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TMI Blog2019 (10) TMI 1220X X X X Extracts X X X X X X X X Extracts X X X X ..... the proviso to sub-section (1) of Section 28 of Customs Act, 1962 has been correctly invoked in the present case - For this reason the penalties imposed under Section 114A of the Customs Act, 1962 are justified - it is also evident that appellants have filed/ caused to file the Bill of Entry on the basis of false or manipulated invoice for mis-declaring the value hence in our view the provision of Section 114AA to get attracted in the present case. It is true that for the act of misdeclaration the goods became liable for confiscation under section 111 (m) of the Customs Act, 1962. Further for their act of misdeclaration making the goods liable for confiscation, Appellants are liable to penalty under Section 112(a). In view of the fact that proviso in Section 114A specifically provides that if the penalty has been imposed under that section, penalty cannot be imposed under Section 112, Commissioner has not imposed any penalty on Appellant 1 on whom penalty under Section 114A has been imposed - no penalties have been imposed on the managing director and executive director of the appellant company. Imposition of redemption fine - HELD THAT:- Since the goods were not available f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h Fifteen Thousand Six Hundred Eighty only), respectively, under section 111(d) 111(m) of the Customs Act, 1962; 6.2.3 I confirm the demand of customs duty amounting to (₹ 33,44,793/- + ₹ 8,54,717/- =) ₹ 41,99,410/- (Rupees forty one lakh ninety nine thousand four hundred and ten only) on M/s I G International under the proviso to section 28(1) of the Customs Act, 1962 and order recovery forthwith; 6.2.4 I confirm the demand of interest of customs duty confirmed at para 6.2.3, on M/s I G International under the proviso to section 28A of the Customs Act, 1962 at the appropriate rates upto the date of payment of the said duty and order recovery forthwith; 6.2.5 I impose a penalty equal to an aggregate amount of the duty as shown in para 6.2.3 above and interest calculated on it at the appropriate rates upto the date of payment of said duty on M/s I G International under section 114A of the Customs Act, 1962; 6.2.6 I impose a penalty of ₹ 4,00,000/- (Rupees Four Lakhs Only) on Shri Gian Chand Arora under section 112(a) of the Customs Act, 1962. 6.2.7 I impose a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 62; and 6.3.8 I do not impose any penalty under Section 112 of the Customs Act, 1962 on M/s I G International as Section 114A clearly precluded imposition of penalty under both the sections 112 and 114A of Customs Act, 1962. 6.4 I further order appropriation of the amount of ₹ 60,00,000/- deposited by M/s I G International voluntarily towards their liabilities of duty interest,, fine and/or penalty for the clearances effected at Nhava Sheva Port and/ or Chennai Port. 6.5 This order is without prejudice to any other action and/ or further action, on the aforesaid noticees/ companies/ firms and/or on other individuals/ persons under the provisions of the Customs Act, 1962 or any other Law for the time being in force. 2.1 Appellant had imported Apples from M/s Dovex Export Co M/s Oneonta Trading Corporation through JNCH Nhava Sheva and Chennai Port, Chennai. Based on intelligence investigations were conducted by Director General Revenue Intelligence in India and USA. These investigations revealed that they had misdeclared the value of imported goods as indicated in the table below: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... HDMUNSENS1948547 02.12.06 605012 26.12.06 13892 23153 9261 210222 HDMUNSENS1958883 06.01.07 634142 22.01.07 13594 23839 10245 227316 HDMUNSENS1960714 13.01.07 648425 06.02.07 13726 23037 9311 209006 APLU098233196 20.01.07 648422 06.02.07 13377 23153 9776 219433 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alue declared to U S Customs; differential duty on the imported goods be not demanded and recovered from them by invoking extended period as per proviso to section 28(1) of the Customs Act, 1962; interest on the differential duty demanded should not be demanded in terms of Section 28AB of the Customs Act, 1962; the imported goods should be held liable for confiscation under Section 111(d) and 111(m) of the Customs Act, 1962; penalty under section 112, 114A and 114AA be not imposed on them. 2.3 Appellants had during the course of investigations deposited a sum of ₹ 60,00,000/- as a part of their differential duty liability. 2.4 Commissioner Customs (Import), Nhava Sheva was appointed as common adjudicating authority vide notification No 60/2009 Customs (NT) dated 08.06.2009, for adjudicating the cases in respect of imports made by the appellant through Chennai Port, Chennai and JNCH, Nhava Sheva. 2.5 The show cause notice has been adjudicated by the Commissioner as per the impugned order referred in para 1, supra. 