Annai Infra Developers Private Limited vs. State Of Kerala

WP(C)/3797/2019HC KeralaGSTCNR KLHC01009948201921 March 2019Bench: HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE22 pages

For Petitioner: SRI.P.T.GEOTOM, P.V.NIRANJANFor Respondent: SRI.P.T.GEOTOM, J.V.NIRANJAN

AI SummaryAllowed

Facts

Annai Infra Developers Pvt. Ltd., a road construction company, challenged ex-parte assessment orders issued from 2014 onwards, contending they never received notice. The State Tax Officer, Palakkad, had assessed the petitioner's work as 'works contract', despite the petitioner filing nil returns. The Government Pleader produced acknowledgments of notice receipt, which the petitioner disputed.

Held

The High Court set aside the ex-parte assessment orders, granting the petitioner an opportunity to appear before the assessing authority and explain the nature of their work. The Court deemed it inappropriate to relegate the petitioner to an appellate remedy given the lack of initial material presented to the assessing authority.

Key Issues

The primary legal issue was whether ex-parte assessment orders, passed without effective notice to the assessee, should be set aside to allow the assessee to present their case regarding the nature of their work.

Sections Cited

None

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances

IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA, 1940 WP(C).No. 3797 of 2019 PETITIONER: ANNAI INFRA DEVELOPERS PRIVATE LIMITED REP. BY ITS MANAGING DIRECTOR, S. ASHOK KUMAR, 7, IV FLOOR, SDS ENCLAVE, 2/5 PERUNDURAI ROAD., ERODE-638 011 BY ADVS. SRI.P.T.GEOTOM P.V.NIRANJAN RESPONDENTS: 1 STATE OF KERALA REP. BY SECRETARY TO GOVERNMENT, TAXES DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM- 695 001 2 THE COMMISSIONER OF COMMERCIAL TAXES TAX TOWER, KILLIPPALAM, KARAMANA P.O, TRIVANDRUM-695 001 3 STATE TAX TOWER WORKS CONTRACT, STATE GST (KERALA), PALAKKAD, PIN-678 001 4 THE CHIEF ENGINEER KERALA STATE RURAL ROADS DEVELOPMENT AGENCY, WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..2.. LOCAL SELF GOVERNMENT (RD) DEPARTMENT, GOVERNMENT OF KERALA, 3RD FLOOR, CSI BUILDING, PULIMOODU JUNCTION, TRIVANDRUM, TRIVANDRUM-695 001 BY ADV. GOVERNMENT PLEADER MM JASMINE GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.03.2019, ALONG WITH WP(C).3804/2019, WP(C).3843/2019, WP(C).3917/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..3.. IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA, 1940 WP(C).No. 3804 of 2019 PETITIONER: M/S.ANNAI INFRA DEVELOPERS PRIVATE LIMITED, REPRESENTED BY ITS MANAGING DIRECTOR - S.ASHOK KUMAR 7, IV FLOOR, SDS ENCLAVE, 2/5, PERUNDURAI ROAD, ERODE-638 011. BY ADVS. SRI.P.T.GEOTOM J.V.NIRANJAN RESPONDENTS: 1 STATE OF KERALA REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM- 695 001. 2 THE COMMISSIONER OF COMMERCIAL TAXES TAX TOWER,KILLIPPALAM, KARAMANA P.O., TRIVANDRUM-695 001. 3 STATE TAX OFFICER WORKS CONTRACT, STATE GST (KERALA), PALAKKAD, PIN-678 001. WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..4.. 