TMI Blog1990 (12) TMI 44X X X X Extracts X X X X X X X X Extracts X X X X ..... of Taxes) Act, 1987, and also of Notification No. 32/IT dated April 2, 1987, regarding the appointment of Income-tax Officers and Notification No. 654/Home/87 dated May 27, 1987, regarding the appointment of the appellate authority. Sikkim became a component State of the Indian Union by and under the Constitution (thirty-sixth) Amendment Act, 1975, which inserted article 371F in the Constitution. Clause (k) of that article provides that, notwithstanding anything in the Constitution, all laws in force immediately before the appointed day (i.e., 26th day of April, 1975) in the territories comprised in the State of Sikkim or any part thereof shall continue to be in force therein until amended or repealed by a competent Legislature or other competent authority. Clause (n) provides that the President may, by public notification, extend with such restrictions or modifications as he thinks fit to the State of Sikkim any enactment which is in force in a State in India, at the date of the notification. The Income-tax Act, 1961, was not in force in Sikkim at the relevant time, and so the law of income-tax which was in force on the appointed day was the law on the subject in the state of S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... collect taxes on income of private limited companies is not tenable and the presumption that the company being a new industry is exempted from payment of income-tax for a period of five years from the date of commencement of production does not hold good, as there was no specific order of the Government allowing the exemption and the benefits under the relevant Notification No. 2/TIC dated February 16, 1974, were not automatic. In exercise of the powers under rule 4(i) of the Manual, he passed the assessment order assessing incometax at Rs. 30,55,108.05 on the declared turnover of Rs. 10,20,62,601.63 for the period from October 15, 1981, to January 31, 1983. A notice of demand bearing the same date was also enclosed therewith. It was mentioned therein that the amount should be paid within 45 days of the issue of the notice failing which the company would be liable to pay simple interest at the rate of 12% per annum from the date of issue of the demand in accordance with Notification No. 1220/I. T. dated December 20, 1973, and if the payment was not made even after three months from the date of the issue of the notice, penal interest at the rate of 20% on the defaulted amount would ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de to the Director of Industries, Government of Sikkim, for a licence to set up a unit and the Government was duly informed that petitioner No. 1 would be claiming exemption from income-tax under the terms of the notification. The Director of Industries, Government of Sikkim, by a letter dated November 9, 1981, conveyed to petitioner No. 1 the approval of the Government for setting up a cigarette manufacturing unit in collaboration with ITC Ltd. subject to the conditions specified in the said letter. Furthermore, there is a participation clause in the notification and the terms thereof have been complied with. Besides, the Government of Sikkim decided not to participate in the venture. Moreover, taxes have not been levied and collected from other cigarette industries similarly circumstanced. (ii) The directors or shareholders of the company are not liable to discharge the income-tax liability of the company, the company being body corporate and a juristic person. (iii) The Income-tax Manual and the Notification No. 1220-200/IT and ST dated December 20, 1973, were neither signed nor approved by the Maharaja of Sikkim and the originals have not been produced. The Maharaja of Sikk ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndition stipulated in the notification bearing No. 1220-200/IT and ST dated December 20, 1973, for admission of the appeal. In the alternative, there is no such pre-condition stipulated in the Manual and no such condition could be imposed by the Notification dated December 20, 1973, which is merely an administrative order. (ix) There is no provision in the Manual for assessment of companies and the word "person" as defined in the said Manual does not include "company" and, therefore, assessment of taxes on a company is without jurisdiction of the Income-tax Officer. (x) The Income-tax Officer is empowered to charge income-tax on the gross sale proceeds of the previous year but he charged income-tax on the alleged gross sale proceeds of the years 1981-82 and 1982-83 on August 4, 1987, which was barred by limitation. The Income-tax Officer had the power and jurisdiction to make assessment on August 4, 1987, only for the accounting year 1986-87 and not prior to that. (xi) The provisions of the Sikkim (Collection of Taxes and Prevention of Evasion of Payment of Taxes) Act, 1987 (hereinafter referred to as "the Recovery Act"), are more onerous than the procedure set out in Order N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he 16th February, 1974. INCENTIVES FOR GROWING INDUSTRIES IN SIKKIM. For quite some time the Government of Sikkim have been considering offering