Supreme Court of India
COMMISSIONER OF INCOME TAX - ILLversusM/S.CALCUTTA KNITWEARS, LUDHIANA
- Citation
- 2014 INSC 186
- Decided
- 12 March 2014
- Disposal
- Dismissed
Holding
A satisfaction note under Section 15880 may be prepared at the time of initiating proceedings, during the assessment proceedings, or immediately after the assessment of the searched person is completed; the limitation period in Section 158E(2)(b) does not restrict the timing of the satisfaction note.
Summary
The case concerned a search under Section 132 of the Income Tax Act on two premises of the Bhatia Group, which led the assessing officer to record a satisfaction note under Section 15880 on 15 July 2005, after the block assessment of the searched person was completed on 30 March 2005. The respondent, M/s Calcutta Knitwears, challenged the validity of the notice issued under Section 15880, arguing that the satisfaction note should have been prepared before the completion of the assessment proceedings and that the limitation period under Section 158E(2)(b) barred the notice. The Revenue contended that Section 15880 allows the satisfaction note to be prepared at any stage, including after completion of the assessment, and that Section 158E(2)(b) only limits the period for completing the assessment, not for recording the satisfaction. The Supreme Court examined the literal wording of Section 15880 and the purpose of the limitation provision, holding that the legislature did not impose any embargo on the timing of the satisfaction note. Accordingly, the Court held that the satisfaction note may be recorded at the time of initiating proceedings, during the assessment, or immediately after its completion, and remanded the matters to the High Courts for fresh consideration.
Issues considered
- At what stage of the proceedings under Chapter XIV‑8 must the assessing officer record a satisfaction note under Section 15880 before issuing a notice?
- Does the limitation period prescribed in Section 158E(2)(b) apply to the preparation of the satisfaction note under Section 15880?
Legislation cited
- Income Tax Act, 1961s. 15880, s. 158B(b), s. 158BC, s. 158BE(2)(b), s. 158D, s. 158E(2)(b)
Subjects
Income TaxSection 15880satisfaction noteblock assessmentstatutory interpretationliteral rulelimitation periodChapter XIV‑8assessment of undisclosed incomesearch under Section 132
Judgment
[2014] 5 S.C.R. 855
COMMISSIONER OF INCOME TAX - Ill A
v.
MIS.CALCUTTA KNITWEARS, LUDHIANA
(Civil Appeal No. 3958 OF 2014 etc)
MARCH 12, 2014
,8
[H.L. DAITU AND S.A. BOBDE, JJ.]
Income Tax Act, 1961 - Chapter XIV-8, ss.15880 and
158BE(2)(b) - Recording of satisfaction notes for issuing
notice under s. 15880 - At what stage of proceedings under C
Chapter XIV-8, the assessing authority to record such
satisfaction note - ~he High Court opined that it could- .only
be prepared. durif?g the course of the assessment
proceedings u/s. 158BC and not after completion of the
proceedings, in view of the limitation period prescribed uls. D
158BE(2)(b) - Held: A reading of s. 15880 indicates that the
satisfaction note could be prepared by the assessing officer
either at the time of initiating proceedings for completion of
assessment of a searched person u/s. 158BC or during the
stage of the assessment proceedings - But, it does not mean E
that satisfaction note cannot be prepared after completion of
the assessment - The language of the provision is clear and
unambiguous - Legislature has not imposed any embargo
on the Assessing' Officer in respect of the stage of the
proceedings during which the satisfaction is to be reached -
F
s. 158BE(2)(b) only provides for the period of limitation for
completion of block assessment uls. 15880 -. It neither
provides for nor imposes any restrictions or conditions on the
period of limitation for preparation of the satisfaction note ul
s. 15880 and consequent issuance thereof - Reasoning of G
the High Court is contrary to the plain and simple language
employed by the legislature u/s. 15880 which provides
adequate flexibility to the Assessing Officer for recor.cJing the
satisfaction - The satisfaction· note could be prepared either
855 H
856 SUPREME COURT REPORTS [2014] 5 S.C.R.
A (a) at the time of or along with the initiation of proceedings
against the searched person under Section 158BC; (b} along
with the assessment proceedings under $ection 158BC; (c)
immediately after the assessment proceedings are completed
under Section 15BBC of the 'searched person - The matters
B are remanded to the respective High Courts for deciding 'the
matters afresh in the light of the above-mentioned
obse1vations on the scope and interpretation of s. 158 BO.
Interpretation of Statutes - Interpretation of fiscal
legislation - Literal rule or rule of strict interpretation - Held:
C The foremost principle of interpretation of fiscal statutes is the
rule of strict interpretation i.e. to follow the literal rule - The
courts while interpreting provisions of fiscal legislation should
neither add nor subtract a word from the provisions of instant
meaning of the section - Departure from the literal rule would
D lead to free play to each Judge to put his own interpretation
which would be destructive of the edifice of the fiscal
legislations - In taxing statutes, even if the literal
inte1pretation results in hardship or inconvenience, it has to
be followed - The language of a taxing statute should
E ordinarily be read and understood in the sense in which it is
harmonious with the object of the statute to effectuate the
legislative animation - A common sense approach, equity,
logic, ethics and morality have no role to play while
interpreting a taxing statute.
F
CIT v. Keshab Chandra Manda/ AIR 1950 SC 265: 1950
SCR 435; Pandian Chemicals Ltd. v. C. I. T. .2003(5) SCC
590; Narsiruddin v. Sita Ram Agarwal AIR 2003 SC 1543:
2003 (1) SCR 634; Bhaiji v. Sub-Divisional Officer, Th and/a
G 2003(1) SCC 692: 2002 (5) Suppl. SCR 116; J.P. Bansal
v. State of Rajasthan and Anr. AIR 2003 SC 1405; State of
Jharkhand and Anr. v. Govind Singh JT 2004(10) SC 349;
Jinia Keotin v. K. S. Manjhi 2003 (1-) SCC 730: 2002 (5)
Suppl. SCR 689; Shiv Shakti Co-operative Housing Society
H v. Swaraj Developers AIR 2003 SC 2434: 2003 (3) SCR 762;
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 857
KNITWEARS, LUDHIANA
Grasim Industries Limited v. Collector of Customs 2002 (4) A
SCC 297: 2002 (2) SCR 945; Union of India v. Hamsoli Devi
2002 (7) SCC 273: 2002 (2) Suppl. SCR 324; Prakash
Nath Khanna v. C.I. T. 2004 (9) SCC 686: 2004 (2 )
SCR 434; Delhi Financial Corporation v. Rajiv Anand 2004
(11) SCC 625; Government of Andhra Pradesh v. Road B
Rollers Owners Welfare Association 2004(6) SCC 210; B.
