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TMI Blog2013 (4) TMI 704X X X X Extracts X X X X X X X X Extracts X X X X ..... fraction (average 6.4 %) of the export values declared by M/s. Nidhi Textiles (in the Shipping Bill and related export documents) before the Indian Customs. While the value declared before the Indian Customs in respect of 39 consignments/shipping bills during the period October, 2006 to April, 2008, amounted to US $ 3009931.41, for the same consignments, the value declared by the importers in Dubai amounted to only US $ 147446, that is, 6.35% of the export value declared in India. Thus the magnitude of overvaluation has been clearly established. The commission of fraud has been admitted to by Shri Rajeev Kumar Tulsyan, Proprietor of the said M/s. Nidhi Textiles in his Statements recorded under Section 108 of the Customs Act, 1962, wherein he has explained that while remittances of the full amount for the exports made were received from overseas buyers through banking channels, the differential amount (difference between the actual and the declared value) was paid back to the local representatives of the overseas buyers in cash and the said statement has not been retracted in any legally permissible manner - Though the appellant has pleaded financial difficulties, no reliable e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssioner (AP), for the Respondent. ORDER There are 63 appeals and 63 stay applications and one COD application which arise from Orders-in-Original No. 83/2011/CAC/CC/BKS, dated 23-12-2011, 09/2012/CAC/CC/ BKS, dated 27-2-2012, 15/2012/CAC/CC/BKS, dated 22-3-2012 and 16/2012/CAC/ CC/BKS, dated 28-3-2012 passed by the Commissioner of Customs (Adjudication), New Custom House, Mumbai. Since the issues involved in all these appeals are common, they are taken up together for consideration. The appeals were heard on 28-1-2013 and 14-3-2013 and orders reserved. 2. As regards the COD application, considering that the reasons stated for the delay in filing the appeal are satisfactory, we allow the application for condonation of delay. 3. A case of overvaluation of export goods to avail undue export benefits in the form of DEPB scrips fraudulently and utilization of such fraudulently obtained DEPB scrips was investigated by the Directorate of Revenue Intelligence (DRI in short). The investigation pertained to fraudulent exports of textile fabrics made by M/s. Nidhi Textiles, M/s. Milan Exports, M/s. Madhuri Impex Pvt. Ltd., Madhuri Synthetics, M/s. Mahavir Synthetics, M/s. Laxmi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 12,35,28,476 83 3,89,68,000 2,46,89,991 3.1 On completion of investigation, show cause notices were issued to the exporters, their associates and the transferees of the DEPB/DFIA scrips. The proposal in the notices were for confiscation of export goods under Section 113 of the Customs Act, imposition of penalty on the exporters/their associates for misdeclaration of values under Section 114 of the Act, confiscation of goods imported using the transferred DEPB scrips under Section 111, demand of duty on the imported goods along with interest under Section 28 read with 28AB and imposition of penalties on the importers under Section 112/114A. The impugned orders have been passed holding the export goods liable to confiscation and imposing penalties on the exporters/their associates, confirming demand of duty with interest and imposition of penalties on the transferees of the licence who are the importers. In the case of Rajat Pharmachem, the party had approached the Settlement Commission by paying the duty liability and the case was settled. The demand is for interest from the transferees apart from imposition of penalt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s as mentioned above. Even from these statements, it is evident that from each consignment, 2 or 3 boxes were opened and after checking the quantity and description declared, the goods were allowed to be exported. Therefore, no presumption can be made for overvaluation of the goods when the goods were subject to physical scale of examination in terms of Board s circular cited supra. (iv) After exportation of the goods, foreign exchange remittances in full were received and no action has been taken against any person for the allegation that the noticee had managed the remittance. In the absence of corroborative evidences on record, no presumption can be made against such allegation. (v) It has been contended by the Revenue that as per the report received from the Consulate General of India, Dubai, vide letter dated 31-5-2009, the value of the goods declared by M/s. Nidhi Textiles was grossly overvalued that declared at the port