9911796707
TMI BlogFinance Act, 1990--Explanatory Notes on the provisions relating to direct taxesX X X X Extracts X X X X X X X X Extracts X X X X ..... credit certificates) ; amended sections 2, 5, 10, 16, 17, 35K, and Schedule 111 of the Wealth-tax Act, 1957 ; inserted a new section 35EEE in the Wealth-tax Act, 1957 ; amended sections 9, 15 and 16 of the Gift-tax Act, 1958. PROVISIONS IN BRIEF The provisions in the Finance Act, in the sphere of direct taxes relate to the following matters : (i) Prescribing the rates of income-tax on incomes liable to tax for assessment year 1990-91, the rates at which tax will be deductible at source during the financial year 1990-91 from Interest (including interest on securities), dividends, salaries paid to employees, winnings from lotteries or crossword puzzles, winnings from horse-races, insurance commission and other categories of income liable to deduction of tax at source under the Income-tax Act, rates for computation of "advance tax" and charging of income-tax on current incomes in certain cases for the financial year 1990-91. (ii) Retaining with modification as to applicability of the provisions for the levy of surcharge at the rate of 8 per cent. of income-tax. (iii) Amendment of the Income-tax Act, 1961 with a view to - (1) streamlining the tax structure by withdrawing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or return even before the end of the relevant assessment year ; (22) providing for processing of revised returns under the new procedure for assessment ; (23) modifying the definition of "regular assessment" ; (24) conferring power on an Income-tax Officer to reopen assessment with the approval of the Deputy Commissioner ; (25) providing for penalties for certain defaults by mutual funds ; (26) providing for punishment for contravention of prohibitory order served for effecting seizure ; (27) removing anomalies in certain cases ; and (28) modifying the provisions relating to the valuation of jewellery under the Wealth-tax Act. INCOME-TAX Rate Structure I. Rates of income-tax In respect of incomes liable to tax for the assessment year 1990-91. 3. In respect of incomes of all categories of taxpayers (corporate as well as non-corporate) liable to tax for the assessment year 1990-91, the rates of income-tax (including surcharge thereon) have been specified in Part I of the First Schedu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lso for the computation of "advance tax" payable during that year in the case of all categories of taxpayers have been specified in Part III of the First Schedule to the Finance Act. These rates are also applicable for charging income-tax during the financial year 1990-91 on current incomes in cases where accelerated assessments have to be made, e.g., provisional assessment of shipping profits arising in India to non-residents, assessment of persons leaving India for good during the financial year 1990-91, assessment of persons who are likely to transfer property to avoid tax or where an order has to be passed in a case of search and seizure for calculating the amount of tax on the estimated undisclosed income, etc. 6. The Finance Act, 1989, specified in Part III of the First Schedule that the amount of income-tax deductible or advance tax payable or income-tax payable, as the case may be, shall be increased by a surcharge calculated at the rate of 8 per cent. of the tax so deductible or advance tax or income-tax so payable in the case of a person whose income exceeded fifty thousand rupees. The Finance Act, 1990, provides that the aforesaid surcharge shall be levied in the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are indicated in the Table below : Finance Act, 1989 Finance Act, 1990 Income level Marginal rate of tax Income level Marginal rate of tax Up to Rs. 10,000 15 per cent Upto Rs. 10,000 10 per cent Rs. 10,000 — 20,000 25 per cent Rs. 10,000 — 20,000 20 per cent Above Rs. 20,000 40 per cent Above Rs. 20,000 35 per cent III- C. Registered firms. 9. In the case of registered firms, the rates of tax have been specified in paragraph C of Part Ill of the First Schedule to the Finance Act. The exemption limit has been raised from Rs. 10,000 to Rs. 15,000 and the rate schedule has been restructured for registered firms carrying on business and also for registered firms carrying on profession. The existing and new rates of income-tax are indicated in the Table below : - TABLE Finance act, 1989 Finance act, 1990 Income level ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cultural income with income derived from agriculture. 12. As in the past, the Finance Act provides that in the case of individuals, Hindu undivided families, other associations of persons, etc., the net agricultural income will be taken into account for the computation of "advance tax" and charging of income-tax. These provisions are on the same lines as those in earlier years. [Section 2 and the First Schedule of the Finance Act.] Streamlining of tax structure. 