Kerala High Court
The Kalamassery Service Co-Operative ... vs The Union Of India on 25 October, 2025
2025:KER
W.P(C)No.7053/2023 & Connected cases 1
IN THE HIGH COURT OF KERALA AT ERNAKULAM CR
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 7053 OF 2023
PETITIONER/S:
1 VELLANGALLUR PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD
NO.R. 1191, KONATHUKUNNU P.O, THRISSUR, PIN-680123
REPRESENTED BY ITS SECRETARY RAJITHA K.S
2 MUKUNDAPURAM TALUK GRAMA VIKASANA CO-OPERATIVE
SOCIETY LTD
NO.R. 1427, NADA - IRINJALAKUDA P.O, THRISSUR
DISTRICT, PIN 680121 REPRESENTED BY SECRETARY PRIYA K
BY ADVS.
SHRI.C.A.JOJO
SRI.S.JIJI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110000.
2 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110000.
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018
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W.P(C)No.7053/2023 & Connected cases 2
4 THE INCOME TAX OFFICER(TDS)
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680001
5 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE
THRISSUR DISTRICT CO-OPERTAIVE BANK),
THRISSUR DISTRICT CO-OPERTAIVE BANK), HEAD OFFICE,
THRISSUR-680001
6 THE GENERAL MANAGER
IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD TANA
JUNCTION, IRINJALAKUDA P.O, PIN-680121
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
9.10.2025 ALONG WITH WP(C) NOS.213/2022, 378/2022 AND CONNECTED
CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 3
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 213 OF 2022
PETITIONER/S:
1 EDARIKODE SERVICE CO-OPERATIVE BANK LTD. NO. F 10739,
EDARIKODE P.O, MALAPPURAM DISTRICT, PIN 676 501,
REPRESENTED BY ITS SECRETARY IN CHARGE, SYAMKUMAR
M.K.
2 THE AREEKODE SERVICE CO-OPERATIVE BANK LTD. NO.
F1571,
AREEKODE P.O, MALAPPURAM DISTRICT, PIN 673 639,
REPRESENTED BY ITS SECRETARY LATHIKA P.
3 THE KEEZHUPARAMBA SERVICE CO-OPERATIVE BANK LTD.,
NO. M 396, VALILLAPUZHA P.O, MALAPPURAM DISTRICT, PIN
673 639, REPRESENTED BY ITS SECRETARY IN CHARGE,
SHEEBARANI A
4 URANGATTIRI SERVICE CO-OPERATIVE BANK LTD. NO. 8895,
H.O. THEERATTAMMAL, URANGATTIRI P.O, AREEKODE,
MALAPPURAM DISTRICT, PIN-673 639 REPRESENTED BY ITS
SECRETASECRETARY,ANWAR T.P.
5 THE VENGARA SERVICE CO-OPERATIVE BANK LTD. NO. F
1186,
MALAPPURAM DISTRICT, PIN 676 304, REPRESENTED BY ITS
SECRETARY, HAMMED
6 PUTHUPPARAMBA SERVICE CO-OPERATIVE BANK LTD. NO.
M822,
P.O. PUTHUPPARAMBA, MALAPPURAM DISTRICT, PIN 679 501,
REPRESENTED BY ITS SECRETARY, SAHADEVAN T.
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W.P(C)No.7053/2023 & Connected cases 4
BY ADVS.
SHRI.C.A.JOJO
SRI.MATHEWS JOSEPH
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINSTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI 682 018.
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD,
THIRUR P.O, MALAPPURAM DISTRICT, PIN 676 101.
4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD.,
HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN 676 505,
REPRESENTED BY ITS GENERAL MANAGER.
5 MANJERI CO-OPERATIVE URBAN BANK LTD.,
MANJERI, TIRUR MALAPPURAM DISTRICT, PIN 676 121,
REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
SHRI.VISHNU PRADEEP
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.ESM.KABEER
SHRI.K.VIDYASAGAR
SRI.GILBERT GEORGE CORREYA
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 5
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 378 OF 2022
PETITIONER/S:
1 MALAPPURAM DISTRICT ELECTRICITY BOARD,
EMPLOYEES CO-OPERATIVE SOCIETY LIMITED NO. M.380, HO
MALAPPURAM, MALAPPURAM DISTRICT-676519, REPRESENTED
BY ITS SECRETARY O. VINOD.
2 CHERAKARA CO-OPERATIVE RURAL BANK LIMITED NO. M.663,
P.O. PULIKKAL, MALAPPURAM DISTRICT-673637,
REPRESENTED BY ITS SECRETARY SUBHADRA.
3 MUTHUVALLUR GRAMA PANCHAYAT
RURAL DEVELOPMENT CO-OPERATIVE SOCIETY LIMITED
NO.M.955, P.O. KONDOTTY, MALAPPURAM DISTRICT-679638,
REPRESENTED BY ITS SECRETARY SHYJA E.
4 MAMPAD RURAL CO-OPERATIVE SOCIEITY LIMITED
NO.M.791, P.O.VADAPURAM, MALAPPURAM DISTRICT-676542,
REPRESENTED BY ITS SECRETARY MANEESH C.M.
5 THAZHEKKODE PANCHAYATH RURAL CO-OPERATIVE SOCIETY
LIMITED NO. M.1036, MALAPPURAM DISTRICT-679341,
REPRESENTED BY ITS SECRETARY SHEENA DEV.
6 MALAPPURAM AIDE SCHOOL TEACHERS
CO-OPERATIVE SOCIETY LIMITED NO. M.49, P.O., DOWN
HILL, MALAPPURAM DISTRICT-676519, REPRESENTED BY ITS
SECRETARY SHEENA P.
7 THENHIPALAM CO-OPERATIVE RURAL BANK LIMITED
NO. M.668, P.O. THENHIPALAM, MALAPPURAM DISTRICT-
673636, REPRESENTED BY ITS SECRETARY LATHA T.
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8 THE VETTIKKATTIRI VANITHA CO-OPERATIVE SOCIETY
LIMITED
NO. M.744, P.O. VELLUVANGAD, MALAPPURAM DISTRICT-
676521, REPRESENTED BY ITS SECRETARY ABDUL HAMEED.
9 THE VETTIKKATTIRI VANITHA CO-OPERATIVE SOCIETY
LIMITED
NO. M.744, P.O. VELLUVANGAD, MALAPPURAM DISTRICT-
676521, REPRESENTED BY ITS SECRETARY ABDUL HAMEED.
0 PULPATTA VANITHA CO-OPERATIVE SOCIETY LIMITED
NO. M.760, P.O. THRIPPANACHI, MALAPPURAM DISTRICT-
673541, REPRESENTED BY ITS SECRETARY PRAVEENA K.
11 KANNAMANGALAM PATTIKAJATHI SERVICE CO-OPERTAIVE
SOCIETY
LIMITED NO. M.297, P.O. KANNAMANGALAM, MALAPPURAM
DISTRICT-676304, REPRESENTED BY THE SECRETARY LAKSHMI
P.
12 EDAVANNA WELFARE CO-OPERATIVE SOCIETY
LIMITED NO. M. 993, P.O. EDAVANNA, MALAPPURAM
DISTRICT-676541, REPRESENTED BY ITS SECRETARY P.
MOHAMMAD.
13 CHEMBRASSERI VANITHA CO-OPERATIVE SOCIETY
LIMITED NO. M.87, P.O. CHEMBRASSERI EAST, MALAPPURAM
DISTRICT-679327, REPRESENTED BY ITS SECRETARY CHINJU
KRISHNA.
14 TUVVUR PANCHAYATH VANITHA
CO-OPERATIVE SOCIETY LIMITED NO. M.580, P.O. TUVVUR,
MALAPPURAM DISTRICT-679327, REPRESENTED BY ITS
SECRETARY JAYASREE M.V.
15 PARAPPUR PANCHAYATH VANITHA SAHAKARANA
SANGAM LIMITED NO. M.610, P.O. IRINGALLUR, VENGARA,
MALAPPURAM DISTRICT-676304, REPRESENTED BY ITS
SECRETARY C.T. ROSHNI.
16 NILAMBUR MERCANTILE CO-OPERATIVE SOCIETY
LIMITED NO. M.763, P.O. NILAMBUR MALAPPURAM DISTRICT-
679329, REPRESENTED BY ITS SECRETARY P. DEVANAND.
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17 KOTTAKKAL CO-OPERATIVE URBAN SOCIETY LIMITED
NO. M.1010, P.O. KOTTAKKAL, MALAPPURAM DISTRICT-
676503, REPRESENTED BY ITS SECRETARY N. BALAKRISHNAN.
18 CHERUKAVU VANITHA SAHAKARANA
SANGAM LIMITED, NO. M.758, P.O. AYIKKAAPADI,
MALAPPURAM DISTRICT-673637, REPRESENTED BY ITS
SECRETARY IN CHARGE BHAVITHA K.
19 KOTTAKKAL VANITHA CO-OPERATIVE
SOCIETY LIMITED, NO. M.757, P.O. KOTTAKKAL,
MALAPPURAM DISTRICT-676503, REPRESENTED BY ITS
SECRETARY SUMI P.
10 VALLIKKUNNU PANCHAYATH AGRICULTURAL IMPROVEMENT
CO-OPERATIVE SOCIETY LIMITED NO. M.938, P.O.
KODAKKAD, MALAPPURAM DISTRICT-676319, REPRESENTED BY
ITS SECRETARY JISH C.
21 TIRURANGADI AGRICULTURAL WORKERS DEVELOPMENT
WELFARE CO-OPERATIVE SOCIETY LIMITED NO. M.887, P.O.
TIRURANGADI, MALAPPURAM DISTRICT, PIN-676306,
REPRESENTED BY ITS SECRETARY K. VIJNA VINOD.
22 VALLIKUNNU PANCHAYATH VANITHA CO-OPERATIVE
SOCIETY LIMITED NO.M.509, P.O. ARIYALLUR, MALAPPURAM
DISTRICT-676312, REPRESENTED BY ITS SECRETARY ANITHA.
23 MOONIYOOR VALLIKUNNU CO-OPERATIVE RURAL BANK
LIMITED NO. M. 673, P.O. MOONIYOOR, MALAPPURAM
DISTRICT, REPRESENTED BY ITS SECRETARY IN CHARGE
SMITHA.
24 VENGARA BLOCK PRAVASI KSHEMA SAHAKARANA SANGAM,
P.O. KUTTALOOR OOAKAM, MALAPPURAM DISTRICT-676519,
REPRESENTED BY ITS SECRETARY SHAJIDA.
25 ALLIKUNNU ANANGADI VANITHA
CO-OPERATIVE SOCIETY LIMITED NO. M.707, KADALUNDI
NAGARAM P.O., ANANGADI, MALAPPURAM DISTRICT-673314,
REPRESENTED BY ITS SECRETARY SHEEBA M.
26 TIRURANGADI TALUK GOVERNMENT TEACHERS
CO-OPERATIVE SOCIETY LIMITED NO. M.405, P.O.
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TIRURANGADI, MALAPPURAM DISTRICT-676306, REPRESENTED
BY ITS SECRETARY BABY E.P.
27 TIRURANGADI TALUK GOVERNMENT EMPLOYEES
CO-OPERATIVE SOCIETY LIMITED NO. M.536, P.O.
TIRURANGADI, MALAPPURAM DISTRICT-676306, REPRESENTED
BY ITS SECRETARY, JYOTHILAKSHMI K.
28 PERUVALLUR VANITHA SAHAKARANA SANGAM LIMITED
NO.M.774, P.O. KADAPPADI, PERUVALLUR, MALAPPURAM
DISTRICT-673638, REPRESENTED BY ITS SECRETARY RAJITHA
A.
29 MLP DT. POSTAL, TELECOM
AND BSNL EMPLOYEES CO-OPERATIVE SOCIETY LIMITED NO.
M.268, P.O. MANJERI, MALAPPURAM DISTRICT-676121,
REPRESENTED BY ITS SECRETARY NANDAKUMAR.
20 PARAPPUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LIMITED NO. M.943, P.O. PARAPPUR, MALAPPURAM
DISTRICT-676501, REPRESENTED BY ITS SECRETARY IN
CHARGE LISHA .
31 PARAPPANANGADI CO-OPERATIVE RURAL BANK
LIMITED NO. M.669, P.O. PARAPPANANGADI, MALAPPURAM
DISTRICT-676303, REPRESENTED BY ITS SECRETARY BHERI
K.
32 MALAPPURAM DISTRICT GOVERNMENT
SCHOOL TEACHER CO-OPERATIVE SOCIETY LIMITED NO.
M.1935, P.O. UPHILL, MALAPPURAM DISTRICT-676122,
REPRESENTED BY ITS SECRETARY SHERI K.
33 FOR MANJERI HOUSING CO-OPERATIVE SOCIETY
LIMITED NO. M.256, P.O. MANJERI MALAPPURAM DISTRICT-
676121, REPRESENTED BY ITS SECRETARY SATHIDEVI N.
34 ELANKUR VANITHA SAHAKARANA SANGAM LIMITED NO.M.754,
P.O. MANHAPATTA, MALAPPURAM DISTRICT-676122,
REPRESENTED BY ITS SECRETARY SAJITHA P.C.
35 KONDOTTY MUNICIPAL PATTIKAJATHI SERVICE CO-OPERATIVE
LIMITED NO. M.560, P.O. KONDOTTY, MALAPPURAM
DISTRICT-673638, REPRESENTED BY ITS SECRETARY.
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36 VAZHAKKAD PATTIKAJATHI SERVICE
SAHAKARANA SANGHAM LIMITED NO. M.340, P.O.
CHERUVAYUR, MALAPPURAM DISTRICT-676505, REPRESENTED
BY ITS SECRETARY SHEELA.
37 PANDIKKAD RURAL CO-OPERATIVE SOCIETY
LIMITED NO.M.819, P.O. PANDIKKAD, MALAPPURAM
DISTRICT-679521, REPRESENTED BY ITS SECRETARY
SREEJITH M.
38 TUVVUR RURAL CO-OPERATIVE SOCIETY
LIMITED NO. M.836, P.O. TUVVUR, MALAPPURAM DISTRICT-
679327, REPRESENTED BY ITS SECRETARY RAGESH V.
39 KARUVARAKUNDU RURAL CO-OPERATIVE
SOCIETY LIMITED M. 803, P.O. KIZHAKETHALA, MALAPPURAM
DISTRICT-676523, REPRESENTED BY ITS SECRETARY V.C.
UNNIKRISHNAN.
40 FOR MALAPPURAM DISTRICT POLICE
CO-OPERATIVE SOCIETY LIMITED NO. M.438, P.O.,
MALAPPURAM, MALAPPURAM DISTRICT-676505, REPRESENTED
BY ITS SECRETARY T. ABDUL RASHEED.
BY ADVS.
SHRI.C.A.JOJO
SRI.MATHEWS JOSEPH
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-
682018.
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD,
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W.P(C)No.7053/2023 & Connected cases 10
THIRUR P.O., MALAPPURAM DISTRICT-676101.
4 MALAPPURAM DISTRICT CO-OPERATIVE
[SOCIETY]*CORRECTED AS BANK LIMITED,
HEAD OFFICE, MANJERI ROAD, MALAPPURAM-676505
REPRESENTED BY ITS GENERAL MANAGER.
5 MANJERI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS
BANK LIMITED,
MANJERI, TIRUR, MALAPPURAM DISTRICT-676121,
REPRESENTED BY ITS GENERAL MANAGER.
6 PONANI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS
BANK LIMITED,
HEAD OFFICE, K.K. JUNCTION, PONNANI, MALAPPURAM
DISTRICT, KERALA-691001, REPRESENTED BY ITS GENERAL
MANAGER.
7 URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK,
PERINTHALMANNA, HEAD OFFICE, PERINTHALMANNA P.O.,
PIN-679322, REPRESENTED BY ITS GENERAL MANAGER.
8 TIRUR URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS
BANK LIMITED,
HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA-
676101, REPRESENTED BY ITS GENERAL MANAGER.
9 KOTTAKKAL CO-OPERATIVE URBAN [SOCIETY]*CORRECTED
AS BANK LIMITED,
KOTTAKKAL P.O., MALAPPURAM-676503, REPRESENTED BY ITS
GENERAL MANAGER.
0 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS
BANK,
KOZHIKODE BRANCH, DOWN HILL, PIN-676505, REPRESENTED
BY ITS GENERAL MANAGER.
11 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS
BANK LIMITED,
MALAPPURAM BRANCH, PARRY SHOPPING COMPLEX, KOTTAPADI,
DOWN HILL, P.O. MALAPPURAM DISTRICT-676505. *[THE
WORD "SOCIETY" OCCURRING IN THE SUFFIX PART OF NAME
OF THE RESPONDENTS 4 TO 11 IS CORRECTED AS "BANK", AS
PER ORDER DATED 17/2/2022 IN I.A:1/22 IN WP(C)
2025:KER
W.P(C)No.7053/2023 & Connected cases 11
378/2022]
BY ADVS.
SHRI.VISHNU PRADEEP, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.ESM.KABEER
SRI.D.SOMASUNDARAM, SC, PONNANI CO-OPERATIVE URBAN
BANK LTD.
SHRI.PRAVEEN K.V., CGC
SRI.GILBERT GEORGE CORREYA
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 384 OF 2022
PETITIONER/S:
1 TIRUR TALUK CO-OPERATIVE EMPLOYEES SOCIETY LTD.
NO.M 275, H.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676
101, REPRESENTED BY ITS SECRETARY KRISHNAKUMARI
PALEERI.
2 TIRUR TALUK CO-OPERATIVE SOCIETY LTD.
NO.M 325, TIRUR P.O., MALAPPURAM DISTRICT, PIN - 676
101 REPRESENTED BY ITS SECRETARY-IN-CHARGE, DINOOP
K.V.
3 THE THIRUNAVAYA VANITHA CO-OPERATIVE SOCIETY LTD.
NO.M 696, VAIRANKODE P.O., MALAPPURAM DISTRICT, PIN -
676 301, REPRESENTED BY ITS SECRETARY NISHITHA T.
4 THE THIRUNAVAYA CO-OPERATIVE URBAN SOCIETY LTD.
NO.M 646, P.O.EDAKULAM, THIRUNAVAYA, MALAPPURAM
DISTRICT, PIN - 676 301, REPRESENTED BY ITS SECRETARY
SUVARNA M.
5 IMBICHIBAVA MEMORIAL RURAL CO-OPERATIVE SOCIETY LTD.
NO.M 778, MALAPPURAM DISTRICT, PIN - 679 571,
REPRESENTED BY ITS SECRETARY SMITHA K.K.R.
6 MALAPPURAM DISTRICT ABHARANA THOZHILAL CREDIT CO-
OPERATIVE SOCIETY LTD.
NO.M 544, P.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676
101, REPRESENTED BY ITS SECRETARY AMBIKA C.
7 TANUR TOWN THEERADESHA FISHERMEN DEVELOPMENT WELFARE
CO-OPERATIVE SOCIETY F(M) 10
P.O.TANUR, MALAPPURAM DISTRICT, PIN - 673 631,
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REPRESENTED BY ITS SECRETARY RAJANI P.
8 THALAKKAD VANITHA CO-OPERATIVE SOCIETY LTD.
NO.M 684, P.O.B.P.ANGADI, TIRUR-2, MALAPPURAM
DISTRICT, PIN - 676 561, REPRESENTED BY ITS SECRETARY
SOUDAMINI K.
9 TIRUR MOTOR TRANSPORT CO-OPERATIVE SOCIETY LTD.
NO.M 486, P.O.THEKKUMMURI, TIRUR, MALAPPURAM
DISTRICT, PIN - 676 105, REPRESENTED BY ITS SECRETARY
SREERAJ S.
10 POOKKAYIL URBAN CO-OPERATIVE SOCIETY LTD.
NO.M 827, P.O.POOKKAYIL, TIRUR, MALAPPURAM DISTRICT,
PIN - 676 107, REPRESENTED BY ITS SECRETARY RANJITHA
R.
11 TIRUR TALUK VANITHA CO-OPERATIVE SOCIETY LTD.
NO.M 501, P.O.THEKKUMMURI, TIRUR, MALAPPURAM
DISTRICT, PIN - 676 105, REPRESENTED BY ITS SECRETARY
ABITHA N.P.
12 TIRUR TALUK MERCANTILE CO-OPERATIVE SOCIETY LTD.
NO.M 793, P.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676
101, REPRESENTED BY ITS SECRETARY MIDHUNDEV M.P.
13 VALANCHERY URBAN CO-OPERATIVE SOCIETY LTD.
NO.M 994, P.O.VALANCHERY, MALAPPURAM DISTRICT, PIN -
676 552, REPRESENTED BY ITS SECRETARY ANVAR SHAFI
T.P.
14 TIRUR REVENUE TALUK MOTOR TRANSPORT VIKASANA
SAHAKARANA SANGAM LTD.
NO.M 559, P.O.K.PURAM, MALAPPURAM DISTRICT, PIN - 676
307, REPRESENTED BY ITS SECRETARY V.SATHYAVATHY.
15 TRIPRANGOD VANITHA CO-OPERATIVE SOCIETY LTD.
NO.M 740, KARATHUR P.O., CODACAL, MALAPPURAM
DISTRICT, PIN - 676 108, REPRESENTED BY ITS SECRETARY
KADEEJATH SABNA.
16 ALATHIYOOR VANITHA CO-OPERATIVE SOCIETY LTD.
NO. M 817, P.O.ALATHIYOOR, MALAPPURAM DISTRICT, PIN -
676 102, REPRESENTED BY ITS SECRETARY SHEEBA V.
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17 PONANI TALUK GOVT. EMPLOYEES CO-OPERATIVE SOCIETY
LTD.
NO. M 421, P.O.PONNANI, MALAPPURAM DISTRICT, PIN -
679 577, REPRESENTED BY ITS SECRETARY JAYALALITHA
O.B.
18 PONANI TALUK GOVT & QUASI GOVT. EMPLOYEES CO-
OPERATIVE CREDIT SOCIETY LTD.
NO. 298, P.O.PONANI, MALAPPURAM DISTRICT, PIN - 679
577, REPRESENTED BY ITS SECRETARY SREEDEVI M.
19 VELIYANCODE PANCHAYAT VANITHA CO-OPERATIVE SOCIETY
LTD.
NO.M 667, P.O.ERAMANGALAM, MALAPPURAM DISTRICT, PIN -
679 587, REPRESENTED BY ITS SECRETARY LEENA P.
20 NANNAMMUKKU MULTIPURPOSE CO-OPERATIVE SOCIETY LTD.
NO. M 781, P.O.MOOKKUTHALA, MALAPPURAM DISTRICT, PIN
- 679 574, REPRESENTED BY ITS SECRETARY SMITHA C.P.
21 MALAPPURAM DISTRICT LIC AGENT'S CO-OPERATIVE SOCIETY
LTD.
NO M 675, P.O.THRIKKANDIYOOR, MALAPPURAM DISTRICT,
PIN - 676 104, REPRESENTED BY ITS SECRETARY
RADHAKRISHNAN K.
22 NANNAMMUKKU PANCHAYATH VANITHA CO-OPERATIVE SOCIETY
LTD.
NO.M 813, P.O.CHANGARAMKULAM,MALAPPURAM DISTRICT, PIN
- 679 575, REPRESENTED BY ITS SECRETARY SUBITHA K.K.
23 MARANCHERY RURAL CO-OPERATIVE SOCIETY LTD.
NO.M 800, P.O.MARANCHERY, MALAPPURAM DISTRICT, PIN -
679 581, REPRESENTED BY ITS SECRETARY REENA M.
24 MALAPPURAM DISTRICT EMPLOYEES HOUSING CO-OPERATIVE
SOCIETY LTD.
NO.M 797, H.O.TRIKKANDIYUR, MALAPPURAM DISTRICT, PIN
- 676 104, REPRESENTED BY ITS SECRETARY K.PRASADAN.
25 VELIYANCODE MULTI-PURPOSE CO-OPERATIVE SOCIETY LTD.
NO.M 766, P.O.ERAMANGALAM, MALAPPURAM DISTRICT, PIN -
679 587, REPRESENTED BY ITS SECRETARY GIRIVASAN T.G.
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26 PERUMPADAPPU RURAL CO-OPERATIVE SOCIETY LTD.
NO.M 831, P.O.PERUMPADAPPU, MALAPPURAM DISTRICT, PIN
- 679 580, REPRESENTED BY ITS SECRETARY RANJITH KUMAR
P.C.
27 CLARI RURAL CO-OPERATIVE SOCIETY LTD.
NO.M 732, P.O.PANTHARANGADI, MALAPPURAM DISTRICT, PIN
- 676 306, REPRESENTED BY ITS SECRETARY SHIJUMON T.
28 EDAPPAL VANITHA CO-OPERATIVE SOCIETY LTD.
NO.M 764, P.O.EDAPPAL, MALAPPURAM DISTRICT, PIN - 679
576, REPRESENTED BY ITS SECRETARY SREEJESH K.
29 KOLOMBA RURAL CO-OPERATIVE SOCIETY LTD.
NO. M 838, P.O.KOLOLAMBA, MALAPPURAM DISTRICT, PIN -
679 576, REPRESENTED BY ITS SECRETARY SHYJI K.M.
30 VATTAMKULAM VIVIDHODHESA SAHAKARANA CO-OPERATIVE
SOCIETY LTD.
NO.M762, P.O.VETTAMKULAM, MALAPPURAM DISTRICT, PIN -
679 578, REPRESENTED BY ITS SECRETARY VYSAKH K.V.
31 TANUR KAYALORA FDWCS F(M) 68
P.O.TANUR, MALAPPURAM DISTRICT, PIN - 679 576,
REPRESENTED BY ITS SECRETARY SHAHANAS A.
32 PARAPPANANGAD CHAPPAPPAD THEKKABHAGAM FDWCS
F(M) 128, P.O.PARAPPANANGAD, MALAPPURAM DISTRICT, PIN
- 679 303, REPRESENTED BY ITS SECRETARY SHANI K.
33 THE TIRUR TALUK CO-OPERATIVE EDUCATION SOCIETY LTD.
NO.M 315, P.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676
101, REPRESENTED BY ITS SECRETARY SHAJID K.
34 PUTHIYAKADAPPURAM MASTSYA THOZHILALEE VIKASANA KSHEMA
SAHAKARANA SANGAM LTD.
NO.DF(M) 140/93, PUTHIYAKADAPPURAM P.O., THANOOR,
MALAPPURAM DISTRICT, PIN - 676 302, REPRESENTED BY
ITS SECRETARY SHEENA P.
BY ADV SHRI.C.A.JOJO
2025:KER
W.P(C)No.7053/2023 & Connected cases 16
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE,NORTH BLOCK, RAISANA HILL, NEW
DELHI - 11000.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI - 682
018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX OFFICE, TARIFF BAZAR, TOWN HALL ROAD,
THIRUR P.O., MALAPPURAM DISTRICT, PIN - 676 101.
4 MALAPPURAM DISTRICT CO-OPERATIVE
[SOCIETY]*CORRECTED AS BANK LIMITED,
HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN - 676 505,
REPRESENTED BY ITS GENERAL MANAGER.
5 MANJERI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS
BANK LIMITED,
MANJERI, TIRUR MALAPPURAM DISTRICT, PIN - 676 121,
REPRESENTED BY ITS GENERAL MANAGER.
6 PONANI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS
BANK LIMITED,
HEAD OFFICE, K.K.JUNCTION, PONNANI, MALAPPURAM
DISTRICT, KERALA, PINCODE - 691 001, REPRESENTED BY
ITS GENERAL MANAGER.
7 URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK
LIMITED,
HEAD OFFICE, PERINTHALMANNA P.O., PIN - 679 322,
REPRESENTED BY ITS GENERAL MANAGER.
8 TIRUR URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS
BANK LIMITED,
HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA - 676
101, REPRESENTED BY ITS GENERAL MANAGER.
9 KOTTAKKAL CO-OP URBAN [SOCIETY]*CORRECTED AS BANK
LIMITED,
KOTTAKKAL P.O., MALAPPURAM, PIN - 676 503,
2025:KER
W.P(C)No.7053/2023 & Connected cases 17
REPRESENTED BY ITS GENERAL MANAGER.
10 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS
BANK LIMITED,
KOZHIKODE BRANCH, DOWN HILL, PIN - 676 505,
REPRESENTED BY ITS GENERAL MANAGER.
11 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS
BANK LIMITED,
MALAPPURAM BRANCH, PARRY SHOPPING COMPLEX, KOTTAPADI,
DOWN HILL, P.O., MALAPPURAM DISTRICT- 676 505. [THE
NAME OF RESPONDENTS 4 TO 11 IS CORRECTED FROM THE
WORD "SOCIETY" TO "BANK" AS PER ORDER DATED
18.03.2022 IN I.A.1/2022 IN WP(C)384/2022.]
BY ADVS.
SHRI.VISHNU PRADEEP, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.ESM.KABEER
SHRI.K.VIDYASAGAR
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 18
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 383 OF 2022
PETITIONER/S:
1 THE ANANTHAVOOR SERVICE CO-OPERATIVE BANK LTD.
NO.F 1545, ANANTHAVOOR P.O., MALAPPURAM DISTRICT, PIN
- 676 501, REPRESENTED BY ITS SECRETARY, LATHA K.V.
2 THE TIRUNAVAYA SERVICE CO-OPERATIVE BANK LTD.
NO.D 1910, TIRUNAVAYA P.O., MALAPPURAM DISTRICT, PIN
- 676 102 REPRESENTED BY ITS SECRETARY SURESH K.M.
3 THE VALANCHERY SERVICE CO-OPERATIVE BANK LTD.
NO.M 728, VALANCHERY P.O., MALAPPURAM DISTRICT, PN -
676 552 REPRESENTED BY ITS SECRETARY SASIKUMAR P.
4 TIRUR SERVICE CO-OPERATIVE BANK LTD.
NO.10094, P.O.TIRUR, CHEMBRA ROAD, MALAPPURAM
DISTRICT, PIN - 676 101 REPRESENTED BY ITS SECRETARY
UMMAR K.K.
5 THE CHERIYAMUNDAM SERVICE CO-OPERATIVE BANK LTD.
NO.D 1974, MALAPPURAM DISTRICT, PIN - 676 103,
REPRESENTED BY ITS SECRETARY, K.P.NIHMATHALLA.
6 MANGALAM SERVICE CO-OPERATIVE BANK LTD.
NO.9701, MALAPPURAM DISTRICT, PIN - 676 561,
REPRESENTED BY ITS SECRETARY ABDUL MAJEED.
7 MARAKKARA SERVICE CO-OPERATIVE BANK LTD.
NO.F 10738, KADAMPUZHA, MALAPPURAM DISTRICT, PIN -
676 553, REPRESENTED BY ITS SECRETARY, INDU T.
8 KUTTIPPURAM SERVICE CO-OPERATIVE BANK LTD.
2025:KER
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NO.M-729, P.O.KUTTIPPURAM, MALAPPURAM DISTRICT, PIN -
679 517, REPRESENTED BY ITS SECRETARY ABDUL RASHEED
K.K.
9 OZHUR SERVICE CO-OPERATIVE BANK LTD.
NO.F 1586, P.O.OZHUR, TANALUR, MALAPPURAM DISTRICT,
PIN - 676307, REPRESENTED BY ITS SECRETARY PADMAJA E.
10 THE PERUMANNA KLARI SERVICE CO-OPERATIVE BANK LTD.
NO.F-770, P.O.KUTTIPPALA, MALAPPURAM DISTRICT, PIN -
676 501, REPRESENTED BY ITS SECRETARY IN -CHARGE
MUHAMMAD HANEEK.
11 THALAKKAD SERVICE CO-OPERATIVE BANK LTD.
NO.4391, P.O.VENGALUR, MALAPPURAM DISTRICT, PIN - 676
102, REPRESENTED BY ITS SECRETARY-IN-CHARGE BEENA A.
12 THE KALPAKANCHERY SERVICE CO-OPERATIVE BANK LTD.
NO.1808, P.O.KALPAKANCHERY, MALAPPURAM DISTRICT, PIN
- 676 551, REPRESENTED BY ITS SECRETARY
P.KADIYAMAKUTTY.
13 THE PONMUNDAM SERVICE CO-OPERATIVE BANK LTD.
NO.10820, P.O.PONMUNDAM, TIRUR, MALAPPURAM DISTRICT,
PIN - 676 106, REPRESENTED BY ITS SECRETARY
T.P.BAHANUVUDHEEN.
14 VETTOM SERVICE CO-OPERATIVE BANK LTD.
NO.1823, P.O.VETTOM, MALAPPURAM DISTRICT, PIN - 676
102, REPRESENTED BY ITS SECRETARY DAM KUMAR P.R.
15 TRIPRANGODE SERVICE CO-OPERATIVE BANK LTD.
NO.1890, P.O.ALATHIYUR, MALAPPURAM DISTRICT, PIN -
676 102, REPRESENTED BY ITS SECRETARY-IN-CHARGE,
A.SIVADASAN.
16 NIRAMARUTHUR SERVICE CO-OPERATIVE BANK LTD.
NO.M.612, P.O.NIRAMARUTHUR, MALAPPURAM DISTRICT, PIN
- 676 109, REPRESENTED BY ITS SECRETARY CHANDRAN V.K.
17 THE PONANI SERVICE CO-OPERATIVE BANK LTD.
NO.4841, P.O.PONNANI, MALAPPURAM DISTRICT, PIN - 679
577, REPRESENTED BY ITS SECRETARY JIJI K.P.
2025:KER
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18 KANMANAM SERVICE CO-OPERATIVE BANK LTD.
NO.10585, P.O.KANMANAM, MALAPPURAM DISTRICT, PIN -
676 5651, REPRESENTED BY ITS SECRETARY MOHAMMED
BASHEER V.M.
19 PURATHUR SERVICE CO-OPERATIVE BANK LTD.
NO.1902, P.O.PURATHUR, TIRUR, MALAPPURAM DISTRICT,
PIN - 676 102, REPRESENTED BY ITS SECRETARY-IN-
CHARGE, MALLIKA M.
20 VADAKKUMPURAM SERVICE CO-OPERATIVE BANK LTD.
NO.F 1505, P.O.EDAYUR NORTH VALANCHERY, MALAPPURAM
DISTRICT, PIN - 676 552, REPRESENTED BY ITS SECRETARY
VINOD V.
21 THE VALAVANNUR SERVICE CO-OPERATIVE BANK LTD.
NO.D 1959, P.O.VALAVANNUR, MALAPPURAM DISTRICT, PIN -
676 551, REPRESENTED BY ITS SECRETARY YOOSAF KALLEKY.
22 KALADY GRAMA PANCHAYATH SERVICE CO-OPERATIVE BANK
LTD.
NO.M 783, P.O.KADANCHERY, MALAPPURAM DISTRICT, PIN -
676 552, REPRESENTED BY ITS SECRETARY SAKHIL P.
23 THAVANUR SERVICE CO-OPERATIVE BANK LTD.
NO.P 516, P.O.AYANKALAM, MALAPPURAM DISTRICT, PIN -
679 573,REPRESENTED BY ITS SECRETARY P.MURALEEDHARAN.
24 TANALLUR SERVICE CO-OPERATIVE BANK LTD.
NO.M-2, P.O.TANALUR, MALAPPURAM DISTRICT, PIN - 676
307, REPRESENTED BY ITS SECRETARY-IN-CHARGE, SAJEEV
P.K.
25 IRIMBILIYAM SERVICE CO-OPERATIVE BANK LTD.
NO.10445, P.O.IRIMBILIYAM, MALAPPURAM DISTRICT, PIN -
679 572, REPRESENTED BY ITS SECRETARY
P.M.BALACHANDRAN.
26 ATHAVANAD SERVICE CO-OPERATIVE BANK LTD.
NO.D 1933, P.O.KARIPPOL, MALAPPURAM DISTRICT, PIN -
676 552, REPRESENTED BY ITS SECRETARY MOHAMMAD HARIS
K.K.
2025:KER
W.P(C)No.7053/2023 & Connected cases 21
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 11000.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI - 682
018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX OFFICER, TARIF BAZAR, TOWN HALL ROAD
THIRUR P.O., MALAPPURAM DISTRICT, PIN - 676 101.
4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD.
HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN - 676 505
REPRESENTED BY ITS GENERAL MANAGER.
5 MANJERI CO-OPERATIVE URBAN BANK LTD.
MANJERI, TIRUR MALAPPURAM DISTRICT, PIN - 676 121,
REPRESENTED BY ITS GENERAL MANAGER.
6 PONANI CO-OPERATIVE URBAN BANK LTD.
HEAD OFFICE, K.K.JUNCTION, PONNANI, MALAPPURAM
DISTRICT, KERALA, PINCODE - 691 001, REPRESENTED BY
ITS GENERAL MANAGER.
7 URBAN CO-OPERATIVE BANK PERINTHALMANNA
HEAD OFFICE, PERINTHALMANNA P.O., PIN - 679 322,
REPRESENTED BY ITS GENERAL MANAGER.
8 TIRUR URBAN CO-OPERATIVE BANK LTD.
HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA - 676
101, REPRESENTED BY ITS GENERAL MANAGER.
9 KOTTAKKAL CO-OP URBAN BANK LTD.
KOTTAKKAL P.O., MALAPPURAM, PIN - 676 503,
REPRESENTED BY ITS GENERAL MANAGER.
10 KERALA STATE CO-OPERATIVE BANK
2025:KER
W.P(C)No.7053/2023 & Connected cases 22
KOZHIKODE BRANCH, DOWN HILL, PIN - 676 505,
REPRESENTED BY ITS GENERAL MANAGER.
11 KERALA STATE CO-OPERATIVE BANK LTD.
MALAPPURAM BRANCH, PARRY SHOPPING COMPLEX, KOTTAPADI,
DOWN HILL P.O., MALAPPURAM DISTRICT - 676 505.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.ESM.KABEER
SHRI.K.VIDYASAGAR
SHRI.D.SOMASUNDARAM
SMT.JAYASREE K.P.
SRI.DEVAPRASANTH.P.J.
SHRI.JOHN JOSEPH
SRI.CHRISTOPHER ABRAHAM
SRI.GILBERT GEORGE CORREYA
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 23
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 732 OF 2022
PETITIONER/S:
1 THE POTHUKAL AGRICULTURAL IMPROVEMENT ,
CO-OPERATIVE SOCIETY LTD. NO. M 930, NATTUKULAM,
MALAPPURAM DISTRICT-679234, REPRESENTED BY ITS
SECRETARY.
2 THE VAZHIKADAVU AGRICULTURAL IMPROVEMENT,
CO-OPERATIVE SOCIETY LIMITED NO. M-899, VAZHIKADAVU,
MALAPPURAM DISTRICT-679233, REPRESENTED BY ITS
SECRETARY.
3 THE KALIKAVU RURAL CO-OPERATIVE SOCIETY LIMITED M
980,
KALIKAVU, MALAPPURAM DISTRICT-676525, REPRESENTED BY
ITS SECRETARY.
4 THE WANDOOR CO-OPERATIVE RURAL BANK LIMITED NO. M
674,
WANDOOR P.O., MALAPPURAM DISTRICT-679328, REPRESENTED
BY ITS SECRETARY.
5 THE KARAPPURAM VANITHA SAHAKARANA SANGHAM,
LIMITED NO. M 698, KARAPPURAM P.O., MALAPPURAM
DISTRICT-679331, REPRESENTED BY ITS SECRETARY.
6 THE ERUMAMUNDA RURAL CO-OPERATIVE SANGHAM,
LIMITED NO. M 742, ERUMAMUNDA P.O., MALAPPURAM
DISTRICT-679334, REPRESENTED BY ITS SECRETARY.
7 THE INDIRAJI VANITHA CO-OPERATIVE SOCIETY,
LIMITED NO. M 923, KARULAI, KINATTINGAL, MALAPPURAM
DISTRICT-679331, REPRESENTED BY ITS SECRETARY.
2025:KER
W.P(C)No.7053/2023 & Connected cases 24
8 THEEDAKKARA AGRICULTURAL IMPROVEMENT CO-OPERATIVE,
SOCIETY LIMITED NO. M 978, EDAKKARA P.O., MALAPPURAM
DISTRICT-679331, REPRESENTED BY ITS SECRETARY.
9 THE CHUNGATHARA AGRICULTURAL IMPROVEMENT,
CO-OPERATIVE SOCIETY LIMITED NO. M 969, CHUNGATHARA,
MALAPPURAM DISTRICT-679334, REPRESENTED BY ITS
SECRETARY.
10 THE NILAMBUR TALUK SERVICE PENSIONER'S,
SAHAKARANA SANGHAM LIMITED NO. M 629, CHUNGATHARA
P.O., MALAPPURAM DISTRICT-679329, REPRESENTED BY ITS
SECRETARY.
11 THE WANDOOR PANCHAYATH VANITHA SAHAKARANA,
SANGHAM LIMITED NO. M 585, WANDOOR P.O., MALAPPURAM
DISTRICT-679328, REPRESENTED BY ITS SECRETARY.
12 THE NILAMBUR CO-OPERATIVE AGRICULTURAL
MARKETING AND PROCESSING SOCIETY LIMITED M 296,
NILAMBUR, MALAPPURAM DISTRICT-679330, REPRESENTED BY
ITS SECRETARY.
13 THE WANDOOR AGRICULTURAL IMPROVEMENT,
CO-OPERATIVE SOCIETY LIMITED NO. M-882, WANDOOR,
MALAPPURAM DISTRICT-679328, REPRESENTED BY ITS
SECRETARY.
14 THE NALLAMATHANNI VANITHA CO-OPERATIVE SOCIETY,
LIMITED NO. M 734, PULLIYIL, NALLAMTANNI P.O.,
MALAPPURAM DISTRICT-679321, REPRESENTED BY ITS
SECRETARY.
15 THE KALKKULAM VANITHA SAHAKARANA SANGHAM,
LIMITED NO. M 724, KARAPPURAM P.O., MALAPPURAM
DISTRICT-679323, REPRESENTED BY ITS SECRETARY.
16 THE MALAPPURAM DISTRICT CO-OPERATIVE MOTOR,
VEHICLES LIMITED NO. M 12, MALAPPURAM P.O.,
MALAPPURAM DISTRICT-676507, REPRESENTED BY ITS
SECRETARY.
17 THE BANK EMPLOYEES CO-OPERATIVE SOCIETY,
2025:KER
W.P(C)No.7053/2023 & Connected cases 25
LIMITED NO. M 269, MALAPPURAM P.O., MALAPPURAM
DISTRICT-673329, REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER (TDS),
AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE-
673001.
4 THE MALAPPURAM DISTRICT CO-OPERATIVE,
BANK LIMITED, DISTRICT CO-OPERATIVE BANK BUILDING,
MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN-
676505.
5 THE KERALA STATE CO-OPERATIVE BANK LIMITED,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
6 THE KOTTAKKAL URBAN CO-OPERATIVE LIMITED,
KOTTAKKAL, MALAPPURAM DISTRICT, REPRESENTED BY ITS
GENERAL MANAGER, PIN-676501.
7 THE URBAN CO-OPERATIVE BANK LIMITED,
PERINTHALMANNA, MALAPPURAM DISTRICT, REPRESENTED BY
ITS GENERAL MANAGER, PIN-679321.
8 THE NILAMBUR CO-OPERATIVE URBAN LIMITED
NILAMBUR, MALAPPURAM DISTRICT, REPRESENTED BY ITS
GENERAL MANAGER, PIN-676542.
9 THE MANJERI CO-OPERATIVE URBAN BANK LIMITED,
2025:KER
W.P(C)No.7053/2023 & Connected cases 26
MANJERI, MALAPPURAM DISTRICT, REPRESENTED BY ITS
GENERAL MANAGER, PIN-676121.
10 THE TIRUR URBAN CO-OPERATIVE LIMITED,
TIRUR, MALAPPURAM DISTRICT, REPRESENTED BY ITS
GENERAL MANAGER, PIN-676101.
11 THE PONNANI CO-OPERATIVE URBAN BANK LIMITED,
PONNANI, MALAPPURAM DISTRICT, REPRESENTED BY ITS
GENERAL MANAGER, PIN-679577.
BY ADVS.
SHRI.A.K.HARIDAS, CGC
SRI.GILBERT GEORGE CORREYA
SRI.K.M.SATHYANATHA MENON
SHRI.K.VIDYASAGAR
SHRI.D.SOMASUNDARAM
SMT.KAVERY S THAMPI
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 27
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 736 OF 2022
PETITIONER/S:
1 PONMUNDAM CO-OPERATIVE URBAN SOCIETY LTD.
NO. M 637, VAILATHUR, PONMUNDAM P.O., MALAPPURAM
DISTRICT, PIN-676106, REPRESENTED BY ITS SECRETARY
A.P. SASIKUMAR.
2 KADUNGATHUKUND RURAL CO-OPERATIVE SOCIETY LIMITED
NO. M 996, KADUNGATHUKUND, KALPAKANCHERY P.O.,
MALAPPURAM DISTRICT-676551, REPRESENTED BY ITS
SECRETARY MASHHURA KOLLAM THODI.
3 PONNANI TALUK MERCANTILE CO-OPERATIVE SOCIETY LIMITED
NO. M.765. C.R. TOWER, EDAPPAL P.O., MALAPPURAM
DISTRICT, PIN-679576, REPRESENTED BY ITS SECRETARY,
SUJITH S.
4 PONNANI TALUK SCHOOL TEACHERS
CO-OPERATIVE SOCIETY LIMITED NO. M 500, PONNANI P.O.,
PONNANI SOUTH, MALAPPURAM DISTRICT-679586,
REPRESENTED BY ITS SECRETARY SINDHU P. PALLANGHATT.
5 PONNANI VANITHA CO-OPERATIVE SOCIETY LIMITED
NO. M 715, PONNANI P.O., MALAPPURAM DISTRICT-679577,
REPRESENTED BY ITS SECRETARY KAVITHA P.
6 THE PONNANI TALUK URBAN CO-OPERATIVE SOCIETY LIMITED
NO. M 945, ERIKKAMANNA, PONNANI P.O., MALAPPURAM
DISTRICT-679577, REPRESENTED BY ITS SECRETARY SMITHA.
7 KALADI GRAMA PANCHAYATH RURAL CO-OPERATIVE
SOCIETY M -905 10, P.O. NARIPARAMBA, MALAPPURAM
DISTRICT-679573, REPRESENTED BY ITS SECRETARY RATHI
2025:KER
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K.
8 THAVANOOR VANITHA CO-OPERATIVE SOCIETY LIMITED
NO. M 736, ATHALOOR P.O., MALAPPURAM DISTRICT-679573,
REPRESENTED BY ITS SECRETARY RAJITHA E.
9 THENHIPPALAM PANCHAYATH VANITHA CO-OPERATIVE SOCIETY
LIMITED
NO. 856, KOHINOOR P.O., CALICUT UNIVERSITY,
MALAPPURAM DISTRICT-673636, REPRESENTED BY ITS
SECRETARY BINSI P.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-
682018.
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O., MALAPPURAM DISTRICT-676101.
4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LIMITED,
HEAD OFFICE, MANJERI ROAD, MALAPPURAM-676505,
REPRESENTED BY ITS GENERAL MANAGER.
5 MANJERI CO-OPERATIVE URBAN BANK LIMITED,
MANJERI, TIRUR, MALAPPURAM DISTRICT-676121,
REPRESENTED BY ITS GENERAL MANAGER.
6 PONANI CO-OPERATIVE URBAN BANK LIMITED,
2025:KER
W.P(C)No.7053/2023 & Connected cases 29
HEAD OFFICE, K.K. JUNCTION, PONNANI, MALAPPURAM
DISTRICT, KERALA -691001, REPRESENTED BY ITS GENERAL
MANAGER.
7 TIRUR URBAN CO-OPERATIVE BANK LIMITED,
HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA-
676101, REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
SHRI.JOSEPH RONY JOSE, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.GILBERT GEORGE CORREYA
SRI.SHOBY K.FRANCIS
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 30
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 833 OF 2022
PETITIONER/S:
THE ELAMKULAM SERVICE CO-OPERATIVE BANK LTD
NO.F 1536, KUNNAKAVU P.O., MALAPPURAM DISTRICT-679
323, REPRESENTED BY ITS SECRETARY
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S PRESS ROAD,
ERNAKULAM,PIN-682 018
3 THE INCOME TAX OFFICER (TDS),
AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA,
KOZHIKODE,PIN-673 001
4 THE MALAPPUAM DITRICT CO-OPERATIVE BANK LTD,
DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM,
REPRESENTED BY ITS GENERAL MANAGER,PIN-676 505
5 THE KERALA STATE CO-OPERAIVE BANK LTD,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033
2025:KER
W.P(C)No.7053/2023 & Connected cases 31
6 THE URBAN CO-OPERATIVE BANK LTD.,
PERINTHALMANNA, MALAPPURAM DISTRICT,REPRESENTED BY
ITS GENERAL MANAGER, PIN-679 321
BY ADVS.
SHRI.VISHNU PRADEEP, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.GILBERT GEORGE CORREYA
SMT.JAYASREE K.P.
SHRI.JOHN JOSEPH
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 32
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 1383 OF 2022
PETITIONER/S:
1 NILAMBUR TALUK CO-OPERATIVE EDUCATIONAL SOCIETY LTD.
NO.M 556
NILAMBUR P. O., MALAPPURAM DISTRICT, PIN - 679 329,
REPRESENTED BY ITS SECRETARY.
2 THE NILAMBUR KALIKAVU RANGE KALLU
X
3 THE KARUVARAKUNDU PANCHAYATH VANITHA CO-OPERATIVE
SOCIETY LIMITED M.601
KIZHEKKETHALA P. O., THARIS, MALAPPURAM DISTRICT, PIN
- 676 519, REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I. S. PRESS ROAD,
ERNAKULAM, PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE,
PIN - 673 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 33
4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD.
DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM,
REPRESENTED BY ITS GENERAL MANAGER, PIN - 676 505.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
6 THE URBAN CO-OPERATIVE BANK LTD.
PERINTHALMANNA, MALAPPURAM DISTRICT, REPRESENTED BY
ITS GENERAL MANAGER, PIN - 679 321.
7 THE NILAMBUR CO-OPERATIVE URBAN LTD.
NILAMBUR, MALAPPURAM DISTRICT, REPRESENTED BY ITS
GENERAL MANAGER, PIN - 676 542.
BY ADV SHRI.VISHNU RAJAGOPAL, CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 34
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 1633 OF 2022
PETITIONER/S:
1 KURUMBATHUR SERVICE CO-OPERATIVE BANK LTD NO. F-1769,
PUNNATHALA P.O, CHUNGAM, VALANCHERY, MALAPPURAM
DISTRICT, PIN 676 552 REPRESENTED BY ITS SECRETARY IN
CHARGE MOHAMMED SALEEM
2 ERANAND TALUK CO-OPERATIVE EDUCATIONAL SOCIETY LTD
NO. M-311
MANJERY P.O, MALAPPURAM DISTRICT, PIN 676 121
REPRESENTGED BY ITS SECRETARY JOB THOMAS M
3 ERANAD RURAL CO-OPERATIVE SOCIETY LTD NO. M 808,
MANJERY P.O, MALAPPURAM DISTRICT PIN 676 121
REPRESENTED BY ITS SECRETARY SHEEJA P
4 THE PARAPPUR VANITHA CO-OPERATIVE SOCIETY LTD NO. M
712
PARAPPUR P.O, VEENALUKKAL, MALAPPURAM DISTRICT, PIN
676 503 REPRESENTED BY ITS SECRETARY K.K JAMEELA
5 KOTTAKKAL AYURVEDA COLLEGE EMPLOYEES CO-OPERATIVE
SOCIETY LTD NO. M 479
EDARIKODE P.O, MALAPPURAM DISTRICT PIN 676 501
REPRESENTED BY ITS SECRETARY SRUTHI K
6 MANJERI MALAPPURAM RANGE KALLUCHETHU VYAVASAYA CO-
OPERATIVE SOCIETY LTD NO. M 615
MANJERI P.O, MALAPPURAM (D) PIN 676 121 REPRESENTING
ITS SECRETARY BINEESH E.V
2025:KER
W.P(C)No.7053/2023 & Connected cases 35
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THHE GOVERNMENT ,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001
2 THE COMMISSIOENR OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG. IS PRESS ROAD, KOCHI 682 018
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O, MALAPPURAM DISTRICT PIN 676 101
4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD
HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN 676 505
REPRESENTED BY ITS GENERAL MANAGER
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.GILBERT GEORGE CORREYA
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 36
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 1808 OF 2022
PETITIONER/S:
EDAKKARA RURAL CO OPERATIVE SOCIETY LTD.
NO.M 759, NILAMBUR TALUK, P O EDAKKARA MALAPPURAM
DISTRICT, PIN-679331., REPRESENTED BY ITS SECRETARY.
BY ADVS.
SHRI.K.J.MANU RAJ
SHRI.RAVI KRISHNAN
SMT.K.VINAYA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER (TDS)
AYAKAR BHAVAN, NORTH BLOCK, MAMAMCHIRA, KOZHIKODE-
673001.
4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD
DISTRICT CO-OPERATIVE BUILDING, MALAPPURAM,
REPRESENTED BY ITS GENERAL MANAGER-676505.
5 THE KERALA STATE CO-OPERATIVE BANK LTD
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR-695033.
6 THE NILAMBUR CO-OPERATIVE URBAN BANK.
NO.F.1043, HEAD OFFICE NILAMBUR, MALAPPURAM DISTRICT-
679329., REPRESENTED BY ITS GENERAL MANAGER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 37
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.P.J.DEVAPRASANTH,SC,NILAMBUR CO.OP
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 38
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 1943 OF 2022
PETITIONER/S:
THE KUMARANALLUR CO-OPERATIVE SERVICE BANK LTD.
F.970, KUMARANALLUR P.O., PALAKKAD DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN-679 552
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO
GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI-110 001
2 THE COMMISSIONER OF INCOME TAX (TDS)CENTRAL REVENUE
BUILDING, IS PRESS ROAD, ERNAKULAM,PIN-682 018
3 THE INCOME TAX OFFICER (TDS),AYAKAR BHAVAN, NORTH
BLOCK, MANANCHIRA, KOZHIKODE,PIN-673 001
4 THE MALAPPURAM DISTRICT CO-OPERTIVE BANK LTD,.
DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM,
REPRESENTED BY ITS GENERAL MANGER, PIN-676 505
5 THE PONNANI URBAN CO-OPERATIVE BANK LTD,PONNANI,
MALAPPURAM DISTRICT REPRESENTED BY ITS GENERAL
MANAGE, PIN-676 505
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,COBANK
TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY
ITS MANAGING DIRECTOR, PIN-695 033
BY ADVS.
SHRI.P.R.AJITH KUMAR, CGC
SRI.SHOBY K.FRANCIS
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 39
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 2208 OF 2022
PETITIONER/S:
THE PERINTALMANNA TALUK CO-OPERATIVE EDUCATIONAL
SOCIETY LTD.NO M 358,
PERINTALMANNA, MALAPPURAM DISTRICT, PIN-679 321,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA,REPRESENTED BY THE SECRETARY TO
GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI-110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE
BUILDING, IS PRESS ROAD, ERNAKULAM, PIN-682 018.
3 THE INCOME TAX OFFICER (TDS), AYAKAR BHAVAN, NORTH
BLOCK, MANANCHIRA, KOZHIKODE, PIN-673 001.
4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD.,
DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM,
REPRESNETED BY ITS GENERAL MANAGER, PIN-676 505.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033.
BY ADV SHRI.VISHNU PRADEEP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 40
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 2780 OF 2022
PETITIONER/S:
MALAPPURAM VANITHA CO-OPERATIVE SOCIETY LTD NO.M-789
JUBILEE ROAD, MALAPPURAM P.O, MALAPPURAM DISTRICT,
PIN 676 505 REPRESENTED BY ITS SECRETARY SHAHARBAN
PULLIYIL
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT ,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O, MALAPPURAM DISTRICT, PIN 676 101
4 MALAPPURAM DISTRICT CO-OPERATIVE SOCIETY LTD,
HEAD OFFICE, MANJERI, ROAD, MALAPPURAM, PIN 676 505,
REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
SHRI.P.R.AJITH KUMAR, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 41
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 3734 OF 2022
PETITIONER/S:
1 SREE VELLAYANI RESIDENTIAL WELFARE CO-OPERATIVE
SOCIETY LTD. NO.T-1591,
OOKKODE, REPRESENTED BY ITS SECRETARY.
2 UPANIYOOR GRAMODHARANA CO-OPERATIVE SOCIETY LTD.
NO.2782,
OOKKODE P.O., NEMOM, PIN-695020, REPRESENTED BY ITS
SECRETARY.
3 SREE VELLAYANI AGRICULTURE IMPROVEMENT CO-OPERATIVE
SOCIETY LTD. T. NO.1728,
SANTHIVILLA MARKET JUNCTION, NEMOM P.O.,
THIRUVANANTHAPURAM, REPRESENTED BY ITS SECRETARY.
4 COLLECTION AGENTS CO-OPERATIVE SOCIETY LTD. T.
NO.1671,
T.C.71/2766 (3), R D SQUARE, KILLIPALLAM, CHALAI
P.O., THIRUVANANTHAPURAM, REPRESENTED BY ITS
SECRETARY.
BY ADVS.
SRI.A.CHANDRA BABU
SMT.REMYA MURALI
SMT.APARNA SARASWATI
RESPONDENT/S:
2025:KER
W.P(C)No.7053/2023 & Connected cases 42
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILLS, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER, (TDS),
AAYAKAR BHAVAN, PEROORKADA RD., KOWDIAR,
THIRUVANANTHAPURAM, KERALA-695003.
4 THE KERALA STATE CO-OPERATIVE BANK,
REGIONAL OFFICE, EAST FORT, FORT P.O.,
THIRUVANANTHAPURAM.
5 THE KERALA STATE CO-OPERATIVE BANK,
KALLIYOOR BRANCH, KALLIYOOR P.O., THIRUVANANTHAPURAM.
6 THE KERALA STATE CO-OPERATIVE BANK,
CHALAI BRANCH, EAST FORT, FORT P.O.,
THIRUVANANTHAPURAM.
BY ADVS.
SRI.NAVANEETH.N.NATH
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 43
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 4385 OF 2022
PETITIONER/S:
KOLLAM NORTH RESIDENCE WELFARE CO-OPERATIVE SOCIETY
LTD.NO.Q 1537
REPRESENTED BY ITS SECRETARY, KADAVOOR, PERINAD P.O.,
KOLLAM DISTRICT, PIN-691601.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 INCOME TAX OFFICER
WARD-2, AAYAKAR BHAVAN, INCOME TAX OFFICE, NEAR
KARBALA JUNCTION, KOLLAM, PIN-691001.
2 THE ADDITIONAL COMMISSIONER OF INCOME TAX,
OFFICE OF THE ADDL. COMMISSIONER OF INCOME TAX, TDS
RANGE, II FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.,
THIRUVANANTHAPURAM, PIN-695003.
3 THE CENTRAL BOARD OF DIRECTOR TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110001.
4 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
2025:KER
W.P(C)No.7053/2023 & Connected cases 44
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI-110001.
5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
THIRUVANANTHAPURAM-695001.
6 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN-695001.
7 THE KERALA STATE CO-OPERATIVE BANK (ERSTWHILE KOLLAM
DISTRICT CO-OPERATIVE BANK),
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN-695033.
BY ADVS.
SRI.CHRISTOPHER ABRAHAM
SHRI.NAVANEETH.N.NATH, CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 45
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 4442 OF 2022
PETITIONER/S:
AVANAKUZHY SERVICE CO-OPERATIVE BANK LTD. NO.2387,
HEAD OFFICE, THANNIMMOODU P. O., AVANAKUZHI,
THIRUVANANTHAPURAM - 695501, REPRESNETED BY ITS
SECRETARY JAYASREE P. S.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110
001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
2025:KER
W.P(C)No.7053/2023 & Connected cases 46
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI - 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM - 695003.
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KAWADIAR, THIRUVANANTHAPURAM - 695003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS
CHIEF EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
SRI.NAVANEETH.N.NATH
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 47
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 4996 OF 2022
PETITIONER/S:
PERUMBADAPPU BLOCK PANCHAYATH COCONUT PROCESSING AND
MARKETING CO-OPERATIVE SOCIETY
NO.M.628, REP. BY ITS SECRETARY, ERAMANGALAM,
MALAPPURAM - 679 579
BY ADV SRI.S.MOHAMMED AL RAFI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI-682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM - 695 003.
5 INCOME TAX OFFICER (TDS)
2025:KER
W.P(C)No.7053/2023 & Connected cases 48
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM - 695 003.
6 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD.
REPRESENTED BY ITS GENERAL MANAGER, MALAPPURAM - 676
505.
7 THE SENIOR MANAGER
MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD.,
ERAMANGALAM BRANCH, MALAPPURAM - 679 579
8 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
SHRI.NAVANEETH.N.NATH, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 49
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 5569 OF 2022
PETITIONER/S:
THE KERALA STATE CO-OPERATIVE BANK LTD.,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, COBANK
TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033.
BY ADV SHRI.B.G.HARINDRANATH (SR.)
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY, MINISTRY OF FINANCE,
NORTH BLOCK, RAISENA HILL, NEW DELHI-110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
AYAKAR BHAVAN KOWDIAR, THIRUVANANTHAPURAM-695 003.
BY ADV SRI.NAVANEETH.N.NATH
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 50
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 5900 OF 2022
PETITIONER/S:
1 MOONNIYUR PANCHAYATH VANITHA CO-OPERATIVE SOCIETY
LTD.NO.M.992
P.O. CHELARI, VELIMUKKU P.O, MALAPPURAM (DT), PIN -
676317, REPRESENTED BY ITS SECRETARY NEETHU DAS M.
2 ANAKKAYAM RURAL CO-OPERATIVE SOCIETY LTD,
NO.M.816, ANAKKAYAM P.O, MALAPPURAM (DT), PIN -
676317, REPRESENTED BY ITS SECRETARY DHANYA K.C.
3 MANJERI MUNICIPAL VANITHA SAHAKARANA SANGAM LTD.NO.
M.519.
COURT ROAD, MANJERI P.O, MALAPPURAM DISTRICT, PIN -
676121, REPRESENTED BY ITS SECRETARY USHAKUMARI C.K.
4 MALAPPURAM DISTRICT BUILDING & OTHER CONSTRUCTION
WORKERS CONTRACT CO-OPERATIVE SOCIETY LTD,
NO.M 772, UP HILL, MALAPPURAM P.O, PIN - 676505,
REPRESENTED BY SECRETARY SHEENA M.
5 MALAPPURAM DISTRICT. ANGANWADI WORKERS & HELPERS CO-
OPERATIVE SOCIETY LTD NO.M. 756.
MALAPPURAM P.O, PIN - 676505, REPRESENTED BY ITS
SECRETARY, NAFEESA C.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
2025:KER
W.P(C)No.7053/2023 & Connected cases 51
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI -
682018.
3 THE INCOME TAX OFFICER(TDS)
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O, MALAPPURAM DISTRICT, PIN - 676101.
4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD,
HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN - 676505,
REPRESENTED BY ITS GENERAL MANAGER.
5 CO-OPERATIVE URBAN BANK LTD NO. 1758,
PERINTHALMANNA, PERINTHALMANNA P.O, PIN - 679322,
REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.GILBERT GEORGE CORREYA
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 52
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 8026 OF 2022
PETITIONER/S:
1 PAYYANNUR CO-OPERATIVE RURAL BANK LTD
NO.F1234, HEAD OFFICE PAYYANNUR, PAYYANNUR P. O.,
KANNUR - 670307, REPRESENTED BY ITS SECRETARY RAJAN
E.
2 PAPPINISSERI CO-OPERATIVE RURAL BANK LTD. NO.F 1321
KALLIASSERI P. O., KALLIASSERI, KANNUR - 670562.,
REPRESENTED BY ITS SECRETARY AMBUJAKSHI K.
3 MADAYI CO-OPERATIVE RURAL BANK LTD.
HEAD OFFICE, PAYANGADI, PAYANGADI P. O., KANNUR -
670303., REPRESENTED BY ITS SECRETARY P. VIMALA.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
2025:KER
W.P(C)No.7053/2023 & Connected cases 53
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110
001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI - 682018.
4 PRINCIPAL COMMISSIONER OF INCOME OF TAX
KOZHIKODE, AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE -
673001.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
P. B. NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS
CHIEF EXECUTIVE OFFICER.
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY(CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 54
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 8742 OF 2022
PETITIONER/S:
CHERUTHAZHAM SERVICE CO-OPERATIVE BANK LTD.
NO. F 747, HO PILATHARA, P.O. PILATHARA, KANNUR-
670504, REPRESENTED BY ITS SECRETARY, DAMODARAN K
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTER OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTER OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 55
INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD,
KOCHI-682018.
4 THE PRINCIPAL COMMISSIONER OF CENTRAL TAX,
KOZHIKODE, AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE-
673001.
5 INCOME TAX OFFICER,
TDS, WARD TDS, KANNUR, AYAKAR BHAVAN, OFFICE OF THE
ADDITIONAL COMMISSIONER OF INCOME TAX, KANNOTHUMCHAL,
CHOVVA P.O., KANNUR-670006.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695001.
BY ADVS.
SMT.STINNIE JOHN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 56
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 8943 OF 2023
PETITIONER/S:
VENGANOOR SERVICE CO-OPERATIVE BANK LTD,
NO 1446, VENGANOOR P.O., THIRUVANANTHAPURAM-
REPRESENTED BY ITS SECRETARY BIMIL KUMAR S A, PIN -
695523
BY ADVS.
DR.K.P.PRADEEP
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SHRI.HAREESH M.R.
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- ,
REPRESENTED BY ITS CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
2025:KER
W.P(C)No.7053/2023 & Connected cases 57
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-, PIN - 682018
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM, PIN - 695003
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003
6 THE KERALA STATE CO-OPERATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN - 695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 58
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10465 OF 2022
PETITIONER/S:
1 PALODE SERVICE CO-OPERATIVE BANK LTD
NO 792, CO-OPERATIVE BUILDING, PALODE KARIMANCODE,
THIRUVANANTHAPURAM 695 562 REPRESENTED BY ITS
SECRETARY, REKHA V.O
2 UZHAMALACKAL SERVICE CO-OPERATIVE BANK LTD NO. T 298,
PUTHUKULANGARA P.O, THIRUVANANTHAPURAM, REPRESENTED
BY ITS SECRETARY ASHA K.S
3 NANNIYODE SERVICE CO-OPERATIVE BANK LTD
NO 1161, NANNIYODE, PACHA P.O, NEDUMANGAD
THIRUVANANTHAPURAM 695 562 REPRESENTED BY ITS
SECRETARY, P LATHAKUMARI
4 MUNDELA SERVICE CO-OPERATIVE BANK LIMITED NO 2433,
MUNDELA P.O, THIRUVANANTHAPURAM 695 543 REPRESENTED
BY ITS SECRETARY RAHUL P.S
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 59
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE , MINISTRY OF FINANCE
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM 695 003
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM , 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANNATHAPURAM 695 003
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
P.B NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 60
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10480 OF 2022
PETITIONER/S:
1 KAZHAKUTTOM SERVICE CO-OPERATIVE BANK LTD. NO. 1457
KAZHAKUTTOM P.O, THIRUVANANTHAPURAM 695 582
REPRESENTED BY ITS SECRETARY ANIL KUMAR S
2 AKKULAM CO-OPERATIVE SOCIETY LTD
NOT 1213, THURUVICAL P.O, THIRUVANANTHAPURAM 695 011
REPRESENTED BY ITS SECRETARY LATHAKUMARI S
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK, NEW DELHI 110 001 REPRESENTED
2025:KER
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BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM 695 003
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM 695 003
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001
BY ADVS.
SHRI.VISHNU PRADEEP, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 62
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10498 OF 2022
PETITIONER/S:
1 THIRUVANANTHAPURAM DISTRICT ELECTRICITY BOARD
EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.3039, POWER
HOUSE, CHALA P O, THIURVANANTHAPURAM-695036,
REPRESENTED BY ITS SECRETARY.
2 KERALA STATE TRANSPORT WORKERS CO-OPERATIVE SOCIETY
LTD NO.RT.133.
S S KOVIL ROAD, THAMPANOOR, THIRUVANANTHAPURAM-
695001, REPRESENTED BY ITS SECRETARY.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-
2 THE COMMISSIONR OF INCOME TAX (TDS_
C R BUILDING, I S PRESS ROAD, KOCHI-682018.
3 THE COMMISSIONER TAX OFFICER (TDS)
3RD FLOOR AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003.
4 THE INCOME TAX OFFICER (TDS_
3RD FLOOR AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003.
2025:KER
W.P(C)No.7053/2023 & Connected cases 63
5 KERALA STATE CO-OPERATIVE BANK LTD.,
(KERALA BANK), REGIONAL OFFICE, EAST FORT P O,
THIRUVANANTHAPURAM-695023, REPRESENTED BY ITS
REGIONAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 64
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10692 OF 2022
PETITIONER/S:
THE PAPPINIVATTAM SERVICE CO-OPERATIVE BANK LTD. NO.
R.309,
P.O. MATHILAKAM, KODUNGALLUR, THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM-
682018.
2 THE INCOME TAX OFFICER (TDS),
INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR-
680001.
3 THE KERALA STATE CO-OPERATIVE BANK LIMITED,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
4 THE MANAGER,
KERALA STATE CO-OPERATIVE BANK LIMITED, S.N. PURAM,
THRISSUR-680665.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 65
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10697 OF 2022
PETITIONER/S:
THE KALAMASSERY SERVICE CO-OPERATIVE BANK LTD
NO E 661, KODUVAZHANGA, NEERICODE P.O, ERNAKULAM
DISTRICT, REPRESENTED BY ITS SECRETARY PIN 683 511
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM,
PIN 682 018
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, I.S PRESS ROAD, ERNAKULAM PIN
682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033
5 THE MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, KALAMASSERY,
PATHADIPALAM BRANCH, ERNAKULAM, PIN 683104
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 66
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 67
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10699 OF 2022
PETITIONER/S:
THE PARUR TALUK CO-OPERATIVE EMPLOYEES'
CO-OPERATIVE SOCIETY LTD NO.K.736, NORTH PARUR,
ERNAKULAM DISTRICT, REPRESENTED BY ITS PRESIDENT.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
2 THE INCOME TAX OFFICER (TDS),
INCOME TAX DEPARTMENT SHAKTAN NAGAR, THRISSUR-680001.
3 THE KERALA STATE CO-OPERATIVE BANK LIMITED,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
4 THE MANAGER,
KERALA STATE CO-OPERATIVE BANK LIMITED, NORTH APRUR
MAIN BRANCH, NORTH PARUR-683513.
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 68
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10705 OF 2022
PETITIONER/S:
THE ALANGAD CO-OPERATIVE BANK LTD.,
NO. E-661 KODUVAZHANGA, NEERICODE P.O., ERNAKULAM
DISTRICT, REPRESENTED BY ITS SECRETARY 683 511.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM
682 018.
3 THE INCOME TAX OFFICER, (TDS),
INCOME TAX DEPARTMENT, I.S. PRESS ROAD, ERNAKULAM 682
018.
4 THE KERALA STATE CO - OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, 695 033
5 THE MANAGER ,
KERALA STATE CO - OPERATIVE BANK LTD.,ALUVA MAIN
BRANCH, ERNAKULAM, 683 101.
2025:KER
W.P(C)No.7053/2023 & Connected cases 69
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 70
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10717 OF 2022
PETITIONER/S:
1 BALARAMAPURAM SERVICE CO-OPERATIVE BANK LTD T/14
BALARAMAPURAM, THIRUVANANTHAPURAM - 695 501,
REPRESENTED BY ITS SECRETARY JAFERKHAN A.
2 PATTOM SERVICE CO-OPERATIVE BANK LTD.NO.T.1318
MEDICAL COLLEGE, KANNAMMOOLA P.O., TRIVANDRUM - 695
011, REPRESENTED BY ITS SECRETARY SREEJI S.
3 MUTTATHARA SERVICE CO-OPERATIVE BANK LTD.
TC 42/942(1), MUTTATHARA, VALLAKKADAVU P.O.,
THIRUVANANTHAPOURAM - 695 008 REPRESENTED BY ITS
SECRETARY NIRMAL V.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 71
2 THE CENTRAL BOARD OF DIRECTOR TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110
001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, 1 S PRESS ROAD,
KOCHI - 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM - 695 003.
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM - 695 003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695
001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 72
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10719 OF 2022
PETITIONER/S:
1 KEEZHILLAM SERVICE CO-OPERATIVE BANK LTD.NO.E3989,
KEEZHILLAM P.O., ERNAKULAM DISTRICT, PIN-683 541,
REPRESENTED BY ITS SECRETARY.
2 PERUMBAVOOR SERVICE CO OPERATIVE BANK LTD.NO.802,
VALLAM, RAYONPURAM P.O., ERNAKULAM DISTRICT, PIN-683
543, REPRESENTED BY ITS SECRETARY.
3 AYYAMPUZHA SERVICE CO OPERATIVE BANK LTD.NO.E788,
AYYAMPUZHA P/.O., ERNAKULAM DISTRICT, PIN-683 581,
REPRESENTED BY ITS SECRETARY.
4 THE CHOWARA SERVICE CO OPERATIVE BANK LTD. NO.587,
CHOWARA P.O., ALUVA, ERNAKULAM DISTRICT, PIN-683 571,
REPRESENTED BY ITS SECRETARY.
5 SREEMOOLANAGARA SERVICE CO OPERATIVE BANK
LTD.NO.4178,
SREEMOOLANAGARA P.O., ERNAKULAM DISTRICT, PIN-683
580, REPRESENTED BY ITS SECRETARY.
6 OKKAL AGRICULTURAL IMPROVEMENT SERVICE CO OPERATIVE
SOCIETY NO.E 1215,
OKKAL P.O., ERNAKULAM DISTRICT, PIN-683 550,
REPRESENTED BY ITS SECRETARY.
7 THE KANAJOOR SERVICE CO-OPERATIVE BANK LTD.NO.454,
KANJOOR P.O., ALUVA TALUK, ERNAKULAM DISTRICT, PIN-
683 575, REPRESENTED BY ITS SECRETARY.
2025:KER
W.P(C)No.7053/2023 & Connected cases 73
8 KARAYAMPARAMBU SERVICE CO OPERATIVE BANK LTD.NO.1573,
VALLAM, RAYONPURAM P.O., ERNAKULAM DISTRICT, PIN-683
543, REPRESENTED BY ITS SECRETARY.
9 GOVENRMENT SERVANTS CO-OPERATIVE SOCIETY LTD.NO.131,
PERUMBAVOOR P.O., ERNAKULAM DISTRICT, PIN-683 542,
REPRESENTED BY ITS HON.SECRETARY.
0 PERUMBAVOOR KSRTC EMPLOYEES CO OPERATIVE SOCIETY
LTD.NO.E783,
PERUMBAVOOR P.O., ERNAKULAM DISTRICT, PIN-683 542,
REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.M.M.MONAYE
SHRI.M.PAUL VARGHESE
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI, PIN-110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES.,
ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW
DELHI-110 001, REPRESENTED BY ITS CHAIRPERSON.
3 COMMISSIONER OF INCOME TAX (TDS),
C.R.BUILDINGS, I.S PRESS ROAD, ERNAKULAM-682 018.
4 STATE OF KERALA,
DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, REPRESENTED BY SECRETARY TO
GOVERNMENT.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIEITES,
STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM.
2025:KER
W.P(C)No.7053/2023 & Connected cases 74
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
7 DEPUTY GENERAL MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., CREDIT
PROCESSING CENTRE, KAKKANAD, KOCHI-682 030.
BY ADVS.
SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 75
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10720 OF 2022
PETITIONER/S:
1 VAZHAKKULAM BLOCK RURAL CO-OPERATIVE SOCIETY LTD
E-1082, MEKKAD P.O., ERNAKULAM-683 547, REPRESENTED
BY SECRETARY JYOTHIMOL.E.J.
2 KOOVAPPADY BLOCK RURAL CO-OPERATIVE BANK LTD.,
E-1083, KURUPPAMPADY P.O., ERNAKULAM-683 545,
REPRESENTED BY ITS SECRETARY M.Y.ELDHOSE
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECTOR TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
2025:KER
W.P(C)No.7053/2023 & Connected cases 76
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD,
KOCHI-682 018
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM-695 003
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM , 3RD FLOOR, AATAKAR BHAVAN,
KAWADIAR, THIRUVANANTHAPURAM-695 003
6 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 77
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10721 OF 2022
PETITIONER/S:
THE POOMANGALAM SERVICE CO-OPERATIVE BANK LTD
NO.R 712.H.O.ARIPALAM POOMANGALAM, THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (T D S)
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD,
ERNAKULAM.PIN- 682 018.
2 THE INCOME TAX OFFICER, (T.D.S)
INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR, PIN
680 001.
3 THE KERALA STATE CO-OPERATIVE BANKLTD.
COBANK TOWERS, PALAYAM,THIRUVANANTHAPURAM,,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033
4 THE MNAGER
KERALA STATE CO-OPERATIVE BANK LTD, VELLANGALLUR.,
THRISSUR, PIN-680 662
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 78
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10722 OF 2022
PETITIONER/S:
THE MADAPPALLY SERVICE CO-OPERATIVE BANK LTD
NO.160, PERUMPANACHY P.O., CHEGANACHERRY, KOTTAYAM
DISTRICT, REPRESENTED BY ITS SECRETARY
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682 018
2 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, KOTTAYAM, PIN-686 001
3 TH KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033
4 THE MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., PERUMPANACHY
BRANCH, KOTTAYAM DISTRICT, PIN-686 101
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 79
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10731 OF 2022
PETITIONER/S:
1 KURUPAMPADY SERVICE CO-OPERATIVE BANK LTD
HEAD OFFICE, P.O.KURUPPAMPADY, ERNAKULAM-683545,
REPRESENTED BY ITS SECRETARY JAYAPRAKASH N.
2 KRARIYELY SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, KRARIYELY, KOMBANADU P.O., ERNAKULAM-
683546, REPRESENTED BY ITS SECRETARY M.V.SHAJI.
3 VAZHAKKULAM SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, SOUTH VAZHAKKULAM P.O., ALUVA,
ERNAKULAM-683105, REPRESENTED BY ITS SECRETARY
RENJINI VASUDEVAN.
4 MALAYIDAMTHURUTH SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, MALAYIDAMTHURUTHU P.O., ERNAKULAM-
683561, REPRESENTED BY ITS SECRETARY IN CHARGE
T.A.THANKAPPAN.
5 KODANADU SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.KODANADU, ERNAKULAM-683544,
REPRESENTED BY ITS SECRETARY NEETHU G. KRISHNAN.
6 OKKAL SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.OKKAL, ERNAKULAM-683550, REPRESENTED
BY ITS SECRETARY ANJU T.S.
7 VENGOLA SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.VENGOLA, ERNAKULAM-683556,
REPRESENTED BY ITS SECRETARY SINDHU KUMAR.
2025:KER
W.P(C)No.7053/2023 & Connected cases 80
8 MARAMPALLY SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, MARAMPALLY P.O., ERNAKULAM-683105,
REPRESENTED BY ITS SECRETARY FATHIMA T.K.
9 ASAMANOOR SERVICE CO-OPERATIVE BANK LTD.NO.317,
HEAD OFFICE, ODAKKALI, ASAMANOOR P.O., ERNAKULAM-
683549, REPRESENTED BY SECRETARY KIRAN P. ASHOK.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM-695003.
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM-695003.
2025:KER
W.P(C)No.7053/2023 & Connected cases 81
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 82
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10735 OF 2022
PETITIONER/S:
OACHIRA SERVICE CO-OPERATIVE BANK LTD
NO.1391, OACHIRA P.O., KOLLAM-690 526, REPRESENTED BY
ITS SECRETARY MEERADEVI .V.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 83
INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD,
KOCHI-682 018
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM-695 002
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KAWADIAR, THIRUVANANTHAPURAM-695 002
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY )CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 84
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10738 OF 2022
PETITIONER/S:
1 THE ANNAMANADA SERVICE CO-OPERATIVE BANK LIMITED NO.
159
ANNAMANADA, CHALAKUDY TALUK, THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN 680 741
2 THE ASHTAMICHIRA SERVICE CO-OPERATIVE BANK LTD NO 325
ASHTAMICHIRA, CHALAKUDY TALUK , THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN 680 731
3 THE ANNALLOOR SERVICE CO-OPERATIVE BANK LTD NO. 445
ANNALLOOR, CHALAKUDY TALUK, THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN 680 731
4 THE IRANIKULAM THIRUMUKKULAM SERVICE CO-OPERATIVE
BANK LTD NO. 339, CHALAKUDY TALUK, IRANIKULAM,
THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN
680 734
5 THE POYYA CO-OPERATIVE BANK LTD NO. 812
POOPPATHY, THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY, PIN 680 733
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA NILL, NEW DELHI 110
2025:KER
W.P(C)No.7053/2023 & Connected cases 85
001
2 THE COMMISSIONER OF INCOME TAX(TDS)
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM,
PIN 682 018
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR PIN
680 001
4 THE KERALA STATE CO-OPERATIVE BANK LTD
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033
5 THE MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, MALA,
IRINJALAKUDA, THRISSUR PIN 680 732
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 86
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10741 OF 2022
PETITIONER/S:
THE KARALAM SERVICE CO-OPERATIVE BANK LTD. NO. 600
KIZHUTHANI, THANISSERY P.O., THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682018.
3 THE INCOME TAX OFFICER,
(TDS), INCOME TAX DEPARTMENT, SHAKTAN NAGAR,
THRISSUR, PIN-680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
5 THE MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., IRINJALAKUDA,
THRISSUR, PIN-680662.
2025:KER
W.P(C)No.7053/2023 & Connected cases 87
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 88
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10744 OF 2022
PETITIONER/S:
PONKUNNAM SERVICE CO-OPERATIVE BANK LTD NO.527
HEAD OFFICE, PONKUNNAM, KOTTAYAM-686 505, REPRESENTED
BY ITS SECRETARY GEETHA GOPINATH
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, DEPARTMENT OF REVENUE, MINISTRY OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 89
FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE
BUILDINGS, I S PRESS ROAD, KOCHI-682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 90
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10747 OF 2022
PETITIONER/S:
1 CHIRAKKADAVU SERVICE CO-OPERATIVE BANK LTD NO.2057
HEAD OFFICE, CHIRAKADAVU P.O,KOTTAYAM-686 520,
REPRESENTED BY ITS SECRETARY MERCY JOHN. .,
2 ELAMGULAM SERVICE CO OPERATIVE BANK LTD, NO 3576,
HEAD OFFICE, KOORALI P.O, KOTTAYAM-686 522,
REPRESENTED BY ITS SECRETARY SAJITHA M.P.
3 ELIKULAM SERVICE CO-OPERATIVE BANK LTD, K 158,
HEAD OFFICE, MADUKKAKUNNU P.O.KOTTAYAM-686 577,
REPRESENTED BY ITS SECRETARY, VIMALKUMAR T.M.
4 KANAMALA SERVICE CO-OPERATIVE BANK LTD, K 268,
HEAD OFFICE, ERUTHUAPUZHA, PAMPAVALLEY P.O.KOTTAYAM-
686 510, REPRESENTED BY ITS SECRETARY THARA THOMAS.
5 KANNIMALA SERVICE CO-OPERATIVE BANK LTD NO 3978,
HEAD OFFICE, KANNIMALA P.O.ERUMELY KOTTAYAM-686 509.
REPRESENTED BY ITS SECRETARY, BINNY M GEAORGE
6 KANJIRAPALLY SERVICE CO-OPERATIVE BANK LTD NO 2061,
HEAD OFFICE, KANJIRAPALLY, KOTTAYAM-686 507,
REPRESENTED BY ITS SECRETARY, SHAIJU FRANCIS
7 ERUMELY SERVICE CO-OPERATIVE BANK LTD K 113,
HEAD OFFICE, ERUMELY P.O.KOTTAYAM-686 509,
REPRESENTED BY ITS SECRETARY, ROSHINA IBRAHIM.
8 MUNDAKAYAM SERVICE CO-OPERATIVE BANK LTD K 122,
HEAD OFFICE, MUNDAKKAYAM, KOTTAYAM-686 513,
2025:KER
W.P(C)No.7053/2023 & Connected cases 91
REPRESENTED BY ITS SECRETARY, MINUMOL BABY.
9 PARATHODE SERVICE CO-OPERATIVE BANK LTD NO 3002,
HEAD OFFICE, VELICHIYANI, PARATHODE, P.O.KOTTAYAM-686
512, REPRESENTED BY ITS SECRETARY, REKHAMOL C.R.
0 MANIMALA SERVICE CO-OPERATIVE BANK LTD, K 641,
HEAD OFFICE, MANIMALA P.O.KOTTAYAM-686 543,
REPRESENTED BY ITS SECRETARY MANJU V.S.
11 KORUTHODU SERVICE CO-OPERATIVE BANK K 365,
HEAD OFFICE, KORUTHODU P.O.KANJIRAPALLY, KOTTAYAM-686
513, REPRESENTED BY ITS SECRETARY, BABU MATHEW.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED
BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE, BUILDINGS , I.S PRESS ROAD,
KOCHI-682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
2025:KER
W.P(C)No.7053/2023 & Connected cases 92
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
BY ADV SRI.CHRISTOPHER ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 93
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10787 OF 2022
PETITIONER/S:
THECHAMPAKARA SERVICE CO-OPERATIVE BANK LTDNO.3511,
KARUKACHAL, KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX(TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,
PIN-682 018.
2 THE INCOME TAX OFFICER (TDS),
INCOME TAX DEPARTMENT, KOTTAYAM, PIN-686 001.
3 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033.
4 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LTD.,
KARUKACHAL BRANCH, KOTTAYAM DISTRICT, PIN-686 539.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 94
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10799 OF 2022
PETITIONER/S:
1 THE NANDIPULAM SERVICE CO-OPERATIVE BANK LIMITED NO.
R2
NANDIPULAM P.O., THRISSUR DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN-680319.
2 THE THOTTIPPAL SERVICE CO-OPERATIVE BANK LIMITED
NO.634,
THOTTIPPAL, THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY.
3 THE PUDUKKAD TOWN SERVICE CO-OPERATIVE BANK LIMITED
NO.R 1306,
PUDUKKAD P.O., THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY.
4 THE INCHAKUNDU SERVICE CO-OPERATIVE BANK LIMITED NO.
R 197,
INCHAKUNDU, THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY.
5 THE VARANTHARAPPILLY SERVICE CO-OPERATIVE BANK
LIMITED NO.450,
VARANTHARAPPILLY, THRISSUR DISTRICT, REPRESENTED BY
ITS SECRETARY.
6 THE AMBALLUR SERVICE CO-OPERATIVE BANK LIMITED
NO.503,
MANNAMPETTA, VARAKARA P.O., THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN-680302.
7 THE VELLIKULANGARA SERVICE CO-OPERATIVE BANK LIMITED
2025:KER
W.P(C)No.7053/2023 & Connected cases 95
NO.425,
VELLIKULANGARA, THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY.
8 THE KODAKARA FARMERS SERVICE CO-OPERATIVE BANK
LIMITED NO.R-761,
KODAKARA P.O., THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY.
9 THE KODUSSERY ELINJIPRA SERVICE CO-OPERATIVE BANK
LIMITED NO.R 228,
KODUSSERY P.O., THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY, PIN-680721.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682018.
3 THE INCOME TAX OFFICER,
(TDS), INCOME TAX DEPARTMENT, SHAKTAN NAGAR,
THRISSUR, PIN-680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
BY ADVS.
SRI.R.MURALEEKRISHNAN (MALAKKARA)
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 96
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10810 OF 2022
PETITIONER/S:
KUZHUR SERVICE CO-OPERATIVE BANK LIMITED
KUZHUR.P.O, THRISSUR, PIN-680734, REPRESENTED BY ITS
SECRETARY SUNITHA.V.R.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SHRI.RAJATH R NATH
SMT.G.REMADEVI
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI-110001.
2 COMMISSIONER OF INCOME TAX(TDS),
CENTRAL REVENUE BUILDING,I S PRESS ROAD, KOCHI-
682018.
3 THE INCOME TAX OFFICER(TDS),
AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR, PIN-680001.
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE,GOVERNMENT OF INDIA, NORTH BLOCK,
2025:KER
W.P(C)No.7053/2023 & Connected cases 97
NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN.
5 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
6 THE ADDITIONAL COMMISSIONER OF INCOME TAX
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003.
7 THE KERALA STATE CO-OPERATIVE BANK LTD.(KERALA BANK),
PO NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN-695033, REPRESENTED BY ITS
MANAGING DIRECTOR.
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY(CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM,PIN-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 98
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10818 OF 2022
PETITIONER/S:
KORATTY SERVICE CO-OPERTIVE BANK LTD NO.628
KORATTY, THRISSUR, PIN-680 308, REPRESENTED BY ITS
SECRETARY SANIL KUMAR N.G.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SMT.HARIMA HARIHARAN
SHRI.RAJATH R NATH
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF
REVENUE,MINISTRY OF FINANCE GOVERNMENT OF INDIA,
NORTH BLOCK, NEW DELHI-110 001
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, KOCHI-682
018
3 THE INCOME TAX OFFICER (TDS),
AAYAKAR BHAVAN, SAKTHAN THAMPURAM NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR,PIN-680 001
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 99
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001,REPRESENTED BY ITS CHAIRMAN
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS.PRESS ROAD,
KOCHI-682 018
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003
7 THE KERALA STATE CO-OPERATIVE BANK LTD (KERALA BANK),
PO NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM,PIN-695 033, REPRESENTED BY ITS
MANAGING DIRECTOR.
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM,PIN-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 100
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10828 OF 2022
PETITIONER/S:
KALLAMKUNNU SERVICE CO-OPREATIVE BANK LIMITED,
KALLAMKUNNU P.O., NADAVARAMBA, THRISSUR, 680 661,
REPRESENTED BY ITS SECRETARY GANESH C.K.,
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SHRI.RAJATH R NATH
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY , DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI 110001.
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI 682
018.
3 THE INCOME TAX OFFICER, (TDS),
AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR 680 001.
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 101
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 11001, REPRESENTED BY TIS CHAIRMAN.
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD ,
KOCHI 682 018.
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE , 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM 695 003.
7 THE KERALA STATE CO -OPERATIVE BANK LTD,
(KERALA BANK), P.O. NO. 6515, CO- BANK TOWERS,
PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY
ITS MANAGING DIRECTOR.
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM 695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 102
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10831 OF 2022
PETITIONER/S:
CHALAKUDY SERVICE CO-OPERATIVE BANK LIMITED,
NO. R 192, CHALAKUDY P.O, THRISSUR DISTRICT, 680 307,
REPRESENTED BY ITS SECRETARY SABIN K.P.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SHRI.RAJATH R NATH
SMT.G.REMADEVI
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH
BLOCK , NEW DELHI 110 001.
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI 682
018.
3 THE INCOME TAX OFFICER (TDS),
AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR, PIN 680 001.
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 103
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001, REPRESENTED BY ITS
CHAIRMAN.
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI 682 018.
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003.
7 THE KERALA STATE CO-OPERATIVE BANK LTD., (KERALA
BANK),
PO NO. 6515, CO- BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN 695 033, REPRESENTED BY ITS
MANAGING DIRECTOR.
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN 695 001.
BY ADVS.
SMT.M.S.KIRAN, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 104
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10845 OF 2022
PETITIONER/S:
KALLUR SERVICE CO-OPERATIVE BANK LIMITED,
ALAGAPPA NAGAR, THRISSUR DISTRICT 680 317,
REPRESENTED BY ITS SECRETARY, SMT.A.A. PUSHPALATHA.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SHRI.RAJATH R NATH
SMT.HARIMA HARIHARAN
SMT.G.REMADEVI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI 110001.
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI 682
018.
3 THE INCOME TAX OFFICER (TDS),
AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR 680 001.
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 105
MINISTRY OF FINANCE, GOVERNMENT IF INDIA, NORTH
BLOCK, NEW DELHI 11001, REPRESENTED BY ITS CHAIRMAN.
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX ,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018.
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM 695 003.
7 THE KERALA STATE CO - OPERATIVE BANK LTD.,
(KERALA BANK), P.O. NO. 6515 , CO- BANK TOWERS,
PALAYAM, THIRUVANANTHAPURAM 695 033. REPRESENTED BY
ITS MANAGING DIRECTOR.
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO - OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF INDIA,
THIRUVANANTHAPURAM 695 001.
BY ADVS.
SHRI.K.B.SAJAN
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 106
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10855 OF 2022
PETITIONER/S:
MELOOR SERVICE CO-OPERATIVE BANK LTD
NO.R.196, MELOOR.P.O, CHALAKUDY, THRISSUR DISTRICT-
680311,REPRESENTED BY ITS SECRETARY SINDHU.M.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SHRI.RAJATH R NATH
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI-110001.
2 COMMISSIONER OF INCOME TAX(TDS),
CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI-
682018.
3 THE INCOME TAX OFFICER(TDS),
AAYAKAR BHAVAN,SAKTHAN THAMPURAM NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR,PIN-680001.
4 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF
FINANCE ,GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-
2025:KER
W.P(C)No.7053/2023 & Connected cases 107
110001,REPRESENTED BY ITS CHAIRMAN.
5 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
6 THE ADDITIONAL COMMISSIONER OF INCOME TAX
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003.
7 KERALA STATE CO-OPERATIVE BANK LTD.,
(KERALA BANK), PO NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN-695033, REPRESENTED BY ITS
MANAGING DIRECTOR.
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM,PIN-
695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 108
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10891 OF 2022
PETITIONER/S:
THE VAIKOM TALUK CO-OPERATIVE EMPLOYEES' CO-OPERATIVE
SOCIETY LTD. NO. K 415,
THALAYOLAPARAMBU, KOTTAYAM DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN-686505.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682018.
3 THE INCOME TAX OFFICER,
(TDS), INCOME TAX DEPARTMENT, AYKAR BHAVAN, KOTTAYAM,
PIN-686001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
5 THE MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD.,
THALAYOLAPARAMBU, KOTTAYAM DISTRICT, PIN-686505.
2025:KER
W.P(C)No.7053/2023 & Connected cases 109
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 110
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10936 OF 2022
PETITIONER/S:
1 VAKKOM FARMERS SERVICE CO-OPERATIVE BANK LTD
NO 542, VAKKOM P.O, THIRUVANANTHAPURAM 695 308
REPRESENTED BY ITS MANAGING DIRECTOR SATHEESAN S
2 THONNAKKAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY
LTDNO. HW 21
THONNAKKAL P.O, THIRUVANNATHAPURAM 695 317
REPRESENTED BY ITS SECRETARY SUDHEER KUMAR C
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 111
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001
REPRESENTED BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM 695 003
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM , 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM 695 003
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
P.B NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001
BY ADV SRI.R.MURALEEKRISHNAN (MALAKKARA)
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 112
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10937 OF 2022
PETITIONER/S:
1 TRAVANCORE AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD
NO A 1183, BARANIKAVU SOUTH P.O, ALAPUZHA 690 503
REPRESENTED BY ITS SECRETRY ROY ISSAC DANIEL
2 MAVELIKARA ELECTRICITY EMPLOYEES CO-OPERATIVE SOCIETY
LTD
NO A-646 MAVELIKARA, ALAPUZHA 690 101 REPRESENTED BY
SECRETARY BENOY H
3 MAVELIKARA AIDED SCHOOL EMPLOYEES CO-OPERATIVE
SOCIETY LTD NO A 288,
MAVELIKARA, ALAPUZHA 690 101 REPRESENTED BY ITS
SECRETARY K.A RAJI
4 MAVELIKARA GOVERNMENT SERVANTS CO-OPERATIVE SOCIETY
LTD
NO A 792, MAVELIKARA, ALAPUZHA 690 101, REPRESENTED
BY ITS SECRETARY CHANDRAN PILLAI P
5 BARANIKAVU PANCHAYATH MULTY PURPOSE CO-OPERATIVE
SOCIETY LTD
NO A 1164, MOONAMKUTTY, PALLICKAL P.O, ALAPUZHA 690
503 REPRESENTED BY ITS SECRETARY BIJUKUMAR P
6 NOORANAD RURAL HOUSING CO-OEPRATIVE SOCEITY LTD
NO A 293, NOORANAD P.O, ALAPUZHA 690 504 REPRESENTED
BY ITS SECRETARY P.K JAYACHANDRAN
7 THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE DEPARTMENT
EMPLOYEES CO-OEPRATIVE SOCIETY LTD NO. T 323, JAWAHAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 113
SAHAKARANA BHAVAN , DPI JUNCTION, JAGATHY,
THIRUVANANTHAPURAM 695 014 REPRESENTED BY ITS
SECRETARY DILEEP KUMAR V
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.RASMI NAIR T.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE , MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
CO-OPERATIVE SOCIETIES KERALA REGION, MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE
BUILDINGS, I S PRESS ROAD, KOCHI 682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
P B NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001
BY ADVS.
2025:KER
W.P(C)No.7053/2023 & Connected cases 114
SHRI.T.V.VINU, CGC
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 115
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10968 OF 2022
PETITIONER/S:
1 VAZHAKKULAM BLOCK VANITHA CO-OPERATIVE SOCIETY LTD.
NO.E 1126, MARAMPALLY P.O., ERNAKULAM - 683 105,
REPRESENTED BY ITS SECRETARY REJITHA UNNIKRISHNAN.
2 KUNNATHUNAD TALUK CO-OPERATIVE EMPLOYEES CO-OPERATIVE
SOCIETY LTD.NO.E 771
PERUMBAVOOR P.O., ERNAKULAM - 683 542, REPRESENTED BY
SECRETARY SHYJI M.S.
3 DEVASWOLM BOARD EMPLOYEE'S CO-OPERATIVE SOCIETY
LTD.NO.E 759
PERUMBAVOOR P.O., ERNAKULAM - 683 542, REPRESENTED BY
ITS SECRETARY SREENATH K.V.
4 VADAVUKODU BLOCK VANITHA CO-OPERATIVE SOCIETY
LTD.NO.E 1105
PATTIMATTOM P.O., ERNAKULAM - 683 562, REPRESENTED BY
ITS SECRETARY BEENA V.T.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.NEENA ARIMBOOR
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 116
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110
001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDING, I S PRESS ROAD,
KOCHI - 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 117
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10967 OF 2022
PETITIONER/S:
1 UZHUVA SERVICE CO-OPERATIVE BANK LTD NO.A 305,
PATTANAKKAD P.O, CHERTHALA-688 531, REPRESENTED BY
ITS SECRETARY- K.T. JOHN.
2 THE THYCATTUSSERY SERVICE CO-OPERATIVE BANK LTD. NO.
326,
THYCATTUSSERY P.O-688 582, REPRESENTED BY ITS
SECRETARY- VISHNU V.A
3 THANNEERMUKAM SERVICE CO-OPERATIVE BANK LTD. NO. A
809,
THANNEERMUKKAM P.O, CHERTHALA-688 527, REPRESENTED BY
ITS SECRETARY- AJITHKUMAR P.D.