suitable incentives for the new industries in Sikkim with a view to promote orderly and speedy industrial development of the country. The Government of Sikkim, after careful consideration of the matter, have now decided to make available the following concessions for new industrial establishments in Sikkim with immediate effect. (i) Electricity : The existing concessional rate of 25 N. P. per unit up to a monthly consumption of 1,500 units and 18 N. P. per unit above 1,500 units plus the usual rebate of 10% for payment within the due date will be continued till the Lower Lagyap Project is completed. The existing rate will be reviewed after the Lagyap Project is completed. (ii) H. T. Lines : There will be no charge for expansion of power lines except for the length and cost of equipment which are within the premises of the consumers, provided the return on capital invested on the power line beyond highway or a public road is found to be adequate. (iii) Water Tax : Wherever the industries make their own arrangement for the su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... k Industrial Area. 4. Kanchenjunga Properties Private Limited should have 51 (fifty one) per cent. share in participation with ITC Limited. There is nothing in this letter dated November 9, 1991, to show whether petitioner No. 1 was to be entitled to exemption from payment of income-tax or whether petitioner No. 1 had informed the Government that the company would be claiming such exemption. No copy of the letter of petitioner No. 1 submitting the proposal, in consequence of which the letter dated November 9, 1981, was sent by the Government was filed by any of the parties. Therefore, there is nothing on record to substantiate the plea of the petitioners that the Government had been duty informed that the company would be claiming income-tax. In fact, certain pleadings of an earlier Writ Petition bearing No. 10 of 1982, G. B. Chettri v. State of Sikkim, negative the plea of the petitioners. That petition was brought as a public interest litigation by five employees of a rival cigarette manufacturing unit, namely, the Sikkim Tobacco Private Ltd., that set up a unit in collaboration with Golden Tobacco Company Ltd., for revoking the permission granted by the Government, vide lett ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ched the Government of Sikkim for latter's approval. Furthermore, since the answering respondent's project required that land be made available to it by the State Government, it was considered appropriate that the State Government approve the establishment of the said factory." 29.... It is submitted that the guidelines prescribed in the alleged notification dated February 16, 1974, only apply to the case of an industry seeking the benefits under the said alleged notification. Where, therefore, an industry does not seek to obtain or derive benefits enumerated thereunder, there is no question of the alleged notification having any application. Even assuming, therefore, without admitting that the said guidelines prescribed that the Government must have a share in the equity participation of a company not being a small scale industry, these guidelines could only come into play and would, therefore, only apply where the concerned industry has asked for and actually received such benefits or is to receive such benefits. In the present case, the answering respondent had neither asked for nor received any benefits under the said alleged notification and, therefore, in any event, and wit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the concessions, if it was not satisfied about the participation referred to in paragraph (vii), where even negotiation was contemplated. Shri S. R. Sarkar, learned counsel appearing on behalf of the petitioners, has contended that the whole of the notification of 1974 except paragraph (v)(b) was repealed by the Sikkim Industries Licensing Ordinance, 1982, and, therefore, only that paragraph is to be read and, if this is done, then it would appear that the exemption was automatic. There is no merit in the contention that the exemption which was not automatic before the repeal of a portion of the notification would become automatic after the repeal. After the merger of Sikkim with India in the year 1975, the State Legislature did not have the competence to enact any law or amend the pre-existing law about income-tax, income-tax being a Central subject. Besides, the argument that only paragraph (v)(b) of the notification continued after the promulgation of the Ordinance has no merit for the reason that section 9 of the Ordinance was subsequently repealed by the Sikkim Industries Licensing Act, 1982, as if section 9 of the Ordinance never existed. Section 9 of the Ordinance runs a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Ordinance itself, i.e., June 19, 1982. Section 8 of the Act came into force from the same date on which section 9 of the Ordinance became effective, i.e., May 24, 1976. The result thus was that section 9 of the Ordinance was repealed as if it never existed. Thus, paragraphs (v)(b) and (vii)(a) and (b) continued to exist from May 24, 1976, by virtue of section 8 of the Act. The