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TMI Blog2017 (5) TMI 592X X X X Extracts X X X X X X X X Extracts X X X X ..... drinks were also to be covered by aerated branded soft drinks, there was no occasion for subordinate legislative authority, i.e., the State Government, to include such products in notification under Section 6(1)(d). What is scope and ambit of Item 5 of Entry 71 as amended? - Held that: - A bare perusal of Entry 71 as above indicates that the Entry covers nonalcoholic beverages and their powders, concentrates and tablets in any form including Item No.2 contains fruit juice, fruit concentrates, fruit squash, fruit syrup and pulp and fruit cordial - the Entry of fruit juice based drinks got subsumed in the residuary entry and the amendment by S.R.O. No.119 of 2008 did not change or affect the character and content of the products which were included in Entry 71. Whether common parlance test is the only test to be applied for understanding the different entries under Section 6(1)(a) and Section 6(1)(d)? - Held that: - the Entry 2 under Section 6(1)(a) uses the word 'aerated'. This is scientific term and has been repeatedly used in different statutes including the Central Excise Tariff and different HSN codes also uses the term 'aerated'. The word 'aerated' is scientific and tech ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nes dismissed the clarification application which cannot be sustained. Whether CESTAT decision in the case of COMMISSIONER OF C. EX., BHOPAL Versus PARLE AGRO PVT. LTD. [2008 (3) TMI 67 - CESTAT NEW DELHI], has any relevance with regard to the classification of product in question? - Held that: - the CESTAT did not hold the product to be under the “aerated water” was a factor which necessitated a more deeper consideration by the High Court to find out as to whether the product is 'aerated branded soft drink' or not. The High Court in its judgment found that since the product charged with air or carbon dioxide was an aerated drink. From the manufacturing process which was on the record, it is clear that carbon dioxide to the extent of 0.6 percent was added as preservative. Technical note submitted on behalf of the appellant clearly mentioned that use of carbon dioxide was only as a preservative of 'Appy Fizz'. Whether decision and opinion of Food Safety Authorities on the product in question were relevant? - Whether the Committee of Joint Commissioners as well as the High Court has rightly discarded technical and expert opinion relied by the appellant? - Held that: - Before th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... os. 1469798 of 2016 and SLP(C) No.9467 of 2016 are between the same parties whereas Civil Appeals arising out of SLP(C) Nos.2446061 of 2016 have been filed by different appellants. Civil Appeals arising out of SLP(C) Nos. 1469798 of 2016 5. The appellantM/ s. Parle Agro (P) Ltd. is a dealer engaged in fruit juice based drink known as Appy Fizz which has obtained certificate of registration under Kerala Value Added Tax Act, 2003 (hereinafter referred to as Act, 2003 ). The appellant was classifying the product as fruit juice based drink under Entry 71 of the notification issued under Section 6(1)(d) of Act, 2003 till 2007 and was paying @ 12.5% VAT. One M/s. Trade Lines (a distributor of appellant Company) was assessed by the authorities under the Act, 2003 holding that M/s. Trade Lines is liable to pay tax @ 20% on the product. M/s. Trade Lines filed OT Revision No.114/2013 in the High Court of Kerala against the order passed by Kerala Value Added Appellate Tribunal dismissing the appeal. The High Court vide its judgment and order dated 17th November, 2014 dismissed the revision upholding the order passed by the Assessment Officer and the First Appellate Authority. Sp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eal No.7 of 2015 in the Kerala High Court. The Division Bench by its judgment and order dated 5th February, 2016 dismissed the appeal filed by the appellant upholding the order dated 6th November, 2015. A review application was also filed by the appellant to review the judgment dated 5th February, 2016 which has been dismissed on 23rd March, 2016. 