OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED, V. THE ASSISTANT COMMISSIONER OF INCOME TAX

WP(C)/21952/2022

AI Insights

Olam Food Ingredients India Private Limited filed writ petitions against the Assistant Commissioner of Income Tax and other officials, seeking enforcement of the Appellate Tribunal's orders regarding tax assessments for several years. The Tribunal's orders, which favored the petitioner, were not implemented by the tax authorities due to alleged non-cooperation from the petitioner. The court, after hearing both parties, decided to facilitate the completion of the assessments by setting a timeline for the petitioner to provide necessary documents and for the tax authorities to finalize the assessments, while also addressing the issue of potential limitation under the Income Tax Act.

• Counselvise Citation: [2022] 140 COUNSELVISE.COM (IT) 683610 (HC-KERALA)
• Appeal Type: Others
• Pronouncement Date: 17-08-2022
• Assessment Year: misc
• Other Referred Cases: ITA No. 52/2015, ITA Nos. 19, 45 and 129 of 2013, I.T.A. Nos. 513/COCHI/2009 and 514/COCHI/2009, I.T.A. No. 516/COCHI/2009
• Laws Referred To: Income Tax Act
• Result in Favour of: Partly Allowed
• Court: HIGH COURT
• Department Lawyers: JOSE JOSEPH
• Assessee Lawyers: ALEXANDER MARKOS
• Keywords: Appellate Tribunal; Assessment Order; Document Requirement; Income Tax; Limitation; Non-cooperation
• Section: 148; 143(3); 142(1); 154; 153; 144C; 144C(13); 144C(5); 254; 92CA(3); 144C(8); 155

Judgement Text

"IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17TH DAY OF AUGUST 2022 / 26TH SRAVANA, 1944 WP(C) NO. 21627 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED (FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTD AND OLAM EXPORTS INDIA LTD.) FLOOR NO. 5, BISHOP JEROME NAGAR KOLLAM -, KERALA, INDIA REPRESENTED BY ITS DIRECTOR, AMIT KHAKHOLIA, PIN - 691001 BY ADV ALEXANDER JOSEPH MARKOS RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, KOLLAM RANGE, KOLLAM, KERALA -, PIN - 691001 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, KOLLAM RANGE, KOLLAM, KERALA , PIN - 691001 3 PR. CHIEF COMMISSIONER OF INCOME TAX A.R.BUILDING. I.A.PREGS ROAD, COCH]N - KERALA, PIN - 682018 BY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 17.08.2022, ALONG WITH WP(C).21952/2022, 21979/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -2- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17TH DAY OF AUGUST 2022 / 26TH SRAVANA, 1944 WP(C) NO. 21952 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED, (FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTD AND OLAM EXPORTS INDIA LTD.) FLOOR NO. 5, BISHOP JEROME NAGAR, KOLLAM -, KERALA, INDIA REPRESENTED BY ITS DIRECTOR, AMIT KHAKHOLIA., PIN - 691001 BY ADV ALEXANDER JOSEPH MARKOS RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, KOLLAM RANGE, KOLLAM, KERALA-, PIN - 691001 2 PR. CHIEF COMMISSIONER OF INCOME TAX C.R, BUILDING, I.S PRESS ROAD, COCHIN -, PIN - 682018 BY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 17.08.2022, ALONG WITH WP(C).21627/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -3- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17TH DAY OF AUGUST 2022 / 26TH SRAVANA, 1944 WP(C) NO. 21979 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED, (FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTD. AND OLAM