13. With the reduction in the rates of taxes in the case of domestic companies, registered firms and co-operative societies and on a review of some of the incentives and concessions available to taxpayers, the following incentives and concessions have been withdrawn or modified : - (a) Under the existing provisions of section 32A of the Income-tax Act, a deduction of an amount equal to twenty per cent. of the cost of new ship or aircraft or plant and machinery installed or put to use is allowed in computing the profits and gains from business or profession. This concession has been withdrawn in relation to new ship or aircraft acquired or new plant or machinery installed after the 31st day of March, 1990. Cop ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Income-tax Act, all categories of assessees are entitled to a deduction equal to 20 per cent. of the profits derived by them from new small-scale industrial undertakings (other than those engaged in mining) set up in any rural area. The deduction is allowed in respect of each of the ten assessment years beginning with the assessment year relevant to the previous year in which the industrial undertaking begins to manufacture or produce articles or things. The small-scale industrial undertakings which begin to manufacture or produce articles or things after the 31st day of March, 1990, will not be eligible for this deduction. [Section 21 of the Finance Act.] (f) Under the existing provisions of section 115J of the Income-tax Act, in the case of a company whose total income as computed under the Income-tax Act, is less than 30 per cent. of the book profit, as computed under that section, the total income chargeable to tax will be 30 per cent. of the book profit. The provision was enacted to restrict the erosion of the base of taxable inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ame in this behalf, out of the moneys due to him on account of his retirement, whether on superannuation or otherwise. The deposits under the aforesaid scheme are also exempt from wealth-tax under section 5(1)(xxviic) of the Wealth-tax Act. 15.1 The aforesaid exemptions have now been extended in respect of deposits made under the aforesaid scheme also by an employee of a statutory corporation or a Government company on retirement, whether on superannuation or otherwise. 15.2 This amendment will take effect from 1st April, 1991, and will, accordingly, apply in relation to the assessment year 1991-92 and subsequent years. [Sections 5 and 52 of the Finance Act.] Exemption in respect of interest on securities held by the Registrar, Supreme Court, in Reserve Bank's SGL Account No. SL/DH 048 16.The amount of US $470 million paid by the Union Carbide Corporation and the Union Carbide India Ltd. on the directions of the Supreme Court as compensation for the victims of the Bhopal gas leak disaster stands deposited in the Reserve Bank of India to the credit of the Registrar, Supreme Court, in the form of certain Government securities. Under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hing the return of his income, whichever is earlier. The deduction is limited to 20 per cent. of the profits of such business as computed before making deduction under the provision and will be allowed before the loss, if any, brought forward from earlier years is set off. 17.3 The other salient features of the new scheme of Tea Development Account are . (i) The special account with the National Bank for Agriculture and Rural Development is the account maintained in accordance with and for the purposes specified in the scheme approved in this behalf by the Tea Board. (ii) The amount standing to the credit of such special account may be withdrawn only for the purposes specified in such scheme. Except in the circumstances mentioned below at (iii), if the amount released by NABARD in a year is not utilized for the purpose for which it is released, the amount not so utilised will be treated as taxable profits of that year and taxed accordingly. (iii) Apart from the purposes specified in the scheme, the amount standing in the credit of the special account may be allowed to be withdrawn in any of the following circumstances (a) closure of business ; (b) death of the taxpaye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... otherwise transferred. The deduction allowed earlier will, however, not be withdrawn in cases where the asset is transferred within the 8 year-period to Government, local authority, statutory corporation or Government company. It will also not be withdrawn where the transfer takes place in connection with the succession of a firm by a company. For this purpose it is necessary that : (a) the scheme continues to apply to the company in the manner applicable to the firm ; (b) the successor company takes over all the properties and liabilities of the firm ; and (c) all the shareholders of the company were partners of the firm before the succession. 