TMI Blog2013 (12) TMI 237X X X X Extracts X X X X X X X X Extracts X X X X ..... ts member - Article 4(ii)(h) of the bye laws of the co-operative society permits the membership of the co-operative society to the AOP if it has been approved by the Central Registrar – The issue restored to AO for fresh examination. Deduction u/s 80P(2) (a)(i) - Locker rent – Held that:- the assessee is not carrying on the business of banking. It is carrying on the business of providing credit facilities to its members. This income in our opinion cannot be regarded to be the profits and gains of business attributable to providing credit facilities to its member – The provision of safe deposit vaults is part of ordinary banking business – Decided against assessee. Deduction u/s 80P(2)(a)(i) - Purchase of vehicle fund - Provision for investment fluctuation reserve – Held that:- The investment fluctuation reserve is directly linked with the income from investment business - The deduction is allowed when the provision is made out of such investment income - If the provision for purchase of vehicle fund is made out of the income earned by the assessee from the business of providing credit facilities to members on which the assessee is entitled for deduction under section 80(2)( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nst the order of the Commissioner of Income-tax (Appeals) bearing Nos. 151, 152 and 153/NAG/2012. I. T. A. No. 151/NAG/2012 In all these appeals, the Revenue has taken the following common grounds of appeal : "1. On the facts and circumstances of the case and in law, the learned Commissioner of Income-tax (Appeals) has erred in holding that the activities of the assessee are not those of a co-operative bank. 2. On the facts and circumstances of the case and in law, the learned Commissioner of Income-tax (Appeals) has erred in directing to allow deduction under section 80P to the assessee even though the assessee carries on banking and other business in the name of a credit co-operative society." The only issue involved in each of the assessment years on the grounds taken by the Revenue is whether the assessee is a credit co-operative society or a co-operative bank. The brief facts of the case are that the Assessing Officer during the course of assessment proceedings noted that the assessee has income from banking and non-banking activities. The non-banking activities are mainly that of BOT which is an activity of road construction in the form of a join ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ntemplated : one that carries on the business of banking and the other that provides credit facilities to its members. These are distinct and separate as is evident from the disjunctive clause 'or' used to identify the two categories. It is, therefore, worthwhile to examine the definitions of co-operative society and cooperative bank as per Part-V of the Banking Regulation Act, which is as follows : Section 56 of the Banking Regulation Act : 56. Act to apply to co-operative societies subject to modifications.The provisions of this Act as in force for the time being, shall apply to, or in relation to, co-operative societies as they apply to, or in relation to banking companies subject to the following modifications, namely : (a) Throughout this Act, unless the context otherwise requires, (i) references to a 'banking company' or 'the company' or 'such company' shall be construed as references to a co-operative bank (ii) references to 'commencement of this Act' shall be construed as references to commencement of the Banking Laws (Application to Co-operative Societies) Act, 1965 (23 of 1965) ; (b) in section 2, the words and figures 'the Companies Act, 1956 (1 of 1956) and' s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on a prima facie scrutiny of the audited balancesheet, it is observed that the applicant co-operative credit society has reached the entry point norms, the proposal may be transmitted to our concerned Regional Office. (ii) Before forwarding the proposals to our Regional Office, the Registrar Co-operative Societies may also satisfy himself that the overall methods of operation as revealed by the audit of the applicant co-operative credit society are satisfactory. While sending the proposals to the Regional Office a brief mention about the overall performance of the applicant society and its methods of operation may be made. (iii) On receipt of an "in principle" approval for the proposed conversion of the co-operative credit society into primary co-operative society will have to be advised to amend its bye-laws on the lines of model bye-laws prescribed for primary co-operative banks. It should be made very clear to the applicant society that the bank should not commence its banking business until it adopts model byelaws and it is issued licence by the Reserve Bank of India under section 22 of the Banking Regulation Act, 1949. (iv) The applicant society should submit to the Regi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ant that it is eligible for deduction under section 80P (2)(a)(i). However since the appellant-society carries on various activities other than that of providing credit