4 THE CHIEF ENGINEER KERALA STATE RURAL ROADS DEVELOPMENT AGENCY, LOCAL SELF GOVERNMENT (RD) DEPARTMENT, GOVERNMENT OF KERALA, 3RD FLOOR, CSI BUILDING, PULIMOODU JUNCTION, TRIVANDRUM-695 001. BY ADV. GOVERNMENT PLEADER MM JASMINE GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.03.2019, ALONG WITH WP(C).3843/2019, WP(C).3917/2019, WP(C).3797/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..5.. IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA, 1940 WP(C).No. 3843 of 2019 PETITIONER: ANNAI INFRA DEVELOPERS PRIVATE LIMITED REP.BY ITS MANAGING DIRECOTR-S.ASHOK KUNAR, 7, IV FLOOR, SDS ENCAL,VE, 2/5.PERUNDURAI ROAD, ERODE-638 011 BY ADVS. SRI.P.T.GEOTOM SRI.P.T.GEOTOM RESPONDENTS: 1 STATE OF KERALA REP.BY SECRETARY TO GOVERNMENT, TAXES DEPARTMENT,SECRETARIAT, THIRUVANANTHPAURAM-695 001 2 THE COMMISSIONER OF COMMERCIAL TAXES TAX TOWER, KILLIPPALAM, KARAMANA .P.O., TRIVANDRUM-695 001 3 STATE OF OFFICER WORKS CONTRACT,STATE GST (KERALA), PALAKKAD, PIN-678 001 WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..6.. 4 THE CHIEF ENGINEER., KERALA STATE RURAL ROAD DEVELOPMENT AGENCY, LOCAL SELF GOVERNMENT (RD) DEPARTMENT, GOVERNMENT, OF KERALA, 3RD FLOOR, CSI BUILDING, PULI,MOODU JUNCTION, TRIVANDRAM-695 001 BY ADV. GOVERNMENT PLEADER MM JASMINE GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.03.2019, ALONG WITH WP(C).3917/2019, WP(C).3804/2019, WP(C).3797/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..7.. IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE A.MUHAMED MUSTAQUE THURSDAY ,THE 21ST DAY OF MARCH 2019 / 30TH PHALGUNA, 1940 WP(C).No. 3917 of 2019 PETITIONERS: M/S.ANNAI INFRA DEVELOPERS PRIVATE LIMITED, REPRESENTED BY ITS MANAGING DIRECTOR - S.ASHOK KUMAR, 7, IV FLOOR, SDS ENCLAVE, 2/5, PERUNDURAI ROAD, ERODE 638 011. BY ADVS. SRI.P.T.GEOTOM SRI.P.T.GEOTOM RESPONDENTS: 1 STATE OF KERALA REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES DEPARTMENT, SECRETARIAT, THIRUVANANTHAPURAM 695 001. 2 THE COMMISSIONER OF COMMERCIAL TAXES, TAX TOWER, KILLIPPALAM, KARMANA P.O., TRIVANDRUM 695 001. 3 STATE TAX OFFICER, WORKS CONTRACT, STATE GST (KERALA), WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..8.. PALAKKAD 678 001. 4 THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENT AGENCY, LOCAL SELF GOVERNMENT (RD) DEPARTMENT, GOVERNMENT OF KERALA, 3RD FLOOR, CSI BUILDING, PULIMOODU JUNCTION, TRIVANDRUM 695 001. BY ADV. GOVERNMENT PLEADER MM JASMINE GP THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 21.03.2019, ALONG WITH WP(C).3843/2019, WP(C).3804/2019, WP(C).3797/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).NOs.3797/19,3804/19,3843/19&3917/19 ..9..

JUDGMENT These writ petitions are filed by Annai Infra Developers Pvt.Ltd., a company based in Erode, Tamil Nadu, engaged in road construction in Kerala. Petitioners challenged an assessment order in all these writ petitions from 2014 onwards. These all orders were passed ex-parte. Petitioners contention is that they were not received any notice. The learned Government Pleader filed a counter and produce acknowledgment. This would show that notice was received by the petitioners. However, the learned counsel for the petitioners disputes the signature therein.

Admittedly, the petitioners were registered dealers and filed returns disclosing the nil receipt. The assessment has now proceeded as though the work undertaken by the petitioners as work contract.

