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Kerala High Court

Annai Infra Developers Private Limited vs State Of Kerala on 21 March, 2019

Author: A.Muhamed Mustaque

Bench: A.Muhamed Mustaque

         IN THE HIGH COURT OF KERALA AT ERNAKULAM

                           PRESENT

      THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE

  THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA,
                           1940

                    WP(C).No. 3797 of 2019




PETITIONER:


              ANNAI INFRA DEVELOPERS PRIVATE LIMITED
              REP. BY ITS MANAGING DIRECTOR, S. ASHOK
              KUMAR, 7, IV FLOOR, SDS ENCLAVE, 2/5
              PERUNDURAI ROAD., ERODE-638 011

              BY ADVS.
              SRI.P.T.GEOTOM
              P.V.NIRANJAN




RESPONDENTS:

     1        STATE OF KERALA
              REP. BY SECRETARY TO GOVERNMENT, TAXES
              DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM-
              695 001

     2        THE COMMISSIONER OF COMMERCIAL TAXES
              TAX TOWER, KILLIPPALAM, KARAMANA P.O,
              TRIVANDRUM-695 001

     3        STATE TAX TOWER
              WORKS CONTRACT, STATE GST (KERALA), PALAKKAD,
              PIN-678 001

     4        THE CHIEF ENGINEER
              KERALA STATE RURAL ROADS DEVELOPMENT AGENCY,
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                           ..2..


           LOCAL SELF GOVERNMENT (RD) DEPARTMENT,
           GOVERNMENT OF KERALA, 3RD FLOOR, CSI BUILDING,
           PULIMOODU JUNCTION, TRIVANDRUM, TRIVANDRUM-695
           001

           BY ADV. GOVERNMENT PLEADER

           MM JASMINE GP


THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION
ON 21.03.2019, ALONG WITH WP(C).3804/2019,
WP(C).3843/2019, WP(C).3917/2019, THE COURT ON THE SAME
DAY DELIVERED THE FOLLOWING:
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                               ..3..


         IN THE HIGH COURT OF KERALA AT ERNAKULAM

                           PRESENT

      THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE

  THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA,
                           1940

                    WP(C).No. 3804 of 2019




PETITIONER:

              M/S.ANNAI INFRA DEVELOPERS PRIVATE LIMITED,
              REPRESENTED BY ITS MANAGING DIRECTOR - S.ASHOK
              KUMAR 7, IV FLOOR, SDS ENCLAVE, 2/5,
              PERUNDURAI ROAD, ERODE-638 011.

              BY ADVS.
              SRI.P.T.GEOTOM
              J.V.NIRANJAN




RESPONDENTS:

     1        STATE OF KERALA
              REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES
              DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM-
              695 001.

     2        THE COMMISSIONER OF COMMERCIAL TAXES
              TAX TOWER,KILLIPPALAM, KARAMANA P.O.,
              TRIVANDRUM-695 001.

     3        STATE TAX OFFICER
              WORKS CONTRACT, STATE GST (KERALA), PALAKKAD,
              PIN-678 001.
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                           ..4..


     4     THE CHIEF ENGINEER
           KERALA STATE RURAL ROADS DEVELOPMENT AGENCY,
           LOCAL SELF GOVERNMENT (RD) DEPARTMENT,
           GOVERNMENT OF KERALA, 3RD FLOOR, CSI BUILDING,
           PULIMOODU JUNCTION, TRIVANDRUM-695 001.

           BY ADV. GOVERNMENT PLEADER
           MM JASMINE GP


THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION
ON 21.03.2019, ALONG WITH WP(C).3843/2019,
WP(C).3917/2019, WP(C).3797/2019, THE COURT ON THE SAME
DAY DELIVERED THE FOLLOWING:
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                               ..5..