petitioners have alleged that clause (vii) of the notification of 1974 has been complied with by them because their cigarette manufacturing unit was a small scale industry and, in the circumstances, the requirement stipulated in the Director of Industries letter dated November 9, 1981, that Kanchenjunga Properties (Private) Ltd. should have 51% of the shares in participation with ITC Ltd. would only mean that 51 % of the shares should be held by the local, promoters of petitioner No. 1. The submission that the manufacturing unit was a small scale industry is repudiated in the affidavit filed on behalf of the respondents and there is nothing on record to substantiate the petitioner's allegation in this behalf. In fact, as stated earlier, in the earlier Writ Petition bearing No. 10 of 1982, where the pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent and well being of the people at large, including themselves, they may claim that others who are also liable to pay tax must not be left out. The concerned authorities should, therefore, see that those who have been left out be also proceeded against. Arguments were also advanced on the question whether the notification of 1974 amounted to a pre-merger law within the meaning of clause (k) of article 371F of the Constitution. But, since, in view of the above discussion, petitioner No. 1 is not entitled to exemption under the notification even if the notification is treated as law, it is not necessary to decide this question. Accordingly, it is held that petitioner No. 1 was not exempt from paying income-tax under the Manual. Now, the question is whether the directors or shareholders of the company cannot be proceeded against for discharging the tax liability of the company, the company being a body corporate and a juristic person. The petitioners have alleged that petitioner No. 1 company being limited by shares and as a juristic person, petitioners Nos. 2 to 5 who have already paid the value of their shares cannot be made liable to pay the tax due from the company. There is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the veil of corporate entity and to pay regard to the economic realities behind the legal facade. For example, the court had power to disregard the corporate entity if it is used for tax evasion or to circumvent tax obligation . . . " Again the Supreme Court reiterated in L. I. C. of India v. Escorts Ltd. [1986] 59 Comp Cas 548 ; AIR 1986 SC 1370, 1418. " (90) ... Generally and broadly speaking, we may say that the corporate veil may be lifted where a statute itself contemplates lifting the veil, or fraud or improper conduct is intended to be prevented, or a taxing statute or a beneficent statute is sought to be evaded or where associated companies are inextricably connected as to be, in reality, part of one concern. It is neither necessary nor desirable to enumerate the classes of cases where lifting the veil is permissible, since that must necessarily depend on the relevant statutory or other provisions, the object sought to be achieved, the impugned conduct, the involvement of the element of the public interest, the effect on parties who may be affected, etc." Jagadish Swarup, in his Commentaries on the Companies Act, 1956, 2nd Edition, Vol. 1, at page 110, has referred t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had no doubt that income-tax had to be paid. The question is : Did the distribution of almost the whole profit amongst the members of the two groups without making provision for the payment of income-tax not amount to a fraudulent or improper act on the part of the directors ? Had they made provision for income-tax, they could not have distributed almost the whole of the profits amongst themselves, their family members and members of the group as they did. So, if, in the circumstances, the directors are required to discharge the income-tax liability of the company, it will not amount to their making good any loss which could have been incurred by the company for, then they will merely be parting with the money which they were not entitled to have with themselves or their family members or members of another group. It is significant to note that income-tax liability is much less than what was distributed by the directors as dividend. It was not disputed during arguments that the assets of the company are not enough to satisfy the income-tax liability. Where profits have been unjustifiably distributed and tax obligation is sought to be circumvented by treating the corporate entity a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he merger since Government employees the businessmen were paying income-tax under no other law than the Manual of 1948. Since these were in force immediately before the appointed day, they are laws as per the provisions of clause (k) of article 371 F. It is true that the Income-tax Manual and the relevant notification have not been published till now so as to bring them within easy reach of the people and even the courts have to act on the typed or cyclostyled copies. The need for publication of laws can never be over-emphasised since, without publication, it is difficult to get access to them. So, the