|
Advanced Search Options
Case Laws
Showing 301 to 320 of 1054 Records
-
2011 (2) TMI 1335
Issues:
Interpretation of Section 6A of the Andhra Pradesh General Sales Tax Act, 1957 regarding tax liability on goods purchased for manufacturing and sale.
Analysis:
The judgment pertains to a revision filed against the order of the Sales Tax Appellate Tribunal (STAT) in a case involving the interpretation of Section 6A of the Andhra Pradesh General Sales Tax Act, 1957. The respondent, an assessee, was involved in the production and sale of agarbathies. The key issue before the STAT was whether raw-agarbathies should be considered a distinct commercial product from the finished agarbathies. The STAT referred to various legal precedents, including judgments from the Supreme Court and different High Courts, to determine that for a product to be considered distinct, the raw material must undergo a significant change resulting in a different product. In this case, the raw-agarbathies did not lose their identity after the manufacturing process, and thus, the purchase turnover related to raw-agarbathies was not subject to tax under Section 6A of the Act.
The judgment emphasized that under Section 6A, goods purchased must be consumed in the manufacturing process of other goods for sale to be liable to tax. The manufacturing process should result in the emergence of another product, indicating a different commercial product. The STAT observed the process of making agarbathies, where raw agarbathies were prepared by mixing various ingredients, rolled into shape, and then scented before sale. It was concluded that raw-agarbathies retained their identity even after scenting, and therefore, Section 6A did not apply to them.
The High Court, concurring with the STAT's well-reasoned order, found no error of law or omission in deciding legal questions. Consequently, the High Court dismissed the tax revision case, upholding the decision of the STAT. This judgment clarifies the application of Section 6A of the Act concerning the tax liability on goods purchased for manufacturing and sale, emphasizing the need for a significant transformation in the raw material to constitute a different commercial product for tax purposes.
-
2011 (2) TMI 1334
Seizure proceeding initiated under section 48(7) of the U.P. VAT Act - Held that:- It would meet the ends of justice if the goods are allowed to be released on furnishing security equal to the amount of tax that is leviable on the goods seized and for the remaining amount upon furnishing security other than cash or bank guarantee to the satisfaction of the authority. It is further directed that so far as entry tax is concerned, the petitioner shall furnish security other than cash or bank guarantee to the extent of 20 per cent instead of 40 per cent as demanded by the authority.
On such prayer being made it is provided that it will be open for the applicants to furnish bank guarantee in case it is not able to arrange for the security other than bank guarantee as directed above.
-
2011 (2) TMI 1333
Whether the sale was not an "inter-State sale" but was an "intra-State sale" and consequently, liable to payment of tax under the Tamil Nadu General Sales Tax Act?
Held that:- From the orders impugned in these writ petitions, we are not able to ascertain whether or not the transactions suffered tax under the Central Sales Tax Act or what is the date of bill raised pursuant to such transfer claimed to have been made by the petitioner in favour of such purchases in the State of Tamil Nadu. In order to ascertain the said fact, it has become imperative to remit the matter back to the assessing authority, so that, the petitioner as well as the respondent-Department can place necessary materials to enable the assessing authority to conclude whether the sales effected fall strictly under section 3(b) of the Central Sales Tax Act for the petitioner to claim relief under the said provision.
Appeal allowed. The matters are remitted back to the third respondent to examine the above factors, namely, whether the sales effected suffered tax under the Central Sales Tax Act as well as the date of the bill raised by the petitioner with reference to such sales effected toy the petitioner
-
2011 (2) TMI 1332
Whether the Sales Tax Department can claim priority of debt over others in regard to the arrears of tax due to the Stave?
Held that:- The order of attachment made by the Commercial Tax Department invoking the provisions of the Revenue Recovery Act does not hold good, insofar as the property which was taken possession by the third respondent invoking section 29 of the State Financial Corporations Act, 1951 is concerned. Since the possession of the property has already been taken by the secured creditor, there is no question of attaching the said property by the Commercial Tax Department. The Sub-registrar was not justified in refusing to register the sale deed executed by the third respondent in favour of the petitioner. Therefore, the document produced by the petitioner dated November 11, 2010, duly executed by the third respondent, requires consideration by the second respondent, disregarding the order of attachment made by the first respondent. W.P. allowed.
