Canara Bank, Trivandrum V. DCIT (TDS), Trivandrum

ITA 474/COCH/2018

• Counselvise Citation: [2019] 115 COUNSELVISE.COM (IT) 9558 (ITAT-COCHIN)
• Duration Of Justice: 11 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-09-2019
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Next Hearing Date: 24-09-2019
• Assessment Year: 2009-2010
• Appeal Filed On: 16-10-2018
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: A S BINDHU
• Keywords: TDS
• Section: 201(1); 201

Judgement Text

1 IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN BEFOR E S/ SHRI CHANDRA POOJARI , AM & GEORGE GEORGE K., J M I .T . A. NO. 474 / COCH/ 201 8 ASSESSMENT YEAR : 2009 - 10 CANARA BANK, CANTONMENT BRANCH, TRIVANDRUM. [PAN:AAACC 6106 G ] VS. THE DEPUTY COMMISSIONER OF INCOME - TAX(TDS), TRIVANDRUM. (ASSESSEE - APPELLANT) (REVENUE - RESPONDENT) ASSESSEE BY NONE (WRITTEN SUBMISSION) REVENUE BY SMT. A.S. BINDHU, SR. DR D ATE OF HEARING 24/09/2019 DATE OF PRONOUNCEMENT 26 / 09 /201 9 O R D E R PER CHANDRA POOJARI, A M : THIS APPEAL FILED BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER OF THE CIT(A), TRIVANDRUM DATED 31/07/2018 AND PERTAIN TO THE ASSESSMENT YEAR 2009 - 10. 2. THERE WAS A SHORT DELAY OF 15 DAYS IN FILING THE APPEAL BEFORE THE TRIBUNAL. THE ASSESSEE HAS FILED CONDONATION PETITION ACCOMPANIED BY AN AFFIDAVIT STATING THAT THE ORIGINAL ORDER OF THE CIT(A) WAS RECEIVED ON 2 ND AUGUST, 2018 AND AS PER THE PROVISIONS OF INCOME TAX ACT, THE APPEAL SHOULD HAVE BEEN FILED ON 1 ST I.T.A. NO. 474/COCH/2018 2 OCTOBER, 2018, HOWEVER, THE APPEAL WAS FILED ON 15 TH OCTOBER, 2018 DUE TO THE REASON THAT THE TAXATION DEPARTMENT OF THE BANK WAS SITUATED IN BANGALORE AND TO FILE AN APPEAL BEFORE THE TRIBUNAL AS PER THE BANKS POLICY IT HAS TO GET APPROVAL FROM THE TAXATION DEPARTMENT. THE ORIGINAL ASSESSMENT ORDER AND TH E APPELLAT E ORDER WERE SENT TO THE DEPARTMENT FOR APPROVAL. IT WAS STATED THAT THERE WAS CHANGE IN THE TOP EXECUTIVE OF THE BANK IN THE MONTH OF SEPTEMBER AND DUE TO THIS CHANGE, THE APPROVAL WAS DELAYED WHICH WAS RECEIVED ONLY IN THE FIRST WEEK OF OCTOBE R 2018 AND THE PAPERS WERE SUBMITTED TO THE CHARTERED ACCOUNTANT FOR PREPARATION OF THE APPEAL. IT WAS SUBMITTED THAT THE DELAY IN FILING THE APPEAL WAS NOT WILLFUL BUT DUE TO REASONS BEYOND THE CONTROL OF THE ASSESSEE. HENCE, IT WAS PRAYED THAT THE DELAY OF 15 DAYS IN FILING THE APPEAL MAY BE CONDONED AND THE APPEAL ADMITTED. 2.1 WE HAVE GONE THROUGH THE CONDONATION PETITION AND WE FIND THAT THERE IS SUFFICIENT CAUSE FOR FILING THE APPEAL BELATEDLY BEFORE THE TRIBUNAL. HENCE, WE CONDONE THE SHORT DELAY OF 15 DAYS IN FILING THE APPEAL AND ADMIT THE APPEAL FOR ADJUDICATION. 