7. Civil Appeals arising out of SLP(C)No.1469798 of 2016 have been filed against the aforesaid order dated 5th February, 2016 and the review order dated 23rd March, 2016 by the appellant. Civil Appeal arising out of SLP(C)No.9467 of 2016 8. The Assistant Commissioner (Assessment) and the Commissioner of Commercial Taxes have filed this appeal challenging the judgment dated 5th October, 2015 by which writ appeal filed by the Assistant Commissioner(Assessment) and another against the direction of the learned Single Judge dated 31st August, 2015 has been dismissed. Civil Appeals arising out of SLP(C)Nos.2446061 of 2016 9. M/s. We Six Traders Etc.Etc. is a dealer in fruit juices and other drinks manufactured by M/s. Parle Agro (P) Ltd. Assessment Commissioner has issued notices for assessment years 201011 to 201314 an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to pick up the certain products earlier covered under Entry 71 and place them in Schedule under Section 6, then entry 'aerated branded soft drinks, excluding soda' which earlier did not cover the said product, would also have been amended at the same time. He submits that if prior to 2007, 'Appy Fizz' could not be considered as an 'aerated branded soft drink' then there is no identifiable logic that the product would be so covered after 2007. Especially, there was no indication that the said product had been removed/ejected from Entry 71 after the amendment in 2007. 12. Further, he submits that common parlance test which has been applied by the High Court is not the correct test to determine the classification to include the product, as entries under the VAT Act are technical or scientific in nature. Soft drinks under Kerala VAT would be those drinks that are synthetic whether or not aerated. The product in question is not a synthetic product. It contains more than 10% fruit juice. It is fruit juice based drink and not covered by Section 6(1)(a). A fruit juice based drink is more akin to fruit juice than soft drink. Subclause (5) of Entry 71 covers simila ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d counsel for the respondent, further, submits that CESTAT ruling has no relevance with regard to the classification under Act, 2003, since, the CESTAT ruling considered the different headings under Central Excise Tariff Act, 1975 which is not relevant. Learned counsel submitted that under the Rules of interpretation as contained in the Act, 2003, the product being not covered with any of HSN number common parlance or commercial parlance test has rightly been applied by the High Court. Under the common parlance even if the product contained more than 10% fruit concentrate it is a soft drink as commonly known and tax liability @ 20% has rightly been imposed. 16. Learned counsel for the parties have placed reliance on various cases which shall be referred to while considering the submissions in detail. 17. We have considered the submissions made by the learned counsel for the parties and perused the records. 18. From the submissions of learned counsel for the parties and the pleadings of the parties following are the main issues which arise for consideration in these appeals: ( 1) What is interrelation between Section 6(1)(a) and Section 6(1)(d) of Act, 2003? ( 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5%. Entry 71 which is relevant for the present case as notified by the State as existing prior to amendment by the S.R.O.No.119 of 2008 is as follows: 71. Nonalcoholic beverages and their powders, concentrates and tablets including (I) aerated water, soda water, mineral water, water sold in sealed containers or pouches (ii) fruit juice, fruit concentrate, fruit squash, fruit syrup and fruit cordial [x x x] (v) other nonalcoholic beverages; not failing under any other entry in this List or in any of the Schedule. ( 1) Water not containing added sugar or other sweetening matter; [x x x] ( b) Aerated water ( 2) Water containing added sugar or other sweetening matter. 2201.10.20 (3) Fruit juices and vegetables juices, unfermented and not containing added spirit, whether or not containing added sugar of other sweetening matter 2009 (4) Fruit pulp or fruit juice based drinks 2202.90.30 (5) Soft drink concentrates (a) Sharbat 2106.90.11; (b) other 2106.90.19 (6) Beverages containing milk 2202.90.30 20. The words (iii) soft drinks of all varieties omitted by S.R.O. No. 543/2007 dated 20607 published in Kerala Extrao ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... plastic sheets] *** 20] 4. Pan Masala 2106. 90.20 22.5 5. Churna for pan 2106. 90.70 22.5 6. Pan chutney *** 22.5 7. Other manufactured tobacco and manufactured tobacco substitutes homogenized or reconstituted tobacco; tobacco extracts and essences 2403 22.5 Explanation: The Rules of Interpretation of the Schedules appended to the Schedules of this Act shall apply to the interpretation of the HSN codes mentioned in this clause. xxx xxx xxx xxx ( d) in the case of goods not falling under clause (a) or (c) at the rate of 14.5% at all points of sale of such goods within the State, Government may notify a list of goods taxable at the rate of 14.5%; 22. A legislative history of Section 6(1)(a) clearly indicates that Section 6(1)(a) always covered 'aerated branded soft drinks' excluding soda' w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onsidering the fact in issue decide whether such orders have prospective operation only. ... ... ... ... ... ... ... ... 