-
2011 (2) TMI 1331
Issues:
Assessment under Karnataka Sales Tax Act, 1957 - Reopening of assessment for assessment year 2003-04 based on availability of original application form 8AA - Validity of revisional authority's decision under section 22A - Composition scheme for payment of tax - Deemed permission if certificate not issued within 30 days of application - Dispute regarding availability of original application form.
Analysis:
The appeal before the High Court was against the order passed by the revisional authority under section 22A(1) of the Karnataka Sales Tax Act, 1957. The assessee, a registered dealer under the Act, had filed returns for the assessment year 2003-04 and opted for a composition scheme by applying tax at four per cent on the declared value. Subsequently, a notice was issued seeking documentary evidence for a specific turnover related to a labor contract and the application for opting the composition scheme. The Joint Commissioner accepted the tax payment on labor receipts under the composite scheme. However, the Additional Commissioner initiated suo motu proceedings to review the order, citing the unavailability of the original form 8AA in the records.
The Additional Commissioner rejected the assessee's plea and passed an order deeming the Joint Commissioner's decision prejudicial to revenue. The assessee filed an application seeking revision of the order under section 25A, which was also rejected. The High Court noted that the assessee had regularly filed applications for composition tax subsequent to the disputed period, and the Xerox copy of the application was available in the department's records. The court emphasized that the unavailability of the original application after five years could not be a valid reason to set aside the assessment order accepting the composition tax paid by the assessee.
The High Court found that the revisional authority was unjustified in interfering with the Joint Commissioner's order. Consequently, the appeal was allowed, the impugned order was set aside, and the original order was restored. The court directed each party to bear their costs.
-
2011 (2) TMI 1330
Issues:
1. Exemption eligibility under the U.P. Trade Tax Act and Central Sales Tax Act.
2. Claim for refund of excess tax deposited under the Acts.
3. Interpretation of sections 29 and 29A of the U.P. Trade Tax Act.
4. Consideration of adjustment of tax realized with the monetary limit.
Exemption Eligibility: The judgment pertains to two revisions against the Tribunal's order for the assessment year 2000-01 under the U.P. Trade Tax Act, 1948, and the Central Sales Tax Act, 1956. The applicant established a manufacturing unit and applied for exemption under the expansion scheme, which was granted from the date of application. The applicant claimed 100% exemption on the turnover, which was allowed by the assessing authority without dispute.
Claim for Refund: The applicant sought a refund of excess tax deposited during a specific period under both Acts. The refund was refused under section 29A of the U.P. Trade Tax Act. The applicant contended that the excess amount deposited should be refunded under section 29 of the Act and suggested adjusting the tax paid against the monetary limit for subsequent years.
Interpretation of Sections 29 and 29A: The applicant argued that the excess amount deposited should be refunded under section 29 of the Act. However, the standing counsel contended that refund under section 29A(3) is only permissible to parties from whom the tax was realized. The court held that since the applicant realized and deposited the tax, refund under section 29 was not applicable, and section 29A(3) governed the refund process.
Adjustment of Tax Realized: The court rejected the applicant's claim for adjusting the tax realized with the monetary limit. The assessing authority had already granted 100% exemption on the turnover, and there was no provision in the Act for such an adjustment. The court emphasized that without specific provisions allowing adjustment, the claim could not be accepted.
Conclusion: The court dismissed both revisions, ruling that the applicant was not entitled to a refund under section 29 due to realizing and depositing the tax. Additionally, the claim for adjustment of the excess tax paid with the monetary limit was rejected as there was no provision for such adjustment in the Act.
-
2011 (2) TMI 1329
Tax on the purchases of bricks - whether the assessee was neither the manufacturer nor importer of the bricks?
Held that:- In the present case, the purchase voucher of the purchases of bricks could not be furnished therefore the assessee failed to establish that the tax on the bricks have been levied or is leviable under this Act. In the absence of purchase voucher it has not been established that the brick-kiln owner from whom the bricks have been purchased was under the compounding scheme under section 7D of the Act and the tax has been paid under the compounding scheme. In the circumstances, the claim of exemption cannot be allowed. For the purposes of levy of tax under section 3F of the Act and the determination of the net turnover the point of levy of tax under the notification is not relevant. Under the Notification No. 2-711 dated February 27, 1997 only the rate of tax mentioned in the notification is relevant and not the point on which the commodity is liable to tax. Therefore, the argument of learned counsel for the assessee cannot be accepted. Against assessee.