facilities to members the Assessing Officer is required to ascertain and quantify the income from providing credit facilities to members and consider only such amounts as is eligible for deduction under section 80P(2)(a)(i). This ground is therefore disposed of accordingly." The learned Departmental representative before us vehemently argued that the assessee is involved in a number of activities such as banking, BOT (road construction in the form of joint venture) running a sugar factory on lease basis, running a residential hostel at Tirupati, marketing of agricultural produce, running a boys hostel at Pune and general insurance commission agency. The assessee had income from interest on advance, income from investments, commission income, locker rent, godown rent, etc. This all is tantamount to be income from banking operations. It has income from other different sources which are regarded to be the nonbanking business. The majority of the income is derived from banking operation since the assessee has banking ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd undersigned is the author. We have carefully considered the rival submissions along with the order of the tax authorities below. The question before us is whether the assessee is a co-operative society engaged in carrying on the business of banking or providing credit facilities to its members and its gross total income includes income therefrom. Whether the assessee is eligible to avail of the deduction under section 80P(2)(a)(i). According to this section, if a co-operative society is engaged in carrying on the business of banking or providing credit facilities to its members and its gross total income includes any income therefrom, the co-operative society is entitled to the deduction. Section 80P(2)(a)(i) is explicitly clear that if the co-operative society is engaged in the business of banking or providing credit facilities to its members, the co-operative society is eligible for the deduction. There is an embargo put by section 80P(4) which was introduced into the statute by the Finance Act, 2006 with effect from April 1, 2007. This section denies the deduction to a co-operative society even if the co-operative society is carrying on the business of banking or the co-ope ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e bank. The primary co-operative bank is defined under section 56 clause (ccv) of the Banking Regulation Act, 1949 as under : "(ccv) 'primary co-operative bank' means a co-operative society, other than a primary agricultural credit society, (1) the primary object or principal business of which is the transaction of banking business ; (2) the paid-up share capital and reserves of which are not less than one lakh of rupees ; and (3) the bye-laws of which do not permit admission of any other cooperative society as a member. Provided that this sub-clause shall not apply to the admission of a co-operative bank as a member by reason of such co-operative bank subscribing to the share capital of such co-operative society out of funds provided by the State Government for the purpose :" From the aforesaid definition, it is apparent that if the co-operative society complied with all the three conditions namely that, firstly the primary object or principal business transacted by it is a banking business, secondly, the paid-up share capital and reserve of which are not less than one lakh or more and thirdly bye-laws of the co-operative society do not permit admission of any other co-o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the society will be to promote the interest of all its members to attain their social and economic betterment through self-help and mutual aid in accordance with the co-operative principles. 1. To promote social and economic betterment of members through self-help and mutual aid in accordance with co-operation principles as specified in the first schedule of the Act. 2. To encourage thrift, self-help and co-operation among members. 3. Accept deposit from members. 4. Issue the shares to the members. 5. Give loans to members. 6. To borrow or to raise money for the business of the society. 7. Provide safe deposit vaults and ancillary services. 8. To purchase lease, take on rent land and building and construct building and premises and maintain them for the use of the society or use of its employees or use of its members. 9. Accept grants, subsidies, assistance and concessions from internal and external sources subject to any law for the time being in force. 10. Promote subsidy institutions for the furtherance of the objectives of the society as incidental thereto. 