TMI Blog2020 (3) TMI 448X X X X Extracts X X X X X X X X Extracts X X X X ..... 8.2.2016 has an effect of interfering with the vested right already accrued in favour of writ petitioners in respect of purchase and sales made between the period 23.09.2015 to 07.02.2016, and, is liable to be struck down as being violative of Articles 14 and 19(1)(g) of the Constitution of India? - HELD THAT:- The substituted provisos inserted vide notification dated 08.02.2016 are not clarificatory in nature and, has an effect of curtailing the vested right of the dealers in respect of purchases and sales of goods made between the period 23.09.2015 to 07.02.2016 and is, thus declared ultra vires to the extent said provisos have been given retrospective effect. In other words, these provisions are held to be intra vires w.e.f. 7.2.2016 only and onwards. Whether Amendment carried out in sub-section 8 of Section 18 of the JVAT Act, wherein a new clause (xviii) has been inserted after existing clause (xvii) of the aforesaid section, is ultra-vires and violative of Articles 14 and 19(1)(g) of the Constitution of India? - HELD THAT:- By virtue of said amendment the State Government is putting restrictions on the availability of ITC on such raw materials which are consumed or burnt u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 23.09.2015 till 16.02.2017 and during the said period no assessment could be made and for the said period no forfeiture of ITC can take place and the computation of ITC is to be made for the said period in terms of existing Rule i.e. Rule 26(5) JVAT Rules, including the formula prescribed therein. Any assessment order, scrutiny order, etc, passed in respect of the writ petitioners having an effect of forfeiture of ITC are hereby declared illegal and quashed for the period 23.09.2015 till 16.2.2017. - W.P.(T) No. 134 of 2016, 1101 of 2016, 1227 of 2016, 1228 of 2016, 1243 of 2016, 1318 of 2016 And others - - - Dated:- 29-1-2020 - HON BLE MR. JUSTICE H. C. MISHRA AND HON BLE MR. JUSTICE DEEPAK ROSHAN For the Petitioners: Mr. Biren Poddar, Sr. Advocate, Mrs. Darshana Poddar Mishra, Advocate, Mr. Piyush Poddar, Advocate, Mr. Manav Poddar, Advocate, Ms. Rakhi Sharma, Advocate, Mr. Sumeet Gadodia, Advocate, Ms. Shilpi Sandil, Advocate, Mr. Ranjeet Kushwaha, Advocate, Mr. Nitin Kr. Pasari, Advocate, Ms. Vishakha Gupta, Mr. Sidhi Jalan, Advocate, Mr. Vaibhav Vishal, Advocate, Ms. Amrita Sinha, Advocate And Mr. Aditya Khandwal, Advocate For the Respondents-State : Mr. Ajit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny, M/s Highco Engineers Pvt. Ltd., M/s Estro Engineers, M/s RSP Metaliks Pvt. Ltd., M/s Vananchal Steel Alloys Pvt. Ltd, M/s Hariom Smelters Pvt. Ltd., M/s Naredi Steel Traders, M/s ASL Industries Ltd., M/s ASL Enterprises Ltd., M/s Balaji Cellphone Pvt. Ltd., M/s Ladhu Ram and Sons, M/s Shree Balaji Enterprises, M/s J P Steel Udyog, M/s Himadri Steel Pvt. Ltd., M/s Shree Om Metals Private Limited, M/s Modi Sales Agency, M/s Tatanagar Metal Industries, M/s T and T Metals Private Limited, M/s Nutech Auto Private Limited, M/s RSB Transmission (I) Ltd., M/s Suraj Automobiles, Apex Auto Limited, M/s Ankur Biochem Private Limited, M/s Shri Marooti (S.S.F.) Industries Pvt. Ltd., M/s Shri Marooti (S.S.F.) Industries Pvt. Ltd., M/s Balaji Cellphone Private Limited, M/s Pravat Fabricators Private Ltd., Hari Om Casting Co. Pvt. Ltd., Jamshedpur Continuous Annealing Processing Company Private Limited, Jharkhand Ispat Pvt. Ltd., Aloke Steels Industries Private Limited, M/s Vinayak Precon Industries, M/s Pushkar Techno Private Limited, M/s Vinayak Ferrocon Industries, M/s Jagdamba Ingotech Steel Private Limited, Electrosteel Steels limited, M/S SMG Metals Minerals, Maa Chhinmastika Cement ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs of goods. Since in the batch of the present writ applications the only issue for adjudication is the validity of the amendment carried out under the JVAT Act, and/or JVAT Rules, individual facts of the writ applications are not discussed as the same are not in dispute. However, for proper appreciation of the issues involved in the instant writ applications, it would be appropriate to notice the various amendments carried out under the provision of Section-18 of the JVAT Act, including the amendment carried out under Rule- 26 of the JVAT Rules, which are as under:- (i) Amendment No.1 Vide notification dated 23.09.2015 an Amendment was carried out in Clause-(ii) of sub-section-4 of Section-18 of the JVAT Act, 2005 and, Clause-(iii) of sub-section-4 of Section-18 of the JVAT Act, 2005, as under:- Amendment in Section-18- b) In clause (ii) of sub-section (4), after the existing provision Sale in course of inter-State trade