THE ANDOORKONAM SERVICE CO-OPERATIVE BANK LTD., V. THE ASSISTANT COMMISSIONER OF INCOME TAX,

WP(C)/9673/2019

AI Insights

The case involves multiple writ petitions filed by various Primary Agricultural Credit Societies (PACCS) challenging the tax deduction at source on interest income from deposits with the State Treasury and District Co-operative Banks. The main legal issue was whether these societies qualify for exemptions under Sections 194A(3)(iii)(a) and 194A(3)(iii)(v) of the Income Tax Act. The court examined the definitions of 'banking' and 'co-operative society' under relevant laws and previous judgments to determine the applicability of these exemptions.

• Counselvise Citation: [2019] 140 COUNSELVISE.COM (IT) 758524 (HC-KERALA)
• Appeal Type: Others
• Pronouncement Date: 03-12-2019
• Assessment Year: misc
• Other Referred Cases: The Hooseini co-operative credit vs. Assessee [(2015) 377 ITR 272], Income Tax Appellate Tribunal, Kochi Bench in ITA No. 596/COCH/2017, Income Tax Appellate Tribunal, Kochi Bench in ITA No. 420/COCH/2018
• Laws Referred To: Income Tax Act, Banking Regulation Act, 1949, Kerala Co-operative Societies Act 1969
• Result in Favour of: Partly Allowed
• Court: HIGH COURT
• Department Lawyers: CHRISTOPHER ABRAHAM; THOMAS ABRAHAM
• Assessee Lawyers: K P PRADEEP; SANAND RAMAKRISHNAN; NEENA ARIMBOOR; T T BIJU; T THASMI; ANJANA KANNATH
• Keywords: Banking Business; Co-operative societies; Exemption; Income by way of interest; Tax deduction at source
• Section: 194A; 194A(3)(iii)(a); 194A(3)(iii)(v)

Judgement Text

"IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.7795 OF 2019(Y) PETITIONER: THE CHIRAYINKEEZHU SERVICE CO-OPERATIVE BANK LIMITED NO.1155, BANK BUILDING, CHIRAYANKIL.P.O. THIRUVANANTHAPURAM-695304, REPRESENTED BY ITS SECRETARY ANIL KUMAR.A BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 3 INCOME TAX OFFICER, WARD 2(5)-RANGE 2 AYAKAR BHAVAN, INCOME TAX, KOWADIAR, THIRUVANANTHAPURAM-695003. 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK HEAD OFFICE, THIRUVANANTHAPURAM EAST FORT P.O., THIRUVANANTHAPURAM-695023 REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS THYCAUD.P.O., THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY(CO-OPERATION), GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001 WP(C).No.7795 OF 2019 & CONNECTED CASES 2 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC THOMAS ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).10094/2019(J) AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 3 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.10094 OF 2019(J) PETITIONER: OACHIRA SERVICE CO-OPERATIVE BANK LTD. NO. 1391, OACHIRA P.O, KOLLAM DISTRICT - 690 526, REPRESENTED BY ITS SECRETARY MEERADEVI V. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENTS: 1 THE CENTRAL BOARD OF DISTRICT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI - 682 018 3 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKKADA, KOLLAM - 691 001, REPRESENTED BY ITS GENERAL MANAGER 5 TREASURY DIRECTOR DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, WP(C).No.7795 OF 2019 & CONNECTED CASES 4 THYCAUD P.O, THIRUVANANTHAPURAM - 695 014 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001 R1 AND R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 5 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.10096 OF 2019(J) PETITIONERS: 1 KULASEKHARAPURAM SERVICE COOPERATIVE BANK LTD.NO.Q.218 NO.Q.218,CLAPPANA P.O, KOLLAM DISTRICT-690546, REPRESENTED BY ITS SECRETARY LEELAMANY A, 2 VAYANAKAM SERVICE COOPERATIVE BANK LTD NO.1438, VAYANAKAM, NJAKKANAL P.O, OACHIRA, KOLLAM DISTRICT- 690533, REPRESENTED BY ITS SECRETARY ANITHA JAYAPRASAD., BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENTS: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI-682018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695003. WP(C).No.7795 OF 2019 & CONNECTED CASES 6 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, DISTRICT CO--OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM-691001, REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY P.C SASIDHARAN. SC FOR KOLLAM DISTRICT CO- OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 7 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.10101 OF 2019(K) PETITIONER/S: VAKKOM FARMERS SERVICE CO-OPERATIVE BANK LTD NO.542, VAKKOM P.O, THIRUVANANTHAPURAM - 695 308, REPRESENTED BY ITS MANAGING DIRECTOR SATHEESAN. S. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S ROAD, KOCHI - 682 018 3 ADDITIONAL COMMISSINER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK HEAD OFFICE, THIRUVANANTHAPURM, EAST FORT P.O, THIRUVANANTHAPURAM - 695 023, REPRESENTED BY ITS GENERAL MANAGER 5 TREASURY DIRECTOR WP(C).No.7795 OF 2019 & CONNECTED CASES 8 DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, TGIRUVANANTHAPURAM - 695 014 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY(CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVNANTHAPURAM- 695 001 R1 AND R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 9 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.10105 OF 2019(K) PETITIONER: ARACKAL SERVICE CO-OPERATIVE BANK LTD.NO.1858 ARACKAL, PERUMANOOR P.O, KOLLAM DISTRICT - 691 532, REPRESENTED BY ITS SECRETARY ABHILASH BY ADV. DR.K.P.PRADEEP RESPONDENTS: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION,MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018 3 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKKADA, KOLLAM - 691 001, REPRESENTED BY ITS GENERAL MANAGER 5 TREASURY OFFICER DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM - 695 014 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, WP(C).No.7795 OF 2019 & CONNECTED CASES 10 THIRUVANANTHAPURAM - 695 001 R1 AND R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SC, P.C SASIDHARAN, THE KOLLAM DISTRICT CO- OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 11 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.10474 OF 2019(H) PETITIONER: VAZHAPPALLY SERVICE CO-OPERATIVE BANK LTD. NO. K 108 VAZHAPPALLY, CHANGANASSERY, KOTTAYAM, 686 103. REPRESENTED BY ITS SECRETARY SHINY SEBASTIAN BY ADVS. SRI.T.A.SHAJI (SR.) SHRI.NIKHIL SUNNY MOOKEN SRI.S.ABHILASH VISHNU RESPONDENTS: 1 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, IS PRESS ROAD, COCHIN- 682 018 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AYAKAR BHAWAN, KAWADIAR, TRIVANDRUM- 695 003 3 INCOME TAX OFFICER, WARD-3, THIRUVALLA 689 101 4 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD KOCHI 682 018 5 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001 REPRESENTED BY ITS CHAIRMAN 6 THE KOTTAYAM DISTRICT CO-OEPRATIVE BANK LTD DISTRICT CO-OEPRATIVE BANK BUILDING, T.B ROAD CENTRAL JUNCTION, KOTTAYAM-686 001 REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 12 7 STATE OF KERALA REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVT., CO-OPERATION(C) DEPARTMENT, THIRUANANTHAPURAM 695 001 OTHER PRESENT: SRI. CHRISTOPHER ABRAHAM- SC, SMT. MM.JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 13 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.10479 OF 2019(H) PETITIONERS: 1 KANGAZHA SERVICE CO-OPERATIVE BANK LIMITED NO. 1145 REPRESENTED BY ITS SECRETARY KANGAZHA P.O., KOTTAYAM DISTRICT, KERALA, PIN- 695005. 2 NEENDOOR SERVICE CO-OPERATIVE BANK LIMITED, NO.2641, REPRESENTED BY ITS SECRETARY NEENDOOR P.O., KOTTAYAM DISTRICT, KERALA, PIN- 686601. 3 RANNI CO-OPERATIVE BANK LIMITED, NO.65, REPRESENTED BY ITS SECRETARY RANNI P.O., PATHANAMTHITTA DISTRICT, KERALA, PIN- 689672. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENTS: 1 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TRIVANDRUM- 695003. 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI- 682018. 3 THE TREASURY DIRECTOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM- 695003. 4 THE SUB-TREASURY OFFICER, SUB-TREASURY, KOTTAYAM, KOTTAYAM- 686601. 5 THE STATE OF KERALA, WP(C).No.7795 OF 2019 & CONNECTED CASES 14 REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTHAPURAM- 695001. 6 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD., REPRESENTED BY ITS GENERAL MANAGER, KOTTAYAM- 686601. 7 THE PATHANAMTHITTA DISTRICT CO-OPERATIVE BANK LTD., REPRESENTED BY ITS GENERAL MANAGER, PATHANAMTHITTA- 689645. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R6 BY SRI.ATHUL SHAJI, SC, KOTTAYAM DISTRICT CO.OPERATIVE BANK LTD. R7 BY ADV. SRI.T.P.PRADEEP OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 15 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.10782 OF 2019(W) PETITIONER/S: EZHUMATTOOR SERVICE CO-OPERATIVE BANK LIMITED NO. 1546, EZHUMATTOOR P.O. PATHANAMTHITTA-689586, REPRESENTED BY ITS SECRETARY, LALITHAMMA M.K, BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, I.S PRESS ROAD, KOCHI-682018. 3 THE INCOME TAX OFFICER, INCOME TAX OFFICER, WARD-4, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, THIRUVALLA RANGE, T.K. ROAD, THIRUVALLA, PATHANAMTHITTA- 689101. 4 THE PATHANAMTHITTA DISTRICT CO-OPERATIVE BANK HEAD OFFICE, PATHANAMTHITTA, PATHANAMTHITTA-689645, REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, WP(C).No.7795 OF 2019 & CONNECTED CASES 16 THYCAUD P.O, THIRUVANANTHAPURAM-695014. 6 THE STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. R1 AND R3 BY ADV. SRI.CHRISTOPHER ABRAHAM R4 BY ADV. SRI.T.P.PRADEEP OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 17 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.11301 OF 2019(K) PETITIONER/S: M/S. KARAKULAM SERVICE CO-OPERATIVE BANK LTD. KP-1/382, KARAKULAM.P.O., NEDUMANGAD, TRIVANDRUM- 695564-REPRESENTED BY ITS SECRETARY, SHRI.K.PADMAKUMAR BY ADVS. SRI.V.P.NARAYANAN SMT.DIVYA RAVINDRAN RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001- REPRESENTED BY ITS CHAIRMAN 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI-682018. 3 THE INCOME TAX OFFICER, WARD 2(3), THIRUVANANTHAPURAM-695003 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD., NEDUMANGAD MAIN BRANCH, THIRUVANANTHAPURAM. 5 THE TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUDU.P.O., THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY 9CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001 WP(C).No.7795 OF 2019 & CONNECTED CASES 18 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 19 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.11420 OF 2019(B) PETITIONER/S: 1 CHATHANNOOR SERVICE CO-OPERATIVE BANK LTD. NO.2544, CHATHANNOOR.P.O., KOLLAMDISTRICT-691572, REPRESENTED BY ITS SECRETARY IN CHARGE, RAJENDRAPRASAD. 2 CHATHANNOOR RURAL CO-OPERATIVE SOCIETY LTD. NO.1425, CHATHANNOOR.P.O., KOLLAM DISTRICT-691572, REPRESENTED BY ITS SECRETARY SUJADEVI.G BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.RESS ROAD, KOCHI-682018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD., HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM-691001, REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 20 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD.P.O., THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. R1 AND R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN, THE KOLLAM DISTRICT CO- OPERATIVE BANK LTD., OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, P.C SASIDHARAN (R4), GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 21 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.11438 OF 2019(D) PETITIONER/S: POLPULLY SERVICE CO-OPERATIVE BANK LIMITED NO.F 1198, REPRESENTED BY ITS SECRETARY POLPULLY P.O., PALAKKAD DISTRICT, KERALA, PIN - 678 552 BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENTS: 1 THE TREASURY DIRECTOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM - 695 003 2 THE SUB -TREASURY OFFICER SUB-TREASURY, PALAKKAD 3 THE ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, KOWDIAR, TRIVANDRUM - 695 003 4 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI - 682 018 5 THE STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTHAPURAM - 695 001 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 22 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.11507 OF 2019(K) PETITIONER: KOTTAYI SERVICE CO-OPERATIVE BANK LIMITED NO.F. 1223 REPRESENTED BY ITS SECRETARY KOTTAYI P.O, PALAKKAD DISTRICT, KERALA, PIN-678 572 BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 THE TREASURY DIRECTOR OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM-695 003 2 THE SUB TREASURY OFFICER, SUB-TREASURY, KOZHALMANNAM, PALAKKAD. 3 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TRIVANDRUM-695 003 4 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG, IS PRESS , ROAD, KOCHI-682 018 5 THE STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTHAPURAM-695 001 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 23 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.11895 OF 2019(J) PETITIONER/S: KUMARANALLOOR SERVICE CO-OPERATIVE BANK LIMITED NO.3898, REPRESENTED BY ITS SECRETARY, PERUMBAIKKDU.P.O., KOTTAYAM DISTRICT, KERALA, PIN- 686016. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 THE TREASURY DIRECTOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM-695003. 2 THE DISTRICT TREASURY OFFICER, DISTRICT TREASURY, KOTTAYAM. 3 THE SUB-TREASURY OFFICER, SUB-TREASURY, GANDHINAGAR. 4 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TTRIVANDRUM-695003. 5 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINITSRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG., I.S.PRESS ROAD, KOCHI-682018. 6 THE STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTHPURAM-695001. R4 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT WP(C).No.7795 OF 2019 & CONNECTED CASES 24 OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 25 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12270 OF 2019(G) PETITIONER/S: 1 KANMANAM SERVICE CO-OPERATIVE BANK LIMITED, NO.10585, KANMANAM P.O., MALAPPURAM (DT), PIN- 676 551, REPRESENTED BY ITS SECRETARY MOHAMED BASHEER. 2 VENGARA SERVICE CO-OPERATIVE BANK LIMITED, NO.1186, VENGARA P.O., MALAPPURAM (DT), PIN - 676 304, REPRESENTED BY ITS SECRETRY, HAMEED M. 3 CHERIYAMUNDAM SERVICE CO-OPERATIVE BANK LIMITED, NO.D 1974, THALKKADATHOOR P.O., MALAPPURAM (DT), PIN - 676 103, REPRESENTED BY ITS SECRETARY IN- CHARGE, K.O.NIHMATHULLA. 4 TANALUR SERVICE CO-OPERATIVE BANK LIMITED, NO.M.2, K.PURAM P.O., MALAPPURAM (DT), PIN- 676 307, REPRESENTED BY ITS SECRETARY IN-CHARGE, SAJEEV P.K. 5 THALAKKAD SERVICE CO-OPERATIVE BANK LIMITED, NO.4391, VENGALUR P.O., MALAPPURAM (DT), PIN - 676 102, REPRESENTED BY ITS SECRETARY, JAYADEVAN P.T. 6 EDARIKODE SERVICE CO-OPERATIVE BANK LIMITED, NO.10739, EDARIKODE P.O., MALAPPURAM (DT), PIN- 676 501, REPRESENTED BY ITS SECRETARY, ABDUL JALEEL. 7 ANANTHAVOOR SERVICE CO-OPERATIVE BANK LIMITED, NO.F. 1545, ANANTHAVOOR P.O., MALAPPURAM (DT), PIN- 676 301, REPRESENTED BY ITS SECRETARY, ALAVI K. 8 ATHAVANAD SERVICE CO-OPERATIVE BANK LIMITED, NO.D 1933, KARIPPOL P.O., MALAPPURAM (DT), PIN - 676 552, REPRESENTED BY ITS SECRETARY, MOHAMMED HARIS K.K. 9 KURUMBATHUR SERVICE CO-OPERATIVE BANK LIMITED, PUNNATHALA P.O., MALAPPURAM (DT), PIN- 676 551, WP(C).No.7795 OF 2019 & CONNECTED CASES 26 REPRESENTED BY ITS SECRETARY, MOHAMMED SALEEM P. 10 PONMUNDAM SERVICE CO-OPERATIVE BANK LIMITED, PONMUNDAM P.O., MALAPPURAM (DT), PIN - 676 108, REPRESENTED BY ITS SECRETARY, BAHAVUDHEEN. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTHAPURAM - 695 001. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TRIVANDRUM - 695 003. 3 THE COMMISSIONER OF INCOME TAX (TDS), KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI - 682 018. 4 THE TREASURY DIRECTOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM - 695 003. 5 THE DISTRICT TREASURY OFFICER, DISTRICT TREASURY, MALAPPURAM - 676 101. 6 THE SUB TREASURY OFFICER, SUB TREASURY, TIRUR - 676 101. 7 THE SUB TREASURY OFFICER, SUB-TREASURY, VALANCHERY P.O., PIN- 676 552. 8 THE SUB TREASURY OFFICER, SUN-TREASURY, KOTTACKAL P.O., PIN - 676 503. 9 THE SUB TREASURY OFFICER, SUB-TREASURY, VENGARA P.O., PIN- 676 304. 10 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., MANJERI ROAD, MALAPPURAM, PIN- 676 505. 11 URBAN CO-OPERTIVE BANK PERINTHALMANNA, PERINTHALMANNA P.O., MALAPPURAM (DT), PIN- 676 101. WP(C).No.7795 OF 2019 & CONNECTED CASES 27 12 MANJERY COOPERATIVE URBAN BANK, MANJERI P.O., PIN- 676 121. 13 KOTTACKAL CO-OPERATIVE URBAN BANK, KOTTACKAL P.O., PIN - 676 503. 14 PONNANI URBAN CO-OPERTIVE BANK, PONNANI P.O., PIN- 679 577. 15 KERALA STATE CO-OPERATIVE BANK, MALAPPURAM BRANCH, PIN-676 505. R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R15 BY ADV. SRI.GILBERT GEORGE CORREYA R10 BY ADV. I.V PRAMOD; SC FOR MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 28 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12271 OF 2019(H) PETITIONER/S: 1 KUTTIPPURAM SERVICE CO-OPERATIVE BANK LIMITED NO.M 729, KUTTIPPURAM P.O., MALAPPURAM (DT), PIN- 679 571 REPRESENTED BY ITS SECRETARY, ABDUL RSHEED. 2 MANGALAM SERVICE CO-OPERATIVE BANK LIMITED NO.9701, MANGALAM P.O., MALAPPURAM (DT), PIN-676 561 REPRESENTED BY ITS SECRETARY, ABDUL MAJEED. 3 TRIPRANGODE SERVICE CO-OPERATIVE BANK LIMITED NO.D1910, TRIPRANGODE P.O., MALAPPURAM (DT), PIN- 676 108 REPRESENTED BY ITS SECRETARY, SAJEEV P.V. 4 THIRUNAVAYA SERVICE CO-OPERATIVE BANK LIMITED NO.D 1910, THIRUNAVAYA P.O., PIN-676 301 REPRESENTED BY ITS SECRETARY, SURESH K.M., AGED 49 YEARS, S/O. PARANGODAN NAIR. 5 VALAVANNUR SERVICE CO-OPERATIVE BANK LIMITED NO.D 1959, VALAVANNUR P.O., MALAPPURAM (DT), PIN- 676 551 REPRESENTED BY ITS SECRETARY IN-CHARGE YOOSAF KALLERI. 6 VETTOM SERVICE CO-OPERATIVE BANK LIMITED NO.1823, VETTOM P.O., MALAPPURAM (DT), PIN-676 102 REPRESENTED BY ITS SECRETARY, DAMKUMAR P.R. 7 THE OZHUR SERVICE CO-OPERATIVE BANK LIMITED NO.F 1586, OZHUR P.O., MALAPPURAM (DT), PIN-676 307 REPRESENTED BY ITS SECRETARY IN-CHARGE E PADMAJA. 8 TIRUR SERVICE CO-OPERATIVE BANK LIMITED NO.10094, TIRUR P.O., MALAPPURAM (DT), PIN-676 101 REPRESENTED BY ITS SECRETARY, UMMER K. 9 VALANCHERY SERVICE CO-OPERATIVE BANK LIMITED NO.M 728, VALANCHERY P.O., MALAPPURAM (DT), PIN-676 552 REPRESENTED BY ITS SECRETARY, P.SASIKUMAR. WP(C).No.7795 OF 2019 & CONNECTED CASES 29 10 THE KALPAKANCHERY SERVICE CO-OPERATIVE BAJK LIMITED NO.1808, KALPAKANCHERY P.O., MALAPPURAM (DT), PIN- 676 551 REPRESENTED BY ITS SECRETARY, MRS. KADIYAMMAKUTTY KALLATTIL. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTAHPURAM-695 001. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, KOWDIAR, TRIVANDRUM-695 003. 3 THE COMMISSIONER OF INCOME TAX (TDS) KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682018. 4 THE TREASURY DIRECTOR OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM-695 003. 5 THE DISTRICT TREASURY OFFICER DISTRICT TREASURY, MALAPPURAM, 676 101. 6 THE SUB TRERASURY OFFICER SUB TREASURY, TIRUR-676 101. 7 THE SUB TREASURY OFFICER SUB-TREASURY, VALANCHERY P.O., PIN-676 552. 8 THE SUB TREASURY OFFICER SUB TREASURY, KOTTACKAL P.O., PIN-676 503. 9 THE SUB TREASURY OFFICER SUB-TREASURY, VENGARA P.O, PIN-676 304. 10 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD. MANJERI ROAD, MALAPPURAM, PIN-676 505. 11 URBAN CO-OPERATIVE BANK PERINTHALMANNA PERINTHALMANNA P.O., MALAPPURAM (DT), PIN-676 505. WP(C).No.7795 OF 2019 & CONNECTED CASES 30 12 MANJERY CO-OPERATIVE URBAN BANK MANJERI P.O., PIN-676121. 13 KOTTACKAL CO-OPERTIVE URBAN BANK KOTTACKAL P.O., PIN-676 503. 14 PONNANI URBAN CO-OPERATIVE BANK PONNANI P.O., PIN-679 577. 15 KERALA STATE CO-OPERATIVE BANK MALAPPURAM BRANCH, PIN-676 505. R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R15 BY ADV. SRI.GILBERT GEORGE CORREYA R10 BY ADV. I.V PRAMOD; SC FOR MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 31 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12352 OF 2019(T) PETITIONER: THE PULLUMPARA SERVICE CO-OPERATIVE BANK LTD.NO.2429 REPRESENTED BY ITS SECRETARY, MUKKUDIL P.O., VENJARAMOODU, THIRUVANANTHAPURAM DISTRICT-695 607. BY ADVS. SRI.T.R.HARIKUMAR SRI.JAIBY PAUL SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, IIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O., THIRUVANANTHAPURAM DISTRICT-695 003. 