Madras High Court
M/S.Sahana Jewellery Exports Private ... vs Income Tax Officer on 21 August, 2020
Author: Anita Sumanth
Bench: Anita Sumanth
W.P. Nos.7136, 7155 & 7411 of 2020
and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 21.08.2020
CORAM
THE HONOURABLE DR. JUSTICE ANITA SUMANTH
W.P. Nos.7136, 7155 & 7411 of 2020
and WMP.Nos.8505, 8506, 13817, 8535, 8536,
13914, 8874, 8875 & 13782 of 2020
M/s.Sahana Jewellery Exports Private Limited,
Represented by its Managing Director D.R.Ragunath
600, Raja Street, Coimbatore
Coimbatore 641 001. .. Petitioner in WP.No.7136/2020
DAR Paradise Private Limited
Rep. by its Director D.R.Ragunath 599 Raja Street,
Coimbatore Coimbatore 641001. .. Petitioner in WP.No.7155/2020
Tara Jewellery
Rep. by its Partner Paras K.Soni
61 West Bashyakarula Road, R.S.Puram,
Coimbatore 641 002. .. Petitioner in WP.No.7411/2020
Vs.
Income Tax Officer
Corporate Ward 3, Coimbatore
63 Race Course Road Coimbatore 641 018.
.. 1st Respondent in WP.7136/2020
Deputy Commissioner of Income Tax Corporate Circle 2
63 Race Course Road,
Coimbatore 641018. .. 1st Respondent in WP.7155/2020
Assistant Commissioner of Income Tax,
Non Corporate Circle 2
63, Race Course Road Coimbatore 641 018.
.. 1st Respondent in WP.7411/2020
http://www.judis.nic.in
1
W.P. Nos.7136, 7155 & 7411 of 2020
and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
Principal Commissioner of Income Tax 1,
63 Race Course Road, Coimbatore 641 018.
.. 2nd Respondent in all WPs
Prayer in WP.No.7136 of 2020: Writ Petition filed under Article 226 of the
Constitution of India praying Writ of Certiorari to call for the records on the
file of the First Respondent relating to the application made by the Petitioner
for stay of demand for the assessment year 2016-17 and quash the order of the
First Respondent in PAN AAECS7045N in DIN Letter No. ITBA / COM / F /
17 / 2019-20 / 1024361388(1) dated 28.01.2020 for the Assessment year 2016-
17 along with the consequential order of the Second Respondent dated
09.03.2020 in C No. 117 / PCIT-1 / CBE / AAECS7045N / 2019-20 and direct
the First Respondent to not to treat the petitioner as an assessee in default
pending disposal of the appeal file by the petitioner before the Commissioner of
Income Tax (Appeals) Coimbatore.
Prayer in WP.No.7155 of 2020: Writ Petition filed under Article 226 of the
Constitution of India praying to Writ of Certiorari to call for the records on the
file of the 1st respondent relating to the application made by the petitioner for
the assessment year 2016 -17 and quash the order of the 1st respondent in PAN
AAFCD 3066 P in DIN and Letter No.ITBA / COM / F/17/2019 -20
/1024477226 (1) dated 30/01/2020 for the Assessment Year 2017 -18 along
with the consequential order of the Second Respondent dated 09.03.2020 in C
No 117/PCIT-1/CBE/AAFCD3066P/2019-20 and direct the 1st respondent not
to treat the petitioner as an assessee in default pending disposal of the appeal
filed by the petitioner before the commissioner of Income Tax (Appeals)
Coimbatore.
http://www.judis.nic.in
2
W.P. Nos.7136, 7155 & 7411 of 2020
and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
Prayer in WP.No.7411 of 2020: Writ Petition filed under Article 226 of the
Constitution of India praying to Writ of Certiorari to call for the records on the
file of the First Respondent relating to the application made by the petitioner
for stay of demand for the assessment year 2017-18 and quash the order of the
First Respondent in PAN AAGFT2345B in DIN and Letter No. ITBA/ COM/
F/ 17/ 2019-20/ 1024859545 (1) dated 07.02.2020 for the Assessment year
2017- 18 along with the consequential order of the second Respondent dated
09.03.2020 in C.No. 117/ PCIT -1/ CBE/ AAGFT2345B/ 2019-20 and direct
the First Respondent not to treat the Petitioner as an assessee in default
pending disposal of the appeal filed by the Petitioner before the commissioner
of Income Tax (appeals) Coimbatore.
