2) Whether or not in the facts and
circumstances of the case the petitioner
University's activity of sale of Prospectus to help
students, which activity is integral to its sole
activity of imparting education, amounts to the
Petitioner University 'carrying on business' as a
'dealer' and therefore liable to tax under the KVAT
Act, 2003.
3) Whether or not the Petitioner University
could be considered as a 'dealer' and 'carrying on
business' as defined under Sections 2(12) and
2(6) of the KVAT Act, 2003 in regard to sale of
Prospectus to students, merely for the reason that
the price charged for sale of Prospectus is higher
than the cost of printing.
4) Whether or not the Hon.ble Appellate
Tribunal is correct in holding that the Petitioner
University is liable interest u/s 36(1) of the KVAT
Act, 2003 for non-payment of tax, when it is not a
'dealer' and carrying on business and therefore
outside perview of the Act.
5) Whether or not the provisions of the KVAT
Act, 2003 are applicable to the petitioner
University established by Statute with the sole
object of imparting education to students and
more so when sale of Prospectus to students is an
integral part of its sole object of imparting
education.
6) Whether or not the impugned Order dated
2-2-2024 passed by the Hon'ble Appellate Tribunal
is otherwise in accordance with law.
6. Sri Aditya Vikram Bhat, learned Additional
7. Per contra, Sri T.N. Keshava Murthy, learned
counsel, along with Sri C.S. Suryakanth, learned counsel for the
respondent-University, made the following submissions:
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7.1 The University, being a statutory body established
to impart education, is not a dealer engaged in any trade,
commerce, manufacture, or any adventure or concern of a
commercial nature, and therefore does not fall within the
definition of "business" under Section 2(6) of the KVAT Act,
2003, or "dealer" under Section 2(12) thereof, and
consequently, is not liable for registration.
7.2 The primary activity of the University is imparting
education, which lies entirely outside the ambit and scope of
the KVAT Act. It is submitted that the imparting of education
cannot be treated as a business. The supply of prospectus is in
furtherance of the educational activity and is intended for the
convenience of students, providing details of course material,
syllabus, duration of courses, application for enrolment, fee
structure, and other relevant information.
7.3 The supply of prospectus is limited to the cost
incurred in printing, processing of applications, evaluation of
eligibility, and other associated services. The price charged for
the prospectus contains no element of profit. Learned counsel
submits that the University is not a dealer, is not engaged in
any business, and is therefore not required to be registered as
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a dealer or to file returns under the KVAT Act. It is further
submitted that the respondent-University has no profit motive
and has not derived any profit. The contention of the State that
the printing and sale of prospectus resulted in profit to the
University is without any basis. The printing and sale of
prospectus is not a continuous activity but occurs only at the
beginning of the academic session. Moreover, the State has not
taken into account other charges included in the cost of the
prospectus, such as application processing, eligibility
evaluation, registration, and admission of students, among
others.
7.4 Learned counsel further submits that the sale of
prospectus is an integral part of the University's educational
objectives, carried out without any business nexus or profit
motive. It is submitted that, in connection with the activity of
printing and sale of prospectus, the University has not earned
any profit. Learned counsel also contends that the reliance
placed by the Tribunal on the judgment of this Court in
Manipal University (supra) is misplaced and is not applicable
to the facts of the present case.
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7.5 Learned counsel for the respondent-University
further relies upon the judgment of the Rajasthan High Court in
Commercial Taxes Officer vs. Banasthali Vidyapith in SB
STRP No.205/2014, dated 06.02.2015.
8. We have considered the submissions advanced by
the learned counsels for the parties and have perused the
appeal papers, along with the findings recorded by the
authorities in the impugned orders.
8.1 We note that the respondent-University is a
statutory body established under the Karnataka State Open
University Act, 1992, with the primary object of imparting
distance education in multiple disciplines to students who are
unable to pursue studies in regular colleges. The University has
printed and supplied prospectus to such students, containing
information mainly regarding course content, syllabus, duration
of courses, application forms for enrollment, fee structure, and
other courses offered.
9. It is the case of the State that the sale of
prospectus is not incidental to the imparting of education, that
the prospectus are sold at a higher rate, and that profit is
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thereby generated. According to the State, as the activity of
printing and sale of prospectus is in the nature of business or
trade, the University is required to be registered as a dealer
under the KVAT Act and comply with its other provisions. The
respondent-University, on the other hand, contends that the
fee charged for the prospectus not only covers the cost of
printing but also includes charges for other services rendered,
such as enrollment, verification of applications, application
processing, and other incidental services.