and commerce falling under sub-section (1) of Section 8 of the Central Sales Tax Act, 1956 ( 74 of 1956) , a proviso shall be added in the following manner:- Provided that the Input Tax Credit on purchases when sold in course of inte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t, 1956 and balance input tax shall not be available for adjustment from any tax, penalty or interest payable The aforesaid amendments were also initially given retrospective effect with effect from 1.4.2015. (iv) Amendment No.4 Vide notification dated 17 th February, 2017, Amendment was carried out under Rule-26 of the JVAT Rules, and the amendment in Rule- 26 was carried out in the following manner:- Amendment in Rule-26 A new sub-rule as sub-rule (11A) shall be inserted after sub- rule (11) in the following manner:- Sub-rule (11A)- Where any VAT dealer is making inter-state sales falling under sub-section(1) as well as sub-section(2) of section(8) of the C.S.T. Act, 1956 and the inputs are common in both, the amount so claimed as input tax credit for the purpose of section 18(4)(ii) and 18(4)(iii) shall be calculated in the following manner:- (a) For the purpose of calculating input tax credit not admissible for adjustment from any tax payable as mentioned in Section 18(4)(ii) and 18(4)(iii) of the Act, the under mentioned formula shall apply:- Proportionate input Tax credit on such CST payable on inter-state sales falling under s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sub-section- 4 of Section-18 of the JVAT Act, including the amendment carried out under Section 18(8) of the JVAT Act, shall come into force with effect from 23.09.2015 and not w.e.f. 1.4.2015. Thus, in substance, retrospective operation of the amendments carried out under Section 18(8) of the JVAT Act, was annulled and the said amendment was made effective from the date of insertion of the said provisions under the Act. However, the amendment carried out vide notification dated 8.2.2016 by which substituted proviso was inserted to clause-(ii) and (iii) of sub-section-4 of Section-18 of the JVAT Act, 2005 with effect from 1.4.2015, was made operative with effect from 23.09.2015. Thus, retrospective operation of the proviso inserted vide amendment Act contained in notification dated 8.2.2016 still continued. However, the period of retrospectivity was reduced and the said provision was made operative w.e.f. 23.09.2015 instead of 01.04.2015. The aforesaid ordinance contained in notification dated 9th June, 2017 was converted into an Act in terms of provisions contained under Section 173 of the Jharkhand Goods and Services Tax Act, 2017. 6. Mr. Biren Poddar, learned Senior Advocate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... given retrospective effect from 23.09.2015. 9. It has been vehemently contended that even if ITC is held to be a concession, said concession cannot be withdrawn retrospectively which has an effect of curtailment of vested rights already accrued in favour of dealers in respect of purchases of Inputs for the period between 23.09.2015 to 08.02.2016. In this regard, learned counsels for the petitioners have relied upon a decision of the Hon ble Supreme Court in the case of Jayam and Company Vs Assistant Commissioner and Anr, reported in (2016) 15 SCC 125 (relevant paragraphs 2, 6, 16 to 19). Further, the constitutional validity of the amendment carried under sub-section 8 of Section 18 of the JVAT Act, vide amending Act dated 23.09.2015 was pressed by the writ petitioners. Mr. Sumeet Gadodia, learned Advocate appearing for the petitioners assailed the constitutional validity of the said amendment by contending inter-alia that said amendment is violating the equality clause enshrined under Article 14 of the Constitution of India. It has been submitted that it is well known principle of law that a Taxing statutes is not beyond the pale of challenge under Article 14 of the Constitu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the effect of the amendment would be deemed to come into force only w.e.f. 17.2.2017, it would not be open to the Assessing Authority to arbitrarily make assessment or forfeiture of ITC without any machinery provision prior to 17.2.2017. It has been further submitted that under Section 18(2) of the JVAT Act, provisions have been incorporated for availment of ITC and it has been provided in the said section that a registered dealer is entitled to ITC to be calculated in such manner, as may be prescribed. It has been contended that in absence of any guidelines contained under the Act for calculation of ITC, the same would be governed by the Rules containing the machinery provisions, and thus, in absence of machinery provisions being incorporated in the rules prior to 17.2.2017,the amendment carried out under the Act cannot be given effect to and is unworkable and hence, no forfeiture of ITC can be made for the period commencing from 23.09.2015 to 16.2.2017. 