Kerala High Court
Akshay Kishor Sali vs State Of Kerala on 17 March, 2025
Author: V.G.Arun
Bench: V.G.Arun
Crl.MC.No.1003/23 & con.cases
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 1003 OF 2023
CRIME NO.RC 0342023E0002/2023 OF CBCID, THIRUVANANTHAPURAM,
Thiruvananthapuram
PETITIONERS:
1 RAJAN KOYOTH VEETTIL SIDHARTH,
AGED 32 YEARS
S/O. K.V. RAJAN,LIEUTENANT COMMANDER, NAVAL PAY
OFFICE, MUMBAI,INDIAN NAVAL ACADAMY, EZHIMALA,
KANNUR, PIN - 670310
2 NISHANT SINGH POSWAL,
AGED 32 YEARS
S/O. LATE KANWAR PAL VERMA,LIEUTENANT
COMMANDER,NAVAL PAY OFFICE, MUMBAI,INDIAN NAVAL
ACADAMY, EZHIMALA, KANNUR, PIN - 670310
3 SUMIT SINGH,
AGED 31 YEARS
S/O. NAIB SINGH,LIEUTENANT COMMANDER,NAVAL PAY
OFFICE, MUMBAI,INDIAN NAVAL ACADAMY, EZHIMALA,
KANNUR, PIN - 670310
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4 ROSHAN KUMAR SINGH,
AGED 32 YEARS
S/O. BINOD KUMAR SINGH,LIEUTENANT COMMANDER,NAVAL
PAY OFFICE, MUMBAI,INDIAN NAVAL ACADAMY,
EZHIMALA, KANNUR, PIN - 670310
5 . RAJKUMAR SHARMA,
AGED 31 YEARS
S/O. PARSHOTAM DAS,LIEUTENANT COMMANDER,NAVAL PAY
OFFICE, MUMBAI,INDIAN NAVAL ACADAMY, EZHIMALA,
KANNUR, PIN - 670310
6 PAWAN SINGH RATHORE,
AGED 30 YEARS
S/O. DARWAN SINGH RATHOUR,LIEUTENANT
COMMANDER,NAVAL PAY OFFICE, MUMBAI,INDIAN NAVAL
ACADAMY, EZHIMALA, KANNUR, PIN - 670310
7 MADATHIL VALAPPIL RAHUL RAMAN,
AGED 32 YEARS
SON OF M.V. KUNHI RAMAN,LIEUTENANT
COMMANDER,NAVAL PAY OFFICE, MUMBAI,INDIAN NAVAL
ACADAMY, EZHIMALA, KANNUR, PIN - 670310
BY ADVS.
K.P.SANTHI
M.C.BINDUMOL
TARA PREM
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RESPONDENTS:
1 STATE OF KERALA,
REPRESENTED BY THE PUBLIC PROSECUTOR, HIGH COURT
OF KERALA, ERNAKULAM., PIN - 682031
2 JOINT COMMISSIONER OF INCOME TAX (HQ),(TECH
OFFICE OF PRINCIPAL CHIEF COMMISSIONER OF INCOME
TAX,KERALA, 2ND FLOOR, C.R. BUILDING, I.S.PRESS
ROAD, KOCHI, PIN - 682018
3 CENTRAL BUREU OF INVESTIGATION,
SPECIAL CRIME BRANCH, THIRUVANANTHAPURAM, PIN -
695024
BY ADV SREELAL N.WARRIER, SPL.PUBLIC PROSECUTOR,
CENTRAL BUREAU OF INVESTIGATION (CBI)
OTHER PRESENT:
SRI. M.C. ASHI, PP. SRI. SREELAL. N. WARRIER SPL.
PP FOR CBI.
SRI. JOSE JOSEPH SC, FOR INCOME TAX DEPARTMENT.
THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON
13.03.2025, ALONG WITH Crl.MC.67/2025, 2003/2023 AND
CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE
FOLLOWING:
Crl.MC.No.1003/23 & con.cases
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 67 OF 2025
CRIME NO.RC 0342023E0002/2023 OF CENTRAL BUREAU OF
INVESTIGATION, THIRUVANANTHAPURAM, Thiruvananthapuram
AGAINST THE ORDER/JUDGMENT DATED IN CC NO.123 OF 2024
OF CHIEF JUDICIAL MAGISTRATE, ERNAKULAM
PETITIONERS:
1 CHANDRAN GANAPATHIYADAN,
AGED 59 YEARS
S/O. KUNJIRAMAN, KALATHIL HOUSE, KARA PERAVOOR
P.O., KEEZHALLUR,THALASSERY, KANNUR, PIN - 670702
2 VINOD KUMAR K.,
AGED 48 YEARS
S/O. BAMBU B, KIZHAKKEKKARA HOUSE, BERIAM,
KARADKA, KASARAGOD, PIN - 671542
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BY ADVS.
SHABU SREEDHARAN
JAYACHANDRAN NAIR G.
ARCHANA U.
REENU S. BABU
RATHEESH.V.R.
LEKSHMI J.
BIJU JACOB B.O.
KARISHMA JOHN
RESPONDENTS:
1 UNION OF INDIA,
REPRESENTED BY THE ASST. SOLICITOR GENERAL,
OFFICE OF THE ASST. SOLICITOR GENERAL, HIGH COURT
OF KERALA, ERNAKULAM, PIN - 682031
2 CENTRAL BUREAU OF INVESTIGATION,
REPRESENTED BY ITS DEPUTY SUPERINTENDENT OF
POLICE, CBI, SCB, TC 1757/5, "CBI OCR COMPLEX",
MUTTATHARA, VALLAKADAVU P.O., THIRUVANANTHAPURAM,
PIN - 695008
THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON
13.03.2025, ALONG WITH Crl.MC.1003/2023 AND CONNECTED
CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:
Crl.MC.No.1003/23 & con.cases
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 2003 OF 2023
CRIME NO.RC 0342023E0002/2023 OF CENTRAL BUREAU OF
INVESTIGATION, THIRUVANANTHAPURAM, Thiruvananthapuram
PETITIONER:
AKSHAY KISHOR SALI
AGED 32 YEARS
S/O K.V.RAJAN, LIEUTENANT COMMANDER, NAVAL PAY
OFFICE, MUMBAI, INDIAN NAVAL ACADAMY,
EZHIMALA,KANNUR, PIN - 670310
BY ADVS.
K.P.SANTHI
TARA PREM
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RESPONDENTS:
1 STATE OF KERALA
REPRESENTED BY THE PUBLIC PROCECUTOR, HIGH COURT
OF KERALA, ERNAKULAM, PIN - 682031
2 JOINT COMMISSIONER OF INCOME TAX(HQ)
(TECH), OFFICE OF PRINCIPAL CHIEF COMMISSIONER OF
INCOME TAX, KERALA, 2ND FLOOR, C.R.BUILDING,
I.S.PRESS ROAD, KOCHI, PIN - 682018
3 CENTRAL BUREAU OF INVESTIGATION
SPECIAL CRIME BRANCH, THIRUVANANTHAPURAM,
REPRESENTED BY THE SUPRENTENDENT OF POLICE, PIN -
695024
BY ADV Sreelal Warriar
THIS CRIMINAL MISC. CASE HAVING BEEN FINALLY HEARD ON
13.03.2025, ALONG WITH Crl.MC.1003/2023 AND CONNECTED
CASES, THE COURT ON 17.03.2025 PASSED THE FOLLOWING:
Crl.MC.No.1003/23 & con.cases
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2025:KER:27705
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
MONDAY, THE 17TH DAY OF MARCH 2025 / 26TH PHALGUNA, 1946
CRL.MC NO. 10877 OF 2024
CRIME NO.36/2007 OF CRIME BRANCH, MALAPPURAM, Malappuram
AGAINST THE ORDER/JUDGMENT DATED IN CC NO.194 OF 2024
OF CHIEF JUDICIAL MAGISTRATE ,MANJERI
PETITIONERS:
1 GOLDEN FOREX PVT.LTD @ GOLDEN FOREX CENTER LTD@
GOLDENFOREX AND FINANCE SERVICES,
ZEENATH PLAZA, EZHUR ROAD, THIRUR, MALAPPURAM
(REPRESENTED BY NASIM P.K, MANAGING DIRECTOR ),
PIN - 676101
2 NASIM P.K,
AGED 48 YEARS
S/O. HAMZA HAJI,PANNIKANDATHIL HOUSE, ANNARA,
THIRUR, MALAPPURAM, PIN - 676101
3 ZEENATH,
AGED 68 YEARS
W/O. HAMZA HAJI, PANNIKANDATHIL HOUSE, ANNARA,
THIRUR, MALAPPURAM, PIN - 676101
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BY ADVS.