2 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110 001. 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI-110 001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES THIRUVANANTHAPURAM-695 001. 5 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD. REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM-695 023. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT WP(C).No.7795 OF 2019 & CONNECTED CASES 32 R5 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 33 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12403 OF 2019(A) PETITIONER/S: THE MANICKAL SERVICE CO-OPERATIVE BANK LTD NO.1910, REPRESENTED BY ITS SECRETARY, PIRAPPANCODE P.O.THIRUVANANTHAPURAM DISTRICT 695 607 BY ADVS. SRI.T.R.HARIKUMAR SRI.JAIBY PAUL SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF THE ASSISTANT COMMISSIONER OF INCOMENT TAX, TDS RANGE, IIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.THIRUVANANTHAPURAM DISTRICT 695 003. 2 THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT) MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI 110001. 3 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI 110001. 4 THE REGISTRAR OF CO-OPERATIVES SOCIETIES, THIRUVANANTHAPURAM-695 001. 5 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD, REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM- 695 023. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R5 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM WP(C).No.7795 OF 2019 & CONNECTED CASES 34 DIST. CO.OP BANK OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 35 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12407 OF 2019(A) PETITIONER/S: 1 KOLKALAM SERVICE CO-OPERATIVE BANK LIMITED NO F 1073, CHENGOTTUR P.O, MALAPPURAM (DT) PIN 676 503, REPRESENTED BY ITS SECRETARY, AYISHAKUTTY O. 2 THE MARAKKARA SERVICE CO-OPERATIVE BANK LIMITED NO F90738, RANDATHANI P.O MALAPPURAM (DT) PIN 676 510, REPRESENTED BY ITS SECRETARY, INDU T, 3 PURATHUR SERVICE CO-OPERATIVE BANK LIMITED, NO D1902, PURATHUR P.O.MALAPPURAM (DT) PIN 676 102, REPRESENTED BY ITS SECRETARY IN CHARGE ASHRAF N. 4 VADAKKUMPURAM SERVICE CO-OPERATIVE BANK LIMITED, NO 1505, EDAYUR NORTH PO PIN 676 52, REPRESENTED BY ITS SECRETARY, VINOD V. 5 IRINBILIYAM SERVICE CO-OPERATIVE BNAK LIMITED NO 10445, IRIMBILIYAM P.O.MALAPPURAM (DT) PIN 679 572, REPRESENTED BYITS SECRETARY P.M. BALACHANDRAN. 6 ARIYALLUR SERVICE CO-OPERATIVE BANK LIMITED NO F 7730, ARIYALLUR P.O.MALAPPURAM (DT) PIN 676 312,REPRESENTED BY ITS SECRETARY, SMITHA K. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 STATE OF KERALA WP(C).No.7795 OF 2019 & CONNECTED CASES 36 REPRESENTED BY ITS SECRETARY (CO-OPERATION) SECRETARIAT, THIRUVANANTHAPURAM 695 001. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TRIVANDRUM-695 003. 3 THE COMMISSIONER OF INCOME TAX (TDS), KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG, IS PRESS , ROAD KOCHI 682 018. 4 THE TREASURY DIRECTOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM 695 003. 5 THE DISTRICT TREASURY OFFICER, DISTRICT TREASURY, MALAPPURAM 676 101, 6 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, MANJERI ROAD, MALAPPURAM, PIN 676 505 R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R6 BY ADV. SRI.I.V.PRAMOD OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 37 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12453 OF 2019(F) PETITIONER/S: PONNANI SERVICE CO-OPERATIVE BANK LIMITED NO.4841, PONNANI, MALAPPURAM DISTRICT. REPRESENTED BY SECRETARY BY ADV. SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), KOZHIKODE, PIN-673001. 3 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, PIN-676504, REPRESENTED BY GENERAL MANAGER. 4 THE BRANCH MANAGER, MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., EVENING BRANCH, PONNAI, MALAPPURAM, PIN-679577. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, DEPARTMENT OF CO-OPERATION, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O., THIRUVANANTHAPURAM, PIN-695014. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R3-4 BY ADV. SRI.I.V.PRAMOD OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 38 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12498 OF 2019(J) PETITIONER/S: THE NELLIMOODU SERVICE CO-OPERATIVE BANK LTD.NO.2639 REPRESENTED BY ITS SECRETARY, NELLIMOODU P.O, THIRUVANANTHAPURAM DISTRICT-695 524 BY ADVS. SRI.T.R.HARIKUMAR SRI.JAIBY PAUL SRI.ARJUN RAGHAVAN RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O, THIRUVANANTHAPURAM DISTRICT-695 003 2 THE CENTRAL BOARD OF DIRECT TAXES., REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110 001 3 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI-110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM-695 001. 5 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD, REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM-695 023 R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX WP(C).No.7795 OF 2019 & CONNECTED CASES 39 DEPARTMENT R5 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 40 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12547 OF 2019(P) PETITIONER/S: 1 BALARAMAPURAM SERVICE CO-OPERATIVE BANK LTD., T/14, BALARAMAPURAM, THIRUVANANTHAPURAM, PIN - 695 501, REPRESENTED BY ITS SECRETARY A.JAFEERKHAN. 2 VENPAKAL SERVICE CO-OPERATIVE BANK LTD.NO.T 155, VENPAKAL P.O., VIA, ARALUMMOODU, NEYYATTINKARA, THIRUVANANTHAPURAM - 695 123, REPRESENTED BY ITS SECRETARY, SINI V.G. 3 KALLIYOOR SERVICE CO-OPERATIVE BANK LTD.NO.1243, KALLIYOOR P.O., THIRUVANANTHAPURAM - 695 042, REPRESENTED BY ITS SECRETARY, MURALEEDHARAN P. 4 ANTHIYOOR SERVICE CO-OPERATIVE BANK LTD.NO.1166, ANTHIYOOR, BALARAMAPURAM P.O., THIRUVANANTHAPURAM - 695 501, REPRESENTED BY ITS SECRETARY C.PREMAKUMAR. 5 AVANAKUZHI SERVICE CO-OPERATIVE BANK LTD.NO.2387, THANNIMOODU P.O., THIRUVANANTHAPURAM - 695 123, REPRESENTED BY ITS SECRETARY P.S.JAYASREE. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN. WP(C).No.7795 OF 2019 & CONNECTED CASES 41 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003. 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK HEAD OFFICE, THIRUVANANTHAPURAM EAST FORT P.O., THIRUVANANTHAPURAM - 695 023, REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM - 695 014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 42 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12582 OF 2019(W) PETITIONER/S: THE ARUVIKKARA FARMERS SERVICE CO-OPERATIVE BANK LTD NO.603, REPRESENTED BY ITS MANAGING DIRECTOR, ARUVIKKARA.P.O, THIRUVANANTHAPURAM DISTRICT-695564. BY ADVS. SRI.T.R.HARIKUMAR SRI.JAIBY PAUL SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR.P.O, THIRUVANANTHAPURAM DISTRICT-695003. 2 THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH BLOCK DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NOW DELHI-110001. 3 UNION OF INIDA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI-110001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM-695001 5 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD, REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM-695023. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R5 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM WP(C).No.7795 OF 2019 & CONNECTED CASES 43 DIST. CO.OP BANK OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 44 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12696 OF 2019(J) PETITIONER/S: PEROORKADA SERVICE CO-OPERATIVE BANK LIMITED NO. T 1412, REPRESENTED BY ITS SECRETARY PEROORKADA P.O, THIRUVANANTHAPURAM DISTRICT, KERALA, PIN 695 005 BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 KERALA STATE CO-OPERATIVE BANK LTD REPRESENTED BY ITS MANAGING DIRECTOR, CO-OP BANK TOWER, TRIVANDRUM 695 003 2 KERALA STATE CO-OPERATIVE BANK LTD, REPRESENTED BY ITS DEPUTY GENERAL MANAGER, CO-OP BANK TOWER, TRIVANDRUM 695 003 3 KERALA STATE CO-OPERATIVE BANK LTD, REPRESENTED BY ITS BRANCH MANAGER, PEROORKADA BRANCH, TRIVANDRUM 695 003 4 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TRIVANDRUM 695 003 R1 BY ADV. SRI.GILBERT GEORGE CORREYA R4 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 45 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12709 OF 2019(K) PETITIONER/S: THE NATTAKOM CO-OPERATIVE BANK NO.86, H.P.PAKKIL.P.O., KOTTAYAM-686012. REPRESENTED BY ITS SECRETARY G.K.GEETHAKUMARI BY ADVS. SRI.T.A.SHAJI (SR.) SHRI.NIKHIL SUNNY MOOKEN SRI.S.ABHILASH VISHNU RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX(TDS) CENTRAL REVENUE BUILDING, IS PRESS ROAD, COCHIN- 682018. 2 THE ADDL.COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AYAKAR BHAWAN, KAWADIAR, TRIVANDRUM-695003. 3 INCOME TAX OFFICER, WARD-3, KOTTAYAM-686001. 4 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 5 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 6 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD., DISTRICT CO-OPERATIVE BANK BUILDING, T.B.ROAD, CENTRAL JUNCTION, KOTTAYAM-6860001, REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 46 7 STATE OF KERALA REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVT., CO-OPERATION (C) DEPARTMENT, THIRUVANNATHAPURAM- PIN-695001. R1 TO R5 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R6 BY SRI.ATHUL SHAJI, SC, KOTTAYAM DISTRICT CO.OPERATIVE BANK LTD. OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 47 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12758 OF 2019(T) PETITIONER/S: THE VAMANAPURAM SERVICE CO-OPERATIVE BANK LTD NO.927 REPRESENTED BY ITS SECRETARY, VAMANAPURAM P.O, THIRUVANANTHAPURAM DISTRICT 695 606 BY ADVS. SRI.M.SASINDRAN SRI.V.VENUGOPAL RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110 001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI 682 018. 3 INCOME TAX OFFICER, WARD (25)-RANGE 2 AYAKAR BHAVAN, INCOME TAX, KOWADIAR, THIRUVANANTHAPURAM 695 003 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK HEAD OFFICE, THIRUVANANTHAPURAM, EAST FORT P.O, THIRUVANANTHAPURAM 695 023 REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM 695 014 6 STATE OF KERALA, WP(C).No.7795 OF 2019 & CONNECTED CASES 48 REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001 R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 49 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12828 OF 2019(C) PETITIONER/S: AREACODE SERVICE CO-OPERATIVE BANK LTD. NO. F.1571, AREACODE, P.O AREACODE 673 639 MALAPPURAM DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV. SRI.P.C.SASIDHARAN RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES,DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK,NEW DELHI 110 001, REPRESENTED BY ITS CHAIRMAN 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI 682 018 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, INCOME TAX OFFICE, ERNAKULAM, CENTRAL REVENUE BUILDING, IFS ROAD, KOCHI 682018 4 ADDITIONAL COMMISSIONER OF INCOME TAX, INCOME TAX, THIRUR, MALAPPURAM DISTRICT 676 101 5 MALAPPURAM DISTRICT CO-OPERATIVE BANK, REPRESENTED BY ITS GENERAL MANAGER, MALAPPURAM 676 505 6 DIRECTOR OF TREASURIES, OFFICE OF THE DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM 695 014 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001 WP(C).No.7795 OF 2019 & CONNECTED CASES 50 8 KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS MANAGING DIRECTOR, CO-TOWERS, THIRUVANANTHAPURAM 695 001 9 BRANCH MANAGER, KERALA STATE CO-OPERATIVE BANK, MALAPPURAM 676 121 10 MANJERI CO-OPERATIVE URBAN BANK, MANJERI , REPRESENTED BY ITS GENEREAL MANAGER, MALAPPURAM DISTRICT 676 121 11 PERINTHALMANNA CO-OPERATIVE URBAN BANK, REPRESENTED BY ITS GENERAL MANAGER, PEREINTHALMANNA 679 322 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R7 BY GOVERNMENT PLEADER R8 AND R9 BY ADV. SRI.GILBERT GEORGE CORREYA R5 BY ADV. I.V PRAMOD; MALAPPURAM DISTRICT CO- OPERATIVE BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 51 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.12900 OF 2019(J) PETITIONER/S: VATTIYOORKAVU SERVICE CO-OPERATIVE BANK LIMITED NO.1652 REPRESENTED BY ITS SECRETARY, VATTIYOORKAVU.P.O, THIRUVANANTHAPURAM DISTRICT, KERALA, PIN-695013 BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 KERALA STATE CO-OPERATIVE BANK LTD REPRESENTED BY ITS MANAGING DIRECTOR, CO-OP BANK TOWER, TRIVANDRUM-695003 2 THE BRANCHJ MANAGER, KERALA STATE CO-OPERATIVE BANK LTD PEROORKADA BRANCH, TRIVADNRUM-695005. 3 THE MANAGING DIRECTOR, TRIVANDRUM DISTRICT CO-OPERATIVE BANK LTD, TRIVANDRUM-695003 4 THE BRANCH MANAGER, TRIVANDRUM CO-OPERATIVE URBANBANK LTD P.B.NO.115, M.G.ROAD, TRIVANDRUM-695001 5 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TRIVANDRUM-695003. R1 BY ADV. SRI.GILBERT GEORGE CORREYA R3 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK R5 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 52 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13062 OF 2019(G) PETITIONER/S: 1 AYIROOR VILLAGE SERVICE CO-OPERATIVE BANK LIMITED ELAKAMON P.O, AYIROOR, VARKALA, THIRUVANANTHAPURAM 695 310, REPRESENTED BY ITS SECRETARY PRASANNAKUMARI P.O. 2 EDAVA SERVICE CO-OPEARATIVE BANK LTD NO. 3782, EDAVA P.O, THIRUVANANTHAPURAM 695 311 REPRESENTED BY ITS SECRETARY R. PUSHPALETHA. 3 MUTTATHARA SERVICE CO-OPERATIVE BANK LTD, NO. 413, MUTTATHARA, VALLAKKADAVU P.O, THIRUVANANTHAPURAM 695 008 REPRESENTED BY ITS SECRETARY BEENA S. 4 CHEMMARUTY SERVICE CO-OPERATIVE BANK LTD T NO 328, PANAYARA P.O, VARKALA, THIRUVANANTHAPURAM 695 146 REPRESENTED BY ITS SECRETARY SAHAJA S. 5 VETTOOR SEREVICE CO-OPERATIVE BANK LTD T 728 MELEVETTOOR P.O, VARKALA, THIRUVANANTHAPURAM 695 312 REPRESENTED BY ITS SECRETARY GIRIJA D. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001, REPRESENTED BY ITS CHAIRMAN. WP(C).No.7795 OF 2019 & CONNECTED CASES 53 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRASL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018 3 ADDITIONAL COMMISSIONEER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM 695 003 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK, HEAD OFFICE, THIRUVANANTHAPURAM, EAST FORT P.O, THIRUVANANTHAPURAM 695 023 REPRESENTED BY ITS GENERAL MANAGER. 5 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, DITRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM 691 001 REPRESENTED BY ITS GENERAL MANAGER. 6 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM 695 014 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK R5 BY SRI. P.C SASIDHARAN FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 54 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13412 OF 2019(B) PETITIONER/S: 1 THE KEEZHOOR SERVICE CO-OPERATIVE BANK LTD., NO.K.323,KEEZHOOR.P.O,KOTTAYAM DIST.-686605,REP.BY ITS SECRETARY MS.SHOBHANA.M.M. 2 THE KAPPUMTHALA SERVICE CO-OPERATIVE BANK LTD.NO.K.142, KAPPUMTHALA.P.O,MUTTUCHIRA-686612, REP.BY ITS SECRETARY MS.LISSYMOL GEORGE. BY ADVS. SRI.A.KUMAR SRI.P.J.ANILKUMAR SMTG.MINI(1748) SRI.P.S.SREE PRASAD SHRI.ABRAHAM JOB SRI.AJAY V.ANAND RESPONDENT/S: 1 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) 3RD FLOOR,39 AAYAKARBHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 2 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD. DISTRICT CO-OPERATIVE BANK BUILDING, POST BOX NO.140,KOTTAYAM-686001. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R2 BY ADV. SRI.ATHUL SHAJI THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 55 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13546 OF 2019(P) PETITIONER/S: MITHIRMALA SERVICE CO-OPERATIVE BANK LTD NO.2452 KALLARA PANCHAYAT NEDUMANGAD TALUK, MITHIRAMALA.P.O., THIRUVANANTHAPURAM-695610 REPRESENTED BY ITS SECRETARY SHYLA BY ADV. SRI.C.S.SUMESH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIAPL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA CENTRAL REVENUE BUILDING,S IS PRESS ROAD, KOCHI-682018 3 INCOME TAX OFFICER, WARD 2(5)-RANGE 2 AYAKAR BHAVAN, INCOME TAX, KOWDIAR THIRUVANANTHAPURAM-695003 4 THE THIRUVANANTHPAURAM DISTRICT CO-OPERATIVE BANK HEAD OFFICE, THIRUVANANTHAPURAM EAST FORT .P.O, THIRUVANANTHAPURAM-695023 REPRESENTED BY IT'S GENERAL MANAGER. 5 TREASURY DIRECTOR DIRECTORATE OF TREASURIES, KRISHNA BUILDING,S THYCAUD.P.O., THIRUVANANTHAPURAM-695014 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY9CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA THIRUVANANTHAPURAM-695001 WP(C).No.7795 OF 2019 & CONNECTED CASES 56 R1 BY ADV. SHRI.P.VIJAYAKUMAR, ASG OF INDIA R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 57 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13695 OF 2019(J) PETITIONER: AMBALATHUMBHAGOM SERVICE CO-OPERATIVE BANK LTD NO. 2836 AMBALATHUMBHAGAM, PORUVAZHY, KOLLAM DISTRICT 690 520, REPRESENTED BY ITS SECRETARY, K VISWANATHAN THAMPI. BY ADV. DR.K.P.PRADEEP RESPONDENTS: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS I S PRESS ROAD, KOCHI 682 018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR THIRUVANANTHAPURAM 695 003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LIMITED, HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDINGS, CHINNAKADA, KOLLAM 691 001. REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM 695 014. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY CO- OPERATION, WP(C).No.7795 OF 2019 & CONNECTED CASES 58 GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI. P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LIMITED OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 59 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13726 OF 2019(M) PETITIONER: VARKALA SERVICE CO-OPERATIVE BANK LTD PUNNAMOODU,VARKALA,THIRUVANANTHAPURAM DISTRICT- 695141,REPRESENTED BY ITS SECRETARY, GOPALA KURUP.S. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENTS: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI-682 018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE,3RD FLOOR,AATAKAR BHAVAN, KAWADIAR,THIRUVANANTHAPURAM-695003. 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK, HEAD OFFICE,THIRUVANANTHAPURAM, EAST FORT.P.O,THIRUVANANTHAPURAM-695023,REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 60 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES,KRISHNA BUILDINGS,THYCAUD.P.O,THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO- OPERATION),GOVERNMENT SECRETARIATE,GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 61 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13826 OF 2019(C) PETITIONER: URANGATTIRI SERVICE CO-OPERATIVE BANK LIMITED NO.8895,URANGATTIRI.P.O., MALAPPURAM (DT),PIN-673 639 REPRESENTED BY ITS SECRETARY BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENTS: 1 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO- OPERATION),SECRETARIAT, THIRUVANANTHAPURAM-695 001 2 THE COMMISSIONER OF INCOME TAX (TDS), KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI- 682 018 3 THE GENERAL MANAGER, MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, MANJERI ROAD, MALAPPURAM,PIN-676 505 4 THE TREASURY DIRECTOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM-695 003 5 THE DISTRICT TREASURY OFFICER, DISTRICT TREASURY, MALAPPURAM-676 101 6 THE BRANCH MANAGR, MANJERI URBAN CO-OPERATIVE BANK LTD, AREEKODE BRANCH, AREEKODE P.O., MALAPPURAM (DT),PIN-673 639 WP(C).No.7795 OF 2019 & CONNECTED CASES 62 R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R3 BY SRI.I.V PRAMOD; SC FOR MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, I.V PRAMOD, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 63 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13945 OF 2019(P) PETITIONER: PULAMANTHOLE SERVICE CO-OPERATIVE BANK LIMITED NO.F 1565, PULAMANTHOLE.P.O., MALAPPURAM DISTRICT-679323 REPRESENTED BY ITS SECRETARY BY ADV. SRI.O.D.SIVADAS RESPONDENTS: 1 THE COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM PIN-682018 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), KOZHIKODE, PIN-673001 3 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN-676505 4 THE BRANCH MANAGER MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, KUTTUPARA BRANCH, KUTTUPPARA, MALAPPURAM, PIN- 679323. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, DEPARTMENT OF CO-OPERATION, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD.P.O., THIRUVANANTHAPURAM, PIN-695014. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SMT. M.M JASMINE- G.P WP(C).No.7795 OF 2019 & CONNECTED CASES 64 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 65 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.13946 OF 2019(P) PETITIONER/S: THE KURUVAMBALAM SERVICE CO-OPERATIVE BANK LTD, FO 1638 CHEMMALASSERY P.O, MALAPPURAM , REPRESENTED BY ITS SECRETARY. BY ADV. SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) KOZHIKODE, PIN - 673 001. 3 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN - 676 505. 4 THE BRANCH MANAGER MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, PERUNTHALMANNA BRANCH, PERUNTHALMANNA, MALAPPURAM, PIN - 679 321. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES DEPARTMENT OF CO-OPERATION, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD. P.O, THIRUVANANTHAPURAM, PIN - 695 014. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 66 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.14895 OF 2019(J) PETITIONER/S: THE THALAPALAM SERVICE CO-OPERATIVE BANK LTD. PLASSANAL, KOTTAYAM DISTRICT, KOTTAYAM , REPRESENTED BY ITS SECRETARY, SMT. JESSY THOMAS. BY ADVS. SRI.A.KUMAR SRI.P.J.ANILKUMAR SMTG.MINI(1748) SRI.P.S.SREE PRASAD SHRI.ABRAHAM JOB SRI.AJAY V.ANAND RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI-682 018 3 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS). 3RD FLOOR, AAYAKARBHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003 4 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM-695 014 5 THE DISTRICT TREASURY, MEENACHIL P.O, PALA, KOTTAYAM-686 577, REPRESENTED BY DISTRICT TREASURY OFFICER. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 67 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.15165 OF 2019(U) PETITIONER/S: ELAMKULAM SERVICE CO-OPERATIVE BANK LIMITED NO.F 1536, KUNNAKKAVU P.O.,MALAPPURAM DISTRICT-679340, REPRESENTED BY ITS SECRETARY. BY ADV. SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), KOZHIKODE, PIN-673001. 3 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN-676505. 4 THE BRANCH MANAGER, MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., PERUNTHALMANNA BRANCH, PERUNTHALMANNA, MALAPPURAM, PIN-679321. 5 THE REGISTAR OF CO-OPERATIVE SOCIETIES, DEPARTMENT OF CO-OPERATION, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O., THIRUVANANTHAPURAM, PIN-695014. R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 68 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.15691 OF 2019(J) PETITIONER/S: THE PEROOR SERVICE CO-OPERATIVE BANK LTD NO. 76 PEROOR P.O., KOTTYAM DISTRICT 686 537, REPRESENTED BY ITS SECRETARY ANNAMMA M.I., BY ADVS. SRI.T.A.SHAJI (SR.) SHRI.NIKHIL SUNNY MOOKEN SRI.S.ABHILASH VISHNU RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS) TDS, CENTRAL REVENUE BUILDING, IS PRESS ROAD, COCHIN 682 018. 2 THE ADDL. COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AYAKAR BHAWAN, KAWADIAR, TRIVANDRUM 695 003. 3 INCOME TAX OFFICER, WARD-3, KOTTAYAM 686001. 4 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGIONAL, MINISTRY OF FINANCE,GOVERNMENT OF INDIA CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI 682 018 5 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001, REPRESENTED BY ITS CHAIRMAN. 6 THE KOTTAYAM DISTRICT WP(C).No.7795 OF 2019 & CONNECTED CASES 69 CO-OPERATIVE BANK LTD., DISTRICT CO-OPERATIVE BANK BUILDING, T.B. ROAD, CENTRAL JUNCTION, KOTTAYAM 686001, REPRESENTED BY ITS GENERAL MANAGER. 7 STATE OF KERALA REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVERNMENT, CO-OPERATION C DEPARTMENT, THIRUVANANTHAPURAM 695 001. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R6 BY ADV. SRI.ATHUL SHAJI OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 70 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.15693 OF 2019(J) PETITIONER/S: THE AYIROOPPARA FARMERS SERVICE CO-OPERATIVE BANK LTD.NO.2154 REPRESENTED BY ITS MANAGING DIRECTOR, POTHENCODE(P.O), THIRUVANANTHAPURAM-695584. BY ADVS. SRI.G.BIJU SRI.V.A.VINOD RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRMAN, DEPARTMENT OF REVENUE/MINISTRY OF FINANCE, ROOM NO.143E, NORTH BLOCK, GOVERNMENT OF INDIA, NEW DELHI-110001. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR(P.O), THIRUVANANTHAPURAM-695003. 3 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD, REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, EAST FORT, FORT (P.O), THIRUVANANTHAPURAM-695023. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM-695001. 5 THE TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANNATHAPURAM-695014. WP(C).No.7795 OF 2019 & CONNECTED CASES 71 R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R3 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 72 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.16128 OF 2019(M) PETITIONER/S: THE THONNAKKAL SERVICE CO-OPERATIVE BANK LTD NO.1754, 16TH MILE STONE TO VENGODE ROAD, KEEZHTHONNAKKAL, KERALA-695589, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.G.RAJEEV SMT.LEKSHMI RAMAKRISHNAN SHRI.MUHAMMAD JASHEEN J. SHRI.REJITH RAJENDRAN RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVT. OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI-682018. 3 INCOME TAX OFFICER, WARD 2 (5) - RANGE 2, AYAKAR BHAVAN, INCOME TAX, KOWDIAR, THIRUVANANTHAPURAM-695003. 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK, HEAD OFFICE, EAST FORT P.O., THIRUVANANTHAPURAM- 695023. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM-695014. WP(C).No.7795 OF 2019 & CONNECTED CASES 73 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CORPORATION), GOVT. SECRETARIAT, GOVT. OF KERALA, THIRUVANANTHAPURAM. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 74 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.17027 OF 2019(C) PETITIONER/S: PARAVUR SERVICE CO-OPERATIVE BANK LTD.NO.1801. REPRESENTED BY ITS SECRETARY, PARAVUR P. O., KOLLAM DISTRICT - 691301 BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P. O., THIRUVANANTHAPURAM - 695 003 2 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI - 110 001 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - 110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES THIRUVANANTHAPURAM - 695 001 5 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD., REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, CHINNAKADA, KOLLAM, PIN - 691 001 R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT WP(C).No.7795 OF 2019 & CONNECTED CASES 75 R5 BY SRI. P. C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD. OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 76 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.17706 OF 2019(K) PETITIONER/S: THE PATTIKKAD SERVICE CO-OPERATIVE BANK LIMITED NO. P 455 PATTIKKAD.P.O,MALAPPURAM DISTRICT-679325, REPRESENTED BY ITS SECRETARY. BY ADV. SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDINGS,I.S.PRESS ROAD,ERNAKULAM,PIN-682018. 2 THE ADDITIONAL COMMISSOINER OF INCOME TAX(TDS), KOZHIKODE,PIN-673001. 3 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, DISTRICT CO-OPERATIVE BANK BUILDING,MALAPPURAM,REPRESENTED BY ITS GENERAL MANAGER,PIN-676505. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, HEAD OFFICE,PALAYAM,THIRUVANANTHAPURAM, REPRESENTED BY GENERAL MANAGER,PIN-695033. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, DEPARTMENT OF CO-OPERATION,JAWAHAR SAHAKARANA BHAVAN,DPI JUNCTION,THYCAUD.P.O, THIRUVANANTHAPURAM,PIN-695014. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI. GILBERT GEORGE CORREYA; SC FOR THE KERALA STATE CO-OPERATIVE BANK LTD SMT. M.M JASMINE- G.P, SRI. GILBERT GEORGE CORREYA- SC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 77 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.18895 OF 2019(J) PETITIONER/S: THE ANGADIPPURAM SERVICE CO-OPERATIVE BANK LTD.NO.P-581 ROSHNI PLAZA, ANGADIPPURAM , MALAPPURAM, REPRESENTED BY ITS SECRETARY BY ADV. SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM, PIN 682 018 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), KOZHIKODE,PIN-673 001 3 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER PIN 676 505. 4 THE SENIOR MANAGER, MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, ANGADIPPURAM BRANCH, MALAPPURAM, PIN 679 321. 5 THE SENIOR MANAGER, MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, PERINTHALMANNA BRANCH, MALAPPURAM, PIN 679 322. 6 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, DEPARTMENT OF CO-OPERATION, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O.THIRUVANANTHAPURAM, PIN 695 014. R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R3 BY SRI.I.V.PRAMOD, SC THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SMT. MM JASMINE- G.P, SRI. I.V. PRAMOD- SC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 78 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.19676 OF 2019(H) PETITIONER/S: MADHAVA VILASOM SERVICE CO-OPERATIVE BANK LTD.NO.1347 REPRESENTED BY ITS SECRETARY, ARASUMOODU, KULATHOOR P.O.THIRUVANANTHAPURAM DISTRICT BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ADDITIONAL COMMISSIONER OF INCOME TAX OFFICE OF THE ADDL. COMMISSIONER OF INCOME TAX, TDS RANGE, 111RD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.THIRUVANANTHAPURAM DISTRICT-695 003. 2 THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT) MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110 001. 3 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI-110001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM-695 001. 5 THE TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O.THIRUVANANTHAPURAM-695 014. 6 THE DISTRICT TREASURY OFFICER, STATUE, PALAYAM, THIRUVANANTHAPURAM-695 001. WP(C).No.7795 OF 2019 & CONNECTED CASES 79 7 THE TREASURY OFFICER, SUB-TREASURY, ENGINEERING COLLEGE, AMBADY NAGAR, CHAVADIMUKKU, BAPUJI NAGAR, PONGUMOODU, THIRUVANANTHAPURAM-695 016 8 THE STATE CO-OEPRATIVE BANK, REPRESENTED BY ITS MANAGING DIRECTOR, THIRUANANTHAPURAM 695 001 9 THE THIRUANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD REPRESENTED BY ITS GENERAL MANAGER HEAD OFFICE, EAST FORT, THIRUANANTHAPURAM 695 023 R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, THOMAS ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 80 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.19797 OF 2019(Y) PETITIONER/S: KARAKULAM FARMERS SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD NO. 1644, KARAKULAM, THIRUVANANTHAPURAM 695 564 REPRESENTED BY ITS SECRETARY INDULEKHA BY ADV. SRI.VINOD KUMAR.C RESPONDENT/S: 1 THE CENTRAL BOARD OF TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 REPRESENTED BY ITS CHAIRMAN 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION , MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM 682 018 3 THE INCOME TAX OFFICER, WARD 2 (3), THIRUVANANTHAPURAM 695 003 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD, NEDUMANGAD MAIN BRANCH, THIRUVANANTHAPURAM 5 THE NEDUMANGAD CO-OPERATIVE URBAN BANK LTD NO. 3193, NEDUMANGAD, THIRUVANANTHAPURAM 6 THE TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCADU P.O, THIRUVANANTHAPURAM 695 014 7 STATE OF KERALA, WP(C).No.7795 OF 2019 & CONNECTED CASES 81 REPRESENTED BY SECRETARY (CO OPERATION) GOVERNMENT OF KERALA, SECRETARIAT, THIRUVANANTHAPURAM R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SC , CHRISTOPHER ABRAHAM,, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 82 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.23879 OF 2019(H) PETITIONER: TRIVANDRUM AYURVEDA COLLEGE DEPARTMENT EMPLOYEES CO-OPERATIVE SOCIETY LTD- T 331, AYURVEDA COLLEGE,MAHATHMA GANDHI ROAD, AYURVEDA COLLEGE JUNCTION,PULIMOODU, THIRUVANANTHAPURAM-695001,REPRESENTED BY ITS SECRETARY JENI.S.R. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE,GOVERNMENT OF INDIA,NORTH BLOCK,NEW DELHI-110001,REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE,GOVERNMENT OF INDIA,CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,KOCHI-682018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE,3RD FLOOR,AATAKAR BHAVAN, KAWADIAR,THIRUVANANTHAPURAM-695003. 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK, HEAD OFFICE,THIRUVANANTHAPURAM, EAST FORT.P.O,THIRUVANANTHAPURAM-695023,REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES,KRISHNA BUILDINGS,THYCAUD.P.O,THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO- WP(C).No.7795 OF 2019 & CONNECTED CASES 83 OPERATION),GOVERNMENT SECRETARIATE, GOVERMENT OF KERALA,THIRUVANANTHAPURAM-695001. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 84 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.30654 OF 2019(F) PETITIONER: KODUVAZHANOOR SERVICE CO-OPERATIVE BANK LTD.NO.3144 REPRESENTED BY ITS SECRETARY, KODUVAZHANOOR P.O., (VIA) PULIMATH, THIRUVANANTHAPURAM DISTRICT. BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ADDITIONAL COMMISSIONER OF INCOME TAX OFFICE OF THE ADDL. COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O., THIRUVANANTHAPURAM DISTRICT-695 003. 2 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110 001. 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI-110 001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES THIRUVANANTHAPURAM-695 001. 5 THE TREASURY DIRECTOR DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM-695 014. 6 THE DISTRICT TREASURY OFFICER STATUE, PALAYAM, THIRUVANANTHAPURAM-695 001. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT WP(C).No.7795 OF 2019 & CONNECTED CASES 85 OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 86 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.6843 OF 2019(E) PETITIONER/S: TRIVANDRUM SERVICE CO-OPERATIVE BANK LTD., GOVERNMENT PRESS ROAD, PUTHENCHANTHA, TRIVANDRUM, REPRESENTED BY SECRETARY. BY ADVS. SRI.ANIL D. NAIR SRI.R.SREEJITH SRI.ACHYUT K PADMARAJ SMT. ARYA ANIL SHRI.GOKULRAJ L. RESPONDENT/S: 1 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AAYKAR BHAWAN, KAWDIAR, THIRUVANANTHAPURAM - 03. 2 THIRUVANANTHAPURAM DISTRICT COOPERATIVE BANK LTD., HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM - 695 023. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R2 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 87 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8507 OF 2019(K) PETITIONER/S: THE ETTUMANOOR SERVICE CO-OPERATIVE BANK ETTUMANOOR PEROOR ROAD, ETTUMANANOOR, KOTTAYAM - 686 631. REPRESENTED BY ITS SECRETARY-IN-CHARGE JESSAMMA JOHN BY ADVS. SRI.S.ARUN RAJ SMT.C.T.SUJA RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, IS PRESS ROAD, COCHIN- 682 018 2 THE ADDL. COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AAYAKAR BHAWAN, KAWADIAR, TRIVANDRUM - 695 003. 3 INCOME TAX OFFICER WARD-5, KOTTAYAM - 686 001 4 THE PRINCIPAL CHIEF MINISTER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 5 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN 6 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK DISTRICT CO-OPERATIVE BANK BUILDING, T.B. ROAD, CENTRAL JUNCTION, KOTTAYAM - 686 001. REPRESENTED BY ITS GENERAL MANAGER WP(C).No.7795 OF 2019 & CONNECTED CASES 88 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATIVE DEPARTMENT),GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R6 BY SRI.ATHUL SHAJI, SC, KOTTAYAM DISTRICT CO.OPERATIVE BANK LTD. R7 BY GOVERNMENT PLEADER OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 89 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8724 OF 2019(M) PETITIONER/S: 1 CHIRAKADAVU SERIVE CO-OPERATIVE BANK LTD. HEAD OFFICE,CHIRAKADAVU.P.O,KOTTAYAM- 686520,REPRESENTED BY ITS SECRETARY NAJIB.C.P. 2 ELAMGULAM SERVICE CO-OPERATIVE BANK LTD 3576 HEAD OFFICE,KOORALI.P.O,KOTTAYAM-686522,REPRESENTED BY ITS SECRETARY IN CHARGE JOSEPH THOMAS. 3 ELIKULAM SERVICE CO-OPERATIVE BANK LTD K 158, HEAD OFFICE,MADUKKAKUNNU.P.O, KOTTAYAM-686577,REPRESENTED BY ITS SECRETARY VIMALKUMAR.T.M. 4 INCHIANY SERVICE CO-OPERATIVE BANK LTD K 154, HEAD OFFICE,INCHIANY.P.O, KANJIRAPALLY TALUK,KOTTAYAM-686512, REPRESENTED BY ITS SECRETARY K.T.JOSEPH. 5 KANAMALA SERVICE CO-OPERATIVE B ANK LTD K 268, HEAD OFFICE,ERUTHUAPUZHA, PAMPAVALLEY.P.O,KOTTAYAM-686510, REPRESENTED BY ITS SECRETARY INCHARGE SAJEEVE.V.R. 6 KANNIMALA SERVICE CO-OPERATIVE BANK LTD 3978, HEAD OFFICE,KANNIMALA.P.O, ERUMELY,KOTTAYAM-686509, REPRESENTED BY ITS SECRETARY, THOMAS P THOMAS. 7 KOOVAPPALLY SERVICE CO-OPERATIVE BANK LTD 3949, HEAD OFFICE,KOOVAPPALLY,KOTTAYAM-686518,REPRESENTED BYITS SECRETARY JOSE MANOJ. 8 KANJIRAPPALLY SERVICE CO-OPERATIVE BANK LTD 2061, HEAD OFFICE,KANJIRAPPALLY,KOTTAYAM- 686507,REPRESENTED BY ITS SECRETARY TOMY SEBASTIAN. WP(C).No.7795 OF 2019 & CONNECTED CASES 90 9 KANJIRAPALLY CENTRAL SERVICE CO-OPERATIVE BANK 1537, HEAD OFFICE,KANJIRAPALLY,KOTTAYAM- 686507,REPRESENTED BY ITS SECRETARY ANSHAD HUSSAIN. 10 KORUTHODU SERVICE CO-OPERATIVE BANK K 365, HEAD OFFICE,KORUTHODU.P.O, KANJIRAPALLY,KOTTAYAM-686513, REPRESENTED BY ITS SECRETARY LILLYKUTTY JOSEPH. 11 ERUMELY SERVICE CO-OPERATIVE BANK LTD. K 113, HEAD OFFICE,ERUMELY.P.O,KOTTAYAM-686509, REPRESENTED BY ITS SECRETARY,MERCYKUTTY MATHEW. 12 MUNDAKAYAM SERVICE CO-OPERTIVE BANK LTD. K 122, HEAD OFFICE,MUNDAKKAYAM,KOTTAYAM-686513,REPRESENTED BY ITS SECRETARY IN CHARGE LISSY JOSEPH. 13 PARATHODE SERVICE CO-OPERATIVE BANK LTD.3002, HEAD OFFICE,VELICHIYANI,PARATHODE.P.O, KOTTAYAM-686512,REPRESENTED BY ITS SECRETARY IN CHARGE REKHAMOL.C.R. 14 MANIMALA SERVICE CO-OPERATIVE BANK LTD.K.641 HEAD OFFICE,MANIMALA.P.O,KOTTAYAM-686543, REPRESENTED BY ITS SECRETARY MANJU.V.S. 15 PONKUNNAM SERVICE CO-OPERATIVE HEAD OFFICE,PONKUNNAM,KOTTAYAM-686505, REPRESENTED BY ITS SECRETARY GEETHA GOPINATH. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE,MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK,NEW DELHI- 110001,REPRESENTED BY IT'S CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION,MINISTRY OF FINANCE, GOVERNMENT OF INDIA,CENTRAL REVENUE BUILDINGS,I S PRESS ROAD,KOCHI-682018. WP(C).No.7795 OF 2019 & CONNECTED CASES 91 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE,3RD FLOOR,AATAKAR BHAVAN, KAWADIAR,THIRUVANANTHAPURAM-695003. 4 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE,KOTTAYAM,DISTRICT CO-OPERATIVE BANK BUILDING,KOTTAYAM-686001,REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES,KRISHNA BUILDINGS,THYCAUD.P.O, THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO- OPERATION),GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA,THIRUVANANTHAPURAM-695001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.ATHUL SHAJI, SC, KOTTAYAM DISTRICT CO.OPERATIVE BANK LTD. OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC ATHUL SHAJI, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 92 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8847 OF 2019(E) PETITIONER/S: KOLLAM DISTRICT POSTAL TELCOM BSNL EMPLOYEES CO- OPERATIVE SOCIETY LTD NO Q. 880, KOLLAM 691 001, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE KOWDIAR, TRIVANDRUM 695 003. 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG. IS PRESS ROAD, KOCHI 682 018 3 THE TREASURY DIRETOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM 695 003. 