10. We have scrutinized the documents placed on
record by both sides. Although the State contends that the
University has earned profit by charging a higher fee for the
supply of prospectus, no details have been furnished to
substantiate such contention. The mere fact that the fee for the
prospectus is relatively high cannot, by itself, be construed as
evidence of profit. In the absence of such details, this Court
finds it difficult to accept the State's contention that profit has
been made on the sale of prospectus.
11. The other issue for consideration is the requirement
of registration under the KVAT Act and compliance with its
other provisions. For the purpose of examining this issue, the
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following provisions are relevant and are extracted hereunder
for convenience:
11.1 Sections 2(6), 2(12), 2(34), 2(35), 2(36), and
Section 4 of the KVAT Act, for ready reference, are extracted as
follows:
(6) 'Business' includes:-
(a) any trade, commerce, manufacture or any
adventure or concern in the nature of trade,
commerce or manufacture, whether or not
such trade, commerce, manufacture,
adventure or concern is carried on in
furtherance of gain or profit and whether or
not any gain or profit accrues therefrom; and
(b) any transaction in connection with, or
incidental or ancillary to, such trade,
commerce, manufacture, adventure or
concern.
(12) 'Dealer' means any person who carries on the
business of buying, selling, supplying or distributing
goods, directly or otherwise, whether for cash or for
deferred payment, or for commission, remuneration or
other valuable consideration, and includes-
(a) an industrial, commercial or trading
undertaking of the Government, the Central
Government, a State Government of any State
other than the State of Karnataka, a statutory
body, a local authority, company, a Hindu
undivided family, an Aliyasanthana Family, a
partnership firm, a society, a club or an
association which carries on such business;
(b) a casual trader, a person who has,
whether as principal, agent or in any other
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capacity, carries on occasional transactions of
a business nature involving the buying,
selling, supply or distribution of goods in the
State, whether for cash or for deferred
payment, or for commission, remuneration or
other valuable consideration;
(c) a commission agent, a broker or del
credere agent or an auctioneer or any other
mercantile agent by whatever name called,
who carries on the business of buying, selling
, supplying or distributing goods on behalf of
any principal;
(d) a non-resident dealer or an agent of a
non-resident dealer, a local branch of a firm or
company or association situated outside the
State;
(e) a person who sells goods produced by him
by manufacture or otherwise;
(f) a person engaged in the business of
transfer otherwise than in pursuance of a
contract of property in any goods for cash
deferred payment or other valuable
consideration.
(g) a person engaged in the business of
transfer of property in goods (whether as
goods or in some other form) involved in the
execution of a works contract;
(h) a person engaged in the business of
delivery of goods on hire purchase or any
system of payment by installments;
(i) a person engaged in the business of
transfer of the right to use any goods for any
purpose (whether or not for a specified
period) for cash, deferred payment or other
valuable consideration; Explanations.- (1) A
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society (including a cooperative society), club
or firm or an association which, whether or
not in the course of business, buys, sells,
supplies goods or distributes goods from or to
its members for cash, or for deferred payment
or for commission, remuneration or other
valuable consideration, shall be deemed to be
a dealer for the purposes of this Act.
(2) The Central Government or a State
Government or a local authority or a statutory
body which whether or not, in the course of
business, buys, sells, supplies or distributes
goods, directly or otherwise, for cash or
deferred payment or for commission,
remuneration or other valuable consideration
shall be deemed to be a dealer for the
purposes of this Act.
(3) In respect of the transfer of the right to
use feature films, the person who transfers
such right to the exhibitor and from whom the
exhibitor derives the right to make such use
shall be deemed to be the dealer under this
clause.
(4) (a) An agriculturist who sells exclusively
agricultural produce grown on land cultivated
by him personally or a person who is
exclusively engaged in poultry farming and
sells the products of such poultry farm shall
not be deemed to be a dealer within the
meaning of this clause;
(b) Where the agriculturist is a company and
is selling pepper, cardamom, rubber, timber,
wood, raw cashew or coffee grown on land
cultivated by it personally, directly or
otherwise, such company, shall be deemed to
be a dealer in respect of turnovers relating to
sales of such produce.
