TMI Blog2016 (9) TMI 555X X X X Extracts X X X X X X X X Extracts X X X X ..... sclosure income is untenable because the Commission has got not only power to decide the lis before them but also to find out if at all any income left out or could not be disclosed by the assessee to come to a mechanism of settlement. The settlement of lis is not only covered by the dispute arose before them but also for the dispute yet to come. So the Commission has got wide power to consider the income disclosed, add additional income after due investigation and also to add any income which is found to be valid as per report under Rule-9 submitted by the Department and finally settle the tax payable by the assessee. Where there is a term of settlement including demand by way of tax, penalty or interest and such payment has been made, but subsequently found by the Settlement Commission that it has been obtained by fraud and misrepresentation, the Commission has power to declare the said settlement as void. When the order of the Commission has been communicated to the Department, the Department could have agitated before the Commission to declare the same as void but instead as appears from the arguments of both sides that in terms of the settlement, the Assessing Officer has b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct, 1961 (hereinafter called as the Act ) is under challenge by the Commissioner of Income Tax, Sambalpur, the petitioner. Facts 2. The factual matrix leading to this case is that on 12.11.2009, there were search and seizure operation made under Section 132 of the Act in the business premises of Sri Kamaljeet Singh Ahluwalia and group and several incriminating documents, cash and other material were seized. The search operation was made by opposite parties 2 to 6 for the assessment years ranging from 2004-05 to 2010-11. The Ahluwalia group has got business in iron ore mining, sponge iron ore plant and rolling mill. This group has also business of manufacturing of cement. The statement of Sri Kamaljeet Singh Ahluwalia was recorded under Section 132(4) of the Act. During the search and seizure operation, Sri Ahluwalia has admitted undisclosed income of ₹ 150.00 crores but later on by letter dated 16.11.2009, Sri Ahluwalia retracted from the disclosure made on 12.11.2009. However, after the search and seizure operation, the opposite parties 2 to 6 filed an application before the Commission on 9.9.2011 for determination of the total income and fixation of tax liability ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iii. Shri Pawan Kumar Ahluwalia Assessment Years Particulars Amount (In Rs.Cr) 2007-08 Removal of rejects Suppression of Sales 6.02 5.59 Sub Total (A) 11.61 2008-09 Transportation charges of rejects Suppression of Sales Amount transferred to the dummy 7.73 4.18 12.27 Sub Total (B) 24.18 2009-10 Transportation charges of rejects Suppression of Sales 17.30 5.98 Sub Total (C) 23.28 2010-11 Suppression of Sales (D) 4.20 Grand Total (A+B+C+D) 63.27 iv. Prashan Kumar Ahluwalia Assessment Years Particulars Amount (In Rs.Cr) 2008-09 Transportation charges of rejects Machinery Hire Charges ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd statement recorded of different managers who clarified that nothing except statutory payment of Government over and above the contractual payment is borne by the mines owners and all other expenses relating to the entire mining process are incurred by the mining contractors. It is stated that M/s.Triveni Earth Movers (P) Limited at iron ore mines of opposite party no.3 at Guali in Keonjhar was engaged by later as mining contractor and said contractor, i.e., M/s.Triveni Earth Movers (P) Limited did all work including mining development, handling and dumping etc. till dispatching of the mining product under the supervision of the staff of opposite party no.3 and Government officials. Similarly, the CIT reported that M/s.AMR Construction Limited, Hyderabad and M/s.Indu Projects Private Limtied, Hyderabad have not rendered any service in either sector to the assessee group, they have issued cheques in favour of some Kolkata based parties on the promise made by the assessee group that they would give work orders for big amount in future. 9. The CIT also found when the vendors have not provided any service to assessee group, the payments were made to the alleged vendors through acc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y the iron ore at the price tendered by it and, in the event, the requirement of the highest bidder is less than the quarterly production of OMC, the balance stock is sold to the next highest bidder, but only at the price quoted by the highest bidder. The demand of material of OMC is their because the price of OMC in iron ore market of Odisha is the lowest, but the assessee group sold their products at higher rate than the OMC even if their grade of course is +3 which is +63FE by suppressing the sales because the CIT found that the assessee have sold product to M/s.P.K.Ores Pvt. Limited and M/s.TTL Minerals Export Pvt. Limited at higher rate whereas they have sold the same product to M/s.Shree Metaliks Limited at lower rate by understating the rate and in most of the cases, it is understood that difference between the final price and recorded price has been received in cash. Thus, the CIT found the suppression of sales. 