4 THE SUB TREASURY OFFICER, SUB TREASURY, KOLLAM 691 001 5 COMMISSIONER OF INCOME TAX (TDS), KOCHI, IS PRESS ROAD, PIN 682 018 6 THE KOLLAM DISTRICT CO-OPERATIVE BANK, REPRESENTED BY ITS GENERAL MANAGER, KOLLAM, MAIN BRANCH, PIN 691 001 7 THE QUILON CO-OPERATIVE URBAN BANK LTD REPRESENTED BY ITS BRANCH MANAGER, MAIN BRANCH, WP(C).No.7795 OF 2019 & CONNECTED CASES 93 KOLLAM 691 001 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTHAPURAM 695 001. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R6 BY ARI. P.C SASIDHARAN; SC THE KOLLAM DISTRICT CO-OPERATIVE BANK OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 94 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8879 OF 2019(H) PETITIONER/S: 1 PEROORKADA SERVICE CO-OPERATIVE BANK LIMITED, NO.T.1412 REPRESENTED BY ITS SECRETARY PEROORKADA P.O., THIRUVANANTHAPURAM DISTRICT, KERALA, PIN - 695 005 2 MUDAVANMUGHAL SERVICE CO-OPERATIVE BANK LIMITED NO.T 847, REPRESENTED BY ITS SECRETARY, POOJAPPURA P.O., THIRUVANANTHAPURAM DISTRICT, KERALA, PIN - 695 012 3 MANAMBUR SERVICE CO-OPERATIVE BANK LIMITED NO.2825, REPRESENTED BY ITS SECRETARY, MANAMBUR P.O., THIRUVANANTHAPURAM DISTRICT, KERALA, PIN - 695 605 BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE TDS RANGE, KOWDIAR, TRIVANDRUM - 695 003 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG, IS PRESS, ROAD , KOCHI - 682 018 3 THE TREASURY DIRECTOR OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM - 695 003 WP(C).No.7795 OF 2019 & CONNECTED CASES 95 4 THE SUB-TREASURY OFFICER SUB-TREASURY, KUDAPPANAKUNNU, TRIVANDRUM - 695 003 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), SECRETARIAT, THIRUVANANTHAPURAM - 695 001 6 THE TRIVANDRUM DISTRICT CO-OPERATIVE BANK LTD, REPRESENTED BY ITS GENERAL MANAGER, TRIVANDRUM - 695 003 R1-2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R3-5 BY GOVERNMENT PLEADER R6 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 96 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8910 OF 2019(K) PETITIONER/S: THE VALLAPUZHA SERVICE CO-OPERATIVE BANK LTD. NELLAYA P.O., PALAKKAD DISTRICT, REPRESENTED BY ITS SECRETARY, P.ASHRAFALI,AGED 47,S/O.SRAJU BY ADVS. SRI.HARISANKAR V. MENON SMT.MEERA V.MENON RESPONDENT/S: 1 THE ASST.COMMISSIONER OF INCOME TAX(TDS), PALAKKAD-678 001 2 THE DISTRICT REASURY OFFICER, RURAL DISTRICT TREASURY, CHERPULASSERY, PALAKKAD- 679 503 3 JOINT REGISTRAR GENERAL, CO-OPERATIVE SOCIETIES DEPARTMENT, CIVIL STATION, PALAKKAD-678 001 R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 97 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8919 OF 2019(L) PETITIONER/S: THE ANAD FARMERS SERVICE CO-OPERATIVE BANK LTD NO.919., REPRESENTED BY ITS MANAGING DIRECTOR, ANAD P.O., NEDUMANGAD, THIRUVANANTHAPURAM BY ADVS. DR.K.P.PRADEEP SRI.ASWIN.P.JOHN RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK,NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018 3 INCOME TAX OFFICER, WARD 295)-RANGE 2,AYAKARA BHAVAN, INCOME TAX, KOWDIYAR, THIRUVANANTHAPURAM-695 003 4 THE THIRUVANANTHAPURAM DISTRICT CO-OEPRATIVE BANK LTD, NEDUMANGAD MAIN BRAN NEDUMANGAD MAIN BRANCH, THIRUVANANTHAURAM 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES , KRISHNA BUILDINGS, THYCADU P.O., THIRUVANANTHAPURAM-695 014 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (COOPERATION), WP(C).No.7795 OF 2019 & CONNECTED CASES 98 GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUANANTHAPURAM-695 001 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 99 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8921 OF 2019(M) PETITIONER/S: THE PARAVUR S.N.V.REGIONAL CO-OPERATIVE BANK LIMITED S.PARAVUR. PO,KOLLAM-691301,REPRESENTED BY ITS PRESIDENT. BY ADV. SRI.B.SURESH KUMAR RESPONDENT/S: 1 THE CENTRAL BOARDOF DIRECT TAXES DEPARTMENT OF REVENUE DEPARTMENT OF REVENUE,MINISTRY OF FINANCE, GOVERNMENT OF INDIA,NORTH BLOCK,NEW DELHI-110001. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION,MINISTRY OF FINANCE, GOVERNMENT OF INDIA,CENTRAL REVENUE BUILDINGS,IS PRESS ROAD,KOCHI-682018.. 3 ADDITIONAL COMMISSIONER OF INCOME TAX OFFICER(TDS), OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX OFFICER(TDS),3RD FLOOR, AAYAKAR BHAVAN,KOWADIAR , THIRUVANANTHAPURAM-695003. 4 THE TREASURY DIRECTOR, DIRECTORATE OF TREASURIES,KRISHNA BUILDINGS,THAMPANOOR ROAD,THYCAUD.P.O,THIRUVANANTHAPURAM-695014. 5 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE,KOLLAM,CHINNAKKADA, HEAD POST OFFICE PO,KOLLAM 691001 REPRESENTED BY ITS GENERAL MANAGER. 6 TH EQUILON CO-OPERATIE URBAN BANK LTD, MAIN BRANCH,YMCA ROAD,CHINNAKKADA, WP(C).No.7795 OF 2019 & CONNECTED CASES 100 KOLLAM-691001,REPRESENTED BY ITS BRANCH MANAGER. 7 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES,FORT PO, THIRUVANANTHAPURAM-695023. 8 THE STATE OF KERALA, REPRESENTED BY ITS PRINCIPAL SECRETARY TO THE CO- OPERATIVE DEPARTMENT,SECRETARIAT,FORT PO, THIRUVANANTHAPURAM-695023. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: P. VIJAYAKUMAR SCGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 101 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8926 OF 2019(M) PETITIONER/S: M/S. ANICADU SERVICE CO-OPERATIVE BANK LTD NO.A113., NOOROMMAVU P.O., PUNNAVELLY, ANICADU.,PATHANAMTHITA-689 589, REPRESENTED BY ITS SECRETARY SHAIJU C.ALEX BY ADV. DR.K.P.PRADEEP RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682 018 3 THE INCOME TAX OFFICER, INCOME TAX OFFICER, WARD-4, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, THIRUVALLA RANGE, T.K.ROAD, THIRUVALLA, PATHANAMTHITTA-689 010 4 THE PATHANAMTHITTA DISTRICT CO-OERATIVE BANK HEAD OFFICE, PATHANAMTHITTA, PATHANAMTHITTA-689 645, REPRESENTED BY ITS GENERAL MANAGER, 5 TREASURY DIRECTOR DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM-695 014 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001 WP(C).No.7795 OF 2019 & CONNECTED CASES 102 R4 BY ADV. SRI.T.P.PRADEEP R1 TO R3 BY SRI. JOSE JOSEPH SC; INCOME TAX DEPARTMENT OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 103 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8928 OF 2019(M) PETITIONER/S: 1 ELAMADU SERVICE CO-OPERATIVE BANK LTD. Q.382, ELAMADU P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY JALAJA. 2 THE MATHRA SERVICE CO-OPERATIVE BANK Q.314, MATHRA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SURESHKUMAR G. 3 PIDAVOOR SERVICE CO-OPERATIVE BANK Q.2807, PIDAVOOR P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY G. RAJEEVKUMAR. 4 EDAMON SERVICE CO-OPERATIVE BANK Q.687, EDAMON P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY N.S. GIRIJA RANI. 5 URUKUNNU SERVICE CO-OPERATIVE BANK Q.190, URUKUNNU P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SHERLY M.D. 6 ELAMPAL SERVICE CO-OPERATIVE BANK Q.604, ELAMPAL P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY MANI P. 7 PUNNALA SERVICE CO-OPERATIVE BANK Q.1389, PUNNALA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY PUSHPALATHA O. 8 PATTAZHI VADAKKEKARA SERVICE CO-OPERATIVE BANK LTD. NO.HW25, CHELIKUZHY P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SHEELA DEVI. 9 KUMBALAM SERVICE CO-OPERATIVE BANK Q.311, KUMBALAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS WP(C).No.7795 OF 2019 & CONNECTED CASES 104 SECRETARY B. BINDHU. 10 VELIYAM REGIONAL SERVICE CO-OPERATIVE BANK Q.4171, ODANAVATTOM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY B. VIKRAMAN PILLAI. 11 MURANTHAL SERVICE CO-OPERATIVE BANK Q.1914, PERINAD P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY P.A.SREEJITH. 12 PERUMBUZHA GRAMODHARANA SERVICE CO-OPERATIVE BANK Q.2533, PERUMBUZHA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY R. SURESH BABU. 13 KUNDARA PANCHAYATH SERVICE CO-OPERATIVE BANK Q.401, KUNDARA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SHYNI M.G. 14 SASTHAMKOTTA SERVICE CO-OPERATIVE BANK Q.2531, PORUVAZHY P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY B. RAJAMANI. 15 PIRAVANTHOOR SERVICE CO-OPERATIVE BANK Q. 1471, PIRAVANTHOOR P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY S. SABU. BY ADV. SRI.K.P.PRADEEP RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI-682018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANTHAPURAM-695003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM-691001, REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 105 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS THYCAUD P.O., THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 106 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8946 OF 2019(P) PETITIONER/S: 1 AVANEESWARAM SERVICE COOPERATIVE BANK Q, 1847, KUNNIKODU P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY K.S. VIJAYAKUMARY. 2 PATTAZHY SERVICE COOPERATIVE BANK Q, 1023, PATTAZHY P.O, KOLLAM, REPRESENTED BY ITS SECRETARY VIJAYASREE. 3 VELINAGANNOOR SERVICE COOPERATIVE BANK Q,2873, KARINAGANNOOR P.O, KOLLAM REPRESENTED BY ITS P.K. RAMACHANDRAN. 4 THELAVOOR SERVICE COOPERATIVE BANK , Q,646, THALAVOOR P.O, KOLLAM, REPRESENTED BY ITS SECRETARY SANDHYA B.T, 5 YEROOR SERVICE COOPERATIVE BANK Q, 1816, YEROOR P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY,SREELATHA K.V, 6 ARYANKAVU SERVICE COOPERATIVE BANK Q, 2965, ARYANKAVU P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY, V. VIJUKUMAR, 7 PUNALUR SERVICE COOPERATIVE BANK Q. 2634, NELLIPALLY P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY A.R NOUSHAD. 8 KULATHUPUZHA SERVICE COOPERATIVE BANK Q.1867, KULATHUPUZHA P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY, JAYAKUMAR. 9 KUNDAYAM SERVICE COOPERATIVE BANK Q, 3259, KUNDAYAM P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY, G. REVEENDRAN PILLAI. WP(C).No.7795 OF 2019 & CONNECTED CASES 107 10 PATHANAPURAM SERVICE COOPERATIVE BANK Q. 3658, PATHANAPURAM P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY ABDUL SALAM. 11 THEVALAKKARA FARMERS SERVICE COOPERATIVE BANK Q.4047, THEVALAKARA P.O, KOLLAM DISTRICT, REPRESENTED BY ITS RADHAMONY, 12 ANJALUMMODU SERVICE COOPERATIVE BANK Q.613, PERINAD P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY K. SIVAKUMAR. 13 CHANNAPETTA SERVICE COOPERATIVE BANK Q 358, CHANNPETTA P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SARAMMA PHILIP, 14 ANCHAL SERVICE COOPERATIVE BANK Q.2574, ANCHAL P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SASILEKHA. 15 KAREEPRA SERVICE COOPERATIVE BANK Q 3827, KALAKKODU P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY THOHYMOL P.S, BY ADVS. DR.K.P.PRADEEP SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI-682018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA,KOLLAM-691001., REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 108 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC P C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 109 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8957 OF 2019(T) PETITIONER/S: 1 THEKKUMBHAGAM SERVICE CO OPERATIVE BANK, CHAVARA SOUTH P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETRY Y.VINCENT. 2 EAST KALLADA SERVICE COOPERATIVE BANK Q.3748, EAST KALLADA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY K.R.BABY JAYA. 3 UMMANNOOR SERVICE COOPERATIVE BANK Q.219, UMMANNOOR P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY RAJASEKHARAN PILLAI J. 4 SOORANADU FARMERS SERVICE COOPERTIVE BANK Q.1136, SOORANAD P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY RAMANI V. 5 PATHARAM SERVICE COOPERATIVE BANK Q.721, PATHARAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY PREMKUMAR B. 6 PERAYAM SERVICE COOPERATIVE BANK Q.2369, MULAVANA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY RAJAN S. 7 KOTTAMKARA SERVICE COOPERATIVE BANK Q.132, CHANDANATHOPPU P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARIAT DILEEPKUMAR. 8 NEDUMPANA SERVICE COOPERATIVE BANK Q.117, NEDUMPANA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY AJITHKUMAR. 9 KOLLOORVILA SERVICE COOPERATIVE BANK Q.214, VADAKKEVILA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY RIYAS. WP(C).No.7795 OF 2019 & CONNECTED CASES 110 10 VELLIMON SERVIE COOPERATIVE BANK Q.2355, VELLIMON P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY S.SINDHU. 11 IVERKALA SERVICE COOPERATIVE BANK Q.2006, IVERKALA EAST P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY MEERA P. 12 DECENT JUNCTION SERVICE COOPERATIVE BANK Q.133, DECENT JN. P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SHYLAJA R. 13 EDAMULAKKAL SERVICE COOPERTIVE BANK Q.2047, EDAMULAKKAL P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY RAJALEKSHMI AMMA. 14 CHADAYAMANGALAM SERVCE COOPERATIVE BANK Q.1868, CHADAYAMANGALAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY K.SUNILKUMAR. 15 ERAVIPURAM SERVICE COOPERATIVE BANK Q.234, VALATHUNGAL P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY BINU JACOB. 16 POOTHAKULAM SERVICE COOPERATIVE BANK Q.2944, POOTHAKULAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY ANITHA. BY ADVS. DR.K.P.PRADEEP SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD., WP(C).No.7795 OF 2019 & CONNECTED CASES 111 HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM - 691 001, REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDING, THYCAUD P.O., THIRUVANANTHAPURAM - 695 014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM,, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 112 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8961 OF 2019(U) PETITIONER/S: 1 PATTATHANAM SERVICE COOPERATIVE BANK Q.2471, MUKUNDAPURAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SHAJI D. 2 PAZHANGANAM SERVICE CO-OPERATIVE BANK Q.3848, NALLILA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY PADMA V.SINGH. 3 PERINAD CKP VILSAOM SERVICE COOPERATIVE BANK Q.1361, PERINAD P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY JASMIN S. 4 THRIKKADAVOOR SERVICE COOPERATIVE BANK Q.188, PERINAD P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY GITTY SUDHEER. 5 PEROOR SERVICE COOPERATIVE BANK Q.1222, T.K.M.C.P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY ARCHANA S. 6 PATTATHANAM SERVICE COOPERATIVE BANK Q.1145, PATTATHANAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY S.K.SOBHA. 7 THE WEST KALLADA SERVICE COOPERTIVE BANK Q.4002, WEST KALLADA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY P.S.LEENA. 8 MYNAGAPPALLY SERVICE CO-OPERATIVE BANK Q.69, MYNAGAPPALLY P.O., KOLLAM, REPRESENTED BY ITS SECRETARY B.VIJAYAMMA. 9 SOORANADU GRAMODHARANA SERVICE COOPERATIVE BANK Q.3947, WP(C).No.7795 OF 2019 & CONNECTED CASES 113 SOORANAD P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY DIVYA D.L. 10 KARIMTHOTTUVA SERVICE COOPERATIVE BANK Q.2594, EAST KALLADA P.O., KOLLAM, REPRESENTED BY ITS SECRETARY AMBIKA DEVI. 11 THAZHAVA SERVICE COOPERATIVE BANK Q.160, SRPM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY, M.PRASEETHA. 12 KALAKKODU SERVICE COOPERATIVE BANK Q.1194, KALAKKODU P.O., KOLLAM DISTRICT, REPRESENTED BY THE ITS SECRETARY USHAKUMARY. 13 ULIYAKOVIL SERVICE CO-OPERATIVE BANK Q.1003, ASRAMAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY K.K.SANTHI. 14 IVERKALA SERVICE COOPERATIVE BANK Q 193, INVERKALA EAST P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY, USHAKUMARY. 15 THURUTHIKARA SERVICE COOPERATIVE BANK, KUNNATHOOR P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY BEENA VISWAM. BY ADVS. DR.K.P.PRADEEP SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRALBOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 3 ADDITIONAL COMMISSIONR OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD., HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM- 691 001, REPRESENTED BY ITS WP(C).No.7795 OF 2019 & CONNECTED CASES 114 GENERAL MANAGER. 5 TREASURY OFFICER, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM - 695 014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 115 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8962 OF 2019(U) PETITIONER/S: 1 CHAVARA SERVICE COOPERATIVE BANK Q 147, PUTHENCHANTHA P.O., KOLLAM DISTRICT REPRESENTED BY ITS SECRETARY K.R.SURESHKUMAR. 2 THODIYOOR SERVICE COOPERATIVE BANK Q.2406 THODIYOOR P.O., KOLLAM DISTRICT REPRESENTED BY ITS SECRETARY S.K. SREERANGAN. 3 KARUNAGAPPLLY SERVICE COOPERATIVE BANK Q.1343 KARUNAGAPPALLY P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SUTHAN T. 4 PUTHIYAKAVU SERVICE COOPERATIVE BANK Q.1240 K.S.PURAM P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SAFUNA.Y 5 KULASEKHARAM SERVICE COOPERATIVE BANK Q.995 KATTILKKADAV P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY NASEEMA BEEVI. 6 CLAPPANA SERVICE COOPERATIVE BANK Q.867 CLAPANA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SHANITHAMOL. 7 CHIRAKARA SERVICE COOPERATIVE BANK Q.1894 CHIRAKARA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY ASHOKKUMAR. 8 EAST KALLADA SERVICE COOPERATIVE BANK Q.187 EAST KALLADA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY AJITH PRASAD.N. 9 CHAKKUVARAKKAL SERVICE COOPERATIVE BANK Q.1521 CHAKKUVARAKKAL P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY RAMESHKUMAR. 10 THRIKKANAMANGAL SERVICE COOPERATIVE BANK Q.2431 WP(C).No.7795 OF 2019 & CONNECTED CASES 116 KOTTARAKKARA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY S.RAJENDRAN. 11 VETTIKKAVALA SERVICE COOPERATIVE BANK Q.1381 VETTIKKAVALA P.O., KOLLAM DISTRICT. REPRESENTED BU ITS SECRETARY J.KRISHNAKUMARY 12 POOYAPPALLY SERVICE COOPERATIVE BANK MEEYANNOOR P.O., KOLLAM DISTRICT REPRESENTED BY ITS SECRETARY ANILKUMAR 13 EZHUKONE SEVICE COOPERATIVE BANK Q.2935 EZHUKONE P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY ANILKUMAR K. 14 ADICHANALLOOR SERVICE COOPERATIVE BANK Q.2603 ADICHANALLOOR P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SHAJIKUMAR G. BY ADVS. DR.K.P.PRADEEP SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 3 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR THIRUVANANTHAPURAM-695003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD. HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM-691001 REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATIION) WP(C).No.7795 OF 2019 & CONNECTED CASES 117 GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA THIRUVANANTHAPURAM-695 001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 118 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.8972 OF 2019(V) PETITIONER/S: 1 POOVATTOOR EAST SERVICE COOPERATIVE BANK Q.3503, KALAYAPURAM P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SINDHU R. 2 CHITHARA SERVICE COOPERATIVE BANK Q 2818, CHITHARA P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY SUBHA C.C. 3 THUDAYANNOOR SERVICE COOPERATIVE BANK Q 371, THUDAYANNOOR P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY ANITHA S. NAIR 4 THRIKKOVILVATTOM SERVICE CO-OPERATIVE BANK Q 78, MUKHATHALA P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY BEENA RANI B.J. 5 VADAKKEVILA SERVICE COOPERATIVE BANK Q. 2292, THATTAMALA P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRTARY LEENA S 6 MANGADU SERVICE COOPERATIVE BANK Q. 1069 MANGADU P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY D. SREELEKHA 7 PADINJARE KOLLAM SERVICE CO-OPERATIVE BANK Q.73 KAVANADU P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY TOZY.P 8 PUNNATHALA SERVICE CO-OPERATIVE BANK Q.491, PUNNATHALA, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY VASANTHA T. 9 PANAYAM PANCHAYATH SERVICE COOPEREATIVE BANK Q.1345, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY WP(C).No.7795 OF 2019 & CONNECTED CASES 119 SUBHASH D.S, 10 CHTHANNOOR REGIONAL SERVICE COOPERATIVE BANK Q. 153, CHATHANNOOR P.O, KOLLAM DITRICT, REPRESENTED BY ITS SECRETARY G.S SURESH. 11 ELAMKULAM SERVICE CO-OPERATIVE BANK Q. 1879, KALLUVATHUKKAL P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY BAIJU R. 12 PARAVUR REGIONAL SERVICE COOPERATIVE BANLK Q. 1649, PARAVUR P.O, KOLLAM DISTRICT,,REPRESENTED BY PRASAD C. 13 KILIKOLLOOR SERVICE COOPERATIVE BANK, KILIKOLLOOR P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY A. PRADEE 14 NEDUGOLAM SERVICE CO-OPERATIVE BANK Q. 2845, NEDUGOLAM P.O, KOLLAM DISTRICT, REPRESENTED BY ITS PRAMOD S. 15 NADAKKAL SERVICE CO-OPERATIVE BANK Q. 1874 KALLUVATHUKKAL P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY J. RAAJI. 