SHYAMSUNDAR RADHESHYAM AGRAWAL & ANR.versusPUSHPABAI NILKANTH PATIL & ORS.

                  [2024] 9 S.C.R. 881 : 2024 INSC 730

            Shyamsundar Radheshyam Agrawal & Anr.
                              v.
                Pushpabai Nilkanth Patil & Ors.
                       (Civil Appeal No. 10804 of 2024)
                              24 September 2024
               [Pankaj Mithal and R. Mahadevan,* JJ.]


                            Issue for Consideration
       Whether the appellants are liable to pay stamp duty and penalty
       on the agreements to sell executed prior to the sale deed executed
       in their favour.

                                   Headnotes†
       Maharashtra Stamp Act, 1958 – s.4 and Explanation 1 to
       Article 25 of Schedule I – Registration Act, 1908 – s.17 –
       Transfer of Property Act, 1882 – s.53A – Appellants instituted
       a suit seeking declaration and injunction – Defendant No.46
       took out an application u/ss. 33, 34 & 37 of the 1958 Act
       r/w. s.17 of the Registration Act, to impound the six original
       agreements for sale viz., Exh.145/3 dated 20.07.1994, Exh.145/9
       dated 20.07.1994, Exh.145/15 dated 12.10.1994, Exh.145/19
       dated 12.10.1994, Exh.145/23 dated 27.04.2006 and Exh.145/25
       dated 19.09.2004 produced by the appellants, so as to get
       them registered, on the premise that the said documents
       include a clause that the physical possession of the properties
       mentioned therein, was transferred to the purchasers; however,
       they were not duly stamped; and hence, the documents require
       the payment of stamp duty of the conveyance – Correctness:
       Held: In the instant case, in the documents, though there was a
       clause for conveyance between the vendors and purchasers in
       relation to the respective properties, the value of the properties were
       above Rs.100/- and there was also a clause by which possession
       was admittedly handed over on the date of the agreement, implying
       acquisition of possessory rights protected under Section 53A of
       the Transfer of Property Act, which requires payment of proper
       stamp duty and registration as mandated under Section 17 of the
       Registration Act – Further, as per Section 4(2) of the Maharashtra
       Stamp Act, the parties are at liberty to determine as to which
* Author
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       of the document shall be principal document – As noted, the
       agreement for sale consists of a clause whereby the possession
       was handed over to the purchaser satisfying the requirement
       to treat the instrument as conveyance and what remained was
       only the formality of execution of the sale deed – Therefore, it
       can be safely concluded that the agreement for sale was the
       principal document on which stamp duty was to be paid as per
       Article 25 – Even considering the contention of the appellant,
       that the sale agreements ultimately concluded in the sale deed
       on which stamp duty was paid, would not by ipso facto absolve
       the primary liability of paying the appropriate stamp duty at the
       time of execution of the sale agreement as it was the principal
       document – Therefore, this Court is of the opinion that Section 4
       of the Act cannot come to the aid of the appellants – Therefore,
       all these six documents ought to have been necessarily stamped
       and registered. [Para 14]

                               Case Law Cited
       Veena Hasmukh Jain v. State of Maharashtra [1999] 1 SCR 302 :
       (1999) 5 SCC 725 : 1999 SCC Online SC 78 – relied on.

                                 List of Acts
       Maharashtra Stamp Act, 1958; Registration Act, 1908; Transfer of
       Property Act, 1882.

                              List of Keywords
       Stamp Duty; Penalty; Agreement to sell; Physical possession of
       properties; Conveyance; Sale deed; Section 4 of Maharashtra
       Stamp Act, 1958; Section 17 of Registration Act, 1908;
       Section 53 A of Transfer of Property Act, 1882.

                             Case Arising From
       CIVIL APPELLATE JURISDICTION : Civil Appeal No. 10804 of 2024
       From the Judgment and Order dated 03.03.2021 of the High Court
       of Judicature at Bombay in WP No. 4695 of 2017

                          Appearances for Parties
       Rohan Thawani, C. George Thomas, Ansh Mittal, Advs. for the
       Appellants.
[2024] 9 S.C.R.                                                          883

              Shyamsundar Radheshyam Agrawal & Anr. v.
                   Pushpabai Nilkanth Patil & Ors

     Abdul Azeem Kalebudde, Dr. Rajiv Masodkar, Satyajeet Kumar,
     Anand Dilip Landge, Siddharth Dharmadhikari, Aaditya Aniruddha
     Pande, Bharat Bagla, Sourav Singh, Aditya Krishna, Ms. Preet
     S. Phanse, Adarsh Dubey, Advs. for the Respondents.