4 MUHAMMA SERVICE CO-OPERATIVE BANK LTD. NO. 1670,
MUHAMMA P.O, CHERTHALA 688 525, REPRESENTED BY ITS
SECRETARY- SUNIL KUMAR.
5 THURAVOOR SOUTH SERVICE CO-OPERATIVE BANK LTD. NO.
2727,
THURAVOOR P.O,CHERTHALA- 688 532, REPRESENTED BY ITS
SECRETARY- ANI T.P.
6 THURAVOOR KIZHAKKEKKARA SERVICE CO-OPERATIVE BANK LTD
NO. 1053,
THURAVOOR P.O, CHERTHALA- 688 532, REPRESENTED BY ITS
SECRETARY- GEETHADEVI
7 THURAVOOR CO-OPERATIVE BANK LTD. NO. 935,
THURAVOOR P.O, ALAPPUZHA 688 532, REPRESENTED BY ITS
SECRETARY, N PRADEESH PRABHU.
2025:KER
W.P(C)No.7053/2023 & Connected cases 118
8 VALAMANGALAM SERVICE CO-OPERATIVE BANK LTD. NO. 144,
THURAVOOR P.O, ALAPPUZHA 688 532, REPRESENTED BY ITS
SECRETARY- BINEESH K.P.
9 PANAVALLY VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO.
1249,
THRICHATTUKULAM P.O, ALAPPUZHA 688 526, REPRESENTED
BY ITS SECRETARY, PRATHIBA MOHAN.
0 THE EZHUPUNNA SOUTH SERVICE CO-OPERATIVE BANK LTD.
NO. 1124,
EZHUPUNNA SOUTH P.O, CHERTHALA- 688 537, REPRESENTED
BY ITS SECRETARY K.N. SATHEESAN.
11 CHANDIROOR SERVICE CO-OPERATIVE BANK LTD. NO. 959,
CHANDIROOR P.O, CHERTHALA 688 471, REPRESENTED BY ITS
SECRETARY- ABDULKALAM.
12 ARTHINKAL VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO.
3772,
ARTHUNKAL P.O, CHERTHALA -688 530, REPRESENTED BY ITS
SECRETARY-ALICE M.
13 PALLIPURAM VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO.
335,
PALLIPURAM P.O, CHERTHALA- 688 541, REPRESENTED BY
ITS SECRETARY- SAJI JOB.
14 THE PERUMPALAM SERVICE CO-OPERATIVE BANK LTD. NO. 46,
PERUMPALAM P.O, CHERTHALA 688 570, REPRESENTED BY ITS
SECRETARY- AJITHKUMAR V K.
15 PALLIPURAM SERVICE CO-OPERATIVE BANK LTD. NO. 1308,
PALLIPURAM P.O, CHERTHALA- 688 541, REPRESENTED BY
ITS SECRETARY, RADHAKRISHNAN P.
16 AROOR GRAMEENA SERVICE CO-OPERATIVE BANK LTD. NO.
1436, AROOR P.O,
CHERTHALA-688 534, REPRESENTED BY ITS SECRETARY-
JAYASREE R.
17 AROOKUTTY SERVICE CO-OPERATIVE SOCIETY LTD. NO. 1008,
2025:KER
W.P(C)No.7053/2023 & Connected cases 119
AROOKUTTY P.O, CHERTHALA- 688 535, REPRESENTED BY ITS
SECRETARY - SUJATHADEVI.
18 VAYALAR SERVICE CO-OPERATIVE BANK LTD. NO. 1428,
VAYALAR EAST P.O, CHERTHALA- 688 536, REPRESENTED BY
ITS SECRETARY- SHYNIMOL P.
19 VAYALAR KIZHAKKE SERVICE CO-OPERATIVE BANK LTD. NO.
1328,
VAYALAR EAST P.O, CHERTHALA- 688 536, REPRESENTED BY
ITS SECRETARY- SINDHU V.A
0 CHERTHALA TALUK AGRICULTURAL CREDIT CO-OPERATIVE
SOCIETY LTD. NO. H W 11,
CHERTHALA P.O, CHERTHALA- 688 533, REPRESENTED BY ITS
SECRETARY - A MINI.
21 KANNANKARA SERVICE CO-OPERATIVE BANK LTD. NO. 1806,
KANNANKARA P.O, CHERTHALA -688 527, REPRESENTED BY
ITS SECRETARY- P L MARIAMMA
22 SREEKANDAMANGALAM SERVICE CO-OPERATIVE BANK LTD. NO.
974.
MUTTATHIPARAMBU P.O, CHERTHALA-688 527, REPRESENTED
BY ITS SECRETARY IN CHARGE- ALICE VARGHESE.
23 CHERTHALA GOVT. SERVANTS CO-OPERATIVE BANK LTD NO.
235,
CHERTHALA P.O, CHERTHALA-688 524, REPRESENTED BY ITS
SECRETARY- SANDHY C.
24 THE THYCATTUSSERY SERVICE CO-OPERATIVE BANK LTD. NO.
275,
THYCATTUSSERY P.O, CHERTHALA 688 528, REPRESENTED BY
ITS SECRETARY- SAJI K THOMAS.
25 PANAVALLY SERVICE CO-OPERATIVE BANK LTD. NO. 901,
POOCHAKKAL P.O, CHERTHALA- 688 528, REPRESENTED BY
ITS SECRETARY - SREELAL K.
26 MARARIKULAM SERVICE CO-OPERATIVE BANK LTD. NO. 1509,
MARARIKULAM NORTH P.O. ALAPPUZHA 688 523, REPRESENTED
BY ITS SECRETARY - SHAJI T.A,
2025:KER
W.P(C)No.7053/2023 & Connected cases 120
27 KADAKKARAPPALLY SERVICE CO-OPERATIVE BANK LTD. NO.
1125,
KADAKKARAPPILLY P.O, CHERTHALA 688529, REPRESENTED BY
ITS SECRETARY- BRIJESH CHANDRAN.
28 KAVIL SERVICE CO-OPERATIVE BANK LTD. NO. 2093,
PATTANAKKAD P.O, CHERTHALA- 688 531, REPRESENTED BY
ITS SECRETARY- SANOJ C.P.
29 KALAVAMKODAM SERVICE CO-OPERATIVE BANK LTD. NO. 895,
KALAVOMKODAM P.O, CHERTHALA- 688 524, REPRESENTED BY
ITS SECRETARY- ANAND K.T.
0 PARAYAKAD SERVICE CO-OPERATIVE BANK LTD. NO. 2869,
PARAYAKAD P.O, CHERTHALA 688 540, REPRESENTED BY ITS
SECRETARY M.K. USHAKUMARI.
31 CHERTHALA TOWN SERVICE CO-OPERATIVE BANK LTD. NO.
1435,
CHERTHALA P.O, CHERTHALA - 688 533, REPRESENTED BY
ITS SECRETARY- B VINOD.
32 THE VETTACKKAL SERVICE CO-OPERATIVE BANK LTD. NO.
1812,
VETTACKKAL P.O, CHERTHALA-688 587, REPRESENTED BY ITS
SECRETARY- S GANGA PRASAD.
33 VETTACKAL KARSHIKA SERVICE CO-OPERATIVE BANK LTD. NO.
4292,
VETTACKKAL P.O, CHERTHALA 688 587, REPRESENTED BY ITS
SECRETARY- V.C. AMBILY.
34 KAYIPPURAM SERVICE CO-OPERATIVE BANK LTD. NO. 1300,
MUHAMMA P.O, CHERTHALA- 688 525, REPRESENTED BY ITS
SECRETARY - JAYA C P.
35 SHERTALLAY SOUTH SERVICE CO-OPERATIVE BANK LTD. NO.
1344,
SHERTALLAY P.O, SHERTALLAY- 688 552, REPRESENTED BY
ITS SECRETARY- D BABU.
36 KALAVOOR SERVICE CO-OPERATIVE BANK LTD. NO. 1497,
KALAVOOR P.O, CHERTHALA 688 522, REPRESENTED BY ITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 121
SECRETARY- FULL ADDITIONAL CHARGE VIJIMOL S.
37 THE CHATHURTHIAKARY SERVICE CO-OPERATIVE BANK LTD.
NO. 1247,
CHATHURTHIAKARY P.O, ALAPPUZHA 688 502, REPRESENTED
BY ITS SECRETARY, ANIL KUMAR A.
38 S.L. PURAM SERVICE CO-OPERATIVE BANK LTD. NO. A 64,
S/L. PURAM P.O, ALAPPUZHA 688 523, REPRESENTED BY ITS
SECRETARY- SUSEELA P.G.
39 ALLEPPEY ELECTRICITY EMPLOYEES CO-OPERATIVE SOCIETY
LTD. NO. A 769,
POWER HOUSE P.O, ALAPPUZHA 688 524, REPRESENTED BY
ITS SECRETARYP P U REKHA,
40 CHERTHALA TALUK,
AIDED PRIMARY TEACHER'S CO-OPERATIVE SOCIETY LTD. NO.
A 272 P.O, CHERTHALA 688524, REPRESENTED BY ITS
SECRETARY - P S MAMACHAN.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 000.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG. IS PRESS ROAD, KOCHI 682 018.
3 INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX DEPT. ALAPPUZHA 688 011.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(ERSTWHILE ALAPPUZHA DISTRICT CO-OPERATIVE BANK),
2025:KER
W.P(C)No.7053/2023 & Connected cases 122
OPP. MUNICIPAL TOWN HALL, ALAPPUZHA REGION, ALAPPUZHA
, KERALA-688 011
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 123
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11001 OF 2022
PETITIONER/S:
1 PALLICKAL NADUVILEMURI SERVICE CO-OPERATIVE BANK LTD.
NO.965,
PALLICKAL NADUVILEMURI P.O., KAYAMKULAM, ALAPPUZHA-
690503, REPRESENTED BY ITS SECRETARY RAGESH K.R.
2 CORPORATION BANK
BANK LIMITED NO. H.W.14, HEAD OFFICE, KALLUMALA P.O.,
MAVELIKARA, ALAPPUZHA-690110, REPRESENTED BY ITS
SECRETARY BINDU A.
3 PATHIYOOR FARMERS SERVICE CO-OPERATIVE BANK LIMITED
1282,
HEAD OFFICE, PATHIYOOR, KEERIKAD P.O., ALAPPUZHA-
690506, REPRESENTED BY ITS MANAGING DIRECTOR MAYA S.
4 NOORANAD SERVICE CO-OPERATIVE BANK LIMITED NO.1559,
PADANILAM P.O., NOORANAD, ALAPPUZHA-690543,
REPRESENTED BY ITS SECRETARY N. UDAYAN.
5 THEKKEKARA SERVICE CO-OPERATIVE BANK LIMITED NO.A
218,
PONAKAM, MAVELIKARA P.O., ALAPPUZHA-690101,
REPRESENTED BY ITS SECRETARY S. SINDHUKUMARI.
6 KANNAMANGALAM SERVICE CO-OPERATIVE BANK LIMITED
NO.2135,
HEAD OFFICE, PELA P.O., THATTARAMPALAM, ALAPPUZHA-
690103, REPRESENTED BY ITS SECRETARY JAYASREE M.
7 PONNEZHA SERVICE CO-OPERATIVE BANK LIMITED NO.3522,
THEKKEKARA P.O., MAVELIKARA, ALAPPUZHA-690107,
2025:KER
W.P(C)No.7053/2023 & Connected cases 124
REPRESENTED BY ITS SECRETARY K.U. INDUKALA.
8 PERINGALA SERVICE CO-OPERATIVE BANK LIMITED NO.2152,
KOIPPALLIKARANMA, OLAKETTIAMBALAM P.O., ALAPPUZHA-
690510, REPRESENTED BY IT SECRETARY PREETHAKUMARI P.
9 KATTANAM SERVICE CO-OPERATIVE BANK LIMITED NO.120,
PALLICKAL P.O., ALAPPUZHA-690503, REPRESENTED BY ITS
SECRETARY S. VENUGOPALAN NAIR.
0 KANNANKUZHI SERVICE CO-OPERATIVE BANK LIMITED
NO.2998,
KANNANKUZHY P.O., VIA CHARUMOODU, ALAPPUZHA-690505,
REPRESENTED BY ITS SECRETARY SEENA S.R.
11 VALLIKUNNAM KADUVINAL SERVICE CO-OPERATIVE BANK
LIMITED NO.1392,
VALLIKUNNAM, ALAPPUZHA-690501, REPRESENTED BY ITS
SECRETARY J. RAVEENDRANATH.
12 BHARANICKAVU SERVICE CO-OPERATIVE BANK LIMITED
NO.829,
PALLICKAL P.O., ALAPPUZHA-690503, REPRESENTED BY ITS
SECRETARY K.S. JAYAPRAKASH.
13 KUNNAM SERVICE CO-OPERATIVE BANK LIMITED NO.559,
ALAPPUZHA-690408, REPRESENTED BY ITS SECRETARY BINU
S.
14 MAVELIKKARA BLOCK VANITHA CO-OPERATIVE BANK LIMITED
NO. A 912,
KUNNAM P.O., ALAPPUZHA-690108, REPRESENTED BY ITS
SECRETARY VRINDA S.
15 PALAMEL SERVICE CO-OPERAIVE BANK LIMITED NO.4018,
NOORANAD P.O., ALAPPUZHA-690504, REPRESENTED BY ITS
SECRETARY MANJU T.G.
16 KOOVAPPALLY SERVICE CO-OPERATIVE BANK LIMITED
NO.3549,
KOOVAPPALLY P.O., KOTTAYAM-686518, REPRESENTED BY ITS
SECRETARY JOSE MANOJ.
17 THANIYAM PANCHAYATH SERVICE CO-OPERATIVE BANK LIMITED
2025:KER
W.P(C)No.7053/2023 & Connected cases 125
NO. R387,
KIZHUPPILLIKARA P.O., THRISSUR-680702, REPRESENTED BY
ITS SECREARY UNNIKRISHNAN K.V.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.NEENA ARIMBOOR
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682018.
4 KERALA STATE CO-OPERATIVE BANK LTD.,
P.B. NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADVS.
SRI.KRISHNADAS P.NAIR, SENIOR PANEL COUNSEL
SHRI.THOMAS ABRAHAM
2025:KER
W.P(C)No.7053/2023 & Connected cases 126
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 127
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11009 OF 2022
PETITIONER/S:
KADUKUTTY SERVICE CO-OPERATIVE BANK LIMITED
NO. 628,KADUKUTTY P.O, CHALAKUDY, THRISSUR, PIN- 680
315 REPRESENTED BY ITS SECRETARY E.K.VIJAYA.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001
2 COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD,KOCHI- 682
018
3 THE INCOME TAX OFFICER (TDS)
AAYAKAR BHAVAN, SAKTHAN THMPURAN NAGAR, MUNCIPAL
OFFICE ROAD, THRISSUR. PIN- 680 001
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE.
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
2025:KER
W.P(C)No.7053/2023 & Connected cases 128
BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX ,
KERALA REGION , MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI-682 018
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003
7 THEKERALA STATE CO-OPERATIVE BANK LTD,
(KERALA BANK) P.O.NO. 6515, CO-BANK TOWERSPALAYAM,
THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS
MANAGING DIRECTOR,
8 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO_OPERATION),
GOVERNMENT SECRETARIAT GOVERNMENT OF KERALA,
THIRUVANANTHAPURM-PIN-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 129
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11035 OF 2022
PETITIONER/S:
PERUNGUZHI SERVICE CO-OPERATIVE BANK LTD. NO.2403
REPRESENTED BY ITS SECRETARY, PERUNGUZHI P.O.,
THIRUVANANTHAPURAM DISTRICT - 695 305.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX,
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O.,
THIRUVANANTHAPURAM, PIN-695 003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/ MNISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI, PIN - 110
001.
3 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI , PIN 110 001.
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
2025:KER
W.P(C)No.7053/2023 & Connected cases 130
THIRUVANANTHAPURAM, PIN - 695 001.
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695 001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN - 695 033.
BY ADVS.
SHRI.JUSTUS S., CGC
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 131
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11042 OF 2022
PETITIONER/S:
VILVATTOM SERVICE CO-OPERATIVE BANK LTD NO.337
P.O.KURICHIKKARA, THRISSUR, REPRESENTED BY THE
SECRETARY - 680 028.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM -
682 018.
3 THE INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695
033, REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SMT.SOWMIAVATHY T.C., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 132
SHRI.B.G.HARINDRANATH (SR.)
SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 133
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11058 OF 2022
PETITIONER/S:
1 MANNANAM SERVICE CO-OPERATIVE BANK LTD
NO 3647, MANNANAM P.O, KOTTAYAM 686 561 REPRESENTED
BY ITS SECRETARY-ABY JACOB
2 AYARKUNNAM SERVICE CO-OPERATIVE BANK LTD NO. 4147,
AYARKUNNAM P.O, KOTTAYAM 686 564, REPRESENTED BY ITS
SECRETARY MANOJ K
3 THE PUNNATHURA SERVICE CO-OPERATIVE BANK LTD NO. 1712
PUNNATHURA P.O 686 583 REPRESENTED BY ITS SECRETARY-
BIJU VARGHESE
4 CHENGALAM SERVICE CO-OPERATIVE BANK LTD NO. K 253
CHENGALAM P.O, KOTTAYAM 686 585 REPREENTED BY ITS
SECRETARY-IN-CHARGE JOJIE NIRAPPEL
5 ETTUMANOOR BLOCK URBAN CO-OPERATIVE SOCIETYLTD K 1026
THELLAKOM P.O, KOTTAYAM 686 630 REPRESENTED BY ITS
SECRETARY V C JAYAKUMAR
6 AREEPARAMBU SERVICE CO-OPERATIVE BANK LTD NO. 1393
AREEPARAMPU P.O, KOTTAYAM 686 501 REPRESENTED BY ITS
SECRETARY SHIBY N C
7 VIJAYAPURAM SERVICE CO-OPERATIVE BANK LTD NO. 4066
MANARCAD P.O, KOTTAYAM 686 019 REPRESENTED BY ITS
SECRETARY-BINDU P SCARIA
8 PEROOR SERVICE CO-OPERATIVE BANK LTD NO. 76
PEROOR PO, KOTTAYAM 686 637 REPRESENTED BY ITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 134
SECRETARY PREETHY K SASI
9 THIRUVANACHOOR SERVICE CO-OPERATIVE BANK LTD NO.
1942,
THIRUVANCHOOR P.O, KOTTAYAM REPRESENTED BY ITS
SECRETARY E K LATHAMOL
0 THE ATHIRAMPUZHA REGIONAL SERVICE CO-OPERATIVE BANK
LTD NO. 3806
ATHIRAMPUZHA P.O, KOTTAYAM REPRESENTED BY ITS
SECRETARY-KUNJUMON MD
11 MAHATMA GANDHI UNIVERSITY EMPLOYEES CO-OPERATIVE
SOCIETY LTD NO K- 771
PRIYADARSINI HILLS P.O, KOTTAYAM 686 560 REPRESENTED
BY ITS SECRETARY-JESSON THOMAS
12 CHENGALAM SOUTH SERVICE CO-OPERATIVE BANK LTD NO.
1016
CHENGALAM SOUTH P.O, KOTTAYAM 686 020 REPRESENTED BY
ITS SECRETARY SUNILMON P.S
13 KUMARAKOM SERVICE CO-OPERATIVE BANK LTD NO. 2298
KUMARAKOM P.O, KOTTAYAM DISTRICT 686 563 REPRESENTED
BY ITS SECRETARY THOMAS MANI.
14 KUMARAKOM REGIONAL SERVICE CO-OPERATIVE BANK LTD NO.
315
KUMARAKOM P.O, KOTTAYAM DISTRICT 686 563 REPRESENTED
BY ITS SECRETARY VIDYA B MENON
15 MRF EMPLOYEES CO-OPERATIVE SOCIETY LTD NO. K 674
VADAVATHOOR P.O, KOTTAYAM 686 010 REPRESENTED BY ITS
SECRETARY DEVASIA P S
16 AIDED PRIMARY TEACHER'S CO-OPERATIVE SOCIETY LTD NO.
K-334
KOTTAYAM P.O 686 001 REPRESENTED BY ITS SECRETARY
BIJU ABRAHAM
17 KOTTAYAM AIDED SECONDARY SCHOOL TEACHER'S CO-
OPERATIVE SOCIETY LTD NO 659
P.O KOTTAYAM 686 019 REPRESENTED BY ITS SECRETARY
CHERIAN VARGHESE
2025:KER
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18 THE CO-OPERATIVE DEPARTMENTAL EMPLOYEES COOPERATIVE
SOCIETY LTD NO. K-294
KOTTAYAM P.O 686 001 REPRESENTED BY ITS SECRETARY
GEORGE JOSEPH K
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018
3 THE INCOME TAX OFFICE (TDS)
INCOME TAX DEPARTMENT, PUBLIC LIBRARY BUILDING,
SASTRI ROAD, KOTTAYAM 686 001
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
(ERSTWHILE KOTTAYAM DISTRICT CO-OPERATIVE BANK) POST
BOX NO. 140, KOTTAYAM DISTRICT OFFICE, KOTTAYAM 686
001
BY ADVS.
SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 136
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11072 OF 2022
PETITIONER/S:
1 THE VENNOR SERVICE CO-OPERATIVE BANK LTD NO.675
VENNOR, ALATHUR P.O., THRISSUR-680741, REPRESENTED BY
ITS SECRETARY- E.D.SABU.
2 THE WEST CHALAKUDY SERVICE CO-OPERATIVE BANK LTD.
NO.R 262,
CHALAKKUDY P.O., -680307, REPRESENTED BY ITS
SECRETARY- VALSA M.V.
3 THE ERIYAD SERVICE CO-OPERATIVE BANK LTD. NO.98,
ERIYAD P.O., KODUNGALLUR, PIN-680666, REPRESENTED BY
ITS SECRETARY- A.S.RAFI.
4 KURUVILASSERY SERVICE CO-OPERATIVE BANK LTD. NO.4185,
KURUVILASSERY P.O., THRISSUR-680732, REPRESENTED BY
ITS SECRETARY- NIXON N.C.
5 VIYYUR SERVICE CO-OPERATIVE BANK LTD. NO.177,
VIYYUR P.O., THRISSUR-680010, REPRESENTED BY ITS
SECRETARY- T.C.ALICE.
6 VEMBALLUR SERVICE CO-OPERATIVE BANK LTD. NO.F.917,
PATHAZHAKKAD P.O., PATHAZHAKKAD, THRISSUR-680668,
REPRESENTED BY ITS SECRETARY MEERA K.I.
7 METHALA SERVICE CO-OPERATIVE BANK LTD. R-298,
METHALA P.O., KODUNGALLUR-680664, REPRESENTED BY ITS
SECRETARY- MINI T.C.
2025:KER
W.P(C)No.7053/2023 & Connected cases 137
8 THRISSUR DISTRICT CITIZENS CO-OPERATIVE SOCIETY LTD.
NO. R-1405,
KOVILAGATHUPADAM P.O., THRISSUR-680020, REPRESENTED
BY ITS SECRETARY- JITHA J.
9 THE AZHIKODE SERVICE CO-OPERATIVE BANK LTD. 287,
AZHIKODE P.O., THRISSUR-680666, REPRESENTED BY ITS
SECRETARY-SAJEENA O.A.
0 THE THRISSUR DISTRICT SMALL SCALE MANUFACTURES SOCIAL
WELFARE CO-OPERATIVE SOCIETY LTD. NO.R-1401,
VELLIYANNUR P.O., THRISSUR-680021, REPRESENTED BY ITS
SECRETARY- SAJITHA T.G.
11 EDAVILANGU SERVICE CO-OPERATIVE BANK LTD. 3468,
EDAVILANGU P.O., KODUNGALLUR-680671, REPRESENTED BY
ITS SECRETARY- MAYA P.S.
12 PUDUKAD SERVICE CO-OPERATIVE BANK LTD. 580,
PUDUKAD P.O., THRISSUR -680301, REPRESENTED BY ITS
SECRETARY- K.V.ANITHA.
13 ALA SERVICE CO-OPERATIVE BANK LTD. 321,
SHANTHIPURAM P.O., KODUNGALLUR-680668, REPRESENTED BY
ITS SECRETARY- RAJENDRAN P.R.
14 THE TRICHUR GOVT. SERVANTS CO-OPERATIVE SOCIETY LTD.
NO.34,
P.O. TRICHUR-680022, REPRESENTED BY ITS SECRETARY-
RAJESH SHANMUGHAN A.
15 PANAMKUTTICHIRA PEOPLE'S WELFARE CO-OPERATIVE SOCIETY
LTD. NO.R-1441,
OLLUR P.O., THRISSUR-680306, REPRESENTED BY ITS
SECRETARY-SIJI SHAJAN.
16 THRISSUR GOVT. MEDICAL COLLEGE EMPLOYEES CO-OPERATIVE
SOCIETY LTD. NO.R-806,
MEDICAL COLLEGE P.O., THRISSUR-680596, REPRESENTED BY
ITS SECRETARY- SUDHA A.K.
17 KERALA ESIC EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.R-
282,
THRISSUR-680020, REPRESENTED BY ITS SECRETARY-
2025:KER
W.P(C)No.7053/2023 & Connected cases 138
SANTHOSH THOMAS.
18 KERALA AGRICULTURAL AND KERALA VETTINARY UNIVERSITY
SAHAGARNASANGAM CO-OPERATIVE SOCIETY
LTD. NO.R-162, MANNUTHY P.O., MANNUTHY-680651,
REPRESENTED BY ITS SECRETARY- PADMINI E P S.
19 THRISSUR DISTRICT MUNICIPAL AND CORPORATION EMPLOYEES
CO-OPERATIVE SOCIETY LTD. NO.R-38,
P.O. THRISSUR-680014, REPRESENTED BY ITS SECRETARY-
P.R.ASHA.
0 THRISSUR KARSHIKA KARSHIKETHARA VIKASANA CO-OPERATIVE
SOCIETY LTD. NO.R-1395,
CHEMBUKKAVU P.O., THRISSUR-680020, REPRESENTED BY ITS
SECRETARY- NADIYA K.P.
21 MALA MULTI-PURPOSE CO-OPERATIVE SOCIETY LTD. NO.R-
1159,
AANNAMANDA P.O., THRISSUR-680741, REPRESENTED BY ITS
SECRETARY- JISHA K.S.
22 MANNUTHY TOWN CO-OPERATIVE SOCIETY LTD.NO.R-1143,
MANNUTHY P.O., THRISSUR-680651, REPRESENTED BY ITS
SECRETARY- PRIYA C.T.
23 BELLWICS NADAVARAMBA KRISHNA BELL METAL WORKERS
ANTICRAFTS INDUSTRIAL CO-OPERATIVE SOCIETY
LTD. NO.199, NADAVARAMBA P.O., IRINJALAKUDA-680661,
REPRESENTED BY ITS SECRETARY- AMBILY T.S.
24 MANNUTHY VYAPARI VYAVASAYI CO-OPERATIVE SOCIETY LTD.
NO.R-1139,
MANNUTHY P.O., THRISSUR-680651, REPRESENTED BY ITS
SECRETARY- VINOD K. VARGHESE.
25 CHERPU TOWN WELFARE CO-OPERATIVE SOCIETY LTD. NO.R-
1504,
CHERPU P.O., 680561, REPRESENTED BY ITS SECRETARY-
DEEPA RAJAN.
26 PANANCHERY MARKETING & PROCESSING CO-OPERATIVE
SOCIETY LTD. NO.R-1217,
PATTIKKAD P.O., -680652, REPRESENTED BY ITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 139
SECRETARY- SANOJ THOMAS.
27 CHERPU BLOCK PRAVASI SHEMA SAHAKARNASANGA LTD. NO.R-
1490,
CHERPU P.O., 6805561, REPRESENTED BY ITS SECRETARY-
ASHA T.V.
28 CHERPU BLOCK WOOD BASED ENTERPRIENEURS SOCIAL WELFARE
CO-OPERATIVE SOCIETY LTD. NO.R-1388,
CHOWUR P.O., THRISSUR-680027, REPRESENTED BY ITS
SECRETARY- LINI SHIJU.
29 IRINJALAKUDA SERVICE CO-OPERATIVE BANK LTD. NO.594,
IRINJALAKUDA P.O., 680121, REPRESENTED BY ITS
SECRETARY- RUBY P.J.
0 KILLIMANGALAM FARMERS SERVICE CO-OPERATIVE BANK LTD.
NO.25,
KILLIMANGALAM P.O., THRISSUR-680591, REPRESENTED BY
ITS MANAGING DIRECTOR - SIMMI G. NAIR.
31 PANJAL PANCHAYAT GRAMEENA MULTIPURPOSE CO-OPERATIVE
SOCIETY LTD. NO.R-1364,
PANIKULAM P.O., CHERUTHURUTHY-679531, REPRESENTED BY
ITS SECRETARY- SEEJA HARIDAS.
32 THIRUVILAMALA SERVICE CO-OPERATIVE BANK LTD. NO.R-
234,
THIRUVILAMALA P.O., THRISSUR-680588, REPRESENTED BY
ITS SECRETARY- VINODKUMAR S.
33 IRINJALAKUDA EDL.DT AIDED PRIMARY TEACHERS CO-
OPERATIVE SOCIETY LTD. NO.R-379,
CHALAKKUDY P.O., 680307, REPRESENTED BY ITS
SECRETARY- SHEELA C.K.
34 OLLUR BHAVANA NIRMANA SAHAKARNASANGAM LTD. NO.R-1317,
OLLUR P.O., THRISSUR-680306, REPRESENTED BY ITS
SECRETARY- NISHA ABISHKUMAR.
35 THRISSUR DISTRICT GOVERNMENT TEACHERS CO-OPERATIVE
LTD. NO.R-294,
KODAKKARA P.O., THRISSUR-680684, REPRESENTED BY ITS
2025:KER
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SECRETARY- JYOTHILAKSHMI P.K.
36 ERUMAPETTY PANCHAYATH MULTIPURPOSE CO-OPERATIVE
SOCIETY LTD. NO.R-1305,
ERUMAPETTY P.O., THRISSUR-680584, REPRESENTED BY ITS
SECRETARY- SUNITHA T.C.
37 K.S.R.T.C. EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.R-
710,
CHALAKUDY P.O., 680307, REPRESENTED BY ITS SECRETARY-
SHEELA P.K.
38 PAZHAYANNUR FARMERS SERVICE CO-OPERATIVE BANK LTD.
NO.71,
PAZHAYANNUR P.O., THRISSUR-680527, REPRESENTED BY ITS
MANAGING DIRECTOR- SREEDHARAN P.
39 VILVATTAM TOWN CO-OPERATIVE SOCIETY LTD. NO.R-1136,
VILLADAM P.O., RAMAVARMAPURAM-680631, REPRESENTED BY
ITS SECRETARY- K.G.LATHA.
0 OLLUR MEGHALA THOZHILALI CO-OPERATIVE SOCIETY LTD.
NO.R-1142,
NADATHARA P.O., THRISSUR-680751, REPRESENTED BY ITS
SECRETARY- SUJITHA P.S.
41 KONDAZHY SERVICE CO-OPERATIVE BANK LTD. NO.678,
KONDAZHY P.O., THRISSUR-679106, REPRESENTED BY ITS
SECRETARY- LEEMA C.M.
42 THRISSUR DISTRICT LABOUR CONTRACT CO-OPERATIVE
SOCIETY LTD. NO.R-1389,
POOTHOLE P.O., THRISSUR-680004, REPRESENTED BY ITS
SECRETARY- SINDHU K.R.
43 KADANGODE PANCHAYAT MULTIPURPOSE CO-OPERATIVE SOCIETY
LTD. NO.R-1121,
CHIRAMENGAD P.O., PANNITHADAM-680604, REPRESENTED BY
ITS SECRETARY- PREETHY T.B.
44 RAJEEV GANDHI RURAL CO-OPERATIVE SOCIETY LTD. NO.R-
1363,
PULIYANNUR P.O., VELLATTANJUR, THRISSUR-680601,
REPRESENTED BY ITS SECRETARY- JOICY V.L.
2025:KER
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45 KECHERI GURUPAVANAPPURAM PEOPLES SOCIAL WELFARE CO-
OPERATIVE SOCIETY LTD. NO.R-1426,
KECHERI P.O., THRISSUR-680501, REPRESENTED BY ITS
SECRETARY- RATHEESH K.G.
46 VELUR PANCHAYAT KARSHIKA KARSHIKETHARA CO-OPERATIVE
SOCIETY LTD. NO.R-1266,
VELUR P.O., THRISSUR-680601, REPRESENTED BY ITS
SECRETARY- PRIYA P.
47 NADATHARA GRAMA VIKASANA SAHAKARNASANGAM LTD. NO.R-
1297,
NADATHARA P.O., THRISSUR-680751, REPRESENTED BY ITS
SECRETARY-MINI C.L.
48 OLLUR MEKHALA SELF EMPLOYEES CO-OPERATIVE SOCIETY
LTD. NO.R-1205,
MULLUKKARA P.O., MANNUTHY, THRISSUR-680651,
REPRESENTED BY ITS SECRETARY- LOVELY BIJU.
49 KURIACHIRA SERVICE CO-OPERATIVE BANK LTD. NO.637,
KURIACHIRA P.O., THRISSUR-680026, REPRESENTED BY ITS
SECRETARY- LEENA THOMAS.
50 THRISSUR JILLA MERCANTILE SAHAKARANA SANGAM LTD.
NO.R-1428,
P.O.THRISSUR-680020, REPRESENTED BY ITS SECRETARY-
RENCY MAJOR.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESNETED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI.
2025:KER
W.P(C)No.7053/2023 & Connected cases 142
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI-682018.
3 THE INCOME TAX OFFICER (TDS),
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR, PIN-680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK),
SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THIRUVAMBADI
P.O., THRISSUR, PIN-680022, REPRESENTED BY ITS
GENERAL MANAGER.
5 THE GENERAL MANAGER,
KODUNGALLUR TOWN CO-OPERATIVE BANK LTD., KODUNGALLUR
P.O., THRISSUR, PIN-680664.
6 THE GENERAL MANAGER,
THRISSUR URBAN CO-OPERATIVE BANK LTD., HEAD OFFICE,
MISSION QUARTERS, THRISSUR-680001.
7 THE GENERAL MANAGER,
IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD., TANA
JUNCTION, IRINJALAKUDA P.O., PIN-680121.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.C.D.DILEEP,SC,TRICHUR URBN CO-OPBAN
SRI.DEVAPRASANTH.P.J.
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 143
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11087 OF 2022
PETITIONER/S:
1 VARAPETTY SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.VARAPPETTY, ERNAKULAM-686 691,
REPRESENTED BY ITS SECRETARY, SUNIL.T.R.
2 KUTTAMPUZHA SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.KUTTAMPUZHA, ERNAKULAM-686 681,
REPRESENTED BY ITS SECRETARY, BENNY DANIEL.
3 KAVILANGAD SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, NDTTIMATTOM P.O., ERNAKULAM-686 693,
REPRESENTED BY ITS SECRETARY, P.K.MADHUSOODHANAN.
4 KEERAMPARA SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, KEERAMPARA, ERNAKULAM-686 681,
REPRESENTED BY ITS SECRETARY, GEORGE.K.C.
5 ONNUKAL SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.OONNUKAL, ERNAKULAM-686 693,
REPRESENTED BY ITS SECRETARY, K.K.BINOY.
6 IDAMALAYAR SERVICE CO-OPERATIVE BANK LTD.,
HEAD OFFICE, VADATTUPARA P.O., ERNAKULAM-686 681,
REPRESENTED BY ITS SECRETARY, ROBERT.K.M.
7 KOTTAPPADY SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.KOTTAPPADY, ERNAKULAM-686 691,
REPRESENTED BY ITS SECRETARY, SHABU.P.S.
8 KOTHAMANGALAM SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.KOTHAMANGALAM, ERNAKULAM-686 691,
2025:KER
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REPRESENTED BY ITS SECRETARY, ROY ABRAHAM.
9 MATHIRAPPILLY SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.KOTHAMANGALAM, ERNAKULAM-686 691,
REPRESENTED BY ITS SECRETARY, SABEENA.R.
0 MALIPPARA SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, MALIPPARA, ERNAKULAM-686 691,
REPRESENTED BY ITS SECRETARY, GRACY GEORGE.
11 KADAVOOR SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.KADAVOOR, ERNAKULAM-686 691,
REPRESENTED BY ITS SECRETARY, GOPU S.NAIR.
12 KOZHIPILLY SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.KOZHIPPILY, ERNAKULAM-686 691,
REPRESENTED BY ITS SECRETARY, UMADEVI.K.V.
13 POTHANICAD FARMERS SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, P.O.POTHANICAD, ERNAKULAM-686 671,
REPRESENTED BY ITS MANAGING DIRECTOR PAUL P.VARGHESE.
14 PINDIMANA SERVICE CO OPERATIVE BANK LTD.,
HEAD OFFICE, PINDIMANA, ERNAKULAM-686 691,
REPRESENTED BY ITS SECRETARY, SUBI C.VARGHESE.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001.
2025:KER
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2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001.
BY ADVS.
SHRI.RAMKUMAR J., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11092 OF 2022
PETITIONER/S:
1 KANDANASSERY PANCHAYATH VANITHA CO-OPERATIVE SOCIETY
LTD NO.R-1141
ARIYANNOOR P.O, 680 102 REPRESENTED BY ITS SECRETARY-
BIJI HAREESH
2 KUTTIKAD FARMERS SERVICE CO-OPERATIVE BANK LTD NO 572
KUTTIKAD P.O THRISSUR 680 724 REPRESENTED BY ITS
MANAGING DIRECTOR LISSY K G
3 THE PULLOOT SERVICE CO-OPERATIVE BANK LTD NO. 611,
PULLUT P.O, THRISSUR 680 663 REPRESENTED BY ITS
SECRETARY ANITHAKUMARI M K
4 CHAVAKKAD DISTRICT AIDED PRIMARY TEACHERS CO-
OPERATIVE SOCIETY LTDNO. 377
CHOONDAL P.O, THRISSUR 680 502 REPRESENTED BY ITS
SECRETARY JENCY A J
5 LOKAMAKESWARAM SERVICE CO-OPERATIVE BANK LTD NO. 249
P.O KODUNGALLUR 680 664, REPRESENTED BY ITS SECRETARY
IN CHARGE RASEENA P.K
6 PARALAM SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD NO R
1439
KODANNUR P.O, THRISSUR 680 563 REPRESENTED BY ITS
SECRETARY PREETY MOL TOM
7 OLLUR TOWN CO-OPERATIVE SOCIETY LTD NO. R 1120
OLLUR P.O, THRISSUR, PIN 680 306 REPREENTED BY ITS
SECRETARY LINTO
2025:KER
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8 VARANDARAPPILLY PANCHAYATH VANITHA CO-OPERATIVE
SOCIETY LTD NO R 1114
VARANDRAPPILLY P.O, 680 303 REPRESENTED BY ITS
SERETARY SHANTHI AJ
9 MULAYAM AYYAPPANKAVU GRAMEENA NON AGRICULTURAL CO-
OPERATIVE SOCIETY LTD NO. R 1304
MULAYAM P.O THRISSUR 680 751 REPRESENTED BY ITS
SECRETARY JISHA MOHAN K
0 THRISSUR DISTRICT ELECTRICITY BOARD EMPLOYEES CO-
OPERATIVE SOCIETY LTD NO. R 787
POOTHOLE , P.O THRISSUR 680 004 REPRESENTED BY ITS
SECRETARY SINDHU M C
11 THE KATTAKAMPAL SERVICE CO-OPERATIVE BANK LTD NO.
163,
KATTAKAMPAL P.O 680 544 REPRESENTED BY ITS SECRETARY
MARIAMMA C I
12 IRINJALAKUDA EDUCATIONAL DISTRICT PRIVATE SECONDARY
SCHOOL TEACHERS CO-OPERATIVE SOCIETY LTD
NO 703, ALOOR P.O, PIN 680 683 REPREENTED BY ITS
HONANRY SECRETARY JACKSON C VAZHAPPILLY
13 OLLUR SERVICE CO-OPERATIVE BANK LTD NO. 279
OLLUR P.O, THRISSUR 680 306 REPRESENTED BY ITS
SECRETARY JOJO T K
14 PARAPPUKKURA RURAL CO-OPERATIVE BANK LTD R-1101
PARAPPUKKURA P.O TRICHUR 680 310 REPRESENTED BY ITS
SECRETARY BINOY K C
15 THE PAZHANJI SERVICE CO-OPEERATIVE BANK LTD NO 68
PAZHANI P.O, THRISSUR 680 542 REPRESENTED BY ITS
SECRETARY SALIM M
16 MUNDUR MEGHALA VYAPARI VYAVASAYI CO-OPERATIVE SOCIETY
LTD NO R 1167,
MUNDUR P.O, THRISSUR 680 541 REPRESENTED BY ITS
SECRETARY SUMANA P S
17 THE PEOPLES MULTIPURPOSE CO-OEPRATIVE SOCEITY LTD NO
R-1223
2025:KER
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P.O MELOOR 680 311 MELOOR 680 311 REPRESENTED BY ITS
SECRETARY REJINI SOJAN
18 CHEERPU SERVICE CO-OPERATIVE BANK LTDNO. 3540
PERUMBILLISSERY P.O, THRISSUR 680 561 REPRESENTED BY
ITS SECRETARY REKHA M S
19 CHALAKUDYMULTIPURPOSE CO-OPERATIVE SOCIETY LTDNO R
1213
CHALAKUDYP.O 680 307 REPRESENTED BY ITS SECRETARY P K
PREETHA
0 ERUMAPETTY GRAMA PANCHAYATH VANITHA CO-OPERATIVE
SOCEITY LTD NO. R 1301
CHITTANDA P.O, THRISSUR 680 585 REPRESENTED BY ITS
SECRETARY JIJI V P
21 MUNDATHICODE VANITHA CO-OPERATIVE SOCEITY LTD NO R
1279
MUNDATHICODE P.O, THRISSUR 680 623 REPRESENTED BY ITS
SECRETARY SEEMA JAYAPRAKASAN
22 OLLUKKARA BLOCK RUBBER TAPPING THOZHILALI CO-
OPERATIVE SOCIETY LTD NO. R 1346
POOCHATTY P.O, THRISSUR 680 751 REPRESENTED BY ITS
HONORARY SECRETARY SOORYAKALA SURENDRAN
23 SIFL EMPLOYEES CO-OPERATIVE CREDIT SOCIETYLTD NO. R
778
ATHANI, P.O THRISSUR 680 581 REPRESENTED BY ITS
SECRETARY A K VIJAYANKUMARY
24 REGIONAL KERA KARSHAKA CO-OPERATIVE SOCIEITY LTD NO R
1203
KOZHUKULLY P.O, THRISSUR 680 751 REPRESENTED BY ITS
SECRETARY T K SUMA
25 OLLUKKARA BLOCK PANCHAYATH POULTRY AND GOAT FARMERS
DEVELOPMENT CO-OPERATIVE SOCEITY LTD NO. R
ERAVINMANGALAM P.O, THRISSUR 680 751 REPRESENTED BY
ITS SECRETARY SUNANDHA M K
26 NADATHARA PANCHAYATH VANITHA SERVICE CO-OPERATIVE
SOCEITY LTD NO R 980
2025:KER
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KOZHUKKULLY P.O THRISSUR 680 751 REPRESENTED BY ITS
SECRETARY SHYBI K.V
27 OLLUR AREA HEAD ROAD AND GENEERAL WORKERS CO-
OPEERATIVE SOCIETY LTD NO R 1235,
MANNUTHY P.O, THRISSUR 680 651 REPRESENTED BY ITS
SECRETARY RAJI P
28 THE KAIPARAMBU PANCHAYATH MULTIPURPOSE CO-OPERATIVE
SOCIETY LTD NO R 1124
KAIPARAMBU P.O, THRISSUR 680 546 REPRESENTED BY ITS
SECRETARY JESSY JOHN C
29 POOVATHUMKADAVU FARMERS SERVICE CO-OPERATIVE BANK LTD
NO 4686
PANANGAD P.O, THRISSUR 680 665 REPRESENTED BY ITS
MANAGING DIRECTOR SHEEBA V R
0 MARATHAKKARA SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD
NO R 1449
MARATHAKKARA P.O, THRISSUR 680 306 REPRESENTED BY ITS
SECRETARY LIGI BENNY
31 THE ORUMANAYUR SERVICE CO-OPERATIVE BANK LTD NO R 209
ORUMANAYUR P.O THRISSUR 680 512 REPRESENTED BY ITS
SECRETARY IN CHARGE SUJO C A
32 THE PUNNAYURKULAM SERVICE CO-OPERATIVE BANK LTD NO. P
417
PUNNAYURKULAM P.O, THRISSUR 680 561 REPRESENTED BY
ITS SECRETARY A K SATHEESH KUMAR
33 VENKITANGU FARMERS CO-OPERATIVE BANK LTD NO. R 187
VENTITANGU P.O, THRISSUR 680 510 REPRESENTED BY ITS
MANAGING DIRECTOR-IN-CHARGE-ANGEL JOHN A
34 THAIKKAD SERVICE CO-OPERATIVE BANK LTD NO F 7084
BRAHMAKULAM P.O, THRISSUR 680 104 REPRESENTED BY ITS
SECRETARY HARISH E M
35 OLLUKKARA AREA HOUSING CO-OPERATIVE LTD NO. R 164
MQANNUTHY P.O, THRISSUR 680 651 REPRESENTED BY ITS
SECRETARY SUVARNA K K
2025:KER
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36 GURUVAYUR VYAPARI VYAVASAYI CO OPERATIVE SOCIETY LTD
NO R 1325
GURUVAYUR P.O, THRISSUR 680 101 REPRESENTED BY ITS
SECRETARY SONI SATHEESH
37 CHAVAKKAD FIRKA CO-OPERATIVE RURAL BANK LTD NO F 1250
CHAVAKKAD . P.O, THRISSUR 680 506 REPRESENTED BY ITS
SECRETARY IN CHARGE T VIJAYAKRISHNAN
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001
2 ITHE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018
3 THE INCOME TAX OFFICER (TDS)
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN 680 001
4 THE KERALA STATE STATE CO-OPERATIVE BANK LTD
(ERSTWHILE PATHANAMTHITTA SERVICE CO-OPERATIVE BANK)
HEAD OFFICE, THRISSUR 680 001
5 THE GENERAL MANAGER
KODUNGALLUR TOWN CO-OPERATIVE BANK LTD, KODUNGALLUR
P.O, THRISSUR, PIN 680 664
6 THE GENERAL MANAGER
THRISSUR URBAN CO-OPERATIVE BANK LTD, HEAD OFFICE,
MISSION QUARTERS, THRISSUR 680 001
7 THE GENERAL MANAGER
IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD, TANA
2025:KER
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JUNCTION, IRINJALAKUDA P.O, PIN 680 121
8 THE GENERAL MANAGER
GURUVAYOOR CO-OPERATIVE URBAN BANK LTD, GURUVAYOOR
P.O, PIN 680 101
BY ADVS.
SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.DEVAPRASANTH.P.J.
SRI.C.D.DILEEP,SC,TRICHUR URBN CO-OPBAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 152
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11096 OF 2022
PETITIONER/S:
1 THIROOR SERVICE CO-OPERATIVE BANK LTD.NO.4140,
THIROOR P.O., MULAMKUNNATHUKAVU, THRISSUR-680 581,
REPRESENTED BY ITS SECRETARY.
2 MUNDUR SERVICE CO-OPERATIVE BANK LTD.NO.189,
P.O.ANJUR MUNDUR, THRISSUR-680 541, REPRESENTED BY
ITS SECRETARY.
3 VADADIAM SERVICE CO OPERATIVE BANK LTD. NO.575,
P.O.AVANUR, THRISSUR-680 541, REPRESENTED BY ITS
SECRETARY.
4 THE THRISSUR SERVICE CO OPERATIVE BANK LTD. NO.R
1097,
PATTURAIKKAL,THRISSUR-22, REPRESENTED BY ITS
SECRETARY.
5 MOOSPET SERVICE CO OPERATIVE BANK LT. NO.682,
MOOSPET, THRISSUR-5, REPRESENTED BY ITS SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 153
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM-
682 018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER 9TDS), AAYAKAR
BAHVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 154
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11117 OF 2022
PETITIONER/S:
CHIRANELLUR SERVICE CO-OPERATIVE BANK LTD., NO.640,
CHIRANELLUR P.O., THRISSUR DISTRICT - 680 501,
REPRESENTED BY ITS SECRETARY
BY ADVS.
SRI.GEORGE POONTHOTTAM (SR.)
SMT.NISHA GEORGE
SHRI.ANSHIN K.K
SHRI.REGINALD VALSALAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.,
THIRUVANANTHAPURAM, PIN-695 003.
2 THE CENTARL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/ MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI, PIN 110 001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI - 110 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 155
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD
P.O., THIRUVANANTHAPURAM, PIN - 695 014.
5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO
GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695 001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN - 695 033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.JUSTUS S., CGC
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 156
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11130 OF 2022
PETITIONER/S:
1 THIRUVANANTHAPURAM TALUK PRESS THOZHILALY WELFARE CO-
OPERATIVE SOCIETY LTD.
NO.T-1651, KOLIYAKODE, INDUSTRIAL ESTATE.P.O,
THIRUVANANTHAPURAM-695019, REPRESENTED BY ITS
SECRETARY.
2 TERUMO PENPOL EMPLOYEES CO-OPERATIVE SOCIETY LTD,
NO.T1293, PULIYARAKONAM, THIRUVANANTHAPURAM-695573,
REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.A.CHANDRA BABU
SMT.REMYA MURALI
SHRI.AVIJITH A.V
SMT.PREJITHA S.SALIM
SMT.APARNA SARASWATI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY, MINISTRY OF FINANCE,
NORTH BLOCK, RAISANA HILLS, NEW DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX(TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
2025:KER
W.P(C)No.7053/2023 & Connected cases 157
3 THE INCOME TAX OFFICER,(TDS),
AAYAKAR BHAVAN, PEROORKADA ROAD, KOWDIAR,
THIRUVANANTHAPURAM, KERALA-695003.
4 THE KERALA STATE CO-OPERATIVE BANK (KERALA BANK),
FORT MAIN BRANCH, EAST FOR, FORT.P.O,
THIRUVANANTHAPURAM-695023, REPRESENTED BY ITS BRANCH
MANAGER.
5 THE KERALA STATE CO-OPERATIVE BANK ,
MALAYINKEEZHU BRANCH, MALAYINKEEZHU.P.O,
THIRUVANANTHAPURAM-695571, REPRESENTED BY ITS BRANCH
MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 158
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11135 OF 2022
PETITIONER/S:
ULLALA SERVICE CO-OPERATIVE BANK LTD NO.1142
ULLALA, THALAYAZHAM P.O, KOTTAYAM - 686607,
REPRESENTED BY ITS SECRETARY MIDHUNLAL K.M.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110001, REPRESENTED BY ITS
CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
2025:KER
W.P(C)No.7053/2023 & Connected cases 159
REGION,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI - 682018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM - 695003.
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM - 695003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695001.
BY ADVS.
SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 160
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11138 OF 2022
PETITIONER/S:
KANIPPAYOOR SERVICE CO-OPERATIVE BANK LTD. NO. 280
KANIPPAYOOR P.O, THRISSUR DISTRICT, REPRESENTED BY
ITS SECRETARY.
BY ADVS.
SRI.GEORGE POONTHOTTAM (SR.)
SMT.NISHA GEORGE
SHRI.ANSHIN K.K
SHRI.REGINALD VALSALAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM - PIN - 695003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E,NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI - PIN -
110001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 161
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O,
THIRUVANANTHAPURAM - PIN - 695014.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION , GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM - PIN - 695001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO.
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM -
PIN - 695033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 162
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11144 OF 2022
PETITIONER/S:
1 THE AVOLY SERVICE CO-OPERATIVE BANK LTD,
NO. 2950, AVOLY P.O, MUVATTUPUZHA, ERNAKULAM DISTRICT
- 686670, REPRESENTED BY ITS SECRETARY.
2 THE KALLOORKAD FARMERS CO-OPERATIVE BANK LTD, NO.
2605.
KALLOORKAD P.O, MUVATTUPUZHA, ERNAKULAM DISTRICT -
686668, REPRESENTED BY THE MANAGING DIRECTOR IN
CHARGE.
3 ENANALLOOR SERVICE CO-OPERATIVE BANK LTD NO. 1447.
AYAVANA P.O, MUVATTUPUZHA, ERNAKULAM DISTRICT -
686668, REPRESENTED BY ITS SECRETARY.
4 THE MULANTHURUTHY SERVICE CO-OPERATIVE BANK LTD NO.
23,
MULANTHURUTHY, ERNAKULAM DISTRICT - 682314,
REPRESENTED BY ITS SECRETARY.
5 THE PANANGAD SERVICE CO-OPERATIVE BANK LTD NO. 655,
PANANGAD P.O, ERNAKULAM DISTRICT - 682506,
REPRESENTED BY ITS SECRETARY.
6 THE MARADU SERVICE CO-OPERATIVE BANK LTD NO. 43,
MARADU P.O, ERNAKULAM DISTRICT - 682304, REPRESENTED
BY ITS SECRETARY.
BY ADVS.
SMT.NISHA GEORGE
SHRI.REGINALD VALSALAN
2025:KER
W.P(C)No.7053/2023 & Connected cases 163
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM, PIN - 695003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI - PIN -
110001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001.
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O,
THIRUVANANTHAPURAM - PIN - 695014.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM - PIN - 695001.
6 THE KERALA STATE CO-OPERATIVE BANK
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN - 695033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.PRAVEEN K.V., CGC
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 164
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11143 OF 2022
PETITIONER/S:
PEECHI SERVICE CO-OPERATIVE BANK LTD NO R-935
PATTIKKAD P.O, THRISSUR - 680652, REPRESENTED BY ITS
SECRETARY.
BY ADVS.
SRI.GEORGE POONTHOTTAM (SR.)
SMT.NISHA GEORGE
SHRI.ANSHIN K.K
SHRI.REGINALD VALSALAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM, PIN - 695003.
2 THE CENTRAL BOARD OF DIRECTOR TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI - PIN -
110001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 165
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES.
THIRUVANANTHAPURAM - PIN - 695001.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001.
6 THE KERALA STATE CO-OPERATIVE BANK
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO.
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM -
PIN - 695033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 166
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11149 OF 2022
PETITIONER/S:
ERNAKULAM DISTRICT GOVERNMENT COLLEGE EMPLOYEES CO-
OPERATIVE SOCIETY LIMITED
NO.E 844, MAHARAJAS COLLEGE, ERNAKULAM REPRESENTED BY
ITS SECRETARY.
BY ADVS.
SMT.A.K.PREETHA
SRI.C.ANIL KUMAR
SHRI.JITHIN VARGHESE
RESPONDENT/S:
1 COMMISSIONER OF INCOME TAX(TDS)
C.R.BUILDING, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682
018.
2 THE INCOME TAX OFFICER (TDS)
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682
018.
3 KERALA STATE CO-OPERATIVE BANK LTD,
MARINE DRIVE BRANCH, ERNAKULAM - 682 031 REPRESENTED
BY ITS BRANCH MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 167
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 168
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11150 OF 2022
PETITIONER/S:
THIRUVAMKULAM SERVICE CO-OPERATIVE SOCIETY LIMITED
NO.26,
THIRUVAMKULAM, ERNAKULAM - 682 305, REPRESENTED BY
ITS PRESIDENT K.B.JAYAKUMAR.
BY ADVS.
SMT.A.K.PREETHA
SRI.C.ANIL KUMAR
SHRI.JITHIN VARGHESE
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX(TDS)
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682
018.
2 THE INCOME TAX OFFICER (TDS)
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682
018.
3 KERALA STATE CO-OPERATIVE BANK LTD.
THRIPUNITHURA BRANCH, STATUE, THRIPUNITHURA - 682 301
REPRESENTED BY ITS BRANCH MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 169
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 170
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11165 OF 2022
PETITIONER/S:
KERALA HIGH COURT EMPLOYEES CREDIT CO-OPERATIVE
SOCIETY LTD
NO. E.830, HIGH COURT BUILDING, ERNAKULAM DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN - 682031.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN - 682018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, ERNAKULAM, PIN - 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033.
5 THE MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD, MARINE DRIVE
BRANCH, ERNAKULAM, PIN - 682001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 171
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 172
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11171 OF 2022
PETITIONER/S:
THE DEVASWAM BOARD EMPLOYEES CO-OPERATIVE SOCIETY LTD
NO.K 458, ETTUMANOOR, KOTTAYAM DISTRICT, REPRESENTED
BY ITS SECRETARY, PIN - 686 001.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, AYKAR BHAVAN, KOTTAYAM, PIN -
686 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
5 THE MANAGER
THE KERALA STATE CO-OPERATIVE BANK LTD., ETTUMANOOR,
KOTTAYAM DISTRICT, PIN - 686 631.
2025:KER
W.P(C)No.7053/2023 & Connected cases 173
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11187 OF 2022
PETITIONER/S:
1 MAVILAYIL SERVICE CO-OPERAITVE BANK LTD
MAVILAYI P.O., KANNUR - 670 622, REPRESENTED BY ITS
SECRETARY KINCE VARGHESE.
2 PAZHASSI SERVICE CO-OPERATIVE BANK LTD.
NO.F 1532, P.O.MATTANNUR, KANNUR - 670 702,
REPRESENTED BY ITS SECRETARY SARALA K.C.
3 KUTTYERI SERVICE CO-OPERATIVE BANK LTD.
NO.1266, HEAD OFFICE, KUTTYERI P.O., KANNUR - 670
142, REPRESENTED BY ITS SECRETARY BALAKRISHNAN P.
4 KUTHUPARAMBA SERVICE CO-OPERATIVE BANK LTD.
NO.F 1507, HEAD OFFICE, KUTHUPARAMBA P.O., KANNUR -
670 643, REPRESENTED BY ITS SECRETARY M.BEENA.
5 CHENGALAYI SERVICE CO-OPERATIVE BANK LTD.
NO.C 101, HEAD OFFICE, CHENGALAYI P.O., KANNUR - 670
631 REPRESENTED BY ITS SECRETARY SHAJI E.V.
6 IRITTY CO OPERATIVE RURAL BANK LTD.
IRITTY P.O., KANNUR - 670 703 REPRESENTED BY ITS
SECRETARY SUJATHA P.T.
7 KARIVELLUR SERVICE CO-OPERATIVE BANK LTD.
KARIVELLUR P.O., KANNUR - 670 521, REPRESENTED BY ITS
SECRETARY SARASWATHI R.
8 KADANNAPPALLY PANAPUZHA SERVICE CO-OPERATIVE BANK
LTD.
2025:KER
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P.O.KADANNAPPALLY, KANNUR - 670 501 REPRESENTED BY
ITS SECRETARY MADHUSOODANAN V.V.
9 EDAKKADAPPAN SERVICE CO OPERATIVE BANK LTD.
P.O.EDAKKAD, KANNUR - 670 663 REPRESENTED BY ITS
SECRETARY DILEEP KUMAR T.
0 CHALA SERVICE CO-OPERATIVE BANK LTD.
CHALA WEST, THOTTADA P.O., KANNUR - 670 007,
REPRESENTED BY ITS SECRETARY REETHA K.P.
11 MORAZHA KALLIASSERY SERVICE CO-OPERATIVE BANK LTD.
P.O.ANCHAMPEEDIKA, KANNUR - 670 631 REPRESENTED BY
ITS SECRETARY T.N., MADHUSOODNAN.
12 NARATH SERVICE CO OPERATIVE BANK LTD.
P.O.NARATH, KANNUR - 670 601 REPRESENTED BY ITS
SECRETARY BHAGYANANTHAN P.M.
13 KANHIRODE SERVICE CO-OPERATIVE BANK LTD.
P.O.KANHIRODE, KANNUR - 670 592, REPRESENTED BY ITS
SECRETARY PRADEEP K.
14 KOOVERI SERVICE CO-OPERATIVE BANK LTD.
P.O.CHAPPARAPADAVU, KANNUR - 670 581 REPRESENTED BY
ITS SECRETARY K.BHANUPRAKASHAN.
15 ELAYAVOOR SERVICE CO-OPERATIVE BANK LTD.
P.O.KUNAYAD, KANNUR - 670 594 REPRESENTED BY ITS
SECRETARY SURESH BABU P.
16 PAPPINISSERI SERVICE CO-OPERATIVE BANK LTD.
P.O.PAPPINISSERI, KANNUR - 670 561 REPRESENTED BY ITS
SECRETARY PREMAN KUNNIRIKKAN.
17 MATTUL SERVICE CO-OPERATIVE BANK LTD.
P.O.MATTUL BORTH, KANNUR - 670 325 REPRESENTED BY ITS
SECRETARY RAJU M.
18 IRIKKUR SERVICE CO-OPERATIVE BANK LTD.
IRIKKUR P.O., KANNUR - 670 593 REPRESENTED BY ITS
SECRETARY MANEESH P.V.
2025:KER
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19 KANNUR SERVICE CO-OPERATIVE BANK LTD.
THANA P.O., KANNUR - 670 012 REPRESENTED BY ITS
SECRETARY JYOTHI A.M.
0 KALLAD SERVICE CO-OPERATIVE BANK LTD.
KALLIAD P.O., KANNUR - 670 593 REPRESENTED BY ITS
SECRETARY SAJITHKUMARI M.
21 KOTTIYOOR SERVICE CO-OPERATIVE BANK LTD.
P.O.KOTTIYOOR, KANNUR - 670 651 REPRESENTED BY ITS
SECRETARY SANITHA C.L.
22 PERINGOME SERVICE CO-OPERATIVE BANK LTD.
P.O.PERINGOME, KANNUR 670 653 REPRESENTED BY ITS
SECRETARY GEETHA K.R.
23 MOWANCHERY CO-OPERATIVE RURAL BANK LTD.
P.O.MOWANCHERY, KANNUR - 670 613 REPRESENTED BY ITS
SECRETARY RAMESHBABU C.P.
24 MANGATTIDOM SERVICE CO-OPERATIVE BANK LTD.
P.O.MANGATTIDOM, KANNUR - 670 643 REPRESENTED BY ITS
SECRETARY RETHNAKARAN T.
25 ERAMAM KUTTUR SERVICE CO-OPERATIVE BANK LTD.
P.O.MATHAMANGALAM BAZAR, KANNUR - 670 306 REPRESENTED
BY ITS SECRETARY RAJAMOHAN K.V.
26 POYILOOR SERVICE CO-OPERATIVE BANK LTD.
P.O.POYILOOR, KANNUR - 670 693 REPRESENTED BY ITS
SECRETARY PRAJEESH K.
27 THILLENKERI SERVICE CO-OPERATIVE BANK LTD.
P.O.THILLENKERI, KANNUR - 670 702 REPRESENTED BY ITS
SECRETARY UJALAKUMARI P.M.
28 PADITOTCHAL SERVICE CO-OPERATIVE BANK LTD.
P.O.PADIYOTCHAL, KANNUR - 670 353 REPRESENTED BY ITS
SECRETARY SMITHA K.N.
29 KANNADIPARAMBA SERVICE CO-OPERATIVE BANK LTD.
P.O.KANNADIPARAMBA, KANNUR - 670 604 REPRESENTED BY
ITS SECRETARY PURUSHOTHAMAN K.
2025:KER
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0 KANDAMKUNNU SERVICE CO-OPERATIVE BANK LTD.
NIRMALAGIRI, KANNUR - 670 701 REPRESENTED BY ITS
SECRETARY BABU P.
31 PATTUVAM SERVICE CO-OPERATIVE BANK LTD.
P.O.PATTUVAM, KANNUR - 670 701 REPRESENTED BY ITS
SECRETARY SRIVINVASAN K.P.
32 PARIYARAM SERVICE CO-OPERATIVE BANK LTD.
PARIYARAM P.O., KANNUR - 670 502 REPRESENTED BY ITS
SECRETARY SASEENDRAN N.
33 KANHILERI- SIVAPURAM SERVICE CO-OPERATIVE BANK LTD.
P.O.KANHILERI, KANNUR - 670 702 REPRESENTED BY ITS
SECRETARY M.REJITHA.
34 KAPPAD SERVICE CO-OPERATIVE BANK LTD.
P.O.KAPPAD, KANNUR - 670 006 REPRESENTED BY ITS
SECRETARY RAJEEVAN P.K.
35 PAYYANNUR SERVICE CO-OPERATIVE BANK LTD.
P.O.PAYYANNUR, KANNUR - 670 307 REPRESENTED BY ITS
SECRETARY NISHA T.V.
36 KOROM SERVICE CO-OPERATIVE BANK LTD.
P.O.KANAYI, PAYYANNUR, KANNUR - 670 307 REPRESENTED
BY ITS SECRETARY SURENDRAN K.C.
37 PANNIYANUR SERVICE CO-OPERATIVE BANK LTD.
P.O.PANNIYANNUR, KANNUR - 670 671 REPRESENTED BY ITS
SECRETARY PAVITHRAN K.
38 CHUZHALI SERVICE CO-OPERATIVE BANK LTD.
P.O.CHUZHALI, KANNUR 670 142 REPRESENTED BY ITS
SECRETARY SAJEESH KUMAR P.K.
39 PUZHATHI SERVICE CO-OPERATIVE BANK LTD.
P.O.KAKKAD, KANNUR - 670 005 REPRESENTED BY ITS
SECRETARY JAYARAJAN P.
40 KADAMBOOR SERVICE CO-OPERATIVE BANK LTD.
P.O.EDAKKAD, KANNUR - 670 663 REPRESENTED BY ITS
SECRETARY PRAMEELA C.
2025:KER
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41 MUZHAKUNNU SERVICE CO-OPERATIVE BANK LTD.
P.O.CHITTARIPARAMBA, KANNUR 670 650 REPRESENTED BY
ITS SECRETARY SACHITHA K.
42 KADACHIRA SERVICE CO-OPERATIVE BANK LTD.
P.O.KADACHIRA, KANNUR - 670 621 REPRESENTED BY ITS
SECRETARY SANIL P.
43 AZHIKODE SERVICE CO-OPERATIVE BANK LTD.
P.O.AZHIKODE, KANNUR - 670 009 REPRESENTED BY ITS
SECRETARY RAJEEVAN M.K.
44 PERALASSERI SERVICE CO-OPERATIVE BANK LTD.
MUNDALLUR P.O., KANNUR - 670 622 REPRESENTED BY ITS
SECRETARY KAMALAKSHAN K.P.
45 KEEZXHALLUR SERVICE CO-OPERATIVE BANK LTD.
MATTANNUR P.O., KANNUR - 670 702 REPRESENTED BY ITS
SECRETARY MURALIDHARAN P.M.
46 MALAPATTOM SERVICE CO-OPERATIVE BANK LTD.
MALAPATTOM P.O., KANNUR - 670 631 REPRESENTED BY ITS
SECRETARYJAYALAKSHMI P.T.
47 KUTHUPARAMBA SERVICE CO-OPERATIVE BANK LTD.
P.O.KOOTHUPARAMBA, KANNUR - 670 643 REPRESENTED BY
ITS SECRETARY SAJIMA K.P.
48 CHERUKUNU SERVICE CO-OPERATIVE BANK LTD.
P.O.CHERUKUNNU, KANNUR - 670 301 REPRESENTED BY ITS
SECRETARY BABURAJ E.
49 PAYYAVOOR SERVICE CO-OPERATIVE BANK LTD.
P.O.PAYYAVOOR, KANNUR - 670 633 REPRESENTED BY ITS
SECRETARY RAJESH KUMAR M.V.
50 KANKOL SERVICE CO-OPERATIVE BANK LTD.
P.O.KANKOL, KANNUR - 670 307 REPRESENTED BY ITS
SECRETARY RATHI K.P.
51 ULIKKAL SERVICE CO-OPERATIVE BANK LTD.
P.O.ULIKKAL, KURUVA, KANNUR - 670 505 REPRESENTED BY
ITS SECRETARY BINU THOMAS.
2025:KER
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52 KUNNARU SERVICE CO-OPERATIVE BANK LTD.
P.O.PALAKKODE, KANNUR - 670 305 REPRESENTED BY ITS
SECRETARY SUNIL KUMAR K.P.
53 PATTIAM SERVICE CO-OPERATIVE BANK LTD.
P.O.PATHAYAKUNNU, KANNUR - 670 691 REPRESENTED BY ITS
SECRETARY SREEJAKUMAR P.
54 MATHIL SERVICE CO-OPERATIVE BANK LTD.
MATHIL P.O., KANNUR - 670 307 REPRESENTED BY ITS
SECRETARY THAMBAN T.
55 KOLARI SERVICE CO-OPERATIVE BANK LTD.
KOLARI P.O., KANNUR - 670 702 REPRESENTED BY ITS
SECRETARY K.NARAYANAN.
56 KURUMATHUR SERVICE CO-OPERATIVE BANK LTD.
P.O.KURUMATHUR, KANNUR - 670 142 REPRESENTED BY ITS
SECRETARY RAVICHANDRAN E.
57 P;ONNAMPARA SERVICE CO-OPERATIVE BANK LTD.
P.O.PERINGOM, KANNUR - 670 307 REPRESENTED BY ITS
SECRETARY SHEEBA V.V.
58 KUTHUPARAMBA CO OPERATIVE RURAL BANK LTD.
P.O.KOOTHUPARAMBA, KANNUR - 670 643 REPRESENTED BY
ITS SECRETARY T.P.YAMUNA.
59 VENGAD SERVICE CO-OPERATIVE BANK LTD.
P.O.VENGAD, KANNUR - 670 612 REPRESENTED BY ITS
SECRETARY VIMALA M.
60 VALIYANNUR SERVICE CO-OPERATIVE BANK LTD.
P.O.VARAM, KANNUR - 670 599 REPRESENTED BY ITS
SECRETARY SUNIL KUMAR P.
61 KUNHUMANGALAM SERVICE CO-OPERATIVE BANK LTD.
P.O.KUNHIMANGALAM, KANNUR - 670 309 REPRESENTED BY
ITS SECRETARY USHA KUMARI V.P.
62 KOYYODE SERVICE CO-OPERATIVE BANK LTD.
P.O.KOYYODE, KANNUR - 670 621 REPRESENTED BY ITS
SECRETARY SHISNA T.C.
2025:KER
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63 ALAKKODE SERVICE CO-OPERATIVE BANK LTD.
P.O.ALAKKODE, KANNUR - 670 571 REPRESENTED BY ITS
SECRETARY E.A.JOSEPH.
64 IRINAV SERVICE CO-OPERATIVE BANK LTD.
P.O.IRINAV, KANNUR 670 301 REPRESENTED BY ITS
SECRETARY K.RAJEEVAN.
65 PALLIKKUNNU SERVICE CO-OPERATIVE BANK LTD.
P.O.CHALAD, KANNUR - 670 014 REPRESENTED BY ITS
SECRETARY ANILA M.
66 KANNAPURAM SERVICE CO-OPERATIVE BANK LTD.
P.O.CHERUKUNNU, KANNUR - 670 301 REPRESENTED BY ITS
SECRETARY ARUNAKUMAR T.K.
67 VELLUR SERVICE CO-OPERATIVE BANK LTD.
P.O.VELLUR, PAYYANUR, KANNUR - 670 307 REPRESENTED BY
ITS SECRETARY THANKAMANI K.
68 MULLAKKODI CO-OPERATIVE RURAL BANK LTD.
P.O.KOLACHERI, KANNUR - 670 601 REPRESENTED BY ITS
SECRETARY VALSAN T.V.
69 RAMANTHALI SERVICE CO-OPERATIVE BANK LTD.
P.O.RAMANTHALI, KANNUR 670 308 REPRESENTED BY ITS
SECRETARY K.V.SURENDRAN.
70 PATHIRIYAD SERVICE CO-OPERATIVE BANK LTD.
NO.F 1465, P.O.PATHIRIYAD, KANNUR - 670 741
REPRESENTED BY ITS SECRETARY RUBY CHACKO.
71 AECHOOR SERVICE CO-OPERATIVE BANK LTD.
NO.L 75, P.E.EACHUR, KANNUR - 670 591 REPRESENTED BY
ITS SECRETARY SHAJI P.P.
72 KANNUR TOWN SERVICE CO-OPERATIVE BANK LTD.
P.O.KANNUR, KANNUR - 670 002 REPRESENTED BY ITS
SECRETARY BEENA E.
73 PUNNAD SERVICE CO-OPERATIVE BANK LTD.
NO.LL 57, P.O.IRITTY, KANNUR - 670 703 REPRESENTED BY
SECRETARY K.C.RAJEEV.
2025:KER
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74 PERAVOOR REGIONAL SERVICE CO-OPERATIVE BANK LTD.
NO.C 338, HEAD OFFICE, PERAVOOR, P.O.PERAVOOR, KANNUR
- 670 673 REPRESENTED BY ITS SECRETARY BALAKRISHNAN
V.V.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF INDIA,
NORTH BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS
CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018.
4 PRINCIPAL COMMISSIONER OF INCOME OF TAX KOZHIKODE
AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE - 673 001.
5 INCOME TAX OFFICER
TDS WARD TDS, KANNUR, AYAKAR BHAVAN, OFFICE OF THE
ADDITIONAL COMMISSIONER OF INCOME TAX, KANNOTHUMCHAL,
CHOVVA P.O., KANNUR - 670 006.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
2025:KER
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EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
SHRI.VIVEK A.V.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 183
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11184 OF 2022
PETITIONER/S:
PUTHUPPALLY SERVICE CO-OPERATIVE BANK LTD N.O 1504,
HEAD OFFICE, PUTHUPPALLY P.O.KOTTAYAM-686 611,
REPRESENTED BY ITS SECRETARY BALAKRISHNAN K.N.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110 001.
2 THE CENTRAL BOARD OF DIRECTO TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED
BY ITS CHAIRMAN
3 PRINCIPAL CHIEF, COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
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INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANNTHAPURAM-695 003.
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKARA BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM-695 003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANNTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 185
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11186 OF 2022
PETITIONER/S:
1 THE PANACHIKKADU REGIONAL SERVICE CO-OPERATIVE BANK
LTD NO.3959
CHANNANIKKADU P.O.KOTTAYAM DISTRICT, REPRESENTED BY
ITS SECRETARY.
2 THE KOLLAD SERVICE CO-OPERATIVE BANK LTD NO 1830,
KOLLAD P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
3 THE MEENADOM SERVICE CO-OPERATIVE BANK LTD NO K 401,
MEENADOM P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
4 THE ANICKAD REGIONAL FARMERS SERVICE CO-OPERATIVE
BANK LTD NO 3867,
ANICKAD P.O.PALLICKATHODU, KOTTAYAM DISTRICT,
REPRESENTED BY ITS MANAGING DIRECTOR
5 THE KOOROPPADA SERVICE CO-OPERATIVE BANK LTD NO 3965,
KOROPPADA P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY.
6 THE VELLOOR SERVICE CO-OPERATIVE BANK LTD NO K 231,
VELLOOR P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
7 THE PAMPADY SERVICE CO-OPERATIVE BANK LTD NO K 831,
PAMPADY P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
2025:KER
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8 KUMARAKOM VADAKKUMBHAGOM SERVICE CO-OPERATIVE BANK
LIMITED NO 1070,
KUMARAKOM, KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM,
PIN-682 018
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11194 OF 2022
PETITIONER/S:
THALAYAZHAM SERVICE CO-OPERATIVE BABK LTD NO 509
THALAYAZHAM P.O., KOTTAYAM - 686 607, REPRESENTED BY
ITS SECRETARY JOSE K.O.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS
CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
2025:KER
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REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM - 695 033.
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM - 695 003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (C-OPERATION),
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
SHRI.RAMKUMAR J., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 189
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11203 OF 2022
PETITIONER/S:
1 THE VANDIPERIYAR SERVICE CO-OPERATIVE BANK LTD.NO.K-
354,
REPRESENTED BY ITS SECRETARY, SAJEESH MATHEW, AGED 32
YEARS, S/O.MATHEW, HEAD OFFICE, VANDIPERIYAR P.O.,
IDUKKI-685 533.
2 THE KOKKAYAR SERVICE CO-OPERATIVE BANK LTD. NO.3267,
REPRESENTED BY ITS SECRETARY, SHAMEENA.N.I.,
D/O.ISMAIL, AGED 48 YEARS, HEAD OFFICE, NARAKAMPUZHA,
KOOTTIKKAL P.O., IDUKKI-685 514.
3 THE PERUVANTHANAM SERVICE CO-OPRATIVE BANK LTD. NO.K
186,
REPRESENTED BY ITS SECRETARY, SHEENA JOSEPH, W/O.JOSE
THOMAS, AGED 46 YEARS, HEAD OFFICE, PERUVANTHANAM
P.O., IDUKKI-685 532.
4 THE PAMBANASR SERVICE CO-OPERATIVE BANK LTD. NO.K-
351,
REPRESENTED BY ITS SECRETARY, P.SUDHESH KUMAR, AGED
57 YEARS, S/O.PRABHAKARAN NAIR, HEAD OFFICE, PAMBANAR
P.O., IDUKKI DISTRICT-685 531.
5 THE CHENKARA SERVICE CO-OPERATIVE BANK LTD. NO.I-254,
REPRESENTED BY ITS SECRETORY, MARYKUTTY JOSEPH,
W/O.GEORGE, AGED 57 YEARS, HEAD OFFICE, CHELIMADA,
KUMILY P.O., IDUKKI-685 507.
BY ADVS.
2025:KER
W.P(C)No.7053/2023 & Connected cases 190
SRI.GEORGE MATHEW
SHRI.PRAVEEN S.
SMT.ELSA DENNY PINDIS
SRI.M.D.SASIKUMARAN
SHRI.SUNIL KUMAR A.G
SRI.DIPU JAMES
SHRI.MATHEW K.T.
SHRI.GEORGE K.V.
SHRI.STEPHY K REGI
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
002.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682
018.
3 THE INCOME TAX OFFICER,
TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8,
THODUPUZHA, IDUKKI DISTRICT-685 584.
4 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT,
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM-695 014.
6 THE KERALA STATE CO-OPERATIVE BANK LTD., (KERALA
BANK),
REPRESENTED BY ITS MANAGING DIRECTOR 7 CHIEF
EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033.
7 THE DEPUTY GENERAL MANAGER,
CENTRAL PROCESSING CENTER, THE KERALA STATE CO
2025:KER
W.P(C)No.7053/2023 & Connected cases 191
OPERATIVE BANK LTD., (KERALA BANK), VAZHATHOPE, IUKKI
COLONY P.O., IDUKKI DISTRICT-685 602.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 192
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11224 OF 2022
PETITIONER/S:
KOTHAVARA SERVICE CO-OPERATIVE BANK LTD,
NO. 1359, KOTHAVARA P.O. KOTTAYAM 686 607,
REPRESENTED BY ITS SECRETARY, ANILKUMAR V.S.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI 11001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 11001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 193
INDIA, CENTRAL REVENUE, BUILDINGS, I.S. PRESS ROAD
KOCHI 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANCE 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM 695 003.
5 INCOME TAX OFFICER, (TDS),
THIRUVANANTHAPURAM , 3RD FLOOR AAYAKAR BAHVAN,
KOWDIAR, THIRUVANANTHAPURAM 695 003.
6 THE KERALA STATE CO - OPERATIVE BANK LTD,
PB NO. 6515, CO BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM 695 001.
BY ADVS.
SHRI.JUSTUS S., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SMT.SINDHUMOL.T.P., CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 194
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11232 OF 2022
PETITIONER/S:
THE KALAMASSERY SERVICE CO-OPERATIVE
BANK LIMITED NO. 3046, KALAMASSERY NORTH, ERNAKULAM
DISTRICT, REPRESENTED BY ITS SECRETARY, 683 104.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM
682 018.
2 THE INCOME TAX OFFICER, (TDS),
INCOME TAX DEPARTMENT, ERNAKULAM, 680001.
3 THE KERALA STATE CO - OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR 695 033.
4 THE MANAGER,
KERALA STATE CO OPERATIVE BANK LTD., KALAMASSERY,
PATHADIPALAM BRANCH, ERNAKULAM 682 104.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 195
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11248 OF 2022
PETITIONER/S:
1 THUDANGAD SERVICE CO-OPERATIVE BANK LTD.NO. 2410
REPRESENTED BY ITS SECRETARY, BENNY MATHEW, S/O
MATHEW, AGED 56 YEARS, HEAD OFFICE, THUNDANGANGAD P
O, IDUKKI-685587.
2 KODIKULAM SERVICE CO-OPERATIVE BANK LTD.NO.2823
REPRESENTED BY ITS SECRETARY, ABIN MICHAEL, S/O
MICHAEL, AGED 28 YEARS, HEAD OFFICE, KODIKULAM P O,
IDUKKI-685582.
3 UDUMBANOOR SERVICE CO-OPERATIVE BANK LTD.NO. E-93
REPRESENTED BY ITS SECRETARY, , REMYA BALACHANDRAN,
W/O AJEESH KUMAR, AGED 37 YEARS, HEAD OFFICE,
UDUMBANOOR P O, IDUKKI DISTRICT-685595.
4 KARIKODE SERVICE CO-OPERATIVE BANK LTD NO.4009.
REPRESENTED BY ITS SECRETARY, MOLLY P V, W/O SUNNY P
J, AGED 56 YEARS,HEAD OFFICE, KARIKODE, THODUPUZHA P
O, IDUKKI-685584.
5 MANAKKAD SERVICE CO-OPERATIVE BANK LTD NO. 1706
REPRESENTED BY ITS SECRETARY, NIRMAL SHAJI, S/O
SHAJI, AGED 31 YEARS, MANAKKAD, MANAKKAD P O, IDUKKI-
685608.
6 PURAPUZHA SERVICE CO-OPERATIVE BANK LTD NO.E-70
AGED 46 YEARS
REPRESENTED BY ITS SECRETARY, IN -CHARGE, BINDUMOL M
J, W/O SREEKUMAR B, HEAD OFFICE, PURAPUZHA P O,
PURAPUZHA, IDUKKI-685583.
2025:KER
W.P(C)No.7053/2023 & Connected cases 196
7 THE ARAKULAM FARMERS SERVICE CO-OPERATIVE BANK LTD
NO.E-70
AGED 55 YEARS
REPRESENTED BY ITS MANAGING DIRECTOR, JOSHY V MATHEW,
S/O MATHEW, HEAD OFFICE, ARAKULAM P O, THODUPUZHA,
IDUKKI, -685591.
8 KUMARAMANGALAM SERVICE CO-OPERATIVE BANK LTD
NO.4122M,
REPRESENTED BY ITS SECRETARY, AJITH V ABRAHAM, S/O
ROY ABRAHAM, AGED 27 YEARS, HEAD OFFICE, KALOOR EAST,
KALOOR P O, IDUKKI-685608.
9 VELLIYAMATTAM, SERVICE CO-OPERATIVE BANK LTD NO.3958
AGED 50 YEARS
REPRESENTED BY ITS SECRETARY IN-CHARGE, JOJO
SEBASTIAN, S/O SEBASTIAN, HEAD OFFICE, PANNIMATTAM P
O, THODUPUZHA-685588.
10 THE PUTHUPARIYARAM SERVICE CO-OPERATIE BANK LTD.NO.E-
55.
REPRESENTED BY ITS SECRETARY JENCY MATHEW, AGED 50
YEARS, W/O SEBASTIAN, PUTHUPARIYARAM P O, IDUKKI-
685608.
11 THE THODUPUZHA TALUK RURAL MERCHATNT'S CO-OPERATIVE
WELFARE SOCIETY LTD.NO.I-768,
REPRESENTED BY ITS SECRETARY,SHAJI VARGHESE, S/O
VARGHESE, AGED 54 YEARS, EDAVETTY P O, THODUPUZHA
TALUK, IDUKKI DISTRICT-685588.
12 THODUPUZHA TOWN SERVICE CO-OPERATIVE BANK LTD NO.I-
233
REPRESENTED BY ITS SECRETARY, RAKHI C, W/O JAGADEESH,
AGED 41 YEARS, HEAD OFFICE, THODUPUZHA P O, IDUKKI-
685584.
13 THE THODUPUZHA SERVICE CO-OPERATIVE BANK LTD NO.969.
REPRESENTED BY ITS SECRETARY, JAYASREE P, W/O T R
SOMAN, AGED 50 YEARS, HEAD OFFICE, THODUPUZHA P O,
IDUKKI-685584.
14 THE IDUKKI DISTRICT KERALA BANK EMPLOYES' CO-
OPERATIVE SOCIETY NO.E-323
2025:KER
W.P(C)No.7053/2023 & Connected cases 197
REPRESENTED BY ITS SECRETARY, JAYACHANDRAN K, S/O P K
KARUNAKARAN NAIR, HEAD OFFICE, VAZHATHOPE, IDUKKI
COLONY P O, IDUKKI DISTRICT-685602.
15 THE THODUPUZHA TALUK REGIONAL SOCIAL WELFARE CO-
OPERATIVE SOCIETY LTD NO.I-690,
REPRESENTED BY ITS SECRETARY, ANJITH REJI, AGED 27
YEARS, S/O P N REJI, VENGALLUR P O, THODUPUZHA TALUK,
IDUKKI DISTRICT-685608.
BY ADVS.
SRI.GEORGE MATHEW
SHRI.PRAVEEN S.
SMT.ELSA DENNY PINDIS
SRI.M.D.SASIKUMARAN
SHRI.SUNIL KUMAR A.G
SRI.DIPU JAMES
SHRI.MATHEW K.T.
SHRI.GEORGE K.V.
SHRI.STEPHY K REGI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110002.
2 THE COMMISSINER OF INCOME TAX
CENTRAL REVENUE BUILDINGS I.S.PRESS ROAD, KOCHI-
682018.
3 THE INCOME TAX OFFICER
TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8,
THODUPUZHA, IDUKKI DISTRICT-685584.
4 STATE OF KERALA
REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT,
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES
2025:KER
W.P(C)No.7053/2023 & Connected cases 198
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM-695014.
6 THE KERALA STATE CO-OPERATIVE BANK LTD
REPRESENTED BY MANAGING DIRECTOR AND CHIEF EXECUTIVE
OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-
695033.
7 THE DEPUTY GENERAL MANAGER
CENTER PROCESSING CENTRE, THE KERALA STATE CO-
OPERATIVE BANK LTD, (KERALA BANK), VAZHATHOPER,
IDUKKI COLONY P O, IDUKKI DISTRICT-685602.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 199
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11247 OF 2022
PETITIONER/S:
1 THE KUMARANALLOOR SERVICE CO-OPERATIVE BANK LTD.
NO.3998,
PERUMPAIKKAD P O, KOTTAYAMM DISTRICT, REPRESENTED BY
ITS SECRETARY.
2 THE NEEENDOOR SERVICE CO-OPERATIVE BANK LTD. NO.2641
NEENDOOR P O, KOTTAYAM DISTRICT, PIN-686601.
REPRESENTED BY ITS SECRETARY.
3 THE KAIPUZHA SERVICE CO-OPERATIVE BANK LTD. NO.3793
KAIPUZHA P O, KOTTAYAM DISTRICT, PIN-686602,
REPRESENTED BY ITS SECRETARY.
4 THE GOVERNMENT EMPLOYEES CO-OPERATIVE SOCIETY LTD
NO.K-338
ETTUMANOOR P O, KOTTAYAM DISTRICT, PIN-686631,
REPRESENTED BY ITS SECRETARY.
5 THE KALLARA VILLAGE SERVICE CO-OPERATIVE BANK LTD.
NO.3123
KALLARA, KOTTAYAM DISTRICT, PIN-686611. REPRESENTED
BY ITS SECRETARY.
6 THE KALLARA SERVICE CO-OPERATIVE BANK LTD. NO.582
KALLARA SOUTH P O, KOTTAYAM DISTRICT, PIN-686611,
REPRESENTED BY ITS SECRETARY.
7 THE AYMANAM VILLAGE SERVICE CO-OPERATIVE BANK LTD.
NO.750.
AYMANAM, KOTTAYAM DISTRICT, PIN-686005, REPRESENTED
BY ITS SECRETARY.
2025:KER
W.P(C)No.7053/2023 & Connected cases 200
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX
CENTRAL REVENUE BUILDING, I S PRESS ROAD, ERNAKULAM,
PIN-682018.
3 THE INCOME TAX OFFICER
INCOME TAX DEPARTMENT KOTTAYAM, PIN-686001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
5 THE REGIONAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, REGIONAL OFFICE,
KOTTAYAM, PIN-686001.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 201
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11262 OF 2022
PETITIONER/S:
THALAYOLAPARAMBU FARMERS SERVICE CO-OPERATIVE BANK
LTD.NO.278,
THALAYOLAPARAMBU P.O, KOTTAYAM 686 605, REPRESENTED
BY ITS MANAGING DIRECTOR, MRS. MINIMOL ISSAC.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
2025:KER
W.P(C)No.7053/2023 & Connected cases 202
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM-695 003.
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM- 695 003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD. ,
PB NO. 6515, CO- BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- 695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM- 695 001.
BY ADVS.
SHRI.KARTHIK S.A., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 203
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11260 OF 2022
PETITIONER/S:
THE KOTTAYAM DISTRICT POSTS, TELECOM & BSNL EMPLOYEES
CO-OPERATIVE SOCIETY LTD NO. K 343,
KOTTAYAM, REPRESENTED BY ITS SECRETARY- 686 001.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, KOTTAYAM ,
PIN 682 018.
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX DEPARTMENT, SHAKTAN NAGAR, KOTTAYAM, PIN
680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033.
5 THE MANAGER,
THE KERALA STATE CO-OPERATIVE BANK LTD., KOTTAYAM,
PIN 686 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 204
BY ADVS.
SHRI.RAMKUMAR J., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 205
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11263 OF 2022
PETITIONER/S:
THOTTAKAM SERVICE CO-OPERATIVE BANK LTD.NO.470,
OTTAKAM P.O, KOTTAYAM- 686 607, REPRESENTED BY ITS
SECRETARY, SHIJU K.K.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX ,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 206
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM- 695 003.
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM- 695 003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO. 6515, CO - BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM- 695 001.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 207
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11271 OF 2022
PETITIONER/S:
1 ALAPAD-PULLU SERVICE CO-OPERATIVE BANK LIMITED
NO 130, ALAPAD P.O. THRISSUR REPRESENTED BY ITS
SECRETARY, PIN - 680641
2 CHAZHUR SERVICE CO-OPERATIVE BANK
LIMITED NO 106, P.O. CHAZHUR THRISSUR REPRESENTED BY
THE SECRETARY, PIN - 680571
BY ADVS.
SRI.C.HARIKUMAR
SMT.SANDRA SUNNY
SHRI.ARUN KUMAR M.A
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI REPRESENTED BY ITS
CHAIRMAN, PIN - 110001
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 208
INDIA CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD
ERNAKULAM, PIN - 682018
4 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS)
OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX
3RD FLOOR, AAYAKAR BHAVAN, KOWADIAR
THIRUVANANTHAPURAM, PIN - 695003
5 THE INCOME TAX OFFICER (TDS)
AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR MUNICIPAL
OFFICE ROAD THRISSUR, PIN - 680001
6 THE KERALA STATE CO-OPERATIVE BANK LIMITED
PB NO 6515, COBANK TOWERS VIKAS BHAVAN P.O., PALAYAM
THIRUVANANTHAPURAM REPRESENTED BY ITS CHIEF EXECUTIVE
OFFICER, PIN - 695033
7 THE KERALA STATE CO-OPERATIVE BANK LIMITED
PERINGOTTUKKARA BRANCH KHADI GRAMODYOG BUILDING,
PERINGOTTUKKARA P.O. THRISSUR REPRESENTED BY ITS
BRANCH MANAGER, PIN - 680565
8 THE STATE OF KERALA
REPRESENTED BY ITS PRINCIPAL SECRETARY TO THE CO-
OPERATIVE DEPARTMENT SECRETARIAT, FORT P.O.
THIRUVANANTHAPURAM, PIN - 695023
BY ADVS.
SHRI.S.BIJU, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.P.C.SASIDHARAN, SC, THRISSUR DISTRICT
CO.OPERATIVE BANK LTD.
GOVERNMENT PLEADER
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 209
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11272 OF 2022
PETITIONER/S:
THE PERUMATTY SERVICE CO-OPERATIVE BANK LTD NO.757
POLLACHI ROAD, VANDITHAYALAM P.O., PALAKKAD - 678
534, REPRESENTED BY ITS SECRETARY, YESODHA N.
BY ADV SMT.MEERA V.MENON
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (TDS)
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 18.
2 THE INCOME TAX OFFICER
INCOME TAX DEPARTMENT, WARD NO.5, PALAKKAD - 678 001.
3 THE KERALA STATE CO-OPERATIVE BANK
REGIONAL OFFICE, PB.NO.21, H.P.O.ROAD, SULTHANPET,
PALAKKAD - 678 001, REPRESENTED BY ITS GENERAL
MANAGER-IN-CHARGE.
4 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT, MINISTRY OF
FINANCE (DEPARTMENT OF REVENUE), NORTH BLOCK, NEW
DELHI - 110 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 210
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 211
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11273 OF 2022
PETITIONER/S:
VILAPPIL SERVICE CO-OPERATIVE BANK LTD.
NO.2522, HEAD OFFICE, PEYYAD, THIRUVANANTHAPURAM, PIN
- 695 573, REPRESENTED BY ITS SECRETARY, S.
RICHARDSON, S/O.S. STEPHENSON, AGED 56 YEARS,
RESIDING AT TRIPTHI, MALAYAM P.O., THIRUVANANTHAPURAM
DISTRICT
BY ADVS.
SRI.BABU S. NAIR
SMT.SMITHA BABU
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY MINISTRY OF FINANCE
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN -
110001
2 THE CENTRAL BOARD OF DIRECT TAXES
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI, PIN - 682018
2025:KER
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4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM, PIN - 695003
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003
6 THE KERALA STATE CO-OPERATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 STATE OF KERALA
STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-
OPERATION) GOVERNMENT SECRETARIATE,
THIRUVANANTHAPURAM, PIN - 695001
BY ADVS.
SRI.CHRISTOPHER ABRAHAM
SHRI.THOMAS ABRAHAM
GOVERNMENT PLEADER
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 213
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11286 OF 2022
PETITIONER/S:
THE NATTAKAM SERVICE CO-OPERATIVE BANK LTD.
NO.3839, PAKKIL P.O., KOTTAYAM DISTRICT, REPRESENTED
BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, AYKAR BHAVAN, KOTTAYAM, PIN -
686 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
5 THE MANAGER
KERALA STATE CO-OEPRATIVE BANK LTD., PAKKIL, KOTTAYAM
DISTRICT, PIN - 686 539.
2025:KER
W.P(C)No.7053/2023 & Connected cases 214
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 215
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11301 OF 2022
PETITIONER/S:
COCHIN PORT EMPLOYEE CO-OPERATIVE SOCIETY LTD.,
NO. 855, WILLINGTON ISLAND COCHIN, COCHIN 682 009,
REPRESENTED BY ITS SECRETARY, DILEEP A.P.
BY ADVS.
SHRI.ANIL D. NAIR (SR.)
SMT.TELMA RAJU
SHRI.ARAVIND SREEKUMAR
SMT.EDATHARA VINEETA KRISHNAN
RESPONDENT/S:
1 JOINT COMMISSIONER OF INCOME TAX (TDS),
C.R. BUILDING, I.S PRESS ROAD, KOCHI 682 018.
2 KERALA STATE CO-OPERATIVE BANK LTD. ,
ERNAKULAM BRANCH BUILDING NO. 41/4263, GROUND FLOOR
MARKET ROAD, ERNAKULAM NORTH P.O, KOCHI 682 018, REP.
BY REGIONAL MANAGER.
3 KERALA STATE CO-OPERATIVE BANK LTD.,
MATTANCHERRY, ERNAKULAM, KERALA- 682 002, REP. BY
MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 216
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 217
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11309 OF 2022
PETITIONER/S:
1 MUPPATHADAM SERVICE CO-OPERATIVE BANK LTD. NO. E 216
MUPPATHADAM P.O, ERNAKULAM DISTRICT, PIN - 683110,
REPRESENTED BY ITS SECRETARY.
2 KUNNATHUNAD SERVICE CO-OEPARATIVE BANK LTD NO. E3,
KUMARAPURAM, P.O, ERNAKULAM DISTRICT, PIN - 683565,
REPRESENTED BY ITS SECRETARY.
3 CHERANALLOOR SERVICE CO-OPERATIVE SOCIETY LTD, NO.
2417,
EDAVOOR P.O, KOOVAPADY, ERNAKULAM DISTRICT, PIN -
683544, REPRESENTED BY ITS SECRETARY.
4 ELOOR RURAL CO-OPERATIVE BANK LTD, NO.E-1098
ELOOR EAST, UDYOGAMANDAL, ERNAKULAM DISTRICT, PIN -
683501, REPRESENTED BY ITS SECRETARY.
5 ANGAMALY URBAN CO-OPERATIVE SOCIETY LTD NO.E-1081
T.B. JUNCTION SAHAKARANA BHAVAN, ERNAKULAM DISTRICT,
PIN - 683572, REPRESENTED BY ITS SECRETARY.
6 MOOKKANNOOR SERVICE CO-OPERATIVE BANK LTD NO. E-62,
MOOKKANNOOR, P.O, ANGAMALY, ERNAKULAM DISTRICT, PIN -
683577, REPRESENTED BY ITS SECRETARY.
7 NELLAD-VEETTOOR SERVICE CO-OPERATIVE SOCIETY LTD
NO.E-332.
NELLAD P.O, ERNAKULAM DISTRICT, PIN - 686669,
REPRESENTED BY ITS SECRETARY.
2025:KER
W.P(C)No.7053/2023 & Connected cases 218
8 TRIPUNITHURA HOUSING CO-OPERATIVE BANK SOCIETY NO. E
715,
TRIPUNITHURA P.O, ERNAKULAM DISTRICT, PIN - 682301,
REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.M.M.MONAYE
SHRI.M.PAUL VARGHESE
SRI.K.V.SANOSH
SMT.NIRMALA P.V.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI, PIN - 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI - 110001.
3 COMMISSIONER OF INCOME TAX (TDS)
C.R. BUILDINGS, I.S. PRESS ROAD, ERNAKULAM - 682018.
4 STATE OF KERALA
DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT,
REPRESENTED BY SECRETARY TO GOVERNMENT,
THIRUVANANTHAPURAM - 695001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM - 695001.
6 THE KERALA STATE CO-OPERATIVE BANK LTD,
CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, THIRUVANANTHAPURAM - 695033.
7 DEPUTY GENERAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, CREDIT PROCESSING
2025:KER
W.P(C)No.7053/2023 & Connected cases 219
CENTRE, KAKKANAD, KOCHI - 682030.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 220
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11316 OF 2022
PETITIONER/S:
1 THE PALAKKAD SERVICE CO-OPERATIVE BANK LTD NO.F 1200
G.B.ROAD, PALAKKAD - 678 001 REPRESENTED BY ITS
SECRETARY, SHRI.C.RAMESHKUMAR.
