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TMI Blog2012 (4) TMI 238X X X X Extracts X X X X X X X X Extracts X X X X ..... led appeal before ld. CIT(A) and all the facts and submissions were filed in writing which has been reproduced in the order of ld. CIT(A) at pages 2 to 10. It will be useful to reproduce the same in this order as under :- "(a) Mr. Ambrish Pareek, husband of the appellant met with a vehicular road accident on 17.7.2000 on National Highway 8, (Delhi-Jaipur) in which he succumbed to the injuries on the same day. Motor accident claim was filed on 24-10-2000. Award was passed on 10th June, 2004. The Tribunal passed an award of Rs. 2,60,53,600/- along with interest @ 6% per annum from the date of filing of the claim application till realization, after adjusting Rs. 50,000/- interim compensation out of which the appellant and her minor daughter's share was Rs. 1,30,03,600/- and Rs. 1,00,00,000/- respectively. (b) Being aggrieved, the appellant as well as United India Insurance Company Limited, the Insurer, preferred cross appeals before the Rajasthan High Court, Jaipur Bench, Jaipur. The Hon'ble Court by order dated 6.8.2004 stayed operation of the award. Subsequently, the ad-interim order dated 6.8.2004 was modified by the Hon'ble Court on 6.5.2005. In terms of the said ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot yet final. The Insurance Company has disputed the right to claim the compensation. The appellant in its application dated 11th September 2008 in para 3.2 has reproduced the claim and plea of the Insurance company: "That the learned Tribunal has not discussed and considered the sharp contradiction between the FIR which was recorded on the basis of the signed statement i.e. Parcha Bayan, given by Smt. Sharda Pareek herself just after the incident, wherein she has admitted this fact that one Trolla which was going ahead applied the brakes all of sudden and the Tata Sumo, which was at the back of the Trolla, collided with the Trolla. She has further stated that the Trolla driver was driving rashly and negligently and has caused the accident due to rash and negligent driving. In this FIR no negligence has been alleged on the part of Insured Tata Sumo. She changed her statement by submitting an affidavit given after more than one month before the police stating therein that the accident occurred only due to negligence to insured Tata Sumo and the driver of the Tata Sumo was negligent. In the present order learned tribunal has not considered the effect of such contradiction saying tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R 697 "A mere claim to income without an enforceable right thereto cannot, therefore, be regarded as an accrued income for the purpose of the Income-tax Act." (xi) CIT v. Laxman Dass [2000] 246-ITR-622 held, dismissing the application for reference, that the Tribunal was correct in holding that the amounts received by the assessee by way of interest in respect of additional compensation under the Land Acquisition Act, 1894, were not taxable in view of the finding of the Tribunal that the grant of additional compensation and interest thereon had not become final due to appeals preferred by the Government to the High Court. (g) For deciding the issue under appeal, the question to be answered is what will happen if the so called interest is required to be refunded? Whether the tax which the revenue is presently collecting treating this as income be refunded to the assessee by the revenue on account of such refund of the so called interest by the assessee to the Insurance company? The answer is clear no. The existing provisions of Income Tax Act, 1961 do not provide for refund of tax under the instant situation i.e. where the receipt is treated as income but ultimately tu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the appellant is subject to the final decision of the appeal and the amount so received is liable to be refunded if the decision of the appeal is against the present appellant. (j) The impugned interest is discretionary and not statutory. The Hon'ble High Court exercised its discretion and directed to deposit. It is not statutory and as of right as held in the following judgments:- 2003 (1) TAC 48 (AP) A.P.S.R.T.C. v. B Vijaya "...Whereas the interest payable under Section 171 of the M.V. Act is on account of death or injury caused to any person arising out of motor vehicle accident due to negligence.... Whereas under Section 171 of the M.V. Act discretion has been given to the Tribunal to grant interest at such rate the Tribunal may deem fit & appropriate... taking into account various factors such as loss or earnings, percentage of disability suffered etc...." II (225) ACC 850 Sarvat Kouchak v. National Insurance Co. Ltd. "The power of the Tribunal to grant interest is discretionary and is to be properly passed on due reasons both while awarding or decling interest. "A.C.J. 2006 (3) 1058 (1060 Para 8) United India Insurance