13. Reliance has been placed by the petitioners on the following decisions:- (1) Regional Transport Officer, Chittore Vs Associated Transport Madras(P) Ltd and Ors, reported in (1980) 4 SCC 597, relevant paragraph- 3 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tted that initially the amendment carried out vide Amending Act contained in notification dated 23.9.2015 was given retrospective effect, but, subsequently the retrospective operation of the said Act was removed and said amended provision was made effective with effect from 23.9.2015 itself. However, it has been admitted that substituted proviso which was inserted vide Amending Act contained in Notification dated 8.2.2016, even after subsequent amendment, still has retrospective effect at least with effect from 23.9.2015. However, the said retrospective effect given to the amended proviso is sought to be justified by submitting inter-alia that said substituted proviso was merely clarificatory in nature. It has been submitted that by virtue of the original provision inserted by amending Act dated 23.9.2015 benefit of ITC was already restricted only to the extent of CST payable under Section- 8(1) of the CST Act, and subsequent proviso which inserted the provisions of forfeiture of balance available ITC was, in substance, to give effect to the original provision which was already inserted. It is in this background that it has been contended that substituted proviso is merely clarific ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Government does not have powers to make Rules with retrospective effect. It has been contended that power conferred upon the State Government to frame Rules were to generally carry out the purposes of the Act and since, by virtue of the impugned amendments, more particularly substituted proviso inserted in clause (ii) and (iii) of sub-section-4 of Section-18 of the JVAT Act, 2004 which provides for forfeiture of ITC, Rules were amended with retrospective effect to give effect to the said amended proviso. While placing reliance over sub-section(3) of Section-94, it was contended that said provision provides inter-alia that every Rule framed under Section- 94 is required to be laid before the State Legislature and the State Legislature can modify such Rule or even annul the Rule. On the strength of said provision, it has been contended that Section 94 gives sufficient indication that Rule making power conferred upon the State Government did not restrict the State Government to frame Rules with retrospective effect for carrying out the purposes of the Act. 21. In addition, it has been argued by the learned Advocate General that even in absence of the amended Rules inserted vide not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (C) is the total turnover as defined under the Act during the period, but shall not include- i) Purchase price of goods taxable under Section 10 of the Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer of a business as a whole iv) [ xxx] (iii) This sub-rule is not applicable, if the VAT dealer is making exempt transactions. 22. By comparing the formula prescribed under the existing Rule 26(5) with the formula prescribed under newly inserted Rule 26(11A) of the Rules, it has been contended that, in substance, this formula is the same and hence, there was adequate machinery provision already existing under the rules for computation of forfeited amount of ITC in terms of amendment carried out under the JVAT Act. 23. The learned Advocate General further while relying upon the decision of the Hon ble Supreme Court in the case of Mahim Patram(P) Ltd V. Union of India, (2007) 3 SCC 668 , has contended inter-alia that even if there does not exist any machinery provision for giving effect to the amendments carried out under the JVAT Act, the said amendment cannot be said t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iso to clause(ii) and clause(iii) of sub-section 4 of Section 18 of the JVAT Act vide amendment notification dated 23.09.2015 was substituted by insertion of new proviso vide amendment act contained in notification dated 8.02.2016. 26. During the course of arguments the learned counsels for the petitioners have not pressed their challenge to the insertion of proviso to clause (ii) and (iii) of section 18(4) of the JVAT Act and have confined their challenge to the retrospective effect being granted to the substituted proviso inserted vide notification dated 08.02.2016 which have been given retrospective effect with effect from 23.09.2015. Accordingly we have been called upon to answer the aforesaid issue with regard to amendment having been given retrospective effect. 