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Showing 701 to 720 of 420402 Records
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2024 (11) TMI 922
Classification of services rendered - services rendered by the respondent to their parent company situated in USA is an ‘intermediary service’ or 'export services’ - HELD THAT:- The basic requirement to be an intermediary is that there should be at least three parties; an intermediary is someone who arranges or facilitates the supply of goods or services or securities between two or more persons. There is main supply and the role of the intermediary is to arrange or facilitate another supply between two or more other persons and, does not himself provide the main supply.
The present case is more or less similar to the Illustration 4 of the said Circular dated 20.09.2021 which says 'A' is a manufacturer and supplier of computers based in USA and supplies its goods all over the world. As a part of this supply, 'A' is also required to provide customer care service to its customers to address their queries and complains related to the said supply of computers. 'A' decides to outsource the task of providing customer care services to a BPO firm, 'B'. 'B' provides customer care service to 'A' by interacting with the customers of 'A' and addressing / processing their queries / complains. 'B' charges 'A' for this service. 'B' is involved in supply of main service 'customer care service' to 'A', and therefore, "B' is not an intermediary.
No merit in the appeal filed by the Revenue.
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2024 (11) TMI 921
Demand of Service Tax and penalties - appellant and SAIL appellant has been appointed as the authorized dealer for sale of GP Coils/GP Sheets - whether the activity carried on by the appellant falls under the business auxiliary service as defined in Section 65 (19) of the Finance Act? - whether the appellant can be called Commission Agent rendering business auxiliary service?
HELD THAT:- The goods are purchased from SAIL for which the appellant pays to SAIL on its own account as an owner of the said goods. The appellant is also registered with VAT/Sales Tax during the relevant period and has been paying VAT/Sales Tax. The Transaction between SAIL and the appellant dealer was on principal to principal basis and the discount of 1.5% was an incentive for lifting the specified quantity of 300 MTs per month.
We also find that this issue has been examined by the Tribunal in various cases relied upon by the appellant cited (Supra). We also find that recently the Tribunal of Mumbai, in the case of My Car (Pune) Pvt. Ltd. [2023 (6) TMI 995 - CESTAT MUMBAI] held that Department does not dispute that there was such agreements, scheme between the appellant in the car manufacturers and the account of the appellant only reflect the actual discount allowed to them.
Department's argument is that the said discount/commission is in view of services rendered by the appellant by way of popularisation of the sales and consumption of the products by the end customer. We find it difficult to accept the conclusion arrived at in the impugned order that all the discounts/commission/incentives given by the manufacturer for the various types of targets achieved in terms of the number of vehicles sold under a particular model/category, consistent achievement of targets by each quarter, exchange bonus etc., are to be treated as compensation for the services rendered by the appellants by way of popularization of sales and purchase of the cars of the manufacturer.
The element of sales promotion or marketing services is involved only when the appellants provide some service to the end customer in sale of the cars. If the discounts/commission/incentives are given in terms of the specific schemes or an agreement entered by the manufacturer of car with the appellants, then such transaction cannot be overstretched to categorize it as service for the purpose of charging service tax.
Also assessed respondent is the authorized dealer of car manufactured by MUL and are getting certain incentives in respect of sale target set out by the manufacturer. These targets are as per the circular issued by MUL. Hence these cannot be treated as business auxiliary service.
In respect of sales/target incentive, the Revenue wants to tax this activity under the category of business auxiliary service. We have gone through the circular issued by MUL which provides certain incentives in respect of cars sold by the assessee-respondent. These incentives are in the form of trade discount. In these circumstances, we find no infirmity in the adjudication order whereby the adjudicating authority dropped the demand.
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2024 (11) TMI 920
Clandestine removal - unbranded biris - appellant submitted that they were carrying job work for Samar Biri Factory and the unbranded biri is not full manufactured condition - Non-compliance with N/N. 214/86-CE. - HELD THAT:- The factual documentary evidence prove that the Samsuddin Ahmed was undertaking the job work of semi-finished Biri making which was not in a fully manufactured and marketable condition. Hence, the same cannot be treated as finished goods for demanding the Excise Duty. Further, as per the verification report given by the Assistant Commissioner, Siliguri, Samar Biri factory has for the receipt of semifinished biris and has carried out certain more work and have paid the applicable excise duty and the same have been cleared from their end. Therefore, there are no justification in the seizure, confiscation and imposition of Redemption Fine on 297 bangs of unbranded biris.
