TMI Blog2017 (3) TMI 189X X X X Extracts X X X X X X X X Extracts X X X X ..... TMI 586 - ITAT PUNE ] - ITA Nos.1384 & 1385/PUN/2015, ITA Nos.1469 & 1470/PUN/2015 - - - Dated:- 23-2-2017 - JUSTICE (RETD.) DEV DARSHAN SUD, PRESIDENT (AS THIRD MEMBER), MS. SUSHMA CHOWLA, JUDICIAL MEMBER AND SHRI ANIL CHATURVEDI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBERS Assessee by : Shri Sunil Pathak Department by : S/Shri S.K. Rastogi, CIT, Sandeep Garg, CIT, Suhas Kulkarni and Rajeev Kumar, CIT ORDER Per Pradip Kumar Kedia, AM The aforesaid captioned cross appeals filed by the assessee and the Revenue are against the order of CIT(A)-11, Pune, dated 17.08.2015 relating to assessment years 2011-12 2012-13 arising from the assessment order passed under section 143(3) of the Income Tax Act, 1961 (in short the Act ). 2. The cross appeals filed by the assessee and the Revenue were heard together and are being disposed of by this consolidated order. ITA No.1384/PN/2015, A .Y. 2011-12 (By Assessee): 3. In this appeal, the issue in controversy agitated on behalf of the assessee is disallowance of additional depreciation on windmill quantified at ₹ 12,62,02,718/- relevant to assessment year 2011-12. 4. The relevant facts, in brief, are that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng activity nor engaged in production activity. The assessee is engaged in business of Water Park and trading in goods which is not manufacturing activity in the year under consideration. The Assessing Officer went on to observe that generation of electricity with the use of windmill does not tantamount to production of article or thing per se. He held that the conditions of section 32(1)(iia) are not fulfilled and accordingly disallowed the additional depreciation claim of the assessee. 6. Aggrieved, the assessee preferred appeal before the CIT(A). It was reiterated before the CIT(A) that the assessee was qualified for claim of additional depreciation since the assessee was producing power through wind energy from windmills installed during the year. This tantamount to manufacture or production of article or thing in terms of S. 32(1)(iia). The CIT(A), however, was also not impressed with the submissions of the assessee. The CIT(A) referred to the various judicial decisions cited by the assessee and observed that these decisions were rendered prior to amendment carried out in section 32(1)(iia) of the Act w.e.f. 1-4- 2013. The CIT(A) noted that specific amendment in section 32( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... round that electricity is not an article or thing . It was submitted that the Delhi Bench of the Tribunal in NTPC Ltd. case categorically held that the depreciation is allowable on plants and machinery producing electricity. 8.2 Dr. Pathak, next adverted our attention to another decision of ITAT in the case CIT vs. Hutti Gold Mines Co. Ltd. [60 SOT 147 (Bang.)] and ACIT vs. Mr. M. Satishkumar [ITA No.718/Mds./2012] wherein also it has been held that subsequent amendment has given an impetus to the view that generation of electricity is a manufacturing process and qualifies for benefits under section 32(1)(iia) of the Act. 8.3 Dr. Pathak thereafter referred to the another decision of Pune Bench of ITAT in the case of M/s D.J. Malpani vs. ACIT, ITA Nos.1148 to 1154/PN/2013 order dated 30.10.2015 i.e. rendered after the amendment to section 32(1)(iia) of the Act. In view of these decisions, the Ld. Counsel claimed that the assessee is eligible to claim additional depreciation for the assessment years even prior to 01.04.2013 i.e. the date from which the amendment was stated to be made effective. In short, Dr. Pathak would submit that even without amendment, the activity of gene ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ar. The controversy that precisely arises in the present case is whether the assessee is entitled to additional depreciation @ 20% concerning assessment years prior to AY 2013 -14 with reference to business of generation and distribution of power in terms of S. 32(1)(iia) as it stood prior to its amendment effective from 01.04.2013 .? In other words, the question to be determined is whether an assessee engaged in business of generation and distribution of power is eligible for additional depreciation as per existing provision having regard to specific amendment specifically carried out w.e.f. 1-4-2013 to cover power sector. 