Co. Ltd. v. Smt. Mrinalini Talukdar & other ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... interest payable in any manner in respect of any moneys borrowed or debt incurred. The inclusive definition provides interest on deposit, claim or other similar right or obligation. By applying the rule of interpretation, i.e., "ejusdem generis" the definition of interest as is provided under s. 2(28A) of the IT Act, the specific words used in the aforesaid section are interest payable on moneys borrowed or debt incurred. These are specific words which are followed by the inclusive general words like deposit, claim or other similar right or obligation. Therefore, the general words like deposit, claim, etc. have to be used in the sense as are used specifically in respect of moneys borrowed or debt incurred. The inclusive definition has, therefore, to be read along with specific words of money borrowed or debt incurred. In the present case, the claimants have received the decretal amount from the assessee-company through the Court of Law (MACT). The claimants and the assessee-company as such have no connection whatsoever with regard to interest payable on moneys borrowed or debt incurred. The claimants filed claims for compensation in the Court of law for death and bodily injuries su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ere cannot be any estoppels against the statue and Article 265 of the Constitution of India in unmistakable terms provides that no tax shall be levied or collected except by authority of law. Acquiescence cannot take away from the appellant the relief and to where the tax is levied or collected without authority of law. We submit as explained earlier such amount is not income and not of the year under appeal. Alternatively, the claim can be raised, for the first time, before the CIT(A). Therefore, although the note appended with the Return of income was integral part of the Return and the assessee had rightly raised the claim of exemption by way of appending the note. However, as a matter of precaution and to ensure that the justice is not obstructed for technical reasons, as is attempted by the ld. AO, we raise the same claim again before your honours. Reliance is placed on the following judicial pronouncements: (i) CIT v. Rewari Central Co-operative Bank Ltd. (263 ITR 598) Punjab & Haryana (ii) Union Coal Co. Ltd. v. CIT (70 ITR 45) Calcutta HC (m) Charging of interest under Section 234C is illegal particularly because tax was deductible on the amount of inter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . What the assessee had received was a sum of money and not merely a right/claim to receive the same. The AO also held that the assessee was free to revise her return of income but the same had not been done till the date of finalization of the assessment order. Further the provisions of section 199 read as under: "199 credit for tax deducted - (1) Any deduction made in accordance with the foregoing provisions of this chapter and paid to the Central Government shall be treated as a payment of tax on the behalf of the person from whose income the deduction was made, or of the owner of the security, or depositor or owner of property or of limit-holder or of the shareholder, as the case may be, and credit shall be given to him for the amount so deducted on the production of the certificate furnished under section 203 in the assessment made under this Act for the assessment year for which such income assessable." As per this provision, the tax deducted was to be treated as the payment of this tax on behalf of person from whose income the deduction was made and credit was allowed for the amount so deducted for the assessment year for which such income was assessable. The AO held that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... subject is contained in the Fatal Accident Act, 1855 and the provisions of the Motor Vehicle Act, 1939 appear to be merely providing a forum and a procedure for the claim for the compensation. But, in fact, provisions of section 110A to 110F of the Motor Vehicles Act, 1939 make a self-contained Code and substantive piece of legislation in themselves. The provisions of this Act are more comprehensive. This Act being a special legislation it was a wider range as compared to the Fatal Accident Act, 1855. The restrictive provisions of section 1A of Fatal Accident Act cannot override the law laid down in section 110A of the Motor Vehicle Act, 1939. In case of conflict, if any, the latter being a special enactment shall have the overriding effect over the former. It may be appreciated that section 1A would come into play in the cases of death of a person caused by wrongful act, neglect or default of other. The section 110A of Motor Vehicles Act, 1939 reads as under: 110A. Application for compensation. (1) An application for compensation arising out of an accident of the nature specified in sub-section (1) of sec. 110 may be made- (a) By the