14. The CIT, in its report under Rule-9 has also found that there are transactions made by Pawan Kumar Ahluwalia, opposite party no.4, has opened bank accounts in Indusin Bank, Barbil Branch in the district of Keonjhar and has transferred to five dummy account ho ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment of different witnesses examined by the Department. Had it been given, the persons could have stated before the Department about the statutory payment of Government over and above the contractual payment made by the mines owners. 17. It is stated that the Commission has not applied its mind while explaining the turnover of the assessee before calculating the gross profit. The Commission has adopted the turnover figures in case of opposite party no.2 for assessment years 2008-09, 2009-10 of ₹ 448.47 crores and ₹ 442.26 crores in its order at page 48 as against ₹ 455.42 crores and ₹ 482.13 crores admitted in the returns of income filed before the Assessing Officer which is reflected in the report of the CIT under Rule-9 at pages 21 to 24. Similarly discrepancy is found in the case of opposite party no.2 for assessment year 2007-08 where ₹ 218.67 crores only was admitted as against ₹ 222.55 crores admitted in the returns of income filed before the Assessing Officer which is reflected in the report of CIT under Rule-9. Thus, the order of the Commission suffers from gross illegality since it is not legally or factually possible to reduce the tu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... should not have allowed the application of the assessee. The Commission has no power to proceed further to make additions in the actual income although it has the power of assessing under Section 147 of the Act. In this regard, the petitioner relies on the decision of the Hon ble Madrass High Court in the case of Mr.G.Jayaraman V- The Settlement Commission, (2011) 196 TAXMANN 552 (Mad). The petitioner has summed up the illegality in the impugned order in the following manner: A. The order passed by the Ld. ITSC is without jurisdiction as the assessee had failed to comply with the statutory requirements u/s 245-C which stipulates that there must be full and true disclosure in the Settlement Applications by the Assessees for exercise of jurisdiction by the ITSC; B. It is submitted that the assessee must act with candor and the disclosure must be full and true. A full disclosure is a disclosure of all materials facts which does not contain any hidden material or suppression of facts. A true disclosure is a disclosure which is truthful in all respect. In the present case, the assesses in their Settlement Applications have furnished the admitted additional income on affida ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee group and that they have issued cheques in favour of Kolkata based companies which are mre accommodation entry operators; K. The Ld.ITSC has erred in law and in facts by not resolving the issues mentioned in para no.7 and para no.8 in spite of bringing the same to its notice by the Department; L. The Lc. ITSC has erred in law and in facts by failing to quantify the undisclosed income on the basis of the reports from the CIT as well as other materials/evidences brought before the Ld.ITSC; M. The Lc. ITSC has also erred in strangely reducing the turnover that has been disclosed by the assesses in their own returns; and N. The Ld. ITSC has never accorded its satisfaction that the assesses have been able to make full and true disclosure of income amounting to patent misrepresentation of facts in their Settlement Applications which should entail nullification, and in such view, the ITSC ought not have granted immunity to the assesses. 21. It is stated that in view of the decision of Hon ble Supreme Court in the case of Jyotendrasinhji V- S.I.Tripathi, AIR 1993 SC 1991, this Court has got power of review for which the writ petition under Article ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed that the additional income on estimate and this exercise may not be fully acceptable to the department and as such it is not a true and full disclosure of the undisclosed income. 25. Mr.Acharya further submitted that the form prescribed under Rule-44C and 44CA of the I.T.Rule in Part-C, item-3 of the application has not been properly filled up to prove the manner in which such income has been derived. The assessee, without disclosing the manner in which the income has been derived, has proceeded further and has come before the Commission which has the wide experience and wisdom in settling the tax disputes to intervene in the matter and determine and settle the correct income belonging to the assessee and its group to avoid further litigation. In this regard, he relied upon the decision of the Bombay High Court dated 13.6.2013 passed in W.P.