3. THE ASSESSEE HAS RAISED THE FOLLOWING GROUNDS OF APPEAL: 1. THE CIT(A) HAS ERRED IN CHARGING INTEREST U/S. 201(1A) FROM THE DATE ON WHICH TAX WAS DEDUCTABLE AND UPTO 31/03/2015 IGNORING THE CONTENTION OF THE APPELLANT THAT SUPREME COURT HAS HELD IN HINDUSTHAN COCA - COLA CASE (245 ITR 13) THAT INTEREST U/S. 201(1A) SHOULD BE CHARGED ONLY UPTO THE DATE ON WHICH DEDUCTEE ASSESSEE PAI D THE TAX ON TOTAL INCOME. I.T.A. NO. 474/COCH/2018 3 2. THE CIT(A) DID NOT CONSIDER THE EVIDENCE PRODUCED BY THE APPELLANT THAT THE DEDUCTEE (KERALA STATE BEVERAGES CORPORATION) HAD INCLUDED THE INTEREST PAID BY THIS APPELLANT IN ITS TOTAL INCOME FOR THE A.Y. 2009 - 10 AND PAI D THE ENTIRE TAX ON TOTAL INCOME BY 31/05/2010. 4 . THE FACTS OF THE CASE ARE THAT ON VERIFICATION OF THE CASE RECORD OF THE KERALA STATE BEVERAGES CORPORATION LTD., TRIVANDRUM AND THE QUARTERLY TDS RETURNS FILED BY THE ASSESSEES CANTONMENT BRANCH, TRIVA NDRUM, THE ASSESSING OFFICER FOUND THAT THE SAID BRANCH HAD PAID TO THE SAID CORPORATION AN AMOUNT OF RS.4,10,16,457/ - AS INTEREST DURING THE F.Y. 2008 - 09 BUT HAD DEDUCTED RS.42,31,627/ - ONLY AS TAX U/S. 194A OF THE ACT. THE TAX DEDUCTIBLE U/S. 194A AGAIN ST THE INTEREST PAID TO THE SAID CORPORATION FOR THE F.Y. 2008 - 09 WAS AT 20.6% SINCE THE DEDUCTEE IS A DOMESTIC COMPANY AND TAX AT 20.6% WORKED OUT AT RS.84,49,390/ - . HENCE, THE ASSESSING OFFICER FOUND THAT THERE WAS SHORT DEDUCTION OF TAX AT RS.42,17,763 / - . AGAINST THE SAID DEFAULT COMMITTED IN SHORT DEDUCTION OF TAX, THE ASSESSING OFFICER TREATED THE ASSESSEE AS ASSESSEE IN DEFAULT U/S. 201(1A) OF THE ACT AND DIRECTED THE ASSESSEE TO REMIT THE TAX OF RS.42,17,763/ - WHICH WAS NOT DEDUCTED AT SOURCE TO TH E EXCHEQUER AND FURTHER LEVIED INTEREST OF RS.30,36,744/ - U/S. 201(1A) OF THE ACT AGAINST THE DEFAULT COMMITTED IN SHORT DEDUCTION OF TAX. 5 . ON APPEAL, THE CIT(A) AGREED WITH THE ASSESSEE THAT THE ASSESSEE CANNOT BE TREATED AS ASSESSEE IN DEFAULT IN V IEW OF THE JUDGMENT OF THE SUPREME COURT IN THE CASE OF HINDUSTHAN COCA - COLA BEVERAGES PVT. LTD. VS. CIT (293 ITR 226) I.T.A. NO. 474/COCH/2018 4 W HEREIN IT WAS HELD THAT WHERE NO TAX HAS BEEN DEDUCTED OR THERE IS SHORT FALL IN TAX DEDUCTED BUT THE DEDUCTEE HAD PAID THE TAX ON INCOM E EARNED THEN NO TAX SHALL BE RECOVERED FRO M THE DEDUCTOR. THE CIT(A) OBSERVED THAT WHAT IS SHOWN IN THE RETURN FILED BY THE SAID CORPORATION IS THE INTEREST OF RS.22,96,05,562/ - RECEIVED FROM FIXED DEPOSITS AND IT WAS NOT KNOWN WHERE THIS AMOUNT INCLUDED THE AMOUNT OF RS.4,10,16,457/ - CLAIMED TO HAVE BEEN PAID BY THE ASSESSEE OR NOT WHICH IS TO BE VERIFIED. ACCORDING TO THE