Supreme Court of India
STATE OF WEST BENGAL AND ORSversusMD. KHALIL ETC.
- Citation
- 2000 INSC 302
- Decided
- 8 May 2000
- Disposal
- Dismissed
- Bench
- S S M QUADRI
Holding
Entry tax and penalty may be levied only on a "dealer" as defined by the Act; a mere possessor is not liable, and the burden of proof rests on the Authority with no statutory presumption against the possessor.
Summary
The State of West Bengal challenged the West Bengal Taxation Tribunal’s order quashing a demand for entry tax and penalty on MD Khalil, who was found possessing dry fruits in a cold storage in Calcutta. The Authority had issued notice under Section 14(3) of the Calcutta Metropolitan Area Act, 1972, alleging the goods were brought into the metropolitan area without payment of tax. Khalil contended that he purchased the goods locally, was not a "dealer" as defined in Section 2(c), and could not produce documents proving the source of the goods. The Tribunal held that the burden of proving unauthorised entry lay with the Authority and that no material existed to show the goods were imported without tax, consequently setting aside the demand. On appeal, the Supreme Court affirmed that only a dealer is liable to pay tax and penalty, a mere possessor does not fall within the definition, and the Act contains no provision for a statutory presumption against the possessor. Accordingly, the Court dismissed the appeal, upholding the Tribunal’s decision.
Issues considered
- Whether a person merely possessing specified goods, who is not a "dealer" under Section 2(c) of the Calcutta Metropolitan Area Act, can be liable to entry tax and penalty under Section 14(3).
- Whether the burden of proving that goods were brought into the metropolitan area without payment of tax lies on the Authority or the possessor.
- Whether the Act permits a statutory presumption that a possessor who fails to produce documents has imported the goods without tax.
Legislation cited
Subjects
entry taxdealer definitionburden of proofpresumptionCalcutta Metropolitan Areatax assessmentpenaltystatutory declaration
Judgment
IT STATE OF WEST BENGAL AND ORS. A
--tt v.
MD. KHALil.. ETC.
- MAYS, 2000
[SYED SHAH MOHAMMED QUADRI AND SIITVARAJ V. PATil.., JJ.] B
Calcutta Metropolitan Area Act, 1972-Sections 2(c), 14(3), (6) and
(6)(b)-Certain goods brought into Calcutta without payment of entry tax-
Respondents contended that goods were purchased form local market but were
unable to prove the same-Demand notices challenged before High Court in c
writ petition-Interim order for payment of tax and penalty-Matter trans-
/erred to Tribunal, which put onus upon Authority to prove that goods wem
imported without payment of tax-Demand for entry tax and penalty set
aside-On appeal Held, respondents do not fall within the term "dealer", who
is mquired to deliver a statutory declaration for tax purposes and is alone
responsible for the tax and penalty-No tax can be levied without there being D
any material to show that goods wem brought into Calcutta without payment
of tax-Tax is to be levied upon entry of specified goods into Calcutta and not
on possession of specified goods therein-No presumption can be raised that
.. >
the possessor of specified goods, who fails to prove local purchase, has
imported goods without payment of tax. E
Respondents allegedly brought certain goods into Calcutta without
paying the required entry tax under the Calcutta Metropolitan Area Act,
1972. They challenged the demand notices in a writ petition before the
ffigh Court but were directed by an interim order, to pay the assessed tax
F
, in addition to penalty, if any. The matter was transferred to the Taxation
Tribunal, where the respondents challenged the imposition of tax and
penalty under the Act. Their case was that they had purchased the goods
from the local market but were unable to furnish relevant details. Tribunal
.
_.
put the onus of proving that the goods were brought from outside the
Metropolitan Area and that it was the respondent who so brought those G
goods on the Entry Tax Authority and held that there was no material on
., record to establish the same. It therefore set aside the demand for entry tax
and penalty. Hence these appeals.
Appellants contended that the onus of proving that goods were
brought from outside the Metropolitan Area was wrongfully put upon H
1189
1190 SUPREME COURT REPORTS [2000] 3 S.C.R.
A them; and that they could draw a rebuttable presumption that entry tax
has not been paid when the goods were not produced in the Metropolitan
Area but were found stored therein.
