NO.15 GANDHIJI ROAD, ERODE ERODE DISTRICT. ... RESPONDENT in WP No.1138 of 2020 1 THE INCOME TAX OFFICER, WARD- 2 (3) TPR INCOME TAX OFFICE NBO 121 60 FEET ROAD TIRUPPUR- 641602. ... RESPONDENT in WP No.1139 of 2020 1 THE INCOME TAX OFFICER WARD 2 (5) ERODE INCOME TAX OFFICER NO. 15 GANDHIJI ROAD ERODE 638 001. ... RESPONDENT in WP No.1141 of 2020 1 THE INCOME TAX OFFICER, WARD 2 (1) TPR INCOME TAX OFFICE , NO.121 60 FEET ROAD, TIRUPPUR 641 602. ... RESPONDENT in WP No.1143 of 2020 1 THE INCOME TAX OFFICER WARD 2 (5) ERODE INCOME TAX OFFICER NO. 15 GANDHIJI ROAD, ERODE 638 001. ... RESPONDENT in WP No.1145 of 2020 1 THE INCOME TAX OFFICER, WARD- 2 (3) TPR INCOME TAX OFFICE NBO 121 60 FEET ROAD TIRUPPUR- 641602. ... RESPONDENT in WP No.1146 of 2020 1 THE INCOME TAX OFFICER, WARD 2 (1) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD, TIRUPPUR 641 602. ... RESPONDENT in WP No.1149 of 2020 1 THE INCOME TAX OFFICER, 1 THE INCOME TAX OFFICER WARD 2 (5) ERODE INCOME TAX OFFICER NO. 15 GANDHIJI ROAD ERODE 638 001. ... RESPONDENT in WP No.1141 of 2020 1 THE INCOME TAX OFFICER, WARD 2 (1) TPR INCOME TAX OFFICE , NO.121 60 FEET ROAD, TIRUPPUR 641 602. ... RESPONDENT in WP No.1143 of 2020 1 THE INCOME TAX OFFICER WARD 2 (5) ERODE INCOME TAX OFFICER NO. 15 GANDHIJI ROAD, ERODE 638 001. ... RESPONDENT in WP No.1145 of 2020 1 THE INCOME TAX OFFICER, WARD- 2 (3) TPR INCOME TAX OFFICE NBO 121 60 FEET ROAD TIRUPPUR- 641602. ... RESPONDENT in WP No.1146 of 2020 1 THE INCOME TAX OFFICER, WARD 2 (1) TPR INCOME TAX OFFICE NO.121 60 FEET ROAD, TIRUPPUR 641 602. ... RESPONDENT in WP No.1149 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 3 (3) CBE, NO. 63 RACE COURSE ROAD, COIMBATORE 641 018. ... RESPONDENT in WP No.1150 of 2020 1 THE INCOME TAX OFFICER, WARD- 2 (3) TPR INCOME TAX OFFICE NBO 121 60 FEET ROAD TIRUPPUR- 641602. ... RESPONDENT in WP No.1152 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 3 (2) CBE, NO. 63 RACE COURSE ROAD, COIMBATORE 641 018. ... RESPONDENT in WP No.1155 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (2) CBE, NO. 63 RACE COURSE ROAD, COIMBATORE 641 018. ... RESPONDENT in WP No.1161 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 1 (2) CBE, NO. 63 RACE COURSE ROAD, COIMBATORE 641 018. ... RESPONDENT in WP No.1166 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 1 (2) CBE NO. 63 RACE COURSE ROAD, COIMBATORE 641 018. ... RESPONDENT in WP No.1169 of 2020 1 THE INCOME TAX OFFICER, NON CORP WARD - 4 (1) CBE INCOME TAX OFFICE NO. 63 RACE COURSE ROAD COIMBATORE 641 018. ... RESPONDENT in WP No.1171 of 2020 1 THE INCOME TAX OFFICER, WARD - 2(1) ERODE INCOME TAX OFFICE, NO. 15 GANDHIJI ROAD ERODE 638 001 ERODE DISTRICT. ... RESPONDENT in WP No.1293 of 2020 1 THE INCOME TAX OFFICER, WARD - 2(1) ERODE INCOME TAX OFFICE, NO. 15 GANDHIJI ROAD ERODE 638 001 ERODE DISTRICT. ... RESPONDENT in WP No.1299 of 20201 THE ASSESSING OFFICER WARD - 2 (5) ERODE INCOME TAX OFFICE NO. 15 GANDHIJI ROAD ERODE 638 001 ERODE DISTRICT. ... RESPONDENT in WP No.1420 of 2020 Petitions filed under Article 226 of The Constitution ofIndia praying for the issuance of Writ of Certiorari, Calling for the entire records relating to the impugnedorder passed by the respondent in Order No.ITBA/AST/S/143(3)/2019-20/102156681(1), dated 03.12.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022191177 (1) dated 12/12/2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022514123 (1) dated 17/12/2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022573979 (1) dated 18/12/2019 and quash the same.WP No.26 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022662139 (1) dated 19/12/2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022812858 (1) dated 21/12/2019 and quash the same.WP No.1107 of 2020: Calling for the entire records relating to the impugnedorder passed by the Respondent in Order no ITBA/AST/S/143(3)/2019-20/1021926082(1) dated 9.12.