of import, Dubai. Only 26 consignments under drawback scheme were exported to Dubai and the balance 74 consignments were exported to Sri Lanka, Jeddah and Morocco. No overvaluation has been alleged for the goods exported to these countries in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ue has been referred to Larger Bench in the case of Rainbow Silks reported in 2010 (259) E.L.T. 718. (xi) Since the export business of the appellant is stuck since long, the appellant is facing acute financial hardship and there will be undue hardship if the appellant is directed to deposit any amount. (xii) The appellant also relies on the following decisions, - Sri Balaji Traders - 2008 (230) E.L.T. 457 Advance Exports - 2007 (218) E.L.T. 39 Kanhaiya Exports - 2006 (204) E.L.T. 295 Nico Extrusions Pvt. Ltd. - 2009 (248) E.L.T. 497 4.1 The ld. Counsel for S/Shri Sanjay Kumar Agarwal and Parmanand Joshi has submitted that the orders passed against them imposing penalty was ex parte as they were not served with the show cause notice or heard by the adjudicating authority and therefore, the same are not sustainable in law. Nevertheless they take up the same arguments as adopted by M/s. Nidhi Textiles. 5. On behalf of the transferees, the ld. Counsels for the appellants made the following submissions. (i) The appellants are transferees of Licenses issued under DEPB/DFIA/Focus Market Schemes under the Foreign Trade Policy. The Licenses are endorsed as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion of India - 1990 (46) E.L.T. 527. (g) Kantilal Manilal Company v. Union of India - 1994 (69) E.L.T. 240. (h) Wearon Exports Private Limited v. Union of India - 2004 (163) E.L.T. 149 (i) CC v. Jupiter Exports - 2007 (213) E.L.T. 641. (j) Taparia Overseas P. Ltd. v. UOI - 2003 (161) E.L.T. 47 (k) Ajay Kumar Co. v. CC - 2006 (205) E.L.T. 747 upheld in 2009 (238) E.L.T. 387. (l) CC v. Patiala Castings P. Ltd. - 2012 (283) E.L.T. 269 Since a license obtained by fraud/misrepresentation is only voidable and not void it follows that if before it is avoided a third party acquires such license bona fide for value and without notice of the fraud, the rights of such third party are protected. (v) It is a settled law that if the seller of the goods had acquired the same under a voidable transaction (as distinguished from void) and such seller sells such goods to an innocent buyer who pays for the same and acquires the same without notice of any fraud by which the seller had obtained such goods, the rights of such innocent purchaser stand protected. Reliance is placed in this behalf on the following judgments : (a) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (ix) Duty ought to be demanded from the original licencee-exporter who is guilty of the fraud/misrepresentation. It is an undisputed position that the appellants were bona fide purchasers for value without notice of the alleged fraud on the part of the original licensees-exporters. The fraud, if any, has admittedly been committed by the original licensees-exporters and not by the appellants. In such circumstances, not demanding duty from the original licensees-exporters and demanding the same from the bona fide transferees would amount to placing premium on fraud and enabling the fraudsters to escape the consequences of their fraud. As laid down in Sravani Impex P. Ltd. v. Addl. Dir. General, DRI, Chennai - 2010 (252) E.L.T. 19 (AP), when the DEPB scrips have been sold to third parties, the only course open to the Customs is to demand repayment of DEPB Credit from the original licensee-exporter under Section 28 of the Customs Act, 1962. As a matter of fact in the present cases, the department has during investigations recovered part of the duty amounts from the original licensee-exporters. It is submitted that the department having powers under the law to effect recovery is in a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the said M/s. Nidhi Textiles created a maze of bogus/paper financial transactions. The said bogus financial transactions were completed by getting cheques drawn in the name of the non-existing/fictitious suppliers through and discounting the cheques issued by using the services of cheque-discounting financial brokers. (iii) The fraud is further proven by evidences collected during investigation both locally and at Dubai (through diplomatic sources) which shows that the value declared by the Dubai based importers of the said goods (i.e. M/s. AGS General Trading, Dubai M/s. Ditty Trading (LLC), Dubai and others is just a fraction (average 6.7 %) of the value declared by M/s. Nidhi Textiles at the time of export (in the Shipping Bill and related export documents) before the Indian Customs. The commission of fraud has been admitted to by Shri Rajeev Kumar Tulsyan, proprietor of the said M/s. Nidhi Textiles in his statements recorded under Section 108 of the Customs Act, 1962. Shri Tulsyan has also admitted that while remittances of the full amount for the exports made were received from overseas buyers through the banking channel, the differential amount (difference between the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rity has rightly held that the goods imported by the transferee importers in the instant case are liable to confiscation since conditions of Notification 34/97-Cus. have not been fulfilled by the importers. 