Madras High Court
Aditya Birla Finance Limited vs The Deputy Commissioner Of Income ... on 31 August, 2021
W.P.No.25325 of 2017
and M.P.Nos.26783 & 26784 of 2017
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 31.08.2021
CORAM
THE HON'BLE Mr. JUSTICE S.M.SUBRAMANIAM
W.P.No.25325 of 2017
and
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Aditya Birla Finance Limited
having its Registered Office at
Indian Rayon Compound, Veraval,
Gujarat – 362 266 and a branch at
Srinivas Towers, # 5, 1st Floor, Cenotaph
Road, Teynampet, Chennai – 600018
And represented by its Chief Manager & authorised
Signatory Mr.Karthik Kumar ... Petitioner
Vs
1. The Deputy Commissioner of Income Tax
Circle 3 (1) No.44, Williams
Cantonment, Tiruchirapalli.
2. The Assistant Commissioner of Income Tax
Central Circle 1I(1), Room No.122, 1st Floor,
Investigation Wing, 46 Nungambakkam High
Road, Chennai – 600 034.
3. The Joint Sub-Registrar,
Chennai Central Joint-I,
Sub-Registrar Office, Mylapore,
Chennai – 600 004.
4. Dr.A.M.Arun
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1
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and M.P.Nos.26783 & 26784 of 2017
5. Mrs. A.Meera
(R4 & R5 – impleaded as per order, dated 07.06.2018 by TSSJ in
W.M.P.Nos.9163 & 9260 of 2018 in W.P.25325 of 2017.
... Respondents
PRAYER: Writ Petition filed under Article 226 of the Constitution of
India praying to issue a Writ of Mandamus directing the 1st and 2nd
respondents to lift and /or raise or remove the Order of attachment of
immovable properties under Section 281 of the Act, 1961 Form No.ITCP
16 TRC No.36, 37, 38/C-2/201-18 dated 27.09.2017 passed by the first
respondent and registered as document No.1 of 2017 before the third
respondent.
(Prayer amended as per Order dated 14.08.2018 by KRCBJ in
W.M.P.23675 of 2018 in W.P.25325 of 2017 by KRCBJ)
For Petitioner : M/s.U. Vinay Metha
For Respondents : 1. Mr.A.P.Srinivas,
Senior Standing Counsel for
Respondents 1 & 2
2. Mr.V.Veluchamy,
Govt. Advocate for Respondent
No.3
3. Mr.K.Pradeep
for Respondents 4 & 5
ORDER
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The relief sought for in the present Writ Petition is to direct the
first and second respondents to lift and/or raise or remove the Order of
attachment of immovable properties under Section 281 of the Act, 1961
Form No.ITCP 16 TRC No.36, 37, 38/C-2/201-18 dated 27.09.2017
passed by the first respondent and registered as document No.1 of 2017
before the third respondent.
2. The petitioner, Aditya Birla Finance Limited is a Non-Banking
Financial Company duly registered with the Reserve Bank of India and
incorporated under the provisions of the Companies Act, 1956.
3. The learned counsel for the petitioner states that the property
belongs to the impleaded respondents 4 and 5 was mortgaged with the
petitioner Finance Company on 23.04.2013 vide document No.453 of
2013. On 18.08.2014 another mortgage was created in favour of the
petitioner vide document No.2467 of 2014 and on 22.10.2015, the third
Mortgage was created in favour of the petitioner vide document No.3168
of 2015.
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4. The learned counsel for the petitioner states that when the
properties belong to the respondents 4 & 5 are under mortgage, the first
respondent / Deputy Commissioner of Income Tax, passed an Order of
Attachment on 03.11.2015, which all are reflected in the Encumbrance
Certificate of the third respondent / Joint Sub-Registrar. In view of the
fact that the mortgage in favour of the writ petitioner was created prior to
the Attachment Order, the petitioner made a request to the second
respondent to lift the attachment enabling them to deal with the property
as the borrower failed to repay the loan amount.
5. The question of priority based on the date of mortgage is also
raised by the petitioner. The learned counsel for the petitioner has
reiterated that the Attachment by the Income Tax Department was made
at latter point of time in the year 2015 and the subject properties were
mortgaged in favor of the petitioner through registered documents during
the years 2013, 2014 & 2015. Thus, the Attachment became null and
void and liable to be set aside.