11. The relevant provisions of section 32 of the Act governing depreciation allowance, post amendment, is noted hereunder for ready reference :- Section 32, (1) In respect of depreciation of- (i) buildings, machinery, plant or furniture, being tangible assets; (ii) know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature, being intanqible assets acquired on or after the 1st day of April, 1998, owned, wholly or partly, by the assessee and used for the purposes of the busin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (other than ships and aircraft) to the assessee engaged in the business of manufacture or production of any article or thing in the year of acquisition and instalment. Under the existing provisions, the benefit of initial depreciation is not available on the new machinery or plant installed by an assessee engaged in the business of generation or generation and distribution of power. In order to encourage new investment by the assessees engaged in the business of generation or generation and distribution of power, it is proposed to amend this section to provide that an assessee engaged in the business of generation or generation and distribution of power shall also be allowed initial depreciation at the rate of 20% of actual cost of new machinery or plant (other than ships and aircraft) acquired and installed in a previous year. This amendment will take effect from 1st April, 2013 and will, accordingly, apply in relation to the assessment year 2013-14 and subsequent assessment years. [Clause 7] 14. A bare reading of the Explanatory Memorandum amply spells out the intention of the legislature in no uncertain terms. The Act was amended to grant additional depreciation to an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... clause (iia) reveals that a further sum equal to 20% of the actual cost of such machinery or plant shall be allowed as deduction under clause (ii). We take notice that under clause (ii), depreciation is allowed on block of asset while under clause (i), reference is to business of generation of power etc. at prescribed percentages. Thus, power sector is separately categorized. As a corollary, it is seen that the varied depreciation is applicable in the case of assets to an assessee engaged in the power generation business under clause (i) in distinction to other assesses under clause (ii). In view of specific reference to clause (ii) in S. 32(1)(iia), it is not possible to overlook that business of generation of power is otherwise catalogued under clause (i) is also taken within the sweep of clause (iia) by virtue of this amendment. 17. Section 32 determines, confers and regulates the right of allowance on account of depreciation to the assessee and is thus a substantive section. The substantive nature is also evident from the fact that deprecation allowance is mandatory and its claim is not left to the option of the assessee. Notably, S. 32(iia) grants vested right to claim d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by necessary implication. When read with ordinary sense, the insertion made seeking to include power sector in the ambit of clause (iia) has clearly widened the scope of the existing benefit from a prospective date and thus cannot be read into the existing provision having regard to the amendment. Thus, the normal presumption of applicability of amendment with a prospective date cannot be disturbed in the light of express intendment now available in this regard. 19. We shall now address ourselves to various judicial decisions extensively quoted by the learned counsel for the assessee, Dr. Pathak relied upon large number of decisions to canvass that the generation of power and distribution is equivalent to manufacture or production of any article or thing. He heavily relied upon the decision of the co-ordinate bench of tribunal in the case of NTPC vs. Dy. CIT ITA No. 1438 / Del/ 2009 relevant to assessment year 2005 -06. He submitted that as per the aforesaid decision, the power generation and distribution activity tantamounts to manufacture or production of article or thing. Hence, the assessee is entitled to depreciation even under the existing provisions applicable to the rele ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... coordinate bench in the case of Avinash N. Bhosale has only followed the decision of the tribunal in the case of NTPC ( supra) which no longer holds the field as a binding precedent. Likewise, the decision arrived at in the case of Hutti Gold mines ( supra) is without addressing the issue in the light of express legislative intention behind the amendment carried out in Finance Act, 2012. It merely observed that the amendment gives impetus to the view that generation of electricity is a manufacturing process and thus qualifies for benefit under S. 32(1)(iia). The distinction between clause (ii) referred to in S. 32(1)(iia) qua clause (i) was also not addressed in the decision. In the same vain, other decisions referred to on behalf of the assessee namely ACIT vs. M. Satiskumar and D J Malpani (supra) has arrived at the conclusion