Premanand and Ors. v. Mohan Koikal and Ors. (2011) 4 SCC
266: 2011 (3) SCR 932; J. Srinivasa Rao v. Govt. of A.P. and
Anr. 2006(13) SCALE 27; Raja Jagadambika Pratap Narain
Singh v. C.B.D. T. [1975] 100 ITR 698 (SC); Swedish Match c
AB v. Securities and Exchange Board, India AIR 2004 SC
4219: 2004 (3) Suppl.SCR 745; CIT v. Ajax Products Ltd.
(1965) 55 ITR 74,1 (SC) - relied on.
Federal Commissioner of Taxation v. Westraders Pty Ltd.
(1980) 144 CLR 55; Inland Revenue Commissioners v. D
Westminster (Duke), [1936] AC 1; Cooper Brookes
(Wollongong) Pty Ltd v. Federal Commissioner of Taxation
(1981) 147 CLR 297; C & J Clark Ltd v. Inland Revenue
Commissioners [1975] 1 ,WLR 413; BP Refinery
(Westernport) Pty Ltd v. Hastings Shire, (1977) 180 CLR 266; E
Hepp/es v. FCT (1991) 173 CLR 492; The Cape Brandy
Syndicate v. Inland Revenue Commissioners (1921) 1 KB
64; Commissioner of Stamp Duties (NSW) v. Simpson (1917)
24 CLR 209; Viscount Haldane in Lumsden v Inland
Revenue Commissioners (1914) AC 877; Grundy v. F
Pinniger (1852) 1 LJ Ch 405 - referred to.
Principles of Statutory Interpretations by G.P. Singh, 12th
Ed, 201 O; Lexis Nexis Butterworths Wadhwa Nagpur,
Bennion on Statutory Interpretation, 5th Ed., Lexis Nexis, G
p. 863; Interpretation of Statutes by Vepa P. Sarathi, 5th Ed.,
Easter Book Company, Chapter VIII, Taxing Statutes -.
referred to.
Interpretation of Statutes - Interpretation of
machinery provision of a taxing statute - While H
SUPREME COURT REPORTS [2014] 5 S.C.R.
A interpreting a machinery provision, the courts would
interpret a provision in such a manner that it would give
meaning to the charging provisions - The machinery
provisions should be liberally construed by the courts -
Whenever, the intention to impose liability is clear, the
B machinery provision must be so construed as would
effectuate the object and purpose of the statute and not
defeat the same.
Mahim Patram Private Ltd. v. Union of India (UOI) and
C Ors. (2007) 3 SCC 668: 2007 (3) SCR 73; J. Srinivasa
Rao v. Govt. of Andhra Pradesh and Anr. 2006 (13) SCALE
27; Gursahai Saiga/ v. Commissioner of Income-tax,
Punjab (1963] 1 ITR 48 (SC); /spat Industries Ltd.
v. Commissioner of Customs, Mumbai, 2006 (202)
ELT561(SC); J.K. Synthetics Limited and Bir/a Cement
D Works and another v. Commercial Taxes Officer and another
(1994) 4 SCC 276; CIT v. Mahaliram Ramjidas (1940) 8 ITR
442; Indian United Mills Ltd. v. Commissioner of Excess
Profits Tax, Bombay (1955] 27 ITR 20(SC); Gursahai Saigal
v. CIT, Punjab (1963] 1 ITR 48(SC); Commissioner of
E Wealth Tax, Meerut v. Sharvan Kumar Swarup & Sons (1994)
6 SCC 623: 1994 (3) Suppl. SCR 750; CIT v. National Taj
Traders (1980) 1 SCC 370: 1980 (2) SCR 268; Associated
Cement Company Ltd. v. Commercial Tax Officer, Kata and
Ors. (48) STC 466 - relied on.
F
Whitney v. Commissioners of Inland Revenue 1926 AC
37 - referred to.
Bennion on Statutorylnterpretation by Francis Bennion,
5th Ed. - referred to.
G
Case Law Reference:
2004 (3) Suppl.SCR 745 relied on Para 23
(1965) 55 ITR 741 (SC) relied on Para 23
H
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 859
KNITWEARS, LUDHIANA
2003(5) sec 590 relied on Para 23 A
(1921) 1 KB 64 referred to Para 24
(1917) 24 CLR 209 referred to Para 25
(1914) AC 877 referred to Para 25
B
(1852) 1 LJ Ch 405 referred to Para 26
1950 SCR 435 relied on Para 27
2003 (1) SCR 634 relied on Para 27
c
2002 (5) Suppl. SCR 116 relied on Para 27
AIR 2003 SC 1405 relied on Para 27
JT 2004(10) SC 349 relied on Para 2i
2002 (5) Suppl. SCR 689 relied on Para 27 D
2003 (3) SCR 762 relied on Para 27
2002 (2) SCR 945 relied on Para 27
2002 (2) Suppl. SCR 324 relied on Para 27 E
[1975] 1 WLR 413 referred to Para 29
(1977) 180 CLR 266 referred to Para 29
2004 (2) SCR 434 relied on Para 32
F
2004 (11 > sec 625 relied on Para 32
2004(6) sec 21 o relied on Para 32
2011 (3) SCR 932 relied on Para 33
G
2006(13) SCALE 27 relied on Para 34
[1975] 100 ITR 698 (SC) relied on Para 34
[1936] AC 1 referred to Para 28
H
860 SUPREME COURT REPORTS [2014] 5 S.C.R.
A (1981) 147 CLR 297 referred to Para 29
(1991) 173 CLR 492 referred to Para 30
2004 (2) SCR 434 referred to Para 32
2007 (3) SCR 73 relied on Para 35 ·
B
2006 (13) SCALE 27 relied on Para 35
2006 (202) ELT561 (SC) relied on Para 35
(1994) 4 sec 276 relied on Para 35
c
(1940) 8 ITR 442 relied on Para 36
[1963] 1 ITR 48 (SC) relied on Para 37
[1955] 27 ITR 20(SC) relied on Para 37
D [1963] 1 ITR 48(SC) relied on Para 37
1994 (3) Suppl. SCR 750 relied on Para 37
1980 (2) SCR 268 relied on Para 37
E (48) STC 466 relied on Para 37
CIVIL APPELLATE JURISDICTON : Civil Appeal No.
