Kerala High Court
Mar Gregorious Memorial Muthoot ... vs The Commissioner Of Income Tax on 22 October, 2025
Author: A.Muhamed Mustaque
Bench: A.Muhamed Mustaque
1
ITA No.60 of 2020 and con.cases 2025:KER:78571
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE
&
THE HONOURABLE MR. JUSTICE HARISANKAR V. MENON
WEDNESDAY, THE 22ND DAY OF OCTOBER 2025 / 30TH ASWINA, 1947
ITA NO. 60 OF 2020
AGAINST THE ORDER DATED 21.02.2019 IN ITA NO.69/COCH/2018 OF
I.T.A.TRIBUNAL, COCHIN BENCH
--------
APPELLANT/RESPONDENT IN ITA:
MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE,
KOZHENCHERRY, PATHANAMTHITTA-689 641, REP. BY ITS
MANAGING PARTNER, MR.GEORGE ALEXANDER MUTHOOT.
BY ADVS.
SHRI.M.GOPIKRISHNAN NAMBIAR
SHRI.K.JOHN MATHAI
SRI.JOSON MANAVALAN
SRI.KURYAN THOMAS
SHRI.PAULOSE C. ABRAHAM
SHRI.RAJA KANNAN
RESPONDENT/APPELLANT IN ITA:
THE COMMISSIONER OF INCOME TAX,
C.R.BUILDING, I.S.PRESS ROAD, KOCHI-682 018.
BY SRI.JOSE JOSEPH, STANDING COUNSEL
THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 22.10.2025, ALONG
WITH ITA NO.69/2020 AND CONNECTED CASES, THE COURT ON THE SAME DAY
DELIVERED THE FOLLOWING:
2
ITA No.60 of 2020 and con.cases 2025:KER:78571
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE
&
THE HONOURABLE MR. JUSTICE HARISANKAR V. MENON
WEDNESDAY, THE 22ND DAY OF OCTOBER 2025 / 30TH ASWINA, 1947
ITA NO. 69 OF 2020
AGAINST THE ORDER DATED 21.02.2019 IN ITA NO.70/COCH/2018 OF
I.T.A.TRIBUNAL, COCHIN BENCH
-----
APPELLANT/APPELLANT IN ITA:
MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE
KOZHENCHERRY, PATHANAMTHITTA-689 641, REPRESENTED BY ITS
MANAGING PARTNER, MR. GEORGE ALEXANDER MUTHOOT.
BY ADVS.
SHRI.M.GOPIKRISHNAN NAMBIAR
SHRI.K.JOHN MATHAI
SRI.JOSON MANAVALAN
SRI.KURYAN THOMAS
SHRI.PAULOSE C. ABRAHAM
SHRI.RAJA KANNAN
RESPONDENT/APPELLANT IN ITA:
THE COMMISSIONER OF INCOME TAX,
C.R.BUILDING, I.S PRESS ROAD,
KOCHI-682 018.
BY SRI.JOSE JOSEPH, STANDING COUNSEL
THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 22.10.2025, ALONG
WITH ITA NO.60/2020 AND CONNECTED CASES, THE COURT ON THE SAME DAY
DELIVERED THE FOLLOWING:
3
ITA No.60 of 2020 and con.cases 2025:KER:78571
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE
&
THE HONOURABLE MR. JUSTICE HARISANKAR V. MENON
WEDNESDAY, THE 22ND DAY OF OCTOBER 2025 / 30TH ASWINA, 1947
ITA NO. 72 OF 2020
AGAINST THE ORDER DATED 21.02.2019 IN ITA NO.72/COCH/2018 OF
I.T.A.TRIBUNAL, COCHIN BENCH
-----
APPELLANT/APPELLANT IN ITA:
MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE
KOZHENCHERRY, PATHANAMTHITTA 689 641, REPRESENTED BY IS
MANAGING PARTNER, MR. GEORGE ALEXANDER MUTHOOT.
BY ADVS.
