M/S.Cognizant Technology ... vs Assistant Commissioner Of Income ...
2021 Latest Caselaw 16148 Mad

                                                                        WP No.29023 of 2018

                                   IN THE HIGH COURT OF JUDICATURE AT MADRAS

                                               DATED : 09-08-2021

                                                    CORAM

                              THE HONOURABLE MR. JUSTICE S.M.SUBRAMANIAM

                                               WP No.29023 of 2018
                                                      And
                                              WMP No.33925 of 2018


                     M/s.Cognizant Technology Solutions India
                          Private Limited,
                     Represented by Authorised Signatory Mr.Gopakumar R.,
                     No.165, Menon Eternity Building,
                     6th Floor, St. Mary's Road,
                     Chennai-600 018.                         ..     Petitioner

                                                       vs.


                     1.Assistant Commissioner of Income Tax,
                       Large Taxpayer Unit-1,
                       7th Floor, Room No.712,
                       121, Nungambakkam High Road,
                       Chennai-600 034.

                     2.Joint Commissioner of Income Tax,
                       Large Taxpayer Unit,
                       7th Floor, Room No.712,
                       121, Nungambakkam High Road,
                       Chennai-600 034.                        ..     Respondents



                     1/28


https://www.mhc.tn.gov.in/judis/
                                                                                WP No.29023 of 2018

                                   Writ Petition is filed under Article 226 of the Constitution of
                     India, praying for the issuance of a Writ of Certiorari, calling for the records
                     on the file of the first respondent and quash the impugned notice
                     PAN:AAACD3312M dated 29.03.2018 issued under Section 148 of the
                     Income Tax Act for the Assessment Year 2013-2014 in Notice
                     No.ITBA/AST/148/2017-18/1009530834 (1) along with the impugned order
                     in LTU1/AAACD3312M/2018-19 dated 16.10.2018.
                                   For Petitioner             : Mr.N.V.Balaji

                                   For Respondents            : Mr.A.P.Srinivas,
                                                                Senior Standing Counsel for
                                                                Income Tax.

                                                        ORDER

The lis on hand is filed challenging the notice issued under

Section 148 of the Income Tax Act, 1961 for the assessment year 2013-2014

and the order passed by the Assessing Authority, disposing of the objections

filed by the petitioner.

2. The petitioner is a Company incorporated under the Companies

Act, 1956 and is engaged in the business of software development. The

petitioner is regularly assessed to income tax. The petitioner had filed its

return of income for the assessment year 2013-2014 under Section 139(1) of

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

the Income Tax Act, 1961 on 30.11.2013.

3. The case of the petitioner was taken up for scrutiny and the first

respondent sought for various details from time to time during the

assessment proceedings. All the details were provided by the petitioner

during the course of assessment proceedings. Accordingly, the first

respondent passed the assessment order on 31.12.2016 under Section 143(3)

read with Section 92CA of the Income Tax Act, 1961.

4. Although the first respondent in the assessment order had

discussed on certain additions to be made in determining the book profits

under Section 115JB, he did not give effect to the same in the computations

attached to that order. A rectification petition was filed in this regard. Under

these circumstances, a notice under Section 148 of the Income Tax Act,

1961 was issued for reopening of assessment for the assessment year 2013-

2014 stating that the income chargeable to tax has escaped assessment.

5. The petitioner responded to the notice and requested for

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

reasons. The reasons were provided and the petitioner submitted its

objections elaborately. The said objections were also disposed of by the

Assessing Authority and challenging the said disposal order, the present

writ petition is filed by the petitioner.

6. The learned counsel appearing on behalf of the petitioner

mainly raised a contention that the reasons stated for reopening of

assessment amounts to change of opinion. Secondly, the reasons for

reopening has not been provided within a reasonable time and therefore, the

proceedings are bad in law.

7. To substantiate the said grounds raised for assailing the order

impugned, the learned counsel for the petitioner drawn the attention of this

Court with reference to the reasons furnished to the petitioner-Assessee by

the first respondent in proceedings dated 30.08.2018. The reasons are

attacked by the petitioner and the objections submitted by the petitioner are

relied upon. The reasons for reopening are met with complete particulars in

comparison with the discussions and the adjudication made by the

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

Assessing Authority, while passing the original assessment order under

Section 143(3) of the Income Tax Act, 1961.