2 THE PALAKAKD CO-OPERATIVE EMPLOYEES CO-OP.SOCIETY
LTD.NO.P 609
SREEKRISHNA TEMPLE ROAD, KUNNATHURMEDU, PALAKKAD-13,
REPRESENTED BY ITS SECRETARY-IN-CHARGE, SHRI.AKHIL
V.S.
3 PROYADARSHINI MULTI PURPOSE CO-OP. SOCIETY LTD.NO.P-
1340
CROWN PLAZA, VALIPARAMBU ROAD, PALAKKAD-13,
REPRESENTED BY ITS SECRETARY-IN-CHARGE,
SMT.T.S.JANCY.
4 THE KANJIKODE SERVICE CO-OP.BANK LTD.NO.1199
KANJIKODE POST, PALAKKAD, REPRESENTED BY ITS
SECRETARY, SHRI.RADHAKRISHNAN S.
5 PARLI CO-OPERATIVE URBAN CREDIT SOCIETY LTD.NO.P 1223
PARLI POST, PALAKKAD - 678 612 REPRESENTED BY ITS
SECRETARY, SMT.SUJATHA N.
6 RAJEEV GANDHJI MULTIPURPOSE CO-OPERATIVE SOCIETY
LTD.NO.P 1324
AKATHETHARA POST, PALAKKAD, REPRESENTED BY ITS
HONORARY SECRETARY, SHRI.S.GOPINATHAN NAIR.
7 KARIMPUZHA CO-OP. URBAN SOCIETY LTD.NO.P 1171
ELAMBULASERRY, PALAKKAD, REPRESENTED BY ITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 221
SECRETARY, SHRI.JOHNSON K.
8 THE KANNADI CO-OPERATIVE URBAN CREDIT SOCIETY
LTD.NO.P 1207
KAZCHAPARAMBU JUNCTION, KANNADI POST, PALAKKAD,
REPRESENTED BY ITS SECRETARY, SMT.MEERA V.
BY ADVS.
SHRI.A.KUMAR (SR.)
SHRI.P.J.ANILKUMAR
SMTG.MINI(1748)
SRI.P.S.SREE PRASAD
SHRI.JOB ABRAHAM
SHRI.AJAY V.ANAND
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110 001 REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695
033 REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA STATE CO-OPERATIVE BANK LTD
REGIONAL OFFICE, PALAKKAD, H.P.O.ROAD, SULTHANPET,
PALAKKAD.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 222
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 223
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11332 OF 2022
PETITIONER/S:
1 KOTHAMANGALAM TALUK MERCANTILE CO-OPERATIVE SOCIETY
LTD NO. 1159,
KOTHAMANGALAM- ERNAKULAM 686 691, REPRESENTED BY ITS
SECRETARY MANOJ K.S
2 KOTHAMANGALAM TALUK CO-OPERATIVE EMPLOYEES,
CO-OPERATIVE SOCIETY LTD. NO. E 746, KOTHAMANGALAM,
ERNAKULAM 686 691, REPRESENTED BY ITS SECRETARY,
BINOY N.R.
3 PREMIER TYRES EMPLOYEES' MULTI PURPOSE CO-OPERATIVE
SOCIETY LTD. NO. E 282,
KALAMASSERY P.O, ERNAKULAM- 683 104, REPRESENTED BY
ITS SECRETARY SUBBAMMA S.
4 COCHIN UNIVERSITY EMPLOYEES SAHAKARANA SANDHAM LTD.
NO. E 757,
COCHIN UNVERSITY P.O, ERNAKULAM 682 022, REPRESENTED
BY ITS SECRETARY, AKSHAYA BHAT V.L.
5 WAYANAD DISTRICT DRIVERS CO-OPERATIVE SOCIETY LTD.
NO. W 14,
KALPETTA, WAYANAD 6873 121, REPRESENTED BY ITS
SECRETARY AJAY V.R.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
2025:KER
W.P(C)No.7053/2023 & Connected cases 224
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
P B NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 225
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11323 OF 2022
PETITIONER/S:
1 MANJAPRA SERVICE CO-OPERATIVE BANK LTD.
NO.4232, MANJAPRA, P.O.KOCHI - 683 581 REPRESENTED BY
ITS SECRETARY.
2 KALADY KANJOOR RURAL CO-OPERATIVE BANK LTD.NO.E -
1097
KALADY P.O., KOCHI - 682 574, REPRESENTED BY ITS
SECRETARY SINDHU V.
3 THE VENNALA SERVICE CO-OPERATIVE BANK LTD.NO.E-774
VENNALA P.O., KOCHI - 682 028, REPRESENTED BY ITS
SECRETARY LAJI M.N.
4 THAMMANAM SERVICE CO-OPERATIVE BANK LTD.NO.E-182
THAMMANAM P.O., KOCHI - 682 032 REPRESENTED BY ITS
SECRETARY MAYADEVI M.
5 EDAPPALLY VADAKKUMBHAGAM SERVICE CO-OPERATIVE BANK
LTD.NO.E-1431
PONIKARA P.O., KOCHI - 682 041 REPRESENTED BY ITS
SECRETARY SINDHU C.K.
6 THIRUMARAYOOR SERVICE CO-OPERATIVE BANK LTD.NO.809
ARAKKUNAM P.O., KOCHI - 682 313 REPRESENTED BY ITS
SECRETARY ANNAMA VARKEY.
7 THE VELIYANAD CO-OPERATIVE SOCIETY LTD.NO.29
VELIYANAD P.O., ARAKKUNAM, KOCHI - 682 313
REPRESENTED BY ITS SECRETARY SINDHU M.R.
2025:KER
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8 EDAPPALLY SERVICE CO-OPERATIVE BANK LTD.NO.328
EDAPALLY P.O., KOCHI - 682 024, REPRESENTED BY ITS
SECRETARY LEENA MATHAI.
9 THURAVOOR SERVICE CO-OPERATIVE BANK LTD.NO.E-69
THURAVOOR P.O., KOCHI - 688 532 REPRESENTED BY ITS
SECRETARY PAULY SEBASTIAN.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 11000.
2 THE COMMISSIONER OF INCOME TAX (TDS)
C.R.BUILDING, I.S.PRESS ROAD, KOCHI - 682 018.
3 THE INCOME TAX OFFICER (TDS)
3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM
- 695 003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
(ERSTWHILE THE ERNAKULAM DISTRICT CO-OPERATIVE BANK),
KAKKANAD P.O., KOCHI - 682 030.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 227
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11325 OF 2022
PETITIONER/S:
THE PERINGOTTUKURUSSIL SERVICE CO-OPERATIVE BANK LTD
NO.P-519
NO.P-519, PARUTHIPULLY.P.O, PALAKKAD, PIN-678 573
REPRESENTED BY ITSSECRETARY -IN-CHARGE-
C .N .SUCHITHRAN
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-11000.
2 THECOMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG. I.S.PRESS, ROAD, KOCHI-682018
3 THE INCOME TAX OFFICER(TDS)
AYAKKAR BHAVAN, CHURCH ROAD, PALAKKAD-678001
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
(ERSTWHILE PALAKKAD DISTRICT SERVICE CO-OPERATIVE
BANK), HEAD POST OFFICE ROAD, SULTHANPETTA, PALAKKAD-
678 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 228
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 229
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11326 OF 2022
PETITIONER/S:
1 THE VARANAD SERVICE CO-OPERATIVE BANK LTD. NO. 1248,
VARANAD P.O, CHERTHALA- 688 583, REPRESENTED BY ITS
SECRETARY C P RAJAN.
2 KANJIKUZHY SERVICE CO-OPERATIVE BANK LTD. NO. 1558,
S.L. PURAM P.O, KANJIKUZHY-688 523, REPRESENTED BY
ITS SECRETARY- P GEETHA.
3 CHERTHALA TALUK,
GOVT. EMPLOYEES AND PENSIONERS CO-OPERATIVE SOCIETY
LTD. NO. A 1195, CHERTHALA P.O- 688 524, REPRESENTED
BY ITS HONARARY SECRETARY K BHARATHAN.
4 THE MUTTOM SERVICE CO-OPERATIVE BANK LTD. NO. 1165,
CHERTHALA P.O, 688 524, REPRESENTED BY ITS SECRETARY-
MERCY JOHN.
5 THE CHERTHALA CO-OPERATIVE URBAN SOCIETY LTD. NO.
2655,
CHERTHALA P.O, 688 524, REPRESENTED BY ITS SECRETARY-
D MADHUSUDHAN.
6 KIZHAKKENALPATHIL SERVICE CO-OPERATIVE BANK LTD. NO.
1164,
CHERTHALA P.O, 688 524, REPRESENTED BY ITS SECRETARY-
MADHUSUDANAN K P.
7 CHERTHALA SERVICE CO-OPERATIVE BANK LTD. NO. 1688,
CHERTHALA, P.O- 688524, REPRESENTED BY ITS SECRETARY-
A T CHANDRA BABU
2025:KER
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8 THE EZHUPUNNA SERVICE CO-OPERATIVE BANK LTD. NO. 953,
EZHUPUNNA P.O, CHERTHALA-688 537, REPRESENTED BY ITS
SECRETARY- BENNY CHACKO.
9 THE AROOR SERVICE CO-OPERATIVE SOCIETY LTD. NO. 2174,
AROOR P.O, ALAPPUZHA- 688 534, REPRESENTED BY ITS
SECRETARY- SELVARAJ C S
0 CHERUVARANAM SERVICE CO-OPERATIVE BANK LTD. NO. 1817,
VARANAM P.O, CHERTHALA, P.O- 688555, REPRESENTED BY
ITS SECRETARY-SINI C.
11 ERAMALLOOR SERVICE CO-OPERATIVE BANK LTD. NO. 1105,
ERAMALLOOR P.O, CHERTHALA 688 537, REPRESENTED BY ITS
SECRETARY- JOLLY B.
12 SHERTALLAI TALUK ,
AIDED SECONDARY SCHOOL EMPLOYEES' C.S. LTD. NO. A
276, CHERTHALA, P.O. 688 524, REPRESENTED BY ITS
SECRETARY- RENJITHA BAI.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL , NEW
DELHI 110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS , ROAD, KOCHI 682 018.
3 INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX DEPT. ALAPPUZHA 688 011.
2025:KER
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4 THE KERALA STATE CO-OPERATIVE BANK LTD.
OPP. MUNICIPAL TOWN HALL, ALAPPUZHA, KERALA 688 011,
REPRESENTED BY ITS REGIONAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 232
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11327 OF 2022
PETITIONER/S:
1 VALLIVATTAM SERVICE CO-OPERATIVE BANK LTDN O 4170,
VALLIVATTAM, THRISSUR-680 123, REPRESENTED BY ITS
SECRETARY
2 THE VELLANGALLUR SERVICE CO-OPERATIVE BANK LTD NO
768,
P.O.VELLANGALLUR, THRISSUR, REPRESENTED BY ITS
SECRETARY-680 123.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682 018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR
2025:KER
W.P(C)No.7053/2023 & Connected cases 233
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 234
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11335 OF 2022
PETITIONER/S:
1 KADUTHURUTHY REGIONAL SERVICE CO-OPERATIVE BANK
LTD.NO.4061
KADUTHURUTHY P.O., KOTTAYAM DISTRICT, REPRESENTED BY
ITS SECRETARY - 686 604.
2 THE UDAYANAPURAM SERVICE CO-OPERATIVE BANK
LTD.NO.1321
UDAYANAPURAM P.O., KOTTAYAM DISTRICT - 68143
REPRESENTED BY ITS SECRETARY.
3 THE VELLAVOOR SERVICE CO-OPERATIVE BANK LTD.NO.4300
KADAYANICKADU P.O., KOTTAYAM DISTRICT - 686 541,
REPRESENTED BY ITS SECRETARY.
4 THE VAZHOOR FARMER'S SERVICE CO-OPERATIVE BANK
LTD.NO.2278
PULICKALKVALA P.O., KOTTAYAM DISTRICT - 686 515,
REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KURICHY SERVICE CO-OPERATIVE BANK LTD.NO.1538
KURICHY P.O., KOTTAYAM DISTRICT - 686 535,
REPRESENTED BY ITS SECRETARY.
6 THE VELLAVOOR CENTRAL SERVICE CO-OPERATIVE BANK
LTD.NO.3435
THAZHATHUVADAKARA P.O., KOTTAYAM DISTRICT - 686 541
REPRESENTED BY ITS SECRETARY.
7 THE NEDUMKUNNAM SOUTH SERVICE CO-OPERATIVE BANK
LTD.NO.1271
PUNNAVELY P.O., KOTTAYAM DISTRICT, NEDUMKKUNNAM - 689
2025:KER
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589, REPRESENTED BY ITS SECRETARY.
8 THE NEDUMKUNNAM SERVICE CO-OPERATIVE BANK LTD.1301
NEDUMKKUNNAM P.O. - 689 589, KOTTAYAM DISTRICT,
REPRESENTED BY ITS SECRETARY.
9 THE CHEERANCHIRA SERVICE CO-OPERATIVE BANK LIMITED
NO.1626
CHEERANCHIRAN P.O., CHANGANACHERRY - 686 106,
KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY.
0 THE VAZHAPPALLY SERVICE CO-OPERATIVE BANK LIMITED
NO.K 108
VAZHAPPALLY P.O., CHANGANACHERRY, KOTTAYAM DISTRICT -
686 103, REPRESENTED BY ITS SECRETARY.
11 THE ITHITHANAM JANATHA SERVICE CO-OPERATIVE BANK
LIMITED NO.K 1297
MALAKUNNAM P.O., CHANGANACHERRY, KOTTAYAM DISTRICT -
686 535, REPRESENTED BY ITS SECRETARY.
12 THE THRUTHY SRVICE CO-OPERATIVE BANK LIMITED NO.K
1486
THRUTHY P.O., CHANGANACHERRY - 686 535, REPRESENTED
BY ITS SECRETARY.
13 THE PAIPPAD SERVICE CO-OPERATIVE BANK LIMITED NO.K
1698
NALUKODY P.O., PAIPPAD, CHANGANACHERRY, KOTTAYAM
DISTRICT - 686 548, REPRESENTED BY ITS SECRETARY.
14 THE KANGAZHA SERVICE CO-OPERATIVE BANK LIMITED
NO.1145
KANGAZHA P.O., CHANGANACHERRY, KOTTAYAM DISTRICT -
686 541, REPRESENTED BY ITS SECRETARY.
15 THE NALUNNAKKAL SERVICE CO-OPERATIVE BANK LIMITED
NO.296
NALUNNAKKAL P.O., CHANGANACHERRY, KOTTAYAM DISTRICT -
686 538, REPRESENTED BY ITS SECRETARY.
16 THE VAKATHANAM SERVICE CO-OPERATIVE BANK LIMITED
NO.4246
VAKATHANAM P.O., CHANGANACHERRY, KOTTAYAM DISTRICT -
2025:KER
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686 538, REPRESENTED BY ITS SECRETARY.
17 THE PAIPPAD CENTRAL SERVICE CO-OPERATIVE BANK LIMITED
NO.3125
PALLICKACHIRA KAVALA P.O., CHANGANACHERRY, KOTTAYAM
DISTRICT - 686 537, REPRESENTED BY ITS SECRETARY.
18 THE NEELAMPEROOR SERVICE CO-OPERATIVE BANK LIMITED
NO.1788
NEELAMPEROOR P.O., ALAPPUZHA DISTRICT - 686 534,
REPRESENTED BY ITS SECRETARY.
19 THE T.V.PURAM FARMERS' SERVICE CO-OPERATIVE BANK
LIMITED NO.622
VAIKOM, KOTTAYAM DISTRICT - 686 534, REPRESENTED BY
ITS SECRETARY.
20 THE NEDUMKUNNAM REGIONAL SERVICE CO-OPERATIVE BANK
LIMITED NO.286
NEDUMKUNNAM, KOTTAYAM DISTRICT - 686 534 REPRESENTED
BY ITS SECRETARY.
21 THE NEEZHOOR SERVICE CO-OPERATIVE BANK LIMITED NO.136
NEEZHOOR, KOTTAYAM DISTRICT - 686 534, REPRESENTED BY
ITS SECRETARY.
22 THE ELECTRICITY BOARD EMPLOYEES CO-OPERATIVE SOCIETY
LIMITED NO.K 705
PAKKIL, KOTTAYAM DISTRICT - 686 534, REPRESENTED BY
ITS SECRETARY- 686 539.
23 THE VAIKOM URBAN CO-OPERATIVE SOCIETY LIMITED NO.K
1011
VAIKOM, KOTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY - 686 505.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
2025:KER
W.P(C)No.7053/2023 & Connected cases 237
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, KOTTAYAM, PIN - 686 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
5 THE REGIONAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD., REGIONAL
OFFICER, KOTTAYAM, PIN- 686 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 238
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11342 OF 2022
PETITIONER/S:
CHENDMANGALAM SERVICE CO-OPERATIVE BANK LIMITED
CHENDAMANGALAM P.O.NORTH PARAVOOR, PIN-683 512,
REPRESENTED BY ITS SECRETARY OUSEPH T.V.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SHRI.RAJATH R NATH
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110 001
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI-682
018
3 THE INCOME TAX OFFICER (TDS),
KAP COMPLEX, HIGHWAY, SH 16, PERIYAR NAGAR, ALUVA,
PIN-683 101
4 THE CENTRAL BOARD OF DIRECTO TAXES DEPARTMENT OF
REVENUE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 239
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NOW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682 018
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003.
7 THE KERALA STATE CO-OPERATIVE BANK LTD (KERALA BANK),
PO NO 6515, CO-BANK TOWERS , PALAYAM,
THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS
MANAGING DIRECTOR
8 KERALA BANK,
NORTH PARAVUR BRANCH MAIN, NORTH PARAVOOR P.O.PIN-683
513, REPRINTED BY ITS MANAGING DIRECTOR
9 KERALA BANK,
NORTH PARAVUR BRANCH EVENING, NORTH PARAVOOR P.O.PIN-
683 513, REPRINTED BY ITS MANAGING DIRECTOR
10 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN-695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 240
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11355 OF 2022
PETITIONER/S:
VALLUVALLY SERVICE CO-OPERATIVE BANK LIMITED
KOONAMMAVU, NORTH PARAVOOR P.O.PIN-685 518,
REPRESENTED BY ITS SECRETARY LILA M.J.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SRI.V.J.MATHEW (M-1348)
SRI.K.A.ARAVINDAKSHAN
SHRI.RAJATH R NATH
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIAN, NORTH
BLOCK, NEW DELHI-110 001
2 COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682
018.
3 THE INCOME TAX OFFICER (TDS),
KAP COMPLEX, HIGHWAY, SH 16, PERIYAR NAGAR, ALUVA,
PIN-683 101.
2025:KER
W.P(C)No.7053/2023 & Connected cases 241
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS
CHAIRMAN.
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682 018.
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003.
7 THE KERALA STATE CO-OPERATIVE BANK LTD,
(KERALA BANK), PO NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS
MANAGING DIRECTOR
8 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN-695 001.
BY ADVS.
SHRI.C.DINESH, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 242
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11366 OF 2022
PETITIONER/S:
1 THE WADAKKANCHERY SERVICE CO-OPERATIVE BANK LTD
NO. 3279, THALAPPILLY, THRISSUR, REPRESENTED BY ITS
SECRETARY, 680 582
2 AMBALAPAD SERVICE CO-OPERATIVE BANK LTD
NO. 759, P.O.KUNDUKADU, THRISSUR, REPRESENTED BY ITS
SECRETARY. 680 028
3 THE PERINGANDOOR SERVICE CO-OPERATIVE BANK LTD
NO. 297, ATHANI, THRISSUR, REPRESENTED BY
THESECRETARY,680 102
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682 018
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 243
4 THE KERALA STATE CO-OPERATIVE BANKLTD
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR,
BY ADVS.
SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 244
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11371 OF 2022
PETITIONER/S:
1 AYYANTHOLE SERVICE CO-OPERATIVE BANK LTD.NO.494
AYYANTHOLE, THRISSUR, REPRESENTED BY ITS SECRETARY-
680 611
2 THE AVINISSERY SERVICE CO-OPERATIVE BANK LTD NO.400,
AVINISSERY P.O., THRISSUR, REPRESENTED BY ITS
SECRETARY-680 611
3 AYYANTHOLE PANCHAYAT SERVICE CO-OPERATIVE BANK LTD
NO.471,
KARIATTUKARA, P.O.ELTHURUTH, THRISSUR-680 611,
REPRESENTED BY ITS SECRETARY
4 ARANATTUKARA ORIENTAL SERVICE CO-OPERATIVE BANK LTD
NO.171,
ARANATTUKARA, THRISSUR DISTRICT,REPRESENTED BY ITS
SECRETARY-680 611
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM-
2025:KER
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682 018
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR
BY ADV SHRI.B.G.HARINDRANATH (SR.)
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 246
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11373 OF 2022
PETITIONER/S:
THE ADAT FARMERS SERVICE CO-OPERATIVE BANK
LTD NO.689, PURANATTUKARA, THRISSUR-680 551,
REPRESENTED BY ITS MANAGING DIRECTOR
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS RAD, ERNAKULAM-682
018
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAM NAGAR, THRISSUR-680 001
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR
BY ADVS.
SHRI.M.A.SHAJI, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
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SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 248
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11381 OF 2022
PETITIONER/S:
KARUVANNUR SERVICE CO-OPERATIVE BANK LTD
KARUVANNUR P.O., THRISSUR ,PIN-680 711, REPRESENTED
BY ITS SECRETARY-IN-CHARGE SREEKALA .E.S.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SHRI.RAJATH R NATH
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI-110 001
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682
018
3 THE INCOME TAX OFFICER (TDS),
AAYAKAR BHAVAN, SAKTHAN THAMPURAM NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR, PIN-680 001
4 THE CENTRAL BOARD OF DIRECTOR TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN
2025:KER
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5 PRICIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003
7 THE KERALA STATE CO-OPERATIVE BANK LTD,
( KERALA BANK), PO NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM,PIN-695 033, REPRESENTED BY ITS
MANAGING DIRECTOR
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM,PIN-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11407 OF 2022
PETITIONER/S:
1 THE GOVT .SERVANTS CO-OP SOCIETY LTD
LTD NO.139, WADAKKANCHERY, THRISSUR DISTRICT,
REPRESENTED BY ITS SECRETARY-680682.
2 MACHAD PARASPARA SAHAYA SAHAKARANA SANGHASM LTD NO.R-
1267,
PUNNAMPARAMBU, THEKKUMKARA P O, THRISSUR DISTRICT-
680589., REPRESENTED BY ITS SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033,
REPRESENTED BY ITS MANAGING DIRECTOR.
2025:KER
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BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 252
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11415 OF 2022
PETITIONER/S:
1 PALLIPURAM SERVICE CO-OPERATIVE BANKNO.760
PALLIPURAM, CHERAI, ERNAKULAM-683514, REPRESENTED BY
ITS SECRETARY, SR.K.S.AJAYAKUMAR.
2 KUZHUPPILLY SERVICE CO-OPERATIVE BANK.
CHERUVYPE JUNCTION, AYYAMPILLY, KUZHUPILLY-682501,
REPRESENTED BY ITS SECRETARY, SRI.AJAYAKUMAR V.A.
3 EDAVANAKKAD SERVICE CO-OPERATIVE BANK.
EDAVANAKKAD, VYPIN, KOCHI-682509, REPRESENTED BY ITS
SECRETARY SMT.RASEENA B A.
4 OCHANTHURUTH SERVICE CO-OPERATIVE BANK
OCHANTHURUTH, COCHIN, ERNAKULAM-682508, REPRESENTED
BY ITS SECRETARY, SRI.A.S.GOPALAKRISHNAN.
BY ADVS.
SHRI.AJI V.DEV
SRI.ALAN PRIYADARSHI DEV
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2025:KER
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2 PRINCIPAL CHIEF COMMISSIONER OF INCOEM TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
3 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN.
4 THE KERALA STATE CO-OPERATIVE BANK LIMITED
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
THIRUVANANTHAPURAM-695033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 254
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11420 OF 2022
PETITIONER/S:
OLLUKKARA LABOUR CONTRACT CO-OPERATIVE SOCIETY
LTDNO.R.855
P O MANNUTHY, THRISSUR, REPRESENTED BY THE SECRETARY,
PIN-680651.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER(TDS)
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033.
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 255
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 256
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11441 OF 2022
PETITIONER/S:
1 CHAVAKKAD SERVICE CO-OPERATIVE BANK LTD. NO.F.9991,
P.O.CHAVAKKAD, THRISSUR, REPRESENTED BY ITS
SECRETARY.
2 PERAKAM SERVICE CO-OPERATIVE BANK LTD. NO.F.6916,
P.O.PERAKAM, CHAVAKKAD, THRISSUR, REPRESENTED BY ITS
SECRETARY.
3 PUNNAYUR PANCHAYAT SERVICE CO-OPERATIVE BANK LTD.
NO.P.584,
P.O.EDAKKARA, THRISSUR-680518, REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001.
2025:KER
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4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 258
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11440 OF 2022
PETITIONER/S:
THE RAMAPURAM REGIIONAL SERVICE CO-OPERATIVE BANK
LTD. NO.4111,
RAMAPURAM P.O., KOTTAYAM-686576, REPRESENTED BY ITS
SECRETARY SANTHOSH SEBASTIAN, S/O. SEBASTIAN, AGED 43
YEARS, VICAHTTU HOUSE, CHAKAMPUZHA P.O., RAMAPURAM,
PALA, KOTTAYAM DISTRICT, PIN-686574.
BY ADVS.
SHRI.BABY THOMAS
SMT.MARIAMMA JOSEPH
SMT.ALICIA JOSE
SHRI.GEORGE T.J
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682018.
3 INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI
2025:KER
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ROAD, KOTTAYAM-686001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD. (KERALA
BANK),
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
THIRUVANANTHAPURAM-695033, REP. BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695001.
BY ADV SRI.CHRISTOPHER ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 260
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11450 OF 2022
PETITIONER/S:
1 CHIRAKKAL SERVICE CO-OPERATIVE BANK LTD
CHIRAKKAL P.O., KANNUR-670011, REPRESENTED BY ITS
SECRETARY CHANDRAN P.
2 TELLICHERY TOWN SERVICE CO-OPERATIVE BANK LTD.,
P.O.TELLICHERY, KANNUR-670101, REPRESENTED BY ITS
SECRETARY ROSILY M.O.
3 MUZHAPPILANGAD SERVICE CO-OPERATIVE BANK LTD.,
P.O.MUZHAPPILANGAD, KANNUR-670662, REPRESENTED BY ITS
SECRETARY AJESH R.K.
4 CHOKLI SERVICE CO-OPERATIVE BANK LTD.,
CHOKLI P.O., KANNUR-670672, REPRESENTED BY ITS
SECRETARY VIJAYAN C.
5 KOODALI SERVICE CO-OPERATIVE BANK LTD.,
P.O.KOODALI, KANNUR -670592, REPRESENTED BY ITS
SECRETARY SAJEEVAN E.
6 CHITTARIPARAMBA SERVICE CO-OPERATIVE BANK LTD.,
P.O.CHITTARIPARAMBA, KANNUR-670650, REPRESENTED BY
ITS SECRETARY RAJEEV K.V.
7 PORORA SERVICE CO-OPERATIVE BANK LTD.,
P.O.PORORA, KANNUR-670702, REPRESENTED BY ITS
SECRETARY M.K.VANAJA.
8 VADAKKUMBAD SERVICE CO-OPERATIVE BANK LTD.,
P.O.VADAKKUMBAD, THALASSERY, KANNUR-670105,
2025:KER
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REPRESENTED BY ITS SECRETARY SREEJILA V.
9 KODIYERI CO-OPERATIVE RURAL BANK LTD.,
P.O.PARAL, KANNUR-670671, REPRESENTED BY ITS
SECRETARY ARUNKUMAR K.P.
10 PONNIAM SERVICE CO-OPERATIVE BANK LTD.,
P.O.PONNIAM, KANNUR-670641, REPRESENTED BY ITS
SECRETARY RATNAKARAN K.R.
11 PUNNOL SERVICE CO-OPERATIVE BANK LTD.,
KURICHIYIL P.O., KANNUR-670102, REPRESENTED BY ITS
SECRETARY K.V.SANTHOSHKUMAR.
12 ANJARAKANDY FARMERS SERVICE CO-OPERATIVE BANK LTD.,
P.O.MAMBA, KANNUR-670611, REPRESENTED BY ITS
SECRETARY ANILKUMAR M.P.
13 PANOOR SERVICE CO-OPERATIVE BANK LTD.
P.O.PANOOR, KANNUR-670692, REPRESENTED BY ITS
SECRETARY VINOD T.K.
14 THADIKKADAVU SERVICE CO-OPERATIVE BANK LTD.,
P.O.CHAPPARAPPADAVU, KANNUR-670581, REPRESENTED BY
ITS SECRETARY KURYAN THOMAS.
15 DHARMADAM SERVICE CO-OPERATIVE BANK LTD.,
PALAYAD P.O., KANNUR-670661, REPRESENTED BY ITS
SECRETARY SURESHKUMAR N.P.
16 MADAI SERVICE CO-OPERATIVE BANK LTD.,
P.O.VENGARA, KANNUR-670305, REPRESENTED BY ITS
SECRETARY K.AJITHKUMAR.
17 PAYAM SERVICE CO-OPERATIVE BANK LTD.,
PAYAM P.O., KANNUR-670704, REPRESENTED BY ITS
SECRETARY MATHEW K.M.
18 CHAVASSERY SERVICE CO-OPERATIVE BANK LTD.,
P.O.CHAVASSERY, KANNUR-670702, REPRESENTED BY ITS
SECRETARY SATHEESH CHANDRAN K.P.
19 PATTANUR SERVICE CO-OPERATIVE BANK LTD.,
2025:KER
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P.O.IRIKKUR, KANNUR-670593, REPRESENTED BY ITS
SECRETARY RAJEVAN K.V.
20 KADAVATHUR SERVICE CO-OPERATIVE BANK LTD.,
KADAVATHUR, KANNUR-670676, REPRESENTED BY ITS
SECRETARY CHANDRAN M.
21 THONDIYIL SERVICE CO-OPERATIVE BANK LTD.,
THONDIYIL P.O., KANNUR-670673, REPRESENTED BY ITS
SECRETARY JOJO JOSEPH.
22 KARARINAKAM SERVICE CO-OPERATIVE BANK LTD.,
P.O.KADALAYI, KURUVA, KANNUR-670003, REPRESENTED BY
ITS SECRETARY LATHEESH K.
23 KANDAMKUNNU SERVICE CO-OPERATIVE BANK LTD. NO. LL 20,
KAITHERY, P.O.NIRMALAGIRI, KANNUR-670701, REPRESENTED
BY ITS SECRETARY BABU P.
24 MANATHANA SERVICE CO-OPERATIVE BANK LTD.,
P.O.MANATHANA, KANNUR-670674, REPRESENTED BY ITS
SECRETARY GOURI K.
25 KUTTIATTOOR PANCHAYATH SERVICE CO-OPERATIVE BANK LTD.
NO.C 817,
HEAD OFFICE, CHEKKIKULAM P.O., KANNUR 670592,
REPRESENTED BY ITS SECRETARY RAJAN T.
26 TALIPARAMBA SERVICE CO-OPERATIVE BANK LTD.,
P.O.TALIPARAMBA, KANNUR-670141, REPRESENTED BY ITS
SECRETARY PUSHPAKUMARI T.V.
27 PATTIAM SERVICE CO-OPERATIVE BANK LTD. NO.C 1464,
PATTIAM, KOTTAYODI P.O., PATHAYAKUNNU, KANNUR-670691,
REPRESENTED BY ITS SECRETARY SREEJA KUMARI P.
28 PERINGALAM SERVICE CO-OPERATIVE BANK LTD.,
P.O.PULLOOKKARA, KANNUR-67676, REPRESENTED BY ITS
SECRETARY PRASEEDA T.T.
29 KUNNIRIKKA SERVICE CO-OPERATIVE BANK LTD. NO.6971,
P.O.PATHIRIYAD, KANNUR-670741, REPRESENTED BY ITS
SECRETARY PREETHA K.P.V.
2025:KER
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30 KADIRUR SERVICE CO-OPERATIVE BANK LTD.,
P.O.KADIRUR, KANNUR-670642, REPRESENTED BY ITS
SECRETARY K.ASHOKAN.
31 NADUVIL SERVICE CO-OPERATIVE BANK LTD.,
P.O.NADUVIL, KANNUR-670582, REPRESENTED BY ITS
SECRETARY TOMY JOSEPH.
32 MOKERI SERVICE CO-OPERATIVE BANK LTD.,
P.O.KOORARA, TELLICHERY, KANNUR-670694, REPRESENTED
BY ITS SECRETARY K.RAMACHANDRAN.
33 KARIYAD SERVICE CO-OPERATIVE BANK LTD.,
P.O.KARIYAD SOUTH, KANNUR-673316, REPRESENTED BY ITS
SECRETARY AJITHKUMAR K.
34 KOTTAYAM SERVICE CO-OPERATIVE BANK LTD.,
P.O.KOTTAYAMPOYIL, KANNUR-670691, REPRESENTED BY ITS
SECRETARY SAMPATHKUMAR M.
35 PINAYARI SERVICE CO-OPERATIVE BANK LTD.,
P.O.PINARAYI, KANNUR-670741, REPRESENTED BY ITS
SECRETARY A.SREEGANAN
36 THOLAMBRA SERVICE CO-OPERATIVE BANK LTD.,
THOLAMBRA, KANNUR-670673, REPRESENTED BY ITS
SECRETARY SHAJAN P.V.
37 EZHOME SERVICE CO-OPERATIVE BANK LTD.,
P.O.EZHOME, KANNUR-670334, REPRESENTED BY ITS
SECRETARY PREMARAJAN P.V.
38 VALAPATTANAM SERVICE CO-OPERATIVE BANK LTD.,
P.O.VALAPATTANAM, KANNUR-670010, REPRESENTED BY ITS
SECRETARY M.V.GOWRI.
39 CHOVVA CO-OPERATIVE RURAL BANK LTD.,
P.O.CHOVVA, KANNUR-670006, REPRESENTED BY ITS
SECRETARY MOHANAN P.
40 KUTTIKKAKAM SERVICE CO-OPERATIVE BANK LTD.NO.F 1287,
P.O.KUTTIKKAKAM, KANNUR-670663, REPRESENTED BY
2025:KER
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ASHOKAN P.
41 KELAKAM SERVICE CO-OPERATIVE BANK LTD.,
P.O.KELAKAM, KANNUR-670674, REPRESENTED BY ITS
SECRETARY K.P.JOLLY.
42 KOLAVALLOOR SERVICE CO-OPERATIVE BANK LTD.,
P.O.CHERUPARAMBA, THOOVAKKUNNU, KANNUR-670693,
REPRESENTED BY ITS SECRETARY VAIJAYANTHI T.H.
43 NUCHIYAD SERVICE CO-OPERATIVE BANK LTD. NO. C 220,
P.O.MANIKKADAVU, KANNUR-670705, REPRESENTED BY ITS
SECRETARY GEORGE JOSEPH T.
44 PUTHUR SERVICE CO-OPERATIVE BANK LTD. NO. LL 23,
KAIVELIKKAL, P.O.PUTHUR, KANNUR-670692, REPRESENTED
BY ITS SECRETARY A.MANOJ KUMAR.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
2025:KER
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KOCHI-682018.
4 PRINCIPAL COMMISSIONER OF INCOME TAX,
KOZHIKODE, AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE-
673001.
5 INCOME TAX OFFICER,
TDS, WARD TDS, KANNUR, AYAKAR BHAVAN, OFFICE OF THE
ADDITIONAL COMMISSIONER OF INCOME TAX, KANNOTHUMCHAL,
CHOVVA P.O., KANNUR-670006.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING: :
2025:KER
W.P(C)No.7053/2023 & Connected cases 266
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11446 OF 2022
PETITIONER/S:
KARTHEDOM SERVICE CO-OPERATIVE BANK LTD. NO.123,
MALIPURAM, ERNAKULAM-682511, REPRESENTED BY ITS
SECRETARY SRI. AJITHA P.V.
BY ADVS.
SHRI.AJI V.DEV
SRI.ALAN PRIYADARSHI DEV
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
3 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
2025:KER
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THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS
MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 268
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11445 OF 2022
PETITIONER/S:
1 MULLASSERY SERVICE CO-OPERATIVE BANK LTD. NO.R 280,
P.O.MULLASSERY, THRISSUR, REPRESENTED BY ITS
SECRETARY, 680509.
2 ARATTUPUZHA SERVICE CO-OPERATIVE BANK LTD. NO.632,
ARATTUPUZHA, THRISSUR, REPRESENTED BY ITS SECRETARY,
680515.
3 THE ELAVALLY SERVICE CO-OPERATIVE BANK LTD. NO.F
1456,
P.O.VAKA, THRISSUR, REPRESENTED BY ITS SECRETARY,
680602.
4 THE KOTTAPPADY SERVICE CO-OPERATIVE BANK LTD. NO.R
210,
P.O.KOTTAPADI, THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY, 680505.
5 ANNAKARA SERVICE CO-OPERATIVE BANK LTD. NO.F 549,
PERUVALLUR, THRISSUR-680508, REPRESENTED BY ITS
SECRETARY.
6 THE CHITTATTUKARA SERVICE CO-OPERATIVE BANK LTD. NO.F
1642,
CHITTATTUKARA P.O., THRISSUR, REPRESENTED BY ITS
SECRETARY, 680507.
BY ADV SRI.E.S.ASHRAF
2025:KER
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RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SHRI.M.JAYAKRISHNAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 270
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11458 OF 2022
PETITIONER/S:
EDANADU SERVICE CO-OPERATIVE BANK LTD. NO 1768
EDANADU, VALLICHIRA VILLAGE, MEENACHIL TALUK,
KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY
BY ADV SRI.P.C.HARIDAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001
REPRESENTED BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
ERNAKULAM 682 018
4 THE ADDITIONAL COMMISSIONER OF INCOME TAX
OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX,
3RD FLOOR, AAYAKAR BHAVAN, KOWADIAR,
THIRUVANANTHAPURAM 695 003
5 THE INCOME TAX OFFICER (TDS)
2025:KER
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HGVG+7JW, BAKER HILL, KOTTAYAM 686 002
6 THE KERALA STATE CO-OPERATIVE BANK LIMITED
PB NO. 6515, COBANK TOWERS, VIKAS BHAVAN P.O,
PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY
ITS GENERAL MANAGER
7 THE KERALA STATE CO-OPERATIVE BANK LIMITED
PALA BRANCH, VAZHAYIL BLDS, PALA P.O 686 575
REPRESENTED BY ITS BRANCH MANAGER
8 THE STATE OF KERALA
REPRESENTED BY ITS PRINCIPAL SECRETARY TO THE CO-
OPERATIVE DEPARTMENT, SECRETARIAT, FORT P.O,
THIRUVANANTHAPURAM 695 023
BY ADVS.
SHRI.S.BIJU, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 272
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11467 OF 2022
PETITIONER/S:
1 KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION,
DISTRICT COMMITTEE, KASARAGOD, REPRESENTED BY
ITSSECRETARY, K.P.VALSALAN, AGED 54 YEARS,
S/O.KOMBATH CHANDAN, PALLIPPARA P.O., PETTIKUNDU,
KASARAGOD-671 313.
2 PALLIKERE SERVICE CO-OPERATIVE BANK LTD.NO.L-68,
HEAD OFFICE, PALLIKERE, P.O.BAKAL FORT, KASARAGOD-671
316, REPRESENTED BY ITS SECRETARY, PUSHKARAKSHAN.K.,
AGED 55 YEARS, SON OF APPAKUNHI.K.B.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
2025:KER
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DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,`
PB NO.6615, CO BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 274
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11478 OF 2022
PETITIONER/S:
THE AVITTATHUR SERVICE CO-OPERATIVE BANK LTD.NO.706,
AVITTATHUR, THRISSUR, RESPRESENTED BY THE SECRETARY,
PIN-680 683.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001.
2 THE COMMISSIONER OF INCOME TAX 9TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM-
682 018.
3 THE INCOME TAX OFFICER 9TDS),
OFFICE OF THE INCOME TAX OFFICER 9TDS), AAYAKAR
BAHVAN, SAKTHAN THAMPURAM NAGAR, THRISSUR-680 001.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SMT.M.SHAJNA, CGC
SRI.CHRISTOPHER ABRAHAM
2025:KER
W.P(C)No.7053/2023 & Connected cases 275
SHRI.B.G.HARINDRANATH (SR.)
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 276
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11480 OF 2022
PETITIONER/S:
1 VALLACHIRA SERVICE CO-OPERATIVE BANK LTD. NO.527,
VALLACHIRA P.O., THRISSUR, REPRESENTED BY ITS
SECRETARY, PIN-680 301.
2 PANAMKULAM ETTUMUNA SERVICE CO OPERATIVE BANK
LTD .NO.626,
PANAMKULAM, THRISSUR, REPRESENTED BY ITS SECRETARY,
PIN-680 711.
3 URAKAM SERVICE CO OPERATIVE BANK LTD.NO.526,
URAKAM, THRISSUR, REPRESENTED BY ITS SECRETARY, PIN-
680 562.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW
DELHI-110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, ERNAKULAM-
682 018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER 9TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001.
2025:KER
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4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695
033,REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADV SHRI.B.G.HARINDRANATH (SR.)
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 278
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11489 OF 2022
PETITIONER/S:
1 THE KOOTTAR SERVICE CO-OPERATIVE BANK LTD NO. K-373
REP BY ITS SECRETARY, K.G SURESH KUMAR, S/O.
GOPINATH, AGED 46 YEARS, HEAD OFFICE, KARNAPURAM
P.O., KOOTTAR, IDUKKI-685 552
2 BALAGRAM SERVICE CO-OPERATIVE BANK LTD.,
NO.I-150, REPRESENTED BY ITS SECRETARY RAJIMOL P.V.,
AGED 35 YEARS, W/O DINESH .L.T., HEAD OFFICE .
BALAGRAM ,P.O.IDUKKI-685 552
3 UDUMBANCHOLA SERVICE CO-OPERATIVE BANK LTD,
NO.K-396, REPRESENTED BY ITS SECRETARY, SREEKALA
C.S., W/O. SLYMON, AGED 41 YEARS, HEAD OFFICE,
UDUMBANCHOLA P.O., IDUKKI-685 554
4 UDUMBANCHOLA CO-OPERATIVE EMPLOYEES CO-OPERATIVE
SOCIETY LTD.,
NO.1-168, REP BY ITS SECRETARY ANITHA V.NAIR,
D/O.VELAYUDHAN NAIR, HEAD OFFICE, NEDUMKANDAM LA
P.O., IDUKKI-685 553
5 THE IDUKI DISTRICT POLICE CO-OPERATIVE SOCIETY LTD.,
NO.1-490, REP BY ITS SECRETARY SANAL KUMAR, S/O.
HARIDAS, HEAD OFFICE, IDUKKI COLONY P.O., CHERUTHONI,
IDUKKI-685 602
6 THE SANTHANPARA SERVICE CO-OPERATIVE LTD NO.,
K-344, REPRESENTED BY ITS SECRETARY, TOMICHAN.K.J.,
AGED 51 YEARS, S/O. JOSEPH, HEAD OFFICE, SANTHANPARA
P.O., IDUKKI-685 619
2025:KER
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BY ADVS.
SRI.GEORGE MATHEW
SRI.M.D.SASIKUMARAN
SHRI.PRAVEEN S.
SHRI.SUNIL KUMAR A.G
SRI.DIPU JAMES
SHRI.MATHEW K.T.
SHRI.GEORGE K.V.
SHRI.STEPHY K REGI
SMT.ELSA DENNY PINDIS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -110
002
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682
018
3 THE INCOME TAX OFFICER,
TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8,
THODUPUZHA, IDUKKI DISTRICT-685 584
4 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT,
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM-695 014
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
( KERALA BANK), REP BY ITS MANAGING DIRECTOR & CHIEF
EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033
7 THE DEPUTY GENERAL MANAGER,
2025:KER
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CENTRAL PROCESSING CENTER, THE KERALA STATE CO-
OPERATIVE BANK LTD., (KERALA BANK), VAZHATHOPE,
IDUKKI COLONY P.O., IDUKKI DISTRICT-685 602
BY ADVS.
SHRI.B.PRAMOD, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 281
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11487 OF 2022
PETITIONER/S:
1 THE MULLAKKARA VILLAGE SERVIC CO-OPERATIVE BANK LTD
NO.R.677, P.O.MULLURKARA, THRISSUR, -680 588 ,
REPRESENTED BY ITS SECRETARY-680 588
2 VENGANALLUR SERVICE CO OPERATIVE BANK,
LTD NO.22, VENGANALLUR, THRISSUR,REPRESENTED BY ITS
SECRETARY-680585
3 THE DESAMANGALAM SERVICE CO -OPERATIVE BANK LTD
NO.134,
DESAMANGALAM,THRISSUR, REPRESENTED BY ITS SECRETARY-
679 532
4 THE CHERUTHURUTHY SERVICE CO-OPERATIVE BANK LTD
NO.121,
CHERUTHURUTHY, THRISSUR DISTRICT, REPRESENTED BY ITS
SECRETARY-679 121
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM-
2025:KER
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682 018
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 283
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11507 OF 2022
PETITIONER/S:
1 KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION
DISTRICT COMMITTEE, PALAKKAD, REPRESENTED BY ITS
SECRETARY, RAMAKRISHNAN K., AGED 49 YEARS, S/O.
M.MADHAVAN NAIR, PRESIDENT, SREEKRISHNAPURAM SERVICE
CO-OPERATIVE BANK LTD. NO.F.1213, SREEKRISHNAPURAM,
KARIMPUZHA, PALAKKAD-678595.
2 SREEKRISHNAPURAM SERVICE CO-OPERATIVE BANK LTD.
NO.F.1213,
SREEKRISHNAPURAM, KARIMPUZHA, PALAKKAD-678595,
REPRESENTED BY ITS PRESIDENT, RAMAKRISHNAN K., AGED
49 YEARS, S/O. M.MADHAVAN NAIR, KIZHAKKEKALAM,
VAKKADAPURAM P.O., KARAKURISSI, PALAKKAD.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2025:KER
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2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695001.
BY ADVS.
SRI.M.JAYAKRISHNAN
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11530 OF 2022
PETITIONER/S:
ENGANDIYUR FARMERS SERVICE CO-OPERATIVE BANK LTD.
NO.F-977, P.O.ENGANDIYUR, THRISSUR - 680 615,
REPRESENTED BY THE MANAGING DIRECTOR.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM -
682 018.
3 THE INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
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SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11544 OF 2022
PETITIONER/S:
1 THE ALAKODE SERVICE CO-OPERATIVE BANK LTD NO.1588,
REPRESENTED BY ITS SECRETARY, SHINTO JOSE, S/O.JOSE,
AGED 42 YEARS, HEAD OFFICE, ALAKODE P.O., IDUKKI-685
588.
2 THE PUTHUPARIYARAM SERVICE CO-OPERATIVE BANK LTD.,
NO.3-55, REPRESENTED BY ITS SECRETARY, JENCY MATHEW,
AGED 50 YEARS W/O.SEBASTIAN, PUTHUPARIYARAM P.O.,
IDUKKI - 685 608.
3 MANAKKAD SERVICE CO-OPERATIVE BANK LTD.,
NO.1706, REPRESENTED BY ITS SECRETARY, NIRMAL SHAJI,
S/O.SHAJI, AGED 31 YEARS, MANAKKAD, MANAKKAD P.O.,
IDUKKI - 685 608.
4 MUTHALAKODAM SERVICE CO-OPERATIVE BANK LTD.,
NO.140, REPRESENTED BY ITS SECRETARY, SAJI PAUL,
S/O.PAUL, AGED 51 YEARS, HEAD OFFICE, MUTHALAKODAM,
IDUKKI - 685 605.
5 THE NEDUMATTAM SERVICE CO-OPERATIVE BANK LTD.,
NO.1292, REPRESENTED BY ITS SECRETARY, SINU K.G.,
S/O.GOPALAN, AGED 44 YEARS, HEAD OFFICE, VANDAMATTAM
P.O., IDUKKI - 685 582.
6 KARIKODE SERVICE CO-OPERATIVE BANK LTD.,
NO.4009, REPRESENTED BY ITS SECRETARY, MOLLY P.V.,
W/O.SUNNY P.J., AGED 56 YEARS, HEAD OFFICE, KARIKODE,
THODUPUZHA P.O., IDUKKI - 685 584.
7 KODIKULAM SERVICE CO-OPERATIVE BANK LTD.,
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NO.2823, REPRESENTED BY ITS SECRETARY, ABIN MICHAEL,
S/O.MICHAEL, AGED 28 EYARS, HEAD OFFICE, KODIKULAM
P.O., IDUKKI - 685 582.
8 KUMARAMANGALAM SERVICE CO-OPERATIVE BANK LTD.,
NO.4122, REPRESENTED BY ITS SECRETARY, AJITH V.
ABRAHAM, S/O.ROY ABRAHAM, AGED 27 YEARS, HEAD OFFICE,
KALOOR EAST, KALOOR P.O., IDUKKI - 685 608.
9 UDUMBANOOR SERVICE CO-OPERATIVE BANK LTD.,
NO.E-93, REP. BY ITS SECRETARY, REMYA BALACHANDRAN,
W/O.AJEESH KUMAR, AGED 37 YEARS, HEAD OFFICE,
UDUMBANOOR P.O., IDUKKI DISTRICT - 685 595.
0 THE THODUPUZHA SERVICE CO-OPERATIVE BANK LTD.,
NO.969, REPRESENTED BY ITS SECRETARY, JAYASREE P.,
W/O.T.R.SOMAN, AGED 50 YEARS, HEAD OFFICE, THODUPUZHA
P.O., IDUKKI - 685 584.
11 THE THODUPUZHA TALUK REGIONAL SOCIAL WELFARE
CO-OPERATIVE SOCIETY LTD.,NO.I-690, REP. BY ITS
SECRETARY, ANJITH REJI, AGED 27 YEARS, S/O.P.N.REJI,
VENGALLUR P.O., THODUPUZHA TALUK, IDUKKI DISTRICT -
685 608.
12 THODUPUZHA TOWN SERVICE CO-OPERATIVE BANK LTD.,
NO.I-233, REPRESENTED BY ITS SECRETARY, RAKHI C.,
W/O.JAGADEESH, AGED 41 YEARS, HEAD OFFICE THODUPUZHA
P.O., IDUKKI - 685 584.
13 THE KARIMANOOR SERVICE CO-OPERATIVE BANK LTD.,
NO.967, REPRESENTED BY ITS SECRETARY, JAIN V. GEORGE,
S/O.GEORGE, AGED 42 YEARS, HEAD OFFICE, KARIMANOOR
P.O., IDUKKI - 685 581.
14 THE KARIMKUNNAM SERVICE CO-OPERATIVE BANK LTD.,
NO.2670, REPRESENTED BY ITS SECRETARY, DEENA BABY,
W/O.BABY, AGED 41 YEARS, HEAD OFFIE, KARIMKUNNAM
P.O., IDUKKI - 685 586.
15 MUTTAM SERVICE CO-OPERATIVE BANK LTD.,
NO.1284, REPRESENTED BY ITS SECRETARY, ARUN DOMINIC,
S/O.DOMINIC, AGED 33 YEARS, HEAD OFFICE, MUTTAM P.O.,
IDUKKI - 685 587.
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16 VAZHITHALA SERVICE CO-OPERATIVE BANK LTD., NO.908,
REPRESENTED BY ITS SECRETARY, REGI N. ABRAHAM,
W/O.SHAJI, AGED 48 YEARS, HEAD OFFICE, VAZHITHALA
P.O., IDUKKI - 585 583.
BY ADVS.
SRI.GEORGE MATHEW
SRI.M.D.SASIKUMARAN
SHRI.PRAVEEN S.
SHRI.SUNIL KUMAR A.G
SHRI.MATHEW K.T.
SHRI.GEORGE K.V.
RESPONDENT/S:
1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO
GOVERNMENT MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI - 110 002.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, KOCHI - 682
018.
3 THE INCOME TAX OFFICER, TDS OFFICE,
MAHIMA TOWERS STATE HIGHWAY-8, THODUPUZHA, IDUKKI
DISTRICT - 685 584.
4 STATE OF KERALA, REP. BY ITS SECRETARY,
FINANCE DEPARTMENT GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM-695 001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM - 695 014.
6 THE THODUPUZHA URBAN CO-OPERATIVE BANK LTD., NO.394,
REP. BY ITS GENERAL MANAGER, HEAD OFFICE, THODUPUZHA
TALUK, THODUPUZHA P.O., IDUKKI DISTRICT - 685 584.
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BY ADV SHRI.B.PRAMOD, SENIOR PANEL COUNSEL
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11555 OF 2022
PETITIONER/S:
1 KOTTATHARA SERVICE CO-OPERATIVE BANK LTD .
KOTTATHARA P.O., KALPETTA VIA., WAYANAD - 673 124,
REPRESENTED BY ITS SECRETARY SUMESHAN M.
2 MADAKKIMAL SERVICE CO-OPERATIVE BANK LTD.
P.O.MADAKKIMALA, WAYANAD - 673 122 REPRESENTED BY ITS
SECRETARY SREEHARI P.
3 VENGAPPALLY SERVICE CO-OPERATIVE BANK LTD.
PINANGODE P.O., WAYNAD - 673 121 REPRESENTED BY ITS
SECRETARY ABDUL JAFFER.
4 PADINHARATHARA SERVICE CO-OPERATIVE BANK LTD.
PADINHARATHARA P.O., WAYANAD - 673 575 REPRESENTED BY
ITS SECRETARY MOIDOO K.
5 POOTHADY SERVICE CO-OPERATIVE BANK LTD.
NO.F 1011, HEAD OFFICE, KENCHIRA, WAYANAD - 673 596
REPRESENTED BY ITS SECRETARY BIJI VINOD.
6 ANJUKUNNU SERVICE CO-OPERATIVE BANK LTD.
NO.C 311, P.O.ANJUKUNNU, WAYANAD - 670 645
REPRESENTED BY ITS SECRETARY SAJITH P.T.
7 THARUVANA SERVICE CO-OPERATIVE BANK LTD.
NO.F 521, THARUVANA, WAYANAD - 670 645 REPRESENTED BY
ITS SECRETARY VIJAYESWARI T.
8 MULLANKOLY SERVICE CO-OPERATIVE BANK LTD.
P.O.PADICHIRA, WAYANAD - 673 579 REPRESENTED BY ITS
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SECRETARY SAJI JOSEPH K.
9 PULPULLY SERVICE CO-OPERATIVE BANK LTD.
P.O.PULPALLY, WAYANAD - 673 579 REPRESENTED BY ITS
SECRETARY P.M.MOHANDAS.
0 KALPETTA SERVICE CO-OPERATIVE BANK LTD.
NO.F 6807, KALPETTA, WAYANAD - 673 121 REPRESENTED BY
ITS SECRETARY SAJOHN M.P.
11 THAVINHAL SERVICE CO-OPERATIVE BANK LTD.
NO. C 4032, THALAPUZHA P.O., WAYANAD - 670 644
REPRESENTED BY ITS SECRETARY NAZEEMA P.K.
12 KANIYAMBETTA SERVICE CO-OPERATIVE BANK LTD.
P.O.KANIYAMBETTA, WAYANAD - 673 124 REPRESENTED BY
ITS SECRETARY NISHA VARGHESE.
13 NALLURNAD SERVICE CO-OPERATIVE BANK LTD.
NO.6913, NALLURNAD P.O., DWARAKA, MANANTHAWADI,
WAYANAD - 670 645 REPRESENTED BY ITS SECRETARY RAJU
MATHEW.
14 MANANTHAVADI FARMER'S SERVICE CO-OPERATIVE BANK LTD.
NO.F 4034, MANANTHAVADY, WAYANAD - 670 645
REPRESENTED BY ITS MANAGING DIRECTOR M.MANOJ KUMAR.
15 MEENANGADI SERVICE CO-OPERATIVE BANK LTD.
MEENANGADI P.O., WAYANAD - 673 591 REPRESENTED BY ITS
SECRETARY MURALI M.N.
16 EACHOME SERVICE CO-OPERATIVE BANK LTD.
NO.C 6612, P.O.EACHOME, PANAMARAM, WAYANAD - 670 721
REPRESENTED BY ITS SECRETARY P.M.DEVASIA.
17 THEKKUMTHARA SERVICE CO-OPERATIVE BANK LTD.
P.O.THEKKUMTHARA, WAYANAD - 673 122 REPRESENTED BY
ITS SECRETARY PRIYA K.M.
18 PANMARAM SERVICE CO-OPERATIVE BANK LTD.
P.O.PANAMARAM, WAYANAD - 670 721 REPRESENTED BY ITS
SECRETARY SANDHYA E.
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19 THIRUNELLY SERVICE CO-OPERATIVE BANK LTD.
NO.4389, HEAD OFFICE, KATTIKULAM, WAYANAD - 670646,
REPRESENTED BY ITS SECRETARY VASANTHA KRISHNAN T.
20 SULTHAN BATHERY SERVICE CO-OPERATIVE BANK LTD.
NO.LL 11, P.O.SULTHAN BATHERY, WAYANAD - 673 592,
REPRESENTED BY ITS SECRETARY JESSY C.V.
21 THARIODE SERVICE CO-OPERATIVE BANK LTD.
P.O.KAVUMMANNAM, WAYANAD - 673 122 REPRESENTED BY ITS
SECRETARY THOMAS P.V.
22 TRIKKAIPETTA SERVICE CO-OPERATIVE BANK LTD.
NO.F 7602, HEAD OFFICE, MEPPADI P.O., WAYANAD - 673
577 REPRESENTED BY ITS SECRETARY SREEJITH K.S.
23 AMBALAVAYAL SERVICE CO-OPERATIVE BANK LTD.
AMBALAVAYAL P.O., WAYANAD - 673 593 REPRESENTED BY
ITS SECRETARY ATHIRA KRISHNAN
24 THONDERNAD SERVICE CO-OPERATIVE BANK LTD.
NO W 85, CHEPPAD, P.O.MAKKIYAD, WAYANAD - 670 731
REPRESENTED BY ITS SECRETARY KURIAKOSE P.A.
25 VYTHIRI SERVICE CO-OPERATIVE BANK LTD.
NO.F 868, P.O.VYTHIRI, WAYANAD - 673 576, REPRESENTED
BY ITS SECRETARY K.BINDU.
26 VELLIMUNDA SERVICE CO-OPERATIVE BANK LTD.
NO.C 530, P.O.KATTAYAD, WAYANAD - 670 731 REPRESENTED
BY ITS SECRETARY MUHAMMED RAFEEQ.
27 PERIYA SERVICE CO-OPERATIVE BANK LTD.
NO.W 284, P.O.PERIYA, WAYANAD - 670 644 REPRESENTED
BY ITS SECRETARY JOBISH K.J.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
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RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS
CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI - 682 018.
4 PRINCIPAL COMMISSIONER OF INCOME OF TAX KOZHIKODE
AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE - 673 001.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
SMT.M.S.KIRAN, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11558 OF 2022
PETITIONER/S:
1 KANHANGAD BLOCK VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD.NO.C 887,
VAZHUNNORODY, P.O.UPPILIKAI, KASARAGOD -671314,
REPRESENTED BY ITS SECRETARY ANEESH K.V.
2 BALAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S
293,
BALAL, BALAL P.O., KASARAGOD-671533, REPRESENTED BY
SECRETARY PRASANTH V.
3 KOTTAPPARA FARMER'S WELFARE CO-OPERATIVE SOCIETY LTD.
NO. S460,
KOTTAPPARA, P.O.PULLUR, KASARAGOD-671531, REPRESENTED
BY ITS SECRETARY SHYAMKUMAR K.
4 POTHANICAD BHAVANA NIRMANA SAHAKARANA SANGAM LTD. NO.
E 708,
POTHANICAD P.O., ERNAKULAM-686671, REPRESENTED BY ITS
SECRETARY SINDHU C.K.,
5 POTHANICAD AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD. NO.E 1231,
POTHANICAD P.O., KOTHAMANGALAM, ERNAKULAM-686671,
REPRESENTED BY ITS SECRETARY SALY IYPE.
6 VORKADY AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY
LTD. NO. S 419,
SUNKADAKATTE, MAJEERPALLA, P.O.VORKADY, MANJESWAR,
KASARAGOD-671323, REPRESENTED BY ITS SECRETARY
RAVINDRA MOOLYA M.
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7 ENMAKAJE PANCHAYATH PUBLIC WELFARE CO-OPERATIVE
SOCIETY LTD. NO.K 574,
P.O.KATUKUKKE, MANJESWAR, KASARAGOD -671552,
REPRESENTED BY ITS SECRETARY AJITH G.
8 CHEEMENI URBAN CO-OPERATIVE SOCIETY LTD. NO.S 358,
P.O.CHEEMENI, KASARAGOD-671313, REPRESENTED BY ITS
SECRETARY SATHI K.
9 CHITTUR PRIMARY CO-OPERATIVE AGRICULTURAL AND RURAL
DEVELOPMENT BANK LTD. NO.P 619,
P.O.CHITTUR, PALAKKAD-678101, REPRESENTED BY ITS
SECRETARY V.SHIELA.
10 PERLA PRIMARY AGRICULTURAL WELFARE CO-OPERATIVE
SOCIETY LTD. NO. S 394,
P.O.PERLA, KASARAGOD-671552, REPRESENTED BY ITS
SECRETARY RAMAKRISHNA RAI.
11 HOSDURG TALUK MOTOR TRANSPORT WORKERS WELFARE CO-
OPERATIVE SOCIETY LTD. NO.S 476,
PERIYA, PERIYA P.O., KASARAGOD-671320, REPRESENTED BY
ITS SECRETARY SRUTHI T.
12 PATTAMBI BLOCK BHAVANA NIRMANA SAHAKARANA SANGAM LTD.
NO.P 816,
NETHIRIMANGALAM, SANKARAMANGALAM P.O., PATTAMBI,
PALAKKAD-679303, REPRESENTED BY ITS SECRETARY
B.C.BIJU.
13 MANNARKKAD CO-OPERATIVE EMPLOYEES' CO-OPERATIVE
SOCIETY LTD. NO.P 629,
MANNARKKAD P.O., PALAKKAD-678582, REPRESENTED BY ITS
SECRETARY P.K.MOHANDAS.
14 VADATTUPARA RURAL CO-OPERATIVE SOCIETY LTD. NO.E
1087,
VADATTUPARA P.O., ERNAKULAM-686681, REPRESENTED BY
ITS SECRETARY SUNITHA M.VARGHESE.
15 PADNE AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD.
NO.S 386,
UDINOOR P.O., KASARAGOD -671310, REPRESENTED BY ITS
SECRETARY REMYA K.V.
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16 KOTHAMANGALAM VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD.NO.E 916,
KOTHAMANGALAM P.O., ERNAKULAM-686691, REPRESENTED BY
ITS SECRETARY BINDHU MATHAI.
17 KOTHAMANGALAM RURAL CO-OPERATIVE SOCIETY LTD.NO.E
1079,
KOTHAMANGALAM P.O., ERNAKULAM-689691, REPRESENTED BY
ITS SECRETARY JUBY JOHNSON.
18 MALABAR RUBBER AND OTHER AGRICULTURAL MARKETING AND
PROCESSING CO-OPERATIVE SOCIETY LTD. NO.254,
MALAKKALLU, MALAKKALLU P.O., KASARAGOD-671532,
REPRESENTED BY ITS SECRETARY SURESH KUMAR M.
19 KANHANGAD CO-OPERATIVE URBAN SOCIETY LTD. NO.324,
HOSDURG, P.O.KANHANGAD, KASARAGOD-671315, REPRESENTED
BY ITS SECRETARY SHOBA P.
20 KASTURBA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO.S 519,
WEAVERS STREET, P.O.NILESWAR, KASARAGOD -671314,
REPRESENTED BY ITS SECRETARY REJITHA K.
21 NILESHWAR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO. S 319,
P.O.NELESHWAR, KASARAGOD-671314, REPRESENTED BY ITS
SECRETARY SIVAPRASAD A.
22 NILESHWAR EX-GULFMEN WELFARE CO-OPERATIVE SOCIETY
LTD. S 92,
P.O.KOTTAPPURAM, NILESHWAR, KASARAGOD-671314,
REPRESENTED BY ITS SECRETARY RAJANI A.K.
23 PUTHIGE-ENMAKAJE CO-OPERATIVE URBAN SOCIETY LTD.,
SEETHANGOLI, P.O.EDNAD, KASARAGOD -671321,
REPRESENTED BY ITS SECRETARY HEMALATHA KODOTH.
24 TRIKARIPUR CO-OPERATIVE URBAN SOCIETY LTD. NO.S 320,
TRIKARIPUR, KASARAGOD -671310, REPRESENTED BY ITS
SECRETARY RAMESAN U.
25 CHERUVATHUR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
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NO.S 194,
V.V.NAGAR, P.O.CHERUVATHUR, KASARAGOD-671313,
REPRESENTED BY ITS SECRETARY SAJINI K.V.
26 CHITTUR GOVERNMENT SERVICE CO-OPERATIVE SOCIETY LTD.
NO.P 160,
CHITTUR P.O., PALAKKAD-678101, REPRESENTED BY ITS
SECRETARY GIRIJAVALLABHAN C.
27 CHEEMENI VANITHA SAHAKARANA SANGAM LTD. NO.S 212,
P.O.CHEEMENI, KASARAGOD-671313, REPRESENTED BY ITS
SECRETARY UDAYA BHANU K.
28 PARAPPA CO-OPERATIVE URBAN SOCIETY LTD. NO.S 330,
PARAPPA P.O., KASARAGOD -671533, REPRESENTED BY ITS
SECRETARY GIRISH P.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
2025:KER
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4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADVS.
SHRI.M.JAYAKRISHNAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 300
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11570 OF 2022
PETITIONER/S:
1 KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION
ASSOCIATION, DISTRICT COMMITTEE, KOLLAM REPRESENTED
BY ITS PRESIDENT, M.C. BINUKUMAR, AGED 48 YEARS S/O
K. CHELLAPPAN, PRESIDENT, ELAMADU SERVICE CO-
OPERATIVE BANK LTD, ELAMADU P.O.AYOOR, KOLLAM-691 508
2 ELAMADU SERVICE CO-OPERATIVE BANK LTD
ELAMADU.P.O, AYOOR, KOLLAM-691 508 REPRESENTED BY ITS
SECRETARY A JALAJA
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH
BLOCK NEW DELHI-110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE MINISTRY OF FINANCE ,
2025:KER
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GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI-682018
4 ADDITIONAL COMMISSIONER OF INCOME TAX ,
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM, -695 003
5 THE KERALA STATE CO-OPERATIVE BANK LTD
P.B.NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER,
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO_OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURM-695001
BY ADVS.
SMT.M.S.KIRAN, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 302
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11591 OF 2022
PETITIONER/S:
1 KOTTAPPADY EAST SERVICE CO-OPERATIVE BANK LTD.NO.E
152,
HEAD OFFICE AYROOR, AYROORPADAM P.O., ERNAKULAM-686
692, REPRESENTED BY ITS SECRETARY PATHROSE.K.P.
2 CHERUVATTOOR RURAL CO-OPERATIVE BANK LTD. NO.E 1089,
IRIMALLOOR P.O., KOTHAMANGALAM-686 691, REPRESENTED
BY ITS SECRETARY ICY MOL.M.J.
3 MAYYIL SERVICE CO-OPERATIVE BANK LTD. NO.C 343,
HEAD OFFICE, MAYYIL, KANNUR-6790 602, REPRESENTED BY
ITS SECRETARY SREELAL.C.
4 VORKADY SERVICE CO-OPERATIVE BANK LTD. NO.C 321,
P.O.VORKADY, VIA MANJESHWAR, KASARAGOD-671 321,
REPRESENTED BY ITS SECRETARY SHRIVASHSA BHAT.
5 ELAVANCHERY SERVICE CO OPERATIVE BANK LTD. NO.P 517,
ELAVANCHERY P.O., NEMMARA VIA, PALAKKAD-678 508,
REPRESENTED BY ITS SECRETARY V.SOUMAN.
6 ELAPPULLY SERVICE CO OPERATIVE BANK LTD. NO.F 1193,
ELAPPULLY P.O., PALAKKAD-678 622, REPRESENTED BY ITS
SECRETARY PARTHAN.N.
7 KANJIRAPPALLY CENTRAL SERVICE CO OPERATIVEBANK 1537,
HEAD OFFICE, KANJIRAPALLY, KOTTAYAM-686 507,
REPRESENTED BY ITS SECRETARY SOUDA.P.K.
8 INCHIANY SERVICE CO OPERATIVE BANK LTD.K 154,
2025:KER
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HEAD OFFICE, INCHIANY P.O., KANJIRAPALLY TLAUK,
KOTTAYAM-686 512, REPRESENTED BY ITS SECRETARY THOMAS
K.GEORGE.
9 PERUMBAVOOR URBAN CO OPERATIVE BANK LTD. NO.2024,
P.O.PERUMBAVOOR, ERNAKULAM-683 542, REPRESENTED BY
ITS SECRETARY BEEVIJA.P.H.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY, , MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
PB NO.6515, CO BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 304
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 305
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11601 OF 2022
PETITIONER/S:
THEVARA URBAN CO-OPERATIVE SOCIETY LTD. NO. E-784,
PERUMANOOR , COCHIN 682 016, REPRESENTED BY THE
SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM
682 018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR,
KANDAMKULATHY TOWER, M G ROAD, KARIKKAMURI, SHENOYS ,
KOCHI, KERALA 682 011.
4 THE KERALA STATE CO OPERATIVE BANK LTD,
CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 306
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 307
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11599 OF 2022
PETITIONER/S:
THAZHEKKAD SERVICE CO-OPERATIVE BANK LTD NO R 167,
THAZHEKKAD, MALA, THRISSUR-680 691, REPRESENTED BY
THE SECRETARY
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF
INDIA,MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL,
NEW DELHI-110 001
2 THE COCMMISSIONER OF INCME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM-
682 018
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR,
KANDAMKULATHY TOWER, M.G.ROAD, KARIKKAMURI, SHENOYS,
KOCHI, KERALA 682 011.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 308
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 309
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11600 OF 2022
PETITIONER/S:
THE PULLUR SERVICE CO-OPERATIVE BANK
LTD., NO. 550 , PULLUR P.O, THRISSUR 680 683,
REPRESENTED BY THE SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110001.
2 THE COMMISSIONER OF INCOM TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM
682 018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR,
KANDAMKULATHY TOWER, M. G ROAD, KARIKKAMURI, SHENOYS,
KOCHI, KERALA 682 011.
4 THE KERALA STATE CO -OPERATIVE BANK LTD,
CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 310
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 311
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11604 OF 2022
PETITIONER/S:
THE NELLAYI PARAPPUKARA SERVICE CO-OPERATIVE BANK
LTD.
460, NELLAYI P.O.THRISSUR-680 305, REPRESENTED BY ITS
SECRETARY
BY ADVS.
SMT.NISHA GEORGE
SHRI.ANSHIN K.K
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE 111RD FLOOR, AAYAKAR BHAVAN, KOWDIAR
P.O.THIRUVANANTHAPURAM, PIN-695 003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO 143, E NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT) MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI PIN-110 001
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI, PIN-110 001.
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
2025:KER
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THIRUVANANTHAPURAM, PIN-695 001.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF OF CO-OPERATION, GOVERNMENT
SECRETARIAT, THIRUVANANTHAPURAM, PIN-695 001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN-695 033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 313
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11607 OF 2022
PETITIONER/S:
1 THE THODUPUZHA TALUK EDUCATIONAL CO-OPERATIVE SOCIETY
LTD NO 1-159,
REPRESENTED BY ITS HON SECRETARY, STEPEHN P.S.S/O
SIMON, HEAD OFFICE, THODUPUZHA TALUK & POST, IDUKKI
DISTRICT-685 584.
2 THE L.I.C.AGENTS CO-OPERATIVE SOCIETY LTD, NO 1-394,
REPRESENTED BY ITS SECRETARY IN-CHARGE, SABU M.R.AGED
49 YEARS, S/O RAMAKRISHNAN, HEAD OFFICE, NEDUMKANDAM
P.O.UDUMBANCHOLA TALUK, IDUKKI DISTRICT-685 553.
3 THE IDUKKI DISTICT PANCHAYATH EMPLOYEES CO-OPERATIVE
SOCIETY LTDD, NO 1-193,
REPRESENTED BY MEJO CHERIAN, AGED 44 YEARS, S/O P.U.
CHERIAN, HEAD OFFICE, NEDUMKANDAM P.O.UDUMBANCHOLA
TALUK, IDUKKI DISTRICT-685 553.
4 THE VYAPARI CO-OPERATIVE SOCIETY LTD 1-467,
REPRESENTED BY ITS SECRETARY, NELSON XAVIER, AGED 53
YEARS, S/O THANISLAVOSE, HEAD OFFICE, NEDUMKANDAM
P.O.IDUKKI DISTRICT-685 553
BY ADVS.
SRI.GEORGE MATHEW
SHRI.PRAVEEN S.
SMT.ELSA DENNY PINDIS
SRI.M.D.SASIKUMARAN
SHRI.SUNIL KUMAR A.G
SRI.DIPU JAMES
SHRI.MATHEW K.T.
2025:KER
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SHRI.GEORGE K.V.
SHRI.STEPHY K REGI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
002.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDINGS I.S PRESS ROAD, KOCHI-682
018.
3 THE INCOME TAX OFFICER,
TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8,
THODUPUZHA, IDUKKI DISTRICT-685 014
4 STATE OF KERALA,
REP BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT
SECRETARIAT, THIRUVANANTHAPURAM-695 001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM-695 014.
6 THE KERALA STATE CO-OPERATIVE BANK LTD,
(KERALA BANK), REP BY ITS MANAGING DIRECTOR & CHIEF
EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-685 033.
7 THE DEPUTY GENERAL MANAGER,
CENTRAL PROCESSING CENTER, THE KERALA STATE CO-
OPERATIVE BANK LTD, (KERALA BANK), VAZHATHOPE, IDUKKI
COLONY P.O.IDUKKI -685 602.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 315
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 316
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11605 OF 2022
PETITIONER/S:
VARAVOOR SERVICE CO-OPERATIVE SOCIETY LTD NO R299,
VARAVOOR P.O.THRISSUR-680 585, REPRESENTED BY THE
SECRETARY-IN-CHARGE.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW
DELHI-110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM-
682 018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR,
KANDAMKULATHY TOWER, M.G.ROAD, KARIKKAMURI, SHENOYS,
KOCHI, KERALA-682 011.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SRI.RAHUL RAJ
2025:KER
W.P(C)No.7053/2023 & Connected cases 317
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 318
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11609 OF 2022
PETITIONER/S:
CHATHEDOM SERVICE CO-OPERATIVE BANK LIMITED,
THURUTHIPURAM P.O., ERNAKULAM 680 667, REPRESENTED BY
ITS SECRETARY IN CHARGE BIJU.P.S.
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SRI.P.F.JOY
SHRI.RAJATH R NATH
SMT.HARIMA HARIHARAN
SMT.G.REMADEVI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 11001.
2 COMMISSIONER OF INCOME TAX
(TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI
682 018.
3 THE INCOME TAX OFFICER, (TDS),
KAP COMPLEX, HIGH WAY SH 16, ALUVA 683 101.
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
2025:KER
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MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 11001, REPRESENTED BY ITS CHAIRMAN.
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018.
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE , 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM 695 003.
7 THE KERALA STATE CO OPERATIVE BANK LTD,
(KERALA BANK), PO NO. 6515, CO- BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS
MANAGING DIRECTOR.
8 THE KERALA STATE CO OPERATIVE BANK LTD,
KERALA BANK), V C S COMPLEX, PUTHENVELIKKARA P.O.,
683 594, REPRESENTED BY ITS MANAGING DIRECTOR.
9 STATE OF KERALA
REPRESENTED BY ITS SECRETARY ( CO - OPERATION)
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM 695 001.
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 320
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 10302 OF 2022
PETITIONER/S:
PATTEPADAM RURAL CO-OPERATIVE SOCIETY LTD.NO. R 1040
KOTTANALLUR P.O., THRISSUR, REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
2025:KER
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SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 322
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11616 OF 2022
PETITIONER/S:
KEEZHILLAM AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD NO.E-1248
RAYAMANGALAM P.O., ERNAKULAM DISTRICT, PIN-683545,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.BINU PAUL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682018.
3 INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI
ROAD, KOTTAYAM-686001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
THIRUVANANTHAPURAM-695033.
BY ADVS.
2025:KER
W.P(C)No.7053/2023 & Connected cases 323
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 324
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11619 OF 2022
PETITIONER/S:
1 THE KERALA ADVOCATE GENERAL DEPARTMENT STAFF CO-
OPERATIVE SOCIETY LTD NO.E 315
ERNAKULAM, REPRESENTED BY ITS SECRETARY, PIN-682 018
2 THE CMFRI EMPLOYEES CO-OPERATIVE SOCIETY LTD
NO.E.832,
ERNAKULAM, PRESENTED BY ITS SECRETARY, PIN- 682018
3 THE CENTRAL EXCISE EMPLOYEES CO-OPERATIVE CREDIT
SOCIETY LTD
NO. E. 674.C.R.BUILDING.I.S.PRESS ROAD, KOCHI-682
018, REPRESENTED BY ITS SECRETARY, PIN- 682 018
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (TDS)
CNTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
PIN-682 018
2 THE INCOME TAX OFFICER, (TDS),
INCOME TAX DEPARTMENT, ERNAKULAM-PIN-680 001
3 THE KERALA STATE CO-OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM, THRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR. PIN-695 033
4 THE MANAGER,
2025:KER
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KERALA STATE CO-OPERATIVE BANK LTD, MARINE DRIVE
BRANCH, ERNAKULAM, PIN- 682 031
BY ADVS.
SHRI.ANISH JAIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 326
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11620 OF 2022
PETITIONER/S:
THE LEMONGRASS OIL AND GENERAL MARKETING CO-OPERATIVE
SOCIETY LTD. NO.3200,
KURUPPAMPADY, KURUPPAMPADY P.O., PIN-683545,
ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY.
BY ADV SRI.BINU PAUL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682018.
3 INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI
ROAD, KOTTAYAM-686001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
THIRUVANANTHAPURAM-695033.
BY ADVS.
2025:KER
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SHRI.ANISH JAIN, CGC
SRI.CHRISTOPHER ABRAHAM
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 328
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11621 OF 2022
PETITIONER/S:
THE FACT EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD
LIMITED NO. E. 663, UDYOGMANDAL .P.O, ERNAKULAM
DISTRICT, 683501, REPRESENTED BY ITS SECRETARY,
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001
2 THE COMMISSIONER OF INCOME TAX
CENTRAL REVENUE BUILDING. I.S.PRESS ROAD,
ERNAKULAM,PIN-682018
3 THE INCOMETAX OFFICER, (TDS )
INCOME TAX DEPARTMENT ,I.S.PRESS ROAD, ERNAKULAM-PIN-
682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM., THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033
5 THE MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, KALAMASSERY,
ERNAKULAM-, PIN-683 104
2025:KER
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BY ADV SHRI.SHYAMDEEP S.SHENOY, CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 330
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11627 OF 2022
PETITIONER/S:
P.W.D. IRRIGATION & L.S.G.D. EMPLOYEES CO-OPERATIVE
SOCIETY LTD. NO. T. 638,
REPRESENTED BY ITS SECRETARY, PUBLIC OFFICE BUILDING,
THIRUVANANTHAPURAM-695542.
BY ADVS.
SRI.S.V.PREMAKUMARAN NAIR
SRI.R.T.PRADEEP
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, MINISTRY OF FINANCE,
NORTH BLOCK, NEW DELHI-110001.
2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
C.R.BUILDING, I.S.PRESS ROAD, KACHERIPADY, ERNAKULAM-
682018.
3 THE CHIEF COMMISSIONER OF INCOME TAX,
AAYAKAR BHAVAN, PEROORKADA ROAD, KOWDIAR,
THIRUVANANTHAPURAM-695003.
4 DEPUTY COMMISSIONER OF INCOME TAX,
AAYAKAR BHAVAN, PEROORKADA ROAD, KOWDIAR,
THIRUVANANTHAPURAM-695003.
2025:KER
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5 THE KERALA STATE CO-OPERATIVE BANK LTD.,
REPRESENTED BY ITS MANAGING DIRECTOR, PB NO.6515,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-
695033.
6 MANAGER,
THE KERALA STATE CO-OPERATIVE BANK LTD., NANTHENCODE
BRANCH, THIRUVANANTHAPURAM, PIN-695011.
7 MANAGER,
THE KERALA STATE CO-OPERATIVE BANK LTD., M & E
PUTHENCHANTHA BRANCH, THIRUVANANTHAPURAM, PIN-695141.
8 MANAGER,
THE KERALA STATE CO-OPERATIVE BANK LTD., M & E FORT
BRANCH, THIRUVANANTHAPURAM, PIN-695023.
9 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF REGISTRAR OF CO-OPERATIVE SOCIETIES,
THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 332
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11646 OF 2022
PETITIONER/S:
MARADY AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
LTD.,
NO. E 1188, SOUTH MARADY P.O, MUVATTUPUZHA- 686 673,
REPRESENTED BY ITS SECRETARY LALY VARGHESE.
BY ADV SHRI.S.ARUN RAJ
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL , NEW DELHI , PIN 110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, COCHIN- 682
018.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI 682 018.
4 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE , MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001,
REPRESENTED BY ITS CHAIRMAN.
5 KERALA STATE CO-OPERATIVE BANK (KERALA BANK),
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FORMERLY ERNAKULAM DISTRICT CO-OPERATIVE BANK LTD)
MUVATTUPUZHA RURAL BRANCH, POST OFFICE JUNCTION,
MUVATTUPUZHA, ERNAKULAM 686 661, REPRESENTED BY ITS
BRANCH MANAGER.
6 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM , PIN 695 001.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 334
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11649 OF 2022
PETITIONER/S:
1 AIRAPURAM SERVICE CO-OPERATIVE BANK LTD NO.2124
AIRAPURAM P.O., ERNAKULAM DISTRICT, PIN - 683 541
REPRESENTED BY ITS SECRETARY IN CHARGE.
2 MANNAM SERVICE CO-OPERATIVE BANK LTD.NO.E 277
MANNAM P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN - 683
520, REPRESENTED BY ITS SECRETARY.
3 KAITHARAM SERVICE CO-OPERATIVE BANK LTD.NO.1112
KAITHANAM P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN -
683 519, REPRESENTED BY ITS SECRETARY.
4 GANDHI SMARAKA SERVICE CO-OPERATIVE BANK LTD.NO.1349
NANTHIATTUKUNNAM, N.PARAVUR, ERNAKULAM DISTRICT, PIN
- 683 513, REPRESENTED BY ITS SECRETARY.
5 PALLIYAKKAL SERVICE CO-OPERATIVE BANK LTD.NO.2232
EZHIKKARA P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN -
683 513, REPRESENTED BY ITS SECRETARY.
6 CHETTIKKAD SERVICE CO-OPERATIVE BANK LTD.NO.851
CHETTIKKA, KUNJITHAI P.O., ERNAKULAM DISTRICT, PIN -
683 522, REPRESENTED BY ITS SECRETARY.
7 PERUMBAVOOR AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD.NO.E 1208
PERUMBAVOOR PATTAL P.O., ERNAKULAM DISTRICT,PIN - 683
548, REPRESENTED BY ITS PRESIDENT.
8 PARAVUR VADAKKEKARA SERVICE CO-OPERATIVE BANK
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LTD.NO.3131
NEENDOOR, VADAKKEKARA P.O., ERNAKULAM DISTRICT, PIN -
683 522, REPRESENTED BY ITS SECRETARY.
9 THIRUVANKULAM AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD.NO.E 1219
KARINGACHIRA, IRIMPANAM P.O., ERNAKULAM DISTRICT, PIN
- 682 309, REPRESENTED BY ITS SECRETARY.
10 COCHIN NAVAL BASE CIVILIAN EMPLOYEES CO-OPERATIVE
HOUSING SOCIETY LTD.
NO.E 737, KOCHI, ERNAKULAM DISTRICT, PIN - 682 004,
REPRESENTED BY ITS SECRETARY.
11 ELOOKKARA SERVICE CO-OPERATIVE BANK LTD.
NO.1765, ELOOKKARA, MUPPATHADAM P.O., ALUVA,
ERNAKULAM DISTRICT, PIN - 683 110, REPRESENTED BY ITS
SECRETARY.
12 ASAMANNOOR AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD.NO.E 1216
ASAMANNOOR P.O., ODAKKALI, ERNAKULAM DISTRICT, PIN -
683 549, REPRESENTED BY ITS HON. SECRETARY.
13 KOLENCHERY RURAL CO-OPERATIVE BANK LTD.NO.E 1072
KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311,
REPRESENTED BY ITS SECRETARY.
14 KUNNATHUNAD AIDED SCHOOL STAFF CO-OPERATIVE SOCIETY
LTD.NO.1090
KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311,
REPRESENTED BY ITS SECRETARY.
15 KUNJITHAI SERVICE CO-OPERATIVE BANK LTD.NO.1937
KUNJITHAI P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN -
683 522, REPRESENTED BY ITS SECRETARY IN CHARGE.
16 KOLENCHERY MEGHALA MERCANTILE WELFARE CO-OPERATIVE
SOCIETY LTD.
NO.E 1343, KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN -
682 311, REPRESENTED BY ITS SECRETARY.
17 EDAKOCHI SERVICE CO-OPERATIVE BANK LTD.NO.116
EDAKOCHI P.O., KOCHI, ERNAKULAM DISTRICT, PIN - 682
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010, REPRESENTED BY ITS SECRETARY.
18 KOLENCHERRY AREA PRAVASI CO-OPERATIVE SOCIETY LTD.
NO.E 1421
PERINGALA P.O., PERINGALA, ERNAKULAM DISTRICT, PIN -
683 565, REPRESENTED BY ITS SECRETARY.
19 PALLURUTHY MANDALAM SERVICE CO-OPERATIVE BANK
LTD.NO.65
PALLURUTHY P.O., KOCHI, ERNAKULAM DISTRICT, PIN - 682
006, REPRESENTED BY ITS SECRETARY.
20 NELLAD AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
LTD.NO.E 1220
NELLAD P.O., ERNAKULAM DISTRICT, PIN - 686 669,
REPRESENTED BY ITS SECRETARY.
21 KUMBALANGI SERVICE CO-OPERATIVE BANK LTD.NO.762
KUMBALANGI P.O., KOCHI, ERNAKULAM DISTRICT, PIN - 682
007, REPRESENTED BY ITS SECRETARY.
22 NORTH CHELLANAM PANCHAYATH SERCVICE CO-OPERATIVE
SOCIETY LTD.
NO.E 871, KANNAMALY P.O., CHERIYA KADAVU, ERNAKULAM
DISTRICT, PIN - 682 008, REPRESENTED BY ITS
SECRETARY.
23 CHITTATTUKARA PANCHAYATH SERVICE CO-OPERATIVE BANK
LTD.
NO.1443, VALIYAPALLAMTHURUTH, CHENDAMANGALAM P.O.,
ERNAKULAM DISTRICT, PIN - 683 512, REPRESENTED BY ITS
SECRETARY IN CHARGE.
24 BPCL KOCHI REFINERY EMPLOYEES CO-OPERATIVE CREDIT
SOCIETY LTD.NO.E 213
AKASHYA BHARAT BUILDINGS, AMBALAMUGAL P.O., ERNAKULAM
DISTRICT, PIN - 682 302, REPRESENTED BY ITS HON.
SECRETARY.
25 POOTHRIKKA KUCS LTD.NOL.E95
(D) APCOS, POOTHRIKKA P.O., ERNAKULAM DISTRICT, PIN -
682 308, REPRESENTED BY ITS SECRETARY.
26 THE THURUTHIPURAM SERVICE CO-OPERATIVE BANK LTD.
2025:KER
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NO.E 1789, THURUTHIPURAM P.O., ERNAKULAM DISTRICT,
PIN - 680 667, REPRESENTED BY ITS PRESIDENT.
27 MALANKARA ORTHODOX SYRIAN CHURCH MEDICAL COLLEGE
EMPLOYEES CO-OPERATIVE SOCIETY LTD.NO.E 1136,
KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311,
REPRESENTED BY ITS PRESIDENT.
28 KEL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD.NO.E
777
MAMALA P.O., THIRUVANKULAM, ERNAKULAM DISTRICT, PIN -
682 305, REPRESENTED BY ITS PRESIDENT.
29 KOLENCHERY AREA VYAPARI VYAVASAI WELFARE CO-OPERATIVE
SOCIETY LTD.NO.E 1352
SAMITHI BUILDINGS, KOLENCHERY P.O., ERNAKULAM
DISTRICT, PIN - 682 311, REPRESENTED BY ITS
SECRETARY.
30 ST.PETER'S COLLEGE STAFF CO-OPERATIVE SOCIETY LTD.
NO.E 705, KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN -
682 311, REPRESENTED BY ITS SECRETARY.
31 SYNTHITE EMPLOYEES CO-OPERATIVE SOCIETY LTD
NO.E 1120, KADAYIRUPPU P.O., ERNAKULAM DISTRICT, PIN
- 682 311, REPRESENTED BY ITS SECRETARY.
32 PARUR CO-OPERATIVE BANK LTD.NO.1759
NORTH PARUR P.O., ST.GERMAN'S ROAD, ERNAKULAM
DISTRICT, PIN- 683 513, REPRESENTED BY ITS SECRETARY.
33 KADUNGALLOORE SERVICE CO-OPERATIVE BANK LTD.NO.2165
EAST KADUNGALLOOR P.O., ERNAKULAM DISTRICT, PIN - 682
102, REPRESENTED BY ITS SECRETARY.
34 TELK EMPLOYEES MULTI PURPOSE CO-OPERATIVE SOCIETY
LTD.NO.E 291
ANGAMALY SOUTH P.O., ERNAKULAM DISTRICT, PIN - 683
573, REPRESENTED BY ITS SECRETARY.
35 KAMCO EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD.NO.E
335
ATHANI P.O., ALUVA, ERNAKULAM DISTRICT, PIN - 683
585, REPRESENTED BY ITS SECRETARY.
2025:KER
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36 AKAPARAMBU SERVICE CO-OPERATIVE SOCIETY LTD.NO.E 943
MAIKAVE, VAPPALASSERY P.O., ERNAKULAM DISTRICT, PIN-
683 572, REPRESENTED BY ITS SECRETARY IN CHARGE.
37 THE ERNAKULAM DISTRICT CO-OPERATIVE BANK EMPLOYEES
CO-OPERATIVE SOCIETY LTD.NO.E 166
TRANSVENUE APARTMENT , NEAR POST OFFICE, KAKKANAD,
ERNAKULAM DISTRICT, PIN - 682 030, REPRESENTED BY ITS
SECRETARY.
38 THE CENTRAL SERVICES CO-OPERATIVE SOCIETY LTD.NO.E
223
MANIKKATH ROAD, RAVIPURAM, KOCHI, PIN - 682 316,
REPRESENTED BY ITS SECRETARY.
39 ALLAPRA AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
LTD.E 1389
ALLAPRA P.O. - 683 556, ERNAKULAM DISTRICT,
REPRESENTED BY ITS PRESIDENT.
40 MULANTHURUTHY RURAL CO-OPERATIVE BANK LTD.E 1336
MULANTHURUTHY P.O., HOSPITAL JUNCTION, ERNAKULAM, PIN
- 682 314, REPRESENTED BY ITS SECRETARY.
41 MALANKARA EMPLOYEES CO-OPERATIVE SOCIETY LTD.NO.E
1166
PUTHENCRUZ P.O., ERNAKULAM DISTRICT, PIN - 628 308,
REPRESENTED BY ITS SECRETARY.
42 MANEED PANCHAYATH GRAMEENA CO-OPERATIVE SOCIETY LTD.
NO.E 1358, EZHAKKARANAD, EZHAKKARANAD P.O.,
PUTHENCRUZ (VIA), PIN - 628 308, REPRESENTED BY ITS
HON. SECRETARY.
43 THURAVOOR GRAMEENA SERVICE CO-OPERATIVE SOCIETY LTD.
NO.E 1392, THURAVOOR P.O., ERNAKULAM DISTRICT, PIN -
683 572, REPRESENTED BY ITS PRESIDENT.
BY ADVS.
SRI.M.M.MONAYE
SHRI.M.PAUL VARGHESE
SRI.K.V.SANOSH
2025:KER
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SMT.NIRMALA P.V.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI, PIN - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI - 110 001.
3 COMMISSIONER OF INCOME TAX (TDS)
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM - 682 018.
4 STATE OF KERALA
DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT,
REPRESENTED BY SECRETARY TO GOVERNMENT,
THIRUVANANTHAPURAM - 695 011.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM - 695
001.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, THIRUVANANTHAPURAM - 695 033.
7 DEPUTY GENERAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD., CREDIT
PROCESSING CENTRE, KAKKANAD, KOCHI - 682 030.
BY ADVS.
SHRI.JAGADEESH LAKSHMAN, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 340
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 341
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11654 OF 2022
PETITIONER/S:
KARUVANTHIRUTHY SERVICE CO-OPERATIVE BANK
NO.D 2638, KARUVANTHIRUTHY P.O., FEROKE, KOZHIKODE-
673 631, REPRESENTED BY ITS SECRETARY-KHALID
SHAMEEM.K.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001
2 THECOMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682
018
3 THE INCOME TAX OFFICER (TDS),
AYAKKAR BHAVAN, MANANCHIRA, KOZHIKODE-673 001-678001
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(ERSTWHILE KOZHIKODE DISTRICT CO-OPERATIVE BANK), ALI
ROAD, COLOMBO BUILDING, KOZHIKODE-678 002
2025:KER
W.P(C)No.7053/2023 & Connected cases 342
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 343
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11683 OF 2022
PETITIONER/S:
NEDUPUZHA SERVICE CO-OPERATIVE BANK LTD NO.555
NEDUPUZHA P.O., THRISSUR-680 007 REPRESENTED BY ITS
SECRETARY IN CHARGE.
BY ADV SRI.S.SHYAM KUMAR
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY,DEPARTMENT OF
REVENUE,MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH
BLOCK ,NEW DELHI-110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH
BLOCK,NEW DELHI -110001,REPRESENTED BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA,CENTRAL
REVENUE BUILDINGS,IS PRESS ROAD,COCHIN -682018
4 INCOME TAX OFFICER(TDS)
OFFICE OF THE INCOME TAX OFFICE(TDS),AAYAKAR
BHAVAN,SAKTHAN THAMPURAN NAGAR,THRISSUR-680 001
5 THE KERALA STATE CO-OPERATIVE BANK LTD,P.B.NO.6515
CO-BANK TOWERS,PALAYAM,THIRUVANATHAPURAM-
2025:KER
W.P(C)No.7053/2023 & Connected cases 344
695033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER
6 STATE OF KERALA-REPRESENTED BY ITS SECRETARY
DEPARTMENT OF CO-
OPERATION,SECRETARIAT,THIRUVANANTHAPURAM-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 345
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11679 OF 2022
PETITIONER/S:
COCHIN NAVAL BASE CIVILIAN EMPLOYEES CO-OPERATIVE
SOCIETY LTD N O 4146,
COCHIN-682 004, ERNAKULAM, REPRESENTED BY ITS
SECRETAY-IN-CHARGE
BY ADV SRI.S.SHYAM KUMAR
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
COCHIN-682 018
4 INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICE (TDS) AAYAKAR BHAVAN,
SAKATHAN THAMPURAN NAGAR, THRISSUR-680 001
5 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515,
2025:KER
W.P(C)No.7053/2023 & Connected cases 346
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033.
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
6 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO-
OPERATION, SECRETARIAT, THIRUVANANTHAPURAM-695 001
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 347
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11684 OF 2022
PETITIONER/S:
COCHIN CITY SERVICE CO-OPERATIVE BANK LTD. NO. E-1101
CHITTOOR ROAD,AYYAPPANKAVU,KOCHI-18,REPRESENTED BY
ITS SECRETARY
BY ADV SRI.S.SHYAM KUMAR
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY,DEPARTMENT OF
REVENUE,MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH
BLOCK ,NEW DELHI-110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH
BLOCK,NEW DELHI -110001,REPRESENTED BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA,CENTRAL
REVENUE BUILDINGS,IS PRESS ROAD,COCHIN -682018
4 INCOME TAX OFFICER(TDS)
OFFICE OF THE INCOME TAX OFFICE(TDS),AAYAKAR
BHAVAN,SAKTHAN THAMPURAN NAGAR,THRISSUR-680 001
5 THE KERALA STATE CO-OPERATIVE BANK LTD,P.B.NO.6515
CO-BANK TOWERS,PALAYAM,THIRUVANATHAPURAM-
2025:KER
W.P(C)No.7053/2023 & Connected cases 348
695033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER
6 STATE OF KERALA-REPRESENTED BY ITS SECRETARY
DEPARTMENT OF CO-
OPERATION,SECRETARIAT,THIRUVANANTHAPURAM-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 349
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11718 OF 2022
PETITIONER/S:
THE THALORE SERVICE CO-OPERATIVE BANK LTD
1-269, THALORE, THRISSUR - 680 306, REPRESENTED BY
ITS SECRETARY, T.V.SHAJIKUMAR.
BY ADV SMT.MEERA V.MENON
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX(TDS)
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 18.
2 THE INCOME TAX OFFICER
WARD 2(5), AAYAKAR BHAVAN, THRISSUR - 680 001.
3 THE KERALA STATE CO-OPERATIVE BANK
P.B.NO.6515, COBANK TOWERS, VIKAS BHAVAN P.O.,
PALAYAM, THIRUVANANTHAPURAM - 695 033, REPRESENTED BY
ITS BRANCH MANAGER.
4 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT, MINISTRY OF
FINANCE (DEPARTMENT OF REVENUE), NORTH BLOCK, NEW
DELHI - 110 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 350
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 351
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11721 OF 2022
PETITIONER/S:
THRIKKARUVA PANCHAYAT RESIDENCE WELFARE CO-OPERATIVE
SOCIETY LTD.NO.Q 1547, NO. Q 1547
SECRETARY -IN-CHARGE, KANJAVELY P O, KOLLAM DISTRICT-
691602.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P O,
THIRUVANANTHAPURAM, PIN-695003.
2 THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT,RAISANA HILL, NEW DELHI, PIN-110001.
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES
2025:KER
W.P(C)No.7053/2023 & Connected cases 352
THIRUVANANTHAPURAM, PIN-695001.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN-695001.
6 THE KERALA STATE CO-OPERATIVE BANK
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P B
NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN-695033.