Respondent contended that any person possessing specific goods
cannot be termed a dealer within Section 2(c) of the Act on whom the
B liability to pay the tax lies, that appellants were to prove that the goods
were brought from outside the Metropolitan Area, without the payment of
entry tax; that {mport of specified goods by a dealer and purchasing them
from a local market are two different things and no tax should be levied if
they are unable to prove local sale; and that there is no provision in the Act
c placing burden of proof on the possessor of the goods to establish that
goods were imported on payment of tax and Section 14(3) of the Act does
not intend to tax them.
Dismissing the appeals, the Court
D HELD: 1. A perusal of Section 14(3) of the Calcutta Metropolitan
Area Act, 1972 discloses thatitis meant to check tax evasion. The liability to
pay the tax under Section 14(1) and the tax penalty under Section 14(2) and
(3) is on the dealer. It is only in a case falling under Section 14(6)(b), that a
person other than a dealer is dealt with and a duty is cast on him to produce
documents, accounts register etc. when he is required to do so by the pre-
E
scribed Authority. The dealer is the person required to deliver the statutory
declaration and is also answerable for the tax as well as for the penalty
imposed under the Act. There are four categories of persons who fall within
the meaning of the term "dealer''. A person who is in possession of the speci-
fied goods does not fall within the meaning of that term. The respondent is
F not a 'dealer' within the meaning of the Act. [1197-F; 1198-D-F]
2. For assessing entry tax under sub-section (3) of Section 14 of the
Entry Tax Act, it has to be shown that the specified goods have been
brought into Calcutta Metropolitan Area; that such goods have been
G
brought without payment of tax leviable thereon under the Act; and that
such goods are found in possession of the respondent."Without there being
any material to show that the specified goods in the possession of the
-
...
respondent have been brought into the Calcutta Metropolitan Area and
that they were brought without payment of any tax leviable thereon, no
tax can be levied even on a dealer. It cannot be lost sight of that the tax
H under the Act is a tax on the entry of the specified goods into the Calcutta
STATE v. MD. KHALil.. [SYED SHAH MOHAMMED QUADRI, J.] 1191
Metropolitan Area and not on possession of the specified goods within the A
Calcutta Metropolitan Area.[1199-A-E]
3. A presumption is a rule of law which requires the Court to draw
a given conclusion on proof or existence of certain facts and leaves it to
the party disputing the conclusion to rebut the same. Presumptions may
be of fact or of law. A presumption is an inference sanctioned by law B
which does not logically or necessarily foil ow from the proved facts.
There is no provision in the Act which may enable the Authority to raise
the presumption that a possessor of the specified goods, who fails to
produce before the Authority his accounts register or document on being
required to do so, has imported the goods into the Calcutta Metropolitan C
Area without payment of tax. On the facts and circumstances of the case,
it is impossible for a Court to infer that the respondent has imported the
goods into the Calcutta Metropolitan Area without payment of tax. [1199-
F-H; 1200-A]
CIVIL APPELLATE JURISDICTION : Civil Appeal No. 12060 of D
1996 Etc.
From the Judgment and Order dated 11.1.96 of the West Bengal
Taxation Tribunal, Calcutta in Case No. RN-20(1') of 1994.
- > Tapas Ray and Avijit Battacharjee for the Appellants.
Gopal Chandra Chakravaity, Subodh Markandeya, Udayan Chakravarty
E
and P.K. Chakravarty for the Respondents.
The Judgment of the Court was delivered by
SYED SHAH MOHAMMED QUADRI, J. Leave is granted in the
, connected matter S.L.P.(c) No.19573 of 1996. These two appeals raise an
F
--
~
identical and interesting question of law.
C.A. No.12060of1~96 is filed by the State of West Bengal challenging
the validity of the judgment of the West Bengal Taxation Tribunal (for short
'the Tribunal') in Case No.20(T) of 1994 dated January 11, 1996, by which G
the application filed by the respondent was allowed and the impugned demand
')' of tax and penalty was quashed. That judgment was followed by the Tribunal
in Case No.RN-192(T) of 1995, filed by the respondent which was allowed
quashing the demand of tax and penalty on February 20, 1996 which is
assailed in C.A.No ....... of 2000 @ S.L.P. © No.19573 of 1996.