SHRI.M.GOPIKRISHNAN NAMBIAR
SHRI.K.JOHN MATHAI
SRI.JOSON MANAVALAN
SRI.KURYAN THOMAS
SHRI.PAULOSE C. ABRAHAM
SHRI.RAJA KANNAN
RESPONDENT/APPELLANT IN ITA:
THE COMMISSIONER OF INCOME TAX,
C.R. BUILDING, I.S PRESS ROAD, KOCHI 682 018.
BY SRI.JOSE JOSEPH, STANDING COUNSEL
THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 22.10.2025, ALONG
WITH ITA.60/2020 AND CONNECTED CASES, THE COURT ON THE SAME DAY
DELIVERED THE FOLLOWING:
4
ITA No.60 of 2020 and con.cases 2025:KER:78571
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE
&
THE HONOURABLE MR. JUSTICE HARISANKAR V. MENON
WEDNESDAY, THE 22ND DAY OF OCTOBER 2025 / 30TH ASWINA, 1947
ITA NO. 70 OF 2020
AGAINST THE ORDER DATED 21.02.2019 IN ITA NO.71/COCH/2018 OF
I.T.A. TRIBUNAL, COCHIN BENCH
------
APPELLANT/RESPONDENT IN ITA:
MAR GREGORIOUS MEMORIAL MUTHOOT MEDICAL CENTRE,
KOZHENCHERRY, PATHANAMTHITTA-689641, REPRESENTED BY ITS
MANAGING PARTNER, MR.GEORGE ALEXANDER MUTHOOT.
BY ADVS.
SHRI.M.GOPIKRISHNAN NAMBIAR
SHRI.K.JOHN MATHAI
SRI.JOSON MANAVALAN
SRI.KURYAN THOMAS
SHRI.PAULOSE C. ABRAHAM
SHRI.RAJA KANNAN
RESPONDENT/APPELLANT IN ITA:
THE COMMISSIONER OF INCOME TAX,
C.R. BUILDING, I.S. PRESS ROAD, KOCHI-682018.
BY SRI.JOSE JOSEPH, STANDING COUNSEL
THIS INCOME TAX APPEAL HAVING BEEN FINALLY HEARD ON 22.10.2025, ALONG
WITH ITA NO.60/2020 AND CONNECTED CASES, THE COURT ON THE SAME DAY
DELIVERED THE FOLLOWING:
5
ITA No.60 of 2020 and con.cases 2025:KER:78571
JUDGMENT
[ITA Nos.60, 69, 72 and 70 of 2020]
Harisankar V. Menon, J.
The appellant, in these appeals, is a partnership firm
engaged in running a hospital, having obtained registration
under the provisions of the Income Tax Act, 1961 (hereinafter
referred to as the 'Act'). The appeals have been filed
challenging the order dated 21.02.2019 in I.T.A No.69 to
72/COCH/2018 of the Income Tax Appellate Tribunal, Cochin
Bench. For ease of reference, I.T.A.No.60 of 2020 with
respect to the assessment year 2002-03 is treated as the lead
case, and the fact situation is noticed therefrom.
2. The appellant, admittedly, had been receiving
deposits from the public, paying interest on such deposits.
The deposit received by the appellant firm was being
withdrawn by its partners and utilizing the said withdrawals
in their business ventures. The partners were paying interest
on such advances to the appellant firm. The assessment for
the year 2002-03 was completed under Section 143(3) read
ITA No.60 of 2020 and con.cases 2025:KER:78571
with Section 147 of the Act by the Assessing Officer, holding
that:
i. The interest charged by the appellant from the
partners on advances made by them requires to be
estimated at 20%.
ii. The interest paid by the appellant to the public is not
to be allowed as business expenditure of the
appellant.