(C) No.3900 of 2013 rendered in the case of CIT (Central) Pune V- ITSC. While the petitioner has raised objection before the Commission about the validity of the application under Section 245C(1), the Commission has observed in the manner we hold that this is not the stage to come to a specific conclusion on the adequacy of disclosure an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tal disclosure of the income by the opposite parties 2 to 6 of ₹ 141.30 crores, in view of the decision of the Hon ble Supreme Court, the opposite parties 2 to 6 have not made full and true disclosure of their undisclosed income under Section 245c(1) to warrant the jurisdiction of the Commission. 27. Mr.Acharya further submitted that the Commission has committed error by not considering the undisclosed income of ₹ 835.00 crores as found by the Department during the survey and as such delay in filing the writ petition will not stand on the way to make judicial review of the impugned order. He further submitted that the officer of the Income Tax Department, believing the present impugned order as conclusive, did not challenge the order of the Settlement Commission immediately. But after the lacunae in the Commission s order were discovered, the same has been filed with delay challenging in this writ petition. He also submitted that CIT (DR) who appears before the Commissioner happens to be the only officer who is acquainted with the day to day affairs of the proceeding and he is the person who can know whether there has been full and true disclosure as per the provisio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nce of the provisions of Section 245C(1) of the Act. He submitted that rather in the case of Ace Investment Ltd. V- CIT, (2003) 264 ITR 571 (Madras), Madras High Court has held that once the Settlement Commission found that the applicant has not made full and true disclosure, the application itself is non-maintainable for which the contention of the learned counsel for the petitioner has no merit. He further submitted that counter in the arguments of the learned Senior Advocate for the opposite parties 2 to 6 that three Judges Bench of the Hon ble Supreme Court in the case of Commissioner of Income Tax V- Om Prakash Mittal; (2005) 273 ITR 326 (SC) have held where the order has been obtained by fraud or misrepresentation of facts, then the order of the Settlement Commission would be void. Relying upon such decision, he submitted that Section 245I although says that the order of settlement is conclusive but it does not take away the power of commission to decide whether the settlement order had been obtained by fraud or misrepresentation of facts. Relying on the decision of the Gujarat High Court in the case of Vishnubhai Mafatlal Patel V- Asst. CIT; (2013) 31 Taxman.com 99 (Guj) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... investigation, but not the ₹ 110.00 crores. So, he submitted that in factual aspect, the matter should be clear enough to convince the Court moreover he pointed out that there is power of the Commission to review its own judgment, if any fraud has been subsequently discovered by the Commission, in that context, the Commission can set aside its own order. But in this case, the Commission did not find out any fraud but further made assessment through the Deputy Commissioner and necessary payment has been made by the opposite parties 2 to 6. He further submitted that as per Section 245D(6-B) of the Act after necessary deposit, the order of the Commission becomes final. If at all the Department has any objection, it could have been ventilated through review to the Commission itself who may reopen the case if it finds the grounds tenable. The Department have not raised any objection by filing review application within the time framed by the Act, it has no meaning to challenge in this Court. He also narrated the decision as per the counter affidavit to support his contention. He thoroughly supported the Commission and its report and rather he challenged the writ petition stating th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ipal Commissioner or the Commissioner. Since no such petition has been filed by the Principal Commissioner or Commissioner, the writ petition lacks maintainability under Article 226 of the Constitution of India. Hence, it is prayed to dismiss the same. POINTS FOR CONSIDERATON 34. The main points for consideration is as to whether (I) the impugned order passed by the Commission has reached its finality; and (II) whether this Court can entertain the petition challenging the order of the Commission under the writ jurisdiction. DISCUSSION ON POINT NO.I 35. The main contention of the learned Senior Standing Counsel for the petitioner is that the Commission had no jurisdiction to entertain the application because it has not been filled up properly and when there is no true and full disclosure of the undisclosed income by the assessee, the order of the Commission had not reached its finality. On the other hand, the contention of the learned Senior Advocate for the opposite parties 2 to 6 is that the order of the Commission having been reached its finality, the same has been acted upon by the Department. 