27. The learned counsels appearing for the petitioners contended inter-alia that the effect of the substituted proviso inserted vide notification dated 8.2.2016 is that for the first time provisions have been incorporated under the Act for forfeiture of balance ITC remaining with a dealer after availing ITC on purchase of goods when sold in course of inter-State trade and commerce under section 8(1) of the CST Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rried forward for adjustment against the tax due for subsequent tax period or periods and such credit or part thereof remains unadjusted even after a period of 24 months from the close of the year for tax period for which the return showing the excess input tax credit, the dealer may opt to claim refund of the amount of such input tax by way of assessment, reassessment or audit assessment. 3(ii) Where a dealer opts for such refund under sub-section 3(i), he shall make an application that effect to the prescribed authority within such time and such manner as may be prescribed; 3(iii) Any refund covered under this sub-section shall be granted in such manner and subject to such conditions and restrictions as may be prescribed . Thus, under the scheme of the JVAT Act, excess ITC was allowed to be carried forward for the subsequent tax period for adjustment against tax liability and even provisions were made for refund of such excess ITC if the same remained unadjusted even after a period of 24 months. 30. A perusal of the provision of Section 18(4)(ii)and 18(4)(iii) of the JVAT Act, without insertion of substituted proviso would reveal that although in the aforesaid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ective operation which has an effect to take away or impair the existing right or create new obligation or impose a new liability otherwise than as regards matter of procedure. 32. As we have already held above, present amendment has an effect of introducing the provision of forfeiture of ITC for the first time and hence, it creates new obligation and/or liability and thus, it cannot be said to be merely clarificatory. It is true that where the legislative competence of the State legislature is not under question, Legislature has ample power to give retrospective effect to the provision. However, it is a settled law that provisions which are made for the first time to the detriment of a dealer cannot be given retrospective effect when vested right accrued in favour of dealer is sought to be taken away. Such amendment cannot be given retrospective effect. In this regard we would like to place reliance upon a judgment of the Hon ble Supreme Court in the case of Jayam and Company Vs. Assistant Commissioner Ors (Supra) . The said judgment has been relied by the learned counsels for the petitioners and the respondents both. In the said judgment of the Hon ble Supreme Court, amen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1.1.2007. (Emphasis supplied) 33. In view of discussions held aforesaid, we declare that the substituted provisos inserted vide notification dated 08.02.2016 are not clarificatory in nature and, has an effect of curtailing the vested right of the dealers in respect of purchases and sales of goods made between the period 23.09.2015 to 07.02.2016 and is, thus declared ultra vires to the extent said provisos have been given retrospective effect. In other words, these provisions are held to be intra vires w.e.f. 7.2.2016 only and onwards. Question No.III. 34. By virtue of the amending Act dated 23.09.2015, a new clause (xviii) was inserted in sub-section-8 of section 18 of the JVAT Act, which has an effect of denying ITC on such goods which are consumed or burnt up in the manufacturing process and is not transferred into or existent in the finished product. The said provision reads as under:- 18- Input Tax Credit- ......... ........... (8) No input tax credit under sub-Section (1) shall be claimed or be allowed to a registered dealer- ............................ (xviii) In respect of goods consumed or burnt up in course of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unconsumable raw materials. 