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Rasiklal M. Parikh Versus Assistant Commissioner of Income Tax-19 (2) , Mumbai

2017 (3) TMI 1247 - BOMBAY HIGH COURT

Admission of Additional evidence by the ITAT- exemption u/s 54F - an opportunity to the Appellant to rebut the detrimental conclusions - Held that:- In this case the appellant produced the additional evidence and admittedly after making submissions in support of it being allowed to be produced, also made submissions on merits. The petitioner/appellant did not call upon the Tribunal to pass an on order on his application to produce additional evidence contained in the AEPB before making his submi .....

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pellants were aware that the attention of the Tribunal had been invited to the documents in question and the Tribunal had in fact considered contents of the documents on merits and as to how it would affect the appellants' case. - Having done so, in our view no injustice has been caused to the appellants. Had the Tribunal declined to consider the documents in our view it would have been appropriate that some reasons will have to be given by them for depriving the parties the benefit of the s .....

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cided in favour of revenue - Applicability of Section 54F(1) juxtaposed with Section 54F(4) - non-completion of construction of the building in which the appellant – assessee had agreed to purchase flats - contiguity of three flats which the appellant – assessee had agreed to purchase - Held that:- We have already observed that we are not required to go into this aspect in order to answer the question, since on first principles, we find that the assessee had not complied with Section 54F. In .....

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they are in pari materia. Likewise Sections 22 and 22(2A) were in pari materia with Sections 139 and 80 respectively of the 1961 Act. However, in our view this does not come to assistance of Mr. Shah inasmuch as the language of Section 54 will not admit of such an interpretation. We have already taken a view that the consequences of the amount of capital gains or difference between amount spent for purchase of house and the total amount of capital gains not being deposited in the specified accou .....

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ided in favour of the appellant the appellant, he probably may not have considered the procedure followed by the Tribunal as ad-hocism. The Revenue could have possibly objected to the course followed by the Tribunal. In the circumstances we do not find that the Tribunal infringed upon the principles of natural justice in not providing an opportunity to the Appellants to rebut the conclusions described as detrimental. In any event this Court is not in a position to verify whether in fact the cont .....

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& A. K. MENON, JJ. Mr. Sanjiv M. Shah for the Appellant. Ms. Shehnaz Bharucha for the Respondent. JUDGEMENT (PER A.K. MENON, J.) 1. This appeal under Section 260A of the Income Tax Act, 1961(the Act) assails the order dated 31st October, 2012 passed by the Income Tax Appellate Tribunal (Tribunal). The impugned order relates to Assessment Year 2006-07. 2. This appeal was admitted on 28th January, 2015 on the following substantial questi .....

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w, the Tribunal was right in approving the denial of exemption under Section 54F? (C) Whether the Tribunal infringed the principles of natural justice in not providing an opportunity to the Appellant to rebut the detrimental conclusions inferred by the Tribunal based on the additional evidences adduced by the appellant and the Circular no.495 dated 22nd September, 1987? 3. Vide order dated 28th January, 2015 the Court expedited the hearing of the appeal in view of the appe .....

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/o:p> Accordingly vide order dated 12th January, 2017 we held that the amendment sought is impermissible and the Chamber Summons came to be dismissed. The appeal has since been taken up for hearing. 4. Mr. Shah, the learned counsel for the appellant submitted that the challenge is twofold. Firstly, he assails the failure of the Tribunal to pass an order upon the application to lead additional evidence under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 (ITAT Rules) and se .....

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n 143(3) of the Act which was upheld by order dated 7th July 2011 of the Commissioner of Income Tax (Appeals) [CIT(A)]. During the pendency of the appeal before the Tribunal, the appellant had on or about 9th July, 2012 filed an application seeking admission of additional evidence. In view of the impending hearing of the appeal on 8th October, 2012, the appellant contended that certain additional and material documents accompanying the application were sought to be introduced for the first time .....

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the developer in relation to the housing project (iv) copies of 4 letters addressed by the developers to the appellant and (v) a Sketch Plan of flat nos.901, 902 and 903. Mr. Shah submitted that on the scheduled date of hearing i.e. 8th October, 2012 the appeal was heard finally. The grievance of the appellant before the Tribunal was that the CIT(A) incorrectly denied exemption under Section 54F of the Act. Mr. Shah submitted that the appeal was then heard but came to be dismissed on 31st Octob .....