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 353
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11728 OF 2022
PETITIONER/S:
ATTINGAL PRAVASI KSHEMA VIKASANA SAHAKARANA SANGAM
LTD NO.T 2166
REPRESENTED BY ITS SECRETARY, PALAKUNNU, ,
CHIRAYINKEEZHU, THIRUVANANTHAPURAM DISTRICT, PIN-
695304.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P O,
THIRUVANANTHAPURAM, PIN-695003.
2 THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT,RAISANA HILL, NEW DELHI, PIN-110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 354
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES
THIRUVANANTHAPURAM, PIN-695001.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN-695001.
6 THE KERALA STATE CO-OPERATIVE BANK
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P B
NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN-695033.
BY ADVS.
SMT.M.S.KIRAN
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 355
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11727 OF 2022
PETITIONER/S:
ARIMPUR PANCHAYAT KARSHIKETHARA CO-OPERATIVE SOCIETY
LTD NO.R 1273 P.O.VELUTHUR, THRISSUR, -680 012,
REPRESENTED BY ITS SECRETARY
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM-
682 018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,
REPRESENTED BY ITS MANAGING DIRECTOR
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 356
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 357
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11740 OF 2022
PETITIONER/S:
1 THE AYYAPANCOVIL SERVICE CO-OPERATIVE BANK
LTD.NO.3558
REPRESENTED BY ITS SECRETARY, JOJOMON JOSE, S/O.
JOSE, AGED 40 YEARS, HEAD OFFICE, AYYAPPANCOIL P.O,
IDUKKI 685 510
2 THE NEDUMKANDAM URBAN CO-OPERATIVE SOCIETY LTD NO 1-
104
REPRESENTED BY ITS SECRETARY , JOSEPH THOMAS, AGED 50
YEARS, S/O. THOMAS, HEAD OFFICE, NEDUMKANDAM P.O,
IDUKKI 685 553
BY ADVS.
SRI.GEORGE MATHEW
SHRI.PRAVEEN S.
SRI.M.D.SASIKUMARAN
SHRI.SUNIL KUMAR A.G
SRI.DIPU JAMES
SMT.ELSA DENNY PINDIS
SHRI.MATHEW K.T.
SHRI.GEORGE K.V.
SHRI.STEPHY K REGI
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY
OF FINACE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
2025:KER
W.P(C)No.7053/2023 & Connected cases 358
002
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI 682
018
3 THE INCOME TAX OFFICER
TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8,
THODUPUZHA, IDUKKI DISTRICT 685 584
4 STATE OF KERALA
REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT,
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001
5 REGISTRAR OF CO-OPERATIVE SOCIETIESE SOCIETIES
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM 695 014
6 THE KERALA STATE CO-OPERATIVE BANK LTD.(KERALA BANK)
REPRESENTED BY ITS MANAGING DIRECTOR AND CHIEF
EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033
7 THE DEPUTY GENERAL MANAGER
CENTRAL PROCESSING CENTER, THE KERALA STATE CO-
OEPRATIVE BANK LTD, (KERALA BANK) VAZHATHOPE, IDUKKI
COLONY P.O, IDUKKI DISTRICT 685 602
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 359
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11738 OF 2022
PETITIONER/S:
1 EDAVANAKAD AYYAMPILLY FISHERMEN DEVELOPMENT WELFARE
CO-OPERATIVE SOCIETY
(E) 7/87/CZ, KUZHUPILLY, AYYAMPILLY P.O. - 682 501.
2 PAZHANGAD FISHERMEN DEVELOPMENT WELFARE CO-OPERATIVE
SOCIETY
(E) 118/92, EDAVANAKKAD P.O. - 682 502.
3 CHERAI MUNAMBAM MATSYATHOZHILALI VIKASANA KSHEMA
SAHAKARANA SANGHAM
F(E) 6/87/CZ, CHERAI - 683 514.
BY ADVS.
SHRI.AJI V.DEV
SRI.ALAN PRIYADARSHI DEV
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI - 682 018.
2025:KER
W.P(C)No.7053/2023 & Connected cases 360
3 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001 REPRESENTED BY ITS
CHAIRMAN.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
THIRUVANANTHAPURAM - 695 033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 361
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11765 OF 2022
PETITIONER/S:
1 THE KASARGOD MERCHANTS CO-OPERATIVE SOCIETY LTD .NO.
S.113,
VYAPARA BHAVAN, M.G.ROAD, KASARAGOD-671121,
REPRESENTED BY ITS SECRETARY KISHOR KUMAR M.
2 AJANUR URBAN SERVICE CO-OPERATIVE SOCIETY LTD.
NO.S.322,
ATHINHAL, MANIKOTH P.O., KANHANGAD, KASARAGOD-671316,
REPRESENTED BY ITS SECRETARY SAVITHIRI K.V.
3 NILESHWAR RANGE KALLU CHETHU VYAVASAYA THOZHILALI CO-
OPERATIVE SOCIETY LTD. NO.S.309,
NILESHWAR P.O., KASARAGOD -671314, REPRESENTED BY ITS
SECRETARY SANTHOSH C.
4 KONNAKADU VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO.S.289,
KONNAKADU P.O., KASARAGOD-671534, REPRESENTED BY ITS
SECRTARY G.CHITHARA LEKHA.
5 MALOM VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO.S.288,
MALOM, DARKAS P.O., VELLARIKUNDU, KASARAGOD -671533,
REPRESENTED BY ITS SECRETARY SUMATHY K.
6 THE MADIKAI PANCHAYATH VANITHA SERVICE CO-OPERATIVE
SOCIETY LTD. NO.S.291,
POOTHAKKAL, ACHIKANAM P.O., KASARAGOD-671531,
REPRESENTED BY ITS SECRETARY RAJANI C.
7 HOSDURG VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
2025:KER
W.P(C)No.7053/2023 & Connected cases 362
NO.S.240,
HOSDURG, KANHANGAD P.O., KASARAGOD -671315,
REPRESENTED BY ITS SECRETARY JAYASREE K.
8 THE KASARAGOD AGRICULTURAL WELFARE CO-OPERATIVE
SOCIETY LTD. NO.S.415,
SREERAM ARCADE, ICB ROAD, KASARAGOD -671121,
REPRESENTED BY ITS SECRETARY SAJESH KUMAR K.V.
9 KUMBLA GENERAL WORKERS WELFARE CO-OPERATIVE SOCIETY
LTD. NO. S.426,
KUMBLA P.O., KASARAGOD-671321, REPRESENTED BY ITS
SECRETARY ANIL KUMAR T.
10 MALAYORA MEKHALA VANITHA CO-OPERATIVE SOCIETY LTD.
NO.S.363,
CHITTARIKKAL P.O., KASARAGOD-671326, REPRESENTED BY
ITS SECRETARY VIJANI E.P.
11 KASARAGOD DISTRICT CO-OPERATIVE HOSPITAL SOCIETY LTD.
NO.S.42,
KUMBLA P.O., KASARAGOD-671321, REPRESENTED BY ITS
SECRETARY RATHNAKARA G.
12 HOSDURG RANGE KALLU CHETHU THOZHILALI VYAVASALA
SAHAKARANA SANGHAM LTD. NO.S.310,
KUNNUMMAL, KANHANGAD P.O., KASARAGOD-671315,
REPRESENTED BY ITS SECRETARY USHA P.V.
13 THE PARAPPA VANITHA CO-OPERATIVE SOCIETY LTD.
NO.S.368,
PARAPPA P.O., KASARAGOD -671533, REPRESENTED BY ITS
SECRETARY SUJITHA P.
14 THE KOTACHERY CO-OPERATIVE MARKETING SOCIETY LTD.
NO.L.354,
KANHANGAD P.O., KASARAGOD -671315, REPRESENTED BY ITS
SECRETARY LATHA M.
15 KALPETTA ZONE LABOUR CONTRACT CO-OPERATIVE SOCIETY
LTD. NO.W.209,
KALPETTA P.O., WAYANAD-673121, REPRESENTED BY ITS
SECRETARY NITHIN SUNNY.
2025:KER
W.P(C)No.7053/2023 & Connected cases 363
16 THE WAYANAD DISTRICT POLICE CO-OPERATIVE SOCIETY LTD.
NO.W.208,
KALPETTA NORTH P.O., WAYANAD-673122, REPRESENTED BY
ITS SECRETARY RAJANI K.K.
17 VILAPPIL CO-OPERATIVE RURAL DEVELOPMENT SOCIETY LTD.
NO.T.1494,
PEYAD P.O., THIRUVANANTHAPURAM-695573, REPRESENTED BY
ITS SECRETARY BINDUMOL C.G.
18 KARAVARAM VILLAGE RESIDENCE WELFARE CO-OPERATIVE
SOCIETY LTD. NO.T.1940,
THOTTAKKAD, KARAVARAM P.O., THIRUVANANTHAPURAM-
695605, REPRESENTED BY ITS SECRETARY P.JAYESH.
19 CHEPPAD SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD.NO.A
1207,
KANJOOR, CHEPPAD P.O., ALAPPUZHA-690507, REPRESENTED
BY ITS SECRETARY V.GOPALAN NAIR.
20 ANGAMALY MERCANTILE CO-OPERATIVE SOCIETY LTD.
NO.E.1203,
ANGAMALY P.O., ERNAKULAM-683572, REPRESENTED BY ITS
SECRETARY REMYA P.R.
21 KOTHAMANGALAM TALUK MALSYA VYAPARA VITHARANA
THOZHILALY CO-OPERATIVE SOCIETY LTD.NO.E.1154,
KOTHAMANGALAM P.O., ERNAKULAM-686691, REPRESENTED BY
ITS SECRETARY ELDHOSE P.K.
22 KOTHAMANGALAM VYAPARI VYAVASAYI CO-OPERATIVE SOCIETY
LTD.NO.E.1240,
KOTHAMANGALAM, ERNAKULAM-686691, REPRESENTED BY ITS
SECRETARY CHANDRABOSE K.P.
23 KOTHAMANGALAM HOUSING CO-OPERATIVE SOCIETY LTD.
NO.E.314,
KOTHAMANGALAM P.O., ERNAKULAM-686691, REPRESENTED BY
ITS SECRETARY ELDHO JOSEPH.
24 VADATTUPARA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO.I.356,
VADATTUPARA P.O., ERNAKULAM-686694, REPRESENTED BY
ITS SECRETARY STELLA ANTONY.
2025:KER
W.P(C)No.7053/2023 & Connected cases 364
25 THE PALAKKAD TALUK CO-OPERATIVE EMPLOYEES' AND CO-
OPERATIVE PENSIONER'S CO-OPERATIVE HOUSING
SOCIETY LTD. NO.P.1435, PALAYAPPETTA, PALAKKAD-
678001, REPRESENTED BY ITS SECRETARY K.NITHYANANDAN.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 365
BY ADVS.
SHRI.SHYAMDEEP S.SHENOY, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 366
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11760 OF 2022
PETITIONER/S:
1 THALASSERY CO-OPERATIVE RURAL BANK LTD.,
NO.F. 1263, THALASSERY P.O, KANNUR - 670103,
REPRESENTED BY ITS MANAGER IN CHARGE C.M.
SANTHOSHKUMAR.
2 KOOTTUMUGHAM SERVICE CO-OPERATIVE BANK LTD NO. C. 72,
KOOTTUMUGHAM, SREEKANDAPURAM, KANNUR - 670631,
REPRESENTED BY ITS SECRETARY P P V PRADEEPAN,
3 KOLLAKKAD SERVICE CO-OPERATIVE BANK LTD,
NO. C.277, KOLAKKAD P.O, PERAVOOR, KANNUR - 670673,
REPRESENTED BY ITS SECRETARY LAJINA M.V.
4 KOLAYAD SERVICE CO-OPERATIVE BANK LTD, NO. F.1088,
KOLAYAD P.O, KANNUR - 670650, REPRESENTED BY ITS
SECRETARY, A.J. JESSY.
5 PERALAM SERVICE CO-OPERATIVE BANK LTD NO. L.L.63,
KOZHUMMAL P.O, KANNUR - 670522, REPRESENTED BY ITS
SECRETARY, KRISHNAN K.M.
6 THE NALLEPILLY SERVICE CO-OEPRATIVE BANK LTD NO.
R.43,
NALLEPILLY P.O, PALAKKAD - 678553, REPRESENTED BY ITS
SECRETARY SUMESH K.S.
7 ARAYOOR SERVICE CO-OPERATIVE BANK LTD,
NO. 692, NEYYATTINKARA, ARAYOOR P.O,
THIRUVANANTHAPURAM - 695122, REPRESENTED BY ITS
SECRETARY MARY VALSA P.
2025:KER
W.P(C)No.7053/2023 & Connected cases 367
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD,
KOCHI- 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB.NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695001.
BY ADVS.
SHRI.SHYAMDEEP S.SHENOY, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
2025:KER
W.P(C)No.7053/2023 & Connected cases 368
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 369
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11766 OF 2022
PETITIONER/S:
1 THE PATTAMBI GOVT EMPLOYEES CO OPERATIVE SOCIETY LTD.
NO.P.614,
PATTAMBI P.O., PALAKKAD-679303, REPRESENTED BY ITS
SECRETARY AJAYAKUMAR U.
2 PALAKKAD DISTRICT KERALA WATER AUTHRITY EMPLOYEES CO-
OPERATIVE SOCIETY LTD. NO.P.1095,
KALAMANDAPAM P.O., PALAKKAD-678001, REPRESENTED BY
ITS SECRETARY RAVINDRAN K.
3 THIRUVAZHIYAD-KAIRADY CO-OPERATIVE CREDIT SOCIETY
LTD. NO.P.508,
ADIPPERANDA, KAIRADY P.O., PALAKKAD-678510,
REPRESENTED BY ITS SECRETARY PRASAD C.G.
4 SREEKRISHNAPURAM BHAVAN NIRMANA SAHAKARANA SANGAM
LTD. NO.P.814,
CHANTHAPPURA P.O., SREEKRISHNAPURAM, PALAKKAD-679513,
REPRESENTED BY ITS SECRETARY MURALI MOHAN.
5 POSTAL, TELEGAM, BSNL EMPLOYEES CO-OPERATIVE SOCIETY
LTD. NO.1940,
THIRUVANANTHAPURAM, THIRUVANANTHAPURAM-695001,
REPRESENTED BY ITS SECRETARY SANDHYA RANI V.A.
6 THE PALAKKAD DISTRICT POSTAL, TELECOM AND BSNL
EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.P.638,
KARALA STREET, KOPPAM, PALAKKAD-678001.
7 VILAPPIL COMMERCIAL DEVELOPMENT CO-OPERATIVE SOCIETY
LTD. NO.T.1825,
2025:KER
W.P(C)No.7053/2023 & Connected cases 370
PULIYARAKONAM P.O., THIRUVANANTHAPURAM-695573,
REPRESENTED BY ITS SECRETARY AJITHA J.P.
8 VILAPPIL PANCHAYATH PRIMARY AGRICULTURAL CREDIT CO-
OPERATIVE SOCIETY LTD. NO.T.1624,
VILAPPILSALA P.O., THIRUVANANTHAPURAM-695573,
REPRESENTED BY ITS SECRETARY SURESH KUMAR S.
9 KUNNATHUNAD TALUK KARSHAKA KSHEMA ULPANNA VIPANANA
CO-OPERATIVE SOCIETY LTD. NO.E 1312,
VALAYANCHIRANAGAR P.O., PERUMBAVOOR, ERNAKULAM-
683556, REPRESENTED BY ITS SECRETARY M.P.ELDHO.
10 KATTAKADA AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD. NO.T 1543,
KATTAKADA P.O., THIRUVANANTHAPURAM-695572,
REPRESENTED BY ITS SECRETARY GAYATHRI G.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
2025:KER
W.P(C)No.7053/2023 & Connected cases 371
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADVS.
SHRI.SHYAMDEEP S.SHENOY, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 372
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11768 OF 2022
PETITIONER/S:
1 THE CHANGANASSERY PRIVATE SECONDARY SCHOOL STAFF CO-
OPERATIVE SOCIETY LTD NO K.411,
CHENGANASSERY, KOTTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
2 THE CHANGANASSERY TALUK VYAPARI VYAVASAI CO-OPERATIVE
SOCIETY LTD NO K 994,
CHENGANASSERY, KOTTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
3 THE PUZHAVATHU SERVICE CO-OPERATIVE BANK LTD NO 62,
PUZHAVTHY, CHENGANASSERY, KOTTAYAM DISTRICT,
REPRESENTED BY ITS SECRETARY.
4 THE CHANGANASSERY NORTH SERVICE CO-OPERATIVE BANK LTD
NO 3489,
CHENGANASSERY, KOTTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
5 THE MULAKULAM PANCHYATH SERVICE CO-OPERATIVE BANK LTD
NO K 209,
PERUVA, KOTTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
6 THE VELLOOR SERVICE CO-OPERATIVE BANK LTD NO 785,
VELLOOR P.O , KOTTTAYAM DISTRICT, REPRESENTED BY ITS
SECRETARY
BY ADV SRI.O.D.SIVADAS
2025:KER
W.P(C)No.7053/2023 & Connected cases 373
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN -682 018.
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX DEPARTMENT, KOTTAYAM, PIN-686 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 374
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11772 OF 2022
PETITIONER/S:
TVM DISTRICT I.T.I EMPLOYEES CO-OPERATIVE SOCIETY LTD
NO T 303, .
REPRESENTED BY ITS SECRETARY, CHACKAI,
THIRUVANANTHAPURAM DISTRICT, PIN-695 007
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE 111RD FLOOR, AAYAKAR BHAVAN, KOWDIAR
P.O.THIRUVANANTHAPURAM, PIN-695 003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO 143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT) MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI, PIN-110 001
3 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI PIN-110 001
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
2025:KER
W.P(C)No.7053/2023 & Connected cases 375
THIRUVANANTHAPURAM, PIN-695 001.
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN-695 001
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B NO
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN-695 033.
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 376
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11776 OF 2022
PETITIONER/S:
ANDOORKONAM SERVICE CO-OPERATIVE BANK LTD.NO.3127,
REPRESENTED BY ITS SECRETARY, KEEZHAVOOR P.O,
THIRUVANANTHAPURAM DISTRICT 695 584.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX,
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM , PIN 695 003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI , PIN 110
001.
3 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI , PIN 110 001
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
2025:KER
W.P(C)No.7053/2023 & Connected cases 377
THIRUVANANTHAPURAM , PIN 695 001.
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN 695 001
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO.
6515, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN 695 033.
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 378
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11780 OF 2022
PETITIONER/S:
PALLIPURAM KSHEEROLPADAKA CO-OPERATIVE SOCIETY LTD.
NO.E 36, CHERAI, ERNAKULAM - 683 514 REPRESENTED BY
ITS SECRETARY SRI.JEEMON LAZAR.
BY ADVS.
SHRI.AJI V.DEV
SRI.ALAN PRIYADARSHI DEV
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI - 682 018.
3 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI - 110 001 , REPRESENTED BY ITS CHAIRMAN.
4 THE KERALA STATE CO OPERATIVE BANK LTD.
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
2025:KER
W.P(C)No.7053/2023 & Connected cases 379
THIRUVANANTHAPURAM - 695 033.
BY ADVS.
SHRI.K.R.RAJKUMAR, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 380
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11781 OF 2022
PETITIONER/S:
1 THE KASARAGOD GENERAL WORKERS CO-OPERATIVE SOCIETY
LTD.NO. S. 59,
DINESH BHAVAN, NAYAKS ROAD, KASARGOD -671 121,
REPRESENTED BY ITS SECRETARY VARATHA RAJAN K.
2 RURAL AGRICULTURAL CO-OPERATIVE SOCIETY LTD. NO. 354,
KALIKADAVU P.O. PILICODE, KASARAGOD 671 310,
REPRESENTED BY ITS SECRETARY BABY P.K.
3 THE HOSDURG TALUK MERCHANTILE CO OPERATIVE SOCIETY
LTD. NOS. S. 286,
NILESHWAR P.O, KASARAGOD 671 314, REPRESENTED BY ITS
SECRETARY V.V. JANAKI
4 THE KUMBLA AGRICULTURAL TOURIST WELFARE CO-OPERATIVE
SOCIETY LTD. NO. S 389,
MADHAVA PAI COMPLEX, BADIADUKA ROAD, KUMBALA,
KASARAGOD 671 321, REPRESENTED BY ITS SECRETARY,
K.JAYAKUMAR.
5 THAYYAL THOZHILALI KSHEMA SAHAKARANA SANGAM LTD. NO.
S. 49,
KANHANGAD, KOVVALPALLY, KANHANGAD P.O, KASARGOD 671
315, REPRESENTED BY ITS SECRETARY SREEJA K.
6 THE UDMA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO. S 284,
UDMA P.O, UDMA, KASARAGOD 671 319, REPRESENTED BY ITS
SECRETARY KAIRALI B.
2025:KER
W.P(C)No.7053/2023 & Connected cases 381
7 CHERUVATHUR MERCHANTS WELFARE CO-OPERATIVE SOCIETY
LTD. NO. S. 343,
VYAPARA BHAVAN, CHERUVATHUR P.O, KASARAGOD 671 313,
REPRESENTED BY ITS SECRETARY KAIRALI M.K.
8 PANATHADY PANCHAYATH FARMERS WELFARE CO-OPERATIVE
SOCIETY LTD. NO. S 483,
PANATHUR P.O, KASARAGOD 671 532, REPRESENTED BY ITS
SECRETARY KAVITHA T.G.
9 THE KASARAGOD MERCANTILE CO-OPERATIVE SOCIETY LTD.
NO. S 287,
MALABAR SQUARE BUILDING, NEW BUS STAND, KASARAGOD 671
121, REPRESENTED BY ITS SECRETARY KUNHIRAMAN AC.
0 MALANAD RUBBER AND OTHER AGRICULTURAL MARKETING AND
PROCESSING CO-OPERATIVE SOCIETY LTD. NO. S 254,
MALAKKALLU P.O, KASARAGOD 671 532, REPRESENTED BY ITS
SECRETARY, SURESHKUMAR M.
11 MANJESHWAR BLOCK AGRICULTURAL IMPORVEMENT CO-
OPERATIVE SOCIETY LTD. NO. S 361,
UPPALA KAMAAL COMPLEX, R.S. ROAD, UPPALA P.O,
KASARAGOD 671 322, REPRESENTED BY ITS SECRETARY
RAGHAVAN B.
12 KUNDAMKUZHY VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO. S.404,
KUNDAMKUZHY P.O, CHENGALA VIA, KASARAGOD 671 541,
REPRESENTED BY ITS SECRETARY SMITHAMMA VIJAYAN.
13 THE CHERUVATHUR AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD. NO. S 406,
KUTTAMATH NAGAR, CHERUVATHUR P.O, KASARGOD 671 313,
REPRESENTED BY ITS SECRETARY BABU T
14 THE CHITTARIKKAL PRIMARY AGRICULTURIST WELFARE CO-
OPERATIVE SOCIETY LTD. NO. S. 381,
CHITTARIKKAL P.O, KASARGOD 671 326, REPRESENTED BY
ITS SECRETARY TO T.G. PRADEEP KUMAR.
15 THE WEST ELERI VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD. NO. S. 292,
ELERITHATTU P.O, KASARAGOD 671 314, REPRESENTED BY
2025:KER
W.P(C)No.7053/2023 & Connected cases 382
ITS SECRETARY, P.K. LATHA.
16 THE MADHUR AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY
LTD. NO. S. 398,
ULIYATHADKA P.O, MADHUR, KASARAGOD 671 124,
REPRESENTED BY ITS SECRETARY RAJASHREE M.B
17 KASARAGOD DISTRICT CONTRACTORS CO-OPERATIVE SOCIETY
LTD. NO. S 304,
JAZEEL CCENTRE, PUTHIYAKOTTA, HOSDURG, KANHANGAD,
KASARAGOD 671 315.
18 THE PALLIKERE CO-OPERATIVE CONSUMERS WELFARE SOCIETY
LTD.NO. L 485,
PALLIKERE P.O, KASARAGOD 671316, REPRESENTED BY ITS
SECRETARY INDIRA A.
19 KAYYOOR- CHEEMENI GRAMA PANCHAYATH,
VIVIDHODHESHA VANITHA SAHAKARANA SANGHAM LTD. S275,
CHEEMENI P.O, KASARAGOD- 671 313, REPRESENTED BY ITS
SECRETARY SATHI P.V.
20 THE BEEMANADY VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD. NO. S 321,
BEEANADI P.O, KASARAGOD 671 314, REPRESENTED BY ITS
SECRETARY JAINY THOMAS
21 KASARAGOD DISTRICT CONSTRUCTION WORKERS WELFARE CO-
OPERATIVE SOCIETY LTD NO. S 488,
NILESHWAR P.O, KASARGOD 671 314,REPRESENTED BY ITS
SECRETARY SUSHAMA K.V,
22 THE KASARAGOD DISTRICT CO-OPERATIVE EMPLOYEES WELFARE
CO-OPERATIVE SOCIETY LTD. NO. S. 411,
MELANGOT, KANHANGAD, KASARAGOD 671 315, REPRESENTED
BY ITS SECRETARY JAYAKALA K.
23 THE HOSDURG TALUK BUS OPERATOR'S CO-OPERATIVE SOCIETY
LTD. NO. S 371,
DILSHAD BUILDING, KANHANGAD P.O, KASARAGOD 671 315,
REPRESENTED BY ITS SECRETARY, SOUMYA N.
24 THE NILESWARAM PRAVASI KSHEMA SAHAKARANA SANGAM LTD.
NO. S 544,
2025:KER
W.P(C)No.7053/2023 & Connected cases 383
KOTTUMPURAM, NILESWAR P.O, KASARAGOD 671 314,
REPRESENTED BY ITS SECRETARY GEETHA K.
25 THE KANHANGAD AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD. NO. S. 382,
CHEDI ROAD, UPPILIKAI P.O, KASARAGOD 671 314,
REPRESENTED BY ITS SECRETARY, PRASANNAKUMARI P.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001.,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
P.B. NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001
2025:KER
W.P(C)No.7053/2023 & Connected cases 384
BY ADVS.
SHRI.PRAVEEN K.V., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 385
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11783 OF 2022
PETITIONER/S:
THE GENERAL INSURANCE EMPLOYEES CO-OPERATIVE SOCIETY
LTD.
NO.E 627, SITHRAM COMPLEX, 2ND FLOOR, CHITTOR ROAD,
ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK , RAISANA HILL, NEW DELHI -
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, SHAKTHAN NAGAR, THRISSUR, PIN
- 680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
5 THE MANAGER
KERALA STATE CO-OPERATIVE BANK LTD., ERNAKULAM SOUTH
BRANCH, PIN - 682 016.
2025:KER
W.P(C)No.7053/2023 & Connected cases 386
BY ADVS.
SHRI.T.V.VINU, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 387
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11915 OF 2022
PETITIONER/S:
1 MALLAPPALLY SERVICE CO-OPERATIVE BANK LTD.
KEEZHVAIPUR P.O.689 587 REPRESENTED BY ITS SECRETARY,
MADHULAL P.
2 KILIYANTHARA SERVICE CO OPERATIVE BANK LTD,
P.O.IRITTY, KANNUR-670 703, REPRESENTED BY ITS
SECRETARY, N ASHOKAN
3 KOLACHERI SERVICE C OPERATIVE BANK LTD,
P O CHELERI, KANANUR-670 604, REPRESENTED BY ITS
SECRETARY, BHASKARAN K
4 KANNAVAM SERVICE CO OPERATIVE BANK LTD,
KANNAVAM P.O.KANNOTH, KANNUR-670 650, REPRESENTED BY
ITS SECRETARY CHANDRAN KALATHIL
5 MAMALAKANDAM SERVICE CO OPERATIVE BANK LTD 1-225,
MAMALAKANDAM P.O.ERNAKULAM-686 681, REPRESENTED BY
ITS SECRETARY IN CHARGE JOMON K.J.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 388
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE ,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE , MINISTRY OF FINANCE
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 389
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11784 OF 2022
PETITIONER/S:
SPACE CENTRE EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.
T 1388
REPRESENTED BY ITS SECRETARY - IN - CHARGE, ISRO
POST, THIRUVANANTHAPURAM DISTRICT, PIN - 695022.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM - 695003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI - PIN -
110001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 390
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
THIRUVANANTHAPURAM - PIN - 695001.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM - PIN - 695001.
6 THE KERALA STATE CO-OPERATIVE BANK.
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO.
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM -
PIN - 695033.
BY ADVS.
SRI.NAVANEETH.N.NATH
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 391
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11791 OF 2022
PETITIONER/S:
1 THE CHENDAMANGALAM HANDLOOM WEAVER'S CO-OPERATIVE
SOCIETY LTD. NO. H 47
CHENDAMANGALAM, ERNAKULAM DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN - 683511.
2 THE CHERAI HANDLOOM WEAVERS CO-OPERATIVE SOCIETY
LIMITED NO. 648, CHERAI, ERNAKULAM DISTRICT,
REPRESENTED BY TIS SECRETARY, PIN - 683514.
3 THE CHENDAMANGALAM KARIMPADAM HANDLOOM WEAVER'S CO-
OPERATIVE SOCIETY LIMITED,
NO. H. 191, CHENDAMANGALAM, ERNAKULAM DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN - 683511.
4 THE CHENDAMANGALAM HANDLOOM WEAVERS' CO-OPERATIVE
YARN SOCIETY LIMITED NO. H.115,
CHENDAMANGALAM, ERNAKULAM DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN - 683511.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
2025:KER
W.P(C)No.7053/2023 & Connected cases 392
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN - 682018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, ERNAKULAM, PIN - 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033.
5 THE MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, NORTH PARUR MAIN
BRANCH, ERNAKULAM, PIN - 683513.
BY ADVS.
SHRI.T.V.VINU, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 393
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11792 OF 2022
PETITIONER/S:
1 THRITHALA BLOCK CO-OPERATIVE URBAN CREDIT
SOCIETY.LTD.NO.P.1206,
CHALISSERY P.O., PALAKKAD DISTRICT, PIN CODE-679 536,
REPRESENTED BY ITS SECRETARY, SMT. USHA.V.V.
2 TRITHALA EDUCATIONAL SUB DISTRICT AIDED SCHOOL-
EMPLOYEES CO OPERATIVE SOCIETY LTD. NO.P 1307,
KOOTTANAD P.O., PALAKKAD DISTRICT, PIN CODE-679 533,
REPRESENTED BY ITS SECRETARY, SMT.TUSHARA SANKAR.
3 ANAKKARA MERCANTILE CO OPERATIVE SOCIETY LTD.
NO.1365,
KUMBIDI P.O., PALAKKAD DISTRICT, PIN CODE-679 553,
REPRESENTED BY ITS SECRETARY, SHRI.SAJI.T.K.
4 OTTAPALAM TALUK PRAVASI WELFARE CO OPERATIVE SOCIETY
LTD. NO.P 1309,
MEZHATHUR P.O., PALAKKAD DISTRICT, PIN CODE-679 534,
REPRESENTED BY ITS SECRETARY, SMT.LUJINA.M.
5 VALLUVANAD UN ORGANIZED LABOURS WELFARE CO OPERATIVE
SOCIETY LTD. NO.P 1311,
KUMBIDI P.O., PALAKKAD DISTRICT, PIN CODE-679 553,
REPRESENTED BY ITS SECRETARY, SHRI.SASEEDHARAN.
6 PRIYADARSINI AGRICULTURAL IMPROVEMENT CO OPERATIVE
SOCIETY LTD. NO.P 1310,
ALOOR, P.O., PATTITHARA, PALAKKAD DISTRICT, PIN CODE-
679 534, REPRESENTED BY ITS SECRETARY,
SHRI,K.T.HARIDAS.
2025:KER
W.P(C)No.7053/2023 & Connected cases 394
7 MAHATMA MULTIPURPOSE CO OPERATIVE SOCIETY LTD. NO.P
1318,
KOOTTUPATHA, P.O.NELLIKKATTIRI, PALAKKAD DISTRICT,
PIN CODE-679 533, REPRESENTED BY ITS SECRETARY,
SHRI.ISMAYIL.M.P.
BY ADVS.
SHRI.A.KUMAR (SR.)
SHRI.P.J.ANILKUMAR
SMTG.MINI(1748)
SRI.P.S.SREE PRASAD
SHRI.JOB ABRAHAM
SHRI.AJAY V.ANAND
RESPONDENT/S:
1 THE UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX 9TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,
PIN-682 018.
4 THE KERALA STATE CO OPERATIFE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695
033, REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA STATE CO OPERATIVE BANK,
REGIONAL OFFICE, PB NO.21, HPO ROAD, SULTHANPET,
PALAKKAD-678 001, REPRESENTED BY ITS GENERAL MANAGER.
6 MANAGER,
THE KERALA STATE CO OPERATIVE BANK, PADINJARANGADI
BRANCH, PALAKKAD-679 552.
2025:KER
W.P(C)No.7053/2023 & Connected cases 395
7 MANAGER,
THE KERALA STATE CO OPERATIVE BANK, KOOTTANAD BRANCH,
PALAKKAD-679 5
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 396
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11810 OF 2022
PETITIONER/S:
1 THE MANJOOR SERVICE CO-OPERATIVE BANK LTD.NO.K 73,
KURUPPANTHARA, MANJOOR P.O.,KOTTAYAM DISTRICT-686
603, REPRESENTED BY ITS SECRETARY SIBY JOSE.
2 THE VAIKOM PALLIPPURATHUSSERY SERVICE CO OPERATIVE
BANK LTD.923,
KOTTAYAM DISTRICT-686 606, REPRESENTED BY ITS
SECRETARY SMT.SARASAMMA.P.
3 THE KAPPUMTHALA SERVICE CO-OPERATIVE BANK LTD.NO.K
142,
KAPPUMTHALA P.O., MUTTUCHIRA, KOTTAYAM-686 613,
REPRESENTED BY ITS SECRETARY, SMT.LISSYMOL GEORGE.
4 THE KEEZHOOR SERVICE CO OPERATIVE BANK LTD.NO.K 323,
KEEZHOOR P.O., KOTTAYAM DISTRICT-686 605, REPRESENTED
BY ITS SECRETARY, SMT.M.M.SOBHANA.
BY ADVS.
SHRI.A.KUMAR (SR.)
SHRI.P.J.ANILKUMAR
SMTG.MINI(1748)
SRI.P.S.SREE PRASAD
SHRI.JOB ABRAHAM
SHRI.AJAY V.ANAND
RESPONDENT/S:
2025:KER
W.P(C)No.7053/2023 & Connected cases 397
1 THE UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILLS, NEW
DELHI-110 001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,
PIN-682 018.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695
033, REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 398
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11848 OF 2022
PETITIONER/S:
THE KALAMASSERY URBAN CO-OPERATIVE SOCIETY LIMITED
NO.E-1096, HMT ROAD, KALAMASSERY, ERNAKULAM DISTRICT,
REPRESENTED BY ITS PRESIDENT PIN - 683 104.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I S PRESS ROAD, ERNAKULAM,
PIN - 682 018.
2 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, I.S.PRESS ROAD, ERNAKULAM, PIN
- 682 018.
3 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
4 THE MANAGER
KERALA STATE CO-OPERATIVE BANK LTD., KALAMASSERY
BRANCH, ERNAKULAM, PIN - 683 104.
BY ADVS.
SRI.NAVANEETH.N.NATH
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 399
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 400
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11851 OF 2022
PETITIONER/S:
1 THE SREE SANKARA COLLEGE EMPLOYEES CREDIT CO-
OPERATIVE SOCIETY LTD
NO.E 642, KALADY, ERNAKULAM DISTRICT, REPRESENTED BY
ITS SECRETARY,PIN-683 574
2 THE BANK EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.E 235,
ALUVA, ERNAKULAM DISTRICT, REPRESENTED BY ITS
SECRETARY, PIN-683 101
3 THE U.C COLLEGE EMPLOYEES CREDIT CO-OPERATIVE SOCIETY
LTD NO.E.855,
U.C.COLLEGE P.O., ALUVA, ERNAKULAM DISTRICT,
REPRESENTED BY ITS SECRETARY,PIN-683 101
4 THE AIDED SCHOOL TEACHERS CO-OPERATIVE SOCIETY LTD
NO.E 671,
HIGH ROAD, ALUVA, ERNAKULAM DISTRICT, REPRESENTED BY
ITS SECRETARY,PIN-683 101
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 001
2 THE COMMISSIONER OF INCOME TAX (TDS)
2025:KER
W.P(C)No.7053/2023 & Connected cases 401
CENTRAL REVENUE BUILDING, I.S PRESS ROAD,
ERNAKULAM,PIN682 018
3 THE INCOME TAX OFFICER ,(TDS),
INCOME TAX DEPARTMENT, ERNAKULAM,PIN-682 018
4 THE KERALA STATE CO-OPERATIVE BANK,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR,PIN-695 033
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 402
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11870 OF 2022
PETITIONER/S:
1 THE KUNNUKARA SERVICE CO-OPERATIVE BANK LTD.
NO.827, KUNNUKARA P.O., ERNAKULAM
DISTRICT,REPRESENTED BY ITS SECRETARY-686 604
2 THE MANJALY SERVICE CO-OPERATIVE BANK LTD NO.2266,
MANJALY PARUR P.O., ERNAKULAM DISTRICT,REPRESENTED BY
ITS SECRETARY--683 520
3 THE KARUMALLOOR SERVICE CO-OPERATIVE BANK LTD NO.R
737,
KADAYANICKADU, P.O.,KARUMALLOOR P.O., ERNAKULAM
DISTRICT,REPRESENTED BY ITS SECRETARY--683 511
4 THE PUTHENVELIKKARA SERVICE CO-OPERATIVE BANK LTD
NO.3445,
PUTHENVELIKKARA, ERNAKULAM DISTRICT, REPRESENTED BY
ITS SECRETARY-680 664
5 THE CHERUKADAPPURAM SERVICE CO-OPERATIVE BANK LTD
NO.2959,
CHERUKADAPPURAM, ERNAKULAM DISTRICT,REPRESENTED BY
ITS SECRETARY-683 594
6 THE KONGORPILLY FARMERS SERVICE CO-OPERATIVE BANK LTD
NO.3847,
KONGORPILLY, ERNAKULAM DISTRICT, REPRESENTED BY ITS
MANAGING DIRECTOR
7 THE NEERICODE SERVICE CO-OPERATIVE BANK LTD 1682,
ALANGAD, ALUVA, ERNAKULAM DISTRICT,REPRESENTED BY ITS
SECRETARY-683 518
2025:KER
W.P(C)No.7053/2023 & Connected cases 403
8 THE ELANTHIKARA VANITHA CO-OPERATIVE SOCIETY LIMITED
NO.1682,
ELANTHIKKARA, ERNAKULAM DISTRICT,REPRESENTED BY ITS
SECRETARY-683 594
9 THE PARAUR MAHILA SAHAKARANA SANGHAM LIMITED
NO.K.1259,
NORTH PARUR, ERNAKULAM DISTRICT,-686535, REPRESENTED
BY ITS SECRETARY
10 THE VELIYATHUNADU SERVICE CO-OPERATIVE BANK LTD E
298,
U.C COLLEGE P.O., ALUVA, ERNAKULAM
DISTRICT,REPRESENTED BY ITS SECRETARY-683 102
11 THE GOVERNMENT SERVANTS CO-OPERATIVE URBAN BANK LTD
NO.123,
NORTH PARUR, ERNAKULAM DISTRICT,REPRESENTED BY ITS
SECRETARY-683 102
12 THE THOZHILAY MULTI PURPOSE CO-OPERATIVE SOCIETY LTD
NO.4228,
NORTH PARUR, ERNAKULAM DISTRICT,REPRESENTED BY ITS
SECRETARY-683 102
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,
PIN-682 018
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX DEPARTMENT, IS PRESS ROAD, ERNAKULAM,PIN-
682 018
2025:KER
W.P(C)No.7053/2023 & Connected cases 404
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
COBANK TOWER, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033
BY ADV SHRI.T.V.VINU, CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 405
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11887 OF 2022
PETITIONER/S:
1 PALAKKUZHA SERVICE CO-OPERATIVE BANK LTD. NO. E-81
PALAKKUZHA PO, ERNAKULAM686662 REPRESENTED BY
SECRETARY BABU JOHN
2 KOOTHATTUKULAM FARMERS SERVICE CO-OPERATIVE BANK LTD.
NO. E 45
KOOTHATTUKULAM, ERNAKULAM-686662 REPRESENTED BY
MANAGING DIRECTOR ABHILASH NAMBOOTHIRI
3 THE ARAKKUZHA SERVICE CO OPERATIVE BANK LTD NO. 495,
ARAKKUZHA P О, ERNAKULAM686672 REPRESENTED BY
SECRETARY SIBY MATHEW
4 THE MUVATTUPUZHA AGRICULTURAL CO OPERATIVE BANK LTD
NO. HW 33
MARKET PO, MUVATTUPUZHA, ERNAKULAM-686669 REPRESENTED
BY SECRETARY KISHORE NM
5 THE KAKKOOR SERVICE CO OPERATIVE BANK LTD NO. 163
KAKKOORP.O, ERNAKULAM-686662 REPRESENTED BY SECRETARY
SREEDEVI ANDARJANAM T.S
6 PIRAVOM SERVICE CO OPERATIVE BANK LTD NO. E 83
PIRAVOM P.O, ERNAKULAM-686664 REPRESENTED BY
SECRETARY RANISH KUMAR K
7 THE ANICADU SERVICE CO OPERATIVE BANK LTD NO. 1550,
AVOLY PO, ANICADU, ERNAKULAM686668 REPRESENTED BY
SECRETARY IN CHARGE SINDHU PG. ERNAKULAM DISTRICT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 406
8 MARADY SERVICE COOPERATIVE BANK LTD NO. E 57
S.MARADY P.O, ERNAKULAM, PIN-26563.REPRESENTED BY
SECRETARY VASANTHI , ERNAKULAM DISTRICT.
9 PAIPRA SERVICE CO OPERATIVE BANK LTD NO. 679
MANARY PO, PIN 686673 REPRESENTED BY SECRETARY JEEVAN
B , ERNAKULAM DISTRICT.
10 THRIKKALATHOOR SERVICE CO OPERATIVE BANK LTD NO. 145,
THRIKKALATHOOR, PIN-683541 REPRESENTED BY SECRETARY
GOURY, ERNAKULAM DISTRICT.
11 HOUSING CO OPERATIVE SOCIETY LTD NO. E 728
KOOTHATTUKULAM, KOOTHATTUKULAM P.O, ERNAKULAM-686662
REPRESENTED BY SECRETARY VIJAYAN K N.
12 THE VAZHAKULAM SERVICE CO OPERATIVE BANK LTD NO. 751
VAZHAKULAM P.O, ERNAKULAM-686670 REPRESENTED BY
SECRETARY SHIJUMON VS
13 THE SERVICE CO OPERATIVE BANK LTD NO. 2824,
VAZHAKULAM P.O, ERNAKULAM-683513 REPRESENTED BY
SECRETARY ARUN E R.
14 PAMPAKUDA SERVICE CO OPERATIVE BANK LTD NO. 3520,
PAMPAKUDA P.O, ERNAKULAM 685661 REPRESENTED BY
SECRETARY RIBINA JOHN.
15 RAMAMANGALAM SERVICE CO OPERATIVE BANK LTD NO. 2156,
ERNAKULAM-680563, REPRESENTED BY SECRETARY JIBY
CHERIAN.
16 PIRAVOM RURAL CO OPERATIVE BANK LTD NO. 1802
,PIRAVOM P.O , PIN 686664 REPRESENTED BY SECRETARY
MINI SAJAN. ERNAKULAM DISTRAICT.
17 THE PIRAVOM RURAL COOPERATIVE HOUSING SOCIETY LTD.E
193,
PIRAVOM, PIN 686 664, REPRESENTED BY SECRETARY SALY
JOHN ERNAKULAM DISTRAICT.
18 THE MEKKADAMPU SERVICE CO OPERATIVE BANK LTD NO.
4073,
MEKKADAMPU P.O, PIN - 686664 REPRESENTED BY SECRETARY
2025:KER
W.P(C)No.7053/2023 & Connected cases 407
LIZY K P , ERNAKULAM DISTRAICT.
19 THE VALAKAM SERVICE COOPERATIVE BANK LTD NO. E 108,
KUNNACKAL, PIN 682316, REPRESENTED BY SECRETARY MARY
M.C , ERNAKULAM DISTRAICT.
20 THE MUVATTUPUZHA SERVICE CO OPERATIVE BANK LTD NO. E
781,
MUVATTUPUZHA P.O, REPRESENTED BY SECRETARY SUDHEER K.
ERNAKULAM DISTRAICT.
21 MULAKULAM SERVICE COOPERATIVE BANK LTD NO. 1097,
MULAKULAM NORTH P O,PIN-682318, REPRESENTED BY
SECRETARY BEENA KURUVILA. ERNAKULAM DISTRICT.
22 MUTHALAPURAM SERVICE CO OPERATIVE BANK LTD NO. 140,
MUTHALAPURAM, REPRESENTED BY SECRETARY LIBISHA U.S,
ERNAKULAM DISTRICT.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-11000.
2 THE COMMISSIONER OF INCOME TAX (TDS)
C.R BUILDING, I.S PRESS ROAD, KOCHI-682018
3 THE INCOME TAX OFFICER(TDS)
3RD FLOOR AAYAKAR BAHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PIN-686673 REPRESENTED BY GENERAL MANAGER (ERSTWHILE
THE ERNAKULAM DISTRICT CO-OPERTAIVE BANK), KAKKANAD
2025:KER
W.P(C)No.7053/2023 & Connected cases 408
P.O, KOCHI-632030 REPRESENTAO BU THE GENERAL
MANAGER).
5 MOVATTUPUZHA URBAN BANK LTD,
MOVATTUPUZHA P.O, THOTTUMKAL PIN-686 673 REPRESENTED
BY GENERAL MANAGER.
BY ADVS.
SHRI.JAGADEESH LAKSHMAN, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 409
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11884 OF 2022
PETITIONER/S:
THE PARAVUR S.N.V. REGIONAL CO-OPERATIVE BANK
LTD.NO.1685
S. PARAVUR PO, KOLLAM 691 301
BY ADVS.
SHRI.S.SANTHOSH KUMAR
SMT.BABY SUJATHA
RESPONDENT/S:
1 1. THE UNION OF INDIA REPRESENTED BY ITS SECRETARY
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI 110 001
2 2. THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE, MINISTRY OF FINANCE
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI 110 001 REPRESENTED
BY ITS CHAIRMAN
3 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD ERNAKULAM
682 018
4 4. THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS)
OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX
2025:KER
W.P(C)No.7053/2023 & Connected cases 410
3RD FLOOR, AAYAKAR BHAVAN, KOWADIAR
THIRUVANANTHAPURAM 695 003
5 THE INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM
3RD FLOOR, AAYAKAR BHAVAN KOWADIAR,
THIRUVANANTHAPURAM 695 003
6 THE KERALA STATE CO-OPERATIVE BANK LIMITED
PB NO 6515, COBANK TOWERS VIKAS BHAVAN PO, PALAYAM
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 THE KERALA STATE CO-OPERATIVE BANK LTD. PARAVUR
PARAVUR PO, KOLLAM 691 301 REPRESENTED BY ITS BRANCH
MANAGER
8 THE STATE OF KERALA REPRESENTED BY ITS PRINCIPAL
SECRETARY TO THE CO-OPERATIVE DEPARTMENT
SECRETARIAT, FORT P.O. THIRUVANANTHAPURAM 695 023
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 411
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 11939 OF 2022
PETITIONER/S:
1 CHITTUR RURAL CREDIT CO-OPERATIVE SOCIETY LTD.
NO.P 1240, ANICODE, CHITTUR P.O., PALAKKAD - 678101
REPRESENTED BY ITS SECRETARY IN CHARGE SHYNI S.V.
2 AJANUR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO.S 323, ATHINJAL P.O., MANIKOTH KANHANGAD, KASARGOD
- 671 315, REPRESENTED BY ITS SECRETARY SAVITHRI P.
3 PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD.
NO.S 372, KOVVALPALLI P.O., KANHANGAD, KASARAGOD -
671 315, REPRESENTED BY ITS SECRETARY USHA M.
4 PERLA RUBBER PRODUCERS SOCIETY
REG NO.432/99, P.O.PERLA, KASARAGOD - 671 552
REPRESENTED BY ITS SECRETARY M.PURUSHOTHAMA BHAT.
5 CHIRAYINKEEZHU TALUK AIDED SCHOOL EMPLOYEES CO-
OPERATIVE SOCIETY LTD.
NO.T 401, CHIRAYINKEEZHU - 695 304 REPRESENTED BY ITS
SECRETARY PRIYA S.S.
6 THE KUMBLA GENERAL WORKERS WELFARE CO-OPERATIVE
SOCIETY LTD.
NO.S 426, KUMBLA P.O., KASARAGOD - 671 321
REPRESENTED BY ITS SECRETARY ANIL KUMAR T.
7 THE PALAKKAD TALUK GOVT.EMPLOYEES CO-OPERATIVE
SOCIETY LTD.
NO.P 758, CIVIL STATION, PALAKKAD - 678 001
REPRESENTED BY ITS SECRETARY SOBHANA P.K.
2025:KER
W.P(C)No.7053/2023 & Connected cases 412
8 THE MANNARKKAD TALUK GOVT. EMPLOYEE'S CO-OP CREDIT
SOCIETY LTD.
NO.P.630, P.O.MANNARKKAD, PALAKKAD - 678 582,
REPRESENTED BY ITS SECRETARY UMA N.V.
9 KALLAYAM PRIYADARSINI RESIDENTS WELFARE CO-OPERATIVE
SOCIETY LTD.
NO.T 1115, KALLAYAM P.O., THIRUVANANTHAPURAM - 695
043 REPRESENTED BY ITS SECRETARY SAJI V.S.
10 CHITTARIKKAL VILLAGE VANITHA SERVICE CO-OPERATIVE
SOCIETY LTD.
NO.S 300, KAMBALLUR P.O., KASARAGOD - 670 511
REPRESENTED BY ITS SECRETARY BINDU K.
11 KANHIRAPUZHA CO-OPERATIVE URBAN CREDIT SOCIETY LTD.
NO.P 1172, CHIRAKKALPADI, THRIKALLUR P.O., PALAKKAD -
678 593 REPRESENTED BY ITS SECRETARY ABIN VARGHEES.
12 OTTAPPALAM CO-OPERATIVE HOUSING SOCIETY LTD.
NO.P 608, HOUSING SOCIETY BUILDING, RAILWAY STATION
ROAD, OTTAPPALAM, PALAKKAD - 679 101 REPRESENTED BY
ITS SECRETARY A.SIVADAS.
13 THE KERALA STATE ELECTRICITY BOARD EMPLOYEES CO-OP
SOCIETY LTD.
NO.P 671, PALAKKAD - 678 014 REPRESENTED BY ITS
SECRETARY IN CHARGE P.V.ALPHONSA.
14 THE KOTACHERY CO-OPERATIVE MARKETING SOCIETY LTD.
NO.L 354, P.O.KANHANGAD, KASARAGOD - 671 315
REPRESENTED BY ITS SECRETARY LATHA M.
15 ALANALLUR CO-OPERATIVE URBAN CREDIT SOCIETY LTD.
NO.P 1215, P.O.ALANALLUR, PALAKKAD - 678 601
REPRESENTED BY ITS SECRETARY BINESH O.V.
16 UZHAMALACKAL PANCHAYATH RURAL WELFARE CO-OPERATIVE
SOCIETY
T.1804, UTHUKULANGARA P.O., THIRUVANANTHAPURAM - 695
541 REPRESENTED BY ITS SECRETARY USHAKUMARI S.
17 UZHAMALACKAL HOUSING CO-OPERATIVE SOCIETY LTD.
NO.T 1215, CHARUMOODU, PUTHUKULANGARA P.O.,
2025:KER
W.P(C)No.7053/2023 & Connected cases 413
NEDUMANGAD - 695 541 REPRESENTED BY ITS SECRETARY
BUSHRA BEEVI.
18 VELLANADU BLOCK RESIDENCE WELFARE CO-OP SOCIETY LTD.
NO.T 156 4, ARYANAD P.O., THIRUVANANTHAPURAM - 695
542 REPRESENTED BY ITS SECRETARY JYOTHY S.
19 THIRUVANANTHAPURAM DISTRICT MARKETING AND PROCESSING
CO-OPERATIVE SOCIETY LTD.
NO.T 383, NEDUMANGAD P.O., THIRUVANANTHAPURAM - 695
541 REPRESENTED BY ITS MANAGING DIRECTOR SREEJA
KUMARI.
20 NEDUMANGAD TALUK LOCAL BODIES EMPLOYEES CO-OPERATIVE
SOCIETY LTD.
NO.T 767, NEDUMANGAD P.O., THIRUVANANTHAPURAM - 695
541 REPRESENTED BY ITS SECRETARY J.P.ANEESH.
21 NEDUMANGAD TALUK CO-OPERATIVE EMPLOYEE'S CO-OPERATIVE
SOCIETY LTD.
NO.T 382, NEDUMANGAD, THIRUVANANTHAPURAM - 695 541
REPRESENTED BY SECRETARY J.JAYAKUMAR.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
2025:KER
W.P(C)No.7053/2023 & Connected cases 414
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
, NEW DELHI - 110 001 REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695
001.
BY ADV SHRI.M.SASINDRAN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 415
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12054 OF 2022
PETITIONER/S:
THE ERNAKULAM URBAN CO-OPERATIVE SOCIETY LTD.NO.7
HEAD OFFICE, RAVIPURAM, KOCHI - 682 016 REPRESENTED
BY ITS SECRETARY.
BY ADV SHRI.M.SHYJU
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI, ERNAKULAM - 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LIMITED
P.B.NO.6515, CO BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
2025:KER
W.P(C)No.7053/2023 & Connected cases 416
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001.
BY ADVS.
SHRI.T.V.VINU, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 417
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12057 OF 2022
PETITIONER/S:
THIRUVITHAMCORE CO-OPERATIVE SOCIETY LTD.NO.T.1530
SAHAKARANA BHAVAN, T.C.28/1289, THAKARAPARAMBU ROAD,
SREEKANDAESWARAM, THIRUVANANTHAPURAM - 695 023
REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.B.S.SWATHI KUMAR
SMT.ANITHA RAVINDRAN
SRI.HARISANKAR N UNNI
SHRI.SARANGADHARAN P.
SMT.N.S.SHAMILA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110
001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
2025:KER
W.P(C)No.7053/2023 & Connected cases 418
KOCHI - 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM - 695 003.
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM - 695 003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS
EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695
001.
BY ADVS.
SRI.R.PREM SANKAR
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 419
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12065 OF 2022
PETITIONER/S:
1 KOWDIAR CO-OPERATIVE SOCIETY LTD NO.T 2034,
VEENA TOWERS, TC 4/242, AMBALAMUKKU, KOWDIAR P.O.,
THIRUVANANTHAPURAM, PIN-695 003, REPRESENTED BY ITS
PRESIDENT.
2 THIRUVANANTHAPURAM ICE CREAM DISTRIBUTORS AND SELLERS
CO OPERATIVE SOCIETY LTD. NO.T 1903,
ENCHACKAL JUNCTION, THIRUVANANTHAPURAM, REPRESENTED
BY ITS PRESIDENT.
BY ADVS.
SRI.B.S.SWATHI KUMAR
SMT.ANITHA RAVINDRAN
SRI.HARISANKAR N UNNI
SHRI.SARANGADHARAN P.
SMT.N.S.SHAMILA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
2025:KER
W.P(C)No.7053/2023 & Connected cases 420
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIOENR OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM-695 003.
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKARA BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM-695 003.
6 THE KERALA STATE CO OPERATIVE BANK LTD.,
PB NO.6515, CO BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY, (CO OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
BY ADVS.
SHRI.K.K.SETHUKUMAR, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 421
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12061 OF 2022
PETITIONER/S:
KOCHIN COPERATIVE SOCIETY LTD NO. E-100
AGED 47 YEARS
LALAN ROAD , PALACE ROAD,MATTACHERRY KOCHI
REPRESENTED BY ITS SECRETARY JAMES K.F, PIN - 682002
BY ADVS.
SHRI.ARUN V.G. (K/795/2004)
SMT.V.JAYA RAGI
SHRI.R.HARIKRISHNAN (KAMBISSERIL)
SRI.NEERAJ NARAYAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI REPRESENTED BY ITS
CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI, PIN - 682018
2025:KER
W.P(C)No.7053/2023 & Connected cases 422
4 THE KERALA STATE CO-OPERATIVE BANK LTD
PALAYAM, THIRUVANANTHAPURAM REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
5 THE KERALA STATE CO-OPERATIVE BANK LTD
KOCHI, MATTACHERRY, PALACE ROAD , KOCHI REPRESENTED
BY ITS MAMANGER, PIN - 682002
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN - 682031
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 423
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12076 OF 2022
PETITIONER/S:
CHEMPAZHANTHY AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD. NO. T.1750
CHEMPAZHANTHY P.O, THIRUVANANTHAPURAM DISTRICT,
REPRESENTED BY THE SECRETARY IN CHARGE.
BY ADVS.
SRI.GEORGE POONTHOTTAM (SR.)
SMT.NISHA GEORGE
SHRI.ANSHIN K.K
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM, PIN - 695003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI - PIN -
110001.
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 424
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
D.P.I, JUNCTION, JAWAHAR SAHAKARANA BHAVAN,
THIRUVANANTHAPURAM - 695014.
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO.
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM -
PIN - 695033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 425
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12075 OF 2022
PETITIONER/S:
ATTINGAL EDUCATIONAL DISTRICT GOVT. SCHOOL TEACHERS
CO-OPERATIVE SOCIETY LTD.NO.T 312
REPRESENTED BY ITS SECRETARY, PALACE ROAD, ATTINGAL
P.O, THIRUVANANTHAPURAM DISTRICT - PIN - 695101.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM, PIN - 695003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI - PIN -
110001.
3 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 426
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
THIRUVANANTHAPURAM - PIN - 695001.
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001.
6 THE KERALA STATE CO-OPERATIVE BANK.
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO.
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM -
PIN - 695033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 427
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12082 OF 2022
PETITIONER/S:
RAILWAYMEN'S HOUSE BUILDING CO-OPERATIVE SOCIETY LTD
NO.E-738
REPRESENTED BY ITS ASST. REGISTRAR/ SECRETARY,
RAILWAY BUILDING NO. 77/A, ERNAKULAM , PIN 682 005.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE INCOME TAX OFFICER (TDS)
X
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPREESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E,
NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI , PIN 110
001.
3 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI , PIN 110 001.
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
THIRUVANANTHAPURAM, PIN 695 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 428
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN 695 001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO.
6515, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN 695 033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.SHYAMDEEP S.SHENOY, CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 429
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12086 OF 2022
PETITIONER/S:
THE AVOLI MULTI PURPOSE CO-OPERATIVE SOCIETY LTD .E-
1397
REPRESENTED BY ITS HON. SECRETARY, M.V. KURUVILLA,
AGED 74 YEARS, HEAD OFFICE, ADOOPARAMPU, MUVATTUPUZHA
- 686 661.
BY ADVS.
SRI.GEORGE MATHEW
SRI.M.D.SASIKUMARAN
SHRI.PRAVEEN S.
SHRI.SUNIL KUMAR A.G
SRI.DIPU JAMES
SHRI.MATHEW K.T.
SHRI.GEORGE K.V.
SHRI.STEPHY K REGI
SMT.ELSA DENNY PINDIS
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 002.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDINGS I.S. PRESS ROAD, KOCHI -
682 018.
2025:KER
W.P(C)No.7053/2023 & Connected cases 430
3 THE INCOME TAX OFFICER,
TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY - 8,
THODUPUZHA, IDUKKI DISTRICT - 685 584. -
4 STATE OF KERALA
REP. BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT
SECRETARIAT, THIRUVANANTHAPURAM - 695 001.
5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM - 695 014.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(KERALA BANK) REP. BY ITS MANAGING DIRECTOR & CHIEF
EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033.
7 THE DEPUTY GENERAL MANAGER,
CENTRAL PROCESSING CENTER, THE KERALA STATE CO-
OPERATIVE BANK LTD., (KERALA BANK), REGIONAL OFFICE,
KAKKANAD, ERNAKULAM, KOCHI - 682 030.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 431
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12100 OF 2022
PETITIONER/S:
KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION
DISTRICT COMMITTEE, THIRUVANANTHAPURAM, OFFICE AT
BALARAMAPURAM SERVICE CO-OPERATIVE BANK LTD T/14,
BALARAMAPURAM- THIRUVANANTHAPURAM-695 501,
REPRESENTED BY ITS SECRETARY, PRATHAPACHANDRAN.A
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
2025:KER
W.P(C)No.7053/2023 & Connected cases 432
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALKA
THIRUVANANTHAPURAM-695 001
BY ADV SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 433
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12102 OF 2022
PETITIONER/S:
1 NEDIYANGA SERVICE CO-OPERATIVE BANK LTD
NO.L.L.84, H.O.CHENPANTHOTTY P.O., KANNUR-670 631,
REPRESENTED BY ITS SECRETARY, KRISHNANKUTTY K.P.
2 ARALAM SERVICE CO-OPERATIVE BANK LTD,NO.F.1515,
H.O.KEEZHPALLY, KEEZHPALLY, KANNUR -670 704,
REPRESENTED BY ITS SECRETARY BABU.T.J
3 ERUVESSY SERVICE CO-OPERATIVE BANK LTD NO.C 171,
P.O.CHEMPERI, KANNUR-670 632, REPRESENTED BY ITS
SECRETARY NIZAR.N.
4 PERUMPUZHA GRAMODHARANA SERVICE CO-OPERATIVE BANK
LTD,NO.2533,
PERUMPUZHA P.O., KOLLAM-691 504, REPRESENTED B ITS
SECRETARY S MANIKANDAN PILLAI
5 POOKKOTTUKAVU PANCHAYATH SERVICE CO-OPERATIVE BANK
LTD NO. P 1101
POOKKOTTUKAVU, KADAMUR P.O., PALAKKAD-679 515,
REPRESENTED BY ITS SECRETARY P.G.KRISHNA PRASAD
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 434
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001
BY ADVS.
SHRI.SHYAMDEEP S.SHENOY, CGC
SHRI.M.SASINDRAN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 435
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12105 OF 2022
PETITIONER/S:
THE FEDO EMPLOYEES CO-OPERATIVE SOCIETY LIMITED
LIMITED NO.E 679, UDYOGAMANDAL P.O., ERNAKULAM
DISTRICT - 683 501, REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, I.S.PRESS ROAD, ERNAKULAM,
PIN- 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
5 THE MANAGER
KERALA STATE CO-OPERATIVE BANK LTD., KALAMASSERY,
ERNAKULAM, PIN - 683 104.
2025:KER
W.P(C)No.7053/2023 & Connected cases 436
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 437
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12110 OF 2022
PETITIONER/S:
1 KASARAGOD DISTRICT INSURANCE AGENT'S CO-OPERATIVE
SOCIETY LTD
NO.S 401, KANHANGAD, NEAR KOTTACHERY BUS STAND,
KANHANGAD, KASARGOD -671 315, REPRESENTED BY ITS
SECRETARY LATHIKA.V.
2 UDMA PANCHAYATH VANITHA SERVICE SAHAKARANA SANGAM LTD
NO.S.492,
USMA P.O., KASARAGOD-671 319, REPRESENTED BY ITS
SECRETARY SUKUMARI.K.
3 HOSDURG TALUK MOTOR WORKERS CO-OPERATIVE SOCIETY LTD
NO.S 28,
LAKSHMI NAGAR, KANHANAGAD P.O.,KASARAGOD-671315,
REPRESENTED BY ITS SECRETARY BEENA.K.
4 PALLIKERE VANITHA SERVICE CO-OPERATIVE SOCIETY
NOT.S.433,
PALLIKKERE P.O., BEKAL FORT, KASARAGOD-671 316,
REPRESENTED BY ITS SECRETARY BINDU.P.
5 KUTTIKOL AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY
LTD NO.S 383,
KUTTIKOL P.O., KASARGOD-672 541, REPRESENTED BY ITS
SECRETARY CHATHUKUTTY NAIR
6 KASARGOD RUBBER FARMERS WELFARE CO-OPERATIVE SOCIETY
LTD NO.S 429,
KUTTIKOL, KASARGOD-671 541, REPRESENTED BY ITS
SECRETARY SHOBHA .K.
2025:KER
W.P(C)No.7053/2023 & Connected cases 438
7 BANDADKA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD
NO.S 350,
BANDADKA P.O., CHENGALA (VIA) ,KASARAGOD-671 541,
REPRESENTED BY ITS SECRETARY BABY.K.
8 PILICODE PANCHAYATH VANITHA SERVICE CO-OPERATIVE
SOCIETY LTD NO.S 251,
KALIKADAVU, PILICODE P.O.,KASARAGOD-671 353,
REPRESENTED BY ITS SECRETARY SUSHAMA.P.V.
9 NILESHWAR RURAL CO-OPERATIVE HOUSING SOCIETY LTD
NO.F.F. 103,
NILESHWAR, KASARAGOD-671 314, REPRESENTED BY ITS
SECRETARY, UNNIKRISHNAN.K.M.
10 UDMA KARSHAKA KSHEMA SAHAKARANA SANGHAM LTD NO.S.376,
PALAKUNNU, BEKAL P.O.,KASARGOD-671 318, REPRESENTED
BY ITS SECRETARY K.KRISHNAN
11 KASARGOD DISTRICT P.N.PANICKER SOCIAL WORKERS WELFARE
CO-OPERATIVE SOCIETY LTD NO.S.338 (KASCO),
KANHANGAD P.O., KASARAGOD -671 315, REPRESENTED BY
ITS SECRETARY AMBIKA .V.
12 BEDADKA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO.S
348,
KANHIRATHINGAL, BEDADKA P.O., KASARAGOD-671 541,
REPRESENTED BY ITS SECRETARY SUDHEESH KUMAR.A
13 HOSDURG HOUSING CO-OPERATIVE SOCIETY LTD NO.F F 16,
KANHANGAD.P.O., KASARAGOD-671 315, REPRESENTED BY ITS
SECRETARY, ANILKUMAR.H.J.
14 THALASSERY AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD NO.C 1619,
BABNEESH ARCADE, LOGANS ROAD, THALASSERY, KANNUR-670
649, REPERESENTED BY ITS SECRETARY SATHEESH.M.
15 KOTTARAKKARA TALUK HOUSING CO-OPERATIVE SOCIETY LTD
NO.Q 451,
KOTTARAKARA P.O., KOLLAM-691 506, REPRESENTED BY ITS
SECRETARY G.GOPIKRISHNA
2025:KER
W.P(C)No.7053/2023 & Connected cases 439
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDING, IS PRESS ROAD,KOCHI-
682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATIN) GOVERNMENT
SECRETARIAT, THIRUVANANTHAPURAM-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 440
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 441
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12123 OF 2022
PETITIONER/S:
ITI STAFF CO-OPERATIVE CREDIT SOCIETY LTD NO. E 730,
KALAMASSERY, HMT COLONY P.O, ERNAKULAM DISTRICT, PIN
683 503, REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.M.M.MONAYE
SHRI.M.PAUL VARGHESE
SRI.K.V.SANOSH
SMT.NIRMALA P.V.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI , PIN 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE,
(CBDT) , MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI 110 001.
3 COMMISSIONER OF INCOME TAX (TDS),
C.R. BUILDINGS, I.S. PRESS ROAD, ERNAKULAM, 682 018.
4 STATE OF KERALA,
DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT,
2025:KER
W.P(C)No.7053/2023 & Connected cases 442
REPRESENTED BY SECRETARY TO GOVERNMENT,
THIRUVANANTHAPURAM- 695 001
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR FO CO-OPERATIVE SOCIETIES,
STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM- 695 001.
6 THE KERALA STATE CO-OPERATIVE BANK LTD. ,
CO- BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, THIRUVANANTHAPURAM- 695 033.
7 DEPUTY GENERAL MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD. CREDIT PROCESSING
CENTRE, KAKKANAD, KOCHI 682 030.
BY ADVS.
SHRI.NAVANEETH.N.NATH, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 443
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12124 OF 2022
PETITIONER/S:
THE SAMSKRUTHA SARVAKALASALA CO-OPERATIVE SOCIETY LTD
E.1180
KALADY, ERNAKULAM DISTRICT, REPRESENTED BY ITS
SECRETARY, PIN 683 574.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN 682 018.
3 THE INCOME TAX OFFICER, (TDS),
INCOME TAX DEPARTMENT, ERNAKULAM, PIN 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033.
5 THE BRANCH MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., KALADY BRANCH,
ERNAKULAM DISTRICT, PIN 683 574.
2025:KER
W.P(C)No.7053/2023 & Connected cases 444
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 445
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12126 OF 2022
PETITIONER/S:
1 THE VALLICODE SERVICE CO-OPERATIVE BANK LIMITED
NO.61,
VALLICODE, PATHANAMTHITTA DISTRICT-686 648,
REPRESENTED BY ITS SECRETARY.
2 THE MEZHUVELIL SERVICE CO OPERATIVE BANK LIMITED
NO.2570,
ULLANNOOR, PATHANAMTHITTA DISTRICT-689 645,
REPRESENTED BY ITS SECRETARY.
3 THE PRAKKANAM SERVICE CO OPERATIVE BANK LIMITED
NO.677,
PRAKKANAM P.O., PATHANAMTHITTA DISTRICT-689 643,
REPRESENTED BY ITS SECRETARY.
4 THE KUMBAZHA SERVICE CO OPERATIVE BANK LIMITED
NO.1373,
MYLAPRA, PATHANAMTHITTA DISTRICT-689 647, REPRESENTED
BY ITS SECRETARY.
5 THE THANNITHODE SERVICE CO OPERATIVE BANK LIMITED
NO.Q 364,
THANNITHODE, PATHANAMTHITTA DISTRICT-689 699,
REPRESENTED BY ITS SECRETARY.
6 THE KADAMMANITTA SERVICE CO OPERATIVE BANK LIMITED
NO.PT 44,
KADAMMANITTA P.O., PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN-689 644.
7 THE MEKKOZHOOR SERVICE CO-OPERATIVE BANK LIMITED
2025:KER
W.P(C)No.7053/2023 & Connected cases 446
NO.1191,
MEKKOZHOOR, PATHANAMTHITTA DISTRICT-689 643,
REPRESENTED BY ITS SECRETARY.
8 THE CHENNERKARA SERVICE CO OPERATIVE BANK LIMITED
NO.96,
CHENNEERKARA, PATHANAMTHITTA DISTRICT-689 503,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110
001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,
PIN-682 018.
3 THE INCOME TAX OFFICER (TDS),
AARATTUKULAKKARA COMPLEX, AN PURAM, ALAPUZHA
DISTSRICT-686 011.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033.
5 THE DEPUTY GENERAL MANAGER,
KERALA STATE CO OPERATIVE BANK LTD., PATHANAMTHITTA
DISTRICT OFFICE, PATHANAMTHITTA, PIN-686645.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 447
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12145 OF 2022
PETITIONER/S:
1 PALAKKAD MUNICIPAL SAHAKARANA URBAN CREDIT SOCIETY
LTD.
NO.P 1306, PAPACHAN COMPLEX, KANNARA STREET, ROBINSON
ROAD, PALAKKAD-678 001, REPRESENTED BY ITS SECRETARY,
SHRI. KUPPELAN .S.
2 PALAKKAD TALUK HEADLOAD WORKERS CO-OPERATIVE SOCIETY
LTD, NO.P.1337,
DANCE MARKET BUILDING, MARKET ROAD, PALAKKAD-678 014,
REPRESENTED BY ITS SECRETARY ,SMT.MINI BABU
3 PALAKKAD TALUK BUILDING & ROAD WORKERS CO-OPERATIVE
SOCIETY LTD NO.P1315,
RAJEEV BHAVAN, PENSION STREET, PALAKKAD-678 001,
REPRESENTED BY ITS SECRETARY, SHRI. SUDEVAN .K.K.
4 INDIRA GANDHI MULTI PURPOSE CO-OPERATIVE SOCIETY LTD
NO.P 1330,
PANCHAYATH SHOPPING COMPLEX, KALLEPULLY P.O.,
PALAKKAD-678 005, REPRESENTED B ITS SECRETARY, SHRI.
VISHNUDAS .R.
5 PALAKKAD TALUK AIDED SCHOOL EMPLOYEES CO-OPERATIVE
SOCIETY LTD NO.P 782,
NEAR KSRTS LIN ROAD, PALAKAD-678 004, REPRESENTED BY
ITS SECRETARY, SMT. LATHA.T.
6 THE PALAKKAD DISTRICT EMPLOYEES CO-OPERATIVE SOCIETY
LTD NO.P.1184
CIVIL STATION, PALAKKAD-678 001, REPRESENTED BY ITS
SECRETARY, SHRI. BABU.B.S.
2025:KER
W.P(C)No.7053/2023 & Connected cases 448
7 THE ELAPPULLY RURAL CO-OPERATIVE SOCIETY LTD NO.P
1383,
CHEERMBAKKAVU, VIJAYAPUSHPAM COMPLEX, ELAPPULLY P.O.,
PALAKKAD-678 622, REPRESENTED BY ITS PRESIDENT,
SUNILKUMAR.S
BY ADVS.
SHRI.A.KUMAR (SR.)
SHRI.P.J.ANILKUMAR
SMTG.MINI(1748)
SRI.P.S.SREE PRASAD
SHRI.JOB ABRAHAM
SHRI.AJAY V.ANAND
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK RAISANA HILL, NEW DELHI-110
001
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW
DELHI-110 001, REPRESENTED BY SECRETARY
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD,
ERNAKULAM,PIN-682 018
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,PIN-695
033, REPRESENTED BY ITS MANAGING DIRECTOR
5 THE KERALA STATE CO-OPERATIVE BANK,
REGIONAL OFFICE, P.B.NO.21, H.P.O ROAD, SULTHANPET,
PALAKKAD-678 001
6 SENIOR MANAGER,
THE KERALA STATE CO-OPERATIVE BANK ,PALAKKAD MAIN
BRANCH, PALAKKAD-679 552
2025:KER
W.P(C)No.7053/2023 & Connected cases 449
7 MANAGER,
THE KERALA STATE CO-OPERATIVE BANK, KALLEPULLY
BRANCH, PALAKKAD-678 005
8 MANAGER,
THE KERALA STATE CO-OPERATIVE BANK, MELAMURI BRANCH,
PALAKKAD-678 006
BY ADVS.
SHRI.VISHNU RAJAGOPAL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 450
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12257 OF 2022
PETITIONER/S:
1 THIRUVANANTHAPURAM TALUK CO-OPERATIVE EMPLOYEES CO-
OPERATIVE SOCIETY LTD
NO.T 846, KUTTIKKAD JUNCTION, MANACAUD P.O,
THIRUVANANTHAPURAM DISTRICT, KERALA, PIN 695 009,
REPRESENTED BY ITS SECRETARY.
2 HEALTH SERVICE STAFF CO-OPERATIVE SOCIETY LTD., NO. T
431,
HEAD OFFICE, GENERAL HOSPITAL, VANCHIYOOR P.O,
THIRUVANANTHAPURAM, DISTRICT, KERALA, PIN 695 035,
REPRESENTED BY ITS SECRETARY.
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 00
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018.
3 THE INCOME TAX OFFICER (TDS),
2025:KER
W.P(C)No.7053/2023 & Connected cases 451
3RD FLOOR AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(ERSTWHILE THIRUVANANTHAPURAM SERVICE CO-OPERATIVE
BANK), EAST FORT, THIRUVANANTHAPURAM-695 023,
REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 452
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12263 OF 2022
PETITIONER/S:
KADUNGALLOR SERVICE CO-OPERATIVE BANK LTD. NO.863
REPRESENTED BY ITS SECRETARY, WEST KADUNGALLOOR
P.O.ALUVA-683 110
BY ADVS.
SRI.JOJU KYNADY
SRI.A.ABDUL NABEEL
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, 11RD FLOOR, AAYAKAR BHAVAN, KOWDIAR
P.O.THIRUVANANTHAPURAM, PIN-695 003.
2 THE CENTRAL BOARD OF DIRECTOR TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO 143, E NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT/ MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI-PIN-110 001
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE , NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI, PIN-110 001
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
THIRUVANANTHAPURAM, PIN-695 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 453
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN-695 001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P B NO
6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
PIN-695 033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 454
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12351 OF 2022
PETITIONER/S:
1 THE GOVERNMENT SERVANT'S CO-OPERATIVE BANK LIMITED,
NO. Q 169, KULANADA, PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY 689 503.
2 THE PARIYARAM SERVICE CO - OPERATIVE BANK LIMITTED
NO. Q 391.
PARIYARAM, PATHANAMTHITTA DISTRICT 689 653,
REPRESENTED BY ITS SECRETARY.
3 THE PATHANAMTHITTA POLICE DEPARTMENT EMPLOYEES
CO OPERATIVE SOCIETY LIMITED NO. PT 103,
PATHANAMTHITTA 689 643. PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY.
4 THE KUMBAZHA SERVICE CO OPERATIVE BANK LIMITED, NO.
330,
KUMBAZHA, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL NEW DELHI
11001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
2025:KER
W.P(C)No.7053/2023 & Connected cases 455
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM
682 018.
3 THE INCOME TAX OFFICER, (TDS),
AARATTUKULAKKARA COMPLEX, A.N. PURAM ALAPPUZHA
DISTRICT 686 011.
4 THE KERALA STATE CO OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, 695 033.
5 THE DEPUTY GENERAL MANAGER,
KERALA STATE CO OPERATIVE BANK LTD, PATHANAMTHITTA
DISTRICT OFFICE, PATHANAMTHITTA 689 645.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 456
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12428 OF 2022
PETITIONER/S:
VENGANOOR CO-OPERATIVE RURAL DEVELOPMENT SOCIETY LTD
NO.T-1497
VENGANOOR, VENGANOOR P O, THIRUVANANTHAPURAM, PIN-
695521, REPRESENTED BY ITS SECRETARY, T RAMESH.
BY ADVS.
SRI.D.SAJEEV
SMT.LIGEY ANTONY
RESPONDENT/S:
1 UNION OF INDIA
MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI, 110 001.
REPRESENTED BY ITS SECRETARY.
2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
C.R.BUILDING, I.S. PRESS ROAD, KOCHI, ERNAKULAM. PIN.
682 018.
3 THE ASSISTANT COMMISSIONER OF INCOME TAX
(TDS) 3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O.,
THIRUVANANTHAPURAM. PIN. 695 003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
EAST FORT, THIRUVANANTHAPURAM. PIN. 695 023.
REPRESENTED BY ITS MANAGING DIRECTOR.
2025:KER
W.P(C)No.7053/2023 & Connected cases 457
5 THE BRANCH MANAGER
THE KERALA STATE CO-OPERATIVE BANK LTD., PERIGAMMALA
BRANCH, THIRUVANANTHAPURAM. PIN. 695042,
6 THE BRANCH MANAGER
THE KERALA STATE CO-OPERATIVE BANK LTD., VIZHINJAM
BRANCH, THIRUVANANTHAPURAM. PIN. 695521.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 458
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14068 OF 2022
PETITIONER/S:
1 THE K.P.B. EMPLOYEES CO-OPERATIVE SOCIETY LTD.
NO E 770, KAKKANAD P.O, ERNAKULAM DISTRICT,
REPRESENTED BY ITS PRESIDENT, PIN 682 030
2 THE ERNAKULAM GOVERNMENT EMPLOYEES HOUSE CONSTRUCTION
CO-OPERATIVE SOCIETY LTD NO E 1124, ALUVA, KARSHIKA
BANK BUILDING, ERNAKULAM DISTRICT, REPRESENTED BY ITS
SECRETARY, PIN - 683001.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
INCOME TAX DEPARTMENT, ERNAKULAM, PIN - 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
2025:KER
W.P(C)No.7053/2023 & Connected cases 459
BY ADVS.
SHRI.PRAVEEN K.V., CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 460
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12504 OF 2022
PETITIONER/S:
MEENACHIL TALUK HIGHER SECONDARY TEACHER'S CO-
OPERATIVE SOCIETY LTD.
NO.K 1179, CHERUPUSHPAN BUILDING, OLD PVT BUS STAND,
PALA, KERALA - 686 575, REP. BY ITS HONORARY
SECRETARY BAIBY THOMAS.
BY ADVS.
SHRI.BABY THOMAS
SHRI.GEORGE T.J
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI - 682 018.
3 INCOME TAX OFFICER (TDS)
INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI
ROAD, KOTTAYAM - 686 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD. (KERALA BANK)
2025:KER
W.P(C)No.7053/2023 & Connected cases 461
CO BANK TOWERS VIKAS BHAVAN, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REP. BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
SMT.MAHESWARY.G., SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 462
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12545 OF 2022
PETITIONER/S:
PANAPPAMKUNNU RURAL CO-OPERATIVE SOCIETY LTD. NO. T-
1570
MALACKKAL P.O., CHIRAYINKEEZHU, THIRUVANANTHAPURAM,
PIN - 695 602, REPRESENTED BY ITS SECRETARY,
K.G.NISHA.
BY ADVS.
SRI.D.SAJEEV
SMT.LIGEY ANTONY
RESPONDENT/S:
1 UNION OF INDIA
MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI - 110 001
REPRESENTED BY ITS SECRETARY.
2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
C.R.BUILDING, I.S.PRESS ROAD, KOCHI, ERNAKULAM, PIN -
682 018.
3 THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS)
3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O.,
THIRUVANANTHAPURAM, PIN - 695 003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
EAST FORT, THIRUVANANTHAPURAM, PIN - 695 023
REPRESENTED BY ITS MANAGING DIRECTOR.
2025:KER
W.P(C)No.7053/2023 & Connected cases 463
5 THE BRANCH MANAGER
THE KERALA STATE CO-OPERATIVE BANK OLTD., KILIMANOOR
BRANCH, THIRUVANANTHAPURAM, PIN - 695 601.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 464
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12635 OF 2022
PETITIONER/S:
1 THE KASARAGOD DISTRICT ADVOCATE'S WELFARE CO-
OPERATIVE SOCIETY LTD NO. S 414
HOSDURG P.O., KANHANGAD, KASARAGOD-671315 REPRESENTED
BY ITS SECRETARY AMBILIL K.S.
2 THE PARAPPA FARMER'S WELFARE COOPERATIVE SOCIETY LTD
NO. S 508
PARAPPA P.O., KASARAGOD-671533 REPRESENTED BY ITS
SECRETARY REKHA K.R
3 THE VELLARIKUNDU KARSHAKA KSHEME GRAMA VIKASANA
SAHAKARANA SANGAM LTD, NO. S 459
VELLARIKUNDU P.O., KASARAGOD-671534 REPRESENTED BY
ITS SECRETARY SHEEJA M.V.
4 BRAHMOS AEROSPACE EMPLOYEES COOPERATIVE SOCIETY LTD
NO. T 1324,
BRAHMOS CAMPUS CHACKAI BEACH P.O.,
THIRUVANANTHAPURAM-695007, REPRESENTED BY ITS
SECRETARY SUNILKUMAR J.
5 TELLICHERRY EDUCATIONAL DISTRICT TEACHER'S CO-
OPERATIVE SOCIETY LTD. NO. C 810
LOGANS ROAD, THALASSERY, KANNUR-670101 REPRESENTED BY
ITS SECRETARY SAJINA K.
6 VAMAL VANITHA CO-OPERATIVE SOCIETY LTD NO. C.1683
DIET ROAD, PALAYAD P.O., KANNUR-670661 REPRESENTED BY
ITS SECRETARY BINDU C.P
7 KULUKKALLUR PANCHAYATH AGRICULTURAL IMPROVEMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 465
CREDIT CO-OPERATIVE SOCIETY LTD NO. P.1270,
MULAYANKAV P.O.,KULUKKALLUR, PALAKKAD-679337
REPRESENTED BY ITS SECRETARY V JANARDHANAN.
8 DHARMADAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C1602
, VELLAZHUKKE, PALAYAD, KANNUR-670661 REPRESENTED BY
ITS SECRETARY GEETHA K.
9 AZHIYOOR VANITHA SAHAKARANA SANGAM LTDNO. D 2661
CHOMBALA P.O., KOZHIKODE-673308 REPRESENTED BY ITS
SECRETARY SHAJI O.K
10 NEYYATINKARA WELFARE CO-OPERATIVE SOCIETY LTD NO. T
1800
THIRUMANGALAM, POOVAR ROAD, NEYYATTINKARA,
THIRUVANANTHAPURAM-695121 REPRESENTED BY ITS
SECRETARY PRADEEP R.S.
11 OTTAPPALAM CO-OPERATIVE HOUSING SOCIETY LTD. NO. P
608,
HOUSING SOCIETY BUILDING, RAILWAY STATION ROAD,
OTTAPPALAM, PALAKKAD-679101 REPRESENTED BY ITS
SECRETARY A.SIVADAS.
12 KANHIRAPUZHA CO-OPERATIVE URBAN CREDIT SOCIETY LTD.
NO. P 1172
CHIRAKKALPADI, THRIKALOOR P.O., PALAKKAD-678593
REPRESENTED BY ITS SECRETARY ABIN VARGHEES.
13 LABOUR BANK WELFARE CO-OPERATIVE SOCIETY LTD NO.C1632
MUNEER COMPLEX RAJIV GANDHI ROAD KANNUR-670001
REPRESENTED BY ITS SECRETARY JITHESH K.
14 CHERUPUZHA MERCHANTS WELFARE CO OPERATIVE SOCIETY LTD
NO C 1708
,CHERUPUZHA PO,KANNUR-670511 REPRESENTED BY ITS
SECRETARY SURESH K.
15 KANNUR DISTRICT CONTRACTORS CO OPERATIVE SOCIETY LTD
NO.C1430
SEALAND COMPLEX, TALIPARAMBA.P O,KANNUR-670141
REPRESENTED BY ITS SECRETARY V.V SATHISH KUMAR.
16 TALIPARAMBA GOVT EMPLOYEES CO OPERATIVE SOCIETY LTD
2025:KER
W.P(C)No.7053/2023 & Connected cases 466
NO C 293
TALIPPARAMBA (P.O) KANNUR-670141 REPRESENTED BY ITS
SECRETARY SATHEESAN.
17 TALIPARAMBA RURAL CO OPERATIVE SOCIETY LTD NO C 2056
, EMIRATES ROAD, MAIN ROAD TALIPARAMBA, KANNUR-
670141. REPRESENTED BY ITS SECRETARY PRADEEP T.V.
18 THULUNADU FARMER'S WELFARE CO-OPERATIVE SOCIETY LTD,
NO S 548
KOTTODAL BUILING, KUMBALA, KASARAGOD- 671321
REPRESENTED BY ITS SECRETARY VASANTHA D
19 CHIRAYINKEEZHU TALUK TOURISM CO-OPERATIVE SOCIETY LTD
T 1860
NEAR TOWN UPS, ATTI NGAL, THIRUVANANTHAPURAM - 695101
REPRESENTED BY ITS SECRETARY RATHEESH R.
20 KARIMBA PANCHAYATH KARSHIKA UDPADHANA SAMBARANA
SAMSKARANA VIPANANA CREDIT SAHAKARANA SANGHAM LTD,
P.O. KARIMPA, PALAKKAD-678597 REPRESENTED BY ITS
SECRETARY GEETHA K.
BY ADVS.
DR.K.P.PRADEEP
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED
BY ITS CHAIRMAN.
2025:KER
W.P(C)No.7053/2023 & Connected cases 467
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI- 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD
,PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 468
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12754 OF 2022
PETITIONER/S:
PANGAPPARA SREE NARAYANA GURUMANDIRA SAMITHI
RESIDENCE WELFARE CO-OPERATIVE SOCIETY LTD.NO.T 1720,
REPRESENTED BY ITS SECRETARY, KARIYAVATTOM P.O.,
THIRUVANANTHAPURAM, PIN - 695 581.
BY ADVS.
SHRI.T.R.HARIKUMAR
SRI.ARJUN RAGHAVAN
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.,
THIRUVANANTHAPURAM, PIN - 695 003.
2 THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI, PIN - 110
001.
3 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI, PIN - 110 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 469
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD
P.O., THIRUVANANTHAPURAM - 695 014.
5 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695 001.
6 THE KERALA STATE CO-OPERATIVE BANK
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN - 695 033.
BY ADVS.
SMT.MAHESWARY.G., SENIOR PANEL COUNSEL
SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 470
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12713 OF 2022
PETITIONER/S:
1 VANCHINADU BHAVANA NIRMANA SAHAKARANA SANGHOM LTD NO
1083,
ENCHAKKAL P.O.THIRUVANANTHAPURAM DISTRICT, KERALA,
PIN-695 608, REPRESENTED BY ITS SECRETARY SREEKALA
2 PEROORKADA SERVICE CO-OPERATIVE BANK LIMITED NO T
1412,
PEROORKADA P.O.THIRUVANANTHAPURAM DISTRICT, KERALA,
PIN-695 005, REPRESENTED BY ITS SECRETARY YAMUNA
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110 000
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682 018
3 THE INCOME TAX OFFICER (TDS),
3RD FLOOR AAYAKAR BAHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695 003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
(ERSTWHILE THIRUVANANTHAPURAM SERVICE CO-OPERATIVE
BANK), EAST FORT, THIRUVANANTHAPURAM-695 023.
2025:KER
W.P(C)No.7053/2023 & Connected cases 471
5 KERALA LAND REFORMS AND DEVELOPMENT CO-OPERATIVE
SOCIETY LTD,
S.S.KOVIL ROAD, THAMPANOOR, GENERAL POST OFFICE,
THIRUVANANTHAPURAM-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 472
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12744 OF 2022
PETITIONER/S:
1 MALAMPUZHA SERVICE CO-OPERATIVE BANK LTD NO.P.907
NO.P.907, KADUKKAMKUNNAM.P.O, PALAKKAD-678651,
REPRESENTED BY ITS SECRETARY PRATHEEP.K.P.
2 KALPETTA ZONE LABOUR CONTRACT CO-OPERATIVE SOCIETY
LTD.NO.W.209,
KALPETTA.P.O, WAYANAD-673121,REPRESENTED BY ITS
SECRETARY NITHIN SUNNY.
3 KUTTIKOL AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY
LTD.NO.S 383, KUTTIKOL.P.O,`
KASARAGOD-671541, REPRESENTED BY ITS SECRETARY
CHATHUKUTTY NAIR.
4 BALAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD,
NO.S 293, BALAL, BALAL.P.O, KASARAGOD-
671533,REPRESENTED BY SECRETARY PRASANTH.V.
5 KASARAGOD DISTRICT P.N.PANICKER SOCIAL WORKERS
WELFARE CO-OPERATIVE SOCIETY LTD,
NO.S.338(KASCO), KANHANGAD.P.O, KASARAGOD-
671315,REPRESENTED BY ITS SECRETARY AMBIKA.V
6 UDMA PANCHAYATH VANITHA SERVICE SAHAKARANA SANGAM LTD
NO.S.492, UDMA.P.O,
KASARAGOD-671319, REPRESENTED BY ITS SECRETARY
SUKUMARI.K.
7 BANDADKA VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD.NO.S 350,
BANDADKA.P.O, CHENGALA(VIA), KASARAGOD-
2025:KER
W.P(C)No.7053/2023 & Connected cases 473
671541,REPRESENTED BY ITS SECRETARY BABY.K.
8 THALASSERY AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD.NO.C.1619,
BABNEESH ARCADE, LOGANS ROAD, THALASSERY, KANNUR-
670649,REPRESENTED BY ITS SECRETARY SATHEESH.M.
9 THE PILICODE AGRICULTURIES WELFARE CO-OPERATIVE
SOCIETY LTD.NO.S 385,
KALIKADAVU, P.O.PILICODE, KASARAGOD-
671353,REPRESENTED BY ITS SECRETARY JAYARAJAN.K.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY,DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FIINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI, ERNAKULAM-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE DIRECTOR.
2025:KER
W.P(C)No.7053/2023 & Connected cases 474
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 475
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12753 OF 2022
PETITIONER/S:
ENADIMANGALAM SERVICE CO-OPERATIVE BANK LTD.NO.2151,
VI/3, ELAMANNOOR P.O, PATHANAMTHITTA -691 524,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -110
001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN 682 018.
3 THE INCOME TAX OFFICER, (TDS),
AARATTUKULAKKARA COPLEX, A.N. PURAM, ALAPPUZHA
DISTRICT, PIN 686 011.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033.
5 THE DEPUTY GENERAL MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., PATHANAMTHITTA
DISTRICT OFFICE, PATHANAMTHITTA , PIN 689 645.
2025:KER
W.P(C)No.7053/2023 & Connected cases 476
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 477
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 12759 OF 2022
PETITIONER/S:
1 PUTHIYATHERU URBAN CO-OPERATIVE SOCIETY LTD NO.C-1661
PUTHIYATHERU, P.O.CHIRAKKAL, KANNUR-670011,
REPRESENTED BY ITS SECRETARY SUJITH KUMAR P.P.
2 CHAKKARAKKAL URBAN CO-OPERATIVE SOCIETY LTD NO.C
1564,
CHAKKARAKKAL, P.O.MOWANCHERY, KANNUR-670594,
REPRESENTED BY ITS SECRETARY SASIKUMAR T.K.
3 PAPPINISSERI URBAN CO-OPERATIVE SOCIETY LTD NO.C
1557,
JAMEEL COMPLEX, NR RAILWAY GATE, P.O.PAPPINISSERI,
KANNUR-670561, REPRESENTED BY ITS SECRETARY SOBHANA
K.
4 TALIPARAMBA CO-OPERATIVE URBAN SOCIETY LTD. NO. C
1559,
COURT ROAD, TALIPARAMBA, P.O.TALIPARAMBA, KANNUR-
670141, REPRESENTED BY ITS SECRETARY PADMARAJAN E.
5 ALAKODE URBAN CO-OPERATIVE SOCIETY LTD NO.C 1579,
ALAKODE, P.O.KANNUR-670571, REPRESENTED BY ITS
SECRETARY BIBIN THOMAS.
6 EDAKKAD URBAN CO-OPERATIVE SOCIETY LTD NO.C 1725,
P.O.KADACHIRA, KANNUR-670621, REPRESENTED BY ITS
SECRETARY RAJALAKSHMI T.O.
7 MATTANUR URBAN CO-OPERATIVE SOCIETY LTD NO.C 1563,
MATTANUR, MATTANUR P.O., KANNUR-670702, REPRESENTED
BY ITS SECRETARY SHANIL KUMAR K.
2025:KER
W.P(C)No.7053/2023 & Connected cases 478
8 PILATHARA CO-OPERATIVE URBAN SOCIETY LTD. NO. C 1558,
BUS STAND, PILATHARA, KANNUR-670504, REPRESENTED BY
ITS SECRETARY SURENDRANATH P.V.
9 KAMBIL URBAN CO-OPERATIVE SOCIETY LTD NO.1561,
KAMBIL, KOLACHERY P.O., KANNUR-670601, REPRESENTED BY
ITS SECRETARY AJAYAKUMAR K.
0 PUNALUR URBAN CO-OPERATIVE SOCIETY LTD NO. Q 1508,
T.B.JUNCTION, VALACODU P.O., PUNALUR, KOLLAM-691331,
REPRESENTED BY ITS SECRETARY ROSHNI R.
11 THALASSERY URBAN CO-OPERATIVE SOCIETY LTD NO.C 1719,
MG BAZAR, OLD BUS STAND, THALASSERY, KANNUR-670101,
REPRESENTED BY ITS SECRETARY SREEJA K.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 479
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 480
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13011 OF 2022
PETITIONER/S:
KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION,
DISTRICT COMMITTEE, KOZHIKODE, REPRESENTED BY ITS
SECRETARY, ARAVINDAKSHAN E., AGED 70 YEARS, S/O.
RAMUNNI NAMBIAR, SOORYAKANDI P.O., MEPPAYIL,
VADAKARA, KOZHIKODE-673104.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELH-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
2025:KER
W.P(C)No.7053/2023 & Connected cases 481
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LIMITED,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 482
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13047 OF 2022
PETITIONER/S:
COCHIN NAVAL BASE CONSUMER COOPERTAIVE SOCIETY LTD
MO. E-161
AGED 42 YEARS
NAVAL BASE COMPOUND OLD NH47 KOCHI -682004
REPRESENTED BY ITS SECRETARY AJESH KUMAR
BY ADVS.
SHRI.ARUN V.G. (K/795/2004)
SMT.V.JAYA RAGI
SHRI.R.HARIKRISHNAN (KAMBISSERIL)
SRI.NEERAJ NARAYAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI, REPRESENTED BY ITS
CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
2025:KER
W.P(C)No.7053/2023 & Connected cases 483
KOCHI, PIN - 682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
5 THE KERALA STATE CO-OPERATIVE BANK LTD
ERNAKULAM MAIN BRANCH ,CHITTUR ROAD ,PULLEPADY ROAD
KOCHI, REPRESENTED BY ITS MANGER., PIN - 682035
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN - 695001
BY ADVS.
SRI.CHRISTOPHER ABRAHAM
SRI.N.RAGHURAJ, SC, HIGH POWER COMMITTEE FOR
SABARIMALA, TRAVANCORE DEVASWOM BOARD
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 484
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13114 OF 2022
PETITIONER/S:
1 JANATHA SERVICE CO-OPERATIVE BANK LTD NO. 1042,
V. KOTTAYAM P.O., PATHANAMTHITTA DISTRICT-689656,
REPRESENTED BY ITS SECRETARY.
2 THEKKUTHODE SERVICE CO-OPERATIVE BANK LIMITED NO.
P.T.48,
THEKKUTHODE P.O., PATHANAMTHITTA DISTRICT-689699,
REPRESENTED BY ITS SECRETARY.
3 CHENGARA SERVICE CO-OPERATIVE BANK LIMITED NO.3137,
CHENGARA P.O., MALAYALAPPUZHA ERAM, PATHANAMTHITTA
DISTRICT-689664, REPRESENTED BY ITS SECRETARY.
4 VAKAYAR SERVICE CO-OPERTIVE BANK LIMITED NO.847,
VAKAYAR P.O., KONHI, PATHANAMTHITTA DISTRICT-689698,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.S.SHYAM KUMAR
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
2025:KER
W.P(C)No.7053/2023 & Connected cases 485
NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
COCHIN-682018.
