Wp/7038/2020 Of Aa520 Veerappampalayam Primary Agricultural v. The Deputy Commissioner Of Income Tax

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 07.04.2021 CORAM THE HONOURABLE DR.JUSTICE ANITA SUMANTH W.P.NOS.7038, 7043, 4901, 4441, 4448, 6455 & 7014 OF 2020AND 17938, 17963, 17954, 17944, 17957, 17950, 20711, 20767& 25806 OF 2019 W.M.P.NOS.8392, 8393, 8395, 8400, 8401, 8403, 7625, 7622,5799, 5801, 7623, 5257, 5259, 5266, 5267, 8366, 8369, 14346,16166, 16167, 16171, 16225 & 16226 OF 2020, 17360, 17379,17367, 17343, 17346, 17352, 19868, 19869, 19934, 19937,25253, 25254 OF 2019 AND 2654 OF 2021 1 AA520 VEERAPPAMPALAYAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LIMITED,REPRESENTED BY ITS SECRETARY, A.A.520, VEERAPPAMPALAYAM ARACHALUR (VIA),ERODE - 638 101.PAN: ... PETITIONER in W.P.No.7038 of 2020 1 SAKTHI SUGARS EMPLOYEES CO-OPERATIVE THRIFT CREDIT SOCIETY LIMITED, REPRESENTED BY ITS SECRETARY MR.R.NATARAJAN, SAKTHI NAGAR BHAVANI, ERODE - 638 315.PAN NO. ... PETITIONER in W.P.No.7043 of 2020 1 SLM/ HSG - 82 THE KANGAYAM TALUK COOPERATIVE HOUSING SOCIETY LTD.,REP. BY ITS SECRETARY, P.SELVARAJ, S/O.N.PALANISAMY,NO.12-D, BUNGALAPUDUR ROAD, KOVAI ROAD, KANGAYAM – 638 701,TIRUPPUR DISTRICT. ... PETITIONER in W.P.No.4901 of 2020 1 K.464 UNJALUR KOLATHURPALAYAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD.,REP. BY ITS SECRETARY V.C.SAKTHIVEL MURUGAIAN, S/O.CHINNAPPA GOUNDER, NO.9/183, UNJALUR KOLATHUPALAYAM,UNJALUR – 638 152, ERODE DISTRICT. ... PETITIONER in W.P.No.4441 of 2020 1 AA 529 KOLANALLI KUTTAPPALAYAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY LTD.,REP. BY ITS SECRETARY, K.M.SETHUPATHI, S/O.MALAIYANAN NO.4/4, KUTTAPPALAYAM KOLANALLI. ... PETITIONER in W.P.No.4448 of 2020 1 K 114 GOBICHETTIPALAYAM PUBLIC SERVANTS CO OP THRIFT AND CREDIT SOCIETY LIMITED,REPRESENTED BY ITS SECRETARY MR.S.K.SRINIVASAN, NO.6, FIRST STREET, SEETHAMMAL COLONY,NAGARPALAYAM ROAD, GOBICHETTIPALAYAM,ERODE – 638452.PAN: ... PETITIONER in W.P.No.6455 of 2020 1 K 461 SENGODAGOUNDENPUDUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD.,REP. BY ITS SECRETARY M.SARASWATHI,F/45 S/O.BALASUBRMANI,ARASUR, ARASUR POST, SULUR,COIMBATATORE – 641 407 ... PETITIONER in W.P.No.7014 of 2020 1 K.1645 KURUNALLIPALAYAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD.,REP. BY ITS SECRETARY N.MANI S/O.NANJUDASAMY,NO.7/30 NALLATTIPALAYAM, KINATHUKADAVU TALUK,COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17938 of 2019 1 K 142 ANGALAKURICHI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY,A.K.KALIMUTHU, S/O.KARUPPUSAMY, ANGALAKURICHI - 642 007, POLLACHI TALUK, COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17963 of 2019 1 K.1662 J.KRISHNAPURAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD.,REP. BY ITS SECRETARY,D.KATHIRVEL, S/O.DURAISAMY J.,KRISHNAPURAM AND POST - 641 671 KETHANUR VIA, SULUR TALUK, COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17954 of 2019 1 T.P.SPL.45 VADAPUDUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY V.MOORTHY, M/47 S/O.VELUSAMY, NO.2/186, VADAPUDUR, EZHOOR POST - 641 032,KINATHUKADAVU TALUK, COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17944 of 2019 1 DR (L)C.13 KINATHUKADAVU COOPERATIVE PRIMARY AGRICULTURE AND RURAL DEVELOPMENT BANK LTD.,REP. BY ITS SECRETARY N.SENTHILKUMAR, S/O.C.NAGARATHINAM, KINATHUKADAVU - 642 109,COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17957 of 2019 1 K.1535 VADACHITTUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY S.ARUMUGAM S/O.SIVASAMY, NO.115A-1, ANNA NAGAR 1ST STREET, KINATHUKADAVU AND TALUK,COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17950 of 2019 1 K.484 PUNJAIKALAMANGALAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY,REP. BY ITS PRESIDENT M.CHINNASAMY, S/O.MUTHUSAMY GOUNDER, PUNJAIKALAMANGALAM, GANAPATHIPALAYAM POST,MODAKURUCHI, ERODE DISTRICT. ... PETITIONER in W.P.No.20711 of 2019 1 DR (L)C.13 KINATHUKADAVU COOPERATIVE PRIMARY AGRICULTURE AND RURAL DEVELOPMENT BANK LTD.,REP. BY ITS SECRETARY N.SENTHILKUMAR, S/O.C.NAGARATHINAM, KINATHUKADAVU - 642 109,COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17957 of 2019 1 K.1535 VADACHITTUR PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD., REP. BY ITS SECRETARY S.ARUMUGAM S/O.SIVASAMY, NO.115A-1, ANNA NAGAR 1ST STREET, KINATHUKADAVU AND TALUK,COIMBATORE DISTRICT. ... PETITIONER in W.P.No.17950 of 2019 1 K.484 PUNJAIKALAMANGALAM PRIMARY AGRICULTURAL CO-OPERATIVE CREDIT SOCIETY,REP. BY ITS PRESIDENT M.CHINNASAMY, S/O.MUTHUSAMY GOUNDER, PUNJAIKALAMANGALAM, GANAPATHIPALAYAM POST,MODAKURUCHI, ERODE DISTRICT. ... PETITIONER in W.P.No.20711 of 2019 1 A.A.398 KUPPANDAMPALAYAM PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY, REP. BY ITS SECRETARY K.K.LOGANATHAN, S/O.KOMARASAMY GOUNDER,KARATTUR, KUPPANDAMPALAYAM POST,ATHANI VIA, ANTHIYUR TK, ERODE DISTRICT. ... PETITIONER in W.P.No.20767 of 2019 1 THE POLLACHI NORTH COOPERATIVE PRIMARY AGRICULTURAL AND RURAL DEVELOPMENT BANK LTD., D.R.L.C.5 REP. BY ITS SECRETARY,A.MOHAMED THAJULLAH M/33 S/O.MOHAMED AMANULLAH,NO.69, VALLALAR STREET, VENKATESA COLONY,POLLACHI – 642 001, COIMBATORE DISTRICT. ... PETITIONER in W.P.No.25806 of 2019 .Vs. 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CPC, BANGALORE - 560 500.2 THE INCOME TAX OFFICER, WARD 2 (1), ERODE. 3 THE BRANCH MANAGER, ERODE DISTRICT CENTRAL COOPERATIVE BANK,TN PALAYAM, ERODE. ... RESPONDENTS in W.P.No.7038 of 2020 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTRE, BANGALORE – 560500. 2 THE INCOME TAX OFFICER, WARD 2 (5), ERODE. 3 THE GENERAL MANAGER, ERODE DISTRICT CENTRAL COOPERATIVE BANK LIMITED,NO.1, BHAVANI MAIN ROAD, THIRUNAGAR COLONY, ERODE - 638 003. ... RESPONDENTS in W.P.No.7043 of 2020 1 THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRALIZED PROCESSING CENTER (CPC),INCOME TAX DEPARTMENT,BENGALURU - 560 500.... RESPONDENT in W.P.No.4901 of 2020 1 THE DEPUTY COMMISSIONER OF INCOME TAX CENTRALIZED PROCESSING CENTER (CPC), INCOME TAX DEPARTMENT,BENGALURU - 560 500.... RESPONDENT in W.P.No.4441 of 2020 1 THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRALIZED PROCESSING CENTER (CPC),INCOME TAX DEPARTMENT,BENGALURU - 560 500.... RESPONDENT in W.P.No.4448 of 2020 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTRE, BANGALORE - 560 500. 2 THE INCOME TAX OFFICER, WARD 2 (1), ERODE. 3 THE BRANCH MANAGER, ERODE DISTRICT CENTRAL CO-OPERATIVE BANK, GOBICHETTIPALAYAM. ... RESPONDENTS in W.P.No.6455 of 2020 1 THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.7014 of 2020 1 THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500 ... RESPONDENT in W.P.No.17938 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17963 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17954 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17944 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500.CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17957 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500.CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17950 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER, INCOME TAX DEPARTMENT,BENGALURU - 560 500. ... RESPONDENT in W.P.No.20711 of 2019 ... RESPONDENT in W.P.No.17954 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17944 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500.CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17957 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500.CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.17950 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER, INCOME TAX DEPARTMENT,BENGALURU - 560 500. ... RESPONDENT in W.P.No.20711 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER, INCOME TAX DEPARTMENT,BENGALURU - 560 500. ... RESPONDENT in W.P.No.20767 of 2019 1 THE DEPUTY COMMISSIONER OF INCOME TAX,CENTRALIZED PROCESSING CENTER (CPC),BENGALURU - 560 500. ... RESPONDENT in W.P.No.25806 of 2019 PRAYER:- These Writ Petitions are filed under Article 226 of theConstitution of India praying to issue a Writ of Certiorari, Calling for the records of the first respondent inPAN. No. AADAA8893M - Communication Reference No.CPC/1819/A5/1901971884 relating to the assessment year 2018-19, quash theproceedings dated 29.06.2019 issued under Section 143(1) of theIncome Tax Act. Calling for the records of the first respondent in