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assessee. Exception has been taken to this approach adopted by the Tribunal. Mr. Shah then submitted that there are different ways in which additional evidence may be considered viz under Rule 18 or 29 of the ITAT Rules and by using inherent provisions of Section 254 of the Income Tax Act, 1961. In the instant case the Tribunal by not indicating whether or not the application had been allowed committed a serious error which has caused grave prejudice to the appellant. Mr. Shah submitted that the .....

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developers had no approval for construction of the 9th floor on which the appellant's premises was situate and it is only on 7th September, 2010 that the commencement certificate was validated for construction of the 9th floor. Mr. Shah submitted that the commencement certificate as amended and filed along with the AEPB was used by the Tribunal to deny relief to the appellant. Furthermore, the Tribunal also made reference in paragraph 10 of the order to the Sketch filed along with the AEPB b .....

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wo documents filed by the appellant in the AEPB, without passing an order permitting or rejecting the application. He submitted that the impugned order is therefore vitiated. In the course of his submissions, Mr. Shah relied upon the provisions of the 'ITAT Rules. He invited our attention to Rules 18 and 29 of ITAT Rules which are reproduced below for ease of reference:- 18. (1) If the appellant or the respondent, as the case may be, proposes to refer or rely upon any document or .....

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ation of a paper book in triplicate by and at the cost of the appellant or the respondent containing copies of such statements, papers and documents as it may consider necessary for the proper disposal of the appeal. (3) The papers referred to in sub-rule (1) above must always be legibly written or type-written in double space or printed. If xerox copy of a document is filed, then the same should be legible. Each paper should be certified as a true copy by the party filing the same, o .....

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for filing such additional evidence. (5) The parties shall not be entitled to submit any supplementary paper book, except with the leave of the Bench. (6) Documents that are referred to and relied upon by the parties during the course of arguments shall alone be treated as part of the record of the Tribunal. (7) Paper/paper books not conforming to the above rules are liable to be ignored. 29. Production of additional evidence before the Tribunal. The p .....

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unal, for reasons to be recorded, may allow such document to be produced or witness to be examined or affidavit to be filed or may allow such evidence to be adduced. 9. Mr. Shah submitted that whenever any party applies for production of additional evidence before the Tribunal, the Tribunal may allow such documents to be produced or any affidavit to be filed or reasons to be recorded and Rule 18(4) which provides that additional evidence not forming part of the paper book, was to be .....

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ribunal adopted a different course, omitting to pass an order on the application yet using the contents of the some of the documents in order to arrive at its conclusions in the appeal. Reasons for allowing or rejecting the AEPB could have to be recorded in the final order but was not. The course adopted by the Tribunal was perverse and therefore he submitted question A be answered in the affirmative. 10. In support of his contentions in respect of question (A), Mr. Shah, learned coun .....

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ner of Income Tax and Another 271 ITR 135; (vi) Parkkot Maritima Agencies Pvt. Ltd. v/s. Commissioner of Income Tax in Tax Appeal No.37 of 2016 decided on 15th November, 2016; (vii) Assam Hindu Mission Upper Nawprem v/s. Smt. Elaboris Tron AIR 1999 Gauhati 39; (viii) Smt. Suhasinibai Goenka v/s. Commissioner of Income Tax 216 ITR 518; (ix) Commissioner of Income Tax v/s. Kum. Satya Setia 143 ITR 486; (x) Hukumchand Mills Ltd. Vs. Commission .....

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late Tribunal) Rules directed the parties to file details showing description of the articles manufactured and the amounts received by the assessee. The same was filed on behalf of the assessee. on the directions of the Tribunal. In that case the judicial member of the Tribunal had based the entire reasoning relating to the factual position on the basis of the above material tendered for the first time before the Tribunal and that although the order of the Tribunal had used the word we indicatin .....