The first appellate authority in the appeal filed at the instance
of the appellant-assessee, by Annexure G order in I.T.A
No.T36/CAT(A)/KTM/2015-16 dated 20.08.2013, found that
the activities noticed as above cannot be considered as the
business income of the appellant and requires to be
considered only as "income from other sources" on account
of which, the interest income received from the partners has
to be assessed accordingly. The revenue preferred appeals
against the afore finding before the Appellate Tribunal. The
Tribunal, by impugned order, made reference to the clauses
contained in the partnership deed and found as under:
ITA No.60 of 2020 and con.cases 2025:KER:78571
"8.1. As seen from the object clause of the partnership deed,
these activities carried on by the assessee are not prohibited by
the partnership deed. In other words, these activities are allied
activities relating to the business of the assessee. Further,
looking into the transactions carried on by the assessee with its
partners by advancing funds, it can be inferred that these
transactions have been entered into by the assessee with a profit
motive. The assessee had intention thereby to carry on business
with its partners. It can be said that these transactions were
entered into only for the purpose of carrying on business which
is ancillary activities carried on by the assessee to earn profit
from these transactions from its partners. The word "business"
has not been defined in the taxing statute, yet it postulates the
existence of certain elements in the activity of an assessee which
would invest it with the character of business. According to well
established interpretation of word business as found in taxing
statutes, it is the sense of an occupation or profession which
occupies the time, attention and labour of a person normally with
the object of making profit. To record an activity as business,
there must be of course dealing either actually continued or
contemplated to be continued with a profit motive and not for
support.
8.2. In our opinion, whether or not a person carried on business
in a particular way must depend upon volume, frequency,
continuity and regularity of transactions and the transactions
must ordinarily be entered into with a profit motive. Such motive
must pervade the whole series of transactions effected by the
person in the course of his activity. To infer from a course of
transaction that is intended thereby to carry on business
ordinarily the characteristic of volume, frequency and regularity
of transaction indicating the intention to continue the activity of
carrying on the transactions must exist. Looking into the facts of
ITA No.60 of 2020 and con.cases 2025:KER:78571
the present case, it can easily be said that the assessee entered
into the transactions with its partners with a profit motive.
Therefore, the only inference which can be drawn from this case
is that the income earned by the assessee by advancing funds
to its partners falls under the head 'income from business' and
not under the head 'income from other sources'. In our
considered opinion, after considering the cumulative effect of the
facts and circumstances of the case, the CIT(A) is not justified
in treating the income arising out of these transactions by the
assessee as 'income from other sources'. Accordingly, we
reverse the order of the CIT(A) for all the assessment years and
it is to be assessed as income from business. Consequently, the
claim of deduction of payment of interest is squarely covered
against the assessee by the judgment of the Jurisdictional High
Court in the case of Arun Thomas cited supra wherein it was held
that accepting deposits is prohibited by law and paying interest
on deposits is that of expenditure on an activity prohibited by
law. Therefore, any interest paid on deposits is not to be allowed
as deduction u/s. 36(1)(iii) of the Act.
8.3. Without prejudice to the above, even agreeing with the
argument of the Ld. DR that the income earned by the assessee
from lending funds to its partners is to be assessed as business
income of the assessee, interest payment is not allowable in view
of the judgment of the Jurisdictional High Court in the case of
Arun Thomas, cited supra and in our opinion, that judgment was
stayed by the Supreme Court in Writ Petition No. 33432-
31437/2017 dated 24/11/2017 and the said judgment of the
Jurisdictional High Court is not in operation as of now.
8.4. In view of the above order of the Supreme Court in Writ
Petition No. 33432-31437/2017 dated 24/11/2017, we are
inclined to remit the issue to the file of the CIT(A) to decide
ITA No.60 of 2020 and con.cases 2025:KER:78571
afresh after the final judgment of the Supreme Court in the case
of Arun Thomas cited supra."
It is challenging this order, that the appellant-assessee has
instituted the captioned appeals.
3. Heard Sri.Raja Kannan, the learned counsel for the
appellant-assessee, and Sri.Jose Joseph, the learned
Standing Counsel for the respondent.
4. Sri.Raja Kannan, the learned counsel, seeks to rely
on the findings contained in the judgment of this Court in I.T.A
No.136 of 2011 dated 24.09.2018 (Annexure I), to contend
that the observations made by the Tribunal were against the
findings rendered by the Division Bench of this Court. Sri.Jose
Joseph would, however, contend that the Tribunal, being the
fact-finding authority, was justified in considering the issue
with reference to the partnership deed and the various
clauses contained therein.
5. We have considered the rival submissions and the
connected records.