R.ANIL
B.RAMAN PILLAI (SR.)
SUJESH MENON V.B.
THOMAS SABU VADAKEKUT
MAHESH BHANU S.
RESSIL LONAN
JOEL GEORGE KAMPIYIL
ANANTH KRISHNA K.S.
RESPONDENT:
1 STATE OF KERALA,
REPRESENTED BY PUBLIC PROSECUTOR,HIGH COURT OF
KERALA, PIN - 682031
2 MOIDEEN ( SOUGHT TO BE IMPLEADED )
S/O. BEERAN, EZHOOR, THIROOR, ( SOUGHT TO BE
IMPLEADED )
THIS CRIMINAL MISC. CASE HAVINGHAVING BEEN FINALLY
HEARD ON 13.03.2025, ALONG WITH Crl.MC.1003/2023 AND
CONNECTED CASES, THE COURT ON 17.03.2025 PASSED THE
FOLLOWING:
Crl.MC.No.1003/23 & con.cases
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V.G.ARUN, J
= = = = = = = = = = = = = = = = =
Crl.M.C.Nos.1003 & 2003 of 2023,
10887 of 2024 & 67 of 2025
= = = = = = = = = = = = = = = = = =
Dated this the 17th day of March, 2025
ORDER
Petitioners are some of the accused in Crime No.RC0342023E0002 registered by the CBI/SCB/ Thiruvananthapuram for offences punishable under Sections 120B read with 420 of IPC and Section 276C of the Income Tax Act. The crime was registered on the basis of a letter received from the Principal Chief Commissioner of Income Tax, Kochi alleging that many salaried assessees in Ward-3 Kannur had received huge refund of income tax, by claiming bogus deductions under Sections 80DDB, 80E, 80EE, 80GG, 80GGC etc. Crl.MC.No.1003/23 & con.cases 11 2025:KER:27705
2. These Crl.M.Cs are filed seeking to get the FIR and further proceedings against the petitioners quashed on various grounds.
3. Heard, Advs.K.P.Santhi and Shabu Sreedharan for the petitioners, Adv.Jose Joseph for the Income Tax Department and Adv.Sreelal N Warrier for the Central Bureau of Investigation.
4. Learned counsel for the petitioners contended that in the communication issued by the Principal Chief Commissioner of Income Tax, which led to registration of the crimes, the allegations were raised against agents who had indulged in malpractices while submitting returns on behalf of the assessees. Assessees like the petitioners are completely dependent on the agents for filing income tax returns. The prosecution does not have a case that the bogus claims were raised at the instance of the petitioners. According to the counsel, the Income Tax Department had treated the claim for refund as a mistake and notices were issued under Sections Crl.MC.No.1003/23 & con.cases 12 2025:KER:27705 148, 154, 155 etc. of the Income Tax Act. On receipt of the notices, mistakes were rectified and the ineligible refund, remitted back. This shows that the petitioners had no intention to cheat. Moreover, the petitioners cannot be prosecuted for the offence under Section 276C of the Income Tax Act without previous administrative approval of the Collegium of two CCIT/DGIT rank officers, as evident from Annexure XIX circular produced in Crl.M.C.No.1003 of 2023.
5. Learned Standing Counsel for the Income Tax Department made the following submissions;
From 2014-2015 onwards, many of the assessees in Ward 3, Kannur had raised bogus claims for refund by under- reporting their salary and making ineligible deductions. Filing of return of income is the responsibility of individual tax payers even if it is prepared with the help of an agent. Electronic verification of the return of income has to be done by the tax payer himself, either through Aadhar OTP or net banking. The Crl.MC.No.1003/23 & con.cases 13 2025:KER:27705 returns are processed by the Central Processing Centre without any manual intervention. Therefore, the escaped assessment was noticed only during subsequent verification. Immediately, notices were sent to the petitioners and other assessees. The reply received from the petitioners being unsatisfactory, penalty was imposed on them. Refund of the excess amount claimed and payment of penalty will not absolve the petitioners from criminal liability, as they had committed cheating by filing false returns with intention to deceive the department. The contention based on Annexure XIX circular cannot also be countenanced, since the Department has not initiated prosecution under Section 276C. Instead, the CBI is conducting investigation based on the information given from the Department.
