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Karnataka High Court

Sbicap Trustee Company Ltd vs Tax Recovery Officer on 16 October, 2017

Author: Vineet Kothari

Bench: Vineet Kothari

                            1/9




IN THE HIGH COURT OF KARNATAKA, BENGALURU

   DATED THIS THE 16th DAY OF OCTOBER, 2017

                         BEFORE

    THE HON'BLE Dr.JUSTICE VINEET KOTHARI

REVIEW PETITION Nos.372 OF 2017 & 466-478 OF 2017
                       IN
         WRIT PETITION No.19725/2014 &
    WRIT PETITION Nos.30764-30776/2014 (T-IT)

Between:

1. SBICAP Trustee Company Ltd.
   No.8, 5th Floor, Khetan Bhavan
   198 Jamshedji Tata Road,
   Churchgate, Mumbai - 400 020

   Represented by Authorized Officer
   Mr. R. Lakshminarayana Rao

2. State Bank of India
   A Banking corporation constituted
   Under the State Bank of India Act,
   1955 (23 of 1955)
   Having its Corporate Centre at
   State Bank Bhavan
   Madame Cama Road
   Nariman Point
   Mumbai - 400 021

   And having its Stressed Asset
   Management Branch at,
   2nd Floor, Office Complex
   Building, Local Head Office
   Compound, #65, ST. Marks
   Road, Bengaluru-560001.
                                             Date of Order:16-10-2017
                                   R.P.Nos.372/2017 & 466-478/2017
                           SBICAP Trustee Company Ltd. & Others. Vs.
                                      Tax Recovery Officer & Others.

                           2/9


3. Axis Bank Limited,
   A Company incorporated under the
   Companies Act, 1956 and
   A banking company within the
   Meaning of Section 5(c) of the
   Banking Regulation Act, 1949 and
   Having its registered office at
   Trishul, Third Floor
   Opp. Samartheswar Temple
   Law Garden, Ellisbridge
   Ahmedabad 380 006
   Gujarat, India

  And having its corporate office at
  Axis House, C-2, Wadia International Centre
  Pandurang Budhkar Marg
  Worli, Mumbai - 400 025

4. Bank of Baroda
   A body corporate under the
   Banking Companies (Acquisition and
   Transfer of Undertaking) Act, 1970
   (5 of 1970)
   Having its head office at
   Baroda House
   P.B.No.506, Mandavi
   Vadodara - 396 006.

  Acting through its Branch
  Office at P.O.Box 11745
  Samata Building
  General Bhosale Marg
  Nariman Point, Mumbai -400 021

5. Corporation Bank
   A body corporate under
   Banking Companies (Acquisition and
   Transfer of Undertaking) Act, 1980
   (40 of 1980) Having its
                                                Date of Order:16-10-2017
                                      R.P.Nos.372/2017 & 466-478/2017
                              SBICAP Trustee Company Ltd. & Others. Vs.
                                         Tax Recovery Officer & Others.

                             3/9

   Corporate office at
   Mangaladevi Temple Road
   Pandeshwar, Mangalore - 575 001

   And having its Industrial Finance Branch
   at Rallaram Memorial Bldg.
   1st Floor, CSI Compound
   Mission Road, Bengaluru - 560 027

6. The Federal Bank Limited
   A Company within the
   Meaning of the Companies Act, 1956
   Having its registered office at Federal Towers
   Aluva - 683 101, Kerala

   And having its branch office at
   St. Marks Road, 9
   Halcyon Complex
   St. Marks Road
   Bengaluru - 560 001

7. IDBI Bank Limited
   A company incorporated
   Under the Companies Act, 1956 and
   A banking company within the
   Meaning of the Banking Regulation
   Act, 1949, having its head office at
   IDBI Tower, WTC Complex
   Cuffe Parade, Mumbai - 400 005
   Maharashtra, India

   And acting through its branch
   Office at Corporate Banking
   Group-FAMG
   9th Floor, IDBI Tower
   WTC Complex, Cuffe Parade,
   Colaba, Mumbai - 400 005

8. Indian Overseas Bank
   A body corporate under the
                                               Date of Order:16-10-2017
                                     R.P.Nos.372/2017 & 466-478/2017
                             SBICAP Trustee Company Ltd. & Others. Vs.
                                        Tax Recovery Officer & Others.

                            4/9

  Banking Companies (Acquisition
  And Transfer of Undertaking) Act, 1970
  Having its central office at
  763, Anna Salai
  Chennai - 600 002

  And its branch office at
  'Harikripa', 26-A, S.V.Road
  Santacruz (W), Mumbai-400 054

9. Punjab & Sind Bank
   A body corporate under
   Banking Companies (Acquisition and
   Transfer of undertaking) Act, 1980
   Having its Head Office at 21
   Rajendra Place, New Delhi - 110 008

  And having amongst others
  A branch office at
  J.K.Somani Building
  British Hotel Lane
  Fort, Mumbai - 400 023

10.   Punjab National Bank
      A body corporate under the
      Banking Companies
      (Acquisition and Transfer of
      Undertaking) Act, 1970 (5 of 1970)
      Having its head office at 7
      Bhikaji Cama Place
      New Delhi - 110 607

      Acting through its large
      corporate Branch at
      Centenary Building, 28,
      M.G.Road, Bengaluru - 560 001

11.   State Bank of Mysore
      A body corporate constituted
      Under the State Bank of India
                                               Date of Order:16-10-2017
                                     R.P.Nos.372/2017 & 466-478/2017
                             SBICAP Trustee Company Ltd. & Others. Vs.
                                        Tax Recovery Officer & Others.