8. The learned counsel for the petitioner reiterated that all the

issues were adjudicated elaborately and the very same subject matter and the

very same particulars are taken into consideration for the purpose of

reopening of assessment in a different language and therefore, it is a case of

change of opinion and cannot be fit in with the provisions of Section 147 of

the Income Tax Act, 1961.

9. It is contended that the petitioner-Company have categorically

explained the reasons for assessment and the details submitted during the

assessment proceedings under Section 143(3) of the Income Tax Act, 1961

and references were also cited. Therefore, there is no reason whatsoever for

reopening of assessment.

10. The learned counsel for the petitioner further contended that,

while disposing of the objections, the Competent Authority has not

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

considered any of these objections raised with complete details and

blanketly stated that the reopening of assessment is in accordance with the

provisions of Law and therefore, the said order is not only establishes that

the authorities have not applied their mind, but the objections in detail

submitted by the petitioner had not been considered at all.

11. It is contended that the impugned order disposing of the

objections are passed in a mechanical manner without furnishing any

findings with reference to the objections filed. Therefore, the order

impugned is liable to be set aside.

12. At the outset, it is contended that the assessment order was

initially passed under Section 143(3) of the Income Tax Act, elaborately

considering all the issues and in respect of the issues queries were raised

and the petitioner had also submitted detailed answers for the queries and

accordingly, final assessment order was passed.

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

13. Shockingly, the very same particulars and details adjudicated

were taken into consideration for the purpose of reopening of assessment

and therefore, it is the change of opinion and the initiation itself is in

violation of Section 147 of the Income Tax Act.

14. The learned Senior Standing Counsel, appearing on behalf of

the respondents, disputed the contentions of the learned counsel for the

petitioner, by stating that under Section 147 of the Income Tax Act, if the

Assessing Officer has reason to believe, the same would be sufficient for

reopening of assessment. The materials already considered by the Assessing

Authority may also be a ground to cull out certain new informations and

from and out of such new informations, reassessment proceedings shall be

initiated by the Competent Authority.

15. In the present case, merely comparing the subjects which were

discussed by the Assessing Authority in the assessment order, the petitioner

cannot make out a ground by stating that the very same subject has been

taken into consideration for the purpose of reopening of assessment and

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

therefore, the reopening amounts to change of opinion. Such a ground

deserves no merit consideration as Section 147 of the Income Tax Act,

provide ample powers to the authority to reopen the assessment on

numerous circumstances.

16. The learned Senior Standing Counsel for the respondents

drawn the attention of this Court with reference to the original assessment

order passed for the assessment year 2013-2014 on 31.12.2016.

Undoubtedly, the issues are considered, however, the reasons furnished for

reopening of assessment order would show that from and out of the

materials, the Assessing Authority has reason to believe that dis-allowance

of provision for lease equalisation and charges under Section 115JB was

made. That was not taken into consideration while arriving a taxable income

under Section 115JB.

17. Further, relying on the reasons furnished for reopening of

assessment contended that on those particulars, the Assessing Officer has

reason to believe that the income chargeable to tax on escaped assessment.

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

When the Assessing Officer could able to trace out certain new materials

from and out of the materials submitted by the Assessee during the original

assessment proceedings, such informations are also sufficient enough for

the purpose of reopening of assessment. It is for the Assessee to participate

in the reopening proceedings and place the records, enabling the authority to

complete the reopening proceedings by following the procedures.

18. Considering the arguments as advanced by the respective

learned counsel appearing on behalf of the parties to the lis on hand, this

Court has to consider the fact that reopening of assessment in the present

case is made within four years. Admittedly, when it is made within a period

of four years, then the First Proviso to Section 147 of the Income Tax Act,

is not applicable.