                Judgment / Order of the Supreme Court

                                Judgment

     R. Mahadevan, J.

     Leave granted.
2.   This appeal is filed assailing the final order dated 03.03.2021
     passed by the High Court of Judicature at Bombay (hereinafter
     shortly referred to as “the High Court”) in Writ Petition No.4695 of
     2017, by which, the High Court has dismissed the said writ petition,
     thereby affirming the order dated 26.10.2016 passed by the Court
     of 4th Joint Civil Judge (Senior Division), Thane, (hereinafter shortly
     referred to as “the trial Court”) in allowing the application filed by
     the Defendant No.46 for impounding the six documents produced
     by the appellants herein.
3.   Originally, the appellants instituted a suit in Special Civil Suit No.200
     of 2008 seeking declaration and injunction. Denying the plaint
     averments, the defendants filed their written statements. Thereafter,
     the Defendant No.46 took out an application under Sections 33,
     34 & 37 of the Maharashtra Stamp Act, 1958 r/w Section 17 of the
     Registration Act, to impound the six original agreements for sale
     viz., Exh.145/3 dated 20.07.1994, Exh.145/9 dated 20.07.1994,
     Exh.145/15 dated 12.10.1994, Exh.145/19 dated 12.10.1994,
     Exh.145/23 dated 27.04.2006 and Exh.145/25 dated 19.09.2004
     produced by the appellants, so as to get them registered, on the
     premise that the said documents include a clause that the physical
     possession of the properties mentioned therein, was transferred to
     the purchasers; however, they were not duly stamped; and hence, the
     documents require the payment of stamp duty of the conveyance. By
     order dated 26.10.2016, the trial Court allowed the said application,
     thereby impounding the documents and directing to send the same
     to the Collector of Stamp, Thane, for adjudication of stamp duty and
     penalty, if any, payable by the appellants. Aggrieved by the same,
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       the appellants herein filed the aforesaid writ petition, which was
       dismissed by the High Court, by the order impugned in this appeal.
4.     Referring to Section 4 of the Maharashtra Stamp Act, 1958 (hereinafter
       shortly referred to as “the Act”), the learned counsel appearing on
       behalf of the appellants contended that the agreements to sell in
       relation to the same immovable properties ultimately resulted into
       a sale deed in favour of the appellants and the said sale deed was
       also duly registered, upon payment of the required stamp duty and
       therefore, the prior agreements to sell are not required to be registered
       and stamped. Further, one of the agreements in respect of 2.550 sq.
       meters of land was executed in favour of Mira Bhayandar Municipal
       Corporation and hence, no separate stamp duty is required to be paid
       by the appellants. However, misinterpreting the said provision, the
       trial Court allowed the application filed for impounding the documents
       and directed to send the same to the Collector for adjudication of
       stamp duty and penalty, which was also erroneously affirmed by
       the High Court.
5.     Per contra, the learned counsel appearing on behalf of the
       respondents submitted that on a detailed analysis of the agreements
       to sell, wherein, there was a specific clause about the transfer of
       physical possession to the purchasers therein, the courts below
       have rightly allowed the application filed for impounding these
       documents and, therefore, the same need not be interfered with
       by this Court.
6.     We have heard the learned counsel appearing for the respective
       parties and perused the material on record, more particularly, the
       documents in question.
7.     The issue involved herein is, whether the appellants are liable to
       pay stamp duty and penalty on the agreements to sell executed
       prior to the sale deed executed in their favour, in respect of two
       properties viz., (i) S.No.165/4 admeasuring 2,550 sq. mtrs. and (ii)
       S.No.208/3 admeasuring 860 sq. mtrs. and S.No.208/4 admeasuring,
       5650 sq. mtrs.
8.     In order to determine the stamp duty that is chargeable upon an
       instrument, the legal rule is that the real and true meaning of the
       instrument is to be determined by ascertaining the intention of the
       parties from the contents and the language employed in the whole
[2024] 9 S.C.R.                                                           885