EXPORTS INDIA LTD.) FLOOR NO. 5, BISHOP JEROME NAGAR, KOLLAM -, KERALA, INDIA REPRESENTED BY ITS DIRECTOR, AMIT KHAKHOLIA., PIN - 691001 BY ADVS. ALEXANDER JOSEPH MARKOS ABRAHAM JOSEPH MARKOS ISAAC THOMAS SHARAD JOSEPH KODANTHARA RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1, KOLLAM RANGE, KOLLAM, KERALA, PIN - 691001 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, KOLLAM RANGE, KOLLAM, KERALA -, PIN - 691001 3 PRL. CHIEF COMMISSIONER OF INCOME TAX C.R.BUILDING. I.S. PRESS ROAD, COCHIN ,KERALA, PIN - 682018 BY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 17.08.2022, ALONG WITH WP(C).21627/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -4- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE GOPINATH P. WEDNESDAY, THE 17TH DAY OF AUGUST 2022 / 26TH SRAVANA, 1944 WP(C) NO. 21988 OF 2022 PETITIONER: OLAM FOOD INGREDIENTS INDIA PRIVATE LIMITED, (FORMERLY KNOWN AS OLAM AGRO INDIA PRIVATE LTD AND OLAM EXPORTS INDIA LTD.) FLOOR NO. 5, BISHOP JEROME NAGAR, KOLLAM ,KERALA, INDIA REPRESENTED BY ITS DIRECTOR, AMIT KHAKHOLIA, PIN - 691001 BY ADV ALEXANDER JOSEPH MARKOS RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, KOLLAM RANGE, KOLLAM, KERALA -, PIN - 691001 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, KOLLAM RANGE, KOLLAM, KERALA -., PIN - 691001 3 PR. CHIEF COMMISSIONER OF INCOME TAX C.R BUILDING, I.S PRESS ROAD, COCHIN - 682 018, KERALA BY ADV JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 17.08.2022, ALONG WITH WP(C).21627/2022 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -5- J U D G M E N T The petitioner is common in all these 4 writ petitions. It has approached this court being aggrieved by the fact that the Assistant Commissioner of Income Tax, Circle-I, Kollam Range, Kollam, has not given effect to the orders of Appellate Tribunal in respect of assessment orders for the assessment years 2000-2001, 2001-2002, 2002-2003 and 2008-2009, though the orders of the Tribunal were issued on 25-05-2012 in respect of assessment years 2000-2001, 2001-2002 & 2002-2003 and on 22-11-2013 in respect of assessment year 2008-2009. The orders of the Appellate Tribunal under Section 254 of the Income Tax Act were affirmed by a Division Bench of this court by judgment dated 28-05-2015 in respect of assessment years 2000-2001, 2001-2002 & 2002-2003 and by judgment dated 06-10-2017 in respect of assessment year 2008-2009. 2. The learned counsel appearing for the respondent/Department states that the orders of the Tribunal could not be given effect to only on account of the fact that there is complete non-cooperation on behalf of the petitioner/assessee. The learned counsel for the petitioner in these cases would submit that since the assessment years in question relate to 2000-2001, 2001-2002, 2002-2003 & 2008- 2009, the petitioner will provide whatever details that are now available, to enable to completion of the assessment in the manner directed by the Tribunal. It is submitted that the petitioner also has a case that such assessments are now barred going by the provisions contained in Section 153 of the Income Tax Act. 3. Having regard to the submissions made by the learned counsel in these cases and the learned Standing Counsel appearing for the Department, I am of the opinion that these writ petitions can be disposed of in the following