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(34) 'Taxable turnover' means the turnover on
which a dealer shall be liable to pay tax as determined
after making such deductions from his total turnover
and in such manner as may be prescribed, but shall
not include the turnover of purchase or sale in the
course of inter-State trade or commerce or in the
course of export of the goods out of the territory of
India or in the course of import of the goods into the
territory of India and the value of goods transferred or
despatched outside the State otherwise than by way
of sale;
(35) 'Total turnover' means the aggregate turnover
in all goods of a dealer at all places of business in the
State, whether or not the whole or any portion of such
turnover is liable to tax, including the turnover of
purchase or sale in the course of inter-State trade or
commerce or in the course of export of the goods out
of the territory of India or in the course of import of
the goods into the territory of India and the value of
goods transferred or despatched outside the State
otherwise than by way of sale;
(36) 'Turnover' means the aggregate amount for
which goods are sold or distributed or delivered or
otherwise disposed of in any of the ways referred to in
clause (29) by a dealer, either directly or through
another, on his own account or on account of others,
whether for cash or for deferred payment or other
valuable consideration, and includes the aggregate
amount for which goods are purchased from a person
not registered under the Act and the value of goods
transferred or despatched outside the State otherwise
than by way of sale, and subject to such conditions
and restrictions as may be prescribed the amount for
which goods are sold shall include any sums charged
for anything done by the dealer in respect of the
goods sold at the time of or before the delivery
thereof;
4. Liability to tax and rates thereof.-
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(1) Every dealer who is or is required to be
registered as specified in Sections 22 and 24,
shall be liable to pay tax, on his taxable
turnover.--
(a) in respect of goods mentioned in,-
(i) Second Schedule, at the rate of one per
cent,
(ii) Third Schedule, at the rate of five per
cent, and;
(iii) Fourth Schedule, at the rate of twenty per
cent.
[(b) in respect of.-
(i) declared goods as specified in Section 14 of
the Central Sales Tax Act, 1956 (Central Act
74 of 1956) at the maximum rate specified for
such goods under Section 15 of the said Act;
(ii) cigarettes, cigars, gutkha and other
manufactured tobacco at the rate of [twenty
percent];
(iii) other goods at the rate of [fourteen and
one half per cent.]."
12. Section 4 of the KVAT Act imposes a liability to pay
tax on the taxable turnover of every dealer who is, or is
required to be, registered. Section 4 is, therefore, attracted
only in respect of a registered dealer or a dealer required to be
registered. The term "dealer," as defined in Section 2(12),
means any person who carries on the business of buying,
selling, supplying, or distributing goods, directly or indirectly,
whether for cash, deferred payment, commission,
remuneration, or any other valuable consideration.
13. Section 2(6) of the KVAT Act defines "business" to
include any trade, commerce, manufacture, or any adventure
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or concern of a similar nature, whether or not such trade,
commerce, manufacture, adventure, or concern is carried on in
furtherance of gain or profit, and whether or not any gain or
profit accrues therefrom, as well as any transaction in
connection with, or incidental or ancillary to, such trade,
commerce, manufacture, adventure, or concern.
14. The moot question that arises for consideration is
whether the respondent-University is engaged in "business"
and whether the printing and sale of prospectus can be
regarded as incidental or ancillary to such business.
15. From the material placed before this Court, it is
evident that the respondent-University was established and is
engaged in the primary object of imparting education. The
prospectus contains various details regarding the nature of the
courses and services to be provided by the University to its
students. It is further noted that the respondent-University
receives grant-in-aid from the State. The printing of prospectus
is undertaken solely in furtherance of the main object of
imparting education and is, therefore, incidental. When viewed
in conjunction with the principal object of the University, the
sale of prospectus and any surplus arising therefrom cannot be
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characterized as "business." The submission of the University
that the fee charged for the prospectus covers not only the cost
of printing but also other services such as application
processing, evaluation of eligibility, registration, and admission
cannot be rejected without consideration. The State has not
placed any material to suggest otherwise. Moreover, the
printing and sale of prospectus occurs only at the
commencement of the academic year and, therefore, cannot be
regarded as an activity marked by volume, frequency,
continuity, or regularity. The sale of prospectus is an integral
part of the educational process, and it bears no characteristics
of a commercial objective that would classify it as business,
commerce, trade, or any analogous activity.
