Vellangallur Peoples Welfare vs Union Of India

[Cites 88, Cited by 0] Kerala High Court Vellangallur Peoples Welfare ... vs Union Of India on 25 October, 2025 2025:KER W.P(C)No.7053/2023 & Connected cases 1 IN THE HIGH COURT OF KERALA AT ERNAKULAM CR PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 7053 OF 2023 PETITIONER/S: 1 VELLANGALLUR PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD NO.R. 1191, KONATHUKUNNU P.O, THRISSUR, PIN-680123 REPRESENTED BY ITS SECRETARY RAJITHA K.S 2 MUKUNDAPURAM TALUK GRAMA VIKASANA CO-OPERATIVE SOCIETY LTD NO.R. 1427, NADA - IRINJALAKUDA P.O, THRISSUR DISTRICT, PIN 680121 REPRESENTED BY SECRETARY PRIYA K BY ADVS. SHRI.C.A.JOJO SRI.S.JIJI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110000. 2 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110000. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018 2025:KER W.P(C)No.7053/2023 & Connected cases 2 4 THE INCOME TAX OFFICER(TDS) AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680001 5 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE THRISSUR DISTRICT CO-OPERTAIVE BANK), THRISSUR DISTRICT CO-OPERTAIVE BANK), HEAD OFFICE, THRISSUR-680001 6 THE GENERAL MANAGER IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD TANA JUNCTION, IRINJALAKUDA P.O, PIN-680121 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 9.10.2025 ALONG WITH WP(C) NOS.213/2022, 378/2022 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 3 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 213 OF 2022 PETITIONER/S: 1 EDARIKODE SERVICE CO-OPERATIVE BANK LTD. NO. F 10739, EDARIKODE P.O, MALAPPURAM DISTRICT, PIN 676 501, REPRESENTED BY ITS SECRETARY IN CHARGE, SYAMKUMAR M.K. 2 THE AREEKODE SERVICE CO-OPERATIVE BANK LTD. NO. F1571, AREEKODE P.O, MALAPPURAM DISTRICT, PIN 673 639, REPRESENTED BY ITS SECRETARY LATHIKA P. 3 THE KEEZHUPARAMBA SERVICE CO-OPERATIVE BANK LTD., NO. M 396, VALILLAPUZHA P.O, MALAPPURAM DISTRICT, PIN 673 639, REPRESENTED BY ITS SECRETARY IN CHARGE, SHEEBARANI A 4 URANGATTIRI SERVICE CO-OPERATIVE BANK LTD. NO. 8895, H.O. THEERATTAMMAL, URANGATTIRI P.O, AREEKODE, MALAPPURAM DISTRICT, PIN-673 639 REPRESENTED BY ITS SECRETASECRETARY,ANWAR T.P. 5 THE VENGARA SERVICE CO-OPERATIVE BANK LTD. NO. F 1186, MALAPPURAM DISTRICT, PIN 676 304, REPRESENTED BY ITS SECRETARY, HAMMED 6 PUTHUPPARAMBA SERVICE CO-OPERATIVE BANK LTD. NO. M822, P.O. PUTHUPPARAMBA, MALAPPURAM DISTRICT, PIN 679 501, REPRESENTED BY ITS SECRETARY, SAHADEVAN T. 2025:KER W.P(C)No.7053/2023 & Connected cases 4 BY ADVS. SHRI.C.A.JOJO SRI.MATHEWS JOSEPH SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINSTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI 682 018. 3 THE INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD, THIRUR P.O, MALAPPURAM DISTRICT, PIN 676 101. 4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN 676 505, REPRESENTED BY ITS GENERAL MANAGER. 5 MANJERI CO-OPERATIVE URBAN BANK LTD., MANJERI, TIRUR MALAPPURAM DISTRICT, PIN 676 121, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. SHRI.VISHNU PRADEEP CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.ESM.KABEER SHRI.K.VIDYASAGAR SRI.GILBERT GEORGE CORREYA SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 5 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 378 OF 2022 PETITIONER/S: 1 MALAPPURAM DISTRICT ELECTRICITY BOARD, EMPLOYEES CO-OPERATIVE SOCIETY LIMITED NO. M.380, HO MALAPPURAM, MALAPPURAM DISTRICT-676519, REPRESENTED BY ITS SECRETARY O. VINOD. 2 CHERAKARA CO-OPERATIVE RURAL BANK LIMITED NO. M.663, P.O. PULIKKAL, MALAPPURAM DISTRICT-673637, REPRESENTED BY ITS SECRETARY SUBHADRA. 3 MUTHUVALLUR GRAMA PANCHAYAT RURAL DEVELOPMENT CO-OPERATIVE SOCIETY LIMITED NO.M.955, P.O. KONDOTTY, MALAPPURAM DISTRICT-679638, REPRESENTED BY ITS SECRETARY SHYJA E. 4 MAMPAD RURAL CO-OPERATIVE SOCIEITY LIMITED NO.M.791, P.O.VADAPURAM, MALAPPURAM DISTRICT-676542, REPRESENTED BY ITS SECRETARY MANEESH C.M. 5 THAZHEKKODE PANCHAYATH RURAL CO-OPERATIVE SOCIETY LIMITED NO. M.1036, MALAPPURAM DISTRICT-679341, REPRESENTED BY ITS SECRETARY SHEENA DEV. 6 MALAPPURAM AIDE SCHOOL TEACHERS CO-OPERATIVE SOCIETY LIMITED NO. M.49, P.O., DOWN HILL, MALAPPURAM DISTRICT-676519, REPRESENTED BY ITS SECRETARY SHEENA P. 7 THENHIPALAM CO-OPERATIVE RURAL BANK LIMITED NO. M.668, P.O. THENHIPALAM, MALAPPURAM DISTRICT- 673636, REPRESENTED BY ITS SECRETARY LATHA T. 2025:KER W.P(C)No.7053/2023 & Connected cases 6 8 THE VETTIKKATTIRI VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M.744, P.O. VELLUVANGAD, MALAPPURAM DISTRICT- 676521, REPRESENTED BY ITS SECRETARY ABDUL HAMEED. 9 THE VETTIKKATTIRI VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M.744, P.O. VELLUVANGAD, MALAPPURAM DISTRICT- 676521, REPRESENTED BY ITS SECRETARY ABDUL HAMEED. 0 PULPATTA VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M.760, P.O. THRIPPANACHI, MALAPPURAM DISTRICT- 673541, REPRESENTED BY ITS SECRETARY PRAVEENA K. 11 KANNAMANGALAM PATTIKAJATHI SERVICE CO-OPERTAIVE SOCIETY LIMITED NO. M.297, P.O. KANNAMANGALAM, MALAPPURAM DISTRICT-676304, REPRESENTED BY THE SECRETARY LAKSHMI P. 12 EDAVANNA WELFARE CO-OPERATIVE SOCIETY LIMITED NO. M. 993, P.O. EDAVANNA, MALAPPURAM DISTRICT-676541, REPRESENTED BY ITS SECRETARY P. MOHAMMAD. 13 CHEMBRASSERI VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M.87, P.O. CHEMBRASSERI EAST, MALAPPURAM DISTRICT-679327, REPRESENTED BY ITS SECRETARY CHINJU KRISHNA. 14 TUVVUR PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M.580, P.O. TUVVUR, MALAPPURAM DISTRICT-679327, REPRESENTED BY ITS SECRETARY JAYASREE M.V. 15 PARAPPUR PANCHAYATH VANITHA SAHAKARANA SANGAM LIMITED NO. M.610, P.O. IRINGALLUR, VENGARA, MALAPPURAM DISTRICT-676304, REPRESENTED BY ITS SECRETARY C.T. ROSHNI. 16 NILAMBUR MERCANTILE CO-OPERATIVE SOCIETY LIMITED NO. M.763, P.O. NILAMBUR MALAPPURAM DISTRICT- 679329, REPRESENTED BY ITS SECRETARY P. DEVANAND. 2025:KER W.P(C)No.7053/2023 & Connected cases 7 17 KOTTAKKAL CO-OPERATIVE URBAN SOCIETY LIMITED NO. M.1010, P.O. KOTTAKKAL, MALAPPURAM DISTRICT- 676503, REPRESENTED BY ITS SECRETARY N. BALAKRISHNAN. 18 CHERUKAVU VANITHA SAHAKARANA SANGAM LIMITED, NO. M.758, P.O. AYIKKAAPADI, MALAPPURAM DISTRICT-673637, REPRESENTED BY ITS SECRETARY IN CHARGE BHAVITHA K. 19 KOTTAKKAL VANITHA CO-OPERATIVE SOCIETY LIMITED, NO. M.757, P.O. KOTTAKKAL, MALAPPURAM DISTRICT-676503, REPRESENTED BY ITS SECRETARY SUMI P. 10 VALLIKKUNNU PANCHAYATH AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LIMITED NO. M.938, P.O. KODAKKAD, MALAPPURAM DISTRICT-676319, REPRESENTED BY ITS SECRETARY JISH C. 21 TIRURANGADI AGRICULTURAL WORKERS DEVELOPMENT WELFARE CO-OPERATIVE SOCIETY LIMITED NO. M.887, P.O. TIRURANGADI, MALAPPURAM DISTRICT, PIN-676306, REPRESENTED BY ITS SECRETARY K. VIJNA VINOD. 22 VALLIKUNNU PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LIMITED NO.M.509, P.O. ARIYALLUR, MALAPPURAM DISTRICT-676312, REPRESENTED BY ITS SECRETARY ANITHA. 23 MOONIYOOR VALLIKUNNU CO-OPERATIVE RURAL BANK LIMITED NO. M. 673, P.O. MOONIYOOR, MALAPPURAM DISTRICT, REPRESENTED BY ITS SECRETARY IN CHARGE SMITHA. 24 VENGARA BLOCK PRAVASI KSHEMA SAHAKARANA SANGAM, P.O. KUTTALOOR OOAKAM, MALAPPURAM DISTRICT-676519, REPRESENTED BY ITS SECRETARY SHAJIDA. 25 ALLIKUNNU ANANGADI VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M.707, KADALUNDI NAGARAM P.O., ANANGADI, MALAPPURAM DISTRICT-673314, REPRESENTED BY ITS SECRETARY SHEEBA M. 26 TIRURANGADI TALUK GOVERNMENT TEACHERS CO-OPERATIVE SOCIETY LIMITED NO. M.405, P.O. 2025:KER W.P(C)No.7053/2023 & Connected cases 8 TIRURANGADI, MALAPPURAM DISTRICT-676306, REPRESENTED BY ITS SECRETARY BABY E.P. 27 TIRURANGADI TALUK GOVERNMENT EMPLOYEES CO-OPERATIVE SOCIETY LIMITED NO. M.536, P.O. TIRURANGADI, MALAPPURAM DISTRICT-676306, REPRESENTED BY ITS SECRETARY, JYOTHILAKSHMI K. 28 PERUVALLUR VANITHA SAHAKARANA SANGAM LIMITED NO.M.774, P.O. KADAPPADI, PERUVALLUR, MALAPPURAM DISTRICT-673638, REPRESENTED BY ITS SECRETARY RAJITHA A. 29 MLP DT. POSTAL, TELECOM AND BSNL EMPLOYEES CO-OPERATIVE SOCIETY LIMITED NO. M.268, P.O. MANJERI, MALAPPURAM DISTRICT-676121, REPRESENTED BY ITS SECRETARY NANDAKUMAR. 20 PARAPPUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LIMITED NO. M.943, P.O. PARAPPUR, MALAPPURAM DISTRICT-676501, REPRESENTED BY ITS SECRETARY IN CHARGE LISHA . 31 PARAPPANANGADI CO-OPERATIVE RURAL BANK LIMITED NO. M.669, P.O. PARAPPANANGADI, MALAPPURAM DISTRICT-676303, REPRESENTED BY ITS SECRETARY BHERI K. 32 MALAPPURAM DISTRICT GOVERNMENT SCHOOL TEACHER CO-OPERATIVE SOCIETY LIMITED NO. M.1935, P.O. UPHILL, MALAPPURAM DISTRICT-676122, REPRESENTED BY ITS SECRETARY SHERI K. 33 FOR MANJERI HOUSING CO-OPERATIVE SOCIETY LIMITED NO. M.256, P.O. MANJERI MALAPPURAM DISTRICT- 676121, REPRESENTED BY ITS SECRETARY SATHIDEVI N. 34 ELANKUR VANITHA SAHAKARANA SANGAM LIMITED NO.M.754, P.O. MANHAPATTA, MALAPPURAM DISTRICT-676122, REPRESENTED BY ITS SECRETARY SAJITHA P.C. 35 KONDOTTY MUNICIPAL PATTIKAJATHI SERVICE CO-OPERATIVE LIMITED NO. M.560, P.O. KONDOTTY, MALAPPURAM DISTRICT-673638, REPRESENTED BY ITS SECRETARY. 2025:KER W.P(C)No.7053/2023 & Connected cases 9 36 VAZHAKKAD PATTIKAJATHI SERVICE SAHAKARANA SANGHAM LIMITED NO. M.340, P.O. CHERUVAYUR, MALAPPURAM DISTRICT-676505, REPRESENTED BY ITS SECRETARY SHEELA. 37 PANDIKKAD RURAL CO-OPERATIVE SOCIETY LIMITED NO.M.819, P.O. PANDIKKAD, MALAPPURAM DISTRICT-679521, REPRESENTED BY ITS SECRETARY SREEJITH M. 38 TUVVUR RURAL CO-OPERATIVE SOCIETY LIMITED NO. M.836, P.O. TUVVUR, MALAPPURAM DISTRICT- 679327, REPRESENTED BY ITS SECRETARY RAGESH V. 39 KARUVARAKUNDU RURAL CO-OPERATIVE SOCIETY LIMITED M. 803, P.O. KIZHAKETHALA, MALAPPURAM DISTRICT-676523, REPRESENTED BY ITS SECRETARY V.C. UNNIKRISHNAN. 40 FOR MALAPPURAM DISTRICT POLICE CO-OPERATIVE SOCIETY LIMITED NO. M.438, P.O., MALAPPURAM, MALAPPURAM DISTRICT-676505, REPRESENTED BY ITS SECRETARY T. ABDUL RASHEED. BY ADVS. SHRI.C.A.JOJO SRI.MATHEWS JOSEPH RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI- 682018. 3 THE INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD, 2025:KER W.P(C)No.7053/2023 & Connected cases 10 THIRUR P.O., MALAPPURAM DISTRICT-676101. 4 MALAPPURAM DISTRICT CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, HEAD OFFICE, MANJERI ROAD, MALAPPURAM-676505 REPRESENTED BY ITS GENERAL MANAGER. 5 MANJERI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS BANK LIMITED, MANJERI, TIRUR, MALAPPURAM DISTRICT-676121, REPRESENTED BY ITS GENERAL MANAGER. 6 PONANI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS BANK LIMITED, HEAD OFFICE, K.K. JUNCTION, PONNANI, MALAPPURAM DISTRICT, KERALA-691001, REPRESENTED BY ITS GENERAL MANAGER. 7 URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK, PERINTHALMANNA, HEAD OFFICE, PERINTHALMANNA P.O., PIN-679322, REPRESENTED BY ITS GENERAL MANAGER. 8 TIRUR URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA- 676101, REPRESENTED BY ITS GENERAL MANAGER. 9 KOTTAKKAL CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS BANK LIMITED, KOTTAKKAL P.O., MALAPPURAM-676503, REPRESENTED BY ITS GENERAL MANAGER. 0 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK, KOZHIKODE BRANCH, DOWN HILL, PIN-676505, REPRESENTED BY ITS GENERAL MANAGER. 11 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, MALAPPURAM BRANCH, PARRY SHOPPING COMPLEX, KOTTAPADI, DOWN HILL, P.O. MALAPPURAM DISTRICT-676505. *[THE WORD "SOCIETY" OCCURRING IN THE SUFFIX PART OF NAME OF THE RESPONDENTS 4 TO 11 IS CORRECTED AS "BANK", AS PER ORDER DATED 17/2/2022 IN I.A:1/22 IN WP(C) 2025:KER W.P(C)No.7053/2023 & Connected cases 11 378/2022] BY ADVS. SHRI.VISHNU PRADEEP, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.ESM.KABEER SRI.D.SOMASUNDARAM, SC, PONNANI CO-OPERATIVE URBAN BANK LTD. SHRI.PRAVEEN K.V., CGC SRI.GILBERT GEORGE CORREYA SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 12 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 384 OF 2022 PETITIONER/S: 1 TIRUR TALUK CO-OPERATIVE EMPLOYEES SOCIETY LTD. NO.M 275, H.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676 101, REPRESENTED BY ITS SECRETARY KRISHNAKUMARI PALEERI. 2 TIRUR TALUK CO-OPERATIVE SOCIETY LTD. NO.M 325, TIRUR P.O., MALAPPURAM DISTRICT, PIN - 676 101 REPRESENTED BY ITS SECRETARY-IN-CHARGE, DINOOP K.V. 3 THE THIRUNAVAYA VANITHA CO-OPERATIVE SOCIETY LTD. NO.M 696, VAIRANKODE P.O., MALAPPURAM DISTRICT, PIN - 676 301, REPRESENTED BY ITS SECRETARY NISHITHA T. 4 THE THIRUNAVAYA CO-OPERATIVE URBAN SOCIETY LTD. NO.M 646, P.O.EDAKULAM, THIRUNAVAYA, MALAPPURAM DISTRICT, PIN - 676 301, REPRESENTED BY ITS SECRETARY SUVARNA M. 5 IMBICHIBAVA MEMORIAL RURAL CO-OPERATIVE SOCIETY LTD. NO.M 778, MALAPPURAM DISTRICT, PIN - 679 571, REPRESENTED BY ITS SECRETARY SMITHA K.K.R. 6 MALAPPURAM DISTRICT ABHARANA THOZHILAL CREDIT CO- OPERATIVE SOCIETY LTD. NO.M 544, P.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676 101, REPRESENTED BY ITS SECRETARY AMBIKA C. 7 TANUR TOWN THEERADESHA FISHERMEN DEVELOPMENT WELFARE CO-OPERATIVE SOCIETY F(M) 10 P.O.TANUR, MALAPPURAM DISTRICT, PIN - 673 631, 2025:KER W.P(C)No.7053/2023 & Connected cases 13 REPRESENTED BY ITS SECRETARY RAJANI P. 8 THALAKKAD VANITHA CO-OPERATIVE SOCIETY LTD. NO.M 684, P.O.B.P.ANGADI, TIRUR-2, MALAPPURAM DISTRICT, PIN - 676 561, REPRESENTED BY ITS SECRETARY SOUDAMINI K. 9 TIRUR MOTOR TRANSPORT CO-OPERATIVE SOCIETY LTD. NO.M 486, P.O.THEKKUMMURI, TIRUR, MALAPPURAM DISTRICT, PIN - 676 105, REPRESENTED BY ITS SECRETARY SREERAJ S. 10 POOKKAYIL URBAN CO-OPERATIVE SOCIETY LTD. NO.M 827, P.O.POOKKAYIL, TIRUR, MALAPPURAM DISTRICT, PIN - 676 107, REPRESENTED BY ITS SECRETARY RANJITHA R. 11 TIRUR TALUK VANITHA CO-OPERATIVE SOCIETY LTD. NO.M 501, P.O.THEKKUMMURI, TIRUR, MALAPPURAM DISTRICT, PIN - 676 105, REPRESENTED BY ITS SECRETARY ABITHA N.P. 12 TIRUR TALUK MERCANTILE CO-OPERATIVE SOCIETY LTD. NO.M 793, P.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676 101, REPRESENTED BY ITS SECRETARY MIDHUNDEV M.P. 13 VALANCHERY URBAN CO-OPERATIVE SOCIETY LTD. NO.M 994, P.O.VALANCHERY, MALAPPURAM DISTRICT, PIN - 676 552, REPRESENTED BY ITS SECRETARY ANVAR SHAFI T.P. 14 TIRUR REVENUE TALUK MOTOR TRANSPORT VIKASANA SAHAKARANA SANGAM LTD. NO.M 559, P.O.K.PURAM, MALAPPURAM DISTRICT, PIN - 676 307, REPRESENTED BY ITS SECRETARY V.SATHYAVATHY. 15 TRIPRANGOD VANITHA CO-OPERATIVE SOCIETY LTD. NO.M 740, KARATHUR P.O., CODACAL, MALAPPURAM DISTRICT, PIN - 676 108, REPRESENTED BY ITS SECRETARY KADEEJATH SABNA. 16 ALATHIYOOR VANITHA CO-OPERATIVE SOCIETY LTD. NO. M 817, P.O.ALATHIYOOR, MALAPPURAM DISTRICT, PIN - 676 102, REPRESENTED BY ITS SECRETARY SHEEBA V. 2025:KER W.P(C)No.7053/2023 & Connected cases 14 17 PONANI TALUK GOVT. EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO. M 421, P.O.PONNANI, MALAPPURAM DISTRICT, PIN - 679 577, REPRESENTED BY ITS SECRETARY JAYALALITHA O.B. 18 PONANI TALUK GOVT & QUASI GOVT. EMPLOYEES CO- OPERATIVE CREDIT SOCIETY LTD. NO. 298, P.O.PONANI, MALAPPURAM DISTRICT, PIN - 679 577, REPRESENTED BY ITS SECRETARY SREEDEVI M. 19 VELIYANCODE PANCHAYAT VANITHA CO-OPERATIVE SOCIETY LTD. NO.M 667, P.O.ERAMANGALAM, MALAPPURAM DISTRICT, PIN - 679 587, REPRESENTED BY ITS SECRETARY LEENA P. 20 NANNAMMUKKU MULTIPURPOSE CO-OPERATIVE SOCIETY LTD. NO. M 781, P.O.MOOKKUTHALA, MALAPPURAM DISTRICT, PIN - 679 574, REPRESENTED BY ITS SECRETARY SMITHA C.P. 21 MALAPPURAM DISTRICT LIC AGENT'S CO-OPERATIVE SOCIETY LTD. NO M 675, P.O.THRIKKANDIYOOR, MALAPPURAM DISTRICT, PIN - 676 104, REPRESENTED BY ITS SECRETARY RADHAKRISHNAN K. 22 NANNAMMUKKU PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD. NO.M 813, P.O.CHANGARAMKULAM,MALAPPURAM DISTRICT, PIN - 679 575, REPRESENTED BY ITS SECRETARY SUBITHA K.K. 23 MARANCHERY RURAL CO-OPERATIVE SOCIETY LTD. NO.M 800, P.O.MARANCHERY, MALAPPURAM DISTRICT, PIN - 679 581, REPRESENTED BY ITS SECRETARY REENA M. 24 MALAPPURAM DISTRICT EMPLOYEES HOUSING CO-OPERATIVE SOCIETY LTD. NO.M 797, H.O.TRIKKANDIYUR, MALAPPURAM DISTRICT, PIN - 676 104, REPRESENTED BY ITS SECRETARY K.PRASADAN. 25 VELIYANCODE MULTI-PURPOSE CO-OPERATIVE SOCIETY LTD. NO.M 766, P.O.ERAMANGALAM, MALAPPURAM DISTRICT, PIN - 679 587, REPRESENTED BY ITS SECRETARY GIRIVASAN T.G. 2025:KER W.P(C)No.7053/2023 & Connected cases 15 26 PERUMPADAPPU RURAL CO-OPERATIVE SOCIETY LTD. NO.M 831, P.O.PERUMPADAPPU, MALAPPURAM DISTRICT, PIN - 679 580, REPRESENTED BY ITS SECRETARY RANJITH KUMAR P.C. 27 CLARI RURAL CO-OPERATIVE SOCIETY LTD. NO.M 732, P.O.PANTHARANGADI, MALAPPURAM DISTRICT, PIN - 676 306, REPRESENTED BY ITS SECRETARY SHIJUMON T. 28 EDAPPAL VANITHA CO-OPERATIVE SOCIETY LTD. NO.M 764, P.O.EDAPPAL, MALAPPURAM DISTRICT, PIN - 679 576, REPRESENTED BY ITS SECRETARY SREEJESH K. 29 KOLOMBA RURAL CO-OPERATIVE SOCIETY LTD. NO. M 838, P.O.KOLOLAMBA, MALAPPURAM DISTRICT, PIN - 679 576, REPRESENTED BY ITS SECRETARY SHYJI K.M. 30 VATTAMKULAM VIVIDHODHESA SAHAKARANA CO-OPERATIVE SOCIETY LTD. NO.M762, P.O.VETTAMKULAM, MALAPPURAM DISTRICT, PIN - 679 578, REPRESENTED BY ITS SECRETARY VYSAKH K.V. 31 TANUR KAYALORA FDWCS F(M) 68 P.O.TANUR, MALAPPURAM DISTRICT, PIN - 679 576, REPRESENTED BY ITS SECRETARY SHAHANAS A. 32 PARAPPANANGAD CHAPPAPPAD THEKKABHAGAM FDWCS F(M) 128, P.O.PARAPPANANGAD, MALAPPURAM DISTRICT, PIN - 679 303, REPRESENTED BY ITS SECRETARY SHANI K. 33 THE TIRUR TALUK CO-OPERATIVE EDUCATION SOCIETY LTD. NO.M 315, P.O.TIRUR, MALAPPURAM DISTRICT, PIN - 676 101, REPRESENTED BY ITS SECRETARY SHAJID K. 34 PUTHIYAKADAPPURAM MASTSYA THOZHILALEE VIKASANA KSHEMA SAHAKARANA SANGAM LTD. NO.DF(M) 140/93, PUTHIYAKADAPPURAM P.O., THANOOR, MALAPPURAM DISTRICT, PIN - 676 302, REPRESENTED BY ITS SECRETARY SHEENA P. BY ADV SHRI.C.A.JOJO 2025:KER W.P(C)No.7053/2023 & Connected cases 16 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE,NORTH BLOCK, RAISANA HILL, NEW DELHI - 11000. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX OFFICE, TARIFF BAZAR, TOWN HALL ROAD, THIRUR P.O., MALAPPURAM DISTRICT, PIN - 676 101. 4 MALAPPURAM DISTRICT CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN - 676 505, REPRESENTED BY ITS GENERAL MANAGER. 5 MANJERI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS BANK LIMITED, MANJERI, TIRUR MALAPPURAM DISTRICT, PIN - 676 121, REPRESENTED BY ITS GENERAL MANAGER. 6 PONANI CO-OPERATIVE URBAN [SOCIETY]*CORRECTED AS BANK LIMITED, HEAD OFFICE, K.K.JUNCTION, PONNANI, MALAPPURAM DISTRICT, KERALA, PINCODE - 691 001, REPRESENTED BY ITS GENERAL MANAGER. 7 URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, HEAD OFFICE, PERINTHALMANNA P.O., PIN - 679 322, REPRESENTED BY ITS GENERAL MANAGER. 8 TIRUR URBAN CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA - 676 101, REPRESENTED BY ITS GENERAL MANAGER. 9 KOTTAKKAL CO-OP URBAN [SOCIETY]*CORRECTED AS BANK LIMITED, KOTTAKKAL P.O., MALAPPURAM, PIN - 676 503, 2025:KER W.P(C)No.7053/2023 & Connected cases 17 REPRESENTED BY ITS GENERAL MANAGER. 10 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, KOZHIKODE BRANCH, DOWN HILL, PIN - 676 505, REPRESENTED BY ITS GENERAL MANAGER. 11 KERALA STATE CO-OPERATIVE [SOCIETY]*CORRECTED AS BANK LIMITED, MALAPPURAM BRANCH, PARRY SHOPPING COMPLEX, KOTTAPADI, DOWN HILL, P.O., MALAPPURAM DISTRICT- 676 505. [THE NAME OF RESPONDENTS 4 TO 11 IS CORRECTED FROM THE WORD "SOCIETY" TO "BANK" AS PER ORDER DATED 18.03.2022 IN I.A.1/2022 IN WP(C)384/2022.] BY ADVS. SHRI.VISHNU PRADEEP, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.ESM.KABEER SHRI.K.VIDYASAGAR SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 18 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 383 OF 2022 PETITIONER/S: 1 THE ANANTHAVOOR SERVICE CO-OPERATIVE BANK LTD. NO.F 1545, ANANTHAVOOR P.O., MALAPPURAM DISTRICT, PIN - 676 501, REPRESENTED BY ITS SECRETARY, LATHA K.V. 2 THE TIRUNAVAYA SERVICE CO-OPERATIVE BANK LTD. NO.D 1910, TIRUNAVAYA P.O., MALAPPURAM DISTRICT, PIN - 676 102 REPRESENTED BY ITS SECRETARY SURESH K.M. 3 THE VALANCHERY SERVICE CO-OPERATIVE BANK LTD. NO.M 728, VALANCHERY P.O., MALAPPURAM DISTRICT, PN - 676 552 REPRESENTED BY ITS SECRETARY SASIKUMAR P. 4 TIRUR SERVICE CO-OPERATIVE BANK LTD. NO.10094, P.O.TIRUR, CHEMBRA ROAD, MALAPPURAM DISTRICT, PIN - 676 101 REPRESENTED BY ITS SECRETARY UMMAR K.K. 5 THE CHERIYAMUNDAM SERVICE CO-OPERATIVE BANK LTD. NO.D 1974, MALAPPURAM DISTRICT, PIN - 676 103, REPRESENTED BY ITS SECRETARY, K.P.NIHMATHALLA. 6 MANGALAM SERVICE CO-OPERATIVE BANK LTD. NO.9701, MALAPPURAM DISTRICT, PIN - 676 561, REPRESENTED BY ITS SECRETARY ABDUL MAJEED. 7 MARAKKARA SERVICE CO-OPERATIVE BANK LTD. NO.F 10738, KADAMPUZHA, MALAPPURAM DISTRICT, PIN - 676 553, REPRESENTED BY ITS SECRETARY, INDU T. 8 KUTTIPPURAM SERVICE CO-OPERATIVE BANK LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 19 NO.M-729, P.O.KUTTIPPURAM, MALAPPURAM DISTRICT, PIN - 679 517, REPRESENTED BY ITS SECRETARY ABDUL RASHEED K.K. 9 OZHUR SERVICE CO-OPERATIVE BANK LTD. NO.F 1586, P.O.OZHUR, TANALUR, MALAPPURAM DISTRICT, PIN - 676307, REPRESENTED BY ITS SECRETARY PADMAJA E. 10 THE PERUMANNA KLARI SERVICE CO-OPERATIVE BANK LTD. NO.F-770, P.O.KUTTIPPALA, MALAPPURAM DISTRICT, PIN - 676 501, REPRESENTED BY ITS SECRETARY IN -CHARGE MUHAMMAD HANEEK. 11 THALAKKAD SERVICE CO-OPERATIVE BANK LTD. NO.4391, P.O.VENGALUR, MALAPPURAM DISTRICT, PIN - 676 102, REPRESENTED BY ITS SECRETARY-IN-CHARGE BEENA A. 12 THE KALPAKANCHERY SERVICE CO-OPERATIVE BANK LTD. NO.1808, P.O.KALPAKANCHERY, MALAPPURAM DISTRICT, PIN - 676 551, REPRESENTED BY ITS SECRETARY P.KADIYAMAKUTTY. 13 THE PONMUNDAM SERVICE CO-OPERATIVE BANK LTD. NO.10820, P.O.PONMUNDAM, TIRUR, MALAPPURAM DISTRICT, PIN - 676 106, REPRESENTED BY ITS SECRETARY T.P.BAHANUVUDHEEN. 14 VETTOM SERVICE CO-OPERATIVE BANK LTD. NO.1823, P.O.VETTOM, MALAPPURAM DISTRICT, PIN - 676 102, REPRESENTED BY ITS SECRETARY DAM KUMAR P.R. 15 TRIPRANGODE SERVICE CO-OPERATIVE BANK LTD. NO.1890, P.O.ALATHIYUR, MALAPPURAM DISTRICT, PIN - 676 102, REPRESENTED BY ITS SECRETARY-IN-CHARGE, A.SIVADASAN. 16 NIRAMARUTHUR SERVICE CO-OPERATIVE BANK LTD. NO.M.612, P.O.NIRAMARUTHUR, MALAPPURAM DISTRICT, PIN - 676 109, REPRESENTED BY ITS SECRETARY CHANDRAN V.K. 17 THE PONANI SERVICE CO-OPERATIVE BANK LTD. NO.4841, P.O.PONNANI, MALAPPURAM DISTRICT, PIN - 679 577, REPRESENTED BY ITS SECRETARY JIJI K.P. 2025:KER W.P(C)No.7053/2023 & Connected cases 20 18 KANMANAM SERVICE CO-OPERATIVE BANK LTD. NO.10585, P.O.KANMANAM, MALAPPURAM DISTRICT, PIN - 676 5651, REPRESENTED BY ITS SECRETARY MOHAMMED BASHEER V.M. 19 PURATHUR SERVICE CO-OPERATIVE BANK LTD. NO.1902, P.O.PURATHUR, TIRUR, MALAPPURAM DISTRICT, PIN - 676 102, REPRESENTED BY ITS SECRETARY-IN- CHARGE, MALLIKA M. 20 VADAKKUMPURAM SERVICE CO-OPERATIVE BANK LTD. NO.F 1505, P.O.EDAYUR NORTH VALANCHERY, MALAPPURAM DISTRICT, PIN - 676 552, REPRESENTED BY ITS SECRETARY VINOD V. 21 THE VALAVANNUR SERVICE CO-OPERATIVE BANK LTD. NO.D 1959, P.O.VALAVANNUR, MALAPPURAM DISTRICT, PIN - 676 551, REPRESENTED BY ITS SECRETARY YOOSAF KALLEKY. 22 KALADY GRAMA PANCHAYATH SERVICE CO-OPERATIVE BANK LTD. NO.M 783, P.O.KADANCHERY, MALAPPURAM DISTRICT, PIN - 676 552, REPRESENTED BY ITS SECRETARY SAKHIL P. 23 THAVANUR SERVICE CO-OPERATIVE BANK LTD. NO.P 516, P.O.AYANKALAM, MALAPPURAM DISTRICT, PIN - 679 573,REPRESENTED BY ITS SECRETARY P.MURALEEDHARAN. 24 TANALLUR SERVICE CO-OPERATIVE BANK LTD. NO.M-2, P.O.TANALUR, MALAPPURAM DISTRICT, PIN - 676 307, REPRESENTED BY ITS SECRETARY-IN-CHARGE, SAJEEV P.K. 25 IRIMBILIYAM SERVICE CO-OPERATIVE BANK LTD. NO.10445, P.O.IRIMBILIYAM, MALAPPURAM DISTRICT, PIN - 679 572, REPRESENTED BY ITS SECRETARY P.M.BALACHANDRAN. 26 ATHAVANAD SERVICE CO-OPERATIVE BANK LTD. NO.D 1933, P.O.KARIPPOL, MALAPPURAM DISTRICT, PIN - 676 552, REPRESENTED BY ITS SECRETARY MOHAMMAD HARIS K.K. 2025:KER W.P(C)No.7053/2023 & Connected cases 21 BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 11000. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX OFFICER, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O., MALAPPURAM DISTRICT, PIN - 676 101. 4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD. HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN - 676 505 REPRESENTED BY ITS GENERAL MANAGER. 5 MANJERI CO-OPERATIVE URBAN BANK LTD. MANJERI, TIRUR MALAPPURAM DISTRICT, PIN - 676 121, REPRESENTED BY ITS GENERAL MANAGER. 6 PONANI CO-OPERATIVE URBAN BANK LTD. HEAD OFFICE, K.K.JUNCTION, PONNANI, MALAPPURAM DISTRICT, KERALA, PINCODE - 691 001, REPRESENTED BY ITS GENERAL MANAGER. 7 URBAN CO-OPERATIVE BANK PERINTHALMANNA HEAD OFFICE, PERINTHALMANNA P.O., PIN - 679 322, REPRESENTED BY ITS GENERAL MANAGER. 8 TIRUR URBAN CO-OPERATIVE BANK LTD. HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA - 676 101, REPRESENTED BY ITS GENERAL MANAGER. 9 KOTTAKKAL CO-OP URBAN BANK LTD. KOTTAKKAL P.O., MALAPPURAM, PIN - 676 503, REPRESENTED BY ITS GENERAL MANAGER. 10 KERALA STATE CO-OPERATIVE BANK 2025:KER W.P(C)No.7053/2023 & Connected cases 22 KOZHIKODE BRANCH, DOWN HILL, PIN - 676 505, REPRESENTED BY ITS GENERAL MANAGER. 11 KERALA STATE CO-OPERATIVE BANK LTD. MALAPPURAM BRANCH, PARRY SHOPPING COMPLEX, KOTTAPADI, DOWN HILL P.O., MALAPPURAM DISTRICT - 676 505. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.ESM.KABEER SHRI.K.VIDYASAGAR SHRI.D.SOMASUNDARAM SMT.JAYASREE K.P. SRI.DEVAPRASANTH.P.J. SHRI.JOHN JOSEPH SRI.CHRISTOPHER ABRAHAM SRI.GILBERT GEORGE CORREYA THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 23 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 732 OF 2022 PETITIONER/S: 1 THE POTHUKAL AGRICULTURAL IMPROVEMENT , CO-OPERATIVE SOCIETY LTD. NO. M 930, NATTUKULAM, MALAPPURAM DISTRICT-679234, REPRESENTED BY ITS SECRETARY. 2 THE VAZHIKADAVU AGRICULTURAL IMPROVEMENT, CO-OPERATIVE SOCIETY LIMITED NO. M-899, VAZHIKADAVU, MALAPPURAM DISTRICT-679233, REPRESENTED BY ITS SECRETARY. 3 THE KALIKAVU RURAL CO-OPERATIVE SOCIETY LIMITED M 980, KALIKAVU, MALAPPURAM DISTRICT-676525, REPRESENTED BY ITS SECRETARY. 4 THE WANDOOR CO-OPERATIVE RURAL BANK LIMITED NO. M 674, WANDOOR P.O., MALAPPURAM DISTRICT-679328, REPRESENTED BY ITS SECRETARY. 5 THE KARAPPURAM VANITHA SAHAKARANA SANGHAM, LIMITED NO. M 698, KARAPPURAM P.O., MALAPPURAM DISTRICT-679331, REPRESENTED BY ITS SECRETARY. 6 THE ERUMAMUNDA RURAL CO-OPERATIVE SANGHAM, LIMITED NO. M 742, ERUMAMUNDA P.O., MALAPPURAM DISTRICT-679334, REPRESENTED BY ITS SECRETARY. 7 THE INDIRAJI VANITHA CO-OPERATIVE SOCIETY, LIMITED NO. M 923, KARULAI, KINATTINGAL, MALAPPURAM DISTRICT-679331, REPRESENTED BY ITS SECRETARY. 2025:KER W.P(C)No.7053/2023 & Connected cases 24 8 THEEDAKKARA AGRICULTURAL IMPROVEMENT CO-OPERATIVE, SOCIETY LIMITED NO. M 978, EDAKKARA P.O., MALAPPURAM DISTRICT-679331, REPRESENTED BY ITS SECRETARY. 9 THE CHUNGATHARA AGRICULTURAL IMPROVEMENT, CO-OPERATIVE SOCIETY LIMITED NO. M 969, CHUNGATHARA, MALAPPURAM DISTRICT-679334, REPRESENTED BY ITS SECRETARY. 10 THE NILAMBUR TALUK SERVICE PENSIONER'S, SAHAKARANA SANGHAM LIMITED NO. M 629, CHUNGATHARA P.O., MALAPPURAM DISTRICT-679329, REPRESENTED BY ITS SECRETARY. 11 THE WANDOOR PANCHAYATH VANITHA SAHAKARANA, SANGHAM LIMITED NO. M 585, WANDOOR P.O., MALAPPURAM DISTRICT-679328, REPRESENTED BY ITS SECRETARY. 12 THE NILAMBUR CO-OPERATIVE AGRICULTURAL MARKETING AND PROCESSING SOCIETY LIMITED M 296, NILAMBUR, MALAPPURAM DISTRICT-679330, REPRESENTED BY ITS SECRETARY. 13 THE WANDOOR AGRICULTURAL IMPROVEMENT, CO-OPERATIVE SOCIETY LIMITED NO. M-882, WANDOOR, MALAPPURAM DISTRICT-679328, REPRESENTED BY ITS SECRETARY. 14 THE NALLAMATHANNI VANITHA CO-OPERATIVE SOCIETY, LIMITED NO. M 734, PULLIYIL, NALLAMTANNI P.O., MALAPPURAM DISTRICT-679321, REPRESENTED BY ITS SECRETARY. 15 THE KALKKULAM VANITHA SAHAKARANA SANGHAM, LIMITED NO. M 724, KARAPPURAM P.O., MALAPPURAM DISTRICT-679323, REPRESENTED BY ITS SECRETARY. 16 THE MALAPPURAM DISTRICT CO-OPERATIVE MOTOR, VEHICLES LIMITED NO. M 12, MALAPPURAM P.O., MALAPPURAM DISTRICT-676507, REPRESENTED BY ITS SECRETARY. 17 THE BANK EMPLOYEES CO-OPERATIVE SOCIETY, 2025:KER W.P(C)No.7053/2023 & Connected cases 25 LIMITED NO. M 269, MALAPPURAM P.O., MALAPPURAM DISTRICT-673329, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER (TDS), AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE- 673001. 4 THE MALAPPURAM DISTRICT CO-OPERATIVE, BANK LIMITED, DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN- 676505. 5 THE KERALA STATE CO-OPERATIVE BANK LIMITED, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. 6 THE KOTTAKKAL URBAN CO-OPERATIVE LIMITED, KOTTAKKAL, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN-676501. 7 THE URBAN CO-OPERATIVE BANK LIMITED, PERINTHALMANNA, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN-679321. 8 THE NILAMBUR CO-OPERATIVE URBAN LIMITED NILAMBUR, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN-676542. 9 THE MANJERI CO-OPERATIVE URBAN BANK LIMITED, 2025:KER W.P(C)No.7053/2023 & Connected cases 26 MANJERI, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN-676121. 10 THE TIRUR URBAN CO-OPERATIVE LIMITED, TIRUR, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN-676101. 11 THE PONNANI CO-OPERATIVE URBAN BANK LIMITED, PONNANI, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN-679577. BY ADVS. SHRI.A.K.HARIDAS, CGC SRI.GILBERT GEORGE CORREYA SRI.K.M.SATHYANATHA MENON SHRI.K.VIDYASAGAR SHRI.D.SOMASUNDARAM SMT.KAVERY S THAMPI THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 27 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 736 OF 2022 PETITIONER/S: 1 PONMUNDAM CO-OPERATIVE URBAN SOCIETY LTD. NO. M 637, VAILATHUR, PONMUNDAM P.O., MALAPPURAM DISTRICT, PIN-676106, REPRESENTED BY ITS SECRETARY A.P. SASIKUMAR. 2 KADUNGATHUKUND RURAL CO-OPERATIVE SOCIETY LIMITED NO. M 996, KADUNGATHUKUND, KALPAKANCHERY P.O., MALAPPURAM DISTRICT-676551, REPRESENTED BY ITS SECRETARY MASHHURA KOLLAM THODI. 3 PONNANI TALUK MERCANTILE CO-OPERATIVE SOCIETY LIMITED NO. M.765. C.R. TOWER, EDAPPAL P.O., MALAPPURAM DISTRICT, PIN-679576, REPRESENTED BY ITS SECRETARY, SUJITH S. 4 PONNANI TALUK SCHOOL TEACHERS CO-OPERATIVE SOCIETY LIMITED NO. M 500, PONNANI P.O., PONNANI SOUTH, MALAPPURAM DISTRICT-679586, REPRESENTED BY ITS SECRETARY SINDHU P. PALLANGHATT. 5 PONNANI VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M 715, PONNANI P.O., MALAPPURAM DISTRICT-679577, REPRESENTED BY ITS SECRETARY KAVITHA P. 6 THE PONNANI TALUK URBAN CO-OPERATIVE SOCIETY LIMITED NO. M 945, ERIKKAMANNA, PONNANI P.O., MALAPPURAM DISTRICT-679577, REPRESENTED BY ITS SECRETARY SMITHA. 7 KALADI GRAMA PANCHAYATH RURAL CO-OPERATIVE SOCIETY M -905 10, P.O. NARIPARAMBA, MALAPPURAM DISTRICT-679573, REPRESENTED BY ITS SECRETARY RATHI 2025:KER W.P(C)No.7053/2023 & Connected cases 28 K. 8 THAVANOOR VANITHA CO-OPERATIVE SOCIETY LIMITED NO. M 736, ATHALOOR P.O., MALAPPURAM DISTRICT-679573, REPRESENTED BY ITS SECRETARY RAJITHA E. 9 THENHIPPALAM PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LIMITED NO. 856, KOHINOOR P.O., CALICUT UNIVERSITY, MALAPPURAM DISTRICT-673636, REPRESENTED BY ITS SECRETARY BINSI P. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI- 682018. 3 THE INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O., MALAPPURAM DISTRICT-676101. 4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LIMITED, HEAD OFFICE, MANJERI ROAD, MALAPPURAM-676505, REPRESENTED BY ITS GENERAL MANAGER. 5 MANJERI CO-OPERATIVE URBAN BANK LIMITED, MANJERI, TIRUR, MALAPPURAM DISTRICT-676121, REPRESENTED BY ITS GENERAL MANAGER. 6 PONANI CO-OPERATIVE URBAN BANK LIMITED, 2025:KER W.P(C)No.7053/2023 & Connected cases 29 HEAD OFFICE, K.K. JUNCTION, PONNANI, MALAPPURAM DISTRICT, KERALA -691001, REPRESENTED BY ITS GENERAL MANAGER. 7 TIRUR URBAN CO-OPERATIVE BANK LIMITED, HEAD OFFICE, TIRUR, MALAPPURAM DISTRICT, KERALA- 676101, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. SHRI.JOSEPH RONY JOSE, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.GILBERT GEORGE CORREYA SRI.SHOBY K.FRANCIS SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 30 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 833 OF 2022 PETITIONER/S: THE ELAMKULAM SERVICE CO-OPERATIVE BANK LTD NO.F 1536, KUNNAKAVU P.O., MALAPPURAM DISTRICT-679 323, REPRESENTED BY ITS SECRETARY BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM,PIN-682 018 3 THE INCOME TAX OFFICER (TDS), AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE,PIN-673 001 4 THE MALAPPUAM DITRICT CO-OPERATIVE BANK LTD, DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER,PIN-676 505 5 THE KERALA STATE CO-OPERAIVE BANK LTD, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033 2025:KER W.P(C)No.7053/2023 & Connected cases 31 6 THE URBAN CO-OPERATIVE BANK LTD., PERINTHALMANNA, MALAPPURAM DISTRICT,REPRESENTED BY ITS GENERAL MANAGER, PIN-679 321 BY ADVS. SHRI.VISHNU PRADEEP, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.GILBERT GEORGE CORREYA SMT.JAYASREE K.P. SHRI.JOHN JOSEPH SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 32 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 1383 OF 2022 PETITIONER/S: 1 NILAMBUR TALUK CO-OPERATIVE EDUCATIONAL SOCIETY LTD. NO.M 556 NILAMBUR P. O., MALAPPURAM DISTRICT, PIN - 679 329, REPRESENTED BY ITS SECRETARY. 2 THE NILAMBUR KALIKAVU RANGE KALLU X 3 THE KARUVARAKUNDU PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LIMITED M.601 KIZHEKKETHALA P. O., THARIS, MALAPPURAM DISTRICT, PIN - 676 519, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I. S. PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE, PIN - 673 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 33 4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD. DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN - 676 505. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 6 THE URBAN CO-OPERATIVE BANK LTD. PERINTHALMANNA, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN - 679 321. 7 THE NILAMBUR CO-OPERATIVE URBAN LTD. NILAMBUR, MALAPPURAM DISTRICT, REPRESENTED BY ITS GENERAL MANAGER, PIN - 676 542. BY ADV SHRI.VISHNU RAJAGOPAL, CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 34 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 1633 OF 2022 PETITIONER/S: 1 KURUMBATHUR SERVICE CO-OPERATIVE BANK LTD NO. F-1769, PUNNATHALA P.O, CHUNGAM, VALANCHERY, MALAPPURAM DISTRICT, PIN 676 552 REPRESENTED BY ITS SECRETARY IN CHARGE MOHAMMED SALEEM 2 ERANAND TALUK CO-OPERATIVE EDUCATIONAL SOCIETY LTD NO. M-311 MANJERY P.O, MALAPPURAM DISTRICT, PIN 676 121 REPRESENTGED BY ITS SECRETARY JOB THOMAS M 3 ERANAD RURAL CO-OPERATIVE SOCIETY LTD NO. M 808, MANJERY P.O, MALAPPURAM DISTRICT PIN 676 121 REPRESENTED BY ITS SECRETARY SHEEJA P 4 THE PARAPPUR VANITHA CO-OPERATIVE SOCIETY LTD NO. M 712 PARAPPUR P.O, VEENALUKKAL, MALAPPURAM DISTRICT, PIN 676 503 REPRESENTED BY ITS SECRETARY K.K JAMEELA 5 KOTTAKKAL AYURVEDA COLLEGE EMPLOYEES CO-OPERATIVE SOCIETY LTD NO. M 479 EDARIKODE P.O, MALAPPURAM DISTRICT PIN 676 501 REPRESENTED BY ITS SECRETARY SRUTHI K 6 MANJERI MALAPPURAM RANGE KALLUCHETHU VYAVASAYA CO- OPERATIVE SOCIETY LTD NO. M 615 MANJERI P.O, MALAPPURAM (D) PIN 676 121 REPRESENTING ITS SECRETARY BINEESH E.V 2025:KER W.P(C)No.7053/2023 & Connected cases 35 BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THHE GOVERNMENT , MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE COMMISSIOENR OF INCOME TAX (TDS) CENTRAL REVENUE BLDG. IS PRESS ROAD, KOCHI 682 018 3 THE INCOME TAX OFFICER (TDS) INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O, MALAPPURAM DISTRICT PIN 676 101 4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN 676 505 REPRESENTED BY ITS GENERAL MANAGER BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.GILBERT GEORGE CORREYA SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 36 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 1808 OF 2022 PETITIONER/S: EDAKKARA RURAL CO OPERATIVE SOCIETY LTD. NO.M 759, NILAMBUR TALUK, P O EDAKKARA MALAPPURAM DISTRICT, PIN-679331., REPRESENTED BY ITS SECRETARY. BY ADVS. SHRI.K.J.MANU RAJ SHRI.RAVI KRISHNAN SMT.K.VINAYA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER (TDS) AYAKAR BHAVAN, NORTH BLOCK, MAMAMCHIRA, KOZHIKODE- 673001. 4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD DISTRICT CO-OPERATIVE BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER-676505. 5 THE KERALA STATE CO-OPERATIVE BANK LTD COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR-695033. 6 THE NILAMBUR CO-OPERATIVE URBAN BANK. NO.F.1043, HEAD OFFICE NILAMBUR, MALAPPURAM DISTRICT- 679329., REPRESENTED BY ITS GENERAL MANAGER. 2025:KER W.P(C)No.7053/2023 & Connected cases 37 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.P.J.DEVAPRASANTH,SC,NILAMBUR CO.OP SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 38 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 1943 OF 2022 PETITIONER/S: THE KUMARANALLUR CO-OPERATIVE SERVICE BANK LTD. F.970, KUMARANALLUR P.O., PALAKKAD DISTRICT, REPRESENTED BY ITS SECRETARY, PIN-679 552 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS)CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,PIN-682 018 3 THE INCOME TAX OFFICER (TDS),AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE,PIN-673 001 4 THE MALAPPURAM DISTRICT CO-OPERTIVE BANK LTD,. DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESENTED BY ITS GENERAL MANGER, PIN-676 505 5 THE PONNANI URBAN CO-OPERATIVE BANK LTD,PONNANI, MALAPPURAM DISTRICT REPRESENTED BY ITS GENERAL MANAGE, PIN-676 505 6 THE KERALA STATE CO-OPERATIVE BANK LTD.,COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033 BY ADVS. SHRI.P.R.AJITH KUMAR, CGC SRI.SHOBY K.FRANCIS THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 39 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 2208 OF 2022 PETITIONER/S: THE PERINTALMANNA TALUK CO-OPERATIVE EDUCATIONAL SOCIETY LTD.NO M 358, PERINTALMANNA, MALAPPURAM DISTRICT, PIN-679 321, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA,REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM, PIN-682 018. 3 THE INCOME TAX OFFICER (TDS), AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE, PIN-673 001. 4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM, REPRESNETED BY ITS GENERAL MANAGER, PIN-676 505. 5 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033. BY ADV SHRI.VISHNU PRADEEP THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 40 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 2780 OF 2022 PETITIONER/S: MALAPPURAM VANITHA CO-OPERATIVE SOCIETY LTD NO.M-789 JUBILEE ROAD, MALAPPURAM P.O, MALAPPURAM DISTRICT, PIN 676 505 REPRESENTED BY ITS SECRETARY SHAHARBAN PULLIYIL BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT , MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018 3 THE INCOME TAX OFFICER (TDS) INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O, MALAPPURAM DISTRICT, PIN 676 101 4 MALAPPURAM DISTRICT CO-OPERATIVE SOCIETY LTD, HEAD OFFICE, MANJERI, ROAD, MALAPPURAM, PIN 676 505, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. SHRI.P.R.AJITH KUMAR, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 41 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 3734 OF 2022 PETITIONER/S: 1 SREE VELLAYANI RESIDENTIAL WELFARE CO-OPERATIVE SOCIETY LTD. NO.T-1591, OOKKODE, REPRESENTED BY ITS SECRETARY. 2 UPANIYOOR GRAMODHARANA CO-OPERATIVE SOCIETY LTD. NO.2782, OOKKODE P.O., NEMOM, PIN-695020, REPRESENTED BY ITS SECRETARY. 3 SREE VELLAYANI AGRICULTURE IMPROVEMENT CO-OPERATIVE SOCIETY LTD. T. NO.1728, SANTHIVILLA MARKET JUNCTION, NEMOM P.O., THIRUVANANTHAPURAM, REPRESENTED BY ITS SECRETARY. 4 COLLECTION AGENTS CO-OPERATIVE SOCIETY LTD. T. NO.1671, T.C.71/2766 (3), R D SQUARE, KILLIPALLAM, CHALAI P.O., THIRUVANANTHAPURAM, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.A.CHANDRA BABU SMT.REMYA MURALI SMT.APARNA SARASWATI RESPONDENT/S: 2025:KER W.P(C)No.7053/2023 & Connected cases 42 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILLS, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER, (TDS), AAYAKAR BHAVAN, PEROORKADA RD., KOWDIAR, THIRUVANANTHAPURAM, KERALA-695003. 4 THE KERALA STATE CO-OPERATIVE BANK, REGIONAL OFFICE, EAST FORT, FORT P.O., THIRUVANANTHAPURAM. 5 THE KERALA STATE CO-OPERATIVE BANK, KALLIYOOR BRANCH, KALLIYOOR P.O., THIRUVANANTHAPURAM. 6 THE KERALA STATE CO-OPERATIVE BANK, CHALAI BRANCH, EAST FORT, FORT P.O., THIRUVANANTHAPURAM. BY ADVS. SRI.NAVANEETH.N.NATH CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 43 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 4385 OF 2022 PETITIONER/S: KOLLAM NORTH RESIDENCE WELFARE CO-OPERATIVE SOCIETY LTD.NO.Q 1537 REPRESENTED BY ITS SECRETARY, KADAVOOR, PERINAD P.O., KOLLAM DISTRICT, PIN-691601. BY ADVS. SHRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 INCOME TAX OFFICER WARD-2, AAYAKAR BHAVAN, INCOME TAX OFFICE, NEAR KARBALA JUNCTION, KOLLAM, PIN-691001. 2 THE ADDITIONAL COMMISSIONER OF INCOME TAX, OFFICE OF THE ADDL. COMMISSIONER OF INCOME TAX, TDS RANGE, II FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O., THIRUVANANTHAPURAM, PIN-695003. 3 THE CENTRAL BOARD OF DIRECTOR TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110001. 4 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, 2025:KER W.P(C)No.7053/2023 & Connected cases 44 MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI-110001. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM-695001. 6 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695001. 7 THE KERALA STATE CO-OPERATIVE BANK (ERSTWHILE KOLLAM DISTRICT CO-OPERATIVE BANK), REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695033. BY ADVS. SRI.CHRISTOPHER ABRAHAM SHRI.NAVANEETH.N.NATH, CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 45 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 4442 OF 2022 PETITIONER/S: AVANAKUZHY SERVICE CO-OPERATIVE BANK LTD. NO.2387, HEAD OFFICE, THANNIMMOODU P. O., AVANAKUZHI, THIRUVANANTHAPURAM - 695501, REPRESNETED BY ITS SECRETARY JAYASREE P. S. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX 2025:KER W.P(C)No.7053/2023 & Connected cases 46 KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695003. 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. SRI.NAVANEETH.N.NATH CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 47 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 4996 OF 2022 PETITIONER/S: PERUMBADAPPU BLOCK PANCHAYATH COCONUT PROCESSING AND MARKETING CO-OPERATIVE SOCIETY NO.M.628, REP. BY ITS SECRETARY, ERAMANGALAM, MALAPPURAM - 679 579 BY ADV SRI.S.MOHAMMED AL RAFI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI-682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003. 5 INCOME TAX OFFICER (TDS) 2025:KER W.P(C)No.7053/2023 & Connected cases 48 THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695 003. 6 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD. REPRESENTED BY ITS GENERAL MANAGER, MALAPPURAM - 676 505. 7 THE SENIOR MANAGER MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD., ERAMANGALAM BRANCH, MALAPPURAM - 679 579 8 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. SHRI.NAVANEETH.N.NATH, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 49 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 5569 OF 2022 PETITIONER/S: THE KERALA STATE CO-OPERATIVE BANK LTD., REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033. BY ADV SHRI.B.G.HARINDRANATH (SR.) RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY, MINISTRY OF FINANCE, NORTH BLOCK, RAISENA HILL, NEW DELHI-110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), AYAKAR BHAVAN KOWDIAR, THIRUVANANTHAPURAM-695 003. BY ADV SRI.NAVANEETH.N.NATH THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 50 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 5900 OF 2022 PETITIONER/S: 1 MOONNIYUR PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD.NO.M.992 P.O. CHELARI, VELIMUKKU P.O, MALAPPURAM (DT), PIN - 676317, REPRESENTED BY ITS SECRETARY NEETHU DAS M. 2 ANAKKAYAM RURAL CO-OPERATIVE SOCIETY LTD, NO.M.816, ANAKKAYAM P.O, MALAPPURAM (DT), PIN - 676317, REPRESENTED BY ITS SECRETARY DHANYA K.C. 3 MANJERI MUNICIPAL VANITHA SAHAKARANA SANGAM LTD.NO. M.519. COURT ROAD, MANJERI P.O, MALAPPURAM DISTRICT, PIN - 676121, REPRESENTED BY ITS SECRETARY USHAKUMARI C.K. 4 MALAPPURAM DISTRICT BUILDING & OTHER CONSTRUCTION WORKERS CONTRACT CO-OPERATIVE SOCIETY LTD, NO.M 772, UP HILL, MALAPPURAM P.O, PIN - 676505, REPRESENTED BY SECRETARY SHEENA M. 5 MALAPPURAM DISTRICT. ANGANWADI WORKERS & HELPERS CO- OPERATIVE SOCIETY LTD NO.M. 756. MALAPPURAM P.O, PIN - 676505, REPRESENTED BY ITS SECRETARY, NAFEESA C. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. 2025:KER W.P(C)No.7053/2023 & Connected cases 51 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI - 682018. 3 THE INCOME TAX OFFICER(TDS) INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O, MALAPPURAM DISTRICT, PIN - 676101. 4 MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD, HEAD OFFICE, MANJERI ROAD, MALAPPURAM, PIN - 676505, REPRESENTED BY ITS GENERAL MANAGER. 5 CO-OPERATIVE URBAN BANK LTD NO. 1758, PERINTHALMANNA, PERINTHALMANNA P.O, PIN - 679322, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.GILBERT GEORGE CORREYA SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 52 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 8026 OF 2022 PETITIONER/S: 1 PAYYANNUR CO-OPERATIVE RURAL BANK LTD NO.F1234, HEAD OFFICE PAYYANNUR, PAYYANNUR P. O., KANNUR - 670307, REPRESENTED BY ITS SECRETARY RAJAN E. 2 PAPPINISSERI CO-OPERATIVE RURAL BANK LTD. NO.F 1321 KALLIASSERI P. O., KALLIASSERI, KANNUR - 670562., REPRESENTED BY ITS SECRETARY AMBUJAKSHI K. 3 MADAYI CO-OPERATIVE RURAL BANK LTD. HEAD OFFICE, PAYANGADI, PAYANGADI P. O., KANNUR - 670303., REPRESENTED BY ITS SECRETARY P. VIMALA. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH 2025:KER W.P(C)No.7053/2023 & Connected cases 53 BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI - 682018. 4 PRINCIPAL COMMISSIONER OF INCOME OF TAX KOZHIKODE, AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE - 673001. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. P. B. NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY(CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 54 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 8742 OF 2022 PETITIONER/S: CHERUTHAZHAM SERVICE CO-OPERATIVE BANK LTD. NO. F 747, HO PILATHARA, P.O. PILATHARA, KANNUR- 670504, REPRESENTED BY ITS SECRETARY, DAMODARAN K BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTER OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTER OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 55 INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI-682018. 4 THE PRINCIPAL COMMISSIONER OF CENTRAL TAX, KOZHIKODE, AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE- 673001. 5 INCOME TAX OFFICER, TDS, WARD TDS, KANNUR, AYAKAR BHAVAN, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, KANNOTHUMCHAL, CHOVVA P.O., KANNUR-670006. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. BY ADVS. SMT.STINNIE JOHN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 56 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 8943 OF 2023 PETITIONER/S: VENGANOOR SERVICE CO-OPERATIVE BANK LTD, NO 1446, VENGANOOR P.O., THIRUVANANTHAPURAM- REPRESENTED BY ITS SECRETARY BIMIL KUMAR S A, PIN - 695523 BY ADVS. DR.K.P.PRADEEP SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SHRI.HAREESH M.R. SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX 2025:KER W.P(C)No.7053/2023 & Connected cases 57 KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN - 682018 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM, PIN - 695003 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003 6 THE KERALA STATE CO-OPERATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 58 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10465 OF 2022 PETITIONER/S: 1 PALODE SERVICE CO-OPERATIVE BANK LTD NO 792, CO-OPERATIVE BUILDING, PALODE KARIMANCODE, THIRUVANANTHAPURAM 695 562 REPRESENTED BY ITS SECRETARY, REKHA V.O 2 UZHAMALACKAL SERVICE CO-OPERATIVE BANK LTD NO. T 298, PUTHUKULANGARA P.O, THIRUVANANTHAPURAM, 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 4 MUNDELA SERVICE CO-OPERATIVE BANK LIMITED NO 2433, MUNDELA P.O, THIRUVANANTHAPURAM 695 543 REPRESENTED BY ITS SECRETARY RAHUL P.S BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 59 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM 695 003 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM , 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANNATHAPURAM 695 003 6 THE KERALA STATE CO-OPERATIVE BANK LTD. P.B NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 60 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10480 OF 2022 PETITIONER/S: 1 KAZHAKUTTOM SERVICE CO-OPERATIVE BANK LTD. NO. 1457 KAZHAKUTTOM P.O, THIRUVANANTHAPURAM 695 582 REPRESENTED BY ITS SECRETARY ANIL KUMAR S 2 AKKULAM CO-OPERATIVE SOCIETY LTD NOT 1213, THURUVICAL P.O, THIRUVANANTHAPURAM 695 011 REPRESENTED BY ITS SECRETARY LATHAKUMARI S BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 REPRESENTED 2025:KER W.P(C)No.7053/2023 & Connected cases 61 BY ITS CHAIRMAN 3 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 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM 695 003 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001 BY ADVS. SHRI.VISHNU PRADEEP, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 62 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10498 OF 2022 PETITIONER/S: 1 THIRUVANANTHAPURAM DISTRICT ELECTRICITY BOARD EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.3039, POWER HOUSE, CHALA P O, THIURVANANTHAPURAM-695036, REPRESENTED BY ITS SECRETARY. 2 KERALA STATE TRANSPORT WORKERS CO-OPERATIVE SOCIETY LTD NO.RT.133. S S KOVIL ROAD, THAMPANOOR, THIRUVANANTHAPURAM- 695001, REPRESENTED BY ITS SECRETARY. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 2 THE COMMISSIONR OF INCOME TAX (TDS_ C R BUILDING, I S PRESS ROAD, KOCHI-682018. 3 THE COMMISSIONER TAX OFFICER (TDS) 3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 4 THE INCOME TAX OFFICER (TDS_ 3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 2025:KER W.P(C)No.7053/2023 & Connected cases 63 5 KERALA STATE CO-OPERATIVE BANK LTD., (KERALA BANK), REGIONAL OFFICE, EAST FORT P O, THIRUVANANTHAPURAM-695023, REPRESENTED BY ITS REGIONAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 64 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10692 OF 2022 PETITIONER/S: THE PAPPINIVATTAM SERVICE CO-OPERATIVE BANK LTD. NO. R.309, P.O. MATHILAKAM, KODUNGALLUR, THRISSUR DISTRICT, 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- 682018. 2 THE INCOME TAX OFFICER (TDS), INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR- 680001. 3 THE KERALA STATE CO-OPERATIVE BANK LIMITED, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. 4 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LIMITED, S.N. PURAM, THRISSUR-680665. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 65 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10697 OF 2022 PETITIONER/S: THE KALAMASSERY SERVICE CO-OPERATIVE BANK LTD NO E 661, KODUVAZHANGA, NEERICODE P.O, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY PIN 683 511 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM, PIN 682 018 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, I.S PRESS ROAD, ERNAKULAM PIN 682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033 5 THE MANAGER KERALA STATE CO-OPERATIVE BANK LTD, KALAMASSERY, PATHADIPALAM BRANCH, ERNAKULAM, PIN 683104 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 66 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 67 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10699 OF 2022 PETITIONER/S: THE PARUR TALUK CO-OPERATIVE EMPLOYEES' CO-OPERATIVE SOCIETY LTD NO.K.736, NORTH PARUR, ERNAKULAM DISTRICT, REPRESENTED BY ITS PRESIDENT. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 2 THE INCOME TAX OFFICER (TDS), INCOME TAX DEPARTMENT SHAKTAN NAGAR, THRISSUR-680001. 3 THE KERALA STATE CO-OPERATIVE BANK LIMITED, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. 4 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LIMITED, NORTH APRUR MAIN BRANCH, NORTH PARUR-683513. BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 68 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10705 OF 2022 PETITIONER/S: THE ALANGAD CO-OPERATIVE BANK LTD., NO. E-661 KODUVAZHANGA, NEERICODE P.O., ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY 683 511. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM 682 018. 3 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, I.S. PRESS ROAD, ERNAKULAM 682 018. 4 THE KERALA STATE CO - OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, 695 033 5 THE MANAGER , KERALA STATE CO - OPERATIVE BANK LTD.,ALUVA MAIN BRANCH, ERNAKULAM, 683 101. 2025:KER W.P(C)No.7053/2023 & Connected cases 69 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 70 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10717 OF 2022 PETITIONER/S: 1 BALARAMAPURAM SERVICE CO-OPERATIVE BANK LTD T/14 BALARAMAPURAM, THIRUVANANTHAPURAM - 695 501, REPRESENTED BY ITS SECRETARY JAFERKHAN A. 2 PATTOM SERVICE CO-OPERATIVE BANK LTD.NO.T.1318 MEDICAL COLLEGE, KANNAMMOOLA P.O., TRIVANDRUM - 695 011, REPRESENTED BY ITS SECRETARY SREEJI S. 3 MUTTATHARA SERVICE CO-OPERATIVE BANK LTD. TC 42/942(1), MUTTATHARA, VALLAKKADAVU P.O., THIRUVANANTHAPOURAM - 695 008 REPRESENTED BY ITS SECRETARY NIRMAL V. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 71 2 THE CENTRAL BOARD OF DIRECTOR TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, 1 S PRESS ROAD, KOCHI - 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003. 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695 003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 72 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10719 OF 2022 PETITIONER/S: 1 KEEZHILLAM SERVICE CO-OPERATIVE BANK LTD.NO.E3989, KEEZHILLAM P.O., ERNAKULAM DISTRICT, PIN-683 541, REPRESENTED BY ITS SECRETARY. 2 PERUMBAVOOR SERVICE CO OPERATIVE BANK LTD.NO.802, VALLAM, RAYONPURAM P.O., ERNAKULAM DISTRICT, PIN-683 543, REPRESENTED BY ITS SECRETARY. 3 AYYAMPUZHA SERVICE CO OPERATIVE BANK LTD.NO.E788, AYYAMPUZHA P/.O., ERNAKULAM DISTRICT, PIN-683 581, REPRESENTED BY ITS SECRETARY. 4 THE CHOWARA SERVICE CO OPERATIVE BANK LTD. NO.587, CHOWARA P.O., ALUVA, ERNAKULAM DISTRICT, PIN-683 571, REPRESENTED BY ITS SECRETARY. 5 SREEMOOLANAGARA SERVICE CO OPERATIVE BANK LTD.NO.4178, SREEMOOLANAGARA P.O., ERNAKULAM DISTRICT, PIN-683 580, REPRESENTED BY ITS SECRETARY. 6 OKKAL AGRICULTURAL IMPROVEMENT SERVICE CO OPERATIVE SOCIETY NO.E 1215, OKKAL P.O., ERNAKULAM DISTRICT, PIN-683 550, REPRESENTED BY ITS SECRETARY. 7 THE KANAJOOR SERVICE CO-OPERATIVE BANK LTD.NO.454, KANJOOR P.O., ALUVA TALUK, ERNAKULAM DISTRICT, PIN- 683 575, REPRESENTED BY ITS SECRETARY. 2025:KER W.P(C)No.7053/2023 & Connected cases 73 8 KARAYAMPARAMBU SERVICE CO OPERATIVE BANK LTD.NO.1573, VALLAM, RAYONPURAM P.O., ERNAKULAM DISTRICT, PIN-683 543, REPRESENTED BY ITS SECRETARY. 9 GOVENRMENT SERVANTS CO-OPERATIVE SOCIETY LTD.NO.131, PERUMBAVOOR P.O., ERNAKULAM DISTRICT, PIN-683 542, REPRESENTED BY ITS HON.SECRETARY. 0 PERUMBAVOOR KSRTC EMPLOYEES CO OPERATIVE SOCIETY LTD.NO.E783, PERUMBAVOOR P.O., ERNAKULAM DISTRICT, PIN-683 542, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.M.M.MONAYE SHRI.M.PAUL VARGHESE RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI, PIN-110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES., ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRPERSON. 3 COMMISSIONER OF INCOME TAX (TDS), C.R.BUILDINGS, I.S PRESS ROAD, ERNAKULAM-682 018. 4 STATE OF KERALA, DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, REPRESENTED BY SECRETARY TO GOVERNMENT. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIEITES, STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM. 2025:KER W.P(C)No.7053/2023 & Connected cases 74 6 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 DEPUTY GENERAL MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., CREDIT PROCESSING CENTRE, KAKKANAD, KOCHI-682 030. BY ADVS. SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 75 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10720 OF 2022 PETITIONER/S: 1 VAZHAKKULAM BLOCK RURAL CO-OPERATIVE SOCIETY LTD E-1082, MEKKAD P.O., ERNAKULAM-683 547, REPRESENTED BY SECRETARY JYOTHIMOL.E.J. 2 KOOVAPPADY BLOCK RURAL CO-OPERATIVE BANK LTD., E-1083, KURUPPAMPADY P.O., ERNAKULAM-683 545, REPRESENTED BY ITS SECRETARY M.Y.ELDHOSE BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 THE CENTRAL BOARD OF DIRECTOR TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, 2025:KER W.P(C)No.7053/2023 & Connected cases 76 REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI-682 018 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 003 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM , 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 003 6 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 77 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10721 OF 2022 PETITIONER/S: THE POOMANGALAM SERVICE CO-OPERATIVE BANK LTD NO.R 712.H.O.ARIPALAM POOMANGALAM, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (T D S) CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM.PIN- 682 018. 2 THE INCOME TAX OFFICER, (T.D.S) INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR, PIN 680 001. 3 THE KERALA STATE CO-OPERATIVE BANKLTD. COBANK TOWERS, PALAYAM,THIRUVANANTHAPURAM,, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033 4 THE MNAGER KERALA STATE CO-OPERATIVE BANK LTD, VELLANGALLUR., THRISSUR, PIN-680 662 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 78 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10722 OF 2022 PETITIONER/S: THE MADAPPALLY SERVICE CO-OPERATIVE BANK LTD NO.160, PERUMPANACHY P.O., CHEGANACHERRY, KOTTAYAM DISTRICT, 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 INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, KOTTAYAM, PIN-686 001 3 TH KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033 4 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., PERUMPANACHY BRANCH, KOTTAYAM DISTRICT, PIN-686 101 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 79 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10731 OF 2022 PETITIONER/S: 1 KURUPAMPADY SERVICE CO-OPERATIVE BANK LTD HEAD OFFICE, P.O.KURUPPAMPADY, ERNAKULAM-683545, REPRESENTED BY ITS SECRETARY JAYAPRAKASH N. 2 KRARIYELY SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, KRARIYELY, KOMBANADU P.O., ERNAKULAM- 683546, REPRESENTED BY ITS SECRETARY M.V.SHAJI. 3 VAZHAKKULAM SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, SOUTH VAZHAKKULAM P.O., ALUVA, ERNAKULAM-683105, REPRESENTED BY ITS SECRETARY RENJINI VASUDEVAN. 4 MALAYIDAMTHURUTH SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, MALAYIDAMTHURUTHU P.O., ERNAKULAM- 683561, REPRESENTED BY ITS SECRETARY IN CHARGE T.A.THANKAPPAN. 5 KODANADU SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, P.O.KODANADU, ERNAKULAM-683544, REPRESENTED BY ITS SECRETARY NEETHU G. KRISHNAN. 6 OKKAL SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, P.O.OKKAL, ERNAKULAM-683550, REPRESENTED BY ITS SECRETARY ANJU T.S. 7 VENGOLA SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, P.O.VENGOLA, ERNAKULAM-683556, REPRESENTED BY ITS SECRETARY SINDHU KUMAR. 2025:KER W.P(C)No.7053/2023 & Connected cases 80 8 MARAMPALLY SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, MARAMPALLY P.O., ERNAKULAM-683105, REPRESENTED BY ITS SECRETARY FATHIMA T.K. 9 ASAMANOOR SERVICE CO-OPERATIVE BANK LTD.NO.317, HEAD OFFICE, ODAKKALI, ASAMANOOR P.O., ERNAKULAM- 683549, REPRESENTED BY SECRETARY KIRAN P. ASHOK. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695003. 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 2025:KER W.P(C)No.7053/2023 & Connected cases 81 6 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 82 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10735 OF 2022 PETITIONER/S: OACHIRA SERVICE CO-OPERATIVE BANK LTD NO.1391, OACHIRA P.O., KOLLAM-690 526, REPRESENTED BY ITS SECRETARY MEERADEVI .V. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 83 INDIA, CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI-682 018 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 002 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 002 6 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY )CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 84 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10738 OF 2022 PETITIONER/S: 1 THE ANNAMANADA SERVICE CO-OPERATIVE BANK LIMITED NO. 159 ANNAMANADA, CHALAKUDY TALUK, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 680 741 2 THE ASHTAMICHIRA SERVICE CO-OPERATIVE BANK LTD NO 325 ASHTAMICHIRA, CHALAKUDY TALUK , THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 680 731 3 THE ANNALLOOR SERVICE CO-OPERATIVE BANK LTD NO. 445 ANNALLOOR, CHALAKUDY TALUK, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 680 731 4 THE IRANIKULAM THIRUMUKKULAM SERVICE CO-OPERATIVE BANK LTD NO. 339, CHALAKUDY TALUK, IRANIKULAM, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 680 734 5 THE POYYA CO-OPERATIVE BANK LTD NO. 812 POOPPATHY, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 680 733 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA NILL, NEW DELHI 110 2025:KER W.P(C)No.7053/2023 & Connected cases 85 001 2 THE COMMISSIONER OF INCOME TAX(TDS) CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM, PIN 682 018 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR PIN 680 001 4 THE KERALA STATE CO-OPERATIVE BANK LTD COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033 5 THE MANAGER KERALA STATE CO-OPERATIVE BANK LTD, MALA, IRINJALAKUDA, THRISSUR PIN 680 732 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 86 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10741 OF 2022 PETITIONER/S: THE KARALAM SERVICE CO-OPERATIVE BANK LTD. NO. 600 KIZHUTHANI, THANISSERY P.O., THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 3 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR, PIN-680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. 5 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., IRINJALAKUDA, THRISSUR, PIN-680662. 2025:KER W.P(C)No.7053/2023 & Connected cases 87 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 88 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10744 OF 2022 PETITIONER/S: PONKUNNAM SERVICE CO-OPERATIVE BANK LTD NO.527 HEAD OFFICE, PONKUNNAM, KOTTAYAM-686 505, REPRESENTED BY ITS SECRETARY GEETHA GOPINATH BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, DEPARTMENT OF REVENUE, MINISTRY OF 2025:KER W.P(C)No.7053/2023 & Connected cases 89 FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 90 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10747 OF 2022 PETITIONER/S: 1 CHIRAKKADAVU SERVICE CO-OPERATIVE BANK LTD NO.2057 HEAD OFFICE, CHIRAKADAVU P.O,KOTTAYAM-686 520, REPRESENTED BY ITS SECRETARY MERCY JOHN. ., 2 ELAMGULAM SERVICE CO OPERATIVE BANK LTD, NO 3576, HEAD OFFICE, KOORALI P.O, KOTTAYAM-686 522, REPRESENTED BY ITS SECRETARY SAJITHA M.P. 3 ELIKULAM SERVICE CO-OPERATIVE BANK LTD, K 158, HEAD OFFICE, MADUKKAKUNNU P.O.KOTTAYAM-686 577, REPRESENTED BY ITS SECRETARY, VIMALKUMAR T.M. 4 KANAMALA SERVICE CO-OPERATIVE BANK LTD, K 268, HEAD OFFICE, ERUTHUAPUZHA, PAMPAVALLEY P.O.KOTTAYAM- 686 510, REPRESENTED BY ITS SECRETARY THARA THOMAS. 5 KANNIMALA SERVICE CO-OPERATIVE BANK LTD NO 3978, HEAD OFFICE, KANNIMALA P.O.ERUMELY KOTTAYAM-686 509. REPRESENTED BY ITS SECRETARY, BINNY M GEAORGE 6 KANJIRAPALLY SERVICE CO-OPERATIVE BANK LTD NO 2061, HEAD OFFICE, KANJIRAPALLY, KOTTAYAM-686 507, REPRESENTED BY ITS SECRETARY, SHAIJU FRANCIS 7 ERUMELY SERVICE CO-OPERATIVE BANK LTD K 113, HEAD OFFICE, ERUMELY P.O.KOTTAYAM-686 509, REPRESENTED BY ITS SECRETARY, ROSHINA IBRAHIM. 8 MUNDAKAYAM SERVICE CO-OPERATIVE BANK LTD K 122, HEAD OFFICE, MUNDAKKAYAM, KOTTAYAM-686 513, 2025:KER W.P(C)No.7053/2023 & Connected cases 91 REPRESENTED BY ITS SECRETARY, MINUMOL BABY. 9 PARATHODE SERVICE CO-OPERATIVE BANK LTD NO 3002, HEAD OFFICE, VELICHIYANI, PARATHODE, P.O.KOTTAYAM-686 512, REPRESENTED BY ITS SECRETARY, REKHAMOL C.R. 0 MANIMALA SERVICE CO-OPERATIVE BANK LTD, K 641, HEAD OFFICE, MANIMALA P.O.KOTTAYAM-686 543, REPRESENTED BY ITS SECRETARY MANJU V.S. 11 KORUTHODU SERVICE CO-OPERATIVE BANK K 365, HEAD OFFICE, KORUTHODU P.O.KANJIRAPALLY, KOTTAYAM-686 513, REPRESENTED BY ITS SECRETARY, BABU MATHEW. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE, BUILDINGS , I.S PRESS ROAD, KOCHI-682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, 2025:KER W.P(C)No.7053/2023 & Connected cases 92 PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. BY ADV SRI.CHRISTOPHER ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 93 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10787 OF 2022 PETITIONER/S: THECHAMPAKARA SERVICE CO-OPERATIVE BANK LTDNO.3511, KARUKACHAL, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM, PIN-682 018. 2 THE INCOME TAX OFFICER (TDS), INCOME TAX DEPARTMENT, KOTTAYAM, PIN-686 001. 3 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033. 4 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., KARUKACHAL BRANCH, KOTTAYAM DISTRICT, PIN-686 539. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 94 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10799 OF 2022 PETITIONER/S: 1 THE NANDIPULAM SERVICE CO-OPERATIVE BANK LIMITED NO. R2 NANDIPULAM P.O., THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN-680319. 2 THE THOTTIPPAL SERVICE CO-OPERATIVE BANK LIMITED NO.634, THOTTIPPAL, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. 3 THE PUDUKKAD TOWN SERVICE CO-OPERATIVE BANK LIMITED NO.R 1306, PUDUKKAD P.O., THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. 4 THE INCHAKUNDU SERVICE CO-OPERATIVE BANK LIMITED NO. R 197, INCHAKUNDU, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. 5 THE VARANTHARAPPILLY SERVICE CO-OPERATIVE BANK LIMITED NO.450, VARANTHARAPPILLY, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. 6 THE AMBALLUR SERVICE CO-OPERATIVE BANK LIMITED NO.503, MANNAMPETTA, VARAKARA P.O., THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN-680302. 7 THE VELLIKULANGARA SERVICE CO-OPERATIVE BANK LIMITED 2025:KER W.P(C)No.7053/2023 & Connected cases 95 NO.425, VELLIKULANGARA, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. 8 THE KODAKARA FARMERS SERVICE CO-OPERATIVE BANK LIMITED NO.R-761, KODAKARA P.O., THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. 9 THE KODUSSERY ELINJIPRA SERVICE CO-OPERATIVE BANK LIMITED NO.R 228, KODUSSERY P.O., THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, PIN-680721. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 3 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, SHAKTAN NAGAR, THRISSUR, PIN-680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. BY ADVS. SRI.R.MURALEEKRISHNAN (MALAKKARA) CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 96 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10810 OF 2022 PETITIONER/S: KUZHUR SERVICE CO-OPERATIVE BANK LIMITED KUZHUR.P.O, THRISSUR, PIN-680734, REPRESENTED BY ITS SECRETARY SUNITHA.V.R. BY ADVS. SHRI.K.S.HARIHARAN NAIR SHRI.RAJATH R NATH SMT.G.REMADEVI SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110001. 2 COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING,I S PRESS ROAD, KOCHI- 682018. 3 THE INCOME TAX OFFICER(TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR, PIN-680001. 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE,GOVERNMENT OF INDIA, NORTH BLOCK, 2025:KER W.P(C)No.7053/2023 & Connected cases 97 NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 5 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 6 THE ADDITIONAL COMMISSIONER OF INCOME TAX TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 7 THE KERALA STATE CO-OPERATIVE BANK LTD.(KERALA BANK), PO NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695033, REPRESENTED BY ITS MANAGING DIRECTOR. 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY(CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM,PIN-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 98 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10818 OF 2022 PETITIONER/S: KORATTY SERVICE CO-OPERTIVE BANK LTD NO.628 KORATTY, THRISSUR, PIN-680 308, REPRESENTED BY ITS SECRETARY SANIL KUMAR N.G. BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SMT.HARIMA HARIHARAN SHRI.RAJATH R NATH RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S PRESS ROAD, KOCHI-682 018 3 THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAM NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR,PIN-680 001 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 99 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001,REPRESENTED BY ITS CHAIRMAN 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS.PRESS ROAD, KOCHI-682 018 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003 7 THE KERALA STATE CO-OPERATIVE BANK LTD (KERALA BANK), PO NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM,PIN-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 100 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10828 OF 2022 PETITIONER/S: KALLAMKUNNU SERVICE CO-OPREATIVE BANK LIMITED, KALLAMKUNNU P.O., NADAVARAMBA, THRISSUR, 680 661, REPRESENTED BY ITS SECRETARY GANESH C.K., BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SHRI.RAJATH R NATH SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY , DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110001. 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI 682 018. 3 THE INCOME TAX OFFICER, (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR 680 001. 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 101 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 11001, REPRESENTED BY TIS CHAIRMAN. 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD , KOCHI 682 018. 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE , 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003. 7 THE KERALA STATE CO -OPERATIVE BANK LTD, (KERALA BANK), P.O. NO. 6515, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 102 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10831 OF 2022 PETITIONER/S: CHALAKUDY SERVICE CO-OPERATIVE BANK LIMITED, NO. R 192, CHALAKUDY P.O, THRISSUR DISTRICT, 680 307, REPRESENTED BY ITS SECRETARY SABIN K.P. BY ADVS. SHRI.K.S.HARIHARAN NAIR SHRI.RAJATH R NATH SMT.G.REMADEVI SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK , NEW DELHI 110 001. 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI 682 018. 3 THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR, PIN 680 001. 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 103 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001, REPRESENTED BY ITS CHAIRMAN. 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI 682 018. 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003. 7 THE KERALA STATE CO-OPERATIVE BANK LTD., (KERALA BANK), PO NO. 6515, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN 695 001. BY ADVS. SMT.M.S.KIRAN, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 104 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10845 OF 2022 PETITIONER/S: KALLUR SERVICE CO-OPERATIVE BANK LIMITED, ALAGAPPA NAGAR, THRISSUR DISTRICT 680 317, REPRESENTED BY ITS SECRETARY, SMT.A.A. PUSHPALATHA. BY ADVS. SHRI.K.S.HARIHARAN NAIR SHRI.RAJATH R NATH SMT.HARIMA HARIHARAN SMT.G.REMADEVI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110001. 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI 682 018. 3 THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR 680 001. 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 105 MINISTRY OF FINANCE, GOVERNMENT IF INDIA, NORTH BLOCK, NEW DELHI 11001, REPRESENTED BY ITS CHAIRMAN. 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX , KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018. 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003. 7 THE KERALA STATE CO - OPERATIVE BANK LTD., (KERALA BANK), P.O. NO. 6515 , CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033. REPRESENTED BY ITS MANAGING DIRECTOR. 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO - OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF INDIA, THIRUVANANTHAPURAM 695 001. BY ADVS. SHRI.K.B.SAJAN CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 106 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10855 OF 2022 PETITIONER/S: MELOOR SERVICE CO-OPERATIVE BANK LTD NO.R.196, MELOOR.P.O, CHALAKUDY, THRISSUR DISTRICT- 680311,REPRESENTED BY ITS SECRETARY SINDHU.M. BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SHRI.RAJATH R NATH SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110001. 2 COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI- 682018. 3 THE INCOME TAX OFFICER(TDS), AAYAKAR BHAVAN,SAKTHAN THAMPURAM NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR,PIN-680001. 4 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE ,GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 2025:KER W.P(C)No.7053/2023 & Connected cases 107 110001,REPRESENTED BY ITS CHAIRMAN. 5 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 6 THE ADDITIONAL COMMISSIONER OF INCOME TAX TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 7 KERALA STATE CO-OPERATIVE BANK LTD., (KERALA BANK), PO NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695033, REPRESENTED BY ITS MANAGING DIRECTOR. 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM,PIN- 695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 108 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10891 OF 2022 PETITIONER/S: THE VAIKOM TALUK CO-OPERATIVE EMPLOYEES' CO-OPERATIVE SOCIETY LTD. NO. K 415, THALAYOLAPARAMBU, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN-686505. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 3 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, AYKAR BHAVAN, KOTTAYAM, PIN-686001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. 5 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., THALAYOLAPARAMBU, KOTTAYAM DISTRICT, PIN-686505. 2025:KER W.P(C)No.7053/2023 & Connected cases 109 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 110 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10936 OF 2022 PETITIONER/S: 1 VAKKOM FARMERS SERVICE CO-OPERATIVE BANK LTD NO 542, VAKKOM P.O, THIRUVANANTHAPURAM 695 308 REPRESENTED BY ITS MANAGING DIRECTOR SATHEESAN S 2 THONNAKKAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LTDNO. HW 21 THONNAKKAL P.O, THIRUVANNATHAPURAM 695 317 REPRESENTED BY ITS SECRETARY SUDHEER KUMAR C BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, 2025:KER W.P(C)No.7053/2023 & Connected cases 111 GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001 REPRESENTED BY ITS CHAIRMAN 3 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 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM 695 003 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM , 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003 6 THE KERALA STATE CO-OPERATIVE BANK LTD. P.B NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001 BY ADV SRI.R.MURALEEKRISHNAN (MALAKKARA) THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 112 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10937 OF 2022 PETITIONER/S: 1 TRAVANCORE AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD NO A 1183, BARANIKAVU SOUTH P.O, ALAPUZHA 690 503 REPRESENTED BY ITS SECRETRY ROY ISSAC DANIEL 2 MAVELIKARA ELECTRICITY EMPLOYEES CO-OPERATIVE SOCIETY LTD NO A-646 MAVELIKARA, ALAPUZHA 690 101 REPRESENTED BY SECRETARY BENOY H 3 MAVELIKARA AIDED SCHOOL EMPLOYEES CO-OPERATIVE SOCIETY LTD NO A 288, MAVELIKARA, ALAPUZHA 690 101 REPRESENTED BY ITS SECRETARY K.A RAJI 4 MAVELIKARA GOVERNMENT SERVANTS CO-OPERATIVE SOCIETY LTD NO A 792, MAVELIKARA, ALAPUZHA 690 101, REPRESENTED BY ITS SECRETARY CHANDRAN PILLAI P 5 BARANIKAVU PANCHAYATH MULTY PURPOSE CO-OPERATIVE SOCIETY LTD NO A 1164, MOONAMKUTTY, PALLICKAL P.O, ALAPUZHA 690 503 REPRESENTED BY ITS SECRETARY BIJUKUMAR P 6 NOORANAD RURAL HOUSING CO-OEPRATIVE SOCEITY LTD NO A 293, NOORANAD P.O, ALAPUZHA 690 504 REPRESENTED BY ITS SECRETARY P.K JAYACHANDRAN 7 THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE DEPARTMENT EMPLOYEES CO-OEPRATIVE SOCIETY LTD NO. T 323, JAWAHAR 2025:KER W.P(C)No.7053/2023 & Connected cases 113 SAHAKARANA BHAVAN , DPI JUNCTION, JAGATHY, THIRUVANANTHAPURAM 695 014 REPRESENTED BY ITS SECRETARY DILEEP KUMAR V BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.RASMI NAIR T. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 2 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. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX CO-OPERATIVE SOCIETIES KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD. P B NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001 BY ADVS. 2025:KER W.P(C)No.7053/2023 & Connected cases 114 SHRI.T.V.VINU, CGC SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 115 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10968 OF 2022 PETITIONER/S: 1 VAZHAKKULAM BLOCK VANITHA CO-OPERATIVE SOCIETY LTD. NO.E 1126, MARAMPALLY P.O., ERNAKULAM - 683 105, REPRESENTED BY ITS SECRETARY REJITHA UNNIKRISHNAN. 2 KUNNATHUNAD TALUK CO-OPERATIVE EMPLOYEES CO-OPERATIVE SOCIETY LTD.NO.E 771 PERUMBAVOOR P.O., ERNAKULAM - 683 542, REPRESENTED BY SECRETARY SHYJI M.S. 3 DEVASWOLM BOARD EMPLOYEE'S CO-OPERATIVE SOCIETY LTD.NO.E 759 PERUMBAVOOR P.O., ERNAKULAM - 683 542, REPRESENTED BY ITS SECRETARY SREENATH K.V. 4 VADAVUKODU BLOCK VANITHA CO-OPERATIVE SOCIETY LTD.NO.E 1105 PATTIMATTOM P.O., ERNAKULAM - 683 562, REPRESENTED BY ITS SECRETARY BEENA V.T. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 116 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI - 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 117 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10967 OF 2022 PETITIONER/S: 1 UZHUVA SERVICE CO-OPERATIVE BANK LTD NO.A 305, PATTANAKKAD P.O, CHERTHALA-688 531, REPRESENTED BY ITS SECRETARY- K.T. JOHN. 2 THE THYCATTUSSERY SERVICE CO-OPERATIVE BANK LTD. NO. 326, THYCATTUSSERY P.O-688 582, REPRESENTED BY ITS SECRETARY- VISHNU V.A 3 THANNEERMUKAM SERVICE CO-OPERATIVE BANK LTD. NO. A 809, THANNEERMUKKAM P.O, CHERTHALA-688 527, REPRESENTED BY ITS SECRETARY- AJITHKUMAR P.D. 4 MUHAMMA SERVICE CO-OPERATIVE BANK LTD. NO. 1670, MUHAMMA P.O, CHERTHALA 688 525, REPRESENTED BY ITS SECRETARY- SUNIL KUMAR. 5 THURAVOOR SOUTH SERVICE CO-OPERATIVE BANK LTD. NO. 2727, THURAVOOR P.O,CHERTHALA- 688 532, REPRESENTED BY ITS SECRETARY- ANI T.P. 6 THURAVOOR KIZHAKKEKKARA SERVICE CO-OPERATIVE BANK LTD NO. 1053, THURAVOOR P.O, CHERTHALA- 688 532, REPRESENTED BY ITS SECRETARY- GEETHADEVI 7 THURAVOOR CO-OPERATIVE BANK LTD. NO. 935, THURAVOOR P.O, ALAPPUZHA 688 532, REPRESENTED BY ITS SECRETARY, N PRADEESH PRABHU. 2025:KER W.P(C)No.7053/2023 & Connected cases 118 8 VALAMANGALAM SERVICE CO-OPERATIVE BANK LTD. NO. 144, THURAVOOR P.O, ALAPPUZHA 688 532, REPRESENTED BY ITS SECRETARY- BINEESH K.P. 9 PANAVALLY VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO. 1249, THRICHATTUKULAM P.O, ALAPPUZHA 688 526, REPRESENTED BY ITS SECRETARY, PRATHIBA MOHAN. 0 THE EZHUPUNNA SOUTH SERVICE CO-OPERATIVE BANK LTD. NO. 1124, EZHUPUNNA SOUTH P.O, CHERTHALA- 688 537, REPRESENTED BY ITS SECRETARY K.N. SATHEESAN. 11 CHANDIROOR SERVICE CO-OPERATIVE BANK LTD. NO. 959, CHANDIROOR P.O, CHERTHALA 688 471, REPRESENTED BY ITS SECRETARY- ABDULKALAM. 12 ARTHINKAL VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO. 3772, ARTHUNKAL P.O, CHERTHALA -688 530, REPRESENTED BY ITS SECRETARY-ALICE M. 13 PALLIPURAM VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO. 335, PALLIPURAM P.O, CHERTHALA- 688 541, REPRESENTED BY ITS SECRETARY- SAJI JOB. 14 THE PERUMPALAM SERVICE CO-OPERATIVE BANK LTD. NO. 46, PERUMPALAM P.O, CHERTHALA 688 570, REPRESENTED BY ITS SECRETARY- AJITHKUMAR V K. 15 PALLIPURAM SERVICE CO-OPERATIVE BANK LTD. NO. 1308, PALLIPURAM P.O, CHERTHALA- 688 541, REPRESENTED BY ITS SECRETARY, RADHAKRISHNAN P. 16 AROOR GRAMEENA SERVICE CO-OPERATIVE BANK LTD. NO. 1436, AROOR P.O, CHERTHALA-688 534, REPRESENTED BY ITS SECRETARY- JAYASREE R. 17 AROOKUTTY SERVICE CO-OPERATIVE SOCIETY LTD. NO. 1008, 2025:KER W.P(C)No.7053/2023 & Connected cases 119 AROOKUTTY P.O, CHERTHALA- 688 535, REPRESENTED BY ITS SECRETARY - SUJATHADEVI. 18 VAYALAR SERVICE CO-OPERATIVE BANK LTD. NO. 1428, VAYALAR EAST P.O, CHERTHALA- 688 536, REPRESENTED BY ITS SECRETARY- SHYNIMOL P. 19 VAYALAR KIZHAKKE SERVICE CO-OPERATIVE BANK LTD. NO. 1328, VAYALAR EAST P.O, CHERTHALA- 688 536, REPRESENTED BY ITS SECRETARY- SINDHU V.A 0 CHERTHALA TALUK AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LTD. NO. H W 11, CHERTHALA P.O, CHERTHALA- 688 533, REPRESENTED BY ITS SECRETARY - A MINI. 21 KANNANKARA SERVICE CO-OPERATIVE BANK LTD. NO. 1806, KANNANKARA P.O, CHERTHALA -688 527, REPRESENTED BY ITS SECRETARY- P L MARIAMMA 22 SREEKANDAMANGALAM SERVICE CO-OPERATIVE BANK LTD. NO. 974. MUTTATHIPARAMBU P.O, CHERTHALA-688 527, REPRESENTED BY ITS SECRETARY IN CHARGE- ALICE VARGHESE. 23 CHERTHALA GOVT. SERVANTS CO-OPERATIVE BANK LTD NO. 235, CHERTHALA P.O, CHERTHALA-688 524, REPRESENTED BY ITS SECRETARY- SANDHY C. 24 THE THYCATTUSSERY SERVICE CO-OPERATIVE BANK LTD. NO. 275, THYCATTUSSERY P.O, CHERTHALA 688 528, REPRESENTED BY ITS SECRETARY- SAJI K THOMAS. 25 PANAVALLY SERVICE CO-OPERATIVE BANK LTD. NO. 901, POOCHAKKAL P.O, CHERTHALA- 688 528, REPRESENTED BY ITS SECRETARY - SREELAL K. 26 MARARIKULAM SERVICE CO-OPERATIVE BANK LTD. NO. 1509, MARARIKULAM NORTH P.O. ALAPPUZHA 688 523, REPRESENTED BY ITS SECRETARY - SHAJI T.A, 2025:KER W.P(C)No.7053/2023 & Connected cases 120 27 KADAKKARAPPALLY SERVICE CO-OPERATIVE BANK LTD. NO. 1125, KADAKKARAPPILLY P.O, CHERTHALA 688529, REPRESENTED BY ITS SECRETARY- BRIJESH CHANDRAN. 28 KAVIL SERVICE CO-OPERATIVE BANK LTD. NO. 2093, PATTANAKKAD P.O, CHERTHALA- 688 531, REPRESENTED BY ITS SECRETARY- SANOJ C.P. 29 KALAVAMKODAM SERVICE CO-OPERATIVE BANK LTD. NO. 895, KALAVOMKODAM P.O, CHERTHALA- 688 524, REPRESENTED BY ITS SECRETARY- ANAND K.T. 0 PARAYAKAD SERVICE CO-OPERATIVE BANK LTD. NO. 2869, PARAYAKAD P.O, CHERTHALA 688 540, REPRESENTED BY ITS SECRETARY M.K. USHAKUMARI. 31 CHERTHALA TOWN SERVICE CO-OPERATIVE BANK LTD. NO. 1435, CHERTHALA P.O, CHERTHALA - 688 533, REPRESENTED BY ITS SECRETARY- B VINOD. 32 THE VETTACKKAL SERVICE CO-OPERATIVE BANK LTD. NO. 1812, VETTACKKAL P.O, CHERTHALA-688 587, REPRESENTED BY ITS SECRETARY- S GANGA PRASAD. 33 VETTACKAL KARSHIKA SERVICE CO-OPERATIVE BANK LTD. NO. 4292, VETTACKKAL P.O, CHERTHALA 688 587, REPRESENTED BY ITS SECRETARY- V.C. AMBILY. 