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022573979 (1) dated 18/12/2019 and quash the same.WP No.26 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022662139 (1) dated 19/12/2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in order No.ITBA / AST / S/ 143(3)/2019 -20 /1022812858 (1) dated 21/12/2019 and quash the same.WP No.1107 of 2020: Calling for the entire records relating to the impugnedorder passed by the Respondent in Order no ITBA/AST/S/143(3)/2019-20/1021926082(1) dated 9.12.2019 and quash the same. https://hcservices.ecourts.gov.in/hcservices/ WP No.1118 of 2020: Calling for the entire records relating to the impugnedorder passed by the Respondent in Order no ITBA/AST/S/143(3)/2019-20/10222057887(1) dated 10.12.2019 and quash the same. WP No.1121 of 2020: Calling for the entire records relating to the impugnedorder passed by the Respondent in Order no ITBA/AST/S/143(3)/2019-20/1022995191 (1) dated 24.12.2019 and quash the same. WP No.1123 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1021209508(1), dated 27.11.2019 and quash thesame. WP No.1124 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in No. Nil, dated 9.12.2019 andquash the sameWP No.1125 of 2020: Calling for the entire records relating to the impugnedorder passed by the Respondent in Order no ITBA/AST/S/143(3)/2019-20/1023280221 (1) dated 27.12.2019 and quash the same. WP No.1127 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1021187750(1), dated 27.11.2019 and quash thesame. WP No.1129 of 2020:' Calling for the entire records relating to the impugnedorder passed by the Respondent in DIN AND Order noITBA/AST/S/143(3)/2019-20/1023247857 (1) dated 27.12.2019 andquash the same. https://hcservices.ecourts.gov.in/hcservices/ Calling for the entire records relating to the impugnedorder passed by the respondent in Order No.ITBA/ AST/ S/ 143(3)/ 2019-20 / 1022401676 (1), dated 16.12.2019 and quash thesame. WP No.1133 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1021209480(1), dated 27.11.2019 and quash thesame. WP No.1136 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in No. Nil, dated 12.12.2019 andquash the same.WP No.1138 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in DIN and Order No.ITBA/ AST/ S/143 (3)/ 2019-20 / 1023117148 (1), dated 26.12.2019 and quashthe same WP No.1139 of 2020: Calling for the entire records relating to the impugnedorder passed by the Respondent in DIN AND Order noITBA/AST/S/143(3)/2019-20/1023245386(1) dated B27.12.2019 andquash the same. WP No.1141 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1022259390(1), dated 13.12.2019 and quash thesame. WP No.1143 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in DIN and Order No.ITBA/ AST/ S/143 (3)/ 2019-20 / 1023350910 (1), dated 28.12.2019 and quashthe same. https://hcservices.ecourts.gov.in/hcservices/ WP No.1145 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1022349943(1) dated 14.12.2019 and quash thesame. WP No.1141 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1022259390(1), dated 13.12.2019 and quash thesame. WP No.1143 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in DIN and Order No.ITBA/ AST/ S/143 (3)/ 2019-20 / 1023350910 (1), dated 28.12.2019 and quashthe same. https://hcservices.ecourts.gov.in/hcservices/ WP No.1145 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1022349943(1) dated 14.12.2019 and quash thesame. Calling for the entire records relating to the impugnedorder passed by the Respondent in DIN AND Order noITBA/AST/S/143(3)/2019-20/1023278768(1) dated 27.12.2019 andquash the same. WP No.1149 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in DIN and Order No.ITBA/ AST/ S/143 (3)/ 2019-20 / 1023350258 (1), dated 28.12.2019 and quashthe same.WP No.1150 