CIT(A), THE ASSESSEE CLAIM THAT THE INCOME OF RS.2,29,60,562/ - OFFERED BY THE KERALA STATE BEVERAGES CORPORATION WAS ONLY FOR TAX BUT NOT RS.4,10,16,457/ - AS ORIGINALLY CLAIMED WHICH NEEDS TO BE LOOKED INTO AFRESH. SINCE BOTH THE INCOME OFFERED AND THE TAX PAID BY KERALA STATE BEVERAGES CORPORATION LTD. AGAINST THE INTEREST RECEIVED FROM THE ASSESSEE WAS NOT CLEAR, THE CIT(A) DIRECTED THE ASSESSEE TO FURNISH ALL DOCUMENTS TO THE ASSESSING OFFICER FOR FURTHER VERIFICATION AT HIS END. 5 .1 WITH REGARD TO THE CHARGING OF INTEREST U/S. 201(1A) OF THE ACT, THE CIT(A) OBSERVED THAT ASSESSEE CANNOT ESCAPE THE RIGOUR OF TAX SINCE THEY HAD AGREED THAT THEY HAVE NOT DEDUCTED THE TAX IN FULL LEAVING THEREBY A SHORT DEDUCTION OF RS.42,17,763/ - . HE RELIED ON THE JUDGMENT OF THE SUPREME COURT IN THE CASE OF HINDUSTHAN COCA - COLA BEVERAGES PVT. LTD. VS. CIT (293 ITR 226) WHEREIN IT WAS HELD THAT INTEREST U/S. 2 0 1(1A ) IS TO BE PAID BY THE ASSESSEE. THUS, THE CIT(A) CONFIRMED THE INTEREST CHARGED U/ S. 20(1A) OF THE ACT. I.T.A. NO. 474/COCH/2018 5 6. AGAINST THIS THE ASSESSEE IS IN APPEAL BEFORE US. NONE APPEARED ON BEHALF OF THE ASSESSEE. THE LD. AR HAS FILED WRITTEN SUBMISSION WHEREIN IT WAS SUBMITTED THAT CANARA BANK CANTONMENT BRANCH FILED THE TDS RETURNS FOR THE FINAN CIAL YEAR 2008 - 09. THE DEPARTMENT FOUND THAT THE BRANCH HA D DEDUCTED ONLY 10% AS TAX FROM KERALA STATE BEVERAGES CORPORATION LIMITED (KSBC) AS AGAINST THE ACTUAL RATE OF 20.3% AND A NOTICE WAS ISSUED ON 15/03/2015 TO THE BRANCH TO EXPLAIN WHY IT SHOULD NOT BE TREATED AS AN ASSESSEE IN DEFAULT WITHIN THE MEANING OF SECTION 201 OF THE INCOME TAX ACT. IT WAS SUBMITTED THAT THE BR ANCH SOUGHT ONE MONTH TIME FOR FILING THE REPLY FOR THE REASON THAT THE BANK HAD MIGRATED TO CORE BANKING SYSTEM AND THE RECORDS OF 2008 - 09 WERE IN THE OLD LEGACY SYSTEM AND NEEDED TIME TO CHECK THE RECORDS AND FILE THE REPLY. HOWEVER , IT WAS SUBMITTED THAT THE ASSESSING OFFICER DID NOT PROVIDE TIME AS THE ASSESSMENT WAS GETTING TIME BARRED ON 31/03/2015 AND HE TREATED THE B RANCH AS AN ASSESSEE IN DEFAULT WITHIN THE MEANING OF SECTION 201 OF THE INCOME TAX ACT. THE ASSESSING OFFICER MADE A DEMAND OF RS . 42,17,763 / - FOR SHORT DEDUCTION OF TAX AND ALSO CHARGED RS . 30,36,744 / - AS INTEREST U/S 201 OF THE INCOME TAX ACT AND THE INTEREST WAS CALCULATED AT L.5% PER MONTH FROM THE FIRST DAY OF THE ASSESSMENT YEAR (01/04/2009) TILL THE DATE OF COMPLETION OF ASSESSMENT(3103/2015). 