Kerala High Court
M/S.N K Trading Company vs State Of Kerala on 22 October, 2024
Author: A.K.Jayasankaran Nambiar
Bench: A.K.Jayasankaran Nambiar
2024:KER:78170
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE DR. JUSTICE A.K.JAYASANKARAN NAMBIAR
&
THE HONOURABLE MR. JUSTICE SYAM KUMAR V.M.
TUESDAY, THE 22ND DAY OF OCTOBER 2024/30TH ASWINA, 1946
O.T.REV.NO.14 OF 2023
AGAINST THE ORDER DATED 28.11.2022 IN TA(VAT).NO.73 & 74 OF 2020
OF THE KERALA VALUE ADDED TAX AGRICULTURAL INCOME TAX & SALES
TAX APPELLATE TRIBUNAL, THIRUVANANTHAPURAM
REVISION PETITIONER/APPELLANT/ASSESSEE:
M/S.N.K. TRADING COMPANY,
KALLUVATHUKKAL, KOLLAM, PIN - 691578
REPRESENTED BY ITS MANAGING PARTNER V.SATHEESAN,
BY ADV.SMT.M.K.HAJARA
BY ADV.SRI.IZZUDIN K.M.
RESPONDENT/REVENUE/RESPONDENTS:
STATE OF KERALA,
REPRESENTED BY SECRETARY TO GOVERNMENT,
TAXES DEPARTMENT,GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001
BY SRI.MOHAMMED RAFIQ, SPL. GOVERNMENT PLEADER (TAXES)
THIS OTHER TAX REVISION (VAT) HAVING BEEN FINALLY
HEARD ON 08.10.2024, THE COURT ON 22.10.2024 DELIVERED THE
FOLLOWING:
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'C.R.'
ORDER
Dr. A.K. Jayasankaran Nambiar, J.
This Revision Petition pertains to the assessment year 2011-12
under the Kerala Value Added Tax Act [hereinafter referred to as the
"KVAT Act"], and the petitioner is aggrieved by the order dated
28.11.2022 of the Kerala Value Added Tax Appellate Tribunal in T.A.
(VAT).No.73 of 2020 that decided issues including the issue of
limitation against the petitioner. In the Revision Petition before us,
the following questions of law are raised:
(i) Whether the Appellate Tribunal is justified in law on the
finding that the plea of rejection of limitation on the
assessment proceedings which was made for the year 2011-
12 on 09.07.2018 is in order.
(ii) Whether on the facts and in the circumstances of the case,
the Appellate Tribunal is erred in not appreciating the fact
that the claim of sales return in the case of end customers is
supported by statements as prescribed under rule 59 of the
KVAT Rules 2005 which are produced before the assessing
authority.
(iii) Whether on the facts and in the circumstances of the case,
the Appellate Tribunal went wrong in interpreting section
25AA with respect to the suppression of sales turnover and
allowing corresponding claim of input tax claim from the
purchase of registered dealers.
(iv) Whether on the facts and in the circumstances of the case,
the Appellate Tribunal is erred in not considering the
duplication of assessment of sales return while calculating
the turnover as well as in the computation of tax due.
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During the course of the proceedings, it was accepted by the learned
counsel that questions of law nos.(ii), (iii) and (iv) would have to be
answered against the petitioner/assessee and in favour of the
Revenue. However, the answer to question (i) above would determine
whether or not the petitioner would be liable to pay any amount to
the Department for the assessment year 2011-12. This is because if
we find in favour of the petitioner/assessee on the question of
limitation, then the entire demand for the said assessment year,
which include the demands relating to the issues covered by
questions (ii), (iii) and (iv), would have to be set aside.
2. The self assessment by the petitioner/assessee for the
assessment year 2011-12 was sought to be re-opened by the
Assessing Authority in terms of Section 25(1) of the KVAT Act by a
notice dated 24.01.2018. As per the provisions of Section 25(1) of
the KVAT Act as it stood then, the Assessing Authority had time only
upto 31.03.2017 to issue the notice for assessment of escaped
turnover, and in this case, the notice was issued only on 24.01.2018.
The Assessing Authority however proceeded to complete the
assessment in relation to the petitioner for the said assessment year
by passing an order dated 09.07.2018.