25. We, thus, have to examine the classification of product in the light of provisions of Section 6(1)(a) and Entry 71 as existing after 1st April, 2007. Issue Nos.1 and 2 26. We consider both the issues together. According to Section 6(1) liability to pay tax shall be on the taxable turnover of every dealer as enumerated in subclause (a) to subclause (f). Subclause (a) provides that in the case of goods specified in the Second and Third Schedules tax shall be liable to be paid at the rate specified therein at all points of sale of such goods within the State. Subclause (a) further provides that in the case of goods specified in subclause (a) tax liability shall be at rate of specified in column (4). Subclause (a) contains chart which includes Sl.No., Description of goods, HSN Code and Rate of tax in percentage. The rate of tax as mentioned in in Section 6(1)(a) is 20% or more. The goods enumerated in Section 6(1)(a) are tobacco based goods, pan masala, other manufactured tobacco and manufactured tobacco substitutes. Other category co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng soda 8415 2. Air conditioners 3. Building Materials 29. The aerated branded soft drinks, excluding soda were always covered under Section 6(1)(a) and prior to 1st April, 2007 it bears HSN Code 2201.10.10. Entry 71 Item 4 also reads as fruit pulp or fruit juice based drinks with HSN Code 2202.90.20 . When fruit juice based drinks were covered under Entry 71 the State Government knew that fruit juice based drinks were not covered by Section 6(1)(a). Applicability of the power of State to issue notification under Section 6(1)(d) arises only when goods were not covered by Section 6(1)(a). Fruit juice based drinks, thus, were never treated as 'aerated branded soft drinks' which was the understanding of State of Kerala while issuing notification under Section 6(1(d). Had fruit juice based drinks were also to be covered by aerated branded soft drinks, there was no occasion for subordinate legislative authority, i.e., the State Government, to include such products in notification under Section 6(1)(d). 30. Now, we come to Entry 71 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e interpreting a commodity, if any consistency is observed between the meaning of a commodity without HSN Number and the meaning of a commodity with HSN Number, the commodity should be interpreted by including it in that entry which is having the HSN Number. 33. Applying the common parlance test, the High Court has concluded that product in question is covered by 'aerated branded soft drink'. Strictly speaking the Rule of Interpretation which is given in the Appendix to Act, 2003, are the Rules of Interpretation of Schedules that is Schedule Nos.I, II and III. Thus, for interpretation of any item in the Schedule, Rules of Interpretation as given in the Appendix are applicable. The items which fall for consideration in the present case is Item No.6(1)(a) as well as Entry 71 of S.R.O. No.119 of 2008 issued in exercise of power under Section 6(1)(d), which are the entries which are not mentioned in the Schedule. One more provision which is relevant to notice is the explanation to Section 6(1)(a). The explanation to Section 6(1) (a) provides as follows: Explanation: The 'Rules of Interpretation of the Schedules' appended to the Schedules of this Act shall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r trade understanding inapplicable to the term. While considering the aforesaid case the Court had occasion to consider several earlier cases of this Court. Following was stated in paragraphs 36,37,40,41,42, 43: 36. In deciding this question the first thing that requires to be noted is that Entry 25.15 refers specifically not only to marble but also to other calcareous stones whereas Entry 62 refers to the restricted item marble only. It does not refer to any other stones such as ecaussine, travertine or other calcareous monumental or building stone of a certain specific gravity. Therefore, on a plain reading of these two entries it is apparent that travertine, ecaussine and other calcareous monumental or building stones are not intended to be included in marble as referred to in Entry 62 of Appendix 2 as a restricted item. Moreover, the calcareous stones as mentioned in ITC Schedule has to be taken in scientific and technical sense as therein the said stone has been described as of an apparent specific gravity of 2.5 or more. Therefore, the word marble has to be interpreted, in our considered opinion, in the scientific or technical sense and not in the sense as co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that if a statute contains language which is capable of being construed in a popular sense such statute is not to be construed according to the strict or technical meaning of the language contained in it, but is to be construed in its popular sense, meaning of course, by the words popular sense , that sense which people conversant with the subject matter with which the statute is dealing would attribute to it. But if a word in its popular sense and read in an ordinary way is capable of two constructions, it is wise to adopt such a construction as is based on the assumption that Parliament merely intended to give so much power as was necessary for carrying out the objects of the Act and not to give any unnecessary powers. In other words, the construction of the words is to be adapted to the fitness of the matter of the statute. 