17.4 This provision will take effect from 1st April, 1991, and will, accordingly, apply to the assessment year 1991-92 and subsequent years. [Section 10 of the Finance Act.] Modification of conditions for grant of development rebate and investment allowance. 18. The provisions of section 33 read with section 34 of the Income-tax Act, relating to development rebate, provide for deduction of a percentage of the actual cost of a ship acquired or machinery or plant installed. One of the conditions for the d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r year will not be a year earlier than the year in which the plant, machinery is installed or put to use or the ship is acquired. 18.4 These amendments will take effect retrospectively from 1st April, 1962, in relation to the development rebate and 1st April, 1976, in relation to the investment allowance and will, accordingly, apply from assessment years 1962-63 and 1976-77, respectively and subsequent years. [Sections 7 and 11 of the Finance Act.] Tax concessions in respect of contribution to. a fund or programme of afforestation. 19. Under the existing provisions of section 35CCB, in the case of an assessee having income from business or profession, any expenditure incurred by way of payment of any sum to an approved association or institution is allowed as deduction where the object of such association or institution is undertaking of any approved programme of conservation of natural resources. Deduction for similar payments made by other assessees who are not having income from business or profession is allowed under section 8OGGA of the Income-tax Act. With a view to promoting afforestation, the scope of deduction under sections 35CCB and 8OGGA has been enlarged so a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... than Indian made foreign liquor), forty per cent. of the purchase price paid or payable is deemed to be his income. As a result of different systems prevailing in different States, the term purchase price is being understood in different ways. Therefore, an Explanation has been inserted in clause (a) of sub-section (1) of section 44AC to provide that purchase price shall mean all amounts paid or payable to obtain country liquor, excluding the amount paid or payable towards the bid money in an auction or the highest accepted offer in a tender or any other mode. 21.1. At present, the provisions of section 44AC apply where the goods of the specified nature are sold by the Central Government, a State Government, any local authority, a statutory corporation or authority, a company or a firm. The Explanation below section 44AC has been amended to include co-operative societies within the meaning of the term "seller" in section 44AC. 21.2 These amendments will take effect from 1st April, 1991 and will, accordingly, apply in relation to the assessment year 1991-92 and subsequent years. [Section 14 of the Finance Act.] Modification of tax reliefs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 70,000 Tax on total income 12,900* 15,600** Tax rebate on savings of Rs. 14,500 Nil 2,900 *As per the existing rates. **As per the new rates. Tax payable : Rs. Tax 12,900 Surcharge 1,032 13,932 13,932 12,700 22.6 These amendments will take effect from 1st April, 1991, and will, accordingly, apply in relation to the assessment year 1991-92 and subsequent years. [Sections 2, 30 and 50 of the Finance Act.] Modification of the provisions of tax concession in respect of investments an certain shares, etc. 23. Under the existing provisions of section 80CC of the Income-tax Act, a deduction of an amount equal to fifty per cent. is allowed in respect of investment in shares forming part of an eligible issue of equity capital or units issued under any scheme of a mutual fund or the Unit Trust of India, if the amount mobilised under the scheme is invested only in the eligible issue of capital. The total amount of investment qualifying for deduction under this secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Finance Act.] Modification of the provisions in respect of deposits under National Savings Scheme. 24. Under the existing provisions of section 80CCA of the Income-tax Act, deduction is allowed to an individual, a Hindu undivided family and certain categories of associations of persons or bodies of individuals, in respect of deposits made under the National Savings Scheme and payments made towards notified annuity plans of the Life Insurance Corporation. The deduction is provided on the whole of amount so deposited or paid as does not exceed Rs. 30,000 in a year (Rs. 20,000 for the assessment year 1988-89). 24.1 With a view to provide further incentives for savings, this section has been amended to increase the maximum amount, which would qualify for deduction, to Rs. 40,000. 