3958 of 2014.
From the Judgment & Order dated 20.07.2010 of the High
F Court of Punjab & Haryana at Chandigarh in ITA No. 154 of
2010.·
WITH
C.A. No. 3959, 3960, 3961, 3962, 3963, 3964, 3965, 3966,
G 3967,3968, 3969, 3970, 3971, 3972, 3973, 3974, 3975, 3976,
3977,3978, 3979, 3980, 3981,3982, 3983, 3984, 3985,3986,
3987, 3988, 3989, 3990 and 3991 of 2014.
AND
H
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 861 ·
KNITWEARS, LUDHIANA
S.L.P (C) No. 7741 of 2013. A
Rupesh Kumar, Arijit, Prsad,'Gf1rgi Khanna, Anil Katiyar
(B.V. Balaram Oas), Ajay Vohra, Rishi Kr. Duggar, Kavita Jha,
Mahesh Agarwal, Abhinav Agrawal (for E.C. Agrawala), for the
Appellant.
B
R.P. Bhatt, Sandhya Goswami, E>ivya Suri, D.K. Goyal,
M.K. Choudhary (for Namita Choudhary), P.N. Monga, Manu
Monga, S.S. Ray, Vaibhav G. (for Rakhi Ray) Salil Kapoor,
Vikas Jain, Hardeep Kaur (for Kamal Mohan Gupta), Dr.
Rakesh Gupta, Rishabh Kapoor, Rani Kiyala, Ambhoj Kumar C
Sinha, Anil Katiyar, H. Raghavendra Rao, Anupam Tripathi,
Puneet Kapur, Govind K. Chaturvedi (for Nikhil Jain), for the
Respondent.
The Order of the Court was delivered D
ORDER
1. Delay, if any, in filing and refiling the Special Leave
Petitions is condoned.
E
2. Leave granted.
3. The issue that falls for our consideration and decision
in all these appeals is: at what stage of the proceedings under
Chapter XIV-8 does the assessing authority require to record
his satisfaction for issuing a notice under Section 15880 of F
the Income Tax Act, 1961 ('the Act' for short).
4. Since the issue is common in all these appeals, after
hearing the learned counsel for the parties to the lis, we dispose
of all these appeals by this common order. G
5. For the purpose of disposal of these appeals, we take
the Civil Appeal@ Special Leave Petition (Civil) No.10542 of
2011 as the lead case.
Civil Appeal No.3958 of 2014 @S.L.P.(C)No.10542/2011: H
862 SUPREME COURT REPORTS [2014) 5 S.C.R.
A 6. The respondent in this appeal is a firm engaged in
manufacturing hosiery goods in the name and style of M/s.
Calcutta Knitwears.
7. A search operation under Section 132 of the Act was
carried out in two premises of the Bhatia Group, namely, M/s.
B
Swastik Trading Company and Mis. Kavita International
Company on 05.02.2003 and certain incriminating documents
pertaining to the assessee firm were traced in the said search.
8. After completion of the investigation by the investigating
C agency and handing over of the documents to the assessing
authority, the assessing authority had completed the block
assessments in the case of Bhatia Group. Since certain other
documents did not pertain to the person searched under
Section 132 of the Act, the assessing authority thought it fit to
o transmit those documents, which according to him, pertain to
the "undisclosed income" on account of investment element and
profit element of the assessee firm and require to be assessed
under Section 1588C read with Section 158BO of the Act to
another assessing authority in whose jurisdiction the
E assessments could be completed. In doing so, the assessing
authority had recorded his satisfaction note dated 15.07.2005.
9. The jurisdictional assessing authority for the respondent-
assessee had issued the show cause notice under Section
158BO for the block period 01.04.1996 to 05.02.2003, dated
F 10.02.2006 to the assessee inter alia directing the assessee
to show cause as to why should the proceedings under Section
158BC not be completed. After receipt of the said notice, the
assessee firm had filed its return under Section 15880 for the
said block period declaring its total income as Nil and further
G filed its reply to the said notice challenging the validity of the
said notice under Section 15880, dated 08.03.2006. The
assessee had taken the stand that the notice issued to tt,ie
assessee is (a) in violation of the provisions of Section 15880
as the conditions precedent have not been complied with by
H the assessing officer and (b) beyond the period of limitation
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 863
KNITWEARS, LUDHIANA
as provided for under Section 1588E read with Section 15880 A
and therefore, no action could be initiated against the assessee
and accordingly, requested the assessing officer to drop the
proceedings.
10. The assessing authority, after due consideration of the 8
reply filed to the show cause notice, has rejected the aforesaid
stand of the assessee and assessed the undisclosed income
as Rs. 21,76,916/- (Rs.16,05,744/- (unexplained investment)
and Rs.5, 71, 172/- (profit element)) by order dated 08.02.2008.
The assessing officer is of the view that Section 1588E of the C
Act does not provide for any limitation for issuance of notice
and completion of the assessment proceedings under Section
1588D of the Act and therefore a notice could be issued even
after completion of the proceedings of the searched person
under Section 1588C of the Act.
D
11. Disturbed by the orders passed by the assessing
officer, the assessee firm had carried the matter in appeal
before the Commissioner of Income Tax (Appeal-II) (for short
'the CIT(A)'). The CIT(A), while rejecting the stand of the
assessee in respect of validity of notice issued under Section E
1588D, has partly allowed the appeal filed by the assessee
firm and deleted the additions made by the assessing officer
in its assessments, by his order dated 27.08.2008.
12. The Revenue had carried the matter further by filing
F
appeal before the Income Tax Appellate Tribunal (for short 'the
Tribunal') and the assessee has filed cross objections therein.
The Tribunal, after hearing the parties to the lis, has rejected
the appeal of the Revenue and observed that recording of
satisfaction by the assessing officer as contemplated under
Section 15880 was on a date subsequent to the framing of G
assessment under Section 1588C in case of the searched
person, that is, beyond the period prescribed under Section
1588E(1 )(b) and thereby the notice issued under Section
15880 was belated and consequently the assumption of
864 SUPREME COURT REPORTS [2014] 5 S.C.R.
A jurisdiction by the assessing authority in the impugned block
assessment would be invalid, by order dated 23.04.2009.