11. The society shall undertake insurance business as corporate agent subjected to approval from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ordingly, in our opinion the provisions of section 80P(4) read with Explanation thereunder will not be applicable in the case of the assessee. The assessee, therefore, in our opinion will be eligible for the deduction under section 80P(2)(a)(i). An almost similar view has been taken by us being the member of the Bench in the case of Deputy CIT v. Jayalakshmi Mahila Vividodeshagala Souharda Sahakari Ltd. [2012] 137 ITD 163 (Panaji), I. T. A. Nos.1 to 3 (PNJ) of 2012, vide order dated March 30, 2012 as relied on by the learned authorised representative. We accordingly confirm the order of the Commissioner of Income-tax (Appeals) allowing deduction to the assessee. In the result, we dismiss all the three appeals filed by the Revenue. Now, we will deal with the appeals filed by the assessee. The various grounds of appeal taken by the assessee in all the three appeals filed by it are given as under : I. T. A. No. 179/NAG/2012 1. The learned Commissioner of Income-tax (Appeals) erred in holding that the income of Rs. 47,26,334 from investment made in joint venture is entitled for deduction under section 80P(2)(a)(i). 2. The learned Commissioner of Income-tax (Appeals) erred in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovision which have been added back to the income and which exclusively pertaining to providing credit facility to members is not eligible for exemption as it is not related to providing credit facility. (d) Addition under section 244A Rs. 1,80,124. (e) Unidentified deposit Rs. 10,81,00,000. (f) Provision for investment fluctuation reserve Rs. 84,83,667. 4. The learned Commissioner of Income-tax (Appeals) erred in not allowing godown rent for Rs. 64,23,821 under section 80P(2)(e). 5. The learned Commissioner of Income-tax (Appeals) erred in confirming the addition of Rs. 10,81,00,000 as unidentified deposits. The amount of deposits being to the various persons. 6. The learned Commissioner of Income-tax (Appeals) erred in adding amount of Rs. 24,96,650. 7. The learned Commissioner of Income-tax (Appeals) erred in confirming the addition of Rs. 11,64,232 in respect of amount received for issuing cheques it was not issued. 8. Alternatively the addition can only be to make to the extent of money received during the year and not the opening balance. 9. The learned Commissioner of Income-tax (Appeals) erred in confirming the addition of Rs. 36,94,180. 10. The learned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ture if any is not eligible for deduction under section 80P(2)(a)(i) as is liable to be brought to tax. In respect of income from investments the ratio of the decision reported in 322 ITR 283 (SC) is relevant. It has been held as follows (page 289) : 'Section 80P(1), inter alia, states that where the gross total income of a co-operative society includes any income from one or more specified activities, then such income shall be deducted from the gross total income in computing the total taxable income of the assessee-society. An income, which is attributable to any of the specified activities in section 80P(2) of the Act, would be eligible for deduction. The word "income" has been defined under section 2(24)(i) of the Act to include profits and gains. This sub-section is an inclusive provision. Parliament has included specifically "business profits" into the definition of the word "income". Therefore, we are required to give a precise meaning to the words "profits and gains of business" mentioned in section 80P(2) of the Act. In the present case, as stated above, the assessee-society regularly invests funds not immediately required for business purposes. Interest on such investme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther hand relied on the order of the Commissioner of Income-tax (Appeals). We have carefully considered the rival submissions along with the document and the material submitted before us. The provisions of section 80P(2)(a)(i) restricts the deduction only to the income which has been earned on providing credit facilities by the society to its member. Whether AOP is a member of the co-operative society or not is a fact which requires verification. In this regard article 4 of the bye-laws of the co-operative society is relevant. Article 4(ii)(h) permits the membership of the co-operative society to the AOP if it has been approved by the Central Registrar. Even a corporation owned or controlled by the Government, Central Government, State Government, or any Government, company can become a member of the society. We therefore, in the interest of justice and fairplay to both the parties set aside the order of the Commissioner of Income-tax (Appeals) and restore this issue to the file of the Assessing Officer with a direction the Assessing Officer shall verify whether the joint venture from where the assessee derived interest income is a member of the assessee co-operative society or n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot be regarded to be the profits and gains of business attributable to providing credit facilities to its member. The hon'ble Supreme Court has allowed the deduction in respect of the locker rent to a co-operative society carrying on the banking business because as per section 6(1)(a) of the Banking Regulation Act, 1949 provision of safe deposit vaults is part of ordinary banking business. This thing cannot hold good in the case of credit co-operative society. The decision given in CIT v. Bhopal Co-operative Central Bank Ltd. [1988] 172 ITR 423 (MP) and Guru Harsahai Primary Co-op. Agrl. Dev. Bank Ltd. v. Asst. CIT [2010] 133 TTJ (Asr) 