Wp(C)/21988/2022 Of Olam Food Ingrediants India Private Ltd v. The Assistant Commissioner Of Income Tax

IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17 DAY OF AUGUST 2022 / 26TH SRAVANA, 1944 WP(C) NO. 21627 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED(FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTD ANDOLAM EXPORTS INDIA LTD.)FLOOR NO. 5, BISHOP JEROME NAGARKOLLAM -, KERALA, INDIAREPRESENTED BY ITS DIRECTOR,AMIT KHAKHOLIA, PIN - 691001 BY ADV ALEXANDER JOSEPH MARKOS RESPONDENTS: 1THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, KOLLAM RANGE, KOLLAM, KERALA -, PIN - 6910012THE ADDITIONAL COMMISSIONER OF INCOME TAX,KOLLAM RANGE, KOLLAM,KERALA , PIN - 6910013PR. CHIEF COMMISSIONER OF INCOME TAXA.R.BUILDING. I.A.PREGS ROAD,COCH]N - KERALA, PIN - 682018BY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON17.08.2022, ALONG WITH WP(C).21952/2022, 21979/2022 AND CONNECTEDCASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17 DAY OF AUGUST 2022 / 26TH SRAVANA, 1944WP(C) NO. 21952 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED,(FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTDAND OLAM EXPORTS INDIA LTD.)FLOOR NO. 5, BISHOP JEROME NAGAR,KOLLAM -, KERALA, INDIAREPRESENTED BY ITS DIRECTOR,AMIT KHAKHOLIA., PIN - 691001 BY ADV ALEXANDER JOSEPH MARKOS RESPONDENTS: 1THE ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-1, KOLLAM RANGE,KOLLAM, KERALA-, PIN - 6910012PR. CHIEF COMMISSIONER OF INCOME TAXC.R, BUILDING, I.S PRESS ROAD,COCHIN -, PIN - 682018BY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON17.08.2022, ALONG WITH WP(C).21627/2022 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17 DAY OF AUGUST 2022 / 26TH SRAVANA, 1944WP(C) NO. 21979 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED,(FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTD.AND OLAM EXPORTS INDIA LTD.)FLOOR NO. 5, BISHOP JEROME NAGAR,KOLLAM -, KERALA, INDIAREPRESENTED BY ITS DIRECTOR,AMIT KHAKHOLIA., PIN - 691001BY ADVS.ALEXANDER JOSEPH MARKOSABRAHAM JOSEPH MARKOSISAAC THOMASSHARAD JOSEPH KODANTHARA RESPONDENTS: 1THE ASSISTANT COMMISSIONER OF INCOME TAXCIRCLE-1, KOLLAM RANGE,KOLLAM, KERALA, PIN - 6910012THE ADDITIONAL COMMISSIONER OF INCOME TAX,KOLLAM RANGE, KOLLAM,KERALA -, PIN - 6910013PRL. CHIEF COMMISSIONER OF INCOME TAXC.R.BUILDING. I.S. PRESS ROAD,COCHIN ,KERALA, PIN - 682018BY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON17.08.2022, ALONG WITH WP(C).21627/2022 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17 DAY OF AUGUST 2022 / 26TH SRAVANA, 1944WP(C) NO. 21988 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED,(FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTDAND OLAM EXPORTS INDIA LTD.)FLOOR NO. 5, BISHOP JEROME NAGAR,KOLLAM ,KERALA, INDIAREPRESENTED BY ITS DIRECTOR,AMIT KHAKHOLIA, PIN - 691001 BY ADV ALEXANDER JOSEPH MARKOS RESPONDENTS: 1THE ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-1, KOLLAM RANGE,KOLLAM, KERALA -, PIN - 6910012THE ADDITIONAL COMMISSIONER OF INCOME TAX,KOLLAM RANGE,KOLLAM, KERALA -., PIN - 6910013PR. CHIEF COMMISSIONER OF INCOME TAXC.R BUILDING, I.S PRESS ROAD, COCHIN - 682 018, KERALABY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON17.08.2022, ALONG WITH WP(C).21627/2022 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: J U D G M E N T PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED,(FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTDAND OLAM EXPORTS INDIA LTD.)FLOOR NO. 5, BISHOP JEROME NAGAR,KOLLAM ,KERALA, INDIAREPRESENTED BY ITS DIRECTOR,AMIT KHAKHOLIA, PIN - 691001 BY ADV ALEXANDER JOSEPH MARKOS RESPONDENTS: 1THE ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-1, KOLLAM RANGE,KOLLAM, KERALA -, PIN - 6910012THE ADDITIONAL COMMISSIONER OF INCOME TAX,KOLLAM RANGE,KOLLAM, KERALA -., PIN - 6910013PR. CHIEF COMMISSIONER OF INCOME TAXC.R BUILDING, I.S PRESS ROAD, COCHIN - 682 018, KERALABY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON17.08.2022, ALONG WITH WP(C).21627/2022 AND CONNECTED CASES, THECOURT ON THE SAME DAY DELIVERED THE FOLLOWING: J U D G M E N T The petitioner is common in all these 4 writ petitions. It has approached thiscourt being aggrieved by the fact that the Assistant Commissioner of Income Tax,Circle-I, Kollam Range, Kollam, has not given effect to the orders of AppellateTribunal in respect of assessment orders for the assessment years 2000-2001,2001-2002, 2002-2003 and 2008-2009, though the orders of the Tribunal wereissued on 25-05-2012 in respect of assessment years 2000-2001, 2001-2002 &2002-2003 and on 22-11-2013 in respect of assessment year 2008-2009. Theorders of the Appellate Tribunal under Section 254 of the Income Tax Act wereaffirmed by a Division Bench of this court by judgment dated 28-05-2015 in respectof assessment years 2000-2001, 2001-2002 & 2002-2003 and by judgment dated06-10-2017 in respect of assessment year 2008-2009. 2.The learned counsel appearing for the respondent/Department statesthat the orders of the Tribunal could not be given effect to only on account of thefact that there is complete non-cooperation on behalf of the petitioner/assessee.The learned counsel for the petitioner in these cases would submit that since theassessment years in question relate to 2000-2001, 2001-2002, 2002-2003 & 2008-2009, the petitioner will provide whatever details that are now available, to enableto completion of the assessment in the manner directed by the Tribunal. It issubmitted that the petitioner also has a case that such assessments are now barredgoing by the provisions contained in Section 153 of the Income Tax Act. 3.Having regard to the submissions made by the learned counsel in thesecases and the learned Standing Counsel appearing for the Department, I am of theopinion that these writ petitions can be disposed of in the following manner; W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -6- (i)The Assistant Commissioner of Income Tax, Circle-I, Kollam Range shall,within one month from the date of receipt of a certified copy of thisjudgment, indicate to the petitioner the documents required for givingeffect to the orders of the Tribunal. The petitioner shall endeavour toprovide the details requested for within a period of one month from thedate on which the request is made by the Assistant Commissioner ofIncome Tax in the manner indicated above.within one month from the date of receipt of a certified copy of thisjudgment, indicate to the petitioner the documents required for givingeffect to the orders of the Tribunal. The petitioner shall endeavour toprovide the details requested