37. The Hon ble Supreme in the case of Jayam and Company Vs. Assistant Commissioner Ors ( Supra) have held that ITC is in the nature of concession and it is open for the State Government to prescribe conditions and restrictions for availing benefit of such concession. In the case of Kasinka Trading and Anr (Supra) , in para 23 the Hon ble Supreme Court has observed and held as under:- 23. The appellants appear to be under the impression that even if, in the altered market conditions the continuance of the exemption may not have been justified, yet, Government was bound to continue it to give extra profit to them. That certainly was not the object with which the notification has been issued. The withdrawal of exemption in public interest is a matter of policy and the courts would not bind the government to its policy decisions for all times to come, irrespective of the satisfaction of the Government that a change in the policy was necessary in the public interest . The Courts, do not interfere with the fiscal policy where the Government acts in public interest and neither any fraud or lack of bona fides is alleged much less est ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... een days which may be comprised in one session or in two successive sessions, and if, before the expiry of the session in which it is so laid or the session immediately following, the State Legislature agrees in making any modification in the rule or the State Legislature agrees that the rule should not be made and notify such decision in the Official Gazette, the rule shall from the date of publication of such notification effect only in such modified form or be of no effect, as the case may be so however that any such modification or annulment shall be without prejudice to the validity of anything previously done or omitted to be done under that rule. 40. A bare reading of the said provision would reveal that the delegate has not been conferred powers to frame rules with retrospective effect. It is settled law that unless Statute conferring powers to make Rules, provides for making Rules with retrospective operation, Rules made pursuant to that power can have prospective operation only. (see Accountant General Anr Vs. S. Doriswamy Ors (Supra) 41. The Hon ble Supreme Court in its recent decision rendered in the case of Federation of Indian Mineral Industries and Or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... learned Advocate General is not tenable in the eyes of law in view of judgment of the Hon ble Apex Court in the case of Regional Transport Officer, Chittore Vs Associated Transport Madras(P) Ltd and Ors(Supra) . In the said judgment exactly similar question arose before the Hon ble Apex Court wherein the Rules which were to be framed by the delegate were required to be placed before the State Legislature, which could have affirmed the Rules with or without modification. In the said case, similar arguments were advanced that since in the Act provisions were incorporated for placing the Rule on the table of the State legislature for its approval, there was sufficient indication to infer that retrospectively in the Rule making power was implicit. The aforesaid contention was expressly repelled by the Hon ble Supreme Court in its aforesaid judgment as under:- 4. The legislature has no doubt a plenary power in the nature of enactment of statutes and can itself make retrospective laws subject, of course, to the constitutional limitation. But it is trite law that a delegate cannot exercise the same power unless there is a special conferment thereof to be spelled out from the expre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fore each House of Parliament would not, however, prevent the courts from scrutinising the validity of the rules and holding them to be ultra vires if on such scrutiny the rules are found to be beyond the rule-making power of the Central Government. (Emphasis supplied) 44. In view of discussions made herein above, we are of the firm opinion that provision of Section- 94 of the JVAT Act, 2005 does not confer any power to the State Government to frame any Rule with retrospective effect and thus, the State Government, while enacting the machinery provision for giving effect to the amendment carried out in clause(ii) and (iii) of sub-section-4 of Section 18 of the JVAT Act with retrospective effect i.e. w.e.f. 1.4.2015 have exceeded its jurisdiction, and to that extent amended Rule is ultra vires the provisions of Section 94 of the JVAT Act, 2005. Accordingly, we declare that Amendment carried out under the JVAT Rules, 2006 vide amending Notification dated 17.2.2017 by which Rule 26(11A) was inserted shall have only prospective operation with effect from 17.2.2017 and the provision contained in the aforesaid notification to the extent it gives retrospective application of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isting provision of the Finance Act 1994 itself was sufficient to levy service tax on indivisible works contract. 