13. Aggrieved by the order so passed by the Tribunal, the
Revenue had carried the matter in appeal under Section 260A
8 of the Act before the High Court. The High Court, by its
impugned judgment and order dated 20.07.2010, has rejected
the r~evenue's appeal and confirmed the order passed by the
Tribunal.
14. That is how the Revenue is before us in this appeal.
c
15. We have heard Shri Rupesh Kumar learned counsel
for the Revenue and Shri R.P.Bhatt, Shri Ajay Vohra, Shri
Santosh Krishan, learned counsel and other learned counsel
for the respective assessees-respondents.
D
16. Shri Rupesh Kumar, learned counsel for the Revenue
would contend that the assessing authority, after completion of
the assessment proceedings against the searched person
under Section 158BC, being of the opinion that the other
documents which have surfaced at the time of the search under
E Section 132 of the Act belong to a person other than the
searched person had recorded his satisfaction in the said 1
respect and transmitted the papers to the jurisdictional
assessing officer for the assessments of such person other
than the searched person. Further, he would submit that the
F assessing officer has complied with the requirements of
Section 15880 of the Act in its entirety while preparing the
satisfaction note and transmitting the documents to the
jurisdictional assessing officer and therefore, the Tribunal and
the High Court were not justified in holding that the satisfaction
G. note ought to have been prepared by the assessing officer
before the completion of the assessment proceedings of the .
searched person under Section 158BC of the Act and that the
notice issued under Section 15880 was belated. ·
H 17. Per contra, Shri Bhatt, learned senior counsel and Shri
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 865
KNITWEARS, LUDHIANA
Ajay Vohra and Shri Santosh Krishan learned counsel for the A
assessees would state that a satisfaction note requires to be
made by the assessing officer before the seized documents
were transmitted to another assessing officer in whose
jurisdiction the person other than the searched person is
assessed and submit that the said satisfaction note should be B
recorded before the assessment proceedingeJlf the searched
person are completed under Section 158BC of the Act and not
later in time. By saying so, the learned counsel would justify the
reasoning and the conclusion reached by the Tribunal as well
as the High Court. c
18. In order to resolve the controversy, certain provisions
of the Act require to be noticed by us.
19. Chapter XIV-B of the Act is a special provision carved
out by the legislature for the purpose of the assessments in D
cases pertaining to Sections 132 and 132A of the Act. The said
chapter was introduced by the Finance Act, 1995 with effect
from 01.07.1995 and comprises Sections 1588 to 158BH of
the Act. The provisions under this Chapter were made
inapplicable in case of search initiated under Section 132 or E
Section 132A after 31.05.2003 by introduction of an
amendment to the Chapter as Section 15881 vide the Finance
Act, 2003 with effect from 01.06.2003. The lis before us
requires examination of the provisions of the said Chapter,
particularly Section 15880. F
20. Section 1588 of the Act is the dictionary clause. It
provides for the definition of 'block period" and "undisclosed
income". For the purpose of this case, a reference to the
definition of the "undisclosed inco,me" as provided for in Section
158B(b) is necessary and, therefore, it is noticed. The same G
reads as under:
"Undisclosed income" includes any money, bullion,
jewellery or other valuable article or thing or any income
based on any entry in the books of account or other H
866 SUPREME COURT REPORTS [2014] 5 S.C.R.
A documents or transactions, where such money, bullion,
jewellery, valuable article, thing, entry in the books of
account or other document or transaction represents wholly
or partly income or property which has not been or would
not have been disclosed for the purposes of this Act [or
B any expense, deduction or allowance claimed under this
Act which is found to be false]".
21. Sections 158BC and 15880 of the Act are machinery
provisions. Section 158BC of the Act provides the procedure
for block assessment and Section 15880 of the Act provides
C for assessments in the case of an undisclosed income of any
other person. The said sections are relevant for the purpose
of this case and, therefore, they are extracted. They read as
under:
D "Section 158BC. PROCEDURE FOR BLOCK
ASSESSMENT.
Where any search has been conducted under section 132
or books of account, other documents or assets are
requisitioned under section 132A, in the case of any
E
person, then, -
[(a) The Assessing Officer shall,
(i) In respect of sear~h initiated or books of acco1:1nt or
F other documents or any assets requisitioned after the 30th
day of June, 1995 but before the 1st day of January, 1997
serve a notice to such person requiring him to furnish
within such time not being less than fifteen days;
(ii) In respect of search initiated or books of account or
G other documents or any assets requisitioned on -or after
the 1st day of January, 1997, serve a notice to such person
requiring him to furnish within such time not being less than
fifteen days but not more than forty-five days,
H
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 867
KNITWEARS, LUDHIANA
as may be specified in the notice a return in the prescribed A
form and verified in the same manner as a return under
clause (i) of sub-section (1) of section 142, setting forth
his total income including the undisclosed income for the
block period:
8
Provided that no notice under section 148 is required to
be issued for the purpose of proceeding under this
Chapter:
Provided further that a person who has furnished a return
under this clause shall not be entitled to file a revised C
return;]
(b) The Assessing Officer shall proceed to determine the
undisclosed income of the block period in .the manner laid
down in section 15888 and the provisions of section 142, o
sub-sections (2) and (3) of section 143 [section 144 and
section 145]shall, so far as may be, apply;
(c) The Assessing Officer, on determination of the
undisclosed income of the block period in accordance with
this Chapter.: shall pass an order of assessment and E
determine the tax payable by him on the basis of such
assessment;
(d) The assets seized under section 132 or requisitioned
under section 132A shall be dealt with in accordance with F
the provisions of section 1328.]
*** *** ***
Section 1588D. UNDISCLOSED INCOME OF ANY
OTHER PERSON. G
Where the Assessing Officer is satjsfied that any
undisclosed income belongs to any person, other than the
person with respect to whom search was made under
section 132 or whose books of account or other H
868 SUPREME COURT REPORTS [2014] 5 S.C.R.
A documents or any assets were requisitioned under section
132A then, the books of account, other documents or
assets seized or requisitioned shall be handed over to the
Assessing Officer having jurisdiction over such other
person and that Assessing Officer shall proceed [under
B section 158 BC] against such other person and the
provisions of this Chapter shall apply accordingly."