6.2 Madhuri Impex and others (i) This is case of obtaining DEPB scrips fraudulently by gross misdeclaration and overvaluation and the usage of the said scrips by the Transferees for imports without payment of duty. This includes Appeal No. C/474/12 and 25 other appeals by transferees. The four export firms involved were M/s. Madhuri Impex Pvt. Ltd., M/s. Madhuri Synthetics, M/s. Mahavir Synthetics and M/s. Laxminath Exports who were engaged in export of dyed/printed man made fabrics. Shri Rajesh D. Mundra was the Director of first firm, Proprietor of second firm and looked after the affairs of remaining two firms whose proprietors were his relatives. (ii) M/s. Madhuri Impex Pvt. Ltd. had filed two shipping bills on 29-6-2009 declaring the value as ₹ 1,07,92,660 (FOB). These were detained by DRI and valuation of goods was done by an Expert Committee consisting of the members from textile trade. The Committee arrived at the value of ₹ 16,35,374 (FOB). ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ents have been relied upon have not filed any retraction in this case. 6.3 Milan Exports (i) This is the case of obtaining DEPB scrips fraudulently by gross misdeclaration and overvaluation and the usage of the said scrips by 29 Transferees for imports without payment of duty. Exporter procured low quality fabrics and prepared overvalued invoices in the name of bogus/fictitious/non-existent firms and against these purchases, the cheques in the name of such non-existent firms were also issued by M/s. Milan Exports. These cheques were not deposited but were discounted through various discounters who returned the money in cash to Shri Mohd. Aslam Mohd. Zakaria Naviwala, Authorised Signatory of M/s. Milan Exports who has admitted the same in his various statements. The total actual value for exported 98 consignments redetermined comes to ₹ 5,92,72,580/- (FOB) as against the total declared value of ₹ 21,79,28,101/- (FOB). Total 33 DEPB scrips involving DEPB credit of ₹ 1,29,05,949/- were issued to M/s. Milan Exports. Shri Mohd. Aslam Mohd. Zakaria Naviwala has admitted that they had arranged remittances in India at higher prices from foreign buyers as per th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... duty of ₹ 33,28,612/- has already been settled by the Hon ble Settlement Commission. (b) Interest is payable by M/s. C.J. Shah Company on duty amount under Section 28AB of Customs Act, 1962. (c) Penalty equal to the sum total of duty amount of ₹ 33,28,612/- and applicable interest is imposed on M/s. C.J. Shah and Company under Section 114A of Customs Act, 1962. 6.5 The ld. Addl. Commissioner (AR) relied on the following decisions in support of his contentions :- (a) Friends Trading Co. v. CC - 2011 (267) E.L.T. 57 (Tri.-Del.) affirmed by Punjab Haryana High Court - 2011 (267) E.L.T. 33 (P H) In this case, the DEPB scrips were obtained on the basis of forged/substituted shipping bills and the DEPB scrips were cancelled ab initio by the DGFT. The Tribunal observed that DEPB scheme essentially provides for an alternative mechanism to compensate for duty paid on goods used in export production. When DEPB scrips have been obtained without undertaking exports, the question of granting duty benefit by the exchequer cannot arise. Why should public revenue suffer on account of a fraud committed by someone else, just because he has succ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any benefit on the basis of DEPB scrips which were obtained by submitting forged documents and also held the goods liable for confiscation. The Tribunal observed that the taint attaching to the document on the basis of which benefit is taken is not washed of. Fraud or suppression continues if document is not genuine. As the appellant M/s. Apar Ltd. attempted to import goods under tainted documents, adjudication order imposing penalty on M/s. Apar Ltd. was upheld. (d) Dow Agrosciences India Pvt. Ltd. v. CC - 2012 (283) E.L.T. 524 (Tri.