16. The appellant-State has placed extensive reliance
on the judgment of this Court in Manipal University (supra).
In the cited case, the assessee/dealer was engaged both in the
imparting of education and in the printing and sale of
prospectus. This Court, after noting that the University in that
case was registered as a dealer under the Act, observed that
the University collected substantial amounts each year from the
sale of prospectus. The volume, frequency, continuity, and
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regularity of these transactions indicated engagement in
business with a profit motive. Having regard to the accounts
placed on record, this Court held that Manipal University had
earned profits and that its activities fell within the ambit of
"business." Consequently, the University was rightly required to
be registered as a dealer, and the sale of prospectus was held
to be taxable.
17. However, in the present case, the factual situation
is distinguishable. The printing and sale of prospectus is purely
incidental to the imparting of education and is not carried out
with any intention to conduct business profit. It cannot be held
that the respondent-University, which was established with the
primary object of imparting education to school dropouts, is
engaged in business with a commercial intention. In the
absence of complete accounts, the price at which the
prospectus are sold cannot, by itself, be determinative of
whether the activities of the respondent-University constitute
business or a commercial activity.
18. It is relevant to extract the pertinent paragraphs
from Manipal University (supra), which are as follows:
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12. Section 2(12) defines 'dealer', which means any
person who carries on the business of buying, selling and
supplying or distributing goods, directly or otherwise,
whether for cash or for deferred payment, or for
commission, remuneration or other valuable
consideration and it includes several other categories as
mentioned in this provision. Section 2(34), defines
'taxable turnover' to mean that the turnover on which a
dealer shall be liable to pay tax as determined after
making such deductions from his total turnover, and in
such manner as may be prescribed. 'Total turnover' is
defined by Section 2(35) to mean the aggregate turnover
in all goods of a dealer at all places of business in the
State. Section 2(36) defined 'turnover' to mean the
aggregate amount for which goods are sold or distributed
or delivered or otherwise disposed of in any of the ways
referred to in clause (29) by a dealer. Charging provision
in the KVAT Act is Section 3, which provides that the tax
shall be levied on every sale of goods in the State by a
registered dealer or a dealer liable to be registered under
the provisions of the Act. Section 4 provides that every
dealer who is or is required to be registered shall be liable
to pay tax on his taxable turnover. Section 22 of the Act
speaks about liability to register. Under this provision,
every dealer requires to get himself register if he is falling
within the categories of dealers mentioned therein.
16. We have, as stated earlier, perused the definitions
of 'business' , 'dealer', 'sale', 'taxable turnover' and 'total
turnover'. The definitions of these expressions in the Act
and the Value Added Tax Act of several other States are
similar, in particular Tamil Nadu General Sales Tax Act
and Bombay Sales Tax Act. The Supreme Court in Board
of Trustees of the Port of Madras [1999] 114 STC 520
9SC0, had an occasion to deal with these definitions and
other relevant provisions of the Tamil Nadu General Sales
Tax Act. In this judgment, the Supreme Court also
considered the expression "carrying on business" and
observed that whether a person carries on business in a
particular commodity must depend upon volume,
frequency, continuity and regularity of transaction of
purchase and sale in a class of goods and transaction
must ordinarily be entered into with a profit motive,
which may, however, be statutorily excluded. The
question in issue before the Supreme Court was whether
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the Port trust was established by statute to "carry on
business". It would be relevant to reproduce paragraphs
13 and 14 of the report for our purpose. Paras-13 and 14
of the report read thus :
"13. Now the definition of "business" in
Section 2(d) and in most of the sales tax
statutes is an inclusive definition and includes
"trade or business or manufacture, etc.". This
itself shows that the Legislature has
recognized that the word "business" is wider
than the words "trade, commerce or
manufacture, etc.". The word "business"
though extensively used is a word of indefinite
import, in taxing statutes, it is normally used
in the sense of an occupation, a profession-
which occupies time, attention and labour of a
person, normally with a profit-motive and
there must be a course of dealings, either
actually continued or contemplated to be
continued with a profit-motive and not for
sport or pleasure, (State of Andhra Pradesh v.
H. Abdul Bakshi and Bros. [1964] 15 STC 644
(SC); AIR 1965 SC 531). Even if such profit-
motive is statutorily excluded from the
definition of "business" yet the person could
be doing "business".