(Prayers amended vide order dated 21.08.2020 in WMP Nos.13817. 13914 and
13782 of 2020).
For Petitioner : Mr.N.V.Balaji
For Respondent s : Mr.ANR Jayapratap,
Standing Counsel
COMMON ORDER
For the reasons stated in the affidavit filed in support of the Miscellaneous Petitions filed seeking amendment of prayer in the Writ Petitions and there being no objection to the same by Mr.ANR.Jayapratap, learned Standing Counsel for the respondents, WMP Nos.13817, 1394 and 13782 of 2020 are ordered.
http://www.judis.nic.in 3 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
2. Heard Mr.N.V.Balaji, learned counsel for the petitioner and Mr.ANR.Jayaprathap, learned Standing Counsel for the respondents. By consent expressed by both learned counsel these matters are taken up for final disposal.
3. The petitioners challenge orders passed by the Assessing Officer and by the Principal Commissioner of Income Tax rejecting applications for stay of demand arising from the disputed orders of assessment passed under the provisions of the Income Tax Act, 1961 (in short ‘Act’).
4. A perusal of the impugned orders would show that the orders are non-
speaking and merely call upon the petitioners to remit 20% of the disputed taxes without reference to the tri-fold aspects of prima facie case, financial stringency and balance of convenience. In fact, I have in order dated 13.07.2019 in W.P.No.3849 of 2019 considered a similar position and have passed the following order:
7. The parameters to be taken into account in consideringthe grant of stay of disputed demand are well settled – theexistence of a prima facie case, financial stringency and thebalance of convenience. ‘Financial stringency’ would include withinits ambit the question of 'irreparable injury' and ‘undue hardship’as well. It is only upon an application of the three factors asaforesaid that the assessing officer can exercise discretion for thegrant or rejection, wholly or in part, of a request for stay ofdisputed demand.
8. In addition, periodic Instructions/Circulars in regard to themanner of adjudication of stay petitions are issued by the CentralBoard of Direct Taxes (CBDT) for the guidance of the Departmentalauthorities.
The one oft-quoted by the assessee is OfficeMemorandum F.No.1/6/69/- ITCC, dated 21.08.1969 that states as follows:
http://www.judis.nic.in 4 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 '1. One of the points that came up for considerationin the 8th Meeting of the Informal ConsultativeCommittee was that income-tax assessments wereoften arbitrarily pitched at higher figures and thatthe collection of disputed demand as a result thereofwas also not stayed in spite of the specific provisionin the matter in s. 220(6) of the IT Act, 1961.
2. The then Deputy Prime Minister had observed asunder :
".........Where the income determined on assessmentwas substantially higher than the returned income,say twice the latter amount or more, the collectionof the tax in dispute should be held in abeyance tillthe decision on the appeal provided there were nolapses on the part of the assessees."
3. The Board desire that the above observations maybe brought to the notice of all the Income-taxOfficers working under you and the powers of stayof recovery in such cases up to the stage of firstappeal may be exercised by the Inspecting AssistantCommissioner/Commissioner of Income-tax.
9. Thereafter, Instruction No.1914 was issued bythe CBDT on 21.03.1996 and states as follows:
1. Recovery of outstanding tax demands [Instruction No. 1914 F. No. 404/72/93 ITCC dated 2-12-1993 from CBDT] The Board has felt the needfor a comprehensive instruction on the subject of recovery of tax demand in order to streamlinerecovery procedures. This instruction is accordinglybeing issued in supersession of all earlierinstructions on the subject and reiterates theexisting Circulars on the subject.