36. It is admitted fact that the opposite parties 2 to 6 are the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d-up can be insisted on, thus sealing off chances of continued evasion through similar practices. 2.33. To ensure that the settlement is fair, prompt and independent, we would suggest that there should be a high level machinery for administering the provisions, which would also incidentally relieve the field officer of an onerous responsibility at the risk of having to face adverse criticism which, we are told, has been responsible for the slow rate of disposal of disclosure petitions. We would, therefore, recommend that settlements may be entrusted to a separate body within the Department, to be called the Direct Taxes Settlement Tribunal. It will be a permanent body with three Members. To strength of the Tribunal can be increased later, depending on the work-load. To ensure impartial and quick decision, and to encourage officers with integrity and wide knowledge and experience to accept assignments on the Tribunal, we recommend that its members should be given the same status and emoluments as the members of the Central Board of Direct Taxes. Any taxpayer will be entitled to move a petition before the Tribunal for settlement of his liability under the direct tax laws. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d procedure for settlement of cases was introduced in the IT Act by Taxation Laws (Amendment) Act 1975 published in the Gazette of India Extraordinary Part II dated 9th May, 1973 (Pages 443 to 530). The Statement of Objects and Reasons for the Amendment reads thus: To unearth black-money and prevent its proliferation; to fight and curb tax evasion; to check avoidance of tax through various legal devises, including the formation of trusts and diversion of income or wealth to members of family' to reduce tax arrears and to ensure that in future, tax arrears do not accumulate; to rationalise the exemptions and deductions available under the relevant enactments, and to streamline the administrative set-up and make it functionally efficient . 41. Clause 58 of the Bill introduced in Parliament to introduce separate Chapter in the IT Act for settlement of cases reads thus :- Clause 58 : This clause seeks to insert a new Chapter XIXA in the act, making provision for settlement of cases. 42. The provisions proposed in this Chapter are mainly intended to give a statutory basis for settlement of cases which are necessitated at times in the interest of the revenue. Howeve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t has furnished a return in respect of the total income of that year, tax shall be calculated on the aggregate of the total income returned and the income disclosed in the application as if such aggregate were the total income.] [(1C) The additional amount of income-tax payable in respect of the income disclosed in the application relating to the previous year referred to in sub-section (1B) shall be,- (a) in a case referred to in clause (i) of that sub-section, the amount of tax calculated under that clause; (b) in a case referred to in clause (ii) of that sub-section, the amount of tax calculated under that clause as reduced by the amount of tax calculated on the total income returned for that year; (c) [***].] (1D) Where the income disclosed in the application relates to more than one previous year, the additional amount of income-tax payable in respect of the income disclosed for each of the years shall first be calculated in accordance with the provisions of sub-sections (1B) and (1C) and the aggregate of the amount so arrived at in respect of each of the years for which the application has been made under sub-section (1) shall be the additional a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lowed to be proceeded with under sub-section (1), within thirty days from the date on which the application was made; or (ii) in respect of an application referred to in sub-section (2A) which is deemed to have been allowed to be proceeded with under that sub-section, on or before the 7th day of August, 2007, call for a report from the Commissioner, and the Commissioner shall furnish the report within a period of thirty days of the receipt of communication from the Settlement Commission. (2C) Where a report of the Commissioner called for under sub-section (2B) has been furnished within the period specified therein, the Settlement Commission may, on the basis of the report and within a period of fifteen days of the receipt of the report, by an order in writing, declare the application in question as invalid, and shall send the copy of such order to the applicant and the Commissioner: Provided that an application