3. In appeal proceedings pursued by the petitioner/assessee,
initially before the First Appellate Authority and thereafter before the
Appellate Tribunal, although the petitioner raised a contention
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regarding limitation, the same was rejected by the authorities. It is
therefore that the petitioner is before us in this O.T. Revision
impugning the order of the Appellate Tribunal inter alia on the issue
of limitation.
4. Inasmuch as we are concerned with the provisions of
Section 25(1) of the KVAT Act, as it stood with effect from
01.04.2017, we deem it appropriate to extract the provisions of
Section 25(1) of the KVAT Act as it stood immediately prior to its
amendment with effect from 01.04.2017:
"25. Assessment of escaped turnover:- (1) Where for any
reason the whole or any part of the turnover of business of a dealer
has escaped assessment to tax in any year or return period or has
been under-assessed or has been assessed at a rate lower than the
rate at which it is assessable or any deduction has been wrongly made
therefrom, or where any input tax or special rebate credit has been
wrongly availed of, the assessing authority may, at any time within five
years from the last date of the year to which the return relates,
proceed to determine, to the best of its judgment,the turnover which
has escaped assessment to tax or has been underassessed or has been
assessed at a rate lower than the rate at which it is assessable or the
deduction in respect of which has been wrongly made or input tax or
special rebate credit that has been wrongly availed of and assess the
tax payable on such turn over or disallow the input tax or special
rebate credit wrongly availed of, after issuing a notice on the dealer
and after making such enquiry as it may consider necessary:
Provided that before making an assessment under this
subsection the dealer shall be given a reasonable opportunity of being
heard.
Provided further that where the escapement is due to the
application of incorrect rate of tax, no assessment under this sub-
section shall be made where the dealer files revised return and pays
the tax which has escaped assessment along with interest under sub-
section (5) of section 31 and thrice the interest as settlement fee.
Provided also that the period for the completion of
assessments including those subjected to extension under section 25B
which expired on 31st March, 2015, shall be extended up to 31 st
March, 2016.
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5. The provision was amended through the Kerala Finance Act,
2017 with effect from 01.04.2017 when the period of limitation under
Section 25(1) for proceeding to determine the escaped turnover was
changed from "five years" to "six years from the end of the year to
which the assessment relates" and the third proviso thereto was
amended to read as follows:
"Provided also that the period for proceeding to determine any
assessment including those subjected to extension under section 25B
which expires on 31st March, 2017, shall be extended up to 31 st March,
2018."
6. It is now well settled through a line of decisions of this
Court as affirmed by the Supreme Court that inasmuch as the
amendment to Section 25(1) was expressly made effective only from
01.04.2017, the period for re-opening assessments under Section
25(1) of the KVAT Act have to be seen as enlarged from five years to
six years only with effect from that date, and accordingly, the
provisions of Section 25(1), save the 3rd proviso thereto, have to be
construed as having only a prospective operation [Commercial Tax
Officer, Anchal and Others v. S. Najeem and Another - [2018
(3) KLT 877 (DB)]].
7. As regards the effect of the amendment brought about to
the 3rd proviso to Section 25(1) of the KVAT Act, which too was
amended with effect from 01.04.2017, one among us [Dr. Justice A.K.
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Jayasankaran Nambiar] had, in the decision in Baiju v. State Tax
Officer - [2020 (1) KLT 233], that followed earlier Division Bench
judgments of this Court in Binu Gopinath v. State of Kerala -
[2018 (2) KLT 991] and Paul Varghese v. State of Kerala -
[(2005) 13 KTR 29 (Kerala)] found that the purpose of the
amendment to the 3rd proviso to Section 25(1) of the KVAT Act was
only to extend the time for re-opening those assessments where the
period of limitation for re-opening under the unamended provisions
was to expire by 31.03.2017. The object of the amendment was to
permit a re-opening of such cases till 31.03.2018. The amendment
had to be viewed in the backdrop of the introduction of the new
regime of GST in the State with effect from 22.06.2017, on which
date the KVAT Act was repealed by the State legislature. It was
opined that the circumstances under which the amendment was
carried out clearly brought out the intention of the legislature to
permit a re-opening of past assessments under the KVAT Act up to
31.03.2018 and it was this intention that had to be read into the third
proviso to Section 25(1), as amended with effect from 01.04.2017, so
as to give it full effect. The argument of counsel, placing reliance on
the principles of statutory interpretation was separately dealt with as
follows:
"16. Before parting with the issues, I must also address the
arguments of learned counsel for the petitioners that, going by the
well-settled principles of statutory interpretation, a proviso cannot
enlarge the scope of the main provision to which it is appended.