34 KAYIPPURAM SERVICE CO-OPERATIVE BANK LTD. NO. 1300, MUHAMMA P.O, CHERTHALA- 688 525, REPRESENTED BY ITS SECRETARY - JAYA C P. 35 SHERTALLAY SOUTH SERVICE CO-OPERATIVE BANK LTD. NO. 1344, SHERTALLAY P.O, SHERTALLAY- 688 552, REPRESENTED BY ITS SECRETARY- D BABU. 36 KALAVOOR SERVICE CO-OPERATIVE BANK LTD. NO. 1497, KALAVOOR P.O, CHERTHALA 688 522, REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 121 SECRETARY- FULL ADDITIONAL CHARGE VIJIMOL S. 37 THE CHATHURTHIAKARY SERVICE CO-OPERATIVE BANK LTD. NO. 1247, CHATHURTHIAKARY P.O, ALAPPUZHA 688 502, REPRESENTED BY ITS SECRETARY, ANIL KUMAR A. 38 S.L. PURAM SERVICE CO-OPERATIVE BANK LTD. NO. A 64, S/L. PURAM P.O, ALAPPUZHA 688 523, REPRESENTED BY ITS SECRETARY- SUSEELA P.G. 39 ALLEPPEY ELECTRICITY EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO. A 769, POWER HOUSE P.O, ALAPPUZHA 688 524, REPRESENTED BY ITS SECRETARYP P U REKHA, 40 CHERTHALA TALUK, AIDED PRIMARY TEACHER'S CO-OPERATIVE SOCIETY LTD. NO. A 272 P.O, CHERTHALA 688524, REPRESENTED BY ITS SECRETARY - P S MAMACHAN. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 000. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG. IS PRESS ROAD, KOCHI 682 018. 3 INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX DEPT. ALAPPUZHA 688 011. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., (ERSTWHILE ALAPPUZHA DISTRICT CO-OPERATIVE BANK), 2025:KER W.P(C)No.7053/2023 & Connected cases 122 OPP. MUNICIPAL TOWN HALL, ALAPPUZHA REGION, ALAPPUZHA , KERALA-688 011 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 123 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11001 OF 2022 PETITIONER/S: 1 PALLICKAL NADUVILEMURI SERVICE CO-OPERATIVE BANK LTD. NO.965, PALLICKAL NADUVILEMURI P.O., KAYAMKULAM, ALAPPUZHA- 690503, REPRESENTED BY ITS SECRETARY RAGESH K.R. 2 CORPORATION BANK BANK LIMITED NO. H.W.14, HEAD OFFICE, KALLUMALA P.O., MAVELIKARA, ALAPPUZHA-690110, REPRESENTED BY ITS SECRETARY BINDU A. 3 PATHIYOOR FARMERS SERVICE CO-OPERATIVE BANK LIMITED 1282, HEAD OFFICE, PATHIYOOR, KEERIKAD P.O., ALAPPUZHA- 690506, REPRESENTED BY ITS MANAGING DIRECTOR MAYA S. 4 NOORANAD SERVICE CO-OPERATIVE BANK LIMITED NO.1559, PADANILAM P.O., NOORANAD, ALAPPUZHA-690543, REPRESENTED BY ITS SECRETARY N. UDAYAN. 5 THEKKEKARA SERVICE CO-OPERATIVE BANK LIMITED NO.A 218, PONAKAM, MAVELIKARA P.O., ALAPPUZHA-690101, REPRESENTED BY ITS SECRETARY S. SINDHUKUMARI. 6 KANNAMANGALAM SERVICE CO-OPERATIVE BANK LIMITED NO.2135, HEAD OFFICE, PELA P.O., THATTARAMPALAM, ALAPPUZHA- 690103, REPRESENTED BY ITS SECRETARY JAYASREE M. 7 PONNEZHA SERVICE CO-OPERATIVE BANK LIMITED NO.3522, THEKKEKARA P.O., MAVELIKARA, ALAPPUZHA-690107, 2025:KER W.P(C)No.7053/2023 & Connected cases 124 REPRESENTED BY ITS SECRETARY K.U. INDUKALA. 8 PERINGALA SERVICE CO-OPERATIVE BANK LIMITED NO.2152, KOIPPALLIKARANMA, OLAKETTIAMBALAM P.O., ALAPPUZHA- 690510, REPRESENTED BY IT SECRETARY PREETHAKUMARI P. 9 KATTANAM SERVICE CO-OPERATIVE BANK LIMITED NO.120, PALLICKAL P.O., ALAPPUZHA-690503, REPRESENTED BY ITS SECRETARY S. VENUGOPALAN NAIR. 0 KANNANKUZHI SERVICE CO-OPERATIVE BANK LIMITED NO.2998, KANNANKUZHY P.O., VIA CHARUMOODU, ALAPPUZHA-690505, REPRESENTED BY ITS SECRETARY SEENA S.R. 11 VALLIKUNNAM KADUVINAL SERVICE CO-OPERATIVE BANK LIMITED NO.1392, VALLIKUNNAM, ALAPPUZHA-690501, REPRESENTED BY ITS SECRETARY J. RAVEENDRANATH. 12 BHARANICKAVU SERVICE CO-OPERATIVE BANK LIMITED NO.829, PALLICKAL P.O., ALAPPUZHA-690503, REPRESENTED BY ITS SECRETARY K.S. JAYAPRAKASH. 13 KUNNAM SERVICE CO-OPERATIVE BANK LIMITED NO.559, ALAPPUZHA-690408, REPRESENTED BY ITS SECRETARY BINU S. 14 MAVELIKKARA BLOCK VANITHA CO-OPERATIVE BANK LIMITED NO. A 912, KUNNAM P.O., ALAPPUZHA-690108, REPRESENTED BY ITS SECRETARY VRINDA S. 15 PALAMEL SERVICE CO-OPERAIVE BANK LIMITED NO.4018, NOORANAD P.O., ALAPPUZHA-690504, REPRESENTED BY ITS SECRETARY MANJU T.G. 16 KOOVAPPALLY SERVICE CO-OPERATIVE BANK LIMITED NO.3549, KOOVAPPALLY P.O., KOTTAYAM-686518, REPRESENTED BY ITS SECRETARY JOSE MANOJ. 17 THANIYAM PANCHAYATH SERVICE CO-OPERATIVE BANK LIMITED 2025:KER W.P(C)No.7053/2023 & Connected cases 125 NO. R387, KIZHUPPILLIKARA P.O., THRISSUR-680702, REPRESENTED BY ITS SECREARY UNNIKRISHNAN K.V. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 KERALA STATE CO-OPERATIVE BANK LTD., P.B. NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. SRI.KRISHNADAS P.NAIR, SENIOR PANEL COUNSEL SHRI.THOMAS ABRAHAM 2025:KER W.P(C)No.7053/2023 & Connected cases 126 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 127 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11009 OF 2022 PETITIONER/S: KADUKUTTY SERVICE CO-OPERATIVE BANK LIMITED NO. 628,KADUKUTTY P.O, CHALAKUDY, THRISSUR, PIN- 680 315 REPRESENTED BY ITS SECRETARY E.K.VIJAYA. BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE,, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001 2 COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD,KOCHI- 682 018 3 THE INCOME TAX OFFICER (TDS) AAYAKAR BHAVAN, SAKTHAN THMPURAN NAGAR, MUNCIPAL OFFICE ROAD, THRISSUR. PIN- 680 001 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE. MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH 2025:KER W.P(C)No.7053/2023 & Connected cases 128 BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX , KERALA REGION , MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI-682 018 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003 7 THEKERALA STATE CO-OPERATIVE BANK LTD, (KERALA BANK) P.O.NO. 6515, CO-BANK TOWERSPALAYAM, THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR, 8 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO_OPERATION), GOVERNMENT SECRETARIAT GOVERNMENT OF KERALA, THIRUVANANTHAPURM-PIN-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 129 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11035 OF 2022 PETITIONER/S: PERUNGUZHI SERVICE CO-OPERATIVE BANK LTD. NO.2403 REPRESENTED BY ITS SECRETARY, PERUNGUZHI P.O., THIRUVANANTHAPURAM DISTRICT - 695 305. BY ADVS. SHRI.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, KAWDIAR P.O., THIRUVANANTHAPURAM, PIN-695 003. 2 THE CENTRAL BOARD OF DIRECT TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/ MNISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI, PIN - 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 , PIN 110 001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, 2025:KER W.P(C)No.7053/2023 & Connected cases 130 THIRUVANANTHAPURAM, PIN - 695 001. 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695 001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695 033. BY ADVS. SHRI.JUSTUS S., CGC SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 131 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11042 OF 2022 PETITIONER/S: VILVATTOM SERVICE CO-OPERATIVE BANK LTD NO.337 P.O.KURICHIKKARA, THRISSUR, REPRESENTED BY THE SECRETARY - 680 028. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM - 682 018. 3 THE INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SMT.SOWMIAVATHY T.C., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 132 SHRI.B.G.HARINDRANATH (SR.) SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 133 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11058 OF 2022 PETITIONER/S: 1 MANNANAM SERVICE CO-OPERATIVE BANK LTD NO 3647, MANNANAM P.O, KOTTAYAM 686 561 REPRESENTED BY ITS SECRETARY-ABY JACOB 2 AYARKUNNAM SERVICE CO-OPERATIVE BANK LTD NO. 4147, AYARKUNNAM P.O, KOTTAYAM 686 564, REPRESENTED BY ITS SECRETARY MANOJ K 3 THE PUNNATHURA SERVICE CO-OPERATIVE BANK LTD NO. 1712 PUNNATHURA P.O 686 583 REPRESENTED BY ITS SECRETARY- BIJU VARGHESE 4 CHENGALAM SERVICE CO-OPERATIVE BANK LTD NO. K 253 CHENGALAM P.O, KOTTAYAM 686 585 REPREENTED BY ITS SECRETARY-IN-CHARGE JOJIE NIRAPPEL 5 ETTUMANOOR BLOCK URBAN CO-OPERATIVE SOCIETYLTD K 1026 THELLAKOM P.O, KOTTAYAM 686 630 REPRESENTED BY ITS SECRETARY V C JAYAKUMAR 6 AREEPARAMBU SERVICE CO-OPERATIVE BANK LTD NO. 1393 AREEPARAMPU P.O, KOTTAYAM 686 501 REPRESENTED BY ITS SECRETARY SHIBY N C 7 VIJAYAPURAM SERVICE CO-OPERATIVE BANK LTD NO. 4066 MANARCAD P.O, KOTTAYAM 686 019 REPRESENTED BY ITS SECRETARY-BINDU P SCARIA 8 PEROOR SERVICE CO-OPERATIVE BANK LTD NO. 76 PEROOR PO, KOTTAYAM 686 637 REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 134 SECRETARY PREETHY K SASI 9 THIRUVANACHOOR SERVICE CO-OPERATIVE BANK LTD NO. 1942, THIRUVANCHOOR P.O, KOTTAYAM REPRESENTED BY ITS SECRETARY E K LATHAMOL 0 THE ATHIRAMPUZHA REGIONAL SERVICE CO-OPERATIVE BANK LTD NO. 3806 ATHIRAMPUZHA P.O, KOTTAYAM REPRESENTED BY ITS SECRETARY-KUNJUMON MD 11 MAHATMA GANDHI UNIVERSITY EMPLOYEES CO-OPERATIVE SOCIETY LTD NO K- 771 PRIYADARSINI HILLS P.O, KOTTAYAM 686 560 REPRESENTED BY ITS SECRETARY-JESSON THOMAS 12 CHENGALAM SOUTH SERVICE CO-OPERATIVE BANK LTD NO. 1016 CHENGALAM SOUTH P.O, KOTTAYAM 686 020 REPRESENTED BY ITS SECRETARY SUNILMON P.S 13 KUMARAKOM SERVICE CO-OPERATIVE BANK LTD NO. 2298 KUMARAKOM P.O, KOTTAYAM DISTRICT 686 563 REPRESENTED BY ITS SECRETARY THOMAS MANI. 14 KUMARAKOM REGIONAL SERVICE CO-OPERATIVE BANK LTD NO. 315 KUMARAKOM P.O, KOTTAYAM DISTRICT 686 563 REPRESENTED BY ITS SECRETARY VIDYA B MENON 15 MRF EMPLOYEES CO-OPERATIVE SOCIETY LTD NO. K 674 VADAVATHOOR P.O, KOTTAYAM 686 010 REPRESENTED BY ITS SECRETARY DEVASIA P S 16 AIDED PRIMARY TEACHER'S CO-OPERATIVE SOCIETY LTD NO. K-334 KOTTAYAM P.O 686 001 REPRESENTED BY ITS SECRETARY BIJU ABRAHAM 17 KOTTAYAM AIDED SECONDARY SCHOOL TEACHER'S CO- OPERATIVE SOCIETY LTD NO 659 P.O KOTTAYAM 686 019 REPRESENTED BY ITS SECRETARY CHERIAN VARGHESE 2025:KER W.P(C)No.7053/2023 & Connected cases 135 18 THE CO-OPERATIVE DEPARTMENTAL EMPLOYEES COOPERATIVE SOCIETY LTD NO. K-294 KOTTAYAM P.O 686 001 REPRESENTED BY ITS SECRETARY GEORGE JOSEPH K BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018 3 THE INCOME TAX OFFICE (TDS) INCOME TAX DEPARTMENT, PUBLIC LIBRARY BUILDING, SASTRI ROAD, KOTTAYAM 686 001 4 THE KERALA STATE CO-OPERATIVE BANK LTD. (ERSTWHILE KOTTAYAM DISTRICT CO-OPERATIVE BANK) POST BOX NO. 140, KOTTAYAM DISTRICT OFFICE, KOTTAYAM 686 001 BY ADVS. SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 136 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11072 OF 2022 PETITIONER/S: 1 THE VENNOR SERVICE CO-OPERATIVE BANK LTD NO.675 VENNOR, ALATHUR P.O., THRISSUR-680741, REPRESENTED BY ITS SECRETARY- E.D.SABU. 2 THE WEST CHALAKUDY SERVICE CO-OPERATIVE BANK LTD. NO.R 262, CHALAKKUDY P.O., -680307, REPRESENTED BY ITS SECRETARY- VALSA M.V. 3 THE ERIYAD SERVICE CO-OPERATIVE BANK LTD. NO.98, ERIYAD P.O., KODUNGALLUR, PIN-680666, REPRESENTED BY ITS SECRETARY- A.S.RAFI. 4 KURUVILASSERY SERVICE CO-OPERATIVE BANK LTD. NO.4185, KURUVILASSERY P.O., THRISSUR-680732, REPRESENTED BY ITS SECRETARY- NIXON N.C. 5 VIYYUR SERVICE CO-OPERATIVE BANK LTD. NO.177, VIYYUR P.O., THRISSUR-680010, REPRESENTED BY ITS SECRETARY- T.C.ALICE. 6 VEMBALLUR SERVICE CO-OPERATIVE BANK LTD. NO.F.917, PATHAZHAKKAD P.O., PATHAZHAKKAD, THRISSUR-680668, REPRESENTED BY ITS SECRETARY MEERA K.I. 7 METHALA SERVICE CO-OPERATIVE BANK LTD. R-298, METHALA P.O., KODUNGALLUR-680664, REPRESENTED BY ITS SECRETARY- MINI T.C. 2025:KER W.P(C)No.7053/2023 & Connected cases 137 8 THRISSUR DISTRICT CITIZENS CO-OPERATIVE SOCIETY LTD. NO. R-1405, KOVILAGATHUPADAM P.O., THRISSUR-680020, REPRESENTED BY ITS SECRETARY- JITHA J. 9 THE AZHIKODE SERVICE CO-OPERATIVE BANK LTD. 287, AZHIKODE P.O., THRISSUR-680666, REPRESENTED BY ITS SECRETARY-SAJEENA O.A. 0 THE THRISSUR DISTRICT SMALL SCALE MANUFACTURES SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD. NO.R-1401, VELLIYANNUR P.O., THRISSUR-680021, REPRESENTED BY ITS SECRETARY- SAJITHA T.G. 11 EDAVILANGU SERVICE CO-OPERATIVE BANK LTD. 3468, EDAVILANGU P.O., KODUNGALLUR-680671, REPRESENTED BY ITS SECRETARY- MAYA P.S. 12 PUDUKAD SERVICE CO-OPERATIVE BANK LTD. 580, PUDUKAD P.O., THRISSUR -680301, REPRESENTED BY ITS SECRETARY- K.V.ANITHA. 13 ALA SERVICE CO-OPERATIVE BANK LTD. 321, SHANTHIPURAM P.O., KODUNGALLUR-680668, REPRESENTED BY ITS SECRETARY- RAJENDRAN P.R. 14 THE TRICHUR GOVT. SERVANTS CO-OPERATIVE SOCIETY LTD. NO.34, P.O. TRICHUR-680022, REPRESENTED BY ITS SECRETARY- RAJESH SHANMUGHAN A. 15 PANAMKUTTICHIRA PEOPLE'S WELFARE CO-OPERATIVE SOCIETY LTD. NO.R-1441, OLLUR P.O., THRISSUR-680306, REPRESENTED BY ITS SECRETARY-SIJI SHAJAN. 16 THRISSUR GOVT. MEDICAL COLLEGE EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.R-806, MEDICAL COLLEGE P.O., THRISSUR-680596, REPRESENTED BY ITS SECRETARY- SUDHA A.K. 17 KERALA ESIC EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.R- 282, THRISSUR-680020, REPRESENTED BY ITS SECRETARY- 2025:KER W.P(C)No.7053/2023 & Connected cases 138 SANTHOSH THOMAS. 18 KERALA AGRICULTURAL AND KERALA VETTINARY UNIVERSITY SAHAGARNASANGAM CO-OPERATIVE SOCIETY LTD. NO.R-162, MANNUTHY P.O., MANNUTHY-680651, REPRESENTED BY ITS SECRETARY- PADMINI E P S. 19 THRISSUR DISTRICT MUNICIPAL AND CORPORATION EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.R-38, P.O. THRISSUR-680014, REPRESENTED BY ITS SECRETARY- P.R.ASHA. 0 THRISSUR KARSHIKA KARSHIKETHARA VIKASANA CO-OPERATIVE SOCIETY LTD. NO.R-1395, CHEMBUKKAVU P.O., THRISSUR-680020, REPRESENTED BY ITS SECRETARY- NADIYA K.P. 21 MALA MULTI-PURPOSE CO-OPERATIVE SOCIETY LTD. NO.R- 1159, AANNAMANDA P.O., THRISSUR-680741, REPRESENTED BY ITS SECRETARY- JISHA K.S. 22 MANNUTHY TOWN CO-OPERATIVE SOCIETY LTD.NO.R-1143, MANNUTHY P.O., THRISSUR-680651, REPRESENTED BY ITS SECRETARY- PRIYA C.T. 23 BELLWICS NADAVARAMBA KRISHNA BELL METAL WORKERS ANTICRAFTS INDUSTRIAL CO-OPERATIVE SOCIETY LTD. NO.199, NADAVARAMBA P.O., IRINJALAKUDA-680661, REPRESENTED BY ITS SECRETARY- AMBILY T.S. 24 MANNUTHY VYAPARI VYAVASAYI CO-OPERATIVE SOCIETY LTD. NO.R-1139, MANNUTHY P.O., THRISSUR-680651, REPRESENTED BY ITS SECRETARY- VINOD K. VARGHESE. 25 CHERPU TOWN WELFARE CO-OPERATIVE SOCIETY LTD. NO.R- 1504, CHERPU P.O., 680561, REPRESENTED BY ITS SECRETARY- DEEPA RAJAN. 26 PANANCHERY MARKETING & PROCESSING CO-OPERATIVE SOCIETY LTD. NO.R-1217, PATTIKKAD P.O., -680652, REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 139 SECRETARY- SANOJ THOMAS. 27 CHERPU BLOCK PRAVASI SHEMA SAHAKARNASANGA LTD. NO.R- 1490, CHERPU P.O., 6805561, REPRESENTED BY ITS SECRETARY- ASHA T.V. 28 CHERPU BLOCK WOOD BASED ENTERPRIENEURS SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD. NO.R-1388, CHOWUR P.O., THRISSUR-680027, REPRESENTED BY ITS SECRETARY- LINI SHIJU. 29 IRINJALAKUDA SERVICE CO-OPERATIVE BANK LTD. NO.594, IRINJALAKUDA P.O., 680121, REPRESENTED BY ITS SECRETARY- RUBY P.J. 0 KILLIMANGALAM FARMERS SERVICE CO-OPERATIVE BANK LTD. NO.25, KILLIMANGALAM P.O., THRISSUR-680591, REPRESENTED BY ITS MANAGING DIRECTOR - SIMMI G. NAIR. 31 PANJAL PANCHAYAT GRAMEENA MULTIPURPOSE CO-OPERATIVE SOCIETY LTD. NO.R-1364, PANIKULAM P.O., CHERUTHURUTHY-679531, REPRESENTED BY ITS SECRETARY- SEEJA HARIDAS. 32 THIRUVILAMALA SERVICE CO-OPERATIVE BANK LTD. NO.R- 234, THIRUVILAMALA P.O., THRISSUR-680588, REPRESENTED BY ITS SECRETARY- VINODKUMAR S. 33 IRINJALAKUDA EDL.DT AIDED PRIMARY TEACHERS CO- OPERATIVE SOCIETY LTD. NO.R-379, CHALAKKUDY P.O., 680307, REPRESENTED BY ITS SECRETARY- SHEELA C.K. 34 OLLUR BHAVANA NIRMANA SAHAKARNASANGAM LTD. NO.R-1317, OLLUR P.O., THRISSUR-680306, REPRESENTED BY ITS SECRETARY- NISHA ABISHKUMAR. 35 THRISSUR DISTRICT GOVERNMENT TEACHERS CO-OPERATIVE LTD. NO.R-294, KODAKKARA P.O., THRISSUR-680684, REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 140 SECRETARY- JYOTHILAKSHMI P.K. 36 ERUMAPETTY PANCHAYATH MULTIPURPOSE CO-OPERATIVE SOCIETY LTD. NO.R-1305, ERUMAPETTY P.O., THRISSUR-680584, REPRESENTED BY ITS SECRETARY- SUNITHA T.C. 37 K.S.R.T.C. EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.R- 710, CHALAKUDY P.O., 680307, REPRESENTED BY ITS SECRETARY- SHEELA P.K. 38 PAZHAYANNUR FARMERS SERVICE CO-OPERATIVE BANK LTD. NO.71, PAZHAYANNUR P.O., THRISSUR-680527, REPRESENTED BY ITS MANAGING DIRECTOR- SREEDHARAN P. 39 VILVATTAM TOWN CO-OPERATIVE SOCIETY LTD. NO.R-1136, VILLADAM P.O., RAMAVARMAPURAM-680631, REPRESENTED BY ITS SECRETARY- K.G.LATHA. 0 OLLUR MEGHALA THOZHILALI CO-OPERATIVE SOCIETY LTD. NO.R-1142, NADATHARA P.O., THRISSUR-680751, REPRESENTED BY ITS SECRETARY- SUJITHA P.S. 41 KONDAZHY SERVICE CO-OPERATIVE BANK LTD. NO.678, KONDAZHY P.O., THRISSUR-679106, REPRESENTED BY ITS SECRETARY- LEEMA C.M. 42 THRISSUR DISTRICT LABOUR CONTRACT CO-OPERATIVE SOCIETY LTD. NO.R-1389, POOTHOLE P.O., THRISSUR-680004, REPRESENTED BY ITS SECRETARY- SINDHU K.R. 43 KADANGODE PANCHAYAT MULTIPURPOSE CO-OPERATIVE SOCIETY LTD. NO.R-1121, CHIRAMENGAD P.O., PANNITHADAM-680604, REPRESENTED BY ITS SECRETARY- PREETHY T.B. 44 RAJEEV GANDHI RURAL CO-OPERATIVE SOCIETY LTD. NO.R- 1363, PULIYANNUR P.O., VELLATTANJUR, THRISSUR-680601, REPRESENTED BY ITS SECRETARY- JOICY V.L. 2025:KER W.P(C)No.7053/2023 & Connected cases 141 45 KECHERI GURUPAVANAPPURAM PEOPLES SOCIAL WELFARE CO- OPERATIVE SOCIETY LTD. NO.R-1426, KECHERI P.O., THRISSUR-680501, REPRESENTED BY ITS SECRETARY- RATHEESH K.G. 46 VELUR PANCHAYAT KARSHIKA KARSHIKETHARA CO-OPERATIVE SOCIETY LTD. NO.R-1266, VELUR P.O., THRISSUR-680601, REPRESENTED BY ITS SECRETARY- PRIYA P. 47 NADATHARA GRAMA VIKASANA SAHAKARNASANGAM LTD. NO.R- 1297, NADATHARA P.O., THRISSUR-680751, REPRESENTED BY ITS SECRETARY-MINI C.L. 48 OLLUR MEKHALA SELF EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.R-1205, MULLUKKARA P.O., MANNUTHY, THRISSUR-680651, REPRESENTED BY ITS SECRETARY- LOVELY BIJU. 49 KURIACHIRA SERVICE CO-OPERATIVE BANK LTD. NO.637, KURIACHIRA P.O., THRISSUR-680026, REPRESENTED BY ITS SECRETARY- LEENA THOMAS. 50 THRISSUR JILLA MERCANTILE SAHAKARANA SANGAM LTD. NO.R-1428, P.O.THRISSUR-680020, REPRESENTED BY ITS SECRETARY- RENCY MAJOR. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESNETED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI. 2025:KER W.P(C)No.7053/2023 & Connected cases 142 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI-682018. 3 THE INCOME TAX OFFICER (TDS), AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR, PIN-680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., (ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK), SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THIRUVAMBADI P.O., THRISSUR, PIN-680022, REPRESENTED BY ITS GENERAL MANAGER. 5 THE GENERAL MANAGER, KODUNGALLUR TOWN CO-OPERATIVE BANK LTD., KODUNGALLUR P.O., THRISSUR, PIN-680664. 6 THE GENERAL MANAGER, THRISSUR URBAN CO-OPERATIVE BANK LTD., HEAD OFFICE, MISSION QUARTERS, THRISSUR-680001. 7 THE GENERAL MANAGER, IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD., TANA JUNCTION, IRINJALAKUDA P.O., PIN-680121. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.C.D.DILEEP,SC,TRICHUR URBN CO-OPBAN SRI.DEVAPRASANTH.P.J. SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 143 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11087 OF 2022 PETITIONER/S: 1 VARAPETTY SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, P.O.VARAPPETTY, ERNAKULAM-686 691, REPRESENTED BY ITS SECRETARY, SUNIL.T.R. 2 KUTTAMPUZHA SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, P.O.KUTTAMPUZHA, ERNAKULAM-686 681, REPRESENTED BY ITS SECRETARY, BENNY DANIEL. 3 KAVILANGAD SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, NDTTIMATTOM P.O., ERNAKULAM-686 693, REPRESENTED BY ITS SECRETARY, P.K.MADHUSOODHANAN. 4 KEERAMPARA SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, KEERAMPARA, ERNAKULAM-686 681, REPRESENTED BY ITS SECRETARY, GEORGE.K.C. 5 ONNUKAL SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, P.O.OONNUKAL, ERNAKULAM-686 693, REPRESENTED BY ITS SECRETARY, K.K.BINOY. 6 IDAMALAYAR SERVICE CO-OPERATIVE BANK LTD., HEAD OFFICE, VADATTUPARA P.O., ERNAKULAM-686 681, REPRESENTED BY ITS SECRETARY, ROBERT.K.M. 7 KOTTAPPADY SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, P.O.KOTTAPPADY, ERNAKULAM-686 691, REPRESENTED BY ITS SECRETARY, SHABU.P.S. 8 KOTHAMANGALAM SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, P.O.KOTHAMANGALAM, ERNAKULAM-686 691, 2025:KER W.P(C)No.7053/2023 & Connected cases 144 REPRESENTED BY ITS SECRETARY, ROY ABRAHAM. 9 MATHIRAPPILLY SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, P.O.KOTHAMANGALAM, ERNAKULAM-686 691, REPRESENTED BY ITS SECRETARY, SABEENA.R. 0 MALIPPARA SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, MALIPPARA, ERNAKULAM-686 691, REPRESENTED BY ITS SECRETARY, GRACY GEORGE. 11 KADAVOOR SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, P.O.KADAVOOR, ERNAKULAM-686 691, REPRESENTED BY ITS SECRETARY, GOPU S.NAIR. 12 KOZHIPILLY SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, P.O.KOZHIPPILY, ERNAKULAM-686 691, REPRESENTED BY ITS SECRETARY, UMADEVI.K.V. 13 POTHANICAD FARMERS SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, P.O.POTHANICAD, ERNAKULAM-686 671, REPRESENTED BY ITS MANAGING DIRECTOR PAUL P.VARGHESE. 14 PINDIMANA SERVICE CO OPERATIVE BANK LTD., HEAD OFFICE, PINDIMANA, ERNAKULAM-686 691, REPRESENTED BY ITS SECRETARY, SUBI C.VARGHESE. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 145 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. BY ADVS. SHRI.RAMKUMAR J., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 146 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11092 OF 2022 PETITIONER/S: 1 KANDANASSERY PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO.R-1141 ARIYANNOOR P.O, 680 102 REPRESENTED BY ITS SECRETARY- BIJI HAREESH 2 KUTTIKAD FARMERS SERVICE CO-OPERATIVE BANK LTD NO 572 KUTTIKAD P.O THRISSUR 680 724 REPRESENTED BY ITS MANAGING DIRECTOR LISSY K G 3 THE PULLOOT SERVICE CO-OPERATIVE BANK LTD NO. 611, PULLUT P.O, THRISSUR 680 663 REPRESENTED BY ITS SECRETARY ANITHAKUMARI M K 4 CHAVAKKAD DISTRICT AIDED PRIMARY TEACHERS CO- OPERATIVE SOCIETY LTDNO. 377 CHOONDAL P.O, THRISSUR 680 502 REPRESENTED BY ITS SECRETARY JENCY A J 5 LOKAMAKESWARAM SERVICE CO-OPERATIVE BANK LTD NO. 249 P.O KODUNGALLUR 680 664, REPRESENTED BY ITS SECRETARY IN CHARGE RASEENA P.K 6 PARALAM SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD NO R 1439 KODANNUR P.O, THRISSUR 680 563 REPRESENTED BY ITS SECRETARY PREETY MOL TOM 7 OLLUR TOWN CO-OPERATIVE SOCIETY LTD NO. R 1120 OLLUR P.O, THRISSUR, PIN 680 306 REPREENTED BY ITS SECRETARY LINTO 2025:KER W.P(C)No.7053/2023 & Connected cases 147 8 VARANDARAPPILLY PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO R 1114 VARANDRAPPILLY P.O, 680 303 REPRESENTED BY ITS SERETARY SHANTHI AJ 9 MULAYAM AYYAPPANKAVU GRAMEENA NON AGRICULTURAL CO- OPERATIVE SOCIETY LTD NO. R 1304 MULAYAM P.O THRISSUR 680 751 REPRESENTED BY ITS SECRETARY JISHA MOHAN K 0 THRISSUR DISTRICT ELECTRICITY BOARD EMPLOYEES CO- OPERATIVE SOCIETY LTD NO. R 787 POOTHOLE , P.O THRISSUR 680 004 REPRESENTED BY ITS SECRETARY SINDHU M C 11 THE KATTAKAMPAL SERVICE CO-OPERATIVE BANK LTD NO. 163, KATTAKAMPAL P.O 680 544 REPRESENTED BY ITS SECRETARY MARIAMMA C I 12 IRINJALAKUDA EDUCATIONAL DISTRICT PRIVATE SECONDARY SCHOOL TEACHERS CO-OPERATIVE SOCIETY LTD NO 703, ALOOR P.O, PIN 680 683 REPREENTED BY ITS HONANRY SECRETARY JACKSON C VAZHAPPILLY 13 OLLUR SERVICE CO-OPERATIVE BANK LTD NO. 279 OLLUR P.O, THRISSUR 680 306 REPRESENTED BY ITS SECRETARY JOJO T K 14 PARAPPUKKURA RURAL CO-OPERATIVE BANK LTD R-1101 PARAPPUKKURA P.O TRICHUR 680 310 REPRESENTED BY ITS SECRETARY BINOY K C 15 THE PAZHANJI SERVICE CO-OPEERATIVE BANK LTD NO 68 PAZHANI P.O, THRISSUR 680 542 REPRESENTED BY ITS SECRETARY SALIM M 16 MUNDUR MEGHALA VYAPARI VYAVASAYI CO-OPERATIVE SOCIETY LTD NO R 1167, MUNDUR P.O, THRISSUR 680 541 REPRESENTED BY ITS SECRETARY SUMANA P S 17 THE PEOPLES MULTIPURPOSE CO-OEPRATIVE SOCEITY LTD NO R-1223 2025:KER W.P(C)No.7053/2023 & Connected cases 148 P.O MELOOR 680 311 MELOOR 680 311 REPRESENTED BY ITS SECRETARY REJINI SOJAN 18 CHEERPU SERVICE CO-OPERATIVE BANK LTDNO. 3540 PERUMBILLISSERY P.O, THRISSUR 680 561 REPRESENTED BY ITS SECRETARY REKHA M S 19 CHALAKUDYMULTIPURPOSE CO-OPERATIVE SOCIETY LTDNO R 1213 CHALAKUDYP.O 680 307 REPRESENTED BY ITS SECRETARY P K PREETHA 0 ERUMAPETTY GRAMA PANCHAYATH VANITHA CO-OPERATIVE SOCEITY LTD NO. R 1301 CHITTANDA P.O, THRISSUR 680 585 REPRESENTED BY ITS SECRETARY JIJI V P 21 MUNDATHICODE VANITHA CO-OPERATIVE SOCEITY LTD NO R 1279 MUNDATHICODE P.O, THRISSUR 680 623 REPRESENTED BY ITS SECRETARY SEEMA JAYAPRAKASAN 22 OLLUKKARA BLOCK RUBBER TAPPING THOZHILALI CO- OPERATIVE SOCIETY LTD NO. R 1346 POOCHATTY P.O, THRISSUR 680 751 REPRESENTED BY ITS HONORARY SECRETARY SOORYAKALA SURENDRAN 23 SIFL EMPLOYEES CO-OPERATIVE CREDIT SOCIETYLTD NO. R 778 ATHANI, P.O THRISSUR 680 581 REPRESENTED BY ITS SECRETARY A K VIJAYANKUMARY 24 REGIONAL KERA KARSHAKA CO-OPERATIVE SOCIEITY LTD NO R 1203 KOZHUKULLY P.O, THRISSUR 680 751 REPRESENTED BY ITS SECRETARY T K SUMA 25 OLLUKKARA BLOCK PANCHAYATH POULTRY AND GOAT FARMERS DEVELOPMENT CO-OPERATIVE SOCEITY LTD NO. R ERAVINMANGALAM P.O, THRISSUR 680 751 REPRESENTED BY ITS SECRETARY SUNANDHA M K 26 NADATHARA PANCHAYATH VANITHA SERVICE CO-OPERATIVE SOCEITY LTD NO R 980 2025:KER W.P(C)No.7053/2023 & Connected cases 149 KOZHUKKULLY P.O THRISSUR 680 751 REPRESENTED BY ITS SECRETARY SHYBI K.V 27 OLLUR AREA HEAD ROAD AND GENEERAL WORKERS CO- OPEERATIVE SOCIETY LTD NO R 1235, MANNUTHY P.O, THRISSUR 680 651 REPRESENTED BY ITS SECRETARY RAJI P 28 THE KAIPARAMBU PANCHAYATH MULTIPURPOSE CO-OPERATIVE SOCIETY LTD NO R 1124 KAIPARAMBU P.O, THRISSUR 680 546 REPRESENTED BY ITS SECRETARY JESSY JOHN C 29 POOVATHUMKADAVU FARMERS SERVICE CO-OPERATIVE BANK LTD NO 4686 PANANGAD P.O, THRISSUR 680 665 REPRESENTED BY ITS MANAGING DIRECTOR SHEEBA V R 0 MARATHAKKARA SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD NO R 1449 MARATHAKKARA P.O, THRISSUR 680 306 REPRESENTED BY ITS SECRETARY LIGI BENNY 31 THE ORUMANAYUR SERVICE CO-OPERATIVE BANK LTD NO R 209 ORUMANAYUR P.O THRISSUR 680 512 REPRESENTED BY ITS SECRETARY IN CHARGE SUJO C A 32 THE PUNNAYURKULAM SERVICE CO-OPERATIVE BANK LTD NO. P 417 PUNNAYURKULAM P.O, THRISSUR 680 561 REPRESENTED BY ITS SECRETARY A K SATHEESH KUMAR 33 VENKITANGU FARMERS CO-OPERATIVE BANK LTD NO. R 187 VENTITANGU P.O, THRISSUR 680 510 REPRESENTED BY ITS MANAGING DIRECTOR-IN-CHARGE-ANGEL JOHN A 34 THAIKKAD SERVICE CO-OPERATIVE BANK LTD NO F 7084 BRAHMAKULAM P.O, THRISSUR 680 104 REPRESENTED BY ITS SECRETARY HARISH E M 35 OLLUKKARA AREA HOUSING CO-OPERATIVE LTD NO. R 164 MQANNUTHY P.O, THRISSUR 680 651 REPRESENTED BY ITS SECRETARY SUVARNA K K 2025:KER W.P(C)No.7053/2023 & Connected cases 150 36 GURUVAYUR VYAPARI VYAVASAYI CO OPERATIVE SOCIETY LTD NO R 1325 GURUVAYUR P.O, THRISSUR 680 101 REPRESENTED BY ITS SECRETARY SONI SATHEESH 37 CHAVAKKAD FIRKA CO-OPERATIVE RURAL BANK LTD NO F 1250 CHAVAKKAD . P.O, THRISSUR 680 506 REPRESENTED BY ITS SECRETARY IN CHARGE T VIJAYAKRISHNAN BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 ITHE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018 3 THE INCOME TAX OFFICER (TDS) AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN 680 001 4 THE KERALA STATE STATE CO-OPERATIVE BANK LTD (ERSTWHILE PATHANAMTHITTA SERVICE CO-OPERATIVE BANK) HEAD OFFICE, THRISSUR 680 001 5 THE GENERAL MANAGER KODUNGALLUR TOWN CO-OPERATIVE BANK LTD, KODUNGALLUR P.O, THRISSUR, PIN 680 664 6 THE GENERAL MANAGER THRISSUR URBAN CO-OPERATIVE BANK LTD, HEAD OFFICE, MISSION QUARTERS, THRISSUR 680 001 7 THE GENERAL MANAGER IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD, TANA 2025:KER W.P(C)No.7053/2023 & Connected cases 151 JUNCTION, IRINJALAKUDA P.O, PIN 680 121 8 THE GENERAL MANAGER GURUVAYOOR CO-OPERATIVE URBAN BANK LTD, GURUVAYOOR P.O, PIN 680 101 BY ADVS. SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.DEVAPRASANTH.P.J. SRI.C.D.DILEEP,SC,TRICHUR URBN CO-OPBAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 152 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11096 OF 2022 PETITIONER/S: 1 THIROOR SERVICE CO-OPERATIVE BANK LTD.NO.4140, THIROOR P.O., MULAMKUNNATHUKAVU, THRISSUR-680 581, REPRESENTED BY ITS SECRETARY. 2 MUNDUR SERVICE CO-OPERATIVE BANK LTD.NO.189, P.O.ANJUR MUNDUR, THRISSUR-680 541, REPRESENTED BY ITS SECRETARY. 3 VADADIAM SERVICE CO OPERATIVE BANK LTD. NO.575, P.O.AVANUR, THRISSUR-680 541, REPRESENTED BY ITS SECRETARY. 4 THE THRISSUR SERVICE CO OPERATIVE BANK LTD. NO.R 1097, PATTURAIKKAL,THRISSUR-22, REPRESENTED BY ITS SECRETARY. 5 MOOSPET SERVICE CO OPERATIVE BANK LT. NO.682, MOOSPET, THRISSUR-5, REPRESENTED BY ITS SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 153 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM- 682 018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER 9TDS), AAYAKAR BAHVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001. 4 THE KERALA STATE CO OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SMT.H.SUBHALEKSHMI, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 154 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11117 OF 2022 PETITIONER/S: CHIRANELLUR SERVICE CO-OPERATIVE BANK LTD., NO.640, CHIRANELLUR P.O., THRISSUR DISTRICT - 680 501, REPRESENTED BY ITS SECRETARY BY ADVS. SRI.GEORGE POONTHOTTAM (SR.) SMT.NISHA GEORGE SHRI.ANSHIN K.K SHRI.REGINALD VALSALAN 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, PIN-695 003. 2 THE CENTARL 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, PIN 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. 2025:KER W.P(C)No.7053/2023 & Connected cases 155 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O., THIRUVANANTHAPURAM, PIN - 695 014. 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695 001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695 033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.JUSTUS S., CGC SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 156 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11130 OF 2022 PETITIONER/S: 1 THIRUVANANTHAPURAM TALUK PRESS THOZHILALY WELFARE CO- OPERATIVE SOCIETY LTD. NO.T-1651, KOLIYAKODE, INDUSTRIAL ESTATE.P.O, THIRUVANANTHAPURAM-695019, REPRESENTED BY ITS SECRETARY. 2 TERUMO PENPOL EMPLOYEES CO-OPERATIVE SOCIETY LTD, NO.T1293, PULIYARAKONAM, THIRUVANANTHAPURAM-695573, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.A.CHANDRA BABU SMT.REMYA MURALI SHRI.AVIJITH A.V SMT.PREJITHA S.SALIM SMT.APARNA SARASWATI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILLS, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 2025:KER W.P(C)No.7053/2023 & Connected cases 157 3 THE INCOME TAX OFFICER,(TDS), AAYAKAR BHAVAN, PEROORKADA ROAD, KOWDIAR, THIRUVANANTHAPURAM, KERALA-695003. 4 THE KERALA STATE CO-OPERATIVE BANK (KERALA BANK), FORT MAIN BRANCH, EAST FOR, FORT.P.O, THIRUVANANTHAPURAM-695023, REPRESENTED BY ITS BRANCH MANAGER. 5 THE KERALA STATE CO-OPERATIVE BANK , MALAYINKEEZHU BRANCH, MALAYINKEEZHU.P.O, THIRUVANANTHAPURAM-695571, REPRESENTED BY ITS BRANCH MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 158 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11135 OF 2022 PETITIONER/S: ULLALA SERVICE CO-OPERATIVE BANK LTD NO.1142 ULLALA, THALAYAZHAM P.O, KOTTAYAM - 686607, REPRESENTED BY ITS SECRETARY MIDHUNLAL K.M. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA 2025:KER W.P(C)No.7053/2023 & Connected cases 159 REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI - 682018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695003. 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695001. BY ADVS. SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 160 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11138 OF 2022 PETITIONER/S: KANIPPAYOOR SERVICE CO-OPERATIVE BANK LTD. NO. 280 KANIPPAYOOR P.O, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.GEORGE POONTHOTTAM (SR.) SMT.NISHA GEORGE SHRI.ANSHIN K.K SHRI.REGINALD VALSALAN 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 - PIN - 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, NEW DELHI - PIN - 110001. 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 161 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O, THIRUVANANTHAPURAM - PIN - 695014. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION , GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - PIN - 695001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - PIN - 695033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 162 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11144 OF 2022 PETITIONER/S: 1 THE AVOLY SERVICE CO-OPERATIVE BANK LTD, NO. 2950, AVOLY P.O, MUVATTUPUZHA, ERNAKULAM DISTRICT - 686670, REPRESENTED BY ITS SECRETARY. 2 THE KALLOORKAD FARMERS CO-OPERATIVE BANK LTD, NO. 2605. KALLOORKAD P.O, MUVATTUPUZHA, ERNAKULAM DISTRICT - 686668, REPRESENTED BY THE MANAGING DIRECTOR IN CHARGE. 3 ENANALLOOR SERVICE CO-OPERATIVE BANK LTD NO. 1447. AYAVANA P.O, MUVATTUPUZHA, ERNAKULAM DISTRICT - 686668, REPRESENTED BY ITS SECRETARY. 4 THE MULANTHURUTHY SERVICE CO-OPERATIVE BANK LTD NO. 23, MULANTHURUTHY, ERNAKULAM DISTRICT - 682314, REPRESENTED BY ITS SECRETARY. 5 THE PANANGAD SERVICE CO-OPERATIVE BANK LTD NO. 655, PANANGAD P.O, ERNAKULAM DISTRICT - 682506, REPRESENTED BY ITS SECRETARY. 6 THE MARADU SERVICE CO-OPERATIVE BANK LTD NO. 43, MARADU P.O, ERNAKULAM DISTRICT - 682304, REPRESENTED BY ITS SECRETARY. BY ADVS. SMT.NISHA GEORGE SHRI.REGINALD VALSALAN 2025:KER W.P(C)No.7053/2023 & Connected cases 163 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, PIN - 695003. 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 - PIN - 110001. 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O, THIRUVANANTHAPURAM - PIN - 695014. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - PIN - 695001. 6 THE KERALA STATE CO-OPERATIVE BANK REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.PRAVEEN K.V., CGC SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 164 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11143 OF 2022 PETITIONER/S: PEECHI SERVICE CO-OPERATIVE BANK LTD NO R-935 PATTIKKAD P.O, THRISSUR - 680652, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.GEORGE POONTHOTTAM (SR.) SMT.NISHA GEORGE SHRI.ANSHIN K.K SHRI.REGINALD VALSALAN 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, PIN - 695003. 2 THE CENTRAL BOARD OF DIRECTOR TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI - PIN - 110001. 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 165 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES. THIRUVANANTHAPURAM - PIN - 695001. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001. 6 THE KERALA STATE CO-OPERATIVE BANK REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - PIN - 695033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 166 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11149 OF 2022 PETITIONER/S: ERNAKULAM DISTRICT GOVERNMENT COLLEGE EMPLOYEES CO- OPERATIVE SOCIETY LIMITED NO.E 844, MAHARAJAS COLLEGE, ERNAKULAM REPRESENTED BY ITS SECRETARY. BY ADVS. SMT.A.K.PREETHA SRI.C.ANIL KUMAR SHRI.JITHIN VARGHESE RESPONDENT/S: 1 COMMISSIONER OF INCOME TAX(TDS) C.R.BUILDING, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682 018. 2 THE INCOME TAX OFFICER (TDS) C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682 018. 3 KERALA STATE CO-OPERATIVE BANK LTD, MARINE DRIVE BRANCH, ERNAKULAM - 682 031 REPRESENTED BY ITS BRANCH MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 167 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 168 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11150 OF 2022 PETITIONER/S: THIRUVAMKULAM SERVICE CO-OPERATIVE SOCIETY LIMITED NO.26, THIRUVAMKULAM, ERNAKULAM - 682 305, REPRESENTED BY ITS PRESIDENT K.B.JAYAKUMAR. BY ADVS. SMT.A.K.PREETHA SRI.C.ANIL KUMAR SHRI.JITHIN VARGHESE RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX(TDS) C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682 018. 2 THE INCOME TAX OFFICER (TDS) C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 682 018. 3 KERALA STATE CO-OPERATIVE BANK LTD. THRIPUNITHURA BRANCH, STATUE, THRIPUNITHURA - 682 301 REPRESENTED BY ITS BRANCH MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 169 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 170 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11165 OF 2022 PETITIONER/S: KERALA HIGH COURT EMPLOYEES CREDIT CO-OPERATIVE SOCIETY LTD NO. E.830, HIGH COURT BUILDING, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 682031. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN - 682018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, ERNAKULAM, PIN - 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033. 5 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LTD, MARINE DRIVE BRANCH, ERNAKULAM, PIN - 682001. 2025:KER W.P(C)No.7053/2023 & Connected cases 171 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 172 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11171 OF 2022 PETITIONER/S: THE DEVASWAM BOARD EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.K 458, ETTUMANOOR, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 686 001. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, AYKAR BHAVAN, KOTTAYAM, PIN - 686 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 5 THE MANAGER THE KERALA STATE CO-OPERATIVE BANK LTD., ETTUMANOOR, KOTTAYAM DISTRICT, PIN - 686 631. 2025:KER W.P(C)No.7053/2023 & Connected cases 173 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 174 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11187 OF 2022 PETITIONER/S: 1 MAVILAYIL SERVICE CO-OPERAITVE BANK LTD MAVILAYI P.O., KANNUR - 670 622, REPRESENTED BY ITS SECRETARY KINCE VARGHESE. 2 PAZHASSI SERVICE CO-OPERATIVE BANK LTD. NO.F 1532, P.O.MATTANNUR, KANNUR - 670 702, REPRESENTED BY ITS SECRETARY SARALA K.C. 3 KUTTYERI SERVICE CO-OPERATIVE BANK LTD. NO.1266, HEAD OFFICE, KUTTYERI P.O., KANNUR - 670 142, REPRESENTED BY ITS SECRETARY BALAKRISHNAN P. 4 KUTHUPARAMBA SERVICE CO-OPERATIVE BANK LTD. NO.F 1507, HEAD OFFICE, KUTHUPARAMBA P.O., KANNUR - 670 643, REPRESENTED BY ITS SECRETARY M.BEENA. 5 CHENGALAYI SERVICE CO-OPERATIVE BANK LTD. NO.C 101, HEAD OFFICE, CHENGALAYI P.O., KANNUR - 670 631 REPRESENTED BY ITS SECRETARY SHAJI E.V. 6 IRITTY CO OPERATIVE RURAL BANK LTD. IRITTY P.O., KANNUR - 670 703 REPRESENTED BY ITS SECRETARY SUJATHA P.T. 7 KARIVELLUR SERVICE CO-OPERATIVE BANK LTD. KARIVELLUR P.O., KANNUR - 670 521, REPRESENTED BY ITS SECRETARY SARASWATHI R. 8 KADANNAPPALLY PANAPUZHA SERVICE CO-OPERATIVE BANK LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 175 P.O.KADANNAPPALLY, KANNUR - 670 501 REPRESENTED BY ITS SECRETARY MADHUSOODANAN V.V. 9 EDAKKADAPPAN SERVICE CO OPERATIVE BANK LTD. P.O.EDAKKAD, KANNUR - 670 663 REPRESENTED BY ITS SECRETARY DILEEP KUMAR T. 0 CHALA SERVICE CO-OPERATIVE BANK LTD. CHALA WEST, THOTTADA P.O., KANNUR - 670 007, REPRESENTED BY ITS SECRETARY REETHA K.P. 11 MORAZHA KALLIASSERY SERVICE CO-OPERATIVE BANK LTD. P.O.ANCHAMPEEDIKA, KANNUR - 670 631 REPRESENTED BY ITS SECRETARY T.N., MADHUSOODNAN. 12 NARATH SERVICE CO OPERATIVE BANK LTD. P.O.NARATH, KANNUR - 670 601 REPRESENTED BY ITS SECRETARY BHAGYANANTHAN P.M. 13 KANHIRODE SERVICE CO-OPERATIVE BANK LTD. P.O.KANHIRODE, KANNUR - 670 592, REPRESENTED BY ITS SECRETARY PRADEEP K. 14 KOOVERI SERVICE CO-OPERATIVE BANK LTD. P.O.CHAPPARAPADAVU, KANNUR - 670 581 REPRESENTED BY ITS SECRETARY K.BHANUPRAKASHAN. 15 ELAYAVOOR SERVICE CO-OPERATIVE BANK LTD. P.O.KUNAYAD, KANNUR - 670 594 REPRESENTED BY ITS SECRETARY SURESH BABU P. 16 PAPPINISSERI SERVICE CO-OPERATIVE BANK LTD. P.O.PAPPINISSERI, KANNUR - 670 561 REPRESENTED BY ITS SECRETARY PREMAN KUNNIRIKKAN. 17 MATTUL SERVICE CO-OPERATIVE BANK LTD. P.O.MATTUL BORTH, KANNUR - 670 325 REPRESENTED BY ITS SECRETARY RAJU M. 18 IRIKKUR SERVICE CO-OPERATIVE BANK LTD. IRIKKUR P.O., KANNUR - 670 593 REPRESENTED BY ITS SECRETARY MANEESH P.V. 2025:KER W.P(C)No.7053/2023 & Connected cases 176 19 KANNUR SERVICE CO-OPERATIVE BANK LTD. THANA P.O., KANNUR - 670 012 REPRESENTED BY ITS SECRETARY JYOTHI A.M. 0 KALLAD SERVICE CO-OPERATIVE BANK LTD. KALLIAD P.O., KANNUR - 670 593 REPRESENTED BY ITS SECRETARY SAJITHKUMARI M. 21 KOTTIYOOR SERVICE CO-OPERATIVE BANK LTD. P.O.KOTTIYOOR, KANNUR - 670 651 REPRESENTED BY ITS SECRETARY SANITHA C.L. 22 PERINGOME SERVICE CO-OPERATIVE BANK LTD. P.O.PERINGOME, KANNUR 670 653 REPRESENTED BY ITS SECRETARY GEETHA K.R. 23 MOWANCHERY CO-OPERATIVE RURAL BANK LTD. P.O.MOWANCHERY, KANNUR - 670 613 REPRESENTED BY ITS SECRETARY RAMESHBABU C.P. 24 MANGATTIDOM SERVICE CO-OPERATIVE BANK LTD. P.O.MANGATTIDOM, KANNUR - 670 643 REPRESENTED BY ITS SECRETARY RETHNAKARAN T. 25 ERAMAM KUTTUR SERVICE CO-OPERATIVE BANK LTD. P.O.MATHAMANGALAM BAZAR, KANNUR - 670 306 REPRESENTED BY ITS SECRETARY RAJAMOHAN K.V. 26 POYILOOR SERVICE CO-OPERATIVE BANK LTD. P.O.POYILOOR, KANNUR - 670 693 REPRESENTED BY ITS SECRETARY PRAJEESH K. 27 THILLENKERI SERVICE CO-OPERATIVE BANK LTD. P.O.THILLENKERI, KANNUR - 670 702 REPRESENTED BY ITS SECRETARY UJALAKUMARI P.M. 28 PADITOTCHAL SERVICE CO-OPERATIVE BANK LTD. P.O.PADIYOTCHAL, KANNUR - 670 353 REPRESENTED BY ITS SECRETARY SMITHA K.N. 29 KANNADIPARAMBA SERVICE CO-OPERATIVE BANK LTD. P.O.KANNADIPARAMBA, KANNUR - 670 604 REPRESENTED BY ITS SECRETARY PURUSHOTHAMAN K. 2025:KER W.P(C)No.7053/2023 & Connected cases 177 0 KANDAMKUNNU SERVICE CO-OPERATIVE BANK LTD. NIRMALAGIRI, KANNUR - 670 701 REPRESENTED BY ITS SECRETARY BABU P. 31 PATTUVAM SERVICE CO-OPERATIVE BANK LTD. P.O.PATTUVAM, KANNUR - 670 701 REPRESENTED BY ITS SECRETARY SRIVINVASAN K.P. 32 PARIYARAM SERVICE CO-OPERATIVE BANK LTD. PARIYARAM P.O., KANNUR - 670 502 REPRESENTED BY ITS SECRETARY SASEENDRAN N. 33 KANHILERI- SIVAPURAM SERVICE CO-OPERATIVE BANK LTD. P.O.KANHILERI, KANNUR - 670 702 REPRESENTED BY ITS SECRETARY M.REJITHA. 34 KAPPAD SERVICE CO-OPERATIVE BANK LTD. P.O.KAPPAD, KANNUR - 670 006 REPRESENTED BY ITS SECRETARY RAJEEVAN P.K. 35 PAYYANNUR SERVICE CO-OPERATIVE BANK LTD. P.O.PAYYANNUR, KANNUR - 670 307 REPRESENTED BY ITS SECRETARY NISHA T.V. 36 KOROM SERVICE CO-OPERATIVE BANK LTD. P.O.KANAYI, PAYYANNUR, KANNUR - 670 307 REPRESENTED BY ITS SECRETARY SURENDRAN K.C. 37 PANNIYANUR SERVICE CO-OPERATIVE BANK LTD. P.O.PANNIYANNUR, KANNUR - 670 671 REPRESENTED BY ITS SECRETARY PAVITHRAN K. 38 CHUZHALI SERVICE CO-OPERATIVE BANK LTD. P.O.CHUZHALI, KANNUR 670 142 REPRESENTED BY ITS SECRETARY SAJEESH KUMAR P.K. 39 PUZHATHI SERVICE CO-OPERATIVE BANK LTD. P.O.KAKKAD, KANNUR - 670 005 REPRESENTED BY ITS SECRETARY JAYARAJAN P. 40 KADAMBOOR SERVICE CO-OPERATIVE BANK LTD. P.O.EDAKKAD, KANNUR - 670 663 REPRESENTED BY ITS SECRETARY PRAMEELA C. 2025:KER W.P(C)No.7053/2023 & Connected cases 178 41 MUZHAKUNNU SERVICE CO-OPERATIVE BANK LTD. P.O.CHITTARIPARAMBA, KANNUR 670 650 REPRESENTED BY ITS SECRETARY SACHITHA K. 42 KADACHIRA SERVICE CO-OPERATIVE BANK LTD. P.O.KADACHIRA, KANNUR - 670 621 REPRESENTED BY ITS SECRETARY SANIL P. 43 AZHIKODE SERVICE CO-OPERATIVE BANK LTD. P.O.AZHIKODE, KANNUR - 670 009 REPRESENTED BY ITS SECRETARY RAJEEVAN M.K. 44 PERALASSERI SERVICE CO-OPERATIVE BANK LTD. MUNDALLUR P.O., KANNUR - 670 622 REPRESENTED BY ITS SECRETARY KAMALAKSHAN K.P. 45 KEEZXHALLUR SERVICE CO-OPERATIVE BANK LTD. MATTANNUR P.O., KANNUR - 670 702 REPRESENTED BY ITS SECRETARY MURALIDHARAN P.M. 46 MALAPATTOM SERVICE CO-OPERATIVE BANK LTD. MALAPATTOM P.O., KANNUR - 670 631 REPRESENTED BY ITS SECRETARYJAYALAKSHMI P.T. 47 KUTHUPARAMBA SERVICE CO-OPERATIVE BANK LTD. P.O.KOOTHUPARAMBA, KANNUR - 670 643 REPRESENTED BY ITS SECRETARY SAJIMA K.P. 48 CHERUKUNU SERVICE CO-OPERATIVE BANK LTD. P.O.CHERUKUNNU, KANNUR - 670 301 REPRESENTED BY ITS SECRETARY BABURAJ E. 49 PAYYAVOOR SERVICE CO-OPERATIVE BANK LTD. P.O.PAYYAVOOR, KANNUR - 670 633 REPRESENTED BY ITS SECRETARY RAJESH KUMAR M.V. 50 KANKOL SERVICE CO-OPERATIVE BANK LTD. P.O.KANKOL, KANNUR - 670 307 REPRESENTED BY ITS SECRETARY RATHI K.P. 51 ULIKKAL SERVICE CO-OPERATIVE BANK LTD. P.O.ULIKKAL, KURUVA, KANNUR - 670 505 REPRESENTED BY ITS SECRETARY BINU THOMAS. 2025:KER W.P(C)No.7053/2023 & Connected cases 179 52 KUNNARU SERVICE CO-OPERATIVE BANK LTD. P.O.PALAKKODE, KANNUR - 670 305 REPRESENTED BY ITS SECRETARY SUNIL KUMAR K.P. 53 PATTIAM SERVICE CO-OPERATIVE BANK LTD. P.O.PATHAYAKUNNU, KANNUR - 670 691 REPRESENTED BY ITS SECRETARY SREEJAKUMAR P. 54 MATHIL SERVICE CO-OPERATIVE BANK LTD. MATHIL P.O., KANNUR - 670 307 REPRESENTED BY ITS SECRETARY THAMBAN T. 55 KOLARI SERVICE CO-OPERATIVE BANK LTD. KOLARI P.O., KANNUR - 670 702 REPRESENTED BY ITS SECRETARY K.NARAYANAN. 56 KURUMATHUR SERVICE CO-OPERATIVE BANK LTD. P.O.KURUMATHUR, KANNUR - 670 142 REPRESENTED BY ITS SECRETARY RAVICHANDRAN E. 57 P;ONNAMPARA SERVICE CO-OPERATIVE BANK LTD. P.O.PERINGOM, KANNUR - 670 307 REPRESENTED BY ITS SECRETARY SHEEBA V.V. 58 KUTHUPARAMBA CO OPERATIVE RURAL BANK LTD. P.O.KOOTHUPARAMBA, KANNUR - 670 643 REPRESENTED BY ITS SECRETARY T.P.YAMUNA. 59 VENGAD SERVICE CO-OPERATIVE BANK LTD. P.O.VENGAD, KANNUR - 670 612 REPRESENTED BY ITS SECRETARY VIMALA M. 60 VALIYANNUR SERVICE CO-OPERATIVE BANK LTD. P.O.VARAM, KANNUR - 670 599 REPRESENTED BY ITS SECRETARY SUNIL KUMAR P. 61 KUNHUMANGALAM SERVICE CO-OPERATIVE BANK LTD. P.O.KUNHIMANGALAM, KANNUR - 670 309 REPRESENTED BY ITS SECRETARY USHA KUMARI V.P. 62 KOYYODE SERVICE CO-OPERATIVE BANK LTD. P.O.KOYYODE, KANNUR - 670 621 REPRESENTED BY ITS SECRETARY SHISNA T.C. 2025:KER W.P(C)No.7053/2023 & Connected cases 180 63 ALAKKODE SERVICE CO-OPERATIVE BANK LTD. P.O.ALAKKODE, KANNUR - 670 571 REPRESENTED BY ITS SECRETARY E.A.JOSEPH. 64 IRINAV SERVICE CO-OPERATIVE BANK LTD. P.O.IRINAV, KANNUR 670 301 REPRESENTED BY ITS SECRETARY K.RAJEEVAN. 65 PALLIKKUNNU SERVICE CO-OPERATIVE BANK LTD. P.O.CHALAD, KANNUR - 670 014 REPRESENTED BY ITS SECRETARY ANILA M. 66 KANNAPURAM SERVICE CO-OPERATIVE BANK LTD. P.O.CHERUKUNNU, KANNUR - 670 301 REPRESENTED BY ITS SECRETARY ARUNAKUMAR T.K. 67 VELLUR SERVICE CO-OPERATIVE BANK LTD. P.O.VELLUR, PAYYANUR, KANNUR - 670 307 REPRESENTED BY ITS SECRETARY THANKAMANI K. 68 MULLAKKODI CO-OPERATIVE RURAL BANK LTD. P.O.KOLACHERI, KANNUR - 670 601 REPRESENTED BY ITS SECRETARY VALSAN T.V. 69 RAMANTHALI SERVICE CO-OPERATIVE BANK LTD. P.O.RAMANTHALI, KANNUR 670 308 REPRESENTED BY ITS SECRETARY K.V.SURENDRAN. 70 PATHIRIYAD SERVICE CO-OPERATIVE BANK LTD. NO.F 1465, P.O.PATHIRIYAD, KANNUR - 670 741 REPRESENTED BY ITS SECRETARY RUBY CHACKO. 71 AECHOOR SERVICE CO-OPERATIVE BANK LTD. NO.L 75, P.E.EACHUR, KANNUR - 670 591 REPRESENTED BY ITS SECRETARY SHAJI P.P. 72 KANNUR TOWN SERVICE CO-OPERATIVE BANK LTD. P.O.KANNUR, KANNUR - 670 002 REPRESENTED BY ITS SECRETARY BEENA E. 73 PUNNAD SERVICE CO-OPERATIVE BANK LTD. NO.LL 57, P.O.IRITTY, KANNUR - 670 703 REPRESENTED BY SECRETARY K.C.RAJEEV. 2025:KER W.P(C)No.7053/2023 & Connected cases 181 74 PERAVOOR REGIONAL SERVICE CO-OPERATIVE BANK LTD. NO.C 338, HEAD OFFICE, PERAVOOR, P.O.PERAVOOR, KANNUR - 670 673 REPRESENTED BY ITS SECRETARY BALAKRISHNAN V.V. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 4 PRINCIPAL COMMISSIONER OF INCOME OF TAX KOZHIKODE AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE - 673 001. 5 INCOME TAX OFFICER TDS WARD TDS, KANNUR, AYAKAR BHAVAN, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, KANNOTHUMCHAL, CHOVVA P.O., KANNUR - 670 006. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF 2025:KER W.P(C)No.7053/2023 & Connected cases 182 EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. SHRI.VIVEK A.V. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 183 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11184 OF 2022 PETITIONER/S: PUTHUPPALLY SERVICE CO-OPERATIVE BANK LTD N.O 1504, HEAD OFFICE, PUTHUPPALLY P.O.KOTTAYAM-686 611, REPRESENTED BY ITS SECRETARY BALAKRISHNAN K.N. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001. 2 THE CENTRAL BOARD OF DIRECTO TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF, COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 184 INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANNTHAPURAM-695 003. 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKARA BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANNTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 185 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11186 OF 2022 PETITIONER/S: 1 THE PANACHIKKADU REGIONAL SERVICE CO-OPERATIVE BANK LTD NO.3959 CHANNANIKKADU P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY. 2 THE KOLLAD SERVICE CO-OPERATIVE BANK LTD NO 1830, KOLLAD P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 3 THE MEENADOM SERVICE CO-OPERATIVE BANK LTD NO K 401, MEENADOM P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 4 THE ANICKAD REGIONAL FARMERS SERVICE CO-OPERATIVE BANK LTD NO 3867, ANICKAD P.O.PALLICKATHODU, KOTTAYAM DISTRICT, REPRESENTED BY ITS MANAGING DIRECTOR 5 THE KOOROPPADA SERVICE CO-OPERATIVE BANK LTD NO 3965, KOROPPADA P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY. 6 THE VELLOOR SERVICE CO-OPERATIVE BANK LTD NO K 231, VELLOOR P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 7 THE PAMPADY SERVICE CO-OPERATIVE BANK LTD NO K 831, PAMPADY P.O.KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 2025:KER W.P(C)No.7053/2023 & Connected cases 186 8 KUMARAKOM VADAKKUMBHAGOM SERVICE CO-OPERATIVE BANK LIMITED NO 1070, KUMARAKOM, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM, PIN-682 018 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 187 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11194 OF 2022 PETITIONER/S: THALAYAZHAM SERVICE CO-OPERATIVE BABK LTD NO 509 THALAYAZHAM P.O., KOTTAYAM - 686 607, REPRESENTED BY ITS SECRETARY JOSE K.O. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA 2025:KER W.P(C)No.7053/2023 & Connected cases 188 REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 033. 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695 003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (C-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. SHRI.RAMKUMAR J., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 189 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11203 OF 2022 PETITIONER/S: 1 THE VANDIPERIYAR SERVICE CO-OPERATIVE BANK LTD.NO.K- 354, REPRESENTED BY ITS SECRETARY, SAJEESH MATHEW, AGED 32 YEARS, S/O.MATHEW, HEAD OFFICE, VANDIPERIYAR P.O., IDUKKI-685 533. 2 THE KOKKAYAR SERVICE CO-OPERATIVE BANK LTD. NO.3267, REPRESENTED BY ITS SECRETARY, SHAMEENA.N.I., D/O.ISMAIL, AGED 48 YEARS, HEAD OFFICE, NARAKAMPUZHA, KOOTTIKKAL P.O., IDUKKI-685 514. 3 THE PERUVANTHANAM SERVICE CO-OPRATIVE BANK LTD. NO.K 186, REPRESENTED BY ITS SECRETARY, SHEENA JOSEPH, W/O.JOSE THOMAS, AGED 46 YEARS, HEAD OFFICE, PERUVANTHANAM P.O., IDUKKI-685 532. 4 THE PAMBANASR SERVICE CO-OPERATIVE BANK LTD. NO.K- 351, REPRESENTED BY ITS SECRETARY, P.SUDHESH KUMAR, AGED 57 YEARS, S/O.PRABHAKARAN NAIR, HEAD OFFICE, PAMBANAR P.O., IDUKKI DISTRICT-685 531. 5 THE CHENKARA SERVICE CO-OPERATIVE BANK LTD. NO.I-254, REPRESENTED BY ITS SECRETORY, MARYKUTTY JOSEPH, W/O.GEORGE, AGED 57 YEARS, HEAD OFFICE, CHELIMADA, KUMILY P.O., IDUKKI-685 507. BY ADVS. 2025:KER W.P(C)No.7053/2023 & Connected cases 190 SRI.GEORGE MATHEW SHRI.PRAVEEN S. SMT.ELSA DENNY PINDIS SRI.M.D.SASIKUMARAN SHRI.SUNIL KUMAR A.G SRI.DIPU JAMES SHRI.MATHEW K.T. SHRI.GEORGE K.V. SHRI.STEPHY K REGI RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 002. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018. 3 THE INCOME TAX OFFICER, TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8, THODUPUZHA, IDUKKI DISTRICT-685 584. 4 STATE OF KERALA, REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM-695 014. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., (KERALA BANK), REPRESENTED BY ITS MANAGING DIRECTOR 7 CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033. 7 THE DEPUTY GENERAL MANAGER, CENTRAL PROCESSING CENTER, THE KERALA STATE CO 2025:KER W.P(C)No.7053/2023 & Connected cases 191 OPERATIVE BANK LTD., (KERALA BANK), VAZHATHOPE, IUKKI COLONY P.O., IDUKKI DISTRICT-685 602. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 192 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11224 OF 2022 PETITIONER/S: KOTHAVARA SERVICE CO-OPERATIVE BANK LTD, NO. 1359, KOTHAVARA P.O. KOTTAYAM 686 607, REPRESENTED BY ITS SECRETARY, ANILKUMAR V.S. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 11001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 11001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 193 INDIA, CENTRAL REVENUE, BUILDINGS, I.S. PRESS ROAD KOCHI 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANCE 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM 695 003. 5 INCOME TAX OFFICER, (TDS), THIRUVANANTHAPURAM , 3RD FLOOR AAYAKAR BAHVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003. 6 THE KERALA STATE CO - OPERATIVE BANK LTD, PB NO. 6515, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001. BY ADVS. SHRI.JUSTUS S., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SMT.SINDHUMOL.T.P., CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 194 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11232 OF 2022 PETITIONER/S: THE KALAMASSERY SERVICE CO-OPERATIVE BANK LIMITED NO. 3046, KALAMASSERY NORTH, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, 683 104. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM 682 018. 2 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, ERNAKULAM, 680001. 3 THE KERALA STATE CO - OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR 695 033. 4 THE MANAGER, KERALA STATE CO OPERATIVE BANK LTD., KALAMASSERY, PATHADIPALAM BRANCH, ERNAKULAM 682 104. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 195 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11248 OF 2022 PETITIONER/S: 1 THUDANGAD SERVICE CO-OPERATIVE BANK LTD.NO. 2410 REPRESENTED BY ITS SECRETARY, BENNY MATHEW, S/O MATHEW, AGED 56 YEARS, HEAD OFFICE, THUNDANGANGAD P O, IDUKKI-685587. 2 KODIKULAM SERVICE CO-OPERATIVE BANK LTD.NO.2823 REPRESENTED BY ITS SECRETARY, ABIN MICHAEL, S/O MICHAEL, AGED 28 YEARS, HEAD OFFICE, KODIKULAM P O, IDUKKI-685582. 3 UDUMBANOOR SERVICE CO-OPERATIVE BANK LTD.NO. E-93 REPRESENTED BY ITS SECRETARY, , REMYA BALACHANDRAN, W/O AJEESH KUMAR, AGED 37 YEARS, HEAD OFFICE, UDUMBANOOR P O, IDUKKI DISTRICT-685595. 4 KARIKODE SERVICE CO-OPERATIVE BANK LTD NO.4009. REPRESENTED BY ITS SECRETARY, MOLLY P V, W/O SUNNY P J, AGED 56 YEARS,HEAD OFFICE, KARIKODE, THODUPUZHA P O, IDUKKI-685584. 5 MANAKKAD SERVICE CO-OPERATIVE BANK LTD NO. 1706 REPRESENTED BY ITS SECRETARY, NIRMAL SHAJI, S/O SHAJI, AGED 31 YEARS, MANAKKAD, MANAKKAD P O, IDUKKI- 685608. 6 PURAPUZHA SERVICE CO-OPERATIVE BANK LTD NO.E-70 AGED 46 YEARS REPRESENTED BY ITS SECRETARY, IN -CHARGE, BINDUMOL M J, W/O SREEKUMAR B, HEAD OFFICE, PURAPUZHA P O, PURAPUZHA, IDUKKI-685583. 2025:KER W.P(C)No.7053/2023 & Connected cases 196 7 THE ARAKULAM FARMERS SERVICE CO-OPERATIVE BANK LTD NO.E-70 AGED 55 YEARS REPRESENTED BY ITS MANAGING DIRECTOR, JOSHY V MATHEW, S/O MATHEW, HEAD OFFICE, ARAKULAM P O, THODUPUZHA, IDUKKI, -685591. 8 KUMARAMANGALAM SERVICE CO-OPERATIVE BANK LTD NO.4122M, REPRESENTED BY ITS SECRETARY, AJITH V ABRAHAM, S/O ROY ABRAHAM, AGED 27 YEARS, HEAD OFFICE, KALOOR EAST, KALOOR P O, IDUKKI-685608. 9 VELLIYAMATTAM, SERVICE CO-OPERATIVE BANK LTD NO.3958 AGED 50 YEARS REPRESENTED BY ITS SECRETARY IN-CHARGE, JOJO SEBASTIAN, S/O SEBASTIAN, HEAD OFFICE, PANNIMATTAM P O, THODUPUZHA-685588. 10 THE PUTHUPARIYARAM SERVICE CO-OPERATIE BANK LTD.NO.E- 55. REPRESENTED BY ITS SECRETARY JENCY MATHEW, AGED 50 YEARS, W/O SEBASTIAN, PUTHUPARIYARAM P O, IDUKKI- 685608. 11 THE THODUPUZHA TALUK RURAL MERCHATNT'S CO-OPERATIVE WELFARE SOCIETY LTD.NO.I-768, REPRESENTED BY ITS SECRETARY,SHAJI VARGHESE, S/O VARGHESE, AGED 54 YEARS, EDAVETTY P O, THODUPUZHA TALUK, IDUKKI DISTRICT-685588. 12 THODUPUZHA TOWN SERVICE CO-OPERATIVE BANK LTD NO.I- 233 REPRESENTED BY ITS SECRETARY, RAKHI C, W/O JAGADEESH, AGED 41 YEARS, HEAD OFFICE, THODUPUZHA P O, IDUKKI- 685584. 13 THE THODUPUZHA SERVICE CO-OPERATIVE BANK LTD NO.969. REPRESENTED BY ITS SECRETARY, JAYASREE P, W/O T R SOMAN, AGED 50 YEARS, HEAD OFFICE, THODUPUZHA P O, IDUKKI-685584. 14 THE IDUKKI DISTRICT KERALA BANK EMPLOYES' CO- OPERATIVE SOCIETY NO.E-323 2025:KER W.P(C)No.7053/2023 & Connected cases 197 REPRESENTED BY ITS SECRETARY, JAYACHANDRAN K, S/O P K KARUNAKARAN NAIR, HEAD OFFICE, VAZHATHOPE, IDUKKI COLONY P O, IDUKKI DISTRICT-685602. 15 THE THODUPUZHA TALUK REGIONAL SOCIAL WELFARE CO- OPERATIVE SOCIETY LTD NO.I-690, REPRESENTED BY ITS SECRETARY, ANJITH REJI, AGED 27 YEARS, S/O P N REJI, VENGALLUR P O, THODUPUZHA TALUK, IDUKKI DISTRICT-685608. BY ADVS. SRI.GEORGE MATHEW SHRI.PRAVEEN S. SMT.ELSA DENNY PINDIS SRI.M.D.SASIKUMARAN SHRI.SUNIL KUMAR A.G SRI.DIPU JAMES SHRI.MATHEW K.T. SHRI.GEORGE K.V. SHRI.STEPHY K REGI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110002. 2 THE COMMISSINER OF INCOME TAX CENTRAL REVENUE BUILDINGS I.S.PRESS ROAD, KOCHI- 682018. 3 THE INCOME TAX OFFICER TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8, THODUPUZHA, IDUKKI DISTRICT-685584. 4 STATE OF KERALA REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES 2025:KER W.P(C)No.7053/2023 & Connected cases 198 OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM-695014. 6 THE KERALA STATE CO-OPERATIVE BANK LTD REPRESENTED BY MANAGING DIRECTOR AND CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695033. 7 THE DEPUTY GENERAL MANAGER CENTER PROCESSING CENTRE, THE KERALA STATE CO- OPERATIVE BANK LTD, (KERALA BANK), VAZHATHOPER, IDUKKI COLONY P O, IDUKKI DISTRICT-685602. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 199 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11247 OF 2022 PETITIONER/S: 1 THE KUMARANALLOOR SERVICE CO-OPERATIVE BANK LTD. NO.3998, PERUMPAIKKAD P O, KOTTAYAMM DISTRICT, REPRESENTED BY ITS SECRETARY. 2 THE NEEENDOOR SERVICE CO-OPERATIVE BANK LTD. NO.2641 NEENDOOR P O, KOTTAYAM DISTRICT, PIN-686601. REPRESENTED BY ITS SECRETARY. 3 THE KAIPUZHA SERVICE CO-OPERATIVE BANK LTD. NO.3793 KAIPUZHA P O, KOTTAYAM DISTRICT, PIN-686602, REPRESENTED BY ITS SECRETARY. 4 THE GOVERNMENT EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.K-338 ETTUMANOOR P O, KOTTAYAM DISTRICT, PIN-686631, REPRESENTED BY ITS SECRETARY. 5 THE KALLARA VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO.3123 KALLARA, KOTTAYAM DISTRICT, PIN-686611. REPRESENTED BY ITS SECRETARY. 6 THE KALLARA SERVICE CO-OPERATIVE BANK LTD. NO.582 KALLARA SOUTH P O, KOTTAYAM DISTRICT, PIN-686611, REPRESENTED BY ITS SECRETARY. 7 THE AYMANAM VILLAGE SERVICE CO-OPERATIVE BANK LTD. NO.750. AYMANAM, KOTTAYAM DISTRICT, PIN-686005, REPRESENTED BY ITS SECRETARY. 2025:KER W.P(C)No.7053/2023 & Connected cases 200 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX CENTRAL REVENUE BUILDING, I S PRESS ROAD, ERNAKULAM, PIN-682018. 3 THE INCOME TAX OFFICER INCOME TAX DEPARTMENT KOTTAYAM, PIN-686001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. 5 THE REGIONAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD, REGIONAL OFFICE, KOTTAYAM, PIN-686001. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 201 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11262 OF 2022 PETITIONER/S: THALAYOLAPARAMBU FARMERS SERVICE CO-OPERATIVE BANK LTD.NO.278, THALAYOLAPARAMBU P.O, KOTTAYAM 686 605, REPRESENTED BY ITS MANAGING DIRECTOR, MRS. MINIMOL ISSAC. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, 2025:KER W.P(C)No.7053/2023 & Connected cases 202 KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 003. 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM- 695 003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. , PB NO. 6515, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM- 695 001. BY ADVS. SHRI.KARTHIK S.A., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 203 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11260 OF 2022 PETITIONER/S: THE KOTTAYAM DISTRICT POSTS, TELECOM & BSNL EMPLOYEES CO-OPERATIVE SOCIETY LTD NO. K 343, KOTTAYAM, REPRESENTED BY ITS SECRETARY- 686 001. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, KOTTAYAM , PIN 682 018. 3 THE INCOME TAX OFFICER (TDS), INCOME TAX DEPARTMENT, SHAKTAN NAGAR, KOTTAYAM, PIN 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033. 5 THE MANAGER, THE KERALA STATE CO-OPERATIVE BANK LTD., KOTTAYAM, PIN 686 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 204 BY ADVS. SHRI.RAMKUMAR J., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 205 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11263 OF 2022 PETITIONER/S: THOTTAKAM SERVICE CO-OPERATIVE BANK LTD.NO.470, OTTAKAM P.O, KOTTAYAM- 686 607, REPRESENTED BY ITS SECRETARY, SHIJU K.K. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX , KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 206 INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM- 695 003. 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM- 695 003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO. 6515, CO - BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM- 695 001. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 207 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11271 OF 2022 PETITIONER/S: 1 ALAPAD-PULLU SERVICE CO-OPERATIVE BANK LIMITED NO 130, ALAPAD P.O. THRISSUR REPRESENTED BY ITS SECRETARY, PIN - 680641 2 CHAZHUR SERVICE CO-OPERATIVE BANK LIMITED NO 106, P.O. CHAZHUR THRISSUR REPRESENTED BY THE SECRETARY, PIN - 680571 BY ADVS. SRI.C.HARIKUMAR SMT.SANDRA SUNNY SHRI.ARUN KUMAR M.A RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 208 INDIA CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD ERNAKULAM, PIN - 682018 4 THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX 3RD FLOOR, AAYAKAR BHAVAN, KOWADIAR THIRUVANANTHAPURAM, PIN - 695003 5 THE INCOME TAX OFFICER (TDS) AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR MUNICIPAL OFFICE ROAD THRISSUR, PIN - 680001 6 THE KERALA STATE CO-OPERATIVE BANK LIMITED PB NO 6515, COBANK TOWERS VIKAS BHAVAN P.O., PALAYAM THIRUVANANTHAPURAM REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 7 THE KERALA STATE CO-OPERATIVE BANK LIMITED PERINGOTTUKKARA BRANCH KHADI GRAMODYOG BUILDING, PERINGOTTUKKARA P.O. THRISSUR REPRESENTED BY ITS BRANCH MANAGER, PIN - 680565 8 THE STATE OF KERALA REPRESENTED BY ITS PRINCIPAL SECRETARY TO THE CO- OPERATIVE DEPARTMENT SECRETARIAT, FORT P.O. THIRUVANANTHAPURAM, PIN - 695023 BY ADVS. SHRI.S.BIJU, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.P.C.SASIDHARAN, SC, THRISSUR DISTRICT CO.OPERATIVE BANK LTD. GOVERNMENT PLEADER SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 209 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11272 OF 2022 PETITIONER/S: THE PERUMATTY SERVICE CO-OPERATIVE BANK LTD NO.757 POLLACHI ROAD, VANDITHAYALAM P.O., PALAKKAD - 678 534, REPRESENTED BY ITS SECRETARY, YESODHA N. BY ADV SMT.MEERA V.MENON RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS) C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 18. 2 THE INCOME TAX OFFICER INCOME TAX DEPARTMENT, WARD NO.5, PALAKKAD - 678 001. 3 THE KERALA STATE CO-OPERATIVE BANK REGIONAL OFFICE, PB.NO.21, H.P.O.ROAD, SULTHANPET, PALAKKAD - 678 001, REPRESENTED BY ITS GENERAL MANAGER-IN-CHARGE. 4 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE (DEPARTMENT OF REVENUE), NORTH BLOCK, NEW DELHI - 110 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 210 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 211 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11273 OF 2022 PETITIONER/S: VILAPPIL SERVICE CO-OPERATIVE BANK LTD. NO.2522, HEAD OFFICE, PEYYAD, THIRUVANANTHAPURAM, PIN - 695 573, REPRESENTED BY ITS SECRETARY, S. RICHARDSON, S/O.S. STEPHENSON, AGED 56 YEARS, RESIDING AT TRIPTHI, MALAYAM P.O., THIRUVANANTHAPURAM DISTRICT BY ADVS. SRI.BABU S. NAIR SMT.SMITHA BABU RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 2025:KER W.P(C)No.7053/2023 & Connected cases 212 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM, PIN - 695003 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003 6 THE KERALA STATE CO-OPERATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 STATE OF KERALA STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO- OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. SRI.CHRISTOPHER ABRAHAM SHRI.THOMAS ABRAHAM GOVERNMENT PLEADER CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 213 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11286 OF 2022 PETITIONER/S: THE NATTAKAM SERVICE CO-OPERATIVE BANK LTD. NO.3839, PAKKIL P.O., KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, AYKAR BHAVAN, KOTTAYAM, PIN - 686 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 5 THE MANAGER KERALA STATE CO-OEPRATIVE BANK LTD., PAKKIL, KOTTAYAM DISTRICT, PIN - 686 539. 2025:KER W.P(C)No.7053/2023 & Connected cases 214 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 215 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11301 OF 2022 PETITIONER/S: COCHIN PORT EMPLOYEE CO-OPERATIVE SOCIETY LTD., NO. 855, WILLINGTON ISLAND COCHIN, COCHIN 682 009, REPRESENTED BY ITS SECRETARY, DILEEP A.P. BY ADVS. SHRI.ANIL D. NAIR (SR.) SMT.TELMA RAJU SHRI.ARAVIND SREEKUMAR SMT.EDATHARA VINEETA KRISHNAN RESPONDENT/S: 1 JOINT COMMISSIONER OF INCOME TAX (TDS), C.R. BUILDING, I.S PRESS ROAD, KOCHI 682 018. 2 KERALA STATE CO-OPERATIVE BANK LTD. , ERNAKULAM BRANCH BUILDING NO. 41/4263, GROUND FLOOR MARKET ROAD, ERNAKULAM NORTH P.O, KOCHI 682 018, REP. BY REGIONAL MANAGER. 3 KERALA STATE CO-OPERATIVE BANK LTD., MATTANCHERRY, ERNAKULAM, KERALA- 682 002, REP. BY MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 216 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 217 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11309 OF 2022 PETITIONER/S: 1 MUPPATHADAM SERVICE CO-OPERATIVE BANK LTD. NO. E 216 MUPPATHADAM P.O, ERNAKULAM DISTRICT, PIN - 683110, REPRESENTED BY ITS SECRETARY. 2 KUNNATHUNAD SERVICE CO-OEPARATIVE BANK LTD NO. E3, KUMARAPURAM, P.O, ERNAKULAM DISTRICT, PIN - 683565, REPRESENTED BY ITS SECRETARY. 3 CHERANALLOOR SERVICE CO-OPERATIVE SOCIETY LTD, NO. 2417, EDAVOOR P.O, KOOVAPADY, ERNAKULAM DISTRICT, PIN - 683544, REPRESENTED BY ITS SECRETARY. 4 ELOOR RURAL CO-OPERATIVE BANK LTD, NO.E-1098 ELOOR EAST, UDYOGAMANDAL, ERNAKULAM DISTRICT, PIN - 683501, REPRESENTED BY ITS SECRETARY. 5 ANGAMALY URBAN CO-OPERATIVE SOCIETY LTD NO.E-1081 T.B. JUNCTION SAHAKARANA BHAVAN, ERNAKULAM DISTRICT, PIN - 683572, REPRESENTED BY ITS SECRETARY. 6 MOOKKANNOOR SERVICE CO-OPERATIVE BANK LTD NO. E-62, MOOKKANNOOR, P.O, ANGAMALY, ERNAKULAM DISTRICT, PIN - 683577, REPRESENTED BY ITS SECRETARY. 7 NELLAD-VEETTOOR SERVICE CO-OPERATIVE SOCIETY LTD NO.E-332. NELLAD P.O, ERNAKULAM DISTRICT, PIN - 686669, REPRESENTED BY ITS SECRETARY. 2025:KER W.P(C)No.7053/2023 & Connected cases 218 8 TRIPUNITHURA HOUSING CO-OPERATIVE BANK SOCIETY NO. E 715, TRIPUNITHURA P.O, ERNAKULAM DISTRICT, PIN - 682301, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.M.M.MONAYE SHRI.M.PAUL VARGHESE SRI.K.V.SANOSH SMT.NIRMALA P.V. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI, PIN - 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI - 110001. 3 COMMISSIONER OF INCOME TAX (TDS) C.R. BUILDINGS, I.S. PRESS ROAD, ERNAKULAM - 682018. 4 STATE OF KERALA DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT, REPRESENTED BY SECRETARY TO GOVERNMENT, THIRUVANANTHAPURAM - 695001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM - 695001. 6 THE KERALA STATE CO-OPERATIVE BANK LTD, CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, THIRUVANANTHAPURAM - 695033. 7 DEPUTY GENERAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD, CREDIT PROCESSING 2025:KER W.P(C)No.7053/2023 & Connected cases 219 CENTRE, KAKKANAD, KOCHI - 682030. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 220 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11316 OF 2022 PETITIONER/S: 1 THE PALAKKAD SERVICE CO-OPERATIVE BANK LTD NO.F 1200 G.B.ROAD, PALAKKAD - 678 001 REPRESENTED BY ITS SECRETARY, SHRI.C.RAMESHKUMAR. 2 THE PALAKAKD CO-OPERATIVE EMPLOYEES CO-OP.SOCIETY LTD.NO.P 609 SREEKRISHNA TEMPLE ROAD, KUNNATHURMEDU, PALAKKAD-13, REPRESENTED BY ITS SECRETARY-IN-CHARGE, SHRI.AKHIL V.S. 3 PROYADARSHINI MULTI PURPOSE CO-OP. SOCIETY LTD.NO.P- 1340 CROWN PLAZA, VALIPARAMBU ROAD, PALAKKAD-13, REPRESENTED BY ITS SECRETARY-IN-CHARGE, SMT.T.S.JANCY. 4 THE KANJIKODE SERVICE CO-OP.BANK LTD.NO.1199 KANJIKODE POST, PALAKKAD, REPRESENTED BY ITS SECRETARY, SHRI.RADHAKRISHNAN S. 5 PARLI CO-OPERATIVE URBAN CREDIT SOCIETY LTD.NO.P 1223 PARLI POST, PALAKKAD - 678 612 REPRESENTED BY ITS SECRETARY, SMT.SUJATHA N. 6 RAJEEV GANDHJI MULTIPURPOSE CO-OPERATIVE SOCIETY LTD.NO.P 1324 AKATHETHARA POST, PALAKKAD, REPRESENTED BY ITS HONORARY SECRETARY, SHRI.S.GOPINATHAN NAIR. 7 KARIMPUZHA CO-OP. URBAN SOCIETY LTD.NO.P 1171 ELAMBULASERRY, PALAKKAD, REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 221 SECRETARY, SHRI.JOHNSON K. 8 THE KANNADI CO-OPERATIVE URBAN CREDIT SOCIETY LTD.NO.P 1207 KAZCHAPARAMBU JUNCTION, KANNADI POST, PALAKKAD, REPRESENTED BY ITS SECRETARY, SMT.MEERA V. BY ADVS. SHRI.A.KUMAR (SR.) SHRI.P.J.ANILKUMAR SMTG.MINI(1748) SRI.P.S.SREE PRASAD SHRI.JOB ABRAHAM SHRI.AJAY V.ANAND RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001 REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695 033 REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA STATE CO-OPERATIVE BANK LTD REGIONAL OFFICE, PALAKKAD, H.P.O.ROAD, SULTHANPET, PALAKKAD. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 222 SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 223 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11332 OF 2022 PETITIONER/S: 1 KOTHAMANGALAM TALUK MERCANTILE CO-OPERATIVE SOCIETY LTD NO. 1159, KOTHAMANGALAM- ERNAKULAM 686 691, REPRESENTED BY ITS SECRETARY MANOJ K.S 2 KOTHAMANGALAM TALUK CO-OPERATIVE EMPLOYEES, CO-OPERATIVE SOCIETY LTD. NO. E 746, KOTHAMANGALAM, ERNAKULAM 686 691, REPRESENTED BY ITS SECRETARY, BINOY N.R. 3 PREMIER TYRES EMPLOYEES' MULTI PURPOSE CO-OPERATIVE SOCIETY LTD. NO. E 282, KALAMASSERY P.O, ERNAKULAM- 683 104, REPRESENTED BY ITS SECRETARY SUBBAMMA S. 4 COCHIN UNIVERSITY EMPLOYEES SAHAKARANA SANDHAM LTD. NO. E 757, COCHIN UNVERSITY P.O, ERNAKULAM 682 022, REPRESENTED BY ITS SECRETARY, AKSHAYA BHAT V.L. 5 WAYANAD DISTRICT DRIVERS CO-OPERATIVE SOCIETY LTD. NO. W 14, KALPETTA, WAYANAD 6873 121, REPRESENTED BY ITS SECRETARY AJAY V.R. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. 2025:KER W.P(C)No.7053/2023 & Connected cases 224 SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. P B NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 225 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11323 OF 2022 PETITIONER/S: 1 MANJAPRA SERVICE CO-OPERATIVE BANK LTD. NO.4232, MANJAPRA, P.O.KOCHI - 683 581 REPRESENTED BY ITS SECRETARY. 2 KALADY KANJOOR RURAL CO-OPERATIVE BANK LTD.NO.E - 1097 KALADY P.O., KOCHI - 682 574, REPRESENTED BY ITS SECRETARY SINDHU V. 3 THE VENNALA SERVICE CO-OPERATIVE BANK LTD.NO.E-774 VENNALA P.O., KOCHI - 682 028, REPRESENTED BY ITS SECRETARY LAJI M.N. 4 THAMMANAM SERVICE CO-OPERATIVE BANK LTD.NO.E-182 THAMMANAM P.O., KOCHI - 682 032 REPRESENTED BY ITS SECRETARY MAYADEVI M. 5 EDAPPALLY VADAKKUMBHAGAM SERVICE CO-OPERATIVE BANK LTD.NO.E-1431 PONIKARA P.O., KOCHI - 682 041 REPRESENTED BY ITS SECRETARY SINDHU C.K. 6 THIRUMARAYOOR SERVICE CO-OPERATIVE BANK LTD.NO.809 ARAKKUNAM P.O., KOCHI - 682 313 REPRESENTED BY ITS SECRETARY ANNAMA VARKEY. 7 THE VELIYANAD CO-OPERATIVE SOCIETY LTD.NO.29 VELIYANAD P.O., ARAKKUNAM, KOCHI - 682 313 REPRESENTED BY ITS SECRETARY SINDHU M.R. 2025:KER W.P(C)No.7053/2023 & Connected cases 226 8 EDAPPALLY SERVICE CO-OPERATIVE BANK LTD.NO.328 EDAPALLY P.O., KOCHI - 682 024, REPRESENTED BY ITS SECRETARY LEENA MATHAI. 9 THURAVOOR SERVICE CO-OPERATIVE BANK LTD.NO.E-69 THURAVOOR P.O., KOCHI - 688 532 REPRESENTED BY ITS SECRETARY PAULY SEBASTIAN. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 11000. 2 THE COMMISSIONER OF INCOME TAX (TDS) C.R.BUILDING, I.S.PRESS ROAD, KOCHI - 682 018. 3 THE INCOME TAX OFFICER (TDS) 3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695 003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. (ERSTWHILE THE ERNAKULAM DISTRICT CO-OPERATIVE BANK), KAKKANAD P.O., KOCHI - 682 030. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 227 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11325 OF 2022 PETITIONER/S: THE PERINGOTTUKURUSSIL SERVICE CO-OPERATIVE BANK LTD NO.P-519 NO.P-519, PARUTHIPULLY.P.O, PALAKKAD, PIN-678 573 REPRESENTED BY ITSSECRETARY -IN-CHARGE- C .N .SUCHITHRAN BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-11000. 2 THECOMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG. I.S.PRESS, ROAD, KOCHI-682018 3 THE INCOME TAX OFFICER(TDS) AYAKKAR BHAVAN, CHURCH ROAD, PALAKKAD-678001 4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE PALAKKAD DISTRICT SERVICE CO-OPERATIVE BANK), HEAD POST OFFICE ROAD, SULTHANPETTA, PALAKKAD- 678 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 228 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 229 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11326 OF 2022 PETITIONER/S: 1 THE VARANAD SERVICE CO-OPERATIVE BANK LTD. NO. 1248, VARANAD P.O, CHERTHALA- 688 583, REPRESENTED BY ITS SECRETARY C P RAJAN. 2 KANJIKUZHY SERVICE CO-OPERATIVE BANK LTD. NO. 1558, S.L. PURAM P.O, KANJIKUZHY-688 523, REPRESENTED BY ITS SECRETARY- P GEETHA. 3 CHERTHALA TALUK, GOVT. EMPLOYEES AND PENSIONERS CO-OPERATIVE SOCIETY LTD. NO. A 1195, CHERTHALA P.O- 688 524, REPRESENTED BY ITS HONARARY SECRETARY K BHARATHAN. 4 THE MUTTOM SERVICE CO-OPERATIVE BANK LTD. NO. 1165, CHERTHALA P.O, 688 524, REPRESENTED BY ITS SECRETARY- MERCY JOHN. 5 THE CHERTHALA CO-OPERATIVE URBAN SOCIETY LTD. NO. 2655, CHERTHALA P.O, 688 524, REPRESENTED BY ITS SECRETARY- D MADHUSUDHAN. 6 KIZHAKKENALPATHIL SERVICE CO-OPERATIVE BANK LTD. NO. 1164, CHERTHALA P.O, 688 524, REPRESENTED BY ITS SECRETARY- MADHUSUDANAN K P. 7 CHERTHALA SERVICE CO-OPERATIVE BANK LTD. NO. 1688, CHERTHALA, P.O- 688524, REPRESENTED BY ITS SECRETARY- A T CHANDRA BABU 2025:KER W.P(C)No.7053/2023 & Connected cases 230 8 THE EZHUPUNNA SERVICE CO-OPERATIVE BANK LTD. NO. 953, EZHUPUNNA P.O, CHERTHALA-688 537, REPRESENTED BY ITS SECRETARY- BENNY CHACKO. 9 THE AROOR SERVICE CO-OPERATIVE SOCIETY LTD. NO. 2174, AROOR P.O, ALAPPUZHA- 688 534, REPRESENTED BY ITS SECRETARY- SELVARAJ C S 0 CHERUVARANAM SERVICE CO-OPERATIVE BANK LTD. NO. 1817, VARANAM P.O, CHERTHALA, P.O- 688555, REPRESENTED BY ITS SECRETARY-SINI C. 11 ERAMALLOOR SERVICE CO-OPERATIVE BANK LTD. NO. 1105, ERAMALLOOR P.O, CHERTHALA 688 537, REPRESENTED BY ITS SECRETARY- JOLLY B. 12 SHERTALLAI TALUK , AIDED SECONDARY SCHOOL EMPLOYEES' C.S. LTD. NO. A 276, CHERTHALA, P.O. 688 524, REPRESENTED BY ITS SECRETARY- RENJITHA BAI. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL , NEW DELHI 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS , ROAD, KOCHI 682 018. 3 INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX DEPT. ALAPPUZHA 688 011. 2025:KER W.P(C)No.7053/2023 & Connected cases 231 4 THE KERALA STATE CO-OPERATIVE BANK LTD. OPP. MUNICIPAL TOWN HALL, ALAPPUZHA, KERALA 688 011, REPRESENTED BY ITS REGIONAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 232 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11327 OF 2022 PETITIONER/S: 1 VALLIVATTAM SERVICE CO-OPERATIVE BANK LTDN O 4170, VALLIVATTAM, THRISSUR-680 123, REPRESENTED BY ITS SECRETARY 2 THE VELLANGALLUR SERVICE CO-OPERATIVE BANK LTD NO 768, P.O.VELLANGALLUR, THRISSUR, REPRESENTED BY ITS SECRETARY-680 123. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682 018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001 4 THE KERALA STATE CO-OPERATIVE BANK LTD, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR 2025:KER W.P(C)No.7053/2023 & Connected cases 233 BY ADVS. SHRI.S.VAIDYANATHAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 234 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11335 OF 2022 PETITIONER/S: 1 KADUTHURUTHY REGIONAL SERVICE CO-OPERATIVE BANK LTD.NO.4061 KADUTHURUTHY P.O., KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY - 686 604. 2 THE UDAYANAPURAM SERVICE CO-OPERATIVE BANK LTD.NO.1321 UDAYANAPURAM P.O., KOTTAYAM DISTRICT - 68143 REPRESENTED BY ITS SECRETARY. 3 THE VELLAVOOR SERVICE CO-OPERATIVE BANK LTD.NO.4300 KADAYANICKADU P.O., KOTTAYAM DISTRICT - 686 541, REPRESENTED BY ITS SECRETARY. 4 THE VAZHOOR FARMER'S SERVICE CO-OPERATIVE BANK LTD.NO.2278 PULICKALKVALA P.O., KOTTAYAM DISTRICT - 686 515, REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KURICHY SERVICE CO-OPERATIVE BANK LTD.NO.1538 KURICHY P.O., KOTTAYAM DISTRICT - 686 535, REPRESENTED BY ITS SECRETARY. 6 THE VELLAVOOR CENTRAL SERVICE CO-OPERATIVE BANK LTD.NO.3435 THAZHATHUVADAKARA P.O., KOTTAYAM DISTRICT - 686 541 REPRESENTED BY ITS SECRETARY. 7 THE NEDUMKUNNAM SOUTH SERVICE CO-OPERATIVE BANK LTD.NO.1271 PUNNAVELY P.O., KOTTAYAM DISTRICT, NEDUMKKUNNAM - 689 2025:KER W.P(C)No.7053/2023 & Connected cases 235 589, REPRESENTED BY ITS SECRETARY. 8 THE NEDUMKUNNAM SERVICE CO-OPERATIVE BANK LTD.1301 NEDUMKKUNNAM P.O. - 689 589, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY. 9 THE CHEERANCHIRA SERVICE CO-OPERATIVE BANK LIMITED NO.1626 CHEERANCHIRAN P.O., CHANGANACHERRY - 686 106, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY. 0 THE VAZHAPPALLY SERVICE CO-OPERATIVE BANK LIMITED NO.K 108 VAZHAPPALLY P.O., CHANGANACHERRY, KOTTAYAM DISTRICT - 686 103, REPRESENTED BY ITS SECRETARY. 11 THE ITHITHANAM JANATHA SERVICE CO-OPERATIVE BANK LIMITED NO.K 1297 MALAKUNNAM P.O., CHANGANACHERRY, KOTTAYAM DISTRICT - 686 535, REPRESENTED BY ITS SECRETARY. 12 THE THRUTHY SRVICE CO-OPERATIVE BANK LIMITED NO.K 1486 THRUTHY P.O., CHANGANACHERRY - 686 535, REPRESENTED BY ITS SECRETARY. 13 THE PAIPPAD SERVICE CO-OPERATIVE BANK LIMITED NO.K 1698 NALUKODY P.O., PAIPPAD, CHANGANACHERRY, KOTTAYAM DISTRICT - 686 548, REPRESENTED BY ITS SECRETARY. 14 THE KANGAZHA SERVICE CO-OPERATIVE BANK LIMITED NO.1145 KANGAZHA P.O., CHANGANACHERRY, KOTTAYAM DISTRICT - 686 541, REPRESENTED BY ITS SECRETARY. 15 THE NALUNNAKKAL SERVICE CO-OPERATIVE BANK LIMITED NO.296 NALUNNAKKAL P.O., CHANGANACHERRY, KOTTAYAM DISTRICT - 686 538, REPRESENTED BY ITS SECRETARY. 16 THE VAKATHANAM SERVICE CO-OPERATIVE BANK LIMITED NO.4246 VAKATHANAM P.O., CHANGANACHERRY, KOTTAYAM DISTRICT - 2025:KER W.P(C)No.7053/2023 & Connected cases 236 686 538, REPRESENTED BY ITS SECRETARY. 17 THE PAIPPAD CENTRAL SERVICE CO-OPERATIVE BANK LIMITED NO.3125 PALLICKACHIRA KAVALA P.O., CHANGANACHERRY, KOTTAYAM DISTRICT - 686 537, REPRESENTED BY ITS SECRETARY. 18 THE NEELAMPEROOR SERVICE CO-OPERATIVE BANK LIMITED NO.1788 NEELAMPEROOR P.O., ALAPPUZHA DISTRICT - 686 534, REPRESENTED BY ITS SECRETARY. 19 THE T.V.PURAM FARMERS' SERVICE CO-OPERATIVE BANK LIMITED NO.622 VAIKOM, KOTTAYAM DISTRICT - 686 534, REPRESENTED BY ITS SECRETARY. 20 THE NEDUMKUNNAM REGIONAL SERVICE CO-OPERATIVE BANK LIMITED NO.286 NEDUMKUNNAM, KOTTAYAM DISTRICT - 686 534 REPRESENTED BY ITS SECRETARY. 21 THE NEEZHOOR SERVICE CO-OPERATIVE BANK LIMITED NO.136 NEEZHOOR, KOTTAYAM DISTRICT - 686 534, REPRESENTED BY ITS SECRETARY. 22 THE ELECTRICITY BOARD EMPLOYEES CO-OPERATIVE SOCIETY LIMITED NO.K 705 PAKKIL, KOTTAYAM DISTRICT - 686 534, REPRESENTED BY ITS SECRETARY- 686 539. 23 THE VAIKOM URBAN CO-OPERATIVE SOCIETY LIMITED NO.K 1011 VAIKOM, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY - 686 505. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY 2025:KER W.P(C)No.7053/2023 & Connected cases 237 OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, KOTTAYAM, PIN - 686 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 5 THE REGIONAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD., REGIONAL OFFICER, KOTTAYAM, PIN- 686 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 238 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11342 OF 2022 PETITIONER/S: CHENDMANGALAM SERVICE CO-OPERATIVE BANK LIMITED CHENDAMANGALAM P.O.NORTH PARAVOOR, PIN-683 512, REPRESENTED BY ITS SECRETARY OUSEPH T.V. BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SHRI.RAJATH R NATH SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI-682 018 3 THE INCOME TAX OFFICER (TDS), KAP COMPLEX, HIGHWAY, SH 16, PERIYAR NAGAR, ALUVA, PIN-683 101 4 THE CENTRAL BOARD OF DIRECTO TAXES DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 239 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NOW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682 018 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003. 7 THE KERALA STATE CO-OPERATIVE BANK LTD (KERALA BANK), PO NO 6515, CO-BANK TOWERS , PALAYAM, THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR 8 KERALA BANK, NORTH PARAVUR BRANCH MAIN, NORTH PARAVOOR P.O.PIN-683 513, REPRINTED BY ITS MANAGING DIRECTOR 9 KERALA BANK, NORTH PARAVUR BRANCH EVENING, NORTH PARAVOOR P.O.PIN- 683 513, REPRINTED BY ITS MANAGING DIRECTOR 10 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN-695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 240 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11355 OF 2022 PETITIONER/S: VALLUVALLY SERVICE CO-OPERATIVE BANK LIMITED KOONAMMAVU, NORTH PARAVOOR P.O.PIN-685 518, REPRESENTED BY ITS SECRETARY LILA M.J. BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SRI.V.J.MATHEW (M-1348) SRI.K.A.ARAVINDAKSHAN SHRI.RAJATH R NATH SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIAN, NORTH BLOCK, NEW DELHI-110 001 2 COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682 018. 3 THE INCOME TAX OFFICER (TDS), KAP COMPLEX, HIGHWAY, SH 16, PERIYAR NAGAR, ALUVA, PIN-683 101. 2025:KER W.P(C)No.7053/2023 & Connected cases 241 4 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. 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682 018. 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003. 7 THE KERALA STATE CO-OPERATIVE BANK LTD, (KERALA BANK), PO NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR 8 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN-695 001. BY ADVS. SHRI.C.DINESH, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 242 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11366 OF 2022 PETITIONER/S: 1 THE WADAKKANCHERY SERVICE CO-OPERATIVE BANK LTD NO. 3279, THALAPPILLY, THRISSUR, REPRESENTED BY ITS SECRETARY, 680 582 2 AMBALAPAD SERVICE CO-OPERATIVE BANK LTD NO. 759, P.O.KUNDUKADU, THRISSUR, REPRESENTED BY ITS SECRETARY. 