19. Section 147 enumerates that “if the Assessing Officer has

reason to believe that any income chargeable to tax has escaped assessment

for any assessment year, he may, subject to the provisions of Sections 148 to

153, assess or reassess such income and also any other income chargeable to

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

tax which has escaped assessment and which comes to his notice

subsequently in the course of the proceedings under this Section, or

recompute the loss or the depreciation allowance or any other allowance, as

the case may be, for the assessment year concerned”.

20. Let us now consider the spirit of the language employed in the

said provision. The term “has reason to believe” is considered by the

Constitutional Courts on many occasions. The reasons must have live link

for the purpose of reopening of assessment. Therefore, it is not mere reasons

to believe and such reasons must have some nexus for the purpose for which

the reopening proceedings are initiated.

21. This apart, the reasons should not be change of opinion. The

change of opinion is also elaborately discussed by the Courts. If any

adjudication is made with reference to a particular issue and an

interpretation is given in a particular manner or a finding is given and in

respect of the same finding, if another opinion is formulated, the same

amounts to change of opinion. However, the Courts are expected to be

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

cautious, while forming an opinion whether it is 'change of opinion' or

'reason to believe'.

22. In many occasions, materials are one and the same, issues are

also one and the same. However, from and out of the same materials and

issues, if the Competent Authority could able to trace out a new

information, material or dimension in consonance with the provisions of the

Act, which was omitted by the original Assessing Authority and such failure

of the original Assessing Authority resulted in income chargeable to tax

escaped assessment, then it is a ground for reopening of the assessment. In

certain circumstances, undoubtedly, the Courts are expected to be cautious

in view of the fact that the subjects may be one and the same.

23. The issues discussed by the Assessing Authority as well as

the Original Authority may be one and the same, but the factual inference

and the application of provisions of Income Tax Act and the interpretation

required to be given in such circumstances, creates a reason to believe for

the authority that the income escaped assessment and reopening of

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

assessment is initiated.

24. Thus it is not as if the Assessee can simply compare the issues

discussed by the Assessing Authority and the reasons furnished for

reopening of assessment. Within the issue, if materials are culled out, which

is not discussed or adjudicated by the original assessing authority, then

reopening of assessment is allowable and therefore, mere comparison would

undoubtedly result in denial of an opportunity for the revenue to bring the

tax escaped assessment within the net work. All these intricacies required to

be considered in such cases, where the materials shown are one and the

same both in the original assessment order as well as in the reasons

furnished for reopening of assessment.

25. The other ground raised by the petitioner is that the Assessing

Authority, while disposing of the objections, has not considered the

objections. Though the petitioner has elaborately submitted the objections

with reference to the reasons furnished for reopening of assessment, the said

objections are not considered and no findings are given in this regard. It is

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

necessary for this Court to examine this issue. A distinction is to be drawn

in respect of the disposal of an objection by the Competent Authority and a

final order passed in the reassessment proceedings.

26. Section 147 of the Income Tax Act, contemplates that “the

Assessing Officer has reason to believe that any income chargeable to tax

has escaped assessment, then he is empowered to assess or reassess such

income”. Even during the course of reassessment proceedings, if the

authority would be able to find out some new informations or materials and

such authority is empowered to assess or reassess the said income also. Two

circumstances are contemplated. The first circumstance is that after passing

the assessment order if the Assessing Officer has reason to believe that the

income chargeable to tax has escaped assessment for reopening assessment

proceedings by issue of notice under Section 148 of the Income Tax Act.

The second circumstance would be that any other income chargeable to tax

has escaped assessment and which comes to his notice subsequently in the

course of the proceedings under Section 147, then also the Assessing

Officer is empowered to go for reassessment of such income, which was

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

traced out during the course of proceedings.

27. The significance of the second circumstance is that even after

furnishing of reasons or at the time of continuance of reopening

proceedings, if the Assessing Authority could able to find out any other

income chargeable to tax, which has escaped assessment and which comes

to his notice, then he can provide an opportunity to the Assessee and

proceed with the reassessment against such income escaped assessment

also.

