High Court of KeralaSingle Judge2019-07-08Writ petitions dismissed; petitioners may pursu...

Batch of writ petitions in WP(C).714/2019 and connected matters (Royal Granites; T.P. Mathew & Co.; K.N. Anirudhan; M/S Vee Yes Agencies; V. Sushama; Roy Jacob; M/S Famous Food Products PunnaKKad) v. State Tax Officers, State of Kerala, Union of India and related authorities

Case / Petition Number:WP(C).714/2019 (and connected matters)

Case Details & Bench

Court: High Court of Kerala
Hon'ble Judges: S.V. Bhatti
Judgment Date: 2019-07-08
Court Decision / Holding: The writ petitions are dismissed by referring to and following the judgment in W.P.(C) No.11335 of 2018. The petitioners may pursue appeal or revision with condonation of delay, and the appellate authority should consider the time spent by the petitioners in pursuing writ relief to ensure remedy is not rendered ineffective.
Final Disposition: Writ petitions dismissed; petitioners may pursue appellate/revisional remedies with consideration of time spent pursuing writ relief.

Parties to the Case

Appellants / Petitioners

Royal Granites, Nedumkunnam P.O., Pin-686 542 represented by Managing Partner Eldho P.T.
T.P. Mathew and Co. (Pvt) Ltd., Kochi represented by Director Elias Mathew
K.N. Anirudhan represented by M/S Lloyds Residency
M/S Vee Yes Agencies represented by V.H. Seenil Kumar
V. Sushama represented by Sushara Appliances and Electronics
Roy Jacob represented by Thekkunnel Enterprises
M/S Famous Food Products Punannakkad represented by Abdul Azeez

Respondents

State Tax Officer, 2nd Circle, Changanacherry
Commissioner of State Taxes, Tax Tower, Karamana, Thiruvananthapuram
State of Kerala represented by its Secretary to Taxes
Union of India represented by Revenue Secretary, Department of Revenue, North Block, New Delhi
Central Board of Indirect Taxes and Customs represented by its Chairman, Department of Revenue, North Block, New Delhi
Secretary, Taxes Department, Government of Kerala, Secretariat, Thiruvananthapuram

Legal Representation & Advocates

Counsels for Petitioners

• V.V. Georgekutty
• K.M. Firoz
• M. Shajna
• R. Cherian John
• T. Thomson Emmanuel
• P.S. Soman
• T. Radhamany
• K. Sundar
• V. Satheesh
• M.N. Manmadan (CGC)
• M.K. Hajara
• C. Ramachandran

Counsels for Respondents

• C.E. Unnikrishnan (Special Government Pleader)
• S. Chandrasekhar (State Counsel)
• M.N. Manmadan (CGC)
• SPL. GP (as applicable)

Case Synopsis & Summary

This batch of writ petitions before the Kerala High Court challenges the validity of Section 174 of the Kerala KSGST Act on ultra vires grounds and seeks to quash or defer tax demands raised for multiple assessment years. Petitioners include diverse commercial entities: Royal Granites (WP(C).714/2019), T.P. Mathew & Co. (WP(C).120/2019), K.N. Anirudhan (WP(C).718/2019), M/S Vee Yes Agencies (WP(C).40914/2018), V. Sushama (WP(C).41054/2018), Roy Jacob (WP(C).41117/2018), and M/S Famous Food Products PunnaKKad (WP(C).41465/2018). The petitions contend that Section 174, and in some cases related demands, are unsustainable because of lack of legislative competence or due to limitations (Section 25(1) KVAT Act). The matter was heard on 8 July 2019 along with several connected petitions, with the court noting the controlling ratio from a prior decision, W.P.(C) No.11335 of 2018 (dated 11.01.2019). The court dismisses the petitions, referring to the earlier judgment and stating that relief could be sought through appeals or revisions, with considerations for the time spent pursuing writ relief. The judgment reinforces that petitioners may pursue statutory remedies to avoid irreparable loss, and the court emphasizes that the remedy should not be rendered ineffective by delays. A leading cited decision is Sheen Golden Jewels, noted in the context of contemporaneous litigation, but the court chooses to follow the earlier ratio. Overall, the court disposes of the writ petitions by dismissing them while recognizing the petitioners’ right to challenge through appellate avenues.