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h Court terming it as grossly unfair and illegal and therefore suffering from judicial infirmity and ad-hocism. It is not a case where the appellant before the Tribunal had sought leading of additional evidence documentary or oral. In the present case, the appellant assessee had himself filed the AEPB well before the date of hearing and the Revenue had notice of the application. The appellant-assessee therefore was fully aware of the additional material he sought to rely upon. As against this, i .....

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ravancore Titanium Products Ltd. (supra) is concerned, we note that the Court found that the Tribunal relied upon the documents which were tendered for the first time and that the grounds of appeal before the Commissioner were also not part of the paper book and the Tribunal had considered a working sheet that had been prepared and which was not a part of the documents tendered before the Tribunal as additional evidence in Rule 29 and no reasons were stated by the Tribunal for accepting these ad .....

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s been stated for receiving those documents at that stage. 13. The Court observed that it was competent for the Tribunal to admit additional evidence in accordance with law but for reasons to be stated since the parties would have fair and proper notice of the same thus causing the Court to observe that ad-hocism cannot be countenanced in law. In our view, Asian Techs (supra) and Travancore Titanium Products Ltd. (supra) offer no assistance to the appellant's cause. 14 .....

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nnot be admitted and acted upon at the stages of the appeal it chose to go through them and take a prima facie view that they are against the assessee …... In the present facts, there is no order passed stating the additional evidence cannot be produced/accepted. In the present facts, the evidence was produced by the Assessee and admittedly relied upon by the appellant before us. Thereafter it takes the same into consideration while disposing of the appeal. Although Mr. Shah had contended .....

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nds before the Tribunal, therefore has no application to the present facts. 16. Assam Hindu Mission Upper Nawprem (supra) has no relevance to the instant facts. In Smt. Suhasinibai Goenka (supra) the Court had occasion to consider Rule 29 of the ITAT Rules and observed that the Tribunal had sufficient cause for receiving additional documents filed for fair and just disposal of the case and that the Tribunal should have allowed the assessee to file additional document on record and sho .....

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hah had submitted that the word allow found in Rule 29 of the ITAT Rules indicated that the application would have to be made by the parties seeking to bring additional evidence and the Tribunal could allow such application. We do not find any merit in this submission inasmuch as it is only if the Tribunal so requires it may allow additional evidence to be brought on record. 17. In Zenith Ltd. (supra) this Court observed an order passed by the Tribunal declining to add additional grou .....

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) a Division Bench of this Court had allowed the assessee to place additional material before the Assessing Officer instead of Tribunal. However, we notice that this order came to be passed on request made on behalf of the Revenue by its counsel who did not oppose the request seeking the leading of additional evidence. 18. In the case of Hukumchand Mills Ltd. (supra) the Supreme Court considered the power of the Tribunal under Section 33(4) of the Indian Income Tax Act, 1922 and the A .....

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age 607 which reads as follows : We have frequently held that in the exercise of our appellate jurisdiction we have power not only to correct error in the judgment under review but to make such disposition of the case as justice requires. And in determining what justice does require, the Court is bound to consider any change, either in fact or in, law, which has supervened since the judgment was entered. We do not find the above pronouncements advancing the case of the Appellant give .....

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ertificate could not be brought to the attention of the Assessing Officer or the Commissioner of Income Tax (Appeals) and therefore it was necessary to take notice of the changed circumstances for doing complete justice to the assessee and the Court ought not to shut its eyes to such developments. We are unable to find merit in his submissions since we do not see how this would make any material difference to the Appellants since he had not complied with the mandatory conditions of Section 54.

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upon the Tribunal to pass an on order on his application to produce additional evidence contained in the AEPB before making his submissions on merits and therefore proceeded upon the understanding that the application has been allowed. The Tribunal has taken into consideration the submissions of counsel for the appellants based on the documents forming part of AEPB. There is no doubt in our mind that the Tribunal had permitted the appellants to make submissions on the basis of these documents. I .....

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ents in our view it would have been appropriate that some reasons will have to be given by them for depriving the parties the benefit of the submissions to be made on the basis of such additional documents. This, in our view is necessary since the rules itself provide for the right to seek reliance upon additional documents. We have no doubt that in the present case the Tribunal did not commit any error in the facts and circumstances of the present case in not having passed the order on the appl .....