24.2 Further, under the existing provisions of section 80CCA of the Income-tax Act, where any amount standing to the credit of an assessee under the National Savings Scheme in respect of which a deduction has been allowed together with the interest accrued thereon is withdrawn, it is deemed to be income of the assessee in the year of the withdrawal. Similarly, amount received on account of the surr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed family or the dissolution of association of persons, the amount so received shall be deemed to be the income of the recipient. 25.3 A new sub-section (6) and Explanation thereto has been inserted in section 45 to provide that the difference between the repurchase price of the units and the amount invested therein by the assessee shall be deemed to be the capital gains of the year in which the units are repurchased or the scheme is terminated and taxed accordingly. 25.4 Further, a new section 194F has been inserted to provide for deduction of tax at source at the time of payment of any amount on account of repurchase of units or termination of the scheme. The tax will be deducted at the rate of 20 per cent. 25.5 These amendments will take effect from 1st April, 1991, and will, accordingly, apply in relation to the assessment year 1991-92. [Sections 15, 17 and 40 of the Finance Act.] New provisions relating to deduction of expenditure incurred on handicapped dependent relatives. 26. A new section 80DD relating to deduction in respect of expenditure incurred on handicapped dependent relatives has been inserted in the Income-tax Act. 26.1 Under the new provision, dedu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s supporting this view. 27.2 To put an end to litigation which may arise regarding the taxability of these incentives received by exporters, new clauses (iiia), (iiib) and (iiic) have been inserted in section 28 of the Income-tax Act to provide that profit on sale of import entitlement licences, CCS and drawback of duty respectively shall be chargeable to income-tax under the head "Profits and gains of business or profession". These have, further, been included in the definition of the term "income" in clause (24) of section 2. 27.3 These amendments will take effect retrospectively from the dates from which these incentives were introduced. Thus, amendment with regard to profit on sale of import entitlement licences will apply from 1st April, 1962 ; cash assistance from 1st April, 1967, and drawback of duty from 1st April, 1972, and will, accordingly, apply in relation to the assessment years 1962-63, 1967-68 and 1972-73, respectively, and subsequent years. 28. Under the existing provisions of section 80HHC of the Income-tax Act, exporters are allowed 100 per cent. deduction in respect of the profits derived from export of goods or merchandise. One of the conditions for al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n has been correctly claimed, section 139 has also been amended to allow such taxpayers who were required to furnish their returns of income by the 31st day of August to file their returns by the 31st day of October of the assessment year. 28.3 Under the existing provisions of section 80HHC, the benefit of deduction is also allowed to supporting manufacturers who export goods or merchandise through recognised export houses or trading houses. A person who processes goods or merchandise and exports the same directly is eligible to claim the deduction under section 80HHC. However, if the processor of goods or merchandise sells his goods or merchandise to an export house or trading house for the purposes of export, he is presently denied the benefit of deduction. The benefit of deduction under section 80HHC has now been extended to processors who sell their goods or merchandise to export houses or trading houses for export purposes. The condition for obtaining the benefit is the same as already applicable to supporting manufactures, namely, that of obtaining a disclaimer certificate from the export house or trading house. 28.4 By an amendment in clause (a) of sub-section (2) of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iness 2/3 export 1/3 domestic sales 1/2 export 1/2 domestic sales 1/3 export 2/3 domestic sales (i) Turnover (Rs. in lakhs) (a) FOB export 100 100 100 100 (b) Domestic sales Nil 50 100 200 (c) Total turnover [(ia) + (ib)] 100 150 200 300 (ii) Business profits before incentives (assumed figure) 10 15 20 30 (iii) CCS, DBK, I/L 10 10 10 10 (iv) Total profits of the business [(ii) + (iii)] 20 25 30 40 (v) Deduction u/s 80HHC if entire export proceeds, i.e., Rs. 100 lakhs are brought into India within the stipulated period [(iv) × (ia)/(ic)] 20.00 25 X 100/150 = 16.67 30 X 100/200 =15.00 40 X 100/300 =13.33 (vi) Deduction u/s. 80HHC if only 50 per cent of the export proceeds i.e., Rs. 50 lakhs are brought into India [(iv) × 50% (ia)/(ic)] 20 X 50/100 =10 25 X 50/150 =8.33 30 X 50/200 =7.50 40 X 50/300 =6.67 [Sections 3,6,22 and 23 of the Finance Act] ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [Section 24 of the Finance Act.] Deletion of the definition of the term "security" 30. Under the existing provisions of section 2(42C) of the Income-tax Act, "security" means a Government security as defined in clause (2) of section 2 of the Public Debt Act, 1944. 