2. The Board is of the view that, as a matter ofprinciple, every demand should be recovered assoon as it becomes due. Demand may be kept inabeyance for valid reasons only in accordance withthe guidelines given below :
A. Responsibility:
i. It shall be the responsibility of the AssessingOfficer and the TRO to collect every demand thathas been raised, except the following: http://www.judis.nic.in
(a) Demandwhich has not fallen due;5
W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
(b) Demand which hasbeen stayed by a Court or ITAT or SettlementCommission;
(c)Demand for which a proper proposal for write- off has been submitted;
(d) Demand stayed inaccordance with paras B & C below.
ii. Where demand in respect of which a recoverycertificate has been issued or a statement has beendrawn, the primary responsibility for the collectionof tax shall rest with the TRO. iii. It would be the responsibility of the supervisoryauthorities to ensure that the Assessing Officersand the TROs take all such measures as arenecessary to collect the demand. It must beunderstood that mere issue of a show cause noticewith no followup is not to be regarded as adequateeffort to recover taxes.
B. Stay Petitions:
i. Stay petitions filed with the Assessing Officersmust be disposed of within two weeks of the filing ofpetition by the tax- payer. The assessee must beintimated of the decision without delay. ii. Where stay petitions are made to the authoritieshigher than the Assessing Officer (DC/CIT/CC), it isthe responsibility of the higher authorities todispose of the petitions without any delay, and inany event within two weeks of the receipt of the petition. Such a decision should be communicated tothe assessee and the Assessing Officer immediately.
iii. The decision in the matter of stay of demandshould normally be taken by Assessing Officer/TROand his immediate superior. A higher superiorauthority should interfere with the decision of theAO/TRO only in exceptional circumstances; e.g., where the assessment order appears to beunreasonably high-pitched or where genuinehardship is likely to be caused to the assessee. Thehigher authorities should discourage the assesse from filingreview petitions before them as a matterof routine or in a frivolous manner to gain time forwithholding payment of taxes. C. Guidelines for staying demand:
i. A demand will be stayed only if there are http://www.judis.nic.in validreasons for doing so. Mere filing an appeal 6 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 againstthe assessment order will not be a sufficient reasonto stay the recovery of demand. A few illustrativesituations where stay could be granted are:
It is clarified that in these situations also, stay maybe granted only in respect of the amountattributable to such disputed points. Further whereit is subsequently found that the assessee has notco-operated in the early disposal of appeal or wherea subsequent pronouncement by a higher appellateauthority or court alters the above situation, thestay order may be reviewed and modified. Theabove illustrations are, of course, not exhaustive.
ii. In granting stay, the Assessing Officer mayimpose such conditions as he may think fit. Thus hemay — a. require the assessee to offer suitablesecurity to safeguard the interest of revenue; b.require the assessee to pay towards the disputedtaxes a reasonable amount in lump sum or ininstalments; c. require an undertaking from theassessee that he will co-operate in the earlydisposal of appeal failing which the stay order willbe cancelled. d. reserve the right to review theorder passed after expiry of a reasonable period,say up to 6 months, or if the assessee has not cooperatedin the early disposal of appeal, or where asubsequent pronouncement by a higher appellateauthority or court alters the above situations;
e. reserve a right to adjust refunds arising, if any,against the demand.
iii. Payment by instalments may be liberally allowedso as to collect the entire demand within areasonable period not exceeding 18 months. iv. Since the phrase “stay of demand” does not occurin section 220(6) of the Income-tax Act, theAssessing Officer should always use in any orderpassed under section 220(6) [or under section220(3) or section 220(7)], the expression thatoccurs in the section viz., that he agrees to treat theassessee as not being default in respect of theamount specified, subject to such conditions as hedeems fit to impose.
v. While considering an application under section220(6), the Assessing Officer should consider allrelevant factors having a bearing on http://www.judis.nic.in 7 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 the demandraised and communicate his decision in the form ofa speaking order.