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in its Din and Order No. ITBA /AST / S / 143(3) / 2019-20 / 1022989975(1), dated 24.12.2019 andquash the same WP No.1152 of 2020:Calling for the entire records relating to the impugnedorder passed by the Respondent in DIN AND Order noITBA/AST/S/143(3)/2019-20/1023244160 (1) dated 27.12.2019 andquash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in its DIN and Order No. ITBA /AST / S / 143(3) / 2019-20 / 1022985441(1), dated 24.12.2019 andquash the same.WP No.1161 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in its DIN and Order No. ITBA /AST / S / 143(3) / 2019-20 / 1023055962(1), dated 25.12.2019 andquash the same. https://hcservices.ecourts.gov.in/hcservices/ WP No.1166 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in its DIN and Order No. ITBA /AST / S / 143(3) / 2019-20 / 1023150445(1), dated 26.12.2019 andquash the same. WP No.1169 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in its DIN and Order No. ITBA /AST / S / 143(3) / 2019-20 / 1023232578(1), dated 27.12.2019 andquash the same. WP No.1171 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1023123584(1), dated 26.12.2019 and quash thesame. WP No.1293 of 2020:Calling for the entire records relating to the impugnedorder passed by the respondent in order No. 20121021215, dated05.11.2019 and quash the same.WP No.1299 of 2020: Calling for the entire records relating to the impugnedorder passed by the respondent in Order No. ITBA / AST / S / 143(3) / 2019-20 / 1019850465 (1), dated 06.11.2019 and quash thesame. Calling for the records relating to impugned assessmentorder passed in order No. Nil dated 27/12/2019 (PAN. ), Demand Notice dated 27/12/2019 and the Notice undersection 274 read with section 271 (1) (c) of the Income Tax Act,1961 in DIN and Notice No.ITBA / PNL/S/271 (1) (c) /2019 -20/1023203770 (1) dated 27/12/2109 all on the file of therespondent quash the same. For Petitioner in W.P.No.17, 20, 22, 23, 26, 29, 1123, 1127, 1129, 1131, 1133, 1136, 1141, 1145, 1150, 1155, 1161, 1166, 1169, 1171,1293 & 1299 For Petitioner in W.P.Nos.1107, 1118, 1121, 1125, 1139, 1146 and 1152/2020 :Mr.C.Prakasam for R.Hemalatha For Petitioner in W.P.Nos.1124, 1138, 1143 and 1149 of 2020 :Mr.C.Prakasam for V.Sumitha For Petitioner in W.P. No.1420 of 2020 : Mr.V.Elangovan For Respondent in all WPs : Mr.ANR.Jaya Prathap,Standing Counsel For Petitioner in W.P.No.17, 20, 22, 23, 26, 29, 1123, 1127, 1129, 1131, 1133, 1136, 1141, 1145, 1150, 1155, 1161, 1166, 1169, 1171,1293 & 1299 For Petitioner in W.P.Nos.1107, 1118, 1121, 1125, 1139, 1146 and 1152/2020 :Mr.C.Prakasam for R.Hemalatha For Petitioner in W.P.Nos.1124, 1138, 1143 and 1149 of 2020 :Mr.C.Prakasam for V.Sumitha For Petitioner in W.P. No.1420 of 2020 : Mr.V.Elangovan For Respondent in all WPs : Mr.ANR.Jaya Prathap,Standing Counsel This batch of nine (9) Writ Petitions have been filed byentities claiming to be Primary Agricultural Cooperative CreditSocieties. Since the issues that arise are common to thepetitioners and by consent expressed by all learned counsel, thematters are taken up for adjudication and disposal finally. 2. Returns of income had been filed by the petitionersclaiming exemption in terms of Section 80 P of the Income TaxAct, 1961 (in short 'I.T.Act'). The respondent - AssessingOfficer took the returns up for examination and issued noticesand questionnaires calling for details in regard to whetherdeduction was available under Chapter VIA as claimed, whetherthe sales receipts/turnover had been correctly offered to taxand calling for explanations of the assessee/petitioner inregard to investments/advances/loans. 