-Mumbai) In this case, the DEPB scrips were obtained on the basis of forged shipping bills and bank realization certificate. The DEPB scrips were cancelled ab initio by the DGFT. Hon ble Tribunal held that the DEPBs were not transferable without the licensing authority s endorsement of transferability under the relevant provisions of the EXIM Policy (1997-2002) issued under the FT (D R) Act, 1992. Where such endorsement was statutorily required to make the DEPB scrips/licences transferable, it could only be said that the transaction of transfer of the scrips was governed by provisions of the statute viz. the FT (D R) Act and the EXI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal observed that it is an established principle of law that fraud and justice do not dwell together. An assessee acting in defiance of law has no right to claim innocence when he fails to exercise due care and diligence. Failing to cause enquiry with the issuing authority of DEPB scrips/TRAs crippled the importer appellants to claim bona fide. Regarding the importers having settled their dispute before Settlement Commission and immunity from penalty and prosecution having been granted to them, the trader, broker and sub-broker appellants covered by those adjudications cannot be called upon to pay penalty out of same adjudication, Tribunal did not accept this plea and held that the doctrine of finality does not immune these appellants who defrauded Revenue. (g) Ram Preeti Yadav v. U.P. - AIR 2003 SC 4268 In this case, Hon ble Supreme Court held that no Court in this land will allow a person to keep an advantage which he obtained by fraud. Hon ble Supreme Court also referred to Lazarus Estate v. Berly, (1956) 1 All ER 341 in which the Court of Appeal stated the law thus : I cannot accede to this argument for a moment no Court in this land will a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... H)], forged BRCs and Shipping Bills [Apar Ltd. v. CC - 2012 (276) E.L.T. 534 Dow Agrosciences India P Ltd. v. CC - 2012 (283) E.L.T. 524], DEPB itself forged [ICI India Ltd. v. CC - 2005 (184) E.L.T. 339 Munjal Showa Ltd. v. CC - 2009 (246) E.L.T. 18 (P H)], forged Shipping Bills and BRCs [Sharman Woollen Mills Ltd. v. CC - 2011 (263) E.L.T. 136], fake/false/forged and fabricated TRAs [K.I International Ltd. v. CC - 2012 (282) E.L.T. 67]. Further appeals have been admitted in the Hon ble High Court of Bombay against the decisions of this Tribunal in the case of Apar Ltd. v. CC - 2012 (276) E.L.T. 534 Dow Agrosciences India P Ltd. v. CC - 2012 (283) E.L.T. 524. Thus as laid down by this Tribunal in Sushil Agarwal v. CC - 2012 (283) E.L.T. 377 its ratio comes into jeopardy and it is, therefore, improper and premature to rely on that decision. 7.1 In the present appeals, there is no forgery of any of the export documents. The case is one of overvaluation of export consignments. These consignments were examined by the Customs and the concerned shipping bills assessed and the Customs endorsed these shipping bills. Thereafter, the DGFT made the licences transferable. The appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he said decisions of Bombay High Court should be preferred and applied. 7.3 In any event stay should be granted where there are conflicting views. As submitted herein above, in the present case, the licenses were not obtained by submitting forged documents. Hence the decisions cited by the department do not apply. Assuming while denying that the said decisions apply in the present cases, in view of the conflicting decisions mentioned above, stay should be granted. Reliance is placed in this behalf on the following decisions in which it is held that where there are conflicting views, stay should be granted. Pratap Steel Rolling Mills Ltd. v. CEGAT - 1993 (67) E.L.T. 216 (M.P.) Binani Zinc Ltd. v. Asstt. Collr - 1995 (77) E.L.T. 514 (Ker.) M.M. Forgings v. CCE - 2009 (245) E.L.T. 701 (Tri.) Hindustan Lever Ltd. v. CCE - 2007 (219) E.L.T. 613 (Tri.) Raichur Solvents v. CCE - 1994 (74) E.L.T. 927 8. We have carefully considered the submissions made by both the sides. Both the sides have relied on a number of case laws dealing with different situations and have claimed applicability/non-applicability depending on whe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al Trading, Dubai, M/s. Ditty Trading (LLC), Dubai and others, is just a fraction (average 6.4 %) of the export values declared by M/s. Nidhi Textiles (in the Shipping Bill and related export documents) before the Indian Customs. While the value declared before the Indian Customs in respect of 39 consignments/shipping bills during the period October, 2006 to April, 2008, amounted to US $ 3009931.41, for the same consignments, the value declared by the importers in Dubai amounted to only US $ 147446, that is, 6.35% of the export value declared in India. Thus the magnitude of overvaluation has been clearly established. The commission of fraud has been admitted to by Shri Rajeev Kumar Tulsyan, Proprietor of the said M/s. Nidhi Textiles in his Statements recorded under Section 108 of the Customs Act, 1962, wherein he has explained that while remittances of the full amount for the exports made were received from overseas buyers through banking channels, the differential amount (difference between the actual and the declared value) was paid back to the local representatives of the overseas buyers in cash and the said statement has not been retracted in any legally permissible manner. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l and Mr. Parmanand Joshi that they were not heard before passing of the impugned orders and principles of natural justice has been violated. The records show that notices were sent to the addresses given and sufficient opportunities were given. If they failed in not availing of the opportunity, the mistake lies on them. When all others who were party to the notices were heard, there is no reason why these two appellants would not have been heard by the adjudicating authority. Thus the argument taken is only an alibi to escape the consequences of law. Accordingly, we reject the plea made by them in this regard. 8.4 Shri Sanjay Kumar Agarwal was the Associate of Shri Rajeev Kumar Tulsyan, Proprietor of Nidhi Textiles and he actively assisted Shri Tulsyan in his fraudulent export activities. He dealt with obtaining of export orders, dealing with brokers and appointment of CHA, etc., and he was a partner in profit. He had admitted to his active role in assisting Shri Tulsyan in procuring goods for export without bills, adjustment and manipulation of accounts to show licit purchases, falsifying records, etc. and he shared 50% of the profits with Nidhi Textiles. A penalty of ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s contention is that they have been cancelled ab initio and therefore, they cannot held to be valid and hence the transferees are liable to pay the customs duty involved in these licences along with interest thereon and are also liable to penalty. 9.1 We have to examine the above issue in the light of a catena of judicial decisions relied upon by both the sides. First we take up the cases relied upon by the appellants. 9.1.1 In the East India Commercial case, a question arose whether the infringement of a condition of the import licence would make the licence void. The Hon ble Apex Court held that - infringement of a condition in the licence not to sell the goods imported to third parties is not an infringement of the order, and therefore, the said infringement does not attract Section 167(8) of the Customs Act. Nor is there any legal basis for the contention that licence obtained by misrepresentation makes the licence non est, with the result that the goods should be deemed to have been imported without licence in contravention of the order issued under Section 3 of the Act so as to bring the case within clause (8) of Section 167 of the Sea Customs Act. Assuming that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and transferred the same to others. In the said case, it was held that - it has to be held that the imports made under the DEPB scrips, which were valid at the time of import, the subsequent cancellation of the same on the ground that original allottee procured them by fraud will not have any bearing upon the imports made by the appellant. There is nothing in the impugned order to reflect upon any mala fide on the part of the appellant or to show that he was a party to the fraudulent obtaining of the scrips by M/s. Parker or had any knowledge about the tainted character of the scrips. As such, we are of the view that the imports made by the appellant in terms of the said scrips cannot be held to be invalid. The aforesaid decision was affirmed by the Hon ble Apex Court in the same case reported in 2009 (238) E.L.T. 387 (S.C.). 9.1.6 Similarly in Leader Valves Ltd., the Hon ble Punjab Haryana High Court dealt with a case where DEPB was issued on the basis of forged Bank Realization Certificates and the licences were transferred. The transferee was not a party to the fraud and had purchased the DEPB from the open market in the bona fide belief of its being genuine. Later ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... emanded even from the transferee who had made duty free imports against the forged scrip and for this purpose, the principle of caveat emptor being applicable, longer limitation period under proviso to Section 28(1) would be applicable, while in the latter case, where the DEPB scrip had been validly issued by the DGFT, but being obtained by fraud/misdeclaration on the part of the exporter, was subsequently cancelled, the judgment of the Apex Court in the case of East India Commercial (supra) and Sneha Sales Corporation (supra) will apply and duty cannot be recovered from the transferee if before the cancellation there is no evidence showing that the transferee had not acted bona fide or was aware of the fraud committed by the original holder of the DEPB scrip. 