State in order to ensure proper compliance ought to have published the laws. However, only for this reason, the laws to which access could have been had, if a search had been made for them, though with difficulty did not become inoperative, particularly when they are primarily concerned with levy and collection of taxes and not with punishment for offences for non-compliance. As for the contention of the petitioners that the Income-tax Manual is not jurisprudentially legislative, it being a mere compilation of guidelines prepared by the Officers who used to collect taxes, there is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of income-tax falls within the Union List, the appointment of Income-tax Officers and appellate authorities must have been by the Central Government is also not valid. Since the implementation of the law contained in the Sikkim State Income-tax Manual is the responsibility of the State Government, it is that Government that has the jurisdiction to appoint the Officers to perform the duties thereunder. Further, clause 2(x) of the Manual defines "Income-tax Officer" as meaning a person appointed by the Government entrusted with the conduct or management of the levy or assessment of income-tax coming within the purview of the Manual. Sub-clause (vi) of that clause defines "Government" as "The Government of Sikkim". Both these provisions make it abundantly clear that an Income-tax Officer under the Manual has to be appointed by the State Government. The fact that the subject of income-tax falls within the Union List has no bearing on this point. As regards the question as to the authority competent to hear an appeal against the assessment of income-tax, clause 22 of the Manual provides that an "appeal from the assessment of income-tax or penalty imposed under any of the foregoing cla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he amount in dispute. He will not be, however, treated as such if the appeal, on determination, has been found to be frivolous and preferred only to gain time for payment." The requirement that an appeal may be filed after payment of 50 % of the amount assessed, necessarily means that an appeal cannot be filed without payment of that amount. When person is not to be treated as a defaulter is not germane to the question whether an appeal can or cannot be preferred without depositing the amount. However, it has been made clear that if the appeal is preferred after depositing the amount, the assessee would not, ordinarily, be treated as a defaulter though he will be treated as a defaulter if the appeal, on determination is found to be frivolous and preferred only to gain time for payment. As regards the alternative plea, clause 22 of the Manual reads as under : "22. Appeal against assessment under this Manual.-Appeal from the assessment of income-tax or penalty imposed under any of the foregoing clauses will lie to His Highness the Maharaja of Sikkim through the Department concerned." There is no doubt that the Manual does not require any deposit to be made as a condition preced ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... business at the rate prescribed." Previous year is defined in clause 2(viii) as under: "2(viii). 'previous year' in respect of an assessment means the financial year from 1 St April to 31 St March preceding the year in which tax assessed is to be collected." If the relevant words employed in the definition of "previous year" are substituted for the expression, "previous year" in clause 4(i), the latter clause will read like this: "Income-tax shall be charged on the gross sale proceeds of the financial year from 1 St April to 31 St March preceding the year in which tax assessed is to be collected from all persons engaged in business at the rate prescribed." Thus, there are no words of limitation to restrict the assessment only in respect of the gross sale proceeds of the year which immediately precedes the year in which assessment is made. Neither clause 4(i) nor clause 2(viii) says in which year an assessment is to be made. "Previous year" is defined with reference to the year in which tax assessed is to be collected but does not say when tax can be assessed or for which period tax can be assessed. Evidently, assessment cannot be made in a year for the sale proceeds of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fair and reasonable construction in the background of the context, has the submission of the petitioners any substance. Fair and reasonable construction of clause 4(i) would be to hold that, by using the expression "of the previous year", normal procedure which is ordinarily followed that income of a particular year is assessed in the next year, was mentioned, without the implication that if tax could not be so assessed, income would acquire immunity from tax liability. The submission of the petitioners in this regard thus fails. The next contention raised on behalf of the petitioners is that the Sikkim (Collection of Taxes and Prevention of Evasion of Payment of Taxes) Act, 1987 (hereinafter referred to as Act No. 7 of 1987), is beyond the competence of the State Legislature, since the State Legislature has no power or competence to legislate on any matter relating to levy of income-tax. Under section 4 of this Act, the Government was enjoined upon the duty to appoint one or more Inspectors for the purposes of the Act. "Tax" has been defined under section 3(d) to mean a tax payable under the taxation laws in force in the State of Sikkim. Thus, this Act has been enacted for colle ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Department. 