4 INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAM NAGAR, THRISSUR-680001.
5 THE KERALA STATE CO-OPERATIVE BANK LIMITED, P.B.
NO.6515,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
6 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO-
OPERATION, SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 486
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13112 OF 2022
PETITIONER/S:
1 THRISSUR DISTRICT MARKETING AND PROCESSING CO-
OPERATIVE SOCIETY LTD NO R 1164
THRISSUR DISTRICT, THRISSUR PIN 680001 REPRESENTED BY
SECRETARY JAI JOHN THANJAN
2 THE PARIAYARAM MULTI PURPOSE CO OPERATIVE SOCIETY LTD
NO. R 1186,
KUTTIKKAD PO, THRISSUR DISTRICT, PIN 680724
REPRESENTED BY SECRETARY SHIBY
3 WELFARE AGRICULTURAL CREDIT CO OPERATIVE SOCIETY LTD
NO. R 182,
ELINJIPRA PO, THRISSUR DISTRICT, THRISSUR PIN 680721
REPRESENTED BY SECRETARY PAUL E A
4 KERALA STATE SERVICE PENSIONERS CO OPERATIVE SOCIETY
LTD NO. R 1218,
THRISSUR DISTRICT, CHALAKKUDY PIN 680307 REPRESENTED
BY SECRETARY REBY RAPHEAL 5. CHALAKKUDY TOWN
MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1256,
ILARISSUR DISTRICT, CHALAKKUDI PIN 680307 REPRESENTED
BY SECRETARY KISHORE KUMAR PS 6. CHALAKKUDY BLOCK
MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1272,
THRISSUR DISTRICT, ANAMALA JUNCTION CHALAKKUDI PIN
680307 REPRESENTED BY SECRETARY MUMTHAS SULAIMAN. 7.
TIRUR MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R
1117, P OMG KAVU, THRISSUR DISTRICT, PIN CHALAKKUDY
THRISSUR DISTRICT PIN 680022 REPRESENTED BY SECRETARY
RAGI C RANGANATH 8. KOLAZHY GRAMA PANCHAYATH VANITHA
CO OPERATIVE SOCIETY LTD NO. R 1319, PAMBOOR PO,
KUTTUR, THRISSUR DISTRICT PIN 680013. REPRESENTED BY
2025:KER
W.P(C)No.7053/2023 & Connected cases 487
SECRETARY NISHA NR 9. THE KUTTANELLUR MULTI PURPOSE
CO OPERATIVE SOCIETY LTD NO. R 1330, PO KUTTANELLUR,
THRISSUR DISTRICT, PIN 680014 REPRESENTED BY
SECRETARY PREETHA CP 10.THE PAVARATTY SERVICE CO
OPERATIVE BANK LTD NO. 3918, PO PAVARATTY, THRISSUR
DISTRICT, PIN 680507 REPRESENTED BY SECRETARY RAJESH
P 11. CHALAKKUDY VANITHA CO OPERATIVE SUCIETY LTD NO.
R 1190, CHALAKKUDY, THRISSUR DISTRICT PIN 680307
REPRESENTED BY SECRETARY SHIJI K GEORGE 12.KODASSERY
MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 4275,
ELINJIPRA PO, THRISSUR DISTRICT PIN 680721
REPRESENTED BY SECRETARY LATHIKA KK 3.CHALAKKUDY
TALUK VANITHA CO OPERATIVE SOCIETY LTD NO. R 1453,
CHALAKKUDY, THRISSUR DISTRICT, PIN 680307 REPRESENTED
BY SECRETARY SHINTU VIJAYAN K
5 CHALAKKUDY TOWN MULTIPURPOSE COOPERATIVE SOCIETY LTD
NO. R 1256,
ILARISSUR DISTRICT, CHALAKKUDI PIN 680307 REPRESENTED
BY SECRETARY KISHORE KUMAR PS
6 CHALAKKUDY BLOCK MULTIPURPOSE COOPERATIVE SOCIETY LTD
NO. R 1272,
THRISSUR DISTRICT, ANAMALA JUNCTION CHALAKKUDI PIN
680307 REPRESENTED BY SECRETARY MUMTHAS SULAIMAN.
7 TIRUR MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R
1117,
P OMG KAVU, THRISSUR DISTRICT, PIN CHALAKKUDY
THRISSUR DISTRICT PIN 680022 REPRESENTED BY SECRETARY
RAGI C RANGANATH
8 KOLAZHY GRAMA PANCHAYATH VANITHA CO OPERATIVE SOCIETY
LTD NO. R 1319,
PAMBOOR PO, KUTTUR, THRISSUR DISTRICT PIN 680013.
REPRESENTED BY SECRETARY NISHA NR
9 THE KUTTANELLUR MULTI PURPOSE CO OPERATIVE SOCIETY
LTD NO. R 1330,
PO KUTTANELLUR, THRISSUR DISTRICT, PIN 680014
REPRESENTED BY SECRETARY PREETHA CP
10 THE PAVARATTY SERVICE CO OPERATIVE BANK LTD NO. 3918,
PO PAVARATTY, THRISSUR DISTRICT, PIN 680507
2025:KER
W.P(C)No.7053/2023 & Connected cases 488
REPRESENTED BY SECRETARY RAJESH P 11. CHALAKKUDY
VANITHA CO OPERATIVE SUCIETY LTD NO. R 1190,
CHALAKKUDY, THRISSUR DISTRICT PIN 680307 REPRESENTED
BY SECRETARY SHIJI K GEORGE 12.KODASSERY MULTIPURPOSE
CO OPERATIVE SOCIETY LTD NO. R 4275, ELINJIPRA PO,
THRISSUR DISTRICT PIN 680721 REPRESENTED BY SECRETARY
LATHIKA KK 3.CHALAKKUDY TALUK VANITHA CO OPERATIVE
SOCIETY LTD NO. R 1453, CHALAKKUDY, THRISSUR
DISTRICT, PIN 680307 REPRESENTED BY SECRETARY SHINTU
VIJAYAN K
11 CHALAKKUDY VANITHA CO OPERATIVE SUCIETY LTD NO. R
1190,
CHALAKKUDY, THRISSUR DISTRICT PIN 680307 REPRESENTED
BY SECRETARY SHIJI K GEORGE
12 KODASSERY MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R
4275,
ELINJIPRA PO, THRISSUR DISTRICT PIN 680721
REPRESENTED BY SECRETARY LATHIKA K K
13 CHALAKKUDY TALUK VANITHA CO OPERATIVE SOCIETY LTD NO.
R 1453,
CHALAKKUDY, THRISSUR DISTRICT, PIN 680307 REPRESENTED
BY SECRETARY SHINTU VIJAYAN K
14 THE VATTEKKAD SERVICE CO OPERATIVE BANK LTD NO. 1594,
R 1256,
VARTEKKAD, THRISSUR DISTRICT PIN 680512 REPRESENTED
BY SECRETARY N K PRASAD
15 KORATTY MEGHALA VANITHA CO OPERATIVE SOCIETY LTD NO R
1334,
KORATTY, THRISSUR DISTRICT PIN 680 308 REPRESENTED BY
SECRETARY MAYA P V
16 MOONNUMURY MEGHALA VANITHA CO OPERATIVE SOCIETY LTD
NO. 1118,
MATTATHUR PO, THRISSUR DISTRICT PIN 680684
REPRESENTED BY SECRETARY SIJI. J
17 KAIPAMANGALAM FISHERMEN'S CO-OPERATIVE SOCIETY LTD
NO.2941,
KAIPAMANGALAM P.O, THRISSUR DISTRICT PIN 680681
2025:KER
W.P(C)No.7053/2023 & Connected cases 489
REPRESENTED BY SECRETARY ALMANUJAN
18 VARANDARAPPILLY KARSHIKETHARA VIKASANA CO OPERATIVE
SOCIETY LTD NO. R 1414,
VARANDARAPPILLY PO, THRISSUR DISTRICT PIN 680303
REPRESENTED BY SECRETARY NISHA THOMAS T.
19 PUDUKKAD VYAPARI VYAVASAYI CO OPERATIVE SOCIETY LTD
NO. R 1153,
PUDUKAD PO, THRISSUR DISTRICT PIN 680301 REPRESENTED
BY SECRETARY SUNDARAN T V
20 ADAT PANCHAYATH MULTIPURPOSE CO OPERATIVE SOCIETY LTD
NO. R 1127,
MUTHUVARA, PUZHAKKAL P O, THRISSUR DISTRICT PIN
680553 REPRESENTED BY SECRETARY SIJO JOSE C.
21 KOTTEKKAD PEOPLES WELFARE CO OPERATIVE SOCIETY LTD
NO. R 1420,
KOTTEKKAD, KUTTOOR PO, THRISSUR DISTRICT PIN 680022
REPRESENTED BY SECRETARY MARY LEENA M F
22 KARAYAVATTAM SERVICE COOPERATIVE BANK LTD NO. F 793,
KARAYAVATTAM PO, THRISSUR DISTRICT PIN 680567
REPRESENTED BY SECRETARY P D SINDHU
23 THIRUVATHRA SERVICE CO OPERATIVE BANK LTD NO. F 889,
THIRUVATHRA P O, THRISSUR DISTRICT PIN 680516
REPRESENTED BY SECRETARY BINITHA P B
24 GURUVAYUR DEVASWOM EMPLOYEES CO OPERATIVE SOCIETY LTD
NO. R 794,
GURUVAYUR PO, THRISSUR DISTRICT PIN 680101
REPRESENTED BY SECRETARY BIJI T P.
25 PERINGOTTUKARA KARSHIKETHARA VIKASANA SAHAKARANA
SANGHAM LTD NO. R 1418,
PERINGOTTUKARA PO, THRISSUR DISTRICT PIN 680565
REPRESENTED BY SECRETARY ABHITHA N S. 26. THANIYAM
PRIYADARSINI VANITHA CO OPERATIVE SOCIETY LTD NO. R
1122, KIZHAKKUMMURI PO, PIN 680571 REPRESENTED BY
SECRETARY SHANILA A 27.PERINGOTTUKARA SOCIAL WELFARE
CO OPERATIVE SOCIETY LTD NO R 1403, THRISSUR
DISTRICT, PIN - 680565 REPRESENTED BY SECRETARY
2025:KER
W.P(C)No.7053/2023 & Connected cases 490
RANJANA K RAMACHANDRAN 28.AMBALLUR TOWN CO OPERATIVE
SOCIETY LTD NO. R 1356, ALAGAPPANAGAR PO, THRISSUR
DISTRICT PIN 680302 REPRESENTED BY SECRETARY SEENA
BIJOY 29.ANTHIKKAD BLOCK MULTIPURPOSE CO OPERATIVE
SOCIETY LTD NO. R 1128, PAZHUVIL PO, THRISSUR
DISTRICT PIN 680564 REPRESENTED BY SECRETARY REJI NV
26 THANIYAM PRIYADARSINI VANITHA CO OPERATIVE SOCIETY
LTD NO. R 1122,
KIZHAKKUMMURI PO, PIN 680571 REPRESENTED BY SECRETARY
SHANILA A
27 PERINGOTTUKARA SOCIAL WELFARE CO OPERATIVE SOCIETY
LTD NO R 1403,
THRISSUR DISTRICT, PIN - 680565 REPRESENTED BY
SECRETARY RANJANA K RAMACHANDRAN
28 AMBALLUR TOWN CO OPERATIVE SOCIETY LTD NO. R 1356,
ALAGAPPANAGAR PO, THRISSUR DISTRICT PIN 680302
REPRESENTED BY SECRETARY SEENA BIJOY
29 ANTHIKKAD BLOCK MULTIPURPOSE CO OPERATIVE SOCIETY LTD
NO. R 1128,
PAZHUVIL PO, THRISSUR DISTRICT PIN 680564 REPRESENTED
BY SECRETARY REJI N V
30 THRISSUR BANK EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.R
700
MACHINGAL LANE , THRISSUR MAIN POST OFFICE, THRISSUR-
680001 REPRESENTED BY ITS SECRETARY INCHARGE VINOD
KUMAR K R
31 GRAMAVIKASANA MULTIPURPOSE CO OPERATIVE SOCIETY LTD
NO. R 1211,
MULANKUNNATHUKAVU, THRISSUR DISTRICT PIN 680581
REPRESENTED BY SECRETARY SUDHA A A.
32 THRISSUR DISTRICT SERVICE PENSIONERS WELFARE CO
OPERATIVE SOCIETY LTD NO. R 1506.
AYYANTHOLE PO, THRISSUR DISTRICT PIN 680003
REPRESENTED BY SECRETARY DHANYA G MENON.
33 KALLETTUMKARA SERVICE CO OPERATIVE BANK LTD NO. 141,
KALLETTUMKARAPO, THRISSUR DISTRICT, PIN 680683.
2025:KER
W.P(C)No.7053/2023 & Connected cases 491
REPRESENTED BY SECRETARY K, LASHES
34 THOLUR PANCHAYATH MULTIPURPOSE CO OPERATIVE SOCIETY
LTD NO. R 1154 ,
PARAPPORU, THRISSUR DISTRICT PIN 680552 REPRESENTED
BY SECRETARY JOISY P J.
35 KODAKARA AND MATTATHUR CO OPERATIVE SOCIAL WELFARE
MULTIPURPOSE SOCIETY LTD NO. R 1215,
KODAKARA PO, THRISSUR DISTRICT PIN 680684 REPRESENTED
BY SECRETARY SUGANDHI S M
36 THE KATTOOR SERVICE CO OPERATIVE BANK LTD NO. 426,
KATTOOR PO, THRISSUR DISTRICT PIN 680702 REPRESENTED
BY SECRETARY VIJAYAKUMAR T V 37.DEEPAM WOMENS CO
OPERATIVE SOCIETY LTD NO. R 1247, KODAKARA P O,
THRISSUR DISTRICT PIN 680684 REPRESENTED BY SECRETARY
REKHA P S
37 DEEPAM WOMENS CO OPERATIVE SOCIETY LTD NO. R 1247,
KODAKARA P O, THRISSUR DISTRICT PIN 680684
REPRESENTED BY SECRETARY REKHA P S
38 PUBLIC SOCIAL WELFARE CO OPERATIVE SOCIETY LTD NO. R
1475,
CHALAKKUDY PO, THRISSUR DISTRICT PIN 680307
REPRESENTED BY HONORARY SECRETARY A L DEVASSY. P
39 VADANAPPALLY SERVICE CO OPERATIVE BANK LTD NO. F 211,
THRITHALLUR O, THRISSUR DISTRICT PIN 680619
REPRESENTED BY SECRETARY BIJU M V
40 PULAKKODE SERVICE CO OPERATIVE BANK LTD NO. R 185,
PULAKODE PO, THRISSUR DISTRICT, PIN 680586
REPRESENTED BY SECRETARY JACOB GEORGE.
41 KONDAZHY KARSHIKETHARA SAHAKARANA SANGHAM LTD. NO. R
4274,
KONDAZHY PO, THRISSUR DISTRICT. PIN 679106
REPRESENTED BY SECRETARY SUMOD M S.
BY ADVS.
SHRI.C.A.JOJO
2025:KER
W.P(C)No.7053/2023 & Connected cases 492
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA
, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018
3 THE INCOME TAX OFFICER (TDS)
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR, PIN 680 001
4 THE KERALA STATE CO-OEPRATIVE BANK LTD
(ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK) ]
SAHAKARANA SAPTHATDHI MANDIRAM, TUDA ROAD,
THIRUVAMBADI P.O, THRISSUR, PIN 680 022 REPRESENTED
BY ITS GENERAL MANAGER
5 THE GENERAL MANAGER
THRISSUR URBAN CO-OPERATIVE BANK LTD, HEAD OFFICE,
MISSION QUARTERS, THRISSUR 680 001
6 THE GENERAL MANAGER
IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD , TANA
JUNCTION, IRINJAKUDA P.O, PIN 680 121
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.C.D.DILEEP,SC,TRICHUR URBN CO-OPBAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 493
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13171 OF 2022
PETITIONER/S:
1 PADY NEKRAJE VILLAGE VANITHA SERVICE CO-OPERATIVE
SOCIETY LTD. NO. S 302,
PAIKA P.O., NEKRAJE, KASARAGOD- 671544, REPRESENTED
BY ITS SECRETARY RAMAKRISHNA P.K.
2 MULIYAR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.
S 230,
IRIYANI P.O., MULIYAR, KASARAGOD-671542, REPRESENTED
BY ITS SECRETARY K.P.GANGADHARAN.
3 THE KASARAGOD AGRICULTURAL MARKETING AND PROCESSING
CO-OPERATIVE SOCIETY LTD. NO. S 395,
BADIADKA, PERADALA P.O., KASARAGOD-671551,
REPRESENTED BY ITS SECRETARY PRIYA K.
4 THE KASARAGOD ARTISAN'S DEVELOPMENT & WELFARE CO-
OPERATIVE SOCIETY LTD. NO. S 530,
S.M.S.CENTRE, NAYAKS ROAD, KASARAGOD-671121,
REPRESENTED BY ITS SECRETARY VIJAYA R.
5 THE KUTTIKOL URBAN CO-OPERATIVE SOCIETY LTD. NO. S
347,
PADUPPU P.O., SHANKARAMPADY, CHENGALA VIA, KASARAGOD
-671541, REPRESENTED BY ITS SECRETARY TINCY P.T.
6 THE KANHANGAD VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD. NO. S 263,
PADANAKKAD, KASARAGOD-671314, REPRESENTED BY ITS
SECRETARY GIRIJA O.
7 THE CHENGALA AGRICULTURAL WELFARE CO-OPERATIVE
2025:KER
W.P(C)No.7053/2023 & Connected cases 494
SOCIETY LTD. NO. S 375,
PADY ROAD, CHERKALA P.O., CHENGALA, KASARAGOD-671541,
REPRESENTED BY ITS SECRETARY MURALEEDHARAN K.
8 CHIRAYINKEEZHU BLOCK RURAL DEVELOPMENT CO-OPERATIVE
SOCIETY LTD. NO.T 1636,
CHIRAYINKEEZHU P.O., THIRUVANANTHAPURAM-695304,
REPRESENTED BY ITS SECRETARY GEETHA SIDHARTH.
9 KUMBADAJE AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY
LTD. NO. S 409,
MARPANADKA, KUMBADAJE P.O., KASARAGOD-671551,
REPRESENTED BY ITS SECRETARY ASHAKUMARI K.
10 DELAMPADY AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY
LTD. NO.S 393,
ADOOR, URDOOR P.O., KASARAGOD -671543, REPRESENTED BY
ITS SECRETARY SEEMA C.
11 BETHARPARA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO. S 316,
BETHURPARA, VATTAMTHATTA P.O., KASARAGOD -671542,
REPRESENTED BY ITS SECRETARY KRISHNAN NAIR A.
12 THE CHENGALA VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD. NO. S 407,
CHERKALA, CHENGALA P.O., KASARAGOD -671541,
REPRESENTED BY ITS SECRETARY MADHUSOODHANAN V.
13 KASARAGOD VYAPARI VYAVASAI WELFARE CO-OPERATIVE
SOCIETY LTD. NO. S 477,
DISTRICT VYAPARA BHAVAN, A.T.ROAD, KASARAGOD -671121,
REPRESENTED BY ITS SECRETARY ANITHA K.
14 THE KASARAGOD DISTRICT PRIVATE MOTOR EMPLOYEES
WELFARE CO-OPERATIVE SOCIETY LTD. NO.S 68,
NAYAKS ROAD, KASARAGOD -671121, REPRESENTED BY ITS
SECRETARY BINDU C.P.
15 ADOOR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S
295,
ADOOR, URDOOR P.O., KASARAGOD-671543, REPRESENTED BY
ITS SECRETARY SUPRITHA M.
2025:KER
W.P(C)No.7053/2023 & Connected cases 495
16 SREE NARAYANA GURU VANITHA SERVICE CO-OPERATIVE
SOCIETY LTD. NO. S 543,
CITY CENTRE, IIND FLOOR, BANK ROAD, KASARAGOD -
671121, REPRESENTED BY ITS SECRETARY SWAPNA B.
17 THE KASARAGOD-KARADKA BLOCK VANITHA SERVICE CO-
OPERATIVE SOCIETY LTD. NO. C 963,
NULLIPADY, KASARAGOD -671121, REPRESENTED BY ITS
SECRETARY SHEEJA P.
18 THE MUNNAD VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO. S 268,
PALLATHINGAL, MUNNAD P.O., KASARAGOD -671541,
REPRESENTED BY ITS SECRETARY SREEDEVI K.M.
19 KASARAGOD DISTRICT PRINTING & PUBLISHING CO-OPERATIVE
SOCIETY LTD. NO. S 58,
INDUSTRIAL ESTATE, VIDYANAGAR P.O., KASARAGOD -
671123, REPRESENTED BY ITS SECRETARY THAMARAKSHAN V.
20 KADAKAM VANITHA SERVICE SAHAGARANA SANGAM,
KARADKA P.O., KASARAGOD-671542, REPRESENTED BY ITS
SECRETARY KUNHIRAMAN T.
21 THE KARADKA PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD.
NO. S 528,
GG ROAD, MULLERIA P.O., KASARAGOD -671543,
REPRESENTED BY ITS SECRETARY SUDHEESH KUMAR A.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 496
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADV SHRI.M.SASINDRAN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 497
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13184 OF 2022
PETITIONER/S:
1 THE ADHYAPAKA SERVICE CO-OPERATIVE BANK LTD.
NO. A-300, PUTHUSSERY P.O, KALLOOPARA, PATHANAMTHITTA
- 689602, REPRESENTED BY ITS SECRETARY, SHRI.ALEX
ISSAC.
2 RANNI SERVICE CO-OPERATIVE BANK LTD.
NO. 65, RANNI P.O, PATHANAMTHITTA - 679672,
REPRESENTED BY ITS SECRETARY, SMT. SOOSAN K. THOMAS.
3 ANGADI SERVICE CO-OPERATIVE BANK LTD NO. 2270,
ANGADI P.O, RANNY, PATHANAMTHITTA - 689674,
REPRESENTED BY ITS SECRETARY SHRI. SANOJ N.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI -
682018.
3 THE INCOME TAX OFFICER (TDS),
THIRUVALLA CIRCLE, THIRUVALLA RANGE, T.K. ROAD,
THIRUVALLA, PIN - 689101.
2025:KER
W.P(C)No.7053/2023 & Connected cases 498
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
(ERSTWHILE PATHANAMTHITTA SERVICE CO-OPERATIVE BANK),
REGIONAL OFFICE, ALAPPUZHA, P.B. NO. 104, OPP.
MUNICIPAL TOWN HALL, PIN - 688011, REPRESENTED BY ITS
REGIONAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 499
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13339 OF 2022
PETITIONER/S:
THE ADVOCATES CO-OPERATIVE SOCIETY LTD. NO. R-1177
CHAVAKKAD POST, CHAVAKKAD TALUK, THRISSUR, PIN-
680506, REPRESENTED BY ITS SECRETARY K.S REKHA AGED
37 YEARS, W/O. SIVADASAN, KUNJIKONNAN HOUSE, BLANGAD,
CHAVAKKAD TALUK, THRISSUR - 680506.
BY ADVS.
SRI.RAJIT
SRI.V.V.JOY
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
C.R. BUILDING, I.S. PRESS ROAD, KOCHI - 682018.
3 THE INCOME TAX OFFICER (TDS),
C.R. BUILDINGS, I.S. PRESS ROAD, KOCHI - 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
(ERSTWHILE THE THRISSUR DISTRICT CO-OPERATIVE BANK),
KOLOTHUMPADAM P.O, THRISSUR - 680001, REPRESENTED BY
THE GENERAL MANAGER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 500
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 501
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13303 OF 2022
PETITIONER/S:
THE THIRUVAZHIYODE TRADERS DEVELOPMENT CO-OPERATIVE
SOCIETY LTD. NO. P 1421,
P.O. THIRUVAZHIYODE, PALAKKAD DISTRICT, KERALA 679
514, REPRESENTED BY ITS SECRETARY, SMT.
JYOTHILEKSHMI.
BY ADVS.
SRI.K.ANAND
SHRI.BENNY ANTONY PAREL
SHRI.AMEER SALIM
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110
001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN 682 018.
4 THE KERALA BANK,
2025:KER
W.P(C)No.7053/2023 & Connected cases 502
(THE KERALA STATE CO-OPERATIVE BANK LTD.), COBANK
TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD.),
REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET,
PALAKKAD 678 001.
6 THE KERALA BANK ,
(THE KERALA STATE CO-OPERATIVE BANK LTD.),
SREEKRISHNAPURAM BRANCH, PALAKKAD 679 513. REP. BY
GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 503
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13305 OF 2022
PETITIONER/S:
THE THIRUNARAYANAPURAM VANITHA CO-OPERATIVE CREDIT
SOCIETY LTD. P. 1190
THIRUVAZHIYODE P.O, PALAKKAD DISTRICT, KERALA 679 514
REPRESENTED BY ITS SECRETARY, SMT SHEEJA K
BY ADVS.
SRI.K.ANAND
SHRI.BENNY ANTONY PAREL
SHRI.AMEER SALIM
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001
2 THE CENTRAL BOARD OF DIRECT TAXES
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001 REPRESENTED BY SECRETARY
3 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM,
PIN 682 018
4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD)
2025:KER
W.P(C)No.7053/2023 & Connected cases 504
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695
033 REPRESENTED BY ITS MANAGING DIRECTOR
5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD)
REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET,
PALAKKAD 678 001 REPRESENTED BY GENERAL MANAGER
6 THE KERALA BANK(THE KEREALA STATE CO-OEPRATIVE BANK
LTD)
SREEKRISHNAPURAM BRANCH, PALAKKAD 679 513 REPRESENTED
BY GENERAL MANANGER
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 505
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13318 OF 2022
PETITIONER/S:
KODUKULANJI SERVICE CO-OPERATIVE BANK LTD NO.A.341,
KODUKULANJI, ALAPPUZHA DISTRICT, PIN-689508,
REPRESENTED BY SECRETARY IN-CHARGE.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDING, I.S PRESS ROAD,
KOCHI-682018.
2 THE COMMISSIONER OF INCOME TAX (TDS)
C R BUILDING, I.S PRESS ROAD, KOCHI-682018.
3 THE KERALA STATE CO-OPERATIVE BANK LTD.
(ERSTWHILE ALAPPUZHA DISTRICT SERVICE CO-OPERATIVE
BANK), REGIONAL OFFICE, P B NO.102, OPP MUNICIPAL
TOWN HALL, ALAPPUZHA, PIN-688011, REPRESENTED BY ITS
REGIONAL MANAGER.
4 THE REGISTRAR OF CO-OPERATIVE SOCIEITIES
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P O,
THIRUVANANTHAPURAM-695014.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 506
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 507
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13358 OF 2022
PETITIONER/S:
1 TRIVANDURM DISTRICT JOB WORKER'S CO-OPERATIVE SOCIETY
LTD NO.T 735
KARIKKAKOM, BEACH P.O., THIRUVANANTHAPAURAM DISTRICT,
KERALA, PIN - 695 007 REPRESENTED BY ITS SECRETARY.
2 KERALA STATE COMMERCIAL TAX DEPARTMENT STAFF HOUSING
CO-OPERATIVE SOCIETY LTD.
NO.4385, HEAD OFFICE, TAX TOWERS, 3RD FLOOR,
KALLIPPALAM, KARAMANA P.O., THIRUVANANTHAPURAM - 695
002 REPRESENTED BY ITS SECRETARY.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 11000.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI - 682
018.
3 THE INCOME TAX OFFICER (TDS)
3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM
- 695 003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
2025:KER
W.P(C)No.7053/2023 & Connected cases 508
HEAD OFFICE, COBANK TOWERS, PALAYAM, AIRPORT ROAD,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BYITS
GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 509
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13364 OF 2022
PETITIONER/S:
1 THE PRAMADOM SERVICE CO-OPERATIVE BANK LIMITED NO.534
MALLASSERY P.O., PATHANAMTHITTA DISTRICT-689646,
REPRESENTED BY ITS SECRETARY.
2 THE KALANJOOR SERVICE CO-OPERATIVE BANK LIMITED
NO.1019,
KALANJOOR P.O., PATHANAMTHITTA DISTRICT-689645,
REPRESENTED BY ITS SECRETARY.
3 THE ATHIRUMKAL SERVICE CO-OPERATIVE SOCIETY LIMITED
NO.PT 54,
ALTHRUMKAL PO, PATHANAMTHITTA DISTRICT-689643,
REPRESENTED BY ITS SECRETARY.
4 THE KONNI REGIONAL CO-OPERATIVE BANK LIMITED NO.3833,
KONNI P.O., PATHANAMTHITTA DISTRICT-689647,
REPRESENTED BY ITS SECRETARY.
5 THE MALAYALAPUZHA SERVICE CO-OPERATIVE BANK LIMITED
NO.Q 378,
THAZHAM PO, PATHANAMTHITTA DISTRICT-689699,
REPRESENTED BY ITS SECRETARY.
6 THE ELAKOLLOOR SERVICE CO-OPERATIVE BANK LIMITED
NO.459,
ELAKOLLOOR P.O., PATHANAMTHITTA DISTRICT, REPRESENTED
BY ITS SECRETARY, -689644.
BY ADV SRI.O.D.SIVADAS
2025:KER
W.P(C)No.7053/2023 & Connected cases 510
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682018.
3 THE INCOME TAX OFFICER, (TDS),
AARATTUKULAKKARA COPLEX, A.N.PURAM, ALAPPUZHA
DISTRICT-686011.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033.
5 THE DEPUTY GENERAL MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., PATHANAMTHITTA
DISTRICT OFFICE, PATHANAMTHITTA, PIN-689645.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 511
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13410 OF 2022
PETITIONER/S:
MUVATTUPUZHA SAMOOHYA KSHEMA CO0OPERATIVE SOCIETY
LTD.NO..E.1348.
T B.ROAD, MUVATTUPUZHA P O, ERNAKULAM-686661,
REPRESENTED BY SECRETARY JANARDHANAN.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-11000
2 THE COMMISSIONER OF INCOME TAX
C R BUILDING, I S PRESS ROAD, KOCHI-682018.
3 INCOME TAX OFFICER
C R BUILDING, I S PRESS ROAD, KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
(ERSTWHILE THE ERNAKULAM DISTRICT CO-OPERATIVE BANK)
KAKKANAD P O, KOCHI-682030, REPRESENTED BY THE
GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 512
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 513
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13439 OF 2022
PETITIONER/S:
1 PATHANAMTHITTA SERVICE CO-OPERATIVE BANK LTD. NO. Q.
363,
PATHANAMTHITTA P.O., PIN-689645, REPRESENTED BY ITS
SECRETARY SMT. JANCY K.
2 THUMPAMON THAZHAM SERVICE CO-OPERATIVE BANK LIMITED
NO.134,
THUMPAMON THAZHAM P.O., ELAVAMTHITTA VIA,
PATHANAMTHITTA DISTRICT-689625, REPRESENTED BY ITS
SECRETARY, SMT. SHEEJA BHAI V.R.
3 MYLAPRA SERVICE CO-OPERATIVE BANK LIMITED NO.639,
H.O. MYLAPRA TOWN, MYLAPRA P.O., PATHANAMTHITTA-
689678. REPRESENTED BY ITS SECRETARY, SRI. JOSHUA
MATHEW.
4 AARANMULA SERVICE CO-OPERATIVE BANK LIMITED NO. A
703,
H.O. NAALKALIKKAL, NAALKALIKKAL P.O., AARANMULA, PIN-
689533, REPRESENTED BY ITS SECRETARY, SMT.
GAYATHRIDEVI V.R.
BY ADVS.
SHRI.A.KUMAR (SR.)
SHRI.P.J.ANILKUMAR
SMTG.MINI(1748)
SRI.P.S.SREE PRASAD
SHRI.JOB ABRAHAM
SHRI.AJAY V.ANAND
2025:KER
W.P(C)No.7053/2023 & Connected cases 514
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM-
682018.
4 THE KERALA STATE CO-OPERATIVE BANK LIMITED,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033,
REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA STATE CO-OPERTIVE BANK LIMITED,
(ERSTWHILE PATHANAMTHITTA DISTRICT CO-OPERATIVE
BANK), MYLAPRA ROAD, PATHANAMTHITTA-689645,
REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 515
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13492 OF 2022
PETITIONER/S:
1 THE AYALUR GRAMEENA CO-OPERATIVE CREDIT SOCIETY
LTD.NO 274
AYALUR P.O., PALAKKAD-678510 REPRESENTED BY ITS
SECRETARY HEMALATHAR
2 CHITTUR TALUK BUILDING & ROAD WORKERS CO-OPERATIVE
SOCIETY LTD NO.P 1320
KOLLENGODE P.O., PALAKKAD-678506, REPRESENTED BY ITS
SECRETARY MALATHY KRISHNAN
3 THE ELAVANCHERRY CO-OPERATIVE RURAL CREDIT SOCIETY
LTD NO. P 1248
PANANGATTIRI P.O., PALAKKAD-678506 REPRESENTED BY ITS
SECRETARY BABITHA B
4 THE GOVT. EMPLOYEES & AIDED SCHOOL EMPLOYEES CO-
OPERATIVE HOUSING SOCIETY LTD NO.P 1080
CHITTUR P.O., PALAKKAD-678101 REPRESENTED BY ITS
SECRETARY GIRISH M
5 THE PUDUNAGARAM PRIYADARSHINI VANITHA SAHAKARANA
SANGAM LTD NO. P 1327
KARIPODE P.O., PALAKKAD-678503 REPRESENTED BY ITS
SECRETARY SABITHA BALAKRISHNAN PB
6 THE KODUVAYUR CO-OPERATIVE URBAN CREDIT SOCIETY LTD
NO.773
KODUVAYUR, PALAKKAD-678501, REPRESENTED BY ITS
SECRETARY KRISHNAPRASAD P
7 THE KOLLENGODE AGRICULTURAL IMPROVEMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 516
CO-OPERATIVE SOCIETY LTD NO.P 1375, BLOCK OFFICE
ROAD, KOLLENGODE, PALAKKAD-678506 REPRESENTED BY ITS
SECRETARY SAJESH C
8 THE KOLLENGODE MERCHANTS CO-OPERATIVE SOCIETY LTD
NO.P 1193
BLOCK OFFICE ROAD, KOLLENGODE, PALAKKAD-678506
REPRESENTED BY ITS SECRETARY A RAMLA
9 NALLEPILLY CO-OPERATIVE RURAL CREDIT SOCIETY LTD NO.
P 1350
NALLEPILLY, PALAKKAD678553, REPRESENTED BY ITS
SECRETARY CHENTHAMARAKSHAN M
0 THE KOLLENGODE CO-OPERATIVE URBAN CREDIT SOCIETY LTD.
NO. F 1201
KOLLENGODE, PALAKKAD-678506 REPRESENTED BY ITS
SECRETARY KRISHNADASAN P
11 NENMARA AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY
LTD NO. P 1336
CONSUMER STORE BUILDING, M.G ROAD, NENMARA, PALAKKAD-
678508, REPRESENTED BY ITS SECRETARY K.G ELDHO
12 PALLASSANA RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO.
P 1227
CHIRAKKODE, PALLASSANA P.O., PALAKKAD-678505
REPRESENTED BY ITS SECRETARY INDHU P.C
13 PALLASSANA AGRICULTURAL IMPROVEMENT COOPERATIVE
SOCIETY LTD NO.P 1391
CHIRAKKODE, PALLASSANA P.O., PALAKKAD-678505,
REPRESENTED BY ITS SECRETARY RAJESH P
14 THE PERUVEMBA CO-OPERATIVE URBAN CREDIT SOCIETY LTD
NO. P 1243
PERUVEMBA P.O., PALAKKAD-678531, REPRESENTED BY ITS
SECRETARY SAJEEV N
15 PERUMATTY RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO. P
1211
VANDITHAVALAM, PALAKKAD-678534, REPRESENTED BY ITS
SECRETARY SUNIL S
2025:KER
W.P(C)No.7053/2023 & Connected cases 517
16 THE PUDUNAGARAM CO-OPERATIVE RURAL CREDIT SOCIETY
LTD. NO. P 1218
PUDUNAGARAM P.O., PALAKKAD-678503 REPRESENTED BY ITS
SECRETARY VIPIN DAS G
17 VADAVANNUR RURAL CO-OPERATIVE HOUSING SOCIETY LTD.
NO. F 1485
VADAVANNUR P.O., PALAKKAD-678504, REPRESENTED BY ITS
SECRETARY K RAMANADHAN.
18 VADAVANNUR RURAL CREDIT CO-OPERATIVE SOCIETY LTD. NO.
P 1430
VADAVANNUR P.O., PALAKKAD-678504, REPRESENTED BY ITS
SECRETARY RAMASESHAN.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI- 110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515,
2025:KER
W.P(C)No.7053/2023 & Connected cases 518
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 519
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13545 OF 2022
PETITIONER/S:
1 KOLLAM TALUK CO-OPERATIVE EMPLOYEE'S CO-OPERATIVE
SOCIETY LTD NO. Q 934,
1ST FLOOR, CHIDANAND TOWER, OPP. KUMAR HOSPITAL, HIGH
SCHOOL JN, CUTCHERRY P.O, KOLLAM- 13 REPRESENTED BY
ITS SECRETARY P.J. ANIL KUMAR.
2 URUKUNNU RURAL CO-OPERATIVE SOCIETY LTD NO.Q1468,
URUKUNNU P.O, KOLLAM- 691307 REPRESENTED BY ITS
SECRETARY S. JAYACHANDRAN.
3 PUTHOOR RURAL CO-OPERATIVE SOCIETY, LTD. NO.Q 1399,
PUTHOOR P.O, KOLLAM-691507 REPRESENTED BY ITS
SECRETARY NANDAKUMAR T.G.
4 KULATHUPUZHA PANCHAYAT AGRICULTURAL IMPROVEMENT CO-
OPERATIVE SOCIETY LTD. NO.Q.1606,
KULATHUPUZHA P.O, KOLLAM-691310, REPRESENTED BY ITS
SECRETARY IN CHARGE YESUDAS.A
5 THE OYUR RESIDENTS WELFARE CO-OPERATIVE SOCIETY, LTD.
NO.Q.1504,
OYUR P.O, KOTTARAKKARA, KOLLAM-691510 REPRESENTED BY
ITS SECRETARY ARATHY SURESH
6 KAREEPRA REGIONAL VANITHA CO-OPERATIVE SOCIETY LTD
NO. Q.1372,
KAREEPRA, KUZHIMATHICADU P.O, KOLLAM-691509
REPRESENTED BY ITS SECRETARY GEETHAKUMARY.S
7 THENMALA AGRICULTURE IMPROVEMENT COOPERATIVE SOCIETY,
LTD.NO.Q.1582,
2025:KER
W.P(C)No.7053/2023 & Connected cases 520
EDAMON P.O, PUNALUR, KOLLAM-691307 REPRESENTED BY ITS
SECRETARY SHEENA. S
8 KARAVALUR PANCHAYATH RESIDENTS SOCIAL WELFARE CO-
OPERATIVE SOCIETY LTD. NO.Q.1680,
KARAVALUR P.O, PUNALUR, KOLLAM-691333 REPRESENTED BY
ITS SECRETARY BEENA.R.
9 YEROOR PANCHAYATH AGRICULTURAL IMPROVEMENT CO-
OPERATIVE SOCIETY LTD, NO.Q.1543,
YEROOR P.O, KOLLAM-691312 REPRESENTED BY ITS
SECRETARY SREEJA.S.
10 VILAYIL RESIDENCE WELFARE CO-OPERATIVE SOCEITY LTD,
ATTINGAL P.O., THIRUVANANTHAPURAM-695101 REPRESENTED
BY ITS SECRETARY LETHA L.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI- 682018.
2025:KER
W.P(C)No.7053/2023 & Connected cases 521
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001.
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 522
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13615 OF 2022
PETITIONER/S:
1 KOYYAM SERVICE CO-OPERATIVE BANK LTD NO.L.L.87
KOYYAM P.O, KARIMBAM VIA, KANNUR 670 142 REPRESENTED
BY ITS SECRETARY ASHOKAN K
2 KOLITHATTU SERVICE CO-OPERATIVE BANK LTD NO C 406,
KOLITHATTU, KUTUPUZHA, KANNUR 670 706, REPREENTED BY
ITS SECRETARY NARAYANAN C.G
3 PAZHANGALAM SERVICE CO-OPERATIVE BANK LTD NO 3848,
NALLILA P.O, KOLLAM 695 515 REPRESENTED BY ITS
SECRETARY PATHMA V SINGH
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001
2025:KER
W.P(C)No.7053/2023 & Connected cases 523
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK,, NEW DELHI 110 001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018
4 THE KERALA STATE CO-OEPRATIVE BANK LTD
PB NO 6515.CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION) ,
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM 695 001
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 524
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13687 OF 2022
PETITIONER/S:
IRINJALAKUDA CITIZEN SOCIAL WELFARE SOCIETY, R.1488
22/179, NAKKARA BUILDING, HINDI PRACHAR MANDAL ROAD,
IRINJALAKUDA - 680121., REPRESENTED BY ITS SECRETARY
SHIJI ROMY.
BY ADVS.
SRI.V.M.KRISHNAKUMAR
SMT.P.R.REENA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM
- 682018.
3 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
CO - BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM -
695033, REPRESENTED BY ITS MANAGING DIRECTOR.
2025:KER
W.P(C)No.7053/2023 & Connected cases 525
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 526
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13693 OF 2022
PETITIONER/S:
ERNAKULAM JILLA VANITHA CO-OPERATIVE SOCIETY LTD. NO.
E-1356
REPRESENTED BY ITS SECRETARY, 32/1125-A4,
NARAYANEEYAM, CHATHANGATT ROAD, PALARIVATTOM, COCHIN-
680025.
BY ADVS.
SMT.SREEDEVI KYLASANATH
SRI.ACHUTH KYLAS
SRI.R.MAHESH MENON
SRI.DEAGO JOHN K
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI, PIN-110001.
2 THE CENTRAL BOARD OF DIRECTOR TAXES,
ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI-110001.
3 COMMISSIONER OF INCOME TAX (TDS),
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-682018.
2025:KER
W.P(C)No.7053/2023 & Connected cases 527
4 STATE OF KERALA
DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT,
REPRESENTED BY SECRETARY TO GOVERNMENT ,
THIRUVANANTHAPURAM-695001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
NEAR PRESS CLUB, THIRUVANANTHAPURAM-695001.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, THIRUVANANTHAPURAM-695033.
7 DEPUTY GENERAL MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., CREDIT
PROCESSING CENTRE, KAKKANAD, KOCHI-682030.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 528
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13707 OF 2022
PETITIONER/S:
VADAKKEKAD MULTIPURPOSE CO-OPERATIVE SOCIETY LTD NO.
R1160,
VADAKKEKAD.P.O, THRISSUR-679562, REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.V.A.VINOD
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION,MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
COCHIN-682018.
4 INCOME TAX OFFICER(TDS),
OFFICE OF THE INCOME TAX OFFICE(TDS), AAYAKAR BHAVAN,
SAKTHAN THAMPURAN NAGAR, THRISSUR-680001.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
2025:KER
W.P(C)No.7053/2023 & Connected cases 529
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
6 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO-
OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 530
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13720 OF 2022
PETITIONER/S:
PUNNAYUR PANCHAYATH SOCIAL WELFARE CO-OPERATIVE
SOCIETY LTD.
R 1511, EDAKKAZHIYOOR, THRISSUR - 680 515,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.V.A.VINOD
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
COCHIN - 682 018.
4 INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR
BHAVAN, SAKATHAN THAMPURAN NAGAR, THRISSUR - 680 001.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
2025:KER
W.P(C)No.7053/2023 & Connected cases 531
PB.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO-
OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM
- 695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 532
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13741 OF 2022
PETITIONER/S:
1 MUTHUKULAM SERVICE CO-OPERATIVE BANK LTD.
MUTHUKULAM SOUTH P.O., ALAPUZHA- 690506 REPRESENTED
BY ITS SECRETARY SUBHASH KUMAR N
2 KUMARAPURAM SERVICE CO-OPERATIVE BANK LTD NO 2147,
HEAD OFFICE THAMALLACKAL P.O., ALAPUZHA-690549,
REPRESENTED BY ITS SECRETARY BAIJU RAMESH
3 MAHADEVIKAD SERVICE CO-OPERATIVE BANK LTD
MAHADEVIKKAD P.O., KARTHIKAPPALLY, ALAPUZHA-690516,
REPRESENTED BY ITS SECRETARY SASIKALAK.
4 RAMAPURAM NORTH AISWARIYAPRADAYANI SERVICE CO-
OPERATIVE BANK LTD, NO 1493
KEERIKAD P.O, ALAPUZHA-690508, REPRESENTED BY ITS
SECRETARY G. RATNAKUMARI AMMA
5 PALLIPAD SERVICE CO-OPERATIVE BANK LTD, NO 1744,
KOTTAKKAKAM, MUTTOM P.O., HARIPAD, ALAPUZHA-690514
REPRESENTED BY ITS SECRETARY RAJALAKSHMI S.
6 CHINGOLI SERVICE CO-OPERATIVE BANK LTD, NO 12,
CHINGOLI P.O., ALAPUZHA- 690532, REPRESENTED BY ITS
SECRETARY YAMINE P.
7 KANDALLORE FARMERS SERVICE CO-OPERATIVE BANK LTD, NO
1410
KANDALLORE P.O. ALAPPUZHA-690535 MANAGING DIRECTOR
MINIBHANU R.
2025:KER
W.P(C)No.7053/2023 & Connected cases 533
8 PUTHIYAVILA SERVICE CO-OPERATIVE BANK LTD.NO631,
PATTOLIMARKET P.O., ALAPPUZHA-690531 REPRESENTED BY
ITS SECRETARY HARIKRISHNAN R
9 CHINGOLI SERVICE CO-OPERATIVE BANK LTD, NO 1887,
CHINGOLI P.O., ALAPPUZHA- 690532 REPRESENTED BY ITS
SECRETARY MANU DIVAKARAN
10 CHEPPAD SERVICE CO-OPERATIVE BANK LTD,NO A 702,
CHEPPAD P.O. ALAPUZHA-690507 REPRESENTED BY ITS
SECRETARY JAYAN R.
11 HARIPAD SERVICE CO-OPERATIVE BANK LTD NO 3354,
HARIPAD P.O., ALAPPUZHA-690514 REPRESENTED BY ITS
SECRETARY PADMAKMAR M.
12 KARTHIKAPPALY SERVICE CO-OPERATIVE BANK LTD NO 2301,
KARTHIKAPPALY PO, ALAPPUZHA- 690516 REPRESENTED BY
ITS SECRETARY
13 KARUVATTA SERVICE CO-OPERATIVE BANK LTD , NO 1742,
KARUVATTA PO, ALAPPUZHA, 690517 REPRESENTED BY ITS
SECRETARY
14 GOVT. EMPLOYEES CO.OP. BANK LTD, NO A 245,
KAYAMKULAM PO, ALAPPUZHA 690502 REPRESENTED BY ITS
SECRETARY R MURALI
15 KAYAMKULAM VILLAGE SERVICE CO-OPERATIVE BANK LTD, NO
1596,
PERINGALA P.O. ALAPPUZHA 690559 REPRESENTED BY ITS
SECRETARY BIJU R.
16 KARUVATTA SERVICE CO-OPERATIVE BANK LTD NO 2145,
KARUVATTA P.O., ALAPUZHA-690517 REPRESENTED BY ITS
SECRETARY DEEPA C.K.
17 PERUMPALLY SERVICE CO-OPERATIVE BANK LTD NO 1746,
VALIYAZHEECKAL P.O., ALAPUZHA- 690535, REPRESENTED BY
ITS SECRETARY S CHINTU
18 PULLIKANAKKU SERVICE CO-OPERATIVE BANK LTD, NO 781,
PULLIKANAKU P.O., ALAPUZHA- 690537, REPRESENTED BY
ITS SECRETARY KALADEVI S.
2025:KER
W.P(C)No.7053/2023 & Connected cases 534
19 KAPPIL SERVICE CO-OPERATIVE BANK LTD, NO 1594,
KAPPIL EAST, KRISHNAPURAM P.O. ALAPUZHA-690533
REPRESENTED BY ITS SECRETARY BEENA P.
20 PUTHUPPALLY VILLAGE SERVICE CO-OPERATIVE BANK LTD, NO
1900,
HEAD OFFICE PUTHUPPALLY PUTHUPPALLY P.O., ALAPUZHA-
690527 REPRESENTED BY ITS SECRETARY P. MANILAL
21 MUTHUKULAM SERVICE CO-OPERATIVE BANK LTD NO 1741,
MUTHUKULAM P.O., ALAPUZHA- 690508 REPRESENTED BY ITS
SECRETARY SARITHA YESODHARAN
22 KAYAMKULAM SAHAKARANA BANK LTD, NO A 421,
PALACE ROAD, KRISHNAPURAM P.O., ALAPUZHA-690533
REPRESENTED BY ITS SECRETARY AJITHAKUMARI
23 PALLIPPAD SERVICE CO-OPERATIVE SOCIETY LTD NO 1777,
PALLIPPAD NORTH, PALLIPPAD P.O., ALAPUZHA-690512
REPRESENTED BY ITS SECRETARY SAAJIDA A.
24 ALAPPEY DISTRICT TRAVANCORE DEVASWOM BOARD EMPLOYEES
CO. OPERATIVE SOCIETY LTD NO A 297
HARIPAD P.O., ALAPUZHA-690514 REPRESENTED BY ITS
SECRETARY ASHOKKUMAR G.
25 HARIPAD GOVERNMENT SERVANT'S CO-OPERATIVE SOCEITY
LTD, NO A 284
HARIPAD P.O., ALAPUZHA - 690514, REPRESENTED BY ITS
SECRETARY S. GIRIJA
26 KARTHIKAALLY RURAL WELFARE CO-OPERATIVE SOCIETY LTD,
NO A 1193,
PUTHIYAVILA NORTH, PUTHIYAVILA P.O., ALAPUZHA -
690531 REPRESENTED BY ITS SECRETARY SUKANYA SREEKUMAR
27 MELPADOM SERVICE CO-OPERATIVE SOCIETY LTD NO 182,
MELPADOM P.O., MANNAR VIA ALAPUZHA-689627 REPRESENTED
BY ITS SECRETARY ANU SHIBU
28 KARUVATTA NORTH SERVICE CO-OPERATIVE SOCIETY LTD, NO
1237,
KARUVATTA NORTH P.O., ALAPUZHA-690517, REPRESENTED BY
2025:KER
W.P(C)No.7053/2023 & Connected cases 535
ITS SECRETARY.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED
BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI- 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM- 695001
BY ADVS.
SRI.KRISHNADAS P.NAIR, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
2025:KER
W.P(C)No.7053/2023 & Connected cases 536
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 537
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13746 OF 2022
PETITIONER/S:
ERATHU SERVICE CO-OPERATIVE BANK NO. 2781,
CHURAKODU P.O., ADOOR, PATHANAMTHITTA 691 551,
REPRESENTED BY ITS SECRETARY, GEETHAKUMARI, P., AGED
52 YEARS, W/O. PRADEEP KUMAR, CHURAKODE P.O., ADOOR,
PATHANAMTHITTA 691 551.
BY ADV SRI.SERGI JOSEPH THOMAS
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 11001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I. S PRESS ROAD,
KOCHI 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF
INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIR,
THIRUVANANTHAPURAM 695 003.
2025:KER
W.P(C)No.7053/2023 & Connected cases 538
5 INCOME TAX OFFICER,
(TDS), THIRUVANANTHAPURAM , 3RD FLOOR, AAYAKAR
BHAVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003.
BY ADVS.
SRI.KRISHNADAS P.NAIR, SENIOR PANEL COUNSEL
SRI.CHRISTOPHER ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 539
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13751 OF 2022
PETITIONER/S:
1 PANNIVIZHA SERVICE CO-OPERATIVE BANK LTD. NO. 891,
PANNIVIZHA, ADOOR P.O., ADOOR TALUK, PATHANAMTHITTA-
691523, REPRESENTED BY ITS SECRETARY, M.J. BABU, S/O.
DHARMAPALAN, AGED 52 YEARS, DEEPAM HOUSE, PANNIVIZHA,
ADOOR TALUK, PATHANAMTHITTA-691523.
2 PARAKODE SERVICE CO-OPERATIVE BANK LIMITED NO. 821,
PARAKODE P.O., ADOOR, PATHANAMTHITTA-691554,
REPRESENTED BY ITS SECRETARY, RAJASHREE, W/O.
SASIDHARA KURUP, AGED 57 YEARS, VYSHAGAM HOUSE,
PARAKODE, ADOOR, PATHANAMTHITTA -691554.
3 NEDUMON SERVICE CO-OPERATIVE BANK LIMITED NO.2720,
NEDUMON P.O., PATHANAMTHITTA-691556, REPRESENTED BY
ITS SECRETARY K.P. HUSSAIN, AGED 56 YEARS, S/O.
ZAKEER RAWTHER, SHAHANA MANZIL, NEDUMON P.O.,
EZHAMKULAM, PATHANAMTHITTA-691556.
4 PERINGANADU SERVICE CO-OPERATIVE BANK NO. 2706,
PERINGANADU P.O., ADOOR, PATHANAMTHITTA-691551,
REPRESENTED BY ITS SECRETARY, BIJI B. KRISHNAN, AGED
51 YEARS, W/O.D. UDAYAN, ELAYASSERYIL, KUNNATHUMKARA,
PERINGANADU P.O., ADOOR, PATHANAMTHITTA-691551.
5 KODUMON SERVICE BANK NO.2592,
KODUMON P.O., ADOOR, PATHANAMTHITTA-691555,
REPRESENTED BY ITS SECRETARY, T.K. TULASIDHARAN, AGED
51 YEARS, S/O. A. KOCHURAMAN, THULASI BHAVAN,
AICKADU, KODUMON P.O., ADOOR, PATHANAMTHITTA-691555.
6 PAZHAKULAM PADINJARU CO-OPERATIVE BANK NO. P.T.95,
2025:KER
W.P(C)No.7053/2023 & Connected cases 540
PAZHAKULAM P.O., ADOOR, PATHAMAHTITTA-691527,
REPRESENTED BY ITS SECRETARY, P. BEENAKUMARI, AGED 49
YEARS, W/O. HARSHA KUMAR, PERUMANA HOUSE, PAZHAKULAM
P.O., ADOOR, PATHANAMTHITTA-691527.
7 PARANTHAL SERVICE CO-OPERATIVE BANK NO.A202,
PARANTHAL P.O., PATHANAMTHITTA-689501, REPRESENTED BY
ITS SECRETARY, GEETHADEVI, AGED 57 YEARS, W/O. K.
MOHANAN, SREENIKETAN, PERUMPULLIKAL, MANNAM NAGAR
P.O., PANDALAM, PATHANAMTHITTA-689501.
8 ANGADICKAL SERVICE CO-OPERATIVE BANK NO.1127,
ANGADICKAL P.O., KODUMON, PATHANAMTHITTA-691555,
REPRESENTED BY ITS SECRETARY, SHEEJA G., AGED 45
YEARS, W/O. N. VIJAYAKUMAR, KALLUMPURATHU THEKKETHIL,
ANGADICKAL P.O., KODUMON, PATHANAMTHITTA-691555.
9 MANNADY SERVICE CO-OPERATIVE BANK LIMITED NO.3849,
MANNADY P.O., KADAMPANADU, PATHANAMTHITTA-691530,
REPRESENTED BY ITS SECRETARY, ANILKUMAR K., AGED 51
YEARS, S/O. KUTTAN PILLAI, EDASSERU AZHIKATHU HOUSE,
MANNADY P.O., KADAMPANADU, PATHANAMTHITTA DISTRICT-
691530.
10 KADAMPANDU NORTH SERVICE CO-OPERTIVE BANK NO.55,
KADAMPANADU P.O., PATHANAMTHITTA-691552, REPRESENTED
BY ITS SECRETARY, ANIL SAMUEL, AGED 40 YEARS, S/O.
SAMUEL, ANIL BHAVAN, KADAMPANADU P.O.,
PATHANAMTHITTA-691552.
11 PANDALAM SERVICE CO-OPERATIVE BANK LIMITED NO.704,
PANDALAM P.O., PATHANAMTHITTA-689501, REPRESENTED BY
ITS SECRETARY IN CHARGE, ANILKUMAR P.G., AGED 57
YEARS, S/O. GOPALAPILLAI, PARAPALLIKANDATHIL,
MANGARAM P.O., PANDALAM, PATHANAMTHITTA-689501.
12 ADOOR TALUK SENIOR CITIZENS SERVICE CO-OPERATIVE
SOCIETY
PT 268, PARAKODE P.O., PATHANAMTHITTA-691554,
REPRESENTED BY ITS SECRETARY, S. SARITHA, AGED 33
YEARS, W/O. RANJARAJ, AISWARYA HOUSE, PUTHUSHERRY
BHAGOM, ERATHU P.O., PATHANAMTHITTA-691551.
13 THATTAYIL SERVICE CO-OPERATIVE BANK LIMITED NO.442,
2025:KER
W.P(C)No.7053/2023 & Connected cases 541
KEEZHUKUZHI P.O., PATHANAMTHITTA-689502, REPRESENTED
BY ITS SECRETARY, SREEDEVI C., AGED 47 YEARS, W/O.
AJITHKUMAR, NEDUMPARAMBIL, BHAGAVATHIKUNNU,
KEEZHUKUZHI P.O., PATHANAMTHITTA-689502.
14 THUMPAMOM SERVICE CO-OPERATIVE BANK LIMITED NO.154,
THUMPAMON P.O., PATHANAMTHITTA-689502, REPRESENTED BY
ITS SECRETARY, OMANA M., AGED 53 YEARS, W/O. BABU
SAMUEL, VILAVANTAGUE HOUSE, THUMPAMOM THAZHOM P.O.,
PATHANAMTHITTA-689625.
15 KADAMPANAD SERVICE CO-OPERATIVE BANK LIMITED NO.59,
KADAMPANAD SOUTH P.O., PATHANAMTHITTA-691523,
REPRESENTED BY ITS SECRETARY, R. SURESH KUMAR, AGED
57 YEARS, S/O. RAMAKRISHNA PILLAI, KUMBAZHATHEKKETHIL
HOUSE, KADAMPANAD SOUTH P.O., PATHANAMTHITTA-691523.
BY ADV SRI.K.SHAJ
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 THE ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF
INCOME TAX, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003.
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
2025:KER
W.P(C)No.7053/2023 & Connected cases 542
KOWDIAR, THIRUVANANTHAPURAM-695003.
6 THE KERALA CO-OPERATIVE BANK LIMITED PB NO. 6515,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 543
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13760 OF 2022
PETITIONER/S:
1 THE KASARAGOD DISTRICT POSTAL EMPLOYEES CO-OPERATIVE
SOCIETY LTD NO. S 53
KASARAGOD -671121, REPRESENTED BY ITS SECRETARY BABY
PRASANNA.
2 KASARAGOD DISTRICT TELECOM & BSNL EMPLOYEES CO-
OPERATIVE SOCIETY LTD. NO.S 26,
TELEPHONE BHAVAN, KASARAGOD-671121, REPRESENTED BY
ITS SECRETARY PRASEENA M.
3 CANARA BANK EMPLOYEES CO-OPERATIVE SOCIETY LTD.
NO.4355,
MAIN ROAD, KANHANGAD, KASARAGOD -671315, REPRESENTED
BY ITS SECRETARY, JAYACHANDRAN T.K.
4 KUNDAMKUZHY AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD. NO.S 369,
KUNDAMKUZHY P.O., CHENGALA (VIA), KASARAGOD-671541,
REPRESENTED BY ITS SECRETARY MADHUSOODANAN G.
5 KASARAGOD RUBBER FARMER'S WELFARE CO-OPERATIVE
SOCIETY LTD. NO. S 429,
KUTTIKOL P.O., KASARAGOD -671541, REPRESENTED BY ITS
SECRETARY SHOBHA K.
6 THE CHATTANCHAL CO-OPERATIVE URBAN SOCIETY LTD.
NO.329,
THEKKIL P.O., CHENGALA VIA, KASARAGOD -671541,
REPRESENTED BY ITS SECRETARY ANANDAN E.
7 THE KASARAGOD PUBLIC SERVANTS CO-OPERATIVE SOCIETY
2025:KER
W.P(C)No.7053/2023 & Connected cases 544
LTD. NO.C 290,
H.O.CHANDRAGIRI ROAD, KASARAGOD-671121, REPRESENTED
BY ITS SECRETARY RAGHAVAN K.
8 THE KASARAGOD CO-OPERATIVE URBAN SOCIETY LTD. NO.S
333,
VIDYANAGAR P.O., KASARAGOD-671123, REPRESENTED BY ITS
SECRETARY SREEHARI V.
9 HOSDURG PUBLIC SERVANTS CO-OPERATIVE SOCIETY LTD. NO.
C 291,
KANHANGAD P.O., KASARAGOD -671315, REPRESENTED BY ITS
SECRETARY GAYATHRI A.T.V.
10 THE KASARAGOD SCHOOL TEACHERS CO-OPERATIVE SOCIETY
LTD. NO. S 442,
FORT ROAD, KASARAGOD-671121, REPRESENTED BY ITS
SECRETARY VINEETH T.
11 KERALA STATE ROAD TRANSPORT EMPLOYEES CO-OPERATIVE
SOCIETY LTD. NO.S 12,
KASARAGOD-671121, REPRESENTED BY ITS SECRETARY
GOPALAKRISHNAN E.K.
12 THE KUTTIKOL URBAN CO-OPERATIVE SOCIETY LTD. NO. S
347,
SANKARAMPADY P.O., CHENGALA VIA, KASARAGOD -671541,
REPRESENTED BY ITS SECRETARY TINCY P.T.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY, DEPARTMENT OF REVENUE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 545
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI - 110001,
REPRESENTED BY ITS CHAIRMAN.
3 PFINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, KERALA REGION,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDING, I.S PRESS ROAD, KOCHI - 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB. NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695001.
BY ADVS.
SRI.NAVANEETH.N.NATH
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 546
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13761 OF 2022
PETITIONER/S:
1 OORUTTAMVBALAM SERVICE CO-OPERATIVE BANK LTD.
OORUTTAMBALAM P.O., THIRUVANANTHAPURAM - 695 507
REPRESENTED BY ITS SECRETARY SHAMJI S.L.
2 VAIPUR SERVICE CO-OPERATIVE BANK LIMITED
A-203, III/395, VAIPUR, PATHANAMTHITTA - 689 588
REPRESENTED BY ITS SECRETARY MUHAMMED ISMAIL.
3 ANICADU SERVICE CO-OPERATIVE BANK LTD.
NO.A 113, NOOROMMAVU P.O., PUNNAVELLY, ANICADU,
PATHANAMTHITTA - 689 589, REPRESENTED BY ITS
SECRETARY SHAIJU C.ALEX.
4 P;ATHIYOORKALA SERVICE CO-OPERATIVE BANK LTD.
NO.2626, KEEICKAD P.O., KAYAMKULAM, ALAPPUZHA - 690
503 REPRESENTED BY ITS SECRETARY MAHESHWARI AMMAL V.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
2025:KER
W.P(C)No.7053/2023 & Connected cases 547
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE ,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDING, I S PRESS ROAD, KOCHI - 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS
CHIEF EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM - 695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 548
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13781 OF 2022
PETITIONER/S:
1 THE KADAPRA SERVICE CO-OPERATIVE BANK LTD. NO. 186,
VALANJAVATTAM P.O, THIRUVALLA, PATHANAMTHITTA
DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 104.
2 THE MUNDIAPPALLY SERVICE CO-OPERATIVE BANK LIMITED
NO. A9,
MUNDIAPPALLY, PATHANAMTHITTA DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN 689 581.
3 THE KOIPURAM SERVICE CO-OPERATIVE BANK LIMITED NO.
875,
KADAPRA P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY
ITS SECRETARY , PIN 689 104.
4 THE THRUVALLA TALUK MERCHANT'S CO-OPERATIVE SOCIETY
LIMITED,
NO. PT 189, THIRUVALLA, PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN 689 101.
5 THE THOTTAPUZHASSERY SERVICE CO-OPERATIVE BANK
LIMITED,
NO. A 283, VARAYANNOOR P.O, PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN 689 548.
6 THE THOTTAPUZHASSERY REGIONAL SERVICE CO-OPERATIVE
BANK LIMITED NO. 595,
MARAMON P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN 689 549.
7 THE ERAVIPEROOR SERVICE CO-OPERATIVE BANK LIMITED NO.
1929,
2025:KER
W.P(C)No.7053/2023 & Connected cases 549
ERAVIPEROOR P.O, PATHANAMTHITTA DISTRICT, REPRESENTED
BY ITS SECRETARY, PIN 689 542.
8 THE KUTTAPUZHA SERVICE CO-OPERATIVE BANK LIMITED NO.
1581,
THIRUVALLA P.O, PATHANAMTHITTA DISTRICT, REPRESENTED
BY ITS SECRETARY, PIN 689 103.
9 THE KAVIYOOR SERVICE CO-OPERATIVE BANK LIMITED NO. A
707,
KAVIYOOR P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN 689 582.
10 THE THIRUVALLA SERVICE CO-OPERATIVE BANK LIMITED NO.
1307,
KAVUMBHAGOM, PATHANAMTHITTA DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN 689 102.
11 THE MUTHOOR SERVICE CO-OPERATIVE BANK LIMITED NO.3118
MUTHOOR, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS
SECRETARY, PIN - 689 107.
12 THE TRACO CABLE EMPLOYEES CO-OPERATIVE SOCIETY
LIMITED NO.PT 121
CHUMATHRA P. O., PATHANAMTHITTA DISTRICT, REPRESENTED
BY ITS SECRETARY, PIN - 689 103.
13 THE VALLAMKULAM SERVICE CO-OPERATIVE BANK LIMITED
NO.2163
VALLAKULAM, PATHANAMTHITTA DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN - 689 541.
14 THE PULLAD SERVICE CO-OPERATIVE BANK LIMITED NO.195
PULLAD P. O., PATHANAMTHITTA DISTRICT, REPRESENTED BY
ITS SECRETARY, PIN - 689 531.
15 THE PERINGARA SERVICE CO-OPERATIVE BANK LIMITED NO.A-
790
CHATHANKARY P. O., PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN - 689 112.
16 THE KURIANOOR SERVICE CO-OPERATIVE SOCIETY LIMITED
NO.PT 115
KURIANNOOR P. O., PATHANAMTHITTA DISTRICT,
2025:KER
W.P(C)No.7053/2023 & Connected cases 550
REPRESENTED BY ITS SECRETARY, PIN - 689550.
17 THE KUTTOOR SERVICE CO-OPERATIVE BANK LIMITED NO.A708
KUTTOOR, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS
SECRETARY, PIN - 689 106.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA
X
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I. S. PRESS ROAD,
ERNAKULAM, PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
AARATTUKULAKKARA COPLEX, A. N. PURAM, ALAPUZHA
DISTRICT - 686011.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033.
5 THE DEPUTY GENERAL MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD, PATHANAMTHITTA
DISTRICT OFFICE, PATHANAMTHITTA, PIN-689 645.
BY ADVS.
SHRI.T.C.KRISHNA, SENIOR PANEL COUNSEL
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 551
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13797 OF 2022
PETITIONER/S:
1 THIRUVANANTHAPURAM DISTRICT MERCANTILE CO-OPERATIVE
SOCIETY
LTD NO T 1733, T.C 24/1082 THYCAUD P.O,
THIRUVANANTHAPURAM 695 014 REPRESENTED BY ITS
SECREETARY BINDU PAULOSE
2 THE BADIADUKA PANCHAYATH AGRICULTURIST
WELFARE CO-OPERATIVE SOCIETY LTD NO. S 421, BADIADKA
P.O, PERDALA, KASARAGOD 671 551 REPRESENTED BY ITS
SECRETARY SHOBHA P
3 KASARAGOD PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD
NO S 422, PADHOOR SHOPING COMPLEX, NEW BUS STAND,
KASARAGOD 671 121 REPRESENTED BY ITS SECRETARY SOUMYA
E K
4 THE KARADKA AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD NO. S 391,
MULLERIA P.O, KASARAGOD 671 543 REPRESENTED BY ITS
SECRETARY RATHEESHAN K
5 PUNALUR RURAL CO-OPERATIVE SOCIETY LTD
NO Q 1466, THOLICODE P.O, PUNALUR, KOLLAM 691 333
REPRESENTED BY ITS SECRETARY PRAKASH B
6 OACHIRA PANCHAYATH MULTI PURPOSE SAHAGARANA SANGAM
LTD, NO Q 1676,
OCHIRA P.O, KOLLAM 690 526 REPRESENTED BY ITS
SECRETARY ASHA R
7 KARUNAGAPPALLY RURAL CO-OPERATIVE SOCIETY LTD NO. Q
2025:KER
W.P(C)No.7053/2023 & Connected cases 552
1463,
CHITTUMOOLA, EDAKKULANGARA P.O, KARUNAGAPPALLY,
KOLLAM 690 523 REPRESENTED BY ITS SECRETARY
BEENAKUMARI S
8 KALPATHUR AGRICULTURISTS AND WORKERS DEVELOPMENT AND
WELFARE
CO-OPERATIVE SOCIETY LTD NO D 3033, KALPATHUR P.O,
KOZHIKODE 673 524 REPRESENTED BY ITS SECRETARY
ASHITHA P.K
9 NILAMEL AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
LTD
NO 1599, NILAMEL P.O, KOLLAM 691 535 REPRESENTED BY
ITS SECRETARY V BINU
10 CHITHARA RURAL CO-OPERATIVE SOCIETY LTD
NO Q 1378, CHITHARA P.O, KOTTARAKKARA, KOLLLAM 691
559 REPRESENTED BY ITS SERETARY SANDHYA K.R
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOK NEW DELHI 110 001
REPRESENTED BY ITS CHAIRMAN
2025:KER
W.P(C)No.7053/2023 & Connected cases 553
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOHI 682 018
4 THE KERALA STATE CO-OEPRATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM 695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 554
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13833 OF 2022
PETITIONER/S:
ANANTHAPURAM CO-OPERATIVE SOCIETY LTD.NO.T.184
H.O.KAITHAMUKKU, THIRUVNANTHAPURAM-695 024
BY ADVS.
SRI.GEORGE POONTHOTTAM (SR.)
SMT.NISHA GEORGE
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.,
THIRUVANANATHAPURAM,PIN-695 003
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI,PIN-110 001
3 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI,PIN-110 001
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
D.P.I.JUNCTION, JAWAHAR SAHAKARANA BHAVAN,
THIRUVANANTHAPURAM-695 014
2025:KER
W.P(C)No.7053/2023 & Connected cases 555
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION , GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM,PIN-695 001
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM,PIN-695 033
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 556
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13891 OF 2022
PETITIONER/S:
MANANAK WELFARE CO-OPERATIVE SOCIETY
MANANAK, PERUMKULAM.P.O, THIRUVANANTHAPURAM DISTRICT-
695102. REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.B.KRISHNA MANI
SMT.N.V.SANDHYA
SMT.DHANUJA M.S
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682018.
4 THE ADDITIONAL COMMISSIONER OF INCOME TAX
2025:KER
W.P(C)No.7053/2023 & Connected cases 557
TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR,
THIRUVANANTHAPURAM-695003.
5 IINCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM-695003.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
P B NO.6615, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033.
7 THE STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001.
8 THE MANAGER,
THE KERALA STATE CO-OPERATIVE BANK LTD, KADAKKAVOOR
BRANCH, THIRUVANANTHAPURAM DISTRICT-695309.
BY ADV SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 558
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13895 OF 2022
PETITIONER/S:
1 ELAMPARA VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1139
ELAMPARA P.O., KANNUR-670595 REPRESENTED BY ITS
SECRETARY RADHA.K
2 KOLAYAD PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY LTD
NO. C 1634,
KOLAYAD P.O., KANNUR-670650, REPRESENTED BY ITS
SECRETARY JISHA T
3 CLAPPANA PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD
NO. Q 1368,
PRAYAR (S), ALUMPEEDIKA P.O., KOLLAM-690547
REPRESENTED BY ITS SECRETARY REJINA BEEGAM C.S
4 PERINGATHUR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD
NO. C 1393,
PERINGATHUR P.O., KANNUR-670675 REPRESENTED BY ITS
SECRETARY MAHIJA M.K
5 MONTHAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO.
C 1848,
MONTHAL, OLAVILAM P.O., KANNUR-673313 REPRESENTED BY
ITS SECRETARY BINISHA.P
6 EDAKKAD PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD
NO. C 1227,
KUTTIKKAKAM, KANNUR-670663 REPRESENTED BY ITS
SECRETARY SEETHA.M.V
7 CHENDAYAD VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1378,
2025:KER
W.P(C)No.7053/2023 & Connected cases 559
CHENDAYAD P.O., KANNUR-670692 REPRESENTED BY ITS
SECRETARY SREEJA.K
8 PERINGALAM VANITHA CO-OPERATIVE SOCIETY LTD NO. NO. C
1315,
PULLOOKKARA, MUKKILPEEDIKA, KANNUR-670 672
REPRESENTED BY ITS SECRETARY MAHIJA P
9 PANOOR TOWN VANITHA SERVICE CO-OPERATIVE SOCIETY LTD
NO. C 1668,
PANOOR P.O., KANNUR. 670 692 REPRESENTED BY ITS
SECRETARY SOYA O
10 MATTOOL PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD
NO. C 1404,
MADAKKARA, IRINAVE P.O., KANNUR-670 301 REPRESENTED
BY ITS SECRETARY INDIRA M.V
11 NEW MAHE PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD
NO. 1347,
PERINGADI P.O., KANNUR 673312,REPRESENTED BY ITS
SECRETARY PREMALATHA M
12 KILIANTHARA VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1676,
KILIANTHARA P.O., VALLITHODE, KANNUR-670706
REPRESENTED BY ITS SECRETARY JISHA C
13 ARALAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1706,
ARALAM P.O., KANNUR-670704 REPRESENTED BY ITS
SECRETARY LEENA M.C
14 NELLUNNI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1589,
NELLUNNI, MATTANUR P.O., KANNUR- 670702 REPRESENTED
BY ITS SECRETARY KANAKAVALLI K.K
15 VALLITHODE VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1738,
PERINKARY KAVALA, VALLITHODE P.O., KILIANTHARA,
KANNUR-670706 REPRESENTED BY ITS SECRETARY LOVELY
JACOB
16 PERINCHERI VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1408,
2025:KER
W.P(C)No.7053/2023 & Connected cases 560
KAYANI P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY JYODHI K.M
17 KEEZHUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1591,
KEEZHUR P.O., IRITTY, KANNUR-670703 REPRESENTED BY
ITS SECRETARY LEENA.T
18 PUNNAD VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1607,
PUNNAD P.O., KANNUR-670703 REPRESENTED BY ITS
SECRETARY UMA P.A
19 PADIYOOR-KALLIAD VANITHA CO-OPERATIVE SOCIETY LTD NO.
C 1194,
KALLIAD P.O., KANNUR-670593 REPRESENTED BY ITS
SECRETARY SHERLY P
20 KARIKKOTTAKARI VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1734,
KOOMANTHODE P.O., KANNUR-670704 REPRESENTED BY ITS
SECRETARY SHEEJA K.R
21 ARALAM PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD
NO. 1185,
KEEZHAPALLY P.O., KANNUR-670704 REPRESENTED BY ITS
SECRETARY SAROJINI P.K
22 EDOOR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1655,
EDOOR, PAYAM P.O., KANNUR-670704 REPRESENTED BY ITS
SECRETARY JANCY K.J
23 PAYAM PANCHAYATH PRIYADARSHINI VANITHA SAHAKARANA
SANGAM LTD. NO. C 1654,
PAYAM P.O., KOLIKKADAVU, KANNUR-670704 REPRESENTED BY
ITS SECRETARY PREETHA.K
24 THILLENKERY VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1178,
THILLENKERY, KANNUR-670702 REPRESENTED BY ITS
SECRETARY MINI K
25 THE KODOLIPRAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1568,
PATTANUR P.O., KANNUR-670595 REPRESENTED BY ITS
SECRETARY SARASWATHY К
2025:KER
W.P(C)No.7053/2023 & Connected cases 561
26 PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1569,
KOTOLIPRAM, PATTANNUR P.O., KANNUR-670595 REPRESENTED
BY ITS SECRETARY VANAJAKUMARI P.V
27 THERUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1323,
KANAD, EDAYANNUR P.O., KANNUR-670595 REPRESENTED BY
ITS SECRETARY ANITHA.M
28 KOMATH KUNNUMBRAM VANITHA CO-OPERATIVE SOCIETY LTD
NO. C 1665,
KOMATH KUNNUMBRAM, MOWANCGERY P.O., KANNUR-670613
REPRESENTED BY ITS SECRETARY SEENA M.C
29 THE PATTANUR VILLAGE VANITHA CO-OPERATIVE SOCIETY LTD
NO. C 1254,
CHITHRARI, PATTANUR P.O., KANNUR-670695 REPRESENTED
BY ITS SECRETARY THANKAMANI M.V
30 CHEMBILODE PANCHAYATH VANITHA COOPERATIVE SOCIETY LTD
NO. C 1406,
KOYYODE P.O., KANNUR-670621 REPRESENTED BY ITS
SECRETARY PRAMEELA A
31 PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY, KEEZHALLUR
LTD NO. C 1710,
KEEZHALLUR P.O., KANNUR-670612 REPRESENTED BY ITS
SECRETARY BINDHYA M
32 VILAKOTTUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1699,
VILAKOTTUR P.O., KANNUR-670693 REPRESENTED BY ITS
SECRETARY PRAJEELA T
33 KOODALI VILLAGE VANITHA CO-OPERATIVE SOCIETY LTD NO.
C 1255,
H.O. CHALODE, EDAYANNUR P.O., KANNUR-670595
REPRESENTED BY ITS SECRETARY ANITHA K
34 VELLIYAMPARAMBA VANITHA CO-OPERATIVE SOCIETY LTD NO.
C 1877 ,
PRNSS COLLEGE P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY SHEENA V
2025:KER
W.P(C)No.7053/2023 & Connected cases 562
35 POYILOOR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1691,
THUVAKKUNNU, POYILOOR P.O., KANNUR-670693 REPRESENTED
BY ITS SECRETARY REENA A
36 THALASSERY BLOCK VANITHA CO-OPERATIVE SOCIETY LTD NO.
C 978,
PACHAPOIKA P.O., KUTHUPARAMBA, KANNUR-670643
REPRESENTED BY ITS SECRETARY NITHA.P
37 PATTIAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1138,
PATTIAM-PUTHIYATHERU, PATHAYAKKUNNU P.O., KANNUR-
670691 REPRESENTED BY ITS SECRETARY PRABHA V
38 KEEZHALLUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1166,
KARA PERAVOOR P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY PRAMEELA C
39 KODIYERI VANITHA CO-OPERATIVE SOCIETY LTD NO.C 1350
TEMPLE GATE P.O., MADAPPEDIKA, KANNUR-670102
REPRESENTED BY ITS SECRETARY LAILA V.K
40 KOTTAYAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1365,
KOTTAYAMPOLI P.O., KANNUR-670691 REPRESENTED BY ITS
SECRETARY MINI.K
41 POOKODE VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1387,
POOKODE P.O., KANNUR-670691 REPRESENTED BY ITS
SECRETARY SREEKUMARI.C
42 KADIRUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1340,
PONNIYAM (WEST), KANNUR-670641 REPRESENTED BY ITS
SECRETARY PADMINI.K
43 MUNDAYAMPARAMBA VANITHA CO-OPERATIVE SOCIETY LTD NO.
C 1737,
ST JUDE NAGAR, KILIYANTHARA P.O., KANNUR-670706
REPRESENTED BY ITS SECRETARY SAJIMA K
44 KUNNOTHPARAMBA VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1328,
KUNNOTHPARAMBA, THUVAKKUNNU P.O., KANNUR-670693
2025:KER
W.P(C)No.7053/2023 & Connected cases 563
REPRESENTED BY ITS SECRETARY AJITHA K.K
45 KAITHERI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1893,
KAITHERI, NIRMALAGIRI P.O., KANNUR-670701 REPRESENTED
BY ITS SECRETARY SHIJINA V
46 ULIYIL VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1617,
ULIYIL P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY DEEPA SHAJI
47 CHERUVANCHERY VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1907,
CHERUVANCHERY P.O., KANNUR-670650 REPRESENTED BY ITS
SECRETARY SUNITHA.M
48 KURICHIYIL VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1341,
KURICHIYIL P.O., KANNUR-670102 REPRESENTED BY ITS
SECRETARY JEENA.T
49 THALASSERY TALUK VANITHA WELFARE COOPERATIVE SOCIETY
LTD NO. C 1846,
KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS
SECRETARY SHEENA K.K
50 KANHIRATHIN KEEZHILVANITHA CO-OPERATIVE SOCIETY LTD
NO. C 1861,
CHOKLI P.O., KANNUR-670671 REPRESENTED BY ITS
SECRETARY AMJAPRIYA V ,
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.NEENA ARIMBOOR
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 564
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI- 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 565
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13902 OF 2022
PETITIONER/S:
KANJIRAMATTOM VANITHA CO-OPERATIVE SOCIETY LTD. NO. E
1249,
KALAMASSERY.P.O, ERNAKULAM DISTRICT, PIN-683104,
REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.M.M.MONAYE
SHRI.M.PAUL VARGHESE
SRI.K.V.SANOSH
SMT.NIRMALA P.V.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI, PIN-110011.
2 THE CENTRAL BOARD OF DIRECT TAXES
ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE,
(CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI-110001.
3 COMMISSIONER OF INCOME TAX(TDS)
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-682018.
4 STATE OF KERALA,
2025:KER
W.P(C)No.7053/2023 & Connected cases 566
DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT,
REPRESENTED BY SECRETARY TO GOVERNMENT,
THIRUVANANTHAPURAM-695001.
5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM-695001.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, THIRUVANANTHAPURAM-695033.
7 DEPUTY GENERAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, CREDIT PROCEESING
CENTRE, KAKKANAD, KOCHI-682030.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 567
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13903 OF 2022
PETITIONER/S:
1 KUTHUPARAMBA BLOCK AGRICULTURAL IMPROVEMENT CO-
OPERATIVE SOCIETY LTD. NO.C 1625,
KUTHUPARAMBA P.O., KANNUR-670 643, REPRESENTED BY ITS
SECRETARY BINDU.M.
2 CHOKLI PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD NO. C
1923,
SALALA COMPLEX, SPINNING MILL ROAD, CHOKLI P.O.,
KANNUR-670672 REPRESENTED BY ITS SECRETARY NAMITHA
3 CHITTARIPARAMBA AGRICULTURAL WELFARE COOPERATIVE
SOCIETY LTD NO. C 1700,
CHITTARIPARAMBA P.O., KANNUR- 670650 REPRESENTED BY
ITS SECRETARY SMITHA P.M
4 IRITTY BLOCK PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD
NO. C 1870,
KOODALI, KANNUR-670592 REPRESENTED BY ITS SECRETARY
ROSHIDA RAY
5 KUTHUPARAMBA FARMERS SOCIAL WELFARE COOPERATIVE
SOCIETY LTD NO. C 2043,
THOKKILANGADI, KUTHUPARAMBA P.O., KANNUR-670643
REPRESENTED BY ITS SECRETARY JALAJA T.P
6 PARAT AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY
LTD NO. C 1772,
THOOVAKKUNNU P.O., KANNUR-670693 REPRESENTED BY ITS
SECRETARY JIBIN.K
7 GRAMEENA THOZHILALI KSHEMA CO-OPERATIVE SOCIETY LTD
2025:KER
W.P(C)No.7053/2023 & Connected cases 568
NO. C 1767
CHALODE, EDAYANNUR. P.O., KANNUR-670595 REPRESENTED
BY ITS SECRETARY BINDU T.P
8 CHALODE MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD
NO. C 1882,
EDAYANNUR P.O., KANNUR-670595 REPRESENTED BY ITS
SECRETARY PUSHPAJA P
9 HARIPAD AIDED SECONDARY SCHOOL EMPLOYEE'S CO-
OPERATIVE SOCIETY LTD NO. A 280,
HARIPAD P.O., ALAPUZHA-690514 REPRESENTED BY ITS
SECRETARY K VINOD
10 MALUR AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY LTD
NO. C 1824
MALUR P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY VARSHA P.V
11 IRITTY SERVICE PENSIONER'S WELFARE COOPERATIVE
SOCIETY LTD NO. 1679,
IRITTY P.O., KANNUR-670703 REPRESENTED BY ITS
SECRETARY SOBHA P.V.T
12 NRI'S WELFARE CO-OPERATIVE SOCIETY LTD NO.C 1549,
MATTANUR, KANNUR-670702 REPRESENTED BY ITS SECRETARY
SHEEBA K.M
13 MATTANUR LABOUR AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD NO. C 1863,
MATTANUR P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY PRASANTHI E
14 TEACHERS & EMPLOYEES CO-OPERATIVE SOCIETY LTD NO. C
1202,
MATTANUR P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY THANKACHAN K.A
15 CO-OPERATIVE EMPLOYEES' CO-OPERATIVE SOCIETY LTD NO.
C 379,
MATTANUR P.O., KANNUR670702 REPRESENTED BY ITS
SECRETARY NAVEEN KUMAR R.K
16 IRITTY BLOCK RURAL EMPLOYEES WELFARE COOPERATIVE
2025:KER
W.P(C)No.7053/2023 & Connected cases 569
SOCIETY LTD NO. C 1717,
THILLENKERY P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY NAVEEN K.E
17 BLATHUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO. C
1864,
BLATHUR P.O., KALLIAD, KANNUR-670593 REPRESENTED BY
ITS SECRETARY PREETHA.K
18 IRITTY FARMERS WELFARE CO-OPERATIVE SOCIETY LTD NO. C
1879,
VALLITHODE P.O., KANNUR-670706 REPRESENTED BY ITS
SECRETARY JEEJA C
19 IRITTY UNEMPLOYEES WELFARE CO-OPERATIVE SOCIETY LTD
NO. C 1692,
IRITTY, KANNUR-670703 REPRESENTED BY ITS SECRETARY
SUJITHA P.P.
20 IRITTY TALUK MERCHANTS WELFARE COOPERATIVE SOCIETY
LTD NO. C 1995,
PAYANCHERY, IRITTY P.O., KANNUR-670703 REPRESENTED BY
ITS SECRETARY SREEJA Т.M
21 MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD NO. C
1397,
H.O. IRITTY, IRITTY P.O., KANNUR-670703 REPRESENTED
BY ITS SECRETARY JOHNSON K.A
22 EDOOR AREA EMPLOYEES AND PENSIONER'S WELFARE CO-
OPERATIVE SOCIETY LTD NO. C 1739,
PAYAM, EDOOR P.O., KANNUR-670704 REPRESENTED BY ITS
SECRETARY SHEEBA K.P
23 KOODALI PUBLIC SERVANTS CO-OPERATIVE SOCIETY LTD NO.
C 924,
H.O. MATTANUR, KANNUR670702,REPRESENTED BY ITS
SECRETARY SHYNITH KUMAR C
24 MATTANUR MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD
NO, C 1837
MATTANUR P.O., KANNUR-670702 REPRESENTED BY ITS
SECRETARY RESNA.K
2025:KER
W.P(C)No.7053/2023 & Connected cases 570
25 MATTANUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO.
C 1841
KOTTATH BUILDING, MATTANNUR P.O., KANNUR-670702
REPRESENTED BY ITS SECRETARY DIJESH P.V
26 KADIRUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO. C
1931,
CHUNDANGAPOYIL, PONNIAM P.O., KANNUR-670641
REPRESENTED BY ITS SECRETARY JANISHA PUTHUSSERI
27 KUTHUPARAMBA PUBLIC SERVANT'S CO. OPERATIVE SOCIETY
LTD NO. C1151
KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS
SECRETARY ANITHA K
28 MAMBARAM URBAN CO-OPERATIVE SOCIETY LTD NO. C. 1690,
MAMBARAM P.O., KANNUR-670741 REPRESENTED BY ITS
SECRETARY SHAJI V.K
29 ULIKKAL AREA EMPLOYEES WELFARE COOPERATIVE SOCIETY
LTD NO. C 1594,
ULIKKAL P.O., KANNUR-670705 REPRESENTED BY ITS
SECRETARY SINDHAU PHILIP
30 KUTHUPARAMBU BLOCK AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD NO. C 1885
AYYAPPANTHODE, MANGATTIDAM P.O., KANNUR670643
REPRESENTED BY ITS SECRETARY SUNITHA.K
31 PANOOR PUBLIC WELFARE CO-OPERA NE SOCIETY LTD NO.
1849,
KALLIKKANDY'S.O., KANNUR-670693 REPRESENTED BY ITS
SECRETARY RINOJ C
32 KUTHUPARAMBU THOZILALI KSHEMA SAHAKARANA SANGAM LTD.
NO. C 1915,
KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS
SECRETARY SUPRIYA.N
33 THE AGRICULTURIST & LABOUR WELFARE COOPERATIVE
SOCIETY LTD NO. C 1920,
CHALODE, EDAYANNUR P.O., KANNUR-670595 REPRESENTED BY
ITS SECRETARY SHALINA.N
2025:KER
W.P(C)No.7053/2023 & Connected cases 571
34 CHERUVANCHERY KARSHAKA-KARSHAKA THOZHILALI KSHEMA
SAHAKARANA SANGHAM LTD NO. C 1867,
CHERUVANCHERY P.O., KANNUR670650 REPRESENTED BY ITS
SECRETARY SREESHMA.K
35 PANOOR MERCANTILE CO-OPERATIVE SOCIETY LTD NO. C
1532,
PANOOR P.O., KANNUR-670692 REPRESENTED BY ITS
SECRETARY SHYJA E
36 KUNNOTH PARAMBA PEOPLE'S WELFARE COOPERATIVE SOCIETY
LTD NO. C 1992,
THUVAKKUNNU, KANNUR-670693 REPRESENTED BY ITS
SECRETARY GREESHMA C.L
37 PANOOR AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY
LTD NO. C 1643,
PANOOR P.O., KANNUR-670692 REPRESENTED BY ITS
SECRETARY NEESHMA K
38 CHENDAYAD PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD
NO.C 1847,
CHENDAYAD P.O., KANNUR-670692 REPRESENTED BY ITS
SECRETARY SHIMNA P.V
39 PANOOR PUBLIC SERVANTS WELFARE COOPERATIVE SOCIETY
LTD NO. 1641,
PANOOR P.O. KANNUR-670692 REPRESENTED BY ITS
SECRETARY SUJA T.P
40 THALASSERY TALUK AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD NO. C 1833
KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS
SECRETARY BEENA MANIYATH
41 THALASSERY TALUK LABOUR WELFARE SAHAKARANA SANGAM,
LTD. NO. C 1988
SANGARANELLOOR P.O., KANNUR-670643 REPRESENTED BY ITS
SECRETARY RAJINA.P
42 KANHIRAPUZHA CO-OPERATIVE URBAN CREDIT SOCIETY LTD.
NO.P 1172,
CHIRAKKALPADI, THRIKALLOR P.O., PALAKKAD-678593
REPRESENTED BY ITS SECRETARY ABIN VARGHEES
2025:KER
W.P(C)No.7053/2023 & Connected cases 572
43 MANNARKKAD SAHAKARANA URBAN CREDIT SOCIETY LTD. NO.P
1191,
VADAKKUMANNAM P.O., MANNARKKAD, PALAKKAD-678582
REPRESENTED BY ITS SECRETARY SAJITH P
44 MANNARKKAD PRAVASI WELFARE CO-OPERATIVE SOCIETY LTD
NO. P 1370,
KODATHIPPADI, MANNARKKAD P.O., KANNUR-678582
REPRESENTED BY ITS SECRETARY SATHYA NARAYANAN K.T
45 PATTANCHERY RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO.
1431,
PATTANCHERY P.O., PALAKKAD-678532 REPRESENTED BY ITS
SECRETARY BIJU V
46 PATTANCHERY RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO.
1431,
PATTANCHERY P.O., PALAKKAD-678532 REPRESENTED BY ITS
SECRETARY BIJU V
47 PAZHASSI RAJA LABOUR WELFARE COOPERATIVE SOCIETY LTD,
NO.C.1896,
P.O, KOODALI, KANNUR-670592, REPRESENTED BY ITS
SECRETARY RANJULA K
48 BUILDING MATERIALS CO-OPERATIVE SOCIETY, LTD.NO.
C.1081,
KUTHUPARAMBA, KANNUR-670643, REPRESENTED BY ITS
SECRETARY BEENA CHERIAN
49 PUTHOOR AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY
LTD, NO.C.1771,
P.O, CHENDAYAD, VARAPRA, KANNUR- 670692 REPRESENTED
BY ITS SECRETARY SUJISHA K.P
50 CHERUVANCHERY AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY, LTD, NO.C.1783,
KARYATTUPURAM, P.O, MUTHIYANGA, KANNUR-670671,
REPRESENTED BY ITS SECRETARY N.V. RAJESH
51 THALASSERY TALUK PUBLIC SERVENTS'S WELFARE CO-
OPERATIVE SOCIETY, LTD.NO.C.1669,
P.O, KUTHUPARAMBA, KANNUR-670703 REPRESENTED BY ITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 573
SECRETARY RANJITH P.P
52 KOLAYAD FARMERS WELFARE CO-OPERATIVE SOCIETY LTD
NO.C. 1973,
KOLAYAD P.O, KANNUR-670650 REPRESENTED BY ITS
SECRETARY RAJESH. K.M
53 THALASSERY TALUK NIRMANA THOZHILALI KSHEMA SAHAKARANA
SANGAM, LTD, NO.C. 1913,
PANOOR P.O, KANNUR- 670692 REPRESENTED BY ITS
SECRETARY KRISHNAN. K
54 PERINGATHUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD,
NO.C 1852,
PERINGATHUR P.O, KANNUR-670675, REPRESENTED BY ITS
SECRETARY ROJA.P.P.
55 PANOOR MERCHANTS WELFARE CO-OPERATIVE SOCIETY, LTD
NO.C 1731,
PANOOR P.O., KANNUR-670 692, REPRESENTED BY ITS
SECRETARY SHYNI
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.NEENA ARIMBOOR
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
2025:KER
W.P(C)No.7053/2023 & Connected cases 574
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
PB NO.6515, CO BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY IT CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
BY ADV SHRI.M.SASINDRAN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 575
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13912 OF 2022
PETITIONER/S:
KALAMASSERY GOVT. POLYTECHNIC COLLEGE EMPLOYEES CO-
OPERATIVE SOCIETY LTD. NO.E 1157,
KALAMASSERY P.O., ERNAKULAM DISTRICT, PIN-683104,
REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.M.M.MONAYE
SHRI.M.PAUL VARGHESE
SRI.K.V.SANOSH
SRI.JOE JOSEPH
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI, PIN-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI-110001.
3 COMMISSIONER OF INCOME TAX (TDS),
C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-682018.
4 STATE OF KERALA
2025:KER
W.P(C)No.7053/2023 & Connected cases 576
DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT,
REPRESENTED BY SECRETARY TO GOVERNMENT,
THIRUVANANTHAPURAM-695001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM-695001.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, THIRUVANANTHAPURAM-695033.
7 DEPUTY GENERAL MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., CREDIT
PROCESSING CENTRE, KAKKANAD, KOCHI-682030.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 577
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13939 OF 2022
PETITIONER/S:
PULLUKULANGARA SERVICE CO-OPERATIVE BANK LTD
REPRESENTED BY ITS SECRETARY, PULLUKULANGARA,
KAYAMKULAM.P.O, ALAPPUZHA-690502.
BY ADV SRI.GOKUL D. SUDHAKARAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES
REPRESENTED BY ITS CHAIRMAN DEPARTMENT OF REVENUE,
MINISTRY OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT
OF INDIA, NORTH BLOCK, NEW DELHI-110001.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI-682018.
4 COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003.
5 THE INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICER, ANAVATHILKOTTA,
ALAPPUZHA-688001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 578
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN-695033.
7 STATE OF KERALA,
REPRESENTED BY THE SECRETARY, DEPARTMENT OF CO-
OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM-695001.
BY ADV SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 579
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13940 OF 2022
PETITIONER/S:
1 CHAKKITTAPARA VANITHA CO-OPERATIVE SOCIETY LTD NO. D-
2931
CHAKKITTAPARA P.O, KAYANNA VIA, KOZHIKODE-673526
REPRESENTED BY ITS SECRETARY SHALLY JOSEPH.
2 KAYANNA PRIYADARSINI VANITHA SAHAKARANA SANGAM LTD.
NO 2605,
P.O, KAYANNA BAZAR, KOZHIKODE- 673525 REPRESENTED BY
ITS SECRETARY DHANYA A.K
3 ATHOLI VANITHA CO-OPERATIVE SOCIETY LTD.NO.D.2841,
ATHOLI P.O, KOZHIKIDE- 673315 REPRESENTED BY ITS
SECRETARY PRABITHA KUMARI
4 NOCHAD VANITHA SAHAKARANA SANGHAM, LTD.NO.D.2843,
P.O, KALPPATHUR, ANCHAMPEEDIKA, CALICUT- 673524
REPRESENTED BY ITS SECRETARY SHEEJA.P.K
5 KEEZHARIYUR VANITHA CO-OPERATIVE SOCIETY LTD. NO.
D.2681,
NADUVATHUR P.O, QUILANDY, CALICUT-673620 REPRESENTED
BY ITS SECRETARY PUSHPAVALLY.K
6 MULIYANGAL VANITHA SAITAKARANA SANGAM LTD. NO.1.2881,
CHENOLI PO, PERAMBRA, KOZHIKODE- 673525 REPRESENTED
BY ITS SECRETARY NISHA.P
7 CHANGAROTH PANCHAYATH VANITHA CO-OPERATIVE SOCIETY
LTD. NO.D.2870,
KADIYANGAD, P.O, KOZHIKODE- 673525 REPRESENTED BY ITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 580
SECRETARY SHIJI.M.V
8 MUYIPPOTH VANITHA SAHAKARAVA SANGHAM, LTD.NO.1.3120,
MUYIPPOYH P.O, KOZHIKODE-673524 REPRESENTED BY ITS
SECRETARY SHYNI.K
9 PERAMBRA VANITHA SAHAKARANA SANGHAM, LTD.NO.0.2833,
PERAMBRA KOZHIKODE- 673525 REPRESENTED BY ITS
SECRETARY RAKHI.P
10 KOYILANDY VANITHA CO-OPERATIVE SOCIETY LTD. NO.
D.2572,
TRAFFIC POLICE STATION ROAD, KOYILANDY, KOZHIKODE-
673305 REPRESENTED BY ITS SECRETARY RATHYINA N.K
11 AVITANALLUR PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY
LTD. NO. D.2484,
AVITANALLUR P.O, NADUVANNUR, KOZHIKODE-673618
REPRESENTED BY ITS SECRETARY INDIRA.K.P
12 NADUVANNUR VANITHA SAHAKARANA SANGHAM, LTD.NO.1.2806,
KAVIL P.O, NADUVANNUR, KOZHIKODE-673614 REPRESENTED
BY ITS SECRETARY DEEPAK
13 MALABAR VANITHA CO-OPERATIVE SOCIETY LTD. NO. D.2994,
ULLIYERI P.O KOZHIKODE-673620 REPRESENTED BY ITS
SECRETARY SINDHU.K.M
14 PANOOR REGIONAL VANITHA COOPERATIVE SOCIETY LTD. NO.
C.1575,
PANOOR P.O, KANNUR- 670692 REPRESENTED BY ITS
SECRETARY SAJILA K.T
15 KOTTAYAM KINAVAKKAL VANITHA COOPERATIVE SOCIETY LTD.
NO. C.1494,
KOTTAYAM ANGADI, P.O KOTTAYAM MALABAR, KUTHUPARAMBA,
KANNUR670643 REPRESENTED BY ITS SECRETARY SREESHA. A
16 KARIYAD MAHILA SERVICE COOPERATIVE SOCIETY LTD. NO.
C.1498,
KARIYAD P.O, KANNUR- 673316 REPRESENTED BY ITS
SECRETARY SREEJA.C
2025:KER
W.P(C)No.7053/2023 & Connected cases 581
17 THE KUTTIKOL VANITHA SERVICE COOPERATIVE SOCIETY LTD.
NO.S.434,
KUTTIKOL P.O, KASARAGOD-671541 REPRESENTED BY ITS
SECRETARY SOUMYA.B
18 KUTTIKOL VYAPARI VYAVASAYI KSHEMA SAHAKARANA SANGHAY
LTD. NO. S.553
KUTTIKOL P.O, CHENGALA, KASARAGOD- 671541 REPRESENTED
BY ITS SECRETARY SREEJA C.G
19 PUTHUR PRIYADARSINI VANITHA COOPERATIVE SOCIETY
LTD.NO.C.1615,
PUTHUR P.O, PANOOR, KANNUR - 670692 REPRESENTED BY
ITS SECRETARY DEEPAK
20 THE KUTTIKOL MERCHANT'S WELFARE CO-OPERATIVE SOCIETY
LTD.NO.S.555,
KUTTIKOL P.O, KASARAGOD- 671541 REPRESENTED BY ITS
SECRETARY RAJESH KUMAR K
21 THE KASARAGOD MERCANTILE COOPERATIVE SOCIETY
LTD.NO.S.287,
MALABAR SQUARE BUILDING, NEW BUS STAND, KASARAGOD-
671121 REPRESENTED BY ITS SECRETARY KUNHIRAMAN.A.C
22 THE KUNNAMTHANAM SERVICE COOPERATIVE BANK
LTD.NO.A151,
KUNNAMTHANAM P.O, THIRUVALLA-689581 REPRESENTED BY
ITS SECRETARY SMITHA.GOPINATH
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.NEENA ARIMBOOR
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 582
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018.