Provisions of Law Cited

Section 174 of the KSGST ActSection 25(1) of the KVAT Act

Legal Doctrines & Maxims

Ultra vires

Submissions & Arguments

Contentions of Appellants / Petitioners

The petitioners contend that Section 174 of the KSGST Act is ultra vires the state’s legislative power and, in certain petitions, that the tax demands are barred by the limitation period under Section 25(1) of the KVAT Act. They urge that the challenged provisions exceed legislative competence and/or seek quashment of notices and assessments on grounds of timing and illegality.

Contentions of Respondents

The respondents primarily argue for dismissing the writ petitions, upholding the statutory assessments and demands, and rely on the judgment in W.P.(C) No.11335 of 2018 (11 January 2019). They emphasize availability of statutory remedies (appeal/revision) and guidance to avoid rendering remedies ineffective, urging that the petitioners should pursue appellate channels rather than writ relief.

Cited Precedents (2)

Case Name	Citation	Treatment	Explanation
W.P.(C) No.11335 of 2018	W.P.(C) No.11335 of 2018	Positive	Court follows the ratio laid down in the 2018 decision dated 11.01.2019 to dismiss the current petitions.
M/s. Sheen Golden Jewels (India) Pvt. Ltd. v. The State Tax Officer (IB)-1	[1]	Mentioned Only	Cited as part of the discussion but not a controlling authority for the final order; the court relies on the 2018 W.P. No.11335 decision instead.

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Extracted Judgment Text

Exact text extracted from official judgment records.

## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR.JUSTICE S.V.BHATTI** **MONDAY, THE 08TH DAY OF JULY 2019 / 17TH ASHADHA, 1941** ## **WP(C).No.714 of 2019** **PETITIONER:** **ROYAL GRANITES, NEDUMKUNNAM P.O, PIN-686 542 REPRESENTED BY MANAGING PARTNER, ELDHO P.T.** **BY ADV. SRI.V.V.GEORGEKUTTY** ## **RESPONDENTS:** **1 STATE TAX OFFICER, 2ND CIRCLE, CHANGANACHERRY-686 101** **2 THE COMMISSIONER OF STATE TAXES TAX TOWER, KARAMANA, THIRUVANANTHAPURAM-695 002** **3 THE STATE OF KERALA REPRESENTED BY IT'S SECRETARY TO TAXES, SECRETARIAT, THIRUVANANTHAPURAM-695 001** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.07.2019, ALONG WITH WP(C).120/2019, WP(C).718/2019, WP(C).40914/2018, WP(C).41054/2018, WP(C).41117/2018, WP(C).41465/2018, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WPC No.714/2019 & conn.cases 2 ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MR.JUSTICE S.V.BHATTI** **MONDAY, THE 08TH DAY OF JULY 2019 / 17TH ASHADHA, 1941** ## **WP(C).No.120 of 2019** ## **PETITIONER:** **T.P.MATHEW AND CO. (PVT) LTD., T.P.M.HOUSE, BRISTOW ROAD, WILLINGTON ISLAND, KOCHI - 682 003, REPRESENTED BY ITS DIRECTOR ELIAS MATHEW.** **BY ADVS. SRI.K.M.FIROZ SMT.M.SHAJNA** ## **RESPONDENTS:** |**1**|**THE STATE TAX OFFICER,**| |---|---| ||**2ND CIRCLE, DEPARTMENT OF COMMERCIAL TAXES,**| ||**MATTANCERRY - 682 002.**| |**2**|**COMMISSIONER OF STATE GOODS AND SERVICE TAX**| ||**STATE GST DEPARTMENT, TAX TOWERS,**| ||**THIRUVANANTHAPURAM - 695 001.**| |**3**|**THE STATE OF KERALA**| ||**REPRESENTED BY ITS CHIEF SECRETARY, SECRETARIAT,**| ||**THIRUVANANTHAPURAM - 695 001.**| |**4**|**SECRETARY,**| ||**TAXES DEPARTMENT, GOVERNMENT OF KERALA,**| ||**SECRETARIAT, THIRUVANANTHAPURAM - 695 001.**| |**5**|**UNION OF INDIA**| ||**REPRESENTED BY REVENUE SECRETARY, DEPARTMENT OF**| ||**REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA,**| ||**NORTH BLOCK, NEW DELHI - 110 001.**| **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.07.2019, ALONG WITH WP(C).40914/2018, WP(C).41054/2018, WP(C).41117/2018, WP(C).41465/2018, WP(C).714/2019, WP(C).718/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WPC No.714/2019 & conn.cases 3 ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR.JUSTICE S.V.BHATTI** **MONDAY, THE 08TH DAY OF JULY 2019 / 17TH ASHADHA, 1941** ## **WP(C).No.718 of 2019** ## **PETITIONER:** **K.N.ANIRUDHAN,AGED 66 YEARS S/O NEELAKANTAN PANICKER,PROPRIETOR M/S LLOYDS RESIDENCY,PUNNAMADA,ZILLA COURT WARD, ALAPPUZHA.** **BY ADV. SRI.R.UMASANKAR** ## **RESPONDENTS:** |**1**|**THE STATE TAX OFFICER (LT),**| |---|---| ||**OFFICE OF THE DEPUTY COMMISSIONER,**| ||**STATE TAX OFFICER(LT),ALAPPUZHA-688001.**| |**2**|**THE COMMISSIONER**| ||**STATE GOODS AND SERVICE TAX DEPARTMENT,**| ||**THIRUVANNATHAPURAM-695001.**| |**3**|**STATE OF KERALA**| ||**REPRESENTED BY SECRETARY TO TAXES,**| ||**FINANCE DEPARTMENT,SECRETARIAT,**| ||**THIRUVANANTHAPURAM-695001.**| |**4**|**THE UNION OF INDIA,**| ||**REPRESENTED BY SECRETARY TO FINANCE,**| ||**FINANCE DEPARTMENT,NEW DELHI-110001.