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er three aspects. Firstly, the applicability of Section 54F(1) juxtaposed with Section 54F(4); Secondly, non-completion of construction of the building in which the appellant - assessee had agreed to purchase flats and Thirdly, contiguity of three flats which the appellant - assessee had agreed to purchase. Mr. Shah referred to the impugned order and submitted that relevant portions of the impugned order are to be found in paragraph 8 to 11 thereof. He submitted that the assessee surrendered ten .....

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nd submitted that Section 54F(4) provides that the net amount of consideration which is not appropriated by the assessee towards the purchase of the new asset within one year or which is not utilized by him for the purchase or construction of the new asset before the date of furnishing the return of income under Section 139, shall be deposited by the assessee in a separate account before furnishing the return of income under sub-section (1) of Section 139. This provision according to Mr. Shah is .....

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er of Income Tax vs. Punjab Financial Corporation 254 ITR 492; iii) Commissioner of Income Tax vs. Kullu Valley Transport Co. P. Ltd. 77 ITR 518; iv) Humayun Suleman Merchant vs. The Chief Commissioner of Income Tax, Mumbai in Income Tax Appeal No.545 of 2002 decided on 18th August, 2016; v) K. P. Varghese vs. Income Tax Officer, Ernakulam and Anr. 131 ITR 596 (SC); vi) CBDT and Others vs. Aditya V. Birla 170 ITR 137; vii) Commissioner of I .....

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Shah then made reference to the observations of the Tribunal in paragraphs 9 and 10 of the impugned order wherein the Tribunal had come to certain conclusions apropos the assessee's entitlement to claim exemption under Section 54F of the Act arriving at a decision but had failed to record whether these documents had been admitted in evidence. According to him, had the Tribunal decided the issue of admissibility by passing a reasoned order, the appellant could have been able to clear any dou .....

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in Section 54F the words 'shall' be deposited by him before furnishing such return (such deposit being made in any case not later than the due date applicable in the case of the assessee for furnishing the return of income under sub-section (1) of Section 139), is indicative of its directory nature and it is not mandatory to deposit such sum before the specified date and non-deposit would not be fatal to the appellant - assessee's claim for exemption. 26. According to Mr. .....

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n. He, therefore, submitted that the second question is liable to be answered in the affirmative. He submitted that making the investment is the critical requirement for Section 54. In the present case the Appellant had remitted the entire price before the due date yet the impugned order while dealing with the assessee's case had observed in paragraph 9 that the contention of assessee having invested a sum of ₹ 1.33 crores towards construction of flat before due date of fili .....

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(1) of Section 139). 27. Mr. Shah submitted that this interpretation was incorrect and based on improper appreciation of provisions. Merely because the Tribunal had queried the assessee as to stage of construction and to which the assessee responded that the construction was in progress, the Tribunal had proceeded to hold that construction had not been completed even after a lapse of seven years and declined to accept assessee's contention that three residential flats which were a .....

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P. Ltd. 77 ITR 518 held that Section 24(2) confers benefit of losses being set off and carried forward and there is no provision in Section 22 of that Act for determining losses for the purpose of Section 24(2). Section 22(2A) simply says that in order to get the benefit of Section 24(2) the assessee must submit his loss return within the time specified under Section 22(1). Thus, a return so submitted is a valid return. It further held that if two views are possible, the view one which is favour .....

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teria to section 22, providing for carrying forward of business loss, contained a specific provision whereunder, if the assessee sustains a loss of profit or gain in any year being a previous year, in any business, profession or vocation, the loss cannot be partly or wholly set off or the whole loss, (where the assessee had no other head of income) could be carried forward to the following year demonstrating a beneficial interpretation. 29. Mr.Shah submitted that provisions of Section .....

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tion 22(1) and thus, a return submitted at any time before the assessment is made is a valid return. Relying upon the said observation Mr. Shah submitted that in the present case also the date of filing the return is of no relevance and Section 139(4) should be read as extension of Section 139(1) and to that effect he submitted that the date of filing return is of no relevance provided other conditions had been satisfied, namely, that of investing amount received from the sale of old property. H .....