4 KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 583
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 13996 OF 2022
PETITIONER/S:
1 CHERIYAKUMBALAM AGRICULTURESTS WELFARE CO-OIPERATION
SOCIETY LTD.
NO. D 3066, PALERI P.O., KOZHIKODE- 673508
REPRESENTED BY ITS SECRETARY JITHIL B
2 PERAMBRA AREA MOTOR & ENGINEERING WORKERS CO-
OPERATIVE SOCIETY LTD NO. D 2869,
PERAMBRA P.O., KOZHIKODE-673525 REPRESENTED BY ITS
SECRETARY NIJINLAL.K.N
3 PERAMBRA WEST VANITHA SAHAKARANA SANGAM LTD NO. 3114,
PANNIMUKKU, CHERUVANNUR P.O., MEPPAYUR VIA,
KOZHIKODE-673524 REPRESENTED BY ITS SECRETARY
SUJITH.C
4 KOORACHUND PANCHAYATH VANITHA COOPERATIVE SOCIETY LTD
NO. D 2887,
KOORACHUND P.O., KOZHIKODE-673527 REPRESENTED BY ITS
SECRETARY SHYNI.R
5 PERAMBRA MEKHALA VANITHA CO-OPERATIVE SOCIETY LTD
NO.D 2875,
PERAMBRA P.O., KOZHIKODE-673525 REPRESENTED BY ITS
SECRETARY SREEJINI P
6 KOOTHALI PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD
NO. D 2791,
THANDORAPPARA P.O. KOZHIKODE-673526 REPRESENTED BY
ITS SECRETARY JEENARANI P.P
2025:KER
W.P(C)No.7053/2023 & Connected cases 584
7 CHERUVANNUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD NO. D 2995,
CHERUVANNUR P.O., KOZHIKODE-673524 REPRESENTED BY ITS
SECRETARY AJEESH K.M
8 THE MOKERI AGRICULTURIST IMPROVEMENT COOPERATIVE
SOCIETY LTD NO. C 1770,
MOKERY P.O., PANOOR VIA, KANNUR-670692 REPRESENTED BY
ITS SECRETARY REHINA.K
9 BHUVANESWARI WELFARE CO-OPERATIVE SOCIETY LTD NO. C
1626,
BB COMPLEX, SOUTH BAZAR, KANNUR-670002 REPRESENTED BY
ITS SECRETARY SHEEJA.N.V
10 INDIRAAJI SMARAKA VANITHA SAHAKARANA SANGAM LTD NO. C
1633,
ELAYAVOOR P.O., KANNUR-670594 REPRESENTED BY ITS
SECRETARY REJENI.C
11 KATTAL FARMERS SOCIAL WELFARE COOPERATIVE SOCIETY LTD
NO. T 1629,
KATTAKKADA P.O, THIRUVANANTHAPURAM-695572 REPRESENTED
BY ITS SECRETARY SARITHA.S
12 KALPETTA AGRICULTURAL IMPROVEMENT CO. OPERATIVE
SOCIETY,
KANIYAMBETTA, WAYANAD-673121 REPRESENTED BY ITS
SECRETARY T.T JOSEPH
13 KULATHUMMEL WELFARE CO-OPERATIVE SOCIETY, T 1692,
KATTAKADA P.O., THIRUVANANTHAPURAM-695572 REPRESENTED
BY ITS SECRETARY NISHANTH.N
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.RASMI NAIR T.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 585
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK, NEW DELHI- 110001, REPRESENTED
BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 586
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14006 OF 2022
PETITIONER/S:
KADAPPURAM PANCHAYATH PRAVASI HARITHA CO-OPERATIVE
SOCIETY LTD.
R 1417 , KADAPURAM P.O, ANJANGADI, THRISSUR - 680 514
REPRESENTED BY ITS SECRETARY
BY ADV SRI.V.A.VINOD
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
COCHIN - 682 018.
4 INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICE (TDS) AAYAKAR BHAVAN,
SAKATHAN THAMPURAN NAGAR, THRISSUR - 680 001.
5 THE KERALA STATE CO-OPERATIVE BANK LTD,
2025:KER
W.P(C)No.7053/2023 & Connected cases 587
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033. REPRESENTED BY ITS
CHIEF EXECUTIVE OFFICER.
6 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO-
OPERATION, GOVERNMENT SECRETARIAT, THIRUVNANTHAPURAM-
695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 588
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14010 OF 2022
PETITIONER/S:
M/S.VELLINEZHI PANCHAYATH MULTI PURPOSE CO-OPERATIVE
SOCIETY LTD.
SREELAKSHMI COMPLEX, VELLINEZHI, DIST. PALAKKAD - 679
504 REPRESENTED BY ITS SECRETARY, SMT. PREETHY C.S
BY ADVS.
SRI.V.P.NARAYANAN
SRI.ALAN PRIYADARSHI DEV
RESPONDENT/S:
1 UNION OF INDIA
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001.
REPRESENTED BY ITS SECRETARY,
2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI- 682018
3 THE CHAIRMAN,
CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
2025:KER
W.P(C)No.7053/2023 & Connected cases 589
CHERPULLASSERI BRANCH, DIST. PALAKKAD- 679503
REPRESENTED BY ITS BRANCH MANAGER
BY ADV SHRI.M.SASINDRAN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 590
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14014 OF 2022
PETITIONER/S:
CHAVAKKAD MUNICIPAL PRAVASI KSHEMA CO-OPERATIVE
SOCIETY LTD 1486
CHAVAKKAD P.O., THRISSUR-680506, REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.V.A.VINOD
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
COCHIN-682018.
4 INCOME TAX OFFICER (TDS),
OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.,
2025:KER
W.P(C)No.7053/2023 & Connected cases 591
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO-
OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM-695001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 592
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14017 OF 2022
PETITIONER/S:
THE ALANALLUR CO-OPERATIVE RURAL CREDIT SOCIETY LTD.
NO. P.1333
ALANALLUR P.O., PALAKKAD DISTRICT, KERALA-678601,
REPRESENTED BY ITS SECRETARY, SRI. SREEJITH P.T.
BY ADVS.
SRI.K.ANAND
SMT.M.R.MINI
SHRI.AMEER SALIM
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682018.
4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD.),
2025:KER
W.P(C)No.7053/2023 & Connected cases 593
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-
695033, REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA BANK ( THE KERALA STATE CO-OPERATIVE BANK
LTD.),
REGIONAL OFFICE, PALAKKAD H.P.O. ROAD, SULTHANPET,
PALAKKAD-678001, REPRESENTED BY ITS GENERAL MANAGER.
6 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD.),
ALANALLUR BRANCH, ALANALLUR P.O., PALAKKAD -678601,
REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
SRI.CHRISTOPHER ABRAHAM
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 594
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14047 OF 2022
PETITIONER/S:
1 THE PUDURUTHY SERVICE CO-OPERATIVE BANK LTD NO.825,
MUNDATHICODE P.O., THRISSUR DISTRICT, THRISSUR 680
601, REPRESENTED BY SECRETARY, T HEMALATHA.
2 AVANOOR PANCHAYATH MULTIPURPOSE CO- OPERATIVE SOCIETY
LTD NO. R. 1142,
AVANOOR P.O., THRISSUR DISTRICT 680 541, REPRESENTED
BY SECRETARY DHIVYA C.G.
3 THRISSUR JILLA NRI SERVICE CO - OPERATIVE SOCIETY LTD
NO. R 1269,
POOTHOLE P.O, THRISSUR DISTRICT, THRISSUR 680 004,
REPRESENTED BY SECRETARY GAYATHRI K.P.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT ,
MINISTRY OF FINANCE , NORTH BOCK, RAISANA HILL , NEW
DELHI 110 001.
2 THE COMMOSSIOER OF INCOME TAX (TDS),
CENTRAL REVENUE BIDG, IS PRESS, ROAD, KOCHI 682 018.
3 THE INCOME TAX OFFICER (TDS),
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR 680 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 595
4 THE KERALA STATE CO - OPERATIVE BANK LTD,
(ERST WHILE THRISSUR DISTRICT CO-OPERATIVE BANK)
SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD,
THRIRUVAMBADI P.O, THRISSUR, 680 022, REPRESENTED BY
ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 596
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14061 OF 2022
PETITIONER/S:
THOZHUVANCODE-VATTIYOORKAVU RESIDENTS WELFARE CO-
OPERATIVE SOCIETY LTD NO.T-1247,
ARAPPURA, VATTIYOOR KAVU P.O., THIRUVANANTHAPURAM 695
013, REPRESENTED BY ITS SECRETARY, SARITHA. M.G.
BY ADVS.
SRI.D.SAJEEV
SHRI.AJAYA KUMAR P.J.
SMT.LIGEY ANTONY
RESPONDENT/S:
1 UNION OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI 110 001.
REPRESENTED BY ITS SECRETARY.
2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
C.R. BUILDING, I.S. PRESS ROAD, KOCHI, ERNAKULAM 682
018.
3 THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS),
3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O.,
THIRUVANANTHAPURAM 695 003.
4 THE KERALA STATE CO - OPERATIVE BANK LTD.,
EAST FORT, THIRUVANANTHAPURAM 695 023, REPRESENTED BY
ITS MANAGING DIRECTOR.
2025:KER
W.P(C)No.7053/2023 & Connected cases 597
5 THE BRANCH MANAGER,
THE KERALA STATE CO - OPERATIVE BANK LTD.,
VATTIYOORKAVU BRANCH, THIRUVANANTHAPURAM 695 013.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 598
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14119 OF 2022
PETITIONER/S:
THIRUVANANTHAPURAM DISTRICT GOVERNMENT SERVANTS CO-
OPERATIVE SOCIETY LTD.NO.T-1566,
PUBLIC OFFICE BUILDING, PUBLIC OFFICE P.O.,
THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS
SECRETARY, AJITH.K.I.
BY ADVS.
SRI.D.SAJEEV
SHRI.AJAYA KUMAR P.J.
SMT.LIGEY ANTONY
RESPONDENT/S:
1 UNION OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS SECRETARY.
2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
CR BUILDING, IS PRESS ROAD, KOCHI, ERNAKULAM, PIN-682
018.
3 THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS),
3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O.,
THIRUVANANTHAPURAM, PIN-695 003.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
EAST FORT, THIRUVANANTHAPURAM, PIN-695 023,
2025:KER
W.P(C)No.7053/2023 & Connected cases 599
REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE BRANCH MANAGER,
THE KERALA STATE CO OPERATIVE BANK LTD., M & E
BRANCH, PUTHENCHANTHAI, THIRUVANANTHAPURAM, PIN-695
001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 600
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14122 OF 2022
PETITIONER/S:
1 THE BANK EMPLOYEES CO-OPERATIVE BANK LTD.NO.R 315,
IRINJALAKUDA P.O, THRISSUR DISTRICT, PIN 680121
REPRESENTED BY SECRETARY-INCHARGE PRIYA MENON C.
2 THE KUNNAMKULAM THALUK GOVERNMENT SERVANT'S CO-
OPERATIVE SOCIETY LTD NO. 205,
KUNNAMKULAM P O, THRISSUR DISTRICT, PIN 680503
REPRESENTED BY SECRETARY PRASSETHA K.S.
3 KATTOOR PANCHAYATH VANITHA SAHAKARANA SANGAM LTD NO.R
1250,
KATTOOR PO, THRISSUR DISTRICT, PIN 680702 REPRESENTED
BY SECRETARY VIJAYALAKSHMI.N.
4 MUKUNDAPURAM TALUK GOVT. EMPLOYEE'S CO-OPERATIVE
SOCIETY LTD NO. R.793.
IRINJALAKUDA P.O, THRISSUR, PIN-680121 REPRESENTED BY
ITS SECRETARY MAYA P.M.
5 THRISSUR REGIONAL AGRICULTURAL NON AGRICULTURAL
DEVELOPMENT COOPERATIVE SOCIETY LTD NO. R 1399,
TOMS PLAZA TOWER, IRINJALAKUDA P.O, THRISSUR, PIN-
680121 REPRESENTED BY ITS SECRETARY HILA P.H.
6 VANITHA CO-OPERATIVE SOCIETY LTD NO. R.979,
IRINJALAKUDA P.O, THRISSUR, PIN-680121 REPRESENTED BY
ITS SECRETARY SUDHA K.
BY ADV SHRI.C.A.JOJO
2025:KER
W.P(C)No.7053/2023 & Connected cases 601
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682 018.
3 THE INCOME TAX OFFICER(TDS) ,
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK),
SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD,
THRIRUVAMBADI P.O, THRISSUR, PIN-680022 REPRESENTED
BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 602
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14151 OF 2022
PETITIONER/S:
THE KATAMPAZHIPURAM PANCHAYATH AGRL.IMPROVEMENT CO-
OPERATIVE SOCIETY LTD.NO.P.1314
UMMANAZHI, PALAKKAD DISTRICT, KERALA - 678632.,
REPRESENTED BY ITS SECRETARY, SMT. DHANDY.
BY ADVS.
SRI.K.ANAND
SHRI.BENNY ANTONY PAREL
SHRI.AMEER SALIM
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN - 682018.
4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD).
2025:KER
W.P(C)No.7053/2023 & Connected cases 603
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN -
695033, REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD),
REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET,
PALAKKAD - 678001, REPRESENTED BY ITS GENERAL
MANAGER.
6 THE KERALA BANK
(THE KERALA STATE CO-OPERATIVE BANK LTD), PULAPETTA
BRANCH, PULAPETTA P.O, PALAKKAD - 678632, REPRESENTED
BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 604
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14162 OF 2022
PETITIONER/S:
ARUVAPPULAM FARMERS SERVICE CO-OPERATIVE BANK
LTD.NO.P.T.148
ARUVAPPULAM P.O, KONNI, PATHANAMTHITTA DISTRICT PIN
689 691 REPRESENTED BY ITS MANAGING DIRECTOR,
SIVAKUMAR S
BY ADV SRI.C.B.SREEKUMAR
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH LOCK, NEW DELHI 110 001
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018
4 INCOME TAX OFFICER(TDS)
OFFICE OF THE INCOME TAX (TDS), AAYAKAR BHAVAN,
SAKTHAN THAMPURAN NAGAR, THRISSUR 680 001
2025:KER
W.P(C)No.7053/2023 & Connected cases 605
5 THE KERALA STATE CO-OPERATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001
BY ADV SRI.CHRISTOPHER ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 606
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14195 OF 2022
PETITIONER/S:
1 CARBORUNDUM UNIVERSAL EMPLOYEES CO-OPERATIVE SOCIETY
LTD. NO. E 404
KALAMASSERY P.O, ERNAKULAM 683104 REPRESENTED BY ITS
SECRETARY ANEESH P.B
2 THE MULIYAR PUBLIC WELFARE CO-OPERATIVE SOCEITY LTD
NO. S 558
BOVIKANAM COMPLEX, INFORNT POST OFFICE,. MULIYAR P.O,
KASARAGOD 671 542 REPRESENTED BY ITS SECRETARY JITHIN
A
3 MARIYAPURAM VANITHA WELFARE CO-OPERATIVE SOCIETY
LTDNO T 945
THOTTINKARA, PLAMOOTTUKKADA P.O, THIRUVANANTHAPURAM
695 126 REPRESENTED BY ITS SECRETARY ANITHAKUMARI T.C
4 THIRUPURAM PANCHAYAT RESIDENTS
ASSOCIATIONS WELFARE CO-OPERATIVE SOCIETY LTD NO T
1755, MANNAKKAL, THIRUPURAM P.O, THIRUVANANTHAPURAM
695 133 REPRESENTED BY ITS SECRETARY VIJI C V
5 CHENKAL JOINT FARMING CO-OEPRATIVE SOCIETY LTD NO T
1183,
VLATHANKARA P.O, THIRUVANANTHAPURAM 695 134
REPRESENTED BY ITS SECRETARY SHEEJA G.S
6 KARUMKULAM FARMERS WELFARE CO-OPERATIVE SOCIETY LTD
NO T 1941,
KARUMKULAM , PUTHIYATHURA P.O, THIRUVANANTHAPURAM 695
526 REPRESENTED BY ITS SECRETARY CHITHRA LEKHA M.S
2025:KER
W.P(C)No.7053/2023 & Connected cases 607
7 BALARAMAPURAM VANITHA CO-OPERATIVE SOCIETY LTD NO. T
961
DOUBLE STREET, BALARAMAPURAM P.O, THIRUVANANTHAPURAM
695 501 REPRESENTED BY ITS SECRETARY S JAYALEKHA
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI 110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001
REPRESENTED BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDING S, I S PRESS ROAD,
KOCHI 682 018
4 THE KERALA STATE CO-OPEERATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033 ' REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY(CO-OPERATION) GOVERNMENT
SECRETARIATE, THIRUVANANTHAPURAM 695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 608
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 609
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14341 OF 2022
PETITIONER/S:
1 PANDALAM THEKKEKARA SERVICE CO-OPERATIVE BANK LTD.329
THATTAYIL P.O., PATHANAMTHITTA - 691525, REPRESENTED
BY ITS SECRETARY T.K. ANANTHAKRISHNAN, S/O T.K.
KRISHNAKURUP, AGED 51 YEARS THULASIMANDARAM, MALLIKA,
THATTAYIL P.O., PATHANAMTHITTA - 691525.
2 ENATHU SERVICE CO-OPERATIVE BANK LTD. NO. 2529,
ENATHU P.O. PATHANAMTHITTA - 691554, REPRESENTED BY
ITS SECRETARY, AMBIKAKUMARI M., W/O AGITHA KUMAR,
AGED YEARS, KUDAMUKKU, MAMOODU P.O., PATHANAMTHITTA-
689513
3 PALLICKAL SERVICE CO-OPERATIVE BANK LTD. NO.722
ELAMPALLIL, PAYYANALLOOR P.O., PATHANAMTHITTA -
691523, REPRESENTED BY ITS SECRETARY, SIVAPRABHA
A.G., AGED 41 YEARS, W/O THULASEEDHARAN NAIR,
VINAKAYAKAM HOUSE, PALLICKAL, NOORANAD P.O.,
PATHANAMTHITTA 690504.
BY ADV SRI.K.SHAJ
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
2025:KER
W.P(C)No.7053/2023 & Connected cases 610
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001,
REPRESENTED BY ITS CHAIRMAN
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI - 682018.
4 THE ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF
INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM-695003
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM-695003
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695001
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 611
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14425 OF 2022
PETITIONER/S:
THE NEDUMPRAM SERVICE CO-OPERATIVE BANK LTD NO.A 205
NEDUMBRAM P.O, THIRUVALLA, PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY PIN 689 110
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE,NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM,
PIN 682 018
3 THE INCOME TAX OFFICER (TDS)
AARATTUKULAKKARA COMPLEX, A N PURAM, ALAPUZHA
DISTRICT 686 011
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033
5 THE DEPUTY GENERAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, PATHANAMTHITTA
DISTRICT OFFICE, PATHANAMTHITTA, PIN 689 645
2025:KER
W.P(C)No.7053/2023 & Connected cases 612
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 613
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14559 OF 2022
PETITIONER/S:
1 CALICUT CITY SERVICE CO-OPERATIVE BANK LTD.,
D.2777, CHALAPPURAM P.O., CALICUT - 673 002,
REPRESENTED BY ITS GENERAL MANAGER.
2 OLAVANNA VANITHA SAHAKARANA SANGAM LTD.NO.D 2770,
PALAZHI - PALA, G.A.COLLEGE P.O., CALICUT - 673 014
REPRESENTED BY ITS SECRETARY.
3 KOZHIKODE TOWN VANITHA SAHAKARANA SANGAM LTD.NO.D
2816,
MANKAVU GREENS, AZHCHAVATTOM P.O., KOZHIKODE - 673
007 REPRESENTED BY ITS SECRETARY.
4 BEYPORE VANITHA SAHAKARANA SANGAM LTD.NO.D 2784,
ARAKKINAR P.O., BEYPORE, KOZHIKODE - 673 023,
REPRESENTED BY ITS SECRETARY.
5 FEROKE VANITHA SAHAKARANA SANGAM LTD.NO.D 2467,
PERUMUGAM P.O., FEROKE, KOLLAMPARAM, KOZIKODE - 673
631 REPRESENTED BY ITS SECRETARY.
BY ADVS.
SRI.B.S.SWATHI KUMAR
SMT.ANITHA RAVINDRAN
SRI.HARISANKAR N UNNI
SHRI.SARANGADHARAN P.
SMT.N.S.SHAMILA
2025:KER
W.P(C)No.7053/2023 & Connected cases 614
RESPONDENT/S:
1 THE ASSISTANT COMMISSIONER OF INCOME TAX,
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR
P.O.,THIRUVANANTHAPURAM, PIN - 695 003.
2 THE CENTRAL BOARD OF DIRECT TAXES,
REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143E, NORTH
BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NEW DELHI, PIN - 110
001.
3 UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI, PIN - 110 001.
4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
KERALA STATE, THIRUVANANTHAPURAM, PIN - 695 001.
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695 001.
6 THE KERALA STATE CO-OPERATIVE BANK,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN -695 033.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 615
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14687 OF 2022
PETITIONER/S:
KANNADI AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
,
YAKKARA, KANNADI P.O., KERALA 678 701, REPRESENTED BY
ITS HONORARY SECRETARY, K. SELVAN.
BY ADVS.
SRI.K.ANAND
SHRI.BENNY ANTONY PAREL
RESPONDENT/S:
1 THE UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HIL, NEW
DELHI 110 001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
682 018.
4 THE KERALA BANK
(THE KERALA STATE CO - OPERATIVE BANK LTD.), CO- BANK
TOWERS, PALAYAM, THIRUVANANTHAPURAM 695
2025:KER
W.P(C)No.7053/2023 & Connected cases 616
033,REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA BANK
(THE KERALA STATE CO-OPERATIVE BANK LTD.), REGIONAL
OFFICE, PALAKKAD H.P.O. ROAD, SULTHANPET, PALAKKAD
678 001, REPRESENTED BY ITS GENERAL MANAGER.
6 THE KERALA BANK ,
(THE KERALA STATE CO - OPERATIVE BANK LTD.,) (ERST
WHOLE PALAKKAD CO-OPERATIVE BANK LTD), MURIKKAVU
(WEST YAKKARA) BRANCH, PALAKKAD 678 001. REPRESENTED
BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 617
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14715 OF 2022
PETITIONER/S:
1 THE CHERUPUZHA URBAN CO-OPERATIVE SOCIETY LTD NO.C
1565
CHERUPUZHA P.O., KANNUR-670511 REPRESENTED BY ITS
SECRETARY K.S JEEVAN.
2 THE PAYYANUR URBAN CO-OPERATIVE SOCIETY LTD NO. C
1556
PAYYANUR P.O., KANNUR-670307 REPRESENTED BY ITS
SECRETARY MANOJ KUMAR B.
3 THE PAYYANUR CHAMBER OF COMMERCE MERCHANTS WELFARE
CO-OPERATIVE SOCIETY LTD NO. C 1830
PAYYANUR P.O., KANNUR-670307 REPRESENTED BY ITS
SECRETARY RATNALATHA K.T.
4 PAYYANUR BLOCK AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD, NO C 1592
P.O. PAYYANNUR, KANNUR-670307 REPRESENTED BY ITS
SECRETARY VINODKUMAR P.V.
5 SOCIAL WORKERS WELFARE COOPERATIVE SOCIETY LTD, C
1911
KANDAKORAN MUKKU ANNUR P.O., PAYYANNUR, KANNUR-670307
REPRESENTED BY ITS SECRETARY JISHA K.V.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
2025:KER
W.P(C)No.7053/2023 & Connected cases 618
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695001.
BY ADVS.
SHRI.JOSE ANTONY, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 619
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14806 OF 2022
PETITIONER/S:
POOKKOTTOOR RURAL CO-OPERATIVE SOCIETY LTD.
NO.M-1039, ARAVANKARA, POOKKOTTOOR P.O, MALAPPURAM
DISTRICT, PIN-676517, REPRESENTED BY ITS HONORARY
SECRETARY
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-11000.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O, MALAPPURAM DISTRICT, PIN-676101
4 MALAPPURAM DISTRICT CO-OPERATIVE SOCIETY LTD,
HEAD OFFICE MAJERI ROAD, MALAPPURAM, PIN-57650.
REPRESENTED BY ITS GENERAL MANAGER
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 620
THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON
25.10.2025, ALONG WITH WP(C).7053/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 621
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14807 OF 2022
PETITIONER/S:
1 THRISSUR DISTRICT INDUSTRIAL MANUFACTURERS CO-
OPERATIVE SOCIETY LTD. NO. R.1174
KOLUZHY F.O, THRISSUR, PIN- 680010 REPRESENTED BY ITS
SECRETARY B.V. MINI.
2 THE KERALA FOREST RESEARCH INSTITUTE EMPLOYEE'S CO-
OPERATIVE SOCIETY 18
PEECHI PO, THRISSUR DISTRICT, PIN 680653 REPRESENTED
BY SECRETARY GOPAKUMAR P.
3 PEECHI VANITHA CO-OPERATIVE SOCIETY LTD NO. R.1374
M.G ROAD, PATTIKKAD P.O, THRISSUR, PIN-680652
REPRESENTED BY ITS SECRETARY PRINCY T.K.
4 MUDAPPILAVU VANITHA CO-OPERATIVE SOCIETY LTD NO.R.
1446
MUDAPPILAVU ROAD, CHIYARAM P.O, THRISSUR DISTRICT,
PIN 680026 REPRESENTED BY SECRETARY -IN- CHARGE
RADHIKA RAJU.
5 KIPPARAMBU JANAKE HERA SAHAKARINA SANGAM LTD.NO.1654
KAIPARAMBU PO, THRISSUR PIN-680545 REPRESENTED BY ITS
SECRETARY DHANYA M.S.
6 MALA BLOCK TOWN CO OPERATIVE BANK LTD NO. R 1086
ALOOR PO, THRISSUR DISTRICT PIN 680683 REPRESENTED BY
SECRETARY SHAJU V.O.
BY ADV SHRI.C.A.JOJO
2025:KER
W.P(C)No.7053/2023 & Connected cases 622
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018.
3 THE INCOME TAX OFFICER(TDS)
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680001.
4 THE KERALA (ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE
BANK)
SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD,
THRIRUVAMBADI P.O, THRISSUR, PIN-680022 REPRESENTED
BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 623
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14811 OF 2022
PETITIONER/S:
VILAYUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
P-1379
VILAYUR P.O., PATTAMBI TALUK, PALAKKAD DISTRICT, 679
309,REPRESENTED BY ITS SECRETARY SMT. GEETHA K.S.
BY ADV SRI.A.HAROON RASHEED
RESPONDENT/S:
1 THE UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
MINISTRY OF FINANCE, NORTH BLOCK, RAISAN HILL, NEW
DELHI 110 001. REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX
(TDS), CENTRAL REVENUE BUILDING, IS. PRESS ROAD,
ERNAKULAM 682 018.
4 THE KERALA STAT CO-OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM,THIRUVANANTHAPURAM , 695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA STATE CO -OPERATIVE BANK ,
REGIONAL OFFICE, P.B. NO. 21, H.P.O. ROAD,
SULTHANPET, PALAKKAD 678 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 624
6 MANAGER,
THE KERALA STATE CO-OPERATIVE BANK, KOPPAM BRANCH,
PALAKKAD 679 307.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 625
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14832 OF 2022
PETITIONER/S:
1 KANNUR DISTRICT EX-SERVICEMEN MULTIPURPOSE CO-
OPERATIVE SOCIETY LTD.
NO.C 1009, REPRESENTED BY ITS SECRETARY,
P.O.PAYANGADI R.S., KANNUR - 670 358.
2 PAYANGADI PEOPLES SOCIAL WELFARE CO-OPERATIVE SOCIETY
LTD.
NO.C 2044, REPRESENTED BY ITS SECRETARY,
P.O.PAYANGADI R.S., KANNUR - 670 358.
3 PAYANGADI LABOUR WELFARE CO-OPERATIVE SOCIETY LTD.
NO.C 1650, REPRESENTED BY ITS SECRETARY,
P.O.PAYANGADI R.S., KANNUR - 670 358.
4 THE MADAI AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY
LTD.
NO.C 1838, REPRESENTED BY ITS SECRETARY, P.O.MADAI,
KANNUR - 670 304.
5 NORTH MALABAR PUBLIC WELFARE CO-OPERATIVE SOCIETY
LTD.
NO.C 1976, REPRESENTED BY ITS SECRETARY, PILATHARA,
KANNUR - 670 501.
6 KANNUR TOURISM CO-OPERATIVE SOCIETY LIMITED (KATCOS)
NO.C 1560, REPRESENTED BY ITS SECRETARY, SREEKRISHNA
COMPLEX, ONDEN ROAD, KANNUR - 670 001.
BY ADV SHRI.P.N.MOHANAN
2025:KER
W.P(C)No.7053/2023 & Connected cases 626
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110
001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, ATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM - 695 003.
5 INCOME TAX OFFICER (TDS)
MELE CHOVVA, KANNOTHUMCHAL, KANNUR - 670 006.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 627
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14838 OF 2022
PETITIONER/S:
KARAKULAM SERVICE CO-OPERATIVE BANK LTD
KP-1/382, KARAKULAM-P.O, NEDUMANGAD, TRIVANDRUM-
695564. REPRESENTED BY ITS SECRETARY,
SHRI.B.BIJUKUMAR.
BY ADVS.
SRI.T.M.SREEDHARAN (SR.)
SRI.ALAN PRIYADARSHI DEV
SRI.V.P.NARAYANAN
RESPONDENT/S:
1 UNION OF INDIA
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-
110001.REPRESENTED BY ITS SECRETARY.
2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI-682018.
3 THE CHAIRMAN,
CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 628
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, VIKAS BHAVAN, PALAYAM,
THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS GENERAL
MANAGER.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
VATTIYOORKAVU BRANCH,
VATTIYOORKAVU,THIRUVANANTHAPURAM-695013, REPRESENTED
BY ITS BRANCH MANAGER.
6 KERALA STATE CO-OPERATIVE CONSUMBER FEDERATION -
CONSUMERFED
GANDHINAGAR, ERNAKULAM-600020, REPRESENTED BY ITS
GENERAL MANAGER.
BY ADVS.
SHRI.THOMAS ABRAHAM
SHRI.M.SASINDRAN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 629
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14857 OF 2022
PETITIONER/S:
VILAYUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
P-1379,
VILAYUR.P.O, PATTAMBI TALUK, PALAKKAD DISTRICT-
679309,REPRESENTED BY ITS SECRETARY SMT.GEETHA.K.S.
BY ADV SRI.A.HAROON RASHEED
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE CENTRAL BOARD OF DIRECT TAXES
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001, REPRESENTED BY ITS SECRETARY.
3 THE COMMISSIONER OF INCOME TAX(TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS,PALAYAM, THIRUVANANTHAPURAM,PIN-695033,
RERPESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
REGIONAL OFFICE, P.B.NO.21, H.P.O.ROAD, SULTHANPET,
PALAKKAD-678001, REPRESENTED BY ITS GENERAL MANAGER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 630
6 THE MANAGER,
THE KERALA STATE CO-OPERATIVE BANK, KOPPAM BRANCH,
PALAKKAD-679307.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 631
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14944 OF 2022
PETITIONER/S:
THRIKKATIRI MULTIPURPOSE CO-OP. SOCIETY LTD NO. P
1332
KIZHOOR ROAD, THRIKKATIRI P.O., OTTAPPALAM, PALAKKAD
DISTRICT, KERALA -679 502 REPRESENTED BY ITS
SECRETARY, PRASAD S.
BY ADVS.
SRI.K.ANAND
SHRI.BENNY ANTONY PAREL
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 001
2 THE CENTRAL BOARD OF DIRECT TAXES
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI - 110 001 REPRESENTED BY SECRETARY
3 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN - 682 018
4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD.
2025:KER
W.P(C)No.7053/2023 & Connected cases 632
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695
033 REPRESENTED BY ITS MANAGING DIRECTOR
5 THE KERALA BANK( THE KERALA STATE CO-OPERATIVE BANK
LTD.
REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET,
PALAKKAD 678 001 REPRESENTED BY ITS GENERAL MANAGER
6 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD.
(ERSTWHILE PALAKKAD CO-OPERATIVE BANK LTD)
CHERPULASSERY BRANCH, PALAKKAD 679 503, REPRESENTED
BY ITS GENERAL MANAGER
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 633
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 14960 OF 2022
PETITIONER/S:
THE CHERPULASSERY MUNICIPAL PRAVASI CO-OPERATIVE
SOCIETY LTD NO. P 1397,
CHERPULASSERY, PALAKKAD DISTRICT, KERALA-679503,
REPRESENTED BY ITS SECRETARY, ABDUL NAZAR.K.
BY ADV SRI.K.ANAND
RESPONDENT/S:
1 THE UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE,NORTH BLOCK, RAISANA HILL, NEW DELHI-
110001.
2 THE CENTRAL BOARD OF DIRECT TAXES
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001, REPRESENTED BY SECRETARY.
3 THE COMMISSIONER OF INCOME TAX(TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN-682018.
4 THE KERALA BANK(THE KERALA STATE CO-OPERATIVE BANK
LTD.),
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-
695033.REPRESENTED BY ITS MANAGING DIRECTOR.
5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK
LTD.),
2025:KER
W.P(C)No.7053/2023 & Connected cases 634
REGIONAL OFFICE, PALAKKAD.H.P.O.ROAD, SULTHANPET,
PALAKKAD-678001, REPRESENTED BY ITS GENERAL MANAGER.
6 THE KERALA BANK(THE KERALA STATE CO-OPERATIVE BANK
LTD.),
(ERSTWHILE PALAKKAD CO-OPERATIVE BANK LTD),
CHERPULASSERY BRANCH, PALAKKAD-679503, REPRESENTED BY
ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 635
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15027 OF 2022
PETITIONER/S:
THE ERNAKULAM DISTRICT CO-OPERATIVE EMPLOYEES'
HOUSING CO-OPERATIVE SOCIETY LTD NO. E 933, ERNAKULA
ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110
001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN 682 018.
3 THE INCOME TAX OFFICER, (TDS),
INCOME TAX DEPARTMENT, ERNAKULAM- PIN 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033.
5 THE MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD., ERNAKULAM MAIN
BRANCH, NORTH PARUR, PIN 682 016.
2025:KER
W.P(C)No.7053/2023 & Connected cases 636
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 637
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15066 OF 2022
PETITIONER/S:
1 THE PANANCHERY SERVICE CO-OPERATIVE BANK LTD NO 541
1.PANANCHERY, THRISSUR, REPRESENTED BY ITS
SECRETARY., PIN - 680652
2 OLLUKKARA SERVICE CO-OPERATIVE BANK LTD.NO.544
MANNUTHY, THRISSUR. REPRESENTED BY ITS SECRETARY.,
PIN - 680655
3 THE VELLANIKKARA SERVICE CO-OPERATIVE BANK LTD NO.
545
VELLANIKKARA, P.O, MADAKKATRA, THRISSUR, REPRESENTED
BY ITS SECRETARY., PIN - 680654
4 MOORKANIKKARA SERVICE CO-OPERATIVE BANK LTD.NO.199
4.P.O.KOZHUKULLY, THRISSUR DISTRICT , REPRESENTED BY
ITS SECRETARY., PIN - 680014
5 THE KUTTANELLUR SERVICE CO-OPERATIVE BANK LTD.NO. 758
5.P.O. KUTTANELLUR, THRISSUR -14, REPRESENTED BY ITS
SECRETARY., PIN - 680014
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 638
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682 018
3 THE INCOME TAX OFFICER (TDS)
3.OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD
4.O-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695
033, REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SHRI.P.VIJAYAKUMAR, ASG OF INDIA
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 639
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15438 OF 2022
PETITIONER/S:
1 PAZHASSI VANITHA CO-OPERATIVE SOCIETY LTD.
NO. C-1299, 8TH MILE, P.O, MAYYIL KANNUR- 670602,
REPRESENTED BY ITS SECRETARY SUDHAMANI K.V.
2 IRITTY AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY
LTD, NO.C.1798,
KOLIKKADAVU, P.O, PAYAM, KANNUR-670704 REPRESENTED BY
ITS SECRETARY REMYA P. V.
3 SIVAPURAM VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.
NO. C-2086,
SIVAPURAM P.O, KANNUR-670702 REPRESENTED BY ITS
SECRETARY RIBINA V.K.
4 THALASSERY MUNICIPAL VANITHA SAHAKARANA SANGHAM LTD.
NO.C2084,
THALASSERY, KANNUR-670702 REPRESENTED BY ITS
SECRETARY SINI Y.P.
5 THIRUVANGAD VANITHA SAHAKARANA SANGHAM LTD.
NO.C.1782,
P.O, THIRUVANGAD THALASSERY, KANNUR-670703
REPRESENTED BY ITS SECRETARY RANJISHA M.P.
6 AZHIKODE VANITHA SERVICE SAHAKARANA SANGHAM LTD.
NO.C. 1505,
P.O.AZHIKODE, KANNUR- 670009 REPRESENTED BY ITS
SECRETARY LATHA V.V.
7 COCONUT TAPPING WORKERS SERVICE COOPERTAIVE SOCIETY
(COTSCO) LTD NO.C.1080,
2025:KER
W.P(C)No.7053/2023 & Connected cases 640
H.O SREEKANDAPURAM, KANNUR- 670602 REPRESENTED BY ITS
SECRETARY ANIL KUMAR.P.
8 PANOOR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO. C
1490,
PANOOR P.O., KANNUR670 692 REPRESENTED BY ITS
SECRETARY APARNA P.M.
9 EDAYANNUR VANITHA CO-OPERATIVE SOCIETY, LTD.
NO.C.1226,
EDAYANNUR P.O, KANNUR- 670595 REPRESENTED BY ITS
SECRETARY JEEJA C.H.
10 THALASSERY VANITHA CO-OPERATIVE SOCIETY LTD NO. C.
1187,
MAIN ROAD, THALASSERY, KANNUR-670101 REPRESENTED BY
ITS SECRETARY SAVITHA P.V.
11 THE PAYANGADI CO-OPERATIVE HOUSING SOCIETY LTD NO. C.
832,
P.O PAYYANGADI, KANNUR-670303 REPRESENTED BY ITS
SECRETARY SREEDHEESH P.V.
12 PAZHAYANGADI AREA PUBLIC SERVANTS AND PENSIONERS
WELFARE CO-OPERATIVE SOCIETY LTD. NO.C.1628,
P.O PAZHAYANGADI, KANNUR670358 REPRESENTED BY ITS
SECRETARY VINOD.A.
13 GRAMIKA VANITHA CO-OPERATIVE SOCIETY LTD NO. C. 1431,
P.O KOORARA, KANUUR- 670694 REPRESENTED BY ITS
SECRETARY VIJILA K.P.
14 ERUVESSY VANITHA CO-OPERATIVE SOCIETY LTD
NO. C. 1170, P.O CHEMPERI, KANNUR- 670632 REPRESENTED
BY ITS SECRETARY REMYA T.RAJ.
15 VARAPRA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD,
NO.C.1449.,
P.O CHENDAYAD, KANNUR-670692 REPRESENTED BY ITS
SECRETARY LIBISHA A.V.
16 PAYANGADI VANITHA SERVICE CO-OPERATIVE SOCIETY LTD
NO. C.1658,
SAFAS COMPLEX, MOTTAMBRAM, P.O MADAYI, KANNUR-670304
2025:KER
W.P(C)No.7053/2023 & Connected cases 641
REPRESENTED BY ITS SECRETARY SHEEJA.V.
17 KURUMATHUR VANITHA SAHAKARANA SANGHAM LTD. NO.C.1730,
KURUMATHUR P.O, KANNUR670142, REPRESENTED BY ITS
SECRETARY USHA.P.
18 MANGATTIDOM VANITHA SERVICE CO-OPERATIVE SOCIETY LTD,
NO.C.1433,
P.O SANKARANELLUR, KANNUR-670643 REPRESENTED BY ITS
SECRETARY JISHA V.K.
19 CHAVASSERY VANITHA CO-OPERATIVE SOCIETY LTD.
NO.C.1511,
P.O CHAVASSERY, KANNUR670702, REPRESENTED BY ITS
SECRETARY SMITHA.P.
20 KANNUR VANITHA CO-OPERATIVE SOCIETY LTD, NO.C.1670,
P.O.,
H.Q HOSPITAL, KANNUR- 670017 REPRESENTED BY ITS
SECRETARY BINDU.T.M.
21 PAYYANUR BLOCK MERCHANTS AND INDUSTRIALIST WELFARE CO
OPERATIVE SOCIETY, LTD NO.C1527,
KANKOL P.O, KANNUR. 670307, REPRESENTED BY ITS
SECRETARY SURESH A.P.
22 IRITTY MOTOR TRANSPORT AND MECHANICAL WORKERS WELFARE
CO-OPERATIVE SOCIETY LTD.C.1507,
IRIKKUR ROAD, IRITTY, KANNUR-670703, REPRESENTED BY
ITS SECRETARY SUNITHA. M.
23 NADUVIL VILLAGE VANITHA SAHAKARANA SANGAHAM
LTD.NO.C.1606,
NADUVIL P.O., KANNUR-670582, REPRESENTED BY ITS
SECRETARY RATHNAVALLY P.P.
24 OLAYAMBADI AGRICULTURAL WELFARE COOPERATIVE SOCIETY
LTD NO. C 1918,
OLAYAMBADI, KANNUR- 670306 REPRESENTED BY ITS
SECRETARY SUKANYA.K.
25 KAVIYOOR VANITHA CO-OPERATIVE SOCIETY LTD.NO.C.1533,
P.O OLAVILAM, KANNUR- 673313 REPRESENTED BY ITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 642
SECRETARY SUDHA.M.
26 PAPPINISSERI AGRICULTURE PRODUCERS AND TODDY WORKERS
WELFARE CO-OPERATIVE SOCIETY LTD.NO.C-2124,
PAPPINISSERI AGRICULTURE PRODUCERS AND TODDY WORKERS
WELFARE CO-OPERATIVE SOCIETY LTD.NO.C-2124, (PATCO)
ERIPURAM, P.O PAYANGADI, KANNUR-670303 REPRESENTED BY
ITS SECRETARY RATHI A.V.
27 PANNIYANNUR PANCHAYATH VANITHA SERVICE CO-OPERATIVE
SOCIETY LTD.NO.C.1472,
MANEKKARA, PANNIYANNUR P.O., KANNUR670679,
REPRESENTED BY ITS SECRETARY SEENA T.K.
28 SREEKANDAPURAM PATTIKAJATHI VIKASANA SAHAKARANA
SANGHAM, LTD.NO.C.1072,
P.O., SREEKANDAPURAM, KANNUR-670631 REPRESENTED BY
ITS SECRETARY PREETHA.P.
29 THE TALIPARAMBA BLOCK VANITHA CO-OPERATIVE SOCIETY
LTD, NO.C.944,
TALIPARAMBA, KANNUR670141 REPRESENTED BY ITS
SECRETARY MINIMOL M.V.
30 KOOVERI VILLAGE VANITHA SERVICE CO - OPERATIVE
SOCIETY LTD, NO.C. 1439,
KOOVERI P.O, KANNUR-670581 REPRESENTED BY ITS
SECRETARY SREEJA.V.K.
31 IRITTY CO-OPERATIVE EMPLOYEES WELFARE COOPERATIVE
SOCIETY LTD, NO C 1790,
KEEZHUR, P.O. IRITTY, KANNUR-670703 REPRESENTED BY
ITS SECRETARY PRAJITH P.
32 KUTHUPARAMBA VANITHA SERVICE CO-OPERATIVE SOCIETY
LTD, NO C 1504,
P.O. KUTHUPARAMBA, KANNUR-670643 REPRESENTED BY ITS
SECRETARY REEJA R.
33 PAPPINISSERI VANITHA SAHAKARANA SANGAM LTD, NO C
1219,
P.O. PAPPINISSERI, KANNUR-670561, REPRESENTED BY ITS
SECRETARY SHEEJA E.K.
2025:KER
W.P(C)No.7053/2023 & Connected cases 643
34 CHERUPAZHASSI VANITHA SAHAKARANA SANGAM, NO C 2072,
ARAYIDATHUCHIRA, P.O. CHERUPAZHASSI, KANNUR-670601
REPRESENTED BY ITS SECRETARY GEETHA K.
35 KANNUR GOVERNMENT AYURVEDA COLLEGE EMPLOYEES CO-
OPERATIVE SOCIETY LTD, NO C 1520,
P.O. PARIYARAM, KANNUR-670503 REPRESENTED BY ITS
SECRETARY SANISHA P.
36 NADUVIL PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD,
NO C 1208,
P.O. KARUVANCHAL, KANNUR- 670571, REPRESENTED BY ITS
SECRETARY LINTA JACOB.
37 KALAVALLOOR VANITHA CO-OPERATIVE SOCIETY LTD, NO C
1436,
KUNNOTHPARAMBA, P.O. CHERUPARAMBA, KANNUR-670693
REPRESENTED BY ITS SECRETARY RANJISHA C.
38 EMPLOYEES, PENSIONERS & PUBLIC WELFARE COOPERATIVE
SOCIETY LTD, NO C 1787,
KODIKANDY COMPLEX, CHALODE P.O. EDAYANNUR, KANNUR-
670595 REPRESENTED BY ITS SECRETARY VINEESHA M.
39 KOTHERI VANITHA CO-OPERATIVE SOCIETY LTD, NO C 1804,
KOTHERI, P.O. MATTANUR, KANNUR-670702, REPRESENTED BY
ITS SECRETARY BINDU C.P.
40 MALUR PANCHAYATH VANITHA SERVICE COOPERATIVE SOCIETY
LTD, NO C 1496,
P.O. MALUR, KANNUR- 670702, REPRESENTED BY ITS
SECRETARY AJITHA JANARDHANAN.
41 PANOOR TOWN PEOPLE'S WELFARE CO-OPERATIVE SOCIETY
LTD, NO C 1917,
P.O. PANOOR, KANNUR670692 REPRESENTED BY ITS
SECRETARY SAYANA P.V.
42 KUNHIMANGALAM PUBLIC WELFARE CO-OPERATIVE SOCIETY
LTD, NO C 2008,
ANDAMKOVVAL, KUNHIMANGALAM P.O., KANNUR-670309,
REPRESENTED BY ITS SECRETARY SREERAJ K.P.
43 ERAMALA RURAL CREDIT CO-OPERATIVE SOCIETY LTD, NO D
2025:KER
W.P(C)No.7053/2023 & Connected cases 644
3303,
P.O. KUNNUMMAKKARA, CHOMBALA, KOZHIKODE- 673308,
REPRESENTED BY ITS SECRETARY ASOKAN K.K.
44 NELLIMOODU VANITHA CO-OPERATIVE SOCIETY LTD ;
NO.T.1334,
NELLIMOODU P.O, THIRUVANANTHAPURAM - 695524,
REPRESENTED BY ITS SECRETARY RESHMY V.R.
45 MARANALLOOR GRAMAVIKASANA CO-OPERATIVE SOCIETY LTD,
NO.T.1656,
OORUTTAMBALAM P.O, THIRUVANANTHAPURAM-695507
REPRESENTED BY ITS SECRETARY PRASEETHA CHANDRAN.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033
2025:KER
W.P(C)No.7053/2023 & Connected cases 645
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 646
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15480 OF 2022
PETITIONER/S:
ALAPPUZHA GOVT. SERVANTS' CO-OPEATIVE BANK LTD.NO A
208
COLLECTORATE JUNCTION, P.O ALAPPUZHA, PIN 685 005
REPRESENTED BY SECRETARY R SREEKUMAR.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018
3 INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX DEPT.ALAPPUZHA 688 011
4 THE KERALA STATE CO-OPERATIVE BANK LTD
(ERSTWHILE ALAPPUZHA DISTRICT CO-OPERATIVE BANK) OPP
MUNICIPAL TOWN HALL, ALAPPUZHA REGIONA, ALAPPUZHA,
KERALA 688 011
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 647
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 648
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15487 OF 2022
PETITIONER/S:
MALAPPURAM HOUSING CO-OPERATIVE SOCIETY LTD.
NO.M MOONAMPADI, MALAPPURAM P.0, MALAPPURAM DISTRICT,
PIN-REPRESENTED BY ITS HONORARY SECRETARY
BY ADVS.
SHRI.C.A.JOJO
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.E.S.M.KABEER,SC,MALAPPURAM DIST.CO-
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-11000.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O, MALAPPURAM DISTRICT, PIN-676101
4 MALAPPURAM DISCRICT CO-OPERATIV'S BANK LTD ,
HEAD OFFICE MARJERI MALAPPURAM PIN- 676505
REPRESENTED BY ITS GENERAL MANAGER
2025:KER
W.P(C)No.7053/2023 & Connected cases 649
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 650
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15518 OF 2022
PETITIONER/S:
1 KODUNGALLUR MULTI PURPOSE CO-OPERATIVE SOCIETY LTD
NO.R 1140
KODUNGALLUR P.O, THRISSUR, PIN 680 664, REPRESENTED
BY ITS SECRETARY SARITHA M.S.
2 KODUNGALLUR TALUK MULTI PURPOSE CO-OPERATIVE SOCIETY
LTD. NO. R 1126,
PALLIVALAVU, MATHILAKAM P.O, THRISSUR DISTRICT, PIN
680 685, REPRESENTED BY SECRETARY TO SMITHA C.V.
3 ANANDAPURAM RURAL CO-OPERATIVE SOCIETY LTD. NO. R
1326,
HOSPITAL JUNCTION, ANANDAPURAM P.O, THRISSUR, PIN 680
305, REPRESENTED BY ITS SECRETARY KANJANA NANDANAN.
4 IRINJALAKUDA BLOCK MULTI PURPOSE CO-OPERATIVE SOCIETY
LTD. NO. R 1183, MAPRANAM,
MADAYIKONAM P.O, THRISSUR, PIN 680 712, REPRESENTED
BY SECRETARY K.O. SHEEBA.
5 KAIPAMANGALAM KERA KARSHAKA CO-OPERATIVE SOCIETY LTD.
NO. R 1180,
KAIPAMANGALAM P.O, THRISSUR, PIN 680 046, REPRESENTED
BY ITS SECRETARY PREETHI M.P.
6 KODUNGALLUR TALUK, VYAPARI VYAVASAYI SAHAKARANA
SANGAM LTD. NO. R 1243,
KOTTAPURAM P.O, KODUNGALLUR, THRISSUR , PIN 680 687,
REPRESENTED BY SECRETARY REEJA M.V.
7 KODUNGALLUR GOVERNMENT SERVANT'S CO-OPERATIVE SOCIETY
2025:KER
W.P(C)No.7053/2023 & Connected cases 651
LTD. NO. R,
REPRESENTED BY ITS SECRETARY REKHA M.G.
8 PERINJANAM MULTI- PURPOSE CO-OPERATIVE SOCIETY LTD.
NO. R 1307,
PERINJANAM P.O, THRISSUR , PIN 680 686, REPRESENTED
BY ITS SECRETARY VIJAYALAKSHMI M.B.
9 PULLOOTTE VANITHA SAHAKARANA SANGAM LTD. NO. R, 1532,
PULLOOTTE P.O, KODUNGALLUR, THRISSUR DISTRICT, PIN
680 663 , REPRESENTED BY ITS SECRETARY VANI
VENUGOPAL.
0 KAIPAMANGALAM MULTI- PURPOSE CO-OPERATIVE SOCIETY
LTD. NO. R 1376,
KAIPAMANGALAM P.O, THRISSUR, PIN 680 681, REPRESENTED
BY ITS SECRETARY RAGI E.N.R.
11 MANAPPURAM SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD.
NO. R 1318, CHENDRAPINNI P.O,
THRISSUR, PIN 680 687, REPRESENTED BY ITS SECRETARY
LIJI E.N.B.
12 KAIPAMANGALAM VANITHA SAHAKARANA SANGAM LTD. NO. R
1461,
MOONUPEEDIKA, PERINJANAM P.O, THRISSUR, PIN 680 686,
REPRESENTED BY ITS SECRETARY JIJI V.T.
13 MURIYAD SERVICE CO-OPERATIVE BANK LTD. NO. 479,
MRIYAD P.O, THRISSUR DISTRICT, PIN 680 683,
REPRESENTED BY ITS SECRETARY, M.R. ANIYAN.
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI 110 001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 652
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS ROAD, ERNAKULAM, KOCHI
682 018.
3 THE INCOME TAX OFFICER (TDS),
AYAKAR BHVAN, SAKTHAN NAGAR, THRSSUR, PIN 680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK),
SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THIRUVAMBADI
P.O, THRISSUR DISTRICT CO-OPERATIVE BANK), SAHAKARANA
SAPTHDHI MANDIRAM, TUDA ROAD, THIRUVAMBADI P.O,
THRISSUR, PIN 680 022 REPRESENTED BY ITS GENERAL
MANAGER.
5 KODUNGALLUR TOWN CO-OPERATIVE BANK LTD.,
KODUNGALLUR P.O, THRISSUR, PIN 680 664, REPRESENTED
BY ITS GENERAL MANAGER.
6 IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD. ,
TANA JUNCTION, IRINJALAKUDA P.O, PIN 680 121,
REPRESENTED BY ITS GENERAL MANAGER.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 653
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15596 OF 2022
PETITIONER/S:
1 MADAI VANITHA CO-OPERATIVE SOCIETY LTD
NO.C-1205, VENGARA.P.O, KANNUR-670 305. REPRESENTED
BY ITS SECRETARY SUNEETHI.M.V.
2 MERCHANTS INDUSTRIALIST WELFARE CO-OPERATIVE SOCIETY
LTD,
NO.C-1902, KUTHUPARAMBA.P.O, KANNUR-670643
REPRESENTED BY ITS SECRETARY ASWATHI.K.
3 CENTRAL GOVERNMENT WMPLOYEES & WORKERS CO-OPERATIVE
CREDIT SOCIETY LTD,
NO. T 1413 USRA-17, UDARASIROMANY ROAD,
VAZHUTHACAUD,SASTHAMANGALAM P.O, THIRUVANANTHAPURAM-
695010, REPRESENTED BY ITS SECRETARY MANOJ.K.C.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE ,
MINISTRY OF FINANCE, GOVWERNMENT OF INDIA, NORTH
2025:KER
W.P(C)No.7053/2023 & Connected cases 654
BLOCK NEW DELHI-110001
2 THE CENTRAL BOARDOF DIRECT TAXES
DEPARTMENT OF REVENUE , MINISTRY OF FINANCE
GOVERNMENT OF INDIA, NORTHBLOCK NEW DELHI- 110001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
P.B.NO.6515. CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER,
5 STATE OF KERALA ,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM.695001
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 655
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15598 OF 2022
PETITIONER/S:
1 MADAI VANITHA CO-OPERATIVE SOCIETY LTD.
NO.C-1205, VENGARA P.O., KANNUR-670 305, REPRESENTED
BY ITS SECRETARY SUNEETHI.M.V.
2 MERCHANTS INDUSTRIALIST WELFARE CO-OPERATIVE SOCIETY
LTD.NO.C 1902,
KUTHUPARAMBA P.O., KANNUR-670 643, REPRESENTED BY ITS
SECRETARY ASWATHI.K.
3 CENTRAL GOVERNMENT EMPLOYEES & WORKERS CO OPERATIVE
CREDIT SOCIETY LTD.NO.T 1413,
USRA-17, UDARASIROMANY ROAD, VAZHUTHACAUD,
SASTHAMANGALAM P.O., THIRUVANANTHAPURAM-695 010,
REPRESENTED BY ITS SECRETARY MANOJ.K.C.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
2025:KER
W.P(C)No.7053/2023 & Connected cases 656
BLOCK, NEW DELHI-110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOIME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDING, IS PRESS ROAD,
KOCHI, ERNAKULAM-682 018.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
PB NO.6515, CO BANK TOWERS, PALAYM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001.
BY ADV SHRI.M.SASINDRAN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 657
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15789 OF 2022
PETITIONER/S:
1 THE AMMADAM SERVICE CO-OPERATIVE BANK LTD NO. 533
AMMADAM.P.O, THRISSUR 680563 REPRESENTED BY ITS
SECRETARY
2 THE PAZHUVIL SERVICE CO-OPERATIVE BANK LTD.NO.126
PAZHUVIL WEST, THRISSUR680564 REPRESENTED BY ITS
SECRETARY., PIN - 680564
3 THE KOORKENCHERY SERVICE CO-OPERATIVE BANK LTD NO. 36
P.O. KOORKENHERY, THRISSUR-680007, REPRESENTED BY ITS
SECRETARY -IN CHARGE.
4 THE VENGINISSERY SERVICE CO-OPERATIVE BANK LTD.NO.R
528
4.VENGINISSERY, THRISSUR 680563 REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
1.REPRESENTED BY THE SECRETARY TO GOVERNMENT OF
INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI-110001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682 018
2025:KER
W.P(C)No.7053/2023 & Connected cases 658
3 THE INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001
4 THE KERALA STATE CO-OPERATIVE BANK LTD
4.CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695
033, REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SHRI.P.VIJAYAKUMAR, ASG OF INDIA
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 659
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15825 OF 2022
PETITIONER/S:
1 THE VELLATTANJUR SERVICE CO-OPERATIVE BANK LTD.
NO.3906
P.O.VELLATTANJUR, THRISSUR - 680601, REPRESENTED BY
ITS SECRETARY.
2 VELUR SERVICE CO-OPERATIVE BANK LTD.NO.465
THALAPPILLY TALUK, THRISSUR 680601. REPRESENTED BY
ITS SECRETARY.
3 KECHERY SERVICE CO-OPERATIVE BANK LTD NO.R.286
P.O.KECHERY, THRISSUR 680501, REPRESENTED BY ITS
SECRETARY.
4 THAYYUR SERVICE CO-OPERATIVE BANK LTD.NO.95
4.THAYYUR, THRISSUR DISTRICT - 680584, REPRESENTED BY
ITS SECRETARY.
5 MATTOM SERVICE CO-OPERATIVE BANK LTD.NO.140
P.O. MATTOM, THRISSUR 680602, REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
1.REPRESENTED BY THE SECRETARY TO GOVERNMENT OF
INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI-110001.
2025:KER
W.P(C)No.7053/2023 & Connected cases 660
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682 018
3 THE INCOME TAX OFFICER (TDS)
3.OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SHRI.P.VIJAYAKUMAR, ASG OF INDIA
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 661
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15828 OF 2022
PETITIONER/S:
1 THE KARAMUCK SERVICE CO-OPERATIVE BANK LTD. NO.16
KARAMUCK, THRISSUR 680613, REPRESENTED BY ITS
SECRETARY.
2 THE MANALUR SERVICE CO-OPERATIVE BANK LTD.NO.3
P.O.MANALUR, THRISSUR-680617. REPRESENTED BY ITS
SECRETARY.
3 THE ANTHIKAD SERVICE CO-OPERATIVE SOCIETY LTD NO. 818
P.O. ANTHIKAD, THRISSUR 680641 , REPRESENTED BY ITS
SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELH, PIN - 110001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682018
3 THE INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR, PIN -
680001
2025:KER
W.P(C)No.7053/2023 & Connected cases 662
4 THE KERALA STATE CO-OPERATIVE BANK LTD
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN -
695033
BY ADVS.
SHRI.P.VIJAYAKUMAR, ASG OF INDIA
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.M.JAYAKRISHNAN, CGC
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 663
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 15874 OF 2022
PETITIONER/S:
1 THE PANANGAD SERVICE CO-OPERATIVE BANK LIMITED NO.
3928
POST BALUSSERY, KOZHIKODE , REPRESENTED BY THE
SECRETARY, PIN - 673612
2 CHATHAMANGALAM SERVICE CO-OPERATIVE BANK LIMITED NO.
F-1839
POST CHATHAMANGALAM, KOZHIKODE , REPRESENTED BY THE
SECRETARY, PIN - 673601
3 SIVAPURAM SERVICE CO-OPERATIVE BANK LIMITED NO. 6967
POST KARIYATHANKAVU, VIA BALUSSERY, KOZHIKODE,
REPRESENTED BY THE SECRETARY, PIN - 673612
4 THAMARASSERY SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1239
POST THAMARASSERY, KOZHIKODE , REPRESENTED BY THE
SECRETARY, PIN - 673573
5 UNNIKULAM SERVICE CO-OPERATIVE BANK LIMITED NO. D-
2356
POST EKAROOL, KOZHIKODE , REPRESENTED BY THE
SECRETARY, PIN - 673574
6 CHELANNUR SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1242
POST CHELANNUR, KOZHIKODE , REPRESENTED BY THE
SECRETARY, PIN - 673616
7 KARANNUR SERVICE CO-OPERATIVE BANK LIMITED NO. F-1244
POST ELATHUR, KOZHIKODE, REPRESENTED BY THE
2025:KER
W.P(C)No.7053/2023 & Connected cases 664
SECRETARY, PIN - 673303
8 NANMINDA CO-OPERATIVE RURAL BANK LIMITED NO. F-1238
POST NANMINDA, KOZHIKODE, REPRESENTED BY THE GENERAL
MANGER, PIN - 673613
9 KAKKUR SERVICE CO-OPERATIVE BANK LIMITED NO. LL-33
POST KAKKOOR, KOZHIKODE, REPRESENTED BY THE
SECRETARY, PIN - 673613
10 CHELAVOOR SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1513
POST CHELAVOOR, KOZHIKODE, REPRESENTED BY THE
SECRETARY, PIN - 673571
11 THE CALICUT NORTH SERVICE CO-OPERATIVE BANK LIMITED
NO. LL - 37
POST KARUVASSERY, KOZHIKODE, REPRESENTED BY THE
SECRETARY, PIN - 673010
12 VENGERI SERVICE CO-OPERATIVE BANK LIMITED NO. 2714
POST VENGERI, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673010
13 RAMANATTUKARA SERVICE CO-OPERATIVE BANK LIMITED NO.
7721
POST FEROKE COLLEGE, KOZHIKODE, REPRESENTED BY THE
GENERAL MANAGER, PIN - 673633
14 KURUVATTOOR SERVICE CO-OPERATIVE BANK LIMITED NO. D-
1973
POST KURUVATTOOR, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673811
15 PERUMANNA SERVICE CO-OPERATIVE BANK LIMITED NO. D-
1955
POST PERUMANNA, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673019
16 PERUVAYAL SERVICE CO-OPERATIVE BANK LIMITED NO. LL-26
POST PERUVAYAL, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673008
17 KOMMERI SERVICE CO-OPERATIVE BANK LIMITED NO. D-2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 665
POST KOMMERI, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673007
18 THE BEYPORE SERVICE CO-OPERATIVE BANK LIMITED NO. LL
- 35
POST ARAKKINAR, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673028
19 KUNNAMANGALAM CO-OPERATIVE RURAL BANK LIMITED NO. F-
1246
POST KUNNAMANGALAM KOZHIKODE, REPRESENTED BY THE
SECRETARY, PIN - 673570
20 THE FEROKE SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1095
POST FEROKE, KOZHIKODE, REPRESENTED BY THE SECRETARY,
PIN - 673631
21 PUTHIYANGADI SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1421
POST PUTHIYANGADI, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673021
22 THE CHERUKULATHOOR SERVICE CO-OPERATIVE BANK LIMITED
NO. F-775
POST CHERUKULATHOOR, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673008
23 THE MAVOOR SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1247
POST MAVOOR, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673661
24 IRINGALLUR - PALAZHY SERVICE CO-OPERATIVE BANK
LIMITED NO. F-1171
POST PALAZHY, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673014
25 THE KADALUNDI SERVICE CO-OPERATIVE BANK LIMITED NO.
F-1500
POST KADALUNDI, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673302
26 THE CALICUT TOWN SERVICE CO-OPERATIVE BANK LIMITED
2025:KER
W.P(C)No.7053/2023 & Connected cases 666
NO. D-2665
A.G. ROAD, KOZHIKODE, REPRESENTED BY THE GENERAL
MANAGER., PIN - 673001
27 OLAVANNA SERVICE CO-OPERATIVE BANK LIMITED NO. 2663
POST OLAVANNA, KOZHIKODE REPRESENTED BY THE
SECRETARY., PIN - 673019
28 MANNUR SERVICE CO-OPERATIVE RURAL BANK LIMITED NO. F-
1621
POST MANNUR, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673328
29 KATTIPPARA SERVICE CO-OPERATIVE BANK LIMITED NO. D-
2930
POST KATTIPPARA, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673573
30 AVILORA SERVICE CO-OPERATIVE BANK LIMITED NO. LL-69
POST AVILORA, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673572
31 PUDUPPADY SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1830
PUDUPPADY, KOZHIKODE, REPRESENTED BY THE SECRETARY.,
PIN - 673586
32 NARIKKUNI SERVICE CO-OPERATIVE BANK LIMITED NO. LL-
143
POST NARIKKUNI, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673585
33 KODUVALLY SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1240
POST KODUVALLY, KOZHIKODE , REPRESENTED BY THE
SECRETARY., PIN - 673572
34 THE THIRUVAMBADY SERVICE CO-OPERATIVE BANK LIMITED
NO. L-56
POST THIRUVAMBADY, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673603
35 KODANCHERY SERVICE CO-OPERATIVE BANK LIMITED NO. F-
1762
2025:KER
W.P(C)No.7053/2023 & Connected cases 667
POST KODANCHERY, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673580
36 KOODARANHI SERVICE CO-OPERATIVE BANK LIMITED NO. LL-
74
POST KOODARANHI, KOZHIKODE. REPRESENTED BY THE
SECRETARY., PIN - 673604
37 KODIYATHOOR SERVICE CO-OPERATIVE BANK LIMITED NO. D-
2417
ERANJIMAVU, POST PANNICODE, KOZHIKODE, REPRESENTED BY
THE SECRETARY., PIN - 673602
38 PANNIYANKARA SERVICE CO-OPERATIVE BANK LIMITED NO. D-
2694
P.O. KALLAI, KOZHIKODE, REPRESENTED BY THE
SECRETARY., PIN - 673003
BY ADVS.
SRI.R.SUDHISH
SMT.M.MANJU
SHRI.PRASHANTH KUMAR G.C.
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI., PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT) MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI, PIN -
110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD,
ERNAKULAM, PIN - 682018
2025:KER
W.P(C)No.7053/2023 & Connected cases 668
4 KERALA STATE CO-OPERATIVE BANK LIMITED
RREPRESENTED BY ITS CHIEF EXECUTIVE OFFICER CO-BANK
TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695033
5 STATE OF KERALA
REPRESENTED BY SECRETARY TO GOVERNMENT, DEPARTMENT OF
CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM., PIN - 695001
6 REGISTRAR OF CO-OPERATIVE SOCIETIES
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
STATUE JUNCTION, NEAR PRESS CLUB,
THIRUVANANTHAPURAM., PIN - 695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.C.SASIDHARAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 669
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 16074 OF 2022
PETITIONER/S:
1 THE KUTTEMPEROOR SERVICE CO-OPERATIVE BANK
LTD.NO.611,
KUTTEMPEROOR P.O., MANNAR, ALAPPUZHA-689 623.
REPRESENTED BY ITS SECRETARY SAJIKUMAR P.R.
2 THE BUDHANOOR SERVICE CO-OPERATIVE BANK LTD NO. A-
137,
BUDHANOOR P.O., CHENGANNUR, ALAPPUZHA-689510,
REPRESENTED BY ITS SECRETARY OMANA C.S.
3 ALA SERVICE CO-OPERATIVE BANK LTD NO 2123,
PENNUKKARA P.O., CHENGANNUR, ALAPPUZHA-689520
REPRESENTED BY ITS SECRETARY SREEJITH S.
4 CHERIYANAD SERVICE CO-OPERATIVE BANK LTD NO 99,
CHERIYANAD P.O., CHENGANNUR, ALAPPUZHA-689511
REPRESENTED BY ITS SECRETARY SANDHYA KUMARI S.
5 MANNAR SERVICE CO-OPERATIVE BANK LTD, NO 3997,
MANNAR P.Q., ALAPPUZHA-689622 REPRESENTED BY ITS
SECRETARY GREESHMA ROSE GEORGY.
6 KUTTEMPEROOR SERVICE CO-OPERATIVE BANK LTD NO.
1654,4,
KUTTEMPEROOR P.O., ALAPPUZHA689 623. REPRESENTED BY
ITS SECRETARY AJITHA.K.G.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
2025:KER
W.P(C)No.7053/2023 & Connected cases 670
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI: 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES ,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED
BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695001.
BY ADV SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 671
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 16243 OF 2022
PETITIONER/S:
ALUVA DESABHIVARDHINI SERVICE CO-OPERATIVE BANK
LIMITED
CO-OPERATIVE BUILDING, BYE PASS ROAD, PULINCHODE,
ALUVA, PIN-683 101, REPRESENTED BY ITS SECRETARY A.H
ABDUL RASHEED
BY ADVS.
SHRI.K.S.HARIHARAN NAIR
SMT.G.REMADEVI
SHRI.RAJATH R NATH
SMT.HARIMA HARIHARAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF
REVENUE ,MINISTRY OF FINANCE GOVERNMENT OF INDIA,
NORTH BLOCK, NEW DELHI- 110001.
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-
682018
3 THE INCOME TAX OFFICER (TDS),
KAP COMPLEX, HIGHWAY, SH 16, PERIYAR NAGAR, ALUVA,
PIN- 683101
2025:KER
W.P(C)No.7053/2023 & Connected cases 672
4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN
5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDI IS PRESS ROAD, KOCHI-
682018.
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM-695003
7 THE KERALA STATE CO-OPERATIVE BANK LTD.
(KERALA BANK) PO NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN- 695 033, REPRESENTED BY ITS
MANAGING DIRECTOR
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN-695 001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 673
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 16321 OF 2022
PETITIONER/S:
THE ELANTHOOR SERVICE CO-OPERATIVE BANK LTD NO.460,
ELANTHOOR P.O, KOZHENCHERRY, PATHANAMTHITTA DISTRICT-
689643 REPRESENTED BY ITS SECRETARY MRS. VEENA
V.A,AGED 35,W/O. DINESH CHANDRAN, RESIDING AT
VAZHAVILA PUTHENPARAMBIL, LAKKOOR,MALLASSERRY
P.O,PATHANAMTHITTA DISTRICT, PIN - 689646
BY ADV SRI.V.PHILIP MATHEWS
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO GOVERNMENT,MINISTRY
OF FINANCE , NORTH BLOCK, RAISANA HILL, NEW DELHI,
PIN - 110001
2 STATE OF KERALA
REPRESENTED BY BY SECRETARY, DEPARTMENT OF CO-
OPERATION, KERALA GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION,MINISTRY OF FINANCE, CENTRAL REVENUE
BUILDING,I.S.PRESS ROAD,ERNAKULAM, PIN - 682018
4 THE INCOMETAX OFFICER(TDS)
AARATTUKULAKKARA COMPLEX,A.N. PURAM,ALAPPUZHA, PIN -
688011
2025:KER
W.P(C)No.7053/2023 & Connected cases 674
5 THE KERALA STATE CO-OPERATIVE BANK LTD
COBANK TOWERS,PALAYAM,THIRUVANANTHAPURAM, REPRESENTED
BY ITS MANAGING DIRECTOR, PIN - 695033
6 THE DEPUTY GENERAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD(ERSTWHILE
PATHANAMTHITTA DISTRICT CO-OPERATIVE BANK
LTD),PATHANAMTHITTA DISTRICT OFFICE,MYLAPRA
ROAD,PATHANAMTHITTA, PIN - 689645
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 675
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 16459 OF 2022
PETITIONER/S:
PERUMPAZHUTHOOR SOCIAL WELFARE CO-OPERATIVE SOCIETY
LTD.NO.T 1952,
PERUMPAZHUTHOOR P.O., NEYYATTINKARA,
THIRUVANANTHAPURAM-695126 ,REPRESENTED BY ITS
SECRETARY
BY ADVS.
SHRI.MOHAN DAS A.
SHRI.GOVIND R.
RESPONDENT/S:
1 UNION OF INDIA
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NORTH
BLOCK, RAISINA HILL, NEW DELHI - 110001 REPRESENTED
BY THE SECRETARY TO THE GOVERNMENT OF INDIA
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI - 110001 REPRESENTED
BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
ERNAKULAM - 682018
2025:KER
W.P(C)No.7053/2023 & Connected cases 676
4 ADDITIONAL COMMISSIONER OF INCOME TAX .
TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM - 695003
5 INCOME TAX OFFICER(TDS)
3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANTHAPURAM-
695003,
6 THE KERALA STATE CO-OPERATIVE BANK LTD,
(ERSTWHILE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE
BANK LTD), P.B.NO. 5122, EAST FORT,
FORT.P.O,THIRUVANANTHAPURAM 695 023 REPRESENTED BY
ITS MANAGER.
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 677
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 16598 OF 2022
PETITIONER/S:
1 VATKARA BLOCK PENSIONERS SOCIAL WELFARE SAHAKARANA
SANGAM LTD. NO. D 3213,
V.V. ARCADE, VELLIKULANGARA, ORKKATTERI P.O,
KOZHIKODE 673 501, REPRESENTED BY ITS SECRETARY
PRAJEESH K.
2 VELLIKULANGARA AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD. NO. D 3143,
ORKKATTERI P.O, VATAKARA, KOZHIKODE 673 501,
REPRESENTED BY ITS SECRETARY SAVITHA A.
3 VATAKARA BLOCK AGRICULTURIST AND WORKERS WELFARE CO-
OPERATIVE SOCIETY LTD. NO. D 3152,
ORIKKATTERI P.O, VATAKARA, KOZHIKODE 673 501.,
REPRESENTED BY ITS SECRETARY SANTHOSH A.K.
4 CHORODE PANCHAYATH AGRICULTURAL WORKERS WELFARE CO-
OPERATIVE SOCIETY LTD. NO. D 3191,
VAIKKILASSERY THERU, VAIKKILASSERY P.O, VATAKARA,
KOZHIKODE 673 104, REPRESENTED BY ITS SECRETARY,
SATHEESHKUMAR K.
5 NEERVELI VANITHA SERVICE CO-OPERTIVE SOCIETY LTD. NO.
C 1409,
NEERVELI P.O, KANNUR 670 701, REPRESENTED BY ITS
SECRETARY MINI.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
2025:KER
W.P(C)No.7053/2023 & Connected cases 678
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE ,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI 110 001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
, NEW DELHI 110 001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI 682 018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
P.B. NO. 6515, CO- BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695 001.
BY ADVS.
SRI.CHRISTOPHER ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 679
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 16805 OF 2022
PETITIONER/S:
THE EZHUMATTOOR SERVICE CO-OPERATIVE BANK LTD.
NO.1546
EZHUMATTOOR P.O.,PATHANAMTHITTA - 689586, REPRESENTED
BY ITS SECRETARY ALEXANDER C.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE,GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA,NORTH BLOCK NEW DELHI- 110001,REPRESENTED BY
ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
2025:KER
W.P(C)No.7053/2023 & Connected cases 680
KERALA REGION,MINISTRY OF FINANCE, GOVERNMENT OF
INDIA,CENTRAL REVENUE BUILDINGS,IS PRESS ROAD,KOCHI-
682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO. 6515, CO-BANK
TOWERS,PALAYAM,THIRUVANANTHAPURAM- 695 033,
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT,GOVERNMENT OF
KERALA,THIRUVANANTHAPURAM- 695001.
BY ADVS.
SRI.NAVANEETH.N.NATH
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 681
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 16881 OF 2022
PETITIONER/S:
KARAMVELY SERVICE CO-OPERATIVE SOCIETY LTD NO.PT.45
AGED 48 YEARS
NELLIKKALA.P.O., MALLAPPUZHASSERRY, PATHANAMTHITTA
DISTRICT REPRESENTED BY ITS SECRETARY THULASIDAS.R,
AGED 48, W/O. SURESH KUMAR, RESIDING AT MUNDUVELIL
HOUSE, PRAMADAM, MALLASSERRY.P.O., PATHANAMTHITTA,
PIN - 689643
BY ADV SRI.V.PHILIP MATHEWS
RESPONDENT/S:
1 UNION OF INDIA
UNION OF INDIA REPRESENTED BY ITS SECRETARY TO
GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI., PIN - 110001
2 STATE OF KERALA
REPRESENTED BY SECRETARY, DEPARTMENT OF CO-OPERATION,
KERALA GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM.,
PIN - 695001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, CENTRAL REVENUE
BUILDING, I.S.PRESS ROAD, ERNAKULAM., PIN - 682018
4 INCOME TAX OFFICER (TDS)
AARATTUKULAKKARA COMPLEX, A.N. PURAM, ALAPPUZHA., PIN
- 688011
2025:KER
W.P(C)No.7053/2023 & Connected cases 682
5 THE KERALA STATE CO-OPERATIVE BANK LTD,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033
6 THE DEPUTY GENERAL MANAGER
KERALA STATE CO-OPERATIVE BANK LTD, PATHANAMTHITTA
DISTRICT OFFICE, MYLAPRA ROAD, PATHANAMTHITTA -, PIN
- 689645
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 683
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 17323 OF 2022
PETITIONER/S:
1 MAHATHMA VANITHA SAHAKARANA SANGHAM LTD.NO.C 1677
KALLIKKANDY P.O., KANNUR-670693 REPRESENTED BY ITS
SECRETARY SREEJISHA K.
2 PARAT VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1660,
THOOVAKKUNNU, KANNUR - 670693 REPRESENTED BY ITS
SECRETARY PREETHA K.T.K.
3 THUVAKKUNNU VANITHA SERVICE CO-OPERATIVE SOCIETY LTD
C 1437
THUVAKKUNNU P.O., KANNUR -670 693 REPRESENTED BY ITS
SECRETARY VINCY V.P.
4 KADIRUR VILLAGE VANITHA SAHAKARANA SANGHAM LTD C 1799
KADIRUR P.O., KANNUR - 670642 REPRESENTED BY ITS
SECRETARY SHEENA K.
5 KOTTIYODI VANITHA SERVICE CO-OPERATIVE LTD NO. C 1796
PATHAYAKUNNU P.O., KANNUR - 670691 REPRESENTED BY ITS
SECRETARY BINDU K.
6 MOKERI VANITHA CO-OPERATIVE SOCIETY LTD. NO.C 1150
VALLAYAYI, MUTHIYANGA P.O., KANNUR - 670 691
REPRESENTED BY ITS SECRETARY A.V.SHEHEERA.
7 PERAVOOR PANCHAYATH VANITHA COOPERATIVE SOCIETY LTD
NO. C 1211
PERAVOOR P.O., KANNUR-670 673 REPRESENTED BY ITS
SECRETARY BINDHU G.
2025:KER
W.P(C)No.7053/2023 & Connected cases 684
8 KOLAVALLOOR VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1436
CHERUPARAMBA P.O., KANNUR 670693 REPRESENTED BY ITS
SECRETARY RANJISHA C.
9 URUVACHAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD
NO. C 1476
URAVACHAL, KANNUR 670702 REPRESENTED BY ITS SECRETARY
SAJALA K.
10 VALAPATTANAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C
1155
VALAPATTANAM P.O., KANNUR-670010 REPRESENTED BY ITS
SECRETARY SASIKALA P.
11 ULIYIL RURAL DEVELOPMENT CO-OPERATIVE SOCIETY LTD NO.
C 2067
ULIYIL P.O., KANNUR 670702 REPRESENTED BY ITS
SECRETARY ANOOP KUMAR P.K.
12 PAPPINISSERI WEST VANITHA SERVICE SAHAKARANA SANGAM
LTD C 1441
KARIKKANKULAM, KANNUR-670561 REPRESENTED BY ITS
SECRETARY SHEEJA K.V.
13 EZHOME PANCHAYATH VANITHA KSHEMA SAHAKARANA SANGHAM
LTD NO. C 1501
PAZHAYANGADI, KANNUR-670303 REPRESENTED BY ITS
SECRETARY SAJITHA THAZHATH VALAPP.
14 AZHIKODE TOWN VANITHA SERVICE COOPERATIVE SOCIETY LTD
NO.1583
AZHIKODE P.O., KANNUR-670009 REPRESENTED BY ITS
SECRETARY SHEEBA K.V.
15 PALAKKAD PRAVASI CO-OPERATIVE SOCIETY (PAPCOS) LTD
NO. P 1355
KODATHIPPADI, MANNARKKAD, PALAKKAD-678582 REPRESENTED
BY ITS SECRETARY SHAMLA K.P.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
2025:KER
W.P(C)No.7053/2023 & Connected cases 685
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
SHRI.T.T.BIJU
SHRI.SANAND RAMAKRISHNAN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.
PB NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695
001.
BY ADVS.
SHRI.S.VAIDYANATHAN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 686
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 17707 OF 2022
PETITIONER/S:
GOVT.EMPLOYEE'S CO-OPERATIVE BANK LTD.,
NO.57, KOLLAM-691 013, REPRESENTED BY ITS SECRETARY
RENJITH.K.R.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI-110 001.
2 THE CENTRAL BOARD OF DIRECTOR TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,
REPRESENTED BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 687
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI-682 018.
4 THE KERALA STATE CO OPERATIVE BANK LTD.,
PB NO.6515, CO BANK TOWERS, PALAYM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM-695 001.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 688
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 17716 OF 2022
PETITIONER/S:
1 ITTIVA RURAL CO-OPERATIVE SOCIETY LTD NO.Q.1404.
VYYANAM P.O., KOLLAM-691533 REPRESENTED BY ITS
SECRETARY USHAKUMARI S.
2 KOLLAM VYPARI VYAVASAYI CO-OPERATIVE SOCIETY LTD NO.
Q 1576,
ANCHALUMMOODU, PERINAD P.O., KOLLAM-
691601 ,REPRESENTED BY ITS SECRETARY AFZAL F.
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001.
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI-110001, REPRESENTED
2025:KER
W.P(C)No.7053/2023 & Connected cases 689
BY ITS CHAIRMAN.
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI- 682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695
033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695001.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 690
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 17796 OF 2022
PETITIONER/S:
ANNAMANADA TOWN MARKETING CO-OPERATIVE SOCIETY
LIMITED NO.1001,
ANNAMANADA P.O., THRISSUR, PIN - 680 741, REP. BY ITS
SECRETARY.
BY ADV SHRI.FRANCO T.J.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI - 682
018.
3 THE INCOME TAX OFFICER (TDS),
AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL
OFFICE ROAD, THRISSUR, PIN - 680 001.
4 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110
001, REPRESENTED BY ITS CHAIRMAN.
5 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
2025:KER
W.P(C)No.7053/2023 & Connected cases 691
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI - 682 018.
6 ADDITIONAL COMMISSIONER OF INCOME TAX,
TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR,
THIRUVANANTHAPURAM - 695 003.
7 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(KERALA BANK) P.B.NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, PIN - 695 033, REPRESENTED BY ITS
MANAGING DIRECTOR.
8 THE BRANCH MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD. (KERALA BANK,
ANNAMANADA (BR.) P.O.ANNAMANADA, THRISSUR DISTRICT -
680 741.
9 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN - 695 001.
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 692
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 18070 OF 2022
PETITIONER/S:
THE KODUMON RUBBER PLANTATION EEMPLOYEES CO-OPERATIVE
BANK LTD NO. P.T.24,
KORUVILA, NEDUMONCAVU P.O, PATHANAMTHITTA DISTRICT,
REPRESENTED BY ITS SECRETARY.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM,
PIN 682 018.
3 THE INCOME TAX OFFICER, (TDS),
AARATTUKULAKKARA COPLEX, A.N.PURAM, ALAPPUZHA
DISTRICT, 686 011.
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033.
5 THE DEPUTY GENERAL MANAGER,
2025:KER
W.P(C)No.7053/2023 & Connected cases 693
KERALA STATE CO-OPERATIVE BANK LTD. , PATHANAMTHITTA
DISTRICT, OFFICE, PATHANAMTHITTA, PIN 689 645.
BY ADV SHRI.ANILKUMAR C.R., CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 694
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 18489 OF 2022
PETITIONER/S:
1 THIRU KOCHI SAMOOHYA KSHEMA SAHAKARANA SANGHAM LTD NO
E-1346
[TSKSS LTD NO E -1346], SRM ROAD, PACHALAM, KOCHI-
682012. REPRESENTED BY ITS HONORARY SECRETARY, A.M
VAJRABALA RAO.
2 THE CENTRAL BOARD OF DIRECT TAXES[CBDT],
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001,
REPRESENTED BY ITS CHAIRMAN.
3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
COCHIN -682018.
4 INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR
BHAVAN, SAKATHAN THAMPURAN NAGAR, THRISSUR -680001.
5 THE KERALA STATE CO-OPERATIVE BANK LTD [KERALA BANK]
P.B.NO. 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM -695033. REPRESENTED BY ITS CHIEF
GENERAL MANAGER.
6 STATE OF KERALA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF
COOPERATION, SECRETARIAT, THIRUVANANTHAPURAM -695001.
7 THE REGISTRAR OF CO-OPERATIVE SOCIETIES
KERALA, JAWAHAR THYCAUD P.O, SAHAKARANA DPI JUNCTION,
2025:KER
W.P(C)No.7053/2023 & Connected cases 695
BHAVAN, THIRUVANANTHAPURAM -695014.
8 THE MANAGER
KERALA STATE CO-OPERATIVE BANK [KERALA BANK],
PACHALAM BRANCH, ERNAKULAM -682012.
BY ADVS.
SRI.DIPU.R
SRI.K.S.BAIJU
SMT. DEVI KRIPA R.
SMT.P.V.SARITHA VENUGOPAL
SMT.DHANYA BABU
SMT.P.A.PRIYA
SMT.NEETHU SASI
RESPONDENT/S:
UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINNACE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI - 110001.
BY ADV SMT.KRISHNA S., CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 696
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 18690 OF 2022
PETITIONER/S:
THE ELAKAMON PANCHAYATH RESIDENCE WELFARE CO-
OPERATIVE SOCIETY LTD
NO. 1546, PALAYAMKUNNU P.O., VARKALA,
THIRUVANANTHAPURAM-695146 REPRESENTED BY ITS
SECRETARY GANGA S
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI- 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED
BY ITS CHAIRMAN
2025:KER
W.P(C)No.7053/2023 & Connected cases 697
3 PRINCIPAL CHIEF COMMISSIONER
OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS
PRESS ROAD, KOCHI-682018.
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001
BY ADVS.
SHRI.N.J.ASHWIN, CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.THOMAS ABRAHAM
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 698
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 20028 OF 2022
PETITIONER/S:
THE IDUKKI DISTRICT DEALERS CO-OPERATIVE SOCIETY LTD
NO. 1-401, REPRESENTED BY ITS SECRETARY, SINDHU VIJU,
W/O. S. VIJU, HEAD OFFICE, NEDUMKANDAM POST,
UDUMBANCHOLA TALUK, IDUKKI DISTRICT - 685 553.
BY ADVS.
SRI.GEORGE MATHEW
SRI.M.D.SASIKUMARAN
SHRI.PRAVEEN S.
SHRI.SUNIL KUMAR A.G
SHRI.GEORGE K.V.
SHRI.MATHEW K.T.
SHRI.STEPHY K REGI
SRI.DIPU JAMES
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY
OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -
110 002.
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDINGS I.S. PRESS ROAD, KOCHI -
682 018.
3 THE INCOME TAX OFFICER,
2025:KER
W.P(C)No.7053/2023 & Connected cases 699
TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY - 8,
THODUPUZHA, IDUKKI DISTRICT - 685 584.
4 STATE OF KERALA,
REP. BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT
SECRETARIAT, THIRUVANANTHAPURAM - 695 001.
5 REGISTRAR OF CO-OPERATIVE SOCIETIES,
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD,
THIRUVANANTHAPURAM - 695 014.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
(KERALA BANK) REP. BY ITS MANAGING DIRECTOR & CHIEF
EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM - 695 033.
7 THE DEPUTY GENERAL MANAGER,
CENTRAL PROCESSING CENTER, THE KERALA STATE CO-
OPERATIVE BANK LTD., (KERALA BANK), VAZHATHOPE,
IDUKKI COLONY P.O., IDUKKI DISTRICT - 685 602.
BY ADVS.
GOVERNMENT PLEADER
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.PRAVEEN K.V., CGC
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 700
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 21287 OF 2022
PETITIONER/S:
ANAMALA COLLECTIVE FARMING CO-OPERATIVE SOCIETY
REG NO. 478 , PARIYARAM P.O., CHALAKUDY VIA THRISSUR
DISTRICT, REPRESENTED SECRETARY, PV VIVEK, PIN -
686021
BY ADVS.
SRI.MANU GOVIND
SHRI.AYESHA MARIA JOHN
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, NORTH BLOCK RAISANA HILL, NEW DELHI, PIN
- 110001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,
PIN - 682018
3 THE INCOME TAX OFFICER(TDS)
INCOME TAX BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-, PIN
- 682018
4 THE KERALA STATE COOPERATIVE BANK
CO-BANK TOWERS, VIKAS BHAVAN, P.O PALAYAM,
THIRUVANANTHAPURAM REPRESENTED BY CHIEF EXECUTIVE
2025:KER
W.P(C)No.7053/2023 & Connected cases 701
OFFICER, PIN - 698013
5 THE KERALA STATE COOPERATIVE BANK
TKV TOWER, RAILWAY STATION RD, NORTH CHALAKUDY,
CHALAKUDY, KERALA REPRESENTED BY ITS GENERAL MANAGER,
PIN - 680307
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.B.G.HARINDRANATH (SR.)
SHRI.AMITH KRISHNAN H.
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 702
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 21639 OF 2022
PETITIONER/S:
THE MANAGING COMMITTEE OF KUNNICODE AGRICULTURAL
IMPROVEMNENT CO-OPERATIVE SOCEITY LTD NO Q NO.1594
REPRESENTED BY ITS PRESIDENT, KUNNICODE P.O.KOLLAM-
691 508.
BY ADV SHRI.P.N.MOHANAN
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI-110001.
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001,
REPRESENTED BY ITS CHAIRMAN
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX ,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD,
KOCHI- 682 018.
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM-695 003.
5 INCOME TAX OFFICER (TDS),
2025:KER
W.P(C)No.7053/2023 & Connected cases 703
SREENEELAPADMAM, PARAMESWARA NAGAR, HOSPITAL ROAD,
KOLLAM-691 001.
6 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER.
7 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 704
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 21922 OF 2022
PETITIONER/S:
THE THALAVOOR RURAL CO-OPERATIVE SOCIETY LTD. NO.Q
1428,
REPRESENTED BY ITS SECRETARY, THALAVOOR P.O, KOLLAM
DISTRICT, PIN - 691508
BY ADVS.
SRI.ARJUN RAGHAVAN
SHRI.T.R.HARIKUMAR
RESPONDENT/S:
1 1. THE ASSISTANT COMMISSIONER OF INCOME TAX
OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX,
TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O,
THIRUVANANTHAPURAM, PIN - 695003
2 2. THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY
ITS CHAIRPERSON
ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW
DELHI, PIN - 110001
3 3. UNION OF INDIA, REPRESENTED BY THE SECRETARY TO
GOVERNMENT OF INDIA
MINISTRY OF FINANCE, NORTH BLOCK, CABINET
SECRETARIAT, RAISANA HILL, NEW DELHI, PIN - 110001
2025:KER
W.P(C)No.7053/2023 & Connected cases 705
4 4. THE REGISTRAR OF CO-OPERATIVE SOCIETIES
JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O,
THIRUVANANTHAPURAM, PIN - 695014
5 STATE OF KERALA,
REPRESENTED BY THE SECRETARY TO GOVERNMENT,
DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANNATHAPURAM, PIN - 695001
6 6. THE KERALA STATE CO-OPERATIVE BANK , REPRESENTED
BY ITS CHIEF EXECUTIVE OFFICER
P.B NO.6515, CO-BANK TOWERS, PALAYAM,
THIRUVANATHAPURAM, PIN - 695033
BY ADVS.
SRI.CHRISTOPHER ABRAHAM
SRI.P.C.SASIDHARAN, SC, KOLLAM DISTRICT CO-OPERATIVE
BANK LTD.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 706
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 22198 OF 2022
PETITIONER/S:
KOLARI VANITHA CO-OPERATIVE SOCIETY LTD. NO. C-1648
PALOTTUPALLY, MATTANNUR P.O., KANNUR REPRESENTED BY
ITS SECRETARY DHANYA M, PIN - 670702
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, REPRESENTED BY ITS CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
2025:KER
W.P(C)No.7053/2023 & Connected cases 707
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN -
682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN -
695001
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN -
695001
BY ADVS.
SHRI.M.B.SUDARSANA KUMAR, CGC
SRI.CHRISTOPHER ABRAHAM
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 708
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 22339 OF 2022
PETITIONER/S:
1 1. MULLASSERY BLOCK PANCHAYATH MULTIPURPOSE CO
OPERATIVE SOCIETY LTD
NO. R 1202, POOVATHOOR P O, THRISSUR DISTRICT, PIN
680508 REPRESENTED BY SECRETARY PRAVITHA P.K
2 2. COCONUT FARMERS WELFARE CO-OPERATIVE SOCIETY LTD
NO.R 1377, K.K.M SHOPPING COMPLEX, CHITATTUKARA P.O,
THRISSUR-680 511 REPRESENTED BY ITS SECRETARY SIMILE
V.L
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110000.
2 THE COMMISSIONER OF INCOME TAX (TDS)
(TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-
682018
3 THE INCOME TAX OFFICER(TDS)
AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680001
4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE
THRISSUR DISTRICT CO-OPERTAIVE BANK)
SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD,
2025:KER
W.P(C)No.7053/2023 & Connected cases 709
THRIRUVAMBADI P.O, THRISSUR, PIN-680022 REPRESENTED
BY ITS GENERAL MANAGER,
BY ADVS.
SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.P.C.SASIDHARAN, SC, THRISSUR DISTRICT
CO.OPERATIVE BANK LTD.
SRI.CHRISTOPHER ABRAHAM
SRI.MANU.S, CGC
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 710
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 22917 OF 2022
PETITIONER/S:
MALAYAINKEEZHU AGRICULTURAL DEVELOPMENT CO-OPERATIVE
SOCIETY LTD. NO. T-1866,
MALAYAINKEEZHU P.O., THIRUVANANTHAPURAM REPRESENTED
BY ITS SECRETARY KAVITHA C.R, PIN - 695571
BY ADVS.
DR.K.P.PRADEEP
SHRI.SANAND RAMAKRISHNAN
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI-, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, REPRESENTED BY ITS CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
2025:KER
W.P(C)No.7053/2023 & Connected cases 711
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN -
682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN -
695033
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN -
695001
BY ADVS.
SRI.K.V.SREE VINAYAKAN
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 712
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 23239 OF 2022
PETITIONER/S:
VADAKKEKAD SERVICE CO-OPERATIVE BANK LTD
VADAKKEKAD SERVICE CO-OPERATIVE BANK LTD NO. P 562
VADAKKEKAD P.O, THRISSUR, PIN-679 526 REPRESENTED BY
ITS SECRETARY
BY ADV SHRI.C.A.JOJO
RESPONDENT/S:
1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE
GOVERNMENT
UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE
GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI-110001
2 THE COMMISSIONER OF INCOME TAX (TDS)
2. THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL
REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018
3 THE INCOME TAX OFFICER(TDS)
THE INCOME TAX OFFICER(TDS) AYAKAR BHAVAN, SAKTHAN
NAGAR, THRISSUR PIN-680001
4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE
THRISSUR SERVICE CO-OPERATIVE BANK)
THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE
THRISSUR SERVICE CO-OPERATIVE BANK), HEAD OFFICE,
THRISSUR-680001 REPRESENTED BY ITS GENERAL MANAGER
2025:KER
W.P(C)No.7053/2023 & Connected cases 713
5 GURUVAYOOR URBAN CO-OPERATIVE BANK LTD
GURUVAYOOR URBAN CO-OPERATIVE BANK LTD NEAR THAIKAD,
CHOONDAL ROAD, GURUVAYOOR P.O THRISSUR DISTRICT, PIN-
680104 REPRESENTED BY ITS GENERAL MANAGER
BY ADVS.
SRI.CHRISTOPHER ABRAHAM
SRI.P.C.SASIDHARAN, SC, THRISSUR DISTRICT
CO.OPERATIVE BANK LTD.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 714
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 23780 OF 2022
PETITIONER/S:
CHOONDACHERRY SERVICE CO-OPERATIVE BANK LTD
NO.K.167,CHOONDACHERRY P.O., KOTTAYAM DISTRICT
REPRESENTED BY ITS SECRETARY., PIN - 686579
BY ADVS.