-
2011 (2) TMI 1328
Penalty levied for alleged evasion of tax for inter-State purchase of steel cylinders used in the packing and sale of medical oxygen.
Held that:- Even though rule 58(18) of the Rules does not authorise the petitioner being registered dealer to use form 16 for transport of capital goods, namely, cylinders purchased inter-State, the petitioner's counsel submitted that through a circular the Commissioner has permitted registered dealers also to transport goods purchased for own use under cover of form 16 issued. In view of the Commissioner's order, we feel the violation, if any by the petitioner, is only technical not involving any evasion of tax, and so much so, there is no case of penalty against the petitioner. Penalty cancelled. Appeal allowed.
-
2011 (2) TMI 1327
Rehabilitation scheme - outstanding dues - Held that:- The words "outstanding dues" and "current dues" have to be understood in the context in which rehabilitation scheme is prepared, and the object and purpose of section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985 (SICA). The object of preparing rehabilitation scheme, and to give a protective umbrella to the sick units for rehabilitation is to provide for deferment or for a different treatment of the payment of dues, prior to the cut-off date, which may be termed as outstanding dues. The current dues for the purpose of rehabilitation scheme are those dues, which fall due after the cut-off date. The liabilities created, taxes falling due, assessed and demand raised after the cut-off date, do not fall within the protection of section 22 of the SICA Act. Any demand in pursuance of the assessment orders, prior to the cut-off date has to be classified as outstanding dues, to be protected by the rehabilitation scheme. In the case of reassessment, after remand of a period prior to cut-off date, the dues do not partake the character of current dues.
The writ petition is allowed with declaration that demand for the years 1983-84 and 1986-87, on the orders passed by Assistant Collector, Grade I, Commercial Taxes, Modi Nagar, Ghaziabad shall be included, and be treated as covered by the rehabilitation scheme, as it was framed, or may be modified subsequently. If any amount has been recovered by way of attachment, the same will be subject to adjustment by the BIFR, or provision may be made for its adjustment, in the rehabilitation scheme.
-
2011 (2) TMI 1326
Whether the petitioner is entitled for an order of rectification on the basis of a subsequent order permitting him to pay tax under section 7C of the TNGST Act?
Held that:- The issue regarding the payment of tax under section 7C of the TNGST Act was considered by the assessing authority as well as by the appellate authority. The claim made by the petitioner was rejected on merits. The order is now sought to be rectified on the basis of a subsequent order permitting payment of tax under section 7C of the TNGST Act. The permission granted to pay tax under section 7C(1) for the assessment year 2002-03 was made only on account of the exercise of option during the said year. Therefore, the permission granted for the year 2002-03 would not help the petitioner to rectify the assessment order passed for the year 2001-02. Therefore, I am of the view that the first respondent has rightly rejected the application submitted by the petitioner for rectification. I do not find any error or illegality in the said order warranting interference by this court, by exercising the power of judicial review. W.P. dismissed.
-
2011 (2) TMI 1325
Assessee challenging the order passed by the authorities levying Central sales tax as well as penalty for the goods sold to an extent of ₹ 2,24,24,991
Held that:- In the KST Act, if the return filed is incorrect or incomplete, the assessing authority shall assess the dealer to the best of its judgment recording reasons for such assessments after hearing him and then when making such an order, the authority is empowered to levy penalty. The case of the assessee squarely falls within the aforesaid events, i.e., it is both the case of an incorrect return and an incomplete return. Therefore, the assessing authority was justified in imposing the penalty. The three fact-finding authorities have concurrently held that the tax and penalty is leviable and the said finding is based on legal evidence and within the four corners of law. No case for interference in the revision is made out. Accordingly, the petition is rejected
-
2011 (2) TMI 1324
Clarification issued by the prescribed authority under section 94 of the Kerala Value Added Tax Act, 2003 challenged
Held that:- It is for the appellants to remit the tax with interest on the entire amount collected under the building agreement in terms of the KVAT Act provisions within a period of three weeks from date of receipt of copy of this judgment. There will be direction to the assessing officer to withhold penalty proceedings for two months from now and thereafter consider penalty by taking into account payment of tax and interest as above. Even though counsel for the appellants stated that they are not directly executing contracts and they are engaging sub-contractors who are registered and remitting tax, we are not dealing with tax liability of the appellants in relation to sub-contractors which is a matter to be considered in the course of making assessment by making appropriate claims of exclusions, rebates or set-off applicable in respect of sub-contracts.