The contention is essentially that, inasmuch as the provisions of
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Section 25(1) of the KVAT Act enlarged the period for re-opening
assessments from five years to six years only with effect from
01.04.2017, the third proviso could not be seen as permitting a re-
opening of past assessments beyond the five-year period of
limitation prescribed under the unamended Act. The legal position
with regard to the principles that must guide an interpretation of a
proviso have been pithily stated in the decision of the Supreme
Court in S.Sundaram Pillai & Ors. v. V.R.Pattabiraman & Ors.
- [(1985) 1 SCC 591] as follows:
"A proviso may serve four different purposes:
1. Qualifying or excepting certain provisions from
the main enactment;
2. It may entirely change the very concept of the
intendment of the main enactment by insisting on certain
mandatory conditions to be fulfilled in order to make the
enactment workable;
3. It may be so embedded in the Act itself as to
become an integral part of the enactment and thus
acquire the tenor and colour of the substantive
enactment itself; and
4. It may be used merely to act as an optional
addendum to the enactment with the sole object of
explaining the real intendment of the statutory
provision."
17. In the instant cases, as already noticed above, while
the main part of Section 25(1) clearly indicates that the
extended period of six years for re-opening assessments is to
operate prospectively with effect from 01.04.2017, the third
proviso seeks to carve out those assessments, where the period
of re-opening would have expired by 31.03.2017, for a
differential treatment, by stating that in such cases, the
re-opening could be carried out before 31.03.2018. To treat the
said proviso as having only prospective effect would render
meaningless the words used by the legislature in the said
proviso and accord to it the same meaning as the main
provision. Going by the tests enumerated in Sundaram Pillai
(Supra), the third proviso to Section 25(1), as amended with
effect from 01.04.2017, has to be seen as qualifying the ambit
of the main enactment with the object of explaining the real
intendment of the statutory exercise."
8. The decision in Baiju (supra) was subsequently affirmed by
the Division Bench in appeal and it is our understanding that the
matter was not carried further by the State. While so, we have now
been shown a judgment of the Supreme Court in Assistant
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Commissioner (Assessment) v. M/s. Cholayil Pvt. Ltd. - [2023
KHC Online 7078], where, while considering an argument by the
State Government that the amended provisions of Section 25(1) and
the 3rd proviso thereto would have the effect of enabling the State to
assess the escaped turnover in relation to those years for which the
period of limitation prescribed under the erstwhile provisions of
Section 25(1) had already expired, the court considered the
amendments that were introduced to Section 25(1) and to the 3 rd
proviso thereto with effect from 01.04.2017 and held as follows at
paragraphs 15, 17 and 18:
"15. In this context, what has to be interpreted is the expression
"proceed to determine" as it occurs in sub-Section (1) of Section 25 as
well as the third proviso to the said sub-Section as amended in Finance
Act, 2017. No doubt, in both the provisions, the expression used is
"proceed to determine." The said expression must be considered in light
of the words that occur prior to and subsequent to the said expression.
Under sub-Section (1) of S.25, the intention of the use of the expression
"proceed to determine" is in the context of initiation of proceedings at
any time within five years (now six years after the 2018 amendment) from
the last date of the year to which the return relates. The object and
purpose is that there cannot be a belated initiation of proceedings and at
the whims and fancies of the Department so as to re-open stale returns,
which had already been concluded under the provisions of the said Act.
However, the object of the proviso which also uses the words "proceed to
determine" must be in the context of completion of the Assessment which
had already been initiated in accordance with sub-Section (1) to S.25
within the time-frame as prescribed therein.