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Court in Commissioner of Income Tax vs. Rajesh Kumar Jalan (2006) 286 ITR 271 which has been referred to on behalf of the assessee. He then proceeded to attempt differentiation, referring to the facts of the case of Humayun Merchant (supra). He submitted that relevant dates in that case were 29th April, 1995 but the appellant sold plot of land for consideration. The petitioner paid two installments of ₹ 10 lakhs each in July 1996 and October 1996 before the due date of filing the return un .....

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In our view the submission of Mr. Shah that the expression 'shall' appearing in Section 54F(4) is not mandatory but only directory has no merit inasmuch as not only Section 54F(4) used the word 'shall' be deposited it is followed by the bracketed portion which reads : (such deposit being made in any case not later than the due date applicable in the case of the assessee for furnishing the return of income under sub-section (1) of Section 139) In view of th .....

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do not see how this decision assists Mr. Shah. As far as possible a beneficial provision should be liberally but not if to the extent that renders the intent of the provision redundant. The restrictions on the time within which the conditions of Section 54 have to be complied with are reasonable. If we were to take a different view it would result in dilution of the statutory provision and promote misuse. 33. In J.H. Gotla (supra) the Court observed that interpretation of a taxing St .....

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ter to be issued on the first installment being paid and that the allotment letter is final unless it is cancelled or the allottee withdraws from the scheme. It further observed that under the scheme, the allottee would get title to the property on the issuance of the allotment letter and that the payment of installment is only a follow up action and taking delivery of possession is only a formality. 34. In the fact situation at hand we are afraid the assessee can derive no benefit fr .....

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sent case, however, it is not in dispute that the agreement for sale was entered into only on 24th November, 2008 beyond the period of three years from the date of surrender of tenancy which was 13th September, 2005. Moreover, the developer had no approval for construction of the 9th floor of Wing 'C', wherein the assessee had booked three flats and such approval was received by the builders only on 7th September, 2010. Thus, according to us there is no question of assessee establishing .....

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into within one year of sale of old residential home. On facts, therefore, it clearly can be differentiated. Moreover, the assessee in that case had the benefit of board circular no.471 which clarifies that under the allotment letter issued by DDA under the self-financing scheme, the allottee gets title to property which is not so in the case at hand. We are of the view that the issue pertaining to incomplete construction and that of contiguity of flats need not be gone at this stage since on ve .....

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ise. 36. We have also considered the submission of Mr. Shah based on the case of Munibyrappa (supra) that the case laws relied upon by the appellant before the Tribunal was not considered and the Tribunal had brushed aside case laws in a single sentence. We noted that grievance of the assessee is based on the observations of Tribunal in paragraph 11 that they have not relied on the decisions cited. Every decision cited may not be relevant. We find that the decisions cited were relatin .....

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erein. 37. In the course of the submissions in support of the Appellants' case over exemption under section 54F Mr. Shah has strenuously argued and tried to draw a parallel between the provisions of Section 24(2) of the 1922 Act and Section 72 contending they are in pari materia. Likewise Sections 22 and 22(2A) were in pari materia with Sections 139 and 80 respectively of the 1961 Act. However, in our view this does not come to assistance of Mr. Shah inasmuch as the language of Se .....

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rmative in favour of the Revenue and against the Assessee. The Third Question 38. As far as the third question is concerned, as to whether the Tribunal infringed the principles of natural justice in not providing an opportunity to rebut the conclusion of the Tribunal based on circular no.495, Mr. Shah submitted that the assessee had no opportunity to deal with contents of the circular referred to by the Tribunal in its order. He relied upon circular dated 28th September, 19 .....

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sons was a basic rule of natural justice and one of the fundamentals of good administration. Relying upon this observation Mr. Shah submitted that although the impugned order dealt with documents the same were held against the appellant without providing the appellant an opportunity to meet any doubt that the Tribunal may have had. 39. We do not find that the Tribunal has based its decision on the effect of circular No.495 on the other hand only reference to the said circular is to be .....

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has to be deposited in specified account was required to be deposited before due date of return under Section 139(1). Since it is the case of the Appellants that the deposit has not been so made, the question of the assessee being affected, by the said circular does not arise. 41. We enquired of Mr. Shah as to whether the appellant's application for leading additional evidence was heard separately before the main appeal was taken up for hearing to which he replied that the applica .....

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