16 KADAKKAL SERVICE COOPERATIVE BANK Q. 3456, KADAKKAL P.O, KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY P. ASHOKAN. BY ADVS. DR.K.P.PRADEEP SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECET TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIOENR OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING,S IS PRESS ROAD, KOCHI 682 018. 3 ADDITIONAL COMMISSIOENR OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, WP(C).No.7795 OF 2019 & CONNECTED CASES 120 THIRUVANANTHAPURAM 695 003 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM 691 001 REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM 695 014 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 121 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9245 OF 2019(E) PETITIONER/S: 1 PALODE SERVICE CO-OPERATIVE BANK LTD.NO.792 CO-OPERATIVE BUILDING, PALODE KARIMANCOE, THIRUVANANTHAPURAM-695 562, REPRESENTED BY ITS SECRETARY,REKHA V.O. 2 UZHAMALACKAL SERVICE CO-OPERATIVE BANK LTD, NO T.298, PUTHUKULANGARA P.O.THIRUVANANTHAPURAM-695 541, REPRESENTED BY ITS SECRETARY,ASHA K.S. 3 NANNIYODE SERVICE CO-OPERATIVE BANK LTD,NO 1161, NANNIYODE, PACHA P.O.NEDUMANGAD, THIRUVANANTHAPURAM-695 562, REPRESENTED BY ITS SECRETARY, P.LATHAKUMARI. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD KOCHI-682018 3 INCOME TAX OFFICER, WP(C).No.7795 OF 2019 & CONNECTED CASES 122 WARD 2(5)-RANGE 2, AYAKAR BHAVAN, INCOME TAX, KOWADIAR, THIRUVANANTHAPURAM-695 003. 4 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK, HEAD OFFICE, THIRUVANNANTHAPURAM,EAST FORT P.O.THIRUVANANTHAPURAM-695 023, REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O.THIRUVANANTHAPURAM 695 014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM -695 001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC, THOMAS ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 123 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9272 OF 2019(H) PETITIONER/S: 1 NILAMEL SERVICE COOPERATIVE BANK LTD. NO. 883 NO.Q883, NILAMEL P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY JALEELA. A 2 PUNUKANNOOR DESHABHIVARTHINI SERVICE COOPERATIVE BANK LTD. NO. Q. 2745, PERUMBUZHA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY RANI SAM. 3 PERUMBUZHA SERVICE COOPERATIVE BANK LTD. NO. Q. 2368, PERUMBUZHA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY MANJU K. 4 KULAKKADA SERVICE COOPERATIVE BANK LTD., NO.Q 4299, THAZATHU KULAKKADA P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY G. JYOTHI. 5 VENDAR SERVICE COOPERATIVE BANK LTD. NO. Q. 236, VENDAR P.O., KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY MINIMOL .K 6 NEDUVATHOOR SERVICE COOPERATIVE BANK LTD. NO.Q. 3856, NEELESWARAM P.O., KOLLAM, REPRESENTED BY ITS SECRETARY ASOKA KUMAR BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: WP(C).No.7795 OF 2019 & CONNECTED CASES 124 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCH, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018 3 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 685 003 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD. HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM - 691 001, REPRESENTED BY ITS GENERAL MANAGER 5 TREASURY DIRECTOR DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM - 695 014 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001 R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 125 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9274 OF 2019(H) PETITIONER/S: VENJARAMOOD SERVICE CO-OPERATIVE BANK LTD NO. 2419, REPRESENTED BY ITS SECRETARY, VENJARAMOODU P.O., THIRUVANANTHAPURAM DISTRICT - 695 607 BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF TE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, III RD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O., THIRUVANANTHAPURAM DISTRICT - 695 003 2 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - 110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES THIRUVANANTHAPURAM - 695 001 5 THE THIRUVANANTHAPUAM DISTRICT CO-OPERATIVE BANK LTD REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM - 695 023 R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX WP(C).No.7795 OF 2019 & CONNECTED CASES 126 DEPARTMENT R5 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 127 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9412 OF 2019(B) PETITIONER/S: 1 UMAYANALLOOR SERVICE CO OPERATIVE BANK UMAYANALLOOR P.O,KOLLAM DISTRICT, REPRESENTED BY ITS SECRETARY. 2 THE MAYYANAD REGIONAL CO-OPERATIVE BANK LTD, NO.99, MAYYANAD P.O, KOLLAM, REPRESENTED BY ITS CHIEF EXECUTIVE. 3 THE MAYYANAD SERVICE CO-OPERATIVE BANK LTD, NO.2294, KOOTTIKADA P.O, KOLAM, REPRESENTD BY ITS SECRETARY. BY ADVS. JAYAPRADEEP V SMT.ANN SUSAN GEORGE SMT.O.A.NURIYA SRI.D.S.LOKANATHAN SRI.ALAN PRIYADARSHI DEV RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI-682018. 3 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS-RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWADIAR, THIRUVANANTHAPURAM-695003. WP(C).No.7795 OF 2019 & CONNECTED CASES 128 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK, CHINNAKKADA, KOLLAM-691001, REPRESENTED BY ITS GENERAL MANAGER. 5 THE TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O, THIRUVANANTHAPURAM-695014. 6 THE STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, SECRETARIAT, THIRUVANANTHAPURAM-695001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC PC SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 129 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9475 OF 2019(H) PETITIONER/S: 1 PAMPADY SERVICE CO-OPERATIVE BANK LTD NO.831 SOUTH PAMPADY P.O., KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY SOBHANA V.A. 2 KUDAMALLOOR SERVICE CO-OPERATIVE BANK LTD NO.93, KUDAMALOOR( P.O.), KOTTAYAM-17, REPRESENTED BY ITS SECRETARY HARIKUMAR D. 3 KARAPUZHA SERVICE CO-OPERATIVE BANK LTD NO.74, VELOOR, KOTTAYAM WEST P.O.-686003, REPRESENTED BY ITS SECRETARY RAJEEV K.R. 4 KOLLAD SERVICE CO-OPERATIVE BANK LTD NO.1830, KOLLAD P.O., KOTTAYAM-686004, REPRESENTED BY ITS SECRETARY SASIKALA P.R. 5 THE VAZHOOR FARMERS SERVICE CO-OPERATIVE BANK LTD NO.2278, PULICKALKAVALA P.O., KOTTAYAM-686515, REPRESENTED BY ITS SECRETARY REJI P. KOSHY. 6 NEDUMKUNNAM REGIONAL SERVICE CO-OPERATIVE BANK LTD NO.286, NEDUMKUNNAM P.O., KOTTAYAM-686542, REPRESENTED BY ITS SECRETARY BIJU P.K. 7 NEEZHOOR SERVICE CO-OPERATIVE BANK LTD NO.K-136, NEEZHOOR P.O., KOTTAYAM-686612, REPRESENTED BY ITS SECRETARY AMBIKA DEVI. 8 MULAKKULAM PANCHAYATH SERVICE CO-OPERATIVE BANK LTD NO.209, PERUVA P.O., KOTTAYAM-686610, REPRESENTED BY ITS SECRETARY ALEYACHAN P.V. WP(C).No.7795 OF 2019 & CONNECTED CASES 130 9 THE VELLAVOOR SERVICE CO-OPERATIVE BANK LTD NO.4300, KADAYANICKADU P.O., KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY A.N. KESAVAN NAMPOOTHIRI. 10 KOROPPADA SERVICE CO-OPERATIVE BANK LTD NO.3965, KOOROPPADA P.O., KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY A.G. SYAMALA. 11 KUMARANALOOR SERVICE CO-OPERATIVE BANK LTD NO.3898, PERUMPAIKAD P.O., KOTTAYAM-686028, REPRESENTED BY ITS SECRETARY VIJAYAKUMAR V.G. 12 AYMANAM VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO.750, AYMANAM, KOTTAYAM-686015, REPRESENTED BY ITS SECRETARY K. RUGMINI DEVI K. 13 KUMARAKOM VADAKKUMBHAGAM SERVICE CO-OPERATIVE BANK LTD. NO.1070, KUMARAKOM-686563, REPRESENTED BY ITS SECRETARY K. KRISHNAKUMARI. 14 KADUTHURUTHY REGIONAL SERVICE CO-OPERATIVE BANK LTD. NO.4061, KADUTHURUTHY P.O., KOTTAYAM-6866604, REPRESENTED BY ITS SECRETARY T.C.VINOD. 15 PANACHIKAD REGIONAL SERVICE CO-OPERATIVE BANK LTD. NO.3959, CHANNANIKKADU P.O., KOTTAYAM-686533, REPRESENTED BY ITS SECRETARY PREMU IPE. 16 THRIKKODITHANAM SERVICE CO-OPERATIVE BANK LTD. NO.178, MUTHOOR P.O., THIRUVALLA-686105, REPRESENTED BY ITS SECRETARY USHAKUMARY M. 17 VELLOOR SERVICE CO-OPERATIVE BANK LTD. NO.K 231, VELLOOR P.O., PAMPADY, REPRESENTED BY ITS SECRETARY GEETHA S. PILLAI. 18 ANICKADU REGIONAL FARMERS SERVICE CO-OPERATIVE BANK LTD. NO.3867, ANICKADU P.O., KOTTAYAM-686503, REPRESENTED BY ITS MANAGING DIRECTOR (IN CHARGE), SURESH BABU R. BY ADVS. SRI.S.ABHILASH VISHNU SHRI.NIKHIL SUNNY MOOKEN WP(C).No.7795 OF 2019 & CONNECTED CASES 131 RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX(TDS),) CENTRAL REVENUE BUILDING, IS PRESS ROAD, COCHIN- 682018. 2 THE ADDL. COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AYAKAR BHAWAN, KAWADIAR, TRIVANDRUM-695003. 3 INCOEM TAX OFFICER, WARD-3, THIRUVALLA-689101 4 INCOME TAX OFFICER, WARD-3, THIRUVALLA-689101 5 INCOEM TAX OFFICER, WARD-4, THIRUVALLA-689101 6 INCOME TAX OFFICER, WARD-1, KOTTAYAM-686001. 7 INCOEM TAX OFFICER, WARD-2, KOTTAYAM-686001. 8 INCOME TAX OFFICER, WARD-3, KOTTAYAM-686001. 9 INCOME TAX OFFICER, WARD-4, KOTTAYAM-686001. 10 INCOEM TAX OFFICER, WARD-5, KOTTAYAM-686001. 11 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 12 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 13 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD., DISTRICT CO-OPERATIVE BANK BUILDING, T.B. ROAD, CENTRAL JUNCTION, KOTTAYAM-6860001, REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 132 14 STATE OF KERALA, REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVT., CO-OPERATIVE (C) DEPARTMENT, THIRUVANANTHAPURAM- 695001. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R13 BY ADV. SRI.ATHUL SHAJI OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 133 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9566 OF 2019(U) PETITIONER/S: THE KAZHAKUTTOM SERVICE CO-OPERATIVE BANK LTD REPRESENTED BY ITS SECRETARY , KAZHAKUTAM P.O, THIRUVANANTHAPURAM DISTRICT - 695 582 BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, OFFICE OF TH ASSISTANT COMMISSIONER OF INCOME TAX,TDS RANGE, IIIRD FLOOR, AAYAKARBHAVAN, KOWDIAR P.O, THIRUVANANTHAPURAM - 695 003 2 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/ MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI - 110 001 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - 110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES THIRUVANANTHAPURAM - 695 001 5 THE THIRUVANANTHAPURM DISTRICT CO-OPERATIVE BANK LTD REPRESENTED BY ITS GENERAL MANAGER,HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM - 695 023 R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX WP(C).No.7795 OF 2019 & CONNECTED CASES 134 DEPARTMENT R5 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 135 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9620 OF 2019(B) PETITIONER/S: 1 THE TEEKOY SERVICE CO-OPERATIVE BANK LTD. NO. 3143, TEEKOY P.O., KOTTAYAM DISTRICT-686580, REPRESENTED BY ITS SECRETARY, SHRI.P.M.SEBASTIAN. 2 THE THIDANAD SERVICE CO-OPERATIVE BANK LTD. NO.3990, CHEMMALAMATTOM, KOTTAYAM-686508, REPRESENTED BY ITS SECRETARY IN CHARGE SHRI. EMMANUEL JOSEPH. 3 THE VAYALA SERVICE CO-OPERATIVE BANK LTD. NO.2175, VAYALA P.O., KOTTAYAM DISTRICT-686587, REPRESENTED BY ITS SECRETARY, SHRI.ANANDAKUMAR C.K. 4 THE KADAPLAMATTAM SERVICE CO-OPERATIVE BANK LTD. NO.2633, KADAPLAMATTAM P.O., KOTTAYAM-686571, REPRESENTED BY ITS SECRETARY, SMT. JAISAMMA JOSEPH. 5 THE MEENACHIL SERVICE CO-OPERATIVE BANK LTD. NO.K 271, EDAMATTOM P.O., KOTTAYAM-686578, REPRESENTED BY ITS SECRETARY, SMT.K.M.SALIKUTTY. 6 THE MUTHOLY SERVICE CO-OPERATIVE BANK LTD. NO.1631, THEKKUMMURY, PULIYANNOOR P.O., KOTTAYAM DISTRICT- 686573, REPRESENTED BY ITS SECRETARY IN CHARGE, SHRI. THOMAS P.T. 7 THE VALAVOOR SERVICE CO-OPERATIVE BANK LTD. NO.K 91, VALAVOOR, KOTTAYAM DISTRICT-686635, REPRESENTED BY ITS SECRETARY, SHRI.GOPALAKRISHNAN NAIR K.K. WP(C).No.7795 OF 2019 & CONNECTED CASES 136 8 THE KURAVILANGAD SERVICE CO-OPERATIVE BANK LTD. NO.1049, KURAVILANGAD P.O., KOTTAYAM DISTRICT-686633, REPRESENTED BY ITS SECRETARY SMT. V.N.USHA. 9 THE EZHACHERRY SERVICE CO-OPERATIVE BANK LTD. NO.1548, EZHACHERRY P.O., KOTTAYAM-686651, REPRESENTED BY ITS SECRETARY, SMT. LISSY JOSE. 10 THE VELIYANOOR SERVICE CO-OPERATIVE BANK LTD. NO.K 282, VELIYANOOR P.O., KOTTAYAM DISTRICT-686634, REPRESENTED BY ITS SECRETARY, SMT. SHEEJA M.B. 11 THE KIDANGOOR SERVICE CO-OPERATIVE BANK LTD. NO.3431, KIDANGOOR P.O., KOTTAYAM-686572, REPRESENTED BY ITS SECRETARY, SMT. SUJATHA KUMARI P.C. 12 THE UZHAVOOR SERVICE CO-OPERATIVE BANK LTD. NO.3810, UZHAVOOR P.O., KOTTAYAM-686634, REPRESENTED BY ITS SECRETARY, SHRI. RAMESH S.NAIR. BY ADVS. SRI.SHAJI THOMAS SRI.JEN JAISON RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 3 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN KAWADIAR, THIRUVANANTHAPURAM-695003. 4 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD., HEAD OFFICE, KOTTAYAM DISTRICT CO-OPERATIVE BANK BUILDING, KOTTAYAM-686001, REPRESENTED BY ITS GENERAL MANAGER. WP(C).No.7795 OF 2019 & CONNECTED CASES 137 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O., THIRUVANANTHAPURAM-695014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY ADV. SRI.ATHUL SHAJI OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 138 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9673 OF 2019(H) PETITIONER/S: THE ANDOORKONAM SERVICE CO-OPERATIVE BANK LTD., REPRESENTED BY ITS SECRETARY, KEEZHAVOOR P.O, THIRUVANANTHAPURAM DISTRICT 695 584 BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O, THIRUVANANTHAPURAM DISTRICT 695 003 2 THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/ MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI 110 001 3 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABOINET SECRETARIAT, TAISANA HILL, NEW DELHI 110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM 695 001 5 THE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD, REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, EAST FORT, THIRUVANANTHAPURAM 695 023. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R5 BY SRI.THOMAS ABRAHAM SC THIRUVANANTHAPURAM DIST. CO.OP BANK SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE WP(C).No.7795 OF 2019 & CONNECTED CASES 139 COURT ON THE SAME DAY DELIVERED THE FOLLOWING: IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9686 OF 2019(I) PETITIONER/S: THE KANAKKARY SERVICE CO-OPERATIVE BANK LIMITED NO.3839, VEMPALLY P.O., KOTTAYAM, REPRESENTED BY ITS SECRETARY. BY ADV. SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), THIRUVANANTHAPURAM, PIN- 678 001. 3 THE GENERAL MANAGER, KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD., DISTRICT CO-OPERATIVE BANK BUILDING, KOTTAYAM, PIN - 686 001. 4 THE KADATHURUTHUY URBAN CO-OPERTIVE BANK LTD., K 399, REPRESENTED BY ITS MANAGING DIRECTOR, KADATHURUTHY, KOTTAYAM, PIN - 686 604. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, DEPARTMENT OF CO-OPERATION, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O., THIRUVANANTHAPURAM, PIN- 695 014. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R3 BY ADV. SRI.ATHUL SHAJI OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 140 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9764 OF 2019(U) PETITIONER/S: 1 PUZHAVATHU SERVICE COOPERATIVE BANK LTD PUZHAVATHU,CHANGANASSERY(P.O), KOTTAYAM,686101.REPRESENTED BY ITS SECRETARY ANITHA.G. 2 NEDUMKUNNAM SOUTH SERVICE CO-OPERATIVE BANK LTD.NO.1271, PUNNAVELI(P.O),KOTTAYAM-689589, REPRESENTED BY ITS SECRETARY GEORGE THOMAS. 3 NEDUMKUNNAM SERVICE CO-OPERATIVE BANK LTD.NOP.1301, NEDUMKUNNAM(P.O),KOTTAYAM-686542, REPRESENTE BY ITS SECRETARY JOB THOMAS. 4 CHANGANASSERY NORTH SERVICE CO-OPERATIVE BANK LTD.NO.3489, TEMPLE ROAD,VAZHAPPALLY.P.O, KOTTAYAM DISTRICT,REPRESENTED BY ITS SECRETARY(IN CHARGE),K.UNNIKRISHNAN NAIR. BY ADVS. SRI.T.A.SHAJI (SR.) SHRI.NIKHIL SUNNY MOOKEN SRI.S.ABHILASH VISHNU RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING,IS PRESS ROAD,COCHIN- 682018. 2 THE ADDL.COMMISSIONER OF INCOME TAX, TDS RANGE,3RD FLOOR,AYAKAR BHAWAN,KAWADIAR,TRIVANDRUM-695003. WP(C).No.7795 OF 2019 & CONNECTED CASES 141 3 INCOME TAX OFFICER, WARD-2,KOTTAYAM-686001. 4 INCOME TAX OFFICER, WARD-2,KOTTAYAM-686001. 5 INCOME TAX OFFICER, WARD-4,THIRUVALLA-689101. 6 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION,MINISTRY OF FINANCE,GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS,IS PRESS ROAD,KOCHI- 682018. 7 THE CENTRLA BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE,MINISTRY OF FINANCE,GOVERNMENT OF INDIA, NORTH BLOCK,NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 8 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD, DISTRICT CO-OPERATIVE BANK BUILDING,T.B.R0AD,CENTRAL JUNCTION, KOTTAYAM-686001,REPRESENTED BY ITS GENERAL MANAGER. 9 STATE OF KERALA, REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVT.,CO- OPERATION (C)DEPARTMENT,THIRUVANANTHAPURAM,PIN- 695001. R1 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R8 BY SRI.ATHUL SHAJI, SC, KOTTAYAM DISTRICT CO.OPERATIVE BANK LTD. OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 142 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9768 OF 2019(U) PETITIONER/S: 1 THE POOVARANY SERVICE CO-OPERATIVE BANK LTD NO.2882, POOVARANY P.O.KOTTAYAM DISTRICT-686 577, REPRESENTED BY ITS SECRETARY, SHRI. GEORGEKUTTY K.M. 2 THE KOZHUVANAL SERVICE CO-OPERATIVE BANK LTD, NO.213, KOZHUVANAL P.O.KOTTAYAM-686 573, REPRESENTED BY ITS SECRETARY, SHRI.JOSEPH ANTONY. 3 THE MUTHOLY EAST SERVICE CO-OPERATIVE BANK LTD, NO 1606, MUTHOLY EAST P.O.KOTTAYAM DISTRICT- 686 573, REPRESENTED BY ITS SECRETARY SMT. SHEELA C. BY ADVS. SRI.SHAJI THOMAS SRI.JEN JAISON RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI- 682 018 3 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 003. WP(C).No.7795 OF 2019 & CONNECTED CASES 143 4 THE KOTTAYAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, KOTTAYAM, DISTRICT CO-OPERATIVE BANK BUILDING, KOTTAYAM-686 001, REPRESENTED BY ITS GENERAL MANAGER. 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS, THYCAUD P.O.THIRUVANANTHAPURAM-695 014. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY ADV. SRI.ATHUL SHAJI OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 144 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9774 OF 2019(V) PETITIONER/S: POOVATHUMKADAVU FARMERS SERVICE CO-OPERATIVE BANK LTD, PANANGAD P.O, THRISSUR DISTRICT, PIN 680 665, REPRESENTED BY ITS MANAGING DIRECTOR-IN CHARGE. BY ADVS. SRI.C.A.JOJO SRI.JACOB CHACKO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION)., SECRETARIAT, THIRUVANANTHAPURAM 695 001 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, KOWDIAR, TRIVANDRUM 695 003. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018. 4 JOINT COMMISSIONER OF INCOME TAX (TDS) KOCHI, IS PRESS ROAD, PIN 682 018 5 THE TREASURY DIRECTOR, OFFICE OF THE TREASURY DIRECTOR, THYCAUD, TRIVANDRUM 695 003 6 THE DISTRICT TREASURY OFFICER, DISTRICT TREASURY, THRISSUR 680 003 WP(C).No.7795 OF 2019 & CONNECTED CASES 145 7 THE THRISSUR DISTRICT CO-OPERATIVE BANK, REPRESENTED BY ITS GENERAL MANAGER, THRISSUR, MAIN BRANCH, PIN 690 022 8 THE KODUNGALLUR TOWN CO-OPERATIVE BANK LTD REPRESENTED BY ITS GENERAL MANAGER, MAIN BRANCH KODUNGALLUR 680 665 MANAGER, MAIN BRANCH, KOLLAM 691 001. R4 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC ATHUL SHAJI, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 146 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9820 OF 2019(B) PETITIONER/S: PUNUKKONNOOR SERVICE CO-OPERATIVE BANK LTD NO.2722, SOCIETYJUNCTION,PERUMPUZHA ,KOLLAM, 691504,REPRESENTED BY ITS SECRETARY REJITHAMOL.T.G. BY ADVS. SMT.S.K.DEVI SRI.SANTHOSH P.ABRAHAM RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,GOVERNMENT OF INDIA,NORTH BLOCK,NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION,MINISTRY OF FINANCE,GOVERNMENT OF INDIA,CENTRAL REVENUE BUILDINGS, I S PRESS ROAD,KOCHI-682018. 