Kerala High Court
Rajan Koyoth Veettil Sidharth vs State Of Kerala on 17 March, 2025
Author: V.G.Arun
Bench: V.G.Arun
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 1003 OF 2023
CRIME NO.RC 0342023E0002/2023 OF CBCID, THIRUVANANTHAPURAM,
Thiruvananthapuram
PETITIONERS:
1 RAJAN KOYOTH VEETTIL SIDHARTH,
AGED 32 YEARS
S/O. K.V. RAJAN,LIEUTENANT COMMANDER, NAVAL PAY
OFFICE, MUMBAI,INDIAN NAVAL ACADAMY, EZHIMALA,
KANNUR, PIN - 670310
2 NISHANT SINGH POSWAL,
AGED 32 YEARS
S/O. LATE KANWAR PAL VERMA,LIEUTENANT
COMMANDER,NAVAL PAY OFFICE, MUMBAI,INDIAN NAVAL
ACADAMY, EZHIMALA, KANNUR, PIN - 670310
3 SUMIT SINGH,
AGED 31 YEARS
S/O. NAIB SINGH,LIEUTENANT COMMANDER,NAVAL PAY
OFFICE, MUMBAI,INDIAN NAVAL ACADAMY, EZHIMALA,
KANNUR, PIN - 670310
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4 ROSHAN KUMAR SINGH,
AGED 32 YEARS
S/O. BINOD KUMAR SINGH,LIEUTENANT COMMANDER,NAVAL
PAY OFFICE, MUMBAI,INDIAN NAVAL ACADAMY,
EZHIMALA, KANNUR, PIN - 670310
5 . RAJKUMAR SHARMA,
AGED 31 YEARS
S/O. PARSHOTAM DAS,LIEUTENANT COMMANDER,NAVAL PAY
OFFICE, MUMBAI,INDIAN NAVAL ACADAMY, EZHIMALA,
KANNUR, PIN - 670310
6 PAWAN SINGH RATHORE,
AGED 30 YEARS
S/O. DARWAN SINGH RATHOUR,LIEUTENANT
COMMANDER,NAVAL PAY OFFICE, MUMBAI,INDIAN NAVAL
ACADAMY, EZHIMALA, KANNUR, PIN - 670310
7 MADATHIL VALAPPIL RAHUL RAMAN,
AGED 32 YEARS
SON OF M.V. KUNHI RAMAN,LIEUTENANT
COMMANDER,NAVAL PAY OFFICE, MUMBAI,INDIAN NAVAL
ACADAMY, EZHIMALA, KANNUR, PIN - 670310
BY ADVS.
K.P.SANTHI
M.C.BINDUMOL
TARA PREM
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RESPONDENTS:
1 STATE OF KERALA,
REPRESENTED BY THE PUBLIC PROSECUTOR, HIGH COURT
OF KERALA, ERNAKULAM., PIN - 682031
2 JOINT COMMISSIONER OF INCOME TAX (HQ),(TECH
OFFICE OF PRINCIPAL CHIEF COMMISSIONER OF INCOME
TAX,KERALA, 2ND FLOOR, C.R. BUILDING, I.S.PRESS
ROAD, KOCHI, PIN - 682018
3 CENTRAL BUREU OF INVESTIGATION,
SPECIAL CRIME BRANCH, THIRUVANANTHAPURAM, PIN -
695024
BY ADV SREELAL N.WARRIER, SPL.PUBLIC PROSECUTOR,
CENTRAL BUREAU OF INVESTIGATION (CBI)
OTHER PRESENT:
SRI. M.C. ASHI, PP. SRI. SREELAL. N. WARRIER SPL.
PP FOR CBI.
SRI. JOSE JOSEPH SC, FOR INCOME TAX DEPARTMENT.
THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON
13.03.2025, ALONG WITH Crl.MC.67/2025, 2003/2023 AND
CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE
FOLLOWING:
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 67 OF 2025
CRIME NO.RC 0342023E0002/2023 OF CENTRAL BUREAU OF
INVESTIGATION, THIRUVANANTHAPURAM, Thiruvananthapuram
AGAINST THE ORDER/JUDGMENT DATED IN CC NO.123 OF 2024
OF CHIEF JUDICIAL MAGISTRATE, ERNAKULAM
PETITIONERS:
1 CHANDRAN GANAPATHIYADAN,
AGED 59 YEARS
S/O. KUNJIRAMAN, KALATHIL HOUSE, KARA PERAVOOR
P.O., KEEZHALLUR,THALASSERY, KANNUR, PIN - 670702
2 VINOD KUMAR K.,
AGED 48 YEARS
S/O. BAMBU B, KIZHAKKEKKARA HOUSE, BERIAM,
KARADKA, KASARAGOD, PIN - 671542
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BY ADVS.