for within a period of one month from thedate on which the request is made by the Assistant Commissioner ofIncome Tax in the manner indicated above. (ii)On receipt of the information (to the extent it is available), the AssistantCommissioner of Income Tax, Circle-I, Kollam Range shall complete theassessment for all the assessment years in question, after affording anopportunity of hearing to a representative of the petitioner in these caseswith a period of 3 months thereafter.Commissioner of Income Tax, Circle-I, Kollam Range shall complete theassessment for all the assessment years in question, after affording anopportunity of hearing to a representative of the petitioner in these caseswith a period of 3 months thereafter. (ii)On receipt of the information (to the extent it is available), the AssistantCommissioner of Income Tax, Circle-I, Kollam Range shall complete theassessment for all the assessment years in question, after affording anopportunity of hearing to a representative of the petitioner in these caseswith a period of 3 months thereafter.Commissioner of Income Tax, Circle-I, Kollam Range shall complete theassessment for all the assessment years in question, after affording anopportunity of hearing to a representative of the petitioner in these caseswith a period of 3 months thereafter. (iii) The Assistant Commissioner of Income Tax, Circle-I, Kollam Range shallalso consider the contention of the petitioner that the assessments arebarred by limitation in terms of the provisions contained in Section 153 ofthe Income Tax Act.also consider the contention of the petitioner that the assessments arebarred by limitation in terms of the provisions contained in Section 153 ofthe Income Tax Act. The writ petitions are disposed of as above. All contentions of thepetitioners are left open. AMG Sd/-GOPINATH P. JUDGE APPENDIX OF WP(C) 21952/2022 PETITIONER EXHIBITS Exhibit P1TRUE COPY OF THE ORDER DATED 22.11.2013 PASSED BY THEINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN I.T.(TP) A. NO.03/COCHI/2013 FOR AY 2008-09.INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN I.T.(TP) A. NO.03/COCHI/2013 FOR AY 2008-09. Exhibit P2TRUE COPY OF THE ORDER DATED 06.10.2017 PASSED BY THIS HONOURABLE COURT IN ITA NO.52/2015THIS HONOURABLE COURT IN ITA NO.52/2015 Exhibit P3RETURN OF INCOME FILED BY THE PETITIONER ON 30.09.2008 FOR ASSESSMENT YEAR 2008/200930.09.2008 FOR ASSESSMENT YEAR 2008/2009 Exhibit P4TRUE COPY OF THE AUDITED FINANCIALS FOR THE YEAR ENDED 31ST MARCH 2008ENDED 31ST MARCH 2008 Exhibit P5TRUE COPY OF THE TAX AUDITED REPORT FOR THE YEAR ENDED 31ST MARCH 2008ENDED 31ST MARCH 2008 Exhibit P6TRUE COPY OF THE ORDER DATED 28.10.2011 PASSED BY THETRANSFER PRICING OFFICER, KOCHI (TPO) UNDER SECTION 92CA(3) OF THE INCOME TAX ACT , 1961TRANSFER PRICING OFFICER, KOCHI (TPO) UNDER SECTION 92CA(3) OF THE INCOME TAX ACT , 1961 Exhibit P7TRUE COPY OF THE DRAFT ASSESSMENT ORDER DATED 29.12.2011 PASSED BY THE ADDITIONAL COMMISSIONER OF INCOMETAX, KOLLAM RANGE,KOLLAM UNDER SECTION 144C/92CA OF THE INCOME TAX ACT ,196129.12.2011 PASSED BY THE ADDITIONAL COMMISSIONER OF INCOMETAX, KOLLAM RANGE,KOLLAM UNDER SECTION 144C/92CA OF THE INCOME TAX ACT ,1961 Exhibit P8TRUE COPY OF THE DIRECTIONS DATED 28.08.2012 ISSUED BY THE DISPUTE RESOLUTION