         IN THE HIGH COURT OF KERALA AT ERNAKULAM

                           PRESENT

      THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE

  THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA,
                           1940

                    WP(C).No. 3843 of 2019




PETITIONER:


              ANNAI INFRA DEVELOPERS PRIVATE LIMITED
              REP.BY ITS MANAGING DIRECOTR-S.ASHOK KUNAR, 7,
              IV FLOOR, SDS ENCAL,VE, 2/5.PERUNDURAI ROAD,
              ERODE-638 011

              BY ADVS.
              SRI.P.T.GEOTOM
              SRI.P.T.GEOTOM




RESPONDENTS:

     1        STATE OF KERALA
              REP.BY SECRETARY TO GOVERNMENT, TAXES
              DEPARTMENT,SECRETARIAT, THIRUVANANTHPAURAM-695
              001

     2        THE COMMISSIONER OF COMMERCIAL TAXES
              TAX TOWER, KILLIPPALAM, KARAMANA .P.O.,
              TRIVANDRUM-695 001

     3        STATE OF OFFICER
              WORKS CONTRACT,STATE GST (KERALA), PALAKKAD,
              PIN-678 001
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                           ..6..



     4     THE CHIEF ENGINEER.,
           KERALA STATE RURAL ROAD DEVELOPMENT AGENCY,
           LOCAL SELF GOVERNMENT (RD) DEPARTMENT,
           GOVERNMENT, OF KERALA, 3RD FLOOR, CSI
           BUILDING, PULI,MOODU JUNCTION, TRIVANDRAM-695
           001

           BY ADV. GOVERNMENT PLEADER
           MM JASMINE GP


THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION
ON 21.03.2019, ALONG WITH WP(C).3917/2019,
WP(C).3804/2019, WP(C).3797/2019, THE COURT ON THE SAME
DAY DELIVERED THE FOLLOWING:
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                            ..7..


         IN THE HIGH COURT OF KERALA AT ERNAKULAM

                         PRESENT

      THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE

  THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA,
                           1940

                  WP(C).No. 3917 of 2019




PETITIONERS:

           M/S.ANNAI INFRA DEVELOPERS
           PRIVATE LIMITED,
           REPRESENTED BY ITS MANAGING DIRECTOR - S.ASHOK
           KUMAR, 7, IV FLOOR, SDS ENCLAVE, 2/5,
           PERUNDURAI ROAD,
           ERODE 638 011.

           BY ADVS.
           SRI.P.T.GEOTOM
           SRI.P.T.GEOTOM




RESPONDENTS:

     1     STATE OF KERALA
           REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES
           DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM
           695 001.

     2     THE COMMISSIONER OF COMMERCIAL TAXES,
           TAX TOWER, KILLIPPALAM, KARMANA P.O.,
           TRIVANDRUM 695 001.

     3     STATE TAX OFFICER, WORKS CONTRACT, STATE GST
           (KERALA),
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                           ..8..


           PALAKKAD 678 001.

     4     THE CHIEF ENGINEER,
           KERALA STATE RURAL ROADS DEVELOPMENT AGENCY,
           LOCAL SELF GOVERNMENT (RD) DEPARTMENT,
           GOVERNMENT OF KERALA, 3RD FLOOR,
           CSI BUILDING, PULIMOODU JUNCTION,
           TRIVANDRUM 695 001.

           BY ADV. GOVERNMENT PLEADER
           MM JASMINE GP


THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION
ON 21.03.2019, ALONG WITH WP(C).3843/2019,
WP(C).3804/2019, WP(C).3797/2019, THE COURT ON THE SAME
DAY DELIVERED THE FOLLOWING:
 WP(C).NOs.3797/19,3804/19,3843/19&3917/19

                                       ..9..




                                JUDGMENT

These writ petitions are filed by Annai Infra Developers Pvt.Ltd., a company based in Erode, Tamil Nadu, engaged in road construction in Kerala. Petitioners challenged an assessment order in all these writ petitions from 2014 onwards. These all orders were passed ex-parte. Petitioners contention is that they were not received any notice. The learned Government Pleader filed a counter and produce acknowledgment. This would show that notice was received by the petitioners. However, the learned counsel for the petitioners disputes the signature therein.

2. Admittedly, the petitioners were registered dealers and filed returns disclosing the nil receipt. The assessment has now proceeded as though the work undertaken by the petitioners as work contract.

3. Considering the nature of the issue, I am of the view that the petitioners should be given an WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..10..

opportunity to explain the nature of work undertaken by them. There is no point in relegating the petitioners to invoke the appellate remedy , in the absence of any materials placed before the assessing authority to impress upon them the nature of work undertaken by them. In the interest of justice, it is appropriate that the petitioners should be given an opportunity to explain the nature of work. Hence, the impugned order is set aside. Petitioner is directed to appear before the assessing authority on 05.04.2019, at 11.am and thereafter, after adverting to the objections and materials produced by the petitioners. The proceedings shall be concluded within a period of two months.