41. The court has also referred to the observation of Fry, J. in Holt Co. v. Collyer. The observation is: If it is a word which is of a technical or scientific character then it must be construed according to that which is its primary meaning, namely, its technical or scientific meaning. Referring to the above decisions this Court ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the tariff entry and any other entry in the Tariff Schedule. 38. In the present case, the Entry 2 under Section 6(1)(a) uses the word 'aerated'. This is scientific term and has been repeatedly used in different statutes including the Central Excise Tariff and different HSN codes also uses the term 'aerated'. The word 'aerated' is scientific and technical word used under different statutes and the scientific and technical meaning of the word 'aerated' can be looked into for finding out the real import of the Entry. 39. In view of the above, we are of the opinion that common parlance and commercial parlance test was not the only test which could have been applied for interpreting the entries in items mentioned in Section 6(1)(a) and the entries which contain scientific and technical word were also to be looked into in technical and scientific meaning. Both the High Court and the Committee of Joint Commissioners discarded the evidence of technical and scientific meaning of word. The appellant has rightly relied on the technical evidence brought on the record which indicate that use of carbon dioxide to the extent of 0.6 per cent was only for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ur a sociis, is merely a rule of construction and it cannot prevail in cases where it is clear that the wider words have been deliberately used in order to make the scope of the defined word correspondingly wider. It is only where the intention of the Legislature in associating wider words with words of narrower significance is doubtful, or otherwise not clear that the present rule of construction can be usefully applied. 41. This Court in Pardeep Aggarbatti Vs. State of Punjab, 1997 (96) E.L.T. 219(S.C.), considering Entry 16 of Schedule A of Punjab General Sales Tax Act, 1948, in paragraph 9 has laid down following: 9. Entries in the Schedules of Sales tax and Excise statutes list some articles separately and some articles are grouped together. When they are grouped together, each word in the Entry draws colour from the other words therein. This is the principle of noscitur a sociis . 42. Applying the aforesaid principle of construction of 'noscitur a sociis' on Entry 71, it is clear that clause 5 of Entry 71 has to take colour and meaning from the other items included in Entry 71. Item 5 of Entry 71 uses the words similar other products not specific ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arification. The very purpose of the provision in the form of Section 94 and clothing authority with power to make different nature of considerations to conclude such issues, necessarily, show that no revisional order of this Court in an earlier proceedings could conclude the issues which could be considered in an application for clarification by the competent authority under Section 94 of the KVAT Act. 44. The order passed by the Division Bench in M/s. Trade Lines was a case of assessment of another assessee which decision was based on the materials brought on the record by the said assessee and could not have precluded the appellant from filing the application under Section 94 and when the Division Bench by its judgment of 5th October, 2015 dismissed the appeal of the Revenue, the Committee of Commissioners ought to have followed the observation given by the Division Bench in paragraph 4 quoted above. Thus, we are of the view that the judgment of the Division Bench of Kerala High Court in M/s. Trade Lines did not conclude the issue and the Committee of Commissioners was not absolved from its duty of deciding the same in accordance with the materials brought on the recor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ntaining added sugar or other sweetening matter or flavoured and second is in respect of others. Whereas Central Excise Tariff under