PANEL (DRP), BANGALORE UNDER SECTION 144C(5)/144C(8) OF THE INCOME TAX ACT,1961.BY THE DISPUTE RESOLUTION PANEL (DRP), BANGALORE UNDER SECTION 144C(5)/144C(8) OF THE INCOME TAX ACT,1961. Exhibit P9TRUE COPY OF THE ORDER DATED 27.12.2012 PASSED BY THEJOINT COMMISSIONER OF INCOME TAX, KOLLAM UNDER SECTION 143(3)/144C(13) OF THE INCOME TAX ACT,1961.JOINT COMMISSIONER OF INCOME TAX, KOLLAM UNDER SECTION 143(3)/144C(13) OF THE INCOME TAX ACT,1961. Exhibit P10TRUE COPY OF THE RECEIPT OF PAYMENT OF TAX VIDE CHALLAN DATED 10.08.2013 BEARIN SERIAL NO.10672.CHALLAN DATED 10.08.2013 BEARIN SERIAL NO.10672. Exhibit P11TRUE COPY OF THE REQUEST LETTER DATED 09.01.2020 ADDRESSED BY THE PETITIONER TO THE LST RESP PONDENT.ADDRESSED BY THE PETITIONER TO THE LST RESP PONDENT.Exhibit P12TRUE COPY OF THE NOTICE OF DEMAND DATED 13.01.2020 ISSUED BY THE 1ST RESPONDENT. ISSUED BY THE 1ST RESPONDENT. W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -8- Exhibit P13TRUE COPY OF THE REQUEST LETTER DATED 23.01.2020 ADDRESSED BY THE PETITIONER TO THE LST RESPONDENT Exhibit P14TRUE COPY OF THE GRIEVANCE DATED 25.08.2020 FILED BY THE PETITIONER ON THE E-FILING PORTAL E-NIVARAN Exhibit P15TRUE COPY OF THE GRIEVANCE DATED 22.02.2021 FILED BY THE PETITIONER ON THE E-FILING PORTAL E-NIVARAN. Exhibit P16TRUE COPY OF THE REPRESENTATION DATED 20.10.2021 ADDRESSED BY THE PETITIONER BEFORE THE LST RESPONDENT Exhibit P11TRUE COPY OF THE REQUEST LETTER DATED 09.01.2020 ADDRESSED BY THE PETITIONER TO THE LST RESP PONDENT.ADDRESSED BY THE PETITIONER TO THE LST RESP PONDENT.Exhibit P12TRUE COPY OF THE NOTICE OF DEMAND DATED 13.01.2020 ISSUED BY THE 1ST RESPONDENT. ISSUED BY THE 1ST RESPONDENT. W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -8- Exhibit P13TRUE COPY OF THE REQUEST LETTER DATED 23.01.2020 ADDRESSED BY THE PETITIONER TO THE LST RESPONDENT Exhibit P14TRUE COPY OF THE GRIEVANCE DATED 25.08.2020 FILED BY THE PETITIONER ON THE E-FILING PORTAL E-NIVARAN Exhibit P15TRUE COPY OF THE GRIEVANCE DATED 22.02.2021 FILED BY THE PETITIONER ON THE E-FILING PORTAL E-NIVARAN. Exhibit P16TRUE COPY OF THE REPRESENTATION DATED 20.10.2021 ADDRESSED BY THE PETITIONER BEFORE THE LST RESPONDENT Exhibit P17TRUE COPY OF THE REPRESENTATION DATED 04.05.2022 ADDRESSED BY THE PETITIONER BEFORE THE LST RESPONDENTExhibit P18TRUE COPY OF THE REPRESENTATION DATED 24.05.2022 ADDRESSED BY THE PETITIONER BEFORE THE LET RESPONDENT. APPENDIX OF WP(C) 21979/2022 PETITIONER EXHIBITS Exhibit P1TRUE COPY OF THE ORDER DATED 25.05.2012 PASSED BY THEINCOME TAX APPELLATE TRIBUNAL IN I.T.A. NOS. 513/COCHI/2009 AND 514/COCHI/2009. INCOME TAX APPELLATE TRIBUNAL IN I.T.A. NOS. 513/COCHI/2009 AND 514/COCHI/2009. Exhibit P2TRUE COPY OF THE JUDGMENT DATED 28.05.2015 PASSED BY THIS HON'BLE COURT IN I.T.A. NOS.19, 45 AND 129 OF 2013.THIS HON'BLE COURT IN I.T.A. NOS.19, 45 AND 129 OF 2013. Exhibit P3TRUE COPY OF THE ACKNOWLEDGEMENT OF THE REVISED RETURN OF INCOME FILED BY THE PETITIONER FOR ASSESSMENT YEAR 2000-01.RETURN OF INCOME FILED BY THE PETITIONER FOR ASSESSMENT YEAR 2000-01. Exhibit P4TRUE COPY OF THE ASSESSMENT ORDER DATED 30.03.2004 PASSED BY THE 2ND RESPONDENT UNDER SECTION 143(3)/147OF THE INCOME TAX ACT.PASSED BY THE 2ND RESPONDENT UNDER SECTION 143(3)/147OF THE INCOME TAX ACT. Exhibit P5TRUE COPY