6. Regarding the priority issue with reference to the provisions of
the Income Tax Act and under the provisions of the SARFAESI Act and
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Debt Recovery Tribunals Act, this Court has elaborately considered the
issue in W.P.No.15437 of 2014 dated 19.07.2021 and the relevant
paragraphs are extracted hereunder:
“30.Let us now consider the scope of Section 281 of the
Income Tax Act. Chapter XXIII Section 281 of the Income Tax
Act contemplates certain transfers to be void. Sub-clause (1)
enumerates that “where, during the pendency of any
proceeding under this Act or after the completion thereof, but
before the service of notice under rule 2 of the Second
Schedule, any assessee creates a charge on, or parts with the
possession (by way of sale, mortgage, gift, exchange or any
other mode of transfer whatsoever) of, any of his assets in
favour of any other person, such charge or transfer shall be
void as against any claim in respect of any tax or any other
sum payable by the assessee as a result of the completion of
the said proceeding or otherwise". A close reading of the
above provision would reveal that where during the pendency
of any proceedings under this Act or after the completion
thereof, but before service of notice under rule 2 of the Second
Schedule, if any charge is created by an assessee in favour of
any other person shall be void as against any claim in respect
of any tax or any other some payable by the assessee.
Therefore, it is unambiguous that, during pendency of the
proceedings if any charge is created, then such charge created
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by way of sale, mortgage, gift, exchange or any other mode of
transfer whatsoever shall be void.
31.Schedule II Rule 11 of the Income Tax Act which
contemplates investigation by Tax Recovery Officer. Sub-
Clause (1) to Rule 11 states that "where any claim is preferred
to, or any objection is made to the attachment or sale of, any
property in execution of a certificate, on the ground that such
property is not liable to such attachment or sale, the Tax
Recovery Officer shall proceed to investigate the claim or
objection".
32.Sub-clauses (5) and (6) to Rule 11 of the Income Tax
Act reads as under:
(5) Where the Tax Recovery Officer is
satisfied that the property was, at the said date, in
the possession of the defaulter as his own
property and not on account of any other person,
or was in the possession of some other person in
trust for him, or in the occupancy of a tenant or
other person paying rent to him, the Tax Recovery
Officer shall disallow the claim.
(6) Where a claim or an objection is
preferred, the party against whom an order is
made may institute a suit in a civil court to
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establish the right which he claims to the property
in dispute; but, subject, to the result of such suit
(if any), the order of the Tax Recovery Officer
shall be conclusive.
33.A perusal of the entire Rule would reveal that it is
not an appeal or Revision. It is an investigation by the Tax
Recovery Officer, which is contemplated. Therefore, any
third person if involved in such transfer of property, which is
declared as void under Section 281 of the Income Tax Act
may submit an application for investigation by Tax Recovery
Officer. Therefore, the statute does not assume that every
third person is liable under the Income Tax Act. Schedule II
Rule 11 of the Income Tax Act is a beneficial provision in
respect of the person, who was otherwise cheated by any of
the defaulter of tax arrears, who in turn can submit an
application for further investigation in order to cull out the
truth or genuinity with reference to the transactions or
transfers. Therefore, the Tax Recovery Officer during the
pendency found that the charge created in favour of the
petitioner Bank is valid, then he can pass appropriate orders
withdrawing the attachment made under the provisions of the
Act. If the Tax Recovery Officer is of an opinion that the
attachment made under the provisions of the Act was prior to
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the mortgage or otherwise, then he can pass appropriate
orders confirming the attachment. However, the said Rule is
not relatable to declaration or in the form of an appeal by any
third person. It is only an enabling provision for effective
adjudication of the actual facts and to find out the genuinity
of certain transfers made during the pendency of the Income
tax proceedings and with reference to the provision under
Section 281 of the Income Tax Act.
34.Looking into the provisions of the SARFAESI Act,
more specifically, Section 26E, which contemplates priority to
secured creditors which reads that "notwithstanding anything
contained in any other law for the time being in force, after
the registration of security interest, the debts due to any
Secured Creditor shall be paid in priority over all other debts
and all revenues, taxes, cesses and other rates payable to the
Central Government of State Government or local authority".
35.Let us now consider Section 31B of the Recovery of
Debts and Bunkruptcy Act, 1993 and the said section Section
31B was inserted by Act 44 of 2016 with effect from
01.09.2016. The said provision also deals with priority to
secured creditors, which reads that "notwithstanding
anything contained in any other law for the time being in
force, the rights of secured creditors to realise secured debts
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due and payable to them by sale of assets over which security
interest is created, shall have priority and shall be paid in
priority over all other debts and Government dues including
revenues, taxes, cesses and rates due to the Central
Government, State Government or local authority".