**| ||**BY ADV. SRI.M.N.MANMADAN, CGC**| **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.07.2019, ALONG WITH WP(C).40914/2018, WP(C).41054/2018, WP(C).41117/2018, WP(C).41465/2018, WP(C).120/2019, WP(C).714/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WPC No.714/2019 & conn.cases 4 ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR.JUSTICE S.V.BHATTI** **MONDAY, THE 08TH DAY OF JULY 2019 / 17TH ASHADHA, 1941** ## **WP(C).No.40914 of 2018** ## **PETITIONER:** **M/S VEE YES AGENCIES, 35/3100,VELUTHEDATH HOUSE,PALARIVATTOM, PIN 682 025,ERNAKULAM,REPRESENTED BY ITS PROPRIETOR MR.V.H.SEENIL KUMAR.** ## **BY ADV. SRI.TOMSON T.EMMANUEL** ## **RESPONDENTS:** **1 THE STATE OF KERLA, REPRESENTED BY THE PRINCIPAL SECRETARY TO GOVERNMENT,TAXES DEPARTMENT,GOVERNMENT SECRETARIAT,THIRUVANANTHAPURAM 695 001 2 THE STATE TAX OFFICER, SGST DEPARTMENT,2ND CIRCLE,KALAMASSERY AT CIVIL STATION,KAKKANANDU,PIN 682 030 3 UNION OF INDIA, REPRESENTED BY THE SECRETARY,DEPARTMENT OF REVENUE,MINISTRY OF FINANCE,ROOM NO 46,NORTH BLOCK,NEW DELHI-110001.** ## **OTHER PRESENT:** **SPL. GP. SRI. C.E. UNNIKRISHNAN** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.07.2019, ALONG WITH WP(C).41054/2018, WP(C).41117/2018, WP(C).41465/2018, WP(C).120/2019, WP(C).714/2019, WP(C).718/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WPC No.714/2019 & conn.cases 5 # **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** **THE HONOURABLE MR.JUSTICE S.V.BHATTI** **MONDAY, THE 08TH DAY OF JULY 2019 / 17TH ASHADHA, 1941** ## **WP(C).No.41054 of 2018** ## **PETITIONER:** **V.SUSHAMA, PROPRIETRIX, AGED 52 YEARS, M/S.SUSHARA APPLIANCES AND ELECTRONICS, OPPOSITE TO URBAN BANK, NEDUMANGAD, THIRUVANANTHAPURAM - 695 541.** **BY ADVS. SRI.P.S.SOMAN SMT.T.RADHAMANY SRI.K.SUNDAR SRI.V.SATHEESH (S-3495)** ## **RESPONDENTS:** |**1**|**COMMERCIAL TAX OFFICER**| |---|---| ||**COMMERCIAL TAX DEPARTMENT, REVENUE TOWER,**| ||**NEDUMANGAD P.O., THIRUVANANTHAPURAM - 695 541.**| |**2**|**THE COMMISSIONER**| ||**STATE GOODS AND SERVICE TAX DEPARTMENT, TAX TOWER,**| ||**KARAMANA P.O., THIRUVANANTHAPURAM - 695 001.**| |**3**|**THE SECRETARY, TAXES DEPARTMENT,**| ||**GOVERNMENT OF KERALA, SECRETARIAT,**| ||**THIRUVANANTHAPURAM - 695 001.**| |**4**|**CENTRAL BOARD OF EXCISE AND CUSTOMS**| ||**DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,**| ||**GOVERNMENT OF INDIA, NEW DELHI - 110 001.**| **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.07.2019, ALONG WITH WP(C).40914/2018, WP(C).41117/2018, WP(C).41465/2018, WP(C).120/2019, WP(C).714/2019, WP(C).718/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WPC No.714/2019 & conn.cases 6 ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR.JUSTICE S.V.BHATTI** **MONDAY, THE 08TH DAY OF JULY 2019 / 17TH ASHADHA, 1941** ## **WP(C).No.41117 of 2018** ## **PETITIONER:** **ROY JACOB,AGED 53 YEARS** **(PROPRIETOR), THATTARAKKUNNEL ENTERPRISES, ROOM NO.5, THEKKENETH BUILDING, KADAVANTHARA, KOCHI682 020.** ## **BY ADV. SRI.RAMESH CHERIAN JOHN** ## **RESPONDENTS:** **1 THE ASSISTANT COMMISSIONER(WORKS CONTRACT) O/O THE DEPUTY COMMISSIONER, STATE GOODS AND SERVICE TAX DEPARTMENT, STATE GOODS AND SERVICE TAX COMPLEX, PERUMANOOR P.O., KOCHI-682 015.