SHABU SREEDHARAN
JAYACHANDRAN NAIR G.
ARCHANA U.
REENU S. BABU
RATHEESH.V.R.
LEKSHMI J.
BIJU JACOB B.O.
KARISHMA JOHN
RESPONDENTS:
1 UNION OF INDIA,
REPRESENTED BY THE ASST. SOLICITOR GENERAL,
OFFICE OF THE ASST. SOLICITOR GENERAL, HIGH COURT
OF KERALA, ERNAKULAM, PIN - 682031
2 CENTRAL BUREAU OF INVESTIGATION,
REPRESENTED BY ITS DEPUTY SUPERINTENDENT OF
POLICE, CBI, SCB, TC 1757/5, "CBI OCR COMPLEX",
MUTTATHARA, VALLAKADAVU P.O., THIRUVANANTHAPURAM,
PIN - 695008
THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON
13.03.2025, ALONG WITH Crl.MC.1003/2023 AND CONNECTED
CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 2003 OF 2023
CRIME NO.RC 0342023E0002/2023 OF CENTRAL BUREAU OF
INVESTIGATION, THIRUVANANTHAPURAM, Thiruvananthapuram
PETITIONER:
AKSHAY KISHOR SALI
AGED 32 YEARS
S/O K.V.RAJAN, LIEUTENANT COMMANDER, NAVAL PAY
OFFICE, MUMBAI, INDIAN NAVAL ACADAMY,
EZHIMALA,KANNUR, PIN - 670310
BY ADVS.
K.P.SANTHI
TARA PREM
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RESPONDENTS:
1 STATE OF KERALA
REPRESENTED BY THE PUBLIC PROCECUTOR, HIGH COURT
OF KERALA, ERNAKULAM, PIN - 682031
2 JOINT COMMISSIONER OF INCOME TAX(HQ)
(TECH), OFFICE OF PRINCIPAL CHIEF COMMISSIONER OF
INCOME TAX, KERALA, 2ND FLOOR, C.R.BUILDING,
I.S.PRESS ROAD, KOCHI, PIN - 682018
3 CENTRAL BUREAU OF INVESTIGATION
SPECIAL CRIME BRANCH, THIRUVANANTHAPURAM,
REPRESENTED BY THE SUPRENTENDENT OF POLICE, PIN -
695024
BY ADV Sreelal Warriar
THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON
13.03.2025, ALONG WITH Crl.MC.1003/2023 AND CONNECTED
CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 10877 OF 2024
CRIME NO.36/2007 OF CRIME BRANCH, MALAPPURAM, Malappuram
AGAINST THE ORDER/JUDGMENT DATED IN CC NO.194 OF 2024
OF CHIEF JUDICIAL MAGISTRATE ,MANJERI
PETITIONERS:
1 GOLDEN FOREX PVT.LTD @ GOLDEN FOREX CENTER LTD@
GOLDENFOREX AND FINANCE SERVICES,
ZEENATH PLAZA, EZHUR ROAD, THIRUR, MALAPPURAM
(REPRESENTED BY NASIM P.K, MANAGING DIRECTOR ),
PIN - 676101
2 NASIM P.K,
AGED 48 YEARS
S/O. HAMZA HAJI,PANNIKANDATHIL HOUSE, ANNARA,
THIRUR, MALAPPURAM, PIN - 676101
3 ZEENATH,
AGED 68 YEARS
W/O. HAMZA HAJI, PANNIKANDATHIL HOUSE, ANNARA,
THIRUR, MALAPPURAM, PIN - 676101
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BY ADVS.
R.ANIL
B.RAMAN PILLAI (SR.)
SUJESH MENON V.B.
THOMAS SABU VADAKEKUT
MAHESH BHANU S.
RESSIL LONAN
JOEL GEORGE KAMPIYIL
ANANTH KRISHNA K.S.