9.1.8 Thus what emerges from the above decisions is that if licence has been obtained by fraud by the original allottee who transferred the same to others and the licences were valid at the time of imports by the transferee who bought it for a valid consideration without being aware of the fraud committed by the transferor, subsequent cancellation of the licence will not have any bearing upon the imports already made by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s from M/s. Vivek Impex Pvt. Ltd. who purchased the same from M/s. Shyam International who had purchased the same from M/s. Parker Industries. The Commissioner of Customs held that any concession availed of on the basis of DEPB scrips obtained by producing forged documents could not be retained. This view was affirmed by the Tribunal. The High Court observed that it is a settled principle of common law that a purchaser steps into shoes of the seller and does not acquire better title than the seller. This principle has also been recognized under Section 27 of the Sale of Goods Act, 1932 and accordingly demand of duty on the goods was upheld. The order of the Hon ble High Court was upheld by the Apex Court. 9.2.3 In the Dow Agrosciences India Pvt. Ltd. case, this Tribunal dealt with a situation where DEPB scrips were obtained by submitting forged shipping bills and forged BRCs. Licences were got endorsed for transferability and thereafter transferred. On detection of the fraud, the licences were cancelled ab initio. Consequently DEPB benefits were denied which was challenged before the Tribunal and the Tribunal held as follows :- The transfer of REP licences in the case of Tap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... self clearly indicated that no credit could be earned without exports. We are inclined to accept this plea and hold that the above principle was rightly invoked in this case. In this manner only, fraud on the Revenue can be made actionable. Any different view will only perpetuate the menace of fraud on the Revenue and defeat public interest. If the appellant s argument is accepted, the results will be catastrophic for the Revenue. In our view, it is to secure the revenue that the licensing authority under the FT (D R) Act has been empowered to cancel DEPBs (whether utilized or unutilized) retrospectively. The rule of law demands that the orders issued under the said provision of law be given full effect to. 9.2.4 The view that emerges from the above decisions is that a purchaser of goods cannot acquire a better title than the seller and if the statute provides for transferability by endorsement, then common law will not apply and the specific statute shall prevail. If the statute provides for retrospective cancellation, full effect will have to be given to the said provisions. Whether the DEPB itself was forged or was obtained by submission of forged documents would not make an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er for the purpose of paying import duty and when that instrument is used for paying import duty on any goods, such exporter as holder of the duty exemption certificate is holding out to be the importer for the purpose of Section 28 notwithstanding that the imported goods were not for his use. 9.4 From the above discussions, it can be seen that differing/conflicting views have been expressed on the issue of void and voidability of licenses (depending upon facts of each case) by various High Courts and various Benches of this Tribunal. The views expressed have been conflicting even in similar set of facts. There are also differing perceptions about who should pay the duty, whether it is the original licence holder or the transferor of the licences. There are also contradictory views whether extended time limit could be invoked for raising the demands, when the transferor was an innocent purchaser of the licences. In such circumstances, grant of stay against the demands made on the transferees becomes imperative. The Hon ble High Court of Madhya Pradesh in Partap Steel Rolling Mills Ltd. case held that contrary views expressed by two of the High Courts in the country is sufficient ..... X X X X Extracts X X X X X X X X Extracts X X X X
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