17. However, it is now contended on behalf of the appellants by learned
Senior Counsel, Shri Dwivedi, that the object of the proviso was in fact to
extend the time period of one year to "initiate" the proceedings and
hence, the expression 'proceed to determine' in sub-section (1) of S.25 of
KVAT Act as well as the subsequent third proviso of the said section must
be given the same meaning which would according to learned Senior
Counsel mean that the proviso also extends the period of limitation by
one year at a time by way of substitution of the earlier period being made
at every Financial Year under the respective Finance Acts for the
initiation of proceedings of reassessment under S.25 of the Act. We do not
think that such a meaning could be given to the expression 'proceed to
determine' as submitted by learned senior counsel insofar as the third
proviso to sub-section (1) of S.25 is concerned. Firstly, the said expression
is only w.e.f. the Finance Act, 2017 and not for the earlier period as the
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words used in the third proviso for the earlier period is "completion of
assessments" Thus, the period for completion of assessments cannot
mean 'initiation of proceedings.' Although the Legislature may use the
very same expression in different parts of a section or different parts of
an Act it is ultimately to be seen whether the interpretation so placed on
the very same expression would lead to a logical understanding in line
with the object and the intention of the Legislature or lead to an absurdity
or anomaly. If the same expression used in different parts of a Section or
an Act if given the same meaning leads to an anomaly or absurdity then
the only option the Court would have is to give a contextual meaning to
the said expression.
18. Applying the aforesaid principle to the present case, when the
expression "proceed to determine" is given a contextual meaning in the
instant case it would mean that under sub-section (1) of S.25 of the Act,
the couching of the said expression in the context of the limitation period
would only indicate that it is for 'initiation' of the proceeding for
reassessment by issuance of a notice. But the expression 'proceed to
determine' in the third proviso to sub-section (1) of S.25 by amendment
made to the Finance Act is to 'complete' the proceedings initiated under
sub-Section (1) of S.25 within the time-frame indicated in the said proviso
which, as already noted, must be within one year at a time and the entire
third proviso being substituted every successive year under the
respective Finance Acts is with a view to mandate the Department to
complete the re-opened assessment in a timely manner and within the
period stipulated under the said proviso to sub-Section (1) of the S.25 of
the KVAT Act. Therefore, the department is not right in contending that
the expression 'proceed to determine' in the third proviso gives a lease of
life or an extension of the period of limitation by one year at a time for
'initiation' of the reassessment proceeding under sub-section (1) of S.25
of the Act. Such an interpretation would lead to absurdity as a proviso
cannot militate against the intention of the main provision in sub-section
(1) of S.25 and thus a proviso cannot extend the limitation period which is
fixed under the main provision. The normal function of a proviso is to
exempt something out of the provision or to qualify something enacted
therein which, but for the proviso, would be within the purview of the
provision. As a general rule, a proviso is added to an enactment to qualify
or create an exception to what is in the enactment and ordinarily, a
proviso is not interpreted as stating a general rule. In other words, a
proviso qualifies the generality of the main enactment by providing an
exception and taking out, as it were, from the main enactment, a portion
which, but for the proviso, would fall within the main provision. Further, a
proviso cannot be construed as nullifying the provision or as taking away
completely a right conferred by the enactment."
9. In the light of the above findings of the Supreme Court, we
are essentially called upon to decide whether the view taken in Baiju
(supra), which was affirmed by the Division Bench of this Court, has
to be seen as impliedly overruled by the judgment of the Supreme
Court referred above. It is significant that in the case that was
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decided by the Supreme Court, the interpretation of the amended
provisions of Section 25(1) of the KVAT Act and the 3 rd proviso thereto
arose as an incidental issue, since the facts in that case reveal that
the dispute therein arose in the context of the statutory provisions as
they stood prior to the amendment of 2017.
10. We have heard Smt.Hajara M.K., the learned counsel for
the petitioner as also Sri.Mohammed Rafiq, the learned special
Government Pleader (Taxes) for the respondent/State. We have also
gone through the argument note submitted by the learned special
Government Pleader (Taxes).
11. The learned counsel for the petitioner would contend that
in the light of the clear finding of the Supreme Court as regards the
interpretation to be placed on the 3 rd proviso to the amended Section
25(1), the proceedings initiated by the Revenue for assessing
turnover that pertained to the assessment year 2011-12, on
24.01.2018, had to be seen as clearly barred by time. Per contra, it is
the stand of Sri.Mohammed Rafiq, the learned special Government
Pleader (Taxes) that the decision in Cholayil (supra) did not consider
the challenge to the amended provisions of the Statute and therefore
cannot be seen as attributing a different view to the clear words used
in the Statute. He relies on the following decisions to fortify his
contentions regarding the interpretation to be placed on the
provisions of the 3rd proviso to Section 25(1) of the KVAT Act as
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amended in 2017: Ghanshyamdas v. Regional Assistant
Commissioner of Sales Tax, Nagpur and others - [AIR 1964 SC
766]; State of Punjab and Others v. Tara Chand Lajpat Rai -
[(1967) 19 STC 493 (SC)]; Sales Tax Officer and another v.