-
2011 (2) TMI 1323
Issues:
1. Eligibility of credit on GTA services used for transporting goods from factory to port of export.
2. Disallowance of credit by original authority and imposition of penalties.
3. Decision of the Commissioner (Appeals) setting aside the order of the original authority.
4. Interpretation of "place of removal" in the context of availing Cenvat credit on transportation services.
5. Applicability of Board's circular on determining eligibility for Cenvat credit.
6. Ownership transfer and conditions for availing credit on outward transportation services.
7. Relevance of previous judicial decisions in similar cases.
Eligibility of Credit on GTA Services:
The case involved a dispute regarding the eligibility of availing Cenvat credit on GTA services used for transporting goods from the factory to the port of export. The respondents, being manufacturers of gherkins, exported their products on f.o.b. basis and claimed Cenvat credit on GTA services. The issue arose when a show-cause notice alleged that the credit taken on outward freight was not eligible. The original authority disallowed the credit, imposed penalties, and ordered interest payment. However, the Commissioner (Appeals) set aside this order.
Decision of the Commissioner (Appeals):
The Commissioner (Appeals) accepted the respondents' view that the GTA services qualified as input services for availing credit. They argued that since the price was f.o.b. basis and ownership transfer occurred only upon obtaining the bill of lading, the conditions stipulated by the Board were satisfied. The Commissioner (Appeals) also relied on the decision of the High Court of Punjab and Haryana in a similar case, supporting the respondents' position.
Interpretation of "Place of Removal" for Cenvat Credit:
The determination of the "place of removal" was crucial in deciding the eligibility for availing credit on transportation services. The Board's circular emphasized that for a manufacturer/consignor, the eligibility depended on where the ownership transfer occurred. In cases where the sale was deemed to take place at the destination point, and the freight charges were integral to the price, credit on transportation services could be admissible.
Applicability of Board's Circular and Previous Judicial Decisions:
The Commissioner (Appeals) accepted the respondents' claim that the Board's circular applied to their case, despite the original authority not addressing this aspect. The ownership transfer through the bill of lading at the port of export was deemed reasonable by the Commissioner (Appeals), supported by the cited judgment of the High Court of Punjab and Haryana. The decision of the Larger Bench of the Tribunal, which was under appeal in another case, was not relied upon by the Commissioner (Appeals), making the stay order irrelevant in this context.
Conclusion:
The appeal by the Department was rejected, and the cross-objection supporting the Commissioner (Appeals) was disposed of. The judgment highlighted the importance of ownership transfer and the interpretation of "place of removal" in determining the eligibility for availing Cenvat credit on transportation services, ultimately upholding the decision of the Commissioner (Appeals) in favor of the respondents.
-
2011 (2) TMI 1322
Issues:
1. Application of section 29A of the U.P. Trade Tax Act on a private limited company for the assessment year 1999-2000.
2. Dismissal of appeals filed by the applicant against the assessment order.
3. Interpretation of credit notes issued by the applicant as refund of tax to customers.
4. Allegation of failure by the assessing authority to consider evidence of direct refund to customers.
5. Legal errors by the Tribunal in applying section 29A without considering refund evidence.
Analysis:
1. The judgment dealt with the application of section 29A of the U.P. Trade Tax Act on a private limited company for the assessment year 1999-2000. The assessing authority applied section 29A to a sum deposited by the applicant concerning rebates and discounts to customers. The applicant contended that since the rebate amount was refunded to customers, it should not be treated as tax on turnover subject to forfeiture under section 29A.
2. The appeals filed by the applicant against the assessment order were dismissed by the Joint Commissioner (Appeals) and the Trade Tax Tribunal. The Tribunal did not accept the applicant's argument that the credit notes issued were refunds of tax to customers. The Tribunal considered the credit notes as discounts offered to purchasers, not direct tax refunds.
3. The interpretation of credit notes as tax refunds was a crucial point of contention. The applicant argued that the credit notes issued were indeed refunds of tax to customers. The applicant presented evidence, including a decision in a previous case, to support the claim that direct refunds to purchasers should be considered and not subjected to further deposits with the Department.