person who has sustained the in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal and held: "The interest on the compensation awarded by the Tribunal or enhanced compensation awarded by the appellate court cannot be taken to have accrued on the date of the award of Tribunal granting compensation or from the date of the award of the appellate court granting enhanced compensation, but has to be taken as having accrued year after year from the date of filing of the claim petition till the date of deposit by the insurance company." The Honourable Madras High Court in the case of New India Assurance Co Ltd v. Mani (270 ITR 394) has also decided this issue in the favour of revenue. It was held therein that the compensation amount which earned interest, because of the delayed payment is liable to be taxed and because of the amended provision, when the interest amount exceeding Rs. 50,000 has been paid by the insurance company, during the financial year, they are bound to deduct the income-tax at source under section 194A of the Income-Tax Act, 1961. In the present case, the insurer has also deducted TDS of Rs. 8,11,369/- on the payment of interest and assessee has also shown the interest income in the return of income. Further the shortfall in tax has been co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Honourable Delhi Tribunal in the case of Oriental Insurance Company Ltd. (96 TTJ 589). However this decision was also considered by the Honourable Bangalore Bench in the case of National Insurance Co. Ltd v. ITO (2007-TIOL-306-ITAT-Bang) and it did not agree to the said preposition. The following observations were made: "Learned counsel for assessee has submitted that in similar circumstances, the Delhi Tribunal in the case of Oriental Insurance Company Limited reported in 143 Taxman (ITAT) page 12 held that such payment of interest as ordered by Motor Accident Claims Tribunal (MACT) is not interest within the meaning of section 2(28A) of the I.T. Act. With regard to the decision of jurisdictional High Court reported in 275 ITR 227, it was argued by learned counsel that the issue in that decision was altogether different. In that case, before the Hon'ble High Court, the assessee went for granting stay. Therefore, non deduction of tax before 2003 was not an issue before the Hon'ble High Court; hence, that decision will not help the revenue. We have heard both the sides and perused the materials on record. The only issue before us is as to whether tax has to be deducted u/s 194A(1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the date of payment of compensation. The interest is not an integral part of the compensation but it is distinct and separate. The interest on compensation awarded under the Land Acquisition Act runs from day to day, accruing from the date on which the Government took possession of the land, that being the date on which the land owner's right to receive the entire compensation arises, though determined and paid later. The provisions of section 194A of the Act have been specifically made applicable to the interest payable on the amount of compensation awarded by the Motor Accidents Claims Tribunal. It is not repudiated that the appellant has received the right to claim compensation and interest thereon. The legal position is settled that if income has accrued during any particular year, it is not open either to the assessee or the Income tax Officer to take that income into consideration in any other year. The right to receive interest was not contingent but absolute and only the amount thereof awaited quantification. Thus, in respect of the assessee, there was a debitum in praesenti and the solvendum in future. Though the quantification of interest was interlinked with the tota ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t had accrued to the assessee to receive compensation under section 45(5) as right to receive compensation was subject matter of dispute before higher court is liable to be rejected. The provisions of section 45(5) of the Act were applicable on enhanced compensation on receipt basis, "irrespective of the fact that additional enhanced compensation was subject matter of further litigation. As far as question of taxability of interest was concerned, it would be governed by the decision of Supreme Court in the case of Smt. Rama Bai and case of P. Mariappa Gounder. It was to be taxed on accrual basis from year to year." The other decisions such as Smt. Sankari Manickyamma (105 ITR 172), Hercules Trading Corporation (143 ITR 504) Syed Khadruddin Ali Khan (144 ITR 266), Laxman Dass (246 ITR 622), Abdul Mannan Shah Mohammed (248 ITR 614) and Goyal Charitable Trust (215 ITR 672) have also become redundant after introduction of sub section 5 of section 45 of the I.T. Act. The main thrust of the argument of the counsel of the appellant is that interest is received under an order which is not final. The finality is shaken when order is challenged before a superior