6. The activity carried out by the appellant-assessee,
as noticed earlier, is not in dispute. A reading of the
ITA No.60 of 2020 and con.cases 2025:KER:78571
assessment order for the year 2002-03 would also show that
it is with reference to the completion of the assessment for
the year 2006-07 that the assessment for the year 2002-03
was sought to be reopened. In the assessment year 2006-
07, the expenditure with respect to the interest paid to the
public was disallowed, along with estimating the interest
received by the appellant-assessee from its partners. The
Tribunal found that the expenditure was an allowable
deduction. The finding with respect to the computation of
interest was also deleted by the Tribunal. The revenue
preferred appeals before this Court. By Annexure I judgment,
the deletion of the computation of interest was sustained,
though for different reasons. As regards the expenditure
claimed by the assessee, this Court held as under:
"7. The investment made by the partners in the sister concerns
and the income derived by way of more interest, than that they
were paying to the assessee-firms could be assessed at the
hands of the sister concerns or in the hands of the partners on
which we need not give any specific opinion since that is not the
subject matter of the present appeals. With respect to the
present appeals and the assessments made on the assessee-
firms, we are of the definite opinion that there could be no
addition made under Section 145. We uphold the order of the
ITA No.60 of 2020 and con.cases 2025:KER:78571
Tribunal insofar as deleting the additions made. We answer the
first question of law to the extent that it speaks of interference
of substantive additions made to the interest income received
by the assessee-firms, in favour of the assessee and against the
Revenue. We uphold the findings of the Tribunal on that aspect.
8. The questions of law raised in addition to the interference
with the substantive additions made on best judgment are with
respect to the dis-allowance of expenditure under Section
37(1). There cannot be any dispute, insofar as allowance of
expenditure can be allowed only in the case of a business carried
on by the assessee. The respondent-assessees herein are
respectively a Multi Speciality Hospital and Real Estate firm,
which do not have any business of financing. The advance taken
by the partners also cannot be said to be a business, since as
we have noticed, the assessee does not carry on any business
on finance and the partners by their very status were entitled
to avail such advances from the firm.
9. We garner support from the decision of the Hon'ble Supreme
Court in Madhav Prasad Jatia v. C.I.T. [(1979) 118 ITR 200].
Therein the assessee carried on business in money lending and
had various sources of income from shares, properties etc. It
promised to donate Rs. 10 lakhs to set up an engineering
college. The assessee also debited its capital account and
corresponding credit was given to the account of the college. It
then availed of an overdraft facility of Rs.5.5 lakhs from an
account maintained for business purposes and disbursed it to
the college. The balance was treated as a loan availed by the
assessee from the College. The assessee paid interest to the
bank on the overdraft and to the college for the loan, which
were claimed as business expenditure. The overdraft facility was
held to be not availed for business purposes and the so called
loan from the college was held to be the assessees' own funds.
Here too there was no business in finance carried on by the
ITA No.60 of 2020 and con.cases 2025:KER:78571
Firms and the partners had merely taken advances from the
firm, the application of which was not the concern of the firm."
Thus, we note that as regards the interest income obtained
by the appellant-assessee, with reference to the nature of the
activity noticed in paragraph 7 of the judgment, the Division
Bench of this Court categorically found that the activity was
"not in the nature of business by the assessee" and hence,
the assessee could not claim the business expenditure.
7. We are of the opinion that the Tribunal went wrong
when it rendered the impugned order on 21.02.2019; since
the Tribunal ought to have taken note of Annexure I inter-
party judgment of this Court dated 24.09.2018 referred to
above. The order of the Tribunal is silent as to whether the
afore judgment has been brought to its notice by the
appellant-assessee. The facts as noticed by the Tribunal in
the impugned order and the facts as noticed in the judgment
of this Court at Annexure I, being more or less similar, the
application of the law in the factual position by the Tribunal
ought to have been carried out only with reference to the
principles laid down by this Court. To that extent, we are of
ITA No.60 of 2020 and con.cases 2025:KER:78571
the opinion that the matter requires a revisit at the hands of
the Tribunal.
In such circumstances, these appeals would stand
allowed, setting aside the impugned order of the Tribunal and
directing a fresh consideration of the appeals filed by the
revenue, specifically taking into account the judgment of this
Court at Annexure I.