Subheading No.2202 there are specific headings in respect of soya milk, drinks etc. As per the Central Excise Tariff, the waters; including mineral waters and aerated waters, containing added sugar or other sweetening matter or flavoured are classifiable under subheading No.2202.10. The drinks based on fruit juice are specifically classifiable under Heading No.22029020 of the Tariff. In the present case, there is no dispute regarding the contents of the product. Revenue is not disputing the certificate given by the Ministry of Food and Processing Industries, New Delhi rather they are relying it in the ground of appeal, and as per the certificate, the product in question contains 23% of apple juice, therefore, we find no infirmity in the impugned order. The appeal is dismissed. 48. The Revenue had also filed Civil Appeal No.5354 of 2008 against the order of CESTAT which was dismissed by this Court on 8th July, 2009 affirming the order of CESTAT. 49. The judgment of CESTAT and the order of the Supreme Court were specifically relied by the appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or sound mature fruit. The substances that may be added to fruit juice or pulp are water, peel oil, fruit essences and flavours, salt, sugar, invert sugar, liquid glucose, milk and other ingredients appropriate to the product and processed by heat, in an appropriate manner, before or after being sealed in a container, so as to prevent spoilage. 2. The product may contain food additives permitted in these regulations including Appendix A. The product shall conform to the microbiological requirements given in Appendix B. The product shall meet the following requirements: ( i) Total Soluble Solid (m/m) Not less than 10.0 percent ( ii) Fruit Juice content (m/m) ( a) Lime/Lemon ready to serve beverage Not less than 5.0 percent ( b) All other beverage/drink Not less than 10.0 percent ... ... ... ... 52. It is on the record that the contents of food product of 'Appy Fizz' are more than 10%. In Section 94 proceedings the appellant has filed letter of the Government of India dated 28.03.2005 containing the Subject : Opinion for the product as 'Appy Fizz' . In the letter the Government stated the following: This is with re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uct which has been licensed to be manufactured to the appellant cannot be said to be an irrelevant factor while examining the nature and contents of the product. Whether the product is an aerated branded soft drink or can be covered by residuary of clause (5) of Entry 71 is a question on which the manufacture licence, orders issued by Food Safety and Standards Authority of India were relevant facts which were although cited before the Committee of Joint Commissioners but were brushed aside relying on the Kerala High Court's order in M/s. Trade Lines. We, thus, are of the opinion that the manufacture licence dated 19th August, 2015 granted to appellant and the opinion of the Government of India, Ministry of Food Processing Industries dated 28.03.2005 were relevant for finding the nature of the product of the appellant for the purpose of classification and the Committee of Joint Commissioners as well as High Court erred in not adverting to and considering the aforesaid material. 56. The appellant has also before the Committee of Joint Commissioners produced the technical certificates. The Food Safety and Standards (Food Products Standards Food Additives) Regulations, 2011 in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an environment which will help to prevent spoilage during itself life POINT NO. 2: Technical Opinion on why the category of the product should NOT be classified under FSSA (Food Product Standards as Food additives) Regulation, 2011 chapter 2.3.30 (Carbonated Fruit beverage / drink) OR 2.10.6.1 (Carbonated Fruit beverage/drink) OR 2.10.6.1 (Carbonated Water) APPY FIZZ is not a synthetic carbonated wate APPY FIZZ contains reconstituted natural apple juice made from apple juice concentrate APPY FIZZ is thermally processed Pasteurization Thermal process is not mentioned in 2330 and 21061 APPY FIZZ are not contain artificial sweetenerscaffeine as allowed in 21061 Carbon dioxide(INS 290/E 290) is mentioned as a Packing gas/propellant/carbonating agent/preservative/foaming agent by CODEX ALIMENTATIRUs and its use is allowed as per GMP. Carbon dioxide along with other preservatives help in extending the shelf life of the product as the product is filed in PET bottles/cans and is not filled aseptically. Conclusion: In view of the above mentioned points, I am of the opinion that the APPY FIZZ is a THERMALLY PROCESSED FRUIT BEVERAGE/READY TO S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ( c) Technical expert opinion issued by Professor Dr. Uday S. Annapure dated 11.06.2015 classifying the said product