court. The right to receive c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity. It will not be out of place to state that clause (c) of aforementioned sub-section would be redundant if such arguments are accepted. In fact all the clauses would be redundant if capital gain is to be brought to tax only when compensation attains finality. Sub-section (5) of section 45 has no purpose to serve if above contention is accepted. It is a case where one wants to apply only sub-section (1) of section 45 in total disregard of statutory provision of sub-section (5). Further after insertion of sub-section (5), the scheme of assessment of enhanced or further enhanced compensation is to be taxed only in the year of the receipt. If it is not taxed in that year, but is held to be taxed in the year in which amount of compensation is finally determined, then there is no provision to charge it to tax otherwise than in the year of receipt. Therefore special provision relating to taxability of amount is the year of receipt, cannot be disregarded. For aforesaid reasons also, the arguments advanced on behalf of assessee cannot be accepted. 7. The counsel of the appellant has argued that what will happen if the so called interest is required to be refunded? Whether the tax which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rucial words in the main provision of section 194A(3) are "at the time of the credit of such income to the account of the payee or at the time of payment thereof in cash or by the issue of a cheque or draft or by any other mode, whichever is earlier". This means that if there has been a credit of interest to the account of the creditor, that can be taken into account for the purposes of section 194A. That being so, the amount of interest has already became due and the credit entry has only been made on the basis of such accrued liability, and, therefore, the provisions of section 194A are attracted and income is chargeable to tax. 8. The counsel of the appellant has argued that Interest awarded under the Motor Vehicles Act, 1988 is granted by way of compensation. It is a compensation for forbearance or detention of money and that interest being awarded to a party only for being kept out of the money, which ought to have been paid to him. Thus the interest being part & parcel of compensation is not taxable. I have duly considered this contention of the appellant. The Honourable Mumbai High Court in the case of Mrs. Gauri Deepak Patel v. New India Assurance Co. Ltd. (2010-TIOL-43-HC ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st component. 9. In the fifth ground of appeal, the appellant has challenged the charging of interest U/s 234C. However the charging of interest is mandatory in view of decision of jurisdictional High Court in the case of Hari Narain Soni v. ITO (322 ITR 444) and Honourable Delhi High Court in the case of CIT v. Saw Pipes Ltd. (321 ITR 105). The assessee has herself paid interest of Rs. 15,813/- U/s 234C and the AO has not charged any interest. This ground of appeal is therefore infructuous. Accordingly this ground of appeal is dismissed. 10. Respectfully following the decision of Honourable Gujarat High Court in case of Hansaguri Prafulchandra Ladhani (supra) and Honourable Madras High Court in case of New India Assurance Co. Ltd. v. Mani (270 ITR 394) and facts of the present case, I hold that AO was right in taxing interest income of Rs. 73,25,583/- in the hands of the assessee. All the grounds of appeal are dismissed." 6. Now the assessee is in appeal here before the Tribunal. 7. Contention raised before the lower authorities were reiterated. The ld. Counsel of the assessee also filed written submissions which contained in 12 pages. For the sake of better clarification and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... become a partner only when he was accepted as such by the surviving partners. One of the partners died in 1918, nominating his son, but the surviving partners did not consent to his admission. The refusal of the admission became final in the year 1926, eight years later. Meantime, during these eight years, the share of the income from the partnership due to the deceased partner was being accumulated. Under the provisions of the partnership deed, if the son were to be admitted as partner, this share in the profits would belong wholly to one of the partners E alone; but, if the son were not to be admitted this share was to be divided equally between E and the three others, who were colleagues of the deceased partner, and not wholly to E. Rowlatt, J, held that during the years 1918 to 1926, E could be assessed only in respect of the 25 per cent of every year's income, as E was entitled to that share in any event. As far as the balance seventy five per cent was concerned, the same could not be held to be belonging to E, as the right thereto would result only after the admission of the son of the deceased partner as partner. This right was contingent upon an event which was to happen in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hurdle."