6.1 AT THE TIME OF HEARING OF THE APPEAL BEFORE THE COMMISSIONER OF INCOM E - TAX(APPEALS), IT WAS ARGUED THAT THE JUDGMENT OF THE SUPREME COURT DECISION IN THE CASE OF HINDUSTAN COCO C OLA BEVERAGES PVT. LTD. VS. CIT (293 ITR 226) WAS I.T.A. NO. 474/COCH/2018 6 APPLICABLE TO THE ASSESSEE WHEREIN IT WAS HELD THAT IF THE DEDCUTEE HAS INCLUDED THE INCOME ON WH ICH SHORT DEDUCTION OF TAX WAS MADE HAS BEEN INCLUDED IN THE TOTAL INCOME AND TAX HAS BEEN PAID THERE ON THEN THE DEDUCTOR SHOULD NOT BE TREATED AS AN ASSESSEE IN DEFAULT. THERE WAS ALSO A CONDITION IN THE SAID JUDGMENT THAT THE DEDCUTEE ASSESEE SHOULD HAV E FILED THE RETURN OF I NCOME. I T WAS ALSO HELD BY THE SUPREME COURT THAT I NTEREST FOR SHORT DEDUCTION UNDER SECTION 201 SHOULD BE PAID FROM THE FIRST DAY OF THE ASSESSMENT YEAR TILL THE DATE ON WHICH DEDCUTEE ASSESSEE PAYS THE TAX THEREON. IT WAS SUBMITTED THAT D URING THE HEARING OF THE APPEAL , THE DETAILS REGA R DING THE FILING OF RETURNS BY THE DEDUCTEE ASSESSEE WERE PRODUCED BEFORE THE COMMISSIONER (APPEALS). HOWEVER, T HE COMMISSIONER (APPEALS) AFTER CONSIDERING THE DETAILS REMANDED THE CASE BACK TO THE ASSE SSING OFFICER WITH A DIRECTION TO VERIFY THE DETAILS PRODUCED REGARDING THE TAX RETURNS FILED BY THE DEDUCTEE ASSESSEE AND GIVE EFFECT TO THE JUDGMENT OF THE SUPREME COURT IN THE CASE OF HINDUSTAN COCO C OLA SUPRA. THE CIT(A) HOWEVER UPHELD THE I NTEREST CHARGED U/S 201 ( 1 A)OF THE INCOME TAX ACT BASED ON THE DECISION OF KERALA HIGH COURT IN CIT VS DHANALEKSHMI WEAVING WORKS(245!TR 13) IN WHICH THE H IGH COURT HELD INTEREST U/S 201 (1A) IS MANDATORY AND IT IS A LEVY TO CLAIM COMPENSATION ON THE AMOUNT WHICH OUGHT TO HAVE BEEN DEDUCTED AND DEPOSITED WHICH WAS NOT DONE. HOWEVER , IT WAS SUBMITTED THAT THE C OMMISSIONER ERRED IN DECIDING THE QUANTUM OF I NTEREST AND HE UPHELD THE ORDER OF THE ASSESSING OFFICER WHO CHARGED INTEREST FROM THE FIRST DAY OF THE ASSESSME NT YEAR TILL THE DATE OF C OMPLETION OF ASSESSMENT WHEREAS IT I.T.A. NO. 474/COCH/2018 7 WAS HELD BY THE SUPREME COURT IN THE CASE OF HINDUSTAN COCO C OLA CITED SUPRA THAT I NTEREST SHOULD BE CHARGED FROM THE FIRST DAY OF THE ASSESSMENT YEAR TILL THE DATE ON WHICH THE DEDUCTEE ASSESSEE PAYS THE TAX THEREON. THIS APPEAL IS FILED AGAINST THIS DECISION OF THE HONOURABLE COMMISSIONER OF INCOME TAX (APPEALS). THOUGH THERE WAS SHORT DEDUCTION OF TAX BY THE ASSESSEE, THE DEDCUTEE ASSESSEE HA D INCLUDED THE I NTEREST PAID BY THE ASSESSEE ON THE TOTAL INCOME FOR THE ASSESSMENT Y EAR 2 009 - 10. THE LD. AR ENCLOSED THE COPY OF COMPUTATION OF TOTAL INCOME OF KSBC (DEDUCTEE) AND ITRV . THE WHOLE INTEREST PAID BY THIS ASSESSEE WA S INCLUDED IN THE TOTAL INCOME AS CAN BE SEEN IN THE COMPUTATION STATEMENT. IT WAS SUBMITTED THAT THE ASSESSING OFFICER WHEN CONSIDERING THE DETAILS PRODUCED BY TH E ASSESSEE AT THE TIME OF HEARING OF THE REMANDED CASE HA D HELD THAT THE DEDUCTEE ASSESSEE HA D INCLUDED THE I NTEREST PAID BY THE ASSESSEE IN THE TOTAL INCOME AND HA D PAID THE TAX THEREON AND COMPLETED THE ASSESSMENT DELETING THE SH ORT DEDUCTION OF RS . 