Thus, non following of the procedure under Notification No. 214/86-CE on its own cannot be the ground for demanding the duty from the appellant particularly when it is getting clarified that the principal has paid the Excise Duty at his end. However the appellant and principal should have been followed the procedure and given proper intimation to the respective jurisdiction which has not been done in this case. For such procedural lapse, the appellant is required to be imposed penalty. Accordingly, taking over all view of the factual details of the case, the penalty imposed on Samsuddin Ahmed modified to Rs. 10,000/- and Rs. 25,000/- on Samar Biri Factory.
Appeal disposed off.
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2024 (11) TMI 919
CENVAT Credit - input services - service tax paid on GTA services which were utilized for movement of manufactured goods from the factory to the customer’s premises for delivery of the goods at customer’s place - HELD THAT:- It is undisputed fact that the appellant is under contract for delivery of the goods on FOR destination at the customer’s premises and the goods remained in the ownership of the appellant till the goods reached customer’s premises and that the sale takes place at the customer’s premises and the property or ownership of the goods is transferred to the customer at the customer’s premises. It is settled law that cenvat credit of service tax paid on transportation of goods till the place of removal is admissible to a manufacturer. Now it is to be decided in the present case as to whether customer’s premises is place of removal.
It is noted that in the case of Roofit Industries Ltd. [2015 (4) TMI 857 - SUPREME COURT], Hon’ble Supreme Court has held that the charges which are to be added for arriving at the value of the excisable goods will have to be put up to the stage of the transfer of the ownership of the goods from the manufacturer to the buyer. In para 13 of the said order, it was observed that in that case the sale of goods did not take place at the factory gate of the assessee, but at the place of the buyer on the delivery of the goods.
In the present case the fact on record is that the ownership of the goods remained with the appellant till such time the goods were delivered at the buyer’s premises. Therefore, in the present case the place of removal is buyer’s premises. It is settled law that input service credit is admissible upto the place of removal. Therefore, in the present case the appellant was eligible for the said cenvat credit.
The impugned order is set aside - appeal allowed.
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2024 (11) TMI 918
Seeking quashing of the Criminal Complaint - time limitation - it is contended that the subject complaint is time barred and filed beyond the stipulated time period provided under Section 142(b) of the NI Act - when did the limitation commence for filing the complaint and whether the time spent in pursuing the first complaint filed before the court in Gurugram could be excluded? - HELD THAT:- The primary accused being the company on whose behalf the subject cheques were issued, concededly, was served with a demand notice through email on 11.03.2022 itself. There is no averment from either side that the said email bounced back. The other two accused are the Directors in the accused company. A plain reading of Section 141 NI Act reveals that there is no requirement of serving each Director separately. The notice envisaged under Section 138 NI Act is required to be given to the drawer of the cheque i.e. the accused company in the present case to make good the sum payable under the cheque. A company being a juristic entity is run by living persons who are in charge of its affairs and who guide the actions of that Company and that if such juristic entity is guilty, those who were so responsible for its affairs and who guided actions of such juristic entity must be held responsible and ought to be proceeded against.
Curiously in the present case, while the accused persons are claiming that the service of demand notice on the accused company be considered as service on its Directors as well, the complainant is contending otherwise - this Court has no hesitation to hold that the service of demand notice to the accused company on 11.03.2022 is effective service on petitioner No.2 as well - there is no dispute that petitioner No.3 was also served on 11.03.2022 itself through email.
Once it is held that service of demand notice on the company would be considered as a service on the other petitioners, the next issue as to what would be the starting period of limitation for filing complaint is simple calculation.
Indisputably, the said complaint was not accompanied with any application for condonation of delay. In reply of the petitioners‟ application seeking discharge, the complainant for the first time mentioned the factum of filing of complaint in court at Gurugram and its withdrawal. The said reply was filed on 31.03.2023. However, on date of taking cognizance on 02.08.2022, no such material was available before the trial court. The complaint being filed on 28.04.2022 without offering any explanation of delay or seeking its condonation was filed beyond the period of limitation and not maintainable.
The criminal complaint is quashed and the order taking cognizance is set aside - Petition allowed.