(PB Page No.26 to 27) 4.2. On going through the said plea, it is apparent and patent that the decision of the Hon'ble High Court may be in favour of or against the Insurance Company. It is a case where the claim itself is in dispute and the Insurance Company is still denying the liability for payment of compensation. It is further apparent that no part of the compensation has been directed by the Hon'ble High Court to be paid to the appellant but only interest has been directed to be paid/deposited in the account of the claimants, subject to further orders of the Court. The entire claim is in jeopardy and is in cohate. Hence the impugned amount is not income liable to tax during the year under appeals. We support our proposition by the following decisions: - (i) CIT v. Hindustan Housing and Land Development Trust Ltd. [1986] 161 ITR 524(SC) - please see para 5.3 of the submissions. (PB. Page No. 10-11) (ii) CIT v. Karanbir Singh [2008] 303 ITR 231 (P&H) - please see para 5.3 (iii) of the submissions. (PB. Page No. 12) (iii) CIT v. Syed Khadruddin Ali Khan [1983] 144 ITR 266 (AP) - please see para 5.3 (v) of the submissions. (PB. Page No. 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... quisition of assets, the law has been amended. However, it makes it further clear that unless the law is amended in respect of interest received on undecided compensation the said interest cannot be taxed as income in view of the above judicial pronouncements. The law rightly does not prescribe any situation for refund because fundamentally the Income Tax Act, 1961 provides that any receipt will be taxed as income liable to tax only when this is unconditionally, unequivocally, without doubt and without any sort of uncertainty is received by the assessee. 4.4. We are also enclosing herewith the decisions of the Hon'ble Supreme Court in the under noted cases where original claim allowed by the MACT and the lower Courts is reduced/reversed by the Hon'ble Supreme Court on appeal by the Insurance Company. (i) U.P State Road Transport Corporation v. Krishna Bala and others [2006] ACJ 2114 (SC) (PB Page No. 35-39) "Quantum - fatal accident- deceased -aged 36, drawing Rs. 2300/- p.m.- Claimants; widow and children Tribunal deducted personal expenses of the deceased, adopted multiplier of 22, allowed Rs. 20000/- towards loss of love and affection and Rs. 5000/- for las ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 03] 264 ITR 617 (P&H) (ii) CIT v. Chiranjit Jawa [2004] 270 ITR 173 (P&H) (iii) Oriental Insurance Company Ltd. v. Income Tax Officer ITAT, Delhi 'D' bench (2005) 96 TTJ (Del) 589 "What the assessee - company pays to the claimant, may be a compensation and interest thereon but legally it is the decretal amount which the assessee - company is liable to pay after adjudication of the claim of the claimants through the filing of the proper suit in the MACT Court. The definition of the interest under s.2 (28A) provides interest payable in any manner in respect of any moneys borrowed or debt incurred. The inclusive definition provides interest on deposit, claim or other similar right or obligation. By applying the rule of interpretation, i.e. "ejusdem generis" the definition of interest as is provided under s.2 (28A) of the IT Act, the specific words used in the aforesaid section are interest payable on moneys borrowed or debt incurred. These are specific words which are followed by the inclusive general words like deposit, claim or other similar right or obligation Therefore, the general words like deposit, claim, etc. have to be used in the sense as are used specif ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n for forbearance or detention of money and that interest being awarded to a party only for being kept out of the money, which ought to have been paid to him. In this way it is part and parcel of the compensation. 6 The ld. CIT(A) has based his decision on the following misconceptions:- (i) Section 194A requires deduction of tax at source on interest payment by Insurance Company on compensation amount and hence, as per ld. CIT(A), it becomes income in the hands of the recipient. It is most humbly submitted that the charging section is section 4. Section 194 A is not the charging section or the section which defines the term income. Assessee appellant is not disputing the obligation of the Insurance Company under section 194A for deduction of tax at source. Many a times the payer has to deduct the tax irrespective of the said payment being income in the hands of the recipient. This difference may arise on account of different methods of accounting i.e., mercantile vs. cash followed by the payer or the payee. Therefore, the ld. CIT(A) is totally wrong in basing his decision for the reason of obligation of TDS under section 194A. This misconception of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee by the Revenue on account of such refund of the so-called interest by the assessee to the Insurance Company? 