42,17,763 / - ORIGINALLY ASSESSED . THUS , IT WAS CLEAR FROM THE REVISED ORDER THAT THE DEPARTMENT ALSO AGREE D WITH THE JUDGMENT OF THE SUPREME E COURT IN THE CA SE OF HINDUSTAN COCO C OLA SUPRA AND THE CASE WAS APPLICABLE TO THE ASSESSEE. 6.2 IT WAS SUBMITTED THAT THE S UPREME COURT HA D HELD IN HINDUSTAN COCO C OLA SUPRA THAT I NTEREST SHOULD BE CHARGED FROM THE FIRST DAY OF THE ASSESSMENT YEAR TILL THE DATE OF PAYMENT OF TAX BY THE DEDUCTEE ASSESSEE. HOWEVER, IT WAS SUBMITTED THAT THE ASSESSING OFFICER HAD VERIFIED THE DETAILS OF FILING OF THE I.T.A. NO. 474/COCH/2018 8 RETURNS BY THE DEDUCTEE ASSESSEE AND HA D DELETED THE SHORT DEDUCTION OF RS . 42,17,763 / - . THE DEDCUTEE ASSESSEE HA D PAID THE ENTIRE TAX DUE ON THE TOTAL INCOME ON 31/05/2009 AS PER FORM 26AS . HENCE , BASED ON THE SUPREME COURT JUDGMENT IN THE CASE OF HINDUSTAN COCO C OLA SUPRA, I NTEREST UNDER SECTION 201(1A) SHOULD BE CHARGED ONLY FOR TWO MONTHS ( 1 ST APRIL 2009 TO 31 ST MARCH 2009). IT WAS SUBMITTED THAT THE ASSESSING OFFICER IN THE ORIGINAL ASSESSMENT ORDER HA D CHARGED I NTEREST FROM THE FIRST D AY OF THE ASSESSMENT YEAR TILL THE DATE OF PASSING OF ORDER (1 ST APRIL 2009 TO 31 ST MARCH 2015) WHICH IS AGAINST THE JUDGMENT O F THE SUPREME COURT IN THE CASE OF HINDUSTAN COCO C OLA SUPRA . HOWEVER , IT WAS SUBMITTED THAT THE CIT(A) UPHELD THE I NTEREST CHARGED UNDER SECTION 201(1A) BASED ON THE DECISION OF THE KERALA HIGH COURT IN DHANLEKSHMI W EAVING M ILLS SUPRA BUT FAILED IN QUANT IFYING THE INTEREST TO BE CHARGED. IT WAS SUBMITTED THAT E VEN IN THE CASE OF HINDUSTAN COCO COLA SUPRA, THE SUPR EME COURT HA D HELD THAT I NTEREST SHOULD BE CHARGED UNDER SECTION 201(1A) BUT HELD THAT IT SHOULD BE FOR THE PERIOD FROM THE FIRST DAY OF THE A SSESSMENT YEAR TILL THE DATE OF PAYMENT OF TAX BY THE DEDUCTEE ASSESSEE. THE SUPREME C OURT HA D IN PARA 10 OF THE JUDGMENT IN THE CASE OF HINDUSTAN COCO C OLA SUPRA CLEARLY HELD THAT I NTEREST SHOULD BE CHARGED TILL THE DATE OF PAYMENT OF TAX BY THE DEDCUTEE ASSESSEE. TO QUOTE 'BE THAT AS IT MAY, THE C IRCULAR NO 275/201/95 - ITB ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES, IN OUR CONSIDERED OPINION S HOULD PUT AN END TO THE CONTROVERSY. THE CIRCULAR DECLARES 'NO DEMAND VISUALIZED UNDER SECTION 201(1) OF THE INC OME TAX ACT SHOULD BE ENFORCED AFTER THE TAX DEDUCTOR HAS I.T.A. NO. 474/COCH/2018 9 SATISFIED THE OFFICER IN CHARGE OF TDS, THAT TAXES DUE HAVE BEEN PAID BY