3. The petitioners responded to the queries raised by theOfficer. One of the issues that arose for consideration was theeligibility to exemption claimed on the interest income receivedby the petitioner from deposits/investment of funds in banks.Such income, according to the Officer, was ineligible fordeduction under Section 80P, since it did not form part of the https://hcservices.ecourts.gov.in/hcservices/ operational income of the petitioner/assessee and was liable tobe taxed in terms of Section 56 of the I.T. Act. The Officerrelied on the judgment of the Supreme Court in the case ofTotgars' Cooperative Sale Society Limited V. ITO, Karnataka (322ITR 283). 4. The petitioners were put to notice of the proposal tobring to tax the interest receipts under the head 'othersources'. The petitioners sought to distinguish the judgment inthe case of Totgars (supra) on the grounds that Totgars was aSociety engaged in sales, whereas, the petitioner was a PrimaryAgricultural Cooperative Credit Society. That apart, the fundsthat were deposited giving rise to the interest income did notconstitute a surplus, but a mandatory statutory reserve. 5. Reliance was placed on a judgment of the Supreme Courtin Commissioner of Income Tax, Jalandhar V. Nawanshahar CentralCooperative Bank Limited ((2007) 15 SCC 611) wherein the Benchhas observed that the deposit effected was in the nature of astatutory reserve. According to the petitioners, such statutoryreserve would not fall within the ambit of ‘surplus funds’ andthe judgment in the case of Totgars (supra) was inapplicable totheir cases. 6. In addition, the petitioner also stated that the totalamount invested, Rs.15,51,18,027/- in the case of K.2058Saravanampatti Primary Agricultural Cooperative Credit SocietyLimited, petitioner in W.P.No.17 of 2020, (whose facts are takento be illustrative of the facts in other Writ Petitions as wellon the basis of the submissions of both learned counsel to theeffect that the facts and legalities in all writ petitions aresimilar excepting for the figures involved), comprisedsignificantly of external borrowings. In this case, a sum ofRs.12,57,23,490/- had been borrowed from the Coimbatore DistrictCentral Cooperative Bank. It is not elaborated as to why thisborrowal was effected. Perhaps, it was the mandate of thestatutory reserve that compelled the petitioner to effect theborrowing to maintain such reserve. 7. It was also the contention of the petitioners before theAssessing Officer that if at all interest earned was to bebrought to tax, then, alternatively, interest paid on the loanshould be deducted from interest received or in other words,there should be a netting of the interest paid and received andonly the resultant figure be brought to tax. 8. The Assessing Authority however rejected the submissionscursorily stating in a single line that ‘statutory reserve can https://hcservices.ecourts.gov.in/hcservices/ also be considered as surplus funds of the assessee’. Thejudgement of the Supreme Court in the case of Nawanshahar(supra) has not been considered or discussed and neither has theplea of the petitioner for netting of interest paid and earned. 9. In Nawanshahar (supra), the Supreme Court considered thequestion of whether investments made by a banking concern arepart of the business of banking. The conclusion was that theincome arising from investments would be attributable to thebusiness of the bank and fall under the head 'profits and gainsof business', deductible under Section 80P(2)(a)(i) of the I.T.Act. The earlier view in Bihar Coop. BankLtd. V. CIT ((1960) 39ITR 114, CIT V. Karnataka State Coop. Apex Bank ((2001) 7 SCC654) and CIT V. Ramanathapuram Distt. Coop.Central Bank Ltd.((2009) 17 SCC 620) was followed. 10. At paragraph 4 of the short judgment, the Bench hasstated that the principle in those cases would cover a situationwhere a Co-operative Bank carrying on the business of banking isstatutorily required to place a part of its funds in approvedsecurities. 