4 (UO) relate the co-operative society engaged in the banking business. We have also gone through the decision of Bardoli Vibhag Gramin Vikas v. DIT and Bench (O), Incometax Appellate Tribunal, Ahmedabad in I. T. A. No. 3129 and 2985/Ahd/ 2008. This relates to the assessment year 2005-06 prior to the insertion of section 80P(4) which prohibits the deduction under section 80P(2) and (3) to a co-operative society engaged in banking business by the Finance Act, 2006 with effect from April 1, 2007. During the assessment year a co-operative society even e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... purchase of vehicle fund of Rs. 10,00,000 and fringe benefit tax of Rs. 2,86,180 it is seen that the amounts cannot go to increase income for providing credit facilities. Additions on these amounts are therefore to be excluded for the working out of section 80P(2)(a)(i). Similarly as regards the doubtful loan funds of Rs.12,23,263 and NPA provision of Rs. 1,29,26,927 these are provisions of unascertained and contingent liabilities. Similarly donation of Rs. 91,047 has been added back. As appellant has during the year earned income from mixed activities which both include income eligible for exemption and income not eligible for exemption appellant is not entitled to deduction under section 80P(2)(a)(i) in respect of additions made to returned income." The learned authorised representative before us vehemently contended that disallowance of all these four provisions which include the additional ground admitted by us in turn will increase the income from the business of credit facilities provided to the member and accordingly the deduction available under section 80P(2)(a)(i) shall get increased. The learned authorised representative on the other hand contended that the assessee-s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion under section 80P(2)(a)(i) on the income after reducing these amounts. If this is the fact, the Assessing Officer is directed to increase the deduction available to the assessee to the extent the provisions so disallowed. Thus this ground is allowed for statistical purposes. Ground No. 4 which relate to the godown rent was not pressed by the assessee as the Commissioner of Income-tax (Appeals) has duly allowed deduction to the assessee under section 80P(2)(a)(i). We accordingly dismiss this ground. I. T. A. No. 180/NAG/2012 Ground Nos. 1 and 2 in the appeal filed by the assessee has already been disposed of by us while disposing of the assessee's appeal for the assessment year 2007-08. Ground Nos. 3, 4 and 5 since not pressed by the assessee therefore they are dismissed as not pressed. So far the deduction under section 80P(2)(a)(i) in respect of provision for doubtful loan fund taken by the assessee as additional ground, we have already held while disposing of ground No. 3 for the assessment year 200708 that the facts are to be verified whether the provision for doubtful loan fund has been made out of the income earned for providing credit facilities to the member ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... relying on the provisions of section 292C added the sum of Rs.8,98,420. When the matter went before the Commissioner of Incometax (Appeals), the Commissioner of Income-tax (Appeals) confirmed the addition holding that the assessee failed to discharge its onus satisfactorily relying on the decision of the hon'ble Delhi High Court in the case of Smt. Urmila Gambhir v. CIT [2010] 325 ITR 171 (Delhi). Before us the learned authorised representative reiterated the submissions made before the Assessing Officer and vehemently contended by referring to the facts of the case in the case of Smt. Urmila Gambhir v. CIT [2010] 325 ITR 171 (Delhi) that the said decision is not applicable. In that case, the assessee has duly purchased the agricultural land for which expenditure were mentioned in the loose sheet. The assessee never denied that the paper was not in the handwriting of its employees. Even one paper showing the land rate prevailing at that time was also found and seized which corroborated the figures given in the loose sheet seized. The learned Departmental representative on the other hand relied on the authorities below. We have carefully considered the rival submissions along with t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th this approach of the Assessing Officer as in our opinion the explanation given by the assessee is bona fide and plausible. We therefore, delete the addition by setting aside the order of the Commissioner of Income-tax (Appeals) on this ground. Thus this ground is allowed. I. T. A. No. 181/NAG/2012 Ground Nos. 1 and 2 we have already disposed of while disposing of I.T.A. No. 179/NAG/2012 in the preceding paragraph of this order. Ground No. 3 relates to the sustenance of addition in respect of (a) interest on refund of income-tax, (b) unidentified deposit, and (c) provision for investment fluctuation reserve. So far ground No. 3(a) is concerned, the learned authorised representative did not press it during the course of hearing ; therefore ground No. 3(a) stands dismissed as not pressed. Ground No. 3(b) is the same as ground No. 5 