D. Miscellaneous:
i. Even where recovery of demand has been stayed,the Assessing Officer will continue to review thesituation to ensure that the conditions imposed arefulfilled by the assessee failing which the stay orderwould need to be withdrawn. ii. Where the assessee seeks stay of demand fromthe Tribunal, it should be strongly opposed. If theassessee presses his application, the CIT shoulddirect the departmental representative to requestthat the appeal be posted within a month so thatTribunal’s order on the appeal can be known withintwo months.iii. Appeal effects will have to be givenwithin 2 weeks from the receipt of the appellateorder. Similarly, rectification application should bedecided within 2 weeks of the receipt t hereof.Instances where there is undue delay in giving effectto appellate orders, or in deciding rectificationapplications, should be dealt with very strictly bythe CCITs/CITs.
3. The Board desires that appropriate action istaken in the matter of recovery in accordance withthe above procedure. The Assessing Officer or theTRO, as the case may be, and his immediatesuperior officer shall be held responsible forensuring compliance with these instructions.
4. This procedure would apply mutatis mutandis todemands created under other Direct Taxesenactments also.'
10. Instruction 1914 was partially modified by OfficeMemorandum dated 29.02.2016 taking into account the fact thatAssessing Officers insisted on payment of significant portions of thedisputed demand prior to grant of stay resulting in extremehardship for tax payers. Thus, in order to streamline the grant ofstay and standardize the procedure, modified guidelines wereissued which are as follows:
'.......
(A) In a case where the outstanding demand is disputedbefore CIT (A), the assessing officer shall grant stay ofdemand till disposal of first appeal on payment of 15% of the disputed demand, unless the case falls in the categorydiscussed in pars (B) hereunder. http://www.judis.nic.in (B) In a situation where, 8 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
(a) the assessing officer is of the view that the nature ofaddition resulting in the disputed demand is such thatpayment of a lump sum amount higher than 15% is warranted (e.g. in a case where addition on the same issuehas been confirmed by appellate authorities in earlier yearsor the decision of the Supreme Court /or jurisdictional HighCourt is in favour of Revenue or addition is based oncredible evidence collected in a search or survey operation,etc.) or,
(b) the assessing officer is of the view that the nature ofaddition resulting in the disputed demand is such thatpayment of a lump sum amount lower than 15% iswarranted (e.g. in a case where addition on the same issuehas been deleted by appellate authorities in earlier years orthe decision of the Supreme Court or jurisdictional HighCourt is in favour of the assessee, etc.), the assessingofficer shall refer the matter to the administrative Pr. CIT/CIT, who after considering all relevant facts shall decidethe quantum/ proportion of demand to be paid by theassessee as lump sum payment for granting a stay of thebalance demand.'
11. Instruction 1914 was further modified by OfficeMemorandum bearing number F.No.404/72/93 – ITCC dated 31.07 2017 as follows:
'OFFICE MEMORANDUM F. No. 404/72/93- ITCC dated 31.07.2017 Subject: Partial modification of Instruction No. 1914 dated 21.3.1996 to provide for guidelines for stay of demand at the first appeal stage.
Reference: Board’s O.M. of even number dated 29.2.2016Instruction No. 1914 dated 21.3.1996 contains guidelinesissued by the Board regarding procedure to be followed forrecovery of outstanding demand, including procedure forgrant of stay of demand.
Vide O.M. N0.404/72/93-ITCC dated 29.2.2016 revisedguidelines were issued in partial modification of instructionNo 1914, wherein, inter alia, vide para 4(A) it had been laiddown that in a case where the outstanding demand isdisputed http://www.judis.nic.in before CIT(A), the Assessing Officer shall 9 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 grantstay of demand till disposal of first appeal on payment of15% of the disputed demand unless the case falls in thecategory discussed in para (B) thereunder. Similarreferences to the standard rate of 15% have also beenmade in succeeding paragraphs therein.
2. The matter has been reviewed by the Board in the lightof feedback received from field authorities. In view of theBoard’s efforts to contain over pitched assessments through several measures resulting in fairer and morereasonable assessment orders, the standard rate of 15% ofthe disputed demand is found to be on the lower side.