having regard to the existing decisions governing the field without examining the issue in the light of categorical Explanatory Note explaining the purport of amendment. In the wake of aforesaid discussion, it is difficult to perpetuate the findings given in these decisions. Reliance placed on the decision of Jurisdictional High Court in United Western Ban ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... art and parcel of actual cost of windmill and therefore eligible for accelerated depreciation in parity with windmill. In the course of hearing, the Dr. Pathak fairly admitted that the issue is decided against the assessee in the case of Poonawala Finvest Agro Pvt. Ltd. 118 TTJ 68. In view thereof, we also dismiss Ground no. 4 of the appeal. 23. In the result, the appeal of the assessee in ITA No.1384/PN/2015 relevant to assessment year 2011-12 is dismissed. ITA No.1385/PN/2015, A .Y. 2012-13 (By Assessee): 24. The assessee is raised identical grievance in its appeal in ITA No.1385/PN/2015 relevant to assessment year 2012-13. The facts and issue in this appeal are identical to facts and issue in ITA No.1384/PN/2015. Thus, our decision in ITA No.1384/PN/2015 shall apply mutatis-mutandis to ITA No.1385/PN/2015. 25. In the result, the appeal of the assessee in ITA No.138 5/PN/2015 relevant to assessment year 2012-13 is also dismissed. ITA No.1469/PN/2015, A.Y. 2011 -12 (By Revenue) : 26. The solitary issue raised by the Revenue in its appeal is disallowance of depreciation on costs incurred in relation to installation of windmills to the tune of ₹ 2,78,43,463 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ling and development of land for the purpose of erection of plant and machinery formed part of the actual cost of the plant. H.C. held that there is no difference between this expenditure and the expenditure incurred on erection and installation of plant and machinery and allowed the claim of the assessee. In view of the said decision, the assessee submits that the depreciation should be allowed on the other items as well. However, the assessee would like to submit that ITAT, Pune in the case of Poonawalla Finvest Pvt. Ltd. has decided the issue against the assessee. 4.3 ] As regards, the claim of higher depreciation on electrical items, the assessee submits that items are in the form of transformers, wiring etc. which are necessary to make the windmill functional. Thus, it is submitted that the above items form part and parcel of the windmill and hence, they are an integral part of the windmills. Accordingly, the assessee submits that the cost of these items has been rightly included in the cost of windmills and thus, the depreciation @ 80% is allowable in respect of the said items. The assessee submits that this issue has been decided in favour of the assessee by ITAT Pune i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e and therefore cannot be treated differently. Therefore, impugned capital expenditure towards civil work commissioning etc. also will qualify for the same rate of depreciation as applicable to wind turbine itself. The issue is no longer res-integra and is covered by the decision of Co-ordinate Bench of the Tribunal in the case of Poonawala Finvest Agro (P.) Ltd. vs. ACIT, (2008) 118 TTJ 68 (Pune) wherein it has been clearly held that the capital expenditure incidental to the windmill has to be tested on the touchstone of the functional test and the assessee will be entitled to higher rate of depreciation on such incidental expenditure, if it has no other use except for power generation done by the windmill. Our view is also supported by another decision of the Co-ordinate Bench of Pune Tribunal in the case of M/s D.J. Malpani vs. ACIT in ITA Nos.1148 to 1154/PN/2013, order dated 30.10.2015. Accordingly, we hold that the Revenue is misdirected itself in law in making the impugned disallowance of depreciation. 32. We also find that decision of Pune Bench of the Tribunal in the case of Poonawala Finvest and Agro Pvt. Ltd. (supra) relied upon by Assessing Officer infact suppo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT Vs. Shri Avinash Nivrutti Bhosale in ITA No.823/PN/2011, relating to assessment year 2007 -08, order dated 27.08.2012. The Assessing Officer was of the view that the assessee was not engaged in the manufacture of production of article or thing and hence, was not entitled to the claim of additional depreciation on windmill. The Assessing Officer further observed that the assessee was already enjoying the benefit of higher depreciation @ 80% and in case further additional depreciation of 20% is allowed to the assessee, then the entire 100% of the windmill cost would be allowed as deduction. 