3 THE ADDITIONAL COMMISSIONER OF INCOME TAX,TDS RANGE, 3RD FLOOR,AATAKAR BHAVAN,KOWDIAR, THIRUVANANTHAPURAM-695003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK, HEAD OFFICE,DISTRICT CO-OPERATIVE BANK BUILDING,CHINNAKKADA,KOLLAM-691001,REPRESENTED BY ITS GENERAL MANAGER. 5 THE QUILON CO-OPERATIVE URBAN BANK CHINNAKADA, KOLLAM-695001,REPRESENTED BY ITS SECRETARY. 6 TREASURY DIRECTOR, WP(C).No.7795 OF 2019 & CONNECTED CASES 147 DIRECTORATE OF TREASURIES,KRISHNA BUILDINGS,THYCAUD.P.O,THIRUVANANTHAPURAM-695014. 7 THE SUB TREASURY OFFICER, SUB TREASURY,CIVIL STATION, KOLLAM-691013. 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO- OPERATION),GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R4 BY SRI.P.C SASIDHARAN; SC FOR THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD R5 BY SMT. RENU D.P; SC THE QUILON CO-OPERATIVE URBAN BANK CHINNAKADA OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC RENU DP, SC P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 148 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9838 OF 2019(D) PETITIONER/S: NADKKAL SERVICE COOPERATIVE BANK Q.1874 KALLUVATHUKKAL P.O.KOLLAM DISTRICT-691 578, REPRESENTED BY ITS SECRETARY J.RAJI. BY ADVS. DR.K.P.PRADEEP SRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SRI.T.T.BIJU SMT.T.THASMI SMT.ANJANA KANNATH RESPONDENT/S: 1 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 2 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD KOCHI-682 018 3 ADDITIONAL COMMISSIONER OF INCIME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 003. 4 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, DISTRICT CO-OPERATIVE BANK BUILDING, CHINNAKADA, KOLLAM 691 001, REPRESENTED BY ITS GENERAL MANAGER 5 TREASURY DIRECTOR, DIRECTORATE OF TREASURIES, KRISHNA BUILDINGS THYCAUD P.O.THIRUVANANTHAPURAM 695 014. WP(C).No.7795 OF 2019 & CONNECTED CASES 149 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. 7 THE QUILION CO-OPERATIVE URBAN BANK LTD 960, MAIN BRANCH, YMCA ROAD, CHINNAKKADA, KOLLAM 691 001. REPRESENTED BY ITS SECRETARY R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT R7 BY ADV. SRI.N.DHARMADAN (SR.) R7 BY ADV. SMT.D.P.RENU OTHER PRESENT: SC , CHRISTOPHER ABRAHAM, SC ,P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 150 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9879 OF 2019(H) PETITIONER/S: THE KODUR SERVICE CO-OPERATIVE BANK LIMITED, F.1523, KODUR P.O., MALAPPURAM DISTRICT, REPRESENTED BY ITS SECRETARY BY ADV. SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX CENTRAL REVENUE BUILDING, I.S.PRESS ROAD,ERNAKULAM, PIN-682 018 2 THE ADDITIOANL COMMISSIONER OF INCOME TAX (TDS), KOZHIKODE,PIN-673 001 3 THE DISTRICT TREASURY OFFICER, DISTRICT TREASURY, MALAPPURAM, PIN-675 504 4 THE SUB TREASURY OFFICER, SUB TREASURY, PERINTHALMANNA,PIN-679 321 R2 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT OTHER PRESENT: SMT. M.M JASMINE- G.P THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 151 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.K.JAYASANKARAN NAMBIAR TUESDAY, THE 03RD DAY OF DECEMBER 2019 / 12TH AGRAHAYANA, 1941 WP(C).No.9918 OF 2019(L) PETITIONER/S: THE PANMANA SERVICE CO-OPERATIVE BANK LTD.NO.3035, REPRESENTED BY ITS SECRETARY, KOLLAKA P.O., KARUNAGAPPALLY, KOLLAM DISTRICT - 691 583. BY ADVS. SRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWIDAR P.O., THIRUVANANTHAPURAM - 695 003. 2 THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI - 110 001. 3 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - 110 001. 4 THE REGISTRAR OC-OPERATIVE SOCITIES, THIRUVANANTHAPURAM - 695 001. 5 THE KOLLAM DISTRICT CO-OPERATIVE BANK LTD., REPRESENTED BY ITS GENERAL MANAGER, HEAD OFFICE, CHINNAKADA, KOLLAM, PIN- 691 001. R1 TO R3 BY SRI.CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SC , CHRISTOPHER ABRAHAM, SC, P.C SASIDHARAN, GP MM JASMINE THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 03.12.2019, ALONG WITH WP(C).7795/2019 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No.7795 OF 2019 & CONNECTED CASES 152 “CR” JUDGMENT The issue that arises for consideration in these writ petitions is the entitlement of the petitioners, who are Primary Agricultural Credit Societies registered under the provisions of the Kerala Co-operative Societies Act 1969, to the benefit of an exemption from the provisions of Section 194A of the Income Tax Act (‘the Act’ for short). The said provision mandates a deduction of tax at source, whenever any person, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, effects payment thereof in cash or by issue of cheque or draft or by any other mode. The provisions of Section 194A do not apply in cases specified under Section 194A(3)(iii) of the Act. In these writ petitions, we are concerned with the exemptions provided under Sections 194A(3)(iii)(a) and 194A(3)(iii)(v) of the Act. The said provisions read as under; 194A. Interest other than “ Interest on securities” (1) Any person, not being an individual or a Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income [ by way of interest on securities], shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash or by issue of a cheque or draft or by any other mode, whichever is earlier, deduct income-tax thereon at the rates in force: [provided that an individual or a Hindu undivided family, whose total sales, gross receipts or turnover from the business or profession carried on by him exceed the monetary limits specified under clause (a) or clause (b) of section 44AB during the financial year immediately preceding the financial year in which such interest is credited or paid, shall be liable to deduct income-tax under this Section] (3)The provisions of Sub-section (1) shall not apply- Where the amount of such income or, as the case may be, the aggregate of the amounts of such income credited or paid or likely to be credited or paid during the financial year by the person referred to in sub-section(1) to the account of, or to, the payee, [does not exceed------ (i) xxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxx WP(C).No.7795 OF 2019 & CONNECTED CASES 153 (ii) xxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxx (iii) to such income credited or paid to- (a) Any banking company to which the Banking Regulation Act,1949(10 of 1949), applies, or any Co-operative Society engaged in carrying on the business of banking (including a co-operative land mortgage, bank), or xxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxx (v) to such income credited or[paid by a co-operative society(other than a co-operative bank) to a member thereof or to such income credited or paid by a co-operative society] to any other co-operative society;] 2. It is the case of the petitioners herein that as Primary Agricultural Credit Societies, they are co-operative societies inter alia engaged in carrying on the business of banking and they are therefore entitled to receive the interest amounts earned by them from deposits made with the State Treasuries and the District Co-operative Banks respectively without deduction of tax at source. They contend that in respect of the amounts deposited with the State Treasury, they would be exempted from the requirement of suffering tax deduction at source on an account of the provisions of Section 194A(3)(iii)(a), and in respect of the interest earned from deposits with the District Co- operative Banks, they would be entitled to a similar exemption on account of Section 194A(3)(iii)(v). 3. At the very outset, it might be noticed that in respect of the claim for exemption under Section 194A(3)(iii)(v), the revenue has fairly conceded that in as much as the Primary Agricultural Credit Societies are also Co-operative Societies, they would be entitled to the exemption under Section 194A(3)(iii) (v), whenever the income credited to their account is the interest income that arises from the deposits made by them with another Co-operative Society such as the District Co-operative Bank. In view of the said stand taken by the revenue in these writ petitions, the entitlement of the petitioners to the WP(C).No.7795 OF 2019 & CONNECTED CASES 154 benefit of the exemption under 194A(3)(iii)(v) is found in their favour and the writ petitions that impugn the circulars issued by the various District Co- operative Banks based on the instructions of the Income Tax Department are hereby quashed. 4. As regards the contention of the petitioners with regard to the entitlement to the exemption under 194A(3)(iii)(a), I find that the exemption from the requirement of deducting tax at source is available inter alia only to income credited or paid to any banking company to which the Bank Regulation Act 1949 applies, or to income credited or paid to any co-operative Society engaged in carrying on the business of banking (including a co- operative land mortgage bank). It is the contention of the learned counsel for the petitioners that the phrase 'any co-operative society engaged in carrying on the business of banking’ should be interpreted by considering the normal commercial meaning of the words “business of banking” and when so considered, it would refer to the activities of accepting deposits, lending money and providing the facilities of withdrawing money using Cheques, Demand Drafts etc, that the petitioner societies are offering to their members. It is in particular pointed out that the statutory provisions make a conscious distinction between a banking company to which the Banking Regulation Act 1949 applies, and a Co-operative Society engaged in the business of banking, and that while dealing with the latter, there is no reference to the Banking Regulation Act 1949. It is the further contention of learned counsel for the petitioners that, at any rate, the provisions of the Banking Regulation Act do not apply to Primary Agricultural Credit Societies by virtue of Section 3 of the Banking Regulation Act 1949, and hence, the definition of banking under the said Act cannot be of any relevance to decide the entitlement of the petitioner WP(C).No.7795 OF 2019 & CONNECTED CASES 155 societies to the benefit of exemption under section 194A(3)(iii)(a) of the Income Tax Act. 5. Per contra, it is the submission of the learned Standing Counsel for the respondent Income Tax Department that the meaning to be given to the term banking under Section 194A(3)(iii)(a) has necessarily to be in line with the definition of banking under the Banking Regulation Act, since the said definition is the one that is contained in a statute that regulates the business of banking in the country. It is stated that when there is no definition of the word banking under the Income Tax Act, one has to rely either on the dictionary meaning of the term or on the definition of the term as contained in the relevant regulatory statutes and on such interpretation, the petitioner societies cannot be seen as carrying on the business of banking. Reference is also made to the decision of the Bombay High Court in The Hooseini co-operative credit.. v. Assessee [(2015) 377 ITR 272] to suggest that even if the bye-laws of the petitioner societies permit them to accept deposits from persons other than members, the society cannot be categorized as a society engaged in carrying on the business of banking so long as the bye laws of the society do not provide for banking business as the primary object to be pursued by the society. 6. I have heard the learned counsel Dr. K.P . Pradeep, Sri.T.R. Harikumar, Sri. C.A Jojo, Sri. B. Suresh Kumar, Sri. Jayapradeep V , Sri.Shaji Thomas, Smt. S.K Devi, Sri. V .P Narayanan, Sri. M.Sasindran, Sri. P .C. Sasidharan, Sri. C.S Sumesh, Sri. G.Biju, Sri. G.Rajeev, Sri.Vinod Kumar. C, Sri. Harishankar V . Menon, Sri. O.D Sivadas, Sri. A.Kumar, Sri. Anil.D.Nair, Sri. S.Arun Raj,Sri. S. Abhilash Vishnu and Sri.Nikhil Sunny Mooken WP(C).No.7795 OF 2019 & CONNECTED CASES 156 appearing for the petitioners and also Sri. Christopher Abraham, the learned Standing Counsel appearing for the respondents. 7. On a consideration of the facts and circumstances of the case as also the submissions made across the Bar, I find that Section 194A(3)(iii)(a), uses the phrase “Co-operative Society engaged in carrying on the business of banking (including a co-operative land mortgage bank)” to qualify a Co- operative Society that is entitled for the benefit of exemption from the requirement of tax deduction at source, when it receives income by way of interest income on deposits made by them with the State Treasury. Under the Banking Regulation Act, the word banking is defined as the meaning the accepting, for the purpose of lending or investment, of deposits of money from the public, repayable on demand or otherwise, and withdrawn by cheque, draft, order or otherwise. Section 3 of the said Act which deals with “The application of the Act to Co-operative Societies in certain cases” indicates that the Act will not apply to; (a) a primary agricultural credit society; (b) a co-operative land mortgage bank; (c) any other co-operative society except in the manner and the extent specified in part V . 8. Part V of the Banking Regulation Act comprises of Section 56 which deals with the circumstances, when the Act will apply to Co-operative Societies subject to modifications. The said Part also defines the terms “Co- operative Credit Society,” “Primary Agricultural Credit Society”, “Primary Credit Society” and “Primary Co-operative Bank”. It can be seen from a WP(C).No.7795 OF 2019 & CONNECTED CASES 157 comparison of the definitions referred above that there is a distinction made between societies, the primary object and principal business of which is to provide financial accommodation to its members in connection with various activities, and those societies, the primary object and principal business of which, is the transaction of banking business. When viewed against the back drop of the definition of banking noticed above, it is apparent that it is the criteria of accepting deposits of money from the public, as opposed to members of the society, that serves to categorize a Co-operative Society as one engaged in the business of banking. In my view, in the absence of a definition of “banking” under the Income Tax Act, it would be safe for this Court to adopt the definition of “banking” as contained in the statute that regulates the business of banking in our Country, for the purpose of interpreting the word “banking” and the phrase “business of banking” under the Income Tax Act. On such an interpretation, the benefit of exemption under Section 194A(3)(iii)(a) would apply only when the interest income in respect of deposit made with the treasury accrues/arises to a co-operative society engaged in carrying on the business of banking, which in turn involves acceptance of deposits from the public, and not merely from its own members. In the instant writ petitions, there is no material that would suggest that the writ petitioner societies are engaged in carrying on a business that involves accepting deposits, for the purposes of investment or lending, from public as opposed to their own members. I therefore, find that in respect of the interest income earned on deposits made by the petitioners societies with the Treasury, the circulars issued by the Treasury department, based on like instructions received from the Income Tax Department, directing the deduction of tax at source on such interest income payments, cannot be legally faulted. The challenge in the writ petitions to the said WP(C).No.7795 OF 2019 & CONNECTED CASES 158 circular issued by the Treasury Department is therefore rejected. Before parting with these cases, it must be pointed out that, in as much as the provisions of Section 194A(3)(iii)(a) provide for an exemption from a procedural requirement under the Income Tax, the interpretation to be placed on the said provision has necessarily to be a strict one that leans in favour of the revenue and against the assessee. At any rate, the requirement of deduction of tax at source does not prejudice the writ petitioner assessees, since the tax amounts deducted at source from the payments effected to the petitioner societies would be credited to their account with the Income Tax Department, and adjusted towards any tax liability determined against them in their assessment for the respective years. In the event the petitioner societies succeed in establishing before the Income Tax authorities that they do not have any income liable to tax under the Act, then they would be entitled to a refund of the tax amounts so deducted pursuant to a finalization of their assessments under the Income Tax Act. Alternatively, the petitioners societies also have the option of approaching the Income Tax Department for a certificate under Section 197 of the Income Tax Act. Stating that, in view of their non-liability to tax under the Act, there need be no deduction of tax effected at the time of making payments to them. This aspect has been made clear in the circular of the Treasury department impugned in these writ petitions. In the result, these writ petitions are disposed by declaring that, in the case of deposits made by the petitioner societies with the Co-operative Banks, they would be entitled to the benefit of exemption under Section 194A(3)(iii)(v) of the Income Tax Act and, in respect of the deposits made by WP(C).No.7795 OF 2019 & CONNECTED CASES 159 the petitioner societies with the Treasury, they will not be entitled to the benefit of exemption under Section 194A(3)(iii)(a) of the Income Tax Act. The legality of the circulars and notices impugned in these writ petitions shall stand determined on the basis of the above declarations. Sd/- A.K.JAYASANKARAN NAMBIAR JUDGE SJ WP(C).No.7795 OF 2019 & CONNECTED CASES 160 APPENDIX OF WP(C) 7795/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE ORDER DATED 25/10/2018 IN ITA NO.420/COCH/2018 OF THE INCOME TAX APPELLATE TRIBUNAL, KOZHI EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.45/2018-19 DATED 12-02-2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P3 TRUE COPY OF THE ORDER DATED 31/10/2016 IN ITA NO.279/COCH/2016 ISSUED BY THE LEARNED CINCOME TAX APPELLATE TRIBUNAL, KOCHI. EXHIBIT P4 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5/12/2018 WP(C).No.7795 OF 2019 & CONNECTED CASES 161 APPENDIX OF WP(C) 10094/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO. CA/6628 DATED 19.01.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 05/12/2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO. ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26/12/2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 162 APPENDIX OF WP(C) 10096/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19.01.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO. 58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO.ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018- 19/90 DATED 26-12-2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 163 APPENDIX OF WP(C) 10101/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE ORDER DATED 25.10.2018 IN ITA NO 420/CCH/2018 OF THE INCOME TAX APPELATE TRIBUNAL, KOCHI BENCH EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO. 45/2018-19 DATED 12.02.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P3 TRUE COPY OF THE ORDER DATED 31.10.2016 IN ITA NO. 279/COCH/2016 ISSUED BY THE LEARNED INCOME TAX APPELLATE TRIBUNAL, KOCHI EXHIBIT P4 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 05.12.2018 ISSUED BY THE 5TH RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 164 APPENDIX OF WP(C) 10105/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19.01.