Accordingly. it has been decided that the standard rateprescribed in O.M. dated 29.2.2016 be revised to 20% ofthe disputed demand, where the demand is contested before CIT(A). Thus all references to 15% of the disputeddemand in the aforesaid O.M dated 29.2.2016 hereby standmodified to 20% of the disputed demand. Other guidelinescontained in the O.M. dated 29.2.2016 shall remainunchanged. These modifications may be immediately brought to thenotice of all officers working in your jurisdiction for proper compliance.'
12. The Circulars and Instructions as extracted above are in thenature of guidelines issued to assist the assessing authorities in thematter of grant of stay and cannot substitute or override the basictenets to be followed in the consideration and disposal of staypetitions. The existence of a prima facie case for which someillustrations have been provided in the Circulars themselves, thefinancial stringency faced by an assessee and the balance ofconvenience in the matter constitute the ‘trinity’, so to say, and areindispensable in consideration of a stay petition by the authority.
The Board has, while stating generally that the assessee shall becalled upon to remit 20% of the disputed demand, granted amplediscretion to the authority to either increase or decrease thequantum demanded based on the three vital factors to be takeninto consideration.
13. In the present case, the assessing officer has merelyrejected the petition by way of a non-speaking order reading asfollows:
'Kindly refer to the above. This is to inform you that merefiling of appeal against the said order is not a ground forstay of the demand. Hence your request for stay of demandis rejected and you are requested to pay the demandimmediately. Notice u/s.221(1) of the Income Tax Act, 1961is enclosed http://www.judis.nic.in herewith.' 10 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
14. The disposal of the request for stay by the petitioner leavesmuch to be desired. I am of the categoric view that the AssessingOfficer ought to have taken note of the conditions precedent for thegrant of stay as well as the Circulars issued by the CBDT andpassed a speaking order. Of course the petition seeking stay filedby the petitioner is itself cryptic. However, as noted by theSupreme Court in the case of Commissioner of Income tax vsMahindra Mills, ((2008) 296 ITR 85 (Mad)) in the context of grantof depreciation, the Circular of the Central Board of Revenue (No.14 (SL- 35) of 1955 dated April 11, 1955) requires the officers ofthe department ‘to assist a taxpayer in every reasonable way,particularly in the matter of claiming and securing reliefs. ....Although, therefore, the responsibility for claiming refunds andreliefs rests with the assessees on whom it is imposed by law, officersshould draw their attention to any refunds or reliefs to which theyappear to be clearly entitled but which they have omitted to claim forsome reason or other......’. Thus, notwithstanding that the assesse may not have specifically invoked the three parameters for thegrant of stay, it is incumbent upon the assessing officer to examinethe existence of a prima facie case as well as call upon theassessee to demonstrate financial stringency, if any and arrive atthe balance of convenience in the matter.
15. I thus set aside impugned order dated 25.01.2019. TheAssessing Officer is directed to pass orders de novo on the stayapplication filed by the petitioner in the light of the discussion asaforesaid, after hearing the petitioner, within a period of fourweeks from date of receipt of a copy of this Order. I have, for theaforesaid reason, consciously and deliberately refrained fromreferring to or making any observation on the merits of theassessment.
5. In the present matters, a sample of the impugned orders (W.P.No.7136 of 2020) are extracted below to show the cursory manner in which the stay applications have been disposed.
‘GOVERNMENT OF INDIA MINISTRY OF FINANCE INCOME TAX DEPARTMENT OFFICE OF THE INCOME TAX OFFICER CORP WARD 3, CBE TO SAHANA JEWELLERY EXPORTS PRIVATE LIMITED http://www.judis.nic.in 11 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 SAHANA JEWELLERY EXPORTS PRIVATE LIMITED, 600, RAJA STREET, COIMBATORE 641 001, Tamil Nadu India PAN: Assessment Dated: DIN & Letter No:
AAECS7045N Year: 28/01/2020 ITBA/COM/F/17/2019-
2016-17 20/ 1024361388(1)
Sir/Madam/M/s.