The Writ Petition is disposed as above.

Sd/-

A.MUHAMED MUSTAQUE JUDGE PR/21.03.2019 WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..11..

APPENDIX OF WP(C) 3797/2019 PETITIONER'S EXHIBITS:

EXHIBIT P1 TRUE COPY OF THE CLASS-I CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT.
EXHIBIT P2 TRUE COPY THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENT.
EXHIBIT P3 THE AGREEMENT NO. 175/CE-KSRRDA/2014- 15 DATED 10TH DECEMBER, 2014 EXHIBIT P4 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 04.12.2014.

EXHIBIT P5 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 02.01.2009. EXHIBIT P6 TRUE COPY OF THE INVOICES OF THE GOODS PURCHASED WITH DEDUCTION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER-COMPANY IN STATE OF TAMILNADU.

EXHIBIT P7 TRUE COPY OF THE DEDUCTION OF VAT BY THE KERALA GOVERNMENT.

EXHIBIT P8 THE APPLICATION FOR CLARIFICATION FILED BY THE PETITIONER COMPANY DATED 27TH DECEMBER, 2014 EXHIBIT P9 THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION U/S. 94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL TAXES. EXHIBIT P10 TRUE COPY OF THE TAX APPEAL IN OTA 3 OF 2016 AND I.A. 465 OF 2016.

WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..12..

EXHIBIT P11 TRUE COPY OF THE INTERIM ORDER IN I.A. 465 OF 2016 DATED 30.03.2016 PASSED BY THIS HON'BLE COURT IN OTA 3 OF 2016 EXHIBIT P12 THE IMPUGNED ASSESSMENT ORDER NO.

32091691691195/2014-15 DATED 20.08.2018 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALAKKAD. EXHIBIT P13 TRUE COPY OF THE IMPUGNED DEMAND NOTICE NO. 88/18-19.

RESPONDENTS EXHIBITS:

EXHIBIT R3 A TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3 B TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3 C TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3 D TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3 E TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.
EXHIBIT R3 F TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.
EXHIBIT R3 G TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18.

WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..13..

EXHIBIT R3 H TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..14..

APPENDIX OF WP(C) 3804/2019 PETITIONER'S EXHIBITS:

EXHIBIT P1 TRUE COPY OF THE CLASS-I CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT.
EXHIBIT P2 TRUE COPY OF THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENT.
EXHIBIT P3 THE AGREEMENT NO.175/CE-KSRRDA/2014-15 DATED 10TH DECEMBER, 2014.
EXHIBIT P4 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 4.12.2015.
EXHIBIT P5 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 02.01.2009.
EXHIBIT P6 TRUE COPY OF THE INVOICES OF THE GOODS PURCHASED WITH DEDUCTION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER-COMPANY IN STATE OF TAMILNADU.
EXHIBIT P7 TRUE COPY OF THE DEDUCTION OF VAT BY THE KERALA GOVERNMENT.
EXHIBIT P8 THE APPLICATION FOR CLARIFICATION FILED BY THE PETITIONER-COMPANY DATED 27TH DECEMBER, 2014.
EXHIBIT P9 THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION U/S.94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL TAXES.
EXHIBIT P10 THE TAX APPEAL IN OTA 3 OF 2016 AND I.A. 465 OF 2016.
WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..15..
EXHIBIT P11 THE INTERIM ORDER IN I.A.465 OF 2016 DATED 30.3.2016 PASSED BY THIS HON'BLE COURT INOTA.3 OF 2016.
EXHIBIT P12 THE IMPUGNED ASSESSMENT ORDER NO.32091691195/2017-18 DATED 4.9.2018 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALAKKAD.
EXHIBIT P13 TRUE COPY OF THE IMPUGNED DEMAND NOTICE NO.107/18-19.
RESPONDENTS EXHIBITS:
EXHIBIT R3 A TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3 B TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3 C TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3 D TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3 E TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.
EXHIBIT R3 F TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.
EXHIBIT R3 G TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18.

WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..16..

EXHIBIT R3 H TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..17..