manner; W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -6- (i) The Assistant Commissioner of Income Tax, Circle-I, Kollam Range shall, within one month from the date of receipt of a certified copy of this judgment, indicate to the petitioner the documents required for giving effect to the orders of the Tribunal. The petitioner shall endeavour to provide the details requested for within a period of one month from the date on which the request is made by the Assistant Commissioner of Income Tax in the manner indicated above. (ii) On receipt of the information (to the extent it is available), the Assistant Commissioner of Income Tax, Circle-I, Kollam Range shall complete the assessment for all the assessment years in question, after affording an opportunity of hearing to a representative of the petitioner in these cases with a period of 3 months thereafter. (iii) The Assistant Commissioner of Income Tax, Circle-I, Kollam Range shall also consider the contention of the petitioner that the assessments are barred by limitation in terms of the provisions contained in Section 153 of the Income Tax Act. The writ petitions are disposed of as above. All contentions of the petitioners are left open. Sd/- GOPINATH P. JUDGE AMG W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -7- APPENDIX OF WP(C) 21952/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE ORDER DATED 22.11.2013 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN I.T.(TP) A. NO.03/COCHI/2013 FOR AY 2008-09. Exhibit P2 TRUE COPY OF THE ORDER DATED 06.10.2017 PASSED BY THIS HONOURABLE COURT IN ITA NO.52/2015 Exhibit P3 RETURN OF INCOME FILED BY THE PETITIONER ON 30.09.2008 FOR ASSESSMENT YEAR 2008/2009 Exhibit P4 TRUE COPY OF THE AUDITED FINANCIALS FOR THE YEAR ENDED 31ST MARCH 2008 Exhibit P5 TRUE COPY OF THE TAX AUDITED REPORT FOR THE YEAR ENDED 31ST MARCH 2008 Exhibit P6 TRUE COPY OF THE ORDER DATED 28.10.2011 PASSED BY THE TRANSFER PRICING OFFICER, KOCHI (TPO) UNDER SECTION 92CA(3) OF THE INCOME TAX ACT , 1961 Exhibit P7 TRUE COPY OF THE DRAFT ASSESSMENT ORDER DATED 29.12.2011 PASSED BY THE ADDITIONAL COMMISSIONER OF INCOMETAX, KOLLAM RANGE,KOLLAM UNDER SECTION 144C/92CA OF THE INCOME TAX ACT ,1961 Exhibit P8 TRUE COPY OF THE DIRECTIONS DATED 28.08.2012 ISSUED BY THE DISPUTE RESOLUTION PANEL (DRP), BANGALORE UNDER SECTION 144C(5)/144C(8) OF THE INCOME TAX ACT,1961. Exhibit P9 TRUE COPY OF THE ORDER DATED 27.12.2012 PASSED BY THE JOINT COMMISSIONER OF INCOME TAX, KOLLAM UNDER SECTION 143(3)/144C(13) OF THE INCOME TAX ACT,1961. Exhibit P10 TRUE COPY OF THE RECEIPT OF PAYMENT OF TAX VIDE CHALLAN DATED 10.08.2013 BEARIN SERIAL NO.10672. Exhibit P11 TRUE COPY OF THE REQUEST LETTER DATED 09.01.2020 ADDRESSED BY THE PETITIONER TO THE LST RESP PONDENT. Exhibit P12 TRUE COPY OF THE NOTICE OF DEMAND DATED 13.01.2020 ISSUED BY THE 1ST RESPONDENT. W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -8- Exhibit P13 TRUE COPY OF THE REQUEST LETTER DATED 23.01.2020 ADDRESSED BY THE PETITIONER TO THE LST RESPONDENT Exhibit P14 TRUE COPY OF THE GRIEVANCE DATED 25.08.2020 FILED BY THE PETITIONER ON THE E-FILING PORTAL E-NIVARAN Exhibit P15 TRUE COPY OF THE GRIEVANCE DATED 22.02.2021 FILED BY THE PETITIONER ON THE E-FILING PORTAL E-NIVARAN. Exhibit P16 TRUE COPY OF THE REPRESENTATION DATED 20.10.2021 ADDRESSED BY THE PETITIONER BEFORE THE LST RESPONDENT Exhibit P17 TRUE COPY OF THE REPRESENTATION DATED 04.05.2022 ADDRESSED BY THE PETITIONER BEFORE THE LST RESPONDENT Exhibit P18 TRUE COPY OF THE REPRESENTATION DATED 24.05.2022 ADDRESSED BY THE PETITIONER BEFORE THE LET RESPONDENT. W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -9- APPENDIX OF WP(C) 21979/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE ORDER DATED 25.05.2012 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL IN I.T.A. NOS. 513/COCHI/2009 AND 514/COCHI/2009. Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 28.05.2015 PASSED BY THIS HON'BLE COURT IN I.T.A. NOS.19, 45 AND 129 OF 2013. Exhibit P3 TRUE COPY OF THE ACKNOWLEDGEMENT OF THE REVISED RETURN OF INCOME FILED BY THE PETITIONER FOR ASSESSMENT YEAR 2000-01. Exhibit P4 TRUE COPY OF THE ASSESSMENT ORDER DATED 30.03.2004 PASSED BY THE 2ND RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOME TAX ACT. Exhibit P5 TRUE COPY OF THE ASSESSMENT ORDER DATED 30.09.2004 PASSED BY THE 2ND RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOME TAX ACT. Exhibit P6 TRUE COPY OF THE ORDER DATED 18.02.2005 PASSED BY THE LST RESPONDENT. Exhibit P7 TRUE COPY OF THE ORDER DATED 22.01.2008 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH. Exhibit P8 TRUE COPY OF THE ORDER DATED 12.11.2007 PASSED BY THE LST RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOME TAX ACT. Exhibit P9 TRUE COPY OF THE NOTICE DATED 07.01.2008 ISSUED BY THE LST RESPONDENT UNDER SECTION 154/155 OF THE INCOME TAX ACT, 1961. Exhibit P10 TRUE COPY OF THE RECTIFICATION ORDER DATED 06.05.2008 PASSED BY THE LST RESPONDENT. Exhibit P11 TRUE COPY OF THE ORDER DATED 2 04.02.2009 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS)-LL, KOCHI. Exhibit P12 TRUE COPY OF THE ORDER DATED 16.03.2009 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS) -11, KOCHI. W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -10- Exhibit P13 TRUE COPY OF THE ORDER DATED 30.06.2009 PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, KOLLAM Exhibit P14 TRUE COPY OF THE ORDER DATED 25.11.2011 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN. Exhibit P15 TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 SENT BY THE PETITIONER TO THE 1 ST RESPONDENT. Exhibit P16 TRUE COPY OF THE REPRESENTATION DATED 05.05.2022 SENT BY THE PETITIONER TO THE 1ST RESPONDENT. DATED W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -11- APPENDIX OF WP(C) 21988/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE ORDER DATED 25.05.2012 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN LT.A. NO.516/COCHI/2009. Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 28.05.2015 PASSED BY THIS HONOURABLE COURT IN ITA NOS.19, 45 AND 129 OF 2013 Exhibit P3 TRUE COPY OF THE ACKNOWLEDGEMENT OF THE RETURN OF INCOME FILED BY THE PETITIONER FOR ASSESSMENT YEAR 2002-03. Exhibit P4 TRUE COPY OF THE ASSESSMENT ORDER DATED 28.03.2005 PASSED BY THE LS` RESPONDENT UNDER SECTION 143(3) OF THE INCOMETAXACT 1961. Exhibit P5 TRUE COPY OF THE APPELLATE ORDER 47 - 5253-55 DATED 30.03.2006 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS )-III ,TRIVANDRUM Exhibit P6 TRUE COPY OF THE ORDER DATED 16.08.2007 PASSED BY THE INCOME TAX PASSED BY THE INCOME TAX . APPELLATE TRIBUNAL , COCHIN BENCH , COCHIN Exhibit P7 TRUE COPY OF THE ORDER DATED 12.11.2007 PASSED BY THE LS` RESPONDENT UNDER SECTION 143(3)/147 OF