Subject: Payment of outstanding tax-PAN: AAECS7045N-AY 2016-17- Regarding Ref: Your petition dated 27-01-2020 Your petition regarding stay of recovery of disputed tax and the case laws quoted by you are perused. However as per the Boards instruction no.1914, which is modified by Para 2 of the OM dated 31/07/2017 stay of disputed demand be granted if 20% of the same is paid and stay requested. Hence your request for permanent stay of recovery of disputed tax till the disposal of first appeal by the Commissioner of Income Tax (Appeal), Coimbatore is hereby rejected. You are requested to pay 20% of the demand outstanding immediately and file a fresh petition for the stay balance demand to avoid coercive action.
SILUVAI ANTHONY JOSEPHINE MARY CORP WARD 3, CBE GOVERNMENT OF INDIA OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX-1 NO 63, RACE COURSE, COIMBATORE-641 018 C.No.117/PCII-I/CBE/AAECS7045N/2019-20 Dated:
09/03/2020 PROCEEDINGS OF THE PRINCIPAL COMMISSIONEROF INCOME TAX-1 COIMBATORE Present: Shri G.R.Reddy, http://www.judis.nic.in Principal Commissioner of Income Tax-1 12 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 Coimbatore Sub: Stay of payment of tax – in the case of Sahana Jewellery Exports Private Limited, 600 Raja Street, Coimbatore – 641 001 – AY:2016-17 – PAN : AAECS7045N – Reg.
Ref: Assessee’s Petition dated 31/01/2020 ********** ORDER:
The aforesaid assessee has filed a petition dated 31/01/2020 requesting to grant stay of demand which was raised by the Assessing Officer vide order dated 30/12/1999 passed u/s 143(3) of the Income Tax Act 1961 for the assessment year 2016-17.
2.0 The assessee’s stay petition, facts of the case and the assessment records have been carefully perused. Considering the facts of the case and in view of Instruction No.1914 issued by Central Board of Direct Taxes (CBDT) dated 31/07/2017, the assessee is directed to remit 20% of the demand raised within 5 days from the date of receipt of this order. The Assessing Officer shall monitor the payment of 20% of the disputed demand and thereafter, stay the balance 80% of the disputed demand till disposal of appeal by the Commissioner of Income Tax (Appeals), Coimbatore.
3.0 The petition of the assessee stands disposed accordingly.
(G.R.REDDY) Pr. Commissioner of Income Tax-1 Coimbatore
6. Evidently, the matter needs more application of mind than what is seen above. In the aforesaid circumstances, the impugned orders are set aside.
Orders shall be passed afresh by the 2nd respondent after hearing the petitioners either virtually or by way of a physical hearing as may be mutually convenient to the parties within a period of six (6) weeks from date of uploading of this order. Till such time, recovery proceedings are kept in abeyance.
http://www.judis.nic.in 13 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020
7. These Writ Petitions are disposed as above. No costs. Connected Miscellaneous Petitions are closed.
21.08.2020 Sl Index:Yes/No Speaking order/Non-speaking order Note: Registry is directed to upload this order today.
To
1.Income Tax Officer Corporate Ward 3, Coimbatore 63 Race Course Road Coimbatore 641 018.
2.Deputy Commissioner of Income Tax Corporate Circle 2 63 Race Course Road, Coimbatore 641018.
3.Assistant Commissioner of Income Tax, Non Corporate Circle 2 63, Race Course Road Coimbatore 641 018.
4.Principal Commissioner of Income Tax 1, 63 Race Course Road, Coimbatore 641 018.
http://www.judis.nic.in 14 W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 Dr.ANITA SUMANTH, J.
sl W.P. Nos.7136, 7155 & 7411 of 2020 and WMP.Nos.8505, 8506, 13817, 8535, 8536, 13914, 8874, 8875 & 13782 of 2020 21.08.2020 http://www.judis.nic.in 15