Considering the nature of the issue, I am of the view that the petitioners should be given an ..10.. opportunity to explain the nature of work undertaken by them. There is no point in relegating the petitioners to invoke the appellate remedy , in the absence of any materials placed before the assessing authority to impress upon them the nature of work undertaken by them. In the interest of justice, it is appropriate that the petitioners should be given an opportunity to explain the nature of work. Hence, the impugned order is set aside. Petitioner is directed to appear before the assessing authority on 05.04.2019, at 11.am and thereafter, after adverting to the objections and materials produced by the petitioners. The proceedings shall be concluded within a period of two months. The Writ Petition is disposed as above. A.MUHAMED MUSTAQUE JUDGE PR/21.03.2019 ..11.. APPENDIX OF WP(C) 3797/2019 PETITIONER'S EXHIBITS: EXHIBIT P1OF THE CLASS-I CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT. EXHIBIT P2THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENT. EXHIBIT P3 THE AGREEMENT NO. 175/CE-KSRRDA/2014- 15 DATED 10TH DECEMBER, 2014 EXHIBIT P4 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 04.12.2014. EXHIBIT P5 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 02.01.2009. EXHIBIT P6OF THE INVOICES OF THE GOODS PURCHASED WITH DEDUCTION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER-COMPANY IN STATE OF TAMILNADU. EXHIBIT P7OF THE DEDUCTION OF VAT BY THE KERALA GOVERNMENT. EXHIBIT P8 THE APPLICATION FOR CLARIFICATION FILED BY THE PETITIONER COMPANY DATED 27TH DECEMBER, 2014 EXHIBIT P9 THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION U/S. 94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL TAXES. EXHIBIT P10OF THE TAX APPEAL IN OTA 3 OF 2016 AND I.A. 465 OF 2016. ..12.. EXHIBIT P11OF THE INTERIM ORDER IN I.A. 465 OF 2016 DATED 30.03.2016 PASSED BY THIS HON'BLE COURT IN OTA 3 OF 2016 EXHIBIT P12 THE IMPUGNED ASSESSMENT ORDER NO. 32091691691195/2014-15 DATED 20.08.2018 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALAKKAD. EXHIBIT P13OF THE IMPUGNED DEMAND NOTICE NO. 88/18-19. RESPONDENTS EXHIBITS: EXHIBIT R3 AOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3 BOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3 COF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3 DOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3 EOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3 FOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3 GOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. ..13.. EXHIBIT R3 HOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. ..14.. APPENDIX OF WP(C) 3804/2019 PETITIONER'S EXHIBITS: EXHIBIT P1OF THE CLASS-I CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT. EXHIBIT P2OF THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENT. EXHIBIT P3 THE AGREEMENT NO.175/CE-KSRRDA/2014-15 DATED 10TH DECEMBER, 2014. EXHIBIT P4 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 4.12.2015. EXHIBIT P5 THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 02.01.2009. EXHIBIT P6OF THE INVOICES OF THE GOODS PURCHASED WITH DEDUCTION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER-COMPANY IN STATE OF TAMILNADU. EXHIBIT P7OF THE DEDUCTION OF VAT BY THE KERALA GOVERNMENT. EXHIBIT P8 THE APPLICATION FOR CLARIFICATION FILED BY THE PETITIONER-COMPANY DATED 27TH DECEMBER, 2014. EXHIBIT P9 THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION U/S.94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL TAXES. EXHIBIT P10 THE TAX APPEAL IN OTA 3 OF 2016 AND I.A. 465 OF 2016. ..15.. EXHIBIT P11 THE INTERIM ORDER IN I.A.465 OF 2016 DATED 30.3.2016 PASSED BY THIS HON'BLE COURT INOTA.3 OF 2016. EXHIBIT P12 THE IMPUGNED ASSESSMENT ORDER NO.32091691195/2017-18 DATED 4.9.2018 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALAKKAD. EXHIBIT P13OF THE IMPUGNED DEMAND NOTICE NO.107/18-19. RESPONDENTS EXHIBITS: EXHIBIT R3 AOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3 BOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3 COF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3 DOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3 EOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3 FOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3 GOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. ..16.. EXHIBIT R3 HOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. ..17.. APPENDIX OF WP(C) 3843/2019 PETITIONER'S EXHIBITS: EXHIBIT P1OF THE CLASS-1 CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT EXHIBIT P2OF THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENTS EXHIBIT P3OF THE AGREEMENT NO.175/CE- KSRRDA/2014-15 DATED 10TH DECEMBER,2014 EXHIBIT P4OF THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 04.12.2014 EXHIBIT P5OF THE VAT REGISTRATION ISSUED BY THE TAMILNADU GOVERNMENT DATED 02.01.2009 EXHIBIT P6OF THE INVOICES OF THE GOODS PURCHASED WITH DEDUCTION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER-COMPANY IN STATE OF TAMILNADU EXHIBIT P7OF THE DEDUCTION OF VAT BY THE KERALA GOVERNMENT EXHIBIT P8OF THE APPLICATION FOR CLARIFICATION FIELD BY THE PETITIONER- COMPANY DATED 27THG DECEMBER ,2014 EXHIBIT P9OF THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION, U/S.94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL ..18.. TAXES EXHIBIT P10OF THE TAX APPEAL IN OTA 3 OF 2016 EXHIBIT P11OF THE INTERIM ORDER IN I.A 465 OF 2016 DATED 30.03.2016 PASSED BY THIS HON'BLE COURT IN OTA 3 OF 2016 EXHIBIT P12OF THE IMPUGNED ASSESSMENT ORDER NO.32091691195/2015-16 DATED 20/8/18 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALAKKAD EXHIBIT P13OF THE IMPUGNED DEMAND NOTICE NO.85/18-19 RESPONDENTS EXHIBITS: EXHIBIT R3(A)OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3(B)OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3(C)OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3(D)OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3(E)OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3(E)OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. ..19.. EXHIBIT R3(F)OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3(G)OF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT R3(H)OF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. ..20.. APPENDIX OF WP(C) 3917/2019 PETITIONER'S EXHIBITS: EXHIBIT P1OF THE RELEVANT PAGES CLASS- 1, CONTRACTOR CERTIFICATE ISSUED BY THE PUBLIC WORK DEPARTMENT. EXHIBIT P2OF THE TENDER ISSUED BY THE CHIEF ENGINEER, KERALA STATE RURAL ROADS DEVELOPMENT. EXHIBIT P3OF THE AGREEMENT NO. 175/CE- KSRRDA/2014-15 DATED 10TH DECEMBER, 2014. EXHIBIT P4OF THE VAT REGISTRATION ISSUED BY THE KERALA GOVERNMENT DATED 4.12.2015. EXHIBIT P5OF THE VAT REGISTRATION ISSUED BY THE TAMIL NADU GOVERNMENT DATED 2.1.2009. EXHIBIT P6OF THE RELEVANT PAGE INVOICES OF THE GOODS PURCHASED WITH EDUCATION OF VAT BY THE TAMILNADU GOVERNMENT BY THE PETITIONER COMPANY IN STATE OF TAMILNADU. EXHIBIT P7OF THE DEDUCTION OF VT BY THE KERALA GOVERNMENT. EXHIBIT P8OF THE APPLICATION FOR CLARIFICATION FILED BY THE PETITIONER COMPANY DATED 27TH DECEMBER 2014. EXHIBIT P9OF THE IMPUGNED ORDER PASSED BY THE AUTHORITY FOR CLARIFICATION U/S. 94 OF THE KERALA VALUE ADDED TAX ACT, 2003, DEPARTMENT OF COMMERCIAL ..21.. TAXES. EXHIBIT P10OF THE TAX APPEAL IN OTA 3 OF 2016 AND I.A. 465 OF 2016. EXHIBIT P11OF THE INTERIM ORDER IN I.A. 465 OF 2016 DATED 30.3.2016 PASSED BY THIS HONBLE COURT IN OTA 3 OF 2016. EXHIBIT P12OF THE IMPUGNED ASSESSMENT ORDER NO. 32091691195/2016-17 DATED 4.9.2019 PASSED BY THE ASSESSING AUTHORITY FOR STATE GST AT PALKKAD EXHIBIT P13OF THE IMPUGNED DEMAND NOTICE NO. 108/18-19. RESPONDENTS EXHIBITS: EXHIBIT R3 AOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3 BOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT R3 COF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3 DOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT R3 EOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT R3 FOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2016-17. ..22.. EXHIBIT R3 GOF THE NOTICE DATED 14.05.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT R3 HOF THE NOTICE DATED 26.07.2018 AND ITS ACKNOWLEDGMENT FOR THE ASSESSMENT YEAR 2017-18.

Reproduced from the public record of the Kerala High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.