680 028 3 THE PERINGANDOOR SERVICE CO-OPERATIVE BANK LTD NO. 297, ATHANI, THRISSUR, REPRESENTED BY THESECRETARY,680 102 BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682 018 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 243 4 THE KERALA STATE CO-OPERATIVE BANKLTD CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR, BY ADVS. SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 244 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11371 OF 2022 PETITIONER/S: 1 AYYANTHOLE SERVICE CO-OPERATIVE BANK LTD.NO.494 AYYANTHOLE, THRISSUR, REPRESENTED BY ITS SECRETARY- 680 611 2 THE AVINISSERY SERVICE CO-OPERATIVE BANK LTD NO.400, AVINISSERY P.O., THRISSUR, REPRESENTED BY ITS SECRETARY-680 611 3 AYYANTHOLE PANCHAYAT SERVICE CO-OPERATIVE BANK LTD NO.471, KARIATTUKARA, P.O.ELTHURUTH, THRISSUR-680 611, REPRESENTED BY ITS SECRETARY 4 ARANATTUKARA ORIENTAL SERVICE CO-OPERATIVE BANK LTD NO.171, ARANATTUKARA, THRISSUR DISTRICT,REPRESENTED BY ITS SECRETARY-680 611 BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM- 2025:KER W.P(C)No.7053/2023 & Connected cases 245 682 018 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR BY ADV SHRI.B.G.HARINDRANATH (SR.) THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 246 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11373 OF 2022 PETITIONER/S: THE ADAT FARMERS SERVICE CO-OPERATIVE BANK LTD NO.689, PURANATTUKARA, THRISSUR-680 551, REPRESENTED BY ITS MANAGING DIRECTOR BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS RAD, ERNAKULAM-682 018 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAM NAGAR, THRISSUR-680 001 4 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR BY ADVS. SHRI.M.A.SHAJI, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 247 SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 248 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11381 OF 2022 PETITIONER/S: KARUVANNUR SERVICE CO-OPERATIVE BANK LTD KARUVANNUR P.O., THRISSUR ,PIN-680 711, REPRESENTED BY ITS SECRETARY-IN-CHARGE SREEKALA .E.S. BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SHRI.RAJATH R NATH RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110 001 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682 018 3 THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAM NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR, PIN-680 001 4 THE CENTRAL BOARD OF DIRECTOR TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN 2025:KER W.P(C)No.7053/2023 & Connected cases 249 5 PRICIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003 7 THE KERALA STATE CO-OPERATIVE BANK LTD, ( KERALA BANK), PO NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM,PIN-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 250 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11407 OF 2022 PETITIONER/S: 1 THE GOVT .SERVANTS CO-OP SOCIETY LTD LTD NO.139, WADAKKANCHERY, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY-680682. 2 MACHAD PARASPARA SAHAYA SAHAKARANA SANGHASM LTD NO.R- 1267, PUNNAMPARAMBU, THEKKUMKARA P O, THRISSUR DISTRICT- 680589., REPRESENTED BY ITS SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS MANAGING DIRECTOR. 2025:KER W.P(C)No.7053/2023 & Connected cases 251 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 252 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11415 OF 2022 PETITIONER/S: 1 PALLIPURAM SERVICE CO-OPERATIVE BANKNO.760 PALLIPURAM, CHERAI, ERNAKULAM-683514, REPRESENTED BY ITS SECRETARY, SR.K.S.AJAYAKUMAR. 2 KUZHUPPILLY SERVICE CO-OPERATIVE BANK. CHERUVYPE JUNCTION, AYYAMPILLY, KUZHUPILLY-682501, REPRESENTED BY ITS SECRETARY, SRI.AJAYAKUMAR V.A. 3 EDAVANAKKAD SERVICE CO-OPERATIVE BANK. EDAVANAKKAD, VYPIN, KOCHI-682509, REPRESENTED BY ITS SECRETARY SMT.RASEENA B A. 4 OCHANTHURUTH SERVICE CO-OPERATIVE BANK OCHANTHURUTH, COCHIN, ERNAKULAM-682508, REPRESENTED BY ITS SECRETARY, SRI.A.S.GOPALAKRISHNAN. BY ADVS. SHRI.AJI V.DEV SRI.ALAN PRIYADARSHI DEV RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 253 2 PRINCIPAL CHIEF COMMISSIONER OF INCOEM TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 3 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 4 THE KERALA STATE CO-OPERATIVE BANK LIMITED COBANK TOWERS, VIKAS BHAVAN, PALAYAM, THIRUVANANTHAPURAM-695033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 254 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11420 OF 2022 PETITIONER/S: OLLUKKARA LABOUR CONTRACT CO-OPERATIVE SOCIETY LTDNO.R.855 P O MANNUTHY, THRISSUR, REPRESENTED BY THE SECRETARY, PIN-680651. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER(TDS) OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033. REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 255 SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 256 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11441 OF 2022 PETITIONER/S: 1 CHAVAKKAD SERVICE CO-OPERATIVE BANK LTD. NO.F.9991, P.O.CHAVAKKAD, THRISSUR, REPRESENTED BY ITS SECRETARY. 2 PERAKAM SERVICE CO-OPERATIVE BANK LTD. NO.F.6916, P.O.PERAKAM, CHAVAKKAD, THRISSUR, REPRESENTED BY ITS SECRETARY. 3 PUNNAYUR PANCHAYAT SERVICE CO-OPERATIVE BANK LTD. NO.P.584, P.O.EDAKKARA, THRISSUR-680518, REPRESENTED BY ITS SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 2025:KER W.P(C)No.7053/2023 & Connected cases 257 4 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 258 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11440 OF 2022 PETITIONER/S: THE RAMAPURAM REGIIONAL SERVICE CO-OPERATIVE BANK LTD. NO.4111, RAMAPURAM P.O., KOTTAYAM-686576, REPRESENTED BY ITS SECRETARY SANTHOSH SEBASTIAN, S/O. SEBASTIAN, AGED 43 YEARS, VICAHTTU HOUSE, CHAKAMPUZHA P.O., RAMAPURAM, PALA, KOTTAYAM DISTRICT, PIN-686574. BY ADVS. SHRI.BABY THOMAS SMT.MARIAMMA JOSEPH SMT.ALICIA JOSE SHRI.GEORGE T.J RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, 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 INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI 2025:KER W.P(C)No.7053/2023 & Connected cases 259 ROAD, KOTTAYAM-686001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. (KERALA BANK), COBANK TOWERS, VIKAS BHAVAN, PALAYAM, THIRUVANANTHAPURAM-695033, REP. BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. BY ADV SRI.CHRISTOPHER ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 260 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11450 OF 2022 PETITIONER/S: 1 CHIRAKKAL SERVICE CO-OPERATIVE BANK LTD CHIRAKKAL P.O., KANNUR-670011, REPRESENTED BY ITS SECRETARY CHANDRAN P. 2 TELLICHERY TOWN SERVICE CO-OPERATIVE BANK LTD., P.O.TELLICHERY, KANNUR-670101, REPRESENTED BY ITS SECRETARY ROSILY M.O. 3 MUZHAPPILANGAD SERVICE CO-OPERATIVE BANK LTD., P.O.MUZHAPPILANGAD, KANNUR-670662, REPRESENTED BY ITS SECRETARY AJESH R.K. 4 CHOKLI SERVICE CO-OPERATIVE BANK LTD., CHOKLI P.O., KANNUR-670672, REPRESENTED BY ITS SECRETARY VIJAYAN C. 5 KOODALI SERVICE CO-OPERATIVE BANK LTD., P.O.KOODALI, KANNUR -670592, REPRESENTED BY ITS SECRETARY SAJEEVAN E. 6 CHITTARIPARAMBA SERVICE CO-OPERATIVE BANK LTD., P.O.CHITTARIPARAMBA, KANNUR-670650, REPRESENTED BY ITS SECRETARY RAJEEV K.V. 7 PORORA SERVICE CO-OPERATIVE BANK LTD., P.O.PORORA, KANNUR-670702, REPRESENTED BY ITS SECRETARY M.K.VANAJA. 8 VADAKKUMBAD SERVICE CO-OPERATIVE BANK LTD., P.O.VADAKKUMBAD, THALASSERY, KANNUR-670105, 2025:KER W.P(C)No.7053/2023 & Connected cases 261 REPRESENTED BY ITS SECRETARY SREEJILA V. 9 KODIYERI CO-OPERATIVE RURAL BANK LTD., P.O.PARAL, KANNUR-670671, REPRESENTED BY ITS SECRETARY ARUNKUMAR K.P. 10 PONNIAM SERVICE CO-OPERATIVE BANK LTD., P.O.PONNIAM, KANNUR-670641, REPRESENTED BY ITS SECRETARY RATNAKARAN K.R. 11 PUNNOL SERVICE CO-OPERATIVE BANK LTD., KURICHIYIL P.O., KANNUR-670102, REPRESENTED BY ITS SECRETARY K.V.SANTHOSHKUMAR. 12 ANJARAKANDY FARMERS SERVICE CO-OPERATIVE BANK LTD., P.O.MAMBA, KANNUR-670611, REPRESENTED BY ITS SECRETARY ANILKUMAR M.P. 13 PANOOR SERVICE CO-OPERATIVE BANK LTD. P.O.PANOOR, KANNUR-670692, REPRESENTED BY ITS SECRETARY VINOD T.K. 14 THADIKKADAVU SERVICE CO-OPERATIVE BANK LTD., P.O.CHAPPARAPPADAVU, KANNUR-670581, REPRESENTED BY ITS SECRETARY KURYAN THOMAS. 15 DHARMADAM SERVICE CO-OPERATIVE BANK LTD., PALAYAD P.O., KANNUR-670661, REPRESENTED BY ITS SECRETARY SURESHKUMAR N.P. 16 MADAI SERVICE CO-OPERATIVE BANK LTD., P.O.VENGARA, KANNUR-670305, REPRESENTED BY ITS SECRETARY K.AJITHKUMAR. 17 PAYAM SERVICE CO-OPERATIVE BANK LTD., PAYAM P.O., KANNUR-670704, REPRESENTED BY ITS SECRETARY MATHEW K.M. 18 CHAVASSERY SERVICE CO-OPERATIVE BANK LTD., P.O.CHAVASSERY, KANNUR-670702, REPRESENTED BY ITS SECRETARY SATHEESH CHANDRAN K.P. 19 PATTANUR SERVICE CO-OPERATIVE BANK LTD., 2025:KER W.P(C)No.7053/2023 & Connected cases 262 P.O.IRIKKUR, KANNUR-670593, REPRESENTED BY ITS SECRETARY RAJEVAN K.V. 20 KADAVATHUR SERVICE CO-OPERATIVE BANK LTD., KADAVATHUR, KANNUR-670676, REPRESENTED BY ITS SECRETARY CHANDRAN M. 21 THONDIYIL SERVICE CO-OPERATIVE BANK LTD., THONDIYIL P.O., KANNUR-670673, REPRESENTED BY ITS SECRETARY JOJO JOSEPH. 22 KARARINAKAM SERVICE CO-OPERATIVE BANK LTD., P.O.KADALAYI, KURUVA, KANNUR-670003, REPRESENTED BY ITS SECRETARY LATHEESH K. 23 KANDAMKUNNU SERVICE CO-OPERATIVE BANK LTD. NO. LL 20, KAITHERY, P.O.NIRMALAGIRI, KANNUR-670701, REPRESENTED BY ITS SECRETARY BABU P. 24 MANATHANA SERVICE CO-OPERATIVE BANK LTD., P.O.MANATHANA, KANNUR-670674, REPRESENTED BY ITS SECRETARY GOURI K. 25 KUTTIATTOOR PANCHAYATH SERVICE CO-OPERATIVE BANK LTD. NO.C 817, HEAD OFFICE, CHEKKIKULAM P.O., KANNUR 670592, REPRESENTED BY ITS SECRETARY RAJAN T. 26 TALIPARAMBA SERVICE CO-OPERATIVE BANK LTD., P.O.TALIPARAMBA, KANNUR-670141, REPRESENTED BY ITS SECRETARY PUSHPAKUMARI T.V. 27 PATTIAM SERVICE CO-OPERATIVE BANK LTD. NO.C 1464, PATTIAM, KOTTAYODI P.O., PATHAYAKUNNU, KANNUR-670691, REPRESENTED BY ITS SECRETARY SREEJA KUMARI P. 28 PERINGALAM SERVICE CO-OPERATIVE BANK LTD., P.O.PULLOOKKARA, KANNUR-67676, REPRESENTED BY ITS SECRETARY PRASEEDA T.T. 29 KUNNIRIKKA SERVICE CO-OPERATIVE BANK LTD. NO.6971, P.O.PATHIRIYAD, KANNUR-670741, REPRESENTED BY ITS SECRETARY PREETHA K.P.V. 2025:KER W.P(C)No.7053/2023 & Connected cases 263 30 KADIRUR SERVICE CO-OPERATIVE BANK LTD., P.O.KADIRUR, KANNUR-670642, REPRESENTED BY ITS SECRETARY K.ASHOKAN. 31 NADUVIL SERVICE CO-OPERATIVE BANK LTD., P.O.NADUVIL, KANNUR-670582, REPRESENTED BY ITS SECRETARY TOMY JOSEPH. 32 MOKERI SERVICE CO-OPERATIVE BANK LTD., P.O.KOORARA, TELLICHERY, KANNUR-670694, REPRESENTED BY ITS SECRETARY K.RAMACHANDRAN. 33 KARIYAD SERVICE CO-OPERATIVE BANK LTD., P.O.KARIYAD SOUTH, KANNUR-673316, REPRESENTED BY ITS SECRETARY AJITHKUMAR K. 34 KOTTAYAM SERVICE CO-OPERATIVE BANK LTD., P.O.KOTTAYAMPOYIL, KANNUR-670691, REPRESENTED BY ITS SECRETARY SAMPATHKUMAR M. 35 PINAYARI SERVICE CO-OPERATIVE BANK LTD., P.O.PINARAYI, KANNUR-670741, REPRESENTED BY ITS SECRETARY A.SREEGANAN 36 THOLAMBRA SERVICE CO-OPERATIVE BANK LTD., THOLAMBRA, KANNUR-670673, REPRESENTED BY ITS SECRETARY SHAJAN P.V. 37 EZHOME SERVICE CO-OPERATIVE BANK LTD., P.O.EZHOME, KANNUR-670334, REPRESENTED BY ITS SECRETARY PREMARAJAN P.V. 38 VALAPATTANAM SERVICE CO-OPERATIVE BANK LTD., P.O.VALAPATTANAM, KANNUR-670010, REPRESENTED BY ITS SECRETARY M.V.GOWRI. 39 CHOVVA CO-OPERATIVE RURAL BANK LTD., P.O.CHOVVA, KANNUR-670006, REPRESENTED BY ITS SECRETARY MOHANAN P. 40 KUTTIKKAKAM SERVICE CO-OPERATIVE BANK LTD.NO.F 1287, P.O.KUTTIKKAKAM, KANNUR-670663, REPRESENTED BY 2025:KER W.P(C)No.7053/2023 & Connected cases 264 ASHOKAN P. 41 KELAKAM SERVICE CO-OPERATIVE BANK LTD., P.O.KELAKAM, KANNUR-670674, REPRESENTED BY ITS SECRETARY K.P.JOLLY. 42 KOLAVALLOOR SERVICE CO-OPERATIVE BANK LTD., P.O.CHERUPARAMBA, THOOVAKKUNNU, KANNUR-670693, REPRESENTED BY ITS SECRETARY VAIJAYANTHI T.H. 43 NUCHIYAD SERVICE CO-OPERATIVE BANK LTD. NO. C 220, P.O.MANIKKADAVU, KANNUR-670705, REPRESENTED BY ITS SECRETARY GEORGE JOSEPH T. 44 PUTHUR SERVICE CO-OPERATIVE BANK LTD. NO. LL 23, KAIVELIKKAL, P.O.PUTHUR, KANNUR-670692, REPRESENTED BY ITS SECRETARY A.MANOJ KUMAR. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, 2025:KER W.P(C)No.7053/2023 & Connected cases 265 KOCHI-682018. 4 PRINCIPAL COMMISSIONER OF INCOME TAX, KOZHIKODE, AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE- 673001. 5 INCOME TAX OFFICER, TDS, WARD TDS, KANNUR, AYAKAR BHAVAN, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, KANNOTHUMCHAL, CHOVVA P.O., KANNUR-670006. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: : 2025:KER W.P(C)No.7053/2023 & Connected cases 266 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11446 OF 2022 PETITIONER/S: KARTHEDOM SERVICE CO-OPERATIVE BANK LTD. NO.123, MALIPURAM, ERNAKULAM-682511, REPRESENTED BY ITS SECRETARY SRI. AJITHA P.V. BY ADVS. SHRI.AJI V.DEV SRI.ALAN PRIYADARSHI DEV RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, 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, I S PRESS ROAD, KOCHI-682018. 3 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, VIKAS BHAVAN, PALAYAM, 2025:KER W.P(C)No.7053/2023 & Connected cases 267 THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 268 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11445 OF 2022 PETITIONER/S: 1 MULLASSERY SERVICE CO-OPERATIVE BANK LTD. NO.R 280, P.O.MULLASSERY, THRISSUR, REPRESENTED BY ITS SECRETARY, 680509. 2 ARATTUPUZHA SERVICE CO-OPERATIVE BANK LTD. NO.632, ARATTUPUZHA, THRISSUR, REPRESENTED BY ITS SECRETARY, 680515. 3 THE ELAVALLY SERVICE CO-OPERATIVE BANK LTD. NO.F 1456, P.O.VAKA, THRISSUR, REPRESENTED BY ITS SECRETARY, 680602. 4 THE KOTTAPPADY SERVICE CO-OPERATIVE BANK LTD. NO.R 210, P.O.KOTTAPADI, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY, 680505. 5 ANNAKARA SERVICE CO-OPERATIVE BANK LTD. NO.F 549, PERUVALLUR, THRISSUR-680508, REPRESENTED BY ITS SECRETARY. 6 THE CHITTATTUKARA SERVICE CO-OPERATIVE BANK LTD. NO.F 1642, CHITTATTUKARA P.O., THRISSUR, REPRESENTED BY ITS SECRETARY, 680507. BY ADV SRI.E.S.ASHRAF 2025:KER W.P(C)No.7053/2023 & Connected cases 269 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SHRI.M.JAYAKRISHNAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 270 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11458 OF 2022 PETITIONER/S: EDANADU SERVICE CO-OPERATIVE BANK LTD. NO 1768 EDANADU, VALLICHIRA VILLAGE, MEENACHIL TALUK, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY BY ADV SRI.P.C.HARIDAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 2 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 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, ERNAKULAM 682 018 4 THE ADDITIONAL COMMISSIONER OF INCOME TAX OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, 3RD FLOOR, AAYAKAR BHAVAN, KOWADIAR, THIRUVANANTHAPURAM 695 003 5 THE INCOME TAX OFFICER (TDS) 2025:KER W.P(C)No.7053/2023 & Connected cases 271 HGVG+7JW, BAKER HILL, KOTTAYAM 686 002 6 THE KERALA STATE CO-OPERATIVE BANK LIMITED PB NO. 6515, COBANK TOWERS, VIKAS BHAVAN P.O, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS GENERAL MANAGER 7 THE KERALA STATE CO-OPERATIVE BANK LIMITED PALA BRANCH, VAZHAYIL BLDS, PALA P.O 686 575 REPRESENTED BY ITS BRANCH MANAGER 8 THE STATE OF KERALA REPRESENTED BY ITS PRINCIPAL SECRETARY TO THE CO- OPERATIVE DEPARTMENT, SECRETARIAT, FORT P.O, THIRUVANANTHAPURAM 695 023 BY ADVS. SHRI.S.BIJU, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 272 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11467 OF 2022 PETITIONER/S: 1 KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION, DISTRICT COMMITTEE, KASARAGOD, REPRESENTED BY ITSSECRETARY, K.P.VALSALAN, AGED 54 YEARS, S/O.KOMBATH CHANDAN, PALLIPPARA P.O., PETTIKUNDU, KASARAGOD-671 313. 2 PALLIKERE SERVICE CO-OPERATIVE BANK LTD.NO.L-68, HEAD OFFICE, PALLIKERE, P.O.BAKAL FORT, KASARAGOD-671 316, REPRESENTED BY ITS SECRETARY, PUSHKARAKSHAN.K., AGED 55 YEARS, SON OF APPAKUNHI.K.B. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, 2025:KER W.P(C)No.7053/2023 & Connected cases 273 DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD.,` PB NO.6615, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 274 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11478 OF 2022 PETITIONER/S: THE AVITTATHUR SERVICE CO-OPERATIVE BANK LTD.NO.706, AVITTATHUR, THRISSUR, RESPRESENTED BY THE SECRETARY, PIN-680 683. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2 THE COMMISSIONER OF INCOME TAX 9TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM- 682 018. 3 THE INCOME TAX OFFICER 9TDS), OFFICE OF THE INCOME TAX OFFICER 9TDS), AAYAKAR BAHVAN, SAKTHAN THAMPURAM NAGAR, THRISSUR-680 001. 4 THE KERALA STATE CO OPERATIVE BANK LTD., CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SMT.M.SHAJNA, CGC SRI.CHRISTOPHER ABRAHAM 2025:KER W.P(C)No.7053/2023 & Connected cases 275 SHRI.B.G.HARINDRANATH (SR.) THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 276 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11480 OF 2022 PETITIONER/S: 1 VALLACHIRA SERVICE CO-OPERATIVE BANK LTD. NO.527, VALLACHIRA P.O., THRISSUR, REPRESENTED BY ITS SECRETARY, PIN-680 301. 2 PANAMKULAM ETTUMUNA SERVICE CO OPERATIVE BANK LTD .NO.626, PANAMKULAM, THRISSUR, REPRESENTED BY ITS SECRETARY, PIN-680 711. 3 URAKAM SERVICE CO OPERATIVE BANK LTD.NO.526, URAKAM, THRISSUR, REPRESENTED BY ITS SECRETARY, PIN- 680 562. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW DELHI-110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, ERNAKULAM- 682 018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER 9TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 277 4 THE KERALA STATE CO-OPERATIVE BANK LTD., CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033,REPRESENTED BY ITS MANAGING DIRECTOR. BY ADV SHRI.B.G.HARINDRANATH (SR.) THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 278 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11489 OF 2022 PETITIONER/S: 1 THE KOOTTAR SERVICE CO-OPERATIVE BANK LTD NO. K-373 REP BY ITS SECRETARY, K.G SURESH KUMAR, S/O. GOPINATH, AGED 46 YEARS, HEAD OFFICE, KARNAPURAM P.O., KOOTTAR, IDUKKI-685 552 2 BALAGRAM SERVICE CO-OPERATIVE BANK LTD., NO.I-150, REPRESENTED BY ITS SECRETARY RAJIMOL P.V., AGED 35 YEARS, W/O DINESH .L.T., HEAD OFFICE . BALAGRAM ,P.O.IDUKKI-685 552 3 UDUMBANCHOLA SERVICE CO-OPERATIVE BANK LTD, NO.K-396, REPRESENTED BY ITS SECRETARY, SREEKALA C.S., W/O. SLYMON, AGED 41 YEARS, HEAD OFFICE, UDUMBANCHOLA P.O., IDUKKI-685 554 4 UDUMBANCHOLA CO-OPERATIVE EMPLOYEES CO-OPERATIVE SOCIETY LTD., NO.1-168, REP BY ITS SECRETARY ANITHA V.NAIR, D/O.VELAYUDHAN NAIR, HEAD OFFICE, NEDUMKANDAM LA P.O., IDUKKI-685 553 5 THE IDUKI DISTRICT POLICE CO-OPERATIVE SOCIETY LTD., NO.1-490, REP BY ITS SECRETARY SANAL KUMAR, S/O. HARIDAS, HEAD OFFICE, IDUKKI COLONY P.O., CHERUTHONI, IDUKKI-685 602 6 THE SANTHANPARA SERVICE CO-OPERATIVE LTD NO., K-344, REPRESENTED BY ITS SECRETARY, TOMICHAN.K.J., AGED 51 YEARS, S/O. JOSEPH, HEAD OFFICE, SANTHANPARA P.O., IDUKKI-685 619 2025:KER W.P(C)No.7053/2023 & Connected cases 279 BY ADVS. SRI.GEORGE MATHEW SRI.M.D.SASIKUMARAN SHRI.PRAVEEN S. SHRI.SUNIL KUMAR A.G SRI.DIPU JAMES SHRI.MATHEW K.T. SHRI.GEORGE K.V. SHRI.STEPHY K REGI SMT.ELSA DENNY PINDIS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -110 002 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682 018 3 THE INCOME TAX OFFICER, TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8, THODUPUZHA, IDUKKI DISTRICT-685 584 4 STATE OF KERALA, REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM-695 014 6 THE KERALA STATE CO-OPERATIVE BANK LTD., ( KERALA BANK), REP BY ITS MANAGING DIRECTOR & CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 7 THE DEPUTY GENERAL MANAGER, 2025:KER W.P(C)No.7053/2023 & Connected cases 280 CENTRAL PROCESSING CENTER, THE KERALA STATE CO- OPERATIVE BANK LTD., (KERALA BANK), VAZHATHOPE, IDUKKI COLONY P.O., IDUKKI DISTRICT-685 602 BY ADVS. SHRI.B.PRAMOD, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 281 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11487 OF 2022 PETITIONER/S: 1 THE MULLAKKARA VILLAGE SERVIC CO-OPERATIVE BANK LTD NO.R.677, P.O.MULLURKARA, THRISSUR, -680 588 , REPRESENTED BY ITS SECRETARY-680 588 2 VENGANALLUR SERVICE CO OPERATIVE BANK, LTD NO.22, VENGANALLUR, THRISSUR,REPRESENTED BY ITS SECRETARY-680585 3 THE DESAMANGALAM SERVICE CO -OPERATIVE BANK LTD NO.134, DESAMANGALAM,THRISSUR, REPRESENTED BY ITS SECRETARY- 679 532 4 THE CHERUTHURUTHY SERVICE CO-OPERATIVE BANK LTD NO.121, CHERUTHURUTHY, THRISSUR DISTRICT, REPRESENTED BY ITS SECRETARY-679 121 BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM- 2025:KER W.P(C)No.7053/2023 & Connected cases 282 682 018 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001 4 THE KERALA STATE CO-OPERATIVE BANK LTD, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 283 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11507 OF 2022 PETITIONER/S: 1 KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION DISTRICT COMMITTEE, PALAKKAD, REPRESENTED BY ITS SECRETARY, RAMAKRISHNAN K., AGED 49 YEARS, S/O. M.MADHAVAN NAIR, PRESIDENT, SREEKRISHNAPURAM SERVICE CO-OPERATIVE BANK LTD. NO.F.1213, SREEKRISHNAPURAM, KARIMPUZHA, PALAKKAD-678595. 2 SREEKRISHNAPURAM SERVICE CO-OPERATIVE BANK LTD. NO.F.1213, SREEKRISHNAPURAM, KARIMPUZHA, PALAKKAD-678595, REPRESENTED BY ITS PRESIDENT, RAMAKRISHNAN K., AGED 49 YEARS, S/O. M.MADHAVAN NAIR, KIZHAKKEKALAM, VAKKADAPURAM P.O., KARAKURISSI, PALAKKAD. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 284 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. BY ADVS. SRI.M.JAYAKRISHNAN CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 285 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11530 OF 2022 PETITIONER/S: ENGANDIYUR FARMERS SERVICE CO-OPERATIVE BANK LTD. NO.F-977, P.O.ENGANDIYUR, THRISSUR - 680 615, REPRESENTED BY THE MANAGING DIRECTOR. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM - 682 018. 3 THE INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) 2025:KER W.P(C)No.7053/2023 & Connected cases 286 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 287 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11544 OF 2022 PETITIONER/S: 1 THE ALAKODE SERVICE CO-OPERATIVE BANK LTD NO.1588, REPRESENTED BY ITS SECRETARY, SHINTO JOSE, S/O.JOSE, AGED 42 YEARS, HEAD OFFICE, ALAKODE P.O., IDUKKI-685 588. 2 THE PUTHUPARIYARAM SERVICE CO-OPERATIVE BANK LTD., NO.3-55, REPRESENTED BY ITS SECRETARY, JENCY MATHEW, AGED 50 YEARS W/O.SEBASTIAN, PUTHUPARIYARAM P.O., IDUKKI - 685 608. 3 MANAKKAD SERVICE CO-OPERATIVE BANK LTD., NO.1706, REPRESENTED BY ITS SECRETARY, NIRMAL SHAJI, S/O.SHAJI, AGED 31 YEARS, MANAKKAD, MANAKKAD P.O., IDUKKI - 685 608. 4 MUTHALAKODAM SERVICE CO-OPERATIVE BANK LTD., NO.140, REPRESENTED BY ITS SECRETARY, SAJI PAUL, S/O.PAUL, AGED 51 YEARS, HEAD OFFICE, MUTHALAKODAM, IDUKKI - 685 605. 5 THE NEDUMATTAM SERVICE CO-OPERATIVE BANK LTD., NO.1292, REPRESENTED BY ITS SECRETARY, SINU K.G., S/O.GOPALAN, AGED 44 YEARS, HEAD OFFICE, VANDAMATTAM P.O., IDUKKI - 685 582. 6 KARIKODE SERVICE CO-OPERATIVE BANK LTD., NO.4009, REPRESENTED BY ITS SECRETARY, MOLLY P.V., W/O.SUNNY P.J., AGED 56 YEARS, HEAD OFFICE, KARIKODE, THODUPUZHA P.O., IDUKKI - 685 584. 7 KODIKULAM SERVICE CO-OPERATIVE BANK LTD., 2025:KER W.P(C)No.7053/2023 & Connected cases 288 NO.2823, REPRESENTED BY ITS SECRETARY, ABIN MICHAEL, S/O.MICHAEL, AGED 28 EYARS, HEAD OFFICE, KODIKULAM P.O., IDUKKI - 685 582. 8 KUMARAMANGALAM SERVICE CO-OPERATIVE BANK LTD., NO.4122, REPRESENTED BY ITS SECRETARY, AJITH V. ABRAHAM, S/O.ROY ABRAHAM, AGED 27 YEARS, HEAD OFFICE, KALOOR EAST, KALOOR P.O., IDUKKI - 685 608. 9 UDUMBANOOR SERVICE CO-OPERATIVE BANK LTD., NO.E-93, REP. BY ITS SECRETARY, REMYA BALACHANDRAN, W/O.AJEESH KUMAR, AGED 37 YEARS, HEAD OFFICE, UDUMBANOOR P.O., IDUKKI DISTRICT - 685 595. 0 THE THODUPUZHA SERVICE CO-OPERATIVE BANK LTD., NO.969, REPRESENTED BY ITS SECRETARY, JAYASREE P., W/O.T.R.SOMAN, AGED 50 YEARS, HEAD OFFICE, THODUPUZHA P.O., IDUKKI - 685 584. 11 THE THODUPUZHA TALUK REGIONAL SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD.,NO.I-690, REP. BY ITS SECRETARY, ANJITH REJI, AGED 27 YEARS, S/O.P.N.REJI, VENGALLUR P.O., THODUPUZHA TALUK, IDUKKI DISTRICT - 685 608. 12 THODUPUZHA TOWN SERVICE CO-OPERATIVE BANK LTD., NO.I-233, REPRESENTED BY ITS SECRETARY, RAKHI C., W/O.JAGADEESH, AGED 41 YEARS, HEAD OFFICE THODUPUZHA P.O., IDUKKI - 685 584. 13 THE KARIMANOOR SERVICE CO-OPERATIVE BANK LTD., NO.967, REPRESENTED BY ITS SECRETARY, JAIN V. GEORGE, S/O.GEORGE, AGED 42 YEARS, HEAD OFFICE, KARIMANOOR P.O., IDUKKI - 685 581. 14 THE KARIMKUNNAM SERVICE CO-OPERATIVE BANK LTD., NO.2670, REPRESENTED BY ITS SECRETARY, DEENA BABY, W/O.BABY, AGED 41 YEARS, HEAD OFFIE, KARIMKUNNAM P.O., IDUKKI - 685 586. 15 MUTTAM SERVICE CO-OPERATIVE BANK LTD., NO.1284, REPRESENTED BY ITS SECRETARY, ARUN DOMINIC, S/O.DOMINIC, AGED 33 YEARS, HEAD OFFICE, MUTTAM P.O., IDUKKI - 685 587. 2025:KER W.P(C)No.7053/2023 & Connected cases 289 16 VAZHITHALA SERVICE CO-OPERATIVE BANK LTD., NO.908, REPRESENTED BY ITS SECRETARY, REGI N. ABRAHAM, W/O.SHAJI, AGED 48 YEARS, HEAD OFFICE, VAZHITHALA P.O., IDUKKI - 585 583. BY ADVS. SRI.GEORGE MATHEW SRI.M.D.SASIKUMARAN SHRI.PRAVEEN S. SHRI.SUNIL KUMAR A.G SHRI.MATHEW K.T. SHRI.GEORGE K.V. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 002. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, KOCHI - 682 018. 3 THE INCOME TAX OFFICER, TDS OFFICE, MAHIMA TOWERS STATE HIGHWAY-8, THODUPUZHA, IDUKKI DISTRICT - 685 584. 4 STATE OF KERALA, REP. BY ITS SECRETARY, FINANCE DEPARTMENT GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM - 695 014. 6 THE THODUPUZHA URBAN CO-OPERATIVE BANK LTD., NO.394, REP. BY ITS GENERAL MANAGER, HEAD OFFICE, THODUPUZHA TALUK, THODUPUZHA P.O., IDUKKI DISTRICT - 685 584. 2025:KER W.P(C)No.7053/2023 & Connected cases 290 BY ADV SHRI.B.PRAMOD, SENIOR PANEL COUNSEL THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 291 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11555 OF 2022 PETITIONER/S: 1 KOTTATHARA SERVICE CO-OPERATIVE BANK LTD . KOTTATHARA P.O., KALPETTA VIA., WAYANAD - 673 124, REPRESENTED BY ITS SECRETARY SUMESHAN M. 2 MADAKKIMAL SERVICE CO-OPERATIVE BANK LTD. P.O.MADAKKIMALA, WAYANAD - 673 122 REPRESENTED BY ITS SECRETARY SREEHARI P. 3 VENGAPPALLY SERVICE CO-OPERATIVE BANK LTD. PINANGODE P.O., WAYNAD - 673 121 REPRESENTED BY ITS SECRETARY ABDUL JAFFER. 4 PADINHARATHARA SERVICE CO-OPERATIVE BANK LTD. PADINHARATHARA P.O., WAYANAD - 673 575 REPRESENTED BY ITS SECRETARY MOIDOO K. 5 POOTHADY SERVICE CO-OPERATIVE BANK LTD. NO.F 1011, HEAD OFFICE, KENCHIRA, WAYANAD - 673 596 REPRESENTED BY ITS SECRETARY BIJI VINOD. 6 ANJUKUNNU SERVICE CO-OPERATIVE BANK LTD. NO.C 311, P.O.ANJUKUNNU, WAYANAD - 670 645 REPRESENTED BY ITS SECRETARY SAJITH P.T. 7 THARUVANA SERVICE CO-OPERATIVE BANK LTD. NO.F 521, THARUVANA, WAYANAD - 670 645 REPRESENTED BY ITS SECRETARY VIJAYESWARI T. 8 MULLANKOLY SERVICE CO-OPERATIVE BANK LTD. P.O.PADICHIRA, WAYANAD - 673 579 REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 292 SECRETARY SAJI JOSEPH K. 9 PULPULLY SERVICE CO-OPERATIVE BANK LTD. P.O.PULPALLY, WAYANAD - 673 579 REPRESENTED BY ITS SECRETARY P.M.MOHANDAS. 0 KALPETTA SERVICE CO-OPERATIVE BANK LTD. NO.F 6807, KALPETTA, WAYANAD - 673 121 REPRESENTED BY ITS SECRETARY SAJOHN M.P. 11 THAVINHAL SERVICE CO-OPERATIVE BANK LTD. NO. C 4032, THALAPUZHA P.O., WAYANAD - 670 644 REPRESENTED BY ITS SECRETARY NAZEEMA P.K. 12 KANIYAMBETTA SERVICE CO-OPERATIVE BANK LTD. P.O.KANIYAMBETTA, WAYANAD - 673 124 REPRESENTED BY ITS SECRETARY NISHA VARGHESE. 13 NALLURNAD SERVICE CO-OPERATIVE BANK LTD. NO.6913, NALLURNAD P.O., DWARAKA, MANANTHAWADI, WAYANAD - 670 645 REPRESENTED BY ITS SECRETARY RAJU MATHEW. 14 MANANTHAVADI FARMER'S SERVICE CO-OPERATIVE BANK LTD. NO.F 4034, MANANTHAVADY, WAYANAD - 670 645 REPRESENTED BY ITS MANAGING DIRECTOR M.MANOJ KUMAR. 15 MEENANGADI SERVICE CO-OPERATIVE BANK LTD. MEENANGADI P.O., WAYANAD - 673 591 REPRESENTED BY ITS SECRETARY MURALI M.N. 16 EACHOME SERVICE CO-OPERATIVE BANK LTD. NO.C 6612, P.O.EACHOME, PANAMARAM, WAYANAD - 670 721 REPRESENTED BY ITS SECRETARY P.M.DEVASIA. 17 THEKKUMTHARA SERVICE CO-OPERATIVE BANK LTD. P.O.THEKKUMTHARA, WAYANAD - 673 122 REPRESENTED BY ITS SECRETARY PRIYA K.M. 18 PANMARAM SERVICE CO-OPERATIVE BANK LTD. P.O.PANAMARAM, WAYANAD - 670 721 REPRESENTED BY ITS SECRETARY SANDHYA E. 2025:KER W.P(C)No.7053/2023 & Connected cases 293 19 THIRUNELLY SERVICE CO-OPERATIVE BANK LTD. NO.4389, HEAD OFFICE, KATTIKULAM, WAYANAD - 670646, REPRESENTED BY ITS SECRETARY VASANTHA KRISHNAN T. 20 SULTHAN BATHERY SERVICE CO-OPERATIVE BANK LTD. NO.LL 11, P.O.SULTHAN BATHERY, WAYANAD - 673 592, REPRESENTED BY ITS SECRETARY JESSY C.V. 21 THARIODE SERVICE CO-OPERATIVE BANK LTD. P.O.KAVUMMANNAM, WAYANAD - 673 122 REPRESENTED BY ITS SECRETARY THOMAS P.V. 22 TRIKKAIPETTA SERVICE CO-OPERATIVE BANK LTD. NO.F 7602, HEAD OFFICE, MEPPADI P.O., WAYANAD - 673 577 REPRESENTED BY ITS SECRETARY SREEJITH K.S. 23 AMBALAVAYAL SERVICE CO-OPERATIVE BANK LTD. AMBALAVAYAL P.O., WAYANAD - 673 593 REPRESENTED BY ITS SECRETARY ATHIRA KRISHNAN 24 THONDERNAD SERVICE CO-OPERATIVE BANK LTD. NO W 85, CHEPPAD, P.O.MAKKIYAD, WAYANAD - 670 731 REPRESENTED BY ITS SECRETARY KURIAKOSE P.A. 25 VYTHIRI SERVICE CO-OPERATIVE BANK LTD. NO.F 868, P.O.VYTHIRI, WAYANAD - 673 576, REPRESENTED BY ITS SECRETARY K.BINDU. 26 VELLIMUNDA SERVICE CO-OPERATIVE BANK LTD. NO.C 530, P.O.KATTAYAD, WAYANAD - 670 731 REPRESENTED BY ITS SECRETARY MUHAMMED RAFEEQ. 27 PERIYA SERVICE CO-OPERATIVE BANK LTD. NO.W 284, P.O.PERIYA, WAYANAD - 670 644 REPRESENTED BY ITS SECRETARY JOBISH K.J. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 294 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI - 682 018. 4 PRINCIPAL COMMISSIONER OF INCOME OF TAX KOZHIKODE AAYAKAR BHAVAN, MANANCHIRA, KOZHIKODE - 673 001. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. SMT.M.S.KIRAN, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 295 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11558 OF 2022 PETITIONER/S: 1 KANHANGAD BLOCK VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.NO.C 887, VAZHUNNORODY, P.O.UPPILIKAI, KASARAGOD -671314, REPRESENTED BY ITS SECRETARY ANEESH K.V. 2 BALAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 293, BALAL, BALAL P.O., KASARAGOD-671533, REPRESENTED BY SECRETARY PRASANTH V. 3 KOTTAPPARA FARMER'S WELFARE CO-OPERATIVE SOCIETY LTD. NO. S460, KOTTAPPARA, P.O.PULLUR, KASARAGOD-671531, REPRESENTED BY ITS SECRETARY SHYAMKUMAR K. 4 POTHANICAD BHAVANA NIRMANA SAHAKARANA SANGAM LTD. NO. E 708, POTHANICAD P.O., ERNAKULAM-686671, REPRESENTED BY ITS SECRETARY SINDHU C.K., 5 POTHANICAD AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD. NO.E 1231, POTHANICAD P.O., KOTHAMANGALAM, ERNAKULAM-686671, REPRESENTED BY ITS SECRETARY SALY IYPE. 6 VORKADY AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 419, SUNKADAKATTE, MAJEERPALLA, P.O.VORKADY, MANJESWAR, KASARAGOD-671323, REPRESENTED BY ITS SECRETARY RAVINDRA MOOLYA M. 2025:KER W.P(C)No.7053/2023 & Connected cases 296 7 ENMAKAJE PANCHAYATH PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD. NO.K 574, P.O.KATUKUKKE, MANJESWAR, KASARAGOD -671552, REPRESENTED BY ITS SECRETARY AJITH G. 8 CHEEMENI URBAN CO-OPERATIVE SOCIETY LTD. NO.S 358, P.O.CHEEMENI, KASARAGOD-671313, REPRESENTED BY ITS SECRETARY SATHI K. 9 CHITTUR PRIMARY CO-OPERATIVE AGRICULTURAL AND RURAL DEVELOPMENT BANK LTD. NO.P 619, P.O.CHITTUR, PALAKKAD-678101, REPRESENTED BY ITS SECRETARY V.SHIELA. 10 PERLA PRIMARY AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 394, P.O.PERLA, KASARAGOD-671552, REPRESENTED BY ITS SECRETARY RAMAKRISHNA RAI. 11 HOSDURG TALUK MOTOR TRANSPORT WORKERS WELFARE CO- OPERATIVE SOCIETY LTD. NO.S 476, PERIYA, PERIYA P.O., KASARAGOD-671320, REPRESENTED BY ITS SECRETARY SRUTHI T. 12 PATTAMBI BLOCK BHAVANA NIRMANA SAHAKARANA SANGAM LTD. NO.P 816, NETHIRIMANGALAM, SANKARAMANGALAM P.O., PATTAMBI, PALAKKAD-679303, REPRESENTED BY ITS SECRETARY B.C.BIJU. 13 MANNARKKAD CO-OPERATIVE EMPLOYEES' CO-OPERATIVE SOCIETY LTD. NO.P 629, MANNARKKAD P.O., PALAKKAD-678582, REPRESENTED BY ITS SECRETARY P.K.MOHANDAS. 14 VADATTUPARA RURAL CO-OPERATIVE SOCIETY LTD. NO.E 1087, VADATTUPARA P.O., ERNAKULAM-686681, REPRESENTED BY ITS SECRETARY SUNITHA M.VARGHESE. 15 PADNE AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO.S 386, UDINOOR P.O., KASARAGOD -671310, REPRESENTED BY ITS SECRETARY REMYA K.V. 2025:KER W.P(C)No.7053/2023 & Connected cases 297 16 KOTHAMANGALAM VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.NO.E 916, KOTHAMANGALAM P.O., ERNAKULAM-686691, REPRESENTED BY ITS SECRETARY BINDHU MATHAI. 17 KOTHAMANGALAM RURAL CO-OPERATIVE SOCIETY LTD.NO.E 1079, KOTHAMANGALAM P.O., ERNAKULAM-689691, REPRESENTED BY ITS SECRETARY JUBY JOHNSON. 18 MALABAR RUBBER AND OTHER AGRICULTURAL MARKETING AND PROCESSING CO-OPERATIVE SOCIETY LTD. NO.254, MALAKKALLU, MALAKKALLU P.O., KASARAGOD-671532, REPRESENTED BY ITS SECRETARY SURESH KUMAR M. 19 KANHANGAD CO-OPERATIVE URBAN SOCIETY LTD. NO.324, HOSDURG, P.O.KANHANGAD, KASARAGOD-671315, REPRESENTED BY ITS SECRETARY SHOBA P. 20 KASTURBA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S 519, WEAVERS STREET, P.O.NILESWAR, KASARAGOD -671314, REPRESENTED BY ITS SECRETARY REJITHA K. 21 NILESHWAR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 319, P.O.NELESHWAR, KASARAGOD-671314, REPRESENTED BY ITS SECRETARY SIVAPRASAD A. 22 NILESHWAR EX-GULFMEN WELFARE CO-OPERATIVE SOCIETY LTD. S 92, P.O.KOTTAPPURAM, NILESHWAR, KASARAGOD-671314, REPRESENTED BY ITS SECRETARY RAJANI A.K. 23 PUTHIGE-ENMAKAJE CO-OPERATIVE URBAN SOCIETY LTD., SEETHANGOLI, P.O.EDNAD, KASARAGOD -671321, REPRESENTED BY ITS SECRETARY HEMALATHA KODOTH. 24 TRIKARIPUR CO-OPERATIVE URBAN SOCIETY LTD. NO.S 320, TRIKARIPUR, KASARAGOD -671310, REPRESENTED BY ITS SECRETARY RAMESAN U. 25 CHERUVATHUR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 298 NO.S 194, V.V.NAGAR, P.O.CHERUVATHUR, KASARAGOD-671313, REPRESENTED BY ITS SECRETARY SAJINI K.V. 26 CHITTUR GOVERNMENT SERVICE CO-OPERATIVE SOCIETY LTD. NO.P 160, CHITTUR P.O., PALAKKAD-678101, REPRESENTED BY ITS SECRETARY GIRIJAVALLABHAN C. 27 CHEEMENI VANITHA SAHAKARANA SANGAM LTD. NO.S 212, P.O.CHEEMENI, KASARAGOD-671313, REPRESENTED BY ITS SECRETARY UDAYA BHANU K. 28 PARAPPA CO-OPERATIVE URBAN SOCIETY LTD. NO.S 330, PARAPPA P.O., KASARAGOD -671533, REPRESENTED BY ITS SECRETARY GIRISH P. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 2025:KER W.P(C)No.7053/2023 & Connected cases 299 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. SHRI.M.JAYAKRISHNAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 300 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11570 OF 2022 PETITIONER/S: 1 KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION ASSOCIATION, DISTRICT COMMITTEE, KOLLAM REPRESENTED BY ITS PRESIDENT, M.C. BINUKUMAR, AGED 48 YEARS S/O K. CHELLAPPAN, PRESIDENT, ELAMADU SERVICE CO- OPERATIVE BANK LTD, ELAMADU P.O.AYOOR, KOLLAM-691 508 2 ELAMADU SERVICE CO-OPERATIVE BANK LTD ELAMADU.P.O, AYOOR, KOLLAM-691 508 REPRESENTED BY ITS SECRETARY A JALAJA BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE , 2025:KER W.P(C)No.7053/2023 & Connected cases 301 GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI-682018 4 ADDITIONAL COMMISSIONER OF INCOME TAX , TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM, -695 003 5 THE KERALA STATE CO-OPERATIVE BANK LTD P.B.NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO_OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURM-695001 BY ADVS. SMT.M.S.KIRAN, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 302 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11591 OF 2022 PETITIONER/S: 1 KOTTAPPADY EAST SERVICE CO-OPERATIVE BANK LTD.NO.E 152, HEAD OFFICE AYROOR, AYROORPADAM P.O., ERNAKULAM-686 692, REPRESENTED BY ITS SECRETARY PATHROSE.K.P. 2 CHERUVATTOOR RURAL CO-OPERATIVE BANK LTD. NO.E 1089, IRIMALLOOR P.O., KOTHAMANGALAM-686 691, REPRESENTED BY ITS SECRETARY ICY MOL.M.J. 3 MAYYIL SERVICE CO-OPERATIVE BANK LTD. NO.C 343, HEAD OFFICE, MAYYIL, KANNUR-6790 602, REPRESENTED BY ITS SECRETARY SREELAL.C. 4 VORKADY SERVICE CO-OPERATIVE BANK LTD. NO.C 321, P.O.VORKADY, VIA MANJESHWAR, KASARAGOD-671 321, REPRESENTED BY ITS SECRETARY SHRIVASHSA BHAT. 5 ELAVANCHERY SERVICE CO OPERATIVE BANK LTD. NO.P 517, ELAVANCHERY P.O., NEMMARA VIA, PALAKKAD-678 508, REPRESENTED BY ITS SECRETARY V.SOUMAN. 6 ELAPPULLY SERVICE CO OPERATIVE BANK LTD. NO.F 1193, ELAPPULLY P.O., PALAKKAD-678 622, REPRESENTED BY ITS SECRETARY PARTHAN.N. 7 KANJIRAPPALLY CENTRAL SERVICE CO OPERATIVEBANK 1537, HEAD OFFICE, KANJIRAPALLY, KOTTAYAM-686 507, REPRESENTED BY ITS SECRETARY SOUDA.P.K. 8 INCHIANY SERVICE CO OPERATIVE BANK LTD.K 154, 2025:KER W.P(C)No.7053/2023 & Connected cases 303 HEAD OFFICE, INCHIANY P.O., KANJIRAPALLY TLAUK, KOTTAYAM-686 512, REPRESENTED BY ITS SECRETARY THOMAS K.GEORGE. 9 PERUMBAVOOR URBAN CO OPERATIVE BANK LTD. NO.2024, P.O.PERUMBAVOOR, ERNAKULAM-683 542, REPRESENTED BY ITS SECRETARY BEEVIJA.P.H. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY, , MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018. 4 THE KERALA STATE CO OPERATIVE BANK LTD., PB NO.6515, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 304 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 305 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11601 OF 2022 PETITIONER/S: THEVARA URBAN CO-OPERATIVE SOCIETY LTD. NO. E-784, PERUMANOOR , COCHIN 682 016, REPRESENTED BY THE SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM 682 018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR, KANDAMKULATHY TOWER, M G ROAD, KARIKKAMURI, SHENOYS , KOCHI, KERALA 682 011. 4 THE KERALA STATE CO OPERATIVE BANK LTD, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 306 SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 307 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11599 OF 2022 PETITIONER/S: THAZHEKKAD SERVICE CO-OPERATIVE BANK LTD NO R 167, THAZHEKKAD, MALA, THRISSUR-680 691, REPRESENTED BY THE SECRETARY BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA,MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COCMMISSIONER OF INCME TAX (TDS), CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM- 682 018 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR, KANDAMKULATHY TOWER, M.G.ROAD, KARIKKAMURI, SHENOYS, KOCHI, KERALA 682 011. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 308 SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 309 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11600 OF 2022 PETITIONER/S: THE PULLUR SERVICE CO-OPERATIVE BANK LTD., NO. 550 , PULLUR P.O, THRISSUR 680 683, REPRESENTED BY THE SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110001. 2 THE COMMISSIONER OF INCOM TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM 682 018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR, KANDAMKULATHY TOWER, M. G ROAD, KARIKKAMURI, SHENOYS, KOCHI, KERALA 682 011. 4 THE KERALA STATE CO -OPERATIVE BANK LTD, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 310 SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 311 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11604 OF 2022 PETITIONER/S: THE NELLAYI PARAPPUKARA SERVICE CO-OPERATIVE BANK LTD. 460, NELLAYI P.O.THRISSUR-680 305, REPRESENTED BY ITS SECRETARY BY ADVS. SMT.NISHA GEORGE SHRI.ANSHIN K.K RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE 111RD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.THIRUVANANTHAPURAM, PIN-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 PIN-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, PIN-110 001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, 2025:KER W.P(C)No.7053/2023 & Connected cases 312 THIRUVANANTHAPURAM, PIN-695 001. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695 001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 313 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11607 OF 2022 PETITIONER/S: 1 THE THODUPUZHA TALUK EDUCATIONAL CO-OPERATIVE SOCIETY LTD NO 1-159, REPRESENTED BY ITS HON SECRETARY, STEPEHN P.S.S/O SIMON, HEAD OFFICE, THODUPUZHA TALUK & POST, IDUKKI DISTRICT-685 584. 2 THE L.I.C.AGENTS CO-OPERATIVE SOCIETY LTD, NO 1-394, REPRESENTED BY ITS SECRETARY IN-CHARGE, SABU M.R.AGED 49 YEARS, S/O RAMAKRISHNAN, HEAD OFFICE, NEDUMKANDAM P.O.UDUMBANCHOLA TALUK, IDUKKI DISTRICT-685 553. 3 THE IDUKKI DISTICT PANCHAYATH EMPLOYEES CO-OPERATIVE SOCIETY LTDD, NO 1-193, REPRESENTED BY MEJO CHERIAN, AGED 44 YEARS, S/O P.U. CHERIAN, HEAD OFFICE, NEDUMKANDAM P.O.UDUMBANCHOLA TALUK, IDUKKI DISTRICT-685 553. 4 THE VYAPARI CO-OPERATIVE SOCIETY LTD 1-467, REPRESENTED BY ITS SECRETARY, NELSON XAVIER, AGED 53 YEARS, S/O THANISLAVOSE, HEAD OFFICE, NEDUMKANDAM P.O.IDUKKI DISTRICT-685 553 BY ADVS. SRI.GEORGE MATHEW SHRI.PRAVEEN S. SMT.ELSA DENNY PINDIS SRI.M.D.SASIKUMARAN SHRI.SUNIL KUMAR A.G SRI.DIPU JAMES SHRI.MATHEW K.T. 2025:KER W.P(C)No.7053/2023 & Connected cases 314 SHRI.GEORGE K.V. SHRI.STEPHY K REGI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 002. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDINGS I.S PRESS ROAD, KOCHI-682 018. 3 THE INCOME TAX OFFICER, TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8, THODUPUZHA, IDUKKI DISTRICT-685 014 4 STATE OF KERALA, REP BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM-695 014. 6 THE KERALA STATE CO-OPERATIVE BANK LTD, (KERALA BANK), REP BY ITS MANAGING DIRECTOR & CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-685 033. 7 THE DEPUTY GENERAL MANAGER, CENTRAL PROCESSING CENTER, THE KERALA STATE CO- OPERATIVE BANK LTD, (KERALA BANK), VAZHATHOPE, IDUKKI COLONY P.O.IDUKKI -685 602. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 315 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 316 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11605 OF 2022 PETITIONER/S: VARAVOOR SERVICE CO-OPERATIVE SOCIETY LTD NO R299, VARAVOOR P.O.THRISSUR-680 585, REPRESENTED BY THE SECRETARY-IN-CHARGE. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW DELHI-110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM- 682 018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), 6TH FLOOR, KANDAMKULATHY TOWER, M.G.ROAD, KARIKKAMURI, SHENOYS, KOCHI, KERALA-682 011. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SRI.RAHUL RAJ 2025:KER W.P(C)No.7053/2023 & Connected cases 317 CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 318 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11609 OF 2022 PETITIONER/S: CHATHEDOM SERVICE CO-OPERATIVE BANK LIMITED, THURUTHIPURAM P.O., ERNAKULAM 680 667, REPRESENTED BY ITS SECRETARY IN CHARGE BIJU.P.S. BY ADVS. SHRI.K.S.HARIHARAN NAIR SRI.P.F.JOY SHRI.RAJATH R NATH SMT.HARIMA HARIHARAN SMT.G.REMADEVI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 11001. 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI 682 018. 3 THE INCOME TAX OFFICER, (TDS), KAP COMPLEX, HIGH WAY SH 16, ALUVA 683 101. 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 319 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 11001, REPRESENTED BY ITS CHAIRMAN. 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018. 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE , 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003. 7 THE KERALA STATE CO OPERATIVE BANK LTD, (KERALA BANK), PO NO. 6515, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 8 THE KERALA STATE CO OPERATIVE BANK LTD, KERALA BANK), V C S COMPLEX, PUTHENVELIKKARA P.O., 683 594, REPRESENTED BY ITS MANAGING DIRECTOR. 9 STATE OF KERALA REPRESENTED BY ITS SECRETARY ( CO - OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001. BY ADVS. SHRI.S.VAIDYANATHAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 320 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 10302 OF 2022 PETITIONER/S: PATTEPADAM RURAL CO-OPERATIVE SOCIETY LTD.NO. R 1040 KOTTANALLUR P.O., THRISSUR, REPRESENTED BY ITS SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) 2025:KER W.P(C)No.7053/2023 & Connected cases 321 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 322 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11616 OF 2022 PETITIONER/S: KEEZHILLAM AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD NO.E-1248 RAYAMANGALAM P.O., ERNAKULAM DISTRICT, PIN-683545, REPRESENTED BY ITS SECRETARY. BY ADV SRI.BINU PAUL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, 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 INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI ROAD, KOTTAYAM-686001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, VIKAS BHAVAN, PALAYAM, THIRUVANANTHAPURAM-695033. BY ADVS. 2025:KER W.P(C)No.7053/2023 & Connected cases 323 CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 324 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11619 OF 2022 PETITIONER/S: 1 THE KERALA ADVOCATE GENERAL DEPARTMENT STAFF CO- OPERATIVE SOCIETY LTD NO.E 315 ERNAKULAM, REPRESENTED BY ITS SECRETARY, PIN-682 018 2 THE CMFRI EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.E.832, ERNAKULAM, PRESENTED BY ITS SECRETARY, PIN- 682018 3 THE CENTRAL EXCISE EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD NO. E. 674.C.R.BUILDING.I.S.PRESS ROAD, KOCHI-682 018, REPRESENTED BY ITS SECRETARY, PIN- 682 018 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX (TDS) CNTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- PIN-682 018 2 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, ERNAKULAM-PIN-680 001 3 THE KERALA STATE CO-OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM, THRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR. PIN-695 033 4 THE MANAGER, 2025:KER W.P(C)No.7053/2023 & Connected cases 325 KERALA STATE CO-OPERATIVE BANK LTD, MARINE DRIVE BRANCH, ERNAKULAM, PIN- 682 031 BY ADVS. SHRI.ANISH JAIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 326 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11620 OF 2022 PETITIONER/S: THE LEMONGRASS OIL AND GENERAL MARKETING CO-OPERATIVE SOCIETY LTD. NO.3200, KURUPPAMPADY, KURUPPAMPADY P.O., PIN-683545, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.BINU PAUL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, 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 INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI ROAD, KOTTAYAM-686001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, VIKAS BHAVAN, PALAYAM, THIRUVANANTHAPURAM-695033. BY ADVS. 2025:KER W.P(C)No.7053/2023 & Connected cases 327 SHRI.ANISH JAIN, CGC SRI.CHRISTOPHER ABRAHAM CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 328 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11621 OF 2022 PETITIONER/S: THE FACT EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD LIMITED NO. E. 663, UDYOGMANDAL .P.O, ERNAKULAM DISTRICT, 683501, REPRESENTED BY ITS SECRETARY, BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001 2 THE COMMISSIONER OF INCOME TAX CENTRAL REVENUE BUILDING. I.S.PRESS ROAD, ERNAKULAM,PIN-682018 3 THE INCOMETAX OFFICER, (TDS ) INCOME TAX DEPARTMENT ,I.S.PRESS ROAD, ERNAKULAM-PIN- 682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM., THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033 5 THE MANAGER KERALA STATE CO-OPERATIVE BANK LTD, KALAMASSERY, ERNAKULAM-, PIN-683 104 2025:KER W.P(C)No.7053/2023 & Connected cases 329 BY ADV SHRI.SHYAMDEEP S.SHENOY, CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 330 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11627 OF 2022 PETITIONER/S: P.W.D. IRRIGATION & L.S.G.D. EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO. T. 638, REPRESENTED BY ITS SECRETARY, PUBLIC OFFICE BUILDING, THIRUVANANTHAPURAM-695542. BY ADVS. SRI.S.V.PREMAKUMARAN NAIR SRI.R.T.PRADEEP RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI-110001. 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, C.R.BUILDING, I.S.PRESS ROAD, KACHERIPADY, ERNAKULAM- 682018. 3 THE CHIEF COMMISSIONER OF INCOME TAX, AAYAKAR BHAVAN, PEROORKADA ROAD, KOWDIAR, THIRUVANANTHAPURAM-695003. 4 DEPUTY COMMISSIONER OF INCOME TAX, AAYAKAR BHAVAN, PEROORKADA ROAD, KOWDIAR, THIRUVANANTHAPURAM-695003. 2025:KER W.P(C)No.7053/2023 & Connected cases 331 5 THE KERALA STATE CO-OPERATIVE BANK LTD., REPRESENTED BY ITS MANAGING DIRECTOR, PB NO.6515, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN- 695033. 6 MANAGER, THE KERALA STATE CO-OPERATIVE BANK LTD., NANTHENCODE BRANCH, THIRUVANANTHAPURAM, PIN-695011. 7 MANAGER, THE KERALA STATE CO-OPERATIVE BANK LTD., M & E PUTHENCHANTHA BRANCH, THIRUVANANTHAPURAM, PIN-695141. 8 MANAGER, THE KERALA STATE CO-OPERATIVE BANK LTD., M & E FORT BRANCH, THIRUVANANTHAPURAM, PIN-695023. 9 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 332 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11646 OF 2022 PETITIONER/S: MARADY AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD., NO. E 1188, SOUTH MARADY P.O, MUVATTUPUZHA- 686 673, REPRESENTED BY ITS SECRETARY LALY VARGHESE. BY ADV SHRI.S.ARUN RAJ RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL , NEW DELHI , PIN 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, COCHIN- 682 018. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI 682 018. 4 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. 5 KERALA STATE CO-OPERATIVE BANK (KERALA BANK), 2025:KER W.P(C)No.7053/2023 & Connected cases 333 FORMERLY ERNAKULAM DISTRICT CO-OPERATIVE BANK LTD) MUVATTUPUZHA RURAL BRANCH, POST OFFICE JUNCTION, MUVATTUPUZHA, ERNAKULAM 686 661, REPRESENTED BY ITS BRANCH MANAGER. 6 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM , PIN 695 001. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 334 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11649 OF 2022 PETITIONER/S: 1 AIRAPURAM SERVICE CO-OPERATIVE BANK LTD NO.2124 AIRAPURAM P.O., ERNAKULAM DISTRICT, PIN - 683 541 REPRESENTED BY ITS SECRETARY IN CHARGE. 2 MANNAM SERVICE CO-OPERATIVE BANK LTD.NO.E 277 MANNAM P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN - 683 520, REPRESENTED BY ITS SECRETARY. 3 KAITHARAM SERVICE CO-OPERATIVE BANK LTD.NO.1112 KAITHANAM P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN - 683 519, REPRESENTED BY ITS SECRETARY. 4 GANDHI SMARAKA SERVICE CO-OPERATIVE BANK LTD.NO.1349 NANTHIATTUKUNNAM, N.PARAVUR, ERNAKULAM DISTRICT, PIN - 683 513, REPRESENTED BY ITS SECRETARY. 5 PALLIYAKKAL SERVICE CO-OPERATIVE BANK LTD.NO.2232 EZHIKKARA P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN - 683 513, REPRESENTED BY ITS SECRETARY. 6 CHETTIKKAD SERVICE CO-OPERATIVE BANK LTD.NO.851 CHETTIKKA, KUNJITHAI P.O., ERNAKULAM DISTRICT, PIN - 683 522, REPRESENTED BY ITS SECRETARY. 7 PERUMBAVOOR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD.NO.E 1208 PERUMBAVOOR PATTAL P.O., ERNAKULAM DISTRICT,PIN - 683 548, REPRESENTED BY ITS PRESIDENT. 8 PARAVUR VADAKKEKARA SERVICE CO-OPERATIVE BANK 2025:KER W.P(C)No.7053/2023 & Connected cases 335 LTD.NO.3131 NEENDOOR, VADAKKEKARA P.O., ERNAKULAM DISTRICT, PIN - 683 522, REPRESENTED BY ITS SECRETARY. 9 THIRUVANKULAM AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD.NO.E 1219 KARINGACHIRA, IRIMPANAM P.O., ERNAKULAM DISTRICT, PIN - 682 309, REPRESENTED BY ITS SECRETARY. 10 COCHIN NAVAL BASE CIVILIAN EMPLOYEES CO-OPERATIVE HOUSING SOCIETY LTD. NO.E 737, KOCHI, ERNAKULAM DISTRICT, PIN - 682 004, REPRESENTED BY ITS SECRETARY. 11 ELOOKKARA SERVICE CO-OPERATIVE BANK LTD. NO.1765, ELOOKKARA, MUPPATHADAM P.O., ALUVA, ERNAKULAM DISTRICT, PIN - 683 110, REPRESENTED BY ITS SECRETARY. 12 ASAMANNOOR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD.NO.E 1216 ASAMANNOOR P.O., ODAKKALI, ERNAKULAM DISTRICT, PIN - 683 549, REPRESENTED BY ITS HON. SECRETARY. 13 KOLENCHERY RURAL CO-OPERATIVE BANK LTD.NO.E 1072 KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311, REPRESENTED BY ITS SECRETARY. 14 KUNNATHUNAD AIDED SCHOOL STAFF CO-OPERATIVE SOCIETY LTD.NO.1090 KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311, REPRESENTED BY ITS SECRETARY. 15 KUNJITHAI SERVICE CO-OPERATIVE BANK LTD.NO.1937 KUNJITHAI P.O., N.PARAVUR, ERNAKULAM DISTRICT, PIN - 683 522, REPRESENTED BY ITS SECRETARY IN CHARGE. 16 KOLENCHERY MEGHALA MERCANTILE WELFARE CO-OPERATIVE SOCIETY LTD. NO.E 1343, KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311, REPRESENTED BY ITS SECRETARY. 17 EDAKOCHI SERVICE CO-OPERATIVE BANK LTD.NO.116 EDAKOCHI P.O., KOCHI, ERNAKULAM DISTRICT, PIN - 682 2025:KER W.P(C)No.7053/2023 & Connected cases 336 010, REPRESENTED BY ITS SECRETARY. 18 KOLENCHERRY AREA PRAVASI CO-OPERATIVE SOCIETY LTD. NO.E 1421 PERINGALA P.O., PERINGALA, ERNAKULAM DISTRICT, PIN - 683 565, REPRESENTED BY ITS SECRETARY. 19 PALLURUTHY MANDALAM SERVICE CO-OPERATIVE BANK LTD.NO.65 PALLURUTHY P.O., KOCHI, ERNAKULAM DISTRICT, PIN - 682 006, REPRESENTED BY ITS SECRETARY. 20 NELLAD AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD.NO.E 1220 NELLAD P.O., ERNAKULAM DISTRICT, PIN - 686 669, REPRESENTED BY ITS SECRETARY. 21 KUMBALANGI SERVICE CO-OPERATIVE BANK LTD.NO.762 KUMBALANGI P.O., KOCHI, ERNAKULAM DISTRICT, PIN - 682 007, REPRESENTED BY ITS SECRETARY. 22 NORTH CHELLANAM PANCHAYATH SERCVICE CO-OPERATIVE SOCIETY LTD. NO.E 871, KANNAMALY P.O., CHERIYA KADAVU, ERNAKULAM DISTRICT, PIN - 682 008, REPRESENTED BY ITS SECRETARY. 23 CHITTATTUKARA PANCHAYATH SERVICE CO-OPERATIVE BANK LTD. NO.1443, VALIYAPALLAMTHURUTH, CHENDAMANGALAM P.O., ERNAKULAM DISTRICT, PIN - 683 512, REPRESENTED BY ITS SECRETARY IN CHARGE. 24 BPCL KOCHI REFINERY EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD.NO.E 213 AKASHYA BHARAT BUILDINGS, AMBALAMUGAL P.O., ERNAKULAM DISTRICT, PIN - 682 302, REPRESENTED BY ITS HON. SECRETARY. 25 POOTHRIKKA KUCS LTD.NOL.E95 (D) APCOS, POOTHRIKKA P.O., ERNAKULAM DISTRICT, PIN - 682 308, REPRESENTED BY ITS SECRETARY. 26 THE THURUTHIPURAM SERVICE CO-OPERATIVE BANK LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 337 NO.E 1789, THURUTHIPURAM P.O., ERNAKULAM DISTRICT, PIN - 680 667, REPRESENTED BY ITS PRESIDENT. 27 MALANKARA ORTHODOX SYRIAN CHURCH MEDICAL COLLEGE EMPLOYEES CO-OPERATIVE SOCIETY LTD.NO.E 1136, KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311, REPRESENTED BY ITS PRESIDENT. 28 KEL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD.NO.E 777 MAMALA P.O., THIRUVANKULAM, ERNAKULAM DISTRICT, PIN - 682 305, REPRESENTED BY ITS PRESIDENT. 29 KOLENCHERY AREA VYAPARI VYAVASAI WELFARE CO-OPERATIVE SOCIETY LTD.NO.E 1352 SAMITHI BUILDINGS, KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311, REPRESENTED BY ITS SECRETARY. 30 ST.PETER'S COLLEGE STAFF CO-OPERATIVE SOCIETY LTD. NO.E 705, KOLENCHERY P.O., ERNAKULAM DISTRICT, PIN - 682 311, REPRESENTED BY ITS SECRETARY. 31 SYNTHITE EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.E 1120, KADAYIRUPPU P.O., ERNAKULAM DISTRICT, PIN - 682 311, REPRESENTED BY ITS SECRETARY. 32 PARUR CO-OPERATIVE BANK LTD.NO.1759 NORTH PARUR P.O., ST.GERMAN'S ROAD, ERNAKULAM DISTRICT, PIN- 683 513, REPRESENTED BY ITS SECRETARY. 33 KADUNGALLOORE SERVICE CO-OPERATIVE BANK LTD.NO.2165 EAST KADUNGALLOOR P.O., ERNAKULAM DISTRICT, PIN - 682 102, REPRESENTED BY ITS SECRETARY. 34 TELK EMPLOYEES MULTI PURPOSE CO-OPERATIVE SOCIETY LTD.NO.E 291 ANGAMALY SOUTH P.O., ERNAKULAM DISTRICT, PIN - 683 573, REPRESENTED BY ITS SECRETARY. 35 KAMCO EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LTD.NO.E 335 ATHANI P.O., ALUVA, ERNAKULAM DISTRICT, PIN - 683 585, REPRESENTED BY ITS SECRETARY. 2025:KER W.P(C)No.7053/2023 & Connected cases 338 36 AKAPARAMBU SERVICE CO-OPERATIVE SOCIETY LTD.NO.E 943 MAIKAVE, VAPPALASSERY P.O., ERNAKULAM DISTRICT, PIN- 683 572, REPRESENTED BY ITS SECRETARY IN CHARGE. 37 THE ERNAKULAM DISTRICT CO-OPERATIVE BANK EMPLOYEES CO-OPERATIVE SOCIETY LTD.NO.E 166 TRANSVENUE APARTMENT , NEAR POST OFFICE, KAKKANAD, ERNAKULAM DISTRICT, PIN - 682 030, REPRESENTED BY ITS SECRETARY. 38 THE CENTRAL SERVICES CO-OPERATIVE SOCIETY LTD.NO.E 223 MANIKKATH ROAD, RAVIPURAM, KOCHI, PIN - 682 316, REPRESENTED BY ITS SECRETARY. 39 ALLAPRA AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD.E 1389 ALLAPRA P.O. - 683 556, ERNAKULAM DISTRICT, REPRESENTED BY ITS PRESIDENT. 40 MULANTHURUTHY RURAL CO-OPERATIVE BANK LTD.E 1336 MULANTHURUTHY P.O., HOSPITAL JUNCTION, ERNAKULAM, PIN - 682 314, REPRESENTED BY ITS SECRETARY. 41 MALANKARA EMPLOYEES CO-OPERATIVE SOCIETY LTD.NO.E 1166 PUTHENCRUZ P.O., ERNAKULAM DISTRICT, PIN - 628 308, REPRESENTED BY ITS SECRETARY. 42 MANEED PANCHAYATH GRAMEENA CO-OPERATIVE SOCIETY LTD. NO.E 1358, EZHAKKARANAD, EZHAKKARANAD P.O., PUTHENCRUZ (VIA), PIN - 628 308, REPRESENTED BY ITS HON. SECRETARY. 43 THURAVOOR GRAMEENA SERVICE CO-OPERATIVE SOCIETY LTD. NO.E 1392, THURAVOOR P.O., ERNAKULAM DISTRICT, PIN - 683 572, REPRESENTED BY ITS PRESIDENT. BY ADVS. SRI.M.M.MONAYE SHRI.M.PAUL VARGHESE SRI.K.V.SANOSH 2025:KER W.P(C)No.7053/2023 & Connected cases 339 SMT.NIRMALA P.V. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI, PIN - 110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI - 110 001. 3 COMMISSIONER OF INCOME TAX (TDS) C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM - 682 018. 4 STATE OF KERALA DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT, REPRESENTED BY SECRETARY TO GOVERNMENT, THIRUVANANTHAPURAM - 695 011. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM - 695 001. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, THIRUVANANTHAPURAM - 695 033. 7 DEPUTY GENERAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD., CREDIT PROCESSING CENTRE, KAKKANAD, KOCHI - 682 030. BY ADVS. SHRI.JAGADEESH LAKSHMAN, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 340 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 341 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11654 OF 2022 PETITIONER/S: KARUVANTHIRUTHY SERVICE CO-OPERATIVE BANK NO.D 2638, KARUVANTHIRUTHY P.O., FEROKE, KOZHIKODE- 673 631, REPRESENTED BY ITS SECRETARY-KHALID SHAMEEM.K. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THECOMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI-682 018 3 THE INCOME TAX OFFICER (TDS), AYAKKAR BHAVAN, MANANCHIRA, KOZHIKODE-673 001-678001 4 THE KERALA STATE CO-OPERATIVE BANK LTD., (ERSTWHILE KOZHIKODE DISTRICT CO-OPERATIVE BANK), ALI ROAD, COLOMBO BUILDING, KOZHIKODE-678 002 2025:KER W.P(C)No.7053/2023 & Connected cases 342 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 343 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11683 OF 2022 PETITIONER/S: NEDUPUZHA SERVICE CO-OPERATIVE BANK LTD NO.555 NEDUPUZHA P.O., THRISSUR-680 007 REPRESENTED BY ITS SECRETARY IN CHARGE. BY ADV SRI.S.SHYAM KUMAR RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY,DEPARTMENT OF REVENUE,MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH BLOCK ,NEW DELHI-110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH BLOCK,NEW DELHI -110001,REPRESENTED BY ITS CHAIRMAN 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA,CENTRAL REVENUE BUILDINGS,IS PRESS ROAD,COCHIN -682018 4 INCOME TAX OFFICER(TDS) OFFICE OF THE INCOME TAX OFFICE(TDS),AAYAKAR BHAVAN,SAKTHAN THAMPURAN NAGAR,THRISSUR-680 001 5 THE KERALA STATE CO-OPERATIVE BANK LTD,P.B.NO.6515 CO-BANK TOWERS,PALAYAM,THIRUVANATHAPURAM- 2025:KER W.P(C)No.7053/2023 & Connected cases 344 695033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 6 STATE OF KERALA-REPRESENTED BY ITS SECRETARY DEPARTMENT OF CO- OPERATION,SECRETARIAT,THIRUVANANTHAPURAM-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 345 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11679 OF 2022 PETITIONER/S: COCHIN NAVAL BASE CIVILIAN EMPLOYEES CO-OPERATIVE SOCIETY LTD N O 4146, COCHIN-682 004, ERNAKULAM, REPRESENTED BY ITS SECRETAY-IN-CHARGE BY ADV SRI.S.SHYAM KUMAR RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110 001 2 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 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, COCHIN-682 018 4 INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICE (TDS) AAYAKAR BHAVAN, SAKATHAN THAMPURAN NAGAR, THRISSUR-680 001 5 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, 2025:KER W.P(C)No.7053/2023 & Connected cases 346 CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033. REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO- OPERATION, SECRETARIAT, THIRUVANANTHAPURAM-695 001 BY ADVS. SHRI.S.VAIDYANATHAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 347 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11684 OF 2022 PETITIONER/S: COCHIN CITY SERVICE CO-OPERATIVE BANK LTD. NO. E-1101 CHITTOOR ROAD,AYYAPPANKAVU,KOCHI-18,REPRESENTED BY ITS SECRETARY BY ADV SRI.S.SHYAM KUMAR RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY,DEPARTMENT OF REVENUE,MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH BLOCK ,NEW DELHI-110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH BLOCK,NEW DELHI -110001,REPRESENTED BY ITS CHAIRMAN 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA,CENTRAL REVENUE BUILDINGS,IS PRESS ROAD,COCHIN -682018 4 INCOME TAX OFFICER(TDS) OFFICE OF THE INCOME TAX OFFICE(TDS),AAYAKAR BHAVAN,SAKTHAN THAMPURAN NAGAR,THRISSUR-680 001 5 THE KERALA STATE CO-OPERATIVE BANK LTD,P.B.NO.6515 CO-BANK TOWERS,PALAYAM,THIRUVANATHAPURAM- 2025:KER W.P(C)No.7053/2023 & Connected cases 348 695033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 6 STATE OF KERALA-REPRESENTED BY ITS SECRETARY DEPARTMENT OF CO- OPERATION,SECRETARIAT,THIRUVANANTHAPURAM-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 349 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11718 OF 2022 PETITIONER/S: THE THALORE SERVICE CO-OPERATIVE BANK LTD 1-269, THALORE, THRISSUR - 680 306, REPRESENTED BY ITS SECRETARY, T.V.SHAJIKUMAR. BY ADV SMT.MEERA V.MENON RESPONDENT/S: 1 THE COMMISSIONER OF INCOME TAX(TDS) C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM, KOCHI - 18. 2 THE INCOME TAX OFFICER WARD 2(5), AAYAKAR BHAVAN, THRISSUR - 680 001. 3 THE KERALA STATE CO-OPERATIVE BANK P.B.NO.6515, COBANK TOWERS, VIKAS BHAVAN P.O., PALAYAM, THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS BRANCH MANAGER. 4 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE (DEPARTMENT OF REVENUE), NORTH BLOCK, NEW DELHI - 110 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 350 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 351 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11721 OF 2022 PETITIONER/S: THRIKKARUVA PANCHAYAT RESIDENCE WELFARE CO-OPERATIVE SOCIETY LTD.NO.Q 1547, NO. Q 1547 SECRETARY -IN-CHARGE, KANJAVELY P O, KOLLAM DISTRICT- 691602. BY ADVS. SHRI.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, PIN-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, 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, PIN-110001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES 2025:KER W.P(C)No.7053/2023 & Connected cases 352 THIRUVANANTHAPURAM, PIN-695001. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695001. 6 THE KERALA STATE CO-OPERATIVE BANK REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P B NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695033. BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 353 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11728 OF 2022 PETITIONER/S: ATTINGAL PRAVASI KSHEMA VIKASANA SAHAKARANA SANGAM LTD NO.T 2166 REPRESENTED BY ITS SECRETARY, PALAKUNNU, , CHIRAYINKEEZHU, THIRUVANANTHAPURAM DISTRICT, PIN- 695304. BY ADVS. SHRI.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, PIN-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, 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, PIN-110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 354 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES THIRUVANANTHAPURAM, PIN-695001. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695001. 6 THE KERALA STATE CO-OPERATIVE BANK REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P B NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695033. BY ADVS. SMT.M.S.KIRAN SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 355 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11727 OF 2022 PETITIONER/S: ARIMPUR PANCHAYAT KARSHIKETHARA CO-OPERATIVE SOCIETY LTD NO.R 1273 P.O.VELUTHUR, THRISSUR, -680 012, REPRESENTED BY ITS SECRETARY BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM- 682 018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680 001 4 THE KERALA STATE CO-OPERATIVE BANK LTD, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS MANAGING DIRECTOR BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 356 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 357 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11740 OF 2022 PETITIONER/S: 1 THE AYYAPANCOVIL SERVICE CO-OPERATIVE BANK LTD.NO.3558 REPRESENTED BY ITS SECRETARY, JOJOMON JOSE, S/O. JOSE, AGED 40 YEARS, HEAD OFFICE, AYYAPPANCOIL P.O, IDUKKI 685 510 2 THE NEDUMKANDAM URBAN CO-OPERATIVE SOCIETY LTD NO 1- 104 REPRESENTED BY ITS SECRETARY , JOSEPH THOMAS, AGED 50 YEARS, S/O. THOMAS, HEAD OFFICE, NEDUMKANDAM P.O, IDUKKI 685 553 BY ADVS. SRI.GEORGE MATHEW SHRI.PRAVEEN S. SRI.M.D.SASIKUMARAN SHRI.SUNIL KUMAR A.G SRI.DIPU JAMES SMT.ELSA DENNY PINDIS SHRI.MATHEW K.T. SHRI.GEORGE K.V. SHRI.STEPHY K REGI RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY OF FINACE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 2025:KER W.P(C)No.7053/2023 & Connected cases 358 002 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDINGS, I.S PRESS ROAD, KOCHI 682 018 3 THE INCOME TAX OFFICER TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY-8, THODUPUZHA, IDUKKI DISTRICT 685 584 4 STATE OF KERALA REPRESENTED BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001 5 REGISTRAR OF CO-OPERATIVE SOCIETIESE SOCIETIES OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM 695 014 6 THE KERALA STATE CO-OPERATIVE BANK LTD.(KERALA BANK) REPRESENTED BY ITS MANAGING DIRECTOR AND CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 7 THE DEPUTY GENERAL MANAGER CENTRAL PROCESSING CENTER, THE KERALA STATE CO- OEPRATIVE BANK LTD, (KERALA BANK) VAZHATHOPE, IDUKKI COLONY P.O, IDUKKI DISTRICT 685 602 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 359 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11738 OF 2022 PETITIONER/S: 1 EDAVANAKAD AYYAMPILLY FISHERMEN DEVELOPMENT WELFARE CO-OPERATIVE SOCIETY (E) 7/87/CZ, KUZHUPILLY, AYYAMPILLY P.O. - 682 501. 2 PAZHANGAD FISHERMEN DEVELOPMENT WELFARE CO-OPERATIVE SOCIETY (E) 118/92, EDAVANAKKAD P.O. - 682 502. 3 CHERAI MUNAMBAM MATSYATHOZHILALI VIKASANA KSHEMA SAHAKARANA SANGHAM F(E) 6/87/CZ, CHERAI - 683 514. BY ADVS. SHRI.AJI V.DEV SRI.ALAN PRIYADARSHI DEV RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 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. 2025:KER W.P(C)No.7053/2023 & Connected cases 360 3 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. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, VIKAS BHAVAN, PALAYAM, THIRUVANANTHAPURAM - 695 033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 361 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11765 OF 2022 PETITIONER/S: 1 THE KASARGOD MERCHANTS CO-OPERATIVE SOCIETY LTD .NO. S.113, VYAPARA BHAVAN, M.G.ROAD, KASARAGOD-671121, REPRESENTED BY ITS SECRETARY KISHOR KUMAR M. 2 AJANUR URBAN SERVICE CO-OPERATIVE SOCIETY LTD. NO.S.322, ATHINHAL, MANIKOTH P.O., KANHANGAD, KASARAGOD-671316, REPRESENTED BY ITS SECRETARY SAVITHIRI K.V. 3 NILESHWAR RANGE KALLU CHETHU VYAVASAYA THOZHILALI CO- OPERATIVE SOCIETY LTD. NO.S.309, NILESHWAR P.O., KASARAGOD -671314, REPRESENTED BY ITS SECRETARY SANTHOSH C. 4 KONNAKADU VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S.289, KONNAKADU P.O., KASARAGOD-671534, REPRESENTED BY ITS SECRTARY G.CHITHARA LEKHA. 5 MALOM VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S.288, MALOM, DARKAS P.O., VELLARIKUNDU, KASARAGOD -671533, REPRESENTED BY ITS SECRETARY SUMATHY K. 6 THE MADIKAI PANCHAYATH VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S.291, POOTHAKKAL, ACHIKANAM P.O., KASARAGOD-671531, REPRESENTED BY ITS SECRETARY RAJANI C. 7 HOSDURG VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 362 NO.S.240, HOSDURG, KANHANGAD P.O., KASARAGOD -671315, REPRESENTED BY ITS SECRETARY JAYASREE K. 8 THE KASARAGOD AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY LTD. NO.S.415, SREERAM ARCADE, ICB ROAD, KASARAGOD -671121, REPRESENTED BY ITS SECRETARY SAJESH KUMAR K.V. 9 KUMBLA GENERAL WORKERS WELFARE CO-OPERATIVE SOCIETY LTD. NO. S.426, KUMBLA P.O., KASARAGOD-671321, REPRESENTED BY ITS SECRETARY ANIL KUMAR T. 10 MALAYORA MEKHALA VANITHA CO-OPERATIVE SOCIETY LTD. NO.S.363, CHITTARIKKAL P.O., KASARAGOD-671326, REPRESENTED BY ITS SECRETARY VIJANI E.P. 11 KASARAGOD DISTRICT CO-OPERATIVE HOSPITAL SOCIETY LTD. NO.S.42, KUMBLA P.O., KASARAGOD-671321, REPRESENTED BY ITS SECRETARY RATHNAKARA G. 12 HOSDURG RANGE KALLU CHETHU THOZHILALI VYAVASALA SAHAKARANA SANGHAM LTD. NO.S.310, KUNNUMMAL, KANHANGAD P.O., KASARAGOD-671315, REPRESENTED BY ITS SECRETARY USHA P.V. 13 THE PARAPPA VANITHA CO-OPERATIVE SOCIETY LTD. NO.S.368, PARAPPA P.O., KASARAGOD -671533, REPRESENTED BY ITS SECRETARY SUJITHA P. 14 THE KOTACHERY CO-OPERATIVE MARKETING SOCIETY LTD. NO.L.354, KANHANGAD P.O., KASARAGOD -671315, REPRESENTED BY ITS SECRETARY LATHA M. 15 KALPETTA ZONE LABOUR CONTRACT CO-OPERATIVE SOCIETY LTD. NO.W.209, KALPETTA P.O., WAYANAD-673121, REPRESENTED BY ITS SECRETARY NITHIN SUNNY. 2025:KER W.P(C)No.7053/2023 & Connected cases 363 16 THE WAYANAD DISTRICT POLICE CO-OPERATIVE SOCIETY LTD. NO.W.208, KALPETTA NORTH P.O., WAYANAD-673122, REPRESENTED BY ITS SECRETARY RAJANI K.K. 17 VILAPPIL CO-OPERATIVE RURAL DEVELOPMENT SOCIETY LTD. NO.T.1494, PEYAD P.O., THIRUVANANTHAPURAM-695573, REPRESENTED BY ITS SECRETARY BINDUMOL C.G. 18 KARAVARAM VILLAGE RESIDENCE WELFARE CO-OPERATIVE SOCIETY LTD. NO.T.1940, THOTTAKKAD, KARAVARAM P.O., THIRUVANANTHAPURAM- 695605, REPRESENTED BY ITS SECRETARY P.JAYESH. 19 CHEPPAD SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD.NO.A 1207, KANJOOR, CHEPPAD P.O., ALAPPUZHA-690507, REPRESENTED BY ITS SECRETARY V.GOPALAN NAIR. 20 ANGAMALY MERCANTILE CO-OPERATIVE SOCIETY LTD. NO.E.1203, ANGAMALY P.O., ERNAKULAM-683572, REPRESENTED BY ITS SECRETARY REMYA P.R. 21 KOTHAMANGALAM TALUK MALSYA VYAPARA VITHARANA THOZHILALY CO-OPERATIVE SOCIETY LTD.NO.E.1154, KOTHAMANGALAM P.O., ERNAKULAM-686691, REPRESENTED BY ITS SECRETARY ELDHOSE P.K. 22 KOTHAMANGALAM VYAPARI VYAVASAYI CO-OPERATIVE SOCIETY LTD.NO.E.1240, KOTHAMANGALAM, ERNAKULAM-686691, REPRESENTED BY ITS SECRETARY CHANDRABOSE K.P. 23 KOTHAMANGALAM HOUSING CO-OPERATIVE SOCIETY LTD. NO.E.314, KOTHAMANGALAM P.O., ERNAKULAM-686691, REPRESENTED BY ITS SECRETARY ELDHO JOSEPH. 24 VADATTUPARA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.I.356, VADATTUPARA P.O., ERNAKULAM-686694, REPRESENTED BY ITS SECRETARY STELLA ANTONY. 2025:KER W.P(C)No.7053/2023 & Connected cases 364 25 THE PALAKKAD TALUK CO-OPERATIVE EMPLOYEES' AND CO- OPERATIVE PENSIONER'S CO-OPERATIVE HOUSING SOCIETY LTD. NO.P.1435, PALAYAPPETTA, PALAKKAD- 678001, REPRESENTED BY ITS SECRETARY K.NITHYANANDAN. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. 2025:KER W.P(C)No.7053/2023 & Connected cases 365 BY ADVS. SHRI.SHYAMDEEP S.SHENOY, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 366 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11760 OF 2022 PETITIONER/S: 1 THALASSERY CO-OPERATIVE RURAL BANK LTD., NO.F. 1263, THALASSERY P.O, KANNUR - 670103, REPRESENTED BY ITS MANAGER IN CHARGE C.M. SANTHOSHKUMAR. 2 KOOTTUMUGHAM SERVICE CO-OPERATIVE BANK LTD NO. C. 72, KOOTTUMUGHAM, SREEKANDAPURAM, KANNUR - 670631, REPRESENTED BY ITS SECRETARY P P V PRADEEPAN, 3 KOLLAKKAD SERVICE CO-OPERATIVE BANK LTD, NO. C.277, KOLAKKAD P.O, PERAVOOR, KANNUR - 670673, REPRESENTED BY ITS SECRETARY LAJINA M.V. 4 KOLAYAD SERVICE CO-OPERATIVE BANK LTD, NO. F.1088, KOLAYAD P.O, KANNUR - 670650, REPRESENTED BY ITS SECRETARY, A.J. JESSY. 5 PERALAM SERVICE CO-OPERATIVE BANK LTD NO. L.L.63, KOZHUMMAL P.O, KANNUR - 670522, REPRESENTED BY ITS SECRETARY, KRISHNAN K.M. 6 THE NALLEPILLY SERVICE CO-OEPRATIVE BANK LTD NO. R.43, NALLEPILLY P.O, PALAKKAD - 678553, REPRESENTED BY ITS SECRETARY SUMESH K.S. 7 ARAYOOR SERVICE CO-OPERATIVE BANK LTD, NO. 692, NEYYATTINKARA, ARAYOOR P.O, THIRUVANANTHAPURAM - 695122, REPRESENTED BY ITS SECRETARY MARY VALSA P. 2025:KER W.P(C)No.7053/2023 & Connected cases 367 BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, KOCHI- 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB.NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695001. BY ADVS. SHRI.SHYAMDEEP S.SHENOY, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN 2025:KER W.P(C)No.7053/2023 & Connected cases 368 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 369 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11766 OF 2022 PETITIONER/S: 1 THE PATTAMBI GOVT EMPLOYEES CO OPERATIVE SOCIETY LTD. NO.P.614, PATTAMBI P.O., PALAKKAD-679303, REPRESENTED BY ITS SECRETARY AJAYAKUMAR U. 2 PALAKKAD DISTRICT KERALA WATER AUTHRITY EMPLOYEES CO- OPERATIVE SOCIETY LTD. NO.P.1095, KALAMANDAPAM P.O., PALAKKAD-678001, REPRESENTED BY ITS SECRETARY RAVINDRAN K. 3 THIRUVAZHIYAD-KAIRADY CO-OPERATIVE CREDIT SOCIETY LTD. NO.P.508, ADIPPERANDA, KAIRADY P.O., PALAKKAD-678510, REPRESENTED BY ITS SECRETARY PRASAD C.G. 4 SREEKRISHNAPURAM BHAVAN NIRMANA SAHAKARANA SANGAM LTD. NO.P.814, CHANTHAPPURA P.O., SREEKRISHNAPURAM, PALAKKAD-679513, REPRESENTED BY ITS SECRETARY MURALI MOHAN. 5 POSTAL, TELEGAM, BSNL EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.1940, THIRUVANANTHAPURAM, THIRUVANANTHAPURAM-695001, REPRESENTED BY ITS SECRETARY SANDHYA RANI V.A. 6 THE PALAKKAD DISTRICT POSTAL, TELECOM AND BSNL EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.P.638, KARALA STREET, KOPPAM, PALAKKAD-678001. 7 VILAPPIL COMMERCIAL DEVELOPMENT CO-OPERATIVE SOCIETY LTD. NO.T.1825, 2025:KER W.P(C)No.7053/2023 & Connected cases 370 PULIYARAKONAM P.O., THIRUVANANTHAPURAM-695573, REPRESENTED BY ITS SECRETARY AJITHA J.P. 8 VILAPPIL PANCHAYATH PRIMARY AGRICULTURAL CREDIT CO- OPERATIVE SOCIETY LTD. NO.T.1624, VILAPPILSALA P.O., THIRUVANANTHAPURAM-695573, REPRESENTED BY ITS SECRETARY SURESH KUMAR S. 9 KUNNATHUNAD TALUK KARSHAKA KSHEMA ULPANNA VIPANANA CO-OPERATIVE SOCIETY LTD. NO.E 1312, VALAYANCHIRANAGAR P.O., PERUMBAVOOR, ERNAKULAM- 683556, REPRESENTED BY ITS SECRETARY M.P.ELDHO. 10 KATTAKADA AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD. NO.T 1543, KATTAKADA P.O., THIRUVANANTHAPURAM-695572, REPRESENTED BY ITS SECRETARY GAYATHRI G. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, 2025:KER W.P(C)No.7053/2023 & Connected cases 371 KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. SHRI.SHYAMDEEP S.SHENOY, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 372 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11768 OF 2022 PETITIONER/S: 1 THE CHANGANASSERY PRIVATE SECONDARY SCHOOL STAFF CO- OPERATIVE SOCIETY LTD NO K.411, CHENGANASSERY, KOTTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 2 THE CHANGANASSERY TALUK VYAPARI VYAVASAI CO-OPERATIVE SOCIETY LTD NO K 994, CHENGANASSERY, KOTTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 3 THE PUZHAVATHU SERVICE CO-OPERATIVE BANK LTD NO 62, PUZHAVTHY, CHENGANASSERY, KOTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY. 4 THE CHANGANASSERY NORTH SERVICE CO-OPERATIVE BANK LTD NO 3489, CHENGANASSERY, KOTTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 5 THE MULAKULAM PANCHYATH SERVICE CO-OPERATIVE BANK LTD NO K 209, PERUVA, KOTTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY 6 THE VELLOOR SERVICE CO-OPERATIVE BANK LTD NO 785, VELLOOR P.O , KOTTTAYAM DISTRICT, REPRESENTED BY ITS SECRETARY BY ADV SRI.O.D.SIVADAS 2025:KER W.P(C)No.7053/2023 & Connected cases 373 RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN -682 018. 3 THE INCOME TAX OFFICER (TDS), INCOME TAX DEPARTMENT, KOTTAYAM, PIN-686 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 374 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11772 OF 2022 PETITIONER/S: TVM DISTRICT I.T.I EMPLOYEES CO-OPERATIVE SOCIETY LTD NO T 303, . REPRESENTED BY ITS SECRETARY, CHACKAI, THIRUVANANTHAPURAM DISTRICT, PIN-695 007 BY ADVS. SHRI.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 111RD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.THIRUVANANTHAPURAM, PIN-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, PIN-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 PIN-110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, 2025:KER W.P(C)No.7053/2023 & Connected cases 375 THIRUVANANTHAPURAM, PIN-695 001. 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695 001 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033. BY ADVS. SHRI.S.VAIDYANATHAN, CGC SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 376 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11776 OF 2022 PETITIONER/S: ANDOORKONAM SERVICE CO-OPERATIVE BANK LTD.NO.3127, REPRESENTED BY ITS SECRETARY, KEEZHAVOOR P.O, THIRUVANANTHAPURAM DISTRICT 695 584. BY ADVS. SHRI.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 , PIN 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 , PIN 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 , PIN 110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, 2025:KER W.P(C)No.7053/2023 & Connected cases 377 THIRUVANANTHAPURAM , PIN 695 001. 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN 695 001 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO. 6515, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695 033. BY ADVS. SHRI.S.VAIDYANATHAN, CGC SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 378 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11780 OF 2022 PETITIONER/S: PALLIPURAM KSHEEROLPADAKA CO-OPERATIVE SOCIETY LTD. NO.E 36, CHERAI, ERNAKULAM - 683 514 REPRESENTED BY ITS SECRETARY SRI.JEEMON LAZAR. BY ADVS. SHRI.AJI V.DEV SRI.ALAN PRIYADARSHI DEV RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 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 CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001 , REPRESENTED BY ITS CHAIRMAN. 4 THE KERALA STATE CO OPERATIVE BANK LTD. COBANK TOWERS, VIKAS BHAVAN, PALAYAM, 2025:KER W.P(C)No.7053/2023 & Connected cases 379 THIRUVANANTHAPURAM - 695 033. BY ADVS. SHRI.K.R.RAJKUMAR, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 380 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11781 OF 2022 PETITIONER/S: 1 THE KASARAGOD GENERAL WORKERS CO-OPERATIVE SOCIETY LTD.NO. S. 59, DINESH BHAVAN, NAYAKS ROAD, KASARGOD -671 121, REPRESENTED BY ITS SECRETARY VARATHA RAJAN K. 2 RURAL AGRICULTURAL CO-OPERATIVE SOCIETY LTD. NO. 354, KALIKADAVU P.O. PILICODE, KASARAGOD 671 310, REPRESENTED BY ITS SECRETARY BABY P.K. 3 THE HOSDURG TALUK MERCHANTILE CO OPERATIVE SOCIETY LTD. NOS. S. 286, NILESHWAR P.O, KASARAGOD 671 314, REPRESENTED BY ITS SECRETARY V.V. JANAKI 4 THE KUMBLA AGRICULTURAL TOURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 389, MADHAVA PAI COMPLEX, BADIADUKA ROAD, KUMBALA, KASARAGOD 671 321, REPRESENTED BY ITS SECRETARY, K.JAYAKUMAR. 5 THAYYAL THOZHILALI KSHEMA SAHAKARANA SANGAM LTD. NO. S. 49, KANHANGAD, KOVVALPALLY, KANHANGAD P.O, KASARGOD 671 315, REPRESENTED BY ITS SECRETARY SREEJA K. 6 THE UDMA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 284, UDMA P.O, UDMA, KASARAGOD 671 319, REPRESENTED BY ITS SECRETARY KAIRALI B. 2025:KER W.P(C)No.7053/2023 & Connected cases 381 7 CHERUVATHUR MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD. NO. S. 343, VYAPARA BHAVAN, CHERUVATHUR P.O, KASARAGOD 671 313, REPRESENTED BY ITS SECRETARY KAIRALI M.K. 8 PANATHADY PANCHAYATH FARMERS WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 483, PANATHUR P.O, KASARAGOD 671 532, REPRESENTED BY ITS SECRETARY KAVITHA T.G. 9 THE KASARAGOD MERCANTILE CO-OPERATIVE SOCIETY LTD. NO. S 287, MALABAR SQUARE BUILDING, NEW BUS STAND, KASARAGOD 671 121, REPRESENTED BY ITS SECRETARY KUNHIRAMAN AC. 0 MALANAD RUBBER AND OTHER AGRICULTURAL MARKETING AND PROCESSING CO-OPERATIVE SOCIETY LTD. NO. S 254, MALAKKALLU P.O, KASARAGOD 671 532, REPRESENTED BY ITS SECRETARY, SURESHKUMAR M. 11 MANJESHWAR BLOCK AGRICULTURAL IMPORVEMENT CO- OPERATIVE SOCIETY LTD. NO. S 361, UPPALA KAMAAL COMPLEX, R.S. ROAD, UPPALA P.O, KASARAGOD 671 322, REPRESENTED BY ITS SECRETARY RAGHAVAN B. 12 KUNDAMKUZHY VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S.404, KUNDAMKUZHY P.O, CHENGALA VIA, KASARAGOD 671 541, REPRESENTED BY ITS SECRETARY SMITHAMMA VIJAYAN. 13 THE CHERUVATHUR AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 406, KUTTAMATH NAGAR, CHERUVATHUR P.O, KASARGOD 671 313, REPRESENTED BY ITS SECRETARY BABU T 14 THE CHITTARIKKAL PRIMARY AGRICULTURIST WELFARE CO- OPERATIVE SOCIETY LTD. NO. S. 381, CHITTARIKKAL P.O, KASARGOD 671 326, REPRESENTED BY ITS SECRETARY TO T.G. PRADEEP KUMAR. 15 THE WEST ELERI VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S. 292, ELERITHATTU P.O, KASARAGOD 671 314, REPRESENTED BY 2025:KER W.P(C)No.7053/2023 & Connected cases 382 ITS SECRETARY, P.K. LATHA. 16 THE MADHUR AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO. S. 398, ULIYATHADKA P.O, MADHUR, KASARAGOD 671 124, REPRESENTED BY ITS SECRETARY RAJASHREE M.B 17 KASARAGOD DISTRICT CONTRACTORS CO-OPERATIVE SOCIETY LTD. NO. S 304, JAZEEL CCENTRE, PUTHIYAKOTTA, HOSDURG, KANHANGAD, KASARAGOD 671 315. 18 THE PALLIKERE CO-OPERATIVE CONSUMERS WELFARE SOCIETY LTD.NO. L 485, PALLIKERE P.O, KASARAGOD 671316, REPRESENTED BY ITS SECRETARY INDIRA A. 19 KAYYOOR- CHEEMENI GRAMA PANCHAYATH, VIVIDHODHESHA VANITHA SAHAKARANA SANGHAM LTD. S275, CHEEMENI P.O, KASARAGOD- 671 313, REPRESENTED BY ITS SECRETARY SATHI P.V. 20 THE BEEMANADY VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 321, BEEANADI P.O, KASARAGOD 671 314, REPRESENTED BY ITS SECRETARY JAINY THOMAS 21 KASARAGOD DISTRICT CONSTRUCTION WORKERS WELFARE CO- OPERATIVE SOCIETY LTD NO. S 488, NILESHWAR P.O, KASARGOD 671 314,REPRESENTED BY ITS SECRETARY SUSHAMA K.V, 22 THE KASARAGOD DISTRICT CO-OPERATIVE EMPLOYEES WELFARE CO-OPERATIVE SOCIETY LTD. NO. S. 411, MELANGOT, KANHANGAD, KASARAGOD 671 315, REPRESENTED BY ITS SECRETARY JAYAKALA K. 23 THE HOSDURG TALUK BUS OPERATOR'S CO-OPERATIVE SOCIETY LTD. NO. S 371, DILSHAD BUILDING, KANHANGAD P.O, KASARAGOD 671 315, REPRESENTED BY ITS SECRETARY, SOUMYA N. 24 THE NILESWARAM PRAVASI KSHEMA SAHAKARANA SANGAM LTD. NO. S 544, 2025:KER W.P(C)No.7053/2023 & Connected cases 383 KOTTUMPURAM, NILESWAR P.O, KASARAGOD 671 314, REPRESENTED BY ITS SECRETARY GEETHA K. 25 THE KANHANGAD AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO. S. 382, CHEDI ROAD, UPPILIKAI P.O, KASARAGOD 671 314, REPRESENTED BY ITS SECRETARY, PRASANNAKUMARI P. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. P.B. NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001 2025:KER W.P(C)No.7053/2023 & Connected cases 384 BY ADVS. SHRI.PRAVEEN K.V., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 385 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11783 OF 2022 PETITIONER/S: THE GENERAL INSURANCE EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.E 627, SITHRAM COMPLEX, 2ND FLOOR, CHITTOR ROAD, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK , RAISANA HILL, NEW DELHI - 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, SHAKTHAN NAGAR, THRISSUR, PIN - 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 5 THE MANAGER KERALA STATE CO-OPERATIVE BANK LTD., ERNAKULAM SOUTH BRANCH, PIN - 682 016. 