4. The assessing authority was alleged to have failed to consider the evidence presented by the applicant regarding direct refunds to customers. The Tribunal's lack of specific findings on whether the applicant had refunded the entire tax amount realized from purchasers led to a legal error in applying section 29A.
5. The judgment concluded that the Tribunal erred in law by not considering the evidence of direct refunds to customers and applying section 29A without proper assessment. As a result, the Tribunal's order was set aside, and the matter was remanded back to the Tribunal for a fresh decision based on the court's previous decisions. The revision filed by the applicant was allowed based on the legal errors identified in the Tribunal's decision.
-
2011 (2) TMI 1321
Whether the respondent/Deputy Commercial Tax Officer, Ettayapuram, Tuticorin District, is entitled to claim interest for the belated payment so made by the petitioner in respect of Sree Krishna Carbide Industry as per the notice of demand dated August 31, 2005?
Held that:- This court is of the considered view that in a case where the court of law has permitted the petitioner to pay the tax liability due amount in instalments, then, the claim/levy of interest by the respondent as per demand notice dated August 31, 2005 for the period 1998-99 amounting to a sum of ₹ 1,41,882 is not warranted in view of the peculiar facts and circumstances of the present case which float on the surface.
This court is perforced to interfere with the order passed by the respondent/Deputy Commercial Tax Officer, Ettayapuram, Tuticorin District, dated August 31, 2005 and since the same is not in order and a valid one in the eye of law, this court sets aside the same to promote substantial cause of justice. Viewed in that perspective, the writ petition is allowed.
-
2011 (2) TMI 1320
Denial of deduction on the discounts by the second respondent only on the premise that the discounts had been granted through credit notes raised subsequent to the tax invoices which would result in the reduction of turnover/price and constitute tax liability
Held that:- The sale invoice given by the dealer would be assessed on the total turnover of the assessee. But, the credit notes subsequently issued by the assesse would automatically result in lowering the amount of turnover and results in lower quantum of sales tax and that is the conclusion arrived at by the Division Bench in similar situation treating this as only "incentive" and not as "trade discount". The assessing officer has tried to distinguish and imposed tax on the total turnover on the basis of the invoices issued without taking into consideration the discount extended in the sale transactions, which is usually permissible and it is also in vogue in the sale of goods.
In the circumstances, the impugned order passed by the assessing officer at annexure L is quashed
-
2011 (2) TMI 1319
Issues involved:
1. Whether cut and embossed foil in the manufacture of cigarettes is dutiable.
2. Whether the refund claim of the assessee should be granted according to Section 11B.
Issue 1 - Cut and Embossed Foil:
The appeal was filed by the Commissioner of Central Excise, Mumbai-V challenging the CESTAT's order dated 24-8-2005, which directed the original authority to grant the refund claim of the assessee. The Assistant Commissioner of Central Excise had initially rejected the refund claim on the grounds that embossing and cutting of duty paid aluminium foil constituted manufacture. However, the Commissioner (Appeals) allowed the appeal of the assessee, stating that no marketable commodity emerged from embossing/cutting the foil, and thus duty paid on such activity should be refunded. The CESTAT upheld the Commissioner (Appeals) decision and directed the original authority to handle the refund as per Section 11B of the Central Excise Act, 1944. The Revenue challenged this decision under Section 35G of the Act. The appellant argued that embossing and cutting the foil amounts to manufacturing, but the High Court held that the resulting product did not become a distinct marketable commodity, and therefore, no excise duty is leviable on it.
Issue 2 - Refund Claim and Section 11B:
The High Court ruled that once it is established that the assessee is entitled to a refund, it can only be allowed subject to the provisions of Section 11B of the Central Excise Act, 1944. The Court answered both questions in favor of the assessee and against the Revenue. The appeal was disposed of with no order as to costs.