RESPONDENT:
1 STATE OF KERALA,
REPRESENTED BY PUBLIC PROSECUTOR,HIGH COURT OF
KERALA, PIN - 682031
2 MOIDEEN ( SOUGHT TO BE IMPLEADED )
S/O. BEERAN, EZHOOR, THIROOR, ( SOUGHT TO BE
IMPLEADED )
THIS CRIMINAL MISC. CASE HAVINGHAVING BEEN FINALLY
HEARD ON 13.03.2025, ALONG WITH Crl.MC.1003/2023 AND
CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE
FOLLOWING:
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V.G.ARUN, J
= = = = = = = = = = = = = = = = =
Crl.M.C.Nos.1003 & 2003 of 2023,
10887 of 2024 & 67 of 2025
= = = = = = = = = = = = = = = = = =
Dated this the 17th day of March, 2025
ORDER
Petitioners are some of the accused in Crime
No.RC0342023E0002 registered by the CBI/SCB/
Thiruvananthapuram for offences punishable under Sections
120B read with 420 of IPC and Section 276C of the Income Tax
Act. The crime was registered on the basis of a letter received
from the Principal Chief Commissioner of Income Tax, Kochi
alleging that many salaried assessees in Ward-3 Kannur had
received huge refund of income tax, by claiming bogus
deductions under Sections 80DDB, 80E, 80EE, 80GG, 80GGC
etc.
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2. These Crl.M.Cs are filed seeking to get the FIR and
further proceedings against the petitioners quashed on various
grounds.
3. Heard, Advs.K.P.Santhi and Shabu Sreedharan for the
petitioners, Adv.Jose Joseph for the Income Tax Department and
Adv.Sreelal N Warrier for the Central Bureau of Investigation.
4. Learned counsel for the petitioners contended that in
the communication issued by the Principal Chief Commissioner
of Income Tax, which led to registration of the crimes, the
allegations were raised against agents who had indulged in
malpractices while submitting returns on behalf of the
assessees. Assessees like the petitioners are completely
dependent on the agents for filing income tax returns. The
prosecution does not have a case that the bogus claims were
raised at the instance of the petitioners. According to the
counsel, the Income Tax Department had treated the claim for
refund as a mistake and notices were issued under Sections
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148, 154, 155 etc. of the Income Tax Act. On receipt of the
notices, mistakes were rectified and the ineligible refund,
remitted back. This shows that the petitioners had no intention
to cheat. Moreover, the petitioners cannot be prosecuted for
the offence under Section 276C of the Income Tax Act without
previous administrative approval of the Collegium of two
CCIT/DGIT rank officers, as evident from Annexure XIX circular
produced in Crl.M.C.No.1003 of 2023.
5. Learned Standing Counsel for the Income Tax
Department made the following submissions;
From 2014-2015 onwards, many of the assessees in Ward
3, Kannur had raised bogus claims for refund by under-
reporting their salary and making ineligible deductions. Filing
of return of income is the responsibility of individual tax payers
even if it is prepared with the help of an agent. Electronic
verification of the return of income has to be done by the tax
payer himself, either through Aadhar OTP or net banking. The
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returns are processed by the Central Processing Centre without
any manual intervention. Therefore, the escaped assessment
was noticed only during subsequent verification. Immediately,
notices were sent to the petitioners and other assessees. The
reply received from the petitioners being unsatisfactory, penalty
was imposed on them. Refund of the excess amount claimed
and payment of penalty will not absolve the petitioners from
criminal liability, as they had committed cheating by filing false
returns with intention to deceive the department. The
contention based on Annexure XIX circular cannot also be
countenanced, since the Department has not initiated
prosecution under Section 276C. Instead, the CBI is conducting
investigation based on the information given from the
Department.
6. Learned Standing Counsel for the CBI submitted that,
crime was registered against 31 persons, including the
petitioners, based on a complaint received from the Income Tax
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Department. During investigation, sufficient incriminating
evidence to prove the commission of the offence of cheating was
obtained. Hence, charge sheet was filed against the petitioners
and others for the offence of cheating under Section 420 of the
Indian Penal Code. The intention to commit the offence will
continue to exist even if the loss caused to the Government is
compensated by repaying the ineligible refund received.
Investigation had revealed that some of the accused had
claimed exemption towards housing loan interest, whilst others
had claimed unmerited deductions under Sections 80DDB, 80E,
80EE, 80GG,80GGC etc. of the Income Tax Act. On receipt of
complaint from the Income Tax Department, the documents
were verified meticulously and information was gathered from
officers at various levels and opportunity was given to the
petitioners to prove their innocence. The petitioners were not
able to produce any document to substantiate their claim for
refund.