6. Learned Standing Counsel for the CBI submitted that, crime was registered against 31 persons, including the petitioners, based on a complaint received from the Income Tax Crl.MC.No.1003/23 & con.cases 14 2025:KER:27705 Department. During investigation, sufficient incriminating evidence to prove the commission of the offence of cheating was obtained. Hence, charge sheet was filed against the petitioners and others for the offence of cheating under Section 420 of the Indian Penal Code. The intention to commit the offence will continue to exist even if the loss caused to the Government is compensated by repaying the ineligible refund received. Investigation had revealed that some of the accused had claimed exemption towards housing loan interest, whilst others had claimed unmerited deductions under Sections 80DDB, 80E, 80EE, 80GG,80GGC etc. of the Income Tax Act. On receipt of complaint from the Income Tax Department, the documents were verified meticulously and information was gathered from officers at various levels and opportunity was given to the petitioners to prove their innocence. The petitioners were not able to produce any document to substantiate their claim for refund.
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7. The contention that false claims were raised by the agents and not the petitioners is liable to be rejected outright as the responsibility of filing proper returns is that of the assessee and not the agent. The petitioners themselves are the beneficiaries of such false claims and the agents are paid only a small percentage of the refunded amount. The argument that prosecution under Section 276C can be initiated only with the permission of the Collegium has no relevance, since the crime against the petitioners was investigated by the CBI. Pertinently, in the charge sheet filed by the CBI, only the offence punishable under Section 420 of IPC read with 120-B IPC, is incorporated. The submission that the Income Tax Department had treated the claim for refund as a mistake and issued notices to the petitioners, and the petitioners repaid the amount with penalty, is of no avail, as submission of false returns and acceptance of ineligible refunds are the crucial factors. Going by the scheme of the Income Tax Act, proceedings for Crl.MC.No.1003/23 & con.cases 16 2025:KER:27705 realisation of escaped assessment, imposition of penalty and prosecution for filing false returns are entirely different aspects and realisation of escaped assessment or imposition of penalty will not absolve a person from prosecution. For the reasons aforementioned, the prayer for quashing the proceedings is liable to be rejected. Needless to say, it will still be open for the petitioners to move the trial court for discharge.
The Crl.M.Cs are hence dismissed leaving it for the trial court to pass appropriate orders if applications for discharge are filed by the petitioners.
sd/-
V.G.ARUN, JUDGE Crl.MC.No.1003/23 & con.cases 17 2025:KER:27705 APPENDIX OF CRL.MC 67/2025 PETITIONER ANNEXURES Annexure-1 THE TRUE COPY OF THE LETTER FORWARDED BY THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOZHIKODE TO THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KOCHI DATED 4.2.2020 Annexure-2 THE TRUE COPY OF THE LETTER FORWARDED BY THE JOINT COMMISSIONER OF INCOME TAX, OFFICE OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KOCHI TO THE RESPONDENT CBI DATED 11.3.2020 Annexure-3 THE TRUE COPY OF THE FIR IN RC 0342023E0002 OF CBI/SCB/THIRUVANANTHAPURAM DATED 17.1.2023 Annexure-4 THE TRUE COPY OF FORM NO. 16 SUBMITTED BY THE 1ST PETITIONER FOR THE ASSESSMENT YEAR 2017 - 2018 DATED 1.4.2017 Annexure-5 THE TRUE COPY OF THE TAX PAYER COUNTERFOILS DATED 27.11.2021 Annexure-6 THE TRUE COPY OF FORM NO. 16 SUBMITTED BY THE 1ST PETITIONER FOR THE ASSESSMENT YEAR 2018 - 2019 DATED 1.4.2018 Crl.MC.No.1003/23 & con.cases 18 2025:KER:27705 Annexure-7 THE TRUE COPY OF FORM NO. 16 SUBMITTED BY THE 1ST PETITIONER FOR THE ASSESSMENT YEAR 2019 - 2020 Annexure-8 THE TRUE COPIES OF THE COMPUTERIZED RECEIPTS OF SBI, KANNUR DATED 3.2.2023 ISSUED TO THE 1ST PETITIONER Annexure-9 THE TRUE COPY OF FORM NO. 16 SUBMITTED BY THE 2ND PETITIONER FOR THE ASSESSMENT YEAR 2018 - 2019 DATED 1.4.2018 Annexure-10 THE TRUE COPY OF FORM NO. 16 SUBMITTED BY THE 2ND PETITIONER FOR THE ASSESSMENT YEAR 2019 - 2020 DATED 1.4.2019 Annexure-11 THE TRUE COPIES OF THE COMPUTERIZED RECEIPTS OF SBI, KANNUR DATED 3.2.2023 ISSUED TO THE 2ND PETITIONER Annexure-12 THE TRUE COPY OF THE INTERIM ORDER OF THIS HON'BLE COURT IN CRL MC NO.