2.6 Aggrieved by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ied upon by the department, are unsigned and unauthenticated documents. vii. In view of the submissions as above the contention that there has been any violation on their in the import of any of the consignments. Hence the order holding that these goods are liable to confiscation, redetermination of value and duty payable, demand for interest and penalty imposed needs to be set aside. 4.1 We have heard Ms Pooja Reddy, Advocate for the Appellants and Ms P Vinita Sekhar, Additional Commissioner, Authorized Representative for the revenue. 4.2 Arguing for the appellants while reiterating the submissions made in appeal, learned counsel submitted that The case has been made against them on the basis of unauthenticated and unsigned documents. Such unsigned and unauthenticated documents cannot have much evidentiary value as has been held by the Apex Court in case of East Punjab Trader [1997 (89) ELT 11 (SC)]. She would also rely upon the decisions as follows: Adani Exports Ltd [2009 (243) ELT 115 (TBang)]; Ramkrishna Sales Pvt Ltd [2008 (230) ELT 431 (T-Ahmd)]; ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rtner (Appellant 2) of Appellant, has in his statement recorded under Section 108 of Customs Act, 1962 has admitted about existence of two sets of invoice and also the fact two set of invoices were issued at their instance. He also admitted the fact about making the payment of total amount as per the invoice. All the documents collected through Consulate General were seen and admitted by him. It is now settled law that the statements recorded under Section 108 of Custom Act are substantial piece of evidence and need not be proved again. She relies upon following decisions in this respect. K I Pavunny [1997 (90) ELT 241 (SC)] Govindasamy Ragupathy [1998 (98) ELT 50 (Mad)] Chandra Impex Pvt Ltd [2008 (224) ELT 583 (T-Del)] Sidharth Shankar Roy {2013 (291) ELT 244 (T-Mum)] On issue of retraction she would rely upon the decision of tribunal in case of Pradeep Master Batches Pvt Ltd [2017 (348) ELT 692 (T-Mum)]. D M Mehta Bros [2017 (346) ELT 477 (T- Mum)] On burden of proof she would rely upon the decis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Invoice No E-17643/E-17652BB E-17643 BB E-17652BB Cartons Unit Price Total Cartons Unit Price Total Cartons Unit Price Total Container # HDMU5931590 Seal # 0045204 US# 1 Green CAD Anjou Pears Half Ctn 1575 15.25 24018.75 1575 5.75 905.25 US# 1 Red CAD Anjou Pears Half Ctn 630 14.25 8977.50 630 4.75 2992.50 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the appellant for clearance of the said goods. 5.3 The above facts have been admitted by Shri Gian Chand Arora (Appellant 2) partner in Appellant firm in his statement recorded under Section 108 of Customs Act, 1962, in following words: Today I am shown one letter No. CGNY/Trade/301/37/2007 dated 12.03.2008 from the Consul (Trade), Consulate General of India, New York. The details of declarations made before US Customs by three suppliers i.e. M/s. Stimilt Growers, Oneonta Trading Corporation and Dovex Export Co are enclosed with the said letter. I state that M/s. I.G. International had imported fresh apples from M/s. Dovex Export Co M/s. Oneonta Trading Corporation only. The said declarations mention name of the exporter, ultimate consignee, description, HSUSA Code, total weight, total value, carrier, vessel, filing date, export date, country, filter reference, filter ID, Exporter ID, ultimate consignee ID, line count and port. I have put my dated signature on the said letter and declaration enclosed to the letter, in token of having seen and gone through the same today. The said declarations mention the above details in r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... declaring under stated values. As our company had been importing apples from the said supplier over a period of time we used get some concessions in the value. After perusing the documents shown to me today, I admit that we had declared the USD51297 whereas the actual value was USD89311 and thus we had not declared the actual value of the consignment by USD 38014 and thereby not paid appropriate duty amounting to ₹ 8,54,614/-. Today I am also shown another letter No. CGNY/Trade/301/37/2007 dated 13.10.08 from the Consulate General of India, New York. The letter stated that the Immigration and Customs Enforcement (ICE) have forwarded various shipping documents in respect of fresh apples exported by M/s. Oneonta Trading Corporation, WS, USA to M/s. I.G. International, Chandigarh. The letter further stated that the shipping documents include copies of bills of lading, commercial invoices, packing list, certificate of origin, insurance certificate, phytosanitary certificate etc. It also stated that from the documents enclosed, it was evident that the exporter had