2025:KER W.P(C)No.7053/2023 & Connected cases 386 BY ADVS. SHRI.T.V.VINU, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 387 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11915 OF 2022 PETITIONER/S: 1 MALLAPPALLY SERVICE CO-OPERATIVE BANK LTD. KEEZHVAIPUR P.O.689 587 REPRESENTED BY ITS SECRETARY, MADHULAL P. 2 KILIYANTHARA SERVICE CO OPERATIVE BANK LTD, P.O.IRITTY, KANNUR-670 703, REPRESENTED BY ITS SECRETARY, N ASHOKAN 3 KOLACHERI SERVICE C OPERATIVE BANK LTD, P O CHELERI, KANANUR-670 604, REPRESENTED BY ITS SECRETARY, BHASKARAN K 4 KANNAVAM SERVICE CO OPERATIVE BANK LTD, KANNAVAM P.O.KANNOTH, KANNUR-670 650, REPRESENTED BY ITS SECRETARY CHANDRAN KALATHIL 5 MAMALAKANDAM SERVICE CO OPERATIVE BANK LTD 1-225, MAMALAKANDAM P.O.ERNAKULAM-686 681, REPRESENTED BY ITS SECRETARY IN CHARGE JOMON K.J. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 388 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE , MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 389 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11784 OF 2022 PETITIONER/S: SPACE CENTRE EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO. T 1388 REPRESENTED BY ITS SECRETARY - IN - CHARGE, ISRO POST, THIRUVANANTHAPURAM DISTRICT, PIN - 695022. BY ADVS. SHRI.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 - 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, NEW DELHI - PIN - 110001. 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 390 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM - PIN - 695001. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - PIN - 695001. 6 THE KERALA STATE CO-OPERATIVE BANK. REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - PIN - 695033. BY ADVS. SRI.NAVANEETH.N.NATH SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 391 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11791 OF 2022 PETITIONER/S: 1 THE CHENDAMANGALAM HANDLOOM WEAVER'S CO-OPERATIVE SOCIETY LTD. NO. H 47 CHENDAMANGALAM, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 683511. 2 THE CHERAI HANDLOOM WEAVERS CO-OPERATIVE SOCIETY LIMITED NO. 648, CHERAI, ERNAKULAM DISTRICT, REPRESENTED BY TIS SECRETARY, PIN - 683514. 3 THE CHENDAMANGALAM KARIMPADAM HANDLOOM WEAVER'S CO- OPERATIVE SOCIETY LIMITED, NO. H. 191, CHENDAMANGALAM, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 683511. 4 THE CHENDAMANGALAM HANDLOOM WEAVERS' CO-OPERATIVE YARN SOCIETY LIMITED NO. H.115, CHENDAMANGALAM, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 683511. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) 2025:KER W.P(C)No.7053/2023 & Connected cases 392 CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN - 682018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, ERNAKULAM, PIN - 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033. 5 THE MANAGER KERALA STATE CO-OPERATIVE BANK LTD, NORTH PARUR MAIN BRANCH, ERNAKULAM, PIN - 683513. BY ADVS. SHRI.T.V.VINU, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 393 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11792 OF 2022 PETITIONER/S: 1 THRITHALA BLOCK CO-OPERATIVE URBAN CREDIT SOCIETY.LTD.NO.P.1206, CHALISSERY P.O., PALAKKAD DISTRICT, PIN CODE-679 536, REPRESENTED BY ITS SECRETARY, SMT. USHA.V.V. 2 TRITHALA EDUCATIONAL SUB DISTRICT AIDED SCHOOL- EMPLOYEES CO OPERATIVE SOCIETY LTD. NO.P 1307, KOOTTANAD P.O., PALAKKAD DISTRICT, PIN CODE-679 533, REPRESENTED BY ITS SECRETARY, SMT.TUSHARA SANKAR. 3 ANAKKARA MERCANTILE CO OPERATIVE SOCIETY LTD. NO.1365, KUMBIDI P.O., PALAKKAD DISTRICT, PIN CODE-679 553, REPRESENTED BY ITS SECRETARY, SHRI.SAJI.T.K. 4 OTTAPALAM TALUK PRAVASI WELFARE CO OPERATIVE SOCIETY LTD. NO.P 1309, MEZHATHUR P.O., PALAKKAD DISTRICT, PIN CODE-679 534, REPRESENTED BY ITS SECRETARY, SMT.LUJINA.M. 5 VALLUVANAD UN ORGANIZED LABOURS WELFARE CO OPERATIVE SOCIETY LTD. NO.P 1311, KUMBIDI P.O., PALAKKAD DISTRICT, PIN CODE-679 553, REPRESENTED BY ITS SECRETARY, SHRI.SASEEDHARAN. 6 PRIYADARSINI AGRICULTURAL IMPROVEMENT CO OPERATIVE SOCIETY LTD. NO.P 1310, ALOOR, P.O., PATTITHARA, PALAKKAD DISTRICT, PIN CODE- 679 534, REPRESENTED BY ITS SECRETARY, SHRI,K.T.HARIDAS. 2025:KER W.P(C)No.7053/2023 & Connected cases 394 7 MAHATMA MULTIPURPOSE CO OPERATIVE SOCIETY LTD. NO.P 1318, KOOTTUPATHA, P.O.NELLIKKATTIRI, PALAKKAD DISTRICT, PIN CODE-679 533, REPRESENTED BY ITS SECRETARY, SHRI.ISMAYIL.M.P. BY ADVS. SHRI.A.KUMAR (SR.) SHRI.P.J.ANILKUMAR SMTG.MINI(1748) SRI.P.S.SREE PRASAD SHRI.JOB ABRAHAM SHRI.AJAY V.ANAND RESPONDENT/S: 1 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX 9TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM, PIN-682 018. 4 THE KERALA STATE CO OPERATIFE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA STATE CO OPERATIVE BANK, REGIONAL OFFICE, PB NO.21, HPO ROAD, SULTHANPET, PALAKKAD-678 001, REPRESENTED BY ITS GENERAL MANAGER. 6 MANAGER, THE KERALA STATE CO OPERATIVE BANK, PADINJARANGADI BRANCH, PALAKKAD-679 552. 2025:KER W.P(C)No.7053/2023 & Connected cases 395 7 MANAGER, THE KERALA STATE CO OPERATIVE BANK, KOOTTANAD BRANCH, PALAKKAD-679 5 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 396 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11810 OF 2022 PETITIONER/S: 1 THE MANJOOR SERVICE CO-OPERATIVE BANK LTD.NO.K 73, KURUPPANTHARA, MANJOOR P.O.,KOTTAYAM DISTRICT-686 603, REPRESENTED BY ITS SECRETARY SIBY JOSE. 2 THE VAIKOM PALLIPPURATHUSSERY SERVICE CO OPERATIVE BANK LTD.923, KOTTAYAM DISTRICT-686 606, REPRESENTED BY ITS SECRETARY SMT.SARASAMMA.P. 3 THE KAPPUMTHALA SERVICE CO-OPERATIVE BANK LTD.NO.K 142, KAPPUMTHALA P.O., MUTTUCHIRA, KOTTAYAM-686 613, REPRESENTED BY ITS SECRETARY, SMT.LISSYMOL GEORGE. 4 THE KEEZHOOR SERVICE CO OPERATIVE BANK LTD.NO.K 323, KEEZHOOR P.O., KOTTAYAM DISTRICT-686 605, REPRESENTED BY ITS SECRETARY, SMT.M.M.SOBHANA. BY ADVS. SHRI.A.KUMAR (SR.) SHRI.P.J.ANILKUMAR SMTG.MINI(1748) SRI.P.S.SREE PRASAD SHRI.JOB ABRAHAM SHRI.AJAY V.ANAND RESPONDENT/S: 2025:KER W.P(C)No.7053/2023 & Connected cases 397 1 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILLS, NEW DELHI-110 001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM, PIN-682 018. 4 THE KERALA STATE CO OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 398 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11848 OF 2022 PETITIONER/S: THE KALAMASSERY URBAN CO-OPERATIVE SOCIETY LIMITED NO.E-1096, HMT ROAD, KALAMASSERY, ERNAKULAM DISTRICT, REPRESENTED BY ITS PRESIDENT PIN - 683 104. 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 INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 4 THE MANAGER KERALA STATE CO-OPERATIVE BANK LTD., KALAMASSERY BRANCH, ERNAKULAM, PIN - 683 104. BY ADVS. SRI.NAVANEETH.N.NATH CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 399 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 400 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11851 OF 2022 PETITIONER/S: 1 THE SREE SANKARA COLLEGE EMPLOYEES CREDIT CO- OPERATIVE SOCIETY LTD NO.E 642, KALADY, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY,PIN-683 574 2 THE BANK EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.E 235, ALUVA, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN-683 101 3 THE U.C COLLEGE EMPLOYEES CREDIT CO-OPERATIVE SOCIETY LTD NO.E.855, U.C.COLLEGE P.O., ALUVA, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY,PIN-683 101 4 THE AIDED SCHOOL TEACHERS CO-OPERATIVE SOCIETY LTD NO.E 671, HIGH ROAD, ALUVA, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY,PIN-683 101 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS) 2025:KER W.P(C)No.7053/2023 & Connected cases 401 CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM,PIN682 018 3 THE INCOME TAX OFFICER ,(TDS), INCOME TAX DEPARTMENT, ERNAKULAM,PIN-682 018 4 THE KERALA STATE CO-OPERATIVE BANK, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR,PIN-695 033 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 402 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11870 OF 2022 PETITIONER/S: 1 THE KUNNUKARA SERVICE CO-OPERATIVE BANK LTD. NO.827, KUNNUKARA P.O., ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY-686 604 2 THE MANJALY SERVICE CO-OPERATIVE BANK LTD NO.2266, MANJALY PARUR P.O., ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY--683 520 3 THE KARUMALLOOR SERVICE CO-OPERATIVE BANK LTD NO.R 737, KADAYANICKADU, P.O.,KARUMALLOOR P.O., ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY--683 511 4 THE PUTHENVELIKKARA SERVICE CO-OPERATIVE BANK LTD NO.3445, PUTHENVELIKKARA, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY-680 664 5 THE CHERUKADAPPURAM SERVICE CO-OPERATIVE BANK LTD NO.2959, CHERUKADAPPURAM, ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY-683 594 6 THE KONGORPILLY FARMERS SERVICE CO-OPERATIVE BANK LTD NO.3847, KONGORPILLY, ERNAKULAM DISTRICT, REPRESENTED BY ITS MANAGING DIRECTOR 7 THE NEERICODE SERVICE CO-OPERATIVE BANK LTD 1682, ALANGAD, ALUVA, ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY-683 518 2025:KER W.P(C)No.7053/2023 & Connected cases 403 8 THE ELANTHIKARA VANITHA CO-OPERATIVE SOCIETY LIMITED NO.1682, ELANTHIKKARA, ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY-683 594 9 THE PARAUR MAHILA SAHAKARANA SANGHAM LIMITED NO.K.1259, NORTH PARUR, ERNAKULAM DISTRICT,-686535, REPRESENTED BY ITS SECRETARY 10 THE VELIYATHUNADU SERVICE CO-OPERATIVE BANK LTD E 298, U.C COLLEGE P.O., ALUVA, ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY-683 102 11 THE GOVERNMENT SERVANTS CO-OPERATIVE URBAN BANK LTD NO.123, NORTH PARUR, ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY-683 102 12 THE THOZHILAY MULTI PURPOSE CO-OPERATIVE SOCIETY LTD NO.4228, NORTH PARUR, ERNAKULAM DISTRICT,REPRESENTED BY ITS SECRETARY-683 102 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM, PIN-682 018 3 THE INCOME TAX OFFICER (TDS), INCOME TAX DEPARTMENT, IS PRESS ROAD, ERNAKULAM,PIN- 682 018 2025:KER W.P(C)No.7053/2023 & Connected cases 404 4 THE KERALA STATE CO-OPERATIVE BANK LTD, COBANK TOWER, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033 BY ADV SHRI.T.V.VINU, CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 405 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11887 OF 2022 PETITIONER/S: 1 PALAKKUZHA SERVICE CO-OPERATIVE BANK LTD. NO. E-81 PALAKKUZHA PO, ERNAKULAM686662 REPRESENTED BY SECRETARY BABU JOHN 2 KOOTHATTUKULAM FARMERS SERVICE CO-OPERATIVE BANK LTD. NO. E 45 KOOTHATTUKULAM, ERNAKULAM-686662 REPRESENTED BY MANAGING DIRECTOR ABHILASH NAMBOOTHIRI 3 THE ARAKKUZHA SERVICE CO OPERATIVE BANK LTD NO. 495, ARAKKUZHA P О, ERNAKULAM686672 REPRESENTED BY SECRETARY SIBY MATHEW 4 THE MUVATTUPUZHA AGRICULTURAL CO OPERATIVE BANK LTD NO. HW 33 MARKET PO, MUVATTUPUZHA, ERNAKULAM-686669 REPRESENTED BY SECRETARY KISHORE NM 5 THE KAKKOOR SERVICE CO OPERATIVE BANK LTD NO. 163 KAKKOORP.O, ERNAKULAM-686662 REPRESENTED BY SECRETARY SREEDEVI ANDARJANAM T.S 6 PIRAVOM SERVICE CO OPERATIVE BANK LTD NO. E 83 PIRAVOM P.O, ERNAKULAM-686664 REPRESENTED BY SECRETARY RANISH KUMAR K 7 THE ANICADU SERVICE CO OPERATIVE BANK LTD NO. 1550, AVOLY PO, ANICADU, ERNAKULAM686668 REPRESENTED BY SECRETARY IN CHARGE SINDHU PG. ERNAKULAM DISTRICT. 2025:KER W.P(C)No.7053/2023 & Connected cases 406 8 MARADY SERVICE COOPERATIVE BANK LTD NO. E 57 S.MARADY P.O, ERNAKULAM, PIN-26563.REPRESENTED BY SECRETARY VASANTHI , ERNAKULAM DISTRICT. 9 PAIPRA SERVICE CO OPERATIVE BANK LTD NO. 679 MANARY PO, PIN 686673 REPRESENTED BY SECRETARY JEEVAN B , ERNAKULAM DISTRICT. 10 THRIKKALATHOOR SERVICE CO OPERATIVE BANK LTD NO. 145, THRIKKALATHOOR, PIN-683541 REPRESENTED BY SECRETARY GOURY, ERNAKULAM DISTRICT. 11 HOUSING CO OPERATIVE SOCIETY LTD NO. E 728 KOOTHATTUKULAM, KOOTHATTUKULAM P.O, ERNAKULAM-686662 REPRESENTED BY SECRETARY VIJAYAN K N. 12 THE VAZHAKULAM SERVICE CO OPERATIVE BANK LTD NO. 751 VAZHAKULAM P.O, ERNAKULAM-686670 REPRESENTED BY SECRETARY SHIJUMON VS 13 THE SERVICE CO OPERATIVE BANK LTD NO. 2824, VAZHAKULAM P.O, ERNAKULAM-683513 REPRESENTED BY SECRETARY ARUN E R. 14 PAMPAKUDA SERVICE CO OPERATIVE BANK LTD NO. 3520, PAMPAKUDA P.O, ERNAKULAM 685661 REPRESENTED BY SECRETARY RIBINA JOHN. 15 RAMAMANGALAM SERVICE CO OPERATIVE BANK LTD NO. 2156, ERNAKULAM-680563, REPRESENTED BY SECRETARY JIBY CHERIAN. 16 PIRAVOM RURAL CO OPERATIVE BANK LTD NO. 1802 ,PIRAVOM P.O , PIN 686664 REPRESENTED BY SECRETARY MINI SAJAN. ERNAKULAM DISTRAICT. 17 THE PIRAVOM RURAL COOPERATIVE HOUSING SOCIETY LTD.E 193, PIRAVOM, PIN 686 664, REPRESENTED BY SECRETARY SALY JOHN ERNAKULAM DISTRAICT. 18 THE MEKKADAMPU SERVICE CO OPERATIVE BANK LTD NO. 4073, MEKKADAMPU P.O, PIN - 686664 REPRESENTED BY SECRETARY 2025:KER W.P(C)No.7053/2023 & Connected cases 407 LIZY K P , ERNAKULAM DISTRAICT. 19 THE VALAKAM SERVICE COOPERATIVE BANK LTD NO. E 108, KUNNACKAL, PIN 682316, REPRESENTED BY SECRETARY MARY M.C , ERNAKULAM DISTRAICT. 20 THE MUVATTUPUZHA SERVICE CO OPERATIVE BANK LTD NO. E 781, MUVATTUPUZHA P.O, REPRESENTED BY SECRETARY SUDHEER K. ERNAKULAM DISTRAICT. 21 MULAKULAM SERVICE COOPERATIVE BANK LTD NO. 1097, MULAKULAM NORTH P O,PIN-682318, REPRESENTED BY SECRETARY BEENA KURUVILA. ERNAKULAM DISTRICT. 22 MUTHALAPURAM SERVICE CO OPERATIVE BANK LTD NO. 140, MUTHALAPURAM, REPRESENTED BY SECRETARY LIBISHA U.S, ERNAKULAM DISTRICT. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-11000. 2 THE COMMISSIONER OF INCOME TAX (TDS) C.R BUILDING, I.S PRESS ROAD, KOCHI-682018 3 THE INCOME TAX OFFICER(TDS) 3RD FLOOR AAYAKAR BAHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PIN-686673 REPRESENTED BY GENERAL MANAGER (ERSTWHILE THE ERNAKULAM DISTRICT CO-OPERTAIVE BANK), KAKKANAD 2025:KER W.P(C)No.7053/2023 & Connected cases 408 P.O, KOCHI-632030 REPRESENTAO BU THE GENERAL MANAGER). 5 MOVATTUPUZHA URBAN BANK LTD, MOVATTUPUZHA P.O, THOTTUMKAL PIN-686 673 REPRESENTED BY GENERAL MANAGER. BY ADVS. SHRI.JAGADEESH LAKSHMAN, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 409 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11884 OF 2022 PETITIONER/S: THE PARAVUR S.N.V. REGIONAL CO-OPERATIVE BANK LTD.NO.1685 S. PARAVUR PO, KOLLAM 691 301 BY ADVS. SHRI.S.SANTHOSH KUMAR SMT.BABY SUJATHA RESPONDENT/S: 1 1. THE UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001 2 2. THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001 REPRESENTED BY ITS CHAIRMAN 3 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD ERNAKULAM 682 018 4 4. THE ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX 2025:KER W.P(C)No.7053/2023 & Connected cases 410 3RD FLOOR, AAYAKAR BHAVAN, KOWADIAR THIRUVANANTHAPURAM 695 003 5 THE INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM 3RD FLOOR, AAYAKAR BHAVAN KOWADIAR, THIRUVANANTHAPURAM 695 003 6 THE KERALA STATE CO-OPERATIVE BANK LIMITED PB NO 6515, COBANK TOWERS VIKAS BHAVAN PO, PALAYAM THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 THE KERALA STATE CO-OPERATIVE BANK LTD. PARAVUR PARAVUR PO, KOLLAM 691 301 REPRESENTED BY ITS BRANCH MANAGER 8 THE STATE OF KERALA REPRESENTED BY ITS PRINCIPAL SECRETARY TO THE CO-OPERATIVE DEPARTMENT SECRETARIAT, FORT P.O. THIRUVANANTHAPURAM 695 023 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 411 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 11939 OF 2022 PETITIONER/S: 1 CHITTUR RURAL CREDIT CO-OPERATIVE SOCIETY LTD. NO.P 1240, ANICODE, CHITTUR P.O., PALAKKAD - 678101 REPRESENTED BY ITS SECRETARY IN CHARGE SHYNI S.V. 2 AJANUR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S 323, ATHINJAL P.O., MANIKOTH KANHANGAD, KASARGOD - 671 315, REPRESENTED BY ITS SECRETARY SAVITHRI P. 3 PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD. NO.S 372, KOVVALPALLI P.O., KANHANGAD, KASARAGOD - 671 315, REPRESENTED BY ITS SECRETARY USHA M. 4 PERLA RUBBER PRODUCERS SOCIETY REG NO.432/99, P.O.PERLA, KASARAGOD - 671 552 REPRESENTED BY ITS SECRETARY M.PURUSHOTHAMA BHAT. 5 CHIRAYINKEEZHU TALUK AIDED SCHOOL EMPLOYEES CO- OPERATIVE SOCIETY LTD. NO.T 401, CHIRAYINKEEZHU - 695 304 REPRESENTED BY ITS SECRETARY PRIYA S.S. 6 THE KUMBLA GENERAL WORKERS WELFARE CO-OPERATIVE SOCIETY LTD. NO.S 426, KUMBLA P.O., KASARAGOD - 671 321 REPRESENTED BY ITS SECRETARY ANIL KUMAR T. 7 THE PALAKKAD TALUK GOVT.EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.P 758, CIVIL STATION, PALAKKAD - 678 001 REPRESENTED BY ITS SECRETARY SOBHANA P.K. 2025:KER W.P(C)No.7053/2023 & Connected cases 412 8 THE MANNARKKAD TALUK GOVT. EMPLOYEE'S CO-OP CREDIT SOCIETY LTD. NO.P.630, P.O.MANNARKKAD, PALAKKAD - 678 582, REPRESENTED BY ITS SECRETARY UMA N.V. 9 KALLAYAM PRIYADARSINI RESIDENTS WELFARE CO-OPERATIVE SOCIETY LTD. NO.T 1115, KALLAYAM P.O., THIRUVANANTHAPURAM - 695 043 REPRESENTED BY ITS SECRETARY SAJI V.S. 10 CHITTARIKKAL VILLAGE VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S 300, KAMBALLUR P.O., KASARAGOD - 670 511 REPRESENTED BY ITS SECRETARY BINDU K. 11 KANHIRAPUZHA CO-OPERATIVE URBAN CREDIT SOCIETY LTD. NO.P 1172, CHIRAKKALPADI, THRIKALLUR P.O., PALAKKAD - 678 593 REPRESENTED BY ITS SECRETARY ABIN VARGHEES. 12 OTTAPPALAM CO-OPERATIVE HOUSING SOCIETY LTD. NO.P 608, HOUSING SOCIETY BUILDING, RAILWAY STATION ROAD, OTTAPPALAM, PALAKKAD - 679 101 REPRESENTED BY ITS SECRETARY A.SIVADAS. 13 THE KERALA STATE ELECTRICITY BOARD EMPLOYEES CO-OP SOCIETY LTD. NO.P 671, PALAKKAD - 678 014 REPRESENTED BY ITS SECRETARY IN CHARGE P.V.ALPHONSA. 14 THE KOTACHERY CO-OPERATIVE MARKETING SOCIETY LTD. NO.L 354, P.O.KANHANGAD, KASARAGOD - 671 315 REPRESENTED BY ITS SECRETARY LATHA M. 15 ALANALLUR CO-OPERATIVE URBAN CREDIT SOCIETY LTD. NO.P 1215, P.O.ALANALLUR, PALAKKAD - 678 601 REPRESENTED BY ITS SECRETARY BINESH O.V. 16 UZHAMALACKAL PANCHAYATH RURAL WELFARE CO-OPERATIVE SOCIETY T.1804, UTHUKULANGARA P.O., THIRUVANANTHAPURAM - 695 541 REPRESENTED BY ITS SECRETARY USHAKUMARI S. 17 UZHAMALACKAL HOUSING CO-OPERATIVE SOCIETY LTD. NO.T 1215, CHARUMOODU, PUTHUKULANGARA P.O., 2025:KER W.P(C)No.7053/2023 & Connected cases 413 NEDUMANGAD - 695 541 REPRESENTED BY ITS SECRETARY BUSHRA BEEVI. 18 VELLANADU BLOCK RESIDENCE WELFARE CO-OP SOCIETY LTD. NO.T 156 4, ARYANAD P.O., THIRUVANANTHAPURAM - 695 542 REPRESENTED BY ITS SECRETARY JYOTHY S. 19 THIRUVANANTHAPURAM DISTRICT MARKETING AND PROCESSING CO-OPERATIVE SOCIETY LTD. NO.T 383, NEDUMANGAD P.O., THIRUVANANTHAPURAM - 695 541 REPRESENTED BY ITS MANAGING DIRECTOR SREEJA KUMARI. 20 NEDUMANGAD TALUK LOCAL BODIES EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.T 767, NEDUMANGAD P.O., THIRUVANANTHAPURAM - 695 541 REPRESENTED BY ITS SECRETARY J.P.ANEESH. 21 NEDUMANGAD TALUK CO-OPERATIVE EMPLOYEE'S CO-OPERATIVE SOCIETY LTD. NO.T 382, NEDUMANGAD, THIRUVANANTHAPURAM - 695 541 REPRESENTED BY SECRETARY J.JAYAKUMAR. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE 2025:KER W.P(C)No.7053/2023 & Connected cases 414 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK , NEW DELHI - 110 001 REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695 001. BY ADV SHRI.M.SASINDRAN THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 415 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12054 OF 2022 PETITIONER/S: THE ERNAKULAM URBAN CO-OPERATIVE SOCIETY LTD.NO.7 HEAD OFFICE, RAVIPURAM, KOCHI - 682 016 REPRESENTED BY ITS SECRETARY. BY ADV SHRI.M.SHYJU RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI, ERNAKULAM - 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LIMITED P.B.NO.6515, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA 2025:KER W.P(C)No.7053/2023 & Connected cases 416 REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001. BY ADVS. SHRI.T.V.VINU, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 417 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12057 OF 2022 PETITIONER/S: THIRUVITHAMCORE CO-OPERATIVE SOCIETY LTD.NO.T.1530 SAHAKARANA BHAVAN, T.C.28/1289, THAKARAPARAMBU ROAD, SREEKANDAESWARAM, THIRUVANANTHAPURAM - 695 023 REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.B.S.SWATHI KUMAR SMT.ANITHA RAVINDRAN SRI.HARISANKAR N UNNI SHRI.SARANGADHARAN P. SMT.N.S.SHAMILA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, 2025:KER W.P(C)No.7053/2023 & Connected cases 418 KOCHI - 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003. 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695 003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695 001. BY ADVS. SRI.R.PREM SANKAR CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 419 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12065 OF 2022 PETITIONER/S: 1 KOWDIAR CO-OPERATIVE SOCIETY LTD NO.T 2034, VEENA TOWERS, TC 4/242, AMBALAMUKKU, KOWDIAR P.O., THIRUVANANTHAPURAM, PIN-695 003, REPRESENTED BY ITS PRESIDENT. 2 THIRUVANANTHAPURAM ICE CREAM DISTRIBUTORS AND SELLERS CO OPERATIVE SOCIETY LTD. NO.T 1903, ENCHACKAL JUNCTION, THIRUVANANTHAPURAM, REPRESENTED BY ITS PRESIDENT. BY ADVS. SRI.B.S.SWATHI KUMAR SMT.ANITHA RAVINDRAN SRI.HARISANKAR N UNNI SHRI.SARANGADHARAN P. SMT.N.S.SHAMILA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, 2025:KER W.P(C)No.7053/2023 & Connected cases 420 REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIOENR OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 003. 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKARA BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003. 6 THE KERALA STATE CO OPERATIVE BANK LTD., PB NO.6515, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY, (CO OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. BY ADVS. SHRI.K.K.SETHUKUMAR, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 421 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12061 OF 2022 PETITIONER/S: KOCHIN COPERATIVE SOCIETY LTD NO. E-100 AGED 47 YEARS LALAN ROAD , PALACE ROAD,MATTACHERRY KOCHI REPRESENTED BY ITS SECRETARY JAMES K.F, PIN - 682002 BY ADVS. SHRI.ARUN V.G. (K/795/2004) SMT.V.JAYA RAGI SHRI.R.HARIKRISHNAN (KAMBISSERIL) SRI.NEERAJ NARAYAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 2025:KER W.P(C)No.7053/2023 & Connected cases 422 4 THE KERALA STATE CO-OPERATIVE BANK LTD PALAYAM, THIRUVANANTHAPURAM REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 THE KERALA STATE CO-OPERATIVE BANK LTD KOCHI, MATTACHERRY, PALACE ROAD , KOCHI REPRESENTED BY ITS MAMANGER, PIN - 682002 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN - 682031 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 423 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12076 OF 2022 PETITIONER/S: CHEMPAZHANTHY AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD. NO. T.1750 CHEMPAZHANTHY P.O, THIRUVANANTHAPURAM DISTRICT, REPRESENTED BY THE SECRETARY IN CHARGE. BY ADVS. SRI.GEORGE POONTHOTTAM (SR.) SMT.NISHA GEORGE SHRI.ANSHIN K.K 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, PIN - 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, NEW DELHI - PIN - 110001. 3 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 424 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, D.P.I, JUNCTION, JAWAHAR SAHAKARANA BHAVAN, THIRUVANANTHAPURAM - 695014. 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - PIN - 695033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 425 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12075 OF 2022 PETITIONER/S: ATTINGAL EDUCATIONAL DISTRICT GOVT. SCHOOL TEACHERS CO-OPERATIVE SOCIETY LTD.NO.T 312 REPRESENTED BY ITS SECRETARY, PALACE ROAD, ATTINGAL P.O, THIRUVANANTHAPURAM DISTRICT - PIN - 695101. BY ADVS. SHRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, IIIRD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O, THIRUVANANTHAPURAM, PIN - 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, NEW DELHI - PIN - 110001. 3 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI - PIN - 110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 426 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM - PIN - 695001. 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001. 6 THE KERALA STATE CO-OPERATIVE BANK. REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - PIN - 695033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 427 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12082 OF 2022 PETITIONER/S: RAILWAYMEN'S HOUSE BUILDING CO-OPERATIVE SOCIETY LTD NO.E-738 REPRESENTED BY ITS ASST. REGISTRAR/ SECRETARY, RAILWAY BUILDING NO. 77/A, ERNAKULAM , PIN 682 005. BY ADVS. SHRI.T.R.HARIKUMAR SRI.ARJUN RAGHAVAN RESPONDENT/S: 1 THE INCOME TAX OFFICER (TDS) X 2 THE CENTRAL BOARD OF DIRECT TAXES, REPREESENTED BY ITS CHAIRPERSON, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT)/MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI , PIN 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 , PIN 110 001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM, PIN 695 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 428 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN 695 001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B. NO. 6515, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695 033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.SHYAMDEEP S.SHENOY, CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 429 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12086 OF 2022 PETITIONER/S: THE AVOLI MULTI PURPOSE CO-OPERATIVE SOCIETY LTD .E- 1397 REPRESENTED BY ITS HON. SECRETARY, M.V. KURUVILLA, AGED 74 YEARS, HEAD OFFICE, ADOOPARAMPU, MUVATTUPUZHA - 686 661. BY ADVS. SRI.GEORGE MATHEW SRI.M.D.SASIKUMARAN SHRI.PRAVEEN S. SHRI.SUNIL KUMAR A.G SRI.DIPU JAMES SHRI.MATHEW K.T. SHRI.GEORGE K.V. SHRI.STEPHY K REGI SMT.ELSA DENNY PINDIS RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 002. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDINGS I.S. PRESS ROAD, KOCHI - 682 018. 2025:KER W.P(C)No.7053/2023 & Connected cases 430 3 THE INCOME TAX OFFICER, TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY - 8, THODUPUZHA, IDUKKI DISTRICT - 685 584. - 4 STATE OF KERALA REP. BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM - 695 014. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., (KERALA BANK) REP. BY ITS MANAGING DIRECTOR & CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033. 7 THE DEPUTY GENERAL MANAGER, CENTRAL PROCESSING CENTER, THE KERALA STATE CO- OPERATIVE BANK LTD., (KERALA BANK), REGIONAL OFFICE, KAKKANAD, ERNAKULAM, KOCHI - 682 030. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 431 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12100 OF 2022 PETITIONER/S: KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION DISTRICT COMMITTEE, THIRUVANANTHAPURAM, OFFICE AT BALARAMAPURAM SERVICE CO-OPERATIVE BANK LTD T/14, BALARAMAPURAM- THIRUVANANTHAPURAM-695 501, REPRESENTED BY ITS SECRETARY, PRATHAPACHANDRAN.A BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, 2025:KER W.P(C)No.7053/2023 & Connected cases 432 KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALKA THIRUVANANTHAPURAM-695 001 BY ADV SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 433 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12102 OF 2022 PETITIONER/S: 1 NEDIYANGA SERVICE CO-OPERATIVE BANK LTD NO.L.L.84, H.O.CHENPANTHOTTY P.O., KANNUR-670 631, REPRESENTED BY ITS SECRETARY, KRISHNANKUTTY K.P. 2 ARALAM SERVICE CO-OPERATIVE BANK LTD,NO.F.1515, H.O.KEEZHPALLY, KEEZHPALLY, KANNUR -670 704, REPRESENTED BY ITS SECRETARY BABU.T.J 3 ERUVESSY SERVICE CO-OPERATIVE BANK LTD NO.C 171, P.O.CHEMPERI, KANNUR-670 632, REPRESENTED BY ITS SECRETARY NIZAR.N. 4 PERUMPUZHA GRAMODHARANA SERVICE CO-OPERATIVE BANK LTD,NO.2533, PERUMPUZHA P.O., KOLLAM-691 504, REPRESENTED B ITS SECRETARY S MANIKANDAN PILLAI 5 POOKKOTTUKAVU PANCHAYATH SERVICE CO-OPERATIVE BANK LTD NO. P 1101 POOKKOTTUKAVU, KADAMUR P.O., PALAKKAD-679 515, REPRESENTED BY ITS SECRETARY P.G.KRISHNA PRASAD BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 434 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001 BY ADVS. SHRI.SHYAMDEEP S.SHENOY, CGC SHRI.M.SASINDRAN THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 435 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12105 OF 2022 PETITIONER/S: THE FEDO EMPLOYEES CO-OPERATIVE SOCIETY LIMITED LIMITED NO.E 679, UDYOGAMANDAL P.O., ERNAKULAM DISTRICT - 683 501, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, I.S.PRESS ROAD, ERNAKULAM, PIN- 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 5 THE MANAGER KERALA STATE CO-OPERATIVE BANK LTD., KALAMASSERY, ERNAKULAM, PIN - 683 104. 2025:KER W.P(C)No.7053/2023 & Connected cases 436 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 437 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12110 OF 2022 PETITIONER/S: 1 KASARAGOD DISTRICT INSURANCE AGENT'S CO-OPERATIVE SOCIETY LTD NO.S 401, KANHANGAD, NEAR KOTTACHERY BUS STAND, KANHANGAD, KASARGOD -671 315, REPRESENTED BY ITS SECRETARY LATHIKA.V. 2 UDMA PANCHAYATH VANITHA SERVICE SAHAKARANA SANGAM LTD NO.S.492, USMA P.O., KASARAGOD-671 319, REPRESENTED BY ITS SECRETARY SUKUMARI.K. 3 HOSDURG TALUK MOTOR WORKERS CO-OPERATIVE SOCIETY LTD NO.S 28, LAKSHMI NAGAR, KANHANAGAD P.O.,KASARAGOD-671315, REPRESENTED BY ITS SECRETARY BEENA.K. 4 PALLIKERE VANITHA SERVICE CO-OPERATIVE SOCIETY NOT.S.433, PALLIKKERE P.O., BEKAL FORT, KASARAGOD-671 316, REPRESENTED BY ITS SECRETARY BINDU.P. 5 KUTTIKOL AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD NO.S 383, KUTTIKOL P.O., KASARGOD-672 541, REPRESENTED BY ITS SECRETARY CHATHUKUTTY NAIR 6 KASARGOD RUBBER FARMERS WELFARE CO-OPERATIVE SOCIETY LTD NO.S 429, KUTTIKOL, KASARGOD-671 541, REPRESENTED BY ITS SECRETARY SHOBHA .K. 2025:KER W.P(C)No.7053/2023 & Connected cases 438 7 BANDADKA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO.S 350, BANDADKA P.O., CHENGALA (VIA) ,KASARAGOD-671 541, REPRESENTED BY ITS SECRETARY BABY.K. 8 PILICODE PANCHAYATH VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO.S 251, KALIKADAVU, PILICODE P.O.,KASARAGOD-671 353, REPRESENTED BY ITS SECRETARY SUSHAMA.P.V. 9 NILESHWAR RURAL CO-OPERATIVE HOUSING SOCIETY LTD NO.F.F. 103, NILESHWAR, KASARAGOD-671 314, REPRESENTED BY ITS SECRETARY, UNNIKRISHNAN.K.M. 10 UDMA KARSHAKA KSHEMA SAHAKARANA SANGHAM LTD NO.S.376, PALAKUNNU, BEKAL P.O.,KASARGOD-671 318, REPRESENTED BY ITS SECRETARY K.KRISHNAN 11 KASARGOD DISTRICT P.N.PANICKER SOCIAL WORKERS WELFARE CO-OPERATIVE SOCIETY LTD NO.S.338 (KASCO), KANHANGAD P.O., KASARAGOD -671 315, REPRESENTED BY ITS SECRETARY AMBIKA .V. 12 BEDADKA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO.S 348, KANHIRATHINGAL, BEDADKA P.O., KASARAGOD-671 541, REPRESENTED BY ITS SECRETARY SUDHEESH KUMAR.A 13 HOSDURG HOUSING CO-OPERATIVE SOCIETY LTD NO.F F 16, KANHANGAD.P.O., KASARAGOD-671 315, REPRESENTED BY ITS SECRETARY, ANILKUMAR.H.J. 14 THALASSERY AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD NO.C 1619, BABNEESH ARCADE, LOGANS ROAD, THALASSERY, KANNUR-670 649, REPERESENTED BY ITS SECRETARY SATHEESH.M. 15 KOTTARAKKARA TALUK HOUSING CO-OPERATIVE SOCIETY LTD NO.Q 451, KOTTARAKARA P.O., KOLLAM-691 506, REPRESENTED BY ITS SECRETARY G.GOPIKRISHNA 2025:KER W.P(C)No.7053/2023 & Connected cases 439 BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, IS PRESS ROAD,KOCHI- 682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATIN) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 440 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 441 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12123 OF 2022 PETITIONER/S: ITI STAFF CO-OPERATIVE CREDIT SOCIETY LTD NO. E 730, KALAMASSERY, HMT COLONY P.O, ERNAKULAM DISTRICT, PIN 683 503, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.M.M.MONAYE SHRI.M.PAUL VARGHESE SRI.K.V.SANOSH SMT.NIRMALA P.V. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI , PIN 110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE, (CBDT) , MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI 110 001. 3 COMMISSIONER OF INCOME TAX (TDS), C.R. BUILDINGS, I.S. PRESS ROAD, ERNAKULAM, 682 018. 4 STATE OF KERALA, DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT, 2025:KER W.P(C)No.7053/2023 & Connected cases 442 REPRESENTED BY SECRETARY TO GOVERNMENT, THIRUVANANTHAPURAM- 695 001 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR FO CO-OPERATIVE SOCIETIES, STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM- 695 001. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. , CO- BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, THIRUVANANTHAPURAM- 695 033. 7 DEPUTY GENERAL MANAGER, KERALA STATE CO-OPERATIVE BANK LTD. CREDIT PROCESSING CENTRE, KAKKANAD, KOCHI 682 030. BY ADVS. SHRI.NAVANEETH.N.NATH, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 443 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12124 OF 2022 PETITIONER/S: THE SAMSKRUTHA SARVAKALASALA CO-OPERATIVE SOCIETY LTD E.1180 KALADY, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 683 574. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN 682 018. 3 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, ERNAKULAM, PIN 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033. 5 THE BRANCH MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., KALADY BRANCH, ERNAKULAM DISTRICT, PIN 683 574. 2025:KER W.P(C)No.7053/2023 & Connected cases 444 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 445 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12126 OF 2022 PETITIONER/S: 1 THE VALLICODE SERVICE CO-OPERATIVE BANK LIMITED NO.61, VALLICODE, PATHANAMTHITTA DISTRICT-686 648, REPRESENTED BY ITS SECRETARY. 2 THE MEZHUVELIL SERVICE CO OPERATIVE BANK LIMITED NO.2570, ULLANNOOR, PATHANAMTHITTA DISTRICT-689 645, REPRESENTED BY ITS SECRETARY. 3 THE PRAKKANAM SERVICE CO OPERATIVE BANK LIMITED NO.677, PRAKKANAM P.O., PATHANAMTHITTA DISTRICT-689 643, REPRESENTED BY ITS SECRETARY. 4 THE KUMBAZHA SERVICE CO OPERATIVE BANK LIMITED NO.1373, MYLAPRA, PATHANAMTHITTA DISTRICT-689 647, REPRESENTED BY ITS SECRETARY. 5 THE THANNITHODE SERVICE CO OPERATIVE BANK LIMITED NO.Q 364, THANNITHODE, PATHANAMTHITTA DISTRICT-689 699, REPRESENTED BY ITS SECRETARY. 6 THE KADAMMANITTA SERVICE CO OPERATIVE BANK LIMITED NO.PT 44, KADAMMANITTA P.O., PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN-689 644. 7 THE MEKKOZHOOR SERVICE CO-OPERATIVE BANK LIMITED 2025:KER W.P(C)No.7053/2023 & Connected cases 446 NO.1191, MEKKOZHOOR, PATHANAMTHITTA DISTRICT-689 643, REPRESENTED BY ITS SECRETARY. 8 THE CHENNERKARA SERVICE CO OPERATIVE BANK LIMITED NO.96, CHENNEERKARA, PATHANAMTHITTA DISTRICT-689 503, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM, PIN-682 018. 3 THE INCOME TAX OFFICER (TDS), AARATTUKULAKKARA COMPLEX, AN PURAM, ALAPUZHA DISTSRICT-686 011. 4 THE KERALA STATE CO OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695 033. 5 THE DEPUTY GENERAL MANAGER, KERALA STATE CO OPERATIVE BANK LTD., PATHANAMTHITTA DISTRICT OFFICE, PATHANAMTHITTA, PIN-686645. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 447 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12145 OF 2022 PETITIONER/S: 1 PALAKKAD MUNICIPAL SAHAKARANA URBAN CREDIT SOCIETY LTD. NO.P 1306, PAPACHAN COMPLEX, KANNARA STREET, ROBINSON ROAD, PALAKKAD-678 001, REPRESENTED BY ITS SECRETARY, SHRI. KUPPELAN .S. 2 PALAKKAD TALUK HEADLOAD WORKERS CO-OPERATIVE SOCIETY LTD, NO.P.1337, DANCE MARKET BUILDING, MARKET ROAD, PALAKKAD-678 014, REPRESENTED BY ITS SECRETARY ,SMT.MINI BABU 3 PALAKKAD TALUK BUILDING & ROAD WORKERS CO-OPERATIVE SOCIETY LTD NO.P1315, RAJEEV BHAVAN, PENSION STREET, PALAKKAD-678 001, REPRESENTED BY ITS SECRETARY, SHRI. SUDEVAN .K.K. 4 INDIRA GANDHI MULTI PURPOSE CO-OPERATIVE SOCIETY LTD NO.P 1330, PANCHAYATH SHOPPING COMPLEX, KALLEPULLY P.O., PALAKKAD-678 005, REPRESENTED B ITS SECRETARY, SHRI. VISHNUDAS .R. 5 PALAKKAD TALUK AIDED SCHOOL EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.P 782, NEAR KSRTS LIN ROAD, PALAKAD-678 004, REPRESENTED BY ITS SECRETARY, SMT. LATHA.T. 6 THE PALAKKAD DISTRICT EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.P.1184 CIVIL STATION, PALAKKAD-678 001, REPRESENTED BY ITS SECRETARY, SHRI. BABU.B.S. 2025:KER W.P(C)No.7053/2023 & Connected cases 448 7 THE ELAPPULLY RURAL CO-OPERATIVE SOCIETY LTD NO.P 1383, CHEERMBAKKAVU, VIJAYAPUSHPAM COMPLEX, ELAPPULLY P.O., PALAKKAD-678 622, REPRESENTED BY ITS PRESIDENT, SUNILKUMAR.S BY ADVS. SHRI.A.KUMAR (SR.) SHRI.P.J.ANILKUMAR SMTG.MINI(1748) SRI.P.S.SREE PRASAD SHRI.JOB ABRAHAM SHRI.AJAY V.ANAND RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW DELHI-110 001 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW DELHI-110 001, REPRESENTED BY SECRETARY 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM,PIN-682 018 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,PIN-695 033, REPRESENTED BY ITS MANAGING DIRECTOR 5 THE KERALA STATE CO-OPERATIVE BANK, REGIONAL OFFICE, P.B.NO.21, H.P.O ROAD, SULTHANPET, PALAKKAD-678 001 6 SENIOR MANAGER, THE KERALA STATE CO-OPERATIVE BANK ,PALAKKAD MAIN BRANCH, PALAKKAD-679 552 2025:KER W.P(C)No.7053/2023 & Connected cases 449 7 MANAGER, THE KERALA STATE CO-OPERATIVE BANK, KALLEPULLY BRANCH, PALAKKAD-678 005 8 MANAGER, THE KERALA STATE CO-OPERATIVE BANK, MELAMURI BRANCH, PALAKKAD-678 006 BY ADVS. SHRI.VISHNU RAJAGOPAL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 450 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12257 OF 2022 PETITIONER/S: 1 THIRUVANANTHAPURAM TALUK CO-OPERATIVE EMPLOYEES CO- OPERATIVE SOCIETY LTD NO.T 846, KUTTIKKAD JUNCTION, MANACAUD P.O, THIRUVANANTHAPURAM DISTRICT, KERALA, PIN 695 009, REPRESENTED BY ITS SECRETARY. 2 HEALTH SERVICE STAFF CO-OPERATIVE SOCIETY LTD., NO. T 431, HEAD OFFICE, GENERAL HOSPITAL, VANCHIYOOR P.O, THIRUVANANTHAPURAM, DISTRICT, KERALA, PIN 695 035, REPRESENTED BY ITS SECRETARY. BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 00 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018. 3 THE INCOME TAX OFFICER (TDS), 2025:KER W.P(C)No.7053/2023 & Connected cases 451 3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., (ERSTWHILE THIRUVANANTHAPURAM SERVICE CO-OPERATIVE BANK), EAST FORT, THIRUVANANTHAPURAM-695 023, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 452 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12263 OF 2022 PETITIONER/S: KADUNGALLOR SERVICE CO-OPERATIVE BANK LTD. NO.863 REPRESENTED BY ITS SECRETARY, WEST KADUNGALLOOR P.O.ALUVA-683 110 BY ADVS. SRI.JOJU KYNADY SRI.A.ABDUL NABEEL RESPONDENT/S: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, TDS RANGE, 11RD FLOOR, AAYAKAR BHAVAN, KOWDIAR P.O.THIRUVANANTHAPURAM, PIN-695 003. 2 THE CENTRAL BOARD OF DIRECTOR TAXES, REPRESENTED BY ITS CHAIRPERSON, ROOM NO 143, E NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT/ MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NEW DELHI-PIN-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, PIN-110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, THIRUVANANTHAPURAM, PIN-695 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 453 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN-695 001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P B NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695 033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 454 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12351 OF 2022 PETITIONER/S: 1 THE GOVERNMENT SERVANT'S CO-OPERATIVE BANK LIMITED, NO. Q 169, KULANADA, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY 689 503. 2 THE PARIYARAM SERVICE CO - OPERATIVE BANK LIMITTED NO. Q 391. PARIYARAM, PATHANAMTHITTA DISTRICT 689 653, REPRESENTED BY ITS SECRETARY. 3 THE PATHANAMTHITTA POLICE DEPARTMENT EMPLOYEES CO OPERATIVE SOCIETY LIMITED NO. PT 103, PATHANAMTHITTA 689 643. PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY. 4 THE KUMBAZHA SERVICE CO OPERATIVE BANK LIMITED, NO. 330, KUMBAZHA, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL NEW DELHI 11001. 2 THE COMMISSIONER OF INCOME TAX (TDS), 2025:KER W.P(C)No.7053/2023 & Connected cases 455 CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM 682 018. 3 THE INCOME TAX OFFICER, (TDS), AARATTUKULAKKARA COMPLEX, A.N. PURAM ALAPPUZHA DISTRICT 686 011. 4 THE KERALA STATE CO OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, 695 033. 5 THE DEPUTY GENERAL MANAGER, KERALA STATE CO OPERATIVE BANK LTD, PATHANAMTHITTA DISTRICT OFFICE, PATHANAMTHITTA 689 645. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 456 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12428 OF 2022 PETITIONER/S: VENGANOOR CO-OPERATIVE RURAL DEVELOPMENT SOCIETY LTD NO.T-1497 VENGANOOR, VENGANOOR P O, THIRUVANANTHAPURAM, PIN- 695521, REPRESENTED BY ITS SECRETARY, T RAMESH. BY ADVS. SRI.D.SAJEEV SMT.LIGEY ANTONY RESPONDENT/S: 1 UNION OF INDIA MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI, 110 001. REPRESENTED BY ITS SECRETARY. 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX C.R.BUILDING, I.S. PRESS ROAD, KOCHI, ERNAKULAM. PIN. 682 018. 3 THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS) 3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O., THIRUVANANTHAPURAM. PIN. 695 003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. EAST FORT, THIRUVANANTHAPURAM. PIN. 695 023. REPRESENTED BY ITS MANAGING DIRECTOR. 2025:KER W.P(C)No.7053/2023 & Connected cases 457 5 THE BRANCH MANAGER THE KERALA STATE CO-OPERATIVE BANK LTD., PERIGAMMALA BRANCH, THIRUVANANTHAPURAM. PIN. 695042, 6 THE BRANCH MANAGER THE KERALA STATE CO-OPERATIVE BANK LTD., VIZHINJAM BRANCH, THIRUVANANTHAPURAM. PIN. 695521. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 458 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14068 OF 2022 PETITIONER/S: 1 THE K.P.B. EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO E 770, KAKKANAD P.O, ERNAKULAM DISTRICT, REPRESENTED BY ITS PRESIDENT, PIN 682 030 2 THE ERNAKULAM GOVERNMENT EMPLOYEES HOUSE CONSTRUCTION CO-OPERATIVE SOCIETY LTD NO E 1124, ALUVA, KARSHIKA BANK BUILDING, ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 683001. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) INCOME TAX DEPARTMENT, ERNAKULAM, PIN - 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. 2025:KER W.P(C)No.7053/2023 & Connected cases 459 BY ADVS. SHRI.PRAVEEN K.V., CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 460 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12504 OF 2022 PETITIONER/S: MEENACHIL TALUK HIGHER SECONDARY TEACHER'S CO- OPERATIVE SOCIETY LTD. NO.K 1179, CHERUPUSHPAN BUILDING, OLD PVT BUS STAND, PALA, KERALA - 686 575, REP. BY ITS HONORARY SECRETARY BAIBY THOMAS. BY ADVS. SHRI.BABY THOMAS SHRI.GEORGE T.J RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 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 (TDS) INCOME TAX OFFICE, PUBLIC LIBRARY BUILDING, SHASTRI ROAD, KOTTAYAM - 686 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. (KERALA BANK) 2025:KER W.P(C)No.7053/2023 & Connected cases 461 CO BANK TOWERS VIKAS BHAVAN, PALAYAM, THIRUVANANTHAPURAM - 695 033 REP. BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. SMT.MAHESWARY.G., SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 462 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12545 OF 2022 PETITIONER/S: PANAPPAMKUNNU RURAL CO-OPERATIVE SOCIETY LTD. NO. T- 1570 MALACKKAL P.O., CHIRAYINKEEZHU, THIRUVANANTHAPURAM, PIN - 695 602, REPRESENTED BY ITS SECRETARY, K.G.NISHA. BY ADVS. SRI.D.SAJEEV SMT.LIGEY ANTONY RESPONDENT/S: 1 UNION OF INDIA MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI - 110 001 REPRESENTED BY ITS SECRETARY. 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX C.R.BUILDING, I.S.PRESS ROAD, KOCHI, ERNAKULAM, PIN - 682 018. 3 THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS) 3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O., THIRUVANANTHAPURAM, PIN - 695 003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. EAST FORT, THIRUVANANTHAPURAM, PIN - 695 023 REPRESENTED BY ITS MANAGING DIRECTOR. 2025:KER W.P(C)No.7053/2023 & Connected cases 463 5 THE BRANCH MANAGER THE KERALA STATE CO-OPERATIVE BANK OLTD., KILIMANOOR BRANCH, THIRUVANANTHAPURAM, PIN - 695 601. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 464 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12635 OF 2022 PETITIONER/S: 1 THE KASARAGOD DISTRICT ADVOCATE'S WELFARE CO- OPERATIVE SOCIETY LTD NO. S 414 HOSDURG P.O., KANHANGAD, KASARAGOD-671315 REPRESENTED BY ITS SECRETARY AMBILIL K.S. 2 THE PARAPPA FARMER'S WELFARE COOPERATIVE SOCIETY LTD NO. S 508 PARAPPA P.O., KASARAGOD-671533 REPRESENTED BY ITS SECRETARY REKHA K.R 3 THE VELLARIKUNDU KARSHAKA KSHEME GRAMA VIKASANA SAHAKARANA SANGAM LTD, NO. S 459 VELLARIKUNDU P.O., KASARAGOD-671534 REPRESENTED BY ITS SECRETARY SHEEJA M.V. 4 BRAHMOS AEROSPACE EMPLOYEES COOPERATIVE SOCIETY LTD NO. T 1324, BRAHMOS CAMPUS CHACKAI BEACH P.O., THIRUVANANTHAPURAM-695007, REPRESENTED BY ITS SECRETARY SUNILKUMAR J. 5 TELLICHERRY EDUCATIONAL DISTRICT TEACHER'S CO- OPERATIVE SOCIETY LTD. NO. C 810 LOGANS ROAD, THALASSERY, KANNUR-670101 REPRESENTED BY ITS SECRETARY SAJINA K. 6 VAMAL VANITHA CO-OPERATIVE SOCIETY LTD NO. C.1683 DIET ROAD, PALAYAD P.O., KANNUR-670661 REPRESENTED BY ITS SECRETARY BINDU C.P 7 KULUKKALLUR PANCHAYATH AGRICULTURAL IMPROVEMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 465 CREDIT CO-OPERATIVE SOCIETY LTD NO. P.1270, MULAYANKAV P.O.,KULUKKALLUR, PALAKKAD-679337 REPRESENTED BY ITS SECRETARY V JANARDHANAN. 8 DHARMADAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C1602 , VELLAZHUKKE, PALAYAD, KANNUR-670661 REPRESENTED BY ITS SECRETARY GEETHA K. 9 AZHIYOOR VANITHA SAHAKARANA SANGAM LTDNO. D 2661 CHOMBALA P.O., KOZHIKODE-673308 REPRESENTED BY ITS SECRETARY SHAJI O.K 10 NEYYATINKARA WELFARE CO-OPERATIVE SOCIETY LTD NO. T 1800 THIRUMANGALAM, POOVAR ROAD, NEYYATTINKARA, THIRUVANANTHAPURAM-695121 REPRESENTED BY ITS SECRETARY PRADEEP R.S. 11 OTTAPPALAM CO-OPERATIVE HOUSING SOCIETY LTD. NO. P 608, HOUSING SOCIETY BUILDING, RAILWAY STATION ROAD, OTTAPPALAM, PALAKKAD-679101 REPRESENTED BY ITS SECRETARY A.SIVADAS. 12 KANHIRAPUZHA CO-OPERATIVE URBAN CREDIT SOCIETY LTD. NO. P 1172 CHIRAKKALPADI, THRIKALOOR P.O., PALAKKAD-678593 REPRESENTED BY ITS SECRETARY ABIN VARGHEES. 13 LABOUR BANK WELFARE CO-OPERATIVE SOCIETY LTD NO.C1632 MUNEER COMPLEX RAJIV GANDHI ROAD KANNUR-670001 REPRESENTED BY ITS SECRETARY JITHESH K. 14 CHERUPUZHA MERCHANTS WELFARE CO OPERATIVE SOCIETY LTD NO C 1708 ,CHERUPUZHA PO,KANNUR-670511 REPRESENTED BY ITS SECRETARY SURESH K. 15 KANNUR DISTRICT CONTRACTORS CO OPERATIVE SOCIETY LTD NO.C1430 SEALAND COMPLEX, TALIPARAMBA.P O,KANNUR-670141 REPRESENTED BY ITS SECRETARY V.V SATHISH KUMAR. 16 TALIPARAMBA GOVT EMPLOYEES CO OPERATIVE SOCIETY LTD 2025:KER W.P(C)No.7053/2023 & Connected cases 466 NO C 293 TALIPPARAMBA (P.O) KANNUR-670141 REPRESENTED BY ITS SECRETARY SATHEESAN. 17 TALIPARAMBA RURAL CO OPERATIVE SOCIETY LTD NO C 2056 , EMIRATES ROAD, MAIN ROAD TALIPARAMBA, KANNUR- 670141. REPRESENTED BY ITS SECRETARY PRADEEP T.V. 18 THULUNADU FARMER'S WELFARE CO-OPERATIVE SOCIETY LTD, NO S 548 KOTTODAL BUILING, KUMBALA, KASARAGOD- 671321 REPRESENTED BY ITS SECRETARY VASANTHA D 19 CHIRAYINKEEZHU TALUK TOURISM CO-OPERATIVE SOCIETY LTD T 1860 NEAR TOWN UPS, ATTI NGAL, THIRUVANANTHAPURAM - 695101 REPRESENTED BY ITS SECRETARY RATHEESH R. 20 KARIMBA PANCHAYATH KARSHIKA UDPADHANA SAMBARANA SAMSKARANA VIPANANA CREDIT SAHAKARANA SANGHAM LTD, P.O. KARIMPA, PALAKKAD-678597 REPRESENTED BY ITS SECRETARY GEETHA K. BY ADVS. DR.K.P.PRADEEP SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN. 2025:KER W.P(C)No.7053/2023 & Connected cases 467 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI- 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD ,PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 468 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12754 OF 2022 PETITIONER/S: PANGAPPARA SREE NARAYANA GURUMANDIRA SAMITHI RESIDENCE WELFARE CO-OPERATIVE SOCIETY LTD.NO.T 1720, REPRESENTED BY ITS SECRETARY, KARIYAVATTOM P.O., THIRUVANANTHAPURAM, PIN - 695 581. BY ADVS. SHRI.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, PIN - 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, PIN - 110 001. 3 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI, PIN - 110 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 469 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O., THIRUVANANTHAPURAM - 695 014. 5 STATE OF KERALA REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695 001. 6 THE KERALA STATE CO-OPERATIVE BANK REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695 033. BY ADVS. SMT.MAHESWARY.G., SENIOR PANEL COUNSEL SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 470 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12713 OF 2022 PETITIONER/S: 1 VANCHINADU BHAVANA NIRMANA SAHAKARANA SANGHOM LTD NO 1083, ENCHAKKAL P.O.THIRUVANANTHAPURAM DISTRICT, KERALA, PIN-695 608, REPRESENTED BY ITS SECRETARY SREEKALA 2 PEROORKADA SERVICE CO-OPERATIVE BANK LIMITED NO T 1412, PEROORKADA P.O.THIRUVANANTHAPURAM DISTRICT, KERALA, PIN-695 005, REPRESENTED BY ITS SECRETARY YAMUNA BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110 000 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682 018 3 THE INCOME TAX OFFICER (TDS), 3RD FLOOR AAYAKAR BAHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695 003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE THIRUVANANTHAPURAM SERVICE CO-OPERATIVE BANK), EAST FORT, THIRUVANANTHAPURAM-695 023. 2025:KER W.P(C)No.7053/2023 & Connected cases 471 5 KERALA LAND REFORMS AND DEVELOPMENT CO-OPERATIVE SOCIETY LTD, S.S.KOVIL ROAD, THAMPANOOR, GENERAL POST OFFICE, THIRUVANANTHAPURAM-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 472 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12744 OF 2022 PETITIONER/S: 1 MALAMPUZHA SERVICE CO-OPERATIVE BANK LTD NO.P.907 NO.P.907, KADUKKAMKUNNAM.P.O, PALAKKAD-678651, REPRESENTED BY ITS SECRETARY PRATHEEP.K.P. 2 KALPETTA ZONE LABOUR CONTRACT CO-OPERATIVE SOCIETY LTD.NO.W.209, KALPETTA.P.O, WAYANAD-673121,REPRESENTED BY ITS SECRETARY NITHIN SUNNY. 3 KUTTIKOL AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD.NO.S 383, KUTTIKOL.P.O,` KASARAGOD-671541, REPRESENTED BY ITS SECRETARY CHATHUKUTTY NAIR. 4 BALAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD, NO.S 293, BALAL, BALAL.P.O, KASARAGOD- 671533,REPRESENTED BY SECRETARY PRASANTH.V. 5 KASARAGOD DISTRICT P.N.PANICKER SOCIAL WORKERS WELFARE CO-OPERATIVE SOCIETY LTD, NO.S.338(KASCO), KANHANGAD.P.O, KASARAGOD- 671315,REPRESENTED BY ITS SECRETARY AMBIKA.V 6 UDMA PANCHAYATH VANITHA SERVICE SAHAKARANA SANGAM LTD NO.S.492, UDMA.P.O, KASARAGOD-671319, REPRESENTED BY ITS SECRETARY SUKUMARI.K. 7 BANDADKA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.NO.S 350, BANDADKA.P.O, CHENGALA(VIA), KASARAGOD- 2025:KER W.P(C)No.7053/2023 & Connected cases 473 671541,REPRESENTED BY ITS SECRETARY BABY.K. 8 THALASSERY AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD.NO.C.1619, BABNEESH ARCADE, LOGANS ROAD, THALASSERY, KANNUR- 670649,REPRESENTED BY ITS SECRETARY SATHEESH.M. 9 THE PILICODE AGRICULTURIES WELFARE CO-OPERATIVE SOCIETY LTD.NO.S 385, KALIKADAVU, P.O.PILICODE, KASARAGOD- 671353,REPRESENTED BY ITS SECRETARY JAYARAJAN.K. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY,DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FIINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, ERNAKULAM-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE DIRECTOR. 2025:KER W.P(C)No.7053/2023 & Connected cases 474 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 475 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12753 OF 2022 PETITIONER/S: ENADIMANGALAM SERVICE CO-OPERATIVE BANK LTD.NO.2151, VI/3, ELAMANNOOR P.O, PATHANAMTHITTA -691 524, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI -110 001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN 682 018. 3 THE INCOME TAX OFFICER, (TDS), AARATTUKULAKKARA COPLEX, A.N. PURAM, ALAPPUZHA DISTRICT, PIN 686 011. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033. 5 THE DEPUTY GENERAL MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., PATHANAMTHITTA DISTRICT OFFICE, PATHANAMTHITTA , PIN 689 645. 2025:KER W.P(C)No.7053/2023 & Connected cases 476 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 477 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 12759 OF 2022 PETITIONER/S: 1 PUTHIYATHERU URBAN CO-OPERATIVE SOCIETY LTD NO.C-1661 PUTHIYATHERU, P.O.CHIRAKKAL, KANNUR-670011, REPRESENTED BY ITS SECRETARY SUJITH KUMAR P.P. 2 CHAKKARAKKAL URBAN CO-OPERATIVE SOCIETY LTD NO.C 1564, CHAKKARAKKAL, P.O.MOWANCHERY, KANNUR-670594, REPRESENTED BY ITS SECRETARY SASIKUMAR T.K. 3 PAPPINISSERI URBAN CO-OPERATIVE SOCIETY LTD NO.C 1557, JAMEEL COMPLEX, NR RAILWAY GATE, P.O.PAPPINISSERI, KANNUR-670561, REPRESENTED BY ITS SECRETARY SOBHANA K. 4 TALIPARAMBA CO-OPERATIVE URBAN SOCIETY LTD. NO. C 1559, COURT ROAD, TALIPARAMBA, P.O.TALIPARAMBA, KANNUR- 670141, REPRESENTED BY ITS SECRETARY PADMARAJAN E. 5 ALAKODE URBAN CO-OPERATIVE SOCIETY LTD NO.C 1579, ALAKODE, P.O.KANNUR-670571, REPRESENTED BY ITS SECRETARY BIBIN THOMAS. 6 EDAKKAD URBAN CO-OPERATIVE SOCIETY LTD NO.C 1725, P.O.KADACHIRA, KANNUR-670621, REPRESENTED BY ITS SECRETARY RAJALAKSHMI T.O. 7 MATTANUR URBAN CO-OPERATIVE SOCIETY LTD NO.C 1563, MATTANUR, MATTANUR P.O., KANNUR-670702, REPRESENTED BY ITS SECRETARY SHANIL KUMAR K. 2025:KER W.P(C)No.7053/2023 & Connected cases 478 8 PILATHARA CO-OPERATIVE URBAN SOCIETY LTD. NO. C 1558, BUS STAND, PILATHARA, KANNUR-670504, REPRESENTED BY ITS SECRETARY SURENDRANATH P.V. 9 KAMBIL URBAN CO-OPERATIVE SOCIETY LTD NO.1561, KAMBIL, KOLACHERY P.O., KANNUR-670601, REPRESENTED BY ITS SECRETARY AJAYAKUMAR K. 0 PUNALUR URBAN CO-OPERATIVE SOCIETY LTD NO. Q 1508, T.B.JUNCTION, VALACODU P.O., PUNALUR, KOLLAM-691331, REPRESENTED BY ITS SECRETARY ROSHNI R. 11 THALASSERY URBAN CO-OPERATIVE SOCIETY LTD NO.C 1719, MG BAZAR, OLD BUS STAND, THALASSERY, KANNUR-670101, REPRESENTED BY ITS SECRETARY SREEJA K. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 479 INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 480 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13011 OF 2022 PETITIONER/S: KERALA PRIMARY CO-OPERATIVE SOCIETIES ASSOCIATION, DISTRICT COMMITTEE, KOZHIKODE, REPRESENTED BY ITS SECRETARY, ARAVINDAKSHAN E., AGED 70 YEARS, S/O. RAMUNNI NAMBIAR, SOORYAKANDI P.O., MEPPAYIL, VADAKARA, KOZHIKODE-673104. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELH-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, 2025:KER W.P(C)No.7053/2023 & Connected cases 481 KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LIMITED, PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 482 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13047 OF 2022 PETITIONER/S: COCHIN NAVAL BASE CONSUMER COOPERTAIVE SOCIETY LTD MO. E-161 AGED 42 YEARS NAVAL BASE COMPOUND OLD NH47 KOCHI -682004 REPRESENTED BY ITS SECRETARY AJESH KUMAR BY ADVS. SHRI.ARUN V.G. (K/795/2004) SMT.V.JAYA RAGI SHRI.R.HARIKRISHNAN (KAMBISSERIL) SRI.NEERAJ NARAYAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, 2025:KER W.P(C)No.7053/2023 & Connected cases 483 KOCHI, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 THE KERALA STATE CO-OPERATIVE BANK LTD ERNAKULAM MAIN BRANCH ,CHITTUR ROAD ,PULLEPADY ROAD KOCHI, REPRESENTED BY ITS MANGER., PIN - 682035 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. SRI.CHRISTOPHER ABRAHAM SRI.N.RAGHURAJ, SC, HIGH POWER COMMITTEE FOR SABARIMALA, TRAVANCORE DEVASWOM BOARD CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 484 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13114 OF 2022 PETITIONER/S: 1 JANATHA SERVICE CO-OPERATIVE BANK LTD NO. 1042, V. KOTTAYAM P.O., PATHANAMTHITTA DISTRICT-689656, REPRESENTED BY ITS SECRETARY. 2 THEKKUTHODE SERVICE CO-OPERATIVE BANK LIMITED NO. P.T.48, THEKKUTHODE P.O., PATHANAMTHITTA DISTRICT-689699, REPRESENTED BY ITS SECRETARY. 3 CHENGARA SERVICE CO-OPERATIVE BANK LIMITED NO.3137, CHENGARA P.O., MALAYALAPPUZHA ERAM, PATHANAMTHITTA DISTRICT-689664, REPRESENTED BY ITS SECRETARY. 4 VAKAYAR SERVICE CO-OPERTIVE BANK LIMITED NO.847, VAKAYAR P.O., KONHI, PATHANAMTHITTA DISTRICT-689698, REPRESENTED BY ITS SECRETARY. BY ADV SRI.S.SHYAM KUMAR RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, 2025:KER W.P(C)No.7053/2023 & Connected cases 485 NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, COCHIN-682018. 4 INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAM NAGAR, THRISSUR-680001. 5 THE KERALA STATE CO-OPERATIVE BANK LIMITED, P.B. NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO- OPERATION, SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 486 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13112 OF 2022 PETITIONER/S: 1 THRISSUR DISTRICT MARKETING AND PROCESSING CO- OPERATIVE SOCIETY LTD NO R 1164 THRISSUR DISTRICT, THRISSUR PIN 680001 REPRESENTED BY SECRETARY JAI JOHN THANJAN 2 THE PARIAYARAM MULTI PURPOSE CO OPERATIVE SOCIETY LTD NO. R 1186, KUTTIKKAD PO, THRISSUR DISTRICT, PIN 680724 REPRESENTED BY SECRETARY SHIBY 3 WELFARE AGRICULTURAL CREDIT CO OPERATIVE SOCIETY LTD NO. R 182, ELINJIPRA PO, THRISSUR DISTRICT, THRISSUR PIN 680721 REPRESENTED BY SECRETARY PAUL E A 4 KERALA STATE SERVICE PENSIONERS CO OPERATIVE SOCIETY LTD NO. R 1218, THRISSUR DISTRICT, CHALAKKUDY PIN 680307 REPRESENTED BY SECRETARY REBY RAPHEAL 5. CHALAKKUDY TOWN MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1256, ILARISSUR DISTRICT, CHALAKKUDI PIN 680307 REPRESENTED BY SECRETARY KISHORE KUMAR PS 6. CHALAKKUDY BLOCK MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1272, THRISSUR DISTRICT, ANAMALA JUNCTION CHALAKKUDI PIN 680307 REPRESENTED BY SECRETARY MUMTHAS SULAIMAN. 7. TIRUR MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1117, P OMG KAVU, THRISSUR DISTRICT, PIN CHALAKKUDY THRISSUR DISTRICT PIN 680022 REPRESENTED BY SECRETARY RAGI C RANGANATH 8. KOLAZHY GRAMA PANCHAYATH VANITHA CO OPERATIVE SOCIETY LTD NO. R 1319, PAMBOOR PO, KUTTUR, THRISSUR DISTRICT PIN 680013. REPRESENTED BY 2025:KER W.P(C)No.7053/2023 & Connected cases 487 SECRETARY NISHA NR 9. THE KUTTANELLUR MULTI PURPOSE CO OPERATIVE SOCIETY LTD NO. R 1330, PO KUTTANELLUR, THRISSUR DISTRICT, PIN 680014 REPRESENTED BY SECRETARY PREETHA CP 10.THE PAVARATTY SERVICE CO OPERATIVE BANK LTD NO. 3918, PO PAVARATTY, THRISSUR DISTRICT, PIN 680507 REPRESENTED BY SECRETARY RAJESH P 11. CHALAKKUDY VANITHA CO OPERATIVE SUCIETY LTD NO. R 1190, CHALAKKUDY, THRISSUR DISTRICT PIN 680307 REPRESENTED BY SECRETARY SHIJI K GEORGE 12.KODASSERY MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 4275, ELINJIPRA PO, THRISSUR DISTRICT PIN 680721 REPRESENTED BY SECRETARY LATHIKA KK 3.CHALAKKUDY TALUK VANITHA CO OPERATIVE SOCIETY LTD NO. R 1453, CHALAKKUDY, THRISSUR DISTRICT, PIN 680307 REPRESENTED BY SECRETARY SHINTU VIJAYAN K 5 CHALAKKUDY TOWN MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1256, ILARISSUR DISTRICT, CHALAKKUDI PIN 680307 REPRESENTED BY SECRETARY KISHORE KUMAR PS 6 CHALAKKUDY BLOCK MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1272, THRISSUR DISTRICT, ANAMALA JUNCTION CHALAKKUDI PIN 680307 REPRESENTED BY SECRETARY MUMTHAS SULAIMAN. 7 TIRUR MULTIPURPOSE COOPERATIVE SOCIETY LTD NO. R 1117, P OMG KAVU, THRISSUR DISTRICT, PIN CHALAKKUDY THRISSUR DISTRICT PIN 680022 REPRESENTED BY SECRETARY RAGI C RANGANATH 8 KOLAZHY GRAMA PANCHAYATH VANITHA CO OPERATIVE SOCIETY LTD NO. R 1319, PAMBOOR PO, KUTTUR, THRISSUR DISTRICT PIN 680013. REPRESENTED BY SECRETARY NISHA NR 9 THE KUTTANELLUR MULTI PURPOSE CO OPERATIVE SOCIETY LTD NO. R 1330, PO KUTTANELLUR, THRISSUR DISTRICT, PIN 680014 REPRESENTED BY SECRETARY PREETHA CP 10 THE PAVARATTY SERVICE CO OPERATIVE BANK LTD NO. 3918, PO PAVARATTY, THRISSUR DISTRICT, PIN 680507 2025:KER W.P(C)No.7053/2023 & Connected cases 488 REPRESENTED BY SECRETARY RAJESH P 11. CHALAKKUDY VANITHA CO OPERATIVE SUCIETY LTD NO. R 1190, CHALAKKUDY, THRISSUR DISTRICT PIN 680307 REPRESENTED BY SECRETARY SHIJI K GEORGE 12.KODASSERY MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 4275, ELINJIPRA PO, THRISSUR DISTRICT PIN 680721 REPRESENTED BY SECRETARY LATHIKA KK 3.CHALAKKUDY TALUK VANITHA CO OPERATIVE SOCIETY LTD NO. R 1453, CHALAKKUDY, THRISSUR DISTRICT, PIN 680307 REPRESENTED BY SECRETARY SHINTU VIJAYAN K 11 CHALAKKUDY VANITHA CO OPERATIVE SUCIETY LTD NO. R 1190, CHALAKKUDY, THRISSUR DISTRICT PIN 680307 REPRESENTED BY SECRETARY SHIJI K GEORGE 12 KODASSERY MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 4275, ELINJIPRA PO, THRISSUR DISTRICT PIN 680721 REPRESENTED BY SECRETARY LATHIKA K K 13 CHALAKKUDY TALUK VANITHA CO OPERATIVE SOCIETY LTD NO. R 1453, CHALAKKUDY, THRISSUR DISTRICT, PIN 680307 REPRESENTED BY SECRETARY SHINTU VIJAYAN K 14 THE VATTEKKAD SERVICE CO OPERATIVE BANK LTD NO. 1594, R 1256, VARTEKKAD, THRISSUR DISTRICT PIN 680512 REPRESENTED BY SECRETARY N K PRASAD 15 KORATTY MEGHALA VANITHA CO OPERATIVE SOCIETY LTD NO R 1334, KORATTY, THRISSUR DISTRICT PIN 680 308 REPRESENTED BY SECRETARY MAYA P V 16 MOONNUMURY MEGHALA VANITHA CO OPERATIVE SOCIETY LTD NO. 1118, MATTATHUR PO, THRISSUR DISTRICT PIN 680684 REPRESENTED BY SECRETARY SIJI. J 17 KAIPAMANGALAM FISHERMEN'S CO-OPERATIVE SOCIETY LTD NO.2941, KAIPAMANGALAM P.O, THRISSUR DISTRICT PIN 680681 2025:KER W.P(C)No.7053/2023 & Connected cases 489 REPRESENTED BY SECRETARY ALMANUJAN 18 VARANDARAPPILLY KARSHIKETHARA VIKASANA CO OPERATIVE SOCIETY LTD NO. R 1414, VARANDARAPPILLY PO, THRISSUR DISTRICT PIN 680303 REPRESENTED BY SECRETARY NISHA THOMAS T. 19 PUDUKKAD VYAPARI VYAVASAYI CO OPERATIVE SOCIETY LTD NO. R 1153, PUDUKAD PO, THRISSUR DISTRICT PIN 680301 REPRESENTED BY SECRETARY SUNDARAN T V 20 ADAT PANCHAYATH MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 1127, MUTHUVARA, PUZHAKKAL P O, THRISSUR DISTRICT PIN 680553 REPRESENTED BY SECRETARY SIJO JOSE C. 21 KOTTEKKAD PEOPLES WELFARE CO OPERATIVE SOCIETY LTD NO. R 1420, KOTTEKKAD, KUTTOOR PO, THRISSUR DISTRICT PIN 680022 REPRESENTED BY SECRETARY MARY LEENA M F 22 KARAYAVATTAM SERVICE COOPERATIVE BANK LTD NO. F 793, KARAYAVATTAM PO, THRISSUR DISTRICT PIN 680567 REPRESENTED BY SECRETARY P D SINDHU 23 THIRUVATHRA SERVICE CO OPERATIVE BANK LTD NO. F 889, THIRUVATHRA P O, THRISSUR DISTRICT PIN 680516 REPRESENTED BY SECRETARY BINITHA P B 24 GURUVAYUR DEVASWOM EMPLOYEES CO OPERATIVE SOCIETY LTD NO. R 794, GURUVAYUR PO, THRISSUR DISTRICT PIN 680101 REPRESENTED BY SECRETARY BIJI T P. 25 PERINGOTTUKARA KARSHIKETHARA VIKASANA SAHAKARANA SANGHAM LTD NO. R 1418, PERINGOTTUKARA PO, THRISSUR DISTRICT PIN 680565 REPRESENTED BY SECRETARY ABHITHA N S. 26. THANIYAM PRIYADARSINI VANITHA CO OPERATIVE SOCIETY LTD NO. R 1122, KIZHAKKUMMURI PO, PIN 680571 REPRESENTED BY SECRETARY SHANILA A 27.PERINGOTTUKARA SOCIAL WELFARE CO OPERATIVE SOCIETY LTD NO R 1403, THRISSUR DISTRICT, PIN - 680565 REPRESENTED BY SECRETARY 2025:KER W.P(C)No.7053/2023 & Connected cases 490 RANJANA K RAMACHANDRAN 28.AMBALLUR TOWN CO OPERATIVE SOCIETY LTD NO. R 1356, ALAGAPPANAGAR PO, THRISSUR DISTRICT PIN 680302 REPRESENTED BY SECRETARY SEENA BIJOY 29.ANTHIKKAD BLOCK MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 1128, PAZHUVIL PO, THRISSUR DISTRICT PIN 680564 REPRESENTED BY SECRETARY REJI NV 26 THANIYAM PRIYADARSINI VANITHA CO OPERATIVE SOCIETY LTD NO. R 1122, KIZHAKKUMMURI PO, PIN 680571 REPRESENTED BY SECRETARY SHANILA A 27 PERINGOTTUKARA SOCIAL WELFARE CO OPERATIVE SOCIETY LTD NO R 1403, THRISSUR DISTRICT, PIN - 680565 REPRESENTED BY SECRETARY RANJANA K RAMACHANDRAN 28 AMBALLUR TOWN CO OPERATIVE SOCIETY LTD NO. R 1356, ALAGAPPANAGAR PO, THRISSUR DISTRICT PIN 680302 REPRESENTED BY SECRETARY SEENA BIJOY 29 ANTHIKKAD BLOCK MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 1128, PAZHUVIL PO, THRISSUR DISTRICT PIN 680564 REPRESENTED BY SECRETARY REJI N V 30 THRISSUR BANK EMPLOYEES CO-OPERATIVE SOCIETY LTD NO.R 700 MACHINGAL LANE , THRISSUR MAIN POST OFFICE, THRISSUR- 680001 REPRESENTED BY ITS SECRETARY INCHARGE VINOD KUMAR K R 31 GRAMAVIKASANA MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 1211, MULANKUNNATHUKAVU, THRISSUR DISTRICT PIN 680581 REPRESENTED BY SECRETARY SUDHA A A. 32 THRISSUR DISTRICT SERVICE PENSIONERS WELFARE CO OPERATIVE SOCIETY LTD NO. R 1506. AYYANTHOLE PO, THRISSUR DISTRICT PIN 680003 REPRESENTED BY SECRETARY DHANYA G MENON. 33 KALLETTUMKARA SERVICE CO OPERATIVE BANK LTD NO. 141, KALLETTUMKARAPO, THRISSUR DISTRICT, PIN 680683. 2025:KER W.P(C)No.7053/2023 & Connected cases 491 REPRESENTED BY SECRETARY K, LASHES 34 THOLUR PANCHAYATH MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 1154 , PARAPPORU, THRISSUR DISTRICT PIN 680552 REPRESENTED BY SECRETARY JOISY P J. 35 KODAKARA AND MATTATHUR CO OPERATIVE SOCIAL WELFARE MULTIPURPOSE SOCIETY LTD NO. R 1215, KODAKARA PO, THRISSUR DISTRICT PIN 680684 REPRESENTED BY SECRETARY SUGANDHI S M 36 THE KATTOOR SERVICE CO OPERATIVE BANK LTD NO. 426, KATTOOR PO, THRISSUR DISTRICT PIN 680702 REPRESENTED BY SECRETARY VIJAYAKUMAR T V 37.DEEPAM WOMENS CO OPERATIVE SOCIETY LTD NO. R 1247, KODAKARA P O, THRISSUR DISTRICT PIN 680684 REPRESENTED BY SECRETARY REKHA P S 37 DEEPAM WOMENS CO OPERATIVE SOCIETY LTD NO. R 1247, KODAKARA P O, THRISSUR DISTRICT PIN 680684 REPRESENTED BY SECRETARY REKHA P S 38 PUBLIC SOCIAL WELFARE CO OPERATIVE SOCIETY LTD NO. R 1475, CHALAKKUDY PO, THRISSUR DISTRICT PIN 680307 REPRESENTED BY HONORARY SECRETARY A L DEVASSY. P 39 VADANAPPALLY SERVICE CO OPERATIVE BANK LTD NO. F 211, THRITHALLUR O, THRISSUR DISTRICT PIN 680619 REPRESENTED BY SECRETARY BIJU M V 40 PULAKKODE SERVICE CO OPERATIVE BANK LTD NO. R 185, PULAKODE PO, THRISSUR DISTRICT, PIN 680586 REPRESENTED BY SECRETARY JACOB GEORGE. 41 KONDAZHY KARSHIKETHARA SAHAKARANA SANGHAM LTD. NO. R 4274, KONDAZHY PO, THRISSUR DISTRICT. PIN 679106 REPRESENTED BY SECRETARY SUMOD M S. BY ADVS. SHRI.C.A.JOJO 2025:KER W.P(C)No.7053/2023 & Connected cases 492 SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA , REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018 3 THE INCOME TAX OFFICER (TDS) AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR, PIN 680 001 4 THE KERALA STATE CO-OEPRATIVE BANK LTD (ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK) ] SAHAKARANA SAPTHATDHI MANDIRAM, TUDA ROAD, THIRUVAMBADI P.O, THRISSUR, PIN 680 022 REPRESENTED BY ITS GENERAL MANAGER 5 THE GENERAL MANAGER THRISSUR URBAN CO-OPERATIVE BANK LTD, HEAD OFFICE, MISSION QUARTERS, THRISSUR 680 001 6 THE GENERAL MANAGER IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD , TANA JUNCTION, IRINJAKUDA P.O, PIN 680 121 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.C.D.DILEEP,SC,TRICHUR URBN CO-OPBAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 493 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13171 OF 2022 PETITIONER/S: 1 PADY NEKRAJE VILLAGE VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 302, PAIKA P.O., NEKRAJE, KASARAGOD- 671544, REPRESENTED BY ITS SECRETARY RAMAKRISHNA P.K. 2 MULIYAR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 230, IRIYANI P.O., MULIYAR, KASARAGOD-671542, REPRESENTED BY ITS SECRETARY K.P.GANGADHARAN. 3 THE KASARAGOD AGRICULTURAL MARKETING AND PROCESSING CO-OPERATIVE SOCIETY LTD. NO. S 395, BADIADKA, PERADALA P.O., KASARAGOD-671551, REPRESENTED BY ITS SECRETARY PRIYA K. 4 THE KASARAGOD ARTISAN'S DEVELOPMENT & WELFARE CO- OPERATIVE SOCIETY LTD. NO. S 530, S.M.S.CENTRE, NAYAKS ROAD, KASARAGOD-671121, REPRESENTED BY ITS SECRETARY VIJAYA R. 5 THE KUTTIKOL URBAN CO-OPERATIVE SOCIETY LTD. NO. S 347, PADUPPU P.O., SHANKARAMPADY, CHENGALA VIA, KASARAGOD -671541, REPRESENTED BY ITS SECRETARY TINCY P.T. 6 THE KANHANGAD VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 263, PADANAKKAD, KASARAGOD-671314, REPRESENTED BY ITS SECRETARY GIRIJA O. 7 THE CHENGALA AGRICULTURAL WELFARE CO-OPERATIVE 2025:KER W.P(C)No.7053/2023 & Connected cases 494 SOCIETY LTD. NO. S 375, PADY ROAD, CHERKALA P.O., CHENGALA, KASARAGOD-671541, REPRESENTED BY ITS SECRETARY MURALEEDHARAN K. 8 CHIRAYINKEEZHU BLOCK RURAL DEVELOPMENT CO-OPERATIVE SOCIETY LTD. NO.T 1636, CHIRAYINKEEZHU P.O., THIRUVANANTHAPURAM-695304, REPRESENTED BY ITS SECRETARY GEETHA SIDHARTH. 9 KUMBADAJE AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 409, MARPANADKA, KUMBADAJE P.O., KASARAGOD-671551, REPRESENTED BY ITS SECRETARY ASHAKUMARI K. 10 DELAMPADY AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO.S 393, ADOOR, URDOOR P.O., KASARAGOD -671543, REPRESENTED BY ITS SECRETARY SEEMA C. 11 BETHARPARA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 316, BETHURPARA, VATTAMTHATTA P.O., KASARAGOD -671542, REPRESENTED BY ITS SECRETARY KRISHNAN NAIR A. 12 THE CHENGALA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 407, CHERKALA, CHENGALA P.O., KASARAGOD -671541, REPRESENTED BY ITS SECRETARY MADHUSOODHANAN V. 13 KASARAGOD VYAPARI VYAVASAI WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 477, DISTRICT VYAPARA BHAVAN, A.T.ROAD, KASARAGOD -671121, REPRESENTED BY ITS SECRETARY ANITHA K. 14 THE KASARAGOD DISTRICT PRIVATE MOTOR EMPLOYEES WELFARE CO-OPERATIVE SOCIETY LTD. NO.S 68, NAYAKS ROAD, KASARAGOD -671121, REPRESENTED BY ITS SECRETARY BINDU C.P. 15 ADOOR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO.S 295, ADOOR, URDOOR P.O., KASARAGOD-671543, REPRESENTED BY ITS SECRETARY SUPRITHA M. 2025:KER W.P(C)No.7053/2023 & Connected cases 495 16 SREE NARAYANA GURU VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 543, CITY CENTRE, IIND FLOOR, BANK ROAD, KASARAGOD - 671121, REPRESENTED BY ITS SECRETARY SWAPNA B. 17 THE KASARAGOD-KARADKA BLOCK VANITHA SERVICE CO- OPERATIVE SOCIETY LTD. NO. C 963, NULLIPADY, KASARAGOD -671121, REPRESENTED BY ITS SECRETARY SHEEJA P. 18 THE MUNNAD VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. S 268, PALLATHINGAL, MUNNAD P.O., KASARAGOD -671541, REPRESENTED BY ITS SECRETARY SREEDEVI K.M. 19 KASARAGOD DISTRICT PRINTING & PUBLISHING CO-OPERATIVE SOCIETY LTD. NO. S 58, INDUSTRIAL ESTATE, VIDYANAGAR P.O., KASARAGOD - 671123, REPRESENTED BY ITS SECRETARY THAMARAKSHAN V. 20 KADAKAM VANITHA SERVICE SAHAGARANA SANGAM, KARADKA P.O., KASARAGOD-671542, REPRESENTED BY ITS SECRETARY KUNHIRAMAN T. 21 THE KARADKA PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 528, GG ROAD, MULLERIA P.O., KASARAGOD -671543, REPRESENTED BY ITS SECRETARY SUDHEESH KUMAR A. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 496 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADV SHRI.M.SASINDRAN THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 497 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13184 OF 2022 PETITIONER/S: 1 THE ADHYAPAKA SERVICE CO-OPERATIVE BANK LTD. NO. A-300, PUTHUSSERY P.O, KALLOOPARA, PATHANAMTHITTA - 689602, REPRESENTED BY ITS SECRETARY, SHRI.ALEX ISSAC. 2 RANNI SERVICE CO-OPERATIVE BANK LTD. NO. 65, RANNI P.O, PATHANAMTHITTA - 679672, REPRESENTED BY ITS SECRETARY, SMT. SOOSAN K. THOMAS. 3 ANGADI SERVICE CO-OPERATIVE BANK LTD NO. 2270, ANGADI P.O, RANNY, PATHANAMTHITTA - 689674, REPRESENTED BY ITS SECRETARY SHRI. SANOJ N. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI - 682018. 3 THE INCOME TAX OFFICER (TDS), THIRUVALLA CIRCLE, THIRUVALLA RANGE, T.K. ROAD, THIRUVALLA, PIN - 689101. 2025:KER W.P(C)No.7053/2023 & Connected cases 498 4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE PATHANAMTHITTA SERVICE CO-OPERATIVE BANK), REGIONAL OFFICE, ALAPPUZHA, P.B. NO. 104, OPP. MUNICIPAL TOWN HALL, PIN - 688011, REPRESENTED BY ITS REGIONAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 499 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13339 OF 2022 PETITIONER/S: THE ADVOCATES CO-OPERATIVE SOCIETY LTD. NO. R-1177 CHAVAKKAD POST, CHAVAKKAD TALUK, THRISSUR, PIN- 680506, REPRESENTED BY ITS SECRETARY K.S REKHA AGED 37 YEARS, W/O. SIVADASAN, KUNJIKONNAN HOUSE, BLANGAD, CHAVAKKAD TALUK, THRISSUR - 680506. BY ADVS. SRI.RAJIT SRI.V.V.JOY RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), C.R. BUILDING, I.S. PRESS ROAD, KOCHI - 682018. 3 THE INCOME TAX OFFICER (TDS), C.R. BUILDINGS, I.S. PRESS ROAD, KOCHI - 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE THE THRISSUR DISTRICT CO-OPERATIVE BANK), KOLOTHUMPADAM P.O, THRISSUR - 680001, REPRESENTED BY THE GENERAL MANAGER. 2025:KER W.P(C)No.7053/2023 & Connected cases 500 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 501 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13303 OF 2022 PETITIONER/S: THE THIRUVAZHIYODE TRADERS DEVELOPMENT CO-OPERATIVE SOCIETY LTD. NO. P 1421, P.O. THIRUVAZHIYODE, PALAKKAD DISTRICT, KERALA 679 514, REPRESENTED BY ITS SECRETARY, SMT. JYOTHILEKSHMI. BY ADVS. SRI.K.ANAND SHRI.BENNY ANTONY PAREL SHRI.AMEER SALIM RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN 682 018. 4 THE KERALA BANK, 2025:KER W.P(C)No.7053/2023 & Connected cases 502 (THE KERALA STATE CO-OPERATIVE BANK LTD.), COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD.), REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET, PALAKKAD 678 001. 6 THE KERALA BANK , (THE KERALA STATE CO-OPERATIVE BANK LTD.), SREEKRISHNAPURAM BRANCH, PALAKKAD 679 513. REP. BY GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 503 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13305 OF 2022 PETITIONER/S: THE THIRUNARAYANAPURAM VANITHA CO-OPERATIVE CREDIT SOCIETY LTD. P. 1190 THIRUVAZHIYODE P.O, PALAKKAD DISTRICT, KERALA 679 514 REPRESENTED BY ITS SECRETARY, SMT SHEEJA K BY ADVS. SRI.K.ANAND SHRI.BENNY ANTONY PAREL SHRI.AMEER SALIM RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 REPRESENTED BY SECRETARY 3 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM, PIN 682 018 4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD) 2025:KER W.P(C)No.7053/2023 & Connected cases 504 COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695 033 REPRESENTED BY ITS MANAGING DIRECTOR 5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD) REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET, PALAKKAD 678 001 REPRESENTED BY GENERAL MANAGER 6 THE KERALA BANK(THE KEREALA STATE CO-OEPRATIVE BANK LTD) SREEKRISHNAPURAM BRANCH, PALAKKAD 679 513 REPRESENTED BY GENERAL MANANGER BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 505 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13318 OF 2022 PETITIONER/S: KODUKULANJI SERVICE CO-OPERATIVE BANK LTD NO.A.341, KODUKULANJI, ALAPPUZHA DISTRICT, PIN-689508, REPRESENTED BY SECRETARY IN-CHARGE. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, I.S PRESS ROAD, KOCHI-682018. 2 THE COMMISSIONER OF INCOME TAX (TDS) C R BUILDING, I.S PRESS ROAD, KOCHI-682018. 3 THE KERALA STATE CO-OPERATIVE BANK LTD. (ERSTWHILE ALAPPUZHA DISTRICT SERVICE CO-OPERATIVE BANK), REGIONAL OFFICE, P B NO.102, OPP MUNICIPAL TOWN HALL, ALAPPUZHA, PIN-688011, REPRESENTED BY ITS REGIONAL MANAGER. 4 THE REGISTRAR OF CO-OPERATIVE SOCIEITIES JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P O, THIRUVANANTHAPURAM-695014. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 506 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 507 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13358 OF 2022 PETITIONER/S: 1 TRIVANDURM DISTRICT JOB WORKER'S CO-OPERATIVE SOCIETY LTD NO.T 735 KARIKKAKOM, BEACH P.O., THIRUVANANTHAPAURAM DISTRICT, KERALA, PIN - 695 007 REPRESENTED BY ITS SECRETARY. 2 KERALA STATE COMMERCIAL TAX DEPARTMENT STAFF HOUSING CO-OPERATIVE SOCIETY LTD. NO.4385, HEAD OFFICE, TAX TOWERS, 3RD FLOOR, KALLIPPALAM, KARAMANA P.O., THIRUVANANTHAPURAM - 695 002 REPRESENTED BY ITS SECRETARY. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 11000. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG., IS PRESS ROAD, KOCHI - 682 018. 3 THE INCOME TAX OFFICER (TDS) 3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695 003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 508 HEAD OFFICE, COBANK TOWERS, PALAYAM, AIRPORT ROAD, THIRUVANANTHAPURAM - 695 033 REPRESENTED BYITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 509 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13364 OF 2022 PETITIONER/S: 1 THE PRAMADOM SERVICE CO-OPERATIVE BANK LIMITED NO.534 MALLASSERY P.O., PATHANAMTHITTA DISTRICT-689646, REPRESENTED BY ITS SECRETARY. 2 THE KALANJOOR SERVICE CO-OPERATIVE BANK LIMITED NO.1019, KALANJOOR P.O., PATHANAMTHITTA DISTRICT-689645, REPRESENTED BY ITS SECRETARY. 3 THE ATHIRUMKAL SERVICE CO-OPERATIVE SOCIETY LIMITED NO.PT 54, ALTHRUMKAL PO, PATHANAMTHITTA DISTRICT-689643, REPRESENTED BY ITS SECRETARY. 4 THE KONNI REGIONAL CO-OPERATIVE BANK LIMITED NO.3833, KONNI P.O., PATHANAMTHITTA DISTRICT-689647, REPRESENTED BY ITS SECRETARY. 5 THE MALAYALAPUZHA SERVICE CO-OPERATIVE BANK LIMITED NO.Q 378, THAZHAM PO, PATHANAMTHITTA DISTRICT-689699, REPRESENTED BY ITS SECRETARY. 6 THE ELAKOLLOOR SERVICE CO-OPERATIVE BANK LIMITED NO.459, ELAKOLLOOR P.O., PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, -689644. BY ADV SRI.O.D.SIVADAS 2025:KER W.P(C)No.7053/2023 & Connected cases 510 RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 3 THE INCOME TAX OFFICER, (TDS), AARATTUKULAKKARA COPLEX, A.N.PURAM, ALAPPUZHA DISTRICT-686011. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN-695033. 5 THE DEPUTY GENERAL MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., PATHANAMTHITTA DISTRICT OFFICE, PATHANAMTHITTA, PIN-689645. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 511 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13410 OF 2022 PETITIONER/S: MUVATTUPUZHA SAMOOHYA KSHEMA CO0OPERATIVE SOCIETY LTD.NO..E.1348. T B.ROAD, MUVATTUPUZHA P O, ERNAKULAM-686661, REPRESENTED BY SECRETARY JANARDHANAN. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-11000 2 THE COMMISSIONER OF INCOME TAX C R BUILDING, I S PRESS ROAD, KOCHI-682018. 3 INCOME TAX OFFICER C R BUILDING, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. (ERSTWHILE THE ERNAKULAM DISTRICT CO-OPERATIVE BANK) KAKKANAD P O, KOCHI-682030, REPRESENTED BY THE GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 512 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 513 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13439 OF 2022 PETITIONER/S: 1 PATHANAMTHITTA SERVICE CO-OPERATIVE BANK LTD. NO. Q. 363, PATHANAMTHITTA P.O., PIN-689645, REPRESENTED BY ITS SECRETARY SMT. JANCY K. 2 THUMPAMON THAZHAM SERVICE CO-OPERATIVE BANK LIMITED NO.134, THUMPAMON THAZHAM P.O., ELAVAMTHITTA VIA, PATHANAMTHITTA DISTRICT-689625, REPRESENTED BY ITS SECRETARY, SMT. SHEEJA BHAI V.R. 3 MYLAPRA SERVICE CO-OPERATIVE BANK LIMITED NO.639, H.O. MYLAPRA TOWN, MYLAPRA P.O., PATHANAMTHITTA- 689678. REPRESENTED BY ITS SECRETARY, SRI. JOSHUA MATHEW. 4 AARANMULA SERVICE CO-OPERATIVE BANK LIMITED NO. A 703, H.O. NAALKALIKKAL, NAALKALIKKAL P.O., AARANMULA, PIN- 689533, REPRESENTED BY ITS SECRETARY, SMT. GAYATHRIDEVI V.R. BY ADVS. SHRI.A.KUMAR (SR.) SHRI.P.J.ANILKUMAR SMTG.MINI(1748) SRI.P.S.SREE PRASAD SHRI.JOB ABRAHAM SHRI.AJAY V.ANAND 2025:KER W.P(C)No.7053/2023 & Connected cases 514 RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM- 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LIMITED, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA STATE CO-OPERTIVE BANK LIMITED, (ERSTWHILE PATHANAMTHITTA DISTRICT CO-OPERATIVE BANK), MYLAPRA ROAD, PATHANAMTHITTA-689645, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 515 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13492 OF 2022 PETITIONER/S: 1 THE AYALUR GRAMEENA CO-OPERATIVE CREDIT SOCIETY LTD.NO 274 AYALUR P.O., PALAKKAD-678510 REPRESENTED BY ITS SECRETARY HEMALATHAR 2 CHITTUR TALUK BUILDING & ROAD WORKERS CO-OPERATIVE SOCIETY LTD NO.P 1320 KOLLENGODE P.O., PALAKKAD-678506, REPRESENTED BY ITS SECRETARY MALATHY KRISHNAN 3 THE ELAVANCHERRY CO-OPERATIVE RURAL CREDIT SOCIETY LTD NO. P 1248 PANANGATTIRI P.O., PALAKKAD-678506 REPRESENTED BY ITS SECRETARY BABITHA B 4 THE GOVT. EMPLOYEES & AIDED SCHOOL EMPLOYEES CO- OPERATIVE HOUSING SOCIETY LTD NO.P 1080 CHITTUR P.O., PALAKKAD-678101 REPRESENTED BY ITS SECRETARY GIRISH M 5 THE PUDUNAGARAM PRIYADARSHINI VANITHA SAHAKARANA SANGAM LTD NO. P 1327 KARIPODE P.O., PALAKKAD-678503 REPRESENTED BY ITS SECRETARY SABITHA BALAKRISHNAN PB 6 THE KODUVAYUR CO-OPERATIVE URBAN CREDIT SOCIETY LTD NO.773 KODUVAYUR, PALAKKAD-678501, REPRESENTED BY ITS SECRETARY KRISHNAPRASAD P 7 THE KOLLENGODE AGRICULTURAL IMPROVEMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 516 CO-OPERATIVE SOCIETY LTD NO.P 1375, BLOCK OFFICE ROAD, KOLLENGODE, PALAKKAD-678506 REPRESENTED BY ITS SECRETARY SAJESH C 8 THE KOLLENGODE MERCHANTS CO-OPERATIVE SOCIETY LTD NO.P 1193 BLOCK OFFICE ROAD, KOLLENGODE, PALAKKAD-678506 REPRESENTED BY ITS SECRETARY A RAMLA 9 NALLEPILLY CO-OPERATIVE RURAL CREDIT SOCIETY LTD NO. P 1350 NALLEPILLY, PALAKKAD678553, REPRESENTED BY ITS SECRETARY CHENTHAMARAKSHAN M 0 THE KOLLENGODE CO-OPERATIVE URBAN CREDIT SOCIETY LTD. NO. F 1201 KOLLENGODE, PALAKKAD-678506 REPRESENTED BY ITS SECRETARY KRISHNADASAN P 11 NENMARA AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY LTD NO. P 1336 CONSUMER STORE BUILDING, M.G ROAD, NENMARA, PALAKKAD- 678508, REPRESENTED BY ITS SECRETARY K.G ELDHO 12 PALLASSANA RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO. P 1227 CHIRAKKODE, PALLASSANA P.O., PALAKKAD-678505 REPRESENTED BY ITS SECRETARY INDHU P.C 13 PALLASSANA AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY LTD NO.P 1391 CHIRAKKODE, PALLASSANA P.O., PALAKKAD-678505, REPRESENTED BY ITS SECRETARY RAJESH P 14 THE PERUVEMBA CO-OPERATIVE URBAN CREDIT SOCIETY LTD NO. P 1243 PERUVEMBA P.O., PALAKKAD-678531, REPRESENTED BY ITS SECRETARY SAJEEV N 15 PERUMATTY RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO. P 1211 VANDITHAVALAM, PALAKKAD-678534, REPRESENTED BY ITS SECRETARY SUNIL S 2025:KER W.P(C)No.7053/2023 & Connected cases 517 16 THE PUDUNAGARAM CO-OPERATIVE RURAL CREDIT SOCIETY LTD. NO. P 1218 PUDUNAGARAM P.O., PALAKKAD-678503 REPRESENTED BY ITS SECRETARY VIPIN DAS G 17 VADAVANNUR RURAL CO-OPERATIVE HOUSING SOCIETY LTD. NO. F 1485 VADAVANNUR P.O., PALAKKAD-678504, REPRESENTED BY ITS SECRETARY K RAMANADHAN. 18 VADAVANNUR RURAL CREDIT CO-OPERATIVE SOCIETY LTD. NO. P 1430 VADAVANNUR P.O., PALAKKAD-678504, REPRESENTED BY ITS SECRETARY RAMASESHAN. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, 2025:KER W.P(C)No.7053/2023 & Connected cases 518 CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 519 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13545 OF 2022 PETITIONER/S: 1 KOLLAM TALUK CO-OPERATIVE EMPLOYEE'S CO-OPERATIVE SOCIETY LTD NO. Q 934, 1ST FLOOR, CHIDANAND TOWER, OPP. KUMAR HOSPITAL, HIGH SCHOOL JN, CUTCHERRY P.O, KOLLAM- 13 REPRESENTED BY ITS SECRETARY P.J. ANIL KUMAR. 2 URUKUNNU RURAL CO-OPERATIVE SOCIETY LTD NO.Q1468, URUKUNNU P.O, KOLLAM- 691307 REPRESENTED BY ITS SECRETARY S. JAYACHANDRAN. 3 PUTHOOR RURAL CO-OPERATIVE SOCIETY, LTD. NO.Q 1399, PUTHOOR P.O, KOLLAM-691507 REPRESENTED BY ITS SECRETARY NANDAKUMAR T.G. 4 KULATHUPUZHA PANCHAYAT AGRICULTURAL IMPROVEMENT CO- OPERATIVE SOCIETY LTD. NO.Q.1606, KULATHUPUZHA P.O, KOLLAM-691310, REPRESENTED BY ITS SECRETARY IN CHARGE YESUDAS.A 5 THE OYUR RESIDENTS WELFARE CO-OPERATIVE SOCIETY, LTD. NO.Q.1504, OYUR P.O, KOTTARAKKARA, KOLLAM-691510 REPRESENTED BY ITS SECRETARY ARATHY SURESH 6 KAREEPRA REGIONAL VANITHA CO-OPERATIVE SOCIETY LTD NO. Q.1372, KAREEPRA, KUZHIMATHICADU P.O, KOLLAM-691509 REPRESENTED BY ITS SECRETARY GEETHAKUMARY.S 7 THENMALA AGRICULTURE IMPROVEMENT COOPERATIVE SOCIETY, LTD.NO.Q.1582, 2025:KER W.P(C)No.7053/2023 & Connected cases 520 EDAMON P.O, PUNALUR, KOLLAM-691307 REPRESENTED BY ITS SECRETARY SHEENA. S 8 KARAVALUR PANCHAYATH RESIDENTS SOCIAL WELFARE CO- OPERATIVE SOCIETY LTD. NO.Q.1680, KARAVALUR P.O, PUNALUR, KOLLAM-691333 REPRESENTED BY ITS SECRETARY BEENA.R. 9 YEROOR PANCHAYATH AGRICULTURAL IMPROVEMENT CO- OPERATIVE SOCIETY LTD, NO.Q.1543, YEROOR P.O, KOLLAM-691312 REPRESENTED BY ITS SECRETARY SREEJA.S. 10 VILAYIL RESIDENCE WELFARE CO-OPERATIVE SOCEITY LTD, ATTINGAL P.O., THIRUVANANTHAPURAM-695101 REPRESENTED BY ITS SECRETARY LETHA L. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI- 682018. 2025:KER W.P(C)No.7053/2023 & Connected cases 521 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001. BY ADVS. SHRI.S.VAIDYANATHAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 522 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13615 OF 2022 PETITIONER/S: 1 KOYYAM SERVICE CO-OPERATIVE BANK LTD NO.L.L.87 KOYYAM P.O, KARIMBAM VIA, KANNUR 670 142 REPRESENTED BY ITS SECRETARY ASHOKAN K 2 KOLITHATTU SERVICE CO-OPERATIVE BANK LTD NO C 406, KOLITHATTU, KUTUPUZHA, KANNUR 670 706, REPREENTED BY ITS SECRETARY NARAYANAN C.G 3 PAZHANGALAM SERVICE CO-OPERATIVE BANK LTD NO 3848, NALLILA P.O, KOLLAM 695 515 REPRESENTED BY ITS SECRETARY PATHMA V SINGH BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001 2025:KER W.P(C)No.7053/2023 & Connected cases 523 2 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 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018 4 THE KERALA STATE CO-OEPRATIVE BANK LTD PB NO 6515.CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) , GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM 695 001 BY ADVS. SHRI.S.VAIDYANATHAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 524 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13687 OF 2022 PETITIONER/S: IRINJALAKUDA CITIZEN SOCIAL WELFARE SOCIETY, R.1488 22/179, NAKKARA BUILDING, HINDI PRACHAR MANDAL ROAD, IRINJALAKUDA - 680121., REPRESENTED BY ITS SECRETARY SHIJI ROMY. BY ADVS. SRI.V.M.KRISHNAKUMAR SMT.P.R.REENA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM - 682018. 3 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, CO - BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695033, REPRESENTED BY ITS MANAGING DIRECTOR. 2025:KER W.P(C)No.7053/2023 & Connected cases 525 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 526 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13693 OF 2022 PETITIONER/S: ERNAKULAM JILLA VANITHA CO-OPERATIVE SOCIETY LTD. NO. E-1356 REPRESENTED BY ITS SECRETARY, 32/1125-A4, NARAYANEEYAM, CHATHANGATT ROAD, PALARIVATTOM, COCHIN- 680025. BY ADVS. SMT.SREEDEVI KYLASANATH SRI.ACHUTH KYLAS SRI.R.MAHESH MENON SRI.DEAGO JOHN K RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI, PIN-110001. 2 THE CENTRAL BOARD OF DIRECTOR TAXES, ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI-110001. 3 COMMISSIONER OF INCOME TAX (TDS), C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-682018. 2025:KER W.P(C)No.7053/2023 & Connected cases 527 4 STATE OF KERALA DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT, REPRESENTED BY SECRETARY TO GOVERNMENT , THIRUVANANTHAPURAM-695001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, NEAR PRESS CLUB, THIRUVANANTHAPURAM-695001. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, THIRUVANANTHAPURAM-695033. 7 DEPUTY GENERAL MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., CREDIT PROCESSING CENTRE, KAKKANAD, KOCHI-682030. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 528 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13707 OF 2022 PETITIONER/S: VADAKKEKAD MULTIPURPOSE CO-OPERATIVE SOCIETY LTD NO. R1160, VADAKKEKAD.P.O, THRISSUR-679562, REPRESENTED BY ITS SECRETARY. BY ADV SRI.V.A.VINOD RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION,MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, COCHIN-682018. 4 INCOME TAX OFFICER(TDS), OFFICE OF THE INCOME TAX OFFICE(TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 529 P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO- OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 530 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13720 OF 2022 PETITIONER/S: PUNNAYUR PANCHAYATH SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD. R 1511, EDAKKAZHIYOOR, THRISSUR - 680 515, REPRESENTED BY ITS SECRETARY. BY ADV SRI.V.A.VINOD RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, COCHIN - 682 018. 4 INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR BHAVAN, SAKATHAN THAMPURAN NAGAR, THRISSUR - 680 001. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 531 PB.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO- OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 532 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13741 OF 2022 PETITIONER/S: 1 MUTHUKULAM SERVICE CO-OPERATIVE BANK LTD. MUTHUKULAM SOUTH P.O., ALAPUZHA- 690506 REPRESENTED BY ITS SECRETARY SUBHASH KUMAR N 2 KUMARAPURAM SERVICE CO-OPERATIVE BANK LTD NO 2147, HEAD OFFICE THAMALLACKAL P.O., ALAPUZHA-690549, REPRESENTED BY ITS SECRETARY BAIJU RAMESH 3 MAHADEVIKAD SERVICE CO-OPERATIVE BANK LTD MAHADEVIKKAD P.O., KARTHIKAPPALLY, ALAPUZHA-690516, REPRESENTED BY ITS SECRETARY SASIKALAK. 4 RAMAPURAM NORTH AISWARIYAPRADAYANI SERVICE CO- OPERATIVE BANK LTD, NO 1493 KEERIKAD P.O, ALAPUZHA-690508, REPRESENTED BY ITS SECRETARY G. RATNAKUMARI AMMA 5 PALLIPAD SERVICE CO-OPERATIVE BANK LTD, NO 1744, KOTTAKKAKAM, MUTTOM P.O., HARIPAD, ALAPUZHA-690514 REPRESENTED BY ITS SECRETARY RAJALAKSHMI S. 6 CHINGOLI SERVICE CO-OPERATIVE BANK LTD, NO 12, CHINGOLI P.O., ALAPUZHA- 690532, REPRESENTED BY ITS SECRETARY YAMINE P. 7 KANDALLORE FARMERS SERVICE CO-OPERATIVE BANK LTD, NO 1410 KANDALLORE P.O. ALAPPUZHA-690535 MANAGING DIRECTOR MINIBHANU R. 2025:KER W.P(C)No.7053/2023 & Connected cases 533 8 PUTHIYAVILA SERVICE CO-OPERATIVE BANK LTD.NO631, PATTOLIMARKET P.O., ALAPPUZHA-690531 REPRESENTED BY ITS SECRETARY HARIKRISHNAN R 9 CHINGOLI SERVICE CO-OPERATIVE BANK LTD, NO 1887, CHINGOLI P.O., ALAPPUZHA- 690532 REPRESENTED BY ITS SECRETARY MANU DIVAKARAN 10 CHEPPAD SERVICE CO-OPERATIVE BANK LTD,NO A 702, CHEPPAD P.O. ALAPUZHA-690507 REPRESENTED BY ITS SECRETARY JAYAN R. 11 HARIPAD SERVICE CO-OPERATIVE BANK LTD NO 3354, HARIPAD P.O., ALAPPUZHA-690514 REPRESENTED BY ITS SECRETARY PADMAKMAR M. 12 KARTHIKAPPALY SERVICE CO-OPERATIVE BANK LTD NO 2301, KARTHIKAPPALY PO, ALAPPUZHA- 690516 REPRESENTED BY ITS SECRETARY 13 KARUVATTA SERVICE CO-OPERATIVE BANK LTD , NO 1742, KARUVATTA PO, ALAPPUZHA, 690517 REPRESENTED BY ITS SECRETARY 14 GOVT. EMPLOYEES CO.OP. BANK LTD, NO A 245, KAYAMKULAM PO, ALAPPUZHA 690502 REPRESENTED BY ITS SECRETARY R MURALI 15 KAYAMKULAM VILLAGE SERVICE CO-OPERATIVE BANK LTD, NO 1596, PERINGALA P.O. ALAPPUZHA 690559 REPRESENTED BY ITS SECRETARY BIJU R. 16 KARUVATTA SERVICE CO-OPERATIVE BANK LTD NO 2145, KARUVATTA P.O., ALAPUZHA-690517 REPRESENTED BY ITS SECRETARY DEEPA C.K. 17 PERUMPALLY SERVICE CO-OPERATIVE BANK LTD NO 1746, VALIYAZHEECKAL P.O., ALAPUZHA- 690535, REPRESENTED BY ITS SECRETARY S CHINTU 18 PULLIKANAKKU SERVICE CO-OPERATIVE BANK LTD, NO 781, PULLIKANAKU P.O., ALAPUZHA- 690537, REPRESENTED BY ITS SECRETARY KALADEVI S. 2025:KER W.P(C)No.7053/2023 & Connected cases 534 19 KAPPIL SERVICE CO-OPERATIVE BANK LTD, NO 1594, KAPPIL EAST, KRISHNAPURAM P.O. ALAPUZHA-690533 REPRESENTED BY ITS SECRETARY BEENA P. 20 PUTHUPPALLY VILLAGE SERVICE CO-OPERATIVE BANK LTD, NO 1900, HEAD OFFICE PUTHUPPALLY PUTHUPPALLY P.O., ALAPUZHA- 690527 REPRESENTED BY ITS SECRETARY P. MANILAL 21 MUTHUKULAM SERVICE CO-OPERATIVE BANK LTD NO 1741, MUTHUKULAM P.O., ALAPUZHA- 690508 REPRESENTED BY ITS SECRETARY SARITHA YESODHARAN 22 KAYAMKULAM SAHAKARANA BANK LTD, NO A 421, PALACE ROAD, KRISHNAPURAM P.O., ALAPUZHA-690533 REPRESENTED BY ITS SECRETARY AJITHAKUMARI 23 PALLIPPAD SERVICE CO-OPERATIVE SOCIETY LTD NO 1777, PALLIPPAD NORTH, PALLIPPAD P.O., ALAPUZHA-690512 REPRESENTED BY ITS SECRETARY SAAJIDA A. 24 ALAPPEY DISTRICT TRAVANCORE DEVASWOM BOARD EMPLOYEES CO. OPERATIVE SOCIETY LTD NO A 297 HARIPAD P.O., ALAPUZHA-690514 REPRESENTED BY ITS SECRETARY ASHOKKUMAR G. 25 HARIPAD GOVERNMENT SERVANT'S CO-OPERATIVE SOCEITY LTD, NO A 284 HARIPAD P.O., ALAPUZHA - 690514, REPRESENTED BY ITS SECRETARY S. GIRIJA 26 KARTHIKAALLY RURAL WELFARE CO-OPERATIVE SOCIETY LTD, NO A 1193, PUTHIYAVILA NORTH, PUTHIYAVILA P.O., ALAPUZHA - 690531 REPRESENTED BY ITS SECRETARY SUKANYA SREEKUMAR 27 MELPADOM SERVICE CO-OPERATIVE SOCIETY LTD NO 182, MELPADOM P.O., MANNAR VIA ALAPUZHA-689627 REPRESENTED BY ITS SECRETARY ANU SHIBU 28 KARUVATTA NORTH SERVICE CO-OPERATIVE SOCIETY LTD, NO 1237, KARUVATTA NORTH P.O., ALAPUZHA-690517, REPRESENTED BY 2025:KER W.P(C)No.7053/2023 & Connected cases 535 ITS SECRETARY. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI- 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM- 695001 BY ADVS. SRI.KRISHNADAS P.NAIR, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM 2025:KER W.P(C)No.7053/2023 & Connected cases 536 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 537 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13746 OF 2022 PETITIONER/S: ERATHU SERVICE CO-OPERATIVE BANK NO. 2781, CHURAKODU P.O., ADOOR, PATHANAMTHITTA 691 551, REPRESENTED BY ITS SECRETARY, GEETHAKUMARI, P., AGED 52 YEARS, W/O. PRADEEP KUMAR, CHURAKODE P.O., ADOOR, PATHANAMTHITTA 691 551. BY ADV SRI.SERGI JOSEPH THOMAS RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 11001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I. S PRESS ROAD, KOCHI 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIR, THIRUVANANTHAPURAM 695 003. 2025:KER W.P(C)No.7053/2023 & Connected cases 538 5 INCOME TAX OFFICER, (TDS), THIRUVANANTHAPURAM , 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM 695 003. BY ADVS. SRI.KRISHNADAS P.NAIR, SENIOR PANEL COUNSEL SRI.CHRISTOPHER ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 539 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13751 OF 2022 PETITIONER/S: 1 PANNIVIZHA SERVICE CO-OPERATIVE BANK LTD. NO. 891, PANNIVIZHA, ADOOR P.O., ADOOR TALUK, PATHANAMTHITTA- 691523, REPRESENTED BY ITS SECRETARY, M.J. BABU, S/O. DHARMAPALAN, AGED 52 YEARS, DEEPAM HOUSE, PANNIVIZHA, ADOOR TALUK, PATHANAMTHITTA-691523. 2 PARAKODE SERVICE CO-OPERATIVE BANK LIMITED NO. 821, PARAKODE P.O., ADOOR, PATHANAMTHITTA-691554, REPRESENTED BY ITS SECRETARY, RAJASHREE, W/O. SASIDHARA KURUP, AGED 57 YEARS, VYSHAGAM HOUSE, PARAKODE, ADOOR, PATHANAMTHITTA -691554. 3 NEDUMON SERVICE CO-OPERATIVE BANK LIMITED NO.2720, NEDUMON P.O., PATHANAMTHITTA-691556, REPRESENTED BY ITS SECRETARY K.P. HUSSAIN, AGED 56 YEARS, S/O. ZAKEER RAWTHER, SHAHANA MANZIL, NEDUMON P.O., EZHAMKULAM, PATHANAMTHITTA-691556. 4 PERINGANADU SERVICE CO-OPERATIVE BANK NO. 2706, PERINGANADU P.O., ADOOR, PATHANAMTHITTA-691551, REPRESENTED BY ITS SECRETARY, BIJI B. KRISHNAN, AGED 51 YEARS, W/O.D. UDAYAN, ELAYASSERYIL, KUNNATHUMKARA, PERINGANADU P.O., ADOOR, PATHANAMTHITTA-691551. 5 KODUMON SERVICE BANK NO.2592, KODUMON P.O., ADOOR, PATHANAMTHITTA-691555, REPRESENTED BY ITS SECRETARY, T.K. TULASIDHARAN, AGED 51 YEARS, S/O. A. KOCHURAMAN, THULASI BHAVAN, AICKADU, KODUMON P.O., ADOOR, PATHANAMTHITTA-691555. 6 PAZHAKULAM PADINJARU CO-OPERATIVE BANK NO. P.T.95, 2025:KER W.P(C)No.7053/2023 & Connected cases 540 PAZHAKULAM P.O., ADOOR, PATHAMAHTITTA-691527, REPRESENTED BY ITS SECRETARY, P. BEENAKUMARI, AGED 49 YEARS, W/O. HARSHA KUMAR, PERUMANA HOUSE, PAZHAKULAM P.O., ADOOR, PATHANAMTHITTA-691527. 7 PARANTHAL SERVICE CO-OPERATIVE BANK NO.A202, PARANTHAL P.O., PATHANAMTHITTA-689501, REPRESENTED BY ITS SECRETARY, GEETHADEVI, AGED 57 YEARS, W/O. K. MOHANAN, SREENIKETAN, PERUMPULLIKAL, MANNAM NAGAR P.O., PANDALAM, PATHANAMTHITTA-689501. 8 ANGADICKAL SERVICE CO-OPERATIVE BANK NO.1127, ANGADICKAL P.O., KODUMON, PATHANAMTHITTA-691555, REPRESENTED BY ITS SECRETARY, SHEEJA G., AGED 45 YEARS, W/O. N. VIJAYAKUMAR, KALLUMPURATHU THEKKETHIL, ANGADICKAL P.O., KODUMON, PATHANAMTHITTA-691555. 9 MANNADY SERVICE CO-OPERATIVE BANK LIMITED NO.3849, MANNADY P.O., KADAMPANADU, PATHANAMTHITTA-691530, REPRESENTED BY ITS SECRETARY, ANILKUMAR K., AGED 51 YEARS, S/O. KUTTAN PILLAI, EDASSERU AZHIKATHU HOUSE, MANNADY P.O., KADAMPANADU, PATHANAMTHITTA DISTRICT- 691530. 10 KADAMPANDU NORTH SERVICE CO-OPERTIVE BANK NO.55, KADAMPANADU P.O., PATHANAMTHITTA-691552, REPRESENTED BY ITS SECRETARY, ANIL SAMUEL, AGED 40 YEARS, S/O. SAMUEL, ANIL BHAVAN, KADAMPANADU P.O., PATHANAMTHITTA-691552. 11 PANDALAM SERVICE CO-OPERATIVE BANK LIMITED NO.704, PANDALAM P.O., PATHANAMTHITTA-689501, REPRESENTED BY ITS SECRETARY IN CHARGE, ANILKUMAR P.G., AGED 57 YEARS, S/O. GOPALAPILLAI, PARAPALLIKANDATHIL, MANGARAM P.O., PANDALAM, PATHANAMTHITTA-689501. 12 ADOOR TALUK SENIOR CITIZENS SERVICE CO-OPERATIVE SOCIETY PT 268, PARAKODE P.O., PATHANAMTHITTA-691554, REPRESENTED BY ITS SECRETARY, S. SARITHA, AGED 33 YEARS, W/O. RANJARAJ, AISWARYA HOUSE, PUTHUSHERRY BHAGOM, ERATHU P.O., PATHANAMTHITTA-691551. 13 THATTAYIL SERVICE CO-OPERATIVE BANK LIMITED NO.442, 2025:KER W.P(C)No.7053/2023 & Connected cases 541 KEEZHUKUZHI P.O., PATHANAMTHITTA-689502, REPRESENTED BY ITS SECRETARY, SREEDEVI C., AGED 47 YEARS, W/O. AJITHKUMAR, NEDUMPARAMBIL, BHAGAVATHIKUNNU, KEEZHUKUZHI P.O., PATHANAMTHITTA-689502. 14 THUMPAMOM SERVICE CO-OPERATIVE BANK LIMITED NO.154, THUMPAMON P.O., PATHANAMTHITTA-689502, REPRESENTED BY ITS SECRETARY, OMANA M., AGED 53 YEARS, W/O. BABU SAMUEL, VILAVANTAGUE HOUSE, THUMPAMOM THAZHOM P.O., PATHANAMTHITTA-689625. 15 KADAMPANAD SERVICE CO-OPERATIVE BANK LIMITED NO.59, KADAMPANAD SOUTH P.O., PATHANAMTHITTA-691523, REPRESENTED BY ITS SECRETARY, R. SURESH KUMAR, AGED 57 YEARS, S/O. RAMAKRISHNA PILLAI, KUMBAZHATHEKKETHIL HOUSE, KADAMPANAD SOUTH P.O., PATHANAMTHITTA-691523. BY ADV SRI.K.SHAJ RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, 2025:KER W.P(C)No.7053/2023 & Connected cases 542 KOWDIAR, THIRUVANANTHAPURAM-695003. 6 THE KERALA CO-OPERATIVE BANK LIMITED PB NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 543 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13760 OF 2022 PETITIONER/S: 1 THE KASARAGOD DISTRICT POSTAL EMPLOYEES CO-OPERATIVE SOCIETY LTD NO. S 53 KASARAGOD -671121, REPRESENTED BY ITS SECRETARY BABY PRASANNA. 2 KASARAGOD DISTRICT TELECOM & BSNL EMPLOYEES CO- OPERATIVE SOCIETY LTD. NO.S 26, TELEPHONE BHAVAN, KASARAGOD-671121, REPRESENTED BY ITS SECRETARY PRASEENA M. 3 CANARA BANK EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.4355, MAIN ROAD, KANHANGAD, KASARAGOD -671315, REPRESENTED BY ITS SECRETARY, JAYACHANDRAN T.K. 4 KUNDAMKUZHY AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD. NO.S 369, KUNDAMKUZHY P.O., CHENGALA (VIA), KASARAGOD-671541, REPRESENTED BY ITS SECRETARY MADHUSOODANAN G. 5 KASARAGOD RUBBER FARMER'S WELFARE CO-OPERATIVE SOCIETY LTD. NO. S 429, KUTTIKOL P.O., KASARAGOD -671541, REPRESENTED BY ITS SECRETARY SHOBHA K. 6 THE CHATTANCHAL CO-OPERATIVE URBAN SOCIETY LTD. NO.329, THEKKIL P.O., CHENGALA VIA, KASARAGOD -671541, REPRESENTED BY ITS SECRETARY ANANDAN E. 7 THE KASARAGOD PUBLIC SERVANTS CO-OPERATIVE SOCIETY 2025:KER W.P(C)No.7053/2023 & Connected cases 544 LTD. NO.C 290, H.O.CHANDRAGIRI ROAD, KASARAGOD-671121, REPRESENTED BY ITS SECRETARY RAGHAVAN K. 8 THE KASARAGOD CO-OPERATIVE URBAN SOCIETY LTD. NO.S 333, VIDYANAGAR P.O., KASARAGOD-671123, REPRESENTED BY ITS SECRETARY SREEHARI V. 9 HOSDURG PUBLIC SERVANTS CO-OPERATIVE SOCIETY LTD. NO. C 291, KANHANGAD P.O., KASARAGOD -671315, REPRESENTED BY ITS SECRETARY GAYATHRI A.T.V. 10 THE KASARAGOD SCHOOL TEACHERS CO-OPERATIVE SOCIETY LTD. NO. S 442, FORT ROAD, KASARAGOD-671121, REPRESENTED BY ITS SECRETARY VINEETH T. 11 KERALA STATE ROAD TRANSPORT EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO.S 12, KASARAGOD-671121, REPRESENTED BY ITS SECRETARY GOPALAKRISHNAN E.K. 12 THE KUTTIKOL URBAN CO-OPERATIVE SOCIETY LTD. NO. S 347, SANKARAMPADY P.O., CHENGALA VIA, KASARAGOD -671541, REPRESENTED BY ITS SECRETARY TINCY P.T. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY, DEPARTMENT OF REVENUE, 2025:KER W.P(C)No.7053/2023 & Connected cases 545 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI - 110001, REPRESENTED BY ITS CHAIRMAN. 3 PFINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, I.S PRESS ROAD, KOCHI - 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB. NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695001. BY ADVS. SRI.NAVANEETH.N.NATH CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 546 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13761 OF 2022 PETITIONER/S: 1 OORUTTAMVBALAM SERVICE CO-OPERATIVE BANK LTD. OORUTTAMBALAM P.O., THIRUVANANTHAPURAM - 695 507 REPRESENTED BY ITS SECRETARY SHAMJI S.L. 2 VAIPUR SERVICE CO-OPERATIVE BANK LIMITED A-203, III/395, VAIPUR, PATHANAMTHITTA - 689 588 REPRESENTED BY ITS SECRETARY MUHAMMED ISMAIL. 3 ANICADU SERVICE CO-OPERATIVE BANK LTD. NO.A 113, NOOROMMAVU P.O., PUNNAVELLY, ANICADU, PATHANAMTHITTA - 689 589, REPRESENTED BY ITS SECRETARY SHAIJU C.ALEX. 4 P;ATHIYOORKALA SERVICE CO-OPERATIVE BANK LTD. NO.2626, KEEICKAD P.O., KAYAMKULAM, ALAPPUZHA - 690 503 REPRESENTED BY ITS SECRETARY MAHESHWARI AMMAL V. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 2025:KER W.P(C)No.7053/2023 & Connected cases 547 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE , MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, I S PRESS ROAD, KOCHI - 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM - 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 548 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13781 OF 2022 PETITIONER/S: 1 THE KADAPRA SERVICE CO-OPERATIVE BANK LTD. NO. 186, VALANJAVATTAM P.O, THIRUVALLA, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 104. 2 THE MUNDIAPPALLY SERVICE CO-OPERATIVE BANK LIMITED NO. A9, MUNDIAPPALLY, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 581. 3 THE KOIPURAM SERVICE CO-OPERATIVE BANK LIMITED NO. 875, KADAPRA P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY , PIN 689 104. 4 THE THRUVALLA TALUK MERCHANT'S CO-OPERATIVE SOCIETY LIMITED, NO. PT 189, THIRUVALLA, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 101. 5 THE THOTTAPUZHASSERY SERVICE CO-OPERATIVE BANK LIMITED, NO. A 283, VARAYANNOOR P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 548. 6 THE THOTTAPUZHASSERY REGIONAL SERVICE CO-OPERATIVE BANK LIMITED NO. 595, MARAMON P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 549. 7 THE ERAVIPEROOR SERVICE CO-OPERATIVE BANK LIMITED NO. 1929, 2025:KER W.P(C)No.7053/2023 & Connected cases 549 ERAVIPEROOR P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 542. 8 THE KUTTAPUZHA SERVICE CO-OPERATIVE BANK LIMITED NO. 1581, THIRUVALLA P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 103. 9 THE KAVIYOOR SERVICE CO-OPERATIVE BANK LIMITED NO. A 707, KAVIYOOR P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 582. 10 THE THIRUVALLA SERVICE CO-OPERATIVE BANK LIMITED NO. 1307, KAVUMBHAGOM, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN 689 102. 11 THE MUTHOOR SERVICE CO-OPERATIVE BANK LIMITED NO.3118 MUTHOOR, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 689 107. 12 THE TRACO CABLE EMPLOYEES CO-OPERATIVE SOCIETY LIMITED NO.PT 121 CHUMATHRA P. O., PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 689 103. 13 THE VALLAMKULAM SERVICE CO-OPERATIVE BANK LIMITED NO.2163 VALLAKULAM, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 689 541. 14 THE PULLAD SERVICE CO-OPERATIVE BANK LIMITED NO.195 PULLAD P. O., PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 689 531. 15 THE PERINGARA SERVICE CO-OPERATIVE BANK LIMITED NO.A- 790 CHATHANKARY P. O., PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 689 112. 16 THE KURIANOOR SERVICE CO-OPERATIVE SOCIETY LIMITED NO.PT 115 KURIANNOOR P. O., PATHANAMTHITTA DISTRICT, 2025:KER W.P(C)No.7053/2023 & Connected cases 550 REPRESENTED BY ITS SECRETARY, PIN - 689550. 17 THE KUTTOOR SERVICE CO-OPERATIVE BANK LIMITED NO.A708 KUTTOOR, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 689 106. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA X 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I. S. PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) AARATTUKULAKKARA COPLEX, A. N. PURAM, ALAPUZHA DISTRICT - 686011. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033. 5 THE DEPUTY GENERAL MANAGER, KERALA STATE CO-OPERATIVE BANK LTD, PATHANAMTHITTA DISTRICT OFFICE, PATHANAMTHITTA, PIN-689 645. BY ADVS. SHRI.T.C.KRISHNA, SENIOR PANEL COUNSEL CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 551 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13797 OF 2022 PETITIONER/S: 1 THIRUVANANTHAPURAM DISTRICT MERCANTILE CO-OPERATIVE SOCIETY LTD NO T 1733, T.C 24/1082 THYCAUD P.O, THIRUVANANTHAPURAM 695 014 REPRESENTED BY ITS SECREETARY BINDU PAULOSE 2 THE BADIADUKA PANCHAYATH AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD NO. S 421, BADIADKA P.O, PERDALA, KASARAGOD 671 551 REPRESENTED BY ITS SECRETARY SHOBHA P 3 KASARAGOD PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD NO S 422, PADHOOR SHOPING COMPLEX, NEW BUS STAND, KASARAGOD 671 121 REPRESENTED BY ITS SECRETARY SOUMYA E K 4 THE KARADKA AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD NO. S 391, MULLERIA P.O, KASARAGOD 671 543 REPRESENTED BY ITS SECRETARY RATHEESHAN K 5 PUNALUR RURAL CO-OPERATIVE SOCIETY LTD NO Q 1466, THOLICODE P.O, PUNALUR, KOLLAM 691 333 REPRESENTED BY ITS SECRETARY PRAKASH B 6 OACHIRA PANCHAYATH MULTI PURPOSE SAHAGARANA SANGAM LTD, NO Q 1676, OCHIRA P.O, KOLLAM 690 526 REPRESENTED BY ITS SECRETARY ASHA R 7 KARUNAGAPPALLY RURAL CO-OPERATIVE SOCIETY LTD NO. Q 2025:KER W.P(C)No.7053/2023 & Connected cases 552 1463, CHITTUMOOLA, EDAKKULANGARA P.O, KARUNAGAPPALLY, KOLLAM 690 523 REPRESENTED BY ITS SECRETARY BEENAKUMARI S 8 KALPATHUR AGRICULTURISTS AND WORKERS DEVELOPMENT AND WELFARE CO-OPERATIVE SOCIETY LTD NO D 3033, KALPATHUR P.O, KOZHIKODE 673 524 REPRESENTED BY ITS SECRETARY ASHITHA P.K 9 NILAMEL AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD NO 1599, NILAMEL P.O, KOLLAM 691 535 REPRESENTED BY ITS SECRETARY V BINU 10 CHITHARA RURAL CO-OPERATIVE SOCIETY LTD NO Q 1378, CHITHARA P.O, KOTTARAKKARA, KOLLLAM 691 559 REPRESENTED BY ITS SERETARY SANDHYA K.R BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOK NEW DELHI 110 001 REPRESENTED BY ITS CHAIRMAN 2025:KER W.P(C)No.7053/2023 & Connected cases 553 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOHI 682 018 4 THE KERALA STATE CO-OEPRATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM 695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 554 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13833 OF 2022 PETITIONER/S: ANANTHAPURAM CO-OPERATIVE SOCIETY LTD.NO.T.184 H.O.KAITHAMUKKU, THIRUVNANTHAPURAM-695 024 BY ADVS. SRI.GEORGE POONTHOTTAM (SR.) SMT.NISHA GEORGE 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., THIRUVANANATHAPURAM,PIN-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,PIN-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,PIN-110 001 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, D.P.I.JUNCTION, JAWAHAR SAHAKARANA BHAVAN, THIRUVANANTHAPURAM-695 014 2025:KER W.P(C)No.7053/2023 & Connected cases 555 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION , GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM,PIN-695 001 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM,PIN-695 033 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 556 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13891 OF 2022 PETITIONER/S: MANANAK WELFARE CO-OPERATIVE SOCIETY MANANAK, PERUMKULAM.P.O, THIRUVANANTHAPURAM DISTRICT- 695102. REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.B.KRISHNA MANI SMT.N.V.SANDHYA SMT.DHANUJA M.S RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 THE ADDITIONAL COMMISSIONER OF INCOME TAX 2025:KER W.P(C)No.7053/2023 & Connected cases 557 TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR, THIRUVANANTHAPURAM-695003. 5 IINCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. P B NO.6615, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033. 7 THE STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. 8 THE MANAGER, THE KERALA STATE CO-OPERATIVE BANK LTD, KADAKKAVOOR BRANCH, THIRUVANANTHAPURAM DISTRICT-695309. BY ADV SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 558 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13895 OF 2022 PETITIONER/S: 1 ELAMPARA VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1139 ELAMPARA P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY RADHA.K 2 KOLAYAD PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1634, KOLAYAD P.O., KANNUR-670650, REPRESENTED BY ITS SECRETARY JISHA T 3 CLAPPANA PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO. Q 1368, PRAYAR (S), ALUMPEEDIKA P.O., KOLLAM-690547 REPRESENTED BY ITS SECRETARY REJINA BEEGAM C.S 4 PERINGATHUR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO. C 1393, PERINGATHUR P.O., KANNUR-670675 REPRESENTED BY ITS SECRETARY MAHIJA M.K 5 MONTHAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO. C 1848, MONTHAL, OLAVILAM P.O., KANNUR-673313 REPRESENTED BY ITS SECRETARY BINISHA.P 6 EDAKKAD PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1227, KUTTIKKAKAM, KANNUR-670663 REPRESENTED BY ITS SECRETARY SEETHA.M.V 7 CHENDAYAD VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1378, 2025:KER W.P(C)No.7053/2023 & Connected cases 559 CHENDAYAD P.O., KANNUR-670692 REPRESENTED BY ITS SECRETARY SREEJA.K 8 PERINGALAM VANITHA CO-OPERATIVE SOCIETY LTD NO. NO. C 1315, PULLOOKKARA, MUKKILPEEDIKA, KANNUR-670 672 REPRESENTED BY ITS SECRETARY MAHIJA P 9 PANOOR TOWN VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO. C 1668, PANOOR P.O., KANNUR. 670 692 REPRESENTED BY ITS SECRETARY SOYA O 10 MATTOOL PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1404, MADAKKARA, IRINAVE P.O., KANNUR-670 301 REPRESENTED BY ITS SECRETARY INDIRA M.V 11 NEW MAHE PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO. 1347, PERINGADI P.O., KANNUR 673312,REPRESENTED BY ITS SECRETARY PREMALATHA M 12 KILIANTHARA VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1676, KILIANTHARA P.O., VALLITHODE, KANNUR-670706 REPRESENTED BY ITS SECRETARY JISHA C 13 ARALAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1706, ARALAM P.O., KANNUR-670704 REPRESENTED BY ITS SECRETARY LEENA M.C 14 NELLUNNI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1589, NELLUNNI, MATTANUR P.O., KANNUR- 670702 REPRESENTED BY ITS SECRETARY KANAKAVALLI K.K 15 VALLITHODE VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1738, PERINKARY KAVALA, VALLITHODE P.O., KILIANTHARA, KANNUR-670706 REPRESENTED BY ITS SECRETARY LOVELY JACOB 16 PERINCHERI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1408, 2025:KER W.P(C)No.7053/2023 & Connected cases 560 KAYANI P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY JYODHI K.M 17 KEEZHUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1591, KEEZHUR P.O., IRITTY, KANNUR-670703 REPRESENTED BY ITS SECRETARY LEENA.T 18 PUNNAD VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1607, PUNNAD P.O., KANNUR-670703 REPRESENTED BY ITS SECRETARY UMA P.A 19 PADIYOOR-KALLIAD VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1194, KALLIAD P.O., KANNUR-670593 REPRESENTED BY ITS SECRETARY SHERLY P 20 KARIKKOTTAKARI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1734, KOOMANTHODE P.O., KANNUR-670704 REPRESENTED BY ITS SECRETARY SHEEJA K.R 21 ARALAM PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO. 1185, KEEZHAPALLY P.O., KANNUR-670704 REPRESENTED BY ITS SECRETARY SAROJINI P.K 22 EDOOR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1655, EDOOR, PAYAM P.O., KANNUR-670704 REPRESENTED BY ITS SECRETARY JANCY K.J 23 PAYAM PANCHAYATH PRIYADARSHINI VANITHA SAHAKARANA SANGAM LTD. NO. C 1654, PAYAM P.O., KOLIKKADAVU, KANNUR-670704 REPRESENTED BY ITS SECRETARY PREETHA.K 24 THILLENKERY VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1178, THILLENKERY, KANNUR-670702 REPRESENTED BY ITS SECRETARY MINI K 25 THE KODOLIPRAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1568, PATTANUR P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY SARASWATHY К 2025:KER W.P(C)No.7053/2023 & Connected cases 561 26 PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1569, KOTOLIPRAM, PATTANNUR P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY VANAJAKUMARI P.V 27 THERUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1323, KANAD, EDAYANNUR P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY ANITHA.M 28 KOMATH KUNNUMBRAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1665, KOMATH KUNNUMBRAM, MOWANCGERY P.O., KANNUR-670613 REPRESENTED BY ITS SECRETARY SEENA M.C 29 THE PATTANUR VILLAGE VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1254, CHITHRARI, PATTANUR P.O., KANNUR-670695 REPRESENTED BY ITS SECRETARY THANKAMANI M.V 30 CHEMBILODE PANCHAYATH VANITHA COOPERATIVE SOCIETY LTD NO. C 1406, KOYYODE P.O., KANNUR-670621 REPRESENTED BY ITS SECRETARY PRAMEELA A 31 PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY, KEEZHALLUR LTD NO. C 1710, KEEZHALLUR P.O., KANNUR-670612 REPRESENTED BY ITS SECRETARY BINDHYA M 32 VILAKOTTUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1699, VILAKOTTUR P.O., KANNUR-670693 REPRESENTED BY ITS SECRETARY PRAJEELA T 33 KOODALI VILLAGE VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1255, H.O. CHALODE, EDAYANNUR P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY ANITHA K 34 VELLIYAMPARAMBA VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1877 , PRNSS COLLEGE P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY SHEENA V 2025:KER W.P(C)No.7053/2023 & Connected cases 562 35 POYILOOR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1691, THUVAKKUNNU, POYILOOR P.O., KANNUR-670693 REPRESENTED BY ITS SECRETARY REENA A 36 THALASSERY BLOCK VANITHA CO-OPERATIVE SOCIETY LTD NO. C 978, PACHAPOIKA P.O., KUTHUPARAMBA, KANNUR-670643 REPRESENTED BY ITS SECRETARY NITHA.P 37 PATTIAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1138, PATTIAM-PUTHIYATHERU, PATHAYAKKUNNU P.O., KANNUR- 670691 REPRESENTED BY ITS SECRETARY PRABHA V 38 KEEZHALLUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1166, KARA PERAVOOR P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY PRAMEELA C 39 KODIYERI VANITHA CO-OPERATIVE SOCIETY LTD NO.C 1350 TEMPLE GATE P.O., MADAPPEDIKA, KANNUR-670102 REPRESENTED BY ITS SECRETARY LAILA V.K 40 KOTTAYAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1365, KOTTAYAMPOLI P.O., KANNUR-670691 REPRESENTED BY ITS SECRETARY MINI.K 41 POOKODE VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1387, POOKODE P.O., KANNUR-670691 REPRESENTED BY ITS SECRETARY SREEKUMARI.C 42 KADIRUR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1340, PONNIYAM (WEST), KANNUR-670641 REPRESENTED BY ITS SECRETARY PADMINI.K 43 MUNDAYAMPARAMBA VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1737, ST JUDE NAGAR, KILIYANTHARA P.O., KANNUR-670706 REPRESENTED BY ITS SECRETARY SAJIMA K 44 KUNNOTHPARAMBA VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1328, KUNNOTHPARAMBA, THUVAKKUNNU P.O., KANNUR-670693 2025:KER W.P(C)No.7053/2023 & Connected cases 563 REPRESENTED BY ITS SECRETARY AJITHA K.K 45 KAITHERI VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1893, KAITHERI, NIRMALAGIRI P.O., KANNUR-670701 REPRESENTED BY ITS SECRETARY SHIJINA V 46 ULIYIL VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1617, ULIYIL P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY DEEPA SHAJI 47 CHERUVANCHERY VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1907, CHERUVANCHERY P.O., KANNUR-670650 REPRESENTED BY ITS SECRETARY SUNITHA.M 48 KURICHIYIL VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1341, KURICHIYIL P.O., KANNUR-670102 REPRESENTED BY ITS SECRETARY JEENA.T 49 THALASSERY TALUK VANITHA WELFARE COOPERATIVE SOCIETY LTD NO. C 1846, KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS SECRETARY SHEENA K.K 50 KANHIRATHIN KEEZHILVANITHA CO-OPERATIVE SOCIETY LTD NO. C 1861, CHOKLI P.O., KANNUR-670671 REPRESENTED BY ITS SECRETARY AMJAPRIYA V , BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 564 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI- 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 565 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13902 OF 2022 PETITIONER/S: KANJIRAMATTOM VANITHA CO-OPERATIVE SOCIETY LTD. NO. E 1249, KALAMASSERY.P.O, ERNAKULAM DISTRICT, PIN-683104, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.M.M.MONAYE SHRI.M.PAUL VARGHESE SRI.K.V.SANOSH SMT.NIRMALA P.V. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI, PIN-110011. 2 THE CENTRAL BOARD OF DIRECT TAXES ROOM NO.143 E, NORTH BLOCK, DEPARTMENT OF REVENUE, (CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI-110001. 3 COMMISSIONER OF INCOME TAX(TDS) C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-682018. 4 STATE OF KERALA, 2025:KER W.P(C)No.7053/2023 & Connected cases 566 DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT, REPRESENTED BY SECRETARY TO GOVERNMENT, THIRUVANANTHAPURAM-695001. 5 THE REGISTRAR OF CO-OPERATIVE SOCIETIES OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM-695001. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, THIRUVANANTHAPURAM-695033. 7 DEPUTY GENERAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD, CREDIT PROCEESING CENTRE, KAKKANAD, KOCHI-682030. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 567 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13903 OF 2022 PETITIONER/S: 1 KUTHUPARAMBA BLOCK AGRICULTURAL IMPROVEMENT CO- OPERATIVE SOCIETY LTD. NO.C 1625, KUTHUPARAMBA P.O., KANNUR-670 643, REPRESENTED BY ITS SECRETARY BINDU.M. 2 CHOKLI PEOPLES WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1923, SALALA COMPLEX, SPINNING MILL ROAD, CHOKLI P.O., KANNUR-670672 REPRESENTED BY ITS SECRETARY NAMITHA 3 CHITTARIPARAMBA AGRICULTURAL WELFARE COOPERATIVE SOCIETY LTD NO. C 1700, CHITTARIPARAMBA P.O., KANNUR- 670650 REPRESENTED BY ITS SECRETARY SMITHA P.M 4 IRITTY BLOCK PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1870, KOODALI, KANNUR-670592 REPRESENTED BY ITS SECRETARY ROSHIDA RAY 5 KUTHUPARAMBA FARMERS SOCIAL WELFARE COOPERATIVE SOCIETY LTD NO. C 2043, THOKKILANGADI, KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS SECRETARY JALAJA T.P 6 PARAT AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY LTD NO. C 1772, THOOVAKKUNNU P.O., KANNUR-670693 REPRESENTED BY ITS SECRETARY JIBIN.K 7 GRAMEENA THOZHILALI KSHEMA CO-OPERATIVE SOCIETY LTD 2025:KER W.P(C)No.7053/2023 & Connected cases 568 NO. C 1767 CHALODE, EDAYANNUR. P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY BINDU T.P 8 CHALODE MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1882, EDAYANNUR P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY PUSHPAJA P 9 HARIPAD AIDED SECONDARY SCHOOL EMPLOYEE'S CO- OPERATIVE SOCIETY LTD NO. A 280, HARIPAD P.O., ALAPUZHA-690514 REPRESENTED BY ITS SECRETARY K VINOD 10 MALUR AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1824 MALUR P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY VARSHA P.V 11 IRITTY SERVICE PENSIONER'S WELFARE COOPERATIVE SOCIETY LTD NO. 1679, IRITTY P.O., KANNUR-670703 REPRESENTED BY ITS SECRETARY SOBHA P.V.T 12 NRI'S WELFARE CO-OPERATIVE SOCIETY LTD NO.C 1549, MATTANUR, KANNUR-670702 REPRESENTED BY ITS SECRETARY SHEEBA K.M 13 MATTANUR LABOUR AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1863, MATTANUR P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY PRASANTHI E 14 TEACHERS & EMPLOYEES CO-OPERATIVE SOCIETY LTD NO. C 1202, MATTANUR P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY THANKACHAN K.A 15 CO-OPERATIVE EMPLOYEES' CO-OPERATIVE SOCIETY LTD NO. C 379, MATTANUR P.O., KANNUR670702 REPRESENTED BY ITS SECRETARY NAVEEN KUMAR R.K 16 IRITTY BLOCK RURAL EMPLOYEES WELFARE COOPERATIVE 2025:KER W.P(C)No.7053/2023 & Connected cases 569 SOCIETY LTD NO. C 1717, THILLENKERY P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY NAVEEN K.E 17 BLATHUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1864, BLATHUR P.O., KALLIAD, KANNUR-670593 REPRESENTED BY ITS SECRETARY PREETHA.K 18 IRITTY FARMERS WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1879, VALLITHODE P.O., KANNUR-670706 REPRESENTED BY ITS SECRETARY JEEJA C 19 IRITTY UNEMPLOYEES WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1692, IRITTY, KANNUR-670703 REPRESENTED BY ITS SECRETARY SUJITHA P.P. 20 IRITTY TALUK MERCHANTS WELFARE COOPERATIVE SOCIETY LTD NO. C 1995, PAYANCHERY, IRITTY P.O., KANNUR-670703 REPRESENTED BY ITS SECRETARY SREEJA Т.M 21 MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1397, H.O. IRITTY, IRITTY P.O., KANNUR-670703 REPRESENTED BY ITS SECRETARY JOHNSON K.A 22 EDOOR AREA EMPLOYEES AND PENSIONER'S WELFARE CO- OPERATIVE SOCIETY LTD NO. C 1739, PAYAM, EDOOR P.O., KANNUR-670704 REPRESENTED BY ITS SECRETARY SHEEBA K.P 23 KOODALI PUBLIC SERVANTS CO-OPERATIVE SOCIETY LTD NO. C 924, H.O. MATTANUR, KANNUR670702,REPRESENTED BY ITS SECRETARY SHYNITH KUMAR C 24 MATTANUR MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD NO, C 1837 MATTANUR P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY RESNA.K 2025:KER W.P(C)No.7053/2023 & Connected cases 570 25 MATTANUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1841 KOTTATH BUILDING, MATTANNUR P.O., KANNUR-670702 REPRESENTED BY ITS SECRETARY DIJESH P.V 26 KADIRUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1931, CHUNDANGAPOYIL, PONNIAM P.O., KANNUR-670641 REPRESENTED BY ITS SECRETARY JANISHA PUTHUSSERI 27 KUTHUPARAMBA PUBLIC SERVANT'S CO. OPERATIVE SOCIETY LTD NO. C1151 KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS SECRETARY ANITHA K 28 MAMBARAM URBAN CO-OPERATIVE SOCIETY LTD NO. C. 1690, MAMBARAM P.O., KANNUR-670741 REPRESENTED BY ITS SECRETARY SHAJI V.K 29 ULIKKAL AREA EMPLOYEES WELFARE COOPERATIVE SOCIETY LTD NO. C 1594, ULIKKAL P.O., KANNUR-670705 REPRESENTED BY ITS SECRETARY SINDHAU PHILIP 30 KUTHUPARAMBU BLOCK AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1885 AYYAPPANTHODE, MANGATTIDAM P.O., KANNUR670643 REPRESENTED BY ITS SECRETARY SUNITHA.K 31 PANOOR PUBLIC WELFARE CO-OPERA NE SOCIETY LTD NO. 1849, KALLIKKANDY'S.O., KANNUR-670693 REPRESENTED BY ITS SECRETARY RINOJ C 32 KUTHUPARAMBU THOZILALI KSHEMA SAHAKARANA SANGAM LTD. NO. C 1915, KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS SECRETARY SUPRIYA.N 33 THE AGRICULTURIST & LABOUR WELFARE COOPERATIVE SOCIETY LTD NO. C 1920, CHALODE, EDAYANNUR P.O., KANNUR-670595 REPRESENTED BY ITS SECRETARY SHALINA.N 2025:KER W.P(C)No.7053/2023 & Connected cases 571 34 CHERUVANCHERY KARSHAKA-KARSHAKA THOZHILALI KSHEMA SAHAKARANA SANGHAM LTD NO. C 1867, CHERUVANCHERY P.O., KANNUR670650 REPRESENTED BY ITS SECRETARY SREESHMA.K 35 PANOOR MERCANTILE CO-OPERATIVE SOCIETY LTD NO. C 1532, PANOOR P.O., KANNUR-670692 REPRESENTED BY ITS SECRETARY SHYJA E 36 KUNNOTH PARAMBA PEOPLE'S WELFARE COOPERATIVE SOCIETY LTD NO. C 1992, THUVAKKUNNU, KANNUR-670693 REPRESENTED BY ITS SECRETARY GREESHMA C.L 37 PANOOR AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY LTD NO. C 1643, PANOOR P.O., KANNUR-670692 REPRESENTED BY ITS SECRETARY NEESHMA K 38 CHENDAYAD PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO.C 1847, CHENDAYAD P.O., KANNUR-670692 REPRESENTED BY ITS SECRETARY SHIMNA P.V 39 PANOOR PUBLIC SERVANTS WELFARE COOPERATIVE SOCIETY LTD NO. 1641, PANOOR P.O. KANNUR-670692 REPRESENTED BY ITS SECRETARY SUJA T.P 40 THALASSERY TALUK AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1833 KUTHUPARAMBA P.O., KANNUR-670643 REPRESENTED BY ITS SECRETARY BEENA MANIYATH 41 THALASSERY TALUK LABOUR WELFARE SAHAKARANA SANGAM, LTD. NO. C 1988 SANGARANELLOOR P.O., KANNUR-670643 REPRESENTED BY ITS SECRETARY RAJINA.P 42 KANHIRAPUZHA CO-OPERATIVE URBAN CREDIT SOCIETY LTD. NO.P 1172, CHIRAKKALPADI, THRIKALLOR P.O., PALAKKAD-678593 REPRESENTED BY ITS SECRETARY ABIN VARGHEES 2025:KER W.P(C)No.7053/2023 & Connected cases 572 43 MANNARKKAD SAHAKARANA URBAN CREDIT SOCIETY LTD. NO.P 1191, VADAKKUMANNAM P.O., MANNARKKAD, PALAKKAD-678582 REPRESENTED BY ITS SECRETARY SAJITH P 44 MANNARKKAD PRAVASI WELFARE CO-OPERATIVE SOCIETY LTD NO. P 1370, KODATHIPPADI, MANNARKKAD P.O., KANNUR-678582 REPRESENTED BY ITS SECRETARY SATHYA NARAYANAN K.T 45 PATTANCHERY RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO. 1431, PATTANCHERY P.O., PALAKKAD-678532 REPRESENTED BY ITS SECRETARY BIJU V 46 PATTANCHERY RURAL CREDIT CO-OPERATIVE SOCIETY LTD NO. 1431, PATTANCHERY P.O., PALAKKAD-678532 REPRESENTED BY ITS SECRETARY BIJU V 47 PAZHASSI RAJA LABOUR WELFARE COOPERATIVE SOCIETY LTD, NO.C.1896, P.O, KOODALI, KANNUR-670592, REPRESENTED BY ITS SECRETARY RANJULA K 48 BUILDING MATERIALS CO-OPERATIVE SOCIETY, LTD.NO. C.1081, KUTHUPARAMBA, KANNUR-670643, REPRESENTED BY ITS SECRETARY BEENA CHERIAN 49 PUTHOOR AGRICULTURAL IMPROVEMENT COOPERATIVE SOCIETY LTD, NO.C.1771, P.O, CHENDAYAD, VARAPRA, KANNUR- 670692 REPRESENTED BY ITS SECRETARY SUJISHA K.P 50 CHERUVANCHERY AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY, LTD, NO.C.1783, KARYATTUPURAM, P.O, MUTHIYANGA, KANNUR-670671, REPRESENTED BY ITS SECRETARY N.V. RAJESH 51 THALASSERY TALUK PUBLIC SERVENTS'S WELFARE CO- OPERATIVE SOCIETY, LTD.NO.C.1669, P.O, KUTHUPARAMBA, KANNUR-670703 REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 573 SECRETARY RANJITH P.P 52 KOLAYAD FARMERS WELFARE CO-OPERATIVE SOCIETY LTD NO.C. 1973, KOLAYAD P.O, KANNUR-670650 REPRESENTED BY ITS SECRETARY RAJESH. K.M 53 THALASSERY TALUK NIRMANA THOZHILALI KSHEMA SAHAKARANA SANGAM, LTD, NO.C. 1913, PANOOR P.O, KANNUR- 670692 REPRESENTED BY ITS SECRETARY KRISHNAN. K 54 PERINGATHUR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD, NO.C 1852, PERINGATHUR P.O, KANNUR-670675, REPRESENTED BY ITS SECRETARY ROJA.P.P. 55 PANOOR MERCHANTS WELFARE CO-OPERATIVE SOCIETY, LTD NO.C 1731, PANOOR P.O., KANNUR-670 692, REPRESENTED BY ITS SECRETARY SHYNI BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, 2025:KER W.P(C)No.7053/2023 & Connected cases 574 GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018. 4 THE KERALA STATE CO OPERATIVE BANK LTD., PB NO.6515, CO BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY IT CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. BY ADV SHRI.M.SASINDRAN THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 575 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13912 OF 2022 PETITIONER/S: KALAMASSERY GOVT. POLYTECHNIC COLLEGE EMPLOYEES CO- OPERATIVE SOCIETY LTD. NO.E 1157, KALAMASSERY P.O., ERNAKULAM DISTRICT, PIN-683104, REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.M.M.MONAYE SHRI.M.PAUL VARGHESE SRI.K.V.SANOSH SRI.JOE JOSEPH RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI, PIN-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI-110001. 3 COMMISSIONER OF INCOME TAX (TDS), C.R.BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-682018. 4 STATE OF KERALA 2025:KER W.P(C)No.7053/2023 & Connected cases 576 DEPARTMENT OF FINANCE, GOVERNMENT SECRETARIAT, REPRESENTED BY SECRETARY TO GOVERNMENT, THIRUVANANTHAPURAM-695001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, STATUE, NEAR PRESS CLUB, THIRUVANANTHAPURAM-695001. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., CO-BANK TOWERS, PALAYAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, THIRUVANANTHAPURAM-695033. 7 DEPUTY GENERAL MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., CREDIT PROCESSING CENTRE, KAKKANAD, KOCHI-682030. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 577 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13939 OF 2022 PETITIONER/S: PULLUKULANGARA SERVICE CO-OPERATIVE BANK LTD REPRESENTED BY ITS SECRETARY, PULLUKULANGARA, KAYAMKULAM.P.O, ALAPPUZHA-690502. BY ADV SRI.GOKUL D. SUDHAKARAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES REPRESENTED BY ITS CHAIRMAN DEPARTMENT OF REVENUE, MINISTRY OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI-682018. 4 COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003. 5 THE INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICER, ANAVATHILKOTTA, ALAPPUZHA-688001. 2025:KER W.P(C)No.7053/2023 & Connected cases 578 6 THE KERALA STATE CO-OPERATIVE BANK LTD. REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN-695033. 7 STATE OF KERALA, REPRESENTED BY THE SECRETARY, DEPARTMENT OF CO- OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADV SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 579 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13940 OF 2022 PETITIONER/S: 1 CHAKKITTAPARA VANITHA CO-OPERATIVE SOCIETY LTD NO. D- 2931 CHAKKITTAPARA P.O, KAYANNA VIA, KOZHIKODE-673526 REPRESENTED BY ITS SECRETARY SHALLY JOSEPH. 2 KAYANNA PRIYADARSINI VANITHA SAHAKARANA SANGAM LTD. NO 2605, P.O, KAYANNA BAZAR, KOZHIKODE- 673525 REPRESENTED BY ITS SECRETARY DHANYA A.K 3 ATHOLI VANITHA CO-OPERATIVE SOCIETY LTD.NO.D.2841, ATHOLI P.O, KOZHIKIDE- 673315 REPRESENTED BY ITS SECRETARY PRABITHA KUMARI 4 NOCHAD VANITHA SAHAKARANA SANGHAM, LTD.NO.D.2843, P.O, KALPPATHUR, ANCHAMPEEDIKA, CALICUT- 673524 REPRESENTED BY ITS SECRETARY SHEEJA.P.K 5 KEEZHARIYUR VANITHA CO-OPERATIVE SOCIETY LTD. NO. D.2681, NADUVATHUR P.O, QUILANDY, CALICUT-673620 REPRESENTED BY ITS SECRETARY PUSHPAVALLY.K 6 MULIYANGAL VANITHA SAITAKARANA SANGAM LTD. NO.1.2881, CHENOLI PO, PERAMBRA, KOZHIKODE- 673525 REPRESENTED BY ITS SECRETARY NISHA.P 7 CHANGAROTH PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD. NO.D.2870, KADIYANGAD, P.O, KOZHIKODE- 673525 REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 580 SECRETARY SHIJI.M.V 8 MUYIPPOTH VANITHA SAHAKARAVA SANGHAM, LTD.NO.1.3120, MUYIPPOYH P.O, KOZHIKODE-673524 REPRESENTED BY ITS SECRETARY SHYNI.K 9 PERAMBRA VANITHA SAHAKARANA SANGHAM, LTD.NO.0.2833, PERAMBRA KOZHIKODE- 673525 REPRESENTED BY ITS SECRETARY RAKHI.P 10 KOYILANDY VANITHA CO-OPERATIVE SOCIETY LTD. NO. D.2572, TRAFFIC POLICE STATION ROAD, KOYILANDY, KOZHIKODE- 673305 REPRESENTED BY ITS SECRETARY RATHYINA N.K 11 AVITANALLUR PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY LTD. NO. D.2484, AVITANALLUR P.O, NADUVANNUR, KOZHIKODE-673618 REPRESENTED BY ITS SECRETARY INDIRA.K.P 12 NADUVANNUR VANITHA SAHAKARANA SANGHAM, LTD.NO.1.2806, KAVIL P.O, NADUVANNUR, KOZHIKODE-673614 REPRESENTED BY ITS SECRETARY DEEPAK 13 MALABAR VANITHA CO-OPERATIVE SOCIETY LTD. NO. D.2994, ULLIYERI P.O KOZHIKODE-673620 REPRESENTED BY ITS SECRETARY SINDHU.K.M 14 PANOOR REGIONAL VANITHA COOPERATIVE SOCIETY LTD. NO. C.1575, PANOOR P.O, KANNUR- 670692 REPRESENTED BY ITS SECRETARY SAJILA K.T 15 KOTTAYAM KINAVAKKAL VANITHA COOPERATIVE SOCIETY LTD. NO. C.1494, KOTTAYAM ANGADI, P.O KOTTAYAM MALABAR, KUTHUPARAMBA, KANNUR670643 REPRESENTED BY ITS SECRETARY SREESHA. A 16 KARIYAD MAHILA SERVICE COOPERATIVE SOCIETY LTD. NO. C.1498, KARIYAD P.O, KANNUR- 673316 REPRESENTED BY ITS SECRETARY SREEJA.C 2025:KER W.P(C)No.7053/2023 & Connected cases 581 17 THE KUTTIKOL VANITHA SERVICE COOPERATIVE SOCIETY LTD. NO.S.434, KUTTIKOL P.O, KASARAGOD-671541 REPRESENTED BY ITS SECRETARY SOUMYA.B 18 KUTTIKOL VYAPARI VYAVASAYI KSHEMA SAHAKARANA SANGHAY LTD. NO. S.553 KUTTIKOL P.O, CHENGALA, KASARAGOD- 671541 REPRESENTED BY ITS SECRETARY SREEJA C.G 19 PUTHUR PRIYADARSINI VANITHA COOPERATIVE SOCIETY LTD.NO.C.1615, PUTHUR P.O, PANOOR, KANNUR - 670692 REPRESENTED BY ITS SECRETARY DEEPAK 20 THE KUTTIKOL MERCHANT'S WELFARE CO-OPERATIVE SOCIETY LTD.NO.S.555, KUTTIKOL P.O, KASARAGOD- 671541 REPRESENTED BY ITS SECRETARY RAJESH KUMAR K 21 THE KASARAGOD MERCANTILE COOPERATIVE SOCIETY LTD.NO.S.287, MALABAR SQUARE BUILDING, NEW BUS STAND, KASARAGOD- 671121 REPRESENTED BY ITS SECRETARY KUNHIRAMAN.A.C 22 THE KUNNAMTHANAM SERVICE COOPERATIVE BANK LTD.NO.A151, KUNNAMTHANAM P.O, THIRUVALLA-689581 REPRESENTED BY ITS SECRETARY SMITHA.GOPINATH BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.NEENA ARIMBOOR SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 582 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 KERALA STATE CO-OPERATIVE BANK LTD., PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 583 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 13996 OF 2022 PETITIONER/S: 1 CHERIYAKUMBALAM AGRICULTURESTS WELFARE CO-OIPERATION SOCIETY LTD. NO. D 3066, PALERI P.O., KOZHIKODE- 673508 REPRESENTED BY ITS SECRETARY JITHIL B 2 PERAMBRA AREA MOTOR & ENGINEERING WORKERS CO- OPERATIVE SOCIETY LTD NO. D 2869, PERAMBRA P.O., KOZHIKODE-673525 REPRESENTED BY ITS SECRETARY NIJINLAL.K.N 3 PERAMBRA WEST VANITHA SAHAKARANA SANGAM LTD NO. 3114, PANNIMUKKU, CHERUVANNUR P.O., MEPPAYUR VIA, KOZHIKODE-673524 REPRESENTED BY ITS SECRETARY SUJITH.C 4 KOORACHUND PANCHAYATH VANITHA COOPERATIVE SOCIETY LTD NO. D 2887, KOORACHUND P.O., KOZHIKODE-673527 REPRESENTED BY ITS SECRETARY SHYNI.R 5 PERAMBRA MEKHALA VANITHA CO-OPERATIVE SOCIETY LTD NO.D 2875, PERAMBRA P.O., KOZHIKODE-673525 REPRESENTED BY ITS SECRETARY SREEJINI P 6 KOOTHALI PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD NO. D 2791, THANDORAPPARA P.O. KOZHIKODE-673526 REPRESENTED BY ITS SECRETARY JEENARANI P.P 2025:KER W.P(C)No.7053/2023 & Connected cases 584 7 CHERUVANNUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD NO. D 2995, CHERUVANNUR P.O., KOZHIKODE-673524 REPRESENTED BY ITS SECRETARY AJEESH K.M 8 THE MOKERI AGRICULTURIST IMPROVEMENT COOPERATIVE SOCIETY LTD NO. C 1770, MOKERY P.O., PANOOR VIA, KANNUR-670692 REPRESENTED BY ITS SECRETARY REHINA.K 9 BHUVANESWARI WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1626, BB COMPLEX, SOUTH BAZAR, KANNUR-670002 REPRESENTED BY ITS SECRETARY SHEEJA.N.V 10 INDIRAAJI SMARAKA VANITHA SAHAKARANA SANGAM LTD NO. C 1633, ELAYAVOOR P.O., KANNUR-670594 REPRESENTED BY ITS SECRETARY REJENI.C 11 KATTAL FARMERS SOCIAL WELFARE COOPERATIVE SOCIETY LTD NO. T 1629, KATTAKKADA P.O, THIRUVANANTHAPURAM-695572 REPRESENTED BY ITS SECRETARY SARITHA.S 12 KALPETTA AGRICULTURAL IMPROVEMENT CO. OPERATIVE SOCIETY, KANIYAMBETTA, WAYANAD-673121 REPRESENTED BY ITS SECRETARY T.T JOSEPH 13 KULATHUMMEL WELFARE CO-OPERATIVE SOCIETY, T 1692, KATTAKADA P.O., THIRUVANANTHAPURAM-695572 REPRESENTED BY ITS SECRETARY NISHANTH.N BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.RASMI NAIR T. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 585 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 586 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14006 OF 2022 PETITIONER/S: KADAPPURAM PANCHAYATH PRAVASI HARITHA CO-OPERATIVE SOCIETY LTD. R 1417 , KADAPURAM P.O, ANJANGADI, THRISSUR - 680 514 REPRESENTED BY ITS SECRETARY BY ADV SRI.V.A.VINOD RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE , GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, COCHIN - 682 018. 4 INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICE (TDS) AAYAKAR BHAVAN, SAKATHAN THAMPURAN NAGAR, THRISSUR - 680 001. 5 THE KERALA STATE CO-OPERATIVE BANK LTD, 2025:KER W.P(C)No.7053/2023 & Connected cases 587 P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033. REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO- OPERATION, GOVERNMENT SECRETARIAT, THIRUVNANTHAPURAM- 695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 588 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14010 OF 2022 PETITIONER/S: M/S.VELLINEZHI PANCHAYATH MULTI PURPOSE CO-OPERATIVE SOCIETY LTD. SREELAKSHMI COMPLEX, VELLINEZHI, DIST. PALAKKAD - 679 504 REPRESENTED BY ITS SECRETARY, SMT. PREETHY C.S BY ADVS. SRI.V.P.NARAYANAN SRI.ALAN PRIYADARSHI DEV RESPONDENT/S: 1 UNION OF INDIA DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. REPRESENTED BY ITS SECRETARY, 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 CHAIRMAN, CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., 2025:KER W.P(C)No.7053/2023 & Connected cases 589 CHERPULLASSERI BRANCH, DIST. PALAKKAD- 679503 REPRESENTED BY ITS BRANCH MANAGER BY ADV SHRI.M.SASINDRAN THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 590 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14014 OF 2022 PETITIONER/S: CHAVAKKAD MUNICIPAL PRAVASI KSHEMA CO-OPERATIVE SOCIETY LTD 1486 CHAVAKKAD P.O., THRISSUR-680506, REPRESENTED BY ITS SECRETARY. BY ADV SRI.V.A.VINOD RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, COCHIN-682018. 4 INCOME TAX OFFICER (TDS), OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR-680001. 5 THE KERALA STATE CO-OPERATIVE BANK LTD., 2025:KER W.P(C)No.7053/2023 & Connected cases 591 P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF CO- OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 592 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14017 OF 2022 PETITIONER/S: THE ALANALLUR CO-OPERATIVE RURAL CREDIT SOCIETY LTD. NO. P.1333 ALANALLUR P.O., PALAKKAD DISTRICT, KERALA-678601, REPRESENTED BY ITS SECRETARY, SRI. SREEJITH P.T. BY ADVS. SRI.K.ANAND SMT.M.R.MINI SHRI.AMEER SALIM RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD.), 2025:KER W.P(C)No.7053/2023 & Connected cases 593 COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN- 695033, REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA BANK ( THE KERALA STATE CO-OPERATIVE BANK LTD.), REGIONAL OFFICE, PALAKKAD H.P.O. ROAD, SULTHANPET, PALAKKAD-678001, REPRESENTED BY ITS GENERAL MANAGER. 6 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD.), ALANALLUR BRANCH, ALANALLUR P.O., PALAKKAD -678601, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. SRI.CHRISTOPHER ABRAHAM SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 594 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14047 OF 2022 PETITIONER/S: 1 THE PUDURUTHY SERVICE CO-OPERATIVE BANK LTD NO.825, MUNDATHICODE P.O., THRISSUR DISTRICT, THRISSUR 680 601, REPRESENTED BY SECRETARY, T HEMALATHA. 2 AVANOOR PANCHAYATH MULTIPURPOSE CO- OPERATIVE SOCIETY LTD NO. R. 1142, AVANOOR P.O., THRISSUR DISTRICT 680 541, REPRESENTED BY SECRETARY DHIVYA C.G. 3 THRISSUR JILLA NRI SERVICE CO - OPERATIVE SOCIETY LTD NO. R 1269, POOTHOLE P.O, THRISSUR DISTRICT, THRISSUR 680 004, REPRESENTED BY SECRETARY GAYATHRI K.P. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT , MINISTRY OF FINANCE , NORTH BOCK, RAISANA HILL , NEW DELHI 110 001. 2 THE COMMOSSIOER OF INCOME TAX (TDS), CENTRAL REVENUE BIDG, IS PRESS, ROAD, KOCHI 682 018. 3 THE INCOME TAX OFFICER (TDS), AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR 680 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 595 4 THE KERALA STATE CO - OPERATIVE BANK LTD, (ERST WHILE THRISSUR DISTRICT CO-OPERATIVE BANK) SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THRIRUVAMBADI P.O, THRISSUR, 680 022, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 596 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14061 OF 2022 PETITIONER/S: THOZHUVANCODE-VATTIYOORKAVU RESIDENTS WELFARE CO- OPERATIVE SOCIETY LTD NO.T-1247, ARAPPURA, VATTIYOOR KAVU P.O., THIRUVANANTHAPURAM 695 013, REPRESENTED BY ITS SECRETARY, SARITHA. M.G. BY ADVS. SRI.D.SAJEEV SHRI.AJAYA KUMAR P.J. SMT.LIGEY ANTONY RESPONDENT/S: 1 UNION OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI 110 001. REPRESENTED BY ITS SECRETARY. 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, C.R. BUILDING, I.S. PRESS ROAD, KOCHI, ERNAKULAM 682 018. 3 THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS), 3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O., THIRUVANANTHAPURAM 695 003. 4 THE KERALA STATE CO - OPERATIVE BANK LTD., EAST FORT, THIRUVANANTHAPURAM 695 023, REPRESENTED BY ITS MANAGING DIRECTOR. 2025:KER W.P(C)No.7053/2023 & Connected cases 597 5 THE BRANCH MANAGER, THE KERALA STATE CO - OPERATIVE BANK LTD., VATTIYOORKAVU BRANCH, THIRUVANANTHAPURAM 695 013. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 598 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14119 OF 2022 PETITIONER/S: THIRUVANANTHAPURAM DISTRICT GOVERNMENT SERVANTS CO- OPERATIVE SOCIETY LTD.NO.T-1566, PUBLIC OFFICE BUILDING, PUBLIC OFFICE P.O., THIRUVANANTHAPURAM, PIN-695 033, REPRESENTED BY ITS SECRETARY, AJITH.K.I. BY ADVS. SRI.D.SAJEEV SHRI.AJAYA KUMAR P.J. SMT.LIGEY ANTONY RESPONDENT/S: 1 UNION OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS SECRETARY. 2 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, CR BUILDING, IS PRESS ROAD, KOCHI, ERNAKULAM, PIN-682 018. 3 THE ASSISTANT COMMISSIONER OF INCOME TAX (TDS), 3RD FLOOR, AAYAKAR BHAVAN, KAWDIAR P.O., THIRUVANANTHAPURAM, PIN-695 003. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., EAST FORT, THIRUVANANTHAPURAM, PIN-695 023, 2025:KER W.P(C)No.7053/2023 & Connected cases 599 REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE BRANCH MANAGER, THE KERALA STATE CO OPERATIVE BANK LTD., M & E BRANCH, PUTHENCHANTHAI, THIRUVANANTHAPURAM, PIN-695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 600 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14122 OF 2022 PETITIONER/S: 1 THE BANK EMPLOYEES CO-OPERATIVE BANK LTD.NO.R 315, IRINJALAKUDA P.O, THRISSUR DISTRICT, PIN 680121 REPRESENTED BY SECRETARY-INCHARGE PRIYA MENON C. 2 THE KUNNAMKULAM THALUK GOVERNMENT SERVANT'S CO- OPERATIVE SOCIETY LTD NO. 205, KUNNAMKULAM P O, THRISSUR DISTRICT, PIN 680503 REPRESENTED BY SECRETARY PRASSETHA K.S. 3 KATTOOR PANCHAYATH VANITHA SAHAKARANA SANGAM LTD NO.R 1250, KATTOOR PO, THRISSUR DISTRICT, PIN 680702 REPRESENTED BY SECRETARY VIJAYALAKSHMI.N. 4 MUKUNDAPURAM TALUK GOVT. EMPLOYEE'S CO-OPERATIVE SOCIETY LTD NO. R.793. IRINJALAKUDA P.O, THRISSUR, PIN-680121 REPRESENTED BY ITS SECRETARY MAYA P.M. 5 THRISSUR REGIONAL AGRICULTURAL NON AGRICULTURAL DEVELOPMENT COOPERATIVE SOCIETY LTD NO. R 1399, TOMS PLAZA TOWER, IRINJALAKUDA P.O, THRISSUR, PIN- 680121 REPRESENTED BY ITS SECRETARY HILA P.H. 6 VANITHA CO-OPERATIVE SOCIETY LTD NO. R.979, IRINJALAKUDA P.O, THRISSUR, PIN-680121 REPRESENTED BY ITS SECRETARY SUDHA K. BY ADV SHRI.C.A.JOJO 2025:KER W.P(C)No.7053/2023 & Connected cases 601 RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682 018. 3 THE INCOME TAX OFFICER(TDS) , AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., (ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK), SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THRIRUVAMBADI P.O, THRISSUR, PIN-680022 REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 602 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14151 OF 2022 PETITIONER/S: THE KATAMPAZHIPURAM PANCHAYATH AGRL.IMPROVEMENT CO- OPERATIVE SOCIETY LTD.NO.P.1314 UMMANAZHI, PALAKKAD DISTRICT, KERALA - 678632., REPRESENTED BY ITS SECRETARY, SMT. DHANDY. BY ADVS. SRI.K.ANAND SHRI.BENNY ANTONY PAREL SHRI.AMEER SALIM RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN - 682018. 4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD). 2025:KER W.P(C)No.7053/2023 & Connected cases 603 COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695033, REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD), REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET, PALAKKAD - 678001, REPRESENTED BY ITS GENERAL MANAGER. 6 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD), PULAPETTA BRANCH, PULAPETTA P.O, PALAKKAD - 678632, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 604 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14162 OF 2022 PETITIONER/S: ARUVAPPULAM FARMERS SERVICE CO-OPERATIVE BANK LTD.NO.P.T.148 ARUVAPPULAM P.O, KONNI, PATHANAMTHITTA DISTRICT PIN 689 691 REPRESENTED BY ITS MANAGING DIRECTOR, SIVAKUMAR S BY ADV SRI.C.B.SREEKUMAR RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH LOCK, NEW DELHI 110 001 REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018 4 INCOME TAX OFFICER(TDS) OFFICE OF THE INCOME TAX (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR 680 001 2025:KER W.P(C)No.7053/2023 & Connected cases 605 5 THE KERALA STATE CO-OPERATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM 695 001 BY ADV SRI.CHRISTOPHER ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 606 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14195 OF 2022 PETITIONER/S: 1 CARBORUNDUM UNIVERSAL EMPLOYEES CO-OPERATIVE SOCIETY LTD. NO. E 404 KALAMASSERY P.O, ERNAKULAM 683104 REPRESENTED BY ITS SECRETARY ANEESH P.B 2 THE MULIYAR PUBLIC WELFARE CO-OPERATIVE SOCEITY LTD NO. S 558 BOVIKANAM COMPLEX, INFORNT POST OFFICE,. MULIYAR P.O, KASARAGOD 671 542 REPRESENTED BY ITS SECRETARY JITHIN A 3 MARIYAPURAM VANITHA WELFARE CO-OPERATIVE SOCIETY LTDNO T 945 THOTTINKARA, PLAMOOTTUKKADA P.O, THIRUVANANTHAPURAM 695 126 REPRESENTED BY ITS SECRETARY ANITHAKUMARI T.C 4 THIRUPURAM PANCHAYAT RESIDENTS ASSOCIATIONS WELFARE CO-OPERATIVE SOCIETY LTD NO T 1755, MANNAKKAL, THIRUPURAM P.O, THIRUVANANTHAPURAM 695 133 REPRESENTED BY ITS SECRETARY VIJI C V 5 CHENKAL JOINT FARMING CO-OEPRATIVE SOCIETY LTD NO T 1183, VLATHANKARA P.O, THIRUVANANTHAPURAM 695 134 REPRESENTED BY ITS SECRETARY SHEEJA G.S 6 KARUMKULAM FARMERS WELFARE CO-OPERATIVE SOCIETY LTD NO T 1941, KARUMKULAM , PUTHIYATHURA P.O, THIRUVANANTHAPURAM 695 526 REPRESENTED BY ITS SECRETARY CHITHRA LEKHA M.S 2025:KER W.P(C)No.7053/2023 & Connected cases 607 7 BALARAMAPURAM VANITHA CO-OPERATIVE SOCIETY LTD NO. T 961 DOUBLE STREET, BALARAMAPURAM P.O, THIRUVANANTHAPURAM 695 501 REPRESENTED BY ITS SECRETARY S JAYALEKHA BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI 110 001 2 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 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING S, I S PRESS ROAD, KOCHI 682 018 4 THE KERALA STATE CO-OPEERATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033 ' REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY(CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM 695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT 2025:KER W.P(C)No.7053/2023 & Connected cases 608 SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 609 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14341 OF 2022 PETITIONER/S: 1 PANDALAM THEKKEKARA SERVICE CO-OPERATIVE BANK LTD.329 THATTAYIL P.O., PATHANAMTHITTA - 691525, REPRESENTED BY ITS SECRETARY T.K. ANANTHAKRISHNAN, S/O T.K. KRISHNAKURUP, AGED 51 YEARS THULASIMANDARAM, MALLIKA, THATTAYIL P.O., PATHANAMTHITTA - 691525. 2 ENATHU SERVICE CO-OPERATIVE BANK LTD. NO. 2529, ENATHU P.O. PATHANAMTHITTA - 691554, REPRESENTED BY ITS SECRETARY, AMBIKAKUMARI M., W/O AGITHA KUMAR, AGED YEARS, KUDAMUKKU, MAMOODU P.O., PATHANAMTHITTA- 689513 3 PALLICKAL SERVICE CO-OPERATIVE BANK LTD. NO.722 ELAMPALLIL, PAYYANALLOOR P.O., PATHANAMTHITTA - 691523, REPRESENTED BY ITS SECRETARY, SIVAPRABHA A.G., AGED 41 YEARS, W/O THULASEEDHARAN NAIR, VINAKAYAKAM HOUSE, PALLICKAL, NOORANAD P.O., PATHANAMTHITTA 690504. BY ADV SRI.K.SHAJ RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES 2025:KER W.P(C)No.7053/2023 & Connected cases 610 DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682018. 4 THE ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695003 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 611 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14425 OF 2022 PETITIONER/S: THE NEDUMPRAM SERVICE CO-OPERATIVE BANK LTD NO.A 205 NEDUMBRAM P.O, THIRUVALLA, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY PIN 689 110 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE,NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S PRESS ROAD, ERNAKULAM, PIN 682 018 3 THE INCOME TAX OFFICER (TDS) AARATTUKULAKKARA COMPLEX, A N PURAM, ALAPUZHA DISTRICT 686 011 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033 5 THE DEPUTY GENERAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD, PATHANAMTHITTA DISTRICT OFFICE, PATHANAMTHITTA, PIN 689 645 2025:KER W.P(C)No.7053/2023 & Connected cases 612 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 613 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14559 OF 2022 PETITIONER/S: 1 CALICUT CITY SERVICE CO-OPERATIVE BANK LTD., D.2777, CHALAPPURAM P.O., CALICUT - 673 002, REPRESENTED BY ITS GENERAL MANAGER. 2 OLAVANNA VANITHA SAHAKARANA SANGAM LTD.NO.D 2770, PALAZHI - PALA, G.A.COLLEGE P.O., CALICUT - 673 014 REPRESENTED BY ITS SECRETARY. 3 KOZHIKODE TOWN VANITHA SAHAKARANA SANGAM LTD.NO.D 2816, MANKAVU GREENS, AZHCHAVATTOM P.O., KOZHIKODE - 673 007 REPRESENTED BY ITS SECRETARY. 4 BEYPORE VANITHA SAHAKARANA SANGAM LTD.NO.D 2784, ARAKKINAR P.O., BEYPORE, KOZHIKODE - 673 023, REPRESENTED BY ITS SECRETARY. 5 FEROKE VANITHA SAHAKARANA SANGAM LTD.NO.D 2467, PERUMUGAM P.O., FEROKE, KOLLAMPARAM, KOZIKODE - 673 631 REPRESENTED BY ITS SECRETARY. BY ADVS. SRI.B.S.SWATHI KUMAR SMT.ANITHA RAVINDRAN SRI.HARISANKAR N UNNI SHRI.SARANGADHARAN P. SMT.N.S.SHAMILA 2025:KER W.P(C)No.7053/2023 & Connected cases 614 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, PIN - 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, PIN - 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, PIN - 110 001. 4 THE REGISTRAR OF CO-OPERATIVE SOCIETIES, KERALA STATE, THIRUVANANTHAPURAM, PIN - 695 001. 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695 001. 6 THE KERALA STATE CO-OPERATIVE BANK, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN -695 033. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 615 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14687 OF 2022 PETITIONER/S: KANNADI AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY , YAKKARA, KANNADI P.O., KERALA 678 701, REPRESENTED BY ITS HONORARY SECRETARY, K. SELVAN. BY ADVS. SRI.K.ANAND SHRI.BENNY ANTONY PAREL RESPONDENT/S: 1 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HIL, NEW DELHI 110 001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, 682 018. 4 THE KERALA BANK (THE KERALA STATE CO - OPERATIVE BANK LTD.), CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 2025:KER W.P(C)No.7053/2023 & Connected cases 616 033,REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD.), REGIONAL OFFICE, PALAKKAD H.P.O. ROAD, SULTHANPET, PALAKKAD 678 001, REPRESENTED BY ITS GENERAL MANAGER. 6 THE KERALA BANK , (THE KERALA STATE CO - OPERATIVE BANK LTD.,) (ERST WHOLE PALAKKAD CO-OPERATIVE BANK LTD), MURIKKAVU (WEST YAKKARA) BRANCH, PALAKKAD 678 001. REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 617 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14715 OF 2022 PETITIONER/S: 1 THE CHERUPUZHA URBAN CO-OPERATIVE SOCIETY LTD NO.C 1565 CHERUPUZHA P.O., KANNUR-670511 REPRESENTED BY ITS SECRETARY K.S JEEVAN. 2 THE PAYYANUR URBAN CO-OPERATIVE SOCIETY LTD NO. C 1556 PAYYANUR P.O., KANNUR-670307 REPRESENTED BY ITS SECRETARY MANOJ KUMAR B. 3 THE PAYYANUR CHAMBER OF COMMERCE MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1830 PAYYANUR P.O., KANNUR-670307 REPRESENTED BY ITS SECRETARY RATNALATHA K.T. 4 PAYYANUR BLOCK AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD, NO C 1592 P.O. PAYYANNUR, KANNUR-670307 REPRESENTED BY ITS SECRETARY VINODKUMAR P.V. 5 SOCIAL WORKERS WELFARE COOPERATIVE SOCIETY LTD, C 1911 KANDAKORAN MUKKU ANNUR P.O., PAYYANNUR, KANNUR-670307 REPRESENTED BY ITS SECRETARY JISHA K.V. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI 2025:KER W.P(C)No.7053/2023 & Connected cases 618 SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695001. BY ADVS. SHRI.JOSE ANTONY, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 619 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14806 OF 2022 PETITIONER/S: POOKKOTTOOR RURAL CO-OPERATIVE SOCIETY LTD. NO.M-1039, ARAVANKARA, POOKKOTTOOR P.O, MALAPPURAM DISTRICT, PIN-676517, REPRESENTED BY ITS HONORARY SECRETARY RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-11000. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018 3 THE INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O, MALAPPURAM DISTRICT, PIN-676101 4 MALAPPURAM DISTRICT CO-OPERATIVE SOCIETY LTD, HEAD OFFICE MAJERI ROAD, MALAPPURAM, PIN-57650. REPRESENTED BY ITS GENERAL MANAGER BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 620 THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 25.10.2025, ALONG WITH WP(C).7053/2023 AND CONNECTED CASES, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 621 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14807 OF 2022 PETITIONER/S: 1 THRISSUR DISTRICT INDUSTRIAL MANUFACTURERS CO- OPERATIVE SOCIETY LTD. NO. R.1174 KOLUZHY F.O, THRISSUR, PIN- 680010 REPRESENTED BY ITS SECRETARY B.V. MINI. 2 THE KERALA FOREST RESEARCH INSTITUTE EMPLOYEE'S CO- OPERATIVE SOCIETY 18 PEECHI PO, THRISSUR DISTRICT, PIN 680653 REPRESENTED BY SECRETARY GOPAKUMAR P. 3 PEECHI VANITHA CO-OPERATIVE SOCIETY LTD NO. R.1374 M.G ROAD, PATTIKKAD P.O, THRISSUR, PIN-680652 REPRESENTED BY ITS SECRETARY PRINCY T.K. 4 MUDAPPILAVU VANITHA CO-OPERATIVE SOCIETY LTD NO.R. 1446 MUDAPPILAVU ROAD, CHIYARAM P.O, THRISSUR DISTRICT, PIN 680026 REPRESENTED BY SECRETARY -IN- CHARGE RADHIKA RAJU. 5 KIPPARAMBU JANAKE HERA SAHAKARINA SANGAM LTD.NO.1654 KAIPARAMBU PO, THRISSUR PIN-680545 REPRESENTED BY ITS SECRETARY DHANYA M.S. 6 MALA BLOCK TOWN CO OPERATIVE BANK LTD NO. R 1086 ALOOR PO, THRISSUR DISTRICT PIN 680683 REPRESENTED BY SECRETARY SHAJU V.O. BY ADV SHRI.C.A.JOJO 2025:KER W.P(C)No.7053/2023 & Connected cases 622 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018. 3 THE INCOME TAX OFFICER(TDS) AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680001. 4 THE KERALA (ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK) SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THRIRUVAMBADI P.O, THRISSUR, PIN-680022 REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 623 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14811 OF 2022 PETITIONER/S: VILAYUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY P-1379 VILAYUR P.O., PATTAMBI TALUK, PALAKKAD DISTRICT, 679 309,REPRESENTED BY ITS SECRETARY SMT. GEETHA K.S. BY ADV SRI.A.HAROON RASHEED RESPONDENT/S: 1 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001. 2 THE CENTRAL BOARD OF DIRECT TAXES, MINISTRY OF FINANCE, NORTH BLOCK, RAISAN HILL, NEW DELHI 110 001. REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS. PRESS ROAD, ERNAKULAM 682 018. 4 THE KERALA STAT CO-OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM,THIRUVANANTHAPURAM , 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA STATE CO -OPERATIVE BANK , REGIONAL OFFICE, P.B. NO. 21, H.P.O. ROAD, SULTHANPET, PALAKKAD 678 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 624 6 MANAGER, THE KERALA STATE CO-OPERATIVE BANK, KOPPAM BRANCH, PALAKKAD 679 307. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 625 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14832 OF 2022 PETITIONER/S: 1 KANNUR DISTRICT EX-SERVICEMEN MULTIPURPOSE CO- OPERATIVE SOCIETY LTD. NO.C 1009, REPRESENTED BY ITS SECRETARY, P.O.PAYANGADI R.S., KANNUR - 670 358. 2 PAYANGADI PEOPLES SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD. NO.C 2044, REPRESENTED BY ITS SECRETARY, P.O.PAYANGADI R.S., KANNUR - 670 358. 3 PAYANGADI LABOUR WELFARE CO-OPERATIVE SOCIETY LTD. NO.C 1650, REPRESENTED BY ITS SECRETARY, P.O.PAYANGADI R.S., KANNUR - 670 358. 4 THE MADAI AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO.C 1838, REPRESENTED BY ITS SECRETARY, P.O.MADAI, KANNUR - 670 304. 5 NORTH MALABAR PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD. NO.C 1976, REPRESENTED BY ITS SECRETARY, PILATHARA, KANNUR - 670 501. 6 KANNUR TOURISM CO-OPERATIVE SOCIETY LIMITED (KATCOS) NO.C 1560, REPRESENTED BY ITS SECRETARY, SREEKRISHNA COMPLEX, ONDEN ROAD, KANNUR - 670 001. BY ADV SHRI.P.N.MOHANAN 2025:KER W.P(C)No.7053/2023 & Connected cases 626 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI - 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, ATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM - 695 003. 5 INCOME TAX OFFICER (TDS) MELE CHOVVA, KANNOTHUMCHAL, KANNUR - 670 006. 6 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 627 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14838 OF 2022 PETITIONER/S: KARAKULAM SERVICE CO-OPERATIVE BANK LTD KP-1/382, KARAKULAM-P.O, NEDUMANGAD, TRIVANDRUM- 695564. REPRESENTED BY ITS SECRETARY, SHRI.B.BIJUKUMAR. BY ADVS. SRI.T.M.SREEDHARAN (SR.) SRI.ALAN PRIYADARSHI DEV SRI.V.P.NARAYANAN RESPONDENT/S: 1 UNION OF INDIA DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001.REPRESENTED BY ITS SECRETARY. 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 CHAIRMAN, CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 628 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, VIKAS BHAVAN, PALAYAM, THIRUVANANTHAPURAM-695033, REPRESENTED BY ITS GENERAL MANAGER. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. VATTIYOORKAVU BRANCH, VATTIYOORKAVU,THIRUVANANTHAPURAM-695013, REPRESENTED BY ITS BRANCH MANAGER. 6 KERALA STATE CO-OPERATIVE CONSUMBER FEDERATION - CONSUMERFED GANDHINAGAR, ERNAKULAM-600020, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. SHRI.THOMAS ABRAHAM SHRI.M.SASINDRAN THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 629 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14857 OF 2022 PETITIONER/S: VILAYUR AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY P-1379, VILAYUR.P.O, PATTAMBI TALUK, PALAKKAD DISTRICT- 679309,REPRESENTED BY ITS SECRETARY SMT.GEETHA.K.S. BY ADV SRI.A.HAROON RASHEED RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001, REPRESENTED BY ITS SECRETARY. 3 THE COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS,PALAYAM, THIRUVANANTHAPURAM,PIN-695033, RERPESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. REGIONAL OFFICE, P.B.NO.21, H.P.O.ROAD, SULTHANPET, PALAKKAD-678001, REPRESENTED BY ITS GENERAL MANAGER. 2025:KER W.P(C)No.7053/2023 & Connected cases 630 6 THE MANAGER, THE KERALA STATE CO-OPERATIVE BANK, KOPPAM BRANCH, PALAKKAD-679307. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 631 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14944 OF 2022 PETITIONER/S: THRIKKATIRI MULTIPURPOSE CO-OP. SOCIETY LTD NO. P 1332 KIZHOOR ROAD, THRIKKATIRI P.O., OTTAPPALAM, PALAKKAD DISTRICT, KERALA -679 502 REPRESENTED BY ITS SECRETARY, PRASAD S. BY ADVS. SRI.K.ANAND SHRI.BENNY ANTONY PAREL RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001 2 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001 REPRESENTED BY SECRETARY 3 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN - 682 018 4 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD. 2025:KER W.P(C)No.7053/2023 & Connected cases 632 COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN 695 033 REPRESENTED BY ITS MANAGING DIRECTOR 5 THE KERALA BANK( THE KERALA STATE CO-OPERATIVE BANK LTD. REGIONAL OFFICE, PALAKKAD H.P.O ROAD, SULTHANPET, PALAKKAD 678 001 REPRESENTED BY ITS GENERAL MANAGER 6 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD. (ERSTWHILE PALAKKAD CO-OPERATIVE BANK LTD) CHERPULASSERY BRANCH, PALAKKAD 679 503, REPRESENTED BY ITS GENERAL MANAGER BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 633 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 14960 OF 2022 PETITIONER/S: THE CHERPULASSERY MUNICIPAL PRAVASI CO-OPERATIVE SOCIETY LTD NO. P 1397, CHERPULASSERY, PALAKKAD DISTRICT, KERALA-679503, REPRESENTED BY ITS SECRETARY, ABDUL NAZAR.K. BY ADV SRI.K.ANAND RESPONDENT/S: 1 THE UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE,NORTH BLOCK, RAISANA HILL, NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001, REPRESENTED BY SECRETARY. 3 THE COMMISSIONER OF INCOME TAX(TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN-682018. 4 THE KERALA BANK(THE KERALA STATE CO-OPERATIVE BANK LTD.), COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN- 695033.REPRESENTED BY ITS MANAGING DIRECTOR. 5 THE KERALA BANK (THE KERALA STATE CO-OPERATIVE BANK LTD.), 2025:KER W.P(C)No.7053/2023 & Connected cases 634 REGIONAL OFFICE, PALAKKAD.H.P.O.ROAD, SULTHANPET, PALAKKAD-678001, REPRESENTED BY ITS GENERAL MANAGER. 6 THE KERALA BANK(THE KERALA STATE CO-OPERATIVE BANK LTD.), (ERSTWHILE PALAKKAD CO-OPERATIVE BANK LTD), CHERPULASSERY BRANCH, PALAKKAD-679503, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 635 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15027 OF 2022 PETITIONER/S: THE ERNAKULAM DISTRICT CO-OPERATIVE EMPLOYEES' HOUSING CO-OPERATIVE SOCIETY LTD NO. E 933, ERNAKULA ERNAKULAM DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN 682 018. 3 THE INCOME TAX OFFICER, (TDS), INCOME TAX DEPARTMENT, ERNAKULAM- PIN 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033. 5 THE MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., ERNAKULAM MAIN BRANCH, NORTH PARUR, PIN 682 016. 2025:KER W.P(C)No.7053/2023 & Connected cases 636 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 637 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15066 OF 2022 PETITIONER/S: 1 THE PANANCHERY SERVICE CO-OPERATIVE BANK LTD NO 541 1.PANANCHERY, THRISSUR, REPRESENTED BY ITS SECRETARY., PIN - 680652 2 OLLUKKARA SERVICE CO-OPERATIVE BANK LTD.NO.544 MANNUTHY, THRISSUR. REPRESENTED BY ITS SECRETARY., PIN - 680655 3 THE VELLANIKKARA SERVICE CO-OPERATIVE BANK LTD NO. 545 VELLANIKKARA, P.O, MADAKKATRA, THRISSUR, REPRESENTED BY ITS SECRETARY., PIN - 680654 4 MOORKANIKKARA SERVICE CO-OPERATIVE BANK LTD.NO.199 4.P.O.KOZHUKULLY, THRISSUR DISTRICT , REPRESENTED BY ITS SECRETARY., PIN - 680014 5 THE KUTTANELLUR SERVICE CO-OPERATIVE BANK LTD.NO. 758 5.P.O. KUTTANELLUR, THRISSUR -14, REPRESENTED BY ITS SECRETARY., PIN - 680014 BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 638 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682 018 3 THE INCOME TAX OFFICER (TDS) 3.OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD 4.O-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SHRI.P.VIJAYAKUMAR, ASG OF INDIA CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 639 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15438 OF 2022 PETITIONER/S: 1 PAZHASSI VANITHA CO-OPERATIVE SOCIETY LTD. NO. C-1299, 8TH MILE, P.O, MAYYIL KANNUR- 670602, REPRESENTED BY ITS SECRETARY SUDHAMANI K.V. 2 IRITTY AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD, NO.C.1798, KOLIKKADAVU, P.O, PAYAM, KANNUR-670704 REPRESENTED BY ITS SECRETARY REMYA P. V. 3 SIVAPURAM VANITHA SERVICE CO-OPERATIVE SOCIETY LTD. NO. C-2086, SIVAPURAM P.O, KANNUR-670702 REPRESENTED BY ITS SECRETARY RIBINA V.K. 4 THALASSERY MUNICIPAL VANITHA SAHAKARANA SANGHAM LTD. NO.C2084, THALASSERY, KANNUR-670702 REPRESENTED BY ITS SECRETARY SINI Y.P. 5 THIRUVANGAD VANITHA SAHAKARANA SANGHAM LTD. NO.C.1782, P.O, THIRUVANGAD THALASSERY, KANNUR-670703 REPRESENTED BY ITS SECRETARY RANJISHA M.P. 6 AZHIKODE VANITHA SERVICE SAHAKARANA SANGHAM LTD. NO.C. 1505, P.O.AZHIKODE, KANNUR- 670009 REPRESENTED BY ITS SECRETARY LATHA V.V. 7 COCONUT TAPPING WORKERS SERVICE COOPERTAIVE SOCIETY (COTSCO) LTD NO.C.1080, 2025:KER W.P(C)No.7053/2023 & Connected cases 640 H.O SREEKANDAPURAM, KANNUR- 670602 REPRESENTED BY ITS SECRETARY ANIL KUMAR.P. 8 PANOOR VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO. C 1490, PANOOR P.O., KANNUR670 692 REPRESENTED BY ITS SECRETARY APARNA P.M. 9 EDAYANNUR VANITHA CO-OPERATIVE SOCIETY, LTD. NO.C.1226, EDAYANNUR P.O, KANNUR- 670595 REPRESENTED BY ITS SECRETARY JEEJA C.H. 10 THALASSERY VANITHA CO-OPERATIVE SOCIETY LTD NO. C. 1187, MAIN ROAD, THALASSERY, KANNUR-670101 REPRESENTED BY ITS SECRETARY SAVITHA P.V. 11 THE PAYANGADI CO-OPERATIVE HOUSING SOCIETY LTD NO. C. 832, P.O PAYYANGADI, KANNUR-670303 REPRESENTED BY ITS SECRETARY SREEDHEESH P.V. 12 PAZHAYANGADI AREA PUBLIC SERVANTS AND PENSIONERS WELFARE CO-OPERATIVE SOCIETY LTD. NO.C.1628, P.O PAZHAYANGADI, KANNUR670358 REPRESENTED BY ITS SECRETARY VINOD.A. 13 GRAMIKA VANITHA CO-OPERATIVE SOCIETY LTD NO. C. 1431, P.O KOORARA, KANUUR- 670694 REPRESENTED BY ITS SECRETARY VIJILA K.P. 14 ERUVESSY VANITHA CO-OPERATIVE SOCIETY LTD NO. C. 1170, P.O CHEMPERI, KANNUR- 670632 REPRESENTED BY ITS SECRETARY REMYA T.RAJ. 15 VARAPRA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD, NO.C.1449., P.O CHENDAYAD, KANNUR-670692 REPRESENTED BY ITS SECRETARY LIBISHA A.V. 16 PAYANGADI VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO. C.1658, SAFAS COMPLEX, MOTTAMBRAM, P.O MADAYI, KANNUR-670304 2025:KER W.P(C)No.7053/2023 & Connected cases 641 REPRESENTED BY ITS SECRETARY SHEEJA.V. 17 KURUMATHUR VANITHA SAHAKARANA SANGHAM LTD. NO.C.1730, KURUMATHUR P.O, KANNUR670142, REPRESENTED BY ITS SECRETARY USHA.P. 18 MANGATTIDOM VANITHA SERVICE CO-OPERATIVE SOCIETY LTD, NO.C.1433, P.O SANKARANELLUR, KANNUR-670643 REPRESENTED BY ITS SECRETARY JISHA V.K. 19 CHAVASSERY VANITHA CO-OPERATIVE SOCIETY LTD. NO.C.1511, P.O CHAVASSERY, KANNUR670702, REPRESENTED BY ITS SECRETARY SMITHA.P. 20 KANNUR VANITHA CO-OPERATIVE SOCIETY LTD, NO.C.1670, P.O., H.Q HOSPITAL, KANNUR- 670017 REPRESENTED BY ITS SECRETARY BINDU.T.M. 21 PAYYANUR BLOCK MERCHANTS AND INDUSTRIALIST WELFARE CO OPERATIVE SOCIETY, LTD NO.C1527, KANKOL P.O, KANNUR. 670307, REPRESENTED BY ITS SECRETARY SURESH A.P. 22 IRITTY MOTOR TRANSPORT AND MECHANICAL WORKERS WELFARE CO-OPERATIVE SOCIETY LTD.C.1507, IRIKKUR ROAD, IRITTY, KANNUR-670703, REPRESENTED BY ITS SECRETARY SUNITHA. M. 23 NADUVIL VILLAGE VANITHA SAHAKARANA SANGAHAM LTD.NO.C.1606, NADUVIL P.O., KANNUR-670582, REPRESENTED BY ITS SECRETARY RATHNAVALLY P.P. 24 OLAYAMBADI AGRICULTURAL WELFARE COOPERATIVE SOCIETY LTD NO. C 1918, OLAYAMBADI, KANNUR- 670306 REPRESENTED BY ITS SECRETARY SUKANYA.K. 25 KAVIYOOR VANITHA CO-OPERATIVE SOCIETY LTD.NO.C.1533, P.O OLAVILAM, KANNUR- 673313 REPRESENTED BY ITS 2025:KER W.P(C)No.7053/2023 & Connected cases 642 SECRETARY SUDHA.M. 26 PAPPINISSERI AGRICULTURE PRODUCERS AND TODDY WORKERS WELFARE CO-OPERATIVE SOCIETY LTD.NO.C-2124, PAPPINISSERI AGRICULTURE PRODUCERS AND TODDY WORKERS WELFARE CO-OPERATIVE SOCIETY LTD.NO.C-2124, (PATCO) ERIPURAM, P.O PAYANGADI, KANNUR-670303 REPRESENTED BY ITS SECRETARY RATHI A.V. 27 PANNIYANNUR PANCHAYATH VANITHA SERVICE CO-OPERATIVE SOCIETY LTD.NO.C.1472, MANEKKARA, PANNIYANNUR P.O., KANNUR670679, REPRESENTED BY ITS SECRETARY SEENA T.K. 28 SREEKANDAPURAM PATTIKAJATHI VIKASANA SAHAKARANA SANGHAM, LTD.NO.C.1072, P.O., SREEKANDAPURAM, KANNUR-670631 REPRESENTED BY ITS SECRETARY PREETHA.P. 29 THE TALIPARAMBA BLOCK VANITHA CO-OPERATIVE SOCIETY LTD, NO.C.944, TALIPARAMBA, KANNUR670141 REPRESENTED BY ITS SECRETARY MINIMOL M.V. 30 KOOVERI VILLAGE VANITHA SERVICE CO - OPERATIVE SOCIETY LTD, NO.C. 1439, KOOVERI P.O, KANNUR-670581 REPRESENTED BY ITS SECRETARY SREEJA.V.K. 31 IRITTY CO-OPERATIVE EMPLOYEES WELFARE COOPERATIVE SOCIETY LTD, NO C 1790, KEEZHUR, P.O. IRITTY, KANNUR-670703 REPRESENTED BY ITS SECRETARY PRAJITH P. 32 KUTHUPARAMBA VANITHA SERVICE CO-OPERATIVE SOCIETY LTD, NO C 1504, P.O. KUTHUPARAMBA, KANNUR-670643 REPRESENTED BY ITS SECRETARY REEJA R. 33 PAPPINISSERI VANITHA SAHAKARANA SANGAM LTD, NO C 1219, P.O. PAPPINISSERI, KANNUR-670561, REPRESENTED BY ITS SECRETARY SHEEJA E.K. 2025:KER W.P(C)No.7053/2023 & Connected cases 643 34 CHERUPAZHASSI VANITHA SAHAKARANA SANGAM, NO C 2072, ARAYIDATHUCHIRA, P.O. CHERUPAZHASSI, KANNUR-670601 REPRESENTED BY ITS SECRETARY GEETHA K. 35 KANNUR GOVERNMENT AYURVEDA COLLEGE EMPLOYEES CO- OPERATIVE SOCIETY LTD, NO C 1520, P.O. PARIYARAM, KANNUR-670503 REPRESENTED BY ITS SECRETARY SANISHA P. 36 NADUVIL PANCHAYATH VANITHA CO-OPERATIVE SOCIETY LTD, NO C 1208, P.O. KARUVANCHAL, KANNUR- 670571, REPRESENTED BY ITS SECRETARY LINTA JACOB. 