                             5/9

   (Subsidiary Banks) Act, 1959
   Having its head office at
   Kempe Gowda Road
   Bengaluru - 560 009

   And its corporate Accounts Branch
   At No.18, Ramanashree Arcade
   M.G.Road, Bengaluru - 560 001

12. UCO Bank
   A body corporate constituted
   Under the Banking Companies
   (Acquisition and Transfer of
   Undertakings) Act, 1970 and having
   Its head office at 10
   BTM Sarani, Kolkata - 700 001
   West Bengal, India

   And its Branch office at
   1st Floor, 13/22, K.G.Road
   Bengaluru - 560 009

13. United Bank of India
   A body corporate under the
   Banking Companies (Acquisition and
   Transfer of undertakings) Act, 1970
   (5 of 1970) having its head office at
   11, Hemanta Basu Sarani
   Kolkata - 700 001

   Acting through its branch office
   At 40, K.G.Road, Bengaluru - 560 009

14. J.M.Financial Asset
   Reconstruction Co. Pvt. Ltd.
   Having its registered office at
   7th Floor, Cnergy
   Appasaheb Marathe Marg
   Prabhadevi, Mumbai - 400 025
   (Inserted as per Order dated 26.08.2015)
                                                Date of Order:16-10-2017
                                      R.P.Nos.372/2017 & 466-478/2017
                              SBICAP Trustee Company Ltd. & Others. Vs.
                                         Tax Recovery Officer & Others.

                             6/9


   Petitioner Nos.2 to 14
   Represented by:

   Mr. Debasish Bhattacharjee,
   Age 54 years,
   S/o. Late Sukumar,
   Assistant General Manager &
   Case Lead Officer-6,
   State Bank of India, having its
   Stressed Asset Management
   Branch, 2nd Floor,
   Office Complex Building,
   Local Head Office Compound,
   #65, St. Marks Road,
   Bengaluru-560001.
                                                      ...Petitioners
(By Mr. S.S.Naganand, Sr. Counsel for
    Mr. Shrikara P.K., Advocate)

And

1. Tax Recovery Officer
   Office of the Tax Recovery Officer
   Range 18, 4th Floor, No.59
   HMT Bhavan, Bellary Road
   Bengaluru - 560 032

2. Deputy Commissioner of Income Tax
   Circle 16(2), HMT Bhavan
   Bellary Road, Bengaluru - 560 032

3. Assistant Commissioner of Income Tax(TDS)
   HMT Bhavan, Bellary Road,
   Bengaluru - 560 032

4. Commissioner of Income Tax
   Office of the Commissioner of Income Tax
   4th Floor, HMT Bhavan No.59,
   Bellary Road, Bengaluru - 560 032
                                                   Date of Order:16-10-2017
                                         R.P.Nos.372/2017 & 466-478/2017
                                 SBICAP Trustee Company Ltd. & Others. Vs.
                                            Tax Recovery Officer & Others.

                                 7/9


5. Union of India
   Department of Revenue
   Ministry of Finance
   Government of India
   New Delhi - 110 001

6. Kingfisher Airlines Limited
   A public limited company
   Incorporated under the
   Companies Act, 1956 &
   Having its registered office at
   UB Tower, Level 12
   UB City, 24, Vittal Mallya Road
   Bengaluru - 560 001                                ...Respondents

(By Mr. K.V.Aravind, Advocate for R1 to R5)


       These Review Petitions are filed under Order 47 Rule 1
of CPC, praying to review the order dated 06.07.2017 passed
in W.P.No.19725/2014 & W.P.Nos.30764-30776/2014 on
the file of the Hon'ble High Court of Karnataka, Bengaluru.

      These Review Petitions coming on for Admission this
day, the Court made the following:-

                              ORDER

Mr. S.S.Naganand, Sr. Counsel for Mr. Shrikara P.K., Adv. for Petitioners Mr. K.V.Aravind, Adv. for Respondents.

1. The learned counsels at the Bar fairly submitted that the issue involved in these Writ Petitions which were disposed of by the order dated 06/07/2017 Date of Order:16-10-2017 R.P.Nos.372/2017 & 466-478/2017 SBICAP Trustee Company Ltd. & Others. Vs. Tax Recovery Officer & Others.

8/9 was really between the Secured Creditors, SBICAP Trustee Company Ltd., etc., the present Review Petitioners before the Court and the issue involved was relating to the Service Tax Liability and Income Tax Liability as to whether the Income Tax liability and Service Tax Liability of the Company ordered to be wound up on 18/11/2016 namely, Kingfisher Airlines Limited (KFAL) would take precedence over the Secured Creditors, the present petitioners or not, since the Secured Creditors were standing out of the liquidation.

2. In view of this, the order passed by this Court dated 06/07/2017, dismissing these writ petitions as not surviving for consideration in view of the winding up order passed by this Court in respect of Kingfisher Airlines Limited (KFAL) on 18/11/2016 deserves to be recalled and the present Writ Petitions deserve to be decided on their own merits.

Date of Order:16-10-2017 R.P.Nos.372/2017 & 466-478/2017 SBICAP Trustee Company Ltd. & Others. Vs. Tax Recovery Officer & Others.

9/9

3. The said order dated 06/07/2017 dismissing the Writ Petition No.19725/2014 & W.P.Nos.30764- 30776/2014 c/w. W.P.No.19727/2014 (SBICAP Trustee Company Limited and others Vs. Tax Recovery Officer and others) is accordingly recalled.

3. The said Writ Petitions are restored to their original Numbers and position.

4. The learned counsel for the review petitioners prays for hearing of the said Writ Petitions after a period of four weeks.

5. Post the said Writ Petitions after four weeks, as prayed.

6. Accordingly, the present Review Petitions stand disposed of.

Sd/-

JUDGE BMV*