3. The CIT(A) disallowed the claim of assessee by relying on the amendment to section 32(1)(iia) of the Act, which was inserted w.e.f. 01.04.2013. The CIT(A) was of the view that the business of generation of power has been made eligible for additional depreciation w.e.f. 01.04.2013. He further held that the amendment was not clarificatory or declaratory, since it does not say for the removal of doubts, it is clarified, etc. that the business of generation of power has been included in the section as new class of business, separate and distinct from the business of manufacture or production ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ence to goods has defined for the purpose of sales tax cannot be taken in a narrow sense and merely because electric energy is not tangible or cannot be moved or touched like for instance, a piece of wood or book, it cannot cease to movable property when it has all products of such property. Where it was capable of abstraction, consumption and use and could be transmitted, transferred, delivered, stored, possessed, etc. in the same way as any other movable property, then electric energy was held to be goods . The Hon ble Supreme Court further held that since there could be sale and purchase of electric energy like any other movable object, the electric energy was intended to be covered by the definition of goods . Similar proposition was further laid down by the Hon ble Supreme Court in the case of State of Andhra Pradesh Vs. NTPC reported 2002 (4) TMI 694 (SC) wherein the Hon ble Supreme Court considered what is an electric energy and held the same to be covered by the definition of goods under the Sale of Goods Act, 1930. 6. The Delhi Bench of Tribunal in NTPC Vs. DCIT in ITA No.1438/Del/2009, relating to assessment year 2005-06, order dated 30.04.2012, copy of which is fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as decided by the Tribunal in favour of the assessee by following judgments of Hon ble Madras High Court in CIT Vs. Hi Tech Arai Ltd. (2010) 321 ITR 477 (Mad) and the CIT Vs. Texmo Precision Castings (2010) 321 ITR 481 (Mad). In the facts of the case before the Chennai Bench of Tribunal, the assessee was operating the windmill for generation of electricity and had installed its first windmill in the year 2005. The assessee claimed additional depreciation on the second windmill in the year under appeal and relied on the ratio laid down by the Hon ble Supreme Court in CST Vs. Madhya Pradesh Electricity Board (supra), wherein it was held that electricity falls within the definition of goods as defined under Sale of Goods Act, 1930. Further, reliance was placed on the ratio laid down by the Hon ble Supreme Court in State of Andhra Pradesh Ors. Vs. National Thermal Power Corporation (supra). Reliance was also placed on the decision of Delhi Bench of Tribunal in NTPC Vs. DCIT (supra) and it was pointed out that the term production and generation could be used interchangeably in the case of electricity and generation of electricity can also be termed as production of electricity. Furt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ining and extraction of gold, was not a pre- condition for the grant of additional depreciation under the Stature. Vide para 7.1, the Tribunal held that the amendment brought about in section 32(1)(iia) of the Finance Act, 2012 to include the business of generation and distribution of power to the benefit of additional depreciation is only clarificatory. The Tribunal then relied upon similar view having been taken by the Chennai Bench of Tribunal in ACIT Vs. M. Satish Kumar (supra). Further, vide para 7.2, the Tribunal observed that the plea of the Revenue raised in ground of appeal No.3 was also devoid of merits since in the relevant previous year i.e. the year in which windmills were installed, the assessee was entitled to depreciation only @ 80%. It was further held that the assessee would not have been entitled to additional depreciation, if the assessee was eligible for 100% depreciation. 10. Another decision relied upon by the learned Authorized Representative for the assessee is of Pune Bench of Tribunal in M/s. D.J. Malpani Vs. ACIT in ITA Nos.1148 to 1154/PN/2013, relating to assessment years 2004-05 to 2010-11 and cross appeals filed by the Revenue in ITA Nos.1183 to 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oduction (generation, transmission, delivery and consumption or simultaneous), instantaneously. The Hon ble Supreme Court further held that electricity as goods comes into existence and is consumed simultaneously and the event of sale in the sense of transferring property in the goods merely intervenes as a step between generation and consumption. Following the above said proposition, the Tribunal had held that generation of electricity was akin to manufacture of a new product and where the assessee was involved in manufacturing activity and fulfils the conditions as laid down under section 32(1)(iia) of the Act, it was entitled to the additional depreciation. The Tribunal further held that the amendment to section 32(1)(iia) by the Finance Act, 2012 was w.e.f. 01.04.2013, but it gave impetus to the view that generation of electricity is a manufacturing process and qualifies for benefits under section 32(1)(iia) of the Act. The Bangalore Bench of Tribunal in DCIT Vs. Hutti Gold Mines Co. Ltd. (supra) had held that the said amendment is clarificatory in nature. 