14. The word "carrying on business" requires
something more than merely selling or buying,
etc. Whether a person "carries on business" in
a particular commodity must depend upon the
volume, frequency, continuity and regularity
of transactions of purchase and sale in a class
of goods and the transactions must ordinarily
be entered into with a profit-motive. [Board of
Revenue v. A.M. Ansari [1976] 38 STC 577
(SC); (1976) 3 SCC 512]. Such profit-motive
may, however, be statutorily excluded from
the definition of "business" but still the person
may be "carrying on business". (emphasis
supplied).
17. The Supreme Court in Sai Publication
Fund [2002] 258 ITR 70 (SC) also considered
the definitions of words 'business, dealer and
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sale'. The question raised in the said case was
whether the Trust-Sai Publication Fund, which
had been set up by some devotees of Sai
Baba of Shirdi for spreading his message,
could be held to be a dealer, in respect of sale
books, booklets, pamphlets, photos, stickers
and other publications containing message of
Sai Baba and the turnover on such publication
could be assessed to sale tax under the
Bombay Sales tax Act. The following
observations made by the Supreme Court in
this case in paragraph-11 are relevant for our
purpose, which read thus (page 295 in 126
STC) :
"No doubt, the definition of "business" given
in section 2(5A) of the Act even without profit-
motive is wide enough to include any trade,
commerce or manufacture or any adventure
or concern in the nature of trade, commerce
or manufacture and any transaction in
connection with or incidental or ancillary to
the commencement or closure of such trade,
commerce, manufacture, adventure or
concern. If the main activity is not business,
then any transaction incidental or ancillary
would not normally amount to "business"
unless an independent intention to carry on
"business" in the incidental or ancillary activity
is established. In such cases the onus of proof
of an independent intention to carry on
"business" connected with or incidental or
ancillary sales will rest on the department.
Thus, if the main activity of a person is not
trade, commerce, etc., ordinarily incidental or
ancillary activity may not come within the
meaning of "business. To put it differently, the
inclusion of incidental or ancillary activity in
the definition of "business" pre-supposes the
existence of trade, commerce, etc., The
definition of "dealer" contained in Section
2(11) of the Act clearly indicates that in order
to hold a person to be a "dealer", he must
"carry on business" and then only he may also
be deemed to be carrying on business in
respect of transaction incidental or ancillary
thereto. We have stated above that a main
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and dominant activity of the Trust in
furtherance of its object is to spread
message." (emphasis supplied).
18. In that case (Sai Publication Fund
[2002] 126 STC 288 (SC)); [2002] 258 ITR 70
(SC)), the object of the assessee-trust was to
spread message of Sai Baba of Shirdi and it
was not in dispute that the books and the
literature containing message of Sai Baba
were distributed by the trust to the devotees
of the trust "at cost price". In view of the facts
before the Supreme Court, it was observed
that it cannot be said that the trust carried on
the business of selling and supplying goods so
as to fall within the meaning of dealer under
Section 2(11) of the Bombay Sales Tax Act.
19. The Supreme court in A.M.Ansari
[1976] 38 STC 577 (SC); (1976) 3 SCC 512
also had an occasion to deal with the very
same words/phrases. The observations made
by the Supreme Court in the said report are
relevant for our purpose which read thus
(page 585 in 38 STC):
"...whether a person carries on business in a
particular commodity must depend upon the
volume, frequency, continuity and regularity
of transactions of purchase and sale in a class
of goods and the transactions must ordinarily
be entered into with a profit-motive. The court
further went on to observe that when a
subsidiary product is turned out in the factory
of the assessee regularly and continuously and
it is being sold from time to time, an intention
to carry on business in such product may be
reasonably attributed to the assessee. As the
consideration of profit-motive cannot be
regarded as an essential constituent of the
term 'business' in view of the amendment
introduced in the definition of the term 'dealer'
in 1966, what we are left to consider is
whether the other ingredients of the term
"business", viz., volume, frequency, continuity
and regularity of transactions of sale and
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purchase are satisfied in the instant cases..."
(emphasis supplied).