-
2011 (2) TMI 1318
Issues:
1. Challenge to order passed by revisional authority regarding deduction of expenditure.
2. Dispute over actual expenditure claimed by the assessee.
3. Jurisdiction of proceedings under section 22A(1) of the Karnataka Sales Tax Act, 1957.
4. Assessment of deductions based on vouchers and receipts.
Issue 1: Challenge to Order Passed by Revisional Authority
The appellant, a civil works contractor, challenged the revisional authority's decision that set aside the first appellate authority's order granting deduction of actual expenditure and substituted it with 30% of the expenditure. The appellate authority had directed the assessing authority to grant deductions based on the actual expenditure incurred as supported by documents adduced by the assessee. However, the revisional authority found that the claim of labour and like charges was not adequately supported by proper evidence and granted 30% deductions instead. The court upheld the revisional authority's decision, emphasizing the importance of proper verification and supporting evidence for deductions.
Issue 2: Dispute Over Actual Expenditure Claimed
The assessing authority initially declined to grant the actual expenditure claimed by the assessee, restricting labour and like charges to 25% of the total contract receipts. The appellate authority, upon review, found that the assessing authority had not provided sufficient reasons for rejecting the documents supporting the claim for deductions. It directed the assessing authority to recompute the taxable turnover based on the actual expenditure incurred by the assessee. However, the revisional authority later determined that the claim for labour charges and similar expenses was not adequately supported by relevant evidence, leading to the grant of 30% deductions instead of the full amount claimed.
Issue 3: Jurisdiction of Proceedings under Section 22A(1)
The appellant contended that the initiation of proceedings under section 22A(1) of the Karnataka Sales Tax Act, 1957, was without jurisdiction. However, the court disagreed, stating that the revisional authority was justified in initiating the proceedings to protect the interest of the Revenue. The revisional authority examined the books of accounts, vouchers, and receipts, and concluded that the claim for expenditure was not fully substantiated by proper evidence, hence granting 30% deductions as allowed by law.
Issue 4: Assessment of Deductions Based on Vouchers and Receipts
The assessing authority and the appellate authority had differing views on the grant of deductions based on the entries in the books of accounts. While the appellate authority favored granting deductions based on the entries made, the assessing authority required proper verification and supporting evidence for each claim. The court upheld the revisional authority's decision to grant 30% deductions, as it found that the claim for expenditure lacked adequate support from vouchers and receipts. The court emphasized the importance of proper verification and evidence in determining allowable deductions.
In conclusion, the court rejected the appellant's appeal, affirming the revisional authority's decision to grant 30% deductions instead of the full actual expenditure claimed, based on the lack of proper supporting evidence for the expenses incurred by the assessee.
-
2011 (2) TMI 1317
Whether entry 54 of List II of Seventh Schedule to the Constitution of India empowers the State Legislature to enact a provision for the penalty for non-filing of return and non-payment of tax?
Whether the said provision, if such a power vests in the State Legislature, could be declared ultra vires on the ground that it is arbitrary and confiscatory in nature and as such, violative of articles 14 and 19(1)(g) of the Constitution of India?
Whether the impugned provision is liable to be struck down on the ground of being violative of the principles of natural justice?
Held that:- Difficult to agree with the reasoning of the learned single judge who has held that the offending provision is arbitrary, confiscatory in nature, irrational and unreasonable and violative of articles 14 and 19(1)(g) of the Constitution of India. Therefore, the said order of the learned single judge is liable to be set aside and the constitutional validity of section 72(1) of the Act is to be upheld.
All the writ appeals are allowed.The order passed by the learned single judge striking down section 72(1) of the Act is hereby set aside.It is declared that section 72(1) of the Act is constitutionally valid. It does not suffer from the vice of arbitrariness, irrationality and is not confiscatory in nature and is not hit by articles 14 and 19(1)(g) of the Constitution of India. The order passed by the learned single judge insofar as quashing of the demand notices and assessment orders stands, but the entire matter is now remitted back.
-
2011 (2) TMI 1316
Whether in the facts of the present case the writ petitioner is entitled to get benefit of section 39 of the 1994 Act?
Held that:- In order to get the benefit of tax holiday registration with the Directorate of Cottage and Small Scale Industries is mandatory. It appears that the order dated April 4, 2003 rejecting registration under the 1994 Act has not been challenged by the writ petitioner and thus, has attained the finality.
in order to get the benefit under the provisions of section 39 of the 1994 Act, the writ petitioner must comply with the requirement of the said Act and the Rules framed thereunder. The learned Tribunal below rightly concluded that no exemption could be granted ignoring the provisions of the 1994 Act or the Rules framed thereunder. Appeal dismissed.
............
|
9911796707