raised two invoices, one for the actual commercial transaction and the other one for much lesser ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xport Co. and M/s. Oneonta Trading Corporation to the extent of USD 232662 which resulted in the evasion of customs duty liability voluntarily and request the same be adjusted against the above said amount of ₹ 51,79,217/- plus interest as applicable under law. I also accept the actual invoice value mentioned in the annexure as the correct transacted value for the said fifteen consignments. On being asked as to how the suppressed amount of USD 232662 was paid, I state that it was agreed with the suppliers M/s. Dovex Export Co and M/s. Oneonta Trading Corporation, that they would inform when their representative would come to collect the amount. Accordingly, their representative Mr. Steve from Dovex Export Co and Mr. Dalton came and collected the said suppressed amount in Indian currency from our office on various occasions on the dates informed by the suppliers over telephone. 5.4 It has been constantly held by the tribunal in following decisions that the evidences gathered through the Consulate General from the foreign suppliers/ Customs, are the documents recovered in terms of international agreements and treaties, and could be relied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n and the Bill of Entry is not much relevant. Under these circumstances, we find that the Commissioner was fully justified in enhancing the assessable value on the basis of the export declaration. We, therefore, uphold the duty demand of ₹ 1,57,511/- in addition to the duty already paid by the party. Best Co [2009 (239) ELT 294 (T-Del)] 6.5 A submission has been made that unsigned and unattested photocopy of a report of Italian Customs have been relied. Documents have been obtained through Govt. Agencies of other Countries in pursuance of mutual arrangements for assistance in investigation and the documents have been received through diplomatic channel. Such documents, even if they are in the form of a message cannot be ignored and can be admitted as evidence. These evidences can be taken into consideration along with other evidences in the matter and the evidentiary value of the same can be evaluated. Konia Trading Co [2006 (199) ELT 644 (T-Del)] 8. The report dated 24-7-1999 was written by an officer of the Customs Excise Department of Hong Kong in response to a request for investigative a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rried its own evidentiary value without resorting to any presumption. The contents of the said document were sufficient to establish the fact that the appellant had under-valued the goods covered by these two invoices, since the correct valuation declared before the Customs authorities of Hong Kong in respect of these two invoices as per their official record was now authentically communicated in this report. Orson Electronics Pvt Ltd [1996 (820) ELT 499 (T)] 4. The Collector, it is seen, has adopted the export declaration of value by the supplier before Japanese Customs along with the related ten invoices submitted along with the export declaration in arriving at the assessable value of the imported goods under Section 14 of Customs Act, 1962. It has been argued that no reliance can be placed thereon as it has not been disclosed as to what are the Japanese legal requirements regarding the declaration and even out of 10 invoices, 2 Japanese invoices showed prices lower than those found in the invoices submitted to the Indian Customs. As against this, it is found that the export declaration and connected invoices have been obtained by the In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ds had been compared with those in the Japanese invoices and the part numbers were found to tally. The goods are from the same manufacturer through a supplier having a common chairman with the importer. There is also no substance in the argument that the Collector erred in adding flat 11.15% for freight and insurance as it has been brought out that the freight and insurance actual percentage in the other invoices were unrealistically low. Further, the Collector had also adopted a reasonable mean percentage based on appellants invoices, much below the notional 21% proposed in the show cause notice. It is also futile to argue, in the face of Japanese investigation reports on method of pricing and the documents seized on search of appellants premises, that there has been no suppression of facts by the appellants and that hence there is no ground for invoking the longer period under proviso to Section 28 of Customs Act, 1962 for demanding duty. The Collector s order on determination of assessable value, therefore, calls for no interference. Bhitti Impex Final Order No A/85722-85723/2019 dated 12.04.2019 5.11 Two set of invoices have been recove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... details