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2024 (11) TMI 917
Correct head of income - True character of the income - Income from leasing or letting out the properties in shopping-cum-entertainment Mall - “income from business” or “income from house property” - ITAT held that where the letting out the property is the main object of a company, its income is to be computed under the head “income from business” and it cannot be treated as “income from house property”, affirmed the order passed by the CIT (A)
As decided in HC [2024 (4) TMI 753 - MADHYA PRADESH HIGH COURT] order passed by A.O. nowhere shows that the entire income or substantial income of the assessee was from letting out of the properties, which is admittedly not the principal business activity of the assessee. Therefore, we do not find any perversity in the findings recorded by the ITAT as well as the CIT (A)
HELD THAT:- Having heard the learned Additional Solicitor General appearing for the petitioner and having gone through the materials on record, we see no reason to interfere with the impugned order passed by the High Court of Madhya Pradesh at Indore.
Special Leave Petition is, accordingly, dismissed.
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2024 (11) TMI 916
Denial of foreign tax credit (‘FTC’) on tax paid on foreign income in Sri Lanka - non-filing of Form 67 at the time of filing of original return - procedural v/s mandatory provision - HELD THAT:- Article 23 of the India-Sri Lanka DTAA mandates that reliefs should be provided to avoid double taxation and FTCs should be granted when tax is paid in both the countries. Denying of FTC due to procedural delay in filing Form 67 goes against the DTAA’s objectives.
Section 90 allows relief in cases of double taxation. Although Rule 128(9) requires Form 67, the assessee’s compliance within this rule during the rectification stage demonstrated a good faith or effort to fulfil procedural requirement.
Hon’ble Courts and Tribunal has often held that procedural delay should not be hindered substantive relief when the claimant has made all other substantive requirement.
As the assessee fulfils the substantive requirement of paying taxes in Sri Lanka and subsequently claimed FTC as per DTAA u/s 90 of the Act and filing of the Form 67 during rectification process suffices as a procedural compliance to the claim of FTC. Moreover, the objective of the Article 23 of the DTAA and section 90 to mitigate double taxation which should not be compromised by procedural technicalities when substantive compliance is evident. We find that the assessee is entitled to FTC on foreign tax paid. Appeal of the assessee is allowed.
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2024 (11) TMI 915
Revision u/s 263 - unexplained income u/s. 69A r.w.s. 115BBE - whether the seized cash shown by the assessee under the head ‘income from other sources’ will be treated as unexplained income u/s. 69A r.w.s. 115BBE of the Act or not? - HELD THAT:- On perusal of section 263, it is abundantly clear that for invoking section 263 of the Act, the order of the Ld.AO should be erroneous and should be prejudicial to the interest of revenue.
As per Expln.2(a) of section 263 of the Act, any order shall be deemed to be erroneous in so far as it is prejudicial to the interest of revenue, if the order is passed without making enquiry or verification which should had been made.
In the instant case, as submitted by DR the claim of the assessee was not supported by any contemporaneous demonstrable evidences. Assessee did not provide the list of persons from whom he received the income and to whom he provided the services.
AO failed to verify the same. Therefore we are of the considered view that, there was failure on the part of the AO to make necessary enquiry / verification, hence the order of the Ld. AO is erroneous in so far as it is prejudicial to the interest of revenue. Therefore, in our opinion the invocation of section 263 by the PCIT(C) is as per law. Accordingly, we dismiss this ground of appeal of the assessee.
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2024 (11) TMI 914
Reopening of assessment u/s 147 - assessee claimed to be not engaged in any business activities and had purchased two residential properties - Disallowance of deduction u/s 54F - assessee had claimed deduction in respect of capital gains against the entire sale consideration for purchase of properties during the year and the AO was not satisfied with the purchases of two properties and held that benefit of section 54Fcan be given in respect of “a residential house”, which means ‘one residential house’ therefore, capital gain was recalculated and addition - HELD THAT:- On the basis of admitted facts it comes up that investment was made in two floors of the same building which assessee was using for residence. This aspect that the two floors of the same building were purchased from the same seller is not disputed.
Interpretation of "a residential house" u/s 54F - AO has allowed relief only in respect of one floor and before us several decisions have been referred to by learned AR wherein it is settled that the expression “a residential house” in section 54F(1) has to be understood in the sense that the building should be of residential nature and “a” should not be understood to indicate a singular number. Thus, even in case of purchases of two residential flats assessee is entitled to exemption u/s 54F. Thus, we are inclined to sustain ground no. 1 in favour of the assessee.