37 KALAVALLOOR VANITHA CO-OPERATIVE SOCIETY LTD, NO C 1436, KUNNOTHPARAMBA, P.O. CHERUPARAMBA, KANNUR-670693 REPRESENTED BY ITS SECRETARY RANJISHA C. 38 EMPLOYEES, PENSIONERS & PUBLIC WELFARE COOPERATIVE SOCIETY LTD, NO C 1787, KODIKANDY COMPLEX, CHALODE P.O. EDAYANNUR, KANNUR- 670595 REPRESENTED BY ITS SECRETARY VINEESHA M. 39 KOTHERI VANITHA CO-OPERATIVE SOCIETY LTD, NO C 1804, KOTHERI, P.O. MATTANUR, KANNUR-670702, REPRESENTED BY ITS SECRETARY BINDU C.P. 40 MALUR PANCHAYATH VANITHA SERVICE COOPERATIVE SOCIETY LTD, NO C 1496, P.O. MALUR, KANNUR- 670702, REPRESENTED BY ITS SECRETARY AJITHA JANARDHANAN. 41 PANOOR TOWN PEOPLE'S WELFARE CO-OPERATIVE SOCIETY LTD, NO C 1917, P.O. PANOOR, KANNUR670692 REPRESENTED BY ITS SECRETARY SAYANA P.V. 42 KUNHIMANGALAM PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD, NO C 2008, ANDAMKOVVAL, KUNHIMANGALAM P.O., KANNUR-670309, REPRESENTED BY ITS SECRETARY SREERAJ K.P. 43 ERAMALA RURAL CREDIT CO-OPERATIVE SOCIETY LTD, NO D 2025:KER W.P(C)No.7053/2023 & Connected cases 644 3303, P.O. KUNNUMMAKKARA, CHOMBALA, KOZHIKODE- 673308, REPRESENTED BY ITS SECRETARY ASOKAN K.K. 44 NELLIMOODU VANITHA CO-OPERATIVE SOCIETY LTD ; NO.T.1334, NELLIMOODU P.O, THIRUVANANTHAPURAM - 695524, REPRESENTED BY ITS SECRETARY RESHMY V.R. 45 MARANALLOOR GRAMAVIKASANA CO-OPERATIVE SOCIETY LTD, NO.T.1656, OORUTTAMBALAM P.O, THIRUVANANTHAPURAM-695507 REPRESENTED BY ITS SECRETARY PRASEETHA CHANDRAN. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033 2025:KER W.P(C)No.7053/2023 & Connected cases 645 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 646 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15480 OF 2022 PETITIONER/S: ALAPPUZHA GOVT. SERVANTS' CO-OPEATIVE BANK LTD.NO A 208 COLLECTORATE JUNCTION, P.O ALAPPUZHA, PIN 685 005 REPRESENTED BY SECRETARY R SREEKUMAR. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BLDG, IS PRESS ROAD, KOCHI 682 018 3 INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX DEPT.ALAPPUZHA 688 011 4 THE KERALA STATE CO-OPERATIVE BANK LTD (ERSTWHILE ALAPPUZHA DISTRICT CO-OPERATIVE BANK) OPP MUNICIPAL TOWN HALL, ALAPPUZHA REGIONA, ALAPPUZHA, KERALA 688 011 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 647 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 648 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15487 OF 2022 PETITIONER/S: MALAPPURAM HOUSING CO-OPERATIVE SOCIETY LTD. NO.M MOONAMPADI, MALAPPURAM P.0, MALAPPURAM DISTRICT, PIN-REPRESENTED BY ITS HONORARY SECRETARY BY ADVS. SHRI.C.A.JOJO CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.E.S.M.KABEER,SC,MALAPPURAM DIST.CO- RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-11000. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018 3 THE INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O, MALAPPURAM DISTRICT, PIN-676101 4 MALAPPURAM DISCRICT CO-OPERATIV'S BANK LTD , HEAD OFFICE MARJERI MALAPPURAM PIN- 676505 REPRESENTED BY ITS GENERAL MANAGER 2025:KER W.P(C)No.7053/2023 & Connected cases 649 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 650 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15518 OF 2022 PETITIONER/S: 1 KODUNGALLUR MULTI PURPOSE CO-OPERATIVE SOCIETY LTD NO.R 1140 KODUNGALLUR P.O, THRISSUR, PIN 680 664, REPRESENTED BY ITS SECRETARY SARITHA M.S. 2 KODUNGALLUR TALUK MULTI PURPOSE CO-OPERATIVE SOCIETY LTD. NO. R 1126, PALLIVALAVU, MATHILAKAM P.O, THRISSUR DISTRICT, PIN 680 685, REPRESENTED BY SECRETARY TO SMITHA C.V. 3 ANANDAPURAM RURAL CO-OPERATIVE SOCIETY LTD. NO. R 1326, HOSPITAL JUNCTION, ANANDAPURAM P.O, THRISSUR, PIN 680 305, REPRESENTED BY ITS SECRETARY KANJANA NANDANAN. 4 IRINJALAKUDA BLOCK MULTI PURPOSE CO-OPERATIVE SOCIETY LTD. NO. R 1183, MAPRANAM, MADAYIKONAM P.O, THRISSUR, PIN 680 712, REPRESENTED BY SECRETARY K.O. SHEEBA. 5 KAIPAMANGALAM KERA KARSHAKA CO-OPERATIVE SOCIETY LTD. NO. R 1180, KAIPAMANGALAM P.O, THRISSUR, PIN 680 046, REPRESENTED BY ITS SECRETARY PREETHI M.P. 6 KODUNGALLUR TALUK, VYAPARI VYAVASAYI SAHAKARANA SANGAM LTD. NO. R 1243, KOTTAPURAM P.O, KODUNGALLUR, THRISSUR , PIN 680 687, REPRESENTED BY SECRETARY REEJA M.V. 7 KODUNGALLUR GOVERNMENT SERVANT'S CO-OPERATIVE SOCIETY 2025:KER W.P(C)No.7053/2023 & Connected cases 651 LTD. NO. R, REPRESENTED BY ITS SECRETARY REKHA M.G. 8 PERINJANAM MULTI- PURPOSE CO-OPERATIVE SOCIETY LTD. NO. R 1307, PERINJANAM P.O, THRISSUR , PIN 680 686, REPRESENTED BY ITS SECRETARY VIJAYALAKSHMI M.B. 9 PULLOOTTE VANITHA SAHAKARANA SANGAM LTD. NO. R, 1532, PULLOOTTE P.O, KODUNGALLUR, THRISSUR DISTRICT, PIN 680 663 , REPRESENTED BY ITS SECRETARY VANI VENUGOPAL. 0 KAIPAMANGALAM MULTI- PURPOSE CO-OPERATIVE SOCIETY LTD. NO. R 1376, KAIPAMANGALAM P.O, THRISSUR, PIN 680 681, REPRESENTED BY ITS SECRETARY RAGI E.N.R. 11 MANAPPURAM SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD. NO. R 1318, CHENDRAPINNI P.O, THRISSUR, PIN 680 687, REPRESENTED BY ITS SECRETARY LIJI E.N.B. 12 KAIPAMANGALAM VANITHA SAHAKARANA SANGAM LTD. NO. R 1461, MOONUPEEDIKA, PERINJANAM P.O, THRISSUR, PIN 680 686, REPRESENTED BY ITS SECRETARY JIJI V.T. 13 MURIYAD SERVICE CO-OPERATIVE BANK LTD. NO. 479, MRIYAD P.O, THRISSUR DISTRICT, PIN 680 683, REPRESENTED BY ITS SECRETARY, M.R. ANIYAN. BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI 110 001. 2025:KER W.P(C)No.7053/2023 & Connected cases 652 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS ROAD, ERNAKULAM, KOCHI 682 018. 3 THE INCOME TAX OFFICER (TDS), AYAKAR BHVAN, SAKTHAN NAGAR, THRSSUR, PIN 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., (ERSTWHILE THRISSUR DISTRICT CO-OPERATIVE BANK), SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THIRUVAMBADI P.O, THRISSUR DISTRICT CO-OPERATIVE BANK), SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, THIRUVAMBADI P.O, THRISSUR, PIN 680 022 REPRESENTED BY ITS GENERAL MANAGER. 5 KODUNGALLUR TOWN CO-OPERATIVE BANK LTD., KODUNGALLUR P.O, THRISSUR, PIN 680 664, REPRESENTED BY ITS GENERAL MANAGER. 6 IRINJALAKUDA TOWN URBAN CO-OPERATIVE BANK LTD. , TANA JUNCTION, IRINJALAKUDA P.O, PIN 680 121, REPRESENTED BY ITS GENERAL MANAGER. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 653 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15596 OF 2022 PETITIONER/S: 1 MADAI VANITHA CO-OPERATIVE SOCIETY LTD NO.C-1205, VENGARA.P.O, KANNUR-670 305. REPRESENTED BY ITS SECRETARY SUNEETHI.M.V. 2 MERCHANTS INDUSTRIALIST WELFARE CO-OPERATIVE SOCIETY LTD, NO.C-1902, KUTHUPARAMBA.P.O, KANNUR-670643 REPRESENTED BY ITS SECRETARY ASWATHI.K. 3 CENTRAL GOVERNMENT WMPLOYEES & WORKERS CO-OPERATIVE CREDIT SOCIETY LTD, NO. T 1413 USRA-17, UDARASIROMANY ROAD, VAZHUTHACAUD,SASTHAMANGALAM P.O, THIRUVANANTHAPURAM- 695010, REPRESENTED BY ITS SECRETARY MANOJ.K.C. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE , MINISTRY OF FINANCE, GOVWERNMENT OF INDIA, NORTH 2025:KER W.P(C)No.7053/2023 & Connected cases 654 BLOCK NEW DELHI-110001 2 THE CENTRAL BOARDOF DIRECT TAXES DEPARTMENT OF REVENUE , MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTHBLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S.PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, P.B.NO.6515. CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, 5 STATE OF KERALA , REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM.695001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 655 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15598 OF 2022 PETITIONER/S: 1 MADAI VANITHA CO-OPERATIVE SOCIETY LTD. NO.C-1205, VENGARA P.O., KANNUR-670 305, REPRESENTED BY ITS SECRETARY SUNEETHI.M.V. 2 MERCHANTS INDUSTRIALIST WELFARE CO-OPERATIVE SOCIETY LTD.NO.C 1902, KUTHUPARAMBA P.O., KANNUR-670 643, REPRESENTED BY ITS SECRETARY ASWATHI.K. 3 CENTRAL GOVERNMENT EMPLOYEES & WORKERS CO OPERATIVE CREDIT SOCIETY LTD.NO.T 1413, USRA-17, UDARASIROMANY ROAD, VAZHUTHACAUD, SASTHAMANGALAM P.O., THIRUVANANTHAPURAM-695 010, REPRESENTED BY ITS SECRETARY MANOJ.K.C. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH 2025:KER W.P(C)No.7053/2023 & Connected cases 656 BLOCK, NEW DELHI-110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOIME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI, ERNAKULAM-682 018. 4 THE KERALA STATE CO OPERATIVE BANK LTD., PB NO.6515, CO BANK TOWERS, PALAYM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. BY ADV SHRI.M.SASINDRAN THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 657 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15789 OF 2022 PETITIONER/S: 1 THE AMMADAM SERVICE CO-OPERATIVE BANK LTD NO. 533 AMMADAM.P.O, THRISSUR 680563 REPRESENTED BY ITS SECRETARY 2 THE PAZHUVIL SERVICE CO-OPERATIVE BANK LTD.NO.126 PAZHUVIL WEST, THRISSUR680564 REPRESENTED BY ITS SECRETARY., PIN - 680564 3 THE KOORKENCHERY SERVICE CO-OPERATIVE BANK LTD NO. 36 P.O. KOORKENHERY, THRISSUR-680007, REPRESENTED BY ITS SECRETARY -IN CHARGE. 4 THE VENGINISSERY SERVICE CO-OPERATIVE BANK LTD.NO.R 528 4.VENGINISSERY, THRISSUR 680563 REPRESENTED BY ITS SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA 1.REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682 018 2025:KER W.P(C)No.7053/2023 & Connected cases 658 3 THE INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001 4 THE KERALA STATE CO-OPERATIVE BANK LTD 4.CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SHRI.P.VIJAYAKUMAR, ASG OF INDIA CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 659 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15825 OF 2022 PETITIONER/S: 1 THE VELLATTANJUR SERVICE CO-OPERATIVE BANK LTD. NO.3906 P.O.VELLATTANJUR, THRISSUR - 680601, REPRESENTED BY ITS SECRETARY. 2 VELUR SERVICE CO-OPERATIVE BANK LTD.NO.465 THALAPPILLY TALUK, THRISSUR 680601. REPRESENTED BY ITS SECRETARY. 3 KECHERY SERVICE CO-OPERATIVE BANK LTD NO.R.286 P.O.KECHERY, THRISSUR 680501, REPRESENTED BY ITS SECRETARY. 4 THAYYUR SERVICE CO-OPERATIVE BANK LTD.NO.95 4.THAYYUR, THRISSUR DISTRICT - 680584, REPRESENTED BY ITS SECRETARY. 5 MATTOM SERVICE CO-OPERATIVE BANK LTD.NO.140 P.O. MATTOM, THRISSUR 680602, REPRESENTED BY ITS SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA 1.REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001. 2025:KER W.P(C)No.7053/2023 & Connected cases 660 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682 018 3 THE INCOME TAX OFFICER (TDS) 3.OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SHRI.P.VIJAYAKUMAR, ASG OF INDIA CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 661 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15828 OF 2022 PETITIONER/S: 1 THE KARAMUCK SERVICE CO-OPERATIVE BANK LTD. NO.16 KARAMUCK, THRISSUR 680613, REPRESENTED BY ITS SECRETARY. 2 THE MANALUR SERVICE CO-OPERATIVE BANK LTD.NO.3 P.O.MANALUR, THRISSUR-680617. REPRESENTED BY ITS SECRETARY. 3 THE ANTHIKAD SERVICE CO-OPERATIVE SOCIETY LTD NO. 818 P.O. ANTHIKAD, THRISSUR 680641 , REPRESENTED BY ITS SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELH, PIN - 110001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682018 3 THE INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR, PIN - 680001 2025:KER W.P(C)No.7053/2023 & Connected cases 662 4 THE KERALA STATE CO-OPERATIVE BANK LTD CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695033 BY ADVS. SHRI.P.VIJAYAKUMAR, ASG OF INDIA CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.M.JAYAKRISHNAN, CGC SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 663 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 15874 OF 2022 PETITIONER/S: 1 THE PANANGAD SERVICE CO-OPERATIVE BANK LIMITED NO. 3928 POST BALUSSERY, KOZHIKODE , REPRESENTED BY THE SECRETARY, PIN - 673612 2 CHATHAMANGALAM SERVICE CO-OPERATIVE BANK LIMITED NO. F-1839 POST CHATHAMANGALAM, KOZHIKODE , REPRESENTED BY THE SECRETARY, PIN - 673601 3 SIVAPURAM SERVICE CO-OPERATIVE BANK LIMITED NO. 6967 POST KARIYATHANKAVU, VIA BALUSSERY, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673612 4 THAMARASSERY SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1239 POST THAMARASSERY, KOZHIKODE , REPRESENTED BY THE SECRETARY, PIN - 673573 5 UNNIKULAM SERVICE CO-OPERATIVE BANK LIMITED NO. D- 2356 POST EKAROOL, KOZHIKODE , REPRESENTED BY THE SECRETARY, PIN - 673574 6 CHELANNUR SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1242 POST CHELANNUR, KOZHIKODE , REPRESENTED BY THE SECRETARY, PIN - 673616 7 KARANNUR SERVICE CO-OPERATIVE BANK LIMITED NO. F-1244 POST ELATHUR, KOZHIKODE, REPRESENTED BY THE 2025:KER W.P(C)No.7053/2023 & Connected cases 664 SECRETARY, PIN - 673303 8 NANMINDA CO-OPERATIVE RURAL BANK LIMITED NO. F-1238 POST NANMINDA, KOZHIKODE, REPRESENTED BY THE GENERAL MANGER, PIN - 673613 9 KAKKUR SERVICE CO-OPERATIVE BANK LIMITED NO. LL-33 POST KAKKOOR, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673613 10 CHELAVOOR SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1513 POST CHELAVOOR, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673571 11 THE CALICUT NORTH SERVICE CO-OPERATIVE BANK LIMITED NO. LL - 37 POST KARUVASSERY, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673010 12 VENGERI SERVICE CO-OPERATIVE BANK LIMITED NO. 2714 POST VENGERI, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673010 13 RAMANATTUKARA SERVICE CO-OPERATIVE BANK LIMITED NO. 7721 POST FEROKE COLLEGE, KOZHIKODE, REPRESENTED BY THE GENERAL MANAGER, PIN - 673633 14 KURUVATTOOR SERVICE CO-OPERATIVE BANK LIMITED NO. D- 1973 POST KURUVATTOOR, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673811 15 PERUMANNA SERVICE CO-OPERATIVE BANK LIMITED NO. D- 1955 POST PERUMANNA, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673019 16 PERUVAYAL SERVICE CO-OPERATIVE BANK LIMITED NO. LL-26 POST PERUVAYAL, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673008 17 KOMMERI SERVICE CO-OPERATIVE BANK LIMITED NO. D-2022 2025:KER W.P(C)No.7053/2023 & Connected cases 665 POST KOMMERI, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673007 18 THE BEYPORE SERVICE CO-OPERATIVE BANK LIMITED NO. LL - 35 POST ARAKKINAR, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673028 19 KUNNAMANGALAM CO-OPERATIVE RURAL BANK LIMITED NO. F- 1246 POST KUNNAMANGALAM KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673570 20 THE FEROKE SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1095 POST FEROKE, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673631 21 PUTHIYANGADI SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1421 POST PUTHIYANGADI, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673021 22 THE CHERUKULATHOOR SERVICE CO-OPERATIVE BANK LIMITED NO. F-775 POST CHERUKULATHOOR, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673008 23 THE MAVOOR SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1247 POST MAVOOR, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673661 24 IRINGALLUR - PALAZHY SERVICE CO-OPERATIVE BANK LIMITED NO. F-1171 POST PALAZHY, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673014 25 THE KADALUNDI SERVICE CO-OPERATIVE BANK LIMITED NO. F-1500 POST KADALUNDI, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673302 26 THE CALICUT TOWN SERVICE CO-OPERATIVE BANK LIMITED 2025:KER W.P(C)No.7053/2023 & Connected cases 666 NO. D-2665 A.G. ROAD, KOZHIKODE, REPRESENTED BY THE GENERAL MANAGER., PIN - 673001 27 OLAVANNA SERVICE CO-OPERATIVE BANK LIMITED NO. 2663 POST OLAVANNA, KOZHIKODE REPRESENTED BY THE SECRETARY., PIN - 673019 28 MANNUR SERVICE CO-OPERATIVE RURAL BANK LIMITED NO. F- 1621 POST MANNUR, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673328 29 KATTIPPARA SERVICE CO-OPERATIVE BANK LIMITED NO. D- 2930 POST KATTIPPARA, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673573 30 AVILORA SERVICE CO-OPERATIVE BANK LIMITED NO. LL-69 POST AVILORA, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673572 31 PUDUPPADY SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1830 PUDUPPADY, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673586 32 NARIKKUNI SERVICE CO-OPERATIVE BANK LIMITED NO. LL- 143 POST NARIKKUNI, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673585 33 KODUVALLY SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1240 POST KODUVALLY, KOZHIKODE , REPRESENTED BY THE SECRETARY., PIN - 673572 34 THE THIRUVAMBADY SERVICE CO-OPERATIVE BANK LIMITED NO. L-56 POST THIRUVAMBADY, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673603 35 KODANCHERY SERVICE CO-OPERATIVE BANK LIMITED NO. F- 1762 2025:KER W.P(C)No.7053/2023 & Connected cases 667 POST KODANCHERY, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673580 36 KOODARANHI SERVICE CO-OPERATIVE BANK LIMITED NO. LL- 74 POST KOODARANHI, KOZHIKODE. REPRESENTED BY THE SECRETARY., PIN - 673604 37 KODIYATHOOR SERVICE CO-OPERATIVE BANK LIMITED NO. D- 2417 ERANJIMAVU, POST PANNICODE, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673602 38 PANNIYANKARA SERVICE CO-OPERATIVE BANK LIMITED NO. D- 2694 P.O. KALLAI, KOZHIKODE, REPRESENTED BY THE SECRETARY., PIN - 673003 BY ADVS. SRI.R.SUDHISH SMT.M.MANJU SHRI.PRASHANTH KUMAR G.C. RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI., PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT) MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, ERNAKULAM, PIN - 682018 2025:KER W.P(C)No.7053/2023 & Connected cases 668 4 KERALA STATE CO-OPERATIVE BANK LIMITED RREPRESENTED BY ITS CHIEF EXECUTIVE OFFICER CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695033 5 STATE OF KERALA REPRESENTED BY SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM., PIN - 695001 6 REGISTRAR OF CO-OPERATIVE SOCIETIES OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, STATUE JUNCTION, NEAR PRESS CLUB, THIRUVANANTHAPURAM., PIN - 695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.C.SASIDHARAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 669 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 16074 OF 2022 PETITIONER/S: 1 THE KUTTEMPEROOR SERVICE CO-OPERATIVE BANK LTD.NO.611, KUTTEMPEROOR P.O., MANNAR, ALAPPUZHA-689 623. REPRESENTED BY ITS SECRETARY SAJIKUMAR P.R. 2 THE BUDHANOOR SERVICE CO-OPERATIVE BANK LTD NO. A- 137, BUDHANOOR P.O., CHENGANNUR, ALAPPUZHA-689510, REPRESENTED BY ITS SECRETARY OMANA C.S. 3 ALA SERVICE CO-OPERATIVE BANK LTD NO 2123, PENNUKKARA P.O., CHENGANNUR, ALAPPUZHA-689520 REPRESENTED BY ITS SECRETARY SREEJITH S. 4 CHERIYANAD SERVICE CO-OPERATIVE BANK LTD NO 99, CHERIYANAD P.O., CHENGANNUR, ALAPPUZHA-689511 REPRESENTED BY ITS SECRETARY SANDHYA KUMARI S. 5 MANNAR SERVICE CO-OPERATIVE BANK LTD, NO 3997, MANNAR P.Q., ALAPPUZHA-689622 REPRESENTED BY ITS SECRETARY GREESHMA ROSE GEORGY. 6 KUTTEMPEROOR SERVICE CO-OPERATIVE BANK LTD NO. 1654,4, KUTTEMPEROOR P.O., ALAPPUZHA689 623. REPRESENTED BY ITS SECRETARY AJITHA.K.G. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. 2025:KER W.P(C)No.7053/2023 & Connected cases 670 SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI: 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES , DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695001. BY ADV SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 671 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 16243 OF 2022 PETITIONER/S: ALUVA DESABHIVARDHINI SERVICE CO-OPERATIVE BANK LIMITED CO-OPERATIVE BUILDING, BYE PASS ROAD, PULINCHODE, ALUVA, PIN-683 101, REPRESENTED BY ITS SECRETARY A.H ABDUL RASHEED BY ADVS. SHRI.K.S.HARIHARAN NAIR SMT.G.REMADEVI SHRI.RAJATH R NATH SMT.HARIMA HARIHARAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE ,MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001. 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI- 682018 3 THE INCOME TAX OFFICER (TDS), KAP COMPLEX, HIGHWAY, SH 16, PERIYAR NAGAR, ALUVA, PIN- 683101 2025:KER W.P(C)No.7053/2023 & Connected cases 672 4 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 5 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDI IS PRESS ROAD, KOCHI- 682018. 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-695003 7 THE KERALA STATE CO-OPERATIVE BANK LTD. (KERALA BANK) PO NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN- 695 033, REPRESENTED BY ITS MANAGING DIRECTOR 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN-695 001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 673 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 16321 OF 2022 PETITIONER/S: THE ELANTHOOR SERVICE CO-OPERATIVE BANK LTD NO.460, ELANTHOOR P.O, KOZHENCHERRY, PATHANAMTHITTA DISTRICT- 689643 REPRESENTED BY ITS SECRETARY MRS. VEENA V.A,AGED 35,W/O. DINESH CHANDRAN, RESIDING AT VAZHAVILA PUTHENPARAMBIL, LAKKOOR,MALLASSERRY P.O,PATHANAMTHITTA DISTRICT, PIN - 689646 BY ADV SRI.V.PHILIP MATHEWS RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO GOVERNMENT,MINISTRY OF FINANCE , NORTH BLOCK, RAISANA HILL, NEW DELHI, PIN - 110001 2 STATE OF KERALA REPRESENTED BY BY SECRETARY, DEPARTMENT OF CO- OPERATION, KERALA GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION,MINISTRY OF FINANCE, CENTRAL REVENUE BUILDING,I.S.PRESS ROAD,ERNAKULAM, PIN - 682018 4 THE INCOMETAX OFFICER(TDS) AARATTUKULAKKARA COMPLEX,A.N. PURAM,ALAPPUZHA, PIN - 688011 2025:KER W.P(C)No.7053/2023 & Connected cases 674 5 THE KERALA STATE CO-OPERATIVE BANK LTD COBANK TOWERS,PALAYAM,THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033 6 THE DEPUTY GENERAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD(ERSTWHILE PATHANAMTHITTA DISTRICT CO-OPERATIVE BANK LTD),PATHANAMTHITTA DISTRICT OFFICE,MYLAPRA ROAD,PATHANAMTHITTA, PIN - 689645 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 675 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 16459 OF 2022 PETITIONER/S: PERUMPAZHUTHOOR SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD.NO.T 1952, PERUMPAZHUTHOOR P.O., NEYYATTINKARA, THIRUVANANTHAPURAM-695126 ,REPRESENTED BY ITS SECRETARY BY ADVS. SHRI.MOHAN DAS A. SHRI.GOVIND R. RESPONDENT/S: 1 UNION OF INDIA DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, RAISINA HILL, NEW DELHI - 110001 REPRESENTED BY THE SECRETARY TO THE GOVERNMENT OF INDIA 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI - 110001 REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, ERNAKULAM - 682018 2025:KER W.P(C)No.7053/2023 & Connected cases 676 4 ADDITIONAL COMMISSIONER OF INCOME TAX . TDS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695003 5 INCOME TAX OFFICER(TDS) 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANTHAPURAM- 695003, 6 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE THIRUVANANTHAPURAM DISTRICT CO-OPERATIVE BANK LTD), P.B.NO. 5122, EAST FORT, FORT.P.O,THIRUVANANTHAPURAM 695 023 REPRESENTED BY ITS MANAGER. 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 677 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 16598 OF 2022 PETITIONER/S: 1 VATKARA BLOCK PENSIONERS SOCIAL WELFARE SAHAKARANA SANGAM LTD. NO. D 3213, V.V. ARCADE, VELLIKULANGARA, ORKKATTERI P.O, KOZHIKODE 673 501, REPRESENTED BY ITS SECRETARY PRAJEESH K. 2 VELLIKULANGARA AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO. D 3143, ORKKATTERI P.O, VATAKARA, KOZHIKODE 673 501, REPRESENTED BY ITS SECRETARY SAVITHA A. 3 VATAKARA BLOCK AGRICULTURIST AND WORKERS WELFARE CO- OPERATIVE SOCIETY LTD. NO. D 3152, ORIKKATTERI P.O, VATAKARA, KOZHIKODE 673 501., REPRESENTED BY ITS SECRETARY SANTHOSH A.K. 4 CHORODE PANCHAYATH AGRICULTURAL WORKERS WELFARE CO- OPERATIVE SOCIETY LTD. NO. D 3191, VAIKKILASSERY THERU, VAIKKILASSERY P.O, VATAKARA, KOZHIKODE 673 104, REPRESENTED BY ITS SECRETARY, SATHEESHKUMAR K. 5 NEERVELI VANITHA SERVICE CO-OPERTIVE SOCIETY LTD. NO. C 1409, NEERVELI P.O, KANNUR 670 701, REPRESENTED BY ITS SECRETARY MINI. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. 2025:KER W.P(C)No.7053/2023 & Connected cases 678 SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE , MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110 001. 2 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. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI 682 018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., P.B. NO. 6515, CO- BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695 001. BY ADVS. SRI.CHRISTOPHER ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 679 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 16805 OF 2022 PETITIONER/S: THE EZHUMATTOOR SERVICE CO-OPERATIVE BANK LTD. NO.1546 EZHUMATTOOR P.O.,PATHANAMTHITTA - 689586, REPRESENTED BY ITS SECRETARY ALEXANDER C. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA,NORTH BLOCK NEW DELHI- 110001,REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, 2025:KER W.P(C)No.7053/2023 & Connected cases 680 KERALA REGION,MINISTRY OF FINANCE, GOVERNMENT OF INDIA,CENTRAL REVENUE BUILDINGS,IS PRESS ROAD,KOCHI- 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO. 6515, CO-BANK TOWERS,PALAYAM,THIRUVANANTHAPURAM- 695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT,GOVERNMENT OF KERALA,THIRUVANANTHAPURAM- 695001. BY ADVS. SRI.NAVANEETH.N.NATH CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 681 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 16881 OF 2022 PETITIONER/S: KARAMVELY SERVICE CO-OPERATIVE SOCIETY LTD NO.PT.45 AGED 48 YEARS NELLIKKALA.P.O., MALLAPPUZHASSERRY, PATHANAMTHITTA DISTRICT REPRESENTED BY ITS SECRETARY THULASIDAS.R, AGED 48, W/O. SURESH KUMAR, RESIDING AT MUNDUVELIL HOUSE, PRAMADAM, MALLASSERRY.P.O., PATHANAMTHITTA, PIN - 689643 BY ADV SRI.V.PHILIP MATHEWS RESPONDENT/S: 1 UNION OF INDIA UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI., PIN - 110001 2 STATE OF KERALA REPRESENTED BY SECRETARY, DEPARTMENT OF CO-OPERATION, KERALA GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM., PIN - 695001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM., PIN - 682018 4 INCOME TAX OFFICER (TDS) AARATTUKULAKKARA COMPLEX, A.N. PURAM, ALAPPUZHA., PIN - 688011 2025:KER W.P(C)No.7053/2023 & Connected cases 682 5 THE KERALA STATE CO-OPERATIVE BANK LTD, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695033 6 THE DEPUTY GENERAL MANAGER KERALA STATE CO-OPERATIVE BANK LTD, PATHANAMTHITTA DISTRICT OFFICE, MYLAPRA ROAD, PATHANAMTHITTA -, PIN - 689645 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 683 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 17323 OF 2022 PETITIONER/S: 1 MAHATHMA VANITHA SAHAKARANA SANGHAM LTD.NO.C 1677 KALLIKKANDY P.O., KANNUR-670693 REPRESENTED BY ITS SECRETARY SREEJISHA K. 2 PARAT VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1660, THOOVAKKUNNU, KANNUR - 670693 REPRESENTED BY ITS SECRETARY PREETHA K.T.K. 3 THUVAKKUNNU VANITHA SERVICE CO-OPERATIVE SOCIETY LTD C 1437 THUVAKKUNNU P.O., KANNUR -670 693 REPRESENTED BY ITS SECRETARY VINCY V.P. 4 KADIRUR VILLAGE VANITHA SAHAKARANA SANGHAM LTD C 1799 KADIRUR P.O., KANNUR - 670642 REPRESENTED BY ITS SECRETARY SHEENA K. 5 KOTTIYODI VANITHA SERVICE CO-OPERATIVE LTD NO. C 1796 PATHAYAKUNNU P.O., KANNUR - 670691 REPRESENTED BY ITS SECRETARY BINDU K. 6 MOKERI VANITHA CO-OPERATIVE SOCIETY LTD. NO.C 1150 VALLAYAYI, MUTHIYANGA P.O., KANNUR - 670 691 REPRESENTED BY ITS SECRETARY A.V.SHEHEERA. 7 PERAVOOR PANCHAYATH VANITHA COOPERATIVE SOCIETY LTD NO. C 1211 PERAVOOR P.O., KANNUR-670 673 REPRESENTED BY ITS SECRETARY BINDHU G. 2025:KER W.P(C)No.7053/2023 & Connected cases 684 8 KOLAVALLOOR VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1436 CHERUPARAMBA P.O., KANNUR 670693 REPRESENTED BY ITS SECRETARY RANJISHA C. 9 URUVACHAL VANITHA SERVICE CO-OPERATIVE SOCIETY LTD NO. C 1476 URAVACHAL, KANNUR 670702 REPRESENTED BY ITS SECRETARY SAJALA K. 10 VALAPATTANAM VANITHA CO-OPERATIVE SOCIETY LTD NO. C 1155 VALAPATTANAM P.O., KANNUR-670010 REPRESENTED BY ITS SECRETARY SASIKALA P. 11 ULIYIL RURAL DEVELOPMENT CO-OPERATIVE SOCIETY LTD NO. C 2067 ULIYIL P.O., KANNUR 670702 REPRESENTED BY ITS SECRETARY ANOOP KUMAR P.K. 12 PAPPINISSERI WEST VANITHA SERVICE SAHAKARANA SANGAM LTD C 1441 KARIKKANKULAM, KANNUR-670561 REPRESENTED BY ITS SECRETARY SHEEJA K.V. 13 EZHOME PANCHAYATH VANITHA KSHEMA SAHAKARANA SANGHAM LTD NO. C 1501 PAZHAYANGADI, KANNUR-670303 REPRESENTED BY ITS SECRETARY SAJITHA THAZHATH VALAPP. 14 AZHIKODE TOWN VANITHA SERVICE COOPERATIVE SOCIETY LTD NO.1583 AZHIKODE P.O., KANNUR-670009 REPRESENTED BY ITS SECRETARY SHEEBA K.V. 15 PALAKKAD PRAVASI CO-OPERATIVE SOCIETY (PAPCOS) LTD NO. P 1355 KODATHIPPADI, MANNARKKAD, PALAKKAD-678582 REPRESENTED BY ITS SECRETARY SHAMLA K.P. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. 2025:KER W.P(C)No.7053/2023 & Connected cases 685 SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL SHRI.T.T.BIJU SHRI.SANAND RAMAKRISHNAN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD. PB NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM - 695 001. BY ADVS. SHRI.S.VAIDYANATHAN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 686 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 17707 OF 2022 PETITIONER/S: GOVT.EMPLOYEE'S CO-OPERATIVE BANK LTD., NO.57, KOLLAM-691 013, REPRESENTED BY ITS SECRETARY RENJITH.K.R. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001. 2 THE CENTRAL BOARD OF DIRECTOR TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110 001, REPRESENTED BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 687 INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682 018. 4 THE KERALA STATE CO OPERATIVE BANK LTD., PB NO.6515, CO BANK TOWERS, PALAYM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-695 001. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 688 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 17716 OF 2022 PETITIONER/S: 1 ITTIVA RURAL CO-OPERATIVE SOCIETY LTD NO.Q.1404. VYYANAM P.O., KOLLAM-691533 REPRESENTED BY ITS SECRETARY USHAKUMARI S. 2 KOLLAM VYPARI VYAVASAYI CO-OPERATIVE SOCIETY LTD NO. Q 1576, ANCHALUMMOODU, PERINAD P.O., KOLLAM- 691601 ,REPRESENTED BY ITS SECRETARY AFZAL F. BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001. 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-110001, REPRESENTED 2025:KER W.P(C)No.7053/2023 & Connected cases 689 BY ITS CHAIRMAN. 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI- 682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM- 695001. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 690 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 17796 OF 2022 PETITIONER/S: ANNAMANADA TOWN MARKETING CO-OPERATIVE SOCIETY LIMITED NO.1001, ANNAMANADA P.O., THRISSUR, PIN - 680 741, REP. BY ITS SECRETARY. BY ADV SHRI.FRANCO T.J. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, IS PRESS ROAD, KOCHI - 682 018. 3 THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, MUNICIPAL OFFICE ROAD, THRISSUR, PIN - 680 001. 4 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. 5 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF 2025:KER W.P(C)No.7053/2023 & Connected cases 691 INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI - 682 018. 6 ADDITIONAL COMMISSIONER OF INCOME TAX, TOS RANGE, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM - 695 003. 7 THE KERALA STATE CO-OPERATIVE BANK LTD., (KERALA BANK) P.B.NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. 8 THE BRANCH MANAGER, KERALA STATE CO-OPERATIVE BANK LTD. (KERALA BANK, ANNAMANADA (BR.) P.O.ANNAMANADA, THRISSUR DISTRICT - 680 741. 9 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN - 695 001. BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 692 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 18070 OF 2022 PETITIONER/S: THE KODUMON RUBBER PLANTATION EEMPLOYEES CO-OPERATIVE BANK LTD NO. P.T.24, KORUVILA, NEDUMONCAVU P.O, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S. PRESS ROAD, ERNAKULAM, PIN 682 018. 3 THE INCOME TAX OFFICER, (TDS), AARATTUKULAKKARA COPLEX, A.N.PURAM, ALAPPUZHA DISTRICT, 686 011. 4 THE KERALA STATE CO-OPERATIVE BANK LTD., COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN 695 033. 5 THE DEPUTY GENERAL MANAGER, 2025:KER W.P(C)No.7053/2023 & Connected cases 693 KERALA STATE CO-OPERATIVE BANK LTD. , PATHANAMTHITTA DISTRICT, OFFICE, PATHANAMTHITTA, PIN 689 645. BY ADV SHRI.ANILKUMAR C.R., CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 694 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 18489 OF 2022 PETITIONER/S: 1 THIRU KOCHI SAMOOHYA KSHEMA SAHAKARANA SANGHAM LTD NO E-1346 [TSKSS LTD NO E -1346], SRM ROAD, PACHALAM, KOCHI- 682012. REPRESENTED BY ITS HONORARY SECRETARY, A.M VAJRABALA RAO. 2 THE CENTRAL BOARD OF DIRECT TAXES[CBDT], DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001, REPRESENTED BY ITS CHAIRMAN. 3 THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, COCHIN -682018. 4 INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICE (TDS), AAYAKAR BHAVAN, SAKATHAN THAMPURAN NAGAR, THRISSUR -680001. 5 THE KERALA STATE CO-OPERATIVE BANK LTD [KERALA BANK] P.B.NO. 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM -695033. REPRESENTED BY ITS CHIEF GENERAL MANAGER. 6 STATE OF KERALA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF COOPERATION, SECRETARIAT, THIRUVANANTHAPURAM -695001. 7 THE REGISTRAR OF CO-OPERATIVE SOCIETIES KERALA, JAWAHAR THYCAUD P.O, SAHAKARANA DPI JUNCTION, 2025:KER W.P(C)No.7053/2023 & Connected cases 695 BHAVAN, THIRUVANANTHAPURAM -695014. 8 THE MANAGER KERALA STATE CO-OPERATIVE BANK [KERALA BANK], PACHALAM BRANCH, ERNAKULAM -682012. BY ADVS. SRI.DIPU.R SRI.K.S.BAIJU SMT. DEVI KRIPA R. SMT.P.V.SARITHA VENUGOPAL SMT.DHANYA BABU SMT.P.A.PRIYA SMT.NEETHU SASI RESPONDENT/S: UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINNACE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI - 110001. BY ADV SMT.KRISHNA S., CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 696 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 18690 OF 2022 PETITIONER/S: THE ELAKAMON PANCHAYATH RESIDENCE WELFARE CO- OPERATIVE SOCIETY LTD NO. 1546, PALAYAMKUNNU P.O., VARKALA, THIRUVANANTHAPURAM-695146 REPRESENTED BY ITS SECRETARY GANGA S BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN 2025:KER W.P(C)No.7053/2023 & Connected cases 697 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI-682018. 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-695001 BY ADVS. SHRI.N.J.ASHWIN, CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.THOMAS ABRAHAM SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 698 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 20028 OF 2022 PETITIONER/S: THE IDUKKI DISTRICT DEALERS CO-OPERATIVE SOCIETY LTD NO. 1-401, REPRESENTED BY ITS SECRETARY, SINDHU VIJU, W/O. S. VIJU, HEAD OFFICE, NEDUMKANDAM POST, UDUMBANCHOLA TALUK, IDUKKI DISTRICT - 685 553. BY ADVS. SRI.GEORGE MATHEW SRI.M.D.SASIKUMARAN SHRI.PRAVEEN S. SHRI.SUNIL KUMAR A.G SHRI.GEORGE K.V. SHRI.MATHEW K.T. SHRI.STEPHY K REGI SRI.DIPU JAMES RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 002. 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDINGS I.S. PRESS ROAD, KOCHI - 682 018. 3 THE INCOME TAX OFFICER, 2025:KER W.P(C)No.7053/2023 & Connected cases 699 TDS OFFICE, MAHIMA TOWERS, STATE HIGHWAY - 8, THODUPUZHA, IDUKKI DISTRICT - 685 584. 4 STATE OF KERALA, REP. BY ITS SECRETARY, FINANCE DEPARTMENT, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM - 695 001. 5 REGISTRAR OF CO-OPERATIVE SOCIETIES, OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD, THIRUVANANTHAPURAM - 695 014. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., (KERALA BANK) REP. BY ITS MANAGING DIRECTOR & CHIEF EXECUTIVE OFFICER, COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM - 695 033. 7 THE DEPUTY GENERAL MANAGER, CENTRAL PROCESSING CENTER, THE KERALA STATE CO- OPERATIVE BANK LTD., (KERALA BANK), VAZHATHOPE, IDUKKI COLONY P.O., IDUKKI DISTRICT - 685 602. BY ADVS. GOVERNMENT PLEADER CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.PRAVEEN K.V., CGC SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 700 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 21287 OF 2022 PETITIONER/S: ANAMALA COLLECTIVE FARMING CO-OPERATIVE SOCIETY REG NO. 478 , PARIYARAM P.O., CHALAKUDY VIA THRISSUR DISTRICT, REPRESENTED SECRETARY, PV VIVEK, PIN - 686021 BY ADVS. SRI.MANU GOVIND SHRI.AYESHA MARIA JOHN RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK RAISANA HILL, NEW DELHI, PIN - 110001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, IS PRESS ROAD, ERNAKULAM, PIN - 682018 3 THE INCOME TAX OFFICER(TDS) INCOME TAX BUILDINGS, I.S.PRESS ROAD, ERNAKULAM-, PIN - 682018 4 THE KERALA STATE COOPERATIVE BANK CO-BANK TOWERS, VIKAS BHAVAN, P.O PALAYAM, THIRUVANANTHAPURAM REPRESENTED BY CHIEF EXECUTIVE 2025:KER W.P(C)No.7053/2023 & Connected cases 701 OFFICER, PIN - 698013 5 THE KERALA STATE COOPERATIVE BANK TKV TOWER, RAILWAY STATION RD, NORTH CHALAKUDY, CHALAKUDY, KERALA REPRESENTED BY ITS GENERAL MANAGER, PIN - 680307 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.B.G.HARINDRANATH (SR.) SHRI.AMITH KRISHNAN H. SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 702 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 21639 OF 2022 PETITIONER/S: THE MANAGING COMMITTEE OF KUNNICODE AGRICULTURAL IMPROVEMNENT CO-OPERATIVE SOCEITY LTD NO Q NO.1594 REPRESENTED BY ITS PRESIDENT, KUNNICODE P.O.KOLLAM- 691 508. BY ADV SHRI.P.N.MOHANAN RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001. 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-110001, REPRESENTED BY ITS CHAIRMAN 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX , KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, IS PRESS ROAD, KOCHI- 682 018. 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-695 003. 5 INCOME TAX OFFICER (TDS), 2025:KER W.P(C)No.7053/2023 & Connected cases 703 SREENEELAPADMAM, PARAMESWARA NAGAR, HOSPITAL ROAD, KOLLAM-691 001. 6 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM-695 033, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 7 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM-695 001. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 704 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 21922 OF 2022 PETITIONER/S: THE THALAVOOR RURAL CO-OPERATIVE SOCIETY LTD. NO.Q 1428, REPRESENTED BY ITS SECRETARY, THALAVOOR P.O, KOLLAM DISTRICT, PIN - 691508 BY ADVS. SRI.ARJUN RAGHAVAN SHRI.T.R.HARIKUMAR RESPONDENT/S: 1 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, PIN - 695003 2 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, PIN - 110001 3 3. UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA MINISTRY OF FINANCE, NORTH BLOCK, CABINET SECRETARIAT, RAISANA HILL, NEW DELHI, PIN - 110001 2025:KER W.P(C)No.7053/2023 & Connected cases 705 4 4. THE REGISTRAR OF CO-OPERATIVE SOCIETIES JAWAHAR SAHAKARANA BHAVAN, DPI JUNCTION, THYCAUD P.O, THIRUVANANTHAPURAM, PIN - 695014 5 STATE OF KERALA, REPRESENTED BY THE SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANNATHAPURAM, PIN - 695001 6 6. THE KERALA STATE CO-OPERATIVE BANK , REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER P.B NO.6515, CO-BANK TOWERS, PALAYAM, THIRUVANATHAPURAM, PIN - 695033 BY ADVS. SRI.CHRISTOPHER ABRAHAM SRI.P.C.SASIDHARAN, SC, KOLLAM DISTRICT CO-OPERATIVE BANK LTD. THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 706 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 22198 OF 2022 PETITIONER/S: KOLARI VANITHA CO-OPERATIVE SOCIETY LTD. NO. C-1648 PALOTTUPALLY, MATTANNUR P.O., KANNUR REPRESENTED BY ITS SECRETARY DHANYA M, PIN - 670702 BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL 2025:KER W.P(C)No.7053/2023 & Connected cases 707 REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515 CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033 REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695001 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. SHRI.M.B.SUDARSANA KUMAR, CGC SRI.CHRISTOPHER ABRAHAM CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 708 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 22339 OF 2022 PETITIONER/S: 1 1. MULLASSERY BLOCK PANCHAYATH MULTIPURPOSE CO OPERATIVE SOCIETY LTD NO. R 1202, POOVATHOOR P O, THRISSUR DISTRICT, PIN 680508 REPRESENTED BY SECRETARY PRAVITHA P.K 2 2. COCONUT FARMERS WELFARE CO-OPERATIVE SOCIETY LTD NO.R 1377, K.K.M SHOPPING COMPLEX, CHITATTUKARA P.O, THRISSUR-680 511 REPRESENTED BY ITS SECRETARY SIMILE V.L BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110000. 2 THE COMMISSIONER OF INCOME TAX (TDS) (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI- 682018 3 THE INCOME TAX OFFICER(TDS) AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680001 4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE THRISSUR DISTRICT CO-OPERTAIVE BANK) SAHAKARANA SAPTHDHI MANDIRAM, TUDA ROAD, 2025:KER W.P(C)No.7053/2023 & Connected cases 709 THRIRUVAMBADI P.O, THRISSUR, PIN-680022 REPRESENTED BY ITS GENERAL MANAGER, BY ADVS. SHRI.R.MURALEEKRISHNAN (MALAKKARA), CGC CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.P.C.SASIDHARAN, SC, THRISSUR DISTRICT CO.OPERATIVE BANK LTD. SRI.CHRISTOPHER ABRAHAM SRI.MANU.S, CGC SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 710 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 22917 OF 2022 PETITIONER/S: MALAYAINKEEZHU AGRICULTURAL DEVELOPMENT CO-OPERATIVE SOCIETY LTD. NO. T-1866, MALAYAINKEEZHU P.O., THIRUVANANTHAPURAM REPRESENTED BY ITS SECRETARY KAVITHA C.R, PIN - 695571 BY ADVS. DR.K.P.PRADEEP SHRI.SANAND RAMAKRISHNAN SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA 2025:KER W.P(C)No.7053/2023 & Connected cases 711 REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515 CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. SRI.K.V.SREE VINAYAKAN CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 712 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 23239 OF 2022 PETITIONER/S: VADAKKEKAD SERVICE CO-OPERATIVE BANK LTD VADAKKEKAD SERVICE CO-OPERATIVE BANK LTD NO. P 562 VADAKKEKAD P.O, THRISSUR, PIN-679 526 REPRESENTED BY ITS SECRETARY BY ADV SHRI.C.A.JOJO RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001 2 THE COMMISSIONER OF INCOME TAX (TDS) 2. THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI-682018 3 THE INCOME TAX OFFICER(TDS) THE INCOME TAX OFFICER(TDS) AYAKAR BHAVAN, SAKTHAN NAGAR, THRISSUR PIN-680001 4 THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE THRISSUR SERVICE CO-OPERATIVE BANK) THE KERALA STATE CO-OPERATIVE BANK LTD, (ERSTWHILE THRISSUR SERVICE CO-OPERATIVE BANK), HEAD OFFICE, THRISSUR-680001 REPRESENTED BY ITS GENERAL MANAGER 2025:KER W.P(C)No.7053/2023 & Connected cases 713 5 GURUVAYOOR URBAN CO-OPERATIVE BANK LTD GURUVAYOOR URBAN CO-OPERATIVE BANK LTD NEAR THAIKAD, CHOONDAL ROAD, GURUVAYOOR P.O THRISSUR DISTRICT, PIN- 680104 REPRESENTED BY ITS GENERAL MANAGER BY ADVS. SRI.CHRISTOPHER ABRAHAM SRI.P.C.SASIDHARAN, SC, THRISSUR DISTRICT CO.OPERATIVE BANK LTD. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 714 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 23780 OF 2022 PETITIONER/S: CHOONDACHERRY SERVICE CO-OPERATIVE BANK LTD NO.K.167,CHOONDACHERRY P.O., KOTTAYAM DISTRICT REPRESENTED BY ITS SECRETARY., PIN - 686579 BY ADVS. SRI.T.MADHU SMT.C.R.SARADAMANI SRI.SHAHID AZEEZ SMT.RESHMA SANTHOSH SHRI.RENJISH S. MENON RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, GOVERNMENT OF INDIA, NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, GOVERNMENT OF INDIA, NEW DELHI,REPRESENTED BY ITS CHAIRMAN., PIN - 110001 3 THE PRINCIPAL COMMISSIONER OF INCOME TAX TDS RANGE, THIRD FLOOR, AAYAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM, PIN - 696003 2025:KER W.P(C)No.7053/2023 & Connected cases 715 4 THE MEENACHIL EAST URBAN CO-OPERATIVE BANK LTD NO.4266 REGISTERED OFFICE POONJAR, POONJAR - THEKKEKARA P.O., KOTTAYAM DISTRICT REPRESENTED BY ITS SECRETARY., PIN - 686582 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.SHINU J.PILLAI SMT.S.SUJA SMT.MARIYA RAJAN SMT.LEKSHMI SUMUKHAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 716 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 24428 OF 2022 PETITIONER/S: WADAKANCHERY BLOCK MULTI PURPOSE CO-OPERATIVE SOCIETY LTD. NO.R. 1125 WADAKANCHERY.P.O, THRISSUR- 680582, REPRESENTED BY THE SECRETARY. BY ADV SRI.E.S.ASHRAF RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI-110001 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM- 682 018 3 THE INCOME TAX OFFICER (TDS) OFFICE OF THE INCOME TAX OFFICER (TDS), AAYAKAR BHAVAN, SAKTHAN THAMPURAN NAGAR, THRISSUR - 680 001. 4 THE KERALA STATE CO-OPERATIVE BANK LTD CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695 033, REPRESENTED BY ITS MANAGING DIRECTOR. BY ADVS. SHRI.P.VIJAYAKUMAR, ASG OF INDIA 2025:KER W.P(C)No.7053/2023 & Connected cases 717 SRI.CHRISTOPHER ABRAHAM SHRI.B.G.HARINDRANATH (SR.) SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 718 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 24538 OF 2022 PETITIONER/S: THE PATTIKKAD SERVICE CO-OPERATIVE BANK LTD. AGED 53 YEARS PATTIKKAD.P.O., MALAPPURAM DISTRICT. REPRESENTED BY ITS SECRETARY., PIN - 679325 BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM., PIN - 682018 2 THE INCOME TAX OFFICER, (TDS), AYAKAR BHAVAN, ENGLISH CHURCH ROAD, PALAKKAD,, PIN - 678014 3 CHERPALACHERI CO-OPERATIVE URBAN BANK LTD. NO. 1696 CHERPALACHERI, PALAKKAD DISTRICT REPRESENTED BY ITS GENERAL MANAGER, PIN - 679321 BY ADVS. SHRI.JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.R.SREEHARI SHRI.HAMZA A.V. SHRI.VIGNESH S. SHRI.P.R.AJITH KUMAR 2025:KER W.P(C)No.7053/2023 & Connected cases 719 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 720 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 25354 OF 2022 PETITIONER/S: 1 1. MATTANUR VANITHA CO-OPERATIVE SOCIETY LTD NO C- 1905 MATTANUR, P.O. MATTANUR, KANNUR- 670702 REPRESENTED BY ITS SECRETARY, MINI .P. C.P 2 2. MARUTHAYI PRIYADHARSINI VANITHA CO-OPERATIVE SOCIETY LTD.NO.C.1647 MARUTHAYI, P.O. PORORA, MATTANUR, REPRESENTED BY ITS SECRETARY SUJINA.K.V, PIN - 670702 3 3. PERAVOOR BLOCK VANITHA SAHAKARANA SANGHAM LTD.NO.1181 P.O.KELAKAM, KANNUR, REPRESENTED BY ITS SECRETARY JOSMIN V.J, PIN - 670674 4 4. PRIYADARSINI VANITHA CO-OPERATIVE SOCIETY LTD. NO C-1265 P.O MATTANUR, KANNUR, REPRESENTED BY ITS SECRETARY LATHA P, PIN - 670702 5 5. MATTANNUR RANGE AGRICULTURIST & TODDY TAPPING WORKERS CO-OPERATIVE SOCIETY LTD. NO.C.1535 MATTANUR, P.O MATTANUR, KANNUR REPRESENTED BY ITS SECRETARY SUDHEER KUMAR A, PIN - 670702 6 6. THE MATTANNUR AGRICULTURIST WELFARE CO-OPERATIVE SOCIETY LTD. NO C-1765 P.O MATTANUR, KANNUR, REPRESENTED BY ITS SECRETARY SHIBU V.K, PIN - 670702 7 7. IRITTY BLOCK VANITHA SERVICE CO-OPERATIVE SOCIETY 2025:KER W.P(C)No.7053/2023 & Connected cases 721 LTD.NO.C-1099 P.O MATTANUR, REPRESENTED BY ITS SECRETARY USHA.K, PIN - 670702 8 8. KOTTIYOOR VANITHA CO-OPERATIVE SOCIETY LTD.NO.C- 1176 CHUNGAKKUNNU, KANNUR, REPRESENTED BY ITS SECRETARY JYOTHI V.A, PIN - 670651 BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 2. THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 4 4. THE KERALA STATE CO-OPERATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 STATE OF KERALA 2025:KER W.P(C)No.7053/2023 & Connected cases 722 REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 723 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 26364 OF 2022 PETITIONER/S: 1 MATTANUR FARMER'S WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1884 MATTANUR P.O., KANNUR - REPRESENTED BY ITS SECRETARY GEESHMA K, PIN - 670702 2 PANOOR MUNICIPALITY AGRICULTURIST SOCIAL WELFARE CO- OPERATIVE SOCIETY(PALCOS) LTD C 2051 KARIYAD SOUTH P.O., KANNUR - REPRESENTED BY ITS SECRETARY JISHA P.M, PIN - 670316 3 KANNUR DISTRICT DIFFERENTLY ABLED PEOPLES WELFARE CO- OPERATIVE LTD NO. C 1680 NAYATTUPARA, PATTANUR P.O., KANNUR - REPRESENTED BY ITS SECRETARY MAHIJA T.V, PIN - 670595 4 THALASSERY TALUK RURAL EMPLOYEES WELFARE CO-OPERATIVE SOCIETY LTD NO. C.1698 PANOOR P.O., KANNUR- REPRESENTED BY ITS SECRETARY T SHARMILA, PIN - 670692 5 NEW MAHE PUBLIC WELFARE CO-OPERATIVE SOCIETY LTD NO. C 1838 NEW MAHE P.O., KANNUR- REPRESENTED BY ITS SECRETARY SREESHAD S, PIN - 673311 BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU 2025:KER W.P(C)No.7053/2023 & Connected cases 724 SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515 CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-, PIN - 695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 725 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 26636 OF 2022 PETITIONER/S: 1 MANANTHERI AGRICULTURIST SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD C.2087 NHALIL, MANANTHERI P.O., KANNUR- REPRESENTED BY ITS SECRETARY HARITHA M, PIN - 670643 2 CHITTARIPPARAMBA MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD NO. C 2112 MALABAR COMPLEX, CHITTARIPPARAMBA P.O., KANNUR- REPRESENTED BY ITS SECRETARY SREEYESH K, PIN - 670650 BY ADVS. DR.K.P.PRADEEP SHRI.HAREESH M.R. SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES 2025:KER W.P(C)No.7053/2023 & Connected cases 726 DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-, REPRESENTED BY ITS CHAIRMAN, PIN - 11000 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515 , CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.M.SASINDRAN SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 727 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 25894 OF 2023 PETITIONER/S: 1 ULLIYERI SERVICE CO-OPERATIVE BANK LTD NO.D.2033, ULLIYERI P.O, KOZHIKODE-673323, REPRESENTED BY ITS SECRETARY MONCY VARGHESE 2 THE QUILANDY SERVICE COOPERATIVE BANK LTD NO. F 1869 QUILANDY, KOZHIKODE-673305, REPRESENTED BY ITS SECRETARY SAJINA A.R 3 THIKKODI SERVICE COOPERATIVE BANK LTD NO.1950 THIKKODI P.O., KOZHIKODE-673529, REPRESENTED BY ITS SECRETARY SINDU C K 4 KEEZHARIYOOR SERVICE CO-OPERATIVE BANK LTD NO. F772 KEEZHARIYOOR P.O., KOYILANDY, KOZHIKODE- 673307, REPRESENTED BY ITS SECRETARY LIJI C K 5 THE PERAMBRA REGIONAL CO-OPERATIVE BANK LTD NO. F 1752 PERAMBRA P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY SUDHEESH KUMAR, PIN - 673525 6 ARIKKULAM SERVICE COOPERTAIVE BANK LTD NO. F 1489 ARIKKULAM P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY CHANDRASEKHARAN C.M, PIN - 673620 7 THE MOODADI SERVICE COOPERATIVE BANK LTD NO.D2035 KATALUR P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY BINESH K.P, PIN - 673529 8 KOTTUR SERVICE COOPERATIVE BANK LTD NO. F 450 2025:KER W.P(C)No.7053/2023 & Connected cases 728 AVITANALLUR P.O., KOZHIKODE-REPRESENTED BY ITS SECRETARY BASHEER M, PIN - 673614 9 THE MEPPAYUR CO-OPERATIVE TOWN BANK LTD NO.F-1497 MEPPAYUR P.O.,KOZHIKODE- REPRESENTED BY ITS SECRETARY K.G. BIJUKUMAR, PIN - 673524 10 THE KAYANNA SERVICE CO-OPERATIVE BANK LTD NO. F 761 KAYANNA BAZAR, KOZHIKODE- REPRESENTED BY ITS SECRETARY P. PRAKASAN, PIN - 673525 11 THE THURAYUR SERVICE CO-OPERATIVE BANK LTD NO. F 1878 PAYYOLI ANGADI P.O., KOZHIKODE-REPRESENTED BY ITS SECRETARY ABOOBACKER C.A, PIN - 673523 12 KALLANODE SERVICE CO-OPERATIVE BANK LTD NO. F 1827 KALLANODE P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY TWINKLE K CHANDY, PIN - 673527 13 THE MELUR SERVICE CO-OPERATIVE BANK LTD NO.882 CHELIYA P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY BINESH K.V, PIN - 673306 14 KAVUMTHARA SERVICE CO-OPERATIVE BANK LTD NO. D 3205 NADUVANNUR P.O., KOZHIKODE REPRESENTED BY ITS SECRETARY SHEERSHA V M, PIN - 673614 15 MEPPAYUR SERVICE CO-OPERATIVE BANK LTD NO. D2019 MEPPAYUR P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY JINSHA P, PIN - 673524 16 ATHOLI SERVICE CO-OPERATIVE BANK LTD NO. D 2721 ATHOLI PO., KOZHIKODE- REPRESENTED BY ITS SECRETARY SREEJESH T.P, PIN - 673315 17 THE BALUSSERY REGIONAL CO-OPERATIVE BANK LTD NO. F 1265 BALUSSERY P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY SANTHOSH KUMAR M.M, PIN - 673612 18 THE KARAYAD SERVICE CO-OPERATIVE BANK LTD NO. F 1702 KARAYAD P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY BAVITHA K.V, PIN - 673524 2025:KER W.P(C)No.7053/2023 & Connected cases 729 19 THE CHANGAROTH SERVICE COOPERATIVE BANK LTD NO. D 1998 PALERI TOWN P.O, KOZHIKODE- REPRESENTED BY ITS SECRETARY SOBHA V.M, PIN - 673508 20 THE PAYYOLI SERVICE CO-OPERATIVE BANK LTD NO. F 1267 PAYYOLI PO., KOZHIKODE- REPRESENTED BY ITS SECRETARY JAYADEVAN M.P, PIN - 673522 21 THE CHEMANCHERY SERVICE CO-OPERATIVE BANK LTD NO. F 779 CHEMANCHERY P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY DHANANJAY NARAYANAN, PIN - 673304 22 NADUVANNUR REGIONAL COOPERATIVE BANK LTD NO. F 1269 NADUVANNUR P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY MAJITHA N P, PIN - 673614 23 KALPATHUR SERVICE COOPERATIVE BANK LTD NO.10096 KALPATHUR PO., KOZHIKODE- REPRESENTED BY ITS SECRETARY SAJIL M M, PIN - 673524 24 IRINGAL SERVICE COOPERATIVE BANK LTD NO. F 869 IRINGAL PO., KOZHIKODE- REPRESENTED BY ITS SECRETARY USHA K.P, PIN - 673521 25 KOOTHALI SERVICE COOPERATIVE BANK LTD NO. D 2609 KOOTHALI P.O.,KOZHIKODE- REPRESENTED BY ITS SECRETARY RASHEED K K, PIN - 673525 26 CHERUVANNUR SERVICE COOPERATIVE BANK LTD NO. F 1866, CHERUVANNUR P.O., KOZHIKODE- REPRESENTED BY ITS SECRETARY K BABU, PIN - 673524 BY ADVS. DR.K.P.PRADEEP SHRI.SANAND RAMAKRISHNAN SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 730 RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI-, REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN - 682018 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM, PIN - 695003 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003 6 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515 CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM, PIN - 695001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 731 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 27682 OF 2023 PETITIONER/S: 1 MEPPAYYUR AGRICULTURISTS AND MERCANTILES WELFARE CO OPERATIVE SOCIETY LTD NO.D 2996, MEPPAYUR PO, KOZHIKODE- 673524, REPRESENTED BY ITS SECRETARY JASEEL MUHAMMED P.K. 2 THE MEPPAYUR CO-OPERTIVE HOUSING SOCIETY LTD NO.1923, MEPPAYUR P.O., KOZHIKODE-673524. REPRESENTED BY ITS SECRETARY SUDHEER KUMAR R. 3 KOORACHUNDU CO-OPERATIVE URBAN SOCIETY LTD NO.D-2758, KOORACHUND P.O., KOZHIKODE-673527,REPRESENTED BY ITS SECRETARY SIJO SEBASTIAN. 4 PERAMBRA REGIONAL AGRICULTURIST WELFARE COOPERATIVE SOCIETY LTD NO.D 3036, PERAMBRA P.O., KOZHIKODE,-673525, REPRESENTED BY ITS SECRETARY BEEJA T. 5 PERAMBRA PRAVASI WELFARE COOPERTATIVE SOCIETY LTD NO. 3153, PERAMBRA P.O., KOZHIKODE-673525,REPRESENTED BY ITS SECRETARY JAYASREE. 6 KAYANNAKARSHIKA VIKASANA THOZHILALI KSHEMA SAHAKARANA SANGHAM LTD NO. D3031, KAYANNA BAZAR P.O., KOZHIKODE-673525, REPRESENTED BY ITS SECRETARY BINDU BALAKRISHNAN. 7 IRINGATH VANITHA COOPERATIVE SOCIETY LTD NO. D3302 IRINGATH P.O., KOZHIKODE-673523, REPRESENTED BY ITS SECRETARY HAREESH P.K. 2025:KER W.P(C)No.7053/2023 & Connected cases 732 8 MEPPAYUR MADATHUMBHAGAM VANITHA SAHAKARANA SANGAM LTD NO. D 2993, MEPPAYUR P.O., KOZHIKODE-673524, REPRESENTED BY ITS SECRETARY NALINI P. 9 KOYILANDY TALUK KALLU CHETHU VYVASAYA THOZHILALI SAHAKARANA SANGAM LTD NO. D2728 KOYILANDY, KOZHIKODE-673305, REPRESENTED BY ITS SECRETARY SUJITHA N. 10 ATHOLI PRAVASI WELFARE CO-OPERATIVE SOCIETY LTD NO. D 3107, ATHOLI P.O., KOZHIKODE-673315, REPRESENTED BY ITS SECRETARY SHIMNA K. 11 NADUVANNUR AGRICULTURAL DEVELOPMENT AND PENSIONERS WELFARE CO-OPERATIVE SOCIETY LTD NO. D 3069, NADUVANNUR P.O., KOZHIKODE-673614, REPRESENTED BY ITS SECRETARY ASHISH K.P. 12 PERAMBRA AGRICULTURAL WELFARE CO-OPERATIVE SOCIETY LTD NO. D 3060 PERAMBRA P.O., KOZHIKODE-673525, REPRESENTED BY ITS SECRETARY KUSHBU P. 13 POOKKAD KARSHAKA KSHEMA SAHAKARANA SANGHAM LTD NO. D 3041, CHEMANCHERI, KOZHIKODE-673304, REPRESENTED BY ITS SECRETARY SINITHA MOHAN. 14 THALAYAD MERCHANTS WELFARE CO-OPERATIVE SOCIETY LTD NO. D 3164, THALAYAD P.O., KOZHIKODE- 673574, REPRESENTED BY ITS SECRETARY SWAPNA P. BY ADVS. DR.K.P.PRADEEP SHRI.SANAND RAMAKRISHNAN SHRI.T.T.BIJU SHRI.HAREESH M.R. SMT.T.THASMI SMT.M.J.ANOOPA 2025:KER W.P(C)No.7053/2023 & Connected cases 733 RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK ,NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES , DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK ,NEW DELHI- 110001, REPRESENTED BY ITS CHAIRMAN . 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- 695033,REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER. 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION) , GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 BY ADV CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 734 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 31251 OF 2022 PETITIONER/S: 1 CHETHALLUR SERVICE CO-OPERATIVE BANK LTD, NO F1462 HEAD OFFICE, KARINKALLATHANI, CHETHALLUR P.O., MANNARKKAD, PALAKKAD - REPRESENTED BY ITS SECRETARY ASHARAF K, PIN - 678583 2 THE THACHAMPARA SERVICE CO-OPERATIVE BANK LTD, NO.3150 THACHAMPARA P.O., PALAKKAD- REPRESENTED BY ITS SECRETARY JAYAKUMAR M, PIN - 678593 3 THE ALANALLUR CO-OPERATIVE URBAN CREDIT SOCIETY LTD NO. P1215 ALANALLUR P.O., PALAKKAD- REPRESENTED BY ITS SECRETARY BINESH O.V, PIN - 678601 4 VELLINAZHI PANCHAYATH MULTIPURPOSE CO-OPERATIVE SOCIETY LTD NO. P1361 VELLINEZHI P.O., PALAKKAD- REPRESENTED BY ITS SECRETARY C.S. PREETHI, PIN - 679504 BY ADVS. DR.K.P.PRADEEP SHRI.SANAND RAMAKRISHNAN SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL 2025:KER W.P(C)No.7053/2023 & Connected cases 735 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN - 682018 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM-, PIN - 695003 5 INCOME TAX OFFICER (TDS,THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM-, PIN - 69500 6 CHERPALCHERI CO-OPERATIVE URBAN BANK LTD, NO 1696 KAVUVATTAM, NEAR AYYAPPANKAVU, CHERPALCHERI P.O., PALAKKAD- REPRESENTED BY ITS GENERAL MANAGER, PIN - 679503 7 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO- OPERATION), GOVERNMENT SECRETARIATE, GOVERNMENT OF KERALA, THIRUVANANTHAPURAM-, PIN - 695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.R.SREEHARI SHRI.HAMZA A.V. SHRI.VIGNESH S. SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 736 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 32055 OF 2022 PETITIONER/S: 1 NALLALAM CO-OPERATIVE URBAN SOCIETY LIMITED D-2741 POST NALLALAM, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673027 2 RAMANATTUKARA VANITHA CO-OPERATIVE URBAN SOCIETY LIMITED NO. D-2742 POST RAMANATTUKARA, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673633 3 THIKKODI INTEGRATED AGRICULTURAL DEVELOPMENT CO- OPERATIVE SOCIETY LIMITED NO. D-2892 POST PURAKKAD, KOZHIKODE, REPRESENTED BY THE SECRETARY, PIN - 673522 BY ADVS. SHRI.PRASHANTH KUMAR G.C. SRI.R.SUDHISH SMT.M.MANJU RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY SECRETARY TO GOVERNMENT OF INDIA, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES 2025:KER W.P(C)No.7053/2023 & Connected cases 737 ROOM NO. 143 E, NORTH BLOCK, DEPARTMENT OF REVENUE (CBDT), MINISTRY OF FINANCE, GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRPERSON, NEW DELHI, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I.S. PRESS ROAD, ERNAKULAM, PIN - 682018 4 KERALA STATE CO-OPERATIVE BANK LIMITED RREPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, PIN - 695033 5 STATE OF KERALA REPRESENTED BY SECRETARY TO GOVERNMENT, DEPARTMENT OF CO-OPERATION, GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM -, PIN - 695001 6 REGISTRAR OF CO-OPERATIVE SOCIETIES OFFICE OF THE REGISTRAR OF CO-OPERATIVE SOCIETIES, STATUE JUNCTION, NEAR PRESS CLUB, THIRUVANANTHAPURAM., PIN - 695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SRI.P.C.SASIDHARAN, SC, KOZHIKODE DISTRICT CO- OPERATIVE BANK SHRI.R.PRASANTH KUMAR, CGC SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 738 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 32580 OF 2023 PETITIONER/S: VATTAVILA SOCIAL WELFARE CO-OPERATIVE SOCIETY LTD NO. T. 2292 T.C.51/320(5), VATTAVILA, THIRUMALA P.O., THIRUVANANTHAPURAM REPRESENTED BY ITS SECRETARY K. VENUGOPALAN NAIR, PIN - 695006 BY ADVS. DR.K.P.PRADEEP SHRI.SANAND RAMAKRISHNAN SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 2025:KER W.P(C)No.7053/2023 & Connected cases 739 4 THE KERALA STATE CO-OPERATIVE BANK LTD PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. CHRISTOPHER ABRAHAM, INCOME TAX DEPARTMENT SHRI.P.R.AJITH KUMAR THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 740 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 30686 OF 2021 PETITIONER/S: THE MOORKKANAD PANCHAYATH SERVICE CO-OPERATIVE BANK LTD, NO.496, MOORKAND P.O., MALAPPURAM DISTRICT, REPRESENTED BY ITS SECRETARY, PIN - 679 338. BY ADV SRI.O.D.SIVADAS RESPONDENT/S: 1 THE UNION OF INDIA,REPRESENTED BY THE SECRETARY TO GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI - 110 001. 2 THE COMMISSIONER OF INCOME TAX (TDS) CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, ERNAKULAM, PIN - 682 018. 3 THE INCOME TAX OFFICER (TDS) AYAKAR BHAVAN, NORTH BLOCK, MANANCHIRA, KOZHIKODE, PIN - 673 001. 4 THE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD. DISTRICT CO-OPERATIVE BANK BUILDING, MALAPPURAM REPRESENTED BY ITS GENERAL MANAGER, PIN - 676 505. 5 THE KERALA STATE CO-OPERATIVE BANK LTD. COBANK TOWERS, PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS MANAGING DIRECTOR, PIN - 695 033. BY ADVS. SRI.CHRISTOPHER ABRAHAM SHRI.ESM.KABEER,SRI.GILBERT GEORGE CORREYA THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 741 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 36670 OF 2023 PETITIONER/S: 1 THE POOJAPPURA SOCIAL WELFARE CO-OPERATIVE SOCIETY LIMITED T 2066, POOJAPPURA PO, THIRUVANANTHAPURAM REP. BY ITS SECRETARY, PIN - 695012 2 THE PRESIDENT,THE POOJAPPURA SOCIAL WELFARE CO- OPERATIVE SOCIETY LTD T 2066,POOJAPPURA PO, THIRUVANANTHAPURAM, PIN - 69501 BY ADV SRI.LIJU. M.P RESPONDENT/S: 1 THE KERALA BANK,PB NO.6515, COBANK TOWERS, VIKAS BHAVAN PO, PALAYAM, THIRUVANANTHAPURAM , REP. BY ITS GENERAL MANAGER, PIN - 695033 2 THE GENERAL MANAGER, THE KERALA BANK, PB NO.6515, COBANK TOWERS,VIKAS BHAVAN PO, PALAYAM,THIRUVANANTHAPURAM, PIN - 695033 3 THE INCOME TAX OFFICER ( IMPLEADED VIDE ORDER DT.20.12.2023 IN IA 1/2023) OFFICE OF THE INCOME TAX OFFICER, AAYAKAR BHAVAN, KAWDIAR, THIRUVANANTHAPURAM ( IMPLEADED VIDE ORDER DT. 20.12.2023 IN IA 1/2023) 4 THE COMMISSIONER OF INCOME TAX,OFFICE OF THE COMMISSIONER OF INCOME TAX, AAYAKAR BHAVAN, OLD RAILWAY STATION ROAD, ERNAKULAM NORTH, KOCHI (IMPLEADED VIDE ORDER DT. 20.12.2023 IN IA 1/2023) BY ADV SHRI.THOMAS ABRAHAM THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 742 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 41031 OF 2022 PETITIONER/S: PANOOR CO-OPERATIVE BUILDING SOCIETY LTD, C.335, P.O, PANOOR, KANNUR- REPRESENTED BY ITS SECRETARY PYARI.A, PIN - 670692 BY ADVS. DR.K.P.PRADEEP SHRI.SANAND RAMAKRISHNAN SHRI.HAREESH M.R. SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA SMT.SANU S MALAKEEL RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE GOVERNMENT OF INDIA, NORTH BLOCK NEW DELHI- , REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION 2025:KER W.P(C)No.7053/2023 & Connected cases 743 MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI-, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD, PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION) GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM-, PIN - 695001 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 744 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 9194 OF 2024 PETITIONER/S: KANNAMANGALAM VANITHA CO-OPERATIVE SOCIETY LTD NO.M 1053,E.K.PADY, KANNAMANGALAM P.O, MALAPPURAM (DT), REPRESENTED BY ITS SECRETARY, PIN - 676304 BY ADVS. SHRI.C.A.JOJO SMT.SWATHY S. RESPONDENT/S: 1 UNION OF INDIA,REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH LOCK, RAISANA HILL, NEW DELHI, PIN - 110001 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, I S PRESS, ROAD, KOCHI, PIN - 682018 3 THE INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O, MALAPPURAM DISTRICT, PIN - 676101 4 THE KERALA STATE CO-OPERATIVE BANK LTD, ERSTWHILE MDC BANK), VENGARA BRANCH, MALAPPURAM, REPRESENTED BY ITS SENIOR MANAGER, PIN - 676304 BY ADVS. SRI.G.KEERTHIVAS SRI.P.G.JAYASHANKAR SHRI.NAVANEETH.N.NATH, CGC THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 745 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 41499 OF 2022 PETITIONER/S: CHERPLACHERI SERVICE CO-OPERATIVE BANK LTD NO P 1589 AGED 53 YEARS REPRESENTED BY ITS SECRETARY SMT.PREMALATHA, D/O MADHAVAN NAIR, CHERPLACHERRY P.O., PALAKKAD, PIN - 679503 BY ADVS. SRI.V.P.NARAYANAN SRI.ALAN PRIYADARSHI DEV RESPONDENT/S: 1 UNION OF INDIA DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI, PIN - 110001 2 THE PRINCIPAL CHEIF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENTOF INDIA, CENTRAL REVENUE BUILDING, I.S.PRESS ROAD, KOCHI, PIN - 682018 3 THE CHAIRMAN CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DEHLHI, PIN - 110001 4 CHERPLACHERRY CO -OPERATIVE URBAN BANK KAVUVATTOM, NEAR AYYAPPANKAVU, CHERPLACHERRY, PALAKKAD, PIN - 679503 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 746 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 43925 OF 2023 PETITIONER/S: 1 THE ADOOR TALUK AIDED SCHOOL TEACHERS' CO-OPERATIVE SOCIETY LTD. NO. Q. 836, KADAMPANAD SOUTH P.O., PATHANAMTHITTA DISTRICT , REPRESENTED BY ITS SECRETARY, VIJAYAN PILLAI N., AGED 53 YEARS, S/O NARAYANAN NAIR N., RESIDING AT KALATHIVILAYIL, THOTTUVA, ANAYADI P. O., PATHANAMTHITTA DISTRICT ., PIN - 691553 2 PATHANAMTHITTA DISTRICT K.S.E.B. EMPLOYEES CO- OPERATIVE SOCIETY LTD., NO. PT 39 110 KV SUB STATION BUILDING, PATHANAMTHITTA, PATHANAMTHITTA DISTRICT, REPRESENTED BY ITS SECRETARY, RAJILA J., W/O SAJI S., ISHAN VILLA , ANTHICHIRA, MANNAKKALA P.O., ADOOR, PATHANAMTHITTA DISTRICT., PIN - 689645 BY ADVS. SRI.K.SHAJ SMT.MEERA NAIR.I.P SMT.BEENA N.KARTHA SRI.C.IJLAL SMT.POORNIMA RAJAN SRI.ARUN CHAND SHRI.BHARAT VIJAY P. SHRI.MAJID MUHAMMED K. SMT.MINU VITTORRIA PAULSON SMT.GOPIKA GOPAL SMT.ARCHANA SURESH 2025:KER W.P(C)No.7053/2023 & Connected cases 747 RESPONDENT/S: 1 UNION OF INDIA REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI., PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI-, REPRESENTED BY ITS CHAIRMAN, PIN - 110001 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI ., PIN - 682018 4 ADDITIONAL COMMISSIONER OF INCOME TAX TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM., PIN - 695003 5 INCOME TAX OFFICER (TDS) THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM., PIN - 695003 6 THE KERALA BANK CO-BANK TOWERS, P.B.NO.6515, VIKAS BHAVAN P.O., PALAYAM, THIRUVANANTHAPURAM , REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 7 THE GENERAL MANAGER, KERALA BANK REGIONAL OFFICE, P.B.NO.104, OPP. MUNICIPAL TOWN HALL, ALAPPUZHA, ALAPPUZHA DISTRICT., PIN - 688001 8 STATE OF KERALA REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM ., PIN - 695001 THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 748 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 27670 OF 2024 PETITIONER/S: ARTISANS DEVELOPMENT CO OPERATIVE LTD 4429 KERALA (ARTCO LTD), KOCHUVEETIL TOWERS TC 25/595/5 MODEL SCHOOL JUNCTION, THIRUVANANTHAPURAM G.P.O. THIRUVANANTHAPURAM 695001 REPRESENTED BY ITS MANAGING DIRECTOR MATHEW C.V., AGED 46 YEARS, SON OF VARGHESE C.V., PERMANENT RESIDENCE AT CHIRAYIL HOUSE, POTTAMMEL, NEAR WATER TANK,, KUTHIRAVATTAOM P.O., KOZHIKODE - 673016 BY ADVS. DR.K.P.PRADEEP SHRI.T.T.BIJU SMT.T.THASMI SMT.M.J.ANOOPA RESPONDENT/S: 1 UNION OF INDIA , REPRESENTED BY ITS SECRETARY DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK , NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK , NEW DELHI- , REPRESENTED BY ITS CHAIRMAN, PIN - 110001 2025:KER W.P(C)No.7053/2023 & Connected cases 749 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 4 THE KERALA STATE CO-OPERATIVE BANK LTD., PB NO 6515, CO-BANK TOWERS, PALAYAM, THIRUVANANTHAPURAM- , REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 5 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO- OPERATION) ,GOVERNMENT SECRETARIATE, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. SRI.P.G.JAYASHANKAR SHRI.THOMAS ABRAHAM SRI.NAVANEETH.N.NATH THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 750 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 31176 OF 2024 PETITIONER/S: 1 PERUVALLUR SCHEDULE CAST SERVICE CO-OPERATIVE SOCIETY LTD .,NO.M1044, ILLATHUMADU, PRUVALLUR P.O, MALAPPURAM (DT), REPRESENTED BY ITS SECRETARY, PIN - 673638 2 PERUVALLUR RURAL CO-OPERATIVE SOCIETY LTD., NO.M1014,PARAMBILPEEDIKA P.O, MALAPPURAM (DT), REPRESENTED BY ITS SECRETARY, PIN - 676317 BY ADVS. SHRI.C.A.JOJO SRI.S.JIJI SHRI.JOSEPH ANU A.A RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY TO THE GOVERNMENT, MINISTRY OF FINANCE, NORTH BLOCK, RAISANA HILL, NEW DELHI, PIN - 110000 2 THE COMMISSIONER OF INCOME TAX (TDS), CENTRAL REVENUE BLDG, IS PRESS, ROAD, KOCHI, PIN - 682018 3 THE INCOME TAX OFFICER (TDS), INCOME TAX OFFICE, TARIF BAZAR, TOWN HALL ROAD THIRUR P.O, MALAPPURAM DISTRICT, PIN - 676101 4 THE KERALA STATE CO-OPERATIVE BANK LTD., ,(ERSTWHILE MALAPPURAM DISTRICT CO-OPERATIVE BANK LTD), PARRY SHOPPING COMPLEX,CALICUT ROAD, DOWNHILL, MALAPPURAM, REPRESENTED BY ITS GENERAL MANAGER, PIN - 2025:KER W.P(C)No.7053/2023 & Connected cases 751 676519 BY ADVS. SRI.P.G.JAYASHANKAR SRI.G.KEERTHIVAS SRI.NAVANEETH.N.NATH THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 752 IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR.JUSTICE ZIYAD RAHMAN A.A. SATURDAY, THE 25TH DAY OF OCTOBER 2025 / 3RD KARTHIKA, 1947 WP(C) NO. 37399 OF 2024 PETITIONER/S: 1 ENADIMANGALAM AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY PT 257, ELAMANNOOR P.O., PANCHAYAT JUNCTION, PATHANAMTHITTA DISTRICT REPRESENTED BY ITS SECRETARY, SUNILA S., AGED 42 YEARS, D/O.SURENDRANATHEN, RESIDING AT PRASAD BHAVANAM, EDAKKAD P.O., KOLLAM DISTRICT, PIN - 691552 2 PANDALAM GOVERNMENT SERVANTS CO-OPERATIVE SOCIETY LTD. NO. A 684, PANDALAM P.O., PATHANAMTHITTA DISTRICT - 689501, REPRESENTED BY ITS SECRETARY, SMITHA MOHAN, AGED _ YEARS, RESIDING AT SANTOSH BHAVAN, KAIPUZHA NORTH P.O., KULANADA. PATHANAMTHITTA DISTRICT, PIN - 689503 3 KONNI AGRICULTURAL RURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD., NO. PT-253, CHINA JUNCTION , KONNI P.O., PATHANAMTHITTA DISTRICT - 689691, REPRESENTED BY ITS SECRETARY, DEEPA K., AGED 44 YEARS, D/O P. K. KAMALASANAN RESIDING AT AJITHA BHAVAN, EDAKKAD SOUTH P.O., KOLLAM DISTRICT, PIN - 691552 4 PANDALAM VANITHA CO-OPERATIVE SOCIETY LTD., NO. PT 140, M.M. JUNCTION, PANDALAM P.O., PATHANAMTHITTA DISTRICT - 689501, REPRESENTED BY ITS SECRETARY, ARYA VASUDEVAN AGED 37 YEARS, D/O. P. K. VASUDEVAN RESIDING AT PALANILKUNATHIL, MUDIYOORKONAM P.O., PATHANAMTHITTA DISTRICT 5 PUTHUMALA AGRI DEVELOPMENT AND FARMERS SOCIAL WELFARE 2025:KER W.P(C)No.7053/2023 & Connected cases 753 CO-OPERATIVE SOCIETY LTD. NO. PT 336, PALAMUKKU PUTHUMALA P.O., PATHANAMTHITTA DISTRICT - 691554, REPRESENTED BY ITS SECRETARY, SUBIN G. RAJU, AGED 29 YEARS, S/O. P. G. RAJU, RESIDING AT PULIYANNAL HOUSE, THEPPUPARA P.O., PARAKODE, PATHANAMTHITTA DISTRICT 6 THE CENTRAL TRAVANCORE MERCHANT'S CO-OPERATIVE SOCIETY LTD. NO.PT 210, PANDALAM P.O., PATHANAMTHITTA DISTRICT - 689501, REPRESENTED BY ITS SECRETARY, ROSHINI SOMARAJAN, AGED 51 YEARS, D/O. S. SIVARAMA PILLAI RESIDING AT SOMAKRIPA HOUSE, POOZHIKKAD, POOZHIKKADU P.O., PANDALAM, PATHANAMTHITTA DISTRICT, PIN - 689515 7 KODUMON AGRICULTURAL IMPROVEMENT CO-OPERATIVE SOCIETY LTD. NO. PT 242, KODUMON P.O., PATHANAMTHITTA DISTRICT - 691555, REPRESENTED BY ITS SECRETARY, SINDHU R. NAIR, AGED 45 YEARS, D/O RADHAKRISHNAN NAIR, MANIMANGALATHU HOUSE, NEDUMON P.O., PATHANAMTHITTA DISTRICT, PIN - 691556 BY ADVS. SRI.K.SHAJ SMT.BEENA N.KARTHA SRI.ARUN CHAND SMT.MINU VITTORRIA PAULSON SHRI.BHARAT VIJAY P. SMT.ARCHANA P.P. RESPONDENT/S: 1 UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI, PIN - 110001 2 THE CENTRAL BOARD OF DIRECT TAXES, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI, REPRESENTED BY ITS CHAIRMAN, PIN - 110001 2025:KER W.P(C)No.7053/2023 & Connected cases 754 3 PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KERALA REGION, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, CENTRAL REVENUE BUILDINGS, I S PRESS ROAD, KOCHI, PIN - 682018 4 ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE, OFFICE OF THE ADDITIONAL COMMISSIONER OF INCOME TAX, 3RD FLOOR, AATAKAR BHAVAN, KAWADIAR, THIRUVANANTHAPURAM, PIN - 695003 5 INCOME TAX OFFICER (TDS), THIRUVANANTHAPURAM, 3RD FLOOR, AAYAKAR BHAVAN, KOWDIAR, THIRUVANANTHAPURAM, PIN - 695003 6 THE KERALA BANK, CO-BANK TOWERS, P.B.NO.6515, VIKAS BHAVAN P.O., PALAYAM, THIRUVANANTHAPURAM, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, PIN - 695033 7 THE GENERAL MANAGER, KERALA BANK, REGIONAL OFFICE, P.B.NO.104, OPP. MUNICIPAL TOWN HALL, ALAPPUZHA, ALAPPUZHA DISTRICT, PIN - 688001 8 STATE OF KERALA, REPRESENTED BY ITS SECRETARY (CO-OPERATION), GOVERNMENT SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001 BY ADVS. SHRI.NAVANEETH.N.NATH, CGC SRI.P.G.JAYASHANKAR SMT.K.AMMINIKUTTY SRI.G.KEERTHIVAS THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 09.10.2025 ALONG WITH WP(C)NO.7053/2023 AND CONNECTED CASES, THE COURT ON 25.10.2025 DELIVERED THE FOLLOWING: 2025:KER W.P(C)No.7053/2023 & Connected cases 755 JUDGMENT [WP(C) Nos.7053/2023, 213/2022, 378/2022, 384/2022, 383/2022, 732/2022, 736/2022, 833/2022, 1383/2022, 1633/2022, 1808/2022, 1943/2022, 2208/2022, 2780/2022, 3734/2022, 4385/2022, 4442/2022, 4996/2022, 5569/2022, 5900/2022, 8026/2022, 8742/2022, 8943/2023, 10465/2022, 10480/2022, 10498/2022, 10692/2022, 10697/2022, 10699/2022, 10705/2022, 10717/2022, 10719/2022, 10720/2022, 10721/2022, 10722/2022, 10731/2022, 10735/2022, 10738/2022, 10741/2022, 10744/2022, 10747/2022, 10787/2022, 10799/2022, 10810/2022, 10818/2022, 10828/2022, 10831/2022, 10845/2022, 10855/2022, 10891/2022, 10936/2022, 10937/2022, 10968/2022, 10967/2022, 11001/2022, 11009/2022, 11035/2022, 11042/2022, 11058/2022, 11072/2022, 11087/2022, 11092/2022, 11096/2022, 11117/2022, 11130/2022, 11135/2022, 11138/2022, 11144/2022, 11143/2022, 11149/2022, 11150/2022, 11165/2022, 11171/2022, 11187/2022, 11184/2022, 11186/2022, 11194/2022, 11203/2022, 11224/2022, 11232/2022, 11248/2022, 11247/2022, 11262/2022, 11260/2022, 11263/2022, 11271/2022, 11272/2022, 11273/2022, 11286/2022, 11301/2022, 11309/2022, 11316/2022, 11332/2022, 11323/2022, 11325/2022, 11326/2022, 11327/2022, 11335/2022, 11342/2022, 11355/2022, 11366/2022, 11371/2022, 11373/2022, 11381/2022, 11407/2022, 11415/2022, 11420/2022, 11441/2022, 11440/2022, 11450/2022, 11446/2022, 2025:KER W.P(C)No.7053/2023 & Connected cases 756 11445/2022, 11458/2022, 11467/2022, 11478/2022, 11480/2022, 11489/2022, 11487/2022, 11507/2022, 11530/2022, 11544/2022, 11555/2022, 11558/2022, 11570/2022, 11591/2022, 11601/2022, 11599/2022, 11600/2022, 11604/2022, 11607/2022, 11605/2022, 11609/2022, 10302/2022, 11616/2022, 11619/2022, 11620/2022, 11621/2022, 11627/2022, 11646/2022, 11649/2022, 11654/2022, 11683/2022, 11679/2022, 11684/2022, 11718/2022, 11721/2022, 11728/2022, 11727/2022, 11740/2022, 11738/2022, 11765/2022, 11760/2022, 11766/2022, 11768/2022, 11772/2022, 11776/2022, 11780/2022, 11781/2022, 11783/2022, 11915/2022, 11784/2022, 11791/2022, 11792/2022, 11810/2022, 11848/2022, 11851/2022, 11870/2022, 11887/2022, 11884/2022, 11939/2022, 12054/2022, 12057/2022, 12065/2022, 12061/2022, 12076/2022, 12075/2022, 12082/2022, 12086/2022, 12100/2022, 12102/2022, 12105/2022, 12110/2022, 12123/2022, 12124/2022, 12126/2022, 12145/2022, 12257/2022, 12263/2022, 12351/2022, 12428/2022, 14068/2022, 12504/2022, 12545/2022, 12635/2022, 12754/2022, 12713/2022, 12744/2022, 12753/2022, 12759/2022, 13011/2022, 13047/2022, 13114/2022, 13112/2022, 13171/2022, 13184/2022, 13339/2022, 13303/2022, 13305/2022, 13318/2022, 13358/2022, 13364/2022, 13410/2022, 13439/2022, 13492/2022, 13545/2022, 13615/2022, 13687/2022, 13693/2022, 13707/2022, 13720/2022, 13741/2022, 13746/2022, 13751/2022, 13760/2022, 13761/2022, 13781/2022, 2025:KER W.P(C)No.7053/2023 & Connected cases 757 13797/2022, 13833/2022, 13891/2022, 13895/2022, 13902/2022, 13903/2022, 13912/2022, 13939/2022, 13940/2022, 13996/2022, 14006/2022, 14010/2022, 14014/2022, 14017/2022, 14047/2022, 14061/2022, 14119/2022, 14122/2022, 14151/2022, 14162/2022, 14195/2022, 14341/2022, 14425/2022, 14559/2022, 14687/2022, 14715/2022, 14806/2022, 14807/2022, 14811/2022, 14832/2022, 14838/2022, 14857/2022, 14944/2022, 14960/2022, 15027/2022, 15066/2022, 15438/2022, 15480/2022, 15487/2022, 15518/2022, 15596/2022, 15598/2022, 15789/2022, 15825/2022, 15828/2022, 15874/2022, 16074/2022, 16243/2022, 16321/2022, 16459/2022, 16598/2022, 16805/2022, 16881/2022, 17323/2022, 17707/2022, 17716/2022, 17796/2022, 18070/2022, 18489/2022, 18690/2022, 20028/2022, 21287/2022, 21639/2022, 21922/2022, 22198/2022, 22339/2022, 22917/2022, 23239/2022, 23780/2022, 24428/2022, 24538/2022, 25354/2022, 26364/2022, 26636/2022, 25894/2023, 27682/2023, 31251/2022, 32055/2022, 32580/2023, 30686/2021, 36670/2023, 41031/2022, 9194/2024, 41499/2022, 43925/2023, 27670/2024, 31176/2024, 37399/2024] ... In all these cases, the petitioners are Co-operative Societies registered under the provisions of the Kerala Co-operative Societies Act, 1969 and are classified as Primary Agricultural Credit Societies 2025:KER W.P(C)No.7053/2023 & Connected cases 758 under the said Act and the Rules. In all these cases, the challenge is raised against the Constitutional validity of the proviso to section 194A(3) of the Income Tax Act, 1961 (hereinafter referred to as the Act), by which, a restriction was imposed, based on the gross receipts or turnover of the Societies, in the matter of exemption from the obligation to make TDS from the income as the interests on deposits. 2. The brief facts which are required to examine the issues involved in these writ petitions are as follows: As mentioned above, all these petitioners are Primary Agricultural Credit Societies, which are mainly engaged in the business of providing financial assistance to their members, for agricultural purposes. Section 194A deals with the liability to make deduction of tax at source (TDS) in respect of certain transactions and sub-section (1) thereof imposes a liability upon any person not being an individual or a Hindu undivided family, to deduct such amount as may be prescribed, from the income paid to any person by way of interest, other than the income by way of interest on securities. Subsection (3) of the aforesaid provision 2025:KER W.P(C)No.7053/2023 & Connected cases 759 contemplates certain exceptional circumstances under which, the parties shall be exempted from making TDS. As per clause (v) of subsection (3) of Section 194A, the income credited or paid by a Co-operative society other than a co-operative bank to a member thereof or the income credited or paid by a co-operative society to any other co-operative society, shall be excluded from the operation of sub- section (1) of Section 194A. Similarly, clause (viia) of section 194A(3) provides for a similar exemption in the case of deposits with a primary credit society or a co-operative Land Mortgage Bank or a Co-operative Land Development Bank. 3. Thus, in the light of the statutory stipulations contained in clauses (v) and (viia) of section 194A(3) of the Act, all the petitioners were under no obligation to deduct any TDS in respect of the income received or credited to, as interest on deposits. However, as per Finance Act, 2020, an amendment was brought in, to the aforesaid stipulation, by adding a proviso in respect of the co-operative societies referred to in clause (v)and (viia), which was to the effect that, in case, 2025:KER W.P(C)No.7053/2023 & Connected cases 760 the total sales, gross receipts or turn over of the co-operative societies exceed 50 crores rupees, during the financial year immediately preceding to the financial year referred to sub-section (1) of Section 194A, such interest amount shall be subjected to TDS, when the same is being paid or credited to the payee. The petitioners are aggrieved by the introduction of the said proviso, as according to them, the impact of the same is to the effect that, the exemption which was otherwise available to them by virtue of section 194A(3), has been taken away. 4. According to the petitioners, the introduction of the proviso as referred to above, affects them in two ways, which are as follows: 4.1. Firstly, as per Section 57 of the Kerala Co-operative Societies Act, the funds of the Co-operative Society have to be invested as per the directions of the Registrar. As per various directions issued in this regard, the Co-operative Societies are bound to keep their cash balance with the account operated in the Kerala State Co-operative Bank (Kerala Bank), which is the Apex Co-operative Society of all the 2025:KER W.P(C)No.7053/2023 & Connected cases 761 Co-operative Societies. Moreover, the petitioners do not have the necessary infrastructure to meet the safety requirements for keeping huge amounts of cash and hence, on that reason also, the deposits will have to be with the Kerala State Co-operative Bank. The petitioner is receiving interest for such deposits from the Kerala Bank and it also amounts to income by way of interest, which is liable to be deducted from the income while assessing tax for the respective Societies, in the light of Section 80P(2)(d) of the Income Tax Act. Thus, there is no tax liability upon such income as per the above provision. 