SRI.T.MADHU
SMT.C.R.SARADAMANI
SRI.SHAHID AZEEZ
SMT.RESHMA SANTHOSH
SHRI.RENJISH S. MENON
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY TO GOVERNMENT, MINISTRY
OF FINANCE, DEPARTMENT OF REVENUE, GOVERNMENT OF
INDIA, NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE,
GOVERNMENT OF INDIA, NEW DELHI,REPRESENTED BY ITS
CHAIRMAN., PIN - 110001
3 THE PRINCIPAL COMMISSIONER OF INCOME TAX
TDS RANGE, THIRD FLOOR, AAYAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM, PIN - 696003
2025:KER
W.P(C)No.7053/2023 & Connected cases 715
4 THE MEENACHIL EAST URBAN CO-OPERATIVE BANK LTD
NO.4266 REGISTERED OFFICE POONJAR, POONJAR -
THEKKEKARA P.O., KOTTAYAM DISTRICT REPRESENTED BY ITS
SECRETARY., PIN - 686582
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.SHINU J.PILLAI
SMT.S.SUJA
SMT.MARIYA RAJAN
SMT.LEKSHMI SUMUKHAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 716
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 24428 OF 2022
PETITIONER/S:
WADAKANCHERY BLOCK MULTI PURPOSE CO-OPERATIVE SOCIETY
LTD. NO.R. 1125
WADAKANCHERY.P.O, THRISSUR- 680582, REPRESENTED BY
THE SECRETARY.
BY ADV SRI.E.S.ASHRAF
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI-110001
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM-
682 018
3 THE INCOME TAX OFFICER (TDS)
OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR
BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001.
4 THE KERALA STATE CO-OPERATIVE BANK LTD
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033,
REPRESENTED BY ITS MANAGING DIRECTOR.
BY ADVS.
SHRI.P.VIJAYAKUMAR, ASG OF INDIA
2025:KER
W.P(C)No.7053/2023 & Connected cases 717
SRI.CHRISTOPHER ABRAHAM
SHRI.B.G.HARINDRANATH (SR.)
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 718
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 24538 OF 2022
PETITIONER/S:
THE PATTIKKAD SERVICE CO-OPERATIVE BANK LTD.
AGED 53 YEARS
PATTIKKAD.P.O., MALAPPURAM DISTRICT. REPRESENTED BY
ITS SECRETARY., PIN - 679325
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM.,
PIN - 682018
2 THE INCOME TAX OFFICER, (TDS),
AYAKAR BHAVAN, ENGLISH CHURCH ROAD, PALAKKAD,, PIN -
678014
3 CHERPALACHERI CO-OPERATIVE URBAN BANK LTD. NO. 1696
CHERPALACHERI, PALAKKAD DISTRICT REPRESENTED BY ITS
GENERAL MANAGER, PIN - 679321
BY ADVS.
SHRI.JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.R.SREEHARI
SHRI.HAMZA A.V.
SHRI.VIGNESH S.
SHRI.P.R.AJITH KUMAR
2025:KER
W.P(C)No.7053/2023 & Connected cases 719
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 720
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 25354 OF 2022
PETITIONER/S:
1 1. MATTANUR VANITHA CO-OPERATIVE SOCIETY LTD NO C-
1905
MATTANUR, P.O. MATTANUR, KANNUR- 670702 REPRESENTED
BY ITS SECRETARY, MINI .P. C.P
2 2. MARUTHAYI PRIYADHARSINI VANITHA CO-OPERATIVE
SOCIETY LTD.NO.C.1647
MARUTHAYI, P.O. PORORA, MATTANUR, REPRESENTED BY ITS
SECRETARY SUJINA.K.V, PIN - 670702
3 3. PERAVOOR BLOCK VANITHA SAHAKARANA SANGHAM
LTD.NO.1181
P.O.KELAKAM, KANNUR, REPRESENTED BY ITS SECRETARY
JOSMIN V.J, PIN - 670674
4 4. PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY LTD. NO
C-1265
P.O MATTANUR, KANNUR, REPRESENTED BY ITS SECRETARY
LATHA P, PIN - 670702
5 5. MATTANNUR RANGE AGRICULTURIST & TODDY TAPPING
WORKERS CO-OPERATIVE SOCIETY LTD. NO.C.1535
MATTANUR, P.O MATTANUR, KANNUR REPRESENTED BY ITS
SECRETARY SUDHEER KUMAR A, PIN - 670702
6 6. THE MATTANNUR AGRICULTURIST WELFARE CO-OPERATIVE
SOCIETY LTD. NO C-1765
P.O MATTANUR, KANNUR, REPRESENTED BY ITS SECRETARY
SHIBU V.K, PIN - 670702
7 7. IRITTY BLOCK VANITHA SERVICE CO-OPERATIVE SOCIETY
2025:KER
W.P(C)No.7053/2023 & Connected cases 721
LTD.NO.C-1099
P.O MATTANUR, REPRESENTED BY ITS SECRETARY USHA.K,
PIN - 670702
8 8. KOTTIYOOR VANITHA CO-OPERATIVE SOCIETY LTD.NO.C-
1176
CHUNGAKKUNNU, KANNUR, REPRESENTED BY ITS SECRETARY
JYOTHI V.A, PIN - 670651
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 2. THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI, REPRESENTED BY ITS
CHAIRMAN, PIN - 110001
3 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI, PIN - 682018
4 4. THE KERALA STATE CO-OPERATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
5 STATE OF KERALA
2025:KER
W.P(C)No.7053/2023 & Connected cases 722
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN -
695001
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 723
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 26364 OF 2022
PETITIONER/S:
1 MATTANUR FARMER'S WELFARE CO-OPERATIVE SOCIETY LTD
NO. C 1884
MATTANUR P.O., KANNUR - REPRESENTED BY ITS SECRETARY
GEESHMA K, PIN - 670702
2 PANOOR MUNICIPALITY AGRICULTURIST SOCIAL WELFARE CO-
OPERATIVE SOCIETY(PALCOS) LTD C 2051
KARIYAD SOUTH P.O., KANNUR - REPRESENTED BY ITS
SECRETARY JISHA P.M, PIN - 670316
3 KANNUR DISTRICT DIFFERENTLY ABLED PEOPLES WELFARE CO-
OPERATIVE LTD NO. C 1680
NAYATTUPARA, PATTANUR P.O., KANNUR - REPRESENTED BY
ITS SECRETARY MAHIJA T.V, PIN - 670595
4 THALASSERY TALUK RURAL EMPLOYEES WELFARE CO-OPERATIVE
SOCIETY LTD NO. C.1698
PANOOR P.O., KANNUR- REPRESENTED BY ITS SECRETARY T
SHARMILA, PIN - 670692
5 NEW MAHE PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO.
C 1838
NEW MAHE P.O., KANNUR- REPRESENTED BY ITS SECRETARY
SREESHAD S, PIN - 673311
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
2025:KER
W.P(C)No.7053/2023 & Connected cases 724
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI-, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS
CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN -
682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN -
695033
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-, PIN -
695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 725
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 26636 OF 2022
PETITIONER/S:
1 MANANTHERI AGRICULTURIST SOCIAL WELFARE CO-OPERATIVE
SOCIETY LTD C.2087
NHALIL, MANANTHERI P.O., KANNUR- REPRESENTED BY ITS
SECRETARY HARITHA M, PIN - 670643
2 CHITTARIPPARAMBA MERCHANTS WELFARE CO-OPERATIVE
SOCIETY LTD NO. C 2112
MALABAR COMPLEX, CHITTARIPPARAMBA P.O., KANNUR-
REPRESENTED BY ITS SECRETARY SREEYESH K, PIN - 670650
BY ADVS.
DR.K.P.PRADEEP
SHRI.HAREESH M.R.
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
2025:KER
W.P(C)No.7053/2023 & Connected cases 726
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI-, REPRESENTED BY ITS
CHAIRMAN, PIN - 11000
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN -
682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515
, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN -
695033
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN -
695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.M.SASINDRAN
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 727
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 25894 OF 2023
PETITIONER/S:
1 ULLIYERI SERVICE CO-OPERATIVE BANK LTD NO.D.2033,
ULLIYERI P.O, KOZHIKODE-673323, REPRESENTED BY ITS
SECRETARY MONCY VARGHESE
2 THE QUILANDY SERVICE COOPERATIVE BANK LTD NO. F 1869
QUILANDY, KOZHIKODE-673305, REPRESENTED BY ITS
SECRETARY SAJINA A.R
3 THIKKODI SERVICE COOPERATIVE BANK LTD NO.1950
THIKKODI P.O., KOZHIKODE-673529, REPRESENTED BY ITS
SECRETARY SINDU C K
4 KEEZHARIYOOR SERVICE CO-OPERATIVE BANK LTD NO. F772
KEEZHARIYOOR P.O., KOYILANDY, KOZHIKODE- 673307,
REPRESENTED BY ITS SECRETARY LIJI C K
5 THE PERAMBRA REGIONAL CO-OPERATIVE BANK LTD NO. F
1752
PERAMBRA P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY SUDHEESH KUMAR, PIN - 673525
6 ARIKKULAM SERVICE COOPERTAIVE BANK LTD NO. F 1489
ARIKKULAM P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY CHANDRASEKHARAN C.M, PIN - 673620
7 THE MOODADI SERVICE COOPERATIVE BANK LTD NO.D2035
KATALUR P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY
BINESH K.P, PIN - 673529
8 KOTTUR SERVICE COOPERATIVE BANK LTD NO. F 450
2025:KER
W.P(C)No.7053/2023 & Connected cases 728
AVITANALLUR P.O., KOZHIKODE-REPRESENTED BY ITS
SECRETARY BASHEER M, PIN - 673614
9 THE MEPPAYUR CO-OPERATIVE TOWN BANK LTD NO.F-1497
MEPPAYUR P.O.,KOZHIKODE- REPRESENTED BY ITS SECRETARY
K.G. BIJUKUMAR, PIN - 673524
10 THE KAYANNA SERVICE CO-OPERATIVE BANK LTD NO. F 761
KAYANNA BAZAR, KOZHIKODE- REPRESENTED BY ITS
SECRETARY P. PRAKASAN, PIN - 673525
11 THE THURAYUR SERVICE CO-OPERATIVE BANK LTD NO. F 1878
PAYYOLI ANGADI P.O., KOZHIKODE-REPRESENTED BY ITS
SECRETARY ABOOBACKER C.A, PIN - 673523
12 KALLANODE SERVICE CO-OPERATIVE BANK LTD NO. F 1827
KALLANODE P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY TWINKLE K CHANDY, PIN - 673527
13 THE MELUR SERVICE CO-OPERATIVE BANK LTD NO.882
CHELIYA P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY
BINESH K.V, PIN - 673306
14 KAVUMTHARA SERVICE CO-OPERATIVE BANK LTD NO. D 3205
NADUVANNUR P.O., KOZHIKODE REPRESENTED BY ITS
SECRETARY SHEERSHA V M, PIN - 673614
15 MEPPAYUR SERVICE CO-OPERATIVE BANK LTD NO. D2019
MEPPAYUR P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY JINSHA P, PIN - 673524
16 ATHOLI SERVICE CO-OPERATIVE BANK LTD NO. D 2721
ATHOLI PO., KOZHIKODE- REPRESENTED BY ITS SECRETARY
SREEJESH T.P, PIN - 673315
17 THE BALUSSERY REGIONAL CO-OPERATIVE BANK LTD NO. F
1265
BALUSSERY P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY SANTHOSH KUMAR M.M, PIN - 673612
18 THE KARAYAD SERVICE CO-OPERATIVE BANK LTD NO. F 1702
KARAYAD P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY
BAVITHA K.V, PIN - 673524
2025:KER
W.P(C)No.7053/2023 & Connected cases 729
19 THE CHANGAROTH SERVICE COOPERATIVE BANK LTD NO. D
1998
PALERI TOWN P.O, KOZHIKODE- REPRESENTED BY ITS
SECRETARY SOBHA V.M, PIN - 673508
20 THE PAYYOLI SERVICE CO-OPERATIVE BANK LTD NO. F 1267
PAYYOLI PO., KOZHIKODE- REPRESENTED BY ITS SECRETARY
JAYADEVAN M.P, PIN - 673522
21 THE CHEMANCHERY SERVICE CO-OPERATIVE BANK LTD NO. F
779
CHEMANCHERY P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY DHANANJAY NARAYANAN, PIN - 673304
22 NADUVANNUR REGIONAL COOPERATIVE BANK LTD NO. F 1269
NADUVANNUR P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY MAJITHA N P, PIN - 673614
23 KALPATHUR SERVICE COOPERATIVE BANK LTD NO.10096
KALPATHUR PO., KOZHIKODE- REPRESENTED BY ITS
SECRETARY SAJIL M M, PIN - 673524
24 IRINGAL SERVICE COOPERATIVE BANK LTD NO. F 869
IRINGAL PO., KOZHIKODE- REPRESENTED BY ITS SECRETARY
USHA K.P, PIN - 673521
25 KOOTHALI SERVICE COOPERATIVE BANK LTD NO. D 2609
KOOTHALI P.O.,KOZHIKODE- REPRESENTED BY ITS SECRETARY
RASHEED K K, PIN - 673525
26 CHERUVANNUR SERVICE COOPERATIVE BANK LTD NO. F 1866,
CHERUVANNUR P.O., KOZHIKODE- REPRESENTED BY ITS
SECRETARY K BABU, PIN - 673524
BY ADVS.
DR.K.P.PRADEEP
SHRI.SANAND RAMAKRISHNAN
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 730
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI-, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-,
REPRESENTED BY ITS CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN -
682018
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM, PIN - 695003
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003
6 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN -
695033
7 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,
THIRUVANANTHAPURAM, PIN - 695001
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 731
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 27682 OF 2023
PETITIONER/S:
1 MEPPAYYUR AGRICULTURISTS AND MERCANTILES WELFARE CO
OPERATIVE SOCIETY LTD NO.D 2996,
MEPPAYUR PO, KOZHIKODE- 673524, REPRESENTED BY ITS
SECRETARY JASEEL MUHAMMED P.K.
2 THE MEPPAYUR CO-OPERTIVE HOUSING SOCIETY LTD NO.1923,
MEPPAYUR P.O., KOZHIKODE-673524. REPRESENTED BY ITS
SECRETARY SUDHEER KUMAR R.
3 KOORACHUNDU CO-OPERATIVE URBAN SOCIETY LTD NO.D-2758,
KOORACHUND P.O., KOZHIKODE-673527,REPRESENTED BY ITS
SECRETARY SIJO SEBASTIAN.
4 PERAMBRA REGIONAL AGRICULTURIST WELFARE COOPERATIVE
SOCIETY LTD NO.D 3036,
PERAMBRA P.O., KOZHIKODE,-673525, REPRESENTED BY ITS
SECRETARY BEEJA T.
5 PERAMBRA PRAVASI WELFARE COOPERTATIVE SOCIETY LTD NO.
3153,
PERAMBRA P.O., KOZHIKODE-673525,REPRESENTED BY ITS
SECRETARY JAYASREE.
6 KAYANNAKARSHIKA VIKASANA THOZHILALI KSHEMA SAHAKARANA
SANGHAM LTD NO. D3031,
KAYANNA BAZAR P.O., KOZHIKODE-673525, REPRESENTED BY
ITS SECRETARY BINDU BALAKRISHNAN.
7 IRINGATH VANITHA COOPERATIVE SOCIETY LTD NO. D3302
IRINGATH P.O., KOZHIKODE-673523, REPRESENTED BY ITS
SECRETARY HAREESH P.K.
2025:KER
W.P(C)No.7053/2023 & Connected cases 732
8 MEPPAYUR MADATHUMBHAGAM VANITHA SAHAKARANA SANGAM LTD
NO. D 2993,
MEPPAYUR P.O., KOZHIKODE-673524, REPRESENTED BY ITS
SECRETARY NALINI P.
9 KOYILANDY TALUK KALLU CHETHU VYVASAYA THOZHILALI
SAHAKARANA SANGAM LTD NO. D2728
KOYILANDY, KOZHIKODE-673305, REPRESENTED BY ITS
SECRETARY SUJITHA N.
10 ATHOLI PRAVASI WELFARE CO-OPERATIVE SOCIETY LTD NO. D
3107,
ATHOLI P.O., KOZHIKODE-673315, REPRESENTED BY ITS
SECRETARY SHIMNA K.
11 NADUVANNUR AGRICULTURAL DEVELOPMENT AND PENSIONERS
WELFARE CO-OPERATIVE SOCIETY LTD NO. D 3069,
NADUVANNUR P.O., KOZHIKODE-673614, REPRESENTED BY ITS
SECRETARY ASHISH K.P.
12 PERAMBRA AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY
LTD NO. D 3060
PERAMBRA P.O., KOZHIKODE-673525, REPRESENTED BY ITS
SECRETARY KUSHBU P.
13 POOKKAD KARSHAKA KSHEMA SAHAKARANA SANGHAM LTD NO. D
3041,
CHEMANCHERI, KOZHIKODE-673304, REPRESENTED BY ITS
SECRETARY SINITHA MOHAN.
14 THALAYAD MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD
NO. D 3164,
THALAYAD P.O., KOZHIKODE- 673574, REPRESENTED BY ITS
SECRETARY SWAPNA P.
BY ADVS.
DR.K.P.PRADEEP
SHRI.SANAND RAMAKRISHNAN
SHRI.T.T.BIJU
SHRI.HAREESH M.R.
SMT.T.THASMI
SMT.M.J.ANOOPA
2025:KER
W.P(C)No.7053/2023 & Connected cases 733
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
,NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES ,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK ,NEW DELHI- 110001,
REPRESENTED BY ITS CHAIRMAN .
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN -
682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515,
CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-
695033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER.
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION) ,
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN -
695001
BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 734
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 31251 OF 2022
PETITIONER/S:
1 CHETHALLUR SERVICE CO-OPERATIVE BANK LTD, NO F1462
HEAD OFFICE, KARINKALLATHANI, CHETHALLUR P.O.,
MANNARKKAD, PALAKKAD - REPRESENTED BY ITS SECRETARY
ASHARAF K, PIN - 678583
2 THE THACHAMPARA SERVICE CO-OPERATIVE BANK LTD,
NO.3150
THACHAMPARA P.O., PALAKKAD- REPRESENTED BY ITS
SECRETARY JAYAKUMAR M, PIN - 678593
3 THE ALANALLUR CO-OPERATIVE URBAN CREDIT SOCIETY LTD
NO. P1215
ALANALLUR P.O., PALAKKAD- REPRESENTED BY ITS
SECRETARY BINESH O.V, PIN - 678601
4 VELLINAZHI PANCHAYATH MULTIPURPOSE CO-OPERATIVE
SOCIETY LTD NO. P1361
VELLINEZHI P.O., PALAKKAD- REPRESENTED BY ITS
SECRETARY C.S. PREETHI, PIN - 679504
BY ADVS.
DR.K.P.PRADEEP
SHRI.SANAND RAMAKRISHNAN
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
2025:KER
W.P(C)No.7053/2023 & Connected cases 735
RESPONDENT/S:
1 UNION OF INDIA REPRESENTED BY ITS SECRETARY
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN -
110001
2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF
REVENUE MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS CHAIRMAN,
PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI-, PIN - 682018
4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD
FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-,
PIN - 695003
5 INCOME TAX OFFICER (TDS,THIRUVANANTHAPURAM, 3RD
FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-,
PIN - 69500
6 CHERPALCHERI CO-OPERATIVE URBAN BANK LTD, NO 1696
KAVUVATTAM, NEAR AYYAPPANKAVU, CHERPALCHERI P.O.,
PALAKKAD- REPRESENTED BY ITS GENERAL MANAGER, PIN -
679503
7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-
OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF
KERALA, THIRUVANANTHAPURAM-, PIN - 695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.R.SREEHARI
SHRI.HAMZA A.V.
SHRI.VIGNESH S.
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 736
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 32055 OF 2022
PETITIONER/S:
1 NALLALAM CO-OPERATIVE URBAN SOCIETY LIMITED D-2741
POST NALLALAM, KOZHIKODE, REPRESENTED BY THE
SECRETARY, PIN - 673027
2 RAMANATTUKARA VANITHA CO-OPERATIVE URBAN SOCIETY
LIMITED NO. D-2742
POST RAMANATTUKARA, KOZHIKODE, REPRESENTED BY THE
SECRETARY, PIN - 673633
3 THIKKODI INTEGRATED AGRICULTURAL DEVELOPMENT CO-
OPERATIVE SOCIETY LIMITED NO. D-2892
POST PURAKKAD, KOZHIKODE, REPRESENTED BY THE
SECRETARY, PIN - 673522
BY ADVS.
SHRI.PRASHANTH KUMAR G.C.
SRI.R.SUDHISH
SMT.M.MANJU
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA,
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH
BLOCK, NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
2025:KER
W.P(C)No.7053/2023 & Connected cases 737
ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE
(CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
REPRESENTED BY ITS CHAIRPERSON, NEW DELHI, PIN -
110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD,
ERNAKULAM, PIN - 682018
4 KERALA STATE CO-OPERATIVE BANK LIMITED
RREPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, CO-BANK
TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695033
5 STATE OF KERALA
REPRESENTED BY SECRETARY TO GOVERNMENT, DEPARTMENT OF
CO-OPERATION, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM -, PIN - 695001
6 REGISTRAR OF CO-OPERATIVE SOCIETIES
OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,
STATUE JUNCTION, NEAR PRESS CLUB,
THIRUVANANTHAPURAM., PIN - 695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SRI.P.C.SASIDHARAN, SC, KOZHIKODE DISTRICT CO-
OPERATIVE BANK
SHRI.R.PRASANTH KUMAR, CGC
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 738
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 32580 OF 2023
PETITIONER/S:
VATTAVILA SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD NO.
T. 2292
T.C.51/320(5), VATTAVILA, THIRUMALA P.O.,
THIRUVANANTHAPURAM REPRESENTED BY ITS SECRETARY K.
VENUGOPALAN NAIR, PIN - 695006
BY ADVS.
DR.K.P.PRADEEP
SHRI.SANAND RAMAKRISHNAN
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS
CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI, PIN - 682018
2025:KER
W.P(C)No.7053/2023 & Connected cases 739
4 THE KERALA STATE CO-OPERATIVE BANK LTD
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN -
695001
BY ADVS.
CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT
SHRI.P.R.AJITH KUMAR
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 740
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 30686 OF 2021
PETITIONER/S:
THE MOORKKANAD PANCHAYATH SERVICE CO-OPERATIVE BANK
LTD,
NO.496, MOORKAND P.O., MALAPPURAM DISTRICT,
REPRESENTED BY ITS SECRETARY, PIN - 679 338.
BY ADV SRI.O.D.SIVADAS
RESPONDENT/S:
1 THE UNION OF INDIA,REPRESENTED BY THE SECRETARY TO
GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA
HILL, NEW DELHI - 110 001.
2 THE COMMISSIONER OF INCOME TAX (TDS)
CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM,
PIN - 682 018.
3 THE INCOME TAX OFFICER (TDS)
AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE,
PIN - 673 001.
4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD.
DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM
REPRESENTED BY ITS GENERAL MANAGER, PIN - 676 505.
5 THE KERALA STATE CO-OPERATIVE BANK LTD.
COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,
REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033.
BY ADVS. SRI.CHRISTOPHER ABRAHAM
SHRI.ESM.KABEER,SRI.GILBERT GEORGE CORREYA
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 741
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 36670 OF 2023
PETITIONER/S:
1 THE POOJAPPURA SOCIAL WELFARE CO-OPERATIVE SOCIETY
LIMITED T 2066, POOJAPPURA PO, THIRUVANANTHAPURAM
REP. BY ITS SECRETARY, PIN - 695012
2 THE PRESIDENT,THE POOJAPPURA SOCIAL WELFARE CO-
OPERATIVE SOCIETY LTD T 2066,POOJAPPURA PO,
THIRUVANANTHAPURAM, PIN - 69501
BY ADV SRI.LIJU. M.P
RESPONDENT/S:
1 THE KERALA BANK,PB NO.6515, COBANK TOWERS, VIKAS
BHAVAN PO, PALAYAM, THIRUVANANTHAPURAM , REP. BY ITS
GENERAL MANAGER, PIN - 695033
2 THE GENERAL MANAGER,
THE KERALA BANK, PB NO.6515, COBANK TOWERS,VIKAS
BHAVAN PO, PALAYAM,THIRUVANANTHAPURAM, PIN - 695033
3 THE INCOME TAX OFFICER ( IMPLEADED VIDE ORDER
DT.20.12.2023 IN IA 1/2023)
OFFICE OF THE INCOME TAX OFFICER, AAYAKAR BHAVAN,
KAWDIAR, THIRUVANANTHAPURAM ( IMPLEADED VIDE ORDER
DT. 20.12.2023 IN IA 1/2023)
4 THE COMMISSIONER OF INCOME TAX,OFFICE OF THE
COMMISSIONER OF INCOME TAX, AAYAKAR BHAVAN, OLD
RAILWAY STATION ROAD, ERNAKULAM NORTH, KOCHI
(IMPLEADED VIDE ORDER DT. 20.12.2023 IN IA 1/2023)
BY ADV SHRI.THOMAS ABRAHAM
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 742
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 41031 OF 2022
PETITIONER/S:
PANOOR CO-OPERATIVE BUILDING SOCIETY LTD,
C.335, P.O, PANOOR, KANNUR- REPRESENTED BY ITS
SECRETARY PYARI.A, PIN - 670692
BY ADVS.
DR.K.P.PRADEEP
SHRI.SANAND RAMAKRISHNAN
SHRI.HAREESH M.R.
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
SMT.SANU S MALAKEEL
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK
NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT
OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS
CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA
REGION
2025:KER
W.P(C)No.7053/2023 & Connected cases 743
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL
REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN -
682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
5 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION)
GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-, PIN -
695001
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 744
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 9194 OF 2024
PETITIONER/S:
KANNAMANGALAM VANITHA CO-OPERATIVE SOCIETY LTD NO.M
1053,E.K.PADY, KANNAMANGALAM P.O, MALAPPURAM (DT),
REPRESENTED BY ITS SECRETARY, PIN - 676304
BY ADVS.
SHRI.C.A.JOJO
SMT.SWATHY S.
RESPONDENT/S:
1 UNION OF INDIA,REPRESENTED BY ITS SECRETARY TO THE
GOVERNMENT, MINISTRY OF FINANCE, NORTH LOCK, RAISANA
HILL, NEW DELHI, PIN - 110001
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, I S PRESS, ROAD, KOCHI, PIN -
682018
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O, MALAPPURAM DISTRICT, PIN - 676101
4 THE KERALA STATE CO-OPERATIVE BANK LTD,
ERSTWHILE MDC BANK), VENGARA BRANCH, MALAPPURAM,
REPRESENTED BY ITS SENIOR MANAGER, PIN - 676304
BY ADVS. SRI.G.KEERTHIVAS
SRI.P.G.JAYASHANKAR
SHRI.NAVANEETH.N.NATH, CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 745
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 41499 OF 2022
PETITIONER/S:
CHERPLACHERI SERVICE CO-OPERATIVE BANK LTD NO P 1589
AGED 53 YEARS REPRESENTED BY ITS SECRETARY
SMT.PREMALATHA, D/O MADHAVAN NAIR, CHERPLACHERRY
P.O., PALAKKAD, PIN - 679503
BY ADVS.
SRI.V.P.NARAYANAN
SRI.ALAN PRIYADARSHI DEV
RESPONDENT/S:
1 UNION OF INDIA DEPARTMENT OF REVENUE, MINISTRY OF
FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI,
PIN - 110001
2 THE PRINCIPAL CHEIF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENTOF
INDIA, CENTRAL REVENUE BUILDING, I.S.PRESS ROAD,
KOCHI, PIN - 682018
3 THE CHAIRMAN CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DEHLHI, PIN -
110001
4 CHERPLACHERRY CO -OPERATIVE URBAN BANK
KAVUVATTOM, NEAR AYYAPPANKAVU, CHERPLACHERRY,
PALAKKAD, PIN - 679503
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 746
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 43925 OF 2023
PETITIONER/S:
1 THE ADOOR TALUK AIDED SCHOOL TEACHERS' CO-OPERATIVE
SOCIETY LTD. NO. Q. 836,
KADAMPANAD SOUTH P.O., PATHANAMTHITTA DISTRICT ,
REPRESENTED BY ITS SECRETARY, VIJAYAN PILLAI N., AGED
53 YEARS, S/O NARAYANAN NAIR N., RESIDING AT
KALATHIVILAYIL, THOTTUVA, ANAYADI P. O.,
PATHANAMTHITTA DISTRICT ., PIN - 691553
2 PATHANAMTHITTA DISTRICT K.S.E.B. EMPLOYEES CO-
OPERATIVE SOCIETY LTD., NO. PT 39
110 KV SUB STATION BUILDING, PATHANAMTHITTA,
PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS
SECRETARY, RAJILA J., W/O SAJI S., ISHAN VILLA ,
ANTHICHIRA, MANNAKKALA P.O., ADOOR, PATHANAMTHITTA
DISTRICT., PIN - 689645
BY ADVS.
SRI.K.SHAJ
SMT.MEERA NAIR.I.P
SMT.BEENA N.KARTHA
SRI.C.IJLAL
SMT.POORNIMA RAJAN
SRI.ARUN CHAND
SHRI.BHARAT VIJAY P.
SHRI.MAJID MUHAMMED K.
SMT.MINU VITTORRIA PAULSON
SMT.GOPIKA GOPAL
SMT.ARCHANA SURESH
2025:KER
W.P(C)No.7053/2023 & Connected cases 747
RESPONDENT/S:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI., PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-,
REPRESENTED BY ITS CHAIRMAN, PIN - 110001
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI ., PIN - 682018
4 ADDITIONAL COMMISSIONER OF INCOME TAX
TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF
INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM., PIN - 695003
5 INCOME TAX OFFICER (TDS)
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM., PIN - 695003
6 THE KERALA BANK
CO-BANK TOWERS, P.B.NO.6515, VIKAS BHAVAN P.O.,
PALAYAM, THIRUVANANTHAPURAM , REPRESENTED BY ITS
CHIEF EXECUTIVE OFFICER, PIN - 695033
7 THE GENERAL MANAGER, KERALA BANK
REGIONAL OFFICE, P.B.NO.104, OPP. MUNICIPAL TOWN
HALL, ALAPPUZHA, ALAPPUZHA DISTRICT., PIN - 688001
8 STATE OF KERALA
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM ., PIN -
695001
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 748
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 27670 OF 2024
PETITIONER/S:
ARTISANS DEVELOPMENT CO OPERATIVE LTD 4429 KERALA
(ARTCO LTD),
KOCHUVEETIL TOWERS TC 25/595/5 MODEL SCHOOL JUNCTION,
THIRUVANANTHAPURAM G.P.O. THIRUVANANTHAPURAM 695001
REPRESENTED BY ITS MANAGING DIRECTOR MATHEW C.V.,
AGED 46 YEARS, SON OF VARGHESE C.V., PERMANENT
RESIDENCE AT CHIRAYIL HOUSE, POTTAMMEL, NEAR WATER
TANK,, KUTHIRAVATTAOM P.O., KOZHIKODE - 673016
BY ADVS.
DR.K.P.PRADEEP
SHRI.T.T.BIJU
SMT.T.THASMI
SMT.M.J.ANOOPA
RESPONDENT/S:
1 UNION OF INDIA ,
REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK
, NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK , NEW DELHI- ,
REPRESENTED BY ITS CHAIRMAN, PIN - 110001
2025:KER
W.P(C)No.7053/2023 & Connected cases 749
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI, PIN - 682018
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
PB NO 6515, CO-BANK TOWERS, PALAYAM,
THIRUVANANTHAPURAM- , REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
5 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-
OPERATION) ,GOVERNMENT SECRETARIATE,
THIRUVANANTHAPURAM, PIN - 695001
BY ADVS.
SRI.P.G.JAYASHANKAR
SHRI.THOMAS ABRAHAM
SRI.NAVANEETH.N.NATH
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 750
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 31176 OF 2024
PETITIONER/S:
1 PERUVALLUR SCHEDULE CAST SERVICE CO-OPERATIVE SOCIETY
LTD .,NO.M1044, ILLATHUMADU, PRUVALLUR P.O,
MALAPPURAM (DT), REPRESENTED BY ITS SECRETARY, PIN -
673638
2 PERUVALLUR RURAL CO-OPERATIVE SOCIETY LTD.,
NO.M1014,PARAMBILPEEDIKA P.O, MALAPPURAM (DT),
REPRESENTED BY ITS SECRETARY, PIN - 676317
BY ADVS.
SHRI.C.A.JOJO
SRI.S.JIJI
SHRI.JOSEPH ANU A.A
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT,
MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW
DELHI, PIN - 110000
2 THE COMMISSIONER OF INCOME TAX (TDS),
CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI, PIN -
682018
3 THE INCOME TAX OFFICER (TDS),
INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR
P.O, MALAPPURAM DISTRICT, PIN - 676101
4 THE KERALA STATE CO-OPERATIVE BANK LTD.,
,(ERSTWHILE MALAPPURAM DISTRICT CO-OPERATIVE BANK
LTD), PARRY SHOPPING COMPLEX,CALICUT ROAD, DOWNHILL,
MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN -
2025:KER
W.P(C)No.7053/2023 & Connected cases 751
676519
BY ADVS.
SRI.P.G.JAYASHANKAR
SRI.G.KEERTHIVAS
SRI.NAVANEETH.N.NATH
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 752
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A.
SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947
WP(C) NO. 37399 OF 2024
PETITIONER/S:
1 ENADIMANGALAM AGRICULTURAL IMPROVEMENT CO-OPERATIVE
SOCIETY PT 257,
ELAMANNOOR P.O., PANCHAYAT JUNCTION, PATHANAMTHITTA
DISTRICT REPRESENTED BY ITS SECRETARY, SUNILA S.,
AGED 42 YEARS, D/O.SURENDRANATHEN, RESIDING AT PRASAD
BHAVANAM, EDAKKAD P.O., KOLLAM DISTRICT, PIN - 691552
2 PANDALAM GOVERNMENT SERVANTS CO-OPERATIVE SOCIETY
LTD. NO. A 684,
PANDALAM P.O., PATHANAMTHITTA DISTRICT - 689501,
REPRESENTED BY ITS SECRETARY, SMITHA MOHAN, AGED _
YEARS, RESIDING AT SANTOSH BHAVAN, KAIPUZHA NORTH
P.O., KULANADA. PATHANAMTHITTA DISTRICT, PIN - 689503
3 KONNI AGRICULTURAL RURAL IMPROVEMENT CO-OPERATIVE
SOCIETY LTD., NO. PT-253,
CHINA JUNCTION , KONNI P.O., PATHANAMTHITTA DISTRICT
- 689691, REPRESENTED BY ITS SECRETARY, DEEPA K.,
AGED 44 YEARS, D/O P. K. KAMALASANAN RESIDING AT
AJITHA BHAVAN, EDAKKAD SOUTH P.O., KOLLAM DISTRICT,
PIN - 691552
4 PANDALAM VANITHA CO-OPERATIVE SOCIETY LTD., NO. PT
140,
M.M. JUNCTION, PANDALAM P.O., PATHANAMTHITTA DISTRICT
- 689501, REPRESENTED BY ITS SECRETARY, ARYA
VASUDEVAN AGED 37 YEARS, D/O. P. K. VASUDEVAN
RESIDING AT PALANILKUNATHIL, MUDIYOORKONAM P.O.,
PATHANAMTHITTA DISTRICT
5 PUTHUMALA AGRI DEVELOPMENT AND FARMERS SOCIAL WELFARE
2025:KER
W.P(C)No.7053/2023 & Connected cases 753
CO-OPERATIVE SOCIETY LTD. NO. PT 336,
PALAMUKKU PUTHUMALA P.O., PATHANAMTHITTA DISTRICT -
691554, REPRESENTED BY ITS SECRETARY, SUBIN G. RAJU,
AGED 29 YEARS, S/O. P. G. RAJU, RESIDING AT
PULIYANNAL HOUSE, THEPPUPARA P.O., PARAKODE,
PATHANAMTHITTA DISTRICT
6 THE CENTRAL TRAVANCORE MERCHANT'S CO-OPERATIVE
SOCIETY LTD. NO.PT 210,
PANDALAM P.O., PATHANAMTHITTA DISTRICT - 689501,
REPRESENTED BY ITS SECRETARY, ROSHINI SOMARAJAN, AGED
51 YEARS, D/O. S. SIVARAMA PILLAI RESIDING AT
SOMAKRIPA HOUSE, POOZHIKKAD, POOZHIKKADU P.O.,
PANDALAM, PATHANAMTHITTA DISTRICT, PIN - 689515
7 KODUMON AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY
LTD. NO. PT 242,
KODUMON P.O., PATHANAMTHITTA DISTRICT - 691555,
REPRESENTED BY ITS SECRETARY, SINDHU R. NAIR, AGED 45
YEARS, D/O RADHAKRISHNAN NAIR, MANIMANGALATHU HOUSE,
NEDUMON P.O., PATHANAMTHITTA DISTRICT, PIN - 691556
BY ADVS.
SRI.K.SHAJ
SMT.BEENA N.KARTHA
SRI.ARUN CHAND
SMT.MINU VITTORRIA PAULSON
SHRI.BHARAT VIJAY P.
SMT.ARCHANA P.P.
RESPONDENT/S:
1 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH
BLOCK, NEW DELHI, PIN - 110001
2 THE CENTRAL BOARD OF DIRECT TAXES,
DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI,
REPRESENTED BY ITS CHAIRMAN, PIN - 110001
2025:KER
W.P(C)No.7053/2023 & Connected cases 754
3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX,
KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,
KOCHI, PIN - 682018
4 ADDITIONAL COMMISSIONER OF INCOME TAX,
TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF
INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR,
THIRUVANANTHAPURAM, PIN - 695003
5 INCOME TAX OFFICER (TDS),
THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN,
KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003
6 THE KERALA BANK,
CO-BANK TOWERS, P.B.NO.6515, VIKAS BHAVAN P.O.,
PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS CHIEF
EXECUTIVE OFFICER, PIN - 695033
7 THE GENERAL MANAGER,
KERALA BANK, REGIONAL OFFICE, P.B.NO.104, OPP.
MUNICIPAL TOWN HALL, ALAPPUZHA, ALAPPUZHA DISTRICT,
PIN - 688001
8 STATE OF KERALA,
REPRESENTED BY ITS SECRETARY (CO-OPERATION),
GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN -
695001
BY ADVS.
SHRI.NAVANEETH.N.NATH, CGC
SRI.P.G.JAYASHANKAR
SMT.K.AMMINIKUTTY
SRI.G.KEERTHIVAS
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE
COURT ON 25.10.2025 DELIVERED THE FOLLOWING:
2025:KER
W.P(C)No.7053/2023 & Connected cases 755
JUDGMENT
[WP(C) Nos.7053/2023, 213/2022, 378/2022, 384/2022, 383/2022,
732/2022, 736/2022, 833/2022, 1383/2022, 1633/2022, 1808/2022,
1943/2022, 2208/2022, 2780/2022, 3734/2022, 4385/2022,
4442/2022, 4996/2022, 5569/2022, 5900/2022, 8026/2022,
8742/2022, 8943/2023, 10465/2022, 10480/2022, 10498/2022,
10692/2022, 10697/2022, 10699/2022, 10705/2022, 10717/2022,
10719/2022, 10720/2022, 10721/2022, 10722/2022, 10731/2022,
10735/2022, 10738/2022, 10741/2022, 10744/2022, 10747/2022,
10787/2022, 10799/2022, 10810/2022, 10818/2022, 10828/2022,
10831/2022, 10845/2022, 10855/2022, 10891/2022, 10936/2022,
10937/2022, 10968/2022, 10967/2022, 11001/2022, 11009/2022,
11035/2022, 11042/2022, 11058/2022, 11072/2022, 11087/2022,
11092/2022, 11096/2022, 11117/2022, 11130/2022, 11135/2022,
11138/2022, 11144/2022, 11143/2022, 11149/2022, 11150/2022,
11165/2022, 11171/2022, 11187/2022, 11184/2022, 11186/2022,
11194/2022, 11203/2022, 11224/2022, 11232/2022, 11248/2022,
11247/2022, 11262/2022, 11260/2022, 11263/2022, 11271/2022,
11272/2022, 11273/2022, 11286/2022, 11301/2022, 11309/2022,
11316/2022, 11332/2022, 11323/2022, 11325/2022, 11326/2022,
11327/2022, 11335/2022, 11342/2022, 11355/2022, 11366/2022,
11371/2022, 11373/2022, 11381/2022, 11407/2022, 11415/2022,
11420/2022, 11441/2022, 11440/2022, 11450/2022, 11446/2022,
2025:KER
11445/2022, 11458/2022, 11467/2022, 11478/2022, 11480/2022,
11489/2022, 11487/2022, 11507/2022, 11530/2022, 11544/2022,
11555/2022, 11558/2022, 11570/2022, 11591/2022, 11601/2022,
11599/2022, 11600/2022, 11604/2022, 11607/2022, 11605/2022,
11609/2022, 10302/2022, 11616/2022, 11619/2022, 11620/2022,
11621/2022, 11627/2022, 11646/2022, 11649/2022, 11654/2022,
11683/2022, 11679/2022, 11684/2022, 11718/2022, 11721/2022,
11728/2022, 11727/2022, 11740/2022, 11738/2022, 11765/2022,
11760/2022, 11766/2022, 11768/2022, 11772/2022, 11776/2022,
11780/2022, 11781/2022, 11783/2022, 11915/2022, 11784/2022,
11791/2022, 11792/2022, 11810/2022, 11848/2022, 11851/2022,
11870/2022, 11887/2022, 11884/2022, 11939/2022, 12054/2022,
12057/2022, 12065/2022, 12061/2022, 12076/2022, 12075/2022,
12082/2022, 12086/2022, 12100/2022, 12102/2022, 12105/2022,
12110/2022, 12123/2022, 12124/2022, 12126/2022, 12145/2022,
12257/2022, 12263/2022, 12351/2022, 12428/2022, 14068/2022,
12504/2022, 12545/2022, 12635/2022, 12754/2022, 12713/2022,
12744/2022, 12753/2022, 12759/2022, 13011/2022, 13047/2022,
13114/2022, 13112/2022, 13171/2022, 13184/2022, 13339/2022,
13303/2022, 13305/2022, 13318/2022, 13358/2022, 13364/2022,
13410/2022, 13439/2022, 13492/2022, 13545/2022, 13615/2022,
13687/2022, 13693/2022, 13707/2022, 13720/2022, 13741/2022,
13746/2022, 13751/2022, 13760/2022, 13761/2022, 13781/2022,
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13797/2022, 13833/2022, 13891/2022, 13895/2022, 13902/2022,
13903/2022, 13912/2022, 13939/2022, 13940/2022, 13996/2022,
14006/2022, 14010/2022, 14014/2022, 14017/2022, 14047/2022,
14061/2022, 14119/2022, 14122/2022, 14151/2022, 14162/2022,
14195/2022, 14341/2022, 14425/2022, 14559/2022, 14687/2022,
14715/2022, 14806/2022, 14807/2022, 14811/2022, 14832/2022,
14838/2022, 14857/2022, 14944/2022, 14960/2022, 15027/2022,
15066/2022, 15438/2022, 15480/2022, 15487/2022, 15518/2022,
15596/2022, 15598/2022, 15789/2022, 15825/2022, 15828/2022,
15874/2022, 16074/2022, 16243/2022, 16321/2022, 16459/2022,
16598/2022, 16805/2022, 16881/2022, 17323/2022, 17707/2022,
17716/2022, 17796/2022, 18070/2022, 18489/2022, 18690/2022,
20028/2022, 21287/2022, 21639/2022, 21922/2022, 22198/2022,
22339/2022, 22917/2022, 23239/2022, 23780/2022, 24428/2022,
24538/2022, 25354/2022, 26364/2022, 26636/2022, 25894/2023,
27682/2023, 31251/2022, 32055/2022, 32580/2023, 30686/2021,
36670/2023, 41031/2022, 9194/2024, 41499/2022, 43925/2023,
27670/2024, 31176/2024, 37399/2024]
...
In all these cases, the petitioners are Co-operative Societies
registered under the provisions of the Kerala Co-operative Societies
Act, 1969 and are classified as Primary Agricultural Credit Societies
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under the said Act and the Rules. In all these cases, the challenge is
raised against the Constitutional validity of the proviso to section
194A(3) of the Income Tax Act, 1961 (hereinafter referred to as the
Act), by which, a restriction was imposed, based on the gross receipts or
turnover of the Societies, in the matter of exemption from the obligation
to make TDS from the income as the interests on deposits.
2. The brief facts which are required to examine the
issues involved in these writ petitions are as follows: As mentioned
above, all these petitioners are Primary Agricultural Credit Societies,
which are mainly engaged in the business of providing financial
assistance to their members, for agricultural purposes. Section 194A
deals with the liability to make deduction of tax at source (TDS) in
respect of certain transactions and sub-section (1) thereof imposes a
liability upon any person not being an individual or a Hindu undivided
family, to deduct such amount as may be prescribed, from the income
paid to any person by way of interest, other than the income by way of
interest on securities. Subsection (3) of the aforesaid provision
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contemplates certain exceptional circumstances under which, the parties
shall be exempted from making TDS. As per clause (v) of subsection
(3) of Section 194A, the income credited or paid by a Co-operative
society other than a co-operative bank to a member thereof or the
income credited or paid by a co-operative society to any other
co-operative society, shall be excluded from the operation of sub-
section (1) of Section 194A. Similarly, clause (viia) of section 194A(3)
provides for a similar exemption in the case of deposits with a primary
credit society or a co-operative Land Mortgage Bank or a Co-operative
Land Development Bank.
3. Thus, in the light of the statutory stipulations
contained in clauses (v) and (viia) of section 194A(3) of the Act, all
the petitioners were under no obligation to deduct any TDS in respect of
the income received or credited to, as interest on deposits. However, as
per Finance Act, 2020, an amendment was brought in, to the aforesaid
stipulation, by adding a proviso in respect of the co-operative societies
referred to in clause (v)and (viia), which was to the effect that, in case,
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the total sales, gross receipts or turn over of the co-operative societies
exceed 50 crores rupees, during the financial year immediately
preceding to the financial year referred to sub-section (1) of Section
194A, such interest amount shall be subjected to TDS, when the same is
being paid or credited to the payee. The petitioners are aggrieved by the
introduction of the said proviso, as according to them, the impact of the
same is to the effect that, the exemption which was otherwise available
to them by virtue of section 194A(3), has been taken away.
4. According to the petitioners, the introduction of the
proviso as referred to above, affects them in two ways, which are as
follows:
4.1. Firstly, as per Section 57 of the Kerala Co-operative
Societies Act, the funds of the Co-operative Society have to be invested
as per the directions of the Registrar. As per various directions issued
in this regard, the Co-operative Societies are bound to keep their cash
balance with the account operated in the Kerala State Co-operative
Bank (Kerala Bank), which is the Apex Co-operative Society of all the
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Co-operative Societies. Moreover, the petitioners do not have the
necessary infrastructure to meet the safety requirements for keeping
huge amounts of cash and hence, on that reason also, the deposits will
have to be with the Kerala State Co-operative Bank. The petitioner is
receiving interest for such deposits from the Kerala Bank and it also
amounts to income by way of interest, which is liable to be deducted
from the income while assessing tax for the respective Societies, in the
light of Section 80P(2)(d) of the Income Tax Act. Thus, there is no tax
liability upon such income as per the above provision.
4.2. Moreover, as per clauses (v) and (via) of Section
194A(3) (v) and, it is stipulated that the obligation to deduct any
amount as TDS in respect of the income received or credited as interest
shall not be applicable to the petitioners. However, the newly
introduced proviso to sub section 194A(3), imposes a condition that, in
respect of a Society, whose total sales or gross receipts or turn over
exceeds Rs.50 Crores. Due to the same, the exemption from making
deduction is made not applicable to the petitioner and hence, the
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petitioners are compelled to deduct amounts towards TDS, despite the
fact that, there is no tax liability upon them, as far as the income from
the deposits are concerned, as the same is already exempted under
Section 80P(2)(d) of the Act. According to the petitioners, the
introduction of a criterion of Rs 50 Crores as referred to above,
practically takes away the benefit, which was originally granted to
them. This is because, since all their deposits are to be compulsorily
made to the Kerala Bank being the Apex Society, and the gross
turnover of the Kerala Bank exceeds Rs.50 crores, all the income
received by the petitioners by way of income from the deposits with the
Kerala Bank, are subjected to TDS.
4.3. Secondly, most of the petitioners are having the
turnover of above Rs.50 crores and on account of the same, the
petitioners will have to deduct the amount towards TDS, when the
interest is being credited to the accounts of the members, for the
deposits made by such members of the Society. This is affecting their
business, as according to them, the persons who are interested in
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making deposits with the petitioners are likely to opt for other Societies
whose turnover is less than Rs.50 Crores, so as to avoid the liability to
subject their income to TDS. According to the petitioners, thus, the said
proviso introduces, an unreasonable classification, that violates the
principles enshrined under Art.14 of the Constitution of India. These
writ petitions are submitted in such circumstances, challenging the
validity of the aforesaid statutory provisions.
5. A detailed statement has been filed by the Income Tax
Department, opposing the reliefs sought and denying the contentions
raised in these writ petitions. According to the Department, the proviso
introduced as per Finance Act 2020, is within the legislative
competence of the Central Government and the stipulations contained in
the proviso to Section 194A(3) do not violate any of the fundamental
rights of the petitioners. It was contended that, even though section 80P
of the Income Tax Act provides some benefits to the petitioners, the
same is not an exemption from payment of tax, as far as the income
received by the petitioners as interest from deposits is concerned.
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According to the Department, what is contemplated under Section 80P,
is only a deduction of such income while making the assessment, which
is subject to the other conditions stipulated in the Act. Section 80AC
provides that such deductions shall be allowed only if the return is
furnished for the relevant year. Therefore, in order to ensure that, the
amount receivable to the Department is collected, and there is no
evasion of tax, it is lawful for the Central Government to incorporate
appropriate conditions in the statute and the proviso referred to above,
was as part of the same. According to the Department, the said proviso
does not impose any new liability upon the petitioners and the parties
can get the refund of the amount, upon filing returns with the necessary
documents. In such circumstances, they sought dismissal of these writ
petitions.
6. Heard Sri. A. Kumar, the learned Senior Counsel,
Dr. K.P. Pradeep, Sri.M.M.Monaye, Sri. K.S. Hariharan Nair, and
Sri. Jojo C.A, the learned counsel appearing for the petitioners, Sri.B.G.
Hareendranath and Sri. Thomas Abraham appearing for the Kerala
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Bank, Sri. Mohammed Rafiq, the learned Special Government Pleader
(Taxes) for the State of Kerala and Sri. Christopher Abraham, the
learned Standing Counsel for the Income Tax Department.
7. The main contention raised by the petitioners against
the validity of the proviso to Section 194A(3) is that, the same is liable
to be struck down as it is violative of the principles of the equality as
contemplated under Art. 14 of the Constitution of India, since the same
is creating an unreasonable classification among the Co-operative
Societies, based on the total turnover of the Society. It is also their case
that, by virtue of introduction of proviso, a liability has been imposed
to deduct the amounts as TDS in respect of an income, which is not
otherwise taxable under the provisions of the Income Tax Act. Besides,
the proviso referred to above, takes away the exemption, otherwise
granted to the petitioners, from making any deduction towards TDS in
respect of such income. The petitioners have also highlighted the
serious impact that would result from the said proviso, upon the
interests and prospects of the petitioner-Societies. As mentioned above,
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by virtue of the introduction of a ceiling in turnover, the receipts of the
Societies by way of income of interest on the deposits made by them
with the Kerala Bank, the Apex Society, and the amount to be paid by
the petitioner -Societies to its Members as interests for the deposits
made by such members were subjected to TDS, which were not
otherwise applicable. The petitioners have pointed out that, as far as the
income received by the petitioner-Societies as interests is concerned, the
same is not liable to be taxed by virtue of section 80P of the Act, which
right was upheld by the Hon'ble Supreme Court in Mavilayi Service
Co-operative Bank Ltd v. Commissioner of Income Tax, Calicut
and Another [2021 (1) KHC 303]. Apart from the above, large
number of decisions were cited by the petitioners in support of their
contentions with regard to the Constitutional validity of the statutory
provisions, which shall be dealt with in this judgment, as and when
necessary.
8. On the other hand, the learned Standing Counsel
reiterated the contentions raised by him in the statement and he also
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relied on large number of decisions.
9. The learned Special Government Pleader supported
the contentions raised by the petitioners, by pointing out that, the
proviso introduced as per Finance Act, 2020, practically takes away the
benefits granted to the societies as per the main provision viz. 194A(3),
and thus it had gone beyond the scope of a proviso and hence requires
interference.
10. Before going to the contentions raised from either
side, it is necessary to examine the relevant statutory provisions which
are as follows:
a) Section 80P(1) and 2(d) of the Income Tax Act contemplates
as follows:
"80P. Deduction in respect of income of co-operative societies
(1) Where, in the case of an assessee being a co-operative
society, the gross total income includes any income referred to in
sub-section (2), there shall be deducted, in accordance with and
subject to the provisions of this section, the sums specified in sub-
section (2), in computing the total income of the assessee.
80P2(d):The sums referred to in sub-section(1) shall be the
following, namely:-
in respect of any income by way of interest or dividends derived
by the co-operative society from its investments with any other
co-operative society, the whole of such income"
"b)Section 80AC. Deduction not to be allowed unless return
furnished
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Where in computing the total income of an assessee of any
previous year relevant to the assessment year commencing on or
after-
(i) the 1st day of April, 2006 but before the 1 st day of April, 2018,
any deduction is admissible under section 80-1A or section 80-
1AB or section 80-1B or section 80-1C or section 80-1D or
section 80-1E;
(ii) the 1st day of April,2018, any deduction is admissible under
any provision of this Chapter under the heading "C.- Deductions
in respect of certain incomes".
no such deduction shall be allowed to him unless he furnishes a
return of his income for such assessment year on or before the
due date specified under sub-section(1) of section 139."
"c) 194A. Interest other than "interest on securities"
(1) Any person, not being an individual or a Hindu undivided
family, who is responsible for paying to a resident any income by
way of interest other than income [by way of interest on
securities], shall, at the time of credit of such income to the
account of the payee or at the time of payment thereof in cash or
by issue of a cheque or draft or by any other mode, whichever is
earlier, deduct income-tax thereon at the rates in force:
[Provided that an individual or a Hindu undivided family,
whose total sales, gross receipts or turnover from the
business or profession carried on by him exceed [one
crore rupees in case of business or fifty lakh rupees in
case of profession]during the financial year immediately
preceding the financial year in which such interest is
credited or paid, shall be liable to deduct income-tax
under this section.]
[Explanation.- For the purposes of this section where any
income by way of interest as aforesaid is credited to my
account whether called "Interest payable account" or
"Suspense account" or by any other name, in the books of
account of the person liable to pay such income, such
crediting shall be deemed to be credit of such income to
the account of the payee and the provisions of this section
shall apply accordingly]
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d) 194A(3): The provisions of sub-section (1) shall not
apply--
...............
..........
(v) to such income credited or [paid by a co-operative
society (other than a co-operative bank) to a member
thereof or to such income credited or paid by a co-
operative society] to any other co-operative society;
Explanation.- For the purpose of this clause, "co-
operative bank" shall have the meaning assigned to it in
Part V of the Banking Regulation Act, 1949 (10 of 1949),
(vii) to such income credited or paid in respect of deposits
(other than time deposits made on or after the 1 st day of
July, 1995) with a banking company to which the Banking
Regulation Act, 1949 (10 of 1949) applies (including any
bank or banking institution referred to in section 51 of that
Act.
(viia). to such income credited or paid in respect of,-
(a) deposits with a primary agricultural credit
society or a primary credit society or a co-operative
land mortgage bank or a co-operative land
development bank;
(b) deposits (other than time deposits made on or
after the 1st day of July, 1995) with a co-operative
society, other than a co-operative society or bank
referred to in sub-clause (a), engaged in carrying on
the business of banking;]
[Provided that a co-operative society referred to in
clause (v) or clause (viia) shall be liable to deduct
income-tax in accordance with the provisions of sub-
section(1), if -
(a) the total sales, gross receipts or turnover of
the co-operative society exceeds fifty crore rupees
during the financial year immediately preceding the
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financial year in which the interest referred to in sub-
section (1) is credited or paid; and
(b) the amount of interest, or the aggregate of
the amounts of such interest, credited or paid, or is
likely to be credited or paid, during the financial year
is more than[one lakh] rupees in case of payee being
a senior citizen and [fifty thousand] rupees in any
other case.]
[Explanation 1.- For the purpose of clauses (i)(vii)
and (viia), "time deposits" means deposits
[(including) recurring deposits] repayable on the
expiry of fixed periods.
[Explanation 2.- For the purposes of this sub-section,
"senior citizen" means an individual resident in India
who is of the age of sixty years or more at any time
during the relevant previous year.]
11. The circumstances under which a provision can be
declared as ultra vires of the Constitution, are laid down by the Hon'ble
Supreme Court in several decisions. In Government of Andhra
Pradesh & Ors. v. Smt.P. Laxmi Devi [AIR 2008 SC 1640], this
question was discussed in detail, after referring to a large number of
decisions, and it was observed that, while judges should practice great
restraint in dealing with economic statutes, they should be activists in
defending the civil liberty and fundamental rights of the citizens. In
Union of India v. Elphinstone Spinning and Weaving Co. and
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Others [AIR 2001 SC 724], it was observed as follows:
"9. .............................. There is always a presumption that the
legislature does not exceed its jurisdiction and the burden of
establishing that the legislature has transgressed constitutional
mandates, such as those relating to fundamental rights, is
always on the person who challenges its vires. Unless it
becomes clear beyond reasonable doubt that the legislation in
question transgresses the limits laid down by the organic law of
the Constitution it must be allowed to stand as the true
expression of the national will -- Shell Co. of
Australia v. Federal Commr. of Taxation [1931 AC 275 : 1930
All ER Rep 671 : 100 LJPC 55 : 144 LT 421 (PC)] . The
aforesaid principle, however, is subject to one exception that if
a citizen is able to establish that the legislation has invaded its
fundamental rights then the State must justify that the law is
saved. It is also a cardinal rule of construction that if on one
construction being given the statute will become ultra vires the
powers of the legislature whereas on another construction
which may be open, the statute remains effective and operative,
then the court will prefer the latter, on the ground that the
legislature is presumed not to have intended an excess of
jurisdiction.
12. The Privy Council in Shell Company of Australia
v. Federal Commissioner of Taxation [(1931 AC 275 (298)], it was
observed that, "unless it becomes clear beyond reasonable doubt that,
the legislation in question transgresses the limits laid down by the
organic law of the Constitution, it must be allowed to stand as the true
expression of national will". After referring to the aforesaid
observations of the Privy Council, it was observed by the Hon'ble
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Supreme Court Smt. P. Laxmi Devi's case (supra) that, if two views
are possible, one making the provision in the statute constitutional, and
the other making it as unconstitutional, the former should be preferred.
It was further observed therein that, the court must therefore make every
effort to uphold the Constitutional validity of a statute, even if that
requires the statutory provisions a strained meaning, or narrower or
wider meaning than what appears on the face of it. It is only when all
efforts to do so fail, should the court declare the same as
unconstitutional.
13. As far as the petitioners are concerned, they mainly rely
on the decisions in K.T.Moopil Nair v. State of Kerala and Anr.
[AIR 1961 SC 552], M.R.F. Ltd v. Inspector, Kerala Government &
Ors. [(1998) 8 SCC 227], Shayara Bano v. Union of India and Ors.
[(2017) 9 SCC 1], Ashirvad Films v. Union of India [ (2007) 6 SCC
624], Union of India & Anr. v. Ganpati Dealcom Pvt Ltd. [(2023) 3
SCC 315], Union of India and Ors v. N.S.Rathnam and Sons
[(2015)10 SCC 681], The Commissioner of Income Tax, New Delhi
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v. Eli Lilly and Company (India) Pvt. Ltd [(2009) 15 SCC 1] etc. to
substantiate their contentions to the Constitutional validity of the
statutory provisions.
14.The circumstances under which a statutory provision can be
interfered with, are enumerated in the decisions referred to above,
which are mainly, the lack of legislative competence, violative of the
provisions of Part III of the Constitution or when there is manifest
arbitrariness in the enactment. In this case, apart from the above, it is
also the contention of the petitioners that, the amendment was given
effect to, by way of bringing in a proviso to the main section, and the
effect the said proviso is such that, the purpose for which the original
provision was created, is defeated as it takes away the entire rights of
the parties as per the main provision. Therefore, the same is not
sustainable.
15. The questions involved in these writ petitions are to be
considered by keeping the aforesaid principles in mind. It is also to be
noted that, as far as a taxing statute is concerned, the same stands in a
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high pedestal and it was held in R.K. Garg v. Union of India and ors
[(1981) 4 SCC 675] in the manner as follows:
"8. Another rule of equal importance is that laws relating to
economic activities should be viewed with greater latitude than
laws touching civil rights such as freedom of speech, religion
etc. It has been said by no less a person than Holmes, J., that
the legislature should be allowed some play in the joints,
because it has to deal with complex problems which do not
admit of solution through any doctrinaire or strait-jacket
formula and this is particularly true in case of legislation
dealing with economic matters, where, having regard to the
nature of the problems required to be dealt with, greater play in
the joints has to be allowed to the legislature. The court should
feel more inclined to give judicial deference to legislative
judgment in the field of economic regulation than in other areas
where fundamental human rights are involved. Nowhere has
this admonition been more felicit ously expressed than
in Morey v. Doud [354 US 457 : 1 L Ed 2d 1485 (1957)] where
Frankfurter, J., said in his inimitable style:"
16. One of the main contentions raised by the petitioners is
that, as far as the income received by them by way of interest on
deposits is concerned, the same is not taxable as there is an exemption
contemplated under section 80P(2)(d) of the Act. According to the
petitioners, since the income, which is the subject matter of these
litigations, is not at all taxable, imposing a condition to collect TDS in
respect of such income, is illegal and it amounts to an arbitrary action
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on the part of the State. To substantiate these contentions, the petitioners
are relying upon the observations made by the Hon'ble Supreme Court
in Eli Lilly's case (supra) where it was observed by the Hon'ble
Supreme Court as follows:
"75. To answer the contention herein we need to examine briefly
the scheme of the 1961 Act. Section 4 is the charging section.
Under Section 4(1), total income for the previous year is
chargeable to tax. Section 4(2) inter alia provides that in respect
of income chargeable under sub-section (1), income tax shall be
deducted at source whether it is so deductible under any
provision of the 1961 Act which inter alia brings in the TDS
provisions contained in Chapter XVII-B. *In fact, if a
particular income falls outside Section 4(1) then TDS
provisions cannot come in."
(*highlighted for emphasis)
17. Thus, the specific case of the petitioners is that, since
there is no tax liability, no TDS could be collected. However, the
crucial aspect to be noticed in this regard is that, the exemption from
payment of tax claimed by the petitioners, is by placing reliance upon
section 80P(1) and (2)(d) of the Income Tax Act. As rightly pointed out
by the learned Standing Counsel for the Income Tax, the said provision
does not contemplate an absolute exemption from the liability to pay the
tax in respect of the said income, but instead, what it provides is that,
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the said income could be deducted from the taxable income of the
assessee, subject to the terms and conditions in the statute. It is to be
noted in this regard that as per Section 80AC of the Act, no such
deduction could be allowed unless the return is furnished. In Section
80AC (ii), there is a specific reference to the deduction under the
heading "C-deductions in respect of certain incomes in Chapter VIA of
the Income Tax Act", and Section 80P comes under the same.
Therefore, it is discernible therefrom that, as far as the tax liability on
income from interest is concerned, for a Co-operative society, it is not
an absolute exemption, but it is a deduction permissible for such a
Society, on submitting the returns. Therefore, as pointed out by the
learned Standing Counsel for the Department, since the benefit under
Section 80P is not an exemption from paying tax, but a benefit of
deduction subject to the compliance of the terms and conditions
including filing of return, it cannot be held that, there is no tax liability
at all, for the petitioners under the Act. As far as the observations made
Eli Lilly's case (supra) is concerned, the same was in respect of an
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income which was not taxable under Section 4(1) of the Income Tax
Act 1961, the charging provision. In this case, it cannot be held that
the income is not subjected to tax at all, in the light of the aforesaid
statutory provisions and the benefit is confined to getting the said
amount deducted from the taxable income. This makes a crucial
distinction and therefore, the principles laid down by the Hon'ble
Supreme Court in the above decision, cannot be made applicable to
these cases.
18. Yet another contention raised by the petitioners regarding the
unreasonable classification, is that, by introducing a ceiling of Rs 50
crores of turnover, a sub-classification was created among the Societies,
which are otherwise equally placed. Therefore, it amounts to violation
of Art.14 of the Constitution of India, it was contended. However,
while considering the aforesaid question, the crucial aspect to be noticed
is that, as far as the criteria of Rs.50 crores is concerned, the same
cannot be treated as an unreasonable classification. This is particularly
because, the liability to pay income tax itself is based on the income
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received by the assessee and the scheme of Act itself is to apply
different rates of tax upon different groups, which are created based on
the income they receive. Thus, the classification based on the total
income or the taxable income, forms the basic structure of the Income
Tax Act. Even in respect of the provision that contemplates TDS,
several exemptions are provided based on the income criteria and
various ceiling limits are prescribed in respect of various categories,
based on the income or the amount included in the transaction. Thus,
this being in tune with the statutory structure of the Act, unless it is
shown that, the classification referred to in the proviso is indeed
creating separate classes among the persons having equal status, no
interference could be made. In other words, the difference in the income
or the quantum of the amount involved, itself is the classification that
determines the liability of tax or the amount to be paid as tax, and the
classifications based on the income, form the basic structure of the
Income Tax Act. Since the very concept involved is, "the liability is
higher when the income is higher", fixing a criterion in similar lines, in
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the matter of TDS, cannot be found fault with, by treating it as an
unreasonable classification. Of course, it is true that, as far as the
provisions which are the subject matter of these writ petitions are
concerned, those are in respect of Co-operative Societies, but, the fact
remains that, the tax liability of each Societies is depending upon the
income that they receive, as well as its source, nature etc, and it is not
merely because of their status as a Society. As mentioned above, as far
as an assessee is concerned, different rates of tax are applicable
depending upon the income they earn. Therefore, when it comes to the
question of TDS and the exemption from making deduction towards
TDS, I do not find any illegality in creating a classification based on the
income they receive.
19. The above view is supported by the observations made by a
five judges bench decision of the Honourable Supreme Court in K.T
Moopil Nair's case (supra), where, while considering the challenge
against a taxing statute, namely, the Travencore-Cochin Land Tax Act,
certain observations were made, with regard to the circumstances under
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which such a challenge can be entertained, based on classification. In
paragraph 7 thereof, after referring to Art. 265 of the Constitution of
India, and while upholding the contention that, even a taxing statute can
be subjected to challenge on the basis of unreasonable classification, the
following observations were made :
"7. It cannot be disputed that if the Act infringes the
provisions of Article 14 of the Constitution, it must be struck
down as unconstitutional. For the purpose of these cases, we
shall assume that the State Legislature had the necessary
competence to enact the law, though the petitioners have
seriously challenged such a competence. The guarantee of
equal protection of the laws must extend even to taxing
statutes. It has not been contended otherwise. It does not
mean that every person should be taxed equally. But it does
mean that if property of the same character has to be taxed,
the taxation must be by the same standard, so that the burden
of taxation may fall equally on all persons holding that kind
and extent of property. If the taxation, generally speaking,
imposes a similar burden on everyone with reference to that
particular kind and extent of property, on the same basis of
taxation, the law shall not be open to attack on the ground of
inequality, even though the result of the taxation may be that
the total burden on different persons may be unequal.
*Hence, if the legislature has classified persons or properties
into different categories, which are subjected to different
rates of taxation with reference to income or property, such a
classification would not be open to the attack of inequality on
the ground that the total burden resulting from such a
classification is unequal. Similarly, different kinds of
property may be subjected to different rates of taxation, but
so long as there is a rational basis for the classification,
Article 14 will not be in the way of such a classification
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resulting in unequal burdens on different classes of
properties. But if the same class of property similarly situated
is subjected to an incidence of taxation, which results in
inequality, the law may be struck down as creating an
inequality amongst holders of the same kind of property. It
must, therefore, be held that a taxing statute is not wholly
immune from attack on the ground that it infringes the
equality clause in Article 14, though the courts are not
concerned with the policy underlying a taxing statute or
whether a particular tax could not have been imposed in a
different way or in a way that the Court might think more just
and equitable. The Act has, therefore, to be examined with
reference to the attack based on Article 14 of the
Constitution."
(*Highlighted for emphasis)
20. The learned Special Govt. Pleader raised another
contention to the effect that, Section 194A(3) clause (v) specifically
deals with the income credited or paid by a Co-operative Society to a
member or such income credited or paid by the Co-operative Society to
any other Co-operative Society. It is pointed out that, even in the case
of payment made by a Co-operative Society to any other Co-operative
Society, such payment is made in view of the fact that the payee society
is a member of the payer society. Therefore, the benefit contemplated
under Clause (v) of 194A(3) is in respect of the payment received by the
member of a Society whereas, the proviso to section 194A(3) takes
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away the right of the payee to get the income without being subject to
TDS, based on a criterion, which is applicable to the payer alone. This
is because, the ceiling contemplated in the said proviso is that of the
income of the payer society, which has nothing to do with the payee.
Thus, according to the learned Special Government Pleader, the
stipulations in the proviso had gone beyond the scope of the main
provision and therefore, the same is to be interfered with. Infact, the
petitioners have also raised a contention with regard to the limited scope
of the proviso, when it comes to the question of real purpose and scope
of the main provision.
21. To consider the said question, it is necessary to examine the
principles that relate to the interpretation of a proviso and its
applicability to the main provision. The petitioners brought the attention
of this court to the observations in foreign decisions such as, West
Derby Union v. Metropolitan Life Assurance Company [1897 AC
647 (HL)] and Jennings v. Kelly [1940 AC 206], where it was
observed that, a proviso to a section cannot be used to import into the
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enacting part, something which is not there, but where the enacting part
is susceptible to several possible meanings, it may be controlled by
proviso. Thus, it was contended that, the real purpose of the proviso is
to act as an optional addenda to the enactment with the sole object of
explaining the real intendment of the statutory provision, as held in
Swedish Match AB and Another v. Securities and Exchange Board
and Another [(2004) 11 SCC 641].
22. The aforesaid question was elaborately considered by a three
judges bench of the Honourable Supreme Court in S.Sundaram Pillai
and others v. V.R.Pattabhiraman and others [(1985) 1 SCC 591].
The decisions in West Derby Union (supra) and Jennings (supra),
relied on by the petitioners, were also referred to by the Honourable
Supreme Court in the said decision. In paragraph 30 of the said
decision, Sarathi in Interpretation of Statutes was quoted, which reads
as follows:
"30. Sarathi in Interpretation of Statutes at pages 294-295 has
collected the following principles in regard to a proviso:
(a) When one finds a proviso to a section the natural
presumption is that, but for the proviso, the enacting part of the
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section would have included the subject-matter of the proviso.
(b) A proviso must be construed with reference to the preceding
parts of the clause to which it is appended.
(c) Where the proviso is directly repugnant to a section, the
proviso shall stand and be held a repeal of the section as the
proviso speaks the latter intention of the makers.
(d) Where the section is doubtful, a proviso may be used as a
guide to its interpretation: but when it is clear, a proviso cannot
imply the existence of words of which there is no trace in the
section.
(e) The proviso is subordinate to the main section.
(f) A proviso does not enlarge an enactment except for
compelling reasons.
(g) Sometimes an unnecessary proviso is inserted by way of
abundant caution.
(h) A construction placed upon a proviso which brings it into
general harmony with the terms of section should prevail.
(i) When a proviso is repugnant to the enacting part, the proviso
will not prevail over the absolute terms of a later Act directed to
be read as supplemental to the earlier one.
(j) A proviso may sometimes contain a substantive provision."
23.In paragraph 37 of the said decision, it was observed that, a
proviso is intended to limit the enacted provision so as to except
something which would have otherwise been within it or in some
measure to modify the enacting clause. It was further observed that,
sometimes, a proviso may be embedded in the main provision and
becomes an integral part of it so as to amount to a substantive
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provision itself. In the said decision, the following observation made by
the Honourable Supreme Court in Dwaraka Prasad v Dwaraka Das
Saraf [(1976) 1 SCC 128] was also referred to:
"........ A proviso ordinarily is but a proviso, although the
golden rule is to read the whole section, inclusive of the proviso,
in such manner that they mutually throw light on each other and
result in a harmonious construction."
24.Similarly, in the said decision, the following observations in
Hiralal Rattanlal v State of U.P [(1973) 1 SCC 216)] were also
referred to:
"Ordinarily a proviso to a section is intended to take out a part
of the main section for special treatment. It is not expected to
enlarge the scope of the main section. But cases have arisen in
which this Court has held that despite the fact that a provision
is called proviso, it is really a separate provision and the so-
called proviso has substantially altered the main section."
25. Thus, after referring to a number of precedents and principles,
the purposes of a proviso were summed up in paragraph 43 of
S.Sundaram Pillai's case (supra), in the manner as follows:
"43. We need not multiply authorities after authorities on this
point because the legal position seems to be clearly and
manifestly well established. To sum up, a proviso may serve
four different purposes:
(1) qualifying or excepting certain provisions from the main
enactment:
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(2) it may entirely change the very concept of the intendment
of the enactment by insisting on certain mandatory conditions
to be fulfilled in order to make the enactment workable:
(3) it may be so embedded in the Act itself as to become an
integral part of the enactment and thus acquire the tenor and
colour of the substantive enactment itself; and
(4) it may be used merely to act as an optional addenda to the
enactment with the sole object of explaining the real
intendment of the statutory provision."
26. In this regard, the observations made by the Honourable
Supreme Court in Commissioner of Income Taxes v. Ramkishan
Shrikishan Jhaver and others [AIR 1968 SC 59] are relevant. It was
observed in the said decision, after referring to some other decision of
the Honourable Supreme Court that, in exceptional circumstances, a
proviso may not be really a proviso in accepted sense, but may be a
substantive provision itself.
27. Thus, when we are attempting to deduce the principles from
the decisions referred to above, what could be gathered is that, there is
no hard and fast rule that, a proviso to a main section in all cases, should
be subject to the confines of the enacted provision, but instead, in some
cases it by itself could be a substantive provision, that could alter the
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main provision itself, substantially. On careful examination of decisions
where such an extreme interpretation giving substantive status to the
proviso is given, it can be seen that, those were made after going
through the circumstances under which the said proviso was introduced,
the object behind the same etc, which would ultimately lead to the
purpose for which such a proviso was brought in by the legislature.
Thus, while considering the aforesaid question, the paramount
consideration should be the intention of the legislature while bringing in
such legislation. It is to be noted in this regard that, despite carefully
scanning through the decisions referred to above, nothing could be
found, that restricts the power of the legislature to introduce a statutory
stipulation in the form of a proviso, but on the other hand, there are
decisions, where it was observed that, in certain circumstances, the
proviso could be treated as substantive provision that alters the main
provision. Therefore, in the absence of any such prohibition upon the
legislature, a proviso that was intentionally brought by the legislature to
make substantial changes in the main section, cannot be interfered with,
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merely because of the reason that, it is a proviso. To be precise, in such
circumstances, it has to be treated as part of the main provision, and the
interference could be made only if the other tests to determine the
Constitutionality viz, lack of legislative competence, violative of Part III
of the Constitution, manifest arbitrariness etc, are satisfied.
28. When the proviso to section 194A(3) is examined in that
perspective, it can be seen that, the said proviso was subsequently
introduced by way of an amendment as per Finance Act, 2020, bringing
in, some conditions restricting the operation of the main provision.
Thus, it is evident that it was intended to alter the scope of the main
provision i.e subsection (3) of the Section 194A, and in the light of the
principles referred to above, the same cannot be interfered with, merely
because it is a proviso.
29. Of course, as pointed by the learned Special Government
Pleader, the clause (v) of subsection (3) of Section 194A of the Act,
deals with the exemption from the point of view of the payee, whereas,
the proviso deals with the non-applicability of the said provision
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depending upon the total turnover or total sales or gross receipts of the
payer. However, I am of the view that, the same by itself would not be a
ground to interfere with the said provision. This is mainly because, the
stipulation in Section 194(3) relates to the inapplicability of Section
194A(1) in the matter of TDS, where, the liability to deduct the amount
as TDS is imposed upon the payer. Therefore, by virtue of the proviso,
the ultimate result is the change in restrictions on the applicability of
section 194A(1), which deals with the obligation of the payer, and
hence there is nothing wrong therein, as the basis is the total turnover or
gross receipts or total sales of the payer. It is to be noted that the higher
the turnover, higher the number of transactions and this could be a
reasonable ground to make such a classification.
30.Another contention raised by the petitioners is that, while
fixing the criteria as the turnover or gross receipt or total sales
exceeding Rs 50 Crores, the classification was made by the respondents
without any intelligible differentia and hence the same cannot be
considered as reasonable. Reliance was placed on Asianet Satellite
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Communication v. State of Kerala [2012 (4) KLT 431], where it was
held that the classification of cable TV operators having more than 7500
subscribers for the purpose of subjecting them to tax is violative of
Article 14. However, it is to be noted that, in this case, as mentioned
above, what is taxable, is the income of the assessee, and for that
purpose the tax payers with different income, cannot be treated as
equals, even if such tax payers are having the same status as far as their
occupation/professions/trade is concerned. In Murthy Match Works v.
CCE, [(1974) 4 SCC 428], it was held that;
"15. Certain principles which bear upon classification may be
mentioned here. It is true that a State may classify persons and
objects for the purpose of legislation and pass laws for the
purpose of obtaining revenue or other objects. Every
differentiation is not a discrimination. But classification can be
sustained only it (sic) it is founded on pertinent and real
differences as distinguished from irrelevant and artificial ones.
The constitutional standard by which the sufficiency of the
differentia which form a valid basis for classification may be
measured, has been repeatedly stated by the Courts. If it rests on
a difference which bears a fair and just relation to the object for
which it is proposed, it is constitutional. To put it differently, the
means must have nexus with the ends. Even so, a large latitude
is allowed to the State for classification upon a reasonable basis
and what is reasonable is a question of practical details and a
variety of factors which the Court will be reluctant and perhaps
ill-equipped to investigate. In this imperfect world perfection
even in grouping is an ambition hardly ever accomplished. In
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this context, we have to remember the relationship between the
legislative and judicial departments of Government in the
determination of the validity of classification. Of course, in the
last analysis Courts possess the power to pronounce on the
constitutionality of the acts of the other branches whether a
classification is based upon substantial differences or is
arbitrary, fanciful and consequently illegal. At the same time,
the question of classification is primarily for legislative
judgment and ordinarily does not become a judicial question. A
power to classify being extremely broad and based on diverse
considerations of executive pragmatism, the Judicature cannot
rush in where even the Legislature warily treads. All these
operational restraints on judicial power must weigh more
emphatically where the subject is taxation".
In Union of India v. Nitdip Textile Processors (P) Ltd.,[ (2012) 1 SCC
226], it was observed as follows;
"67. It has been laid down in a large number of decisions of this
Court that a taxation statute, for the reasons of functional
expediency and even otherwise, can pick and choose to tax
some. A power to classify being extremely broad and based on
diverse considerations of executive pragmatism, the judicature
cannot rush in where even the legislature warily treads. All
these operational restraints on judicial power must weigh more
emphatically where the subject is taxation. Discrimination
resulting from fortuitous circumstances arising out of particular
situations, in which some of the tax-payers find themselves, is
not hit by Article 14 if the legislation, as such, is of general
application and does not single them out for harsh treatment.
Advantages or disadvantages to individual assessees are
accidental and inevitable and are inherent in every taxing
statute as it has to draw a line somewhere and some cases
necessarily fall on the other side of the line."
Therefore, merely because, a different yardstick was adopted for the
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assessment or TDS, based on the income, in respect of the Co-operative
Societies, it cannot be treated as unreasonable.
31. Yet another contention raised by the petitioners is that, the
impact of the introduction of the proviso is that, the income of the
petitioners by way of interest for their deposits with the Kerala Bank,
the Apex Society, would be subjected to TDS in its entirety. This is
because, as far as the petitioners are concerned, in the light of the
provisions in the Kerala Co-operative Societies Act, the Rules framed
thereunder, and the Government orders and circulars issued in this
regard, the petitioners are bound to deposit the cash balance with the
Kerala Bank. In view of the fact that, total turnover of the Kerala Bank
being in excess of Rs 50 Crores, all their income from that source is
subjected to TDS and thus the exemption that is granted as per Section
194A (3) is taken away as per the proviso. According to the petitioners,
such a stipulation is arbitrary and amounts to manifest arbitrariness and
hence interference is required. It was also pointed out that, as far as Co-
operative sector is concerned, it is entitled to the Constitutional
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protection as per the various provisions in the Constitution of India. It
was pointed out that such special protection was extended to the said
sector, considering the huge economic impact that can be created by the
Cooperative movement to the economy as a whole and the rural
economy in particular. The observations of the Honourable Supreme
Court in Shayara Bano v. Union of India [(2017) 9 SCC 1] were also
relied on, in which the manifest arbitrariness was accepted as a valid
ground for the challenge against a statutory provision.
32. However, the crucial aspect to be noticed in this regard is that,
the difficulties highlighted by the petitioners, in the matter of
compulsory nature of the deposits and matters incidental thereto, are not
on account of any stipulations in the Income Tax Act itself, but those
are due to the consequences of the provisions in the Kerala Co-operative
Societies Act, and the orders issued by the statutory authorities under
the said Act. Such consequences cannot be a reason for the manifest
arbitrariness on the part of the Central legislature when terms and
conditions in an enactment are brought into force by the said legislature.
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In other words, when the major contributory factor for the denial of the
benefit is on account of a different statute than the one under challenge,
that too being a State subject, the same cannot be taken as a valid
ground to attribute manifest arbitrariness in the Central Statute.
33. Yet another aspect to be noticed in this regard is that, the
hardships or inconvenience of the party subjected to a law, by itself
cannot be a good reason for judicial interference in a statute as laid
down in Ajmera Housing Corporation and Another vs. C.I.T. (2010)
326 ITR 642 (SC). In Union of India v. M.V. Valliappan, (1999) 6
SCC 259, it was observed that , the consideration of hardship is totally
irrelevant for deciding the question of legislative competence. In the
case of taxation, it is settled law that hardship or equity has no role to
play in determining eligibility (sic exigibility) to tax and it is for the
legislature to determine the same. In Rohitash Kumar v. Om Prakash
Sharma, (2013) 11 SCC 451, it was held that, there may be a statutory
provision, which causes great hardship or inconvenience to either the
party concerned, or to an individual, but the court has no choice but to
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enforce it in full rigour.In Bengal Immunity Co. Ltd. v. State of Bihar
[AIR 1955 SC 661] (SCC p. 685, para 43) it was observed by a
Constitution Bench of the Supreme Court that, if there is any hardship,
it is for the legislature to amend the law, and that the court cannot be
called upon to discard the cardinal rule of interpretation for the purpose
of mitigating such hardship. If the language of an Act is sufficiently
clear, the court has to give effect to it, however inequitable or unjust the
result may be. The words, "dura lex sed lex" which mean "the law is
hard but it is the law" may be used to sum up the situation. Therefore,
even if a statutory provision causes hardship to some people, it is not for
the court to amend the law. A legal enactment must be interpreted in its
plain and literal sense, as that is the first principle of interpretation. This
is because, the legislature, being the reflection of the will of the people,
is supposed to have the knowledge and expertise in the matters of
consequence of each provision in every statute and when they are
making a law with particular stipulations, they deemed to have taken
note of such difficulties.
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34. It was also contended by the petitioners that, the petitioners
are eligible to be provided with the benefits that are contemplated under
section 194A (3) (iii) (a) of the Income Tax Act. The said provision
reads as follows:
"194A(3)(iii)(a)": The provision of sub-section (1) shall not
apply-
xxx xxx xxx xxx xxx xxx
(iii) to such income credited or paid to-
(a) any banking company to which the Banking Regulation
Act, 1949 (10 of 1949), applies or any co-operative society
engaged in carrying on the business of banking (including a
co-operative and mortgage bank)"
However, I am not inclined to accept the said contention as well. This is
because, going by the said provision, it can be seen that, what is
contemplated therein, is with respect to the banking companies to which
the Banking Regulation Act, 1949 applies or any co-operative society
engaged in the business of banking, including a co-operative land
mortgage bank. Evidently, the petitioners are not engaged in the
business of banking and their operation is mainly confined to providing
financial assistance to its members for agricultural purposes, where the
concept of mutuality exists. In this regard, it is profitable to examine the
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definition of banking, as defined section 5(b) of the Banking Regulation
Act, 1949, which reads as follows:
""banking" means the accepting, for the purpose of lending or
investment, of deposits of money from the public, repayable on
demand or otherwise, and withdrawal by cheque, draft or
otherwise."
Evidently, the petitioners are not coming within the said definition.
Therefore, the petitioners cannot be treated as the institutions that fall
within Section 194A(3 (iii) of the Income tax Act as well.
Thus, on the overall consideration of the contentions raised by the
petitioners, this Court is of the view that the petitioners could not
establish any of the grounds that are required to exercise any judicial
intervention in the provisions contained in the proviso to section
194A(3) of the Income Tax Act, 1961. Accordingly, these Writ
Petitions are dismissed.
Sd/- ZIYAD RAHMAN A.A.
JUDGE
pkk.
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ORDER
Spoke :
2. Immediately upon pronouncement of the judgment,
learned counsel for the petitioners brought to the notice of this Court,
certain practical difficulties arising from the operation of the interim
order. Accordingly, the matter was listed today for addressing those
concerns. After hearing the parties, the following clarification is
issued:
3. In these cases, though the question of law has been
decided in favour of the Revenue, certain practical issues arise
concerning the interim orders passed during the pendency of the writ
petitions. In all matters, interim orders were in force, staying
deduction of amounts towards TDS, and such orders were duly acted
upon by all concerned. Reversing the consequences of non-deduction
of TDS, which occurred pursuant to the interim orders, would be
practically difficult and likely to cause serious legal and procedural
complications. Hence, it is only just and proper that the interim
orders are made absolute in respect of all transactions up to the date
of pronouncement of the judgment., and it is ordered accordingly.
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This would mean that, in respect of all transactions effected,
pursuant to the interim orders passed by this Court in these writ
petitions, no adverse consequences shall follow, from the judgment
now rendered. This order shall form part of the judgment pronounced
by this Court on 25.10.2025.
29.10.2025 Sd/- ZIYAD RAHMAN A.A.
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APPENDIX OF WP(C) 7053/2023
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED BY VELLANGALLUR BRANCH MANAGER OF
THE 4TH RESPONDENT TO THE 1ST PETITIONER
Exhibit P2 A TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY IRINJALAKUDA BRANCH MANAGER OF
THE 4TH RESPONDENT TO THE 2ND PETITION
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APPENDIX OF WP(C) 213/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR NO. 150/2021
DATED 15.11.2021 ISSUED BY THE 4TH
RESPONDENT TO ITS BRANCH MANAGERS.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH
RESPONDENT TO THE 1ST PETITIONER DATED NIL.
Exhibit P3 A TRUE COPY OF THE FORM NO. 15G SUBMITTED
BY THE 1ST PETITIONER TO THE 4TH RESPONDENT
DATED 02.12.2021.
Exhibit P4 A TRUE COPY OF THE LETTER SUBMITTED BY THE
1ST PETITIONER TO THE 4TH RESPONDENT DATED
04.12.2021.
Exhibit P5 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31.05.2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P6 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH
RESPONDENT DATED 17.12.2021 TO 1ST
PETITIONERS.
Exhibit P7 A TRUE COPY OF THE LETTER DATED 09.12.2021
ISSUED BY THE 3RD RESPONDENT TO 4TH
RESPONDENT.
Exhibit P8 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29.05.2017 ISSUED BY CBDT.
Exhibit P9 A TRUE COPY OF THE INTERIM ORDER IN W.P.C
NO. 30263 OF 2021 DATED 23.12.2021.
2025:KER
APPENDIX OF WP(C) 378/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR NO. 150/2021
DATED 15/11/2021 4TH RESPONDENT TO ITS
BRANCH MANAGERS.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH
RESPONDENT TO THE 25TH PETITIONER DATED
NIL.
Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH
RESPONDENT TO THE 1ST PETITIONER DATED
16/12/2021.
Exhibit P4 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31/05/2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P5 A TRUE COPY OF THE LETTER DATED 09/12/2021
ISSUED BY THE 3RD RESPONDENT TO 4TH
RESPONDENT.
Exhibit P6 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29/05/2017 ISSUED BY CBDT.
Exhibit P7 A TRUE COPY OF THE INTERIM ORDER IN WPC
NO.30263/2021 DATED 23/12/2021.
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APPENDIX OF WP(C) 384/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
THIRUR BRANCH MANGER OF 4TH RESPONDENT
DATED 18/11/2021 TO THE 2ND PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH
RESPONDENT TO THE 1ST PETITIONER DATED NIL.
Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANGER MARANCHERY BRANCH OF THE 4TH
RESPONDENT TO THE 19TH PETITIONER DATED
20/12/2021.
Exhibit P4 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31/05/2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P5 A TRUE COPY OF THE LETTER DATED 09/12/2021
ISSUED BY THE 3RD RESPONDENT TO 4TH
RESPONDENT.
Exhibit P6 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29/05/2017 ISSUED BY CBDT.
Exhibit P7 A TRUE COPY OF THE INTERIM ORDER IN WP(C)
NO.30263 OF 2021 DATED 23/12/2021.
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APPENDIX OF WP(C) 383/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
THIRUR BRANCH MANAGER OF 4TH RESPONDENT
DATED 18/11/2021 TO THE 6TH PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH
RESPONDENT TO THE 6TH PETITIONER DATED NIL.
Exhibit P3 A TRUE COPY OF THE FORM NO.15G SUBMITTED BY
THE 6TH PETITIONER TO THE 4TH RESPONDENT
DATED 01/12/2021.
Exhibit P4 A TRUE COPY OF THE LETTER SUBMITTED BY THE
6TH PETITIONER TO THE 4TH RESPONDENT THIRUR
BRANCH MANAGER DATED 01/12/2021.
Exhibit P5 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31/05/2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P6 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH
RESPONDENT THIRUR BRANCH MANAGER TO THE 6TH
PETITIONER DATED 16/12/2021 TO 6TH
PETITIONER.
Exhibit P7 A TRUE COPY OF THE LETTER DATED 09/12/2021
ISSUED BY THE 3RD RESPONDENT TO 4TH
RESPONDENT.
Exhibit P8 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29/05/2017 ISSUED BY CBDT.
Exhibit P9 A TRUE COPY OF THE INTERIM ORDER IN WP(C)
NO.30263 OF 2021 DATED 28/12/2021.
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APPENDIX OF WP(C) 732/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER ISSUED BY THE
MALAPPURAM DISTRICT CO-OPERATIVE TO THE 3RD
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS.
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APPENDIX OF WP(C) 736/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
VYLATHUR BRANCH MANAGER OF 4TH RESPONDENT
DATED 18/11/2021 TO THE 1ST PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY
VYLATHUR BRANCH MANAGER OF THE 4TH
RESPONDENT TO THE 1ST PETITIONER DATED
17/12/2021.
Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012 -13/516
DATED 31/05/2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P4 A TRUE COPY OF THE LETTER DATED 09/12/2021
ISSUED BY THE 3RD RESPONDENT TO 4TH
RESPONDENT.
Exhibit P5 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29/05/2017 ISSUED BY CBDT.
Exhibit P6 A TRUE COPY OF THE INTERIM ORDER IN WPC
NO.213/2022 DATED 05/01/2022.
2025:KER
APPENDIX OF WP(C) 833/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 16.12.2021
ISSUED BY THE MALAPPURAM DISTRICT CO-
OPERATIVE BANK TO THE PETITIONER PROPOSING
TO LEVY TDS FROM DEPOSITS
2025:KER
APPENDIX OF WP(C) 1383/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED ISSUED BY THE
MALAPPURAM DISTRICT CO-OPERATIVE TO THE 1ST
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS.
2025:KER
APPENDIX OF WP(C) 1633/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
KADAMPUZHA BRANCH MANAGER OF 4TH RESPONDENT
DATED 16-12-2021 TO THE 1ST PETITIONER
Exhibit P2 A TRUE COPY OF THE LETTER RB1/2012-13/516
DATED 31-05-2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS
Exhibit P3 A TRUE COPY OF THE LETTER DATED 09-12-2021
ISSUED BY THE 3RD RESPONDENT TO 4TH
RESPONDENT`
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29-05-2017 ISSUED BY CBDT
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER IN WP(C0
NO. 213 OF 2022 DATED 05-01-2022
2025:KER
APPENDIX OF WP(C) 1808/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE REGISTRATION CERTIFICATE
ISSUED BY THE REGISTRAR OF CO-OPERATIVE
SOCIETIES(GENERAL) MALAPPURAM.
Exhibit P2 THE COPY OF THE NOTICE ISSUED TO THE
PETITIONER BY THE DISTRICT CO-OPERATIVE
BANK MALAPPURAM DATED 15.12.2021.
Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC
NO.30811/2021 DATED 28.12.2021.
Exhibit P4 A TRUE COPY OF THE ORDER IN WPC 30263/2021
DATED 23.12.2021.
2025:KER
APPENDIX OF WP(C) 1943/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED BY THE
MALAPPURAM DISTRICT CO-OPERATIVE BANK, TO
THE PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS
2025:KER
APPENDIX OF WP(C) 2208/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED 01.12.2022
ISSUED BY THE MALAPPURAM DISTRICT CO-
OPERATIVE TO THE PETITIONER PROPOSING TO
LEVY TDS FROM DEPOSITS.
2025:KER
APPENDIX OF WP(C) 2780/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
MALAPPURAM BRANCH MANAGER OF 4TH RESPONDENT
DATED 10-01-2022 TO THE PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER RB1/2012-13/516
DATED 31-05-2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS
Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29-05-2017 ISSUED BY CBDT
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER IN WP(C0
NO. 1633 OF 2022 DATED 17-1-2022
2025:KER
APPENDIX OF WP(C) 3734/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED 4.1.2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS.
Exhibit P2 TRUE COPY OF THE LETTER DATED 4.1.2022
ISSUED BY THE 5TH RESPONDENT TO THE 2ND
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS.
Exhibit P3 TRUE COPY OF THE LETTER DATED 4.1.2022
ISSUED BY THE 5TH RESPONDENT TO THE 3RD
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS.
Exhibit P4 TRUE COPY OF THE LETTER DATED 17.3.2020
ISSUED BY THE 6TH RESPONDENT TO THE 4TH
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS.
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED
23.12.2021 IN WP(C) NO.30263/2021.
2025:KER
APPENDIX OF WP(C) 4385/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE REQUEST FILED BY THE
PETITIONER BEFORE THE ASSESSMENT AUTHORITY
UNDER THE NATIONAL FACELESS ASSESSMENT
SCHEME DATED 6.9.2021.
Exhibit P2 A TRUE COPY OF THE COMMUNICATION DATED
7.4.2018 SUBMITTED BY THE PETITIONER.
Exhibit P3 A TRUE COPY OF THE NOTICE DATED 14.1.2022
ISSUED BY THE 1ST RESPONDENT.
Exhibit P4 A TRUE COPY OF THE COMMUNICATION DATED
1.1.2022 ISSUED FROM THE ANCHALUMOOD BRANCH
OF THE 7TH RESPONDENT.
Exhibit P5 A TRUE COPY OF THE JUDGMENT 18.10.2019 IN
WP(C) NO.11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P6 A TRUE COPY OF JUDGMENT DATED 3.12.2019 IN
WP(C) NO.9274 OF 2019 OF THIS HON'BLE
COURT.
2025:KER
APPENDIX OF WP(C) 4442/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE NOTICE
NO.ITBA/COM/F/17/2021-22/1039272931(1)
DATED 01.02.2022 ISSUED BY THE 5TH
RESPONDENT.
RESPONDENT ANNEXURES
Annexure R2 (a) True copy of the Supreme Court decision in
the case of Union of India and others vs.
Nitdip Textile Processors Pvt. Ltd. and
another
Annexure R2 (b) True copy of the judgment the Bombay High
Court decision the case of All India
Central Bank Officers Federation vs. Union
of India.
2025:KER
APPENDIX OF WP(C) 4996/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE NOTICE DTD. NIL ISSUED BY
7TH RESPONDENT.
2025:KER
APPENDIX OF WP(C) 5569/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF AN ILLUSTRATIVE LIST OF
CERTAIN WRIT PETITIONS FILED BEFORE THIS
HON'BLE COURT CHALLENGING THE INCORPORATION
AND APPLICABILITY OF SECTION 194N TO THE
CO-OPERATIVE SOCIETIES.
Exhibit P2 TRUE COPY OF THE ORDER DATED 23.03.2020 IN
WP(C) NO. 9266/2020 PASSED BY THIS HON'BLE
COURT.
Exhibit P3 TRUE COPY OF THE ORDER DATED 28.04.2020 IN
WP(C) NO. WP(C) NO. 169/2020 PASSED BY THIS
HON'BLE COURT.
Exhibit P4 TRUE COPY OF THE ORDER DATED 31.03.2021 IN
WP(C) NO. 8333/2020 PASSED BY THIS HON'BLE
COURT.
Exhibit P5 TRUE COPY OF THE ORDER DATED 12.01.2022 IN
WP(C) NO. 1040/2022 PASSED BY THIS HON'BLE
COURT.
Exhibit P6 TRUE COPY OF THE ORDER DATED 04.02.2022 IN
WP(C) NO. 3864/2022 OF THIS HON'BLE COURT.
Exhibit P7 TRUE COPY OF THE DEMAND NOTICE DATED 31-01-
2022 ISSUED BY THE OFFICE OF THE DEPUTY
COMMISSIONER, INCOME TAX (TDS),
THIRUVANANTHAPURAM TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 5900/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE PDKL/TDS/2021-22
ISSUED BY THE PANIKKOTTUMPADI BRANCH
MANAGER OF 4TH RESPONDENT DATED 16.12.2021
TO THE 1ST PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31.05.2013 ISSUED BY THE CHIEF
GENERAL MANAGER TO RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29.05.2017 ISSUED BY CBDT.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER IN WP(C)
NO. 2780 OF 2022 DATED 27.01.2022.
2025:KER
APPENDIX OF WP(C) 8026/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 8742/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/02/2022 IN
WPC NO.4442/2022.
2025:KER
APPENDIX OF WP(C) 8943/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 6TH
RESPONDENT
Exhibit P5 TRUE COPY OF THE NOTICE DATED 2-03-2023
ISSUED BY THE REGIONAL OFFICE OF 6TH
RESPONDENT TO THE PETITIONER
2025:KER
APPENDIX OF WP(C) 10465/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT,1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442/2022.
2025:KER
APPENDIX OF WP(C) 10480/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
CT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 10498/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE 781/21-22 DATED
24.03.2022 ISSUED BY THE THIRUVANANTHAPURAM
FORT BRANCH MANAGER OF 4TH RESPONDENT TO
THE 1ST PETITIONER.
Exhibit P2 A TRUE COPY OF THE NOTICE 781/21-22 DATED
24.03.2022 ISSUED BY THE THIRUVANANTHAPURAM
FORT BRANCH MANAGER OF 4TH RESPONDENT TO
THE 2ND PETITIONER.