shall not be declared invalid unless an opportunity has been given to the applicant of being heard: Provided further that where the Commissioner has not furnished the report within the aforesaid period, the Settlement Commission shall proceed fu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... may be placed before it or obtained by it, the 5aSettlement Commission may, in accordance with the provisions of this Act, pass such order as it thinks fit on the matters covered by the application and any other matter relating to the case not covered by the application, but referred to in the report of the Commissioner. (4A) The Settlement Commission shall pass an order under sub-section (4),- (i) in respect of an application referred to in sub-section (2A) or sub-section (2D), on or before the 31st day of March, 2008; (ii) in respect of an application made on or after the 1st day of June, 2007 6[but before the 1st day of June, 2010], within twelve months from the end of the month in which the application was made;] (iii) in respect of an application made on or after the 1st day of June, 2010, within eighteen months from the end of the month in which the application was made.] Xx xx xx xx 47. Sub-section 1 of Section 245D of the Act prescribes the procedure for receipt of an application under Section 245C. According to Sub-section 2(B) of Section 245D of the Act, the Commission shall call for a report from the Principal Commissioner or the Comm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pretending to be real or genuine. The dictionary meaning of the word fictitious is not real or true, imaginary or invented, invented by somebody rather than true. Thus the words bogus and fictitious require (i) either all the recipient or some of them are not genuine or (ii) the payment is paid under a transaction which lacks the commercial essence i.e. some of the contracts are genuine and some are sham. It is true that payment by cheque does not establish the genuineness of transactions or the existence of commercial substance, if it is absent. 36.11 In the applicant s cases, the existence of recipients of the transportation expenses of rejects has not been disproved. As to the payments, the statements recorded do constitute evidence against the applicants though rebuttable, but that is not the end of it. The Department must have adequate material to support its contention. It is a fact that during post search period further evidence was not gathered to know inter-alia as to which of vehicles were used by the applicants and when, and for what period etc. As the jobs (for which payments made) involved deployment/mobilization of a large work force along with vehicles/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2004-05 25,23,707 5,00,000 -- 30,23,707 2005-06 1,95,91,437 5,00,000 -- 2,00,91,437 2006-07 2,37,66,951 5,00,000 -- 2,42,66,951 2007-08 4,49,698 64,00,00,000 12,96,00,000 9,49,698 2008-09 1,21,66,14,990 17,50,00,000 13,06,00,000 1,98,62,14,990 2009-10 1,90,16,42,940 17,50,00,000 10,51,00,000 2,20,72,42,940 2010-11 1,72,71,93,210 99,20,00,000 36,53,00,000 624,90,28,933 Total 4,89,17,28,933 99,20,00,000 36,53,00,000 624,90,28,933 (II) M/s.Kamaljeet Singh Ahluwalia (Firm) Assessment Years ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itions made by the Bench. (Rs.) Total (Rs.) 2004-05 9,67,470 5,00,000 -- 17,67,470 2005-06 18,01,928 5,00,000 -- 23,01,928 2006-07 18,37,028 5,00,000 -- 23,37,028 2007-08 1,25,431 5,00,000 -- 6,25,431 2008-09 82,10,41,920 5,00,00,000 11,88,00,000 98,98,41,920 2009-10 87,03,61,120 50,00,000 7,40,00,000 94,93,61,120 2010-11 69,97,93,610* 7,00,00,000 13,95,00,000 90,92,93,610 Total 2,39,59,28,507 12,70,00,000 33,23,00,000 2,85,52,28,507 *Income returned u/s 139(1) (I) M/s.Kaypee Enterprises (Fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... : The Assessing Officer is directed to compute the tax as per the I.T.law. Interest is to be charged as directed in para 7(ibid). The applicants will make payment of all chargeable tax and interest within 35 (thirty-five) days from the date of receipt of the order of the Assessing Officer giving effect to this order. The order is passed u/s 245D(4) as above. The order shall be void if it is subsequently found that it has been obtained by fraud or misrepresentation of facts. 51. After considering the impugned order, we are convinced that the Commission, after giving appropriate opportunity to the applicant and after going through the report of the Principal Commissioner/Commissioner made under Rule-9, has passed the order under Section 245D of the Act. Section 245D(3) of the Act has empowered the Commission to make inquiry/investigation further to find out the additional income. 