11. The distinction I note, at first blush, is that thisjudgment has been rendered in the case of a Co-operative Bank,whereas, the petitioners before me are Co-operative Societies.The Supreme Court in Citizen Co-operative Society Limited V.Assistant Commissioner of Income-Tax, Circle -9(1), Hyderabad(397 ITR 1) has noted the distinction between a Co-operativeBank that would be governed by the provisions of the BankingRegulation Act, 1949, where its operations would includeengagement of the members of the general public, and a co-operative Society, whose operations would be confined to itsmembers. 12. This is the distinction between the two kinds of co-operative societies as set out under Section 80P(2)(a)(i), thatis, those carrying on the business of banking and thoseproviding credit facilities to its members. However, a commonmandate in both cases, though arising under differentenactments, is for such entity to place a part of its fundsin/with specific facilities/entities. 13. One of the petitioners before me (KalikkanaickenpalayamPrimary Agricultural Cooperative Credit Society Ltd.in W.P.No.29of 2020) has specifically raised before the Assessing Authoritythe argument that the Tamil Nadu Co-operative Societies Act,1983 (in short 'TNCS Act') mandates Co-operative Societies toplace a portion of their funds as a statutory reserve with a https://hcservices.ecourts.gov.in/hcservices/ District Co-operative Bank. The argument appears to be that thestatutory reserve forms part of and is an essential feature ofthe operations and any interest generated therefrom would beoperational income entitled to deduction under Section 80P ofthe I.T.Act. 14. The respondent officer has relied on a more recentjudgment of the Supreme Court in Totgars' (supra), where theBench was concerned with surplus funds which the assessee hadinvested in short term deposits with banks and Governmentfacilities. The question referred for decision was as follows: https://hcservices.ecourts.gov.in/hcservices/ District Co-operative Bank. The argument appears to be that thestatutory reserve forms part of and is an essential feature ofthe operations and any interest generated therefrom would beoperational income entitled to deduction under Section 80P ofthe I.T.Act. 14. The respondent officer has relied on a more recentjudgment of the Supreme Court in Totgars' (supra), where theBench was concerned with surplus funds which the assessee hadinvested in short term deposits with banks and Governmentfacilities. The question referred for decision was as follows: 'Whether, on the facts and in the circumstances of thecase, the Tribunal was right in law in holding thatthe income by way of interest on deposits held withscheduled banks, bonds and other securities waschargeable to tax under section 56 under the head`Income from other sources' without allowing anydeduction in respect of cost of funds andproportionate administrative and other expensesunder section 57?' 15. Thus the issue before the Court in Totgars (supra) wason the classification of interest generated by deposits heldwith scheduled banks, bonds and other securities withoutproviding for a deduction in respect of cost of funds andproportionate administrative and other expenses under Section57. The question of interest generated from deposits made byreason of a statutory mandate was raised and finds reference inthe narration of the petitioners' submissions, the Court has,at para 8 of the report (ITR) stated that 'At the outset, an important circumstance needsto be highlighted. In the present case, the interestheld not eligible for deduction under Section 80P(2)(a)(i) of the Act is not the interest received fromthe members for providing credit facilities to them.What is sought to be taxed under Section 56 of theAct is the interest income arising on the surplusinvested in short-term deposits and securities whichsurplus