7. The ld. CIT(A) has misplaced his reliance on the following judicial pronouncements which are distinguished on facts and on law as under:- 7.1. (i) Smt. Hansaguri Prafulchandra Ladhani and Others v. Oriental Insurance Company Limited and Others, 2007 ACJ 1897 (Gujarat HC) and (ii) New India Assurance Co Ltd v. Mani (270 ITR 394) (Madras HC) and (iii) Mrs. Gauri Deepak Patel v. New India Assurance Co. Ltd. (2010-TIOL-43-HC Mum.) and (iv) New India Assurance Co. Ltd. (275 ITR 227) (Karnataka HC) The ld. CIT(A) has mainly relied on the above Gujarat and Madras High Courts orders refer at CIT(A) order Page No. 22 at para 10. The issue dealt with by the different High Courts in the above cases was related to liability of Insurance Company to deduct tax at source u/s 194A. The decisions have nothing to do with the issue of accrual of income, which is under dispute in the present appeal. Whether a contingent income is income liable to tax has not been the issue for decision in the above case laws relied upon by the l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ese decisions are totally on different issues. These decisions provide guidelines about the years of taxability once a particular receipt is decided to be income. The issue in the present appeal is whether the receipt is income or not liable to be taxed. Unless the said receipt is income liable to be taxed, the year of taxability has no meaning. 7.6 In CIT v. Sun Engineering Works P. Ltd., 198 ITR 297, the Supreme Court held as under: "It is neither desirable nor permissible to pick out a word or a sentence from the judgment of this Court, divorced from the context of the question under consideration and treat it to be the complete 'law' declared by this Court. The judgment must be read as a whole and the observations from the judgment have to be considered in the light of the questions which were before this Court. A decision of this Court takes its colour from the questions involved in the case in which it is rendered and while applying the decision to a latter case, the Courts must carefully try to ascertain the true principle laid down by the decision of this Court and not to pick out words or sentences from the judgment, divorced from the context of the questions under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cipient. However, the Hon'ble Supreme Court in various cases has held that the interest is granted by way of compensation only. This was held in case of Tejinder Singh Gujral v. Inderjit Singh [2007] 1 SCC 508. Similarly in case of Abati Bezbaruah v. Dy. Director General Geological Survey of India [2003] 3 SCC 148 has held that interest is compensation for forbearance or detention of money and that interest being awarded to a party only for being kept out of the money which ought to have been paid to him. In case of Dharampal v. U.P. State Road Transport Corpn., [2008] ACJ 2041 the Hon'ble Supreme Court has held that interest is compensation for forbearance or detention of money which ought to have been paid to the claimant. No rate of interest is fixed under section 171 of the Act and the duty has been bestowed upon the court to determine such rate of interest. If these decisions are taken into consideration, then there will be a debate that whether interest received awarded by the MACT is revenue receipt or a part of compensation. Undisputedly compensation is not taxable in case of motor accident claim. 10.1. However, the moot question is whether the interest so received is taxa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be assessed in the year in which it reached its finality. 10.2 In case of Dharampal (supra), the interest under section 171 of Motor Vehicle Act granted by MACT @ 6% per annum from the date of application till the date of payment. High Court maintained the rate. However, Hon'ble Apex Court discussing various case laws observed that rate of interest would normally depend upon prevailing rate of bank interest on bank deposit at the relevant time and enhanced at 7.5%. By holding so, it was held by Hon'ble Supreme Court that provision of payment of interest is discretionary and it cannot be bound by rule. In para 10 it was held that interest is compensation for forbearance or detention of money, which ought to have been paid to the claimant. No rate of interest is fixed under section 171 of the Act and the duty has been bestowed upon the court to determine such rate of interest. This was rendered by the Hon'ble Apex Court in case of National Insurance Co. Ltd. v. Keshav Bahadur [2004] ACJ 648 which was considered by Hon'ble Supreme Court in case of Dharampal (supra). 10.3 Similarly, in case of Abati Bezbaruah (supra), the Hon'ble Supreme Court has directed to pay the interest @ 9% pe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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