Addition of cash deposit - We find that during assessment proceedings the assessee had filed an affidavit, wherein it was deposed that during financial year relevant to the present assessment year assessee was not involved in any business activity. We find that without any piece of evidence to the contrary the AO has inferred on the basis of cash/credit entries in the bank account that assessee must have been engaged in business activities and such approach itself is not justified for making the addition.
AO discarding the claim of assessee that he was not engaged in any business activity - We find that AO has taken into consideration the credit of the cheque disowned of Rs. 5,72,500/- as business receipts; cash receipt of Rs. 19,37,500/- on sale of property as established by the copy of sale-deed, available at pages 66 of the paper book. There were receipt of Rs. 35,50,000/- by the assessee from his real brother through banking channel as a share of the compensation received on acquisition of ancestral rural agricultural land; and assessee himself had received Rs. 14,02,500/- from the Government of U.P. on the acquisition of ancestral rural agricultural land. Learned AR has also established that certain credit entries of Rs. 44,00,000/- which AO has treated as business receipts were counter entries of repayment of loan given/ debit in bank account during the same financial year from various persons.
AO has extended too far his jurisdiction of reassessment to examine the cash deposits and treating it as business receipts, without any effective enquiry from the assessee. Assessee appeal allowed.
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2024 (11) TMI 913
Bogus purchases - estimation of profit - AR submitted that the assessee has made purchases after due verification of the bonafides of the GST Registration of the impugned two suppliers - HELD THAT:- Where the related sales were accepted, the amount of bogus purchases in its entirety cannot be added to the returned income and only certain percentage of profit embedded in such tainted purchases is to be added as additional income and further, the estimation of profit is over and above the profit already declared by the assessee in the return of income, we feel appropriate to arrive at the profit margin of 10% on the bogus purchases and thus, addition to the extent/partly is deleted. Thus, appeal of the Revenue is dismissed.
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2024 (11) TMI 912
Challenge to notice issued u/s 65 of the Maharashtra Goods and Services Tax Act, 2017 (SGST Act) in Form No. GST ADT-01 read with Rule 101 of the Goods and Services Tax Rules, 2017 (GST Rules) by which the respondents seek to conduct an audit for the financial year 2020-21 - whether the provisions of Section 65 of the SGST Act dealing with audit would apply to a person who was registered under the CGST Act for the period for which an audit is ordered but who ceases to be registered on the date the audit is ordered? - HELD THAT:- In the instant case, the preliminary findings of the audit as per its report dated 11 October 2024 is that the petitioner has claimed an excess input tax credit of Rs.3,60,44,378/- which is ineligible under the provisions of the Act. Furthermore, there is also a prima-facie finding that in the absence of proper documentation reversal of input tax credit (Rs.10,36,950/- + Rs.1,17,75,353/- + Rs.1,17,75,353/-) amounting to Rs.2,45,87,656/- is not in accordance with the law. Preliminary audit reports also suggest short disclosure of other income, resulting in the short payment of tax. The preliminary audit report prima facie has found a total tax plus interest liability of Rs.7,01,31,710/- for the period 2020-21. In our view, the petitioner cannot escape non-facing audit proceedings in the light of these prima facie findings of the audit conducted by the authorities by taking a plea that since they have now been de-registered they are not covered by the provisions of Section 65 of the SGST Act.
There is an obligation cast on a person in whose case of audit is conducted to comply with the directions of the tax authorities under Section 65(5) and these obligations are not affected even if registration is subsequently cancelled. This is made clear from the provisions of Section 29(3) of the SGST Act. If the contention of the petitioner that because they are de-registered, they are not covered by the provisions of Section 65 is accepted, then it would lead to provisions of Section 29(3) dealing with discharge of obligation under the Act or the Rules redundant. It is a settled position that any interpretation that will make the Act's provisions redundant or nugatory cannot be accepted. Instead, we must adopt an interpretation that gives meaning to all the provisions taken together, if necessary, by resorting to a harmonious construction.