Sd/-
A.MUHAMED MUSTAQUE
JUDGE
Sd/-
HARISANKAR V. MENON
JUDGE
ln
ITA No.60 of 2020 and con.cases 2025:KER:78571
APPELLANT'S ANNEXURES:
ANNEXURE A THE TRUE COPY OF THE ORDER DATED 28.12.2009
ISSUED BY THE ACIT, CIRCLE -I, THIRUVALLA.
ANNEXURE B THE TRUE COPY OF THE ORDER DATED 19.10.2010
ISSUED BY THE CIT (APPEALS)-I,
THIRUVANANTHAPURAM.
ANNEXURE C THE TRUE COPY OF THE COMMON ORDER DATED 6.1.2012
ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL,
COCHIN BENCH.
ANNEXURE D THE TRUE COPY OF THE ORDER DATED 19.7.2013
ISSUED BY TH ACIT, CIRCLE-1, THIRUVALLA.
ANNEXURE E THE TRUE COPY OF THE COMMON ORDER DATED
29.7.2015 ISSUED BY THE CIT (APPEALS),
KOTTAYAM.
ANNEXURE F THE TRUE COPY OF THE COMMON ORDER DATED 6.1.2016
ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL,
COCHIN BENCH.
ANNEXURE G THE TRUE COPY OF THE ORDER DATED 22.12.2017
ISSUED BY THE CIT (APPEALS), KOTTAYAM.
ANNEXURE H THE TRUE COPY OF THE COMMON ORDER DATED
21.2.2019 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH.
ANNEXURE H1 THE TRUE COPY OF THE COMMON ORDER DATED
16.7.2019 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH.
ANNEXURE I THE TRUE COPY OF THE JUDGMENT DATED 24.9.2018
PASSED BY THIS HON'BLE COURT IN ITA NO.136/2011
AND CONNECTED MATTERS.
ANNEXURE J THE TRUE COPY OF THE ORDER DATED 24.11.2017
ISSUED BY THE HON'BLE SUPREME COURT IN SLP(C)
NOS.31432-31437/2017.
ITA No.60 of 2020 and con.cases 2025:KER:78571
APPELLANT'S ANNEXURES:
ANNEXURE A THE TRUE COPY OF THE ORDER DATED 28.12.2009 FOR
THE A.Y.2003-04 ISSUED BY THE ACIT, CIRCLE-1,
THIRUVALLA.
ANNEXURE B THE TRUE COPY OF THE ORDER DATED 19.10.2010
ISSUED BY THE CIT (APPEALS)-1,
THIRUVANANTHAPURAM.
ANNEXURE C THE TRUE COPY OF THE COMMON ORDER DATED 6.1.2012
ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL,
COCHIN BENCH.
ANNEXURE D THE TRUE COPY OF THE ORDER DATED 19.7.2013 ISSUED
BY THE ACIT, CIRCLE-1, THIRUVALLA.
ANNEXURE E THE TRUE COPY OF THE COMMON ORDER DATED 29.7.2015
ISSUED BY THE CIT (APPEALS), KOTTAYAM.
ANNEXURE F THE TRUE COPY OF THE COMMON ORDER DATED 6.1.2016
ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL,
COCHIN BENCH.
ANNEXURE G THE TRUE COPY OF THE ORDER DATED 22.12.2017
ISSUED BY THE CIT (APPEALS), KOTTAYAM.
ANNEXURE H THE TRUE COPY OF THE COMMON ORDER DATED 21.2.2019
ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL,
COCHIN BENCH.
ANNEXURE HI THE TRUE COPY OF THE COMMON CORRIGENDUM ORDER
DATED 16.7.2019 ISSUED BY THE INCOME TAX
APPELLATE TRIBUNAL, COCHIN BENCH.
ANNEXURE I THE TRUE COPY OF THE JUDGMENT DATED 24.9.2018
PASSED BY THIS HON'BLE COURT IN ITA NO.136/2011
AND CONNECTED MATTERS.