              Shyamsundar Radheshyam Agrawal & Anr. v.
                   Pushpabai Nilkanth Patil & Ors

     instrument and the description or the nomenclature given to the
     instrument by the parties is immaterial.
9.   According to the appellants, the sale deed having been executed in
     relation to the same immovable properties and stamp duty having
     been paid, the earlier agreements to sell which are part and parcel
     of the same transaction, got merged with the said sale deed and
     hence, separate stamp duty is not required to be paid on the earlier
     agreements to sell. To buttress the same, reliance was placed on
     Section 4 of the Act, which is quoted below for ready reference:
           “4. Several Instruments used in single transaction of
           development agreement, sale, mortgage or settlement:
           1) Where, in the case of any development agreement, sale,
           mortgage or settlement, several instruments are employed
           for completing the transaction, the principal instrument only
           shall be chargeable with the duty prescribed in Schedule –
           I for the conveyance, development agreement, mortgage
           or settlement, and each of the other instruments shall be
           chargeable with a duty of one hundred rupees instead of
           the duty (if any) prescribed for it in that Schedule.
           2) The parties may determine for themselves which of
           the instruments so employed shall, for the purposes of
           sub-section (1), be deemed to be the principal instrument.
           3) If the parties fail to determine the principal instrument
           between themselves, then the officer before whom the
           instrument is produced may, for the purpose of this section,
           determine the principal instrument:
           Provided that the duty chargeable on the instrument so
           determined shall be the highest duty which would be
           chargeable in respect of any of the said instruments
           employed.”
10. The aforesaid provision, especially, Section 4(1), makes it clear that
    where several instruments are executed for completing a transaction,
    the principal instrument alone shall be chargeable with duty prescribed
    in Schedule I. The proviso makes it clear that the duty chargeable on
    the instrument so determined shall be the highest duty which could
    be chargeable in respect of any of the said instruments forming part
    of the same transaction. Each of the other instruments is chargeable
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       with a fixed duty. That apart, sub-section (2) also gives an opportunity
       to the parties to determine for themselves, which of the instruments
       shall be deemed to be the principal instrument. We shall therefore
       look into the documents in question and determine whether they are
       required to be stamped and registered.
11. The documents sought to be impounded at the instance of one of
    the defendants are:
       (i)    Exh.145/3 dated 20.07.1994 – agreement for sale-cum-
              development executed by Vinayak Kashinath Gharat and others
              in favour of Naresh N. Jain, Sunita P. Jain and Kalawati N. Jain,
              which is on the stamp paper of Rs.20/-;
       (ii)   Exh.145/9 dated 20.07.1994 – agreement for sale-cum-
              development executed by Vinayak Kashinath Gharat and others
              in favour of Naresh N. Jain, Sunita P. Jain and Kalawati N. Jain,
              which is on the stamp paper of Rs.20/-;
       (iii) Exh.145/15 dated 12.10.1994 executed by Naresh N. Jain and
             others in favour of M/s.Chedda Enterprises, which is on the
             stamp paper of Rs.20/-;
       (iv) Exh.145/19 dated 12.10.1994 – agreement for sale-cum-
            development executed by Naresh N. Jain and others in favour
            of M/s.Chedda Enterprises, which is on the stamp paper of
            Rs.20/-;
       (v)    Exh.145/23 dated 27.04.2006 – agreement for sale executed
              by M/s.Sunshine Builders and Developers in favour of the
              appellants, which is on the stamp paper of Rs.100/-; and
       (vi) Exh.145/25 dated 19.09.2004 – agreement for development
            -cum- sale executed by M/s.Sunshine Builders and Developers
            in favour of the appellants, which is on the stamp paper of
            Rs.100/-.
12. On a reading of all these six documents, it could be seen that the
    instruments /documents were not forming part of a single transaction
    between the same parties and they were different transactions
    between different vendors and purchasers. Further, for several
    documents to form part of a single transaction, there must be a
    transaction in furtherance of which several other documents are
    executed to complete that transaction and then it becomes imperative
[2024] 9 S.C.R.                                                            887