30.1 The insertion of the definition of the term "security" in section 2 dealing with definition having general application for the purposes of the Act had created anomalies resulting in problems of implementation. Therefore, sub-section (42C) of section 2 of the Income-tax Act has now been omitted. 30.2 Further, section 80L of the Income-tax Act has also been amended to provide that the term "security" appearing therein shall mean a Government security as defined in clause (2) of section 2 of the Public Debt Act, 1944. The same definition of the term "security" has been incorporated in the new section 88 of the Income-tax Act inserted through this Finance Act. This will clarify the nature of the security referred to in the aforesaid two sections and ensure that the interest on National Savings Certificates VIII Issue does not qualify for benefit under section 80L as specified in the scheme framed for this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... utions abroad. Similarly, a deduction under section 80RR equal to twenty-five per cent. of the income received in, or brought into, India in foreign exchange is allowed to a resident individual being an author, playwright, artist, musician, actor or sportsman (including an athlete) who derives income in exercise of his profession from foreign sources. In order to provide a further incentive for bringing foreign exchange into India by these categories of taxpayers, the benefit of deduction in sections 8OR and 80RR has now been enhanced. The new deduction will be:- (i) Fifty per cent. of such income received by the taxpayers ; or (ii) Seventy-five per cent of such income as is brought into India, by or on behalf of the taxpayer in accordance with the Foreign Exchange Regulation Act, 1973, and any rules made thereunder whichever is higher. 32.1 Under the existing provisions of sections 8OR and 80RRA (relating to deduction in respect of remuneration received for services rendered outside India under approved agreements), the deduction is allowed for a maximum continuous period of thirty-six months. With the deletion of the test for determining residential status on the basis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ctions of the Act, relating to assessment and collection of revenue in respect of any class of incomes or class of cases. The provisions of section 139 relating to filing of return of income, section 234A relating to the charging of mandatory interest for defaults in furnishing return of income and section 234B relating to charge of mandatory interest for defaults in payment of advance tax, may sometimes need relaxation. At present, it is not possible for the Board to relax these provisions. 34.1 Therefore, a reference to sections 139, 234A and 234B has been incorporated in clause (a) of sub-section (2) of section 119 so that the Board is empowered to relax the provisions of these sections applicable to any class of income or class of cases. 34.2 Similar amendments have been made in the corresponding provisions in section 10(2)(a) of the Wealth-tax Act and section 9(2)(a) of the Gift-tax Act. 34.3 These amendments will take effect from 1st April, 1990. [Sections 33, 53 and 59 of the Finance Act.] Allowing the firms to file their returns even if their income is below the taxable limit. 35. Under the existing provisions of sub-section (10) of section 139 of the Income-t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [Section 35 of the Finance Act.] Conferring power on Assessing Officers to call for return before the end of an assessment year. 37. Under the existing provisions of clause (i) of sub-section (1) of section 142, the Assessing Officer can require any person to furnish a return of his income only after the end of the relevant assessment year. This has given rise to problems because, if the taxpayers do not file their returns of income in time, the Department has no powers to enforce compliance till the relevant assessment year is over. 37.1 To solve this practical difficulty, clause (i) of sub-section (1) of section 142 has been amended so that if a person fails to furnish return of income by the due date mentioned in section 139(1), a notice calling for the return can be sent to him within the relevant assessment year itself. 37.2 Similar amendments have been made in the corresponding provisions of section 16(4) of the Wealth-tax Act and section 15(4) of the Gift-tax Act. 37.3 These amendments will take effect from 1st April, 1990. [Sections 36, 54 and 60 of the Finance Act.] Processing of revised returns under the new Procedure for assessment. 