H
1192 SUPREME COURT REPORTS (2000) 3 S.C.R.
A Adverting to the facts giving rise to C.A.No.12060 of 1996, the Entry
Tax Authority (for short, "the Authority') carried out a raid on the cold
storage of Mis. Pratap Company at 15/16 Botanical Garden Lane, Howrah,
(for short, 'the cold storage') and seized its record. On examination of the
record, it was noticed that 158 persons deposited dry fruits in the cold storage.
The verification of the depositors showed that pnly 24 out of 158 were in
B
existence. The assessing officer issued notice under Section 14(3) of the Taxes
on Entry of Goods into Calcutta Metropolitan Area Act, 1972 (hereinafter
refeITed to as 'the Entry Tax Act'). The respondent challenged the validity
of that notice in writ petition in the High Court at Calcutta. The High Court
declined to grant stay of further proceedings pursuant to the impugned notice
c and by an interim order directed the respondent to pay the tax as assessed
by the Authority and observed that payment of penalty, if imposed, would
depend upon 'the final determination of the writ petition. The Authority
assessed entry tax on the cold storage and its partners as well as on the
depositors, including the respondent. After the constitution of the West Bengal
D Taxation Tribunal under the West Bengal Taxation TribunaJ Act, 1987, the
application of the respondent alongwith other similar applications was trans-
feITed to the Tribunal. Before the Tribunal, the respondent and others
questioned the imposition of tax and penalty under the Entry Tax Act.
The case of the respondent.before the Tribunal was that he purchased
E the goqds from the local market and deposited the same in the cold storage.
The goods suffered the entry tax in the name of Keshordeo Sonthalia and
others. He denied that he is a 'dealer' within the meaning of Section 2(c)
of the Entry Tax Act. The appellant denied having levied tax on the goods
in respect of which tax was already imposed. The name of the respondent,
-
F it is stated, was found in the registers of the cold storage and that he having
purchased the goods from outside West Bengal, caused their entry into
Calcutta and stored them in the cold storage. The goods (dry fruits) in such
huge quantity could not have been purchased locally and the respondent
failed to furnish the particulars as to from whom he purchased the goods. The
Tribunal took the view that the burden of proving that the goods were
G
brought into Calcutta Metropolitan Area from outside and it was the respond-
ent who so brought those goods lies on the Authority and that the respondent
cannot be called upon to prove that he did not bring the goods from outside
into Calcutta Metropolitan Area. There is no provision in the Entry Tax Act
placing the burden of proof on the possessor of specified goods to show that
H he has not brought the goods from outside. Observing that the conduct of the
-~-
STATE v. MD. KHALIL [SYED SHAH MOHAMMED QUADRI, J.] 1193
~~ respondent might be highly suspicious, the Tribunal held that no material was A
placed on record by the Authority to establish that the goods in question were
brought from outside the Calcutta Metropolitan Area and it was actually the
respondent who brought the goods in the Calcutta Metropolitan Area. In view
of this finding, the Tribunal allowed the application of the respondent, set
aside the demand of entry tax as well as penalty and directed refund of the
B
tax to the respondent within 12 weeks from the date of th~ judgment dated
January 11, 1996.
f
Mr. Tapas Ray, learned senior counsel for the appellants, contended
that the Tribunal committed grave error by fiOCeeding on the basis that the
burden of proof of showing that the gc,.Jds were brought within the entry c
tax area and without payment of entrf tax, was on the Authority and if that
were to be so, the provisions of .;uh-sections (3) and (6) of Section 14 of
the Entry Tax Act would be<'Jme superfluous as in no case the Authority
y
can deal with a case of goods which have already entered within the entry
tax area. It is further contended that under the scheme of the Entry Tax Act
D
when the specified goods, not produced within Calcutta Metropolitan Area,
are found stored within the said area but without proof of payment of the
entry tax or acquisition of the goods, the Authority is entitled to draw a
rebuttable presumption that the person in possession of the goods has
~
,,- )I
brought the goods within the area without payment of tax.
E
Mr. Gopal Chandra Chakravarty, learned senior counsel for the re-
-. spondent, argued that any person who possesses the specific goods cannot be
said to be a 'dealer' within the meaning of Section 2(c) of the Entry Tax Act
and that it was for the appellants to show that the goods were brought into
the Calcutta Metropolitan Area by the respondent without payment of tax and ·
F
A unless a nexus between the possessor of the goods and the evasion of the
entry tax was established imposition of tax on the possessor would be illegal.
