M/S. AL ZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD. V. ACIT

ITA/2/2022

AI Insights

The case involves multiple income tax appeals by M/S Al Zarafa Travel & Manpower Consultants (P) Ltd against the orders of the ITA Tribunal, Cochin Bench. The appeals were consolidated and heard together, focusing on the jurisdiction and competence of the assessing officer as raised by the appellant. The Tribunal had remanded the matter back to the assessing officer, which the appellant contested, arguing that the Tribunal failed to address the jurisdictional competence in its decision. The respondent supported the Tribunal's decision to remand, emphasizing that the appellant could raise objections during the reassessment.

• Counselvise Citation: [2022] 140 COUNSELVISE.COM (IT) 746131 (HC-KERALA)
• Appeal Type: Others
• Pronouncement Date: 26-07-2022
• Assessment Year: misc
• Result in Favour of: Partly Allowed
• Court: HIGH COURT
• Department Lawyers: P K R MENON
• Assessee Lawyers: JOSEPH MARKOSE; PREETHA NAIR
• Keywords: Assessment Order; Income tax appeal; Jurisdiction; Remand
• Section: 250A

Judgement Text

"ITA No.3 of 2022 & conn.cases 1 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI TUESDAY, THE 26TH DAY OF JULY 2022 / 4TH SRAVANA, 1944 ITA NO. 3 OF 2022 AGAINST THE ORDER IN ITA 27/2021 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/Appellant: M/S AL ZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD C/O ELIAS GEORGE & CO., CAS,EGC HOUSE, HIG AVENUE, GANDHI NAGAR,KOCHI - 682 020. [PAN :AAFCA4935NB], PIN - 682020 BY SR.ADV.JOSEPH MARKOSE BY ADV PREETHA S.NAIR RESPONDENT/Respondent: ACIT, CENTRAL CIRCLE-2,5th FLOOR, KANDAMKULATHY TOWER,M.G. ROAD, KOCHI-682 011, PIN - 682011 OTHER PRESENT: P.K.R.MENON, SC FOR ITD, SR. ADV. JOSEPH MARKOSE FOR APPELLANT THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON 26.07.2022, ALONG WITH ITA.2/2022, 4/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA No.3 of 2022 & conn.cases 2 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI TUESDAY, THE 26TH DAY OF JULY 2022 / 4TH SRAVANA, 1944 ITA NO. 2 OF 2022 AGAINST THE ORDER IN ITA 25/2021 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/APPELLANT: M/S AL ZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD. C/O ELIAS GEORGE & CO. Cas, EGC HOUSE, HIG AVENUE, GANDHI NAGAR,KOCHI 682 020 (PAN AAFCA4935NB) BY ADVS. JOSEPH MARKOSE (SR.) PREETHA S.NAIR RESPONDENT/RESPONDENT: ACIT, CENTRAL CIRCLE-2, 5th FLOOR, KADAMKULATHY TOWER, M.G.ROAD, KOCHI 682011. OTHER PRESENT: P.K.R MENON, SC FOR ITD THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON 26.07.2022, ALONG WITH ITA.3/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA No.3 of 2022 & conn.cases 3 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI TUESDAY, THE 26TH DAY OF JULY 2022 / 4TH SRAVANA, 1944 ITA NO. 4 OF 2022 AGAINST THE ORDER IN ITA 28/2021 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/APPELLANT: M/S AL ZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD C/O ELIAS GEORGE & CO., CAS EGC HOUSE, HIG AVENUE GANDHI NAGAR,KOCHI -682 020. [PAN : AAFCA4935NB], PIN - 682020 BY SR.ADV JOSEPH MARKOSE ADV.SMT.PREETHA S.NAIR RESPONDENT/RESPONDENT: ACIT, CENTRAL CIRCLE-2 5TH FLOOR, KANDAMKULATHY TOWER, M.G. ROAD, KOCCHI-682 011, PIN – 682011 SR.ADV.P.K.R.MENON, SC FOR ITD THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON 26.07.2022, ALONG WITH ITA.3/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA No.3 of 2022 & conn.cases 4 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI TUESDAY, THE 26TH DAY OF JULY 2022 / 4TH SRAVANA, 1944 ITA NO. 5 OF 2022 AGAINST THE ORDER IN ITA 26/2021 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/APPELLANT: M/S. AL ZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD. C/O ELIAS GEORGE & CO., CAS EGC HOUSE, HIG AVENUE GANDHI NAGAR, [PAN : AAFCA4935NB], PIN – 682020 BY SR.ADV.JOSEPH MARKOSE BY ADV PREETHA S.NAIR RESPONDENT/Respondent: ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2 5TH FLOOR,KANDAMKULATHY TOWER M.G ROAD,KOCHI, PIN - 682011 THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON 26.07.2022, ALONG WITH ITA.3/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA No.3 of 2022 & conn.cases 5 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI TUESDAY, THE 26TH DAY OF JULY 2022 / 4TH SRAVANA, 1944 ITA NO. 6 OF 2022 AGAINST THE ORDER IN ITA 29/2021 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/Appellant: M/S. AL ZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD., C/O ELIAS GEORGE & CO., CAS EGC HOUSE, HIG AVENUE GANDHI NAGAR, KOCHI -682 020. [PAN : AAFCA4935NB], PIN - 682020 BY SR.ADV.JOSEPH MARKOSE BY ADV