PANNo.AABAS1338R Communication Reference No.CPC/1819/A5/1967888490for the assessment year 2018-19, quash the proceedings dated22.12.2019 issued under Section 143(1) of the Income Tax Act. W.P.NO.4901 OF 2020:- Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837031708115T, dated 29.06.2019 and quash the same. https://hcservices.ecourts.gov.in/hcservices/ Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837037093234T, dated 09/08/2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837054686234T, dated 22/10/2019 and quash the same. Calling for the records of the 1[st]respondent in PANNO.AABAG9929Q in Order No.CPC/1819/A5/1870649044 issued thereinfor the assessment year 2018-19 and quash the intimation underSection 143(1) of the Income Tax Act, dated 29.06.2019. Calling for the entire records relating to the impugnedorder passed by the respondent in demand identificationNo.2019201837027578971T, dated 31/05/2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027616585T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027551796T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027792741T, dated 31.05.2019 and quash the same. https://hcservices.ecourts.gov.in/hcservices/ Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027531660T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027627883T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027539916T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027792741T, dated 31.05.2019 and quash the same. https://hcservices.ecourts.gov.in/hcservices/ Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027531660T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027627883T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027539916T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the Impugnedorder passed by the respondent in Demand IdentificationNo.2019201837030860914T, dated 25.06.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837027638672T, dated 31.05.2019 and quash the same. Calling for the entire records relating to the impugnedorder passed by the respondent in Demand IdentificationNo.2019201837031707103T, dated 29.06.2019 and quash the same. For Petitioner : Mr.P.V.Sudakar in W.P.No.7038 & 7043 of 2020 Mr.C.Prakasam in W.P.Nos.17938, 17944, 17950, 17954, 17957, 17963, 20711, 20767, 25806 of 2019 and 7014 of 2020 No Appearance in W.P.Nos.4441,4901 & 4448 of 2020 Mr.R.L.Ramani, Senior Counsel for Mr.P.V.Sudakar in W.P.No.6455 of 2020 For Respondents : Mrs.Hema Muralikrishnan,Senior Standing Counselin all Wps. Mr.L.P.Shanmugasundaram,Special Government Pleader for R3in W.P.Nos.7038, 7043 & 6455 of 2020 These 16 writ petitions have been filed by Co-operativeSocieties, being either Primary Agricultural Co-operative CreditSocieties, Thrift Societies, Employees Societies or othercategories of Co-operative Societies, and challenge intimationsunder Section 143 (1) of the Income Tax Act, 1961 (in short‘Act’). The year of assessment in all cases is 2018-19. 2. The admitted facts are: (i) None of the Societies have filed returns of incomewithin the time stipulated under Section 139 of the Act andreturns have been filed belatedly on various dates, (ii) The Central Processing Centre (CPC), upon receipt ofthe returns filed, had issued communications proposing anadjustment in terms of Section 143(1)(a) of the Act. The reasonfor the proposed adjustment is ‘error/incorrect claim/inconsistency’ and the details are set out in Part A of thecommunication reading as follows: https://hcservices.ecourts.gov.in/hcservices/ (iii) None of the petitioner societies have either respondedto the notices or furnished any explanation in regard to theproposed alleged adjustment. (iv) In view of the utter silence on the part of thepetitioner, the proposals have come to culminate in theintimations impugned in these writ petitions. 