It is also important to note that provisions of Section 65 of the SGST Act, read with Rule 101, give sufficient and adequate opportunity to a noticee to explain his case before any audit report is prepared. If an assessee has complied with all the provisions of the Act or Rules and has not defaulted in payment of tax or has not made short-payment of tax or has not wrongly availed input tax credit or refund, then there should not be any hesitation on the part of the noticee to make his submissions and come clear rather than to obstruct the audit proceeding by taking the plea which is canvased.
The provisions of Section 65 of the SGST Act would be applicable for conducting the audit of a financial year when a person was registered, although, on the date of ordering the audit, such a person ceases to be registered voluntarily or otherwise.
This writ petition, challenging the impugned notice dated 21 August 2024 (Exhibit-A) and preliminary audit findings dated 11 October 2024 (Exhibit-B), is dismissed.
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2024 (11) TMI 911
Jurisdiction of impugned orders under U.P.G.S.T. Act, 2017 - time limittaion u/s 73 and Section 44 of the Act - retrospective effect of notifications - impugned order passed beyond the time limit prescribed therein as calculated from the due date of filing annual returns prescribed in Section 44 (1), which was extended to 05.02.2020 and the time limit of three years ended on 05.02.2023 but the impugned orders are dated 05.10.2024 and 02.12.2023 - HELD THAT:- Ordinarily the due date for filing annual return is 31st December of the end of the Financial Year, which in the case of financial year 2017-18 would be 31.12.2018, however, this due date for filing annual return, was extended vide notification of the Central Board of Direct Taxes and Customs dated, 03.02.2018 to 05.02.2020 and this notification was adopted by the State of U.P. vide notification dated 05.02.2020. Based on this notification, the period of three years mentioned in sub Section 10 of Section 73 would end on 05.02.2023 meaning thereby, an order under sub Section 9 of Section 73 for the financial year 2017-18 could have been passed by 05.02.2023 but not after it.
Apparently the impugned orders are beyond the time limit prescribed under sub Section 10 of Section 73 as applicable for the financial year 2017-18 and therefore the impugned orders are beyond jurisdiction being barred by the time provided in the said provision, therefore, the writ petition is allowed and the impugned orders dated 05.10.2024 and 02.12.2023 issued by the Deputy Commissioner, State Tax, Sector 05, Lucknow quashed.
The accounts of the petitioner which have been freezed shall be de-freezed - petition allowed.
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2024 (11) TMI 910
Challenge to SCN and adjudication order - inordinate, unexplained delay - violaion of principles of natural justice - HELD THAT:- In similar circumstances, this Court has, through its several decisions, quashed the show cause notice and restrained the Respondents from proceeding further with the adjudication, which is inordinately delayed. In this regard, we refer to our decision in the cases of COVENTRY ESTATES PVT. LTD. VERSUS THE JOINT COMMISSIONER CGST AND CENTRAL EXCISE & ANR. [2023 (8) TMI 352 - BOMBAY HIGH COURT], PARESH H. MEHTA VERSUS THE UNION OF INDIA, THE COMMISSIONER OF CUSTOMS NHAVA SHEVA, (GENERAL) RAIGAD, THE ADDITIONAL DIRECTOR DIRECTORATE OF REVENUE INTELLIGENCE MUMBAI. [2024 (10) TMI 1412 - BOMBAY HIGH COURT], and M/S. ESJAYPEE IMPEX PVT. LTD., SHRI MAHENDRAKUMAR P. PARMAR MANAGING DIRECTOR OF M/S. ESJAYPEE IMPEX PVT. LTD., VERSUS THE UNION OF INDIA, ADDITIONAL DIRECTOR GENERAL, DIRECTORATE OF REVENUE INTELLIGENCE, MUMBAI, COMMISSIONER OF CUSTOMS (IMPORT-I) , MUMBAI [2024 (11) TMI 622 - BOMBAY HIGH COURT].
The impugned order is set aside - the Respondents are restrained from taking further steps or proceedings in furtherance of it - petition allowed.
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2024 (11) TMI 909
Seeking interference by restoration of the appeal - petitioner could not respond to the notices for prosecuting his appeal because he was unwell - HELD THAT:- Considering petitioner was unwell and under medical treatment at the time notices referred to in impugned order regarding the appeal were served upon him, it is required to interfere. Impugned order is set aside and quashed only on the ground that petitioner appears to have been prevented from prosecuting his appeal.
The writ petition is disposed of.