PREETHA S.NAIR RESPONDENT/Respondent: ACIT, CENTRAL CIRCLE-2, 5TH FLOOR, KANDAMKULATHY TOWER, M.G. ROAD, KOCHI-682 011, PIN - 682011 THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON 26.07.2022, ALONG WITH ITA.3/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA No.3 of 2022 & conn.cases 6 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE S.V.BHATTI & THE HONOURABLE MR.JUSTICE BASANT BALAJI TUESDAY, THE 26TH DAY OF JULY 2022 / 4TH SRAVANA, 1944 ITA NO. 7 OF 2022 AGAINST THE ORDER IN ITA 30/2021 OF I.T.A.TRIBUNAL,COCHIN BENCH APPELLANT/Appellant: M/S. AL ZARAFA TRAVEL & MANPOWER CONSULTANTS (P) LTD., C/O ELIAS GEORGE & CO., CAS EGC HOUSE, HIG AVENUE GANDHI NAGAR, [PAN : AAFCA4935NB], PIN - 682020 BY SR.ADV.JOSEPH MARKOSE BY ADV PREETHA S.NAIR RESPONDENT/RESPONDENT: ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,5th FLOOR, KANDAMKULATHY TOWER, M.G. ROAD, KOCHI, PIN - 682011 THIS INCOME TAX APPEAL HAVING COME UP FOR ADMISSION ON 26.07.2022, ALONG WITH ITA.3/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: ITA No.3 of 2022 & conn.cases 7 JUDGMENT [ITA Nos.3/2022, 2/2022, 4/2022, 5/2022, 6/2022, 7/2022] S.V.Bhatti, J. The appeals are directed against the order of remand. 2. Learned Senior Advocate Mr.Joseph Markose invited our attention to the grounds of appeal filed by the assessee before the Tribunal. 3. Ground No.1 deals with the competence and jurisdiction of the officer who made the assessment order impugned before the Tribunal. Now the complaint of the appellant is that the said ground was urged before the Tribunal but the Tribunal did not examine the merits and recorded a finding. Therefore, the submission made basing upon such an omission by the Tribunal is that the ground if considered and decided in favour of the assessee, there is no need for remand. Remand in the manner now stated by the Tribunal, the assessee would have difficulty from the findings recorded by the Commissioner on the competence or jurisdiction of the assessing authority. The Tribunal, therefore, ought to have examined all these issues. ITA No.3 of 2022 & conn.cases 8 4. Learned Senior Advocate PKR Menon appearing for the respondent argues that the assessee challenges the order of remand. The order of remand gives reasons and circumstances in which the Tribunal was satisfied to remit the matter to the primary authority. It is always open to the assessee to raise objections available in law and fact before the Assessing Authority as and when the opportunity is afforded. Therefore, there is hardly a ground warranting interference of this Court under Section 250A of the Act. 5. We have heard the learned Senior Counsel and with their assistance, we have gone through the order of the Commissioner and the Tribunal. Prima facie, we are of the view that the possible apprehension the assessee may encounter after remand cannot be ignored by this Court in the particular circumstances of the case. Therefore, we are convinced to observe that the remand by the order dated 10.02.2022 of the Tribunal is only on issues in appeal and the assessing officer uninfluenced by any observation of the Commissioner rendered on jurisdiction of the assessing officer decides the said objection as well in accordance with law. ITA No.3 of 2022 & conn.cases 9 The appeals are dismissed with the above observations. Sd/- S.V.BHATTI, JUDGE Sd/- BASANT BALAJI, JUDGE css/ ITA No.3 of 2022 & conn.cases 10 APPENDIX OF ITA 4/2022 PETITIONER ANNEXURES Annexure A1 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.20215 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LL, KOCHI Annexure A2 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV-LL), KOCHI Annexure A3 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LL, KOCHI Annexure A4 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LI, KOCHI Annexure A5 TRUE COPY OF THE PANCHANAMA PREPARED ON 28.03.2015 BY THE INCOME THAX OFFICER (HQ), OFFICE OF THE DIRECTOR OF INCOME TAX(LNV.), KOCHI. Annexure A6 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LL, KOCHI. Annexure A7 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV-LL), KOCHI Annexure B1 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2009-10 Annexure B2 TRUE COPY OF THE ASSESSMENT ORDER DATED 23.