36.It is necessary to consider the conflicting provisions
of the Income Tax Act, SARFAESI Act and Recovery of Debts
and Bunkruptcy Act, 1993.
37.On the one hand, the Income Tax Act states that,
where during the pendency of any proceedings under the
Income Tax Act or after completion thereof, any assessee
creates a charge on or parts with the possession by way of
mortgage, sale, etc. Shall be void against any claim in respect
of any tax. So also, the SARFAESI Act states that Section 26E
contemplates that the secured creditors shall be paid in
priority over all other debts and all revenues, taxes, cesses
and other rates payable to the Central Government of State
Government or local authority. Therefore, equal weightage is
given in respect of the secured creditors. So also Section 31B
of Recovery of Debts and Bunkruptcy Act, 1993 states that
sale of assets over which security interest is created, shall
have priority and shall be paid in priority over all other debts
and Government dues including revenues, taxes, cesses and
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rates due to the Central Government, State Government or
local authority.
38.Thus, conflicting provisions in these three
independent statutes are creating heart burning issues
between the secured creditors as well as the Tax Department.
Some of the decisions are in favour of the Tax Department
and some of the decisions are in favour of the Banks. With
reference to Section 26E of the SARFAESI Act and Section
31B of the Recovery of Debts and Bankruptcy Act, 1993,
judgments are given in favour of the Banks in view of the fact
that the said provisions contemplates priority over the
Government dues is to be given to the Banks. The tenor of
Section 281 of the Income Tax Act which contemplates that
any such transaction made during the pendency of any
proceedings under the Income Tax Act shall be void. Thus,
the understanding would be that if the proceedings under the
Income Tax Act are pending at the time of creating mortgage,
sale, gift, etc., then Section 281 of the Income Tax Act would
be pressed into operation. The next question is at the time of
creation of mortgage, sale, gift etc., the Income Tax
Proceedings are pending as contemplated under Section 281
of the Income Tax Act, such transactions became void. Thus,
it is unambiguous that the transactions or transfers made
during the pendency of the Income tax proceedings are void.
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This being the purposive interpretation to be adopted, all
transfers, mortgages etc., made during the pendency of the
Income tax proceedings shall became void under Section 281
of the Income Tax Act. Once Section 281 of the Income Tax
Act was pressed into service and the transactions or transfers
became void, any mortgage, transfer etc., thereafter would be
of no validity. In other words, the transfer or transactions
made against the void transactions under the Income Tax Act
are invalid in the eye of law. Therefore, even before invoking
the provisions of the SARFAESI Act and DRT Act, Section 281
of the Income Tax Act intervenes and declares the
transactions or transfers as void, if any such transactions or
transfers are made during the pendency of the Income Tax
proceedings. In such circumstances, invoking the provisions
of the SARFAESI Act or DRT Act for the purpose of claiming
priority would not arise at all. Law expects that the parties to
be prudent and careful. Before mortgage, transfer or
transactions, an enquiry is required by the respective parties
as the buyer must beware (caveat emptor) of the
encumbrances or the statutory implications or the genuinity
of the title etc., Thus, the principles of caveat emptor would be
applicable in such circumstances, where a transactions or
transfers are made during the pendency of the Income tax
proceedings. In such cases, the Income tax proceedings are
known only to the tax defaulter and not to the third party
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purchaser or the mortgagee Bank or otherwise. Thus, the void
transfers or transactions made during the pendency of the
Income tax proceedings cannot be the subject matter for any
mortgage or further transfers or transactions etc., This being
the possible perceptions, the Courts are bound to consider,
which transaction will prevail over and which Act would be
applicable with reference to the facts and circumstances.
39.More elaborately the facts at the first instance to be
considered and then the application of law which is to be
applied at the first instance also to be considered. For
instance in the case where the income tax proceedings are
pending under the Income Tax Act and if a mortgage is
entered into by the tax defaulter with any Bank, then it is the
duty of the Bank to ensure that no other proceedings are
pending and it is the duty of the person who is borrowing loan
to inform the same to the Bankers. Under these
circumstances, the Income Tax Department is alien to the
transaction of mortgage between the bank and the tax
defaulter and therefore, the Act will automatically come to the
rescue of the Income Tax Department declaring such
transfers as void under Section 281 of the Income Tax Act.