Exhibit P3 A TRUE COPY OF THE RBI/2012-13/516 DATED
31.05.2013 ISSUED BY THE CHIEF GENERAL
MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL
BANKS.
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29.05.2017 ISSUED BY CBDT.
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER IN WPC
NO.2780 OF 2022 DATED 27.01.2022.
2025:KER
APPENDIX OF WP(C) 10692/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDINGS DATED
09/03/2020 ISSUED BY THE 3RD RESPONDENT TO
THE PETITIONER.
Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED
18/03/2020 IN WPC NO.8502/2020 ISSUED BY
THIS HON'BLE COURT.
Exhibit P3 TRUE COPY OF THE PROCEEDING DATED
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 10697/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 25-03-2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 10699/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDINGS 26/03/2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 10705/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 10717/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN
WP(C) NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 10719/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 1ST PETITIONER KEEZHILLAM
SERVICE CO-OP BANK LTD.NO.E3989.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVE ON THE 2ND PETITIONER PERUMBAVOOR
SERVICE CO-OP BANK LTD.NO.802.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 3RD PETITIONER AYYAMPUZHA
SERVICE CO-OPERATIVE BANK LTD.NO.E788.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVE ON THE 4TH PETITIONER CHOWARA SERVICE
CO-OPERATIVE BANK LTD.NO.587.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 5TH PETITIONER
SREEMOOLANAGARA SERVICE CO-OPERATIVE BANK
LTD.NO.4178.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 6TH PETITIONER OKKAL SERVICE
CO-OPERATIVE BANK LTD.NO.E1215.
Exhibit P7 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 7TH KANJOOR SERVICE CO-
OPERATIVE BANK LTD.NO.454.
Exhibit P8 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE 8TH PETITIONER KARAYAMPARAMBU
SERVICE CO-OPERATIVE BANK LTD.NO.1573.
Exhibit P9 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 9TH SERVICE CO-OPERATIVE BANK
LTD.NO.PETITIONER GOVERNMENT SERVANTS
SERVICE CO-OPERATIVE BANK LTD.NO.131.
Exhibit P10 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE 10TH PETITIONER PERUMBAVOOR
KSRTC EMPLOYEES CO OPERATIVE SOCIETY
LTD.NO.E 783.
Exhibit P11 TRUE COPY OF THE INTERIM ORDER IN WPC
NO.18435/20 DATED 18.03.2020.
2025:KER
APPENDIX OF WP(C) 10720/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 10721/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 9.03.2020
ISSUED BY THE 3RD RESPONDENT TO THE
PETITIONER.
Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED
23.03.20220 IN WP(C) NO. 9319 OF 2020
ISSUED BY THIS HON'BLE COURT.
Exhibit P3 TRUE COPY OF THE PROCEEDING 24.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 10722/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDINGS 25.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER
2025:KER
APPENDIX OF WP(C) 10731/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 10735/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 10738/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER 24-03-2022 ISSUED
BY THE 5TH RESPONDENT TO THE 1ST PETITIONER
Exhibit P2 TRUE COPY OF THE LETTER 24-03-2022 ISSUED
BY THE 5TH RESPONDENT TO THE 2ND PETITIONER
Exhibit P3 TRUE COPY OF THE LETTER 24-03-2022 ISSUED
BY THE 5TH RESPONDENT TO THE 3RD PETITIONER
Exhibit P4 TRUE COPY OF THE LETTER 24-03-2022 ISSUED
BY THE 5TH RESPONDENT TO THE 4TH
PETITIONER.
Exhibit P5 TRUE COPY OF THE LETTER 24-03-2022 ISSUED
BY THE 5TH RESPONDENT TO THE 5TH PETITIONER
2025:KER
APPENDIX OF WP(C) 10741/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED 24.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 10744/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 19.02.2022 IN
WPC NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 10747/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO 4442 OF 2022
2025:KER
APPENDIX OF WP(C) 10787/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER 24.03.2922 ISSUED
BY THE 4TH RESPONDENT TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 10799/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 5TH RESPONDENT TO THE 1ST PETITIONER.
Exhibit P2 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 5TH RESPONDENT TO THE 2ND PETITIONER.
Exhibit P3 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 5TH RESPONDENT TO THE 3RD PETITIONER.
Exhibit P4 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 5TH RESPONDENT TO THE 4TH PETITIONER.
Exhibit P5 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 5TH RESPONDENT TO THE 5TH PETITIONER.
Exhibit P6 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 6TH RESPONDENT TO THE 1ST PETITIONER.
Exhibit P7 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 7TH RESPONDENT TO THE 2ND PETITIONER.
Exhibit P8 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 8TH RESPONDENT TO THE 3RD PETITIONER.
Exhibit P9 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY
THE 9TH RESPONDENT TO THE 4TH PETITIONER.
2025:KER
APPENDIX OF WP(C) 10810/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED
7TH RESPONDENT PROPOSING TO LEVY TDS FROM
DEPOSITS.
2025:KER
APPENDIX OF WP(C) 10818/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED
BY 7TH RESPONDENT PROPOSING TO LEVY TDS
FROM DEPOSITS
2025:KER
APPENDIX OF WP(C) 10828/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED BY 7TH RESPONDENT PROPOSING TO LEVY
TDS FROM DEPOSITS.
2025:KER
APPENDIX OF WP(C) 10831/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 25.03.2022 ISSUED
BY 7TH RESPONDENT PROPOSING T LEVY TDS FROM
DEPOSITS.
2025:KER
APPENDIX OF WP(C) 10845/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED
BY 7TH RESPONDENT TO LEVY TDS FROM
DEPOSITS.
2025:KER
APPENDIX OF WP(C) 10855/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 25-03-2022 ISSUED
BY 7TH RESPONDENT PROPOSING TO LEVY TDS
FROM DEPOSITS.
2025:KER
APPENDIX OF WP(C) 10891/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE 25.3.2020 ISSUED BY
THE 5TH RESPONDENT TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 10936/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN
WP(C) NO. 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 6TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 10937/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN
WP(C) NO. 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 10968/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 10967/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
PATTANAKKAD BRANCH MANAGER OF THE 4TH
RESPONDENT DATED 24.03.2022 TO THE 1ST
PETITIONER.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
POOCHAKKAL BRANCH MANAGER OF 4TH RESPONDENT
DATED 24.03.2022 TO THE 9TH PETITIONER.
Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31.05.2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS .
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29.05.2017 ISSUED BY CBDT.
2025:KER
APPENDIX OF WP(C) 11001/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 20220.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT,1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/02/2022 IN
WPC NO.4442/2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11009/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED
BY 7TH RESPONDENT PROPOSING TO LEVY TDS
FROM DEPOSITS.
2025:KER
APPENDIX OF WP(C) 11035/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF NOTICE FORMAT DATED NIL
ISSUED FROM CHIRAYINKEEZHU BRANCH OF THE
6TH RESPONDENT TO PETITIONER.
Exhibit P2 A TRUE COPY OF JUDGMENT DATED 18.10.2019 IN
WP(C) NO.11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A
OF INCOME TAX ACT, 1961, AS APPEARING IN
THE WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
10.2.2022 IN WP(C) NO.4385 OF 2022.
2025:KER
APPENDIX OF WP(C) 11042/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25/3/2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29/5/2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER IN WP(C)
NO.30263/2021 DATED 23/12/2021.
2025:KER
APPENDIX OF WP(C) 11058/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
KOTTAYAM GANDHINAGAR BRANCH MANAGER OF 4TH
RESPONDENT DATED 24-03-2022 TO THE 1ST
PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31-05-2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS
Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29-05-2017 ISSUED BY CBDT
2025:KER
APPENDIX OF WP(C) 11072/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
ANNAMANNADA BRANCH MANAGER OF 4TH
RESPONDENT DATED 24.3.2022 TO THE 1ST
PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY MORNING
BRANCH MANAGER THRISSUR OF THE 4TH
RESPONDENT TO THE 19TH PETITIONER DATED
26.3.2021.
Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31.5.2013 ISSUED BY THE CHIEF GENERAL
MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL
BANKS.
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29.5.2017 ISSUED BY CBDT.
2025:KER
APPENDIX OF WP(C) 11087/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11092/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
KUTTIKAD FARMERS BRANCH MANAGER OF 4TH
RESPONDENT DATED 18-11-2021 TO THE 2ND
PETITIONER
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY
THRISSUR MAIN BRANCH MANAGER OF THE 4TH
RESPONDENT TO THE 6TH PETITIONER DATED 17-
12-2021
Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31-05-2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO 18/2017
DATED 29-05-2017 ISSUED BY CBDT
2025:KER
APPENDIX OF WP(C) 11096/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE NOTICE DATED NIL ISSUED TO
THE 3RD PETITIONER BY THE 4TH RESPONDENT.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED TO THE 4TH PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 26.03.2022
ISSUED TO THE 5TH PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P6 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.05.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P7 TRUE COPY OF THE INTERIM ORDER IN WPC
NO.30263/2021 DATED 23.12.2021.
2025:KER
APPENDIX OF WP(C) 11117/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM KECHERY BRANCH OF THE 6TH
RESPONDENT BANK TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019
IN WP(C)NO.11176 OF 2019 OF THIS HON'BLE
COURT
Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C)NO.4385 OF 2022 PASSED
BY THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11130/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED 24.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE 1ST
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS
Exhibit P2 TRUE COPY OF THE LETTER DATED 24.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE 1ST
PETITIONER PROPOSING TO LEVY TDS FROM
WITHDRAWAL EXCEEDING RS 1 CRORES UNDER
SECTION 194 N OF THE INCOME TAX ACT
Exhibit P3 TRUE COPY OF THE LETTER DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 2ND
PETITIONER PROPOSING TO LEVY TDS FROM
DEPOSITS
Exhibit P4 TRUE COPY OF THE LETTER DATED 01.02.2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER PROPOSING TO LEVY TDS FROM
DESPOSITS MAINTAINED BY THE 2ND PETITIONER
WITH THE 5TH RESPONDENT
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED
03.02.2022 AND ORDER DATED 08.02.2020 IN
W.P(C)NO.3734/2022.
2025:KER
APPENDIX OF WP(C) 11135/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT,2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE NOTICE
NO.ITBA/COM/F/17/2021-22/1039272931(1)
DATED 1.2.2022 ISSUED BY THE 5TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11138/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM KUNNAMKULAM BRANCH OF THE 6TH
RESPONDENT BANK TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019
IN WP(C) NO. 11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED
BY THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11144/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED FROM VAZHAKKULAM BRANCH OF THE 6TH
RESPONDENT BANK TO THE 1ST PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM THE MUVATTUPUZHA RURAL BRANCH
OF THE 6TH RESPONDENT BANK TO THE 2ND
PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM THE MUVATTUPUZHA RURAL BRANCH
OF THE 6TH RESPONDENT BANK TO THE 3RD
PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM THE MULATHURUTHY BRANCH OF THE
6TH RESPONDENT BANK TO THE 4TH PETITIONER.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM THE VYTTILA BRANCH OF THE 6TH
RESPONDENT BANK TO THE 5TH RESPONDENT.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 29.03.2022
ISSUED FROM THE THRIPUNITHURA BRANCH OF THE
6TH RESPONDENT BANK TO THE 6TH PETITIONER.
Exhibit P7 TRUE COPY OF THE JUDGMENT DATED 18.10.2019
IN WP(C) NO. 11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P8 TRUE COPY OF THE EXTRACT OF SECTION 194 OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P9 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED
BY THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11143/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM PATTIKKAD BRANCH OF THE 6TH
RESPONDENT BANK TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019
IN WP(C) NO.11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED
BY THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11149/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED 26/03/2022
ISSUED BY THE 3RD RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11150/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LETTER DATED 25/03/2022
ISSUED BY THE 3RD RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11165/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 28.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11171/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION 24/03/2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11187/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 6TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11184/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE NOTICE NO
ITBA/COM/F/17/2021-22/1039272931(1) DATED
1.2.2022 ISSUED BY THE 5TH RESPONDENT
2025:KER
APPENDIX OF WP(C) 11186/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 1ST PETITIONER
Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 2ND PETITIONER
Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 3RD PETITIONER
Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 4TH PETITIONER
Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 5TH PETITIONER
Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 6TH PETITIONER
Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 7TH PETITIONER
Exhibit P8 TRUE COPY OF THE COMMUNICATION LETTER
24.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 8TH PETITIONER
2025:KER
APPENDIX OF WP(C) 11194/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE NOTICE
NO.ITBA/COM/F/17/2021-22/1039272931(1)
DATED 1/2/2022 ISSUED BY THE 5TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11203/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DATED 27.03.2020 ISSUED BY 1ST RESPONDENT.
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF ORDER DATED 10.02.2022 IN WPC
NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11224/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT 1961.
Exhibit P3 TRUE COPY OF THE NOTICE NO.
ITBA/COM/F/17/2021-22/103927293(1) DATED
1.2.2022 ISSUED BY THE 5TH RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11232/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION 25.3.2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11248/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DATED 27.03.2020 ISSUED BY 1ST RESPONDENT.
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194A OF INCOME TAX ACT,1961.
Exhibit P3 TRUE COPY OF ORDER DATED 10.02.2022 IN WPC
NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11247/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 1ST PETITIONER.
Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER DATE
24.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 2ND PETITIONER.
Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER DATED
24.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 3RD PETITIONER.
Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER DATE
24.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 4TH PETITIONER.
Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER DATE
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 5TH PETITIONER.
Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER DATE
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 6TH PETITIONER.
Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER DATE
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 7TH PETITIONER.
2025:KER
APPENDIX OF WP(C) 11262/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE NOTICE NO.
ITBA/COM/F/17/2021-22/1039272931(1)
2025:KER
APPENDIX OF WP(C) 11260/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER
26.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 11263/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE NOTICE NO.
ITBA/COM/F/17/2021-22/ 1039272931(1) DATED
1.2.2022 ISSUED BY THE 5TH RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11271/2022
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF THE
GAZETTE OF INDIA EXTRAORDINARY DATED
27.3.2020
Exhibit P2 THE TRUE COPY OF THE ORDER IN W.P.(C.) NO
4442 OF 2022 OF THIS HON'BLE COURT DATED
10.02.2022
Exhibit P3 THE TRUE COPY OF THE NOTICE UNDER SECTION
194A ISSUED BY THE 7TH RESPONDENT TO THE
1ST PETITIONER DATED 24.3.2022
Exhibit P4 THE TRUE COPY OF THE NOTICE UNDER SECTION
194A ISSUED BY THE 7TH RESPONDENT TO THE
2ND PETITIONER DATED 24.3.2022
2025:KER
APPENDIX OF WP(C) 11272/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF NOTICE ISSUED BY THE 3RD
RESPONDENT.
Exhibit P2 COPY OF ORDER IN WP(C) NO.1633/2022 OF THIS
HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11273/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE LETTER ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER DATED 25-3-
2022.
2025:KER
APPENDIX OF WP(C) 11286/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 24/3/2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11301/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF LETTER DATED 25.03.2022 ISSUED
BY THE 2ND RESPONDENT TO THE PETITIONER.
Exhibit P2 TRUE COPY OF LETTER DATED 25.03.2022 ISSUED
BY THE RESPONDENT TO THE PETITIONER.
Exhibit P3 TRUE COPY OF LETTER DATED 28.03.2022 ISSUED
BY THE 3RD RESPONDENT TO THE PETITIONER.
Exhibit P4 TRUE COPY OF LETTER DATED 28.03.2022 ISSUED
BY THE 3RD RESPONDENT TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 11309/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE 1ST PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE 2ND PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 3RD PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE 4TH PETITIONER.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE 5TH PETITIONER.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE 6TH PETITIONER.
Exhibit P7 TRUE COPY OF THE NOTICE DATED 26.03.2022
SERVED ON THE 7TH PETITIONER.
Exhibit P8 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE 8TH PETITIONER.
Exhibit P9 A TRUE PHOTOCOPY OF THE ORDER DATED
10.02.2022 IN WP(C) NO. 4442/2022.
2025:KER
APPENDIX OF WP(C) 11316/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMON NOTICE ISSUED BY
THE DISTRICT CO-OPERATIVE BANKS TO ALL THE
PETITIONERS CO-OPERATIVE SOCIETIES DATED
25/03/2022.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
02/11/2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23/12/2021 IN WRIT PETITION (C)
NO.30686/2021.
2025:KER
APPENDIX OF WP(C) 11332/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
W.P.C NO. 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11323/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
KALADY BRANCH MANAGER OF 4TH RESPONDENT
DATED 18/11/2021 TO THE 1ST PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY
PALARIVATTOM BRANCH MANAGER OF THE 4TH
RESPONDENT TO THE 1ST PETITIONER DATED
17/12/2021.
Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31/05/2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29/05/2017 ISSUED BY CBDT.
2025:KER
APPENDIX OF WP(C) 11325/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
MANAGER IN CHARGE OF 4TH RESPONDENT DATED
25.03.2022 TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 11326/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
CHERTHALA BRANCH MANAGER OF 4TH RESPONDENT
DATED 25.03.2022 TO THE 1ST PETITIONER.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
CHERTHALA BRANCH MANAGER OF 4TH RESPONDENT
DATED 25.03.2022 TO THE 6TH PETITIONER.
Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31.05.2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29.05.2017 ISSUED BY CBDT.
2025:KER
APPENDIX OF WP(C) 11327/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT
Exhibit P4 TRUE COPY OF THE CIRCULAR NO 18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES
Exhibit P5 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO 4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11335/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED
25/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 2ND PETITIONER.
Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER
25/03/.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 3RD PETITIONER.
Exhibit P3 TRUE COPY OF THE COMMUNICATION DATED
25/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 4TH PETITIONER.
Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 5TH PETITIONER.
Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER
25/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 6TH PETITIONER.
Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 7TH PETITIONER.
Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 8TH PETITIONER.
Exhibit P8 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 9TH PETITIONER.
Exhibit P9 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 10TH PETITIONER.
Exhibit P10 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 11TH PETITIONER.
Exhibit P11 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 12TH PETITIONER.
Exhibit P12 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 13TH PETITIONER.
Exhibit P13 TRUE COPY OF THE COMMUNICATION LETTER
25/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 14TH PETITIONER.
2025:KER
Exhibit P14 TRUE COPY OF THE COMMUNICATION LETTER
25/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 15TH PETITIONER.
Exhibit P15 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 16TH PETITIONER.
Exhibit P16 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 17TH PETITIONER.
Exhibit P17 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 18TH PETITIONER.
Exhibit P18 TRUE COPY OF THE COMMUNICATION LETTER
25/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 19TH PETITIONER.
Exhibit P19 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 20TH PETITIONER.
Exhibit P20 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 21ST PETITIONER.
Exhibit P21 TRUE COPY OF THE COMMUNICATION LETTER
24/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 22ND PETITIONER.
Exhibit P22 TRUE COPY OF THE COMMUNICATION LETTER
25/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE 23RD PETITIONER.
2025:KER
APPENDIX OF WP(C) 11342/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE CIRCULAR DATED 21.3.2022 ISSUED
BY THE 7TH RESPONDENT
2025:KER
APPENDIX OF WP(C) 11355/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE CIRCULAR DATED 21.03.2022
ISSUED BY THE 7TH RESPONDENT.
Exhibit P2 COPY OF THE LETTER DATED 25.03.2022
SUBMITTED BY THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 11366/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27/3/2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/3/2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25/3/2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE NOTICEDATED 24/3/2022
ISSUED TO THE 3RD PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29/5/2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P6 TRUE COPY OF THE ORDER DATED 10/02/2022 IN
W.P.(C).NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11371/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT
Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 3RD PETITIONER BY THE 4TH
RESPONDENT
Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 4TH PETITIONER BY THE 4TH
RESPONDENT
Exhibit P6 TRUE COPY OF THE CIRCULAR NO.18/20217 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES
Exhibit P7 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11373/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 020 DATED 27.3.2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT
Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11381/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE CIRCULAR DATED 21.03.2022
ISSUED BY THE 7TH RESPONDENT
2025:KER
APPENDIX OF WP(C) 11407/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.03.2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29/05/2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P5 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11415/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED 27.03.2020.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE 1ST PETITIONER DATED 30.03.2022.
Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE 2ND PETITIONER DATED 30.03.2022.
Exhibit P4 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE 3RD PETITIONER DATED 30.03.2022.
Exhibit P5 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE 4TH PETITIONER DATED 30.03.2022.
2025:KER
APPENDIX OF WP(C) 11420/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.03.2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.05.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442/2022.
2025:KER
APPENDIX OF WP(C) 11441/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED TO THE 3RD PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P6 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11440/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE LETTER ISSUED BY R4 TO
RAMAPURAM BRANCH MANAGER DATED 24.3.22.
Exhibit P4 A TRUE PHOTOCOPY OF THE ORDER DATED
10.2.2022 IN WP(C) NO.4442/2022.
2025:KER
APPENDIX OF WP(C) 11450/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11446/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED NIL.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE PETITIONER DATED 30.3.2022.
2025:KER
APPENDIX OF WP(C) 11445/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 3RD PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 4TH PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 5TH PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P7 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 4TH PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P8 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P9 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11458/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF THE FINANCE
ACT 2020
Exhibit P2 TRUE COPY OF THE ORDER DATED 10-02-2022 IN
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25-03-2022 OF
THE 7TH RESPONDENT
2025:KER
APPENDIX OF WP(C) 11467/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE 1ST
PETITIONER ASSOCIATION.
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
Exhibit P5 TRUE COPY OF CIRCULAR NO.,GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11478/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DTED 27.03.2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.05.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE HON'BLE HIGH COURT ORDER
DATED 10.02.2022 IN WPC NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11480/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.03.2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED TO THE 3RD PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.05.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES/.
Exhibit P6 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11489/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DTD 27.03.2020 ISSUED BY 1ST RESPONDENT
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194 A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF ORDER DTD 10.02.2022 IN WPC
NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11487/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 1ST PETITIONER BY THE 4TH
RESPONDENT
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 2ND PETITIONER BY THE 4TH
RESPONDENT
Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 3RD PETITIONER BY THE 4TH
RESPONDENT
Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE 4TH PETITIONER BY THE 4TH
RESPONDENT
Exhibit P6 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P7 TRUE COPY OF THE ORDER DATED 01.02.2022 IN
WPC NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11507/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE 1ST
PETITIONER ASSOCIATION.
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P5 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11530/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27/3/2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/3/2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29/5/2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10/02/2022 IN
WP(C) NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11544/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DTD. 27.03.2022 ISSUED BY 1ST RESPONDENT.
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF ORDER DTD. 10.02.2022 IN
WP(C)NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11555/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11558/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11570/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE 1ST
PETITIONER ASSOCIATION.
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FIANANCE
ACT, 2020.
Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT. 1961
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP (C) NO. 4442 OF 2022.
Exhibit P5 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 5TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11591/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11601/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27/3/2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 26/3/2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED
29/5/2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO. 4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11599/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT
Exhibit P3 TRUE COPY OF THE CIRCULAR NO 18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO 4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11600/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27/3/2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24/3/2020
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE CIRCULAR NO. 18/2017,
DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD
OF DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO. 4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11604/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED FORM PUTHUKKAD BRANCH OF THE 6TH
RESPONDENT BANK TO THE PETITIONER
Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019
IN WPC NO 11176 OF 2019 OF THIS HON'BLE
COURT
Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF
INCOME TAX ACT,1961 AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED
10.2.2022 IN WPC NO 4385 OF 2022 PASSED BY
THIS HON'BLE COURT
2025:KER
APPENDIX OF WP(C) 11607/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DATED 27.3.2020 ISSUED BY 1ST RESPONDENT
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194 A OF INCOME TAX ACT 1961
Exhibit P3 TRUE COPY OF ORDER DATED 10.2.2022 IN WPC
NO 4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11605/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT
Exhibit P3 TRUE COPY OF THE CIRCULAR NO 18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO 4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11609/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 23.03.2022 ISSUED
BY 7TH RESPONDENT PROPOSING TO LEVY TDS
FROM DEPOSITS.
2025:KER
APPENDIX OF WP(C) 10302/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT.
Exhibit P3 TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11616/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE PHOTO COPY OF THE LETTER DATED
25.3.2022 ISSUED BY THE BRANCH MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD.,
PERUMBAVOOR.
Exhibit P2 A TRUE PHOTO COPY OF THE ORDER DATED
10.2.2022 IN WPC NO.4442/2022.
2025:KER
APPENDIX OF WP(C) 11619/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE 25.03.2022 ISSUED
BY THE 4TH RESPONDENT TO THE 1ST
PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE 25.03.2022 ISSUED
BY THE 4TH RESPONDENT TO THE 2ND
PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE 25.03.2022 ISSUED
BY THE 4TH RESPONDENT TO THE 3RD
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11620/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE PHOTO COPY OF THE LETTER DATED
30.3.2022 ISSUED BY THE BRANCH MANAGER,
KERALA STATE CO-OPERATIVE BANK LTD.,
PERUMBAVOOR.
Exhibit P2 A TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442/2022.
2025:KER
APPENDIX OF WP(C) 11621/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11627/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF NOTICE DATED 25.3.2022 BY 5TH
RESPONDENT AS REGARD DEDUCTION OF TDS FROM
INTEREST PAYABLE TO PETITIONER.
2025:KER
APPENDIX OF WP(C) 11646/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE LETTER DATED 25.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11649/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 1ST PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 2ND PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 3RD PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 4TH PETITIONER.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 5TH PETITIONER.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 6TH PETITIONER.
Exhibit P7 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 7TH PETITIONER.
Exhibit P8 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 8TH PETITIONER.
Exhibit P9 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 9TH PETITIONER.
Exhibit P10 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 10TH PETITIONER.
Exhibit P11 TRUE COPY OF THE NOTICE DATED 26/03/2022
SERVED ON THE 11TH PETITIONER.
Exhibit P12 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 12TH PETITIONER.
Exhibit P13 13TH COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 13TH PETITIONER.
Exhibit P14 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 14TH PETITIONER.
Exhibit P15 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 15TH PETITIONER.
Exhibit P16 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 16TH PETITIONER.
Exhibit P17 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 17TH PETITIONER.
Exhibit P18 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 18TH PETITIONER.
Exhibit P19 TRUE COPY OF THE NOTICE DATED 25/03/2022
2025:KER
SERVED ON THE 19TH PETITIONER.
Exhibit P20 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 20TH PETITIONER.
Exhibit P21 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 21ST PETITIONER.
Exhibit P22 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 22ND PETITIONER.
Exhibit P23 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 23RD PETITIONER.
Exhibit P24 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 24TH PETITIONER.
Exhibit P25 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 25TH PETITIONER.
Exhibit P26 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 26TH PETITIONER.
Exhibit P27 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 27TH PETITIONER.
Exhibit P28 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 28TH PETITIONER.
Exhibit P29 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 29TH PETITIONER.
Exhibit P30 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 30TH PETITIONER.
Exhibit P31 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 31TH PETITIONER.
Exhibit P32 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 32ND PETITIONER.
Exhibit P33 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 33RD PETITIONER.
Exhibit P34 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 34TH PETITIONER.
Exhibit P35 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 35TH PETITIONER.
Exhibit P36 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 36TH PETITIONER.
Exhibit P37 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 37TH PETITIONER.
Exhibit P38 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 38TH PETITIONER.
Exhibit P39 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 39TH PETITIONER.
2025:KER
Exhibit P40 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 40TH PETITIONER.
Exhibit P41 TRUE COPY OF THE NOTICE DATED 30/03/2022
SERVED ON THE 41ST PETITIONER.
Exhibit P42 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 42ND PETITIONER.
Exhibit P43 TRUE COPY OF THE NOTICE DATED 25/03/2022
SERVED ON THE 43RD PETITIONER.
Exhibit P44 A TRUE PHOTOCOPY OF THE ORDER DATED
10/02/2022 IN WP(C) NO.442/2022.
2025:KER
APPENDIX OF WP(C) 11654/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
FEROKE BRANCH MANAGER OF 4THR RESPONDENT
DATED 26.03.2022 TO THE PETITIONER
2025:KER
APPENDIX OF WP(C) 11683/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE G.O.(MS).NO. 324/2016/FIN
DATED 15.08.2016 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE G.O.(RT) NO. 6818/2016/
FIN DATED 18.08.2016 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE CIRCULAR, NO.GBT/14/2021-
22 DATED 21.03.2022 ISSUED BY THE 5TH
RESPONDENT, TO ITS REGIONAL MANAGERS.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P7 TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P8 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C) .NO. 4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11679/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE GO(MS) NO 324/2016/FIN
DATED 15.8.2016 ISSUED BY THE 6TH
RESPONDENT
Exhibit P4 TRUE COPY OF THE GO(RT) NO 6818/2016/FIN
DATED 18.8.2016 ISSUED BY THE 6TH
RESPONDENT
Exhibit P5 TRUE COPY OF THE CIRCULAR NO GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 5TH
RESPONDENT TO ITS REGIONAL MANAGERS
Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER
Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED
10.2.022 IN WPC NO 442 OF 2022
2025:KER
APPENDIX OF WP(C) 11684/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF FINANCE ACT,
2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE G.O.(MS). NO.324/2016/FIN
DATED 15.08.2016 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE G.O.(RT) NO. 6818/2016/FIN
DATED 18.08.2016 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE CIRCULAR NO. GBT/14/2021-
22 DATED 21.03.2022 ISSUED BY THE 5TH
RESPONDENT, TO ITS REGIONAL MANAGERS.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN W.P.(C) NO. 4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 11718/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF NOTICE ISSUED BY THE 3RD
RESPONDENT.
Exhibit P2 COPY OF ORDER IN .P.(C) NO.1633/2022 OF
THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11721/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (NO.2) ACT, 2019.
Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (NO.2) BILL DATE 05.07.2019.
Exhibit P3 A TRUE COPY OF THE REPRESENTATION SUBMITTED
BY THE MINISTER FOR CO-OPERATION TO THE
FINANCE MINISTER, GOVERNMENT OF INDIA.
Exhibit P4 A TRUE COPY OF THE LETTER DO
NO.370149/212/2019-T[L DATED 02.01.2020 OF
THE MINISTER OF STATE FOR FINANCE AND
CORPORATE AFFAIRS, GOVERNMENT OF INDIA.
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED
23.03.2020 IN WPC NO.9237 OF 2020 OF THIS
HON'BLE COURT.
Exhibit P6 A TRUE COPY OF THE INTERIM ORDER DATED
29.03.2020 IN WPC NO.10988 OF 2022 OF THIS
HON'BLE COURT.
Exhibit P7 A TRUE COPY OF THE NOTICE DATED 23.03.2022
ISSUED BY THE ANCHALUMOOD EVENING BRANCH OF
THE 6TH RESPONDENT TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 11728/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF NOTICE DATED 30.03.2022
ISSUED UNDER SECTION 194 A (3) (V0 OR THE
INCOME TAX ACT, FROM CHIRAYINKEEZHU BRANCH
OF THE 6TH RESPONDENT TO PETITIONER.
Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WPC
NO.11176 OF 2019 OF THIS HON'BLE COURT.
Exhibit P3 A TRUE COPY OF EXTRACT OF SECTION 194 A OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
30.03.2022 IN WPC NO.11035 OF 2022 OF THIS
HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11727/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27.3.2020
Exhibit P2 TRUE COPY OF THE NOTICE DATED 26.3.2022
ISSUED TO THE PETITIONER BY THE 4TH
RESPONDENT
Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED
29.5.2017 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11740/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DTD 27-03-2020 ISSUED BY 1ST RESPONDENT.
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF ORDER DTD 10-02-2022 IN W.P(C)
NO. 4442 OF 2022
2025:KER
APPENDIX OF WP(C) 11738/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED NIL.
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE 1ST PETITIONER DATED 25/03/2022.
Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE 1ST PETITIONER DATED 25/03/2022.
Exhibit P4 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE 2ND PETITIONER DATED 25/03/2022.
2025:KER
APPENDIX OF WP(C) 11765/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11760/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT. 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WP(C) NO. 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11766/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11768/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER
30.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE PETITIONER
Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER
30.3.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 6TH PETITIONER
2025:KER
APPENDIX OF WP(C) 11772/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF NOTICE DATED 25.3.2022
ISSUED UNDER SECTION 194 A(3) (V) OF THE
INCOME TAX ACT, FROM PETTAH BRANCH OF THE
6TH RESPONDENT TO PETITIONER
Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WPC
NO 11176 OF 2019 OF THIS HON'BLE COURT
Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194 A
OF INCOME TAX ACT, 1961 AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
30.3.2022 IN WPC NO 11035 OF 2022 OF THIS
HON'BLE COURT
2025:KER
APPENDIX OF WP(C) 11776/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED UNDER SECTION 194 A(3) (V) OF THE
INCOME TAX ACT FROM THE POTHENCODE BRANCH
OF THE 6TH RESPONDENT TO PETITIONER.
Exhibit P2 A TRUE COPY OF THE JUDGMENT 18.10.2019 IN
W.P.C NO. 11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A
OF INCOME TAX ACT, 1961, AS APPEARING IN
THE WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C) NO. 4385 OF 2022 OF
THIS HON'BLE COURT.
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED
23.04.2020 IN W.P TMP NO. 107 OF 2020
(PRESENTLY WP(C) NO. 10659 OF 2020) OF THIS
HON'BLE COURT.
Exhibit P6 A TRUE COPY OF THE NOTICE DATED 23.03.2022
ISSUED BY 6TH RESPONDENT TO KIZHUVILAM
SERVICE CO-OPERATIVE BANK, UNDER SECTION
194 N OF THE INCOME TAX ACT.
Exhibit P7 A TRUE COPY OF THE INTERIM ORDER DATED
29.03.2022 IN W.P.C NO. 10988 OF 2022 OF
THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11780/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE REGISTRATION CERTIFICATE
OF THE PETITIONER DATED 22/07/1978.
Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED NIL.
Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE PETITIONER DATED 25/3/2022.
2025:KER
APPENDIX OF WP(C) 11781/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WP(C) NO. 4442 OF 2022.
Exhibit P4 TRUE COPY OF THE CIRCULAR NO. GBT/14/2021-
22 DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 11783/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 25/03/2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11915/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
APPENDIX OF WP(C) 11784/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF NOTICE DATED 30.03.2022
ISSUED UNDER SECTION 194 A (3)(V) OF THE
INCOME TAX ACT, FROM PETTAH BRANCH OF THE
6TH RESPONDENT TO PETITIONER.
Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WP(C)
NO. 11176 OF 2019 OF THIS HON'BLE COURT.
Exhibit P3 A TRUE COPY OF EXTRACT OF SECTION 194A OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
30.03.2022 IN WP(C) NO. 11035 OF 2022 OF
THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 11791/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED
31.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 1ST PETITIONER.
Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER DATED
31.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 2ND PETITIONER.
Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER DATED
31.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 3RD PETITIONER.
Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER DATED
31.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 4TH PETITIONER.
2025:KER
APPENDIX OF WP(C) 11792/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE FIRST
PETITIONER DATED 25.03.2022.
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED TO THE
SECOND PETITIONER DATED 25.03.2022.
Exhibit P1 B TRUE COPY OF THE NOTICE ISSUED TO THE THIRD
PETITIONER DATED 25.03.2022.
Exhibit P1 C TRUE COPY OF THE NOTICE ISSUED TO THE
FOURTH PETITIONER DATED 25.03.2022.
Exhibit P1 D TRUE COPY OF THE NOTICE ISSUED TO THE FIFTH
PETITIONER DATED 25.03.2022.
Exhibit P1 E TRUE COPY OF THE NOTICE ISSUED TO THE SIXTH
PETITIONER DATED 25.03.2022.
Exhibit P1 F TRUE COPY OF THE NOTICE ISSUED TO THE
SEVENTH PETITIONER DATED 25.03.2022.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
02.11.2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED
23.12.2021 IN WIT PETITION(C)
NO.30686/2021.
2025:KER
APPENDIX OF WP(C) 11810/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED BY TO THE
FIRST PETITIONER DATED 24.03.2022.
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY TO THE
SECOND PETITIONER DATED 25.03.2022.
Exhibit P1 B TRUE COPY OF THE NOTICE ISSUED BY TO THE
THIRD PETITIONER DATED 26.03.2022.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
02.11.2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED
23.12.2021 IN WRIT PETITION (C)
NO.30686/2021.
Exhibit P1 C TRUE COPY OF THE NOTICE ISSUED BY THE
FOURTH PETITIONER DATED 30.03.2022
2025:KER
APPENDIX OF WP(C) 11848/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24/03/2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 11851/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION 24.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE 1ST
PETITIONER
Exhibit P2 TRUE COPY OF THE COMMUNICATION 25.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE 2ND
PETITIONER
Exhibit P3 TRUE COPY OF THE COMMUNICATION 25.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE 3RD
PETITIONER
Exhibit P4 TRUE COPY OF THE COMMUNICATION 25.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE 4TH
PETITIONER
2025:KER
APPENDIX OF WP(C) 11870/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 1ST PETITIONER
Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 2ND PETITIONER
Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 3RD PETITIONER
Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 4TH PETITIONER
Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 5TH PETITIONER
Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 6TH PETITIONER
Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 7TH PETITIONER
Exhibit P8 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 8TH PETITIONER
Exhibit P9 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 9TH PETITIONER
Exhibit P10 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 10TH PETITIONER
Exhibit P11 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 11TH PETITIONER
Exhibit P12 TRUE COPY OF THE COMMUNICATION LETTER DATED
25.03.2022 ISSUED BY THE 4TH RESPONDENT TO
THE 12TH PETITIONER
2025:KER
APPENDIX OF WP(C) 11887/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
KOOTHATTUKULAM BRANCH MANAGER OF 4TH
RESPONDENT DATED 26/3/2022 TO THE 1TH
PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31/5/2013 ISSUED BY THE CHIF GENERAL
MANAGER OF RBI TO AL SCHEDULED COMMERCIAL
BANKS.
Exhibit P3 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29/5/2017 ISSUED BY CBDT.
2025:KER
APPENDIX OF WP(C) 11884/2022
PETITIONER EXHIBITS
Exhibit1 EXHIBIT P1: TRUE COPY OF THE RELEVANT PAGES
OF THE GAZETTE OF INDIA EXTRAORDINARY DATED
27.3.2020
Exhibit2 EXHIBIT P2: TRUE COPY OF THE ORDER IN W.P.
(C) NO 4442 OF 2022 OF THIS HON'BLE COURT
DATED 10.02.2022
Exhibit3 EXHIBIT P3: TRUE COPY OF THE NOTICE DATED
24.3.2022 ISSUED TO THE PETITIONER BY THE
7TH RESPONDENT UNDER SECTION 194A
2025:KER
APPENDIX OF WP(C) 11939/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX AC, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 12054/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE
DATED 26TH MAKARAM 1090(1914) ISSUED TO THE
PETITIONER SOCIETY.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/03/2022
NUMBERED AS KSCB/GBT/194N/2021-22 WITH
REGARD TO SECTION 194N OF THE INCOME TAX
ACT, 1961 ISSUED BY 4TH RESPONDENT THROUGH
BRANCH MANAGER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25/03/2022
ISSUED THROUGH THE BRANCH MANAGER, MAIN
BRANCH, ERNAKULAM BY THE 4TH RESPONDENT
WITH RESPECT TO SECTION 194A (3) (V) OF
INCOME TAX ACT, 1961.
Exhibit P4 TRUE COPY OF THE COMMUNICATION ISSUED BY
THE PETITIONER BANK TO THE 4TH RESPONDENT
DATED 31/03/2022.
2025:KER
APPENDIX OF WP(C) 12057/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE
FINANCE ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER IN WP(C) 4442/2022
DATED 10/2/2022.
Exhibit P4 TRUE COPY OF THE CIRCULAR
NO.KSCB/GBT/194N/811(A) 2021-22 DATED
24/3/2022 ISSUED BY THE 6TH RESPONDENT.
2025:KER
APPENDIX OF WP(C) 12065/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE
FINANCE ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER IN WPC 4442/2022
DATED 10.02.2022.
Exhibit P4 TRUE COPY OF THE CIRCULAR
NO.KSCB/GBT/194N/2021-22 DATED 25.03.2022
ISSUED BY THE 6TH RESPONDENT.
Exhibit P5 TRUE COPY OF THE CIRCULAR
NO.KSCB/GBT/194N/802/2021-22 DATED
24.03.2022 ISSUED BY THE 6TH RESPONDENT.
2025:KER
APPENDIX OF WP(C) 12061/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP (C) NO 4442 OF 2022
Exhibit P4 TRUE COPY OF NOTICE DATED 25-03-2022 ISSUED
BY THE 5TH RESPONDENT
2025:KER
APPENDIX OF WP(C) 12076/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM SREEKARYAM BRANCH OF THE 6TH
RESPONDENT BANK TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019
IN WP(C) NO. 11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED
BY THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 12075/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (NO.2) ACT, 2019.
Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (NO.S) BILL DATED 05.07.2019.
Exhibit P3 A TRUE COPY OF THE REPRESENTATION SUBMITTED
BY THE MINISTER FOR CO-OPERATION TO THE
FINANCE, GOVERNMENT OF INDIA.
Exhibit P4 A TRUE COPY OF THE LETTER DO NO.
370149/212/2019-TPL DATED 02.01.2020 OF THE
MINSTER OF STATE FOR FINANCE AND CORPORATE
AFFAIRS, GOVERNMENT OF INDIA.
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED
23.03.2020 IN WP(C) NO. 9237 OF 2020 OF
THIS HON'BLE COURT.
Exhibit P6 A TRUE COPY OF THE INTERIM ORDER DATED
29.03.2022 IN WP(C) NO. 10988 OF 2022 OF
THIS HON'BLE COURT.
Exhibit P7 A TRUE COPY OF THE NOTICE DATED NIL ISSUED
UNDER SECTION 194N OF THE INCOME TAX ACT,
FROM THE ATTINGAL M & E BRANCH OF THE 6TH
RESPONDENT TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 12082/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (NO.2) ACT, 2019.
Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (NO.2) BILL DATED 05.07.2019.
Exhibit P3 A TRUE COPY OF THE REPRESENTATION SUBMITTED
BY THE MINISTER FOR CO-OPERATION TO THE
FINANCE MINISTER, GOVERNMENT OF INDIA.
Exhibit P4 A TRUE COPY OF THE LETTER DO NO.
370149/212/2019-TPL DATED 02.01.2020 OF THE
MINISTER OF STATE FOR FINANCE AND CORPORATE
AFFAIRS, GOVERNMENT OF INDIA.
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED
23.03.2020 IN W.P.C NO. 9237 OF 2020 OF
THIS HON'BLE COURT.
Exhibit P6 A TRUE COPY OF THE INTERIM ORDER DATED
29.03.2022 IN W.P.C NO. 10988 OF 2022 OF
THIS HON'BLE COURT.
Exhibit P7 A TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED UNDER SECTION 194 N OF THE INCOME
TAX ACT, FROM THE ERNAKULAM EVENING BRANCH
OF THE 6TH RESPONDENT TO THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 12086/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DTD. 27.03.2020 ISSUED BY 1ST RESPONDENT.
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF ORDER DTD. 10.02.2022 IN WP(C)
4442 OF 2022.
2025:KER
APPENDIX OF WP(C) 12100/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE
PETITIONER ASSOCIATION
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACTS OF
SECTION 194 A OF INCOME TAX ACT, 1961
Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
Exhibit P5 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATE 21.03.2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
APPENDIX OF WP(C) 12102/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INFORMATION TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
APPENDIX OF WP(C) 12105/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 26/03/2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 12110/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
APPENDIX OF WP(C) 12123/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022
SERVED ON THE PETITIONER.
2025:KER
APPENDIX OF WP(C) 12124/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION 24.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
APPENDIX OF WP(C) 12126/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 2ND
PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 3RD
PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 4TH
PETITIONER.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 5TH
PETITIONER.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 6TH
PETITIONER.
Exhibit P7 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 7TH
PETITIONER.
Exhibit P8 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 8TH
PETITIONER.
2025:KER
APPENDIX OF WP(C) 12145/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE FIRST
PETITIONER DATED 25.03.2022
Exhibit P1A TRUE COPY OF THE NOTICE ISSUED TO THE
SECOND PETITIONER DATED 25.03.2022
Exhibit P1B TRUE COPY OF THE NOTICE ISSUED TO THE THIRD
PETITIONER DATED 25.03.2022
Exhibit P1C TRUE COPY OF THE NOTICE ISSUED TO THE
FOURTH PETITIONER DATED 25.03.2022
Exhibit P1D TRUE COPY OF THE NOTICE ISSUED TO THE FIFTH
PETITIONER DATED 25.03.2022
Exhibit P1E TRUE COPY OF THE NOTICE ISSUED TO THE SIXTH
PETITIONER DATED 25.03.2022
Exhibit P1F TRUE COPY OF THE NOTICE ISSUED TO THE
SEVENTH PETITIONER DATED 25.03.2022
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
02.11.2015
Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED
23.12.2021 IN WRIT PETITION C NO.30686/2021
2025:KER
APPENDIX OF WP(C) 12257/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
THIRUVANANTHAPURAM FORT MAIN BRANCH MANAGER
OF 4TH RESPONDENT DATED 24.03.2022 TO THE
1ST PETITIONER.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
VANCHIYOOR BRANCH MANAGER, OF 4TH
RESPONDENT DATED 25.03.2022 TO THE 2ND
PETITIONER.
2025:KER
APPENDIX OF WP(C) 12263/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF NOTICE DATED 23.3.2022
ISSUED FROM ALUVA (MAIN)BRANCH OF THE 6TH
RESPONDENT TO PETITIONER
Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WPC
NO 11176 OF 2019 OF THIS HON'LE COURT
Exhibit P3 A TRUE COPY OF THE INTERIM ORDER DATED
10.2.2022 IN WPC NO 4385 OF 2022
2025:KER
APPENDIX OF WP(C) 12351/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5 RESPONDENT TO THE IST
PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5 RESPONDENT TO THE 2ND
PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 4TH RESPONDENT TO THE 3RD
PETITIONER.
2025:KER
APPENDIX OF WP(C) 12428/2022
PETITIONER COURT EXHIBITS
EXHIBIT P3 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 6TH RESPONDENT TO PETITIONER.
Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE
DATED 18.09.2002 ISSUED BY THE JOINT
REGISTRAR OF CO-OPERATIVE SOCIETIES
(GENERAL), THIRUVANANTHAPURAM.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO PETITIONER.
2025:KER
APPENDIX OF WP(C) 14068/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE COMMUNICATION 25-03-2022
ISSUED BY THE 4TH RESPONDENT TO THE 1ST
PETITIONER
Exhibit P2 TRUE COPY OF THE COMMUNICATION 25-03-2022
ISSUED BY THE 4TH RESPONDENT TO THE 2ND
PETITIONER.
2025:KER
APPENDIX OF WP(C) 12504/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE LETTER DATED 24/03/2022
ISSUED BY THE PALA BRANCH MANAGER OF THE
4TH RESPONDENT BANK.
Exhibit P4 A TRUE COPY OF THE ORDER DATED 10/02/2022
IN WP(C) NO.4442/2022.
2025:KER
APPENDIX OF WP(C) 12545/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE
DATED 07/06/2005 ISSUED BY THE JOINT
REGISTRAR OF CO-OPERATIVE SOCIETIES
(GENERAL), THIRUVANANTHAPURAM.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/03/2022
ISSUED BY THE 5TH RESPONDENT TO PETITIONER.
2025:KER
APPENDIX OF WP(C) 12635/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT,1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
APPENDIX OF WP(C) 12754/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF NOTICE DATED 25/03/2022
ISSUED UNDER SECTION 194 A(3)(V) OF THE
INCOME TAX ACT, FROM SREEKARIYAM BRANCH OF
THE 6TH RESPONDENT TO PETITITIONER.
Exhibit P2 A TRUE COPY OF JUDGMENT 18/10/2019 IN WP(C)
NO.11176 OF 2019 OF THIS HON'BLE COURT.
Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A
OF INCOME TAX ACT, 1961, AS APPEARING IN
THE WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
01/04/2022 IN WP(C) NO.11784 OF 2022 OF
THIS HON'BLE COURT.
2025:KER
APPENDIX OF WP(C) 12713/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
PARASALA BRANCH MANAGER OF 4TH RESPONDENT
DATED 31.3.2022 TO THE 1ST PETITIONER
2025:KER
APPENDIX OF WP(C) 12744/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (2)ACT, 2019
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE ACT, 2020.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1000
APPENDIX OF WP(C) 12753/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1001
APPENDIX OF WP(C) 12759/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1002
APPENDIX OF WP(C) 13011/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE
PETITIONER ASSOCIATION.
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10/02/2022 IN
WPC NO.4442/2022.
Exhibit P5 TRUE COPY OF THE CIRCULAR NO. GBT/14/2021-
22 DATED 21/03/2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1003
APPENDIX OF WP(C) 13047/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP (C) NO 4442 OF 2022
Exhibit P4 TRUE COPY OF NOTICE DATED 25-03-2022 ISSUED
BY THE 5TH RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1004
APPENDIX OF WP(C) 13114/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE GO(MS) NO.324/2016/FIN
DATED 15/08/2016 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P4 TRUE COPY OF THE GO(RT) NO.6818/2016/FIN.
DATED 18/08/2016 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 25/03/2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER IN RESPECT OF SECTION 194 A(3)
(V).
Exhibit P6 TRUE COPY OF THE NOTICE DATED 25/03/2022
ISSUED BY THE 5TH RESPONDENT TO THE 2ND
PETITIONER IN RESPECT OF SECTION 194 A(3)
(V).
Exhibit P7 TRUE COPY OF THE NOTICE DATED 25/03/2022
ISSUED BY THE 5TH RESPONDENT TO THE 3RD
PETITIONER IN RESPECT OF SECTION 194 A(3)
(V).
Exhibit P8 TRUE COPY OF THE NOTICE DATED 25/03/2022
ISSUED BY THE 5TH RESPONDENT TO THE 4TH
PETITIONER IN RESPECT OF SECTION 194 A(3)
(V).
Exhibit P9 TRUE COPY OF THE INTERIM ORDER DATED
10/02/2022 IN WPC NO.4442/2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1005
APPENDIX OF WP(C) 13112/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
CHALAKUDY BRANCH MANAGER OF 4TH RESPONDENT
DATED 24-03-2022 TO THE 6TH PETITIONER.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
CHELAKKARA BRANCH MANAGER OF 4TH RESPONDENT
DATED 24-03-2022 TO THE 40TH PETITIONER
Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31-05-2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P4 A TRUE COPY OF THE CIRCULAR NO 18/2017
DATED 29-05-2017 ISSUED BY CBDT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1006
APPENDIX OF WP(C) 13171/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1007
APPENDIX OF WP(C) 13184/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR DATED
21.03.2022 ISSUED BY THE 4TH RESPONDENT.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
THIRUVALLA BRANCH MANAGER OF 4TH RESPONDENT
DATED 25.03.2022 TO THE 1ST PETITIONER.
Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE
PATHANAMTHITTA DEPUTY GENERAL MANAGER OF
4TH RESPONDENT DATED 25.03.2022 TO THE 2ND
PETITIONER.
Exhibit P4 A TRUE COPY OF THE NOTICE ISSUED BY THE
PATHANAMTHITTA DEPUTY BRANCH MANAGER OF 4TH
RESPONDENT DATED 25.03.2022 TO THE 3RD
PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1008
APPENDIX OF WP(C) 13339/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE 4TH
RESPONDENT DATED 03.03.2022 TO THE
PETITIONER.
Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31.05.2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS.
Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017
DATED 29.05.2017 ISSUED BY CBDT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1009
APPENDIX OF WP(C) 13303/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE NO. KB/R5/2021-22
DATED 25.03.2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED
02.11.2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23.12.2021 IN WRIT PETITION (C) NO.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1010
APPENDIX OF WP(C) 13305/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE NO KB/R5/2021-22
DATED 25-03-2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED
02-11-2015
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23-12-2021 IN WRIT PETITION (C) NO
2025:KER
W.P(C)No.7053/2023 & Connected cases 1011
APPENDIX OF WP(C) 13318/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR NO.GBT/13/2021-
22 DATED 21.03.2022 ISSUED BY THE 3RD
RESPONDENT TO THE PETITIONER.
Exhibit P2 A TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED BY THE VENMONY BRANCH MANAGER OF THE
3RD RESPONDENT TO THE PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1012
APPENDIX OF WP(C) 13358/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
THIRUVANANTHAPURAM PETTA BRANCH MANAGER OF
4TH RESPONDENT DATED 31/03/2022 TO THE 1ST
PETITIONER.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
KARAMANA BRANCH MANAGER OF 4TH RESPONDENT
DATED 31/03/2022 TO THE 2ND PETITIONER.
Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE
PALAKKAD MAIN BRANCH MANAGER OF 4TH
RESPONDENT DATED 25/03/2022 TO THE 2ND
PETITIONER.
Exhibit P4 A TRUE COPY OF THE NOTICE ISSUED BY THE
THEVARA BRANCH MANAGER OF 4TH RESPONDENT
DATED 25/03/2022 TO THE 2ND PETITIONER.
Exhibit P5 A TRUE COPY OF THE NOTICE ISSUED BY THE
GENERAL MANAGER OF 4TH RESPONDENT DATED
21/03/2022 TO THE PETITIONERS.
Exhibit P6 A TRUE COPY OF THE LETTER NO.RBI/2012-
13/516 DATED 31/05/2013 ISSUED BY RBI CHIEF
GENERAL MANAGER.
Exhibit P7 A TRUE COPY OF THE CIRCULAR NO.18/2017
DATED 29/05/2017 ISSUED BY CBDT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1013
APPENDIX OF WP(C) 13364/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 2ND
PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 3RD
PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 4TH
PETITIONER.
Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 5TH
PETITIONER.
Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 6TH
PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1014
APPENDIX OF WP(C) 13410/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
MUVATTUPUZHA BRANCH MANAGER OF 4TH
RESPONDENT DATED 25.03.2022 TO THE
PETITIONER.
Exhibit P2 A TRUE COPY OF THE CIRCULAR ISSUED BY THE
GENERAL MANAGER OF 4TH RESPONDENT DATED
21.03.2022 TO THE PETITIONER
2025:KER
W.P(C)No.7053/2023 & Connected cases 1015
APPENDIX OF WP(C) 13439/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE FIRST
PETITIONER DATED 25/03/2022.
Exhibit P1(A) TRUE COPY OF THE NOTICE ISSUED TO THE
SECOND PETITIONER DATED 25/03/2022.
Exhibit P1(B) TRUE COPY OF THE NOTICE ISSUED TO THE THIRD
PETITIONER DATED 25/03/2022.
Exhibit P1(C) TRUE COPY OF THE NOTICE ISSUED TO THE
FOURTH PETITIONER DATED 25/03/2022.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED
02/11/2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED
23/12/2021 IN WPC NO.30686/2021.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1016
APPENDIX OF WP(C) 13492/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1017
APPENDIX OF WP(C) 13545/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 1904A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1018
APPENDIX OF WP(C) 13615/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN
WP(C) NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1019
APPENDIX OF WP(C) 13687/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED BY THE
BRANCH MANAGER , KERALA STATE COOPERATIVE
BANK LTD TO THE PETITIONER DATED 24.03.2022
Exhibit P2 TRUE COPY OF THE NOTICE
NO.ITBA/COM/F/17/2021-22/1040408269(1)
DATED 07.03.2022 ISSUED BY 3RD RESPONDENT
TO THE DISTRICT COOPERATIVE BANK THRISSUR
Exhibit P3 TRUE COPY OF THE DEMAND NOTICE ISSUED TO
THE PETITIONER BY 3RD RESPONDENT DATED
16.03.2022
Exhibit P4 TRUE COPY OF THE NOTICE FORM 4TH RESPONDENT
DATED 24.03.2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1020
APPENDIX OF WP(C) 13693/2022
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE NOTICE SERVED ON THE
PETITIONER UNDER SECTION 194 N OF THE
INCOME TAX ACT, 1961 DATED 26.3.2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1021
APPENDIX OF WP(C) 13707/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE CERTIFICATE OF
REGISTRATION IN FORM 3 DATED 27.11.2003
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 5TH
RESPONDENT, TO ITS REGIONAL MANAGERS.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN W.P.(C)NO.4442 OF 2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1022
APPENDIX OF WP(C) 13720/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE CERTIFICATE OF
REGISTRATION IN FORM 3 DATED 03/02/2018.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 5TH
RESPONDENT, TO ITS REGIONAL MANAGERS.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24/03/2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 22/03/2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED
10/02/202 IN WP(C) NO.4442 OF 2012.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1023
APPENDIX OF WP(C) 13741/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1024
APPENDIX OF WP(C) 13746/2022
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT 2020.
Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT 1961.
Exhibit P3 THE TRUE COPY OF THE ORDER DATED 10/02/2022
IN WPC NO. 4442 OF 2022.
Exhibit P4 THE TRUE COPY OF CIRCULAR NO. GBT/14/2021-
22 DATED 21/03/2022 ISSUED BY THE 6TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1025
APPENDIX OF WP(C) 13751/2022
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT 2020.
Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT,1961.
Exhibit P3 THE TRUE COPY OF THE ORDER DATED 10/02/2022
IN WPC NO.4442/2022.
Exhibit P4 THE TRUE COPY OF THE CIRCULAR NO.
GBT/14/2021-22 DATED 21/03/2022 ISSUED BY
THE 6TH RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1026
APPENDIX OF WP(C) 13760/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT. 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WP(C) NO. 4442 OF 2022,
Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1027
APPENDIX OF WP(C) 13761/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1028
APPENDIX OF WP(C) 13781/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE 1ST
PETITIONER
2025:KER
W.P(C)No.7053/2023 & Connected cases 1029
APPENDIX OF WP(C) 13797/2022
PETITIONER EXHIBITS
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OD INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN
W.P(C) NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1030
APPENDIX OF WP(C) 13833/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM VANCHIYOOR BRANCH OF THE 6TH
RESPONDENT BANK TO THE KAITHAMUKKU BRANCH
OF THE PETITIONER
Exhibit P1A TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED FROM PETTAH BRANCH OF THE 6TH
RESPONDENT BANK TO THE KAITHAMUKKU BRANCH
OF THE PETITIONER SOCIETY
Exhibit P1B TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED FROM THIRUMALA BRANCH OF THE 6TH
RESPONDENT BANK TO THE THIRUMALA BRANCH OF
THE PETITIONER SOCIETY
Exhibit P1C TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED FROM VATTIYOORKAVU BRANCH OF THE 6TH
RESPONDENT BANK TO THE VATTIYOORKAVU BRANCH
OF THE PETITIONER SOCIETY
Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019
IN WPC NO. 11176 OF 2019 OF THIS HON'BLE
COURT
Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF
INCOME TAX ACT, 1961, AS APPEARING IN THE
WEBSITE OF INCOME TAX DEPARTMENT
Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED
10.02.022 IN WPC NO.4385 OF 2022 PASSED BY
THIS HON'BLE COURT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1031
APPENDIX OF WP(C) 13891/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE BYELAW OF THE MANAK
WELFARE CO-OPERATIVE SOCIETY LTD.NO. 1262.
Exhibit P2 TRUE COPY OF THE RELEVANT PORTION OF
FINANCE ACT,2020.
Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF THE INCOME TAX ACT 1961.
Exhibit P4 TRUE COPY OF THE ORDER DATED 10/2/2022 IN
W.P(C)NO.4442/2022 BEFORE THE HON'BLE HIGH
COURT OF KERALA, ERNAKULAM
Exhibit P5 TRUE COPY OF THE PROCEEDING DATED
24/3/2022, NO.KSCB/GBT/194N/142/2021-2022
ISSUED BY THE 6TH RESPONDENT.
Exhibit P6 TRUE COPY OF THE PROCEEDING DATED
24/3/2022, N0.143/2021-2022 ISSUED BY THE
6TH RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1032
APPENDIX OF WP(C) 13895/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT,1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
Exhibit P4 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1033
APPENDIX OF WP(C) 13902/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022
SERVED ON THE PETITIONER
Exhibit P2 TRUE COPY OF THE INTERIM ORDER OF STAY IN
WP(C)NO.12123 OF 2022 DATED 04.04.2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1034
APPENDIX OF WP(C) 13903/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1035
APPENDIX OF WP(C) 13912/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.3.2022
SERVED ON THE PETITIONER.
Exhibit P2 TRUE COPY OF THE INTERIM STAY ORDER IN
WP(C) NO.12123 OF 2022 DATED 4.4.2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1036
APPENDIX OF WP(C) 13939/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF NOTICE DATED 25.03.2022
ISSUED FROM KUNNAMKULAM BRANCH OF THE 6TH
RESPONDENT TO PETITIONER.
Exhibit P2 A TRUE COPY OF JUDGMENT 18-10-2019 IN
WP(C)NO.11176 OF 2019 OF THIS HON'BLE
COURT.
Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194 A
OF THE INCOME TAX ACT, 1961, AS APPEARING
IN THE WEBSITE OF INCOME TAX DEPARTMENT
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN WP(C)NO.4385 OF 2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1037
APPENDIX OF WP(C) 13940/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1038
APPENDIX OF WP(C) 13996/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN
WPC NO.4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT /14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1039
APPENDIX OF WP(C) 14006/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE CERTIFICATE OF
REGISTRATION IN FORM 3 IN DATED 12.12.2013
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/202122
DATED 21.03.2022 ISSUED BY THE 5TH
RESPONDENT, TO ITS REGIONAL MANAGERS.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P4 TRUE THE NOTICE DATED 07.04.2022 ISSUED BY
THE 5TH RESPONDENT
Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN W.P.(C).NO.4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1040
APPENDIX OF WP(C) 14010/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED 27.3.2022
Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE PETITIONER DATED 25.03.2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1041
APPENDIX OF WP(C) 14014/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE CERTIFICATE OF
REGISTRATION IN FORM 3 IN DATED 22.9.2017.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22
DATED 21.3.2022 ISSUED BY THE 5TH
RESPONDENT, TO ITS REGIONAL MANAGERS.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P4 A TRUE COPY OF THE NOTICE DATED 7.4.2022
ISSUED BY THE 5TH RESPONDENT.
Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED
10.2.2022 IN WP(C) NO.4442 OF 2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1042
APPENDIX OF WP(C) 14017/2022
PETITIONER EXHIBITS
Exhibit P1 & P1(A) TRUE COPY OF THE NOTICES NO.KB/R5/2021-22
DATED 25.3.2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
2.11.2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23.12.2021 IN WRIT PETITION (C)
NO.30686/2021.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1043
APPENDIX OF WP(C) 14047/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE
ATHANI BRANCH MANAGER OF 4TH RESPONDENT
DATED 21.03.2022.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
ATHANI BRANCH MANAGER OF 4TH RESPONDENT
DATED 30.03.2022 TO THE IST PETITIONER.
Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE
MUNDOOR BRANCH MANAGER OF 4TH RESPONDENT
DATED 25.03.2022 TO THE 2ND PETITIONER.
Exhibit P4 A TRUE COPY OF THE NOTICE ISSUED BY THE
THRISSUR WEST FORT BRANCH MANAGER OF 4TH
RESPONDENT DATED 30.03.2022 TO THE 3RD
PETITIONER.
Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED
07.04.2022 IN WPC NO. 13380 /2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1044
APPENDIX OF WP(C) 14061/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE
DATED 30.04.1994 ISSUED BY THE JOINT
REGISTRAR OF CO-OPERATIVE SOCIETIES
(GENERAL), THIRUVANANTHAPURAM.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE DATED 28.03.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1045
APPENDIX OF WP(C) 14119/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE
DATED 09.05.2005 ISSUED BY THE JOINT
REGISTRAR OF CO OPERATIVE SOCIETIES
(GENERAL), THIRUVANANTHAPURAM.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY THE 5TH RESPONDENT TO PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1046
APPENDIX OF WP(C) 14122/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE
GENERAL MANAGER OF 4TH RESPONDENT DATED
21.03.2022.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
IRINJALAKUDA BRANCH MANAGER OF 4TH
RESPONDENT DATED 24.03.2022 TO THE 1ST
PETITIONER.
Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE
KUNNAMKULAM BRANCH MANAGER OF 4TH
RESPONDENT DATED 08.04.2022 TO THE 2ND
PETITIONER.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 07.
04.2022 IN WPC NO.13380/2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1047
APPENDIX OF WP(C) 14151/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE NO. KB/R5/2021-22
DATED 25.03.2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
02.11.2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23.12.2021 IN WRIT PETITIONER(C) NO.
30686/2021.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1048
APPENDIX OF WP(C) 14162/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE
FINANCE ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER IN W.P(C0NO.
4442/2022 DATED 10-02-2022
Exhibit P4 TRUE COPY OF THE CIRCULAR NO
KSCB/GBT/194N/2021-22 DATED 06-04-2022
ISSUED BY THE 5TH RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1049
APPENDIX OF WP(C) 14195/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN
WPC NO. 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1050
APPENDIX OF WP(C) 14341/2022
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 .
Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 THE TRUE COPY OF THE ORDER DATED 10/02/2022
IN W.P.(C) NO. 4442 OF 2022.
Exhibit P4 THE TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P5 THE TRUE COPY OF LETTER NO.3762/21-22 DATED
25/02/2022 ISSUED BY THE 6TH RESPONDENT TO
THE 1ST PETITIONER.
Exhibit P6 THE TRUE COPY OF LETTER NO. 3767/21-22
ISSUED BY THE 6TH RESPONDENT TO THE 3RD
PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1051
APPENDIX OF WP(C) 14425/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE 03-04-2022 ISSUED
BY THE 4TH RESPONDENT TO THE PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1052
APPENDIX OF WP(C) 14559/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE
NO.KSCB/GBT/194N/008/2021-22 DATED
30/3/2022 TO THE 1ST PETITIONER.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 30/3/2022
ISSUED BY THE 6TH RESPONDENT TO THE 1ST
PETITIONER.
Exhibit P3 TRUE COPY OF THE NOTICE
NO.KSCB/GBT/194N/2021-22 DATED 10/4/2022 TO
THE 2ND PETITIONER.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 10/4/2022
ISSUED BY THE 6TH RESPONDENT TO THE 2ND
PETITIONER.
Exhibit P5 TRUE COPY OF THE NOTICE
NO.KSCB/GBT/194N/2021-22 DATED 5/4/2022 TO
THE 3RD PETITIONER.
Exhibit P6 TRUE COPY OF THE NOTICE
NO.KSCB/GBT/194N/2021-22 DATED 20/3/2022 TO
THE 4TH PETITIONER.
Exhibit P7 TRUE COPY OF THE NOTICE DATED 20/3/2022
ISSUED BY THE 6TH RESPONDENT TO THE 4TH
PETITIONER.
Exhibit P8 TRUE COPY OF THE NOTICE
NO.KSCB/GBT/194N/2021-22 DATED 24/3/2022 TO
THE 5TH PETITIONER.
Exhibit P9 TRUE COPY OF THE NOTICE DATED 24/3/2022
ISSUED BY THE 6TH RESPONDENT TO THE 5TH
PETITIONER.
Exhibit P10 TRUE COPY OF THE JUDGMENT IN WP(C) N
O.11176/2019 DATED 18/10/2019.
Exhibit P11 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P12 TRUE COPY OF THE ORDER IN WP(C)
NO.4442/2022 DATED 10/2/2022.
Exhibit P13 TRUE COPY OF THE ORDER IN WP(C)
NO.8333/2020 DATED 22/11/2021.
Exhibit P14 TRUE COPY OF THE ORDER IN WP(C)
NO.10988/2022 DATED 29/3/2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1053
APPENDIX OF WP(C) 14687/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE NO. KB/R5/2021-22
DATED 25.03.2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P1 (A) TRUE COPY OF THE NOTICE NO. KB/R5/2021-22
DATED 25.03.2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED
02.11.2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23.12.2021 IN WRIT PETITION (C) NO.
30686/2021.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1054
APPENDIX OF WP(C) 14715/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A F INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WPC NO 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED ISSUED BY THE 4TH RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1055
APPENDIX OF WP(C) 14806/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
MALAPPURAM BRANCH MANAGER OF 4TH RESPONDENT
DATED 21.11.2021 TO THE PETITIONER
Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31.05.2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS
Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC
NO.13380 OF 2022 DATED 07.04.2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1056
APPENDIX OF WP(C) 14807/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE
GENERAL RESPONDENT DATED 21.03.2022.
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
ATHANI BRANCH MANAGER OF 4TH RESPONDENT
DATED 24/03/2022 TO THE 1ST PETITIONER.
Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE
PATTIKKAD BRANCH MANAGER OF 4TH RESPONDENT
DATED 25/03/2022 TO THE 2ND PETITIONER.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
07/04/2022 IN WPC NO.13380/2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1057
APPENDIX OF WP(C) 14811/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE
GAZETTE OF INDIA NOTIFICATION DATED
01.08.2019.
Exhibit P2 TRUE COPY OF THE PRESS RELEASE DATED
20.08.2019 ISSUED BY THE CENTRAL BOARD OF
DIRECT TAXES.
Exhibit P3 TRUE COPY OF THE RELEVANT PORTIONS OF THE
FINANCE ACT, 2020 AS NOTIFIED BY GAZETTE OF
INDIA NOTIFICATION DATED 27.03.20.
Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED BY RESPONDENT NO. 6.
Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED
11/4/2020 IN WPC NO. 9438 OF 2020 WPC NO.
TMP- 38/2020.
Exhibit P6 TRUE COPY OF THE INTERIM ORDER IN WPC NO.
11813/2022 DATED 1/4/2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1058
APPENDIX OF WP(C) 14832/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED 27.03.2020 .
Exhibit P2 A TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 A TRUE COPY OF THE ORDER DATED 10.02.2022
IN W.P.(C).NO.4442/2022.
Exhibit P4 A TRUE COPY OF THE NOTICE 16.04.2022 ISSUED
IN RESPECT OF THE FIRST PETITIONER.
Exhibit P5 A TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED IN RESPECT OF THE SECOND PETITIONER.
Exhibit P6 A TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED IN RESPECT OF THE THIRD PETITIONER.
Exhibit P7 A TRUE COPY OF THE NOTICE DATED 31.03.2022
ISSUED IN RESPECT OF THE FOURTH PETITIONER.
Exhibit P8 A TRUE COPY OF THE NOTICE DATED 30.03.2022
ISSUED IN RESPECT OF THE FIFTH PETITIONER.
Exhibit P9 A TRUE COPY OF THE NOTICE DATED 25.03.2022
ISSUED IN RESPECT OF THE SIXTH PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1059
APPENDIX OF WP(C) 14838/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED NIL.
Exhibit P2 TRUE COPY OF THE LETTER ISSUED BY THE
BRANCH MANAGER OF THE 4TH RESPONDENT BANK
TO THE PETITIONER DATED 31.03.2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1060
APPENDIX OF WP(C) 14857/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE
PETITIONER CO OPERATIVE SOCIETIES DATED
25/3/2022 BY THE 6TH RESPONDENT BANK
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
02.11.2015.
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23.12.2021 IN WRIT PETITION(C)NO.30686/2021
OF THE HIGH COURT OF KERALA
Exhibit P4 TRUE COPY OF THE INTERIM ORDER PASSEDB
DATED 01/04/2022 IN WRIT PETITION
(C)NO.11792/2022 OF THE HIGH COURT OF
KERALA.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1061
APPENDIX OF WP(C) 14944/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE NO KB/R5/2021-22
DATED 25-03-2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P1A TRUE COPY OF THE NOTICE NO KB/R5/2021-22
DATED 25-03-2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER.
Exhibit P2 TRUE COPY OF THE CIRCULAR NO 18/2015 DATED
02-11-2015
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23-12-2021 IN WRIT PETITION (C) NO 23-12-
2021 IN WRIT PETITION(C) NO 30686/2021
2025:KER
W.P(C)No.7053/2023 & Connected cases 1062
APPENDIX OF WP(C) 14960/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE NO.KB/R5/2021-22
DATED 25-03-2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER
Exhibit P1(A) TRUE COPY OF THE NOTICE NO.KB/R5/2021-22
DATED 25.03.2022 ISSUED BY THE 6TH
RESPONDENT TO THE PETITIONER
Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED
02.11.2015
Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED
23.12.2021 IN WRIT
PETITION(C)NO.30686/2021.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1063
APPENDIX OF WP(C) 15027/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 25.04.2022
ISSUED BY THE 4TH RESPONDENT TO THE
PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1064
APPENDIX OF WP(C) 15066/2022
PETITIONER EXHIBITS
Exhibit EXHIBIT P1:- TRUE COPY OF THE RELEVANT
PAGES OF FINANCE ACT, 2020 DATED 27/3/2020
Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED
25/3/2022 ISSUED TO THE 1ST PETITIONER BY
THE 4TH RESPONDENT.
Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 2ND PETITIONER BY
THE 4TH RESPONDENT.
Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED
25/3/2022 ISSUED TO THE 3RD PETITIONER BY
THE 4TH RESPONDENT.
Exhibit5 EXHIBIT-P5: TRUE COPY OF THE NOTICE DATED
25/3/2022 ISSUED TO THE 4TH PETITIONER BY
THE 4TH RESPONDENT.
Exhibit6 EXHIBIT-P6: TRUE COPY OF THE NOTICE DATED
25/3/2022 ISSUED TO THE 5TH PETITIONER BY
THE 4TH RESPONDENT.
Exhibit7 EXHIBIT-P7:TRUE COPY OF THE CIRCULAR
NO.18/2017 DATED 29/5/2017 ISSUED BY THE
CENTRAL BOARD OF DIRECT TAXES.
Exhibit8 EXHIBIT P8:- TRUE COPY OF THE ORDER DATED
10.02.2022 IN W.P.(C).NO. 4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1065
APPENDIX OF WP(C) 15438/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 .
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1066
APPENDIX OF WP(C) 15480/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR NO GBT 14/2021-
22 ISSUED BY THE GENERAL MANAGER OF 4TH
RESPONDENT DATED 21-03-2022
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
ALAPPUZHA BRANCH MANAGER OF 4TH RESPONDENT
DATED 28-03-2022 TO THE PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1067
APPENDIX OF WP(C) 15487/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
MALAPPURAM BRANCH MANAGER OF 4TH RESPONDENT
DATED 03-04-2019
Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516
DATED 31-05-2013 ISSUED BY THE CHIEF
GENERAL MANAGER OF RBI TO ALL SCHEDULED
COMMERCIAL BANKS
Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC NO
13380 OF 2022 DATED 07-04-2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1068
APPENDIX OF WP(C) 15518/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE
GENERAL MANAGER OF 4TH .
Exhibit P2 A TRUE COPY OF THE CIRCULAR ISSUED BY THE
GENERAL MANAGER OF 4TH RESPONDENT DATED
21.03.2022.
Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE
KODUNGALLUR BRANCH MANAGER OF 4TH
RESPONDENT DATED 25.03.2022 TO THE 1ST
PETITIONER.
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED
07.04.2022 IN W.P.C NO. 13380/2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1069
APPENDIX OF WP(C) 15596/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT,2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT.1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WP(C) NO. 4442 OF 2022.
Exhibit P4 TRUE COPY CIRCULAR NO GBT/14/2021 -22 DATED
21.03.2022 ISSUED BY THE 4TH RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1070
APPENDIX OF WP(C) 15598/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE (2) ACT, 2019.
Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF THE
FINANCE ACT, 2020.
Exhibit P3 TRUE COPY OF THE ORDER DATED 06.04.2022 IN
WPC NO.12744 OF 2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1071
APPENDIX OF WP(C) 15789/2022
PETITIONER EXHIBITS
Exhibit1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT
PAGES OF FINANCE ACT, 2020 DATED 27/3/2020
Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 1ST PETITIONER BY
THE 4TH RESPONDENT.
Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 2ND PETITIONER BY
THE 4TH RESPONDENT.
Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 3RD PETITIONER BY
THE 4TH RESPONDENT.
Exhibit5 EXHIBIT-P5: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 4TH PETITIONER BY
THE 4TH RESPONDENT.
Exhibit6 EXHIBIT-P6:TRUE COPY OF THE CIRCULAR
NO.18/2017 DATED 29/5/2017 ISSUED BY THE
CENTRAL BOARD OF DIRECT TAXES.
Exhibit7 EXHIBIT P7:- TRUE COPY OF THE ORDER DATED
10.02.2022 IN W.P.(C).NO. 4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1072
APPENDIX OF WP(C) 15825/2022
PETITIONER EXHIBITS
Exhibit1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT
PAGES OF FINANCE ACT, 2020 DATED 27/3/2020
Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED
25/3/2022 ISSUED TO THE 1ST PETITIONER BY
THE 4TH RESPONDENT.
Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED
25/3/2022 ISSUED TO THE 2ND PETITIONER BY
THE 4TH RESPONDENT.
Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED
25/3/2022 ISSUED TO THE 3RD PETITIONER BY
THE 4TH RESPONDENT.
Exhibit5 EXHIBIT-P5: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 4TH PETITIONER BY
THE 4TH RESPONDENT.
Exhibit6 EXHIBIT P6:- TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 5TH PETITIONER BY
THE 4TH RESPONDENT.
Exhibit7 EXHIBIT-P7:TRUE COPY OF THE CIRCULAR
NO.18/2017 DATED 29/5/2017 ISSUED BY THE
CENTRAL BOARD OF DIRECT TAXES.
Exhibit8 EXHIBIT P8:- TRUE COPY OF THE ORDER DATED
10.02.2022 IN W.P.(C).NO. 4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1073
APPENDIX OF WP(C) 15828/2022
PETITIONER EXHIBITS
Exhibit1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT
PAGES OF FINANCE ACT, 2020 DATED 27/3/2020
Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 1ST PETITIONER BY
THE 4TH RESPONDENT.
Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 2ND PETITIONER BY
THE 4TH RESPONDENT.
Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED
24/3/2022 ISSUED TO THE 3RD PETITIONER BY
THE 4TH RESPONDENT.
Exhibit5 EXHIBIT-P5:TRUE COPY OF THE CIRCULAR
NO.18/2017 DATED 29/5/2017 ISSUED BY THE
CENTRAL BOARD OF DIRECT TAXES.
Exhibit6 EXHIBIT P6:- TRUE COPY OF THE ORDER DATED
10.02.2022 IN W.P.(C).NO. 4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1074
APPENDIX OF WP(C) 15874/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF NOTICE DATED 30.3.2022 ISSUED BY
THE 4TH RESPONDENT TO 1ST PETITIONER UNDER
SECTION 194 A (3) (V) OF INCOME TAX ACT
Exhibit P2 COPY OF THE NOTICE ISSUED BY THE 4TH
RESPONDENT TO THE 1ST PETITIONER UNDER
SECTION 194 N OF INCOME TAX ACT DATED
30.3.2022
Exhibit P3 COPY OF JUDGMENT OF THIS HON'BLE COURT
DATED 18-10-2019 IN W.P.(C) NO. 11176 OF
Exhibit P4 COPY OF THE SECTION 194 A OF INCOME TAX
ACT, 1961, AS APPEARING IN THE WEBSITE OF
INCOME TAX DEPARTMENT
Exhibit P5 COPY OF THE INTERIM ORDER OF THIS
HONOURABLE COURT DATED 10.2.2022 IN W.P.(C)
NO. 4385 OF 2022
Exhibit P6 COPY OF THE INTERIM ORDER OF THIS
HONOURABLE COURT DATED 22.11.2021 IN W.P.
(C) NO. 25368 OF 2019
Exhibit P7 COPY OF THE INTERIM ORDER OF THIS HON'BLE
COURT DATED 01-12-2021 IN WP(C) NO. 27301
OF 2021
Exhibit P8 COPY OF THE ORDER OF THIS HONOURABLE COURT
DATED 10.2.2022 IN W.P.(C) NO. 4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1075
APPENDIX OF WP(C) 16074/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1076
APPENDIX OF WP(C) 16243/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE NOTICE DATED 26.03.2022 ISSUED
BY 7TH RESPONDENT PROPOSING TO LEVY TDS
FROM DESPOSITS
2025:KER
W.P(C)No.7053/2023 & Connected cases 1077
APPENDIX OF WP(C) 16321/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF LETTER DATED 09.03.2020 FROM THE
6TH RESPONDENT TO THE PETITIONER
Exhibit P2 COPY OF LETTER DATED 23.09.2019 FROM THE
4TH RESPONDENT TO THE BRANCH MANAGER OF THE
PATHANAMTHITTA DISTRCIT CO-OPERATIVE BANK
Exhibit P3 COPY OF LETTER DATED 10.03.2020 RECEIVED
PETITIONER FROM THE SIXTH RESPONDENT
Exhibit P 4 COPY OF THE RELEVANT PAGES (AMENDED
PROVISIONS IN SECTION 194A(3) OF INCOME TAX
ACT )OF THE FINANCE ACT,2020
Exhibit P5 COPY OF THE INTERIM ORDER DATED 10.2.2022
PASSED IN W.P.(C) NO.4442 OF 2022
Exhibit P 6 COPY OF INTERIM ORDER DATED 19.04.22 PASSED
IN W.P.C.NO. 14162 OF 2022
Exhibit P7 COPY OF NOTICE NO. 3718 /21-22 DATED
25.3.2022 ISSUED BY THE 6TH RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1078
APPENDIX OF WP(C) 16459/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020
Exhibit P2 A TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 A TRUE COPY OF THE ORDER DATED 10.02.2022
IN WRIT PETITION (C) NO. 4442 OF 2022
Exhibit P4 A TRUE COPY OF CIRCULAR NO GBT/14/202122
DATED 21.03.2022 ISSUED BY THE 6TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1079
APPENDIX OF WP(C) 16598/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
W.P.C NO. 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1080
APPENDIX OF WP(C) 16805/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT,1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP (C) NO 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1081
APPENDIX OF WP(C) 16881/2022
PETITIONER EXHIBITS
Exhibit1 COPY OF NOTICE NO.3699/21-22 DATED
25.3.2022 ISSUED BY RESPONDENT NO.6
Exhibit2 COPY OF ORDER DATED 10.2.2022 IN W.P.C.4442
OF 2022
Exhibit3 COPY OF ORDER DT.19.4.2022 IN W.P.C.14162
OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1082
APPENDIX OF WP(C) 17323/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10/02/2022 IN
WP(C) NO.4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21/03/2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1083
APPENDIX OF WP(C) 17707/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN
WPC NO.4442OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1084
APPENDIX OF WP(C) 17716/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP O NO 4442 OF 2022.
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1085
APPENDIX OF WP(C) 17796/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE INTERIM ORDER IN WP(C)
NO.10818/2022 DATED 29/03/2022 PASSED BY
THIS HON'BLE HIGH COURT OF KERALA.
Exhibit P2 TRUE COPY OF THE NOTICE DATED 24/03/2022
ISSUED TO THE PETITIONER BY THE 7TH
RESPONDENT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1086
APPENDIX OF WP(C) 18070/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDING 11.04.2022
ISSUED BY THE 5TH RESPONDENT TO THE
PETITIONER.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1087
APPENDIX OF WP(C) 18489/2022
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020.
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961, FROM
THE WEB SITE OF INCOME TAX DEPARTMENT.
Exhibit P3 THE TRUE COPY OF THE G.O.(MS) NO
324/2016/FIN DATED 15-8-2016.
Exhibit P4 THE TRUE COPY OF THE G.O.(RT)NO.
6818/2016/FIN DATED 18-8-2016.
Exhibit P5 THE TRUE COPY OF THE CIRCULAR WITH
NO.GBT /14/2021-22, DATED 21.03.2022 ISSUED
BY THE 5TH RESPONDENT, TO ITS REGIONAL
MANAGERS.
Exhibit P6 THE TRUE COPY OF NOTICE DATED 30-032022
ISSUED BY THE 8TH RESPONDENT TO PETITIONER.
Exhibit P7 THE TRUE COPY OF THE INTERIM ORDER DATED
10.02.2022 IN W.P.(C).NO. 4442/2022.
Exhibit P8 THE TRUE COPY OF INTERIM ORDER DATED 01-04-
2022 IN WPC NO 11684/2022 .
Exhibit P9 THE TRUE COPY OF INTERIM ORDER DATED 04-04-
2022 IN WPC NO 12098/2022.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1088
APPENDIX OF WP(C) 18690/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1089
APPENDIX OF WP(C) 20028/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION
DTD 27.03.2022 ISSUED BY 1ST RESPONDENT
Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION
194A OF INCOME TAX ACT, 1961.
Exhibit P3 TRUE COPY OF ORDER DTD 10.02.2022 IN WPC
NO.4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1090
APPENDIX OF WP(C) 21287/2022
PETITIONER EXHIBITS
Exhibit P1 THE COPY OF NOTICE ISSUED TO THE PETITIONER
BY THE KERALA STATE COOPERATIVE BANK,
CHALAKUDDY BRANCH DATED 28.03.2020
Exhibit P2 COPY OF INTERIM ORDER DATED 28.12.2021 IN
WPC 30811 OF 2021
Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC
30263 OF 2021 DATED 23.12.2021
2025:KER
W.P(C)No.7053/2023 & Connected cases 1091
APPENDIX OF WP(C) 21639/2022
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED 27.3.2020
Exhibit P2 A TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194 A OF INCOME TAX ACT, 1961.
Exhibit P3 A TRUE COPY OF THE ORDER DATED 10.2.2022 IN
Exhibit P4 A TRUE COPY OF THE NOTICE 25.3.2022 TO THE
PETITIONER
2025:KER
W.P(C)No.7053/2023 & Connected cases 1092
APPENDIX OF WP(C) 21922/2022
PETITIONER EXHIBITS
Exhibit-P1 A TRUE COPY OF NOTICE DATED 01-06-2022
ISSUED UNDER SECTION 194 A(3)(V) OF THE
INCOME TAX ACT, FROM KUNNICODE BRANCH OF
THE 6TH RESPONDENT TO PETITIONER.
Exhibit-P2 A TRUE COPY OF JUDGMENT 18-10-2019 IN WP(C)
NO.11176 OF 2019 OF THIS HON'BLE COURT.
Exhibit-P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A
OF INCOME TAX ACT, 1961, AS APPEARING IN
THE WEBSITE OF INCOME TAX DEPARTMENT.
Exhibit-P4 A TRUE COPY OF THE INTERIM ORDER DATED 01-
04-2022 IN WP(C) NO.11784 OF 2022 OF THIS
HON'BLE COURT.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1093
APPENDIX OF WP(C) 22198/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1094
APPENDIX OF WP(C) 22339/2022
PETITIONER EXHIBITS
Exhibit P1 EXHIBIT-P1 A TRUE COPY OF THE CIRCULAR
NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED
BY THE GENERAL MANAGER OF 4TH RESPONDENT
DATED 21.03.2022
Exhibit P2 EXHIBIT P2: A TRUE COPY OF THE NOTICE
ISSUED BY THE PAVARATTY BRANCH MANAGER OF
4TH RESPONDENT TO THE 1ST PETITIONER DATED
19.04.2022
Exhibit P3 EXHIBIT P3: A TRUE COPY OF THE NOTICE
ISSUED BY THE PAVARATTY BRANCH MANAGER OF
4TH RESPONDENT TO THE 2ND PETITIONER DATED
19.04.2022
Exhibit P4 EXHIBIT P4: A TRUE COPY OF THE INTERIM
ORDER DATED 07.04.2022 IN WP C
2025:KER
W.P(C)No.7053/2023 & Connected cases 1095
APPENDIX OF WP(C) 22917/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1096
APPENDIX OF WP(C) 23239/2022
PETITIONER EXHIBITS
Exhibit P1 EXHIBIT-P1 A TRUE COPY OF THE NOTICE ISSUED
BY THE VADAKKEKAD BRANCH MANAGER OF 4TH
RESPONDENT DATED 25.03.2022 TO THE
PETITIONER
Exhibit P2 EXHIBIT-P2 - A TRUE COPY OF THE INTERIM
ORDER DATED 07.04.2022 IN WP C
2025:KER
W.P(C)No.7053/2023 & Connected cases 1097
APPENDIX OF WP(C) 23780/2022
PETITIONER EXHIBITS
Exhibit P 1 THE TRUE COPY OF THE RECEIPT DATED
26/10/2013 BEARING NO. 0388193 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P 1(a) THE TRUE COPY OF THE RECEIPT DATED
28/10/2013 BEARING NO. 0388229 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P 1(b) THE TRUE COPY OF THE RECEIPT DATED
28/10/2013 BEARING NO. 0388230 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P 1(c) THE TRUE COPY OF THE RECEIPT DATED
05/11/2013 BEARING NO. 0388345 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P (d) THE TRUE COPY OF THE RECEIPT DATED
07/11/2013 BEARING NO. 0388366 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P (e) THE TRUE COPY OF THE RECEIPT DATED
07/11/2013 BEARING NO. 0388367 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(f) THE TRUE COPY OF THE RECEIPT DATED
07/11/2013 BEARING NO. 0388368 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(g) THE TRUE COPY OF THE RECEIPT DATED
11/11/2013 BEARING NO. 0388416 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(h) THE TRUE COPY OF THE RECEIPT DATED
18/11/2017 BEARING NO. 0556475 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(i) THE TRUE COPY OF THE RECEIPT DATED
16/07/2020 BEARING NO. 0518720 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(j) THE TRUE COPY OF THE RECEIPT DATED
16/06/2020 BEARING NO. 0518604 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(k) THE TRUE COPY OF THE RECEIPT DATED
16/06/2020 BEARING NO. 0518603 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(L) THE TRUE COPY OF THE RECEIPT DATED
16/06/2020 BEARING NO. 0518602 ISSUED BY
THE FOURTH RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1098
Exhibit P(m) THE TRUE COPY OF THE RECEIPT DATED
17/08/2020 BEARING NO. 0518951 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P(n) THE TRUE COPY OF THE RECEIPT DATED
10/02/2021 BEARING NO. 0519828 ISSUED BY
THE FOURTH RESPONDENT
Exhibit P 2 THE TRUE COPY OF THE LETTER DATED
30/03/2022 ISSUED BY THE 4TH RESPONDENT TO
THE PETITIONER
Exhibit P 3 TRUE COPY OF THE CIRCULAR NO: 18/2015 DATED
02.11.2015
Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED
23.12.2021 IN WRIT PETITION(C) NO.
30686/2021 ON THE FILES OF THIS HON'BLE
COURT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1099
APPENDIX OF WP(C) 24428/2022
PETITIONER EXHIBITS
Exhibit P1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT
PAGES OF FINANCE ACT, 2020 DATED 27/3/2020
Exhibit P2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED
21/3/2022 ISSUED TO THE PETITIONER BY THE
4TH RESPONDENT.
Exhibit P3 EXHIBIT-P3: TRUE COPY OF THE CIRCULAR
NO.18/2017 DATED 29/5/2017 ISSUED BY THE
CENTRAL BOARD OF DIRECT TAXES.
Exhibit P4 EXHIBIT P4:- TRUE COPY OF THE ORDER DATED
10.02.2022 IN W.P.(C).NO. 4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1100
APPENDIX OF WP(C) 24538/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE
PASS BOOK OF THE PETITIONER WITH THE 3RD
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1101
APPENDIX OF WP(C) 25354/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP (C) NO.4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1102
APPENDIX OF WP(C) 26364/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1103
APPENDIX OF WP(C) 26636/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1104
APPENDIX OF WP(C) 25894/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P 2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P 4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 6TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1105
APPENDIX OF WP(C) 27682/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27-03-2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit 3 TRUE COPY OF THE ORDER DATED 13-1-2023 IN
WP © NO 1100 OF 2023
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1106
APPENDIX OF WP(C) 31251/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit3 TRUE COPY OF THE NOTICE DATED 30-07-2022
ISSUED BY THE 6TH RESPONDENT TO THE 1ST
PETITIONER
Exhibit P4 TRUE COPY OF THE NOTICE DATED 30-07-2022
ISSUED BY THE 6TH RESPONDENT TO THE 2ND
PETITIONER
Exhibit P5 TRUE COPY OF THE NOTICE DATED 30-07-2022
ISSUED BY THE 6TH RESPONDENT TO THE 3RD
PETITIONER
Exhibit P6 TRUE COPY OF THE NOTICE DATED 30-07-2022
ISSUED BY THE 6TH RESPONDENT TO THE 4TH
PETITIONER
Exhibit P7 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1107
APPENDIX OF WP(C) 32055/2022
PETITIONER EXHIBITS
Exhibit P1 COPY OF NOTICE DATED 26.3.2022 ISSUED BY
THE 4TH RESPONDENT TO 1ST PETITIONER UNDER
SECTION 194 A (3) (V) OF INCOME TAX ACT
Exhibit P2 COPY OF NOTICE DATED 26.3.2022 ISSUED BY
THE 4TH RESPONDENT TO 2ND PETITIONER UNDER
SECTION 194 A (3) (V) OF INCOME TAX ACT
Exhibit P3 COPY OF NOTICE DATED 25.3.2022 ISSUED BY
THE 4TH RESPONDENT TO 3RD PETITIONER UNDER
SECTION 194 A (3) (V) OF INCOME TAX ACT
Exhibit P4 COPY OF THE NOTICE ISSUED BY THE 4TH
RESPONDENT TO THE 1ST PETITIONER UNDER
SECTION 194 N OF INCOME TAX ACT DATED
26.3.2022
Exhibit P5 COPY OF THE NOTICE ISSUED BY THE 4TH
RESPONDENT TO THE 2ND PETITIONER UNDER
SECTION 194 N OF INCOME TAX ACT DATED
26.3.2022
Exhibit P6 COPY OF THE NOTICE ISSUED BY THE 4TH
RESPONDENT TO THE 3RD PETITIONER UNDER
SECTION 194 N OF INCOME TAX ACT DATED
26.3.2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1108
APPENDIX OF WP(C) 32580/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020 DATED 27-03-2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 01-4-2022 IN
WP © NO 11765 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
Exhibit P4(a) TRUE COPY OF THE ENGLISH TRANSLATION OF EXT
P4 CIRCULAR DATED 21-03-2022
Exhibit P5 TRUE COPY OF THE NOTICE DATED 30-09-2023
ISSUED BY THE 4TH RESPONDENT
Exhibit P5(a) TRUE COPY OF THE ENGLISH TRANSLATION OF EXT
P5 NOTICE DATED 30-09-2023
2025:KER
W.P(C)No.7053/2023 & Connected cases 1109
APPENDIX OF WP(C) 30686/2021
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE DATED 6/12/2021
ISSUED BY THE MALAPPURAM DISTRICT CO-
OPERATIVE BANK, TO THE PETITIONER PROPOSING
TO LEVY TDS FROM DEPOSITS.
2025:KER
W.P(C)No.7053/2023 & Connected cases 1110
APPENDIX OF WP(C) 36670/2023
PETITIONER EXHIBITS
Exhibit-P1 TRUE COPY OF THE CIRCULAR GBT/14/2021-22
DATED 21.03.2022 ISSUED BY THE 2ND
RESPONDENT ALONG WITH ENGLISH TRANSLATION
2025:KER
W.P(C)No.7053/2023 & Connected cases 1111
APPENDIX OF WP(C) 41031/2022
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE
ACT, 2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN
WP © NO 4442 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1112
APPENDIX OF WP(C) 9194/2024
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE WITH ENGLISH
TRANSLATION, ISSUED BY THE 4TH RESPONDENT
DATED NIL TO PETITIONER
Exhibit P2 A TRUE COPY OF THE INTERIM ORDER IN WP
( C ) NO. 15487 OF 2022 DATED 06.05.2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1113
APPENDIX OF WP(C) 41499/2022
PETITIONER EXHIBITS
EXHIBIT P1 TRUE COPY OF THE FINANCE ACT 2020.
EXHIBIT-P2 TRUE COPY OF THE LETTER DATED 30.7.2022
ISDSDUED BY THE 4TH RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1114
APPENDIX OF WP(C) 43925/2023
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 PUBLISHED IN
EXTRAORDINARY GAZETTE NO. 20 DATED
27/03/2020
Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961 .
Exhibit P3 THE TRUE COPY OF THE ORDER DATED 05/04/2022
IN W.P.(C) NO. 12351 OF 2022 OF THIS
HON'BLE COURT .
Exhibit P4 THE TRUE COPY OF THE ORDER DATED 08/04/2022
IN W.P.(C) NO. 13751 OF 2022 OF THIS
HON'BLE COURT .
Exhibit P5 THE TRUE COPY OF CIRCULAR NO. GBT/14/2021-
22 DATED 21/03/2022 ISSUED BY THE 6TH
RESPONDENT ALONG WITH THE ENGLISH
TRANSLATION
Exhibit P6 THE TRUE COPY OF THE LETTER NO. KSCB/RO-
ALP/BANKING/10/5933/2023-24 DATED
09/11/2023 ISSUED BY THE 7TH RESPONDENT TO
THE PETITIONERS ALONG WITH THE ENGLISH
TRANSLATION
2025:KER
W.P(C)No.7053/2023 & Connected cases 1115
APPENDIX OF WP(C) 27670/2024
PETITIONER EXHIBITS
Exhibit P1 . TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020 DATED 27-03-2020
Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961
Exhibit P3 TRUE COPY OF THE ORDER DATED 19-12-2022 IN
WP © NO 41031 OF 2022
Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22
DATED 21-03-2022 ISSUED BY THE 4TH
RESPONDENT
2025:KER
W.P(C)No.7053/2023 & Connected cases 1116
APPENDIX OF WP(C) 31176/2024
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE
PANIKKOTTUMPADI BRANCH MANAGER OF 4TH
RESPONDENT DATED 27.06.2024 TO THE 1ST
PETITIONER
Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE
PANIKKOTTUMPADI BRANCH MANAGER OF 4TH
RESPONDENT DATED 27.06.2024 TO THE 2ND
PETITIONER
Exhibit P3 A TRUE COPY OF THE RELEVANT PAGES OF THE
BANK PASSBOOK OF THE 1ST PETITIONER ISSUED
BY THE ERSTWHILE MDC BANK DATED 20.03.2021
SHOWING TDS DEDUCTION ON 06.12.2023 AND
30.03.2024
Exhibit P4 A TRUE COPY OF THE INTERIM ORDER IN WP
( C ) NO. 15487 OF 2022 DATED 06.05.2022
2025:KER
W.P(C)No.7053/2023 & Connected cases 1117
APPENDIX OF WP(C) 37399/2024
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF
FINANCE ACT, 2020
Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF
SECTION 194A OF INCOME TAX ACT, 1961.
Exhibit P3 THE TRUE COPY OF THE ORDER DATED 05/04/2022
IN W.P.(C) NO. 12351 OF 2022 OF THIS
HONOURABLE COURT
Exhibit P4 THE TRUE COPY OF THE ORDER DATED 08/04/2022
IN W.P.(C) NO. 13751 OF 2022 OF THIS
HONOURABLE COURT.
Exhibit P5 THE TRUE COPY OF CIRCULAR NO. GBT/14/2021-
22 DATED 21/03/2022 ISSUED BY THE 6TH
RESPONDENT.
Exhibit P6 THE TRUE COPY OF THE LETTER NO. KSCB/RO-
ALP/BANKING/10/5933/2023-24 DATED
09/11/2023 ISSUED BY THE 7TH RESPONDENT TO
THE PETITIONERS.