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2010-11 Annexure B3 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2011 -12. Annexure B4 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2012-13 Annexure B5 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2014-15 Annexure B6 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2015-16 Annexure C TRUE COPY OF THE COMMON ORDER DATED 25.01.2021 FOR ALL THE YEARS INCLUDING ASSESSMENT YEAR 2009-10 PASSED BY THE ITA No.3 of 2022 & conn.cases 11 COMMISSIONER OF INCOME TAX (APPEALS)-3, KOCHI Annexure D1 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2009-10 Annexure D2 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2010-11 Annexure D3 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2011 -12 Annexure D4 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI ASSESSMENT YEAR 2012-13. Annexure D5 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI ASSESSMENT YEAR 2014-15. Annexure D6 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2015-16 Annexure E1 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2009-10 Annexure E2 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2010-11. Annexure E3 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2011 -12. Annexure E4 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2012-13 Annexure E5 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2014-15 ITA No.3 of 2022 & conn.cases 12 Annexure E6 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2015-16. Annexure F CERTIFIED COPY OF THE ORDER DATED 10.02.2022 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL. ITA No.3 of 2022 & conn.cases 13 APPENDIX OF ITA 5/2022 PETITIONER ANNEXURES Annexure A1 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LL, KOCHI, Annexure A2 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV-LL), KOCHI Annexure A3 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LL, KOCHI Annexure A4 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LL, KOCHI Annexure A5 TRUE COPY OF THE PANCHANAMA PREPARED ON 28.03.2015 BY THE INCOME TAX OFFICER (HQ), OFFICE OF THE DIRECTOR OF INCOME TAX(LNV.), KOCHI. Annexure A6 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-LL, KOCHI Annexure A7 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV-LL), KOCHI Annexure B1 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2009-10. Annexure B2 TRUE COPY OF THE ASSESSMENT ORDER DATED 23.12.2016 OF THE RESPONDENT HER ASSESSMENT YEAR 2010-11. Annexure B3 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2011 -12. Annexure B4 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2012-13. Annexure B5 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2014-15. Annexure B6 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2015-16. Annexure C TRUE COPY OF THE COMMON ORDER DATED 25.01.2021 FOR ALL THE YEARS INCLUDING ASSESSMENT YEAR 2009-10 PASSED BY THE ITA No.3 of 2022 & conn.cases 14 COMMISSIONER OF INCOME TAX (APPEALS)-3, KOCHI Annexure D1 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020(CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2009-10. Annexure D2 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2010-11. Annexure D3 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2011 -12. Annexure D4 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2012 -13. Annexure D5 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2014 -15 Annexure D6 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2015-16 Annexure E1 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2009-10 Annexure E2 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2010-11 Annexure E3 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2011-12 Annexure E4 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2012-13 Annexure E5 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2014-15 ITA No.3 of 2022 & conn.cases 15 Annexure E6 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2015-16 Annexure F CERTIFIED COPY OF THE ORDER DATED 10.02.2022 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL. ITA No.3 of 2022 & conn.cases 16 APPENDIX OF ITA 6/2022 PETITIONER ANNEXURES Annexure A1 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-IL, KOCHI. Annexure A2 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-IL, KOCHI. Annexure A3 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-IL, KOCHI. Annexure A4 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-IL, KOCHI. Annexure A5 TRUE COPY OF THE PANCHANAMA PREPARED ON 28.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-IL, KOCHI. Annexure A6 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-IL, KOCHI. Annexure A7 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-IL, KOCHI. Annexure B1 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2009-10. Annexure B2 TRUE COPY OF THE ASSESSMENT ORDER DATED 23.