** **2 STATE OF KERALA REPRESENTED BY THE COMMISSIONER OF GOODS AND SERVICE TAX, O/O THE COMMISSIONER OF GOODS AND SERVICE TAXES, TAX TOWERS, KARAMANA P.O., THIRUVANANTHAPURAM-695002.** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.07.2019, ALONG WITH WP(C).40914/2018, WP(C).41054/2018, WP(C).41465/2018, WP(C).120/2019, WP(C).714/2019, WP(C).718/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WPC No.714/2019 & conn.cases 7 ## **IN THE HIGH COURT OF KERALA AT ERNAKULAM** ## **PRESENT** ## **THE HONOURABLE MR.JUSTICE S.V.BHATTI** **MONDAY, THE 08TH DAY OF JULY 2019 / 17TH ASHADHA, 1941** ## **WP(C).No.41465 of 2018** ## **PETITIONER:** **M/S FAMOUS FOOD PRODUCTS PUNNAKKAD, KARUVARAKUNDU, MALAPPURAM-676 523, REPRESENTED BY IT'S MANAGING PARTNER ABDUL AZEEZ.** **BY ADVS. SMT.M.K.HAJARA SRI.C.RAMACHANDRAN** ## **RESPONDENTS:** **1 THE INTELLIGENCE OFFICER (IB) DEPARTMENT OF COMMERCIAL TAXES, MALAPPURAM-676 553 2 THE STATE TAX OFFICER-1 STATE GOODS AND SERVICES TAX DEPARTMENT, NILAMBUR, MALAPPURAM DISTRICT-679 329 3 THE STATE OF KERALA REPRESENTED BY ITS SECRETARY TO TAXES, SECRETARIAT, THIRUVANANTHAPURAM-695 001 4 THE CENTRAL BOARD OF INDIRECT TAXES AND CUSTOMS REPRESENTED BY ITS CHAIRMAN DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110 001 5 THE UNION OF INDIA REPRESENTED BY ITS PRINCIPAL SECRETARY, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110 001** **THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.07.2019, ALONG WITH WP(C).40914/2018, WP(C).41054/2018, WP(C).41117/2018, WP(C).120/2019, WP(C).714/2019, WP(C).718/2019, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:** WPC No.714/2019 & conn.cases 8 ## **JUDGMENT** **[ WP(C) 714/2019 ,WP(C).120/2019 ,WP(C).718/2019 ,WP(C).40914/2018 ,WP(C).41054/2018 ,WP(C).41117/2018 ,WP(C).41465/2018 ]** In this batch of writ petitions the petitioners have laid challenge amongst others that Section 174 of the KSGST Act is _ultra virus_ of the state's legislative power or on the ground that the demand is barred by limitation under Section 25(1) of the KVAT Act. In some cases, both the grounds have been taken. 2. Heard the learned counsel for the petitioners and the learned Government Pleader. 3. Keeping in view the judgment of this Court in W.P. (C)No.11335 of 2018 dated 11.1.2019, the ratio laid down therein and with the consent of the counsel on either side, the following order is made. 4. The writ petitions are dismissed by referring to and following the judgment in W.P.(C)No.11335 of 2018. The counsel for the petitioners for the present do not invite a finding, though it is against the petitioners in view of the decisions of this Court in WPC No.714/2019 & conn.cases 9 **.** _**M/s.Sheen Golden Jewels (India) Pvt.Ltd. v. The State Tax Officer (IB)-1[1]**_ 5. The petitioners if so advised, can avail the remedy of appeal or revision before the appellate authority/revisional authority as the case may be and avail such remedy of appeal or revision along with an application for condonation of delay. The appellate/principal authority takes note of the time spent by the petitioner/assessee in working out the writ prayer and passes orders appropriately so that the statutory remedy