4. If no case is filed in court within the limitation period prescribed under clause (3), it shall be presumed that the legality of the demand is accepted by the defaulter ; and the Officer-in-charge shall proceed to realise the amount as laid down in these rules. 5. Any suit filed after the expiry of the limitation period of three months calculated from the date of the final writ of demand shall be summarily dismissed. 6. If there is no response to the final writ of demand issued under clause (a), the Officer-in-charge is hereby invested with the civil court's power to realise the amount due, by distress sale of movable and landed property of the defaulter, in that order, up to the extent of the demand. Gangtok, J. S. Lall, I.C.S. The 21 St November, 1950. Dewan, Sikkim State." The procedure prescribed in this order was not found to be adequate and, therefore, to provide for measures for effective collection of taxes and also for prevention of evasion of due tax under the taxation laws in force in the State, the State Legislature passed the Sikkim (Collection of Taxes and Prevention of Evasion of Payment of Taxes) Act, 1987, which received the assent of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t is much more comprehensive and effective for the collection of taxes than that provided in Order 405/50. At the same time, it shortens the procedure. The prescription in the Order of first serving a preliminary writ of demand, then of disposing of objections, if any, then of issuing final writ of demand and, thereafter, waiting for three months, when the party demurring to pay may move the court for adjudication, seems to be unnecessarily prolix in a tax matter. So much of procedure has been substituted for, in the Act, by the mere prescription to serve a demand. Besides, though paragraph 6 of the Order says that "the Officer-in-Charge is hereby invested with civil court's power to realise the amount due, by distress sale of movable and landed property of the defaulter., in that order," it does not Provide for the manner in which the power is to be exercised. After the procedure has been provided for in the Act, the procedure contemplated in the Order cannot co-exist. In sections 5, 6, 7 and 8, the word "shall" has been used which means that, after the commencement of the Act, no discretion has been left for proceeding under the Order. Therefore, Order No. 405/50 stands supersede ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of the Collector to resort to one or the other and to pick and choose some of those in occupation of public properties and premises for the application of the more drastic procedure under section 5, that action had lent itself open to the charge, of discrimination and as being violative of article 14. In the present case, no discretion has been left as regards the collection of taxes. This has been done by the use of the word "shall", as stated earlier. Thus, there is no option but to hold that Order No. 405/50 has stood repealed by the enactment of the Act in so far as the collection of taxes is concerned. In the result, it is declared that the Sikkim State Order No. 405/50 dated November 21, 1950, stands repealed after the enactment of the Sikkim (Collection of Taxes and Prevention of Evasion of Payment of Taxes) Act, 1987, as regards the collection of taxes. In other respects, the petition is dismissed. There shall be no order as to costs. DR. B. N. MISRA C. J. - Facts of the case, respective stands of the parties and the points raised by the petitioners have been noted by my learned brother in his judgment. I come straight to the question whether, as argued by Mr. S. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncentive guaranteed and/or promised. Thus, in the written argument submitted to the court, though there is a reference to the petitioners' letter, there is no mention that the petitioners had given any intimation to the Government that they would be claiming exemption from payment of income-tax. In view of the totally contradictory statements of Shri Mahavir Prasad Agrawal in the present writ petition and in Writ Petition No. 10 of 1982, and as the petitioners have failed to produce before this court a copy of their application to the Government to set up the unit as well as claiming exemption from payment of income-tax, it must be held that the petitioners have failed to prove that they had made any application to the Government to the effect that, on setting up their unit, they would be claiming exemption from payment of income-tax. Further, the petitioners have filed a copy of Order No. 1890/IT dated October 29, 1986, issued by the Income and Sales Tax Department of the Government of Sikkim, annexure 'X', wherein Anil Plastic Industries of Gangtok were exempted from