52. It is reported in the case of Commissioner of Income Tax V M/s.Hindustan Bulk Carriers; (2000) INSC 678 as under: The order of settlement shall provide for the terms of settlement, including any demand by way of tax, penalty or interest, the manner of payment of the sum due under the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... learned Senior Standing Counsel for the Department with regard to true and full disclosure of the statement, being prime requisite under Section 245C to proceed to pass order under Section 245D are settled law and there is no dispute over the same. But in the facts and circumstances of the case, the ground of no true and full disclosure of the statement by the assessee being decided by the Commission, we respectfully do not apply the decisions cited by the Department to the present case at hand because of the peculiar facts and circumstances of the case. 57. The next contention of Mr.Acharya, learned Senior Standing Counsel is that report of the Commission has been obtained by fraud or misrepresentation. 58. It is profitable to quote sub-sections 6 to 6(B) of Section 245D of the Act: 245D. Procedure on receipt of an application under section 245C Xx xx xx xx (6) Every order passed under sub-section (4) shall provide for the terms of settlement including any demand by way of 10[tax, penalty or interest9], the manner in which any sum due under the settlement9 shall be paid and all other matters to make the settlement effective and shall also provide that the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er the settlement and in that order, it must be also maintained that if subsequently it is found by the Settlement Commission that the order has been obtained by fraud or misrepresentation, the Commission has the power to declare the settlement void. 61. Not only this but also under Section 6A of the Act, if the assessee does not pay the tax payable as ordered under Sub-section-4 within 35 days, the assessee is liable to pay the same with simple interest. Similarly, under Section-6B, the Settlement Commission has got power to rectify its mistake within six months from the date of order and while rectifying the mistake, it will give opportunity to both parties of being heard. Thus, the Commission has power to declare the settlement as void and also to correct the mistake, if occurred or found later on. In the instant case, when the order of the Commission was communicated to the Department, the Department could have brought to the notice of the Commission about the mistakes or to declare the same as void but instead it appears from the pleadings and arguments of both sides that the Assessing Officer has been directed to compute the tax as per law and charge the interest as availa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act. The scope of enquiry, whether by High Court under Article 226 or by this Court under Article 136 is also the same - whether the order of the Commission is contrary to any of the provisions of the Act and if so, has it prejudiced the petitioner/appellant. 64. With due regards to the decisions, it is settled that the judicial review of the decision of the Settlement Commission is not permissible but it is permissible to interfere if there is any illegality in the procedure followed by the Commission or if the same is contrary to the provisions of the Act causing prejudice to the appellant. In the instant case, it has been already observed in the aforesaid paragraphs that the Commission has provided proper opportunity to both sides and after that passed the order under Sub-section 4 of Section 245D of the Act. Not only this but also the order has been implemented and the assessees have already paid the tax in view of the terms of the settlement as observed earlier. The authority of the Commission was not invoked by the petitioner to exercise its power under Sub-section 6 for the reasons best known to them. When the statutory authority has already been conferred with t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e aforesaid paragraphs that in the instant case, the order of the Commission has reached its finality. When the order of the Commission has become conclusive being not agitated before the same Commission and no other legal points are submitted, exercise of writ jurisdiction is not available. It is true that if there is law prescribed and is not followed or natural justice has been violated or there is no efficacious remedy available, the writ jurisdiction can be exercised but in view of the discussions made above, we are of the view that the claim of the petitioner is not maintainable under the writ jurisdiction in the facts and circumstances of the case. 69. It may not be out of place to mention that the procedure prescribed in the Act by the Settlement Commission is an exhaustive and comprehensive and in that case, if the party does not follow the procedure, it will be abusive of power if this Court will exercise its power under writ jurisdiction conferred under Articles 226 or 227 of the Constitution of India. Issue No.2 is answered accordingly. CONCLUSION 70. We have already observed that the Commission has passed the order which has become conclusive and reached its f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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