THE DEDUCTEE ASSESSEE. HOWEVER THIS WILL NOT ALTER THE LIABILITY TO CHARGE I NTEREST UNDER SECTION 201(1A) OF THE ACT TILL THE PAYMENT OF TAXES BY THE DEDUCTEE - ASSESSEE OR THE LIABILITY OF PENALTY UNDER SECTION 271C OF THE INCOME TAX ACT' . IN THE PRESENT CASE, THE ASSESSING OFFICER WAS CONVINCED THAT THE DEDUCTEE ASSESSEE HA D INCLUDED THE INTEREST PAID BY TH E ASSESSEE IN THE T OTAL I NCOME AND PAID TAX THER EON. BASED ON THE EVIDENCE PRODUCED , THE ASSESSING OFFICER HAD DELETED THE DEMAND ON ACCOUNT OF THE SHORT DEDUCTION OF RS . 42,17,763 / - . THUS, IT WAS SUBMITTED THAT THE DEDCUTEE ASSESSEE HA D PAID THE TAX DUE ON THE TOTAL I NCOME ON 31/05/2019 AND B ASED ON THE JUDGMENT OF THE SUPREME COURT IN THE CASE OF HINDUSTHAN COCO COLA SUPRA, I NTEREST SHOULD ONLY BE CHARGED FOR TWO MONTHS AND HENCE , IT WAS REQUESTED THE DECISION OF THE CIT(A) I N UPHOLDING THE CHARGING OF THE INTEREST FROM TH E FIRST DAY OF THE ASSESSMENT YEAR TILL THE COMPLETION OF ASSESSMENT BE CANCELLED AND I NTEREST UNDER SECTION 201(1A ) BE CHARGED FROM THE FIRST DAY OF ASSESSMENT YEAR (01/04/2009) TO THE DATE OF PAYMENT OF TAX BY THE DEDUCTEE ASSES SEE (31/05/2009) . 7. LD. DR RELIED ON THE ORDER OF THE LOWER AUTHORITIES. 8. WE HAVE HEARD THE RIVAL SUBMISSIONS AND PERUSED THE RECORD. THE ONLY DISPUTED ISSUE IS WITH REGARD TO PERIOD OF COMPUTATION OF INTEREST U/S. 201(1A) OF THE ACT. THE CONTENTION OF THE LD. AR IS THAT THE SUPREME COURT IN THE CASE OF I.T.A. NO. 474/COCH/2018 10 HINDUSTHAN COCA - COLA BEV ERAGES PVT. LTD. VS. CIT (293 ITR 226) HELD THAT INTEREST U/S. 201(1A) OF THE ACT IS TO BE CHARGED TILL THE DATE OF PAYMENT OF TAX BY DEDUCTEE - ASSESSEE. IN THE PRESENT CASE, THE ASSESSING OFFICER HAS TO CONSIDER THE SHORT DEDUCTION OF TDS AND THEREAFTER, HE SHALL CHARGE INTEREST U/S. 201(1A) OF THE ACT FROM THE DATE OF DEDUCTI BLE TAX TILL THE DATE ON WHICH THE DEDUCTEE - ASSESSEE PAID THE TAX ON ITS TOTAL INCOME. WITH THIS OBSERVATION, WE REMIT THIS ISSUE TO THE FILE OF THE ASSESSING OFFICER TO RE - COMPUTE T HE INTEREST U/S. 201(1A) OF THE ACT . 9. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON THIS 26 TH SEPTEMBER , 2019 SD/ - SD/ - ( GEORGE GEORGE K. ) ( CHANDRA POOJARI ) JUDIICAL MEMBER ACCOUNTANT MEM BER PLACE: KOCHI DATED 26 TH SEPTEMBER , 201 9 GJ COPY TO: 1 . CANARA BANK, CANTONMENT BRANCH, TRIVANDRUM. 2. THE D EPUTY COMMISSIONER OF INCOME - TAX (TDS) , TRIVANDRUM. 3. THE COMMISSIONER OF INCOME - TAX (AP P EALS) , TRIVANDRUM. 4. THE PR. COMMISSIONER OF INCOME - TAX, TRIVANDRUM. 5. D. R., I.T.A.T., COCHIN BENCH, COCHIN. 6 . GUARD FILE. BY ORDER (ASSISTANT REGISTRAR) I.T.A.T., COCHIN I.T.A. NO. 474/COCH/2018 11