              Shyamsundar Radheshyam Agrawal & Anr. v.
                   Pushpabai Nilkanth Patil & Ors

     to charge stamp duty on the principal instrument/document. The
     language used in the provision is very clear, whereby the stamp duty
     is on the instrument and not on the transaction. It will be useful to
     refer to Explanation 1 to Article 25 of Schedule I of the Maharashtra
     Stamp Act, which would read as under:
           “Explanation I.—For the purposes of this article, where
           in the case of agreement to sell an immovable property,
           the possession of any immovable property is transferred
           or agreed to be transferred to the purchaser before the
           execution, or at the time of execution, or after the execution
           of such agreement without executing the conveyance
           in respect thereof, then such agreement to sell shall be
           deemed to be a conveyance and stamp duty thereon shall
           be leviable accordingly:
           Provided that, the provisions of Section 32-A shall apply
           mutatis mutandis to such agreement which is deemed to be
           a conveyance as aforesaid, as they apply to a conveyance
           under that Section:
           Provided further that, where subsequently a conveyance
           is executed in pursuance of such agreement of sale, the
           stamp duty, if any, already paid and recovered on the
           agreement of sale which is deemed to be a conveyance,
           shall be adjusted towards the total duty leviable on the
           conveyance.”
13. It will be apropos to mention here that the agreements were not only
    between different parties but also were executed during different
    periods, by which time the Explanation I to Article 25 of Schedule I
    underwent a change. The words “without executing the conveyance
    in respect thereof” was deleted with effect from 17.08.1994 by
    Maharashtra Act 38 of 1994. The above Explanation I makes it lucid
    that an agreement for sale is to be treated as a “conveyance” if either
    possession is handed over immediately or if it is agreed to be handed
    over within a particular time. A reading of the above Explanation I
    along with Section 4 makes it clear that the duty is levied only on
    the instrument and not on the transaction. This court, in Veena
    Hasmukh Jain v. State of Maharashtra (1999) 5 SCC 725 : 1999
    SCC Online SC 78 while dealing with the question as to whether
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       the agreement to sell can be treated as document of conveyance,
       liable to stamp duty held as follows:
           “4. On examination of these terms, the High Court took the
           view that the agreement in question could be construed to
           be a conveyance falling under Section 2(g) of the Bombay
           Stamp Act inasmuch as the right, title and interest in the flat
           stands transferred in favour of the purchaser on payment
           of instalments as provided therein.
           5. The High Court also examined the scope of Explanation I
           to Article 25 of Schedule I of the Bombay Stamp Act and
           held that the same was attracted to the case. Under
           the agreement, there is an obligation to hand over the
           possession even before execution of a conveyance and,
           therefore, it was a “conveyance” for the purpose of duty
           payable under the Bombay Stamp Act and there was no
           obligation in the agreement to enter into a conveyance at
           a later stage and clearly it was a case which attracted the
           said Explanation. Handing over of the possession on the
           very date of execution was not relevant for determining
           the nature of the document. On that basis, the High Court
           upheld the stand taken by the State in the matter of levy
           of duty. Other questions raised in the writ petition are not
           the subject-matter of these appeals and, therefore, we do
           not advert to those questions. On the conclusion reached
           by the High Court, the writ petition stood dismissed.
           6. The learned counsel appearing for the appellants urged
           before us that the conclusion reached by the High Court
           either on the question of construction of the agreement
           amounting to a “conveyance” or on the applicability of
           Explanation I to Article 25 of Schedule I to the Bombay
           Stamp Act is incorrect. It was submitted that the agreement
           in question had been executed only in terms of Section 4
           of the MOF Act and that under the scheme of the Act, a
           deed of conveyance had to be drawn in terms of Section 11
           thereof. Therefore, it was submitted that the document
           executed in terms of Section 4 of the MOF Act cannot
           be construed to be a “conveyance”. He also submitted
           that under the same Act, duty can be levied only on the
           “instrument” and not on any “transaction”. Here, in the
[2024] 9 S.C.R.                                                          889