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2010-11. Annexure B3 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2011-12. Annexure B4 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2012-13. Annexure B5 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2014-15. Annexure B6 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2015-16. Annexure C TRUE COPY OF THE COMMON ORDER DATED 25.01.2021 FOR ALL THE YEARS INCLUDING ASSESSMENT YEAR 2009-10 PASSED BY THE ITA No.3 of 2022 & conn.cases 17 COMMISSIONER OF INCOME TAX (APPEALS)-3, KOCHI. Annexure D1 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2009-10. Annexure D2 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2010-11. Annexure D3 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2011-12. Annexure D4 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2012-13. Annexure D5 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2014-15. Annexure D6 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2015-16. Annexure E1 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2009-10. Annexure E2 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2010-11. Annexure E3 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2011-12. Annexure E4 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2012-13. Annexure E5 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2014-15. ITA No.3 of 2022 & conn.cases 18 Annexure E6 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2015-16. Annexure F CERTIFIED COPY OF THE ORDER DATED 10.02.2022 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL. ITA No.3 of 2022 & conn.cases 19 APPENDIX OF ITA 7/2022 PETITIONER ANNEXURES Annexure A1 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.20215 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-II, KOCHI. Annexure A2 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV-IL), KOCHI Annexure A3 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV)-II, KOCHI Annexure A4 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-II, KOCHI. Annexure A5 TRUE COPY OF THE PANCHANAMA PREPARED ON 28.03.2015 BY THE INCOME TAX OFFICER (HQ), OFFICE OF THE DIRECTOR OF INCOME TAX(INV.), KOCHI. Annexure A6 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV)-II, KOCHI Annexure A7 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV-II), KOCHI Annexure B1 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2009-10 Annexure B2 TRUE COPY OF THE ASSESSMENT ORDER DATED 23.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2010-11. Annexure B3 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2011-12. Annexure B4 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2012-13. Annexure B5 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2014-15. Annexure B6 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2015-16 Annexure C TRUE COPY OF THE COMMON ORDER DATED 25.01.2021 FOR ALL THE YEARS INCLUDING ASSESSMENT YEAR 2009-10 PASSED BY THE ITA No.3 of 2022 & conn.cases 20 COMMISSIONER OF INCOME TAX (APPEALS)-3, KOCHI Annexure D1 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2009-10. Annexure D2 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2010-11. Annexure D3 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2011-12 Annexure D4 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED 22.02.2021) PASSED BY THE DEPUTY . AS COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI ASSESSMENT YEAR 2012-13. Annexure D5 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI ASSESSMENT YEAR 2014-15. Annexure D6 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2015-16. Annexure E1 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2009-10 Annexure E2 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2010-11 Annexure E3 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2011-12. Annexure E4 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2012-13. Annexure E5 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2014-15 ITA No.3 of 2022 & conn.cases 21 Annexure E6 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2015-16. Annexure F TRUE PHOTO COPY OF THE ORDER DATED 10.02.2022 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL. ITA No.3 of 2022 & conn.cases 22 APPENDIX OF ITA 3/2022 PETITIONER ANNEXURES Annexure A1 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-II, KOCHI. Annexure A2 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV-II), KOCHI Annexure A3 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-II, KOCHI Annexure A4 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-II, KOCHI Annexure A5 TRUE COPY OF THE PANCHANAMA PREPARED ON 28.03.2015 BY THE INCOME TAX OFFICER (HQ), OFFICE OF THE DIRECTOR OF INCOME TAX(LNV.), KOCHI. Annexure A6 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (LNV)-II, KOCHI Annexure A7 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV-II), KOCHI Annexure B1 TRUE COPY OF THE