40.Where the Bank entered into a mortgage well before
the pendency of proceedings under the Income Tax Act, then
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Section 26E of the SARFAESI Act would be applicable and in
such circumstances, the Bank will hold priority over all other
claim including the Government dues. Even in such
circumstances, this Court has to consider the other principles
which all are to be followed in such cases. Admittedly, the
SARFAESI Act and Recovery of Debts and Bunkruptcy Act,
1993 provides priority to the secured creditors and the
Income Tax Act provides priority to the tax arrears to be
recovered. Under these circumstances, this Court is inclined
to consider the common law Doctrine of priority of crown
debts.
41.The “doctrine of constitutional priority” will have
precedence over the other priorities. If the priority clause is
provided under various enactments, the question arises as to
which priority is to be held precedence over the other
priorities. The test of traceability and recognition under the
constitutional provisions would be the proper procedure to
form an opinion.
42.In the present scenario, the SARFAESI Act and the
DRT Act provides priority to secured creditors, i.e. the banks
hold priority. The Income Tax Act contemplates any such
mortgage or sale during the pendency of any proceedings
under the Income Tax Act shall be void. Thus, this Court has
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to test the supremacy on the basis of the constitutional
recognition, which is supreme than the statutes enacted under
the constitution. The taxation laws are constitutionally
recognised with reference to the sovereignty and the policies
of the Government. Thus the supremacy of the Constitution
overtakes the statutes enacted and such enactments
constitutionally recognised directly takes precedence over the
other statutes.
43.The principles of 'doctrine of constitutional priority'
is to be defined as, in the event of the similar provisions of
priority under various enactments, then the statute which is
recognised directly by the Constitution for the purpose of
upholding the sovereignty and integrity of the Nation is to be
considered as holding precedence over the other statutes
providing priority.
44.The Constitutional Bench of the Hon'ble Supreme
Court of India in the case of Builders Supply Corporation vs.
Union of India [1965 AIR 1061] considered the principles
laid down in the case of Kaka Mohamed Ghouse Sahib and
Co. vs. United Commercial Syndicate and others [(1886)
ILR 7 Mad. 434], wherein the Madras High Court has held
that it is a settled principle of constitutional law that as
between creditors of the same rank the Government is entitled
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to priority and the republican character of the Constitution of
India has not abrogated this general doctrine of priority of
State debts. In dealing with this question, Justice Ramamurti
has referred to the relevant decisions in relation to the
arrears of income tax due to the Government and has pointed
out there is a consensus of judicial opinion on the question
that the arrears of tax due to the State can claim priority over
private debts. This position has not been seriously disputed.
45.Similarly, the basic justification for the claim of
priority made by the Income Tax Department in the present
case rests on the well recognised principle that the State is
entitled to raise money by taxation, because unless adequate
revenue is received by the State, it would not be able to
function as sovereign Government at all. It is essential that
as a sovereign the Sate should be able to discharge its
primary governmental functions and in order to able to
discharge such functions efficiently, it must be in possession
of necessary funds and this consideration emphasises the
necessity and the wisdom of conceding to the State, the right
to claim priority in respect of its tax dues.
46.In this context, Part XII of the Constitution of India,
more specifically, Article 265 which states that tax not to be
imposed save by authority of law; Article 266 speaks about
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Consolidated funds and public accounts of India and the
States; Article 267 states Contingency fund; Article 268 states
Duties levied by the Union but collected and appropriated by
the States; Article 268A denotes service tax levied by Union
and collected and appropriated by the Union and the States;
Article 269 states taxes levied and collected by the Union but
assigned to the States; Article 269A denotes levy and
collection of goods and service tax in course of inter-state
trade or commerce and Article 270 states that taxes levied
and distributed between the Union and the States. The
chapter deals with the taxes and its constitutional importance
are to be considered by this Court. Undoubtedly, tax is the
backbone of our Nation's economy and it holds top priority.
In this context, the tax collected goes to the welfare of the
people in general, however the mortgage or sale transaction
between the bank and the tax defaulter can be at no
circumstances be compared with the constitutional
importance of tax being collected from the people for the
purpose of achieving the constitutional goals and
perspectives. Therefore, the provisions of various Acts if there
are conflicting provisions or grant of priority to various
institutions, then the Constitution of India will be the guiding
factor to form an opinion and confer priority. The nature of
transaction, the implications, Constitutional importance and
the other principles enunciated under the Constitution of
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India are the principal factors to be considered to form an
opinion that, which claim shall be given priority over the
other claims as various statutes enacted by the Parliament
gives priority to such institutions irrespective of the fact that
the other Acts are also providing similar priority to other
institutions.