28. In this context, let us consider the spirit of the judgment of the

Hon'ble Supreme Court of India in the case of GKN Driveshafts (India)

Ltd vs. Income Tax Officer and Others [(2003) 1 SCC 72], wherein in

paragraph-5 of the judgment, the opportunity in compliance of the

principles of natural justice has been considered by the Supreme Court and

the following procedures are directed and the same reads as under:-

“5. We see no justifiable reason to interfere with the order under challenge. However, we clarify that when a notice under Section 148 of the

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

Income Tax Act is issued, the proper course of action for the noticee is to file return and if he so desires, to seek reasons for issuing notices. The Assessing Officer is bound to furnish reasons within a reasonable time. On receipt of reasons, the noticee is entitled to file objections to issuance of notice and the assessing officer is bound to dispose of the same by passing a speaking order.

In the instant case, as the reasons have been disclosed in these proceedings, the assessing officer has to dispose of the objections, if filed, by passing a speaking order, before proceeding with the assessment in respect of the abovesaid five assessment years.”

29. Though the Income Tax Act provides opportunity to an

Assessee, the Supreme Court thought fit that an opportunity to be provided

under the Income Tax Act must be in compliance with the principles of

natural justice. That prompted the Apex Court to issue a direction in GKN

Driveshafts (India) Ltd case (cited supra). The directions are that when a

notice under Section 148 of the Income Tax Act is issued, the Assessee may

file a return if he so desires and to seek reasons for reopening. The Supreme

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

Court says that the Assessing Officer is bound to furnish the reasons within

the reasonable period of time. The Assessee is entitled to file objections to

the issuance of notice and the Assessing Officer is bound to dispose of the

same by passing a speaking order.

30. With reference to the directives of the Apex Court of India,

the procedures are to be followed scrupulously as the judgement became the

law of the land under Article 141 of the Constitution of India. However, the

directives are to be read in consonance with the spirit of Section 147 of the

Income Tax Act in order to understand that the directives issued for the

purpose of compliance of the principles of natural justice.

31. The directives of the Apex Court are in between procedures

created by judgment, more specifically, from the initiation of Section 147

proceedings and the disposal of objections by the Assessing Officer.

32. The very purport of directions are to ensure that the Assessee

must know the reasons for reopening and he must be provided with an

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

opportunity to contest the reasons by way of submitting the objections and

such objections must be disposed of by a Competent Authority by passing a

speaking order.

33. The speaking order in the present context means only with

reference to the reasons for reopening of assessment. Therefore, speaking

order would not include the entire issues, which all are to be adjudicated.

After disposing of the reasons and while passing the order of reassessment,

the Assessee would get further opportunity to participate in the

reassessment proceedings and he is entitled to submit any further documents

available during the course of proceedings of reassessment. Therefore, the

submission of objections for the reasons for reopening is not the end of the

matter and there are further proceedings and during such proceedings, the

Assessee is entitled to submit further materials if it is in his knowledge or

the documents available and place it before the Competent Authority for

consideration. Therefore, the disposal of objections by the authority, cannot

be equated with the final order of reassessment or assessment.

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

34. What is required is whether the requisite condition

contemplated under Section 147 of the Income Tax Act is complied with or

not. Section 147 stipulates that the Assessing Officer must have reason to

believe. If such reason to believe is satisfied and disposal of objections

would indicate that the reasons furnished are having live link with the

initiation of proceedings. The said nexus as well as the materials or

informations considered for reopening would be sufficient.

35. Thus, the disposal of objections must be read with reference

to the requisite condition contemplated under Section 147 of the Income

Tax Act, i.e., “the Assessing Officer has reason to believe”. If the said

requirement is complied with, it would be sufficient to proceed with the

reassessment proceedings. It is not as if the entire adjudication of issues

must be done by the Assessing Officer while disposing of the objections

filed by the petitioner with reference to reasons furnished within.

36. The point to be considered is that even after disposal of the

objections if the Assessing Officer under Section 147 of the Income Tax Act

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

noticed that any other income chargeable to tax which has escaped

assessment during the course of proceedings, then also he is empowered to

reassess such income. Thus various circumstances made available for the

Assessing Authority to reopen the assessment, cannot be interfered with in a

routine manner. The authority must be permitted to complete the

reassessment proceedings in all respects. The Assessee would be getting

ample opportunity even after disposal of the objections and before passing

the reassessment proceedings. Even after reassessment order is passed, the

Assessee would be getting further opportunity of appeal etc.