OF THE ASSESSMENT ORDER DATED 30.09.2004 PASSED BY THE 2ND RESPONDENT UNDER SECTION 143(3)/147OF THE INCOME TAX ACT.PASSED BY THE 2ND RESPONDENT UNDER SECTION 143(3)/147OF THE INCOME TAX ACT. Exhibit P6TRUE COPY OF THE ORDER DATED 18.02.2005 PASSED BY THELST RESPONDENT.LST RESPONDENT. Exhibit P7TRUE COPY OF THE ORDER DATED 22.01.2008 PASSED BY THEINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH.INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH. Exhibit P8TRUE COPY OF THE ORDER DATED 12.11.2007 PASSED BY THELST RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOMETAX ACT.LST RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOMETAX ACT. Exhibit P9TRUE COPY OF THE NOTICE DATED 07.01.2008 ISSUED BY THE LST RESPONDENT UNDER SECTION 154/155 OF THE INCOME TAX ACT, 1961.THE LST RESPONDENT UNDER SECTION 154/155 OF THE INCOME TAX ACT, 1961. Exhibit P10TRUE COPY OF THE RECTIFICATION ORDER DATED 06.05.2008PASSED BY THE LST RESPONDENT.PASSED BY THE LST RESPONDENT. Exhibit P11TRUE COPY OF THE ORDER DATED 2 04.02.2009 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS)-LL, KOCHI.THE COMMISSIONER OF INCOME TAX (APPEALS)-LL, KOCHI.Exhibit P12TRUE COPY OF THE ORDER DATED 16.03.2009 PASSED BY THECOMMISSIONER OF INCOME TAX (APPEALS) -11, KOCHI.COMMISSIONER OF INCOME TAX (APPEALS) -11, KOCHI. Exhibit P13TRUE COPY OF THE ORDER DATED 30.06.2009 PASSED BY THEDEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, KOLLAM Exhibit P14TRUE COPY OF THE ORDER DATED 25.11.2011 PASSED BY THEINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN. Exhibit P15TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 SENTBY THE PETITIONER TO THE 1 ST RESPONDENT. Exhibit P16TRUE COPY OF THE REPRESENTATION DATED 05.05.2022 SENTBY THE PETITIONER TO THE 1ST RESPONDENT. DATED W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -11- PETITIONER EXHIBITS APPENDIX OF WP(C) 21988/2022 Exhibit P1TRUE COPY OF THE ORDER DATED 25.05.2012 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN LT.A. NO.516/COCHI/2009.INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN LT.A. NO.516/COCHI/2009. Exhibit P13TRUE COPY OF THE ORDER DATED 30.06.2009 PASSED BY THEDEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, KOLLAM Exhibit P14TRUE COPY OF THE ORDER DATED 25.11.2011 PASSED BY THEINCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN. Exhibit P15TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 SENTBY THE PETITIONER TO THE 1 ST RESPONDENT. Exhibit P16TRUE COPY OF THE REPRESENTATION DATED 05.05.2022 SENTBY THE PETITIONER TO THE 1ST RESPONDENT. DATED W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -11- PETITIONER EXHIBITS APPENDIX OF WP(C) 21988/2022 Exhibit P1TRUE COPY OF THE ORDER DATED 25.05.2012 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN LT.A. NO.516/COCHI/2009.INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN LT.A. NO.516/COCHI/2009. Exhibit P2TRUE COPY OF THE JUDGMENT DATED 28.05.2015 PASSED BY THIS HONOURABLE COURT IN ITA NOS.19, 45 AND 129 OF 2013HONOURABLE COURT IN ITA NOS.19, 45 AND 129 OF 2013Exhibit P3TRUE COPY OF THE ACKNOWLEDGEMENT OF THE RETURN OF INCOME FILED BY THE PETITIONER FOR ASSESSMENT YEAR 2002-03.FILED BY THE PETITIONER FOR ASSESSMENT YEAR 2002-03.Exhibit P4TRUE COPY OF THE ASSESSMENT ORDER DATED 