APPENDIX OF WP(C) 3843/2019 PETITIONER'S EXHIBITS:

EXHIBIT P1 TRUE COPY OF THE CLASS-1 CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT EXHIBIT P2 TRUE COPY OF THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENTS EXHIBIT P3 TRUE COPY OF THE AGREEMENT NO.175/CE-
KSRRDA/2014-15 DATED 10TH DECEMBER,2014 EXHIBIT P4 TRUE COPY OF THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 04.12.2014 EXHIBIT P5 TRUE COPY OF THE VAT REGISTRATION ISSUED BY THE TAMILNADU GOVERNMENT DATED 02.01.2009 EXHIBIT P6 TRUE COPY OF THE INVOICES OF THE GOODS PURCHASED WITH DEDUCTION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER-COMPANY IN STATE OF TAMILNADU EXHIBIT P7 TRUE COPY OF THE DEDUCTION OF VAT BY THE KERALA GOVERNMENT EXHIBIT P8 TRUE COPY OF THE APPLICATION FOR CLARIFICATION FIELD BY THE PETITIONER-

COMPANY DATED 27THG DECEMBER ,2014 EXHIBIT P9 TRUE COPY OF THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION, U/S.94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..18..

TAXES EXHIBIT P10 TRUE COPY OF THE TAX APPEAL IN OTA 3 OF 2016 EXHIBIT P11 TRUE COPY OF THE INTERIM ORDER IN I.A 465 OF 2016 DATED 30.03.2016 PASSED BY THIS HON'BLE COURT IN OTA 3 OF 2016 EXHIBIT P12 TRUE COPY OF THE IMPUGNED ASSESSMENT ORDER NO.32091691195/2015-16 DATED 20/8/18 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALAKKAD EXHIBIT P13 TRUE COPY OF THE IMPUGNED DEMAND NOTICE NO.85/18-19 RESPONDENTS EXHIBITS:

EXHIBIT R3(A) TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3(B) TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3(C) TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3(D) TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3(E) TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.
EXHIBIT R3(E) TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.

WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..19..

EXHIBIT R3(F) TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3(G) TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT R3(H) TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..20..

APPENDIX OF WP(C) 3917/2019 PETITIONER'S EXHIBITS:

EXHIBIT P1 TRUE COPY OF THE RELEVANT PAGES CLASS-
1, CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT.
EXHIBIT P2 TRUE COPY OF THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENT.
EXHIBIT P3 TRUE COPY OF THE AGREEMENT NO. 175/CE-
KSRRDA/2014-15 DATED 10TH DECEMBER, 2014.
EXHIBIT P4 TRUE COPY OF THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 4.12.2015.

EXHIBIT P5 TRUE COPY OF THE VAT REGISTRATION ISSUED BY THE TAMIL NADU GOVERNMENT DATED 2.1.2009.

EXHIBIT P6 TRUE COPY OF THE RELEVANT PAGE INVOICES OF THE GOODS PURCHASED WITH EDUCATION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER COMPANY IN STATE OF TAMILNADU.

EXHIBIT P7 TRUE COPY OF THE DEDUCTION OF VT BY THE KERALA GOVERNMENT.

EXHIBIT P8 TRUE COPY OF THE APPLICATION FOR CLARIFICATION FILED BY THE PETITIONER COMPANY DATED 27TH DECEMBER 2014. EXHIBIT P9 TRUE COPY OF THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION U/S. 94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..21..

TAXES.

EXHIBIT P10 TRUE COPY OF THE TAX APPEAL IN OTA 3 OF 2016 AND I.A. 465 OF 2016.

EXHIBIT P11 TRUE COPY OF THE INTERIM ORDER IN I.A. 465 OF 2016 DATED 30.3.2016 PASSED BY THIS HONBLE COURT IN OTA 3 OF 2016. EXHIBIT P12 TRUE COPY OF THE IMPUGNED ASSESSMENT ORDER NO. 32091691195/2016-17 DATED 4.9.2019 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALKKAD EXHIBIT P13 TRUE COPY OF THE IMPUGNED DEMAND NOTICE NO. 108/18-19.

RESPONDENTS EXHIBITS:

EXHIBIT R3 A TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3 B TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15.
EXHIBIT R3 C TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3 D TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16.
EXHIBIT R3 E TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.
EXHIBIT R3 F TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17.

WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..22..

EXHIBIT R3 G TRUE COPY OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT R3 H TRUE COPY OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18.