was not required for business purposes.Assessee(s) markets the produce of its members whosesale proceeds at times were retained by it. In thiscase, we are concerned with the tax treatment of suchamount. Since the fund created by such retention wasnot required immediately for business purposes, itwas invested in specified securities. The question,before us, is - whether interest on suchdeposits/securities, which strictly speaking accrues to the members' account, could be taxed as businessincome under Section 28 of the Act? In our view, suchinterest income would come in the category of "Incomefrom other sources",....' 16. The revenue has filed counters in a few writ petitionsobjecting to the maintainability of writs sought and againrelying on the judgement of the Supreme Court in the case ofTotgars (supra). Additionally, Mr.Jayapratap points out that theissue in regard to the classification and taxability of interestincome has not been specifically raised in the affidavit filedin support of the Writ Petitions. Upon perusal, the affidavitsappear to be a cut and paste exercise from Writ Petitions filedby other Co-operative Societies challenging orders of assessmentrejecting claims for exemption on the ground of mutuality.Though there is one general ground raised in regard toavailability/entitlement to deduction under Section 80P itself,'The respondent failed to consider that the cooperativesocieties are entitled to seeking deduction u/s.80(P) of IncomeTax Act, but the same was not considered by the respondent’, allother grounds revolve only around the aspect of mutuality andare entirely irrelevant to the issue arising from the presentimpugned order. No specific ground has been raised on theclassification of interest income and whether the same wouldfall within the ambit of income from business or other sources. 17. However, the petitioners have responded to the showcause notice issued by the officer raising this issue and theirresponse has been extracted in the orders of assessment, asfollows: W.P.No.17 of 2020: 'The Supreme Court judgment in Togars Cooperative SaleSociety Ltd no applicable to our society as the abovesociety is a sale society and ours is PrimaryAgricultural Co-operative Credit Society. The former isdealing sale of goods and ours is dealing in creditfacility extended to the members. Also, as per section 80P2a, profits and gainsattributable to the business of the society and the wordattributable is having elaborate meaning as derived inCommissioner of Income-tax vs. Nawanshahar Central Co-operative bank Ltd. Civil Appeal Nos.2499, 2500 of 20058th April 2005. So, the funds deposited is not a surplus fund as decidedin Totgars Co-operative Sale Society Ltd., but a statutory reserve maintained as decided in Commissionerof Income tax Vs. Nanshahar Central Cooperative BankLtd. The amount in investments is Rs.15,51,18,027/- out ofthis Rs.12,57,23,490/0 was borrowed from CoimbatoreDistrict Central Co-operative Bank. if interest earnedis taxed the interest paid to such loans are deductedform the interest on other sources. So, kindly drop the proceeding by taxing the interestincome and accept the returned income' W.P.No.29 of 2020: ‘Received you show cause notice and noted the contents.In this regard we wish to submit the following for yourconsideration. The Supreme Court judgement in Totgars Cooperative SaleSociety Ltd., not applicable to our society as the abovesociety is a sale society and ours is PrimaryAgricultural Cooperative Credit Society. The former isdealing sale of goods and ours is dealing in creditfacility extended to the members. Major difference inboth former is dealing sale of something and ours isdealing in money, when money involved in the bank orcredit society, definitely a reserve must be maintainedfor easy liquidation purpose in case of emergency. Also, as