              Shyamsundar Radheshyam Agrawal & Anr. v.
                   Pushpabai Nilkanth Patil & Ors

           present case, by Explanation I to Article 25 of Schedule I,
           what has been done is to provide for levy of duty on a
           “transaction”, namely, handing over possession and not
           on the “instrument” as such and hence the provision is
           ultra vires the Constitution.
           7. Under Entry 44 of List III-Concurrent List of the Seventh
           Schedule to the Constitution, any State as well as the
           Central Government can levy stamp duties other than
           duties or fees collected by means of judicial stamps, but
           not including rates of stamp duty and in respect of such
           instruments mentioned in Entry 91 of List I-Union List
           of the Seventh Schedule to the Constitution. A duty is
           leviable under Section 3 of the Bombay Stamp Act which
           indicates the instruments executed in the State or those
           outside the State but brought into the State for the first
           time relating to any property situate or to any matter or
           thing done or to be done in the State shall be chargeable
           to stamp duty prescribed under the Bombay Stamp Act.
           Article 25 of Schedule I refers to conveyance and the
           amount of conveyance as sought to be explained by the
           Explanation. Explanation I to Article 25 of Schedule I to
           the Bombay Stamp Act reads as follows:
           “Explanation I.—For the purposes of this article, where in
           the case of agreement to sell an immovable property, the
           possession of any immovable property is transferred to the
           purchaser before the execution, or at the time of execution,
           or after the execution of such agreement without executing
           the conveyance in respect thereof, then such agreement
           to sell shall be deemed to be a conveyance and stamp
           duty thereon shall be leviable accordingly:
           Provided that, the provisions of Section 32-A shall apply
           mutatis mutandis to such agreement which is deemed to be
           a conveyance as aforesaid, as they apply to a conveyance
           under that Section:
           Provided further that, where subsequently a conveyance
           is executed in pursuance of such agreement of sale, the
           stamp duty, if any, already paid and recovered on the
           agreement of sale which is deemed to be a conveyance,
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       shall be adjusted towards the total duty leviable on the
       conveyance.”
       8. The duty in respect of an agreement covered by the
       Explanation is leviable as if it is a conveyance. The
       conditions to be fulfilled are that if there is an agreement to
       sell immovable property and possession of such property
       is transferred to the purchaser before the execution or at
       the time of execution or subsequently without executing
       any conveyance in respect thereof, such an agreement
       to sell is deemed to be a “conveyance”. In the event a
       conveyance is executed in pursuance of such agreement
       subsequently, the stamp duty already paid and recovered
       on the agreement of sale which is deemed to be a
       conveyance shall be adjusted towards the total duty
       leviable on the conveyance. Now, in the present case,
       the agreement entered into clearly provides for sale of
       an immovable property and there is also a specific time
       within which possession has to be delivered. Therefore,
       the document in question clearly falls within the scope
       of Explanation I. It is open to the legislature to levy duty
       on different kinds of agreements at different rates. If the
       legislature thought that it would be appropriate to collect
       duty at the stage of the agreement itself if it fulfils certain
       conditions instead of postponing the collection of such
       duty till the completion of the transaction by execution of
       a conveyance deed inasmuch as all substantial conditions
       of a conveyance have already been fulfilled such as by
       passing of a consideration and delivery of possession of the
       property and what remained to be done is a mere formality
       of execution of a sale deed, it would be necessary to collect
       duty at a later (sic agreement) stage itself though right,
       title and interest may not have passed as such. Still, by
       reason of the fact that under the terms of the agreement,
       there is an intention of sale and possession of the property
       has also been delivered, it is certainly open to the State to
       charge such instruments at a particular rate which is akin
       to a conveyance and that is exactly what has been done
       in the present case. Therefore, it cannot be said that levy
       of duty is not upon the instrument but on the transaction.
[2024] 9 S.C.R.                                                               891

              Shyamsundar Radheshyam Agrawal & Anr. v.
                   Pushpabai Nilkanth Patil & Ors