37. Thus, mere comparison of subject or issues with reference to

the original assessment order and disposal of objections, cannot be a ground

for the purpose of setting aside the reopening proceedings. If the reasons

furnished for reopening of assessment provide any new informations or

materials or based on different dimension under the provisions of the

Income Tax Act, which has not been considered by the original authority,

then also reopening of assessment is permissible.

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

38. This exactly is the reason why Explanation 2 to sub clause (c)

of Section 147 of the Income Tax Act, contemplates, where an assessment

has been made, but income chargeable to tax has been underassessed, then

also the reassessment is permissible. Such income has been assessed at too

low a rate under various circumstances as provided under Explanation 2

also. Thus, the comparison alone cannot be a ground or mere adjudication of

an issue cannot be construed as change of opinion. If such an adjudication is

based on reasons to believe, then the authorities may be allowed to continue

the reopening proceedings for all purposes by following the procedures as

contemplated under law.

39. In respect of the case on hand, the reasons furnished would

reveal the following informations/materials for reopening of assessment:-

(1) In this connection, on verification of the ITMR file and the assessment order, it is observed that in the assessment order an addition to Book profit amounting to Rs.35,91,44,949/- towards disallowance of provision for Lease Equalisation charges under Section 115JB was made. This was not taken into consideration while arriving a

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

taxable income under Section 115JB. In addition to the above, the disallowance made under Section 14A disallowance amounting to Rs.1,92,10,640/- should also be considered for Book profit. The above omission has resulted in short levy of tax to the tune of Rs.7,34,95,572/-.

.. .. .. .. .. .. .. .. .. ..

(2) During the relevant previous year, the assessee company had entered into forward contracts in order to safeguard itself from unfavourable movement in the foreign exchange rates relating to its export earnings. In the return of income, the assessee has claimed an amount of INR 82,06,13,134/- being the mark to market loss on restatement of outstanding forward contracts as on 31.03.2013 as a deduction in computing the income under the head profits and gains from business or profession.

Since the above unrealised expenses being the mark to market loss is not an allowable expenditure and requires to be disallowed and brought to tax.

(3) It is seen from Notes forming part of the Financial Statements for the year ended 31.03.2013, vide Sl. No.25 under other expenses, an amount of

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

Rs.1,86,03,66,315/- was shown as expenses towards software. However, software being an intangible asset requires to be claimed depreciation at 25%. The entire expenditure should not be claimed an expenditure. Hence, the excess allowance requires to be brought to tax. On verification of break up details of repairs and maintenance an amount of Rs.20,11,71,783/- was considered as computer software. The above expenditure should be restricted to 25% depreciation as against the 100%. This has resulted in excess allowance as under.

.. .. .. ... .. .. ... .. .. .. ..

(4) Long Term Capital Loss was computed for Rs.148,06,18,752/- and the same was considered in the computation of total income. However, the above loss was considered for carry forward for future set off. In this connection, it is observed from the computation of long term capital loss was computed by adopting the cost of acquisition at the US Dollar rate as against the Indian Rupee rate. This has resulted in excess long term capital loss to be carry forward as detailed below:-

... .... ... .. ... ... ...

(5) It is seen from Annexure 3 in respect of the

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

computation of short term capital gain it is observed that capital gain was arrive for Rs.40,62,04,596/-. However, as amount of Rs.1,86,37,918/- was deducted from the above short term gain stating that the amount relates to unrealised capital gains accounted in the financial statements as on 31.03.2012 and was added back in the assessment of earlier years. As per income tax act, short term capital gain in computed based on the difference between the cost of acquisition and the cost of sale. Hence the deduction of earlier year unrealised loss is not an acceptable deduction”.

40. The Assessee also submitted elaborate objections for all the

reasons furnished. For disposing of the objections dated 16.10.2018, the

Assessing Authority considered the objections as raised by the petitioner.