per section 80P2A, profits and gainsattributable to the business of the society and the wordattributable is having elaborate meaning as derived inthe COMMISSIONER OF INCOME TAX vs. NAWANSHAHAR CENTRALCOOPERATIVE BANK LTD Civil Appeal Nos.2499 2500 of 20058[th] April, 2005, 2007 208 CTR SC 438:2007 289 ITR 6SC:2007 160 TAXMAN 48 Also it is to be noted that every Cooperative Society isto be maintained a statutory reserve of 25 percent ofthe total deposits including savings bank account andcurrent account balances with District CentralCooperative banks to provide proper liquidity to thesocieties. So, the funds deposited is not a surplus fund as decidedin Totgars Cooperative Sale Society Ltd., but astatutory reserve maintained as decided in COMMISSIONEROF INCOME TAX vs. NAWANSHAHAR CENTRAL COOPERATIVE BANKLTD. The following cases are also to be considered by theHonorable Supreme Court of India in the case of interestreceived on deposits etc., Supreme Court of IndiaCommissioner Of Income-Tax vs Ramanathapuram Distt. Co-Op. ... on 30 October, 2001Equivalent citations: 2002 255 ITR 423 SC Bench: S Bharucha, Y Sabharwal, B KumarORDER So, the funds deposited is not a surplus fund as decidedin Totgars Cooperative Sale Society Ltd., but astatutory reserve maintained as decided in COMMISSIONEROF INCOME TAX vs. NAWANSHAHAR CENTRAL COOPERATIVE BANKLTD. The following cases are also to be considered by theHonorable Supreme Court of India in the case of interestreceived on deposits etc., Supreme Court of IndiaCommissioner Of Income-Tax vs Ramanathapuram Distt. Co-Op. ... on 30 October, 2001Equivalent citations: 2002 255 ITR 423 SC Bench: S Bharucha, Y Sabharwal, B KumarORDER 1. The High Court has answered against the Revenue, thefollowing question :"Whether, on the facts and in the circumstances of thecase, the Appellate Tribunal was correct in law inholding that the interest on securities, subsidiesreceived from the Government and dividend businessincome of the assesse entitled to deductionunder Section 80P(2)(a)(i) of the Income-tax Act, 1961 ?"2. The very question was considered by this court in CITv. Karnataka State Co-operative Apex Bank [2001] 251 ITR194 and the conclusion was reiterated in MehsanaDistrict Central Co-operative Bank Ltd. v. ITO .3. It is now contended on behalf of the Revenue that thedecision of this court in United Commercial Bank Ltd. v.CIT [1957] 32 ITR 688 was not considered.4. We do not think that it is open to the Revenue tourge, through different counsel, the same thing againand again. We are satisfied that the answer to thequestion has been correctly given in the decisionsaforementioned and in the order under appeal.5. The civil appeals are dismissed with costs.Also the jurisdictional Madras High Court also lookinginto the Totgars case and allowed the interest receivedis allowed under section 80P in case of Madras HighCourtThe Commissioner Of Income Tax vs M/S. VeerakeralamPrimary ... on 5 July, 2016 IN THE HIGH COURT OF JUDICATURE AT MADRASDated: 05.07.2016CORAM :THE HONOURABLE MR. JUSTICE S.MANIKUMARandTHE HONOURABLE MR. JUSTICE D.KRISHNAKUMARTax Case Appeal Nos.735, 755 of 2014 and 460 of 2015The Commissioner of Income Tax,63, Race Course Road Coimbatore. .. Appellant in all the above appeals VsM/s. Veerakeralam Primary Agricultural Co-operative Credit SocietyNo.17, Peria Thottam ColonyVeerakeralamCoimbatore 641 007.So, on the basis of the above kindly drop theproceedings by taxing the interest income and accept thereturned income.’ 18. Though all petitioners have not replied identically tothe notices issued by the officer, the above replies areillustrative of the stands adopted by the petitioners at thetime of assessment and crystallize the arguments of thepetitioners’ to the effect that (i) the investments in questiondo not comprise surplus funds (ii) that the inves