1661/2023 DATED 26.9.2023 Annexure-13 THE TRUE COPY OF THE ORDER OF THIS HON'BLE COURT IN CRL MC NO. 1661/2023 DATED 9.10.2024.
Annexure-14 THE CERTIFIED COPY OF THE CHARGE SHEET FILED BY THE RESPONDENT CBI IN RC 0342023E002 OF CBI/SCB/THIRUVANANTHAPURAM BEFORE THE CJM COURT, ERNAKULAM DATED 29.6.2024 Crl.MC.No.1003/23 & con.cases 19 2025:KER:27705 APPENDIX OF CRL.MC 2003/2023 PETITIONER ANNEXURES Annexure I TRUE COPY OF THE FIR NO. RC 0342023E0002 DATED 17-1-2023 Annexure II TRUE COPY OF THE CIRCULAR DATED 9-9- 2019 Annexure III TRUE COPY OF THE LETTER DATED 4-2-2020 OF THE PRINCIPAL COMMISSIONER OF INCOME TAX, KOZHIKODE Annexure IV TRUE COPY OF THE COMPLAINANT DATED 11- 3-2020 OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX Crl.MC.No.1003/23 & con.cases 20 2025:KER:27705 APPENDIX OF CRL.MC 10877/2024 PETITIONER ANNEXURES Annexure 1 THE CERTIFIED COPY OF THE FIR NO.
348/2006 OF THIRUR POLICE STATION Annexure 2 THE CERTIFIED COPY OF THE FINAL REPORT IN CRIME NO. 348 OF 2006 OF THIRUR POLICE STATION, WHICH IS RE-REGISTERED AS CRIME NO.36/CB/MPM/2007 OF CRIME BRANCH , MALAPPURAM AND PENDING AS C.C. NO. 194 OF 2024 BEFORE THE HON'BLE COURT OF THE CHIEF JUDICIAL MAGISTRATE, MANJERI Annexure 3 TRUE COPY OF THE MEDICAL CERTIFICATE DATED 18-9-2024 ISSUED FROM LOURDE HOSPITAL Annexure 4 A TRUE COPY OF THE DISCHARGE SUMMARY DATED 20-2-2023 AFTER ADMITTED ON 16-2- 2024 Crl.MC.No.1003/23 & con.cases 21 2025:KER:27705 APPENDIX OF CRL.MC 1003/2023 PETITIONER ANNEXURES Annexure I TRUE COPY OF FIR NO. RC 0342023E0002 DATED 17-1-2023 OF THE CHIEF JUDICIAL MAGISTRATE COURT, ERNAKULAM Annexure II TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2016-2017 DATED 10-5- 2019 Annexure II(a) TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2014-2015 DATED 30-3- 2021 Annexure II(b) TRUE COPY OF THE NOTICE UNDER SECTION 156 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2014-2015 DATED 12-3- 2022 Annexure III ). TRUE COPY OF THE COUNTERFOIL DATED 22-4-2021 FOR THE ASSESSMENT YEAR 2017- 2018 Annexure III(a) TRUE COPY OF THE COUNTERFOIL DATED 24- 2-2022 FOR THE ASSESSMENT YEAR 2014- 2015 Annexure III(b) TRUE COPY OF THE COUNTERFOIL DATED 12- 4-2022 FOR THE ASSESSMENT YEAR 2014- 2015 Crl.MC.No.1003/23 & con.cases 22 2025:KER:27705 Annexure IV TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2017-2018 DATED 30-3- 2021 Annexure IV(a) TRUE COPY OF THE NOTICE UNDER SECTION 156 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2017-2018 DATED 26-3- 2022 Annexure IV(b) TRUE COPY OF THE NOTICE