47.In support of the said observation, this Court would
like to draw the attention with reference to the judgment of
the Three Judges Bench of the Hon'ble Supreme Court of
India in the case of Central Bank of India vs. State of Kerala
and others [Civil Appeal No.95 of 2005 dated 27.02.2009],
wherein the Apex Court considered the provisions of the DRT
Act and SARFAESI Act and the following observations are
made:
“33.The non obstante clauses contained
in Section 34(1) of the DRT Act and Section 35 of
the Securitisation Act give overriding effect to the
provisions of those Acts only if there is anything
inconsistent contained in any other law or
instrument having effect by virtue of any other
law. In other words, if there is no provision in the
other enactments which are inconsistent with
the DRT Act or Securitisation Act, the provisions
contained in those Acts cannot override other
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legislations. Section 38C of the Bombay Act and
Section 26B of the Kerala Act also contain non
obstante clauses and give statutory recognition to
the priority of State's charge over other debts,
which was recognized by Indian High Courts even
before 1950. In other words, these sections and
similar provisions contained in other State
legislations not only create first charge on the
property of the dealer or any other person liable
to pay sales tax, etc. but also give them overriding
effect over other laws. In Builders Supply
Corporation v. Union of India [(1965) 2 SCR
289], the Constitution Bench considered the
question whether tax payable to the Union of
India has priority over other debts. After making a
reference to the judgments of the Bombay High
Court in Bank of India v. John Bowman and Ors.,
[AIR 1955 Bom. 305], Madras High Court
in Kaka Mohammad Ghouse Sahib & Co. v.
United Commercial Syndicate and others [(1963)
49 I.T.R. 25] and Manickam Chettiar v. Income-
tax Officer, Madura, [(1938) 6 ITR 180], the
Court held :
(i) "The Common Law doctrine of the
priority of Crown debts had a wide sweep but the
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question in the present appeal was the narrow one
whether the Union of India was entitled to claim
that the recovery of the amount of tax due to it
from a citizen must take precedence and priority
over unsecured debts due from the said citizen to
his other private creditors. The weight of
authority in India was strongly in support of the
priority of tax dues.
(ii) The Common Law doctrine on which
the Union of India based its claim in the present
proceedings had been applied and upheld in that
part of India which was known as `British India'
prior to the Constitution.
The rules of Common Law relating to
substantive rights which had been adopted by this
country and enforced by judicial decisions,
amount to `law in force' in the territory of India at
the relevant time within the meaning of Art.
372(1). In that view of the matter, the contention
of the appellant that after the Constitution was
adopted the position of the Union of India in
regard to its claim for priority in the present
proceedings had been alerted could not be
upheld.
(iii) The basic justification for the claim for
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priority of Government debts rests on the well-
recognised principle that the State is entitled to
raise money by taxation, otherwise it will not be
able to function as a sovereign government at all.
This consideration emphasizes the necessity and
wisdom of conceding to the State the right to
claim priority in respect of its tax dues."
34. In State Bank of Bikaner and Jaipur v.
National Iron and Steel Rolling Corporation and
others [(1995) 2 SCC 19], the Court again
recognized the priority of the State's statutory first
charge under Section 11-AAAA of the Rajasthan
Sales Tax Act, 1954 vis-`-vis claim of the bank to
recover its dues from the borrower.
35. In Dena Bank v. Bhikhabhai Prabhudas
Parekh & Co. and others [(2000) 5 SCC 694], the
Court reviewed case law on the subject and
observed:
"The principle of priority of government
debts is founded on the rule of necessity and of
public policy. The basic justification for the claim
for priority of State debts rests on the well-
recognised principle that the State is entitled to
raise money by taxation because unless adequate
revenue is received by the State, it would not be
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able to function as a sovereign Government at all.
It is essential that as a sovereign, the State should
be able to discharge its primary governmental
functions and in order to be able to discharge
such functions efficiently, it must be in possession
of necessary funds and this consideration
emphasises the necessity and the wisdom of
conceding to the State, the right to claim priority
in respect of its tax dues (see Builders Supply
Corpn.). In the same case the Constitution Bench
has noticed a consensus of judicial opinion that
the arrears of tax due to the State can claim
priority over private debts and that this rule of
common law amounts to law in force in the
territory of British India at the relevant time
within the meaning of Article 372(1) of the
Constitution of India and therefore continues to
be in force thereafter. On the very principle on
which the rule is founded, the priority would be
available only to such debts as are incurred by
the subjects of the Crown by reference to the
State's sovereign power of compulsory exaction
and would not extend to charges for commercial
services or obligation incurred by the subjects to
the State pursuant to commercial transactions.