Messers Sudarsanam Iyengar and Sons - [(1969) 2 SCC 396];
Tirur Medical Stores v. State of Kerala - [(1978) 42 STC 118
(Ker)]; Cholayil Private Limited v. Assistant Commissioner
(Assessment) - [2015 (4) KLT 516 (FB)]; Binu Gopinath v. State
of Kerala - [2018 (2) KLT 991] and Binu Gopinath v. State of
Kerala - [2018:KER:21549].
12. We have considered the rival submissions and have once
again examined the amended provisions of Section 25(1) of the KVAT
Act and the 3rd proviso thereto. Reading the said provisions, in the
light of the judgment of the Supreme Court in Cholayil (supra) above,
we find that there is an aspect that was overlooked earlier when Baiju
(supra) was decided. This is with regard to the different phraseology
that is used in Section 25(1) of the KVAT Act and the 3 rd proviso
thereto. In particular, while the phraseology used in Section 25(1) of
the KVAT Act is "at any time within six years from the last date of the
year to which the return relates, proceed to determine, to the best of
its judgment the turnover which has escaped assessment to tax .......
and assess the tax payable on such turnover ...... after issuing a notice
on the dealer and after making such enquiry as it may considered
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necessary". The phraseology used in the 3rd proviso to Section 25(1)
reads "Provided also that the period for proceeding to determine any
assessment including those subjected to extension under Section 25B
which expires on 31st March, 2017, shall be extended up to 31 st
March, 2018".
13. It will be seen therefore that while the main provision of
Section 25(1) speaks of proceeding to determine the turnover which
has escaped assessment and then to assess the tax payable on such
turnover, the 3rd proviso speaks of proceeding to determine the
assessment itself. We believe that it is taking note of the differential
phraseology used in the main provision of Section 25(1) and the 3 rd
proviso thereto that the Supreme Court in Cholayil (supra) found that
the phraseology 'proceed to determine' has a different meaning when
used in the main provision of Section 25(1) and in the 3 rd proviso
thereto. As observed by the Court in Cholayil (supra), 'proceed to
determine' in the main provision of Section 25(1) has the meaning of
'initiation of proceedings for assessment' whereas the phrase
'proceed to determine and assessment' occurring in the 3 rd proviso
thereto has the meaning of 'completing such assessment'. As a
matter of fact, the 3rd proviso to Section 25(1), as it stood prior to the
amendment in 2017, also spoke of completion of assessment and it is
our understanding that the intention of the Legislature remained
unchanged while carrying out the amendment to the 3 rd proviso to
Section 25(1) of the KVAT Act. We may also notice that the extension
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of time upto 31.03.2018 in the 3rd proviso to Section 25(1) is also
granted to assessments subjected to extension under Section 25B
which would otherwise expire on 31.03.2017. Section 25B is itself a
provision that contemplates the grant of extension of the period of
limitation for completing assessments in certain cases, and enabled
the Deputy Commissioner for good and sufficient reasons to extend
the period of completion of assessments beyond the period specified
in Sections 24 and 25 of the KVAT Act. In our view, when the
provisions of Section 25B, which are expressly mentioned in the 3 rd
proviso to Section 25(1), deal with cases for completion of
assessment, then the reference to the first part of the 3 rd proviso must
also be in relation to completion of assessment. We are of the view
that the extension contemplated under the 3rd proviso in either event
is only for completion of assessments that have already been initiated
in accordance with the main provision of Section 25(1) of the KVAT
Act.
14. We are therefore of the view that on the facts of the instant
case, the notice issued to the petitioner on 24.01.2018 to re-open the
assessments pertaining to the assessment year 2011-12, which had
crossed the erstwhile five year limitation period on 31.03.2017, could
not have been saved by invoking the provisions of the 3 rd proviso to
Section 25(1) as amended with effect from 01.04.2017. The
assessments completed against the petitioner/assessee by the order
dated 09.07.2018 has therefore to be seen as bad in law and barred
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by limitation. We therefore answer question no.(i) in favour of the
assessee and against the Revenue.