4.2. Moreover, as per clauses (v) and (via) of Section 194A(3) (v) and, it is stipulated that the obligation to deduct any amount as TDS in respect of the income received or credited as interest shall not be applicable to the petitioners. However, the newly introduced proviso to sub section 194A(3), imposes a condition that, in respect of a Society, whose total sales or gross receipts or turn over exceeds Rs.50 Crores. Due to the same, the exemption from making deduction is made not applicable to the petitioner and hence, the 2025:KER W.P(C)No.7053/2023 & Connected cases 762 petitioners are compelled to deduct amounts towards TDS, despite the fact that, there is no tax liability upon them, as far as the income from the deposits are concerned, as the same is already exempted under Section 80P(2)(d) of the Act. According to the petitioners, the introduction of a criterion of Rs 50 Crores as referred to above, practically takes away the benefit, which was originally granted to them. This is because, since all their deposits are to be compulsorily made to the Kerala Bank being the Apex Society, and the gross turnover of the Kerala Bank exceeds Rs.50 crores, all the income received by the petitioners by way of income from the deposits with the Kerala Bank, are subjected to TDS. 4.3. Secondly, most of the petitioners are having the turnover of above Rs.50 crores and on account of the same, the petitioners will have to deduct the amount towards TDS, when the interest is being credited to the accounts of the members, for the deposits made by such members of the Society. This is affecting their business, as according to them, the persons who are interested in 2025:KER W.P(C)No.7053/2023 & Connected cases 763 making deposits with the petitioners are likely to opt for other Societies whose turnover is less than Rs.50 Crores, so as to avoid the liability to subject their income to TDS. According to the petitioners, thus, the said proviso introduces, an unreasonable classification, that violates the principles enshrined under Art.14 of the Constitution of India. These writ petitions are submitted in such circumstances, challenging the validity of the aforesaid statutory provisions. 5. A detailed statement has been filed by the Income Tax Department, opposing the reliefs sought and denying the contentions raised in these writ petitions. According to the Department, the proviso introduced as per Finance Act 2020, is within the legislative competence of the Central Government and the stipulations contained in the proviso to Section 194A(3) do not violate any of the fundamental rights of the petitioners. It was contended that, even though section 80P of the Income Tax Act provides some benefits to the petitioners, the same is not an exemption from payment of tax, as far as the income received by the petitioners as interest from deposits is concerned. 2025:KER W.P(C)No.7053/2023 & Connected cases 764 According to the Department, what is contemplated under Section 80P, is only a deduction of such income while making the assessment, which is subject to the other conditions stipulated in the Act. Section 80AC provides that such deductions shall be allowed only if the return is furnished for the relevant year. Therefore, in order to ensure that, the amount receivable to the Department is collected, and there is no evasion of tax, it is lawful for the Central Government to incorporate appropriate conditions in the statute and the proviso referred to above, was as part of the same. According to the Department, the said proviso does not impose any new liability upon the petitioners and the parties can get the refund of the amount, upon filing returns with the necessary documents. In such circumstances, they sought dismissal of these writ petitions. 6. Heard Sri. A. Kumar, the learned Senior Counsel, Dr. K.P. Pradeep, Sri.M.M.Monaye, Sri. K.S. Hariharan Nair, and Sri. Jojo C.A, the learned counsel appearing for the petitioners, Sri.B.G. Hareendranath and Sri. Thomas Abraham appearing for the Kerala 2025:KER W.P(C)No.7053/2023 & Connected cases 765 Bank, Sri. Mohammed Rafiq, the learned Special Government Pleader (Taxes) for the State of Kerala and Sri. Christopher Abraham, the learned Standing Counsel for the Income Tax Department. 7. The main contention raised by the petitioners against the validity of the proviso to Section 194A(3) is that, the same is liable to be struck down as it is violative of the principles of the equality as contemplated under Art. 14 of the Constitution of India, since the same is creating an unreasonable classification among the Co-operative Societies, based on the total turnover of the Society. It is also their case that, by virtue of introduction of proviso, a liability has been imposed to deduct the amounts as TDS in respect of an income, which is not otherwise taxable under the provisions of the Income Tax Act. Besides, the proviso referred to above, takes away the exemption, otherwise granted to the petitioners, from making any deduction towards TDS in respect of such income. The petitioners have also highlighted the serious impact that would result from the said proviso, upon the interests and prospects of the petitioner-Societies. As mentioned above, 2025:KER W.P(C)No.7053/2023 & Connected cases 766 by virtue of the introduction of a ceiling in turnover, the receipts of the Societies by way of income of interest on the deposits made by them with the Kerala Bank, the Apex Society, and the amount to be paid by the petitioner -Societies to its Members as interests for the deposits made by such members were subjected to TDS, which were not otherwise applicable. The petitioners have pointed out that, as far as the income received by the petitioner-Societies as interests is concerned, the same is not liable to be taxed by virtue of section 80P of the Act, which right was upheld by the Hon'ble Supreme Court in Mavilayi Service Co-operative Bank Ltd v. Commissioner of Income Tax, Calicut and Another [2021 (1) KHC 303]. Apart from the above, large number of decisions were cited by the petitioners in support of their contentions with regard to the Constitutional validity of the statutory provisions, which shall be dealt with in this judgment, as and when necessary. 8. On the other hand, the learned Standing Counsel reiterated the contentions raised by him in the statement and he also 2025:KER W.P(C)No.7053/2023 & Connected cases 767 relied on large number of decisions. 9. The learned Special Government Pleader supported the contentions raised by the petitioners, by pointing out that, the proviso introduced as per Finance Act, 2020, practically takes away the benefits granted to the societies as per the main provision viz. 194A(3), and thus it had gone beyond the scope of a proviso and hence requires interference. 10. Before going to the contentions raised from either side, it is necessary to examine the relevant statutory provisions which are as follows: a) Section 80P(1) and 2(d) of the Income Tax Act contemplates as follows: "80P. Deduction in respect of income of co-operative societies (1) Where, in the case of an assessee being a co-operative society, the gross total income includes any income referred to in sub-section (2), there shall be deducted, in accordance with and subject to the provisions of this section, the sums specified in sub- section (2), in computing the total income of the assessee. 80P2(d):The sums referred to in sub-section(1) shall be the following, namely:- in respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income" "b)Section 80AC. Deduction not to be allowed unless return furnished 2025:KER W.P(C)No.7053/2023 & Connected cases 768 Where in computing the total income of an assessee of any previous year relevant to the assessment year commencing on or after- (i) the 1st day of April, 2006 but before the 1 st day of April, 2018, any deduction is admissible under section 80-1A or section 80- 1AB or section 80-1B or section 80-1C or section 80-1D or section 80-1E; (ii) the 1st day of April,2018, any deduction is admissible under any provision of this Chapter under the heading "C.- Deductions in respect of certain incomes". no such deduction shall be allowed to him unless he furnishes a return of his income for such assessment year on or before the due date specified under sub-section(1) of section 139." "c) 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 [one crore rupees in case of business or fifty lakh rupees in case of profession]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.] [Explanation.- For the purposes of this section where any income by way of interest as aforesaid is credited to my account whether called "Interest payable account" or "Suspense account" or by any other name, in the books of account of the person liable to pay such income, such crediting shall be deemed to be credit of such income to the account of the payee and the provisions of this section shall apply accordingly] 2025:KER W.P(C)No.7053/2023 & Connected cases 769 d) 194A(3): The provisions of sub-section (1) shall not apply-- ............... .......... (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; Explanation.- For the purpose of this clause, "co- operative bank" shall have the meaning assigned to it in Part V of the Banking Regulation Act, 1949 (10 of 1949), (vii) to such income credited or paid in respect of deposits (other than time deposits made on or after the 1 st day of July, 1995) with a banking company to which the Banking Regulation Act, 1949 (10 of 1949) applies (including any bank or banking institution referred to in section 51 of that Act. (viia). to such income credited or paid in respect of,- (a) deposits with a primary agricultural credit society or a primary credit society or a co-operative land mortgage bank or a co-operative land development bank; (b) deposits (other than time deposits made on or after the 1st day of July, 1995) with a co-operative society, other than a co-operative society or bank referred to in sub-clause (a), engaged in carrying on the business of banking;] [Provided that a co-operative society referred to in clause (v) or clause (viia) shall be liable to deduct income-tax in accordance with the provisions of sub- section(1), if - (a) the total sales, gross receipts or turnover of the co-operative society exceeds fifty crore rupees during the financial year immediately preceding the 2025:KER W.P(C)No.7053/2023 & Connected cases 770 financial year in which the interest referred to in sub- section (1) is credited or paid; and (b) the amount of interest, or the aggregate of the amounts of such interest, credited or paid, or is likely to be credited or paid, during the financial year is more than[one lakh] rupees in case of payee being a senior citizen and [fifty thousand] rupees in any other case.] [Explanation 1.- For the purpose of clauses (i)(vii) and (viia), "time deposits" means deposits [(including) recurring deposits] repayable on the expiry of fixed periods. [Explanation 2.- For the purposes of this sub-section, "senior citizen" means an individual resident in India who is of the age of sixty years or more at any time during the relevant previous year.] 11. The circumstances under which a provision can be declared as ultra vires of the Constitution, are laid down by the Hon'ble Supreme Court in several decisions. In Government of Andhra Pradesh & Ors. v. Smt.P. Laxmi Devi [AIR 2008 SC 1640], this question was discussed in detail, after referring to a large number of decisions, and it was observed that, while judges should practice great restraint in dealing with economic statutes, they should be activists in defending the civil liberty and fundamental rights of the citizens. In Union of India v. Elphinstone Spinning and Weaving Co. and 2025:KER W.P(C)No.7053/2023 & Connected cases 771 Others [AIR 2001 SC 724], it was observed as follows: "9. .............................. There is always a presumption that the legislature does not exceed its jurisdiction and the burden of establishing that the legislature has transgressed constitutional mandates, such as those relating to fundamental rights, is always on the person who challenges its vires. Unless it becomes clear beyond reasonable doubt that the legislation in question transgresses the limits laid down by the organic law of the Constitution it must be allowed to stand as the true expression of the national will -- Shell Co. of Australia v. Federal Commr. of Taxation [1931 AC 275 : 1930 All ER Rep 671 : 100 LJPC 55 : 144 LT 421 (PC)] . The aforesaid principle, however, is subject to one exception that if a citizen is able to establish that the legislation has invaded its fundamental rights then the State must justify that the law is saved. It is also a cardinal rule of construction that if on one construction being given the statute will become ultra vires the powers of the legislature whereas on another construction which may be open, the statute remains effective and operative, then the court will prefer the latter, on the ground that the legislature is presumed not to have intended an excess of jurisdiction. 12. The Privy Council in Shell Company of Australia v. Federal Commissioner of Taxation [(1931 AC 275 (298)], it was observed that, "unless it becomes clear beyond reasonable doubt that, the legislation in question transgresses the limits laid down by the organic law of the Constitution, it must be allowed to stand as the true expression of national will". After referring to the aforesaid observations of the Privy Council, it was observed by the Hon'ble 2025:KER W.P(C)No.7053/2023 & Connected cases 772 Supreme Court Smt. P. Laxmi Devi's case (supra) that, if two views are possible, one making the provision in the statute constitutional, and the other making it as unconstitutional, the former should be preferred. It was further observed therein that, the court must therefore make every effort to uphold the Constitutional validity of a statute, even if that requires the statutory provisions a strained meaning, or narrower or wider meaning than what appears on the face of it. It is only when all efforts to do so fail, should the court declare the same as unconstitutional. 13. As far as the petitioners are concerned, they mainly rely on the decisions in K.T.Moopil Nair v. State of Kerala and Anr. [AIR 1961 SC 552], M.R.F. Ltd v. Inspector, Kerala Government & Ors. [(1998) 8 SCC 227], Shayara Bano v. Union of India and Ors. [(2017) 9 SCC 1], Ashirvad Films v. Union of India [ (2007) 6 SCC 624], Union of India & Anr. v. Ganpati Dealcom Pvt Ltd. [(2023) 3 SCC 315], Union of India and Ors v. N.S.Rathnam and Sons [(2015)10 SCC 681], The Commissioner of Income Tax, New Delhi 2025:KER W.P(C)No.7053/2023 & Connected cases 773 v. Eli Lilly and Company (India) Pvt. Ltd [(2009) 15 SCC 1] etc. to substantiate their contentions to the Constitutional validity of the statutory provisions. 14.The circumstances under which a statutory provision can be interfered with, are enumerated in the decisions referred to above, which are mainly, the lack of legislative competence, violative of the provisions of Part III of the Constitution or when there is manifest arbitrariness in the enactment. In this case, apart from the above, it is also the contention of the petitioners that, the amendment was given effect to, by way of bringing in a proviso to the main section, and the effect the said proviso is such that, the purpose for which the original provision was created, is defeated as it takes away the entire rights of the parties as per the main provision. Therefore, the same is not sustainable. 15. The questions involved in these writ petitions are to be considered by keeping the aforesaid principles in mind. It is also to be noted that, as far as a taxing statute is concerned, the same stands in a 2025:KER W.P(C)No.7053/2023 & Connected cases 774 high pedestal and it was held in R.K. Garg v. Union of India and ors [(1981) 4 SCC 675] in the manner as follows: "8. Another rule of equal importance is that laws relating to economic activities should be viewed with greater latitude than laws touching civil rights such as freedom of speech, religion etc. It has been said by no less a person than Holmes, J., that the legislature should be allowed some play in the joints, because it has to deal with complex problems which do not admit of solution through any doctrinaire or strait-jacket formula and this is particularly true in case of legislation dealing with economic matters, where, having regard to the nature of the problems required to be dealt with, greater play in the joints has to be allowed to the legislature. The court should feel more inclined to give judicial deference to legislative judgment in the field of economic regulation than in other areas where fundamental human rights are involved. Nowhere has this admonition been more felicit ously expressed than in Morey v. Doud [354 US 457 : 1 L Ed 2d 1485 (1957)] where Frankfurter, J., said in his inimitable style:" 16. One of the main contentions raised by the petitioners is that, as far as the income received by them by way of interest on deposits is concerned, the same is not taxable as there is an exemption contemplated under section 80P(2)(d) of the Act. According to the petitioners, since the income, which is the subject matter of these litigations, is not at all taxable, imposing a condition to collect TDS in respect of such income, is illegal and it amounts to an arbitrary action 2025:KER W.P(C)No.7053/2023 & Connected cases 775 on the part of the State. To substantiate these contentions, the petitioners are relying upon the observations made by the Hon'ble Supreme Court in Eli Lilly's case (supra) where it was observed by the Hon'ble Supreme Court as follows: "75. To answer the contention herein we need to examine briefly the scheme of the 1961 Act. Section 4 is the charging section. Under Section 4(1), total income for the previous year is chargeable to tax. Section 4(2) inter alia provides that in respect of income chargeable under sub-section (1), income tax shall be deducted at source whether it is so deductible under any provision of the 1961 Act which inter alia brings in the TDS provisions contained in Chapter XVII-B. *In fact, if a particular income falls outside Section 4(1) then TDS provisions cannot come in." (*highlighted for emphasis) 17. Thus, the specific case of the petitioners is that, since there is no tax liability, no TDS could be collected. However, the crucial aspect to be noticed in this regard is that, the exemption from payment of tax claimed by the petitioners, is by placing reliance upon section 80P(1) and (2)(d) of the Income Tax Act. As rightly pointed out by the learned Standing Counsel for the Income Tax, the said provision does not contemplate an absolute exemption from the liability to pay the tax in respect of the said income, but instead, what it provides is that, 2025:KER W.P(C)No.7053/2023 & Connected cases 776 the said income could be deducted from the taxable income of the assessee, subject to the terms and conditions in the statute. It is to be noted in this regard that as per Section 80AC of the Act, no such deduction could be allowed unless the return is furnished. In Section 80AC (ii), there is a specific reference to the deduction under the heading "C-deductions in respect of certain incomes in Chapter VIA of the Income Tax Act", and Section 80P comes under the same. Therefore, it is discernible therefrom that, as far as the tax liability on income from interest is concerned, for a Co-operative society, it is not an absolute exemption, but it is a deduction permissible for such a Society, on submitting the returns. Therefore, as pointed out by the learned Standing Counsel for the Department, since the benefit under Section 80P is not an exemption from paying tax, but a benefit of deduction subject to the compliance of the terms and conditions including filing of return, it cannot be held that, there is no tax liability at all, for the petitioners under the Act. As far as the observations made Eli Lilly's case (supra) is concerned, the same was in respect of an 2025:KER W.P(C)No.7053/2023 & Connected cases 777 income which was not taxable under Section 4(1) of the Income Tax Act 1961, the charging provision. In this case, it cannot be held that the income is not subjected to tax at all, in the light of the aforesaid statutory provisions and the benefit is confined to getting the said amount deducted from the taxable income. This makes a crucial distinction and therefore, the principles laid down by the Hon'ble Supreme Court in the above decision, cannot be made applicable to these cases. 18. Yet another contention raised by the petitioners regarding the unreasonable classification, is that, by introducing a ceiling of Rs 50 crores of turnover, a sub-classification was created among the Societies, which are otherwise equally placed. Therefore, it amounts to violation of Art.14 of the Constitution of India, it was contended. However, while considering the aforesaid question, the crucial aspect to be noticed is that, as far as the criteria of Rs.50 crores is concerned, the same cannot be treated as an unreasonable classification. This is particularly because, the liability to pay income tax itself is based on the income 2025:KER W.P(C)No.7053/2023 & Connected cases 778 received by the assessee and the scheme of Act itself is to apply different rates of tax upon different groups, which are created based on the income they receive. Thus, the classification based on the total income or the taxable income, forms the basic structure of the Income Tax Act. Even in respect of the provision that contemplates TDS, several exemptions are provided based on the income criteria and various ceiling limits are prescribed in respect of various categories, based on the income or the amount included in the transaction. Thus, this being in tune with the statutory structure of the Act, unless it is shown that, the classification referred to in the proviso is indeed creating separate classes among the persons having equal status, no interference could be made. In other words, the difference in the income or the quantum of the amount involved, itself is the classification that determines the liability of tax or the amount to be paid as tax, and the classifications based on the income, form the basic structure of the Income Tax Act. Since the very concept involved is, "the liability is higher when the income is higher", fixing a criterion in similar lines, in 2025:KER W.P(C)No.7053/2023 & Connected cases 779 the matter of TDS, cannot be found fault with, by treating it as an unreasonable classification. Of course, it is true that, as far as the provisions which are the subject matter of these writ petitions are concerned, those are in respect of Co-operative Societies, but, the fact remains that, the tax liability of each Societies is depending upon the income that they receive, as well as its source, nature etc, and it is not merely because of their status as a Society. As mentioned above, as far as an assessee is concerned, different rates of tax are applicable depending upon the income they earn. Therefore, when it comes to the question of TDS and the exemption from making deduction towards TDS, I do not find any illegality in creating a classification based on the income they receive. 19. The above view is supported by the observations made by a five judges bench decision of the Honourable Supreme Court in K.T Moopil Nair's case (supra), where, while considering the challenge against a taxing statute, namely, the Travencore-Cochin Land Tax Act, certain observations were made, with regard to the circumstances under 2025:KER W.P(C)No.7053/2023 & Connected cases 780 which such a challenge can be entertained, based on classification. In paragraph 7 thereof, after referring to Art. 265 of the Constitution of India, and while upholding the contention that, even a taxing statute can be subjected to challenge on the basis of unreasonable classification, the following observations were made : "7. It cannot be disputed that if the Act infringes the provisions of Article 14 of the Constitution, it must be struck down as unconstitutional. For the purpose of these cases, we shall assume that the State Legislature had the necessary competence to enact the law, though the petitioners have seriously challenged such a competence. The guarantee of equal protection of the laws must extend even to taxing statutes. It has not been contended otherwise. It does not mean that every person should be taxed equally. But it does mean that if property of the same character has to be taxed, the taxation must be by the same standard, so that the burden of taxation may fall equally on all persons holding that kind and extent of property. If the taxation, generally speaking, imposes a similar burden on everyone with reference to that particular kind and extent of property, on the same basis of taxation, the law shall not be open to attack on the ground of inequality, even though the result of the taxation may be that the total burden on different persons may be unequal. *Hence, if the legislature has classified persons or properties into different categories, which are subjected to different rates of taxation with reference to income or property, such a classification would not be open to the attack of inequality on the ground that the total burden resulting from such a classification is unequal. Similarly, different kinds of property may be subjected to different rates of taxation, but so long as there is a rational basis for the classification, Article 14 will not be in the way of such a classification 2025:KER W.P(C)No.7053/2023 & Connected cases 781 resulting in unequal burdens on different classes of properties. But if the same class of property similarly situated is subjected to an incidence of taxation, which results in inequality, the law may be struck down as creating an inequality amongst holders of the same kind of property. It must, therefore, be held that a taxing statute is not wholly immune from attack on the ground that it infringes the equality clause in Article 14, though the courts are not concerned with the policy underlying a taxing statute or whether a particular tax could not have been imposed in a different way or in a way that the Court might think more just and equitable. The Act has, therefore, to be examined with reference to the attack based on Article 14 of the Constitution." (*Highlighted for emphasis) 20. The learned Special Govt. Pleader raised another contention to the effect that, Section 194A(3) clause (v) specifically deals with the income credited or paid by a Co-operative Society to a member or such income credited or paid by the Co-operative Society to any other Co-operative Society. It is pointed out that, even in the case of payment made by a Co-operative Society to any other Co-operative Society, such payment is made in view of the fact that the payee society is a member of the payer society. Therefore, the benefit contemplated under Clause (v) of 194A(3) is in respect of the payment received by the member of a Society whereas, the proviso to section 194A(3) takes 2025:KER W.P(C)No.7053/2023 & Connected cases 782 away the right of the payee to get the income without being subject to TDS, based on a criterion, which is applicable to the payer alone. This is because, the ceiling contemplated in the said proviso is that of the income of the payer society, which has nothing to do with the payee. Thus, according to the learned Special Government Pleader, the stipulations in the proviso had gone beyond the scope of the main provision and therefore, the same is to be interfered with. Infact, the petitioners have also raised a contention with regard to the limited scope of the proviso, when it comes to the question of real purpose and scope of the main provision. 21. To consider the said question, it is necessary to examine the principles that relate to the interpretation of a proviso and its applicability to the main provision. The petitioners brought the attention of this court to the observations in foreign decisions such as, West Derby Union v. Metropolitan Life Assurance Company [1897 AC 647 (HL)] and Jennings v. Kelly [1940 AC 206], where it was observed that, a proviso to a section cannot be used to import into the 2025:KER W.P(C)No.7053/2023 & Connected cases 783 enacting part, something which is not there, but where the enacting part is susceptible to several possible meanings, it may be controlled by proviso. Thus, it was contended that, the real purpose of the proviso is to act as an optional addenda to the enactment with the sole object of explaining the real intendment of the statutory provision, as held in Swedish Match AB and Another v. Securities and Exchange Board and Another [(2004) 11 SCC 641]. 22. The aforesaid question was elaborately considered by a three judges bench of the Honourable Supreme Court in S.Sundaram Pillai and others v. V.R.Pattabhiraman and others [(1985) 1 SCC 591]. The decisions in West Derby Union (supra) and Jennings (supra), relied on by the petitioners, were also referred to by the Honourable Supreme Court in the said decision. In paragraph 30 of the said decision, Sarathi in Interpretation of Statutes was quoted, which reads as follows: "30. Sarathi in Interpretation of Statutes at pages 294-295 has collected the following principles in regard to a proviso: (a) When one finds a proviso to a section the natural presumption is that, but for the proviso, the enacting part of the 2025:KER W.P(C)No.7053/2023 & Connected cases 784 section would have included the subject-matter of the proviso. (b) A proviso must be construed with reference to the preceding parts of the clause to which it is appended. (c) Where the proviso is directly repugnant to a section, the proviso shall stand and be held a repeal of the section as the proviso speaks the latter intention of the makers. (d) Where the section is doubtful, a proviso may be used as a guide to its interpretation: but when it is clear, a proviso cannot imply the existence of words of which there is no trace in the section. (e) The proviso is subordinate to the main section. (f) A proviso does not enlarge an enactment except for compelling reasons. (g) Sometimes an unnecessary proviso is inserted by way of abundant caution. (h) A construction placed upon a proviso which brings it into general harmony with the terms of section should prevail. (i) When a proviso is repugnant to the enacting part, the proviso will not prevail over the absolute terms of a later Act directed to be read as supplemental to the earlier one. (j) A proviso may sometimes contain a substantive provision." 23.In paragraph 37 of the said decision, it was observed that, a proviso is intended to limit the enacted provision so as to except something which would have otherwise been within it or in some measure to modify the enacting clause. It was further observed that, sometimes, a proviso may be embedded in the main provision and becomes an integral part of it so as to amount to a substantive 2025:KER W.P(C)No.7053/2023 & Connected cases 785 provision itself. In the said decision, the following observation made by the Honourable Supreme Court in Dwaraka Prasad v Dwaraka Das Saraf [(1976) 1 SCC 128] was also referred to: "........ A proviso ordinarily is but a proviso, although the golden rule is to read the whole section, inclusive of the proviso, in such manner that they mutually throw light on each other and result in a harmonious construction." 24.Similarly, in the said decision, the following observations in Hiralal Rattanlal v State of U.P [(1973) 1 SCC 216)] were also referred to: "Ordinarily a proviso to a section is intended to take out a part of the main section for special treatment. It is not expected to enlarge the scope of the main section. But cases have arisen in which this Court has held that despite the fact that a provision is called proviso, it is really a separate provision and the so- called proviso has substantially altered the main section." 25. Thus, after referring to a number of precedents and principles, the purposes of a proviso were summed up in paragraph 43 of S.Sundaram Pillai's case (supra), in the manner as follows: "43. We need not multiply authorities after authorities on this point because the legal position seems to be clearly and manifestly well established. To sum up, a proviso may serve four different purposes: (1) qualifying or excepting certain provisions from the main enactment: 2025:KER W.P(C)No.7053/2023 & Connected cases 786 (2) it may entirely change the very concept of the intendment of the enactment by insisting on certain mandatory conditions to be fulfilled in order to make the enactment workable: (3) it may be so embedded in the Act itself as to become an integral part of the enactment and thus acquire the tenor and colour of the substantive enactment itself; and (4) it may be used merely to act as an optional addenda to the enactment with the sole object of explaining the real intendment of the statutory provision." 26. In this regard, the observations made by the Honourable Supreme Court in Commissioner of Income Taxes v. Ramkishan Shrikishan Jhaver and others [AIR 1968 SC 59] are relevant. It was observed in the said decision, after referring to some other decision of the Honourable Supreme Court that, in exceptional circumstances, a proviso may not be really a proviso in accepted sense, but may be a substantive provision itself. 27. Thus, when we are attempting to deduce the principles from the decisions referred to above, what could be gathered is that, there is no hard and fast rule that, a proviso to a main section in all cases, should be subject to the confines of the enacted provision, but instead, in some cases it by itself could be a substantive provision, that could alter the 2025:KER W.P(C)No.7053/2023 & Connected cases 787 main provision itself, substantially. On careful examination of decisions where such an extreme interpretation giving substantive status to the proviso is given, it can be seen that, those were made after going through the circumstances under which the said proviso was introduced, the object behind the same etc, which would ultimately lead to the purpose for which such a proviso was brought in by the legislature. Thus, while considering the aforesaid question, the paramount consideration should be the intention of the legislature while bringing in such legislation. It is to be noted in this regard that, despite carefully scanning through the decisions referred to above, nothing could be found, that restricts the power of the legislature to introduce a statutory stipulation in the form of a proviso, but on the other hand, there are decisions, where it was observed that, in certain circumstances, the proviso could be treated as substantive provision that alters the main provision. Therefore, in the absence of any such prohibition upon the legislature, a proviso that was intentionally brought by the legislature to make substantial changes in the main section, cannot be interfered with, 2025:KER W.P(C)No.7053/2023 & Connected cases 788 merely because of the reason that, it is a proviso. To be precise, in such circumstances, it has to be treated as part of the main provision, and the interference could be made only if the other tests to determine the Constitutionality viz, lack of legislative competence, violative of Part III of the Constitution, manifest arbitrariness etc, are satisfied. 28. When the proviso to section 194A(3) is examined in that perspective, it can be seen that, the said proviso was subsequently introduced by way of an amendment as per Finance Act, 2020, bringing in, some conditions restricting the operation of the main provision. Thus, it is evident that it was intended to alter the scope of the main provision i.e subsection (3) of the Section 194A, and in the light of the principles referred to above, the same cannot be interfered with, merely because it is a proviso. 29. Of course, as pointed by the learned Special Government Pleader, the clause (v) of subsection (3) of Section 194A of the Act, deals with the exemption from the point of view of the payee, whereas, the proviso deals with the non-applicability of the said provision 2025:KER W.P(C)No.7053/2023 & Connected cases 789 depending upon the total turnover or total sales or gross receipts of the payer. However, I am of the view that, the same by itself would not be a ground to interfere with the said provision. This is mainly because, the stipulation in Section 194(3) relates to the inapplicability of Section 194A(1) in the matter of TDS, where, the liability to deduct the amount as TDS is imposed upon the payer. Therefore, by virtue of the proviso, the ultimate result is the change in restrictions on the applicability of section 194A(1), which deals with the obligation of the payer, and hence there is nothing wrong therein, as the basis is the total turnover or gross receipts or total sales of the payer. It is to be noted that the higher the turnover, higher the number of transactions and this could be a reasonable ground to make such a classification. 30.Another contention raised by the petitioners is that, while fixing the criteria as the turnover or gross receipt or total sales exceeding Rs 50 Crores, the classification was made by the respondents without any intelligible differentia and hence the same cannot be considered as reasonable. Reliance was placed on Asianet Satellite 2025:KER W.P(C)No.7053/2023 & Connected cases 790 Communication v. State of Kerala [2012 (4) KLT 431], where it was held that the classification of cable TV operators having more than 7500 subscribers for the purpose of subjecting them to tax is violative of Article 14. However, it is to be noted that, in this case, as mentioned above, what is taxable, is the income of the assessee, and for that purpose the tax payers with different income, cannot be treated as equals, even if such tax payers are having the same status as far as their occupation/professions/trade is concerned. In Murthy Match Works v. CCE, [(1974) 4 SCC 428], it was held that; "15. Certain principles which bear upon classification may be mentioned here. It is true that a State may classify persons and objects for the purpose of legislation and pass laws for the purpose of obtaining revenue or other objects. Every differentiation is not a discrimination. But classification can be sustained only it (sic) it is founded on pertinent and real differences as distinguished from irrelevant and artificial ones. The constitutional standard by which the sufficiency of the differentia which form a valid basis for classification may be measured, has been repeatedly stated by the Courts. If it rests on a difference which bears a fair and just relation to the object for which it is proposed, it is constitutional. To put it differently, the means must have nexus with the ends. Even so, a large latitude is allowed to the State for classification upon a reasonable basis and what is reasonable is a question of practical details and a variety of factors which the Court will be reluctant and perhaps ill-equipped to investigate. In this imperfect world perfection even in grouping is an ambition hardly ever accomplished. In 2025:KER W.P(C)No.7053/2023 & Connected cases 791 this context, we have to remember the relationship between the legislative and judicial departments of Government in the determination of the validity of classification. Of course, in the last analysis Courts possess the power to pronounce on the constitutionality of the acts of the other branches whether a classification is based upon substantial differences or is arbitrary, fanciful and consequently illegal. At the same time, the question of classification is primarily for legislative judgment and ordinarily does not become a judicial question. A power to classify being extremely broad and based on diverse considerations of executive pragmatism, the Judicature cannot rush in where even the Legislature warily treads. All these operational restraints on judicial power must weigh more emphatically where the subject is taxation". In Union of India v. Nitdip Textile Processors (P) Ltd.,[ (2012) 1 SCC 226], it was observed as follows; "67. It has been laid down in a large number of decisions of this Court that a taxation statute, for the reasons of functional expediency and even otherwise, can pick and choose to tax some. A power to classify being extremely broad and based on diverse considerations of executive pragmatism, the judicature cannot rush in where even the legislature warily treads. All these operational restraints on judicial power must weigh more emphatically where the subject is taxation. Discrimination resulting from fortuitous circumstances arising out of particular situations, in which some of the tax-payers find themselves, is not hit by Article 14 if the legislation, as such, is of general application and does not single them out for harsh treatment. Advantages or disadvantages to individual assessees are accidental and inevitable and are inherent in every taxing statute as it has to draw a line somewhere and some cases necessarily fall on the other side of the line." Therefore, merely because, a different yardstick was adopted for the 2025:KER W.P(C)No.7053/2023 & Connected cases 792 assessment or TDS, based on the income, in respect of the Co-operative Societies, it cannot be treated as unreasonable. 31. Yet another contention raised by the petitioners is that, the impact of the introduction of the proviso is that, the income of the petitioners by way of interest for their deposits with the Kerala Bank, the Apex Society, would be subjected to TDS in its entirety. This is because, as far as the petitioners are concerned, in the light of the provisions in the Kerala Co-operative Societies Act, the Rules framed thereunder, and the Government orders and circulars issued in this regard, the petitioners are bound to deposit the cash balance with the Kerala Bank. In view of the fact that, total turnover of the Kerala Bank being in excess of Rs 50 Crores, all their income from that source is subjected to TDS and thus the exemption that is granted as per Section 194A (3) is taken away as per the proviso. According to the petitioners, such a stipulation is arbitrary and amounts to manifest arbitrariness and hence interference is required. It was also pointed out that, as far as Co- operative sector is concerned, it is entitled to the Constitutional 2025:KER W.P(C)No.7053/2023 & Connected cases 793 protection as per the various provisions in the Constitution of India. It was pointed out that such special protection was extended to the said sector, considering the huge economic impact that can be created by the Cooperative movement to the economy as a whole and the rural economy in particular. The observations of the Honourable Supreme Court in Shayara Bano v. Union of India [(2017) 9 SCC 1] were also relied on, in which the manifest arbitrariness was accepted as a valid ground for the challenge against a statutory provision. 32. However, the crucial aspect to be noticed in this regard is that, the difficulties highlighted by the petitioners, in the matter of compulsory nature of the deposits and matters incidental thereto, are not on account of any stipulations in the Income Tax Act itself, but those are due to the consequences of the provisions in the Kerala Co-operative Societies Act, and the orders issued by the statutory authorities under the said Act. Such consequences cannot be a reason for the manifest arbitrariness on the part of the Central legislature when terms and conditions in an enactment are brought into force by the said legislature. 2025:KER W.P(C)No.7053/2023 & Connected cases 794 In other words, when the major contributory factor for the denial of the benefit is on account of a different statute than the one under challenge, that too being a State subject, the same cannot be taken as a valid ground to attribute manifest arbitrariness in the Central Statute. 33. Yet another aspect to be noticed in this regard is that, the hardships or inconvenience of the party subjected to a law, by itself cannot be a good reason for judicial interference in a statute as laid down in Ajmera Housing Corporation and Another vs. C.I.T. (2010) 326 ITR 642 (SC). In Union of India v. M.V. Valliappan, (1999) 6 SCC 259, it was observed that , the consideration of hardship is totally irrelevant for deciding the question of legislative competence. In the case of taxation, it is settled law that hardship or equity has no role to play in determining eligibility (sic exigibility) to tax and it is for the legislature to determine the same. In Rohitash Kumar v. Om Prakash Sharma, (2013) 11 SCC 451, it was held that, there may be a statutory provision, which causes great hardship or inconvenience to either the party concerned, or to an individual, but the court has no choice but to 2025:KER W.P(C)No.7053/2023 & Connected cases 795 enforce it in full rigour.In Bengal Immunity Co. Ltd. v. State of Bihar [AIR 1955 SC 661] (SCC p. 685, para 43) it was observed by a Constitution Bench of the Supreme Court that, if there is any hardship, it is for the legislature to amend the law, and that the court cannot be called upon to discard the cardinal rule of interpretation for the purpose of mitigating such hardship. If the language of an Act is sufficiently clear, the court has to give effect to it, however inequitable or unjust the result may be. The words, "dura lex sed lex" which mean "the law is hard but it is the law" may be used to sum up the situation. Therefore, even if a statutory provision causes hardship to some people, it is not for the court to amend the law. A legal enactment must be interpreted in its plain and literal sense, as that is the first principle of interpretation. This is because, the legislature, being the reflection of the will of the people, is supposed to have the knowledge and expertise in the matters of consequence of each provision in every statute and when they are making a law with particular stipulations, they deemed to have taken note of such difficulties. 2025:KER W.P(C)No.7053/2023 & Connected cases 796 34. It was also contended by the petitioners that, the petitioners are eligible to be provided with the benefits that are contemplated under section 194A (3) (iii) (a) of the Income Tax Act. The said provision reads as follows: "194A(3)(iii)(a)": The provision of sub-section (1) shall not apply- xxx xxx xxx xxx xxx xxx (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 and mortgage bank)" However, I am not inclined to accept the said contention as well. This is because, going by the said provision, it can be seen that, what is contemplated therein, is with respect to the banking companies to which the Banking Regulation Act, 1949 applies or any co-operative society engaged in the business of banking, including a co-operative land mortgage bank. Evidently, the petitioners are not engaged in the business of banking and their operation is mainly confined to providing financial assistance to its members for agricultural purposes, where the concept of mutuality exists. In this regard, it is profitable to examine the 2025:KER W.P(C)No.7053/2023 & Connected cases 797 definition of banking, as defined section 5(b) of the Banking Regulation Act, 1949, which reads as follows: ""banking" means the accepting, for the purpose of lending or investment, of deposits of money from the public, repayable on demand or otherwise, and withdrawal by cheque, draft or otherwise." Evidently, the petitioners are not coming within the said definition. Therefore, the petitioners cannot be treated as the institutions that fall within Section 194A(3 (iii) of the Income tax Act as well. Thus, on the overall consideration of the contentions raised by the petitioners, this Court is of the view that the petitioners could not establish any of the grounds that are required to exercise any judicial intervention in the provisions contained in the proviso to section 194A(3) of the Income Tax Act, 1961. Accordingly, these Writ Petitions are dismissed. Sd/- ZIYAD RAHMAN A.A. JUDGE pkk. 2025:KER W.P(C)No.7053/2023 & Connected cases 798 ORDER Spoke : 2. Immediately upon pronouncement of the judgment, learned counsel for the petitioners brought to the notice of this Court, certain practical difficulties arising from the operation of the interim order. Accordingly, the matter was listed today for addressing those concerns. After hearing the parties, the following clarification is issued: 3. In these cases, though the question of law has been decided in favour of the Revenue, certain practical issues arise concerning the interim orders passed during the pendency of the writ petitions. In all matters, interim orders were in force, staying deduction of amounts towards TDS, and such orders were duly acted upon by all concerned. Reversing the consequences of non-deduction of TDS, which occurred pursuant to the interim orders, would be practically difficult and likely to cause serious legal and procedural complications. Hence, it is only just and proper that the interim orders are made absolute in respect of all transactions up to the date of pronouncement of the judgment., and it is ordered accordingly. 2025:KER W.P(C)No.7053/2023 & Connected cases 799 This would mean that, in respect of all transactions effected, pursuant to the interim orders passed by this Court in these writ petitions, no adverse consequences shall follow, from the judgment now rendered. This order shall form part of the judgment pronounced by this Court on 25.10.2025. 29.10.2025 Sd/- ZIYAD RAHMAN A.A. 2025:KER W.P(C)No.7053/2023 & Connected cases 800 APPENDIX OF WP(C) 7053/2023 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY VELLANGALLUR BRANCH MANAGER OF THE 4TH RESPONDENT TO THE 1ST PETITIONER Exhibit P2 A TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY IRINJALAKUDA BRANCH MANAGER OF THE 4TH RESPONDENT TO THE 2ND PETITION 2025:KER W.P(C)No.7053/2023 & Connected cases 801 APPENDIX OF WP(C) 213/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR NO. 150/2021 DATED 15.11.2021 ISSUED BY THE 4TH RESPONDENT TO ITS BRANCH MANAGERS. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER DATED NIL. Exhibit P3 A TRUE COPY OF THE FORM NO. 15G SUBMITTED BY THE 1ST PETITIONER TO THE 4TH RESPONDENT DATED 02.12.2021. Exhibit P4 A TRUE COPY OF THE LETTER SUBMITTED BY THE 1ST PETITIONER TO THE 4TH RESPONDENT DATED 04.12.2021. Exhibit P5 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31.05.2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P6 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT DATED 17.12.2021 TO 1ST PETITIONERS. Exhibit P7 A TRUE COPY OF THE LETTER DATED 09.12.2021 ISSUED BY THE 3RD RESPONDENT TO 4TH RESPONDENT. Exhibit P8 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29.05.2017 ISSUED BY CBDT. Exhibit P9 A TRUE COPY OF THE INTERIM ORDER IN W.P.C NO. 30263 OF 2021 DATED 23.12.2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 802 APPENDIX OF WP(C) 378/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR NO. 150/2021 DATED 15/11/2021 4TH RESPONDENT TO ITS BRANCH MANAGERS. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT TO THE 25TH PETITIONER DATED NIL. Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER DATED 16/12/2021. Exhibit P4 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31/05/2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P5 A TRUE COPY OF THE LETTER DATED 09/12/2021 ISSUED BY THE 3RD RESPONDENT TO 4TH RESPONDENT. Exhibit P6 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29/05/2017 ISSUED BY CBDT. Exhibit P7 A TRUE COPY OF THE INTERIM ORDER IN WPC NO.30263/2021 DATED 23/12/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 803 APPENDIX OF WP(C) 384/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE THIRUR BRANCH MANGER OF 4TH RESPONDENT DATED 18/11/2021 TO THE 2ND PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER DATED NIL. Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANGER MARANCHERY BRANCH OF THE 4TH RESPONDENT TO THE 19TH PETITIONER DATED 20/12/2021. Exhibit P4 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31/05/2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P5 A TRUE COPY OF THE LETTER DATED 09/12/2021 ISSUED BY THE 3RD RESPONDENT TO 4TH RESPONDENT. Exhibit P6 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/05/2017 ISSUED BY CBDT. Exhibit P7 A TRUE COPY OF THE INTERIM ORDER IN WP(C) NO.30263 OF 2021 DATED 23/12/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 804 APPENDIX OF WP(C) 383/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE THIRUR BRANCH MANAGER OF 4TH RESPONDENT DATED 18/11/2021 TO THE 6TH PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT TO THE 6TH PETITIONER DATED NIL. Exhibit P3 A TRUE COPY OF THE FORM NO.15G SUBMITTED BY THE 6TH PETITIONER TO THE 4TH RESPONDENT DATED 01/12/2021. Exhibit P4 A TRUE COPY OF THE LETTER SUBMITTED BY THE 6TH PETITIONER TO THE 4TH RESPONDENT THIRUR BRANCH MANAGER DATED 01/12/2021. Exhibit P5 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31/05/2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P6 A TRUE COPY OF THE LETTER ISSUED BY THE 4TH RESPONDENT THIRUR BRANCH MANAGER TO THE 6TH PETITIONER DATED 16/12/2021 TO 6TH PETITIONER. Exhibit P7 A TRUE COPY OF THE LETTER DATED 09/12/2021 ISSUED BY THE 3RD RESPONDENT TO 4TH RESPONDENT. Exhibit P8 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/05/2017 ISSUED BY CBDT. Exhibit P9 A TRUE COPY OF THE INTERIM ORDER IN WP(C) NO.30263 OF 2021 DATED 28/12/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 805 APPENDIX OF WP(C) 732/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER ISSUED BY THE MALAPPURAM DISTRICT CO-OPERATIVE TO THE 3RD PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 806 APPENDIX OF WP(C) 736/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE VYLATHUR BRANCH MANAGER OF 4TH RESPONDENT DATED 18/11/2021 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY VYLATHUR BRANCH MANAGER OF THE 4TH RESPONDENT TO THE 1ST PETITIONER DATED 17/12/2021. Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012 -13/516 DATED 31/05/2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P4 A TRUE COPY OF THE LETTER DATED 09/12/2021 ISSUED BY THE 3RD RESPONDENT TO 4TH RESPONDENT. Exhibit P5 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/05/2017 ISSUED BY CBDT. Exhibit P6 A TRUE COPY OF THE INTERIM ORDER IN WPC NO.213/2022 DATED 05/01/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 807 APPENDIX OF WP(C) 833/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 16.12.2021 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK TO THE PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS 2025:KER W.P(C)No.7053/2023 & Connected cases 808 APPENDIX OF WP(C) 1383/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED ISSUED BY THE MALAPPURAM DISTRICT CO-OPERATIVE TO THE 1ST PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 809 APPENDIX OF WP(C) 1633/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE KADAMPUZHA BRANCH MANAGER OF 4TH RESPONDENT DATED 16-12-2021 TO THE 1ST PETITIONER Exhibit P2 A TRUE COPY OF THE LETTER RB1/2012-13/516 DATED 31-05-2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS Exhibit P3 A TRUE COPY OF THE LETTER DATED 09-12-2021 ISSUED BY THE 3RD RESPONDENT TO 4TH RESPONDENT` Exhibit P4 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29-05-2017 ISSUED BY CBDT Exhibit P5 A TRUE COPY OF THE INTERIM ORDER IN WP(C0 NO. 213 OF 2022 DATED 05-01-2022 2025:KER W.P(C)No.7053/2023 & Connected cases 810 APPENDIX OF WP(C) 1808/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE REGISTRATION CERTIFICATE ISSUED BY THE REGISTRAR OF CO-OPERATIVE SOCIETIES(GENERAL) MALAPPURAM. Exhibit P2 THE COPY OF THE NOTICE ISSUED TO THE PETITIONER BY THE DISTRICT CO-OPERATIVE BANK MALAPPURAM DATED 15.12.2021. Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC NO.30811/2021 DATED 28.12.2021. Exhibit P4 A TRUE COPY OF THE ORDER IN WPC 30263/2021 DATED 23.12.2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 811 APPENDIX OF WP(C) 1943/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE ISSUED BY THE MALAPPURAM DISTRICT CO-OPERATIVE BANK, TO THE PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS 2025:KER W.P(C)No.7053/2023 & Connected cases 812 APPENDIX OF WP(C) 2208/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED 01.12.2022 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE TO THE PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 813 APPENDIX OF WP(C) 2780/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE MALAPPURAM BRANCH MANAGER OF 4TH RESPONDENT DATED 10-01-2022 TO THE PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER RB1/2012-13/516 DATED 31-05-2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29-05-2017 ISSUED BY CBDT Exhibit P4 A TRUE COPY OF THE INTERIM ORDER IN WP(C0 NO. 1633 OF 2022 DATED 17-1-2022 2025:KER W.P(C)No.7053/2023 & Connected cases 814 APPENDIX OF WP(C) 3734/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED 4.1.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. Exhibit P2 TRUE COPY OF THE LETTER DATED 4.1.2022 ISSUED BY THE 5TH RESPONDENT TO THE 2ND PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. Exhibit P3 TRUE COPY OF THE LETTER DATED 4.1.2022 ISSUED BY THE 5TH RESPONDENT TO THE 3RD PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. Exhibit P4 TRUE COPY OF THE LETTER DATED 17.3.2020 ISSUED BY THE 6TH RESPONDENT TO THE 4TH PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED 23.12.2021 IN WP(C) NO.30263/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 815 APPENDIX OF WP(C) 4385/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE REQUEST FILED BY THE PETITIONER BEFORE THE ASSESSMENT AUTHORITY UNDER THE NATIONAL FACELESS ASSESSMENT SCHEME DATED 6.9.2021. Exhibit P2 A TRUE COPY OF THE COMMUNICATION DATED 7.4.2018 SUBMITTED BY THE PETITIONER. Exhibit P3 A TRUE COPY OF THE NOTICE DATED 14.1.2022 ISSUED BY THE 1ST RESPONDENT. Exhibit P4 A TRUE COPY OF THE COMMUNICATION DATED 1.1.2022 ISSUED FROM THE ANCHALUMOOD BRANCH OF THE 7TH RESPONDENT. Exhibit P5 A TRUE COPY OF THE JUDGMENT 18.10.2019 IN WP(C) NO.11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P6 A TRUE COPY OF JUDGMENT DATED 3.12.2019 IN WP(C) NO.9274 OF 2019 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 816 APPENDIX OF WP(C) 4442/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE NOTICE NO.ITBA/COM/F/17/2021-22/1039272931(1) DATED 01.02.2022 ISSUED BY THE 5TH RESPONDENT. RESPONDENT ANNEXURES Annexure R2 (a) True copy of the Supreme Court decision in the case of Union of India and others vs. Nitdip Textile Processors Pvt. Ltd. and another Annexure R2 (b) True copy of the judgment the Bombay High Court decision the case of All India Central Bank Officers Federation vs. Union of India. 2025:KER W.P(C)No.7053/2023 & Connected cases 817 APPENDIX OF WP(C) 4996/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE NOTICE DTD. NIL ISSUED BY 7TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 818 APPENDIX OF WP(C) 5569/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF AN ILLUSTRATIVE LIST OF CERTAIN WRIT PETITIONS FILED BEFORE THIS HON'BLE COURT CHALLENGING THE INCORPORATION AND APPLICABILITY OF SECTION 194N TO THE CO-OPERATIVE SOCIETIES. Exhibit P2 TRUE COPY OF THE ORDER DATED 23.03.2020 IN WP(C) NO. 9266/2020 PASSED BY THIS HON'BLE COURT. Exhibit P3 TRUE COPY OF THE ORDER DATED 28.04.2020 IN WP(C) NO. WP(C) NO. 169/2020 PASSED BY THIS HON'BLE COURT. Exhibit P4 TRUE COPY OF THE ORDER DATED 31.03.2021 IN WP(C) NO. 8333/2020 PASSED BY THIS HON'BLE COURT. Exhibit P5 TRUE COPY OF THE ORDER DATED 12.01.2022 IN WP(C) NO. 1040/2022 PASSED BY THIS HON'BLE COURT. Exhibit P6 TRUE COPY OF THE ORDER DATED 04.02.2022 IN WP(C) NO. 3864/2022 OF THIS HON'BLE COURT. Exhibit P7 TRUE COPY OF THE DEMAND NOTICE DATED 31-01- 2022 ISSUED BY THE OFFICE OF THE DEPUTY COMMISSIONER, INCOME TAX (TDS), THIRUVANANTHAPURAM TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 819 APPENDIX OF WP(C) 5900/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE PDKL/TDS/2021-22 ISSUED BY THE PANIKKOTTUMPADI BRANCH MANAGER OF 4TH RESPONDENT DATED 16.12.2021 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31.05.2013 ISSUED BY THE CHIEF GENERAL MANAGER TO RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29.05.2017 ISSUED BY CBDT. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER IN WP(C) NO. 2780 OF 2022 DATED 27.01.2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 820 APPENDIX OF WP(C) 8026/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 821 APPENDIX OF WP(C) 8742/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/02/2022 IN WPC NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 822 APPENDIX OF WP(C) 8943/2023 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 6TH RESPONDENT Exhibit P5 TRUE COPY OF THE NOTICE DATED 2-03-2023 ISSUED BY THE REGIONAL OFFICE OF 6TH RESPONDENT TO THE PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 823 APPENDIX OF WP(C) 10465/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 824 APPENDIX OF WP(C) 10480/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE CT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 825 APPENDIX OF WP(C) 10498/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE 781/21-22 DATED 24.03.2022 ISSUED BY THE THIRUVANANTHAPURAM FORT BRANCH MANAGER OF 4TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE NOTICE 781/21-22 DATED 24.03.2022 ISSUED BY THE THIRUVANANTHAPURAM FORT BRANCH MANAGER OF 4TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 A TRUE COPY OF THE RBI/2012-13/516 DATED 31.05.2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P4 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.05.2017 ISSUED BY CBDT. Exhibit P5 A TRUE COPY OF THE INTERIM ORDER IN WPC NO.2780 OF 2022 DATED 27.01.2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 826 APPENDIX OF WP(C) 10692/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDINGS DATED 09/03/2020 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 18/03/2020 IN WPC NO.8502/2020 ISSUED BY THIS HON'BLE COURT. Exhibit P3 TRUE COPY OF THE PROCEEDING DATED 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 827 APPENDIX OF WP(C) 10697/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 25-03-2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 828 APPENDIX OF WP(C) 10699/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDINGS 26/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 829 APPENDIX OF WP(C) 10705/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 830 APPENDIX OF WP(C) 10717/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN WP(C) NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 831 APPENDIX OF WP(C) 10719/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 1ST PETITIONER KEEZHILLAM SERVICE CO-OP BANK LTD.NO.E3989. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVE ON THE 2ND PETITIONER PERUMBAVOOR SERVICE CO-OP BANK LTD.NO.802. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 3RD PETITIONER AYYAMPUZHA SERVICE CO-OPERATIVE BANK LTD.NO.E788. Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVE ON THE 4TH PETITIONER CHOWARA SERVICE CO-OPERATIVE BANK LTD.NO.587. Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 5TH PETITIONER SREEMOOLANAGARA SERVICE CO-OPERATIVE BANK LTD.NO.4178. Exhibit P6 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 6TH PETITIONER OKKAL SERVICE CO-OPERATIVE BANK LTD.NO.E1215. Exhibit P7 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 7TH KANJOOR SERVICE CO- OPERATIVE BANK LTD.NO.454. Exhibit P8 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE 8TH PETITIONER KARAYAMPARAMBU SERVICE CO-OPERATIVE BANK LTD.NO.1573. Exhibit P9 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 9TH SERVICE CO-OPERATIVE BANK LTD.NO.PETITIONER GOVERNMENT SERVANTS SERVICE CO-OPERATIVE BANK LTD.NO.131. Exhibit P10 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE 10TH PETITIONER PERUMBAVOOR KSRTC EMPLOYEES CO OPERATIVE SOCIETY LTD.NO.E 783. Exhibit P11 TRUE COPY OF THE INTERIM ORDER IN WPC NO.18435/20 DATED 18.03.2020. 2025:KER W.P(C)No.7053/2023 & Connected cases 832 APPENDIX OF WP(C) 10720/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 833 APPENDIX OF WP(C) 10721/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 9.03.2020 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE INTERIM ORDER DATED 23.03.20220 IN WP(C) NO. 9319 OF 2020 ISSUED BY THIS HON'BLE COURT. Exhibit P3 TRUE COPY OF THE PROCEEDING 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 834 APPENDIX OF WP(C) 10722/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDINGS 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 835 APPENDIX OF WP(C) 10731/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 836 APPENDIX OF WP(C) 10735/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 837 APPENDIX OF WP(C) 10738/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER 24-03-2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER Exhibit P2 TRUE COPY OF THE LETTER 24-03-2022 ISSUED BY THE 5TH RESPONDENT TO THE 2ND PETITIONER Exhibit P3 TRUE COPY OF THE LETTER 24-03-2022 ISSUED BY THE 5TH RESPONDENT TO THE 3RD PETITIONER Exhibit P4 TRUE COPY OF THE LETTER 24-03-2022 ISSUED BY THE 5TH RESPONDENT TO THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE LETTER 24-03-2022 ISSUED BY THE 5TH RESPONDENT TO THE 5TH PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 838 APPENDIX OF WP(C) 10741/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED 24.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 839 APPENDIX OF WP(C) 10744/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 19.02.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 840 APPENDIX OF WP(C) 10747/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 841 APPENDIX OF WP(C) 10787/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER 24.03.2922 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 842 APPENDIX OF WP(C) 10799/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 5TH PETITIONER. Exhibit P6 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 6TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P7 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 7TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P8 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 8TH RESPONDENT TO THE 3RD PETITIONER. Exhibit P9 TRUE COPY OF THE LETTER 24.3.2022 ISSUED BY THE 9TH RESPONDENT TO THE 4TH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 843 APPENDIX OF WP(C) 10810/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED 7TH RESPONDENT PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 844 APPENDIX OF WP(C) 10818/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY 7TH RESPONDENT PROPOSING TO LEVY TDS FROM DEPOSITS 2025:KER W.P(C)No.7053/2023 & Connected cases 845 APPENDIX OF WP(C) 10828/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY 7TH RESPONDENT PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 846 APPENDIX OF WP(C) 10831/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY 7TH RESPONDENT PROPOSING T LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 847 APPENDIX OF WP(C) 10845/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY 7TH RESPONDENT TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 848 APPENDIX OF WP(C) 10855/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 25-03-2022 ISSUED BY 7TH RESPONDENT PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 849 APPENDIX OF WP(C) 10891/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE 25.3.2020 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 850 APPENDIX OF WP(C) 10936/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN WP(C) NO. 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 6TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 851 APPENDIX OF WP(C) 10937/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN WP(C) NO. 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 852 APPENDIX OF WP(C) 10968/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 853 APPENDIX OF WP(C) 10967/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE PATTANAKKAD BRANCH MANAGER OF THE 4TH RESPONDENT DATED 24.03.2022 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE POOCHAKKAL BRANCH MANAGER OF 4TH RESPONDENT DATED 24.03.2022 TO THE 9TH PETITIONER. Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31.05.2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS . Exhibit P4 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29.05.2017 ISSUED BY CBDT. 2025:KER W.P(C)No.7053/2023 & Connected cases 854 APPENDIX OF WP(C) 11001/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 20220. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/02/2022 IN WPC NO.4442/2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 855 APPENDIX OF WP(C) 11009/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY 7TH RESPONDENT PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 856 APPENDIX OF WP(C) 11035/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF NOTICE FORMAT DATED NIL ISSUED FROM CHIRAYINKEEZHU BRANCH OF THE 6TH RESPONDENT TO PETITIONER. Exhibit P2 A TRUE COPY OF JUDGMENT DATED 18.10.2019 IN WP(C) NO.11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 10.2.2022 IN WP(C) NO.4385 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 857 APPENDIX OF WP(C) 11042/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P3 TRUE COPY OF THE INTERIM ORDER IN WP(C) NO.30263/2021 DATED 23/12/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 858 APPENDIX OF WP(C) 11058/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE KOTTAYAM GANDHINAGAR BRANCH MANAGER OF 4TH RESPONDENT DATED 24-03-2022 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31-05-2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29-05-2017 ISSUED BY CBDT 2025:KER W.P(C)No.7053/2023 & Connected cases 859 APPENDIX OF WP(C) 11072/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE ANNAMANNADA BRANCH MANAGER OF 4TH RESPONDENT DATED 24.3.2022 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY MORNING BRANCH MANAGER THRISSUR OF THE 4TH RESPONDENT TO THE 19TH PETITIONER DATED 26.3.2021. Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31.5.2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P4 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.5.2017 ISSUED BY CBDT. 2025:KER W.P(C)No.7053/2023 & Connected cases 860 APPENDIX OF WP(C) 11087/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 861 APPENDIX OF WP(C) 11092/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE KUTTIKAD FARMERS BRANCH MANAGER OF 4TH RESPONDENT DATED 18-11-2021 TO THE 2ND PETITIONER Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THRISSUR MAIN BRANCH MANAGER OF THE 4TH RESPONDENT TO THE 6TH PETITIONER DATED 17- 12-2021 Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31-05-2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS Exhibit P4 A TRUE COPY OF THE CIRCULAR NO 18/2017 DATED 29-05-2017 ISSUED BY CBDT 2025:KER W.P(C)No.7053/2023 & Connected cases 862 APPENDIX OF WP(C) 11096/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE NOTICE DATED NIL ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT. Exhibit P5 TRUE COPY OF THE NOTICE DATED 26.03.2022 ISSUED TO THE 5TH PETITIONER BY THE 4TH RESPONDENT. Exhibit P6 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.05.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P7 TRUE COPY OF THE INTERIM ORDER IN WPC NO.30263/2021 DATED 23.12.2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 863 APPENDIX OF WP(C) 11117/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM KECHERY BRANCH OF THE 6TH RESPONDENT BANK TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019 IN WP(C)NO.11176 OF 2019 OF THIS HON'BLE COURT Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C)NO.4385 OF 2022 PASSED BY THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 864 APPENDIX OF WP(C) 11130/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS Exhibit P2 TRUE COPY OF THE LETTER DATED 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER PROPOSING TO LEVY TDS FROM WITHDRAWAL EXCEEDING RS 1 CRORES UNDER SECTION 194 N OF THE INCOME TAX ACT Exhibit P3 TRUE COPY OF THE LETTER DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 2ND PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS Exhibit P4 TRUE COPY OF THE LETTER DATED 01.02.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER PROPOSING TO LEVY TDS FROM DESPOSITS MAINTAINED BY THE 2ND PETITIONER WITH THE 5TH RESPONDENT Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED 03.02.2022 AND ORDER DATED 08.02.2020 IN W.P(C)NO.3734/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 865 APPENDIX OF WP(C) 11135/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT,2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE NOTICE NO.ITBA/COM/F/17/2021-22/1039272931(1) DATED 1.2.2022 ISSUED BY THE 5TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 866 APPENDIX OF WP(C) 11138/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM KUNNAMKULAM BRANCH OF THE 6TH RESPONDENT BANK TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019 IN WP(C) NO. 11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED BY THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 867 APPENDIX OF WP(C) 11144/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED FROM VAZHAKKULAM BRANCH OF THE 6TH RESPONDENT BANK TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM THE MUVATTUPUZHA RURAL BRANCH OF THE 6TH RESPONDENT BANK TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM THE MUVATTUPUZHA RURAL BRANCH OF THE 6TH RESPONDENT BANK TO THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM THE MULATHURUTHY BRANCH OF THE 6TH RESPONDENT BANK TO THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM THE VYTTILA BRANCH OF THE 6TH RESPONDENT BANK TO THE 5TH RESPONDENT. Exhibit P6 TRUE COPY OF THE NOTICE DATED 29.03.2022 ISSUED FROM THE THRIPUNITHURA BRANCH OF THE 6TH RESPONDENT BANK TO THE 6TH PETITIONER. Exhibit P7 TRUE COPY OF THE JUDGMENT DATED 18.10.2019 IN WP(C) NO. 11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P8 TRUE COPY OF THE EXTRACT OF SECTION 194 OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P9 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED BY THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 868 APPENDIX OF WP(C) 11143/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM PATTIKKAD BRANCH OF THE 6TH RESPONDENT BANK TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019 IN WP(C) NO.11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED BY THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 869 APPENDIX OF WP(C) 11149/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED 26/03/2022 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 870 APPENDIX OF WP(C) 11150/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LETTER DATED 25/03/2022 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 871 APPENDIX OF WP(C) 11165/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 28.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 872 APPENDIX OF WP(C) 11171/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 873 APPENDIX OF WP(C) 11187/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 6TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 874 APPENDIX OF WP(C) 11184/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE NOTICE NO ITBA/COM/F/17/2021-22/1039272931(1) DATED 1.2.2022 ISSUED BY THE 5TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 875 APPENDIX OF WP(C) 11186/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 4TH PETITIONER Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 5TH PETITIONER Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 6TH PETITIONER Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 7TH PETITIONER Exhibit P8 TRUE COPY OF THE COMMUNICATION LETTER 24.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 8TH PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 876 APPENDIX OF WP(C) 11194/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE NOTICE NO.ITBA/COM/F/17/2021-22/1039272931(1) DATED 1/2/2022 ISSUED BY THE 5TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 877 APPENDIX OF WP(C) 11203/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DATED 27.03.2020 ISSUED BY 1ST RESPONDENT. Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 878 APPENDIX OF WP(C) 11224/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT 1961. Exhibit P3 TRUE COPY OF THE NOTICE NO. ITBA/COM/F/17/2021-22/103927293(1) DATED 1.2.2022 ISSUED BY THE 5TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 879 APPENDIX OF WP(C) 11232/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION 25.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 880 APPENDIX OF WP(C) 11248/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DATED 27.03.2020 ISSUED BY 1ST RESPONDENT. Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961. Exhibit P3 TRUE COPY OF ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 881 APPENDIX OF WP(C) 11247/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER DATE 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER DATED 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER DATE 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER DATE 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 5TH PETITIONER. Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER DATE 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 6TH PETITIONER. Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER DATE 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 7TH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 882 APPENDIX OF WP(C) 11262/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE NOTICE NO. ITBA/COM/F/17/2021-22/1039272931(1) 2025:KER W.P(C)No.7053/2023 & Connected cases 883 APPENDIX OF WP(C) 11260/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER 26.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 884 APPENDIX OF WP(C) 11263/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE NOTICE NO. ITBA/COM/F/17/2021-22/ 1039272931(1) DATED 1.2.2022 ISSUED BY THE 5TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 885 APPENDIX OF WP(C) 11271/2022 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF THE GAZETTE OF INDIA EXTRAORDINARY DATED 27.3.2020 Exhibit P2 THE TRUE COPY OF THE ORDER IN W.P.(C.) NO 4442 OF 2022 OF THIS HON'BLE COURT DATED 10.02.2022 Exhibit P3 THE TRUE COPY OF THE NOTICE UNDER SECTION 194A ISSUED BY THE 7TH RESPONDENT TO THE 1ST PETITIONER DATED 24.3.2022 Exhibit P4 THE TRUE COPY OF THE NOTICE UNDER SECTION 194A ISSUED BY THE 7TH RESPONDENT TO THE 2ND PETITIONER DATED 24.3.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 886 APPENDIX OF WP(C) 11272/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF NOTICE ISSUED BY THE 3RD RESPONDENT. Exhibit P2 COPY OF ORDER IN WP(C) NO.1633/2022 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 887 APPENDIX OF WP(C) 11273/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE LETTER ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER DATED 25-3- 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 888 APPENDIX OF WP(C) 11286/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 24/3/2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 889 APPENDIX OF WP(C) 11301/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF LETTER DATED 25.03.2022 ISSUED BY THE 2ND RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF LETTER DATED 25.03.2022 ISSUED BY THE RESPONDENT TO THE PETITIONER. Exhibit P3 TRUE COPY OF LETTER DATED 28.03.2022 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER. Exhibit P4 TRUE COPY OF LETTER DATED 28.03.2022 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 890 APPENDIX OF WP(C) 11309/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE 5TH PETITIONER. Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE 6TH PETITIONER. Exhibit P7 TRUE COPY OF THE NOTICE DATED 26.03.2022 SERVED ON THE 7TH PETITIONER. Exhibit P8 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE 8TH PETITIONER. Exhibit P9 A TRUE PHOTOCOPY OF THE ORDER DATED 10.02.2022 IN WP(C) NO. 4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 891 APPENDIX OF WP(C) 11316/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMON NOTICE ISSUED BY THE DISTRICT CO-OPERATIVE BANKS TO ALL THE PETITIONERS CO-OPERATIVE SOCIETIES DATED 25/03/2022. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 02/11/2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23/12/2021 IN WRIT PETITION (C) NO.30686/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 892 APPENDIX OF WP(C) 11332/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.C NO. 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 893 APPENDIX OF WP(C) 11323/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE KALADY BRANCH MANAGER OF 4TH RESPONDENT DATED 18/11/2021 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY PALARIVATTOM BRANCH MANAGER OF THE 4TH RESPONDENT TO THE 1ST PETITIONER DATED 17/12/2021. Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31/05/2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P4 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/05/2017 ISSUED BY CBDT. 2025:KER W.P(C)No.7053/2023 & Connected cases 894 APPENDIX OF WP(C) 11325/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE MANAGER IN CHARGE OF 4TH RESPONDENT DATED 25.03.2022 TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 895 APPENDIX OF WP(C) 11326/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE CHERTHALA BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE CHERTHALA BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE 6TH PETITIONER. Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31.05.2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P4 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29.05.2017 ISSUED BY CBDT. 2025:KER W.P(C)No.7053/2023 & Connected cases 896 APPENDIX OF WP(C) 11327/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT Exhibit P4 TRUE COPY OF THE CIRCULAR NO 18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES Exhibit P5 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 897 APPENDIX OF WP(C) 11335/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER 25/03/.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER. Exhibit P3 TRUE COPY OF THE COMMUNICATION DATED 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 4TH PETITIONER. Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 5TH PETITIONER. Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 6TH PETITIONER. Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 7TH PETITIONER. Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 8TH PETITIONER. Exhibit P8 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 9TH PETITIONER. Exhibit P9 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 10TH PETITIONER. Exhibit P10 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 11TH PETITIONER. Exhibit P11 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 12TH PETITIONER. Exhibit P12 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 13TH PETITIONER. Exhibit P13 TRUE COPY OF THE COMMUNICATION LETTER 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 14TH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 898 Exhibit P14 TRUE COPY OF THE COMMUNICATION LETTER 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 15TH PETITIONER. Exhibit P15 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 16TH PETITIONER. Exhibit P16 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 17TH PETITIONER. Exhibit P17 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 18TH PETITIONER. Exhibit P18 TRUE COPY OF THE COMMUNICATION LETTER 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 19TH PETITIONER. Exhibit P19 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 20TH PETITIONER. Exhibit P20 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 21ST PETITIONER. Exhibit P21 TRUE COPY OF THE COMMUNICATION LETTER 24/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 22ND PETITIONER. Exhibit P22 TRUE COPY OF THE COMMUNICATION LETTER 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE 23RD PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 899 APPENDIX OF WP(C) 11342/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE CIRCULAR DATED 21.3.2022 ISSUED BY THE 7TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 900 APPENDIX OF WP(C) 11355/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE CIRCULAR DATED 21.03.2022 ISSUED BY THE 7TH RESPONDENT. Exhibit P2 COPY OF THE LETTER DATED 25.03.2022 SUBMITTED BY THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 901 APPENDIX OF WP(C) 11366/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit P4 TRUE COPY OF THE NOTICEDATED 24/3/2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit P5 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P6 TRUE COPY OF THE ORDER DATED 10/02/2022 IN W.P.(C).NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 902 APPENDIX OF WP(C) 11371/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT Exhibit P6 TRUE COPY OF THE CIRCULAR NO.18/20217 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES Exhibit P7 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 903 APPENDIX OF WP(C) 11373/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 020 DATED 27.3.2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 904 APPENDIX OF WP(C) 11381/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE CIRCULAR DATED 21.03.2022 ISSUED BY THE 7TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 905 APPENDIX OF WP(C) 11407/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.03.2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit P4 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/05/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P5 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 906 APPENDIX OF WP(C) 11415/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.03.2020. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE 1ST PETITIONER DATED 30.03.2022. Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE 2ND PETITIONER DATED 30.03.2022. Exhibit P4 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE 3RD PETITIONER DATED 30.03.2022. Exhibit P5 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE 4TH PETITIONER DATED 30.03.2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 907 APPENDIX OF WP(C) 11420/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.03.2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.05.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 908 APPENDIX OF WP(C) 11441/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit P5 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P6 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 909 APPENDIX OF WP(C) 11440/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE LETTER ISSUED BY R4 TO RAMAPURAM BRANCH MANAGER DATED 24.3.22. Exhibit P4 A TRUE PHOTOCOPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 910 APPENDIX OF WP(C) 11450/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 911 APPENDIX OF WP(C) 11446/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED NIL. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE PETITIONER DATED 30.3.2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 912 APPENDIX OF WP(C) 11445/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT. Exhibit P6 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 5TH PETITIONER BY THE 4TH RESPONDENT. Exhibit P7 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT. Exhibit P8 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P9 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 913 APPENDIX OF WP(C) 11458/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF THE FINANCE ACT 2020 Exhibit P2 TRUE COPY OF THE ORDER DATED 10-02-2022 IN W.P9C) NO. 4442/2022 Exhibit P3 TRUE COPY OF THE NOTICE DATED 25-03-2022 OF THE 7TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 914 APPENDIX OF WP(C) 11467/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE 1ST PETITIONER ASSOCIATION. Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. Exhibit P5 TRUE COPY OF CIRCULAR NO.,GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 915 APPENDIX OF WP(C) 11478/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DTED 27.03.2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.05.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE HON'BLE HIGH COURT ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 916 APPENDIX OF WP(C) 11480/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.03.2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit P5 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.05.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES/. Exhibit P6 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 917 APPENDIX OF WP(C) 11489/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DTD 27.03.2020 ISSUED BY 1ST RESPONDENT Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF ORDER DTD 10.02.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 918 APPENDIX OF WP(C) 11487/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT Exhibit P4 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT Exhibit P5 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT Exhibit P6 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P7 TRUE COPY OF THE ORDER DATED 01.02.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 919 APPENDIX OF WP(C) 11507/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE 1ST PETITIONER ASSOCIATION. Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. Exhibit P5 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 920 APPENDIX OF WP(C) 11530/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10/02/2022 IN WP(C) NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 921 APPENDIX OF WP(C) 11544/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DTD. 27.03.2022 ISSUED BY 1ST RESPONDENT. Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF ORDER DTD. 10.02.2022 IN WP(C)NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 922 APPENDIX OF WP(C) 11555/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 923 APPENDIX OF WP(C) 11558/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 924 APPENDIX OF WP(C) 11570/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE 1ST PETITIONER ASSOCIATION. Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FIANANCE ACT, 2020. Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT. 1961 Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP (C) NO. 4442 OF 2022. Exhibit P5 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 5TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 925 APPENDIX OF WP(C) 11591/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 926 APPENDIX OF WP(C) 11601/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 26/3/2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO. 4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 927 APPENDIX OF WP(C) 11599/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT Exhibit P3 TRUE COPY OF THE CIRCULAR NO 18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 928 APPENDIX OF WP(C) 11600/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 24/3/2020 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE CIRCULAR NO. 18/2017, DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO. 4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 929 APPENDIX OF WP(C) 11604/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED FORM PUTHUKKAD BRANCH OF THE 6TH RESPONDENT BANK TO THE PETITIONER Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019 IN WPC NO 11176 OF 2019 OF THIS HON'BLE COURT Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961 AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED 10.2.2022 IN WPC NO 4385 OF 2022 PASSED BY THIS HON'BLE COURT 2025:KER W.P(C)No.7053/2023 & Connected cases 930 APPENDIX OF WP(C) 11607/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DATED 27.3.2020 ISSUED BY 1ST RESPONDENT Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT 1961 Exhibit P3 TRUE COPY OF ORDER DATED 10.2.2022 IN WPC NO 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 931 APPENDIX OF WP(C) 11605/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT Exhibit P3 TRUE COPY OF THE CIRCULAR NO 18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 932 APPENDIX OF WP(C) 11609/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 23.03.2022 ISSUED BY 7TH RESPONDENT PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 933 APPENDIX OF WP(C) 10302/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020. Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 934 APPENDIX OF WP(C) 11616/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE PHOTO COPY OF THE LETTER DATED 25.3.2022 ISSUED BY THE BRANCH MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., PERUMBAVOOR. Exhibit P2 A TRUE PHOTO COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 935 APPENDIX OF WP(C) 11619/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 936 APPENDIX OF WP(C) 11620/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE PHOTO COPY OF THE LETTER DATED 30.3.2022 ISSUED BY THE BRANCH MANAGER, KERALA STATE CO-OPERATIVE BANK LTD., PERUMBAVOOR. Exhibit P2 A TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 937 APPENDIX OF WP(C) 11621/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 938 APPENDIX OF WP(C) 11627/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF NOTICE DATED 25.3.2022 BY 5TH RESPONDENT AS REGARD DEDUCTION OF TDS FROM INTEREST PAYABLE TO PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 939 APPENDIX OF WP(C) 11646/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 940 APPENDIX OF WP(C) 11649/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 5TH PETITIONER. Exhibit P6 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 6TH PETITIONER. Exhibit P7 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 7TH PETITIONER. Exhibit P8 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 8TH PETITIONER. Exhibit P9 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 9TH PETITIONER. Exhibit P10 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 10TH PETITIONER. Exhibit P11 TRUE COPY OF THE NOTICE DATED 26/03/2022 SERVED ON THE 11TH PETITIONER. Exhibit P12 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 12TH PETITIONER. Exhibit P13 13TH COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 13TH PETITIONER. Exhibit P14 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 14TH PETITIONER. Exhibit P15 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 15TH PETITIONER. Exhibit P16 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 16TH PETITIONER. Exhibit P17 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 17TH PETITIONER. Exhibit P18 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 18TH PETITIONER. Exhibit P19 TRUE COPY OF THE NOTICE DATED 25/03/2022 2025:KER W.P(C)No.7053/2023 & Connected cases 941 SERVED ON THE 19TH PETITIONER. Exhibit P20 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 20TH PETITIONER. Exhibit P21 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 21ST PETITIONER. Exhibit P22 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 22ND PETITIONER. Exhibit P23 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 23RD PETITIONER. Exhibit P24 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 24TH PETITIONER. Exhibit P25 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 25TH PETITIONER. Exhibit P26 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 26TH PETITIONER. Exhibit P27 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 27TH PETITIONER. Exhibit P28 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 28TH PETITIONER. Exhibit P29 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 29TH PETITIONER. Exhibit P30 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 30TH PETITIONER. Exhibit P31 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 31TH PETITIONER. Exhibit P32 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 32ND PETITIONER. Exhibit P33 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 33RD PETITIONER. Exhibit P34 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 34TH PETITIONER. Exhibit P35 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 35TH PETITIONER. Exhibit P36 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 36TH PETITIONER. Exhibit P37 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 37TH PETITIONER. Exhibit P38 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 38TH PETITIONER. Exhibit P39 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 39TH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 942 Exhibit P40 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 40TH PETITIONER. Exhibit P41 TRUE COPY OF THE NOTICE DATED 30/03/2022 SERVED ON THE 41ST PETITIONER. Exhibit P42 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 42ND PETITIONER. Exhibit P43 TRUE COPY OF THE NOTICE DATED 25/03/2022 SERVED ON THE 43RD PETITIONER. Exhibit P44 A TRUE PHOTOCOPY OF THE ORDER DATED 10/02/2022 IN WP(C) NO.442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 943 APPENDIX OF WP(C) 11654/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE FEROKE BRANCH MANAGER OF 4THR RESPONDENT DATED 26.03.2022 TO THE PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 944 APPENDIX OF WP(C) 11683/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE G.O.(MS).NO. 324/2016/FIN DATED 15.08.2016 ISSUED BY THE 6TH RESPONDENT. Exhibit P4 TRUE COPY OF THE G.O.(RT) NO. 6818/2016/ FIN DATED 18.08.2016 ISSUED BY THE 6TH RESPONDENT. Exhibit P5 TRUE COPY OF THE CIRCULAR, NO.GBT/14/2021- 22 DATED 21.03.2022 ISSUED BY THE 5TH RESPONDENT, TO ITS REGIONAL MANAGERS. Exhibit P6 TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P7 TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P8 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C) .NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 945 APPENDIX OF WP(C) 11679/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE GO(MS) NO 324/2016/FIN DATED 15.8.2016 ISSUED BY THE 6TH RESPONDENT Exhibit P4 TRUE COPY OF THE GO(RT) NO 6818/2016/FIN DATED 18.8.2016 ISSUED BY THE 6TH RESPONDENT Exhibit P5 TRUE COPY OF THE CIRCULAR NO GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 5TH RESPONDENT TO ITS REGIONAL MANAGERS Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 10.2.022 IN WPC NO 442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 946 APPENDIX OF WP(C) 11684/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE G.O.(MS). NO.324/2016/FIN DATED 15.08.2016 ISSUED BY THE 6TH RESPONDENT. Exhibit P4 TRUE COPY OF THE G.O.(RT) NO. 6818/2016/FIN DATED 18.08.2016 ISSUED BY THE 6TH RESPONDENT. Exhibit P5 TRUE COPY OF THE CIRCULAR NO. GBT/14/2021- 22 DATED 21.03.2022 ISSUED BY THE 5TH RESPONDENT, TO ITS REGIONAL MANAGERS. Exhibit P6 TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P7 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN W.P.(C) NO. 4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 947 APPENDIX OF WP(C) 11718/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF NOTICE ISSUED BY THE 3RD RESPONDENT. Exhibit P2 COPY OF ORDER IN .P.(C) NO.1633/2022 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 948 APPENDIX OF WP(C) 11721/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (NO.2) ACT, 2019. Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (NO.2) BILL DATE 05.07.2019. Exhibit P3 A TRUE COPY OF THE REPRESENTATION SUBMITTED BY THE MINISTER FOR CO-OPERATION TO THE FINANCE MINISTER, GOVERNMENT OF INDIA. Exhibit P4 A TRUE COPY OF THE LETTER DO NO.370149/212/2019-T[L DATED 02.01.2020 OF THE MINISTER OF STATE FOR FINANCE AND CORPORATE AFFAIRS, GOVERNMENT OF INDIA. Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED 23.03.2020 IN WPC NO.9237 OF 2020 OF THIS HON'BLE COURT. Exhibit P6 A TRUE COPY OF THE INTERIM ORDER DATED 29.03.2020 IN WPC NO.10988 OF 2022 OF THIS HON'BLE COURT. Exhibit P7 A TRUE COPY OF THE NOTICE DATED 23.03.2022 ISSUED BY THE ANCHALUMOOD EVENING BRANCH OF THE 6TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 949 APPENDIX OF WP(C) 11728/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF NOTICE DATED 30.03.2022 ISSUED UNDER SECTION 194 A (3) (V0 OR THE INCOME TAX ACT, FROM CHIRAYINKEEZHU BRANCH OF THE 6TH RESPONDENT TO PETITIONER. Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WPC NO.11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 A TRUE COPY OF EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 30.03.2022 IN WPC NO.11035 OF 2022 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 950 APPENDIX OF WP(C) 11727/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020 Exhibit P2 TRUE COPY OF THE NOTICE DATED 26.3.2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT Exhibit P3 TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29.5.2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 951 APPENDIX OF WP(C) 11740/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DTD 27-03-2020 ISSUED BY 1ST RESPONDENT. Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF ORDER DTD 10-02-2022 IN W.P(C) NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 952 APPENDIX OF WP(C) 11738/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED NIL. Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE 1ST PETITIONER DATED 25/03/2022. Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE 1ST PETITIONER DATED 25/03/2022. Exhibit P4 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE 2ND PETITIONER DATED 25/03/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 953 APPENDIX OF WP(C) 11765/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 954 APPENDIX OF WP(C) 11760/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT. 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WP(C) NO. 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 955 APPENDIX OF WP(C) 11766/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 956 APPENDIX OF WP(C) 11768/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER 30.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER 30.3.2022 ISSUED BY THE 4TH RESPONDENT TO THE 6TH PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 957 APPENDIX OF WP(C) 11772/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF NOTICE DATED 25.3.2022 ISSUED UNDER SECTION 194 A(3) (V) OF THE INCOME TAX ACT, FROM PETTAH BRANCH OF THE 6TH RESPONDENT TO PETITIONER Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WPC NO 11176 OF 2019 OF THIS HON'BLE COURT Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961 AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 30.3.2022 IN WPC NO 11035 OF 2022 OF THIS HON'BLE COURT 2025:KER W.P(C)No.7053/2023 & Connected cases 958 APPENDIX OF WP(C) 11776/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED UNDER SECTION 194 A(3) (V) OF THE INCOME TAX ACT FROM THE POTHENCODE BRANCH OF THE 6TH RESPONDENT TO PETITIONER. Exhibit P2 A TRUE COPY OF THE JUDGMENT 18.10.2019 IN W.P.C NO. 11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C) NO. 4385 OF 2022 OF THIS HON'BLE COURT. Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED 23.04.2020 IN W.P TMP NO. 107 OF 2020 (PRESENTLY WP(C) NO. 10659 OF 2020) OF THIS HON'BLE COURT. Exhibit P6 A TRUE COPY OF THE NOTICE DATED 23.03.2022 ISSUED BY 6TH RESPONDENT TO KIZHUVILAM SERVICE CO-OPERATIVE BANK, UNDER SECTION 194 N OF THE INCOME TAX ACT. Exhibit P7 A TRUE COPY OF THE INTERIM ORDER DATED 29.03.2022 IN W.P.C NO. 10988 OF 2022 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 959 APPENDIX OF WP(C) 11780/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE REGISTRATION CERTIFICATE OF THE PETITIONER DATED 22/07/1978. Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED NIL. Exhibit P3 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE PETITIONER DATED 25/3/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 960 APPENDIX OF WP(C) 11781/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WP(C) NO. 4442 OF 2022. Exhibit P4 TRUE COPY OF THE CIRCULAR NO. GBT/14/2021- 22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 961 APPENDIX OF WP(C) 11783/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 25/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 962 APPENDIX OF WP(C) 11915/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 963 APPENDIX OF WP(C) 11784/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF NOTICE DATED 30.03.2022 ISSUED UNDER SECTION 194 A (3)(V) OF THE INCOME TAX ACT, FROM PETTAH BRANCH OF THE 6TH RESPONDENT TO PETITIONER. Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WP(C) NO. 11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 A TRUE COPY OF EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 30.03.2022 IN WP(C) NO. 11035 OF 2022 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 964 APPENDIX OF WP(C) 11791/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED 31.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER DATED 31.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER DATED 31.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER DATED 31.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 4TH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 965 APPENDIX OF WP(C) 11792/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE FIRST PETITIONER DATED 25.03.2022. Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED TO THE SECOND PETITIONER DATED 25.03.2022. Exhibit P1 B TRUE COPY OF THE NOTICE ISSUED TO THE THIRD PETITIONER DATED 25.03.2022. Exhibit P1 C TRUE COPY OF THE NOTICE ISSUED TO THE FOURTH PETITIONER DATED 25.03.2022. Exhibit P1 D TRUE COPY OF THE NOTICE ISSUED TO THE FIFTH PETITIONER DATED 25.03.2022. Exhibit P1 E TRUE COPY OF THE NOTICE ISSUED TO THE SIXTH PETITIONER DATED 25.03.2022. Exhibit P1 F TRUE COPY OF THE NOTICE ISSUED TO THE SEVENTH PETITIONER DATED 25.03.2022. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 02.11.2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED 23.12.2021 IN WIT PETITION(C) NO.30686/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 966 APPENDIX OF WP(C) 11810/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE ISSUED BY TO THE FIRST PETITIONER DATED 24.03.2022. Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY TO THE SECOND PETITIONER DATED 25.03.2022. Exhibit P1 B TRUE COPY OF THE NOTICE ISSUED BY TO THE THIRD PETITIONER DATED 26.03.2022. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 02.11.2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED 23.12.2021 IN WRIT PETITION (C) NO.30686/2021. Exhibit P1 C TRUE COPY OF THE NOTICE ISSUED BY THE FOURTH PETITIONER DATED 30.03.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 967 APPENDIX OF WP(C) 11848/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24/03/2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 968 APPENDIX OF WP(C) 11851/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER Exhibit P2 TRUE COPY OF THE COMMUNICATION 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER Exhibit P3 TRUE COPY OF THE COMMUNICATION 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER Exhibit P4 TRUE COPY OF THE COMMUNICATION 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 4TH PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 969 APPENDIX OF WP(C) 11870/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER Exhibit P2 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER Exhibit P3 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER Exhibit P4 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 4TH PETITIONER Exhibit P5 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 5TH PETITIONER Exhibit P6 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 6TH PETITIONER Exhibit P7 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 7TH PETITIONER Exhibit P8 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 8TH PETITIONER Exhibit P9 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 9TH PETITIONER Exhibit P10 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 10TH PETITIONER Exhibit P11 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 11TH PETITIONER Exhibit P12 TRUE COPY OF THE COMMUNICATION LETTER DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 12TH PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 970 APPENDIX OF WP(C) 11887/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE KOOTHATTUKULAM BRANCH MANAGER OF 4TH RESPONDENT DATED 26/3/2022 TO THE 1TH PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31/5/2013 ISSUED BY THE CHIF GENERAL MANAGER OF RBI TO AL SCHEDULED COMMERCIAL BANKS. Exhibit P3 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY CBDT. 2025:KER W.P(C)No.7053/2023 & Connected cases 971 APPENDIX OF WP(C) 11884/2022 PETITIONER EXHIBITS Exhibit1 EXHIBIT P1: TRUE COPY OF THE RELEVANT PAGES OF THE GAZETTE OF INDIA EXTRAORDINARY DATED 27.3.2020 Exhibit2 EXHIBIT P2: TRUE COPY OF THE ORDER IN W.P. (C) NO 4442 OF 2022 OF THIS HON'BLE COURT DATED 10.02.2022 Exhibit3 EXHIBIT P3: TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED TO THE PETITIONER BY THE 7TH RESPONDENT UNDER SECTION 194A 2025:KER W.P(C)No.7053/2023 & Connected cases 972 APPENDIX OF WP(C) 11939/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX AC, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 973 APPENDIX OF WP(C) 12054/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE DATED 26TH MAKARAM 1090(1914) ISSUED TO THE PETITIONER SOCIETY. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/03/2022 NUMBERED AS KSCB/GBT/194N/2021-22 WITH REGARD TO SECTION 194N OF THE INCOME TAX ACT, 1961 ISSUED BY 4TH RESPONDENT THROUGH BRANCH MANAGER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25/03/2022 ISSUED THROUGH THE BRANCH MANAGER, MAIN BRANCH, ERNAKULAM BY THE 4TH RESPONDENT WITH RESPECT TO SECTION 194A (3) (V) OF INCOME TAX ACT, 1961. Exhibit P4 TRUE COPY OF THE COMMUNICATION ISSUED BY THE PETITIONER BANK TO THE 4TH RESPONDENT DATED 31/03/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 974 APPENDIX OF WP(C) 12057/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER IN WP(C) 4442/2022 DATED 10/2/2022. Exhibit P4 TRUE COPY OF THE CIRCULAR NO.KSCB/GBT/194N/811(A) 2021-22 DATED 24/3/2022 ISSUED BY THE 6TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 975 APPENDIX OF WP(C) 12065/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER IN WPC 4442/2022 DATED 10.02.2022. Exhibit P4 TRUE COPY OF THE CIRCULAR NO.KSCB/GBT/194N/2021-22 DATED 25.03.2022 ISSUED BY THE 6TH RESPONDENT. Exhibit P5 TRUE COPY OF THE CIRCULAR NO.KSCB/GBT/194N/802/2021-22 DATED 24.03.2022 ISSUED BY THE 6TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 976 APPENDIX OF WP(C) 12061/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP (C) NO 4442 OF 2022 Exhibit P4 TRUE COPY OF NOTICE DATED 25-03-2022 ISSUED BY THE 5TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 977 APPENDIX OF WP(C) 12076/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM SREEKARYAM BRANCH OF THE 6TH RESPONDENT BANK TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019 IN WP(C) NO. 11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C) NO. 4385 OF 2022 PASSED BY THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 978 APPENDIX OF WP(C) 12075/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (NO.2) ACT, 2019. Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (NO.S) BILL DATED 05.07.2019. Exhibit P3 A TRUE COPY OF THE REPRESENTATION SUBMITTED BY THE MINISTER FOR CO-OPERATION TO THE FINANCE, GOVERNMENT OF INDIA. Exhibit P4 A TRUE COPY OF THE LETTER DO NO. 370149/212/2019-TPL DATED 02.01.2020 OF THE MINSTER OF STATE FOR FINANCE AND CORPORATE AFFAIRS, GOVERNMENT OF INDIA. Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED 23.03.2020 IN WP(C) NO. 9237 OF 2020 OF THIS HON'BLE COURT. Exhibit P6 A TRUE COPY OF THE INTERIM ORDER DATED 29.03.2022 IN WP(C) NO. 10988 OF 2022 OF THIS HON'BLE COURT. Exhibit P7 A TRUE COPY OF THE NOTICE DATED NIL ISSUED UNDER SECTION 194N OF THE INCOME TAX ACT, FROM THE ATTINGAL M & E BRANCH OF THE 6TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 979 APPENDIX OF WP(C) 12082/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (NO.2) ACT, 2019. Exhibit P2 A TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (NO.2) BILL DATED 05.07.2019. Exhibit P3 A TRUE COPY OF THE REPRESENTATION SUBMITTED BY THE MINISTER FOR CO-OPERATION TO THE FINANCE MINISTER, GOVERNMENT OF INDIA. Exhibit P4 A TRUE COPY OF THE LETTER DO NO. 370149/212/2019-TPL DATED 02.01.2020 OF THE MINISTER OF STATE FOR FINANCE AND CORPORATE AFFAIRS, GOVERNMENT OF INDIA. Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED 23.03.2020 IN W.P.C NO. 9237 OF 2020 OF THIS HON'BLE COURT. Exhibit P6 A TRUE COPY OF THE INTERIM ORDER DATED 29.03.2022 IN W.P.C NO. 10988 OF 2022 OF THIS HON'BLE COURT. Exhibit P7 A TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED UNDER SECTION 194 N OF THE INCOME TAX ACT, FROM THE ERNAKULAM EVENING BRANCH OF THE 6TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 980 APPENDIX OF WP(C) 12086/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DTD. 27.03.2020 ISSUED BY 1ST RESPONDENT. Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF ORDER DTD. 10.02.2022 IN WP(C) 4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 981 APPENDIX OF WP(C) 12100/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE PETITIONER ASSOCIATION Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACTS OF SECTION 194 A OF INCOME TAX ACT, 1961 Exhibit P4 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 Exhibit P5 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATE 21.03.2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 982 APPENDIX OF WP(C) 12102/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INFORMATION TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 983 APPENDIX OF WP(C) 12105/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 26/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 984 APPENDIX OF WP(C) 12110/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 985 APPENDIX OF WP(C) 12123/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 24.03.2022 SERVED ON THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 986 APPENDIX OF WP(C) 12124/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION 24.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 987 APPENDIX OF WP(C) 12126/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 5TH PETITIONER. Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 6TH PETITIONER. Exhibit P7 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 7TH PETITIONER. Exhibit P8 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 8TH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 988 APPENDIX OF WP(C) 12145/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE FIRST PETITIONER DATED 25.03.2022 Exhibit P1A TRUE COPY OF THE NOTICE ISSUED TO THE SECOND PETITIONER DATED 25.03.2022 Exhibit P1B TRUE COPY OF THE NOTICE ISSUED TO THE THIRD PETITIONER DATED 25.03.2022 Exhibit P1C TRUE COPY OF THE NOTICE ISSUED TO THE FOURTH PETITIONER DATED 25.03.2022 Exhibit P1D TRUE COPY OF THE NOTICE ISSUED TO THE FIFTH PETITIONER DATED 25.03.2022 Exhibit P1E TRUE COPY OF THE NOTICE ISSUED TO THE SIXTH PETITIONER DATED 25.03.2022 Exhibit P1F TRUE COPY OF THE NOTICE ISSUED TO THE SEVENTH PETITIONER DATED 25.03.2022 Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 02.11.2015 Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED 23.12.2021 IN WRIT PETITION C NO.30686/2021 2025:KER W.P(C)No.7053/2023 & Connected cases 989 APPENDIX OF WP(C) 12257/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE THIRUVANANTHAPURAM FORT MAIN BRANCH MANAGER OF 4TH RESPONDENT DATED 24.03.2022 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE VANCHIYOOR BRANCH MANAGER, OF 4TH RESPONDENT DATED 25.03.2022 TO THE 2ND PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 990 APPENDIX OF WP(C) 12263/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF NOTICE DATED 23.3.2022 ISSUED FROM ALUVA (MAIN)BRANCH OF THE 6TH RESPONDENT TO PETITIONER Exhibit P2 A TRUE COPY OF JUDGMENT 18.10.2019 IN WPC NO 11176 OF 2019 OF THIS HON'LE COURT Exhibit P3 A TRUE COPY OF THE INTERIM ORDER DATED 10.2.2022 IN WPC NO 4385 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 991 APPENDIX OF WP(C) 12351/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5 RESPONDENT TO THE IST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5 RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 992 APPENDIX OF WP(C) 12428/2022 PETITIONER COURT EXHIBITS EXHIBIT P3 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 6TH RESPONDENT TO PETITIONER. Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE DATED 18.09.2002 ISSUED BY THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 993 APPENDIX OF WP(C) 14068/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE COMMUNICATION 25-03-2022 ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER Exhibit P2 TRUE COPY OF THE COMMUNICATION 25-03-2022 ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 994 APPENDIX OF WP(C) 12504/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE LETTER DATED 24/03/2022 ISSUED BY THE PALA BRANCH MANAGER OF THE 4TH RESPONDENT BANK. Exhibit P4 A TRUE COPY OF THE ORDER DATED 10/02/2022 IN WP(C) NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 995 APPENDIX OF WP(C) 12545/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE DATED 07/06/2005 ISSUED BY THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25/03/2022 ISSUED BY THE 5TH RESPONDENT TO PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 996 APPENDIX OF WP(C) 12635/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 997 APPENDIX OF WP(C) 12754/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF NOTICE DATED 25/03/2022 ISSUED UNDER SECTION 194 A(3)(V) OF THE INCOME TAX ACT, FROM SREEKARIYAM BRANCH OF THE 6TH RESPONDENT TO PETITITIONER. Exhibit P2 A TRUE COPY OF JUDGMENT 18/10/2019 IN WP(C) NO.11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 01/04/2022 IN WP(C) NO.11784 OF 2022 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 998 APPENDIX OF WP(C) 12713/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE PARASALA BRANCH MANAGER OF 4TH RESPONDENT DATED 31.3.2022 TO THE 1ST PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 999 APPENDIX OF WP(C) 12744/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (2)ACT, 2019 Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE ACT, 2020. 2025:KER W.P(C)No.7053/2023 & Connected cases 1000 APPENDIX OF WP(C) 12753/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1001 APPENDIX OF WP(C) 12759/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1002 APPENDIX OF WP(C) 13011/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE LIST OF MEMBERS OF THE PETITIONER ASSOCIATION. Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P4 TRUE COPY OF THE ORDER DATED 10/02/2022 IN WPC NO.4442/2022. Exhibit P5 TRUE COPY OF THE CIRCULAR NO. GBT/14/2021- 22 DATED 21/03/2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1003 APPENDIX OF WP(C) 13047/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP (C) NO 4442 OF 2022 Exhibit P4 TRUE COPY OF NOTICE DATED 25-03-2022 ISSUED BY THE 5TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1004 APPENDIX OF WP(C) 13114/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE GO(MS) NO.324/2016/FIN DATED 15/08/2016 ISSUED BY THE 6TH RESPONDENT. Exhibit P4 TRUE COPY OF THE GO(RT) NO.6818/2016/FIN. DATED 18/08/2016 ISSUED BY THE 6TH RESPONDENT. Exhibit P5 TRUE COPY OF THE NOTICE DATED 25/03/2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER IN RESPECT OF SECTION 194 A(3) (V). Exhibit P6 TRUE COPY OF THE NOTICE DATED 25/03/2022 ISSUED BY THE 5TH RESPONDENT TO THE 2ND PETITIONER IN RESPECT OF SECTION 194 A(3) (V). Exhibit P7 TRUE COPY OF THE NOTICE DATED 25/03/2022 ISSUED BY THE 5TH RESPONDENT TO THE 3RD PETITIONER IN RESPECT OF SECTION 194 A(3) (V). Exhibit P8 TRUE COPY OF THE NOTICE DATED 25/03/2022 ISSUED BY THE 5TH RESPONDENT TO THE 4TH PETITIONER IN RESPECT OF SECTION 194 A(3) (V). Exhibit P9 TRUE COPY OF THE INTERIM ORDER DATED 10/02/2022 IN WPC NO.4442/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1005 APPENDIX OF WP(C) 13112/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE CHALAKUDY BRANCH MANAGER OF 4TH RESPONDENT DATED 24-03-2022 TO THE 6TH PETITIONER. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE CHELAKKARA BRANCH MANAGER OF 4TH RESPONDENT DATED 24-03-2022 TO THE 40TH PETITIONER Exhibit P3 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31-05-2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P4 A TRUE COPY OF THE CIRCULAR NO 18/2017 DATED 29-05-2017 ISSUED BY CBDT 2025:KER W.P(C)No.7053/2023 & Connected cases 1006 APPENDIX OF WP(C) 13171/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1007 APPENDIX OF WP(C) 13184/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE THIRUVALLA BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE 1ST PETITIONER. Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE PATHANAMTHITTA DEPUTY GENERAL MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE 2ND PETITIONER. Exhibit P4 A TRUE COPY OF THE NOTICE ISSUED BY THE PATHANAMTHITTA DEPUTY BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE 3RD PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1008 APPENDIX OF WP(C) 13339/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE 4TH RESPONDENT DATED 03.03.2022 TO THE PETITIONER. Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31.05.2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS. Exhibit P3 A TRUE COPY OF THE CIRCULAR NO. 18/2017 DATED 29.05.2017 ISSUED BY CBDT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1009 APPENDIX OF WP(C) 13303/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE NO. KB/R5/2021-22 DATED 25.03.2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED 02.11.2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23.12.2021 IN WRIT PETITION (C) NO. 30686/2021 2025:KER W.P(C)No.7053/2023 & Connected cases 1010 APPENDIX OF WP(C) 13305/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE NO KB/R5/2021-22 DATED 25-03-2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED 02-11-2015 Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23-12-2021 IN WRIT PETITION (C) NO 30686/2021 2025:KER W.P(C)No.7053/2023 & Connected cases 1011 APPENDIX OF WP(C) 13318/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR NO.GBT/13/2021- 22 DATED 21.03.2022 ISSUED BY THE 3RD RESPONDENT TO THE PETITIONER. Exhibit P2 A TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED BY THE VENMONY BRANCH MANAGER OF THE 3RD RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1012 APPENDIX OF WP(C) 13358/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE THIRUVANANTHAPURAM PETTA BRANCH MANAGER OF 4TH RESPONDENT DATED 31/03/2022 TO THE 1ST PETITIONER. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE KARAMANA BRANCH MANAGER OF 4TH RESPONDENT DATED 31/03/2022 TO THE 2ND PETITIONER. Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE PALAKKAD MAIN BRANCH MANAGER OF 4TH RESPONDENT DATED 25/03/2022 TO THE 2ND PETITIONER. Exhibit P4 A TRUE COPY OF THE NOTICE ISSUED BY THE THEVARA BRANCH MANAGER OF 4TH RESPONDENT DATED 25/03/2022 TO THE 2ND PETITIONER. Exhibit P5 A TRUE COPY OF THE NOTICE ISSUED BY THE GENERAL MANAGER OF 4TH RESPONDENT DATED 21/03/2022 TO THE PETITIONERS. Exhibit P6 A TRUE COPY OF THE LETTER NO.RBI/2012- 13/516 DATED 31/05/2013 ISSUED BY RBI CHIEF GENERAL MANAGER. Exhibit P7 A TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/05/2017 ISSUED BY CBDT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1013 APPENDIX OF WP(C) 13364/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 3RD PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 4TH PETITIONER. Exhibit P5 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 5TH PETITIONER. Exhibit P6 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 6TH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1014 APPENDIX OF WP(C) 13410/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE MUVATTUPUZHA BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE PETITIONER. Exhibit P2 A TRUE COPY OF THE CIRCULAR ISSUED BY THE GENERAL MANAGER OF 4TH RESPONDENT DATED 21.03.2022 TO THE PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 1015 APPENDIX OF WP(C) 13439/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE FIRST PETITIONER DATED 25/03/2022. Exhibit P1(A) TRUE COPY OF THE NOTICE ISSUED TO THE SECOND PETITIONER DATED 25/03/2022. Exhibit P1(B) TRUE COPY OF THE NOTICE ISSUED TO THE THIRD PETITIONER DATED 25/03/2022. Exhibit P1(C) TRUE COPY OF THE NOTICE ISSUED TO THE FOURTH PETITIONER DATED 25/03/2022. Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED 02/11/2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER DATED 23/12/2021 IN WPC NO.30686/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 1016 APPENDIX OF WP(C) 13492/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1017 APPENDIX OF WP(C) 13545/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 1904A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1018 APPENDIX OF WP(C) 13615/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN WP(C) NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1019 APPENDIX OF WP(C) 13687/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE ISSUED BY THE BRANCH MANAGER , KERALA STATE COOPERATIVE BANK LTD TO THE PETITIONER DATED 24.03.2022 Exhibit P2 TRUE COPY OF THE NOTICE NO.ITBA/COM/F/17/2021-22/1040408269(1) DATED 07.03.2022 ISSUED BY 3RD RESPONDENT TO THE DISTRICT COOPERATIVE BANK THRISSUR Exhibit P3 TRUE COPY OF THE DEMAND NOTICE ISSUED TO THE PETITIONER BY 3RD RESPONDENT DATED 16.03.2022 Exhibit P4 TRUE COPY OF THE NOTICE FORM 4TH RESPONDENT DATED 24.03.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1020 APPENDIX OF WP(C) 13693/2022 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE NOTICE SERVED ON THE PETITIONER UNDER SECTION 194 N OF THE INCOME TAX ACT, 1961 DATED 26.3.2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1021 APPENDIX OF WP(C) 13707/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE CERTIFICATE OF REGISTRATION IN FORM 3 DATED 27.11.2003 Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 5TH RESPONDENT, TO ITS REGIONAL MANAGERS. Exhibit P3 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN W.P.(C)NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1022 APPENDIX OF WP(C) 13720/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE CERTIFICATE OF REGISTRATION IN FORM 3 DATED 03/02/2018. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 5TH RESPONDENT, TO ITS REGIONAL MANAGERS. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24/03/2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 22/03/2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED 10/02/202 IN WP(C) NO.4442 OF 2012. 2025:KER W.P(C)No.7053/2023 & Connected cases 1023 APPENDIX OF WP(C) 13741/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1024 APPENDIX OF WP(C) 13746/2022 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT 2020. Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT 1961. Exhibit P3 THE TRUE COPY OF THE ORDER DATED 10/02/2022 IN WPC NO. 4442 OF 2022. Exhibit P4 THE TRUE COPY OF CIRCULAR NO. GBT/14/2021- 22 DATED 21/03/2022 ISSUED BY THE 6TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1025 APPENDIX OF WP(C) 13751/2022 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT 2020. Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961. Exhibit P3 THE TRUE COPY OF THE ORDER DATED 10/02/2022 IN WPC NO.4442/2022. Exhibit P4 THE TRUE COPY OF THE CIRCULAR NO. GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 6TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1026 APPENDIX OF WP(C) 13760/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT. 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WP(C) NO. 4442 OF 2022, Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1027 APPENDIX OF WP(C) 13761/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/2/2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1028 APPENDIX OF WP(C) 13781/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE 1ST PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 1029 APPENDIX OF WP(C) 13797/2022 PETITIONER EXHIBITS Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OD INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN W.P(C) NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1030 APPENDIX OF WP(C) 13833/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM VANCHIYOOR BRANCH OF THE 6TH RESPONDENT BANK TO THE KAITHAMUKKU BRANCH OF THE PETITIONER Exhibit P1A TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED FROM PETTAH BRANCH OF THE 6TH RESPONDENT BANK TO THE KAITHAMUKKU BRANCH OF THE PETITIONER SOCIETY Exhibit P1B TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED FROM THIRUMALA BRANCH OF THE 6TH RESPONDENT BANK TO THE THIRUMALA BRANCH OF THE PETITIONER SOCIETY Exhibit P1C TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED FROM VATTIYOORKAVU BRANCH OF THE 6TH RESPONDENT BANK TO THE VATTIYOORKAVU BRANCH OF THE PETITIONER SOCIETY Exhibit P2 TRUE COPY OF THE JUDGMENT DATED 18.10.2019 IN WPC NO. 11176 OF 2019 OF THIS HON'BLE COURT Exhibit P3 TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED 10.02.022 IN WPC NO.4385 OF 2022 PASSED BY THIS HON'BLE COURT 2025:KER W.P(C)No.7053/2023 & Connected cases 1031 APPENDIX OF WP(C) 13891/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE BYELAW OF THE MANAK WELFARE CO-OPERATIVE SOCIETY LTD.NO. 1262. Exhibit P2 TRUE COPY OF THE RELEVANT PORTION OF FINANCE ACT,2020. Exhibit P3 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF THE INCOME TAX ACT 1961. Exhibit P4 TRUE COPY OF THE ORDER DATED 10/2/2022 IN W.P(C)NO.4442/2022 BEFORE THE HON'BLE HIGH COURT OF KERALA, ERNAKULAM Exhibit P5 TRUE COPY OF THE PROCEEDING DATED 24/3/2022, NO.KSCB/GBT/194N/142/2021-2022 ISSUED BY THE 6TH RESPONDENT. Exhibit P6 TRUE COPY OF THE PROCEEDING DATED 24/3/2022, N0.143/2021-2022 ISSUED BY THE 6TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1032 APPENDIX OF WP(C) 13895/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 Exhibit P4 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1033 APPENDIX OF WP(C) 13902/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.03.2022 SERVED ON THE PETITIONER Exhibit P2 TRUE COPY OF THE INTERIM ORDER OF STAY IN WP(C)NO.12123 OF 2022 DATED 04.04.2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1034 APPENDIX OF WP(C) 13903/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1035 APPENDIX OF WP(C) 13912/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 25.3.2022 SERVED ON THE PETITIONER. Exhibit P2 TRUE COPY OF THE INTERIM STAY ORDER IN WP(C) NO.12123 OF 2022 DATED 4.4.2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1036 APPENDIX OF WP(C) 13939/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF NOTICE DATED 25.03.2022 ISSUED FROM KUNNAMKULAM BRANCH OF THE 6TH RESPONDENT TO PETITIONER. Exhibit P2 A TRUE COPY OF JUDGMENT 18-10-2019 IN WP(C)NO.11176 OF 2019 OF THIS HON'BLE COURT. Exhibit P3 A TRUE COPY OF THE EXTRACT OF SECTION 194 A OF THE INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN WP(C)NO.4385 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1037 APPENDIX OF WP(C) 13940/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1038 APPENDIX OF WP(C) 13996/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO.4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT /14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1039 APPENDIX OF WP(C) 14006/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE CERTIFICATE OF REGISTRATION IN FORM 3 IN DATED 12.12.2013 Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/202122 DATED 21.03.2022 ISSUED BY THE 5TH RESPONDENT, TO ITS REGIONAL MANAGERS. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P4 TRUE THE NOTICE DATED 07.04.2022 ISSUED BY THE 5TH RESPONDENT Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN W.P.(C).NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1040 APPENDIX OF WP(C) 14010/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2022 Exhibit P2 A TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE PETITIONER DATED 25.03.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1041 APPENDIX OF WP(C) 14014/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE CERTIFICATE OF REGISTRATION IN FORM 3 IN DATED 22.9.2017. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22 DATED 21.3.2022 ISSUED BY THE 5TH RESPONDENT, TO ITS REGIONAL MANAGERS. Exhibit P3 TRUE COPY OF THE NOTICE DATED 24.3.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P4 A TRUE COPY OF THE NOTICE DATED 7.4.2022 ISSUED BY THE 5TH RESPONDENT. Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED 10.2.2022 IN WP(C) NO.4442 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1042 APPENDIX OF WP(C) 14017/2022 PETITIONER EXHIBITS Exhibit P1 & P1(A) TRUE COPY OF THE NOTICES NO.KB/R5/2021-22 DATED 25.3.2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 2.11.2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23.12.2021 IN WRIT PETITION (C) NO.30686/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 1043 APPENDIX OF WP(C) 14047/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE ATHANI BRANCH MANAGER OF 4TH RESPONDENT DATED 21.03.2022. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE ATHANI BRANCH MANAGER OF 4TH RESPONDENT DATED 30.03.2022 TO THE IST PETITIONER. Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE MUNDOOR BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE 2ND PETITIONER. Exhibit P4 A TRUE COPY OF THE NOTICE ISSUED BY THE THRISSUR WEST FORT BRANCH MANAGER OF 4TH RESPONDENT DATED 30.03.2022 TO THE 3RD PETITIONER. Exhibit P5 A TRUE COPY OF THE INTERIM ORDER DATED 07.04.2022 IN WPC NO. 13380 /2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1044 APPENDIX OF WP(C) 14061/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE DATED 30.04.1994 ISSUED BY THE JOINT REGISTRAR OF CO-OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM. Exhibit P2 TRUE COPY OF THE NOTICE DATED 24.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE DATED 28.03.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1045 APPENDIX OF WP(C) 14119/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE REGISTRATION CERTIFICATE DATED 09.05.2005 ISSUED BY THE JOINT REGISTRAR OF CO OPERATIVE SOCIETIES (GENERAL), THIRUVANANTHAPURAM. Exhibit P2 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY THE 5TH RESPONDENT TO PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1046 APPENDIX OF WP(C) 14122/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE GENERAL MANAGER OF 4TH RESPONDENT DATED 21.03.2022. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE IRINJALAKUDA BRANCH MANAGER OF 4TH RESPONDENT DATED 24.03.2022 TO THE 1ST PETITIONER. Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE KUNNAMKULAM BRANCH MANAGER OF 4TH RESPONDENT DATED 08.04.2022 TO THE 2ND PETITIONER. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 07. 04.2022 IN WPC NO.13380/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1047 APPENDIX OF WP(C) 14151/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE NO. KB/R5/2021-22 DATED 25.03.2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 02.11.2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23.12.2021 IN WRIT PETITIONER(C) NO. 30686/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 1048 APPENDIX OF WP(C) 14162/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER IN W.P(C0NO. 4442/2022 DATED 10-02-2022 Exhibit P4 TRUE COPY OF THE CIRCULAR NO KSCB/GBT/194N/2021-22 DATED 06-04-2022 ISSUED BY THE 5TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1049 APPENDIX OF WP(C) 14195/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-02-2022 IN WPC NO. 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1050 APPENDIX OF WP(C) 14341/2022 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 . Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 THE TRUE COPY OF THE ORDER DATED 10/02/2022 IN W.P.(C) NO. 4442 OF 2022. Exhibit P4 THE TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 6TH RESPONDENT. Exhibit P5 THE TRUE COPY OF LETTER NO.3762/21-22 DATED 25/02/2022 ISSUED BY THE 6TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P6 THE TRUE COPY OF LETTER NO. 3767/21-22 ISSUED BY THE 6TH RESPONDENT TO THE 3RD PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1051 APPENDIX OF WP(C) 14425/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE 03-04-2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1052 APPENDIX OF WP(C) 14559/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE NO.KSCB/GBT/194N/008/2021-22 DATED 30/3/2022 TO THE 1ST PETITIONER. Exhibit P2 TRUE COPY OF THE NOTICE DATED 30/3/2022 ISSUED BY THE 6TH RESPONDENT TO THE 1ST PETITIONER. Exhibit P3 TRUE COPY OF THE NOTICE NO.KSCB/GBT/194N/2021-22 DATED 10/4/2022 TO THE 2ND PETITIONER. Exhibit P4 TRUE COPY OF THE NOTICE DATED 10/4/2022 ISSUED BY THE 6TH RESPONDENT TO THE 2ND PETITIONER. Exhibit P5 TRUE COPY OF THE NOTICE NO.KSCB/GBT/194N/2021-22 DATED 5/4/2022 TO THE 3RD PETITIONER. Exhibit P6 TRUE COPY OF THE NOTICE NO.KSCB/GBT/194N/2021-22 DATED 20/3/2022 TO THE 4TH PETITIONER. Exhibit P7 TRUE COPY OF THE NOTICE DATED 20/3/2022 ISSUED BY THE 6TH RESPONDENT TO THE 4TH PETITIONER. Exhibit P8 TRUE COPY OF THE NOTICE NO.KSCB/GBT/194N/2021-22 DATED 24/3/2022 TO THE 5TH PETITIONER. Exhibit P9 TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED BY THE 6TH RESPONDENT TO THE 5TH PETITIONER. Exhibit P10 TRUE COPY OF THE JUDGMENT IN WP(C) N O.11176/2019 DATED 18/10/2019. Exhibit P11 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P12 TRUE COPY OF THE ORDER IN WP(C) NO.4442/2022 DATED 10/2/2022. Exhibit P13 TRUE COPY OF THE ORDER IN WP(C) NO.8333/2020 DATED 22/11/2021. Exhibit P14 TRUE COPY OF THE ORDER IN WP(C) NO.10988/2022 DATED 29/3/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1053 APPENDIX OF WP(C) 14687/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE NO. KB/R5/2021-22 DATED 25.03.2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P1 (A) TRUE COPY OF THE NOTICE NO. KB/R5/2021-22 DATED 25.03.2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE CIRCULAR NO. 18/2015 DATED 02.11.2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23.12.2021 IN WRIT PETITION (C) NO. 30686/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 1054 APPENDIX OF WP(C) 14715/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A F INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WPC NO 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1055 APPENDIX OF WP(C) 14806/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE MALAPPURAM BRANCH MANAGER OF 4TH RESPONDENT DATED 21.11.2021 TO THE PETITIONER Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31.05.2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC NO.13380 OF 2022 DATED 07.04.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1056 APPENDIX OF WP(C) 14807/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE GENERAL RESPONDENT DATED 21.03.2022. Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE ATHANI BRANCH MANAGER OF 4TH RESPONDENT DATED 24/03/2022 TO THE 1ST PETITIONER. Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE PATTIKKAD BRANCH MANAGER OF 4TH RESPONDENT DATED 25/03/2022 TO THE 2ND PETITIONER. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 07/04/2022 IN WPC NO.13380/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1057 APPENDIX OF WP(C) 14811/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE GAZETTE OF INDIA NOTIFICATION DATED 01.08.2019. Exhibit P2 TRUE COPY OF THE PRESS RELEASE DATED 20.08.2019 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P3 TRUE COPY OF THE RELEVANT PORTIONS OF THE FINANCE ACT, 2020 AS NOTIFIED BY GAZETTE OF INDIA NOTIFICATION DATED 27.03.20. Exhibit P4 TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED BY RESPONDENT NO. 6. Exhibit P5 TRUE COPY OF THE INTERIM ORDER DATED 11/4/2020 IN WPC NO. 9438 OF 2020 WPC NO. TMP- 38/2020. Exhibit P6 TRUE COPY OF THE INTERIM ORDER IN WPC NO. 11813/2022 DATED 1/4/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1058 APPENDIX OF WP(C) 14832/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.03.2020 . Exhibit P2 A TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 A TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.(C).NO.4442/2022. Exhibit P4 A TRUE COPY OF THE NOTICE 16.04.2022 ISSUED IN RESPECT OF THE FIRST PETITIONER. Exhibit P5 A TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED IN RESPECT OF THE SECOND PETITIONER. Exhibit P6 A TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED IN RESPECT OF THE THIRD PETITIONER. Exhibit P7 A TRUE COPY OF THE NOTICE DATED 31.03.2022 ISSUED IN RESPECT OF THE FOURTH PETITIONER. Exhibit P8 A TRUE COPY OF THE NOTICE DATED 30.03.2022 ISSUED IN RESPECT OF THE FIFTH PETITIONER. Exhibit P9 A TRUE COPY OF THE NOTICE DATED 25.03.2022 ISSUED IN RESPECT OF THE SIXTH PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1059 APPENDIX OF WP(C) 14838/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED NIL. Exhibit P2 TRUE COPY OF THE LETTER ISSUED BY THE BRANCH MANAGER OF THE 4TH RESPONDENT BANK TO THE PETITIONER DATED 31.03.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1060 APPENDIX OF WP(C) 14857/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE ISSUED TO THE PETITIONER CO OPERATIVE SOCIETIES DATED 25/3/2022 BY THE 6TH RESPONDENT BANK Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 02.11.2015. Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23.12.2021 IN WRIT PETITION(C)NO.30686/2021 OF THE HIGH COURT OF KERALA Exhibit P4 TRUE COPY OF THE INTERIM ORDER PASSEDB DATED 01/04/2022 IN WRIT PETITION (C)NO.11792/2022 OF THE HIGH COURT OF KERALA. 2025:KER W.P(C)No.7053/2023 & Connected cases 1061 APPENDIX OF WP(C) 14944/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE NO KB/R5/2021-22 DATED 25-03-2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P1A TRUE COPY OF THE NOTICE NO KB/R5/2021-22 DATED 25-03-2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER. Exhibit P2 TRUE COPY OF THE CIRCULAR NO 18/2015 DATED 02-11-2015 Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23-12-2021 IN WRIT PETITION (C) NO 23-12- 2021 IN WRIT PETITION(C) NO 30686/2021 2025:KER W.P(C)No.7053/2023 & Connected cases 1062 APPENDIX OF WP(C) 14960/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE NO.KB/R5/2021-22 DATED 25-03-2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER Exhibit P1(A) TRUE COPY OF THE NOTICE NO.KB/R5/2021-22 DATED 25.03.2022 ISSUED BY THE 6TH RESPONDENT TO THE PETITIONER Exhibit P2 TRUE COPY OF THE CIRCULAR NO.18/2015 DATED 02.11.2015 Exhibit P3 TRUE COPY OF THE INTERIM ORDER PASSED DATED 23.12.2021 IN WRIT PETITION(C)NO.30686/2021. 2025:KER W.P(C)No.7053/2023 & Connected cases 1063 APPENDIX OF WP(C) 15027/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 25.04.2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1064 APPENDIX OF WP(C) 15066/2022 PETITIONER EXHIBITS Exhibit EXHIBIT P1:- TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020 Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit5 EXHIBIT-P5: TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT. Exhibit6 EXHIBIT-P6: TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 5TH PETITIONER BY THE 4TH RESPONDENT. Exhibit7 EXHIBIT-P7:TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit8 EXHIBIT P8:- TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.(C).NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1065 APPENDIX OF WP(C) 15438/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 . Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1066 APPENDIX OF WP(C) 15480/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR NO GBT 14/2021- 22 ISSUED BY THE GENERAL MANAGER OF 4TH RESPONDENT DATED 21-03-2022 Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE ALAPPUZHA BRANCH MANAGER OF 4TH RESPONDENT DATED 28-03-2022 TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1067 APPENDIX OF WP(C) 15487/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE MALAPPURAM BRANCH MANAGER OF 4TH RESPONDENT DATED 03-04-2019 Exhibit P2 A TRUE COPY OF THE LETTER RBI/2012-13/516 DATED 31-05-2013 ISSUED BY THE CHIEF GENERAL MANAGER OF RBI TO ALL SCHEDULED COMMERCIAL BANKS Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC NO 13380 OF 2022 DATED 07-04-2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1068 APPENDIX OF WP(C) 15518/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE CIRCULAR ISSUED BY THE GENERAL MANAGER OF 4TH . Exhibit P2 A TRUE COPY OF THE CIRCULAR ISSUED BY THE GENERAL MANAGER OF 4TH RESPONDENT DATED 21.03.2022. Exhibit P3 A TRUE COPY OF THE NOTICE ISSUED BY THE KODUNGALLUR BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE 1ST PETITIONER. Exhibit P4 A TRUE COPY OF THE INTERIM ORDER DATED 07.04.2022 IN W.P.C NO. 13380/2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1069 APPENDIX OF WP(C) 15596/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT,2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT.1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WP(C) NO. 4442 OF 2022. Exhibit P4 TRUE COPY CIRCULAR NO GBT/14/2021 -22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1070 APPENDIX OF WP(C) 15598/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE (2) ACT, 2019. Exhibit P2 TRUE COPY OF THE RELEVANT PAGES OF THE FINANCE ACT, 2020. Exhibit P3 TRUE COPY OF THE ORDER DATED 06.04.2022 IN WPC NO.12744 OF 2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1071 APPENDIX OF WP(C) 15789/2022 PETITIONER EXHIBITS Exhibit1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020 Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit5 EXHIBIT-P5: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT. Exhibit6 EXHIBIT-P6:TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit7 EXHIBIT P7:- TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.(C).NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1072 APPENDIX OF WP(C) 15825/2022 PETITIONER EXHIBITS Exhibit1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020 Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED 25/3/2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit5 EXHIBIT-P5: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 4TH PETITIONER BY THE 4TH RESPONDENT. Exhibit6 EXHIBIT P6:- TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 5TH PETITIONER BY THE 4TH RESPONDENT. Exhibit7 EXHIBIT-P7:TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit8 EXHIBIT P8:- TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.(C).NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1073 APPENDIX OF WP(C) 15828/2022 PETITIONER EXHIBITS Exhibit1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020 Exhibit2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 1ST PETITIONER BY THE 4TH RESPONDENT. Exhibit3 EXHIBIT-P3: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 2ND PETITIONER BY THE 4TH RESPONDENT. Exhibit4 EXHIBIT-P4: TRUE COPY OF THE NOTICE DATED 24/3/2022 ISSUED TO THE 3RD PETITIONER BY THE 4TH RESPONDENT. Exhibit5 EXHIBIT-P5:TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit6 EXHIBIT P6:- TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.(C).NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1074 APPENDIX OF WP(C) 15874/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF NOTICE DATED 30.3.2022 ISSUED BY THE 4TH RESPONDENT TO 1ST PETITIONER UNDER SECTION 194 A (3) (V) OF INCOME TAX ACT Exhibit P2 COPY OF THE NOTICE ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER UNDER SECTION 194 N OF INCOME TAX ACT DATED 30.3.2022 Exhibit P3 COPY OF JUDGMENT OF THIS HON'BLE COURT DATED 18-10-2019 IN W.P.(C) NO. 11176 OF 2019 Exhibit P4 COPY OF THE SECTION 194 A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT Exhibit P5 COPY OF THE INTERIM ORDER OF THIS HONOURABLE COURT DATED 10.2.2022 IN W.P.(C) NO. 4385 OF 2022 Exhibit P6 COPY OF THE INTERIM ORDER OF THIS HONOURABLE COURT DATED 22.11.2021 IN W.P. (C) NO. 25368 OF 2019 Exhibit P7 COPY OF THE INTERIM ORDER OF THIS HON'BLE COURT DATED 01-12-2021 IN WP(C) NO. 27301 OF 2021 Exhibit P8 COPY OF THE ORDER OF THIS HONOURABLE COURT DATED 10.2.2022 IN W.P.(C) NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1075 APPENDIX OF WP(C) 16074/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1076 APPENDIX OF WP(C) 16243/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF THE NOTICE DATED 26.03.2022 ISSUED BY 7TH RESPONDENT PROPOSING TO LEVY TDS FROM DESPOSITS 2025:KER W.P(C)No.7053/2023 & Connected cases 1077 APPENDIX OF WP(C) 16321/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF LETTER DATED 09.03.2020 FROM THE 6TH RESPONDENT TO THE PETITIONER Exhibit P2 COPY OF LETTER DATED 23.09.2019 FROM THE 4TH RESPONDENT TO THE BRANCH MANAGER OF THE PATHANAMTHITTA DISTRCIT CO-OPERATIVE BANK Exhibit P3 COPY OF LETTER DATED 10.03.2020 RECEIVED PETITIONER FROM THE SIXTH RESPONDENT Exhibit P 4 COPY OF THE RELEVANT PAGES (AMENDED PROVISIONS IN SECTION 194A(3) OF INCOME TAX ACT )OF THE FINANCE ACT,2020 Exhibit P5 COPY OF THE INTERIM ORDER DATED 10.2.2022 PASSED IN W.P.(C) NO.4442 OF 2022 Exhibit P 6 COPY OF INTERIM ORDER DATED 19.04.22 PASSED IN W.P.C.NO. 14162 OF 2022 Exhibit P7 COPY OF NOTICE NO. 3718 /21-22 DATED 25.3.2022 ISSUED BY THE 6TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1078 APPENDIX OF WP(C) 16459/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 A TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 A TRUE COPY OF THE ORDER DATED 10.02.2022 IN WRIT PETITION (C) NO. 4442 OF 2022 Exhibit P4 A TRUE COPY OF CIRCULAR NO GBT/14/202122 DATED 21.03.2022 ISSUED BY THE 6TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1079 APPENDIX OF WP(C) 16598/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.C NO. 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO. GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1080 APPENDIX OF WP(C) 16805/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT,1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP (C) NO 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1081 APPENDIX OF WP(C) 16881/2022 PETITIONER EXHIBITS Exhibit1 COPY OF NOTICE NO.3699/21-22 DATED 25.3.2022 ISSUED BY RESPONDENT NO.6 Exhibit2 COPY OF ORDER DATED 10.2.2022 IN W.P.C.4442 OF 2022 Exhibit3 COPY OF ORDER DT.19.4.2022 IN W.P.C.14162 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1082 APPENDIX OF WP(C) 17323/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10/02/2022 IN WP(C) NO.4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21/03/2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1083 APPENDIX OF WP(C) 17707/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10.02.2022 IN WPC NO.4442OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1084 APPENDIX OF WP(C) 17716/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP O NO 4442 OF 2022. Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1085 APPENDIX OF WP(C) 17796/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE INTERIM ORDER IN WP(C) NO.10818/2022 DATED 29/03/2022 PASSED BY THIS HON'BLE HIGH COURT OF KERALA. Exhibit P2 TRUE COPY OF THE NOTICE DATED 24/03/2022 ISSUED TO THE PETITIONER BY THE 7TH RESPONDENT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1086 APPENDIX OF WP(C) 18070/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE PROCEEDING 11.04.2022 ISSUED BY THE 5TH RESPONDENT TO THE PETITIONER. 2025:KER W.P(C)No.7053/2023 & Connected cases 1087 APPENDIX OF WP(C) 18489/2022 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020. Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, FROM THE WEB SITE OF INCOME TAX DEPARTMENT. Exhibit P3 THE TRUE COPY OF THE G.O.(MS) NO 324/2016/FIN DATED 15-8-2016. Exhibit P4 THE TRUE COPY OF THE G.O.(RT)NO. 6818/2016/FIN DATED 18-8-2016. Exhibit P5 THE TRUE COPY OF THE CIRCULAR WITH NO.GBT /14/2021-22, DATED 21.03.2022 ISSUED BY THE 5TH RESPONDENT, TO ITS REGIONAL MANAGERS. Exhibit P6 THE TRUE COPY OF NOTICE DATED 30-032022 ISSUED BY THE 8TH RESPONDENT TO PETITIONER. Exhibit P7 THE TRUE COPY OF THE INTERIM ORDER DATED 10.02.2022 IN W.P.(C).NO. 4442/2022. Exhibit P8 THE TRUE COPY OF INTERIM ORDER DATED 01-04- 2022 IN WPC NO 11684/2022 . Exhibit P9 THE TRUE COPY OF INTERIM ORDER DATED 04-04- 2022 IN WPC NO 12098/2022. 2025:KER W.P(C)No.7053/2023 & Connected cases 1088 APPENDIX OF WP(C) 18690/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1089 APPENDIX OF WP(C) 20028/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF RELEVANT PAGES OF NOTIFICATION DTD 27.03.2022 ISSUED BY 1ST RESPONDENT Exhibit P2 TRUE COPY OF RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 TRUE COPY OF ORDER DTD 10.02.2022 IN WPC NO.4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1090 APPENDIX OF WP(C) 21287/2022 PETITIONER EXHIBITS Exhibit P1 THE COPY OF NOTICE ISSUED TO THE PETITIONER BY THE KERALA STATE COOPERATIVE BANK, CHALAKUDDY BRANCH DATED 28.03.2020 Exhibit P2 COPY OF INTERIM ORDER DATED 28.12.2021 IN WPC 30811 OF 2021 Exhibit P3 A TRUE COPY OF THE INTERIM ORDER IN WPC 30263 OF 2021 DATED 23.12.2021 2025:KER W.P(C)No.7053/2023 & Connected cases 1091 APPENDIX OF WP(C) 21639/2022 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27.3.2020 Exhibit P2 A TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194 A OF INCOME TAX ACT, 1961. Exhibit P3 A TRUE COPY OF THE ORDER DATED 10.2.2022 IN WPC NO 4442/2022 Exhibit P4 A TRUE COPY OF THE NOTICE 25.3.2022 TO THE PETITIONER 2025:KER W.P(C)No.7053/2023 & Connected cases 1092 APPENDIX OF WP(C) 21922/2022 PETITIONER EXHIBITS Exhibit-P1 A TRUE COPY OF NOTICE DATED 01-06-2022 ISSUED UNDER SECTION 194 A(3)(V) OF THE INCOME TAX ACT, FROM KUNNICODE BRANCH OF THE 6TH RESPONDENT TO PETITIONER. Exhibit-P2 A TRUE COPY OF JUDGMENT 18-10-2019 IN WP(C) NO.11176 OF 2019 OF THIS HON'BLE COURT. Exhibit-P3 A TRUE COPY OF THE EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961, AS APPEARING IN THE WEBSITE OF INCOME TAX DEPARTMENT. Exhibit-P4 A TRUE COPY OF THE INTERIM ORDER DATED 01- 04-2022 IN WP(C) NO.11784 OF 2022 OF THIS HON'BLE COURT. 2025:KER W.P(C)No.7053/2023 & Connected cases 1093 APPENDIX OF WP(C) 22198/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1094 APPENDIX OF WP(C) 22339/2022 PETITIONER EXHIBITS Exhibit P1 EXHIBIT-P1 A TRUE COPY OF THE CIRCULAR NO.GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE GENERAL MANAGER OF 4TH RESPONDENT DATED 21.03.2022 Exhibit P2 EXHIBIT P2: A TRUE COPY OF THE NOTICE ISSUED BY THE PAVARATTY BRANCH MANAGER OF 4TH RESPONDENT TO THE 1ST PETITIONER DATED 19.04.2022 Exhibit P3 EXHIBIT P3: A TRUE COPY OF THE NOTICE ISSUED BY THE PAVARATTY BRANCH MANAGER OF 4TH RESPONDENT TO THE 2ND PETITIONER DATED 19.04.2022 Exhibit P4 EXHIBIT P4: A TRUE COPY OF THE INTERIM ORDER DATED 07.04.2022 IN WP C NO.13380/2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1095 APPENDIX OF WP(C) 22917/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1096 APPENDIX OF WP(C) 23239/2022 PETITIONER EXHIBITS Exhibit P1 EXHIBIT-P1 A TRUE COPY OF THE NOTICE ISSUED BY THE VADAKKEKAD BRANCH MANAGER OF 4TH RESPONDENT DATED 25.03.2022 TO THE PETITIONER Exhibit P2 EXHIBIT-P2 - A TRUE COPY OF THE INTERIM ORDER DATED 07.04.2022 IN WP C NO.13380/2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1097 APPENDIX OF WP(C) 23780/2022 PETITIONER EXHIBITS Exhibit P 1 THE TRUE COPY OF THE RECEIPT DATED 26/10/2013 BEARING NO. 0388193 ISSUED BY THE FOURTH RESPONDENT Exhibit P 1(a) THE TRUE COPY OF THE RECEIPT DATED 28/10/2013 BEARING NO. 0388229 ISSUED BY THE FOURTH RESPONDENT Exhibit P 1(b) THE TRUE COPY OF THE RECEIPT DATED 28/10/2013 BEARING NO. 0388230 ISSUED BY THE FOURTH RESPONDENT Exhibit P 1(c) THE TRUE COPY OF THE RECEIPT DATED 05/11/2013 BEARING NO. 0388345 ISSUED BY THE FOURTH RESPONDENT Exhibit P (d) THE TRUE COPY OF THE RECEIPT DATED 07/11/2013 BEARING NO. 0388366 ISSUED BY THE FOURTH RESPONDENT Exhibit P (e) THE TRUE COPY OF THE RECEIPT DATED 07/11/2013 BEARING NO. 0388367 ISSUED BY THE FOURTH RESPONDENT Exhibit P(f) THE TRUE COPY OF THE RECEIPT DATED 07/11/2013 BEARING NO. 0388368 ISSUED BY THE FOURTH RESPONDENT Exhibit P(g) THE TRUE COPY OF THE RECEIPT DATED 11/11/2013 BEARING NO. 0388416 ISSUED BY THE FOURTH RESPONDENT Exhibit P(h) THE TRUE COPY OF THE RECEIPT DATED 18/11/2017 BEARING NO. 0556475 ISSUED BY THE FOURTH RESPONDENT Exhibit P(i) THE TRUE COPY OF THE RECEIPT DATED 16/07/2020 BEARING NO. 0518720 ISSUED BY THE FOURTH RESPONDENT Exhibit P(j) THE TRUE COPY OF THE RECEIPT DATED 16/06/2020 BEARING NO. 0518604 ISSUED BY THE FOURTH RESPONDENT Exhibit P(k) THE TRUE COPY OF THE RECEIPT DATED 16/06/2020 BEARING NO. 0518603 ISSUED BY THE FOURTH RESPONDENT Exhibit P(L) THE TRUE COPY OF THE RECEIPT DATED 16/06/2020 BEARING NO. 0518602 ISSUED BY THE FOURTH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1098 Exhibit P(m) THE TRUE COPY OF THE RECEIPT DATED 17/08/2020 BEARING NO. 0518951 ISSUED BY THE FOURTH RESPONDENT Exhibit P(n) THE TRUE COPY OF THE RECEIPT DATED 10/02/2021 BEARING NO. 0519828 ISSUED BY THE FOURTH RESPONDENT Exhibit P 2 THE TRUE COPY OF THE LETTER DATED 30/03/2022 ISSUED BY THE 4TH RESPONDENT TO THE PETITIONER Exhibit P 3 TRUE COPY OF THE CIRCULAR NO: 18/2015 DATED 02.11.2015 Exhibit P4 TRUE COPY OF THE INTERIM ORDER DATED 23.12.2021 IN WRIT PETITION(C) NO. 30686/2021 ON THE FILES OF THIS HON'BLE COURT 2025:KER W.P(C)No.7053/2023 & Connected cases 1099 APPENDIX OF WP(C) 24428/2022 PETITIONER EXHIBITS Exhibit P1 EXHIBIT P1:- TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27/3/2020 Exhibit P2 EXHIBIT-P2: TRUE COPY OF THE NOTICE DATED 21/3/2022 ISSUED TO THE PETITIONER BY THE 4TH RESPONDENT. Exhibit P3 EXHIBIT-P3: TRUE COPY OF THE CIRCULAR NO.18/2017 DATED 29/5/2017 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES. Exhibit P4 EXHIBIT P4:- TRUE COPY OF THE ORDER DATED 10.02.2022 IN W.P.(C).NO. 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1100 APPENDIX OF WP(C) 24538/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PORTION OF THE PASS BOOK OF THE PETITIONER WITH THE 3RD RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1101 APPENDIX OF WP(C) 25354/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP (C) NO.4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO.GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1102 APPENDIX OF WP(C) 26364/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1103 APPENDIX OF WP(C) 26636/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1104 APPENDIX OF WP(C) 25894/2023 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P 2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P 4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 6TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1105 APPENDIX OF WP(C) 27682/2023 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27-03-2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit 3 TRUE COPY OF THE ORDER DATED 13-1-2023 IN WP © NO 1100 OF 2023 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1106 APPENDIX OF WP(C) 31251/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit3 TRUE COPY OF THE NOTICE DATED 30-07-2022 ISSUED BY THE 6TH RESPONDENT TO THE 1ST PETITIONER Exhibit P4 TRUE COPY OF THE NOTICE DATED 30-07-2022 ISSUED BY THE 6TH RESPONDENT TO THE 2ND PETITIONER Exhibit P5 TRUE COPY OF THE NOTICE DATED 30-07-2022 ISSUED BY THE 6TH RESPONDENT TO THE 3RD PETITIONER Exhibit P6 TRUE COPY OF THE NOTICE DATED 30-07-2022 ISSUED BY THE 6TH RESPONDENT TO THE 4TH PETITIONER Exhibit P7 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1107 APPENDIX OF WP(C) 32055/2022 PETITIONER EXHIBITS Exhibit P1 COPY OF NOTICE DATED 26.3.2022 ISSUED BY THE 4TH RESPONDENT TO 1ST PETITIONER UNDER SECTION 194 A (3) (V) OF INCOME TAX ACT Exhibit P2 COPY OF NOTICE DATED 26.3.2022 ISSUED BY THE 4TH RESPONDENT TO 2ND PETITIONER UNDER SECTION 194 A (3) (V) OF INCOME TAX ACT Exhibit P3 COPY OF NOTICE DATED 25.3.2022 ISSUED BY THE 4TH RESPONDENT TO 3RD PETITIONER UNDER SECTION 194 A (3) (V) OF INCOME TAX ACT Exhibit P4 COPY OF THE NOTICE ISSUED BY THE 4TH RESPONDENT TO THE 1ST PETITIONER UNDER SECTION 194 N OF INCOME TAX ACT DATED 26.3.2022 Exhibit P5 COPY OF THE NOTICE ISSUED BY THE 4TH RESPONDENT TO THE 2ND PETITIONER UNDER SECTION 194 N OF INCOME TAX ACT DATED 26.3.2022 Exhibit P6 COPY OF THE NOTICE ISSUED BY THE 4TH RESPONDENT TO THE 3RD PETITIONER UNDER SECTION 194 N OF INCOME TAX ACT DATED 26.3.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1108 APPENDIX OF WP(C) 32580/2023 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27-03-2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 01-4-2022 IN WP © NO 11765 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT Exhibit P4(a) TRUE COPY OF THE ENGLISH TRANSLATION OF EXT P4 CIRCULAR DATED 21-03-2022 Exhibit P5 TRUE COPY OF THE NOTICE DATED 30-09-2023 ISSUED BY THE 4TH RESPONDENT Exhibit P5(a) TRUE COPY OF THE ENGLISH TRANSLATION OF EXT P5 NOTICE DATED 30-09-2023 2025:KER W.P(C)No.7053/2023 & Connected cases 1109 APPENDIX OF WP(C) 30686/2021 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE NOTICE DATED 6/12/2021 ISSUED BY THE MALAPPURAM DISTRICT CO- OPERATIVE BANK, TO THE PETITIONER PROPOSING TO LEVY TDS FROM DEPOSITS. 2025:KER W.P(C)No.7053/2023 & Connected cases 1110 APPENDIX OF WP(C) 36670/2023 PETITIONER EXHIBITS Exhibit-P1 TRUE COPY OF THE CIRCULAR GBT/14/2021-22 DATED 21.03.2022 ISSUED BY THE 2ND RESPONDENT ALONG WITH ENGLISH TRANSLATION 2025:KER W.P(C)No.7053/2023 & Connected cases 1111 APPENDIX OF WP(C) 41031/2022 PETITIONER EXHIBITS Exhibit P1 TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 10-2-2022 IN WP © NO 4442 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1112 APPENDIX OF WP(C) 9194/2024 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE WITH ENGLISH TRANSLATION, ISSUED BY THE 4TH RESPONDENT DATED NIL TO PETITIONER Exhibit P2 A TRUE COPY OF THE INTERIM ORDER IN WP ( C ) NO. 15487 OF 2022 DATED 06.05.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1113 APPENDIX OF WP(C) 41499/2022 PETITIONER EXHIBITS EXHIBIT P1 TRUE COPY OF THE FINANCE ACT 2020. EXHIBIT-P2 TRUE COPY OF THE LETTER DATED 30.7.2022 ISDSDUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1114 APPENDIX OF WP(C) 43925/2023 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 PUBLISHED IN EXTRAORDINARY GAZETTE NO. 20 DATED 27/03/2020 Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 . Exhibit P3 THE TRUE COPY OF THE ORDER DATED 05/04/2022 IN W.P.(C) NO. 12351 OF 2022 OF THIS HON'BLE COURT . Exhibit P4 THE TRUE COPY OF THE ORDER DATED 08/04/2022 IN W.P.(C) NO. 13751 OF 2022 OF THIS HON'BLE COURT . Exhibit P5 THE TRUE COPY OF CIRCULAR NO. GBT/14/2021- 22 DATED 21/03/2022 ISSUED BY THE 6TH RESPONDENT ALONG WITH THE ENGLISH TRANSLATION Exhibit P6 THE TRUE COPY OF THE LETTER NO. KSCB/RO- ALP/BANKING/10/5933/2023-24 DATED 09/11/2023 ISSUED BY THE 7TH RESPONDENT TO THE PETITIONERS ALONG WITH THE ENGLISH TRANSLATION 2025:KER W.P(C)No.7053/2023 & Connected cases 1115 APPENDIX OF WP(C) 27670/2024 PETITIONER EXHIBITS Exhibit P1 . TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 DATED 27-03-2020 Exhibit P2 TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961 Exhibit P3 TRUE COPY OF THE ORDER DATED 19-12-2022 IN WP © NO 41031 OF 2022 Exhibit P4 TRUE COPY OF CIRCULAR NO GBT/14/2021-22 DATED 21-03-2022 ISSUED BY THE 4TH RESPONDENT 2025:KER W.P(C)No.7053/2023 & Connected cases 1116 APPENDIX OF WP(C) 31176/2024 PETITIONER EXHIBITS Exhibit P1 A TRUE COPY OF THE NOTICE ISSUED BY THE PANIKKOTTUMPADI BRANCH MANAGER OF 4TH RESPONDENT DATED 27.06.2024 TO THE 1ST PETITIONER Exhibit P2 A TRUE COPY OF THE NOTICE ISSUED BY THE PANIKKOTTUMPADI BRANCH MANAGER OF 4TH RESPONDENT DATED 27.06.2024 TO THE 2ND PETITIONER Exhibit P3 A TRUE COPY OF THE RELEVANT PAGES OF THE BANK PASSBOOK OF THE 1ST PETITIONER ISSUED BY THE ERSTWHILE MDC BANK DATED 20.03.2021 SHOWING TDS DEDUCTION ON 06.12.2023 AND 30.03.2024 Exhibit P4 A TRUE COPY OF THE INTERIM ORDER IN WP ( C ) NO. 15487 OF 2022 DATED 06.05.2022 2025:KER W.P(C)No.7053/2023 & Connected cases 1117 APPENDIX OF WP(C) 37399/2024 PETITIONER EXHIBITS Exhibit P1 THE TRUE COPY OF THE RELEVANT PAGES OF FINANCE ACT, 2020 Exhibit P2 THE TRUE COPY OF THE RELEVANT EXTRACT OF SECTION 194A OF INCOME TAX ACT, 1961. Exhibit P3 THE TRUE COPY OF THE ORDER DATED 05/04/2022 IN W.P.(C) NO. 12351 OF 2022 OF THIS HONOURABLE COURT Exhibit P4 THE TRUE COPY OF THE ORDER DATED 08/04/2022 IN W.P.(C) NO. 13751 OF 2022 OF THIS HONOURABLE COURT. Exhibit P5 THE TRUE COPY OF CIRCULAR NO. GBT/14/2021- 22 DATED 21/03/2022 ISSUED BY THE 6TH RESPONDENT. Exhibit P6 THE TRUE COPY OF THE LETTER NO. KSCB/RO- ALP/BANKING/10/5933/2023-24 DATED 09/11/2023 ISSUED BY THE 7TH RESPONDENT TO THE PETITIONERS.