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO. 58/2018 DATED 05/12/2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26/12/2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 165 APPENDIX OF WP(C) 10474/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE COMMON LETTER DATED 14.01.20196 ISSUED TO PETITIONER BANK, ALONG WITH ITS ENGLISH VERSION EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26.12.2018 ISSUED BY THE 2ND RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.40/2018-19 DATED 14.02.2019 ISSUED BY THE KOTTAYAM DISTRICT CO-OEPRATIVE BANK, ALONG WITH ITS ENGLISH VERSION. EXHIBIT P4 TRUE COPY OF THE LETTER DATED 31.01.2019 ISSUED BY 1ST RESPONDENT TO THE KOTTAYAM DISTRICT CO-OEPRATIVE BANK EXHIBIT P5 TRUE COPY OF THE ORDER DATED 29.01.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO. 596/COCH/2017 EXHIBIT P6 TRUE COPY OF THE ORDER DATED 25.10.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO.420/COCH/2018 WP(C).No.7795 OF 2019 & CONNECTED CASES 166 APPENDIX OF WP(C) 10479/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 1ST RESPONDENT DATED 26.12.2018. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO.40/2018-19 DATED 14.02.2019 ISSUED BY 6TH RESPONDENT DATED 14.02.2019 ALONG WITH ENGLISH TRANSLATION. EXHIBIT P3 A TRUE COPY OF THE LETTER ISSUED BY 3RD RESPONDENT TO THE 1ST PETITIONER DATED 05.12.2019 ALONG WITH ENGLISH TRANSLATION. EXHIBIT P4 A TRUE COPY OF THE LETTER ISSUED BY 7TH RESPONDENT TO THE 3RD PETITIONER AS NO.CA/9855 DATED 02.03.2019 ALONG WITH ENGLISH TRANSLATION. WP(C).No.7795 OF 2019 & CONNECTED CASES 167 APPENDIX OF WP(C) 10782/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/9855 DATED 02-03-2019 WITH ENGLISH TRANSLATION ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WITH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE ORDER DATED 31.10.2016 IN ITA NO.279/COCH/2016 ISSUED BY THE LEARNED INCOME TAX APPELLATE TRIBUNAL, KOCHI. WP(C).No.7795 OF 2019 & CONNECTED CASES 168 APPENDIX OF WP(C) 11301/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CERTIFICATE OF REGISTRATION NO.E.17/2013 DATED 14.2.2013 GRANTED BY THE ASSISTANT REGISTRAR(GENERAL), NEDUMANGAD, UNDER THE KERALA CO-OPERATIVE SOCIETIES ACT EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION RECEIVED FROM THE NEDUMANGAD MAIN BRANCH OF THE 4TH RESPONDENT BANK, ALONG WITH ITS ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.45/2108- 19 DATED 12.02.2019 ISSUED BY THE 4TH RESPONDENT BANK ALONG WITH ITS ENGLISH TRANSLATION EXHIBIT P4 TRUE COPY OF THE CIRCULAR DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT ALONG WITH ITS ENGLISH TRANSLATION EXHIBIT P5 TRUE COPY OF THE ORDER DATED 12.03.2019 IN ITA.NO.49/COCH/2019 OF THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN WP(C).No.7795 OF 2019 & CONNECTED CASES 169 APPENDIX OF WP(C) 11420/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19.1.2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F.NO.ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018- 19/90 DATED 26.12.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 170 APPENDIX OF WP(C) 11438/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR ISSUED BY 3RD RESPONDENT DATED 26.12.2018 EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 05.12.2018 ISSUED BY 1ST RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE LETTER SUBMITTED TO THE 2ND RESPONDENT BY THE PETITIONER DATED 11.03.2019 ALONG WITH ENGLISH TRANSLATION EXHIBIT P4 TRUE COPY OF THE REPLY ISSUED BY 2ND RESPONDENT TO THE PETITIONER IN NO.SBI/2019 DATED 22.03.2019 EXHIBIT P5 TRUE COPY OF THE LETTER ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER DATED 27.03.2019 EXHIBIT P6 TRUE COPY OF THE LETTER ISSUED BY THE PETITIONER TO THE 2ND RESPONDENT DATED 28.03.2019 EXHIBIT P7 TRUE COPY OF THE JUDGMENT OF THE HON'BLE HIGH COURT IN WP(C) NO. 13047/ OF 2009 WP(C).No.7795 OF 2019 & CONNECTED CASES 171 APPENDIX OF WP(C) 11507/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 3RD RESPONDENT DATED 26.12.2018. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO. 58/2018 DATED 08.12.2018 ISSUED BY 1ST RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P3 A TRUE COPY OF THE LETTER SUBMITTED TO THE 2ND RESPONDENT BY THE PETITIONER DATED 01.03.2019. EXHIBIT P4 A TRUE COPY OF THE FORM NO. 15 G SUBMITTED TO THE 2ND RESPONDENT BY THE PETITIONER DATED 02.03.2019 ALONG WITH ENGLISH TRANSLATION. EXHIBIT P5 A TRUE COPY OF THE REPLY NOTICE ISSUED BY 2ND RESPONDENT TO THE PETITIONER AS NO. A1/45/2019 DATED 21.O3.2019 ALONG WITH ENGLISH TRANSLATION. EXHIBIT P6 A TRUE COPY OF THE LETTER SUBMITTED TO THE 2ND RESPONDENT BY THE PETITIONER DATED 28.03.2019. EXHIBIT P7 A TRUE COPY OF THE TAX WITHDRAWAL CHALLAN FOR RS. 42,500/- DATED 28.03.2019 SIGNED BY THE 2ND RESPONDENT . EXHIBIT P8 A TRUE COPY OF THE JUDGMENT OF THE HON'BLE HIGH COURT IN W.P.(C) NO. 13047 OF 2009 DATED 08.12.2014. WP(C).No.7795 OF 2019 & CONNECTED CASES 172 APPENDIX OF WP(C) 11895/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 4TH RESPONDENT DATED 26.12.2018. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 8.12.2018 ISSUED BY 1ST RESPONDENT ALONG WITH ENGLISH TRANSLATION. EXHIBIT P3 A TRUE COPY OF THE RELEVANT PAGES OF THE TSB PASSBOOK OF THE PETITIONER. EXHIBIT P4 A TRUE COPY OF THE JUDGMENT OF THE HON'BLE HIGH COURT IN WPC.NO.13047 OF 2009. WP(C).No.7795 OF 2019 & CONNECTED CASES 173 APPENDIX OF WP(C) 12270/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 2ND RESPONDENT DATED 26.12.2018. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO.F.NO.CR- 35/CIT(TDS)/2018-19/8 DATED 31.01.2019 ISSUED BY 3RD RESPONDENT TO THE 10TH RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 05.12.2018 ISSUED BY 4TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P4 A TRUE COPY OF THE LETTER DATED 03.04.2019 ISSUED BY 10TH RESPONDENT TO THE PETITIONERS WITH ENGLISH TRANSLATION. WP(C).No.7795 OF 2019 & CONNECTED CASES 174 APPENDIX OF WP(C) 12271/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 2ND RESPONDENT DATED 26.12.2018. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO.F.NO.CR- 35/CIT(TDS)/2018-19/8 DATED 31.1.2019 ISSUED BY 3RD RESPONDENT TO THE 10TH RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE CIRCULAR NO.58/2018 DATTED 8.12.2018 ISSUED BY IST RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P4 A RUE COPY OF THE LETTER DATED 3.4.2019 ISSUED BY 10TH RESPONDENT TO THE PETITIONERS WITH ENGLISH TRANSLATION. WP(C).No.7795 OF 2019 & CONNECTED CASES 175 APPENDIX OF WP(C) 12352/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 10.11.2017, ISSUED BY THE ASSISTANT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), NEDUMANGADU. EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 18.2.2019 ISSUED BY THE VENJARAMOODU BRANCH OF THE 5TH RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE CIRCULAR F NO.ADDL.CIT/TDS/TVM/CO-OP SOCIETY/2018-19 DATED 26.12.2018 ISSUED BY THE IST RESPONDENT. EXHIBIT P4 A TRUE COPY OF THE INTERIM ORDER IN WPC NO.9274/2019 DATED 26.3.2019 ISSUED BY THIS HON'BLE COURT. WP(C).No.7795 OF 2019 & CONNECTED CASES 176 APPENDIX OF WP(C) 12403/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 5.12.2018 ISSUED BY THE ASSISTANT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL)NEDUMANGADU EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 18.2.2019 ISSUED BY THE VENJARAMOODU BRANCH OF THE 5TH RESPONDENT EXHIBIT P3 A TRUE COPY OF THE CIRCULAR F NO ADDL CIT/TDS/ TVM/CO-OP SOCIETY/2018-19 DATED 26.12.2018 ISSUED BY THE 1ST RESPONDENT EXHIBIT P4 A TRUE COPY OF THE INTERIM ORDER IN WPC NO 9274/2019 DATED 26.3.2019 ISSUED BY THIS HON'BLE COURT WP(C).No.7795 OF 2019 & CONNECTED CASES 177 APPENDIX OF WP(C) 12407/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 2ND RESPONDENT DATED 26.12.2018 EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO F.NO CR- 35/CIT(TDS)/2018-19/8 DATED 31.1.2019 ISSUED BY 3RD RESPONDENT TO THE 10TH RESPONDENT EXHIBIT P3 A TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 8.12.2018 ISSUED BY 1ST RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P4 A TRUE COPY OF THE CIRCULAR NO 23/2019 DATED 2.4.2019 ISSUED BY 6TH RESPONDENT TO THE PETITIONERS WITH ENGLISH TRANSLATION EXHIBIT P5 A TRUE COPY OF THE JUDGMENT OF THE HON'BLE HIGH COURT IN WPC NO 13047 OF 2009 DATED 8.12.2014 WP(C).No.7795 OF 2019 & CONNECTED CASES 178 APPENDIX OF WP(C) 12453/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE LETTER DATED 02.04.2019 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK PROPOSING TO LEVY TDS FROM DEPOSITS. WP(C).No.7795 OF 2019 & CONNECTED CASES 179 APPENDIX OF WP(C) 12498/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 13.12.2016, ISSUED BY THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR F NO. ADDL. CIT/TDS/TVM/CO-OP SOCIETY/2018-19 DATED 26.12.2018 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE INTERIM ORDER IN WP(C) NO. 11176/2019 DATED 09.04.2019 ISSUED BY THIS HON'BLE COURT. WP(C).No.7795 OF 2019 & CONNECTED CASES 180 APPENDIX OF WP(C) 12547/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.45/2018-19 DATED 12/02/2019 ISSUED BY THE 4TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5/12/2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER DATED 22/3/2019 IN WP(C) NO.8972 OF 2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 181 APPENDIX OF WP(C) 12582/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 12/04/2018, ISSUED BY THE ASSISTANT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), NEDUMANGADU. EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 20/03/2019 ISSUED BY THE NEDUMAGADU M AND E BRANCH OF THE 5TH RESPONDENT EXHIBIT P3 A TRUE COPY OF THE CIRCULAR F NO.ADDL.CIT/TDS/TVM/CO-OP SOCIETY/2018-19 DATED 26/12/2018 ISSUED BY THE 1ST RESPONDENT EXHIBIT P4 A TRUE COPY OF THE INTERIM ORDER IN WP(C)NO.11176/2019 DATED 09/04/2019 ISSUED BY THIS HON'BLE COURT. WP(C).No.7795 OF 2019 & CONNECTED CASES 182 APPENDIX OF WP(C) 12696/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 4TH RESPONDENT DATED 26-12-2018 EXHIBIT P2 A COPY OF THE E-MAIL ISSUED BY 3RD RESPONDENT DATED 30-03-2019 TO THE PETITIONER. EXHIBIT P3 A TRUE COPY OF THE LETTER DATED 30-03-2019 TO THE 3RD RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P4 A TRUE COPY OF THE LETTER DATED 02-04-2019 TO THE 3RD RESPONDENT EXHIBIT P5 A TRUE COPY OF THE E-MAIL LETTER SENT BY 2ND RESPONDENT TO THE PETITIONER DATED 18- 04-2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 183 APPENDIX OF WP(C) 12709/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE COMMON LETTER DATED 14.01.2019 ISSUED TO PETITIONER BANK, ALONG WITH ITS ENGLISH VERSION. EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26.12.2018 ISSUED BY THE 2ND RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.40/2018-19 DATED 14/2/2019 ISSUED BY THE KOTTAYAM DISTRICT CO-OPERATIVE BANK, ALONG WITH ITS ENGLISH VERSION. EXHIBIT P4 TRUE COPY OF THE LETTER DATED 31.1.2019 ISSUED BY THE 1ST RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK. EXHIBIT P5 TRUE COPY OF THE ORDER DATED 29.1.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO.596/COCH/2017 EXHIBIT P6 TRUE COPY O THE ORDER DATED 25.10.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO.420/COCH/2018. WP(C).No.7795 OF 2019 & CONNECTED CASES 184 APPENDIX OF WP(C) 12758/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE JUDGMENT IN APPEAL ITA 187/EF/KLM EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO. 45/2018-19 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE CIRCULAR NO. 58/2018 DATED 05-12-2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P4 A TRUE COPY OF THE CIRCULAR F.NO. ADDL. CIT/TDS/TVM CO-OP, SOCIETY 2018-19 DATED 26-12-2018 ISSUED BY THE OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX THIRUVANANTHAPURAM. EXHIBIT P5 A TRUE COPY OF THE LETTERS DATED 18-02-2019 ISSUED BY THE BRANCH MANAGER OF VENJARAMOODU BRANCH OF THE 4TH RESPONDENT. EXHIBIT P6 A TRUE COPY OF THE LETTER DATD 25-02-2019 ISSUED BY THE BRANCH MANAGER OF KARATE BRANCH OF THE DISTRICT CO-OPERATIVE BANK. EXHIBIT P7 A TRUE COPY OF THE INTERIM ORDER DATED 26- 03-2018 IN W.P(C) 9274/2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 185 APPENDIX OF WP(C) 12828/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CLASSIFICATION ORDER ISSUED BY THE JOINT REGISTRAR OF CO- OPERATIVE SOCIETY, MALAPPURAM. EXHIBIT P2 TRUE COPY OF THE PROCEEDINGS DATED 03-04- 2019 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 5-12-2018 ISSUED BY THE 6TH RESPONDENT EXHIBIT P4 TRUE COPY OF THE PROCEEDINGS F NO CR- 35/CIT/TDS/2018-19/8 DATED 31-01-2019 ISSUED BY THE 2ND RESPONDENT TO THE 5TH RESPONDENT EXHIBIT P5 TRUE COPY OF THE INTERIM ORDER DATED 26/03/2019 IN W.P(C) NO. 9274 OF 2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 186 APPENDIX OF WP(C) 12900/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 5TH RESPONDENT DATED 26.12.2018 EXHIBIT P2 A COPY OF THE E-MAIL ISSUED BY 2ND RESPONDENT DATED 18.04.2019 TO THE PETITIONER EXHIBIT P3 A TRUE COPY OF THE CIRCULAR NO.45/2018-19 DATED 12.02.2019 BY THE 3RD RESPONDENT TO THE PETITIONER WITH ENGLISH TRANSLATION. WP(C).No.7795 OF 2019 & CONNECTED CASES 187 APPENDIX OF WP(C) 13062/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO 45/2018-19 DATED 12-02-2019 ISSUED BY THE 4TH RESPONDENT ENGLISH TRANSLATION. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 5-12-2018 ISSUED BY THE 6TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER DATED 22-3- 2019 IN WP(C) NO. 8972 OF 2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 188 APPENDIX OF WP(C) 13412/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE COMMUNICATION DATED 31.01.2019. EXHIBIT P2 TRUE COPY OF THE COMMUNICATION DATED 14.01.2019 ISSUED BY THE 2ND RESPONDENT ALONG WITH TRUE ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER DATED 22.03.2019 OF THIS HON'BLE COURT IN WP(C)NO.8938/2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 189 APPENDIX OF WP(C) 13546/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 COPY OF CERTIFICATE DATED 16.01.2015 ISSUED BY ASSISTANT REGISTRAR(GENERAL0 CO- OPERATIVE SOCIETIES, NEDUMANGAD, REGARDING THE WORKING CATEGORY OF PETITIONER EXHIBIT P2 COPY OF CIRCULAR NO.45/2018-19 DATED 12/2/19 ISSUED BY THE 4THR RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 LETER DATED 16/02/2019 ISSUED BY THE 4TH RESPONDENT BANK REGARDING THE EDUCATION OF TDS ON THE INTEREST INCOME OF PETITIONERS ISSUED FROM KOLLARA BRANCH FORM 2016-17 TO 2018-19 WITH ENGLISH TRANSLATION EXHIBIT P4 COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P5 COPY OF ORDER DATED 31/10/2016 IN ITA NO.279/COCH/2016 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, KOCHI WP(C).No.7795 OF 2019 & CONNECTED CASES 190 APPENDIX OF WP(C) 13695/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO. CA/6628 DATED 19/01/2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO. 58/2018 DATED 5.12.2018 ISSUED BY THE 6TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER DATED 22.3.2019 IN WPC NO. 8972 OF 2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 191 APPENDIX OF WP(C) 13726/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.45/2018-19 DATED 12.02.2019 ISSUED BY THE 4TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 6TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER DATED 22.3.2019 IN WP(C)NO.8972 OF 2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 192 APPENDIX OF WP(C) 13826/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR F.NO.CR- 35/CIT)TDS0/2018-19/8 ISSUED BY 2ND RESPONDENT DATED 31.01.2019 EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO.23/2019 DATED 02.04.2019 ISSUED BY 3RD RESPONDENT TO THE PETITIONER WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 05.12.2018 ISSUED BY 4TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P4 A TRUE COPY OF THE STAY ORDER OF THE HON'BLE COURT IN WP(C) NO.12407 OF 2019 DATED 17.04.2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 193 APPENDIX OF WP(C) 13945/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE LETTER DATED 12.04.2019 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK PROPOSING TO LEVY TDS FROM DEPOSITS WP(C).No.7795 OF 2019 & CONNECTED CASES 194 APPENDIX OF WP(C) 13946/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 THE COPY OF THE LETTER DATED 04.04.2019 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK PROPOSING TO LEVY TDS FROM DEPOSITS. WP(C).No.7795 OF 2019 & CONNECTED CASES 195 APPENDIX OF WP(C) 14895/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE ORDER OF ITAT IN ITA NO. 279/COCH/2016 DATED 31.10.2016. EXHIBIT P2 TRUE COPY OF THE CIRCULAR DATED 5.12.2018. EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER PASSED BY THIS HON'BLE COURT IN WP(C) NO. 9245/2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 196 APPENDIX OF WP(C) 15165/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE LETTER DATED 12.04.2019 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK PROPOSING TO LEVY TDS FROM DEPOSITS. WP(C).No.7795 OF 2019 & CONNECTED CASES 197 APPENDIX OF WP(C) 15691/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE COMMON LETTER DATED 14.1.20-19 ISSUED TO PETITIONER BANK ALONG WITH ITS ENGLISH VERSION. EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26.12.2018 ISSUED BY THE 2ND RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK. EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO. 40/2018-19 DATED 14.2.2019 ISSUED BY THE KOTTAYAM DISTRICT CO-OPERATIVE BANK,. ALONG WITH ITS ENGLISH VERSION. EXHIBIT P4 TRUE COPY OF THE LETTER DATED 31.1.2019 ISSUED BY THE 1ST RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK. EXHIBIT P5 TRUE COPY OF THE ORDER DATED 29.1.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITS NO. 596/COCH/2017 EXHIBIT P6 TRUE COPY OF THE ORDER DATED 25.10.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO. 420/COCH/2018 WP(C).No.7795 OF 2019 & CONNECTED CASES 198 APPENDIX OF WP(C) 15693/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CERTIFICATE DATED 03.03.2015 ISSUED BY THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES(GENERAL), THIRUVANANTHAPURAM. EXHIBIT P2 TRUE COPY OF CIRCULAR NO.45/2018-19 DATED 12.2.2019 ISSUED BY THE 3RD RESPONDENT WITH ITS ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF CIRCULAR DATED 5.12.2018 ISSUED BY THE DIRECTOR OF TREASURIES WITH ITS ENGLISH TRANSLATION. EXHIBIT P4 TRUE COPY OF COMMUNICATION DATED 26.12.2018 ISSUED BY THE 2ND RESPONDENT. EXHIBIT P5 TRUE COPY OF ORDER DATED 12.03.2019 IN ITA NO.49/COCH/2014 OF THE INCOME TAX APPELLATE TRIBUNAL. EXHIBIT P6 TRUE COPY OF INTERIM ORDER IN WPC NO.9578/2019 DATED28.3.2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 199 APPENDIX OF WP(C) 16128/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE ORDER APPEAL ITA 187/EF/KLM. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.45/2018-19 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.58/2018 05.12.2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P4 TRUE COPY OF THE CIRCULAR NO.F.NO.ADDL.CIT/TDS/TVM CO-OP. SOCIETY 2018-19 DATED 26.12.2018 ISSUED BY THE OFFICER OF THE ADDITIONAL COMMISSION OF INCOME TAX THIRUVANANTHAPURAM. EXHIBIT P5 TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. EXHIBIT P6 TRUE COPY OF THE INTERIM ORDER DATED 26.04.2019 IN W.P.