22. Section 158BC speaks of procedure for assessment
of a person searched under Section 132 of the Act or books
C of accounts, other documents or assets are requisitioned under
section 132A. The limitation for the purpose of completion of
the block assessments for the purpose of Section 158BC of
the Act issas provided under Section 158BE(1 )(a) of the Act,
that is the time limit for completion of block·assessment.
D 23. Section 158BD of the Act provides for "undisclosed
income" of any other person. Before we proceed to explain the
said provision, we intend to remind ourselves of the first or the
basic principles of interpretation of a fiscal legislation. It is time
and again reiterated that the courts, while interpreting the
E provisions of a fiscal legislation should neither add nor subtract
a word from the provisions of instant meaning of the sections.
It may be mentioned that the foremost principle of interpretation
of fiscal statutes in every system of interpretation is the rule of
strict interpretation which provides that where the words of the
F statute are absolutely clear and unambiguous, recourse cannot
be had to the principles of interpretation other than the literal
rule (Swedish Match AB v. Securities and Exchange Board,
India, AIR 2004 SC 4219, CIT v. Ajax Products Ltd. [1965] 55
ITR 741 ·(SC)).
G 24. We may gainfully refer to The Cape Brandy Syndicate
v. Inland Revenue Commissioners [1921] 1 KB 64 at 71
which involved the Finance (No. 2) Act 1915 which imposed
excess profits duty on trade or businesses commenced after
the outbreak of the First World War in 1914. By subjecting the
H
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 869
KNITWEARS, LUDHIANA
legislation to a strict literal interpretation, Rowlatt J. held that A
the Finance (No. 2) Act 1915, in isolation, did not apply to
businesses that commenced after the outbreak of war in 1914
and observed as follows:
" ... the principle in favour of .a strict literal approach . . . 8
simply means that in a taxing Act one has to look merely
at what is clearly said. There is no room for any
intendment. There is no equity about a tax. There is no
presumption as to a tax. Nothing is to be read in, nothing
is to be implied. One can only look fairly at the language C
used."
25. In Commissioner of Stamp Duties (NSW) v.
Sir;npson, (1917) 24 CLR 209 Barton J., citing Viscount
Haldane in Lumsden v Inland Revenue Commissioners,
[1914] AC 877, stated the following: D
"The duty of Judges in construing Statutes is to adhere
to the literal construction unless the context renders it plain
that such a construction cannot be put on the words. This
rule is especially important in cases of Statutes which
E
impose taxation."
The Court in Simpson case (supra) sought to determine
whether a deed poll constituted a settlement for the
purposes of Section 49 of the Stamp Duties Act, 1898
(NSW). Section 3 which defined the word 'settlement' as F
meaning 'any contract or agreement' was examined. The
Court by adopting a strict literal approach held that only a
contract or an agreement could constitute a settlement and
that Section 49 providing for deed poll was not applicable
and therefore, the taxpayer did not have to pay any stamp G
duty.
26. Lord Granworth in Grundy v. Pinniger, (1852) 1 LJ Ch
405 has observed that:
"To adhere as closely as possible to the literal meaping H
870 SUPREME COURT REPORTS [2014] 5 S.C.R.
A of the words used, is a cardinal rule from which if we
depart we launch into a sea of difficulties which it is not
easy to fathom."
That is to say, once the literal rule is departed, then any
B number of interpretations can be put to a statutory provision,
each Judge having a free play to put his own interpretation as
he likes. This would be destructive of the edifice of fiscal
legislations which impose economic duties and sanctions.
27. In taxing statutes, even if the literal interpretation
C results in hardship or inconvenience, it has to be followed (G.P.
Singh's Principles of Statutory Interpretations, 12th Ed, 2010,
Lexis Nexis Butterworths Wadhwa Nagpur; Bennion on
Statutory Interpretation, 5th E~i'.. Lexis Nexis, p. 863; Vepa P.
Sarathi, Interpretation of ${atutes, 5th Ed., Easter Book
D Company, Chapter VIII, Ta~ng Statutes). This Court in CIT v.
Keshab Chandra Manda/, Al R 1950 SC 265 has held that
hardship or inconvenience cannot alter the meaning of the
language employed by the legislature if such meaning is clear
and apparent. Hence departure from the literal rule should only
E be done in very rare cases, and ordinarily there should be
judicial restraint to do so.(Pandian Chemicals Ltd. v. C.I. T.,
2003(5) SCC 590, Narsiruddin v. Sita Ram Agarwal, AIR 2003
SC 1543, Bhaiji v. Sub-Divisional Officer, Thandla, 2003(1)
SCC 692, J.P. Bansal v. State of Rajasthan and Anr., AIR 2003
F SC 1405, State of Jharkhand and Anr. v. Govind Singh : JT
2004(10) SC 349, Jinia Keotin v. K.S. Manjhi, 2003 (1) SCC
730, Shiv Shakti Co-operative Housing Society v. Swaraj
Developers, AIR 2003 SC 2434, Grasim Industries Limited
v. Collector of Custom~, 2002 (4) SCC 297 and Union of India
G v. Hamsoli Devi, 2002 (7) SCC 273)
28. The Australian High Court in Federal Commissioner
of Taxation v. Westraders Pty Ltd, (1980) ·144 CLR 55
considered the scope of Section 36A of the Income Tax
Assessment Act, 1936(Cth}, which on a literal interpretation
H allowed the taxpayer to make a profit and still claim a loss
COMMISSIONER OF INCOME TAX - Ill v. CALCUTIA 871
KNITWEARS, LUDHIANA
for tax purposes. The Commissioner argued the taxpayer's A
conduct amounted to a tax avoidance scheme and should
therefore be disallowed under Section 260 of the Income Tax
Assessment Act, 1936(Cth). The Court held that under a
literal interpretation Section 36A could apply to allow the
taxpayer to claim a loss. Barwick CJ, speaking for the majority B
relied on the decision in Inland Revenue Commissioners v.