12. Both these decisions of Chennai Bench of Tribunal and Bangalore Bench of Tribunal were pronounced after considering ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al matrix or larger Bench of this court takes a view different from the one already taken. Further, it was held by the Hon ble High Court as under:- 23. We are conscious of the fact that we are fallible and, therefore, an order passed by us may not meet the approval of all and some may justifiably consider our order to be incorrect. However, the same has to be corrected / rectified in a manner known to law and not by disregarding binding decisions of this court. In fact our court in Panjumal Hassomal Advani v. Harpal Singh Abnashi Singh Sawhney, AIR 1975 Bom 120 has observed that a co-ordinate bench cannot refuse to follow an earlier decision on the ground that it is incorrect and/or rendered on misinterpretation. This for the reason that the decision of a co-ordinate bench would continue to be binding till it is corrected by a higher court. This principle laid down in respect of a co-ordinate court would apply with greater force on subordinate courts and Tribunals. We are also conscious of the fact that we are not final and our orders are subject to appeals to the Supreme Court. However, for the purposes of certainty, fairness and uniformity of law, all authorities within the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y taken. 14. Further, I find that the Hon ble Madras High Court vide judgment dated 17.03.2015 in CIT Vs. Atlas Export Enterprises (2015) 373 ITR 414 (Mad) while deciding an identical issue relating to assessment year 2006-07 of allowability of additional depreciation has allowed the claim of assessee by relying on its earlier decision in CIT Vs. Hi Tech Arai Ltd. (supra) and CIT Vs. VTM Limited (supra). In other words, the above said decisions of Hon ble Madras High Court which had been applied by Chennai Bench of Tribunal in ACIT Vs. M. Satish Kumar (supra) rules till today. The said decision of Hon ble Madras High Court in CIT Vs. Atlas Export Enterprises (supra) was not relied upon in the present case and I am drawing the support from the said ratio that even after insertion of the amendment to section 32(1)(iia) of the Act by the Finance Act, 2012, the persons engaged in running windmills are entitled to the claim of additional depreciation. It cannot be said that the Hon ble High Court was not aware of the amendment and / or Memorandum explaining the amendment by the Finance Act, 2012. Where the issue is covered by the decision of Pune Bench of Tribunal as well as other Be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come Tax Act, 1922. The question was whether on liquidation, distribution of assets amounts to transaction of transfer so as to attract section 12B of the Indian Income Tax Act, 1922. It was held by the apex court that the said question dealt with distribution of assets of the company in liquidation and on liquidation, such distribution did not amount to transfer the revenue. In that case Revenue had raised a proposition that prior to Finance (No.3) Act, 1956, there was a proviso to section 12B(1) of the Indian Income Tax Act, 1922, under which distribution of capital assets on liquidation of a company was expressly excluded from the transfer, but when the said exclusionary clause was deleted, then the intent of Legislature was to treat the distribution of capital assets on liquidation of the company as a transfer. The said proposition raised by the Revenue was rejected by the Hon ble Supreme Court and it was held that the said exclusionary clause was in the nature of clarification and its deletion did not affect the main section 12B(1) of Indian Income Tax Act, 1922. The apex court held that the proviso was only introduced by the Parliament by way of abundant caution. Applying the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Chennai Bench of Tribunal in ACIT Vs. M. Satish Kumar (supra) and Bangalore Bench of Tribunal in DCIT Vs. Hutti Gold Mines Co. Ltd. (supra) which has decided the issue after insertion by the Finance Act, 2012. 