payment of income-tax for a period of five years from the date of production. No such specific exemption order of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent Notification issued under one of the clauses of the Ordinance could not be revived on the expiry of the Ordinance. That decision has no application to the facts of this case. Here, the 1982 Act has retrospectively restored the pre-May 24, 1976 position. Subject to Constitutional limitation; it is permissible for the Legislature to bring into existence the same state of affairs as obtained before the date of passing of the Ordinance by enacting an express law operating retrospectively to the said effect. This principle has been authoritatively laid down by the Hon'ble Supreme Court in its decision in T. Venkata Reddy v. State of Andhra Pradesh, AIR 1985 SC 724 (see paragraph 20). In the present case, the Sikkim Industries Licensing Act of 1982 restored the same state of affairs as existed prior to May 24, 1976 by virtue of its retrospective operation from that date. Thus, it follows that paragraph (v)(b) and paragraphs (vii)(a) and (b) of the 1974 Notification continued in force. It has been argued by learned counsel for the petitioners that paragraphs (v) and (viii) of the 1974 Notification were independent of each other ; the former dealt with exemption from income-tax and t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e affidavit filed by the State of Sikkim and the contents of paragraph 4(H) of the writ petition, it is seen that, in some cases, the State of Sikkim had undertaken negotiations with new enterprises regarding shareholding. Paragraph (vii)(a) of the 1974 Notification provides that the "guiding principle would be that the majority share in any new enterprise should be that of the Government of Sikkim but this shall be open for negotiation depending on the merits of each case." Therefore, there was nothing wrong in the negotiations with new enterprises. However, nowhere in the aforesaid affidavits is there any statement that exemption from payment of income-tax was automatic under the 1974 Notification as soon as a new industry was established. Accordingly, it must be held that petitioner No. 1 has failed to prove that it had expressly claimed or informed the Government that it would claim exemption from payment of income-tax and that it was not entitled to automatic exemption from payment of income-tax. The next question is whether petitioner No. 1, the company, incorporated under the Sikkim Registration of Companies Act, 1961, is liable to be assessed under the Sikkim State Inco ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... incorporation is never to be used for any illegal purpose, e.g., evasion or circumvention of tax obligations. A catena of decisions upholds this salutary principle and some of these decisions have been referred to by my learned brother who has also discussed in detail the attendant circumstances, including distribution of almost the entire profits amongst the two groups of directors without making provision for tax in order to evade the tax liability of the company, justifying the lifting of the corporate veil. On a careful consideration of the facts and circumstances of this case, I find that this is a fit case where, for the ends of justice and for protection of public interest, the corporate veil must be lifted. It must be held that petitioners Nos. 2 to 5 are jointly and severally liable to pay the income-tax dues of the company, petitioner No. 1. In view of this finding, the question whether petitioners No. 2 to 5 are liable to pay income-tax being "persons engaged in business " in the State of Sikkim does not arise. Another contention raised on behalf of the petitioners is that the procedure prescribed in Order No. 405/50 dated November 21, 1950 (annexure "M"), Notification ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the 1987 Act, particularly sections 4 to 9, dealing with appointment of Inspectors, collection of tax, demand, attachment, sale of property and "search and seizure", respectively, indicates that the 1987 Act has not left any discretion, option or alternative with the concerned authority to proceed to recover income-tax dues in any manner other than that provided in the 1987 Act itself. The aforesaid sections are clearly mandatory and they exhaust the entire field of procedure for recovery of income-tax dues in the State of Sikkim. The statutory provisions for recovery of income-tax laid down in the 1987 Act, after the coming into force of that Act, exclude the application of all other modes for recovery of income-tax provided in the earlier taxation laws and other laws. The 1987 Act leaves no room for the concerned authority to discriminate between one assessee and another in the matter of recovery of income-tax. The allegation of discrimination put forward on behalf of the petitioners must, therefore, be rejected. However, I would not go so far as to hold that the provisions, for recovery of income-tax as "public dues" in the Sikkim State Order No. 405/50 dated November 21, 19 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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