(C)12758/2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 200 APPENDIX OF WP(C) 17027/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 07.01.2015 ISSUED BY THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), KOLLAM EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 22.02.2019 ISSUED BY THE 5TH RESPONDENT EXHIBIT P3 A TRUE COPY OF THE CIRCULAR F NO.ADDL.CIT/TDS/TVM/CO-OP SOCIETY/2018-19 DATED 26.12.2018 ISSUED BY THE 1ST RESPONDENT EXHIBIT P4 A TRUE COPY OF THE INTERIM ORDER IN WP(C) NO.9274/2019 DATED 26.03.2019 ISSUED BY THIS HON'BLE COURT WP(C).No.7795 OF 2019 & CONNECTED CASES 201 APPENDIX OF WP(C) 17706/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE LETTER DATED 18.04.2019 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK PROPOSING TO LEVY TDS FROM DEPOSITS WITH TRANSLATIONS. EXHIBIT P2 TRUE COPY OF THE LETTER DATED 18.01.2019 ISSUED BY THE STATE CO-OPERATIVE BANK MALAPPURAM PROPOSING TO LEVY TDS FROM DEPOSITS. WP(C).No.7795 OF 2019 & CONNECTED CASES 202 APPENDIX OF WP(C) 18895/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE LETTER DATED 4.4.2019 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK. PERINTHALMANNA BRANCH PROPOSING TO LEVY TDS FROM DEPOSITS EXHIBIT P2 TRUE COPY OF THE LETTER DATED 25.4.2019 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK, ANGADIPPURAM BRANCH PROPOSING TO LEVY TDS FROM DEPOSITS WP(C).No.7795 OF 2019 & CONNECTED CASES 203 APPENDIX OF WP(C) 19676/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 13.11.2017, ISSUED BY THE ASSISTANT REGISTRAR OF CO-OPERATIVE SOCIETIES, (GENERAL) THIRUVANANTHAPURAM EXHIBIT P2 A TRUE COPY OF THE CIRCULAR F NO ADDL CIT/TDS/ TVM/CO-OP SOCIETY/20-18-19 DATED 26.12.2018 ISSUED BY THE 1ST RESPONDENT EXHIBIT P3 A TRUE COPY OF THE ORDER IN ITA NO 279/COCH/2016 DATED 31.10.2016 OF THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH EXHIBIT P4 A TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT ALONG WITH ENGLISH TRANSLATION EXHIBIT P5 A TRUE COPY OF THE INTERIM ORDER IN WPC NO 11176/2019 DATED 9.4.2019 ISSUED BY THIS HON'BLE COURT WP(C).No.7795 OF 2019 & CONNECTED CASES 204 APPENDIX OF WP(C) 19797/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF CIRCULAR DATED 05-12-2018 EXHIBIT P2 TRUE COPY OF ORDER DATED 12-03-2019 IN ITA NO 49/COCH/2014 EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER PASSED IN WP 11301/2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 205 APPENDIX OF WP(C) 23879/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.45/2018-19 DATED 12.02.2019 ISSUED BY THE 4TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE INTERIM ORDER DATED 22.3.2019 IN WP(c)NO.8928 OF 2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 206 APPENDIX OF WP(C) 30654/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 22.12.2015, ISSUED BY THE ASSISTANT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), CHIRAYINKEEZHU. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR DATED 30.12.2006 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE G.O(ORD)7618/2014/FIN DATED 8.10.2014. EXHIBIT P4 A TRUE COPY OF THE COMMUNICATION ISSUED BY THE 4TH RESPONDENT DATED 1.11.2014. EXHIBIT P5 A TRUE COPY OF THE ORDER IN ITA NO.279/COCH/2016 DATED 31.10.2016 OF THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH. EXHIBIT P6 A TRUE COPY OF THE DIVISION BENCH JUDGMENT OF THE ALLAHABAD HIGH COURT DATED 7.11.2012 IN INCOME TAX APPEAL NO.429 OF 2009, TITLED AS 'COMMISSIONER OF INCOME TAX AND ANR VS M/S. GULSHAN MERCANTILE URBAN CO-OPERATIVE BANK LTD. EXHIBIT P7 A TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P8 A TRUE COPY OF THE INTERIM ORDER IN WP(C) NO.19676 OF 2019 DATED 18.7.2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 207 APPENDIX OF WP(C) 6843/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE INCOME TAX RETURN ACKNOWLEDGMENT DATED 13/04/2017 FOR THE A.Y.2016-17. EXHIBIT P1 A TRUE COPY OF THE INCOME TAX RETURN ACKNOWLEDGMENT DATED 31/03/2018 FOR THE A.Y.2017-18. EXHIBIT P1 B TRUE COPY OF THE INCOME TAX RETURN ACKNOWLEDGMENT DATED 02/11/2018 FOR THE A.Y.2018-19. EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26/12/2018 ISSUED TO THE 2ND RESPONDENT. EXHIBIT P3 TRUE COPY OF THE LETTER DATED 15/02/2019 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. EXHIBIT P3 A TRANSLATED COPY OF EXHIBIT P3 LETTER DATED 15/02/2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 208 APPENDIX OF WP(C) 8507/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE LETTER DATED 14-1-2019 ISSUED TO THE PETITIONER BY THE 6TH RESPONDENT WHICH WAS SERVED ON THE PETITIONER EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26-12-2018 ISSUED BY THE 2ND RESPONDENT TO THE 6TH RESPONDENT EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO. 40/2018-19 DATED 14-2-2019 ISSUED BY THE 6TH RESPONDENT WHICH WAS SERVED ON THE PETITIONER. EXHIBIT P4 TRUE COPY OF THE LETTER DATED 31-1-2019 ISSUED TO THE 6TH RESPONDENT BY THE 1ST RESPONDENT EXHIBIT P5 TRUE COPY OF THE ORDER DATED 29-1-2018 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH,COCHIN IN ITA NO. 596/COCH/2017. EXHIBIT P6 TRUE COPY OF THE ORDER DATED 25-2-2018 IN ITA NO.420/COCH/2018 OF THE INCOME TAX APPELLATE TRIBUNAL, COCHIN BENCH, COCHIN WP(C).No.7795 OF 2019 & CONNECTED CASES 209 APPENDIX OF WP(C) 8724/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.40/2018-19 DATED 14.02.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26.12.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT EXHIBIT P4 TRUE COPY OF THE ORDER DATED 31.10.2016 IN ITA NO.279/COCH/2016 ISSUED BY THE LEARNED INCOME TAX APPELLATE TRIBUNAL,KOCHI. WP(C).No.7795 OF 2019 & CONNECTED CASES 210 APPENDIX OF WP(C) 8847/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 1ST RESPONDENT DATED 26-12-2018 EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO. F.NO. CR 35/CIT(TDS)/2018-19/23 DATED 31-01-2019 ISSUED BY 5TH RESPONDENT DATED 26-12-2018 TO THE 7TH RESPONDENT EXHIBIT P3 A TRUE COPY OF THE LETTER ISSUED BY 7TH RESPONDENT DATED NIL TO THE 1ST PETITIONER. WP(C).No.7795 OF 2019 & CONNECTED CASES 211 APPENDIX OF WP(C) 8879/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 1ST RESPONDENT DATED 26.12.2018 TO THE PETITIONER EXHIBIT P2 A TRUE COPY OF THE NOTICE ISSUED BY 6TH RESPONDENT DATED 01.03.2019 TO THE 1ST PETITIONER EXHIBIT P3 A TRUE COPY OF THE OBJECTION DATED 02.03.2019 TO THE 6TH RESPONDENT BY THE 1ST PETITIONER EXHIBIT P4 A TRUE COPY OF THE LETTER ISSUED BY 4TH RESPONDENT TO THE 1ST PETITIONER DATED 01.03.2019 EXHIBIT P5 A TRUE COPY OF THE OBJECTION DATED 06.03.2019 TO THE 3RD RESPONDENT BY THE 1ST PETITIONER EXHIBIT P6 A TRUE COPY OF THE PAY IN SLIP SHOWING DEDUCTED TAX OF RS. 42,500/- DATED 18.03.2019 BY THE 6TH RESPONDENT TO THE 1ST PETITIONER EXHIBIT P7 A TRUE COPY OF THE LETTER ISSUED BY 6TH RESPONDENT BRANCH MANAGER TO THE 2ND PETITIONER DATED 01.03.2019 EXHIBIT P8 A TRUE COPY OF THE NOTICE ISSUED BY 1ST RESPONDENT TO THE 3RD PETITIONER DATED 06.03.2019 WP(C).No.7795 OF 2019 & CONNECTED CASES 212 APPENDIX OF WP(C) 8910/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 COPY OF LETTER ISSUED BY THE 2ND RESPONDENT TO THE 3RD RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 213 APPENDIX OF WP(C) 8919/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 THE TRUE COPY OF THE COMMUNICATION RECEIVED FROM THE NEDUMANGAD MAIN BRANCH OF THE 4TH RESPONDENT BANK EXHIBIT P2 THE TRUE COPY OF THE CIRCULAR NO.45/2018-19 DATED 12.2.2019 ISSUED BY THE HEAD OFFICE OF THE 4TH RESPONDENT BANK EXHIBIT P3 THE TRUE COPY OF THE CIRCULAR DATED 5/12/2018 ISSUED BY THE DIRECTOR OF TREASURIES EXHIBIT P4 THE TRUE COPY OF THE ORDER DATED 31.10.2016 IN ITA NO.279/COCH/2016 ISSUED BY THE LEARNED INCOME TAX APPELLATE TRIBUNAL,KOCHI WP(C).No.7795 OF 2019 & CONNECTED CASES 214 APPENDIX OF WP(C) 8921/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE ORDER DATED 25/10/2018 IN ITA NO.420/COCH/2018 & ITA NO.421/COCH/2018 0F THE INCOME TAX APPELLATE TRIBUNAL,KOCHI BENCH. EXHIBIT P2 A TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 15/12/2018 ISUSED BY THE TREASURY DIRECTOR,DIRECTORATE OF TREASURIES,THIRUVANANTHAPURAM. EXHIBIT P3 A TRUE COPY OF THE COMMUNICATION DATED 06/03/2019 ISSUED TO THE SOCIETY BY THE 3RD RESPONDENT. EXHIBIT P4 A TRUE COPY OF THE COMMUNICATION DATED NIL ISSUED TO THE SOCEITY BY THE QUILON CO- OPERATIVE URBAN BANK LTD WHICH WAS RECEIVED ON 20/03/2019. WP(C).No.7795 OF 2019 & CONNECTED CASES 215 APPENDIX OF WP(C) 8926/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/9855 DATED 02.03.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 216 APPENDIX OF WP(C) 8928/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19.1.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO.ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018- 19/90 DATED 26.12.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 217 APPENDIX OF WP(C) 8946/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19.01.2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO.ADDL/CIT/TDS/TVM/CO-OP.SOCIETY/2018- 19/90 DATED 26.12.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 218 APPENDIX OF WP(C) 8957/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19/01/2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5/12/2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO.ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018- 19/90 DATED 26/12/2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 219 APPENDIX OF WP(C) 8961/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19/01/2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5/12/2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO.ADDL/CT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26/12/2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 220 APPENDIX OF WP(C) 8962/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19.1.2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO.ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018- 19/90 DATED 26.12.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 221 APPENDIX OF WP(C) 8972/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO. Ca/6628 DATED 19-01-2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO. 58/2018 DATED 5-12-2018 ISSUED BY THE 5TH RESPONDENT EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO ADDL./CIT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26-12-2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 222 APPENDIX OF WP(C) 9245/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO 45/2018-19 DATED 12.2.2019 ISSUED BY THE 4TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WITH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE ORDER DATED 31.10.2016 IN ITA NO 279/COCH/2016 ISSUED BY THE LEARNED INCOME TAX, APPELLATE TRIBUNAL, KOCHI. WP(C).No.7795 OF 2019 & CONNECTED CASES 223 APPENDIX OF WP(C) 9272/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO CA/6628 DATED 19-01-2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 5-12-2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION. EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26-12-2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 224 APPENDIX OF WP(C) 9274/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 26-09- 2017, ISSUED BY THE JOINT REGISTRAR IF CO- OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM. EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 18/02/2019 ISSUED BY THE VENJARAMMODE BRANCH OF THE 5TH RESPONDENT ALONG WITH ENGLISH TRANSLATION EXHIBIT P3 A TRUE COPY OF THE COMMUNICATION DATED 25/02/2019 ISSUED BY THE KARETTU BRANCH OF THE 5TH RESPONDENT BANK TO THE PETITIONER ALONG WITH ENGLISH TRANSLATION. EXHIBIT P4 A TRUE COPY OF THE CIRCULAR F NO.ADDL.CIT/TDS/TVM/CO-OP SOCIETY/2018-19 DATED 26/12/2018 ISSUED BY THE 1ST RESPONDENT EXHIBIT P5 A TRUE COPY ONE SUCH INTERIM ORDER IN WP(C) NO.8799/2019 DATED 22/03/2019 ISSUED BY THIS HON'BLE COURT. WP(C).No.7795 OF 2019 & CONNECTED CASES 225 APPENDIX OF WP(C) 9412/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 COPY OF THE ORDER IN FAVOUR OF THE 1ST PETITIONER BY THE APPELLATE AUTHORITY DATED 05.03.2019. EXHIBIT P2 COPY OF THE ORDER IN FAVOUR OF THE 2ND PETITIONER BY THE APPELLATE AUTHORITY DATED 05.03.2019. EXHIBIT P3 COPY OF THE INCOME TAX RETURN OF THE 3RD PETITIONER DATED 24.02.2019. EXHIBIT P4 COPY OF THE CIRCULAR ISSUED BY R4 DATED 19.01.2019. EXHIBIT P5 COPY OF THE ORDER DATED 31.10.2016 IN ITA NO.279/COCH/2016 ISSUED BY THE INCOME TAX APPELLATE TRIBUNAL, KOCHI. EXHIBIT P6 COPY OF THE CIRCULAR NO.58/2018 ISSUED BY R5 DATED 05.12.2018. EXHIBIT P7 COPY OF THE ORDER DATED 14.03.2019 IN WPC NO.7795/19. WP(C).No.7795 OF 2019 & CONNECTED CASES 226 APPENDIX OF WP(C) 9475/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE COMMON LETTER DATED 14.1.2019 ISSUED TO PETITIONER BANKS AND ENGLISH TRANSLATION OF EX.P3 EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26.12.2018 ISSUED BY THE 2ND RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.40/2018-19 DATED 14.2.2019 ISSUED BY THE KOTTAYAM DISTRICT CO-OPERATIVE BANK EXHIBIT P4 TRUE COPY OF THE LETTER DATED 26.12.2018 ISSUED BY THE 2ND RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK EXHIBIT P5 TRUE COPY OF THE ORDER DATED 29.1.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO.596/COCH/2017 EXHIBIT P6 TRUE COPY OF THE ORDER DATED 25.10.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO.420/COCH/2018 WP(C).No.7795 OF 2019 & CONNECTED CASES 227 APPENDIX OF WP(C) 9566/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 06/11/2017 ISSUED BY THE ASSISTANT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 14/02/2019 ISSUED BY THE POTHENKODU BRANCH OF THE 5TH RESPONDENT ALONG WITH ENGLISH TRANSLATION EXHIBIT P3 A TRUE COPY OF THE CIRCULAR F NO.ADDL.CIT/TDS/TV/CO-OP SOCIETY 2018-19 DATED 26/12/2018 ISSUED BU THE 1ST RESPONDENT EXHIBIT P4 A TRUE COPY OF ONE SUCH INTERIM ORDER IN WP(C) NO.9274/2019 DATED 26/03/2019 ISSUED BY THIS HONOURABLE COURT WP(C).No.7795 OF 2019 & CONNECTED CASES 228 APPENDIX OF WP(C) 9620/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE PHOTOCOPY OF THE CIRCULAR NO.40/2018- 19 DATED 14.02.2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE PHOTOCOPY OF THE CIRCULAR NO.58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P3 TRUE PHOTOCOPY OF THE PROCEEDINGS F NO.ADDL/SIT/TDS/TVM/CO-OP SOCIETY/2018- 19/90 DATED 26.12.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. EXHIBIT P4 TRUE PHOTOCOPY OF THE ORDER DATED 31.10.2016 IN ITA NO.279/COCH/2016 ISSUED BY THE LEARNED INCOME TAX APPELLATE TRIBUNAL, KOCHI. EXHIBIT P5 TRUE PHOTOCOPY OF THE INTERIM ORDER IN W.P. (C) NO.8724/2019 DATED 21.03.2019 OF THIS HON'BLE COURT. WP(C).No.7795 OF 2019 & CONNECTED CASES 229 APPENDIX OF WP(C) 9673/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 07-11- 2017, ISSUED BY THE ASSISTANT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM. EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 14/02/2019 ISSUED BY THE POTHENKODU BRANCH OF THE 5TH RESPONDENT ALONG WITH ENGLISH TRANSLATION. EXHIBIT P3 A TRUE COPY OF THE CIRCULAR F NO. ADDL.CIT/TDS/TVM/CO-OP SOCIETY/2018-19 DATED 26/12/2018 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P4 A TRUE COPY OF ONE SUCH INTERIM ORDER IN WP(C) NO. 9274/2019 DATED 26/03/2019 ISSUED BY THIS HON'BLE COURT. WP(C).No.7795 OF 2019 & CONNECTED CASES 230 APPENDIX OF WP(C) 9686/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE LETTER NO.C4-35/CIT(TDS) 2018/10/29 DATED 31/01/2019 ISSUED BY THE 1ST RESPONDENT PROPOSING TO THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26/12/2018 ISSUED BY THE 2ND RESPONDENT PROPOSING TO THE 4TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE LETTER NO.AS/562-A/2018-19 DATED 14/01/2019 ISSUED BY THE 2ND RESPONDENT PROPOSING TO LEVY TDS FROM DEPOSITS WITH TRANSLATION. EXHIBIT P4 THE COPY OF THE CIRCULAR NO.40/2018-19 DATED 14/02/2019 ISSUED BY THE 2ND RESPONDENT WITH TRANSLATION. EXHIBIT P5 THE COPY OF THE PROCEEDING DATED 7/03/2019 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER WITH TRANSLATION. WP(C).No.7795 OF 2019 & CONNECTED CASES 231 APPENDIX OF WP(C) 9764/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE COMMON LETTER DATED 14.01.2019 ISSUED TO PETITIONER BANKS,ALONG WITH ITS ENGLISH VERSION. EXHIBIT P2 TRUE COPY OF THE LETTER DATED 26.12.2018 ISSUED BY THE 2ND RESPONDENT TO THE KOTTAYAM DISTRICT CO-OPERATIVE BANK. EXHIBIT P3 TRUE COPY OF THE CIRCULAR NO.40/2018-19 DATED 14.2.2019 ISSUED BY THE KOTTAYAM DISTRICT CO-OPERATIVE BANK,ALONG WITH ITS ENGLISH VERSION. EXHIBIT P4 TRUE COPY OF THE LETTER DATED 31.1.2019 ISSUED BY THE 1ST RESPONDENT TO THE KOTAYAM DISTRICT CO-OPERATIVE BANK. EXHIBIT P5 TRUE COPY OF THE DATED 29.1.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO.596/C0CH/2017. EXHIBIT P6 TRUE COPY OF THE ORDER DATED 25.10.2018 OF THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH IN ITA NO.420/COCH/2018. WP(C).No.7795 OF 2019 & CONNECTED CASES 232 APPENDIX OF WP(C) 9768/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE PHOTOCOPY OF THE CIRCULAR NO 40/2018- 19 DATED 14.2.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE PHOTOCOPY OF THE CIRCULAR NO 58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT EXHIBIT P3 TRUE PHOTOCOPY OF THE PROCEEDINGS F NO ADDL CIT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26.12.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT EXHIBIT P4 TRUE PHOTOCOPY OF THE ODER DATED 31.10.2016 IN ITA NO 279/COCH/2016 ISSUED BY THE LEARNED INCOME TAX APPELLATE TRIBUNAL, KOCHI EXHIBIT P5 TRUE PHOTOCOPY OF THE INTERIM ORDER IN WPC NO 8724/2019 DATED 21.3.2019 OF THIS HON'BLE COURT WP(C).No.7795 OF 2019 & CONNECTED CASES 233 APPENDIX OF WP(C) 9774/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CIRCULAR ISSUED BY 2ND RESPONDENT DATED 26-12-2018 EXHIBIT P2 A TRUE COPY OF THE LETTER NO. F NO. CR JCIT/(TDS) CHN/ 2018-19/DATED 14-12-2018 ISSUED BY 4TH RESPONDENT TO 7TH RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE CIRCULAR IN MALAYALAM NO. 58/2018 DATED 08-12-2018 WITH ENGLISH TRANSLATION. EXHIBIT P4 A TRUE COPY OF THE LETTER IN MALAYALAM NO. G/808/2019(10) DATED 15-02-2019 ISSUED BY 6TH RESPONDENT TO THE PETITIONER WITH ENGLISH TRANSLATION EXHIBIT P5 A COPY OF THE LETTER NO. G/805/2019 ISSUED BY 6TH RESPONDENT IN MALAYALAM DATED 15-03- 2019 TO THE PETITIONER WITH ENGLISH TRANSLATION. WP(C).No.7795 OF 2019 & CONNECTED CASES 234 APPENDIX OF WP(C) 9820/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO.CA/6628 DATED 19.01.2019 ISSUED BY THE 4TH RESPONDENT. EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO.58/2018 DATED 15.12.2018 ISSUED BY THE 8TH RESPONDENT. EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F.NO.ADDL/CIT/TDS/TVM/CO-OP.SOCIETY/2018-19 DATED 26-12-2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT. WP(C).No.7795 OF 2019 & CONNECTED CASES 235 APPENDIX OF WP(C) 9838/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 TRUE COPY OF THE CIRCULAR NO CA/6628 DATED 19.1.2019 ISSUED BY THE 4TH RESPONDENT EXHIBIT P2 TRUE COPY OF THE CIRCULAR NO 58/2018 DATED 5.12.2018 ISSUED BY THE 5TH RESPONDENT WITH ENGLISH TRANSLATION EXHIBIT P3 TRUE COPY OF THE PROCEEDINGS F NO ADDL/CIT/TDS/TVM/CO-OP SOCIETY/2018-19/90 DATED 26.1`2.2018 ISSUED BY THE 3RD RESPONDENT TO THE 4TH RESPONDENT WP(C).No.7795 OF 2019 & CONNECTED CASES 236 APPENDIX OF WP(C) 9879/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 COPY OF THE PROCEEDINGS ISSUED BY THE 4TH RESPONDENT DATED 18.03.2019 PROPOSING TO LEVY TDS FOR THE DEPOSITS WITH TRANSLATION WP(C).No.7795 OF 2019 & CONNECTED CASES 237 APPENDIX OF WP(C) 9918/2019 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE CERTIFICATE DATED 22/11/2018, ISSUED BY THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), KOLLAM. EXHIBIT P2 A TRUE COPY OF THE COMMUNICATION DATED 19/01/2019 ISSUED BY THE 5TH RESPONDENT. EXHIBIT P3 A TRUE COPY OF THE CIRCULAR F.NO.ADDL.CIT/TDS/TVM/CO-OP SOCIETY/2018-19 DATED 26/12/2018 ISSUED BY THE 1ST RESPONDENT. EXHIBIT P4 A TRUE COPY OF ONE SUCH INTERIM ORDER IN WP(C) NO.9274/2019 DATED 26/03/2019 ISSUED BY THIS HON'BLE COURT. "