therefore it will be disposed of subsequently as ground No. 5. Ground No. 3(c) is similar to the ground No. 3(c) in I. T. A. No. 179/NAG/2012. Both the learned authorised representative and the Departmental representative agreed to the same and stated whatever view this Tribunal may take in respect of ground No. 3(c) for the assessment year 2007-08 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 10.81 crores. The assessee made the claim of deduction under section 80P(2)(a)(i) which was also rejected. The assessee went in appeal before the Commissioner of Income-tax (Appeals), the Commissioner of Income-tax (Appeals) confirmed the addition and also rejected the claim of deduction under section 80P(2)(a)(i) by holding as under : "13. I have carefully considered the issue before me. It is necessary to appreciate that the assessee has received these amounts by way of cash and systematically entered the deposits in the name of existing fictitious persons for amounts below Rs. 20,000. This exercise has been done to facilitate acceptance of deposits and repayment of deposits by cash. It is further admitted that these amounts are received from parties to whom the KYC norms have not been applied. 14. The answer to question 4 of Shri Radheshyam Chandak in the course of statement recorded under section 132(4) clearly indicates modus of operandi followed by the assessee and the reason for the disclosure of the amount of Rs. 10.10 crores. The said extract of the said answer is reproduced below : I have gone through your question carefully and have also gone through th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ows : Search and seizure action under section 132 of the Income-tax Act, 1961 was carried out at the business and other office premises of the society on March 20, 2009. During the course of search statement under section 132(4) of the chairman of the society was recorded on May 17, 2009 and as per the statement it was stated that during the course of search various documents in respect of deposits made by different persons were found. The persons in-charge at the head office and in different branches have attended and explained and clarified the queries putforth from time to time. The society which is in the swift mode of development phase has expended its branches not only in Maharashtra but in nearby other states. The manpower, viz., manager, assistant manager and other staff are not fully equipped with KYC norms as well as other banking and financial regulations. As per the statement under section 132(4) on May 17, 2009 it was admitted by the chairman of the society that due to swift expansion certain KYC norms would not be fulfilled like photographs, etc. To safeguard the interest of the society and depositors, the society has offered additional income on this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of providing credit facilities to members income of which is eligible for exemption under section 80P(2)(a)(i). Further it is to be appreciated that the income received from the business of providing credit facilities to members would be only in the nature of interest income. Here the issue in dispute is the amount of alleged deposits which have been accepted as unexplained and offered to tax. I am of the view that when there is violation of established KYC norms and a systematic attempt to circumvent the provisions of section 269SS of the Income-tax Act by accepting amounts below Rs. 20,000 by way of cash it cannot be held that these amounts have been received during the course of carrying on business of providing credit facilities to members. It is also necessary to note that in the statement recorded under section 132(4) on May 16, 2009 and subsequent letter dated June 25, 2009 the appellant has unequivocally admitted that the amount is undisclosed income and offered to pay the taxes thereon. The subsequent claim that this amount is eligible for deduction under section 80P(2)(a)(i) is not tenable as the appellant has failed to establish that this amount is income from business o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion for decision is whether the juristic person should be answerable or its human face through it acts should be answerable. Unobjectionably it is the board of directors. (v) The enquiry should have been directed against the depositors only who are to be considered as the persons owning the deposits. (vi) These deposits have been returned to them also. The details of return of the deposit are filed in the separate paper book. (vii) If depositors place the money in the bank whose numbers are very large, the board of directors cannot remember them all nor can they be expected to substantiate the creditworthiness of the persons concerned as in the case of an individual or Hindu undivided family or firm, etc. (viii) These are deposits which the public place with the bank on their own violation. These are not deposits solicited individually by the board of directors or any person employed by the society. Deposits are different from loans and they should be treated in the manner. (ix) The onus is lighter than in other cases. State Bank of India will not be able to establish