21. It is well-settled that if the main activity
is not business, then the connected, incidental
or ancillary activities of sales would not
normally amount to business unless an
independent intention to conduct business in
these connected, incidental or ancillary
activities is established by the revenue. (See
Board of Trustees of the Port of Madras [1999]
114 STC 520 (SC)). In such cases the onus of
proof of an independent intention to "carry on
`business" connected with or incidental or
ancillary sales would rests on the department.
It is therefore necessary to find out whether
the department has shifted the burden or that
they have established an independent
intention to conduct business in the
connected, incidental or ancillary activity of
sale of prospectus with application form.
19. The Coordinate Bench of this Court in Manipal
University (supra), after prescribing the test as set out in
paragraph 21 and examining the facts, observed that the
University collected substantial amounts from the sale of
prospectus, with volume, frequency, continuity, and regularity
of transactions. The Court further held that the University had
earned profits with a commercial motive, and that its activities,
therefore, fell within the ambit of "business." Consequently, by
virtue of such commercial activity, the University was required
to register as a dealer under the KVAT Act.
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20. If the facts of the present case are tested against
the principles laid down in Manipal University (supra), it is
evident that the respondent-University is not registered as a
dealer. The finding of profit by the Assessing Authority has no
reference to the books of accounts maintained by the
University. The Assessing Authority, relying solely on the cost
of the prospectus, concluded the existence of a profit motive
and the commercial nature of the activity. No contrary material
has been placed on record to disprove the University's
contention that the cost of the prospectus includes charges for
other services, namely printing, processing of applications,
evaluation of eligibility, registration, and admission of students.
21. The finding of the Assessing Authority, the First
Appellate Authority, as well as the Tribunal, that the sale of
prospectus attracts tax under the KVAT Act, is without any
basis and is founded on mere presumption. Both the Tribunal
and the First Appellate Authority committed an error in holding,
based on Manipal University (supra), that the sale of
prospectus is taxable under the KVAT Act, without a proper
examination of the principles laid down by this Court in that
judgment.
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22. The reliance placed on the judgment of the Delhi
High Court in Amway India Enterprises Private Ltd.
(supra), to contend that a person claiming exemption must
establish that the products squarely fall within the category of
exempted goods, is not applicable to the facts of the present
case. The Coordinate Bench of this Court in Manipal
University (supra), at paragraph 21, categorically held that if
the main activity is not business, then the connected,
incidental, or ancillary activities, such as sales, would not
ordinarily amount to business unless the revenue establishes
an independent intention to carry on business in such
connected, incidental, or ancillary activities. In such cases, the
onus to prove an independent intention to carry on business in
connection with, or incidental to, the sales rests upon the
Department. It is, therefore, necessary to ascertain whether
the Department has shifted this burden or has established an
independent intention to conduct business through the
connected, incidental, or ancillary activity of selling prospectus
with application forms.
23. In light of the above observations of the Coordinate
Bench, we hold that the Revenue-State has failed to establish
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that the University had an independent intention to conduct
business through these connected, incidental, or ancillary
activities. Consequently, the burden always remained on the
Revenue to prove that the University carried on business in
such activities. This burden has not been discharged by the
appellant-State, which relies solely on the contention that the
prospectus were sold at a higher price. The mere sale of
prospectus at a higher price, without considering the
University's explanation that the fee charged is composite in
nature, cannot satisfy the requirement set out in paragraph 21
of Manipal University (supra).
24. Once we hold that the respondent-University is not
a dealer and is not required to be registered as a dealer under
the KVAT Act, it necessarily follows that the University is not
required to file returns and has no taxable turnover. In that
event, the issue regarding interest and penalty becomes wholly
academic.
25. The substantial questions of law raised in STRP No.
37 of 2025 are answered in favour of the appellant-University
and against the respondent-State. In view of the answers
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rendered in STRP No. 37 of 2025, the substantial questions of
law raised in STRP No. 36 of 2025 are rendered academic.
26. Accordingly, both Sales Tax Revision Petitions are
disposed of.
27. The order of the Karnataka Appellate Tribunal,
Bengaluru, in STA Nos.233 to 238 of 2015, dated 02.02.2024,
for the assessment periods 2007-08 to 2012-13, the re-
assessment orders dated 26.05.2014, 08.08.2014, and
25.08.2014, along with the consequential demand and recovery
notices, are hereby set aside.
No order as to costs.
Sd/-
(S.G.PANDIT)
JUDGE
Sd/-
(K. V. ARAVIND)
JUDGE
DDU