17. On due consideration of issue raised, the grounds of appeal No.1 to 3 raised by the assessee deserved to be allowed. REFERENCE UNDER SECTION 255(4) OF I.T. ACT, 1961 On a difference of opinion between the Members constituting the aforesaid Bench, three questions are to be referred by virtue of section 255(4) of the I.T. Act for the esteemed view of a Third Member as follows:- 1. In the facts and circumstances of the case, whether the issue of claim of additional depreciation under section 32(1)(iia) of the I.T. Act is settled and covered in favour of the assessee and hence, the same is to be applied for deciding the issue. 2. In order to maintain consistency, whether it is incumbent upon the Tribunal to follow the settled judicial precedents?. 3. In the facts and circumstances of the case, whether the assessee is entitled to the claim of additional depreciation under section 32(1)(iia) of the I.T. Act, in view of amendment by Finance Act, 2012 for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct stands contrast to the understanding of legislature in the light of subsequent amendment and if yes, whether legislative intention as spelt in Explanatory Memorandum will take precedence over the judicial interpretation so made without reference to Explanatory Memorandum? 7. Whether benefit of additional depreciation is restricted to assets referred to in clause (ii) of S. 32(1) in exclusion to assets referred to in clause (i) prior to express inclusion of power sector in S. 32(1)(iia) itself with effect from AY 2013-14. 8. Whether the judicial decisions rendered without deliberation on the effect of clause (ii) on allowability of deduction under S. 32(1)(iia) can be viewed as sub-silentio and consequently not a binding precedent ? 9. Whether reduction of depreciation allowance eligible to wind mill assets to bring these assets at par in the realm of normal rate by I T Rules 1962 for assets installed in FY 2012-13 onwards and simultaneous corresponding grant of additional depreciation to power sector also serves as an indicator of legislative intention to pour benefit of S. 32(1)(iia) hitherto not available with a prospective date. 10. Whether in the totali ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity of generation of power for the period prior to AY 2013-14. 3. Whether the provisions of section 32(1)(iia) are in the nature of substantive provision or merely a procedural one ? and, if held substantive, whether the legislative amendment extending benefits to power sector under the aforesaid provision are prospective in nature or can it be applied retrospectively by holding the insertions made therein w.e.f. 1-4-2013 to be clarificatory in nature. 4. Whether in the facts and in the circumstances of the case, the legislative intention is required to be gathered from the language employed in Explanatory Memorandum or to be derived from judicial interpretations particularly when none of decisions cited has made any reference to aforesaid Explanatory Memorandum for decision making purposes. 5. Whether in the facts and the circumstances of the case, can it be presumed that co-ordinate benches of Tribunals cited have impliedly considered Explanatory Memorandum when there is no reference made to this effect in the decisions of the co-ordinate benches while adjudicating the issue. 6. Whether judicial interpretations relied upon to include generation of power with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ses [(2 015) 373 ITR 414 (Mad.)], wherein the Hon ble High Court of Madras considered the provisions of section 32(1)(iia) of the Act holding that the power generated by windmill was entitled to the benefit of depreciation as contemplated by Sec.32(1)(iia) as aforesaid. The Court holds 6. The facts in the present case are no different from the above-said decision. In the present case, the core business of the assessee is manufacturing and export of textile goods. During the assessment year 2006-07, the assessee had entered into the business of generation of power and installed one windmill. The assessee maintained separate books of account for export division and the windmill division. Since the claim of additional depreciation has to be seen in the context of generation of power through windmill only and the production of textile and its export has nothing to do with the generation of power for the purpose of considering additional depreciation. Further as rightly held by the Tribunal, the Revenue has not brought in any new or contra material to differ from the view of this Court in the decision reported in [2010] 321 ITR 477 (Mad) (Commissioner of Income-tax v. Hi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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