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7. The contention that false claims were raised by the
agents and not the petitioners is liable to be rejected outright as
the responsibility of filing proper returns is that of the assessee
and not the agent. The petitioners themselves are the
beneficiaries of such false claims and the agents are paid only a
small percentage of the refunded amount. The argument that
prosecution under Section 276C can be initiated only with the
permission of the Collegium has no relevance, since the crime
against the petitioners was investigated by the CBI. Pertinently,
in the charge sheet filed by the CBI, only the offence
punishable under Section 420 of IPC read with 120-B IPC, is
incorporated. The submission that the Income Tax Department
had treated the claim for refund as a mistake and issued notices
to the petitioners, and the petitioners repaid the amount with
penalty, is of no avail, as submission of false returns and
acceptance of ineligible refunds are the crucial factors. Going
by the scheme of the Income Tax Act, proceedings for
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realisation of escaped assessment, imposition of penalty and
prosecution for filing false returns are entirely different aspects
and realisation of escaped assessment or imposition of penalty
will not absolve a person from prosecution. For the reasons
aforementioned, the prayer for quashing the proceedings is
liable to be rejected. Needless to say, it will still be open for the
petitioners to move the trial court for discharge.
The Crl.M.Cs are hence dismissed leaving it for the trial
court to pass appropriate orders if applications for discharge
are filed by the petitioners.
sd/-
V.G.ARUN, JUDGE
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PETITIONER ANNEXURES
Annexure-1 THE TRUE COPY OF THE LETTER FORWARDED
BY THE PRINCIPAL COMMISSIONER OF INCOME
TAX, KOZHIKODE TO THE PRINCIPAL CHIEF
COMMISSIONER OF INCOME TAX, KOCHI DATED
4.2.2020
Annexure-2 THE TRUE COPY OF THE LETTER FORWARDED
BY THE JOINT COMMISSIONER OF INCOME
TAX, OFFICE OF THE PRINCIPAL CHIEF
COMMISSIONER OF INCOME TAX, KOCHI TO
THE RESPONDENT CBI DATED 11.3.2020
Annexure-3 THE TRUE COPY OF THE FIR IN RC
0342023E0002 OF
CBI/SCB/THIRUVANANTHAPURAM DATED
17.1.2023
Annexure-4 THE TRUE COPY OF FORM NO. 16 SUBMITTED
BY THE 1ST PETITIONER FOR THE
ASSESSMENT YEAR 2017 - 2018 DATED
1.4.2017
Annexure-5 THE TRUE COPY OF THE TAX PAYER
COUNTERFOILS DATED 27.11.2021
Annexure-6 THE TRUE COPY OF FORM NO. 16 SUBMITTED
BY THE 1ST PETITIONER FOR THE
ASSESSMENT YEAR 2018 - 2019 DATED
1.4.2018
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Annexure-7 THE TRUE COPY OF FORM NO. 16 SUBMITTED
BY THE 1ST PETITIONER FOR THE
ASSESSMENT YEAR 2019 - 2020
Annexure-8 THE TRUE COPIES OF THE COMPUTERIZED
RECEIPTS OF SBI, KANNUR DATED 3.2.2023
ISSUED TO THE 1ST PETITIONER
Annexure-9 THE TRUE COPY OF FORM NO. 16 SUBMITTED
BY THE 2ND PETITIONER FOR THE
ASSESSMENT YEAR 2018 - 2019 DATED
1.4.2018
Annexure-10 THE TRUE COPY OF FORM NO. 16 SUBMITTED
BY THE 2ND PETITIONER FOR THE
ASSESSMENT YEAR 2019 - 2020 DATED
1.4.2019
Annexure-11 THE TRUE COPIES OF THE COMPUTERIZED
RECEIPTS OF SBI, KANNUR DATED 3.2.2023
ISSUED TO THE 2ND PETITIONER
Annexure-12 THE TRUE COPY OF THE INTERIM ORDER OF
THIS HON'BLE COURT IN CRL MC NO.
1661/2023 DATED 26.9.2023
Annexure-13 THE TRUE COPY OF THE ORDER OF THIS
HON'BLE COURT IN CRL MC NO. 1661/2023
DATED 9.10.2024.