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Having reviewed the available judicial
pronouncements their Lordships have summed up
the law as under:
1. There is a consensus of judicial opinion
that the arrears of tax due to the State can claim
priority over private debts.
2. The common law doctrine about priority
of Crown debts which was recognised by Indian
High Courts prior to 1950 constitutes "law in
force" within the meaning of Article 372(1) and
continues to be in force.
3. The basic justification for the claim for
priority of State debts is the rule of necessity and
the wisdom of conceding to the State the right to
claim priority in respect of its tax dues.
4. The doctrine may not apply in respect of debts
due to the State if they are contracted by citizens
in relation to commercial activities which may be
undertaken by the State for achieving socio-
economic good. In other words, where the welfare
State enters into commercial fields which cannot
be regarded as an essential and integral part of
the basic government functions of the State and
seeks to recover debts from its debtors arising out
of such commercial activities the applicability of
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the doctrine of priority shall be open for
consideration."
48.One of the principles, which is impressive in the
judgment cited supra is that the basic justification for the
claim for priority of Government dues rests on the well
recognized principles that the State is entitled to raise money
by taxation otherwise it will not be able to function as
sovereign Government at all. This consideration emphasises
the necessity and wisdom of conceding to the State, the right
to claim priority in respect of its tax dues. The importance of
the above reading is to be considered regarding the present
facts and circumstances.”
7. As far as the factual dispute raised by the petitioner, it is to be
adjudicated before the Competent Authority under the Income Tax Act.
High Court cannot adjudicate those disputed facts involving
scrutinization of original documents and evidences. The petitioner in this
regard is bound to approach the Competent Authority under Rule 11
Schedule II of the Income Tax Act for investigation of the facts for
arriving a decision. When the provisions of the Income Tax provides a
remedy for complete adjudication of these disputed facts, the said remedy
is expected to be exhausted by the petitioner. Thereafter they are at
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liberty to approach the Competent Court of Law, in the event of any
other civil dispute or otherwise.
8. The learned Senior Standing Counsel made a submission that
even at the time of mortgage, the income tax proceedings with reference
to the Assessment Years 2009 - 10, 2010 - 11 and 2011 - 12 were
pending and therefore, mortgage becomes null and void and in view of
the Section 281 of the Income Tax Act. When it is brought to the notice
of this Court that the Income Tax proceedings were pending in relation to
the Assessment Year 2009 - 10, all those facts are to be adjudicated
before the Competent Authority under Rule 11 Schedule II of the Income
Tax Act.
9. In view of the facts and circumstances, the following orders are
passed:
(1) The relief as such sought for in the present writ
petition stands rejected.
(2) The petitioner is at liberty to approach the Tax
https://www.mhc.tn.gov.in/judis/
W.P.No.25325 of 2017
and M.P.Nos.26783 & 26784 of 2017
Recovery Officer by filing an appropriate application under
Schedule II, Rule 11 of the Income Tax Act. In the event of
filing any such application, the Tax Recovery Officer is
directed to investigate the same with reference to the original
documents and pass appropriate orders as expeditiously as
possible.
10. Accordingly, the writ petition stands disposed of. No costs.
Consequently, connected miscellaneous petitions are closed.
31.08.2021
Internet:Yes/No
Index:Yes.
/No
Speaking Order/ Non Speaking Order
Pns/Kbs
S.M.SUBRAMANIAM, J.
Pns
To
https://www.mhc.tn.gov.in/judis/
W.P.No.25325 of 2017
and M.P.Nos.26783 & 26784 of 2017
1.The Deputy Commissioner of Income Tax
Circle 3 (1) No.44, Williams
Cantonment, Tiruchirapalli.
2.The Assistant Commissioner of Income Tax
Central Circle 1I(1), Room No.122, 1st Floor,
Investigation Wing, 46 Nungambakkam High
Road, Chennai – 600 034.
3.The Joint Sub-Registrar,
Chennai Central Joint-I,
Sub-Registrar Office, Mylapore,
Chennai – 600 004.
W.P.No.25325 of 2017
and
M.P.Nos. 26783 & 26784 of 2017
31.08.2021
https://www.mhc.tn.gov.in/judis/