28.03.2005 PASSED BY THE LS` RESPONDENT UNDER SECTION 143(3) OF THE INCOMETAXACT 1961.BY THE LS` RESPONDENT UNDER SECTION 143(3) OF THE INCOMETAXACT 1961.Exhibit P5TRUE COPY OF THE APPELLATE ORDER 47 - 5253-55 DATED 30.03.2006 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS )-III ,TRIVANDRUM30.03.2006 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS )-III ,TRIVANDRUMExhibit P6TRUE COPY OF THE ORDER DATED 16.08.2007 PASSED BY THE INCOME TAX PASSED BY THE INCOME TAX . APPELLATE TRIBUNAL , COCHIN BENCH , COCHIN INCOME TAX PASSED BY THE INCOME TAX . APPELLATE TRIBUNAL , COCHIN BENCH , COCHIN Exhibit P7TRUE COPY OF THE ORDER DATED 12.11.2007 PASSED BY THE LS` RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOME TAX ACT 1961RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOME TAX ACT 1961Exhibit P8TRUE COPY OF THE ORDER DATED 16.03.2009 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS) -11 KOCHI.COMMISSIONER OF INCOME TAX (APPEALS) -11 KOCHI.Exhibit P9TRUE COPY OF THE ORDER DATED 03.11.2009 PASSED B THE 2ND RESPONDENT.RESPONDENT.Exhibit P10TRUE COPY OF THE REPRESENTATION DATED 12.05.2015 ISSUED BY THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE L ST RESPONDENT.THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE L ST RESPONDENT.Exhibit P11TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 ISSUED BY THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE 1 ST RESPONDENTTHE PETITIONER'S CHARTERED ACCOUNTANTS TO THE 1 ST RESPONDENTExhibit P12TRUE COPY OF THE REPRESENTATION DATED 31.07.2018 ISSUED BY THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE 1 ST RESPONDENT.THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE 1 ST RESPONDENT.Exhibit P13TRUE COPY OF THE REPRESENTATION DATED 05.05.2022 ISSUED BY THE PETITIONER TO THE 1 ST RESPONDENT.THE PETITIONER TO THE 1 ST RESPONDENT. W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -12- PETITIONER EXHIBITS APPENDIX OF WP(C) 21627/2022 W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -13- Exhibit P15TRUE COPY OF THE ORDER DATED 28.12.2013 PASSED BY THE LST RESPONDENT.RESPONDENT. Exhibit P16TRUE COPY OF THE ORDER DATED 25.11.2011 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN.INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN. Exhibit P17TRUE COPY OF THE REPRESENTATION DATED 12.05.2015 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P18TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT.THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P19TRUE COPY OF THE REPRESENTATION DATED 31.07.2018 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P16TRUE COPY OF THE ORDER DATED 25.11.2011 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN.INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN. Exhibit P17TRUE COPY OF THE REPRESENTATION DATED 12.05.2015 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P18TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT.THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P19TRUE COPY OF THE REPRESENTATION DATED 31.07.2018 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P20TRUE COPY OF THE REPRESENTATION DATED 05.05.2022 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE 1 ST RESPONDENT. THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE 1 ST RESPONDENT.