Westminster (Duke), [1936] AC 1 which advocated the literal
approach be applied when interpreting taxation legislation and
stated the following:
"It is for the Parliament to specify, and to do so, in my C
opinion, as far as language will permit, with unambiguous
clarity, the circumstances which will attract an obligation
on the part of the citizen to pay tax. The function of the court
is to interpret and. apply the language in which the
Parliament has specified those circumstances. The court D
is to do so by determining the meaning of the words
employed by the Parliament according to the intention of
the Parliament which is discoverable from the language
used by the Parliament. It is not for the court to mould or
to attempt to mould the language of the statute so as to E
produce some result which it might be thought the
Parliament may have intended to achieve, though not
expressed in the actual language employed"
29. In Cooper Brookes (Wollongong) Pty Ltd v. Federal F
Commissioner of Taxation (1981) 147 CLR 297 it is held that
in a taxing statute if the language is unambiguous, departing
from the literal approach 'may lead judges to put their own ideas
of justice or social policy in place of the words of the statute'.
Similar view was espoused in C & J Clark Ltd v. Inland G
Revenue Commissioners, [1975] 1 WLR 413 and BP
Refinery (Westernport) Pty Ltd v. Hastings Shire, (1977) 180
CLR 266.
30. In Hepp/es v. FCT, (1991) 173 CLR 492, the High
Court of Australia unequivocally favoured the principle that H
872 SUPREME COURT REPORTS [2014] 5 S.C.R.
A taxation legislation should be subject to a strict literal
interpretation and opined that such an approach was supported
by 'common sense'. Therein, the taxpayer, on ceasing to be
employed, was paid $40,000 by his employer in exchange for
the taxpayer agreeing that he would not carry on or be
B interested in certain businesses and would not divulge any trade
secrets. The issue before the Court was whether or not such
payment would form part of the taxpayer's assessable income
for the purposes of the Income Tax Assessment Act, 1936(Cth).
It was held that since the Act did not provide for such payments
c to form part of a taxpayer's assessable income, the payment
would not be assessable.
31. This Court in Tata Consultancy Services v. State of
Andhra Pradesh has ascribed plain meaning to the terms
computer and computer programme in a fiscal statute and
D reiterating the proposition laid down in Inland Revenue
Commissioner case (supra), observed that a court should not
be over zealous in searching ambiguities or obscurities in
words which are plain.
E 32. In Prakash Nath Khanna v. C.I. T., 2004 (9) SCC 686,
this Court has explained that the language employed in a
statute is the determinative factor of the legislative intent. The
legislature is presumed to have made no mistake. The
presumption is that it intended to say what it has said. Assuming
F there is a defect or an omission in the words used by the
legislature, the Court cannot correct or make up the deficiency.
Where the legislative intent is clear from the language, the Court
should give effect to it (Delhi Financial Corporation v. Rajiv
Anand, 2004 (11) SCC 625; Government of Andhra Pradesh
G v. Road Rollers Owners Welfare Association, 2004(6) SCC
210).
33.ln 8. Premanand and Ors. v. Mohan Koikal and Ors.,
(2011 )4 SCC 266 this Court has observed as follows:
H "32. The literal rule of interpretation really means that there
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 873
KNITWEARS, LUDHIANA
should be no interpretation. In other words, we should read A
the statute as it is, without distorting or twistjng its
language.
33. We may mention here that the literal rule of
interpretation is not only followed by Judges and lawyers,
8
but it is also followed by the lay man in his ordinary life. To
give an illustration, if a person says "this is a pencil", then
he means that it is a pencil; and it is not that when he says
that the object is a pencil, he means that it is a horse,
donkey or an elephant. In other words, the literal rule of
interpretation simply means that we mean what we say . c.
and we say what we mean. If we do not follow the literal
rule of interpretation, social life will become impossible,
and we will not understand each other. If we say that a
certain object is a book, then we mean it is a book. If we
say it is a book, but we mean it is a horse, table or an D
elephant, then we will not be able to communicate with
each other. Life will become impossible. Hence, the
meaning of the literal rule of interpretation is simply that
we mean what we say and we say what we mean."
E
34. Thus, the language of a taxing statute should ordinarily
be read understood in the sense in which it is harmonious with
the object of the statute to effectuate the legislative animation.
A taxing statute should be strictly construed; common sense
approach, equity, logic, ethics and morality have no role to play. F
Nothing is to be read in, nothing is to be implied; one can only
look fairly at the language used and nothing more and nothing
less. (J. Srinivasa Rao v. Govt. of A.P. and Anr. 2006(13)
SCALE 27, Raja Jagadambika Pratap Narain Singh
v. C.B.D. T., [1975] 100 ITR 698(SC))
G
35. It is also trite that while interpreting a machinery
provision, the courts would interpret a provision in such a way
that it would give meaning to the charging provisions and that
the machinery provisions are liberally construed by the courts.
In Mahim Patram Private Ltd. v. Union of India (UOI) and Ors., H
874 SUPREME COURT REPORTS [2014] 5 S.C.R.
A (2007) 3 SCC 668 this Court has observed that:
"20. A taxing statute indisputably is to be strictly
construed. [See J. Srinivasa Rao v. Govt. of Andhra
Pradesh and Anr., 2006(13)SCALE 27]. It is, however,
B also well-settled that the machinery provisions for
calculating the tax or the procedure for its calculation are
to be construed by ordinary rule of construction. Whereas
a liability has been imposed on a dealer by the charging
section, it is we/I-settled that the court would construe the
statute in such a manner so as to make the machinery
c workaf;ifif:··
21. In J..:Srinivasa Rao (supra), this Court noticed the
decisions of this Court in Gursahai v.Commissioner of
Income-tax·, Punjab, [1963] 1 ITR 48(SC) and /spat
D Industries Ltd. v. Commissioner of Customs, Mumbai,
2006(202)ELT561(SC).ln Gursahai Saiga/ (supra), the
question which fell for consideration before this Court was
construction of the machinery provisions vis-a-vis the
:{ charging provisions. Schedule appended to the Motor
E Vehicles Act is not machinery provision. It is a part of the
charging provision. By giving a plain meaning to the
Schedule appended to the Act, the machinery provision
does not become unworkable. It did not prevent the clear
intention of the legislature from being defeated. It can be
F given an appropriate meaning."
36. A reference to the observations of this Court in J.K.
Synthetics Limited and Bir/a Cement Works and another v.