3. The challenge to the intimations is on the ground thatthey do not confirm to the prescription of Section 143(1)(a) ofthe Act. Mr.Sudhakar and Mr.Prakasam, Mr.Karthikeyan not beingpresent before the Court, would argue that the provisions ofSection 143(1)(a) of the Act can only be invoked in cases wherethere are (i) patent arithmetical errors, (ii) an incorrectclaim, such incorrect claim being apparent from any information/entry contained in the return, (iii) disallowance of lossclaimed if the returns were filed beyond the due date, (iv)disallowance of expenditure indicated in the audit report butnot taken into account in computing total income (v)disallowance of deduction claimed under specified provisions ofthe Act if the return was filed beyond due date or(vi) additional income appearing in Form 26AS or 16A or 16, which has not been taken into account in computing total income.According to them, there is no error as aforesaid that emanatesfrom the returns of income filed by the petitioners and as such,the invocation of Section 143 (1)(a) of the Act is itself flawed. 4. Per contra, Mrs.Hema Muralikrishnan, learned SeniorStanding Counsel for the Revenue would argue that the errorarises from the fact that the returns of income have been filedbelatedly and beyond the dates stipulated under Section 139 ofthe Act. There is no doubt or dispute in this regard. Hence, theclaim under Section 80P could not have been putforth in thelight of provisions contained in Section 80AC(ii) as it stoodpost amendment with effect from 01.04.2018. 5. Learned counsel for the petitioners would than argue thatthe Explanation under Section 143(1)(a) of the Act explains ‘anincorrect claim' for the purpose of Clause (ii) of Section 143(1) (a) of the Act, as meaning a claim based on an entry in areturn of income. According to them, the date of return does notconstitute an 'entry' and hence no adjustment is called for onthis score. 6. Section 143 (1) (a) of the Act reads thus:- '143.(1) Where a return has been made undersection 139, or in response to a notice undersub-section (1) of section 142, such return shallbe processed in the following manner, namely:— (a) the total income or loss shall be computedafter making the following adjustments, namely:— (i) any arithmetical error in the return; (ii) an incorrect claim, if such incorrect claimis apparent from any information in the return; (iii) disallowance of loss claimed, if return ofthe previous year for which set off of loss isclaimed was furnished beyond the due datespecified under sub-section (1) of section 139; (iv) disallowance of expenditure indicated in theaudit report but not taken into account incomputing the total income in the return; (v) disallowance of deduction claimed undersections 10AA,80-IA,80-IAB,80-IB,80-IC,80-ID orsection 80-IE, if the return is furnished beyond the due date specified under sub-section (1) ofsection 139; or (vi) addition of income appearing in Form 26AS orForm 16A or Form 16 which has not been includedin computing the total income in the return: Provided that no such adjustments shall be madeunless an intimation is given to the assessee ofsuch adjustments either in writing or inelectronic mode: Provided further that the response received fromthe assessee, if any, shall be considered beforemaking any adjustment, and in a case where noresponse is received within thirty days of theissue of such intimation, such adjustments shallbe made:' 7. The scope of an 'intimation' under Section 143 (1) (a) ofthe Act, extends to the making of adjustments based upon errorsapparent from the return of income and patent from the record.Thus to say that the scope of 'incorrect claim' should becircumscribed and restricted by the Explanation which employsthe term 'entry' would, in my view, not be correct and theprovision must be given full and unfettered play. Theexplanation cannot curtail or restrict the main thrust or scopeof the provision and due weightage as well as meaning has to beattributed to the purposes of Section 143(1)(a) of the Act. 7. The scope of an 'intimation' under Section 143 (1) (a) ofthe Act, extends to the making of adjustments based upon errorsapparent from the return of income and patent from the record.Thus to say that the scope of 'incorrect claim' should becircumscribed and restricted by the Explanation which employsthe term 'entry' would, in my view, not be correct and theprovision must be given full and unfettered play. Theexplanation cannot