and the higher value. As per the chart prepared and submitted by M/s Delbi Fibres, it is clearly shown that even the total payment of value shown in the invoices provided by Italian Customs were made in two parts. Therefore, it is further established that the actual value shown in the invoice and documents submitted by M/s Delbi Fibres to the Italian Customs authorities is authentic and valid documents which cannot be questioned. On going through the reports submitted by the High Commission, the supplier of goods M/s Delbi Fibres in their statement have stated as follows:- (d) The supplier of the goods, M/s. Delbi Fibres SRL in their statement to Italian Customs authorities have stated as follows:- I confirm that among the clients for whom you have requested for the documentation, ..for the period requested, I held the relations ascertained by you only with individuals. Therefore, I would like to specify that I have never held any relations with CANNON INDSTRIES PVIVATE LTD , Ludhiana (India) and for the period requested, not even with VIJAY CHEMICAL WORKS . With regard to the cash collections, the money is d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as in the para 5 of the judgment, it is specifically recorded that the documents were not recovered through the officially prescribed channel and were not collected from the Customs of the concerned countries. The said para of Hon ble Apex Court Decision is reproduced below: 5.The single Technical Member, who wrote the minority judgment, however, held the view that it was not essential on the part of the Customs Officer to strictly prove the documents as required by the Evidence Act and that the authenticity of the documents, though copies, could not be doubted as they had been collected by the Collector from foreign sources and could be admitted in evidence by virtue of Section 139(ii) of the Customs Act, 1962 which permits the raising of a presumption in respect of documents received from any place outside Indian in the course of investigation of any offence alleged to have been committed by any person under the Act. The majority points out that these documents, which are photocopies, do not bear the signature either of the exporter, the forwarding agent, the stevedore or the Customs Officer. In fact, they do not bear any signature whatsoever and, therefore, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Commissioner on the statement of Shri Gian Chand Arora (Appellant 2), is also well settled by the various decisions of the Hon ble Apex Court and various other Courts as follows: K I Pavunny [1997 (90) ELT 241 (SC)] 25. It would thus be seen that there is no prohibition under the Evidence Act to rely upon the retracted confession to prove the prosecution case or to make the same basis for conviction of the accused. The practice and prudence require that the Court could examine the evidence adduced by the prosecution to find out whether there are any other facts and circumstances to corroborate the retracted confession. It is not necessary that there should be corroboration from independent evidence adduced by the prosecution to corroborate each detail contained in the confessional statement. The Court is required to examine whether the confessional statement is voluntary; in other words, whether it was not obtained by threat, duress or promise. If the Court is satisfied from the evidence that it was voluntary, then it is required to examine whether the statement is true. If the Court on examination of the evidence finds that the retra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate case when the authority thought it expedient to have the contraveners prosecuted under Section 135 etc., separate procedure of filing a complaint has been provided under the Act. By necessary implication, resort to the investigation under Chapter XII of the Code stands excluded unless during the course of the same transaction, the offences punishable under the IPC, like Section 120B etc., are involved. Generally, the evidence in support of the violation of the provisions of the Act consists in the statement given or recorded under Section 108, the recovery panchnama (mediator s report) and the oral evidence of the witnesses in proof of recovery and in connection therewith. This Court, therefore, in evaluating the evidence for proof of the offences committed under the Act has consistently been adopting the consideration in the light of the object which the Act seeks to achieve. Govindasamy Ragupathy [1998 (98) ELT 50 (Mad)] 18. Coming to the retracted confession alleged on the part of the respondent and heavily relied upon by the first appellate court to interfere with, the convincing judgment of the trial court even barely dealing with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 108 even though later retracted is a voluntary statement and was not influenced by threat, duress or inducement etc., and is true one - `Confession when retracted has to be tested under Sections 24 to 30 of Evidence Act - Burden is on the accused to prove that confession was made under threat and only if accused is able to prove that it was not voluntary then onus shifts to prove that it was made voluntary. 