           Therefore, we reject the contention raised on behalf of the
           appellants in that regard.
           9. The learned counsel for the appellants urged that the
           character of an instrument cannot be determined by reason
           of a subsequent event to take place such as handing over
           of possession. But a close examination of the provisions
           of the Explanation will make it clear that in the case of
           an agreement to sell immovable property possession is
           transferred at any time without executing the conveyance
           in respect thereof and such an instrument is deemed to be
           a “conveyance”. The object of the Explanation is clear that
           if an agreement is entered into and that agreement itself
           contemplates the delivery of possession of the property
           within the stipulated time, then such an agreement should
           be deemed to be a conveyance for the purpose of duty
           leviable under the Bombay Stamp Act.
           10. It is clear that the object of the Stamp Act is to levy stamp
           duty on different kinds of instruments. The legislature, in the
           present case, has chosen to levy a rate of duty equivalent
           to conveyance in respect of an agreement though the
           transaction may not have been completed because of
           certain instruments arising out of such agreement being
           executed and possession thereof being taken prior to or
           simultaneous with the document or subsequently. But in
           the Explanation, it is not clear that if the document provides
           that possession has to be taken without execution of the
           conveyance, certainly it would attract the appropriate duty.
           If the agreement provides that possession will be handed
           over on the execution of a conveyance as contemplated
           under Section 11 of the MOF Act, then the Explanation
           shall not be attracted at all. In the present case, it is clear
           that in the terms of the agreement, there is no provision
           made at all for execution of the conveyance. On the other
           hand, what is submitted is that the provisions of the MOF
           Act could be applied to the agreement and, therefore, a
           conveyance could be executed subsequently when it is
           not clear as to when the conveyance is to be executed
           and the stipulated time within which the possession has to
           be handed over. If that is so, it is clear that the document
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          would attract duty as if it is a conveyance as provided in
          the Explanation. Thus we find no error in the view taken
          by the High Court. It is not necessary to examine in these
          appeals as to whether the instrument in question itself
          conveys a title or not. Therefore, we uphold the decision
          of the High Court made in this regard. The appeals are
          dismissed.”
14. In the instant case, in the documents, though there was a clause for
    conveyance between the vendors and purchasers in relation to the
    respective properties, the value of the properties were above Rs.100/-
    and there was also a clause by which possession was admittedly
    handed over on the date of the agreement, implying acquisition of
    possessory rights protected under Section 53A of the Transfer of
    Property Act, which requires payment of proper stamp duty and
    registration as mandated under Section 17 of the Registration Act.
    Further, as per Section 4(2) of the Maharashtra Stamp Act, the parties
    are at liberty to parties to determine as to which of the document
    shall be principal document. As noted above, the agreement for sale
    consists of a clause whereby the possession was handed over to
    the purchaser satisfying the requirement to treat the instrument as
    conveyance and what remained was only the formality of execution
    of the sale deed. Therefore, it can be safely concluded that the
    agreement for sale was the principal document on which stamp duty
    was to be paid as per Article 25. Even considering the contention of
    the appellant, that the sale agreements ultimately concluded in the
    sale deed on which stamp duty was paid, would not by ipso facto
    absolve the primary liability of paying the appropriate stamp duty at
    the time of execution of the sale agreement as it was the principal
    document. Therefore, we are of the opinion that Section 4 of the Act
    cannot come to the aid of the appellants. Therefore, all these six
    documents ought to have been necessarily stamped and registered.
15. Taking note of the facts and circumstances of the case and legal
    position, the trial Court rightly observed that the subsequent sale
    deed cannot be construed as a principal transaction and the
    agreements to sell would be treated as the principal conveyance as
    per Explanation I of Article 25 of Schedule-I of the Act and impounded
    all these documents and directed to send the same to the Collector
    for adjudication of stamp duty and penalty. After, a detailed analysis,
[2024] 9 S.C.R.                                                          893

                Shyamsundar Radheshyam Agrawal & Anr. v.
                     Pushpabai Nilkanth Patil & Ors

     the High Court held that no case for interference was made out by
     the appellants, which, we affirm, to be correct.
16. In addition, we wish to further record that the second proviso to
    Article 25 only states that if the stamp duty is already paid or recovered
    on the agreement to sale, then the same shall be deducted while
    computing the stamp duty payable when the sale deed is executed;
    the proviso does not contemplate a situation similar to this case,
    where the document ought to have been registered with payment of
    stamp duty on the agreement for sale initially and only the balance,
    on the deed of sale after deduction of the duty already paid ought
    to have been collected. Since, the state cannot recover by way of
    stamp duty in excess of what it is entitled to, the recovery shall
    be restricted only to the extent of difference in stamp duty and the
    entire penalty from the date of execution of the agreement for sale
    till the date of payment of stamp duty. Needless to say, that until the
    defect is cured by satisfying the requirements under Section 34, the
    documents impounded cannot also be used in evidence.
17. In view thereof, we find no reason to interfere with the orders passed
    by the Courts below. Accordingly, this appeal fails and is dismissed.
    Pending application(s), if any, shall stand closed.

     Result of the Case: Appeal dismissed.



     †
         Headnotes prepared by: Ankit Gyan