curtail or restrict the main thrust or scopeof the provision and due weightage as well as meaning has to beattributed to the purposes of Section 143(1)(a) of the Act. 8. The provisions of Section 80AC(ii) make it clear thatany deduction that is claimed under Part C of Chapter VIA wouldbe admissible only if the return of income in that case werefiled within the prescribed due date. Thus no claim under anyof the provisions of Part C of Chapter VIA would be admissiblein the case of a belated return. There is no dispute on thisposition. The date of filing of a return of income would beapparent on the face of return and upon a perusal thereof, itwould be clear as to whether the return is a valid return,having been filed within the statutory time limit, or a belatedone. This is mechanical exercise and one that can be carriedout by the CPC, very much within the scope of Section 143 (1)(a) (ii) of the Act. 9. The conduct of the petitioners is also relevant. Not onlyhave the returns been filed belatedly but the petitioners havealso chosen not to co-operate in the conduct of assessment.They are admittedly in receipt of the defect notices from theCPC, but have not bothered to respond to the same. The writpetitions have themselves been filed belatedly and after the elapse of more than six to eight months from the dates ofimpugned orders, in all cases. It is only when the Revenue hasinitiated proceedings for recovery by attachment of bankaccounts have the petitioners approached this Court. This factoralso strengthens my resolve that these are not matterswarranting interference in terms of Article under Section 226 ofthe Constitution of India, quite apart from the decision that Ihave arrived at on the legal issue. 10. These writ petitions are dismissed and connectedMiscellaneous Petitions are also closed. 11. W.M.P.Nos.14346, 16166, 16167, 16171, 16225, 16226 of2020 and 2654 of 2021 have been filed by the Revenue seeking tovacate the stay originally granted by this Court. The MPs donot figure in the main list and I have hence directed that thesame be listed today by way of a special list. The MPs alsostand closed in light of my order as above. No costs. Sd/- Assistant Registrar(CCC) //True Copy// Sub Assistant Registrar rkp To 1.The Deputy Commissioner of Income Tax,CPC, Bangalore – 560 500. 2.The Income Tax Officer, Ward 2 (1), Erode. 3.The Income Tax Officer, Ward 2 (5), Erode. 4.The General Manager,Erode District Central Cooperative Bank Ltd.,No.1, Bhavani Main Road, Thirunagar Colony, Erode – 638 003. 5.The Branch Manager, Erode District Central Cooperative Bank Ltd., Gobichettipalayam, Erode. +1cc to Mrs.Hema Muralikrishnan, Advocate, S.R.No.22063+2ccs to Mr.B.Raveendran, Advocate, S.R.Nos.22262, 22264+1cc to the Special Government Pleader(Co-Op), S.R.Nos.22207 to 22209 Sd/- Assistant Registrar(CCC) //True Copy// Sub Assistant Registrar rkp To 1.The Deputy Commissioner of Income Tax,CPC, Bangalore – 560 500. 2.The Income Tax Officer, Ward 2 (1), Erode. 3.The Income Tax Officer, Ward 2 (5), Erode. 4.The General Manager,Erode District Central Cooperative Bank Ltd.,No.1, Bhavani Main Road, Thirunagar Colony, Erode – 638 003. 5.The Branch Manager, Erode District Central Cooperative Bank Ltd., Gobichettipalayam, Erode. +1cc to Mrs.Hema Muralikrishnan, Advocate, S.R.No.22063+2ccs to Mr.B.Raveendran, Advocate, S.R.Nos.22262, 22264+1cc to the Special Government Pleader(Co-Op), S.R.Nos.22207 to 22209 W.P.NOS.7038, 7043, 4901, 4441, 4448, 6455 &7014 OF 2020 AND 17938, 17963, 17954, 17944,17957, 17950, 20711, 20767 & 25806 OF 2019AND7014 OF 2020 AND 17938, 17963, 17954, 17944,17957, 17950, 20711, 20767 & 25806 OF 2019ANDW.M.P.NOS.8392, 8393, 8395, 8400, 8401, 8403, 7625,7622, 5799, 5801, 7623, 5257, 5259, 5266, 5267,8366, 8369, 14346, 16166, 16167, 16171, 16225 &16226 OF 2020, 17360, 17379, 17367, 17343,17346, 17352, 19868, 19869, 19934, 19937,25253, 25254 OF 2019 AND 2654 OF 20217622, 5799, 5801, 7623, 5257, 5259, 5266, 5267,8366, 8369, 14346, 16166, 16167, 16171, 16225 &16226 OF 2020, 17360, 17379, 17367, 17343,17346, 17352, 19868, 19869, 19934, 19937,25253, 25254 OF 2019 AND 2654 OF 2021 SKY(CO)PBS/05/10/2021