Annexure-14 THE CERTIFIED COPY OF THE CHARGE SHEET
FILED BY THE RESPONDENT CBI IN RC
0342023E002 OF
CBI/SCB/THIRUVANANTHAPURAM BEFORE THE
CJM COURT, ERNAKULAM DATED 29.6.2024
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PETITIONER ANNEXURES
Annexure I TRUE COPY OF THE FIR NO. RC
0342023E0002 DATED 17-1-2023
Annexure II TRUE COPY OF THE CIRCULAR DATED 9-9-
Annexure III TRUE COPY OF THE LETTER DATED 4-2-2020
OF THE PRINCIPAL COMMISSIONER OF INCOME
TAX, KOZHIKODE
Annexure IV TRUE COPY OF THE COMPLAINANT DATED 11-
3-2020 OF THE PRINCIPAL CHIEF
COMMISSIONER OF INCOME TAX
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APPENDIX OF CRL.MC 10877/2024
PETITIONER ANNEXURES
Annexure 1 THE CERTIFIED COPY OF THE FIR NO.
348/2006 OF THIRUR POLICE STATION
Annexure 2 THE CERTIFIED COPY OF THE FINAL REPORT
IN CRIME NO. 348 OF 2006 OF THIRUR
POLICE STATION, WHICH IS RE-REGISTERED
AS CRIME NO.36/CB/MPM/2007 OF CRIME
BRANCH , MALAPPURAM AND PENDING AS C.C.
NO. 194 OF 2024 BEFORE THE HON'BLE
COURT OF THE CHIEF JUDICIAL MAGISTRATE,
MANJERI
Annexure 3 TRUE COPY OF THE MEDICAL CERTIFICATE
DATED 18-9-2024 ISSUED FROM LOURDE
HOSPITAL
Annexure 4 A TRUE COPY OF THE DISCHARGE SUMMARY
DATED 20-2-2023 AFTER ADMITTED ON 16-2-
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PETITIONER ANNEXURES
Annexure I TRUE COPY OF FIR NO. RC 0342023E0002
DATED 17-1-2023 OF THE CHIEF JUDICIAL
MAGISTRATE COURT, ERNAKULAM
Annexure II TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2016-2017 DATED 10-5-
Annexure II(a) TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2014-2015 DATED 30-3-
Annexure II(b) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2014-2015 DATED 12-3-
Annexure III ). TRUE COPY OF THE COUNTERFOIL DATED
22-4-2021 FOR THE ASSESSMENT YEAR 2017-
Annexure III(a) TRUE COPY OF THE COUNTERFOIL DATED 24-
2-2022 FOR THE ASSESSMENT YEAR 2014-
Annexure III(b) TRUE COPY OF THE COUNTERFOIL DATED 12-
4-2022 FOR THE ASSESSMENT YEAR 2014-
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Annexure IV TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 30-3-
Annexure IV(a) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 26-3-
Annexure IV(b) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 21-9-
Annexure V TRUE COPY OF THE COUNTERFOIL DATED 15-
4-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure V(a) TRUE COPY OF THE COUNTERFOIL DATED 20-
10-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure VI TRUE COPY OF THE ORDER DATED 19-12-2022
OF THE 2ND RESPONDENT
Annexure VII TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2015-2016 DATED 30-3-
Annexure VII(a) TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2016-2017 DATED 30-3-
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Annexure VII(b) ). TRUE COPY OF THE NOTICE UNDER
SECTION 148 OF THE INCOME TAX ACT FOR
THE ASSESSMENT YEAR 2017-2018 DATED 30-
3-2021
Annexure VII(c) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT DATED 24-3-
Annexure VIII TRUE COPY OF THE COUNTERFOIL DATED 23-
4-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure VIII(a) TRUE COPY OF THE COUNTERFOIL DATED 23-
4-2022 FOR THE ASSESSMENT YEAR 2016-
Annexure VIII(b) TRUE COPY OF THE COUNTERFOIL DATED 23-
4-2022 FOR THE ASSESSMENT YEAR 2015-
Annexure VIII(c) TRUE COPY OF THE COUNTERFOIL DATED 25-
10-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure VIII(d) ). TRUE COPY OF THE COUNTERFOIL DATED
25-10-2022 FOR THE ASSESSMENT YEAR
2016-2017
Annexure VIII(e) TRUE COPY OF THE COUNTERFOIL DATED 25-
10-2022 FOR THE ASSESSMENT YEAR 2015-
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Annexure VIII(f) TRUE COPY OF THE COUNTERFOIL DATED 24-
11-2022 FOR THE ASSESSMENT YEAR 2016-