the genuineness of the crores of depositors amount. (x) These are not individual oriented but public or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re us and the case law cited before us during the course of hearing. We noted that during the course of search one document was seized. The ownership of which has not been denied by the assessee, it contains handwritten noting being the details of the deposits received by the assessee. These sheets also contain details, of the receipt of membership fees on specific dates. The branch manager admitted that the receipt represents membership fee. It was noted that there was violation of KYC norms. The Assessing Officer took the view that these were the unaccounted deposits in fictitious names. The chairman of the assessee's credit society in his statement recorded on May 16, 2002 offered additional income of Rs. 10.10 crores to protect the interest and reputation of the society. In the said statement he stated that the said sum is offered as income as the society could not strictly follow the KYC norms and since these deposits earned are now withdrawn. The assessee does not have any control over these deposits. He also stated in the said statement since the assessee did not follow the KYC norms, it is not in a position to identify the depositors at this stage. Subsequently, he reworked ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee failed to comply with the KYC norms which could have taken in the case of the assessee to be the charging of the onus by the assessee. The assessee cannot be saved from the clutches of the provisions of section 68 by taking the shelter that manpower of the society engaged for this business was not fully equipped and properly trained and due to which there had been lapses in complying with KYC norms. The decision of CIT v. Lovely Exports P. Ltd. [2009] 319 ITR (St.) 5 (SC) in our opinion will not apply in the present case as in that case the money was given by the shareholders for a consideration, i.e., against the allotment of the shares. This is a case where deposits have been received by the assessee to whom it is to be repaid on demand or after the expiry of fixed period. We therefore, confirm the addition under section 68. To that extent we confirm the order of the Commissioner of Income-tax (Appeals). Now the question arises whether the income so added will be the profit and gains from business or not. While disposing of the appeal of the Revenue, we confirm the order of the Commissioner of Income-tax (Appeals) holding that the assessee is not a co-operative bank therefor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome-tax Act. We have gone through the decision of the Supreme Court in the case of India Leather Corporation P. Ltd. [1997] 227 ITR 552 (SC) as relied by the Commissioner of Income-tax (Appeals). In this case Supreme Court took the view that "it is no doubt true that the words "attributable to" have a wider meaning than the words "derived from". But at the same time it cannot be ignored that normally the word "attributable" implies that "for a result to be attributable to anything it must be wholly, or in material part, caused by that thing". (see : Stroud's Judicial Dictionary, 5th edition, volume I, page 223). A casual connection is necessary. In order that income can be said to be attributable to manufacture or processing of goods for the purpose of the Explanation to section 104(4) of the Act the earning of the income must be directly connected with manufacture or processing of goods. It is also necessary that a material part of the said income should have been earned by that activity." Now the question arises whether the income so added under section 68 being the deposits in respect of which KYC norms were not complied with can be regarded to be the amount of profit and gains ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... judgment reads as under : "Deduction under section 80P(2)(a)(i)-Providing credit facility to members-Loans to members only-As per definition of a 'member' given in Maharashtra Co-operative Societies Act members include nominal members also who are admitted as per the bye-laws of the society-Assessee giving loans only to its members-Therefore, it satisfied the conditions laid down under section 80P(2)(a)(i) and was entitled to deduction cash credit, even if taxed, would be considered as income from the same business, i.e., providing credit facilities to the members, and accordingly, it would also be entitled to deduction under section 80P-Bye-laws do not take the character of the statute-Violation of bye-laws by the assessee could not lead to the automatic conclusion that the assessee was not a co-operative society-Government auditor or the Registrar has not held that the assessee has ceased to be a co-operative society nor have they cancelled the registration of the assessee as a co-operative society-assessee-society would continue to enjoy the status of a cooperative society and, therefore, deduction under section 80P would be available to it." The aforesaid decisi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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