38. Under the provi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sion in clause (40) of section 2 of the Income-tax Act, defines the expression "regular assessment" to mean the assessment made under section 143 or section 144. Prior to April 1, 1989, an assessment could be made under sub-section (1) as well as sub-section (3) of section 143. However, the new section substituted by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989, provides for making of an assessment only under sub-section (3), while under sub-section (1) the return is processed for recovery of any tax or interest due from the assessee or for the issue of any refund due to him without making an assessment. Since the definition of regular assessment in section 2(40) refers to the whole of section 143, without referring to the relevant sub-section, it may raise a controversy whether even the processing of a return under sub-section (1) of the new section 143, is included in "regular assessment". 39.1 Therefore, clause (40) of section 2 has been amended to clarify that regular assessment would mean only an assessment made under sub-section (3) of section 143 or section 144. 39.2 Similar amendment has been made in the corresponding provisions of sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ew to removing this practical difficulty, sub-section (1) of section 151 has been amended to provide that an Income-tax Officer can reopen a case, with the approval of the Deputy Commissioner, where an assessment has been completed under section 143(3) or section 147, if he finds that any income has escaped assessment. 41.2 Similar amendments have been made in the corresponding provisions of section 17 of the Wealth-tax Act and section 16 of the Gift-tax Act. 41.3 These amendments will take effect from 1st April, 1990. [Sections 39, 55 and 61 of the Finance Act.] Removal of anomaly in section 268 of the Income-tax Act. 42. Under the existing provisions of section 268, if an assessee is not furnished with a copy of the order, then, in computing the period of limitation for filing an appeal, the time required for obtaining a copy of such order is to be excluded. This provision needs to be applied also in deciding the limitation period for making a reference application under section 256 of the Act. Therefore, an amendment has been made in section 268 to provide that the time required for obtaining copy of the order complained would be excluded in computing the period of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uch documents, money, bullion, jewellery, etc. Any infringement of such prohibitory order is punishable under section 275A with rigorous imprisonment up to two years and fine. 44.1 The Finance Act, 1988, inserted a second proviso to sub-section (1) of section 132, which empowers the authorised officer to make a constructive seizure, by a similar prohibitory order, in circumstances where, on account of the physical characteristics, volume or weight of the articles to be seized, it is not possible to take physical possession and remove them to a safe place. The contravention of such a prohibitory order has not been made punishable. 44.2 Accordingly, section 275A has been amended to provide for punishment also for contravention of an order made by the authorised officer under the second proviso to sub-section (1) of section 132. 44.3 Further, section 37A of the Wealth-tax Act contains provision for issue of prohibitory orders similar to those mentioned above. However, there are no provisions in the Wealth-tax Act corresponding to section 275A of the Income-tax Act. To remedy this situation and ensure effective compliance, a new section 35EEE has been inserted in the Wealth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 87 and 1989. To remove this anomaly, section 288 has been amended to provide that a person will be disqualified to represent an assessee as an authorised representative in case a penalty for concealment has been imposed on him. 46.1 This amendment will take effect from 1st April, 1990. [Section 49 of the Finance Act 1]. WEALTH-TAX Amendment of section 35K of the Wealth-tax Act. 47. Sub-section (1) of section 35K of the Wealth-tax Act provides that a person shall not be proceeded against for an offence under section 35A (relating to wilful attempt to evade tax, etc.) or section 35D (relating to false statement in verification, etc.) in respect of which penalty for concealment of wealth has been reduced or waived under section 18B. The applicability of the said sub-section (1) was restricted till the assessment year 1988-89 by an amendment made by the Direct Tax Laws (Amendment) Act, 1987, because penalty for concealment of wealth was omitted by the said Amendment Act. However, since penalty for concealment of wealth has been restored by the Direct Tax Laws (Amendment) Act, 1989, with effect from 1st April, 1989, it is necessary that this restriction in the applicab ..... X X X X Extracts X X X X X X X X Extracts X X X X
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