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2024 (11) TMI 908
SCN issued beyond time limitation - HELD THAT:- It was pointed out by learned advocate that the audit ultimately concluded on 2nd August, 2024 which is beyond the period prescribed under the provisions of Section 65(4) of the GST Act and consequently, the impugned show-cause notices issued by the respondent-Authorities in response to each paragraph of the audit report are without jurisdiction.
Issue Notice, returnable on 4th December, 2024. In the meanwhile, the proceedings pursuant to the impugned show-cause notice may continue, however, no final order shall be passed without permission of this Court during pendency of this petition.
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2024 (11) TMI 907
Violation of principles of natural justice - cancellation of registration without providing reasons in the order - petitioner was not submitting his quarterly return - HELD THAT:- Since in the present case, the basis for initiating action was non-filing of return, as alleged in the show cause notice, subsection (2) of the Section 29 is applicable. The proper officer is empowered to cancel registration of a person if he is satisfied that any of the conditions stipulated in Section 29(2)(b) are attracted - The order impugned is completely non speaking and does not record and reason why the registration has been cancelled.
The impugned order is set aside. Case is remanded to concerned authority for consideration afresh and to pass appropriate order(s) in accordance with law - Petition is allowed by way of remand.
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2024 (11) TMI 906
Challenge to order issued under Section 74 of the Central /West Bengal Goods and Services Tax Act, 2017 - HELD THAT:- Having considered the materials on record and taking note of the clarification issued by the Central Board of Indirect Taxes and Customs dated 17th July, 2023, the writ petition raises jurisdictional issue. The writ petition is required to be heard.
Taking note of the prima facie case made out by the petitioners, inter alia, including the clarification offered by the Central Board of Indirect Taxes and Customs dated 17th July, 2023, the petitioners are entitled to a limited protection, especially since a show cause notice dated 30th July, 2024 has already been issued.
Liberty granted to the petitioner to respond to the show cause dated 30th July, 2024. Since the time to respond has already expired during the pendency of the writ petition on 5th September, 2024, the same is extended by three weeks from date - Liberty to mention for inclusion in the list after expiry of the period for exchange of affidavits. Liberty to the respondents to apply.
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2024 (11) TMI 905
Recovery of refund - petitioner objected to the proposed demand by pointing out that Notification No. 54/2018 Central Tax was prospectively introduced w.e.f. 9.10.2018 and therefore refund prior to such date ought not to be recovered - rectification of order - HELD THAT:- This Court while considering the mistakes pointed out in Misc. Civil Application No.1 of 2020 in Special Civil Application No. 15833 of 2018 has passed the rectification order holding that Notification No.54 of 2018 shall apply prospectively with effect from 9th October, 2018 only.
The impugned show cause notice dated 31.03.2023 issued on the basis of retrospective operation of Notification No.54 of 2018 dated 09.10.2018 is held to be without jurisdiction. The impugned notice is therefore, quashed and set aside as Notification No.54/2018 would be applicable prospectively with effect from 09.10.2018 and therefore, the amount quantified for the period prior to 09.10.2018 towards alleged erroneous refund would not survive.
Petition is disposed of.
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2024 (11) TMI 904
Adjudication of challenge to appellate order - short payment of Goods and Services Tax - HELD THAT:- The first Division Bench directed a quantum of deposit with liberty to parties inasmuch as, petitioner could avail of its remedy upon constitution of the Tribunal and in event petitioner does not do so within time provided upon reconstitution, the department would be free to proceed.
The writ petition is disposed of.
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2024 (11) TMI 903
Challenge to order regarding tax demand based on defects highlighted by Audit Department for assessment year 2017-18 - mismatch between GSTR-3B and GSTR-2A leading to tax demand - lack of personal hearing before passing orders by the respondent - HELD THAT:- A perusal of the impugned order, dated 30.12.2023 would reveal that the respondent has once again confirmed the very same demand which was already demanded vide order dated 19.12.2023 on the similar defect, which is nothing but overlapping the earlier issue and it was the subject matter of W.P.No.7855 of 2023, which was disposed of by this and remanded the matter for fresh consideration while setting aside the earlier impugned assessment order dated 19.12.2023.
This Court is inclined to set aside the present impugned assessment order dated 30.12.2023 and remanded the matter for reconsideration. The respondent is directed to reconsider this matter and pass orders afresh after affording an opportunity of personal hearing to the petitioner.
Petition disposed off.
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