The O.T. Revision is thus allowed by setting aside the impugned
order of the Tribunal and answering the question of limitation in
favour of the assessee and against the Revenue.
Sd/-
DR. A.K.JAYASANKARAN NAMBIAR
JUDGE
Sd/-
SYAM KUMAR V.M.
JUDGE
prp/
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APPENDIX OF O.T.REV.NO.14/2023
PETITIONER ANNEXURES:
ANNEXURE A TRUE COPY OF THE AUDITED REPORT DATED
29/12/2012
ANNEXURE B TRUE COPY OF THE PROCEEDINGS - ASSESSMENT
ORDER NO.32020250725/11-12 DATED:
09.07.2018 ISSUED BY THE ASSISTANT
COMMISSIONER (ASSESSMENT) SPECIAL CIRCLE,
KOLLAM
ANNEXURE C TRUE COPY OF THE PROCEEDINGS OF THE DEPUTY
COMMISSIONER (APPEALS) SGST DEPARTMENT,
KOLLAM DATED 26.03.2019
ANNEXURE D CERTIFIED COPY OF THE APPELLATE ORDER
ISSUED BY THE APPELLATE TRIBUNAL ADDL.
BENCH THIRUVANANTHAPURAM IN TA (VAT) NOS.
73/2020 AND 74/2020 DATED: 28.11.2022
ANNEXURE E TRUE COPY OF THE MODIFIED ORDER ISSUED BY
THE ASSISTANT COMMISSIONER(ASSESSMENT)
SPECIAL CIRCLE, KOLLAM VIDE ORDER NO.
32020250725/2011-12 DATED:31.12.2019
ANNEXURE F TRUE COPY OF THE MODIFIED ORDER NO.
32020250725/2011-12 DATED: 13.12.2022
ISSUED BY THE DEPUTY COMMISSIONER (ASSMT.)
SPECIAL CIRCLE, KOLLAM
ANNEXURE G TRUE COPY OF THE REVENUE RECOVERY DEMAND
NOTICE IN FORM NO.1 DATED: 01.12.2019
ANNEXURE H TRUE COPY OF THE REVENUE RECOVERY NOTICE
ISSUED BY REVENUE RECOVERY OFFICE, KOLLAM
DATED: 23.06.2022
ANNEXURE H(i) TRUE COPY OF THE NOTICE D3 937/20(11296/19)
DATED: NIL
ANNEXURE i TRUE COPY OF THE NOTICE OF ATTACHMENT OF
THE ABOVE PROPERTY HAS BEEN ISSUED BY THE
OFFICE OF THE TAHSILDAR (R.R), KOLLAM DATED
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20.10.2022
ANNEXURE j TRUE CO OF THE REVENUE RECOVERY NOTICE
ISSUED BY THE TAHSILDAR (R.R) ,KOLLAM DATED
20.10.2022
ANNEXURE k TRUE COPY OF THE LETTER DATED 17.08.2023
ANNEXURE l TRUE COPY OF THE VALUATION CERTIFICATE AND
PHOTOGRAPH AND LOCATION MAP ISSUED BY THE
EXECUTIVE ENGINEER (RTD.) DATED 14.07.2023
ANNEXURE m TRUE COPY OF THE BUILDING AGE CERTIFICATE
DATED: 18-07-2023
ANNEXURE N TRUE COPY OF LETTER DATED 16.09.2023
ANNEXURE O TRUE COPY OF THE LETTER ISSUED BY THE
SPECIAL DEPUTY COLLECTOR (LA) NHAI, KOLLAM
DATED 21.03.2023
ANNEXURE P TRUE COPY OF LETTER DATED. 16.09.2023
ANNEXURE Q TRUE COPY OF LETTER DATED 20.09.2023
ANNEXURE R TRUE COPY OF CHALAN 2014-15
ANNEXURE S TRUE COPY OF CHALAN 2016-17
ANNEXURE T TRUE COPY OF THE NO DUES CERTIFICATE ISSUED
BY THE STATE BANK OF INDIA DATED:
19.06.2023.
RESPONDENTS ANNEXURES: NIL.
//TRUE COPY//
P.S. TO JUDGE