ASSESSMENT T ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2009-10. Annexure B2 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2010-11. Annexure B3 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2011-12. Annexure B4 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2012-13. Annexure B5 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2014-15. Annexure B6 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2015-16 Annexure C TRUE COPY OF THE COMMON ORDER DATED 25.01.2022 FOR ALL THE YEARS INCLUDING ASSESSMENT YEAR 2009-10 PASSED BY THE ITA No.3 of 2022 & conn.cases 23 COMMISSIONER OF INCOME TAX (APPEALS)-3, KOCHI. Annexure D1 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2009-10. Annexure D2 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2010-11 Annexure D3 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2011-12. Annexure D4 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI ASSESSMENT YEAR 2012-13. Annexure D5 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI ASSESSMENT YEAR 2014-15. Annexure D6 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, KOCHI FOR ASSESSMENT YEAR 2015-16. Annexure E1 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2009-10. Annexure E2 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2010-11. Annexure E3 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2011-12. Annexure E4 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2012-13 Annexure E5 TRUE COPY OF THE APPEAL DATED » J 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2014-15. ITA No.3 of 2022 & conn.cases 24 Annexure E6 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2015-16 Annexure F PHOTO COPY OF THE ORDER DATED 10.02.2022 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL. ITA No.3 of 2022 & conn.cases 25 APPENDIX OF ITA 2/2022 PETITIONER ANNEXURES Annexure A1 TRUE COPY THE PANCHANAMA PREPARED ON 27.03.20215 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV)-II, KOCHI. Annexure A2 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV-II), KOCHI. Annexure A3 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV)-II, KOCHI. Annexure A4 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV)-II, KOCHI. Annexure A5 TRUE COPY OF THE PANCHANAMA PREPARED ON 28.03.2015 BY THE INCOME TAX OFFICER (HQ), OFFICE OF THE DIRECTOR OF INCOME TAX(INV.), KOCHI. Annexure A6 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV)-II, KOCHI. Annexure A7 TRUE COPY OF THE PANCHANAMA PREPARED ON 27.03.2015 BY THE DEPUTY DIRECTOR OF INCOME TAX (INV-II), KOCHI. Annexure BI TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2009-10. Annexure B2 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2010-11. Annexure B3 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2011-12. ITA No.3 of 2022 & conn.cases 26 Annexure B4 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2012-13. Annexure B5 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2014-15. Annexure B6 TRUE COPY OF THE ASSESSMENT ORDER DATED 29.12.2016 OF THE RESPONDENT FOR ASSESSMENT YEAR 2015-16 Annexure C TRUE COPY OF THE COMMON ORDER DATED 25.01.2022 FOR ALL THE YEARS INCLUDING ASSESSMENT YEAR 2009-10 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS)-3, KOCHI. Annexure D1 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, KOCHI FOR ASSESSMENT YEAR 2009-10 Annexure D2 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, KOCHI FOR ASSESSMENT YEAR 2010-11. Annexure D3 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, KOCHI FOR ASSESSMENT YEAR 2011-12. Annexure D4 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- ITA No.3 of 2022 & conn.cases 27 2, KOCHI ASSESSMENT YEAR 2012-13. Annexure D5 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22.02.2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, KOCHI ASSESSMENT YEAR 2014-15. Annexure D6 TRUE COPY OF THE REVISED ASSESSMENT ORDER DATED 22.02.2020 (CORRECTED AS 22. 02 .2021) PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, KOCHI FOR ASSESSMENT YEAR 2015-16. Annexure E1 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2009-10. Annexure E2 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2010-11. Annexure E3 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2011-12. Annexure E4 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2012-13. Annexure E5 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2014-15. Annexure E6 TRUE COPY OF THE APPEAL DATED 03.02.2021 FILED BY THE APPELLANT BEFORE THE INCOME TAX APPELLATE TRIBUNAL FOR AY 2015-16. ITA No.3 of 2022 & conn.cases 28 Annexure F CERTIFIED COPY OF THE ORDER DATED 10.02.2022 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL. "