as ready to serve Fruit beverage falling under the category of 02.03.2010 of FSSAI Regulation 2011 and specifically stated that Appy Fizz is not Carbonated Water. Exhibit J. ( d) Technical Note and Photographs explaining the use of impregnated Carbon Dioxide for the purpose of preservation as well as for the strengthening the wall of PET bottles due to expansion of Carbon Dioxide from inside providing the strength to wall of PET bottle during the transit so as to withstand with the handling hazards while delivering the product to remote area. Note and photocopies are enclosed herewith as Exhibit K and L Colly. ( e) Classification of the product Appy Fizz has been recognized by a legislative body of Kerala Government based on the white paper issued by empowered committed of state Finance Minister while introducing the White Paper on 17.01.2005 and has issued the Original Notification SRO 82 of 2006 dated 21.01.2006 and classified the product based on Central Excise Tariff which interalia is based on HSN at Entry no.71 Sr. No.4 as Fruit Juice Based D ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... further relevant to note that Revenue has not filed any material on the record either before the Clarification Authority or before the High Court in support of its view that product is covered under Section 6(1)(a) that is 'aerated branded soft drink'. This Court in several cases has observed that onus to prove that particular goods fall in particular tariff item is on the Revenue. In this context, in the judgment of this Court in Hindustan Ferodo Ltd. vs. Collector of Central Excise, Bombay, 1997(89) ELT 16(SC) , in paragraph 3 it was laid down: 3. It is not in dispute before us,as it cannot be, that the onus of establishing that the said rings fell within Item 22F lay upon the Revenue. The Revenue led no evidence. The onus was not discharged. Assuming therefore, that the Tribunal was right in rejecting the evidence that was produced on behalf of the appellants, the appeal should, nonetheless, have been allowed. 62. We, thus, conclude that orders of Food Safety Authority and expert opinion regarding process of manufacture relied by the appellant were relevant materials and Clarification Authority and High Court erred in law in discarding these materials. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; is a commodity which is fully covered by Item No.5 of Entry 71 as amended by S.R.O. No.119 of 2008. The High Court discarded scientific and expert opinion with regard to manufacturing process and contents of the product. The orders of Food Safety Authority were also discarded which were relevant for considering the nature and contents of product. The adjudication by CESTAT was relevant at least on the aspect that the 'Appy Fizz' is not aerated which was also discarded by the High Court as well as by the Committee of the Commissioners. In view of the aforesaid discussion, we are of the considered opinion that the appellant has successfully proved from the materials brought on the record that the product 'Appy Fizz' was required to be classified under Item No.5 of the Entry 71 as amended with tax liability at 12.5% after amendment by S.R.O. No.119 of 2008 (now at the rate of 14.5%). 64. Now, coming to the appeal arising out of SLP(C)No.9467 of 2016. The appeal has been filed by the Revenue challenging the judgment of learned Single Judge and Division Bench by which direction was issued to the Committee of the Commissioners to decide the application filed by the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ingle Judge by which order the learned Single Judge disposed of the writ petition by following orders: Accordingly, these writ petitions are disposed of in the following manner: ( i) The demand made in the above cases shall remain stayed till disposal of the appeals, on condition of the petitioners depositing 50% of the amount involved. ( ii) The petitioners are granted four weeks time to remit the amount. ( iii)The Appellate Authority shall endeavour to dispose of the appeal as expeditiously as possible. 67. The learned Single Judge has noted about the pendency of SLP(C)Nos.1469798/ 2016 in this Court where classification of the product was under challenge. By this judgment we are also disposing of the Civil Appeals arising out of SLP(C)Nos.1469714698 of 2016. Further proceedings in case of the assessee that is M/s. We Six Traders Etc.Etc. has to be, thus, concluded in accordance with our decision in Civil Appeals arising out of SLP(C)Nos.1469714698 of 2016. Any amount deposited in pursuance of the interim order of the High Court dated 14th July, 2016 shall abide by the consequential orders to be passed in the proceedings against the assessee. We, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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