The Assessing Authority considered the objections on issue basis and made

findings in paragraphs 5.1, 5.3 and 6.2, extracted as under:-

“5.1 The Assessee's objection is carefully considered, however, it is not accepted for the reason that the relevant issue was not specifically considered by the Assessing Officer. The

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

Assessing Officer nowhere left the traces for verification of the issue, therefore, it does not tantamount to change of opinion and to review of the assessment already completed. The Assessee has to truly and fully disclose the information whereas in this case Assessee failed to furnish the information required on the above issue. It is duty cast on the Assessee to disclose fully and truly all material facts necessary for the purpose of assessment, it is not relevant that had the Assessing Officer been diligent. He could have got all necessary information for the purpose of assessment. In this case Assessing Officer has not formed opinion on this issue. Therefore, reopening of assessment is in accordance with the provisions of Section 147 of the IT Act 1961.

5.3 From the above it is clear that the reassessment is permissible when Assessing Officer did not form opinion on any issue during first assessment and if any reason to believe is formed for escapement of income chargeable to tax that itself is sufficient enough to initiate reassessment proceedings. In view of the above discussion, your objection that reassessment

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

proceedings were based on mere change of opinion and not based on any reason to believe and therefore the reassessment proceedings are invalid is rejected.

6.1. The Assessee's objection is carefully considered, however, it is not accepted for the reason that in the said case (Sahkari Khand Udyog Mandal Limited vs. ACIT) certain direction was issued by the Hon'ble High Court of Gujarat to the concerned Chief Commissioner.

With due respect it may considered that the said decision is not binding in the assessment under consideration as the said decision is not of jurisdictional High Court. Hence Assessee's contention is not entertainable”.

41. The learned counsel for the petitioner referred some of the

judgments and so also the learned Senior Standing Counsel for the Income

Tax Department also referred few judgments. Absolutely, there is no dispute

regarding the proposition of law relied on by both the respective counsel

regarding the judgments cited. The principles in this regard are settled and

the judgments relied on by both the parties to the lis, are considered by this

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

Court. Therefore recording of those judgments repeatedly by this Court may

not be required for the purpose of considering the facts and circumstances

established in the present case on hand. The reasons furnished and disposal

of reasons would play a pivotal role in arriving a decision.

42. Considering the reasons furnished, the objections submitted

by the petitioner and the disposal of the objections by the Competent

Authority, this Court is of an opinion that the intricacies involved in the

issues require an elaborate adjudication and admittedly, the petitioner is

falling under the large tax payer unit and certain intricacies in deeper

manner requires more adjudication with reference to the issues raised. Such

an elaborate adjudication cannot be done with reference to the issues as the

Assessee has to avail the opportunities to be provided, while proceeding

with the reassessment proceedings and it is for the Assessee to participate in

the reopening proceedings and avail the opportunities to be provided for the

purpose of completion of reopening proceedings.

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

43. This being the factum and the principles to the followed,

this Court has no hesitation in arriving a conclusion that the Assessing

Officer in the present case has established that he has reason to believe for

reopening of assessment and there is no infirmity, as such, in reopening of

the assessment under Section 147/148 of the Income Tax Act. The petitioner

has to cooperate for the early completion of the reopening proceedings.

44. Accordingly, the writ petition stands dismissed. However,

there shall be no order as to costs. Consequently, connected miscellaneous

petition is also dismissed.

09-08-2021

Index : Yes/No.

Internet : Yes/No.

Speaking Order/Non-Speaking Order.

Svn

To

1.Assistant Commissioner of Income Tax, Large Taxpayer Unit-1, 7th Floor, Room No.712, 121, Nungambakkam High Road, Chennai-600 034.

https://www.mhc.tn.gov.in/judis/ WP No.29023 of 2018

S.M.SUBRAMANIAM, J.

Svn

2.Joint Commissioner of Income Tax, Large Taxpayer Unit, 7th Floor, Room No.712, 121, Nungambakkam High Road, Chennai-600 034.

WP 29023 of 2018

09-08-2021

https://www.mhc.tn.gov.in/judis/