Commercial Taxes Officer and another,(1994) 4 SCC 276
would be apposite:
G
"13. It is well-known that when a statute levies a tax it does
sb by inserting a charging section by which a liability is
created or fixed a,nd then proceeds to provide
the machinery to make the liability effective. It, therefore,
H provides the machinery for the assessment of the liability
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 875
KNITWEARS, LUDHIANA
already fixed by the charging section, and then provides A
the mode for the recovery and collection of tax, including
penal provisions meant to deal with defaulters ....
Ordinarily the charging section which fixes the liability is
strictly construed but that rule of strict construction is not
extended to the machinery provisions which are construed B
like any other statute. The machinery provisions must, no
doubt, be so construed as would effectuate the object and
purpose of the statute and not defeat the same. (Whitney
v. Commissioners of Inland Revenue 1926 AC 37, CIT
v. Mahaliram Ramjidas (1940) 8 ITR 442, Indian United c
Mills Ltd. v. Commissioner of Excess Profits Tax,
Bombay, [1955] 27 ITR 20(SC) and Gursahai Saigal
v. CIT, Punjab, [1963] 1 ITR 48(SC)."
37. It is the duty of the court while inter"preting
the machinery provisions of a taxing statute to give effect to its D
manifest purpose. Wherever the intention to impose liability is
clear, the Courts ought not be hesitant in espousing a
commonsense interpretation to the machinery provisions so that
the charge does not fail. The machinery provisions must, no
doubt, be so construed as would effectuate the object and E
purpose of the statute and not defeat the same (Whitney v.
Commissioners of Inland Revenue 1926 A C 37 , CIT v.
Mahaliram Ramjidas (1940) 8 ITR 442, Indian United Mills
Ltd. v. Commissioner of Excess Profits Tax, Bombay [1955]
27 ITR 20(SC), and Gursahai Saigal v. CIT, Punjab [1963] 1 F
ITR 48(SC); Commissioner of Wealth Tax, Meerut v. Sharvan
Kumar Swarup & Sons, (1994) 6 SCC 623; CIT v. National
Taj Traders, (1980) 1 SCC 370; Associated Cement
Company Ltd. v. Commercial Tax Officer, Kofa and Ors., (48)
STC 466). Francis Bennion in Bennion on G
Statutory Interpretation, 5th Ed., Lexis Nexis in support of the
aforesaid proposition put forth as an illustration that since
charge made by the legislator in procedural provisions is
excepted to be for the general benefit of litigants and others, it
H
876 SUPREME COURT REPORTS [2014J 5 S.C.R.
A is presumed that it applies to pending· as well as future
proceedings.
38. Having said that, let us revert to discussion of Section
15880 9f the Act. The said provision is.a machinery provision
8 and inserted in the statute book for the purpose of carrying out
assessments of a person other than the searched person under
Sections 132 or 132A of the Act. Under Section 15880 of the
Act, if an officer is satisfied that there exists any undisclosed
income which may belong to a other person other than the
C searched person under Sections 132 or 132A of the Act, after
recording such satisfaction, may transmit the records/
documents/chits/papers etc to the assessing officer having
jurisdiction over such other person. After receipt of the
aforesaid satisfaction and upon examination of the said other
documents relating to such other person, the jurisdictional
O assessing officer may proceed to issue a notice for the
purpose of completion of the assessments under Section
15880 of the Act, the other provisions of XIV-8 shall apply.
39. The opening words of Section 15880 of the Act are
E that the assessing officer must be satisfied that "undisclosed
income" belongs to any other person other than the person with
respect to whom a search was made under Section 132 of the
Act or a requisition of books were made under Section 132A
of the Act and thereafter, transmit the records for assessment
F of such other person. Therefore, the short question that falls for
our consideration and decision is at what stage of the
proceedings should the satisfaction note be prepared by the
assessing officer: whether at the time of initiating proceedings
under Section 1588C for the completion of the assessments
G of the searched person under Section 132 and 132A of the Act
or during the course of the assessment proceedings under
Section 1588C of the Act or after completion of the
proceedings under Section 1588C of the Act.
40. The Tribunal and the High Court are of the opinion that
H it could only be prepared by the assessing officer during the
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 877
KNITWEARS, LUDHIANA
course of the assessment proceedings under Section 1588C A
of the Act and not after the completion of the said proceedings.
The Courts below have relied upon the limitation period
provided in Section 1588E(2)(b) of the Act in respect of the
assessment proceedings initiated under Section 15880, i.e.,
two years from the end of the month in which the notice under 8
Chapter XIV-8 was served on such other person in respect of
search initiated or books of account or other documents or any
assets are requisitioned On or after 01.01.1997. We would
examine whether the Tribunal or the High Court are justified in
coming to the aforesaid conclusion. c
41. We would certainly say that before initiating
proceedings under Section 15880 of the Act, the assessing
officer who has initiated proceedings for completion of the
assessments under Section 158BC of the Act should be
satisfied that there is an undisclosed income which has been 0
traced out when a person was searched under Section 132 or
the books of accounts were requisitioned under Section 132A
of the Act. This is in contrast to the provisions of Section 148
of the Act where recording of reasons in writing are a sine qua
non. Under Section 15880 the existence of cogent and E
demonstrative material is germane to the assessing officers'
satisfaction in concluding that the seized documents belong to
a person other than the searched person is necessary for
initiation of action under Section 15880. The bare reading of
the provision indicates that the satisfaction note could be F
prepared by the assessing officer either at the time of initiating
proceedings for completion of assessment of a searched
person under Section 158BC of the Act or during the stage of
the assessment proceedings. It does not mean that after
completion of the assessment, the assessing officer cannot G
prepare the satisfaction note to the effect that there exists
income tax belonging to any person other than the searched
person in respect of whom a search was made under Section
132 or requisition of books of accounts were made·· under
Section 132A of the Act. The language of the provision is clear H
878 SUPREME COURT REPORTS [2014] 5 S.C.R.
A and unambiguous. The legislature has not imposed any
embargo on the assessing officer ip respect of the stage of
proceedings during which the satisfaction is to be reached and
recorded in respect of th~ person other than the searched
person.
8
42. Further, Section 1588E(2)(b) only provides for the
period of limitation for completion of block assessment under
section 15880 in case of the person other than the searched
person as two years from the end of the month in which the
notice under this Chapter was served on such other person in
C respect of search carried on after 01.01.1997. The said section
does neither provides for nor imposes any restrictions or
conditions on the period of limitation for preparation the
satisfaction note under Section 15880 and consequent
is_suance of notice to the other person. J
0
43. In the lead case, the assessing officer had prepared
a satisfaction note on 15.07.2005 though the assessment
proceedings in the case of a searched person, namely, S.K.
