M/S REHABOTH INDIAN GYPSY NEW LIFE TRUST V. UNION OF INDIA

WP(C)/40176/2023

AI Insights

The case involves multiple writ petitions filed by various charitable trusts against the Union of India and other respondents, concerning issues related to income tax assessments and the decisions of the Interim Board for Settlement-II. The petitions were heard together and addressed similar legal questions regarding the application of tax laws and the procedural aspects of tax assessments for several assessment years. The petitioners, represented by a common set of advocates, sought to withdraw their petitions, expressing intent to refile as needed based on future decisions by the Interim Board. The court's decision to dismiss the petitions as infructuous was based on this withdrawal request.

• Counselvise Citation: [2023] 140 COUNSELVISE.COM (IT) 724985 (HC-KERALA)
• Appeal Type: Others
• Pronouncement Date: 06-12-2023
• Assessment Year: misc
• Result in Favour of: Others
• Court: HIGH COURT
• Department Lawyers: SUSIE VARGHESE
• Assessee Lawyers: N PRASAD; P METHAR; GAYATHRI POTI; PUSHPARAJ P
• Keywords: Assessment years; Income Tax; Settlement application; Writ petition
• Section: 153A; 119(2)(b)

Judgement Text

"IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40119 OF 2023 PETITIONER: M/S AAYANA CHARITABLE TRUST REPRESENTED BY ITS MANAGING TRUSTEE MR. SINY PUNNOOSE 1, MANJADI THIRUVALLA, THIRUVALLA., PIN – 689101 BY ADVS. N.KRISHNA PRASAD P.SHANES METHAR GAYATHRI POTI PUSHPARAJ.K.P RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF REVENUE MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG,NEW DELHI,PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT-II REPRESENTED BY ITS SECRETARY 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET, NEW DELHI, PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE, GOVERNMENT OF INDIA NEW DELHI,PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 M.G. ROAD, KOCHI, PIN – 682011 SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40120/2023, 40122/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 2 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40120 OF 2023 PETITIONER: M/S GROWTH IN FRATERNITY TRUST REPRESENTED BY ITS MANAGING TRUSTEE MR. THOMAS N.S NO. 106, 2ND STREET, 'E' CROSS, OMBR LAYOUT, CHIKKABANASWADI, BANGALORE, PIN – 560033 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY MINISTRY OF FINANCE,3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG NEW DELHI., PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT-II REPRESENTED BY ITS SECRETARY, 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET NEW DELHI., PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI., PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2, M.G. ROAD, KOCHI, PIN – 682011 BY ADV. SRI. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 3 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40122 OF 2023 PETITIONER: M/S SHEKINA PROPHETIC MISSION TRUST; REPRESENTED BY ITS MANAGING TRUSTEE MR. PRABHUDAS J SIRUMUGAI ROAD, 1ST STREET, ANNUR, COIMBATORE, PIN – 641653 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF REVENUE MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG,NEW DELHI, PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT-II REPRESENTED BY ITS SECRETARY 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET NEW DELHI., PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE GOVERNMENT OF INDIA, NEW DELHI, PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 M.G. ROAD, KOCHI., PIN – 682011 BY ADV. SMT. SUSIE B. VARGHESE - SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 4 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40125 OF 2023 PETITIONER: M/S HOLY SPIRIT MINISTRIES M/S HOLY SPIRIT MINISTRIES REPRESENTED BY ITS MANAGING TRUSTEE MR. RAJU N RR NO. 7, WEEH 2779, OPP TO DIYA ACDEMIC SCHOOL, KODIGEHALLI MAIN ROAD, AYYAPPAN NAGAR, K.R.PURAM POST, BENGALURU, PIN – 560036 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG, NEW DELHI, PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT-II 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET, NEW DELHI, PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI., PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2, M.G. ROAD, KOCHI, PIN – 682011 BY ADV. SMT. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 5 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40141 OF 2023 PETITIONER: M/S NEW LIFELINE CHARITABLE MINISTRIES REPRESENTED BY ITS MANAGING TRUSTEE MR. MARTIN K E H NO. 10991/1, SECTOR 29D, CHANDIGARH., PIN – 160062 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF REVENUE MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG, NEW DELHI., PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT-II 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET NEW DELHI, PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE GOVERNMENT OF INDIA, NEW DELHI., PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 M.G. ROAD, KOCHI, PIN – 682011. BY ADV. SMT. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 6 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40154 OF 2023 PETITIONER: M/S LOVE INDIA MINISTRIES REPRESENTED BY ITS MANAGING TRUSTEE MR. OOMMEN MATHEW VII/37 POOTHICOTE, MANJADI THIRUVALLA, THIRUVALLA., PIN – 689105 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF REVENUE - MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG, NEW DELHI., PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT-II REPRESENTED BY ITS SECRETARY 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET, NEW DELHI., PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE GOVERNMENT OF INDIA, NEW DELHI., PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 M.G. ROAD, KOCHI., PIN – 682011. BY ADV. SMT. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 7 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40176 OF 2023 PETITIONER: M/S REHABOTH INDIAN GYPSY NEW LIFE TRUST REPRESENTED BY ITS MANAGING TRUSTEE MR. RAJI JOHN SIRUMUGAI ROAD, 1ST STREET, ANNUR, COIMBATORE., PIN – 641653 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF REVENUE MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG,NEW DELHI, PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT -II 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET, NEW DELHI., PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE, GOVERNMENT OF INDIA NEW DELHI., PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 M.G. ROAD, KOCHI, PIN – 682011. BY ADV. SMT. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 8 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40177 OF 2023 PETITIONER: M/S BELIEVERS EASTERN CHURCH REPRESENTED BY ITS MANAGING TRUSTEE MR. SAMUEL MATHEW XXVI/219, IYERS BUILDING, RAMANCHIRA, TIRUVALLA, PIN – 689101 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY DEPARTMENT OF REVENUE MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG, NEW DELHI, PIN – 110001 2 INTERIM BOARD FOR SETTLEMENT-II INTERIM BOARD FOR SETTLEMENT-II, NEW 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET, NEW DELHI., PIN – 110003 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI., PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 2 M.G. ROAD, KOCHI., PIN – 682011. BY ADV. SMT. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 9 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40186 OF 2023 PETITIONER: M/S NEW HOPE FOUNDATION, REPRESENTED BY ITS MANAGING TRUSTEE MR. JOHN AUXON, KEELPADAPPAI, KANCHIPURAM, CHENNAI., PIN – 601301. BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA, REPRESENTED BY THE FINANCE SECRETARY, DEPARTMENT OF REVENUE MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG, NEW DELHI, PIN – 110001. 2 INTERIM BOARD FOR SETTLEMENT-II, REPRESENTED BY ITS SECRETARY 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET, NEW DELHI, PIN – 110003. 3 THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY ITS CHAIRPERSON, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NEW DELHI, PIN – 110001. 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE – 2 M.G. ROAD KOCHI, PIN – 682011. BY ADV. SMT. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 10 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH WEDNESDAY, THE 6TH DAY OF DECEMBER 2023 / 15TH AGRAHAYANA, 1945 WP(C) NO. 40211 OF 2023 PETITIONER: M/S HOLY BERACHAH MINISTRIES REPRESENTED BY ITS M CENTRAL CIRCLE – 2,A CENTRAL CIRCLE – 2,NAGING TRUSTEE MR. JESUPRASAD S D DOOR NO. 18, G.C COLONY,QUEENS ROAD, BANGALORE., PIN – 560051 BY ADVS. SRI. N. KRISHNA PRASAD SRI. P. SHANES METHAR SMT. GAYATHRI POTI SRI. PUSHPARAJ K. P. RESPONDENTS: 1 UNION OF INDIA REPRESENTED BY THE FINANCE SECRETARY MINISTRY OF FINANCE, 3RD FLOOR,JEEVAN DEEP BUILDING, SANSAD MARG, NEW DELHI., PIN – 110001. 2 INTERIM BOARD FOR SETTLEMENT-II REPRESENTED BY ITS SECRETARY, 9TH FLOOR, LOK NAYAK BHAVAN, KHAN MARKET, NEW DELHI, PIN – 110003. 