of appeal/revision is not rendered ineffective or remedy is lost to an aggrieved party. **Sd/-** **S.V.BHATTI** **JUDGE** Css/ 1 Judgement dated 11.1.2019 in WPC No.11335 of 2018 & conn.cases WPC No.714/2019 & conn.cases 10 ## **APPENDIX OF WP(C) 714/2019** **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPY OF THE ASSESSMENT ORDER AND DEMAND NOTICE FOR THE YEAR 2015-16 DATED 21.8.2018 ISSUED BY THE 1ST RESPONDENT** WPC No.714/2019 & conn.cases 11 ## **APPENDIX OF WP(C) 120/2019** **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPY OF ASSESSMENT ORDER NO.32150649778/2015-16 DATED 14/12/2018 AND DEMAND NOTICE ISSUED BY THE 1ST RESPONDENT FOR THE ASSESSMENT YEAR 2015-16.** WPC No.714/2019 & conn.cases 12 ## **APPENDIX OF WP(C) 718/2019** ## **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPY OF THE NOTICE DATED 23.11.2018 ISSUED BY 1ST RESPONDENT FOR THE YEAR 201516.** **EXHIBIT P1 A TRUE COPY OF ASSESSMENT ORDER DATED 21.12.18 PASSED BY 1ST RESPONDENT FOR THE YEAR 2016-17. EXHIBIT P2 TRUE COPY OF ASSESSMENT ORDER DATED 21.12.18.PASSED BY 1ST RESPONDENT FOR THE YEAR 2016-17. EXHIBIT P2 A TRUE COPY OF ASSESSMENT ORDER DATED 21.12.18 PASSED BY 1ST RESPONDENT FOR THE YEAR 2016-17. EXHIBIT P3 TRUE COPY OF THE INTERIM STAY ORDER DATED 27.11.2018 BY THIS HON'BLE COURT,IN W.P(c)NO.38273 OF 2018.** WPC No.714/2019 & conn.cases 13 ## **APPENDIX OF WP(C) 40914/2018** **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPY OF NOTICE DATED 3.11.2018 FOR THE YEAR 2011-12 ISSUED BY THE 2ND RESPONDENT** **EXHIBIT P2 TRUE COPY OF NOTICE DATED 3.11.2018 FOR THE YEAR 2012-13 ISSUED BY THE 2ND RESPONDENT EXHIBIT P3 TRUE COPY OF NOTICE DATED 3.11.2018 FOR THE YEAR 2014-15 ISSUED BY THE 2ND RESPONDENT EXHIBIT P4 TRUE COPY OF NOTICE DATED 3.11.2018 FOR THE YEAR 2015-16 ISSUED BY THE 2ND RESPONDENT EXHIBIT P5 TRUE COPY OF NOTICE DATED 3.11.2018 FOR THE YEAR 2016 -17 ISSUED BY THE 2ND RESPONDENT** WPC No.714/2019 & conn.cases 14 ## **APPENDIX OF WP(C) 41054/2018** **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPY OF THE ASSESSMENT ORDER NO.32011063705/07-08 DATED 25/09/2017 ISSUED BY THE 1ST RESPONDENT FOR THE YEAR 2007-08.** **EXHIBIT P2 TRUE COPY OF THE INTERIM ORDER PASSED BY THIS HON'ABLE COURT IN WP(C) NO.11335/2018 DATED 04/04/2018.** WPC No.714/2019 & conn.cases 15 ## **APPENDIX OF WP(C) 41117/2018** **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **TRUE COPIES OF THE ORDERS OF ASSESSMENT DATED 25.9.2018 FOR THE PERIOD 2011-12.** **EXHIBIT P2** **TRUE COPIES OF THE ORDERS OF ASSESSMENT DATED 25.9.2018 FOR THE PERIOD 2012-13.** **EXHIBIT P3** **TRUE COPIES OF THE ORDERS OF ASSESSMENT DATED 25.9.2018 FOR THE PERIODS 2013-14.** **EXHIBIT P4** **TRUE COPY OF THE ENVELOPE ENCLOSING THE ORDERS OF ASSESSMENT BY THE FIRST RESPONDENT ADDRESSED TO THE RESIDENTIAL ADDRESS OF THE PETITIONER.** WPC No.714/2019 & conn.cases 16 ## **APPENDIX OF WP(C) 41465/2018** **PETITIONER'S EXHIBITS:** **EXHIBIT P1** **A TRUE COPY OF THE PENALTY ORDER NO. IB/MPM/ENQ/134/2016-17 ISSUED FOR THE YEAR 2016-17 DATED 12.10.2018** **EXHIBIT P2** **A TRUE COPY OF INTERIM ORDER IN WP(C) NO. 13930/18 DATED 13.4.2018**