~
He argued that the import of the specified goods into the entry tax area by
a dealer and purchasing the goods from the local market are two different
,..,.• things and the local purchasers cannot be taxed on the ground of not proving
local purchase. His submission was that the liability to pay the tax lies on G
the dealer under Section 10 of the Entry Tax Act and even the order of the
)'
assessment does· not hold that the respondent is a 'dealer' as defined in
Section 2 (c) of the Entry Tax Act; according to Mr. Chakravarthy, an
assessment under Section 14(3) could be made by the Authority only when
the goods are brought from outside the Calcutta Metropolitan Area without H
1194 SUPREME COURT REPORTS (2000] 3 S.C.R.
A payment of entry tax and that there is no provision in the Act placing the
burden of proof on the possessor of the goods to establish that he imported
the goods on payment of tax and that sub-section (3) of Section- 14 is not
intended to tax such a possessor of the goods.
On the above contentions, the short question that arises for consid-
B eration is: whether under the provisions of the Entry Tax Act, the possessor
of the goods can be subjected to entry tax in the absence of his giving
particulars of his local purchases?
For answering to this question, it may be necessary to refer to Section
c 6 of the Entry Tax Act, the charging section, which reads thus:
"6. (1) Save as otherwise provided in this Chapter, there shall be
levied and collected, for the purposes of this Act, a tax on the entry
of every specified goods into the Calcutta Metropolitan Area (for
consumption, use or sale therein) from any place outside that Area,
D at such rate, not exceeding the rate specified in the corresponding
entry in column 3 of the Schedule, as the State Government may, by
notification~ specify.
(2) Subject to such rules as may be made by the State Government
E in this behalf, no tax shall be levied and collected under this Act on
the entry of any specified goods into the Calcutta Metropolitan Area
if such goods are brought into that ~ea -
(a) as personal luggage by a passenger and the value or the number
or quantity thereof does not exceed the prescribed amount or
F limit, as the case may be, or
(b) in such circumstances and subject to such conditions and
restrictions as may be prescribed."
A perusal of this provision shows that : (i) the tax is on the entry of
G
every specified goods into Calcutta Metropolitan Area; (ii) the goods must
enter from any place outside the Area; (iii) the entry of the goods may be
for consumption, use or sale; (iv) the Government may notify the rate of tax
from time to time but it should not exceed the rate specified in column 3 of
the Schedule; r ~ J personal luggage by a passenger, not exceeding the pre-
H scribed amount of limit with regard to its value, number or quality, as the
STATE v. MD. KHALIL [SYED SHAH MOHAMMED QUADRI, J.) 1195
case may be, is exempt from the tax; and (vi) the State Government is A
empowered to specify the circumstances, conditions and restrictions subject
~o which the goods brought into the Calcutta Metropolitan Area cannot be
taxed. Section 10 of the Entry Tax Act says that the tax levied under the Act
shall be payable by the dealer in relation to the specified goods. The term
'dealer' is defined in Section 2(c) of the Entry Tax Act as follows : B
"2. In this Act, unless the context otheTwise requires, -
t
(a) & (b) *** *** ***
(c) "dealer", in relation to any specified goods entering the Calcutta
Metropolitan area, means a person, - c
(i) who either on his own account or on account of a principal [or
any other person] causes such entry, or
(ii) who takes delivery, or is entitled to take delivery, of such goods
on such entry. D
Explanation I - When the consignor or consignee of any specified
goods entering the Calcutta Metropolitan Area nominates, according
....l
to such rules as may be prescribed, a person to be the dealer for the
purposes of this Act, such person shall be deemed to be a dealer in
relation to such specified goods.
E
Explanation II - When· the consignee of any specified goods
entering the Calcutta Metropolitan Area, despatched to such Metro-
politan Area by rail, road, water, air or post, does not take delivery
of such goods upon such entry and the goods are sold under the p
provisions of any law, the buyer, who takes delivery of such goods
upon the goods being so sold, shall be deemed to be dealer thereof;"
The definition brings in four categories of persons within the meaning
of the term 'dealer' :
G
(i) a person who on his own account or an account of principle or
any other person causes entry of specified good within Calcutta
Metropolitan Area;
(ii) a person who takes delivery or is entitled to take delivery of
such goods on their entry in said area; H
1196 SUPREME COURT REPORTS (2000) 3 S.C.R.
A (iii) a nominated person as a dealer in relation to specific goods the
consignor or the consignee of such goods entering Calcutta
Metropolitan Area;
(iv) a pm-chaser of specified goods which are sold after entry under
the provisions of any law on the consignee of such goods not
B taking delivery of the goods on their entry in the Calcutta
Metropolitan Area either by rail, road, water, air or post.