3 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON DEPARTMENT OF REVENUE - MINISTRY OF FINANCE GOVERNMENT OF INDIA, NEW DELHI., PIN – 110001 4 DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE – 2, M.G. ROAD KOCHI, PIN – 682011. BY ADV. SMT. SUSIE B. VARGHESE-SC THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 06.12.2023, ALONG WITH WP(C).40119/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C) NO. 40119 OF 2023 & Connected Cases 11 DINESH KUMAR SINGH, J. -------------------------- WP(C) Nos.40119, 40120, 40122, 40125, 40141, 40154, 40176, 40177, 40186 & 40211 of 2023 ------------------------- Dated this the 6th day of December, 2023 JUDGMENT 1. After some arguments, the learned Counsel for the petitioner submits that he would like to withdraw these writ petitions with liberty to file fresh petition as and when the Interim Board takes decision on the applications of the petitioner, if any occasion so arises. 2. In view of the aforesaid submission of the Learned Counsel for the petitioner, these writ petitions are dismissed as infructuous with liberty as prayed for. Interim Order, if any, stands vacated. Sd/- DINESH KUMAR SINGH JUDGE Svn WP(C) NO. 40119 OF 2023 & Connected Cases 12 APPENDIX OF WP(C) 40119/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN WP(C) NO. 4299/2021 Exhibit P2 TRUE COPY OFTHE INTERIM ORDER 13.4.2021 IN WP(C) NO. 9076 /2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2015-16 DATED 12.7.2021 ExhibitP3(a) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2016-17 DATED 12.7.2021 Exhibit P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2017-18 DATED 12.7.2021 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2018-19 DATED 12.7.2021 Exhibit P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2019-20 DATED 12.7.2021 Exhibit P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2020-21 DATED 12.7.2021 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S.119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEOPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN WP NO.20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 WP(C) NO. 40119 OF 2023 & Connected Cases 13 APPENDIX OF WP(C) 40120/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN WP(C) NO. 4299/2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN WP(C) NO. 9076 /2021 Exhibit P3 TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2015-16 ISSUED BY THE 4TH RESPONDENT DATED 23.08.2021 Exhibit P3(a) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2016-17 ISSUED BY THE 4TH RESPONDENT DATED 23.08.2021 Exhibit P3(b) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2017-18 ISSUED BY THE 4TH RESPONDENT DATED 23.08.2021 Exhibit P3(c) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2018-19 ISSUED BY THE 4TH RESPONDENT DATED 23.08.2021 ExhibitP3(d) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2019-20 ISSUED BY THE 4TH RESPONDENT DATED 23.08.2021 Exhibit P3(e) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2020-21 ISSUED BY THE 4TH RESPONDENT DATED 23.08.2021 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN W.P.(C) NO.20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 WP(C) NO. 40119 OF 2023 & Connected Cases 14 APPENDIX OF WP(C) 40122/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN WP(C) NO. 4299/2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN WP(C) NO. 9076 /2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2016-17 Exhibit 3(b) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2017-18 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2018-19 Exhibit P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2019-20 Exhibit P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2020-21 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN WP (C) NO.20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 WP(C) NO. 40119 OF 2023 & Connected Cases 15 APPENDIX OF WP(C) 40125/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN W.P (C) NO.4299 OF 2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN W.P.(C) NO.9076 OF 2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2016-17 DATED 23.08.2021 Exhibit P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2017-18 DATED 23.08.2021 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2018-19 DATED 23.08.2021 Exhibit P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2019-20 DATED 23.08.2021 ExhibitP3(e) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2020-21 DATED 23.08.2021 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S.119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN W.P (C) NO. 20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 WP(C) NO. 40119 OF 2023 & Connected Cases 16 APPENDIX OF WP(C) 40141/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN W.P (C) NO.4299 OF 2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN W.P (C) NO.9076 OF 2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2016-17 Exhibit P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2017-18 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2018-19 Exhibit P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2019-20 