UNDER SECTION 156 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2017-2018 DATED 21-9- 2022 Annexure V TRUE COPY OF THE COUNTERFOIL DATED 15- 4-2022 FOR THE ASSESSMENT YEAR 2017- 2018 Annexure V(a) TRUE COPY OF THE COUNTERFOIL DATED 20- 10-2022 FOR THE ASSESSMENT YEAR 2017- 2018 Annexure VI TRUE COPY OF THE ORDER DATED 19-12-2022 OF THE 2ND RESPONDENT Annexure VII TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2015-2016 DATED 30-3- 2021 Annexure VII(a) TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2016-2017 DATED 30-3- 2021 Crl.MC.No.1003/23 & con.cases 23 2025:KER:27705 Annexure VII(b) ). TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2017-2018 DATED 30- 3-2021 Annexure VII(c) TRUE COPY OF THE NOTICE UNDER SECTION 156 OF THE INCOME TAX ACT DATED 24-3- 2022 Annexure VIII TRUE COPY OF THE COUNTERFOIL DATED 23- 4-2022 FOR THE ASSESSMENT YEAR 2017- 2018 Annexure VIII(a) TRUE COPY OF THE COUNTERFOIL DATED 23- 4-2022 FOR THE ASSESSMENT YEAR 2016- 2017 Annexure VIII(b) TRUE COPY OF THE COUNTERFOIL DATED 23- 4-2022 FOR THE ASSESSMENT YEAR 2015- 2016 Annexure VIII(c) TRUE COPY OF THE COUNTERFOIL DATED 25- 10-2022 FOR THE ASSESSMENT YEAR 2017- 2018 Annexure VIII(d) ). TRUE COPY OF THE COUNTERFOIL DATED 25-10-2022 FOR THE ASSESSMENT YEAR 2016-2017 Annexure VIII(e) TRUE COPY OF THE COUNTERFOIL DATED 25- 10-2022 FOR THE ASSESSMENT YEAR 2015- 2016 Crl.MC.No.1003/23 & con.cases 24 2025:KER:27705 Annexure VIII(f) TRUE COPY OF THE COUNTERFOIL DATED 24- 11-2022 FOR THE ASSESSMENT YEAR 2016- 2017 Annexure VIII(g) TRUE COPY OF THE COUNTERFOIL DATED 24- 11-2022 FOR THE ASSESSMENT YEAR 2015- 2016 Annexure VIII(h) TRUE COPY OF THE COUNTERFOIL DATED 24- 11-2022 FOR THE ASSESSMENT YEAR 2017- 2018 Annexure VIII(i) TRUE COPY OF THE COUNTERFOIL DATED 19- 12-2022 FOR THE ASSESSMENT YEAR 2015- 2016 Annexure VIII(j) TRUE COPY OF THE COUNTERFOIL DATED 19- 12-2022 FOR THE ASSESSMENT YEAR 2017- 2018 Annexure VIII(k) TRUE COPY OF THE COUNTERFOIL DATED 19- 12-2022 FOR THE ASSESSMENT YEAR 2016- 2017 Annexure IX . TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2015-2016 DATED 30-3- 2021 Annexure IX(a) TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2016-2017 DATED 30-3- 2021 Crl.MC.No.1003/23 & con.cases 25 2025:KER:27705 Annexure IX(b) TRUE COPY OF THE NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT FOR THE ASSESSMENT YEAR 2017-2018 DATED 30-3- 2021 Annexure X ). 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NO. 104 OF 2024 OF THE CHIEF JUDICIAL MAGISTRATE COURT, ERNAKULAM