f
Section 13 of the Entry Tax Act imposes an obligation on eve1y dealer
of specified goods to deliver a declaration, in the prescribed form, on or
before entry of such goods into the Calcutta Metropolitan Area. He is
c exempted from giving such a declaration if the specified goods are exempted
by sub-section (2) of Section 6, Section 7 or Section 8 from payment of any
tax leviable under the Entry Tax Act.
Section 14 of the Entry Tax Act deals with assessment of tax. It enjoins
the prescribed authority to assess the tax leviable on the entry of such goods
D into Calcutta Metropolitan Area, where a declaration has been made tinder
Section 13 of the Entry Tax Act by a dealer, after making sucil verification
of the specified goods as he may consider necessary before assessing the tax
on the goods. Sub-section (2) takes care of the situation where the dealer has
failed or omitted to make the declaration as required by Section 13 of the
E Entry Tax Act. It authorises the prescribed authority to assess tax on such
goods after their inspection and examination and impose penalty, in the
prescribed manner, not exceeding twice the amount of tax assessed by it.
Sub~sections (3) and (6) of Section 14 which have been the subject
matter of debate may be extracted here :
F
"14. (1) & (2) *** *** ***
(3) Where any specified goods have been brought into the Calcutta
G
Metropolitan Area without the payment of any tax leviable thereon
under this Act, the prescribed authority shall assess the tax leviable
under this Act on such goods and it may also impose on the dealer,
in the prescribed manner, a penalty, not exceeding ten times the tax
-
assessed by it:
Provided that such assessment shall be made after inspection and
verification of such goods, but where such goods are not available for
H inspection and examination by reason of the fact that such goods have
-(
'
STATE v. MD~-KHALIL [SYED SHAH MOHAMMED QUADRI, J.] 1197
been dis~osed of, concealed or mixed with any other goods, such A
assessment shall be made, in such manner and within such time as
may be prescribed, to the best of the ability of the prescribed
authority:
Provided fwther that no penalty shall be imposed under this sub-
section except after giving the dealer a reasonable opportunity of B
being heard.
f
(4) & (5) *** ***
(6) The prescribed authority may, subject to such conditions as may
be prescribed, - C
(a) require any dealer -
(i) to produce before it any accounts, register or document for
examination;
(ii) to furnish any information relating to the stock of goods or D
purchases, sales or deliveries of goods by the dealer or relating
to any other matter, as may be deemed necessary for the purpose
of this section ;
(b) require any person who has in his possession, custody or control
any specified goods or through whom the specified goods are E
suspected by the prescribed authority to have passed, to produce
before it any accounts, register or document for examination
with a view to ascertaining whether any tax leviable under this
Act is oeing or has been assessed or duly paid."
A perusal of sub-section (3) discloses that it is meant to check tax
F
evasion. It deals with a situation where any specified goods have been
brought within the Calcutta Metropolitan Area without the payment of any
tax leviable thereon under the Entry Tax Act. In such a case, which is treated
an agravated violation of the provisions, the prescribed authority has to assess
the tax on such goods and also to impose penalty, in the prescribed manner, G
not exceeding ten times the tax assessed by it on the dealer. The first proviso
)
says that the assessment of the tax has to be after inspection and verification
of such goods. It also provides for what can be termed as the 'best judgment
assessment' when such goods are not available for inspection and examina-
tion for the reason that either they have been disposed of or concealed or H
1198 SUPREME COURT REPORTS [2000] 3 S.C.R.
~
A mixed with any other goods. The second proviso requires that the dealer be ~'
.......,._
given a reasonable opportunity of being heard before the imposition of
penalty.
A plain reading of sub-section (6) shows that it empowers the pre-
scribed Authority to require any dealer to produce before it any accounts,
B register or document for examination and to furnish any information relating
to the stock of goods or purchases, sales or deliveries of goods by the dealer
or relating to any other matter, as may be deemed necessary, for the purpose
of Section 14 of the Entry Tax Act. The prescribed Authority is also
empowered to require any person who has in his possession, custody or
c control any specified goods or through whom the specified goods are
suspected by the prescribed Authority ,to have passed, to produce before it
any register, accounts or document for examination with a view to ascerfain-
ing whether any tax leviable under this Act is being or has been assessed or
duly paid.