Exhibit P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 12.07.2021 FOR THE ASSESSMENT YEARS 2020-21 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN W.P (C) NO.20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 WP(C) NO. 40119 OF 2023 & Connected Cases 17 APPENDIX OF WP(C) 40154/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN WP(C) NO. 4299/2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN WP(C) NO. 9076 /2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2016-17 Exhibit P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2017-18 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2018-19 Exhibit P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2019-20 Exhibit P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2020-21 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN WP NO.20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 WP(C) NO. 40119 OF 2023 & Connected Cases 18 APPENDIX OF WP(C) 40176/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN W.P.(C) NO.4299 OF 2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN W.P(C) NO.9076 OF 2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022 FOR THE ASSESSMENT YEARS 2016-17 Exhibit P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022 FOR THE ASSESSMENT YEARS 2017-18 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022 FOR THE ASSESSMENT YEARS 2018-19 Exhibit P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022 FOR THE ASSESSMENT YEARS 2019-20 Exhibit P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 2.03.2022 FOR THE ASSESSMENT YEARS 20120-21 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 04.10.2021 IN W.P (C) NO.21062 OF 2021 Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 WP(C) NO. 40119 OF 2023 & Connected Cases 19 APPENDIX OF WP(C) 40177/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN WP(C) NO. 4299/2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN WP(C) NO. 9076 /2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2016-17 Exhibit P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2017-18 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2018-19 Exhibit 3(d) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2019-20 Exhibit P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 23.03.2021 FOR THE ASSESSMENT YEARS 2020-21 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN WP NO. 20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 WP(C) NO. 40119 OF 2023 & Connected Cases 20 APPENDIX OF WP(C) 40186/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN WP(C) NO. 4299/2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN WP(C) NO. 9076 /2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2016-17 Exhibit P3(b) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2017-18 Exhibit P3(c) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2018-19 Exhibit P3(d) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2019-20 Exhibit P3(e) TRUE COPY OF NOTICE U/S. 153A DATED 23.08.2021 FOR THE ASSESSMENT YEARS 2020-21 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.9.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN W.P (C) NO.20746 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE Y THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 WP(C) NO. 40119 OF 2023 & Connected Cases 21 APPENDIX OF WP(C) 40211/2023 PETITIONER’S EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER DATED 18.2.2021 IN W.P (C) NO.4299/2021 Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 13.4.2021 IN W.P (C) NO.9076/2021 Exhibit P3 TRUE COPY OF NOTICE U/S. 153A DATED 22.09.2021 FOR THE ASSESSMENT YEARS 2015-16 Exhibit P3(a) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2016-17 DATED 22.09.2021 Exhibit P3(b) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2017-18 DATED 22.09.2021 Exhibit P3(c) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2018-19 DATED 22.09.2021 Exhibit P3(d) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2019-20 DATED 22.09.2021 Exhibit P3(e) TRUE COPY OF NOTICE ISSUED U/S. 153A OF THE ACT FOR THE AY. 2020-21 DATED 22.09.2021 Exhibit P4 TRUE COPY OF THE PRESS RELEASE ISSUED BY THE 3RD RESPONDENT DATED 07.09.2021 Exhibit P5 TRUE COPY OF THE ORDER U/S. 119(2)(B) OF THE ACT DATED 28.09.2021 Exhibit P6 TRUE COPY OF THE SETTLEMENT APPLICATION FEE RECEIPT DATED 25.09.2021 Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 30.09.2021 IN W.P (C) NO.20746 OF 2021 AND CONNECTED CASES Exhibit P8 TRUE COPY OF THE RELEVANT EXTRACT OF THE AMENDMENT MADE BY THE FINANCE ACT, 2021 WITH RETROSPECTIVE EFFECT FROM 01.02.2021 Exhibit P9 TRUE COPY OF THE NOTICE OF HEARING DATED 21.11.2023 "