ANNEXURE J THE TRUE COPY OF THE ORDER DATED 24.11.2017
ISSUED BY THE HON'BLE SUPREME COURT IN SLP(C)
NOS.31432-31437/2017
ITA No.60 of 2020 and con.cases 2025:KER:78571
APPELLANT'S ANNEXURES:
ANNEXURE A THE TRUE COPY OF THE ORDER DATED 28.12.2009 FOR
THE A.Y. 2004-05 ISSUED BY THE ACIT, CIRCLE -
1, THIRUVALLA.
ANNEXURE B THE TRUE COPY OF THE ORDER DATED 19.10.2010
ISSUED BY THE CIT APPEALS -1,
THIRUVANANTHAPURAM.
ANNEXURE C THE TRUE COPY OF THE COMMON ORDER DATED
06.01.2012 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH.
ANNEXURE D THE TRUE COPY OF THE ORDER DATED 19.07.2013
ISSUED BY THE ACIT, CIRCLE 1, THIRUVALLA.
ANNEXURE E THE TRUE COPY OF THE COMMON ORDER DATED
29.07.2015 ISSUED BY THE CIT APPEALS, KOTTAYAM.
ANNEXURE F THE TRUE COPY OF THE COMMON ORDER DATED
06.01.2016 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH.
ANNEXURE G THE TRUE COPY OF THE ORDER DATED 22.12.2017
ISSUED BY THE CIT APPEALS, KOTTAYAM.
ANNEXURE H THE TRUE COPY OF THE COMMON ORDER DATED
21.02.2019 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH.
ANNEXURE H1 THE TRUE COPY OF THE COMMON CORRIGENDUM ORDER
DATED 16.07.2019 ISSUED BY THE INCOME TAX
APPELLATE TRIBUNAL, COCHIN BENCH.
ANNEXURE I THE TRUE COPY OF THE JUDGMENT DATED 24.09.2018
PASSED BY THIS HONBLE COURT IN ITA NO. 136/2011
AND CONNECTED MATTERS.
ANNEXURE J THE TRUE COPY OF THE ORDER DATED 24.11.2017
ISSUED BY THE HONBLE SUPREME COURT IN SLP NOS.
34132/31437/2017.
ITA No.60 of 2020 and con.cases 2025:KER:78571
APPELLANT'S ANNEXURES:
ANNEXURE A THE TRUE COPY OF THE ORDER DATED 28/12/2009 OF
THE A.Y. 2004-05 ISSUED BY THE ACIT, CIRCLE-1,
THIRUVALLA.
ANNEXURE B THE TRUE COPY OF THE ORDER DATED 19/10/2010
ISSUED BY THE CIT (APPEALS)-I,
THIRUVANANTHPURAM.
ANNEXURE C THE TRUE COPY OF THE COMMON ORDER DATED
06/01/2012 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH.
ANNEXURE D THE TRUE COPY OF THE ORDER DATED 19/07/2013
ISSUED BY THE ACIT, CIRCLE-1, THIRUVALLA.
ANNEXURE E THE TRUE COPY OF THE COMMON ORDER DATED
29/07/2015 ISSUED BY CIT (APPEALS), KOTTAYAM.
ANNEXURE F THE TRUE COPY OF THE COMMON ORDER DATED
06/01/2016 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH.
ANNEXURE G THE TRUE COPY OF THE ORDER DATED 22/12/2017
ISSUED BY THE CIT (APPEALS), KOTTAYAM.
ANNEXURE H THE TRUE COPY OF THE COMMON ORDER DATED
21/02/2019 ISSUED BY THE INCOME TAX APPELLATE
TRIBUNAL, COCHIN BENCH IN ITA NOS.69-
72/COCH/2018 AND 73-75/2018.
.
ANNEXURE H1 THE TRUE COPY OF THE COMMON CORRIGENDUM ORDER
DATED 16/07/2019 ISSUED BY THE INCOME TAX
APPELLATE TRIBUNAL, COCHIN BENCH.
ANNEXURE I THE TRUE COPY OF THE JUDGMENT DATED 24/09/2018
PASSED BY THIS HON'BLE COURT IN ITA NO.136/2011
AND CONNECTED MATTERS.
ANNEXURE J THE TRUE COPY OF THE ORDER DATED 24/11/2017
ISSUED BY THE HON'BLE SUPREME COURT IN SLP(C)
NOS.34132-31437/2017.