Annexure VIII(g) TRUE COPY OF THE COUNTERFOIL DATED 24-
11-2022 FOR THE ASSESSMENT YEAR 2015-
Annexure VIII(h) TRUE COPY OF THE COUNTERFOIL DATED 24-
11-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure VIII(i) TRUE COPY OF THE COUNTERFOIL DATED 19-
12-2022 FOR THE ASSESSMENT YEAR 2015-
Annexure VIII(j) TRUE COPY OF THE COUNTERFOIL DATED 19-
12-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure VIII(k) TRUE COPY OF THE COUNTERFOIL DATED 19-
12-2022 FOR THE ASSESSMENT YEAR 2016-
Annexure IX . TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2015-2016 DATED 30-3-
Annexure IX(a) TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2016-2017 DATED 30-3-
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Annexure IX(b) TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 30-3-
Annexure X ). TRUE COPY OF THE COUNTERFOIL DATED
22-4-2022 FOR THE ASSESSMENT YEAR 2016-
Annexure X(a) TRUE COPY OF THE COUNTERFOIL DATED 22-
4-2022 FOR THE ASSESSMENT YEAR 2015-
Annexure X(b) TRUE COPY OF THE COUNTERFOIL DATED 24-
4-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure XI TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2016-2017 DATED 14-2-
Annexure XI(a) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2016-2017 DATED 25-8-
Annexure XI(b) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 14-2-
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Annexure XI(c) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 25-8-
Annexure XII TRUE COPY OF THE COUNTERFOIL DATED 25-
6-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure XII(a) TRUE COPY OF THE COUNTERFOIL DATED 15-
6-2022 FOR THE ASSESSMENT YEAR 2016-
Annexure XII(b) TRUE COPY OF THE COUNTERFOIL DATED 12-
10-2022 FOR THE ASSESSMENT YEAR 2016-
Annexure XII(c) TRUE COPY OF THE COUNTERFOIL DATED 12-
10-2022 FOR THE ASSESSMENT YEAR 2017-
Annexure XIII TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2016-2017 DATED 30-3-
Annexure XIII(a) TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 30-3-
Annexure XIV TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 22-3-
Crl.MC.No.1003/23 & con.cases
2025:KER:27705
Annexure XV TRUE COPY OF THE COUNTERFOIL DATED 4-4-
2022 FOR THE ASSESSMENT YEAR 2016-2017
Annexure XV(a) TRUE COPY OF THE COUNTERFOIL DATED 4-4-
2022 FOR THE ASSESSMENT YEAR 2017-2018
Annexure XVI TRUE COPY OF THE NOTICE UNDER SECTION
148 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 10-5-
Annexure XVI(a) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 26-02-
Annexure XVI(b) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2017-2018 DATED 27-1-
Annexure XVI(c) TRUE COPY OF THE NOTICE UNDER SECTION
156 OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2016-2017 DATED 21-9-
Annexure XVI(d) TRUE COPY OF THE NOTICE UNDER SECTION
133(6) OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2018-2019 DATED 30-10-
Annexure XVI(e) TRUE COPY OF THE NOTICE UNDER SECTION
133(6) OF THE INCOME TAX ACT FOR THE
ASSESSMENT YEAR 2019-2020 DATED 30-10-
Crl.MC.No.1003/23 & con.cases
2025:KER:27705
Annexure XVII TRUE COPY OF THE COUNTERFOIL DATED 28-
02-2021 FOR THE ASSESSMENT YEAR 2017-
Annexure XVII(a) TRUE COPY OF THE COUNTERFOIL DATED 13-
08-2021 FOR THE ASSESSMENT YEAR 2016-
Annexure XVIII TRUE COPY OF THE ORDER DATED 19-12-2022
OF THE 2ND RESPONDENT
Annexure XIX TRUE COPY OF THE CIRCULAR DATED
9/9/2019 ISSUED BY THE GOVERNMENT OF
INDIA
Annexure XX TRUE COPY OF THE LETTER DATED 4/2/2020
OF THE PRINCIPAL COMMISSIONER OF INCOME
TAX, KOZHIKODE
Annexure XXI TRUE COPY OF THE COMPLAINT DATED
11/3/2020 OF THE PRINCIPAL CHIEF
COMMISSIONER OF INCOME TAX, KERALA
Annexure XXII TRUE COPY OF THE FINAL REPORT IN C.C.
NO. 104 OF 2024 OF THE CHIEF JUDICIAL
MAGISTRATE COURT, ERNAKULAM