47. While answering the question regarding absence of machinery provision in the Finance Act and its corresponding rules for computation of leviability of tax on indivisible works contract, the Hon ble Delhi High Court relied upon the judgment of Hon ble Supreme Court in the case of Mahim Patram(P) Ltd V. Union of India , to arrive at a proposition that even when rules are not framed for computation of tax, tax would be leviable. It may be indicated at this stage, that the learned Advocate General during his arguments has also placed extensive reliance on the judgment of the Apex Court in the case of Mahim Patram (P) Ltd (Supra) . The Hon ble Supreme Court in the case of Larsen Tubro Ltd has reiterated the importance of machinery provision for assessment of tax, etc, and has even explained the ratio of the judgment rendered in the case of Mahim Patram (P) Ltd (Supra) . The Hon ble Supreme Court in the said judgment has clearly held that judgment in the case of Mahim Patram (P) Ltd (Supra) . does not lay down the principle that in absence of any rule b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that a tax is leviable even if no Rules are framed for assessment of such tax, which is wholly incorrect. The extracted passage from Mahim Patram case only referred to rules not being framed under the Central Act and not to rules not being framed at all. The conclusion therefore in para 36(2) of the Delhi High Court judgment is wholly incorrect. Para 36(2) reads as follows: (G.D. Builders case, SC Online Del) 36.. .(2) Service tax can be levied on the service component of any contract involving service with sale of gods, etc. Computation of service component is a mater of detail and not a mater relating to validity of imposition of service tax. It is procedural and a mater of calculation. Merely because no rules are framed for computation, it does not follow that no tax is leviable 33. The aforesaid finding in G.D. Builders case is in fact contrary to a long line of decisions which have held that where there is no machinery for assessment, the law being vague, it would not be open to the assessing authority to arbitrarily asses to tax the subject. Various judgments of this Court have been referred to in the following passages from Heinz India (P) Ltd v. State of U.P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4 of Section-18 of the JVAT Act. Not only the State Government framed rules for giving effect to the aforesaid amendments but even the said rules were framed with retrospective effect. This itself clearly demonstrates that machinery provisions were inserted for denying benefit of ITC from being carried forward for adjustment from any tax, penalty or interest therein. 50. In the preceding paragraphs of our judgment, we have already stated that prior to introduction of the substituted proviso in clause(ii) and (iii) of sub-section 4 of Section-18 of the JVAT Act, there was no provision for forfeiture of ITC under the Act and said provision has been inserted for the first time. The effect of the said proviso is to forfeit ITC by making it unavailable from being adjusted against liability of tax, interest and penalty. Thus, in substance, machinery provisions which were prescribed for the first time by virtue of Rule 26(11A) of the JVAT Rules laying down mechanism by which amount of forfeited ITC can be determined, the said provision of the JVAT Act could not be enforced. At this stage, it would be appropriate to refer to Section 18(2) of the JVAT Act, 2005 which reads as under:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te General has also argued though feebly that JVAT Act itself contains provision for computation of ITC. We are not persuaded by the said argument of the learned Advocate General as we have not been shown any provision under the JVAT Act which itself contains machinery provision for computation of ITC. To the contrary, Section 18(2) of the JVAT Act, specifically provides inter-alia that ITC shall be calculated in such manner as may be prescribed. 53. In view of the discussions made hereinabove, we are of the firm opinion that in absence of machinery provision having been prescribed by the State of Jharkhand for giving effect to the proviso inserted in clause(ii) and (iii) of sub-section 4 of Section 18 of the JVAT Act, the said provisos were unworkable between the period 23.09.2015 till 16.02.2017 and during the said period no assessment could be made and for the said period no forfeiture of ITC can take place and the computation of ITC is to be made for the said period in terms of existing Rule i.e. Rule 26(5) JVAT Rules, including the formula prescribed therein. Any assessment order, scrutiny order, etc, passed in respect of the writ petitioners having an effect of forfeiture ..... X X X X Extracts X X X X X X X X Extracts X X X X
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