Bhatia were completed on 30.03.2005. As we have already
· E noticed, the Tribunal and the High Court are of the opinion that
since the satisfaction note was prepared after the proceedings
were completed by the assessing officer under Section 1588C
of the Act which is contrary to the provisions of Section 15880
read with Section 1588E(2)(b) and therefore, have dismissed
F the case of Jhe Revenue. In our considered opinion, the
reasoning of the learned Judges of the High Court is contrary
to the plain and simple language employed by the legislature
under Section 15880 of the Act which clearly provides
adequate flexibility to the assessing officer for recording the
G satisfaction note after the completion of proceedings in respect
of the searched person under Section 158BC. Further, the
interpretation placed by the Courts below by reading into the
. plain language of Section 1588E(2)(b) such as to extend the
period of limitation to recording of satisfaction note would run
H counter to the avowed object of introduction of Chapter to
COMMISSIONER OF INCOME TAX - Ill v. CALCUTIA 879
KNITWEARS, LUDHIANA
provide for cost-effective, efficient and expeditious completion A
of search assessments and avoiding or reducing long drawn
proceedings.
44. In the result, we hold that for the purpose of Section
15880 of the Act a satisfaction note is sine qua non and must
8
be prepared by the assessing officer before he transmits the
records to the other assessing officer who has jurisdiction over
such other person. The satisfaction note could be prepared at
either of the following stages: (a) at the time of or along with
the initiation of proceedings against the searched person under C
Section 1588C of the Act; (b) along with the assessment
proceedings under Section 158BC of the Act; and (c)
immediately after the.assessment proceedings are completed
under Section 158BC of the Act of the searched person.
45. We are informed by Shri Santosh Krishan, who is D
appearing in seven of the appeals that the assessing officer
had not recorded the satisfaction note as required under
Section 15880 of the Act, therefore, the Tribunal and the High
Court were justified in setting aside the orders of assessment
and the orders passed by the first appellate authority. We do E
not intend to examine the aforesaid contention canvassed by
the learned counsel since we are remanding the matters to the
High Court for consideration of the individual cases herein in
light of the observations made by us on the scope and possible
interpretation of Section 158BD of the Act. F
46. With these observations, the appeals are disposed of.
The matters are remanded to the respective High Courts for
deciding the matters afresh after affording an opportunity of
hearing to the parties.
G
Ordered accordingly.
In C.A.N0.3959 OF 2014@ S.L.P.(C)N0.11943 of 2011
C.A.N0.3960 OF 2014@ S.L.P.(C)N0.176@2 of 2011
H
880 SUPREME COURT REPORTS [2014] 5 S.C.R.
A C.A.N0.3961 OF 2014@ S.L.P.(C)N0.17656 of 2011
C.A.N0.3962 OF 2014 @ S.L.P.(C)N0.17661 of 2011
C.A.N0.3963 OF 2014 @ S.L.P.(C)N0.2804 of 2012
B C.A.N0.3964 OF 2014 @ S!L.P.(C)N0.2805 of 2012
C.A.N0.3965 OF 2014 @ S.L.P.(C)N0.5264 of 2012
C.A.N0.3966 OF 2014 @ S.L.P.(C)N0.5265 of 2012
C C.A.N0.3967 OF 2014 @ S.L.P.(C)N0.5266 of 2012
C.A.N0.3968 OF 2014 @ S.L.P.(C)N0.7574 of 2012
C.A.N0.3969 OF 2014 @ S.L.P.(C)N0.7575 of 2012
D C.A.N0.3970 OF 2014 @ S.L.P.(C)N0.7576 9f 2012
C.A.N0.3971 OF 2014@ S.L.P.(C)N0.7577 of 2012
C.A.N9.3972 OF 2014@ S.L.P.(C)N0.9721 of 2012
E C.A.N0.3973 OF 2014@ S.L.P.(C)N0.11460 of 2012
C.A.N0.3974 OF 2014@ S.L.P.(C)N0.12111of2012
C.A.N0.3975 OF 2014@ S.L.P.(C)N0.12886 of 2012
F C.A.N0.3976 OF 2014 @ S.L.P.(C)N0.12887 of 2012
C.A.N0.3977 OF 2014@ S.L.P.(C)N0.15207 of 2012
C.A.N0.3978 OF 2014@ S.L.P.(C)N0.15209 of 2012
G C.A.N0.3979 OF 2014@ S.L.P.(C)N0.16266 of 2012
C.A.N0.3980 OF 2014@ S.L.P.(C)N0.16265 of 2012
C.A.N0.3981 OF 2014@ S.L.P.(C)N0.16319 of 2012
H
COMMISSIONER OF INCOME TAX - Ill v. CALCUTTA 881
KNITWEARS, LUDHIANA
C.A.N0.3982 OF 2014@ S.L.P.(C)N0.16782 of 2012 A
C.A.N0.3983 OF 2014 @ S.L.P.(C)N0.19491 of 2012
C.A.N0.3984 OF 2014@ S.L.P.(C)N0.19492 of 2012
C.A.N0.3985 OF 2014 @ S.L.P.(C)N0.20626 of 2012 · B
C.A.N0.3986 OF 2014 @ S.L.P.(C)N0.21459 of 2012
C.A.N0.3987 OF 2014 @ S.L.P.(C)N0.21460 of 2012
C.A.N0.3988 OF 2014 @ S.L.P.(C)N0.30192 of 2012 C
C.A.N0.3989 OF 2014 @ S.L.P.(C)N0.36559 of 2012
C.A.N0.3990 OF 2014@ S.L.P.(C)N0.12130 of 2013
AND D
WITH C.A.NO. 3991 OF 2014@ S.L.P.(C)N0.15368 of
2013:
In view of the order passed in Civil Appeal @
S.L.P.(C)No.10542 of 2011, these appeals are also disposed E
of in the same terms, conditions, observations and directions
contained therein.
Ordered accordingly.
F
S.L.P .(C)No.774112013:
De-tag and list separately.
Ordered accordingly.
Kalpana K. Tripathy Appeals disposed of SLP de-tagged. G
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