THE INCOME TAX ACT 1961 Exhibit P8 TRUE COPY OF THE ORDER DATED 16.03.2009 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS) -11 KOCHI. Exhibit P9 TRUE COPY OF THE ORDER DATED 03.11.2009 PASSED B THE 2ND RESPONDENT. Exhibit P10 TRUE COPY OF THE REPRESENTATION DATED 12.05.2015 ISSUED BY THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE L ST RESPONDENT. Exhibit P11 TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 ISSUED BY THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE 1 ST RESPONDENT Exhibit P12 TRUE COPY OF THE REPRESENTATION DATED 31.07.2018 ISSUED BY THE PETITIONER'S CHARTERED ACCOUNTANTS TO THE 1 ST RESPONDENT. Exhibit P13 TRUE COPY OF THE REPRESENTATION DATED 05.05.2022 ISSUED BY THE PETITIONER TO THE 1 ST RESPONDENT. W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -12- APPENDIX OF WP(C) 21627/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE ORDER DATED 25.05.2012 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN IN I.T.A. NO.515/COCHI/2009. Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 28.05.2015 PASSED BY THIS HONOURABLE COURT IN ITA NOS.19, 45 AND 129 OF 2013. Exhibit P3 TRUE COPY OF THE ACKNOWLEDGEMENT OF THE RETURN OF INCOME FILED BY THE PETITIONER ON 29.10.2001 FOR ASSESSMENT YEAR 2001-02. Exhibit P4 TRUE COPY OF THE ASSESSMENT ORDER DATED 30.03.2004 PASSED BY THE 2ND RESPONDENT UNDER SECTION 143(3) OF THE INCOME TAX ACT. Exhibit P5 TRUE COPY OF THE ORDER DATED 30.09.2004 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS)-LLL, THIRUVANANTHAPURAM Exhibit P6 TRUE COPY OF THE ORDER DATED 28.09.2006 PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, KOLLAM. Exhibit P7 TRUE COPY OF THE NOTICE DATED 04.12.2006 ISSUED BY THE 2ND RESPONDENT UNDER SECTION 148 OF THE INCOME TAX ACT, 1961 Exhibit P8 TRUE COPY OF THE NOTICE DATED 07. 03.2007 ISSUED BY THE DEPUTY COMMISSIONER OF INCOME TAX UNDER SECTION 142(1 ) (II) OF THE INCOME TAX ACT,1961. Exhibit P9 TRUE COPY OF THE NOTICE DATED 18.10.2007 ISSUED BY THE LST RESPONDENT UNDER SECTION 148 OF THE INCOME TAX ACT,1961. Exhibit P10 TRUE COPY OF THE LETTER DATED 21.04.2008 ISSUED BY THE LST RESPONDENT TO THE PETITIONER. Exhibit P11 TRUE COPY OF THE ORDER DATED 29.04.2008 PASSED BY THE LST RESPONDENT UNDER SEE.143(3)/147 OF THE INCOME TAX ACT. Exhibit P12 TRUE COPY OF THE ORDER DATED 12.05.2008 PASSED BY THE LST RESPONDENT UNDER SECTION 154 OF THE INCOME TAX ACT. Exhibit P13 TRUE COPY OF THE ORDER DATED 18.03.2009 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS)LL, KOCHI Exhibit P14 TRUE COPY OF THE ORDER DATED 26.06.2009 PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, KOLLAM W.P (C) Nos.21627, 21952, 21979 & 21988/2022 -13- Exhibit P15 TRUE COPY OF THE ORDER DATED 28.12.2013 PASSED BY THE LST RESPONDENT. Exhibit P16 TRUE COPY OF THE ORDER DATED 25.11.2011 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN. Exhibit P17 TRUE COPY OF THE REPRESENTATION DATED 12.05.2015 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P18 TRUE COPY OF THE REPRESENTATION DATED 04.04.2017 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P19 TRUE COPY OF THE REPRESENTATION DATED 31.07.2018 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE LST RESPONDENT. Exhibit P20 TRUE COPY OF THE REPRESENTATION DATED 05.05.2022 MADE BY THE CHARTERED ACCOUNTANTS OF THE PETITIONER TO THE 1 ST RESPONDENT. "