D
It may be noticed here that the liability to pay the tax under sub-section
(1) and the tax penalty under sub-sections (2) and (3) is on the dealer. It is
only in a case falling under clause (b) of sub-section (6) of Section 14, that
a person other than a dealer is dealt with and a duty is cast on him to produce
documents, accounts register etc. when he is required to do so by the .....
E prescrilied Authority. The dealer is the person required to deliver the statutory
declaration and is also answerable for the tax as well as for the penalty
imposed under the Entry Tax Act. Therefore, the first thing we have to see .,
whether the respondent is a 'dealer' within the meaning of that term. We have
extracted above the definition of the term 'dealer' and noted four categories
F of persons who fall within the meaning of that term. A person who is in
possession of the specified goods does not fall within the meaning of that
term. It follows that the respondent is not a 'dealer' within the meaning of
the Entry Tax Act.
In the instant case, notice was issued to the respondent under Section
G 14(3) of the Entry Tax Act. It has been held that he is not a 'dealer'. That
apart. for purposes of assessment of specified goods, sub-section (1) of -(
Section 14 of the Entry Ta-v: Act provides for assessment of specified goods
on the basis of the declaration of dealer, albeit after malting such verification
of the specified goods as the prescrib~d Authority may consider necessary.
H Sub-section (2) of Section 14 of the Entry Tax Act provides for assessment
-{
STATE v. MD. KHALIL [SYED SHAH MOHAMMED QUADRI, J.] 1199
~·
~y- on inspection and examination of specified goods where the dealer has failed A
or omitted to make the declaration as required by Section 13 of the Act. For
assessing entry tax under sub-section (3) of Section 14 of the Entry Tax Act,
it has to be shown :
(i) the specified goods have been broughfinto Calcutta Metrnpoli-
tan Area; B
(ii) such goods have been brought without payment of tax leviable
thereon under the Act;
(iii) such goods are found in possession of the respondent.
c
It must be borne in mind that before the tax could be imposed under
sub-section (3) of Section 14 of the Entry Tax Act, the authority will have
)'. to be satisfied of the requirements noted above. Without there being any
material to show that the specified goods in the possession of the respondent
have been brought into the Calcutta Metropolitan Area and that they were
D
brought without payment of any tax leviable thereon, no tax can be levied
under sub-section (3) of Section 14 even on a dealer. It cannot be lost sight
of that the tax under the Entry Tax Act is a tax on the entry of the specified
goods into the Calcutta Metropolitan Area and not on possession of the
specified goods within the Calcutta Metropolitan Area.
E
However, the contention of Mr. Chakravarty is that when specified
goods are found in possession of a person and. when he, on being required
to produce before the Authority any accounts, register or document under
sub-section (6) of Section 14, has failed to do so, a presumption arises that
the specified goods have been brought by him into the Calcutta Metropolitan
F
Area without payment of tax. We are afraid, we cannot accede to this
contention. A presumption is a rule of law which requires the court to draw
a given conclusion on proof or existence of certain facts and leaves it to the
party disputing the conclusion to rebut the same. Presumptions may be of fact
or of law. A presumption is an ipference sanctioned by law which does not
logically or necessarily follow from the proved facts. For raising a presump- G
} tion, as submitted by Mr. Chakravru.ty, there must be a. specific provision in
the Entry Tax Act,: No provision in the said Act is brought to our notice which
may enable the Authority to raise the presumption that a possessor of the
specified goods, who fails to produce before the Authority his accounts,
register or docwnent on being required to.do so, has imported the goods into H
}-,
1200 SUPREME COURT REPORTS [2000] 3 S.C.R.
A the Calcutta Metropolitan Area without payment of tax. On the facts and
circumstances of the case, it is impossible for a Court to infer that the
respondent has imported the goods into the Calcutta Metropolitan Area
without payment of tax.
In the light of the above discussion, we cannot but uphold the im-
B pugned judgments of the Tribunal. The appeals fail and they are accordingly
dismissed with costs.
A.Q. Appeals dismissed.
..
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