21. While such being the position of law, the lower court wasting much of its time in trying to establish that since there is evidence for early retraction of the confession by the accused in his application itself it decided to discard the veracity of the confession statements made by the accused in Exhibits P-6 to P-8 would go to show only its miserable misconception of law since early or delayed retraction is not at all the criterion to decide the evidentiary value of the confession statement made before a Customs Official such as one in the case in hand, especially in the light of the above decisions of the Apex Court. 22. Regarding the defence plea that under Sections 107 and 108 of the Customs Act only by a general or Speci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s not voluntary. In view that the confession statement had been allowed to be marked, the burden to prove that it was not voluntarily given by the accused but had been made to the dictation of the prosecuting officials is heavily on the accused to prove with regard to which there is not a single attempt made on the part of the accused and hence the version of the prosecution has to be relied upon in toto. D M Mehta Bros [2017 (346) ELT 477 (T-Mum)] 5.3 Shri Bhavesh Mehta, in his statement recorded under Section 108 of the Customs Act, 1962 has clearly admitted that he has merely signed the documents on behalf of M/s. D.M. Mehta Bros. and all the work relating to documentation, examination and clearance of the imported goods were undertaken by Shri Prashant Popat. There is no reason to disbelieve the statements of Shri Bhavesh Mehta even though he had subsequently retracted the same. Further, this retraction was done by means of an affidavit before a Notary and not addressed to the officer who had recorded the statement. There is no evidence brought before us that the said retraction was ever made known to the department at all. Therefor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ideration. The subsequent retraction of their statements by these two persons do not reduce the evidentiary value of their original statements for the reason that the retractions were made after a lapse of time and it was not done before the officer who had recorded the statement. The facts narrated therein were also corroborated by the partners of the CHA firm who were examined during the inquiry proceedings. The decision of the Hon ble Allahabad High Court in the case of Zaki Ishrati [2013 (291) E.L.T. 161 (All.)] is relevant and applicable in the facts of the present case. The argument of the ld. Counsel that the reliance cannot be placed on the statement recorded under Section 108 of the Customs Act in a proceeding under CHALR is clearly not tenable as in the Jasjeet Singh Marwaha case (supra), the Hon ble Apex Court in Para 15 of the judgment clearly held that - in our view a statement recorded under Section 108 of the Customs Act, 1962 by the Customs authorities is admissible in evidence and can form the sole basis for suspending CHA s licence, however, subject to the usual safeguards that is voluntary and truthful. Where the statement under Section 108 is retracted it can o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 11A(1) states that the escaped duty was the result of any conscious and deliberate wrong doing and in the order passed under Section 11A(2) there is a legally tenable finding to that effect then the provision of Section 11AC would also get attracted. The converse of this, equally true, is that in the absence of such an allegation in the notice the period for which the escaped duty may be reclaimed would be confined to one year and in the absence of such a finding in the order passed under Section 11A(2) there would be no application of the penalty provision in Section 11AC of the Act. On behalf of the assessees it was also submitted that Sections 11A and 11AC not only operate in different fields but the two provisions are also separated by time. The penalty provision of Section 11AC would come into play only after an order is passed under Section 11A(2) with the finding that the escaped duty was the result of deception by the assessee by adopting a means as indicated in Section 11AC. 19. From the aforesaid discussion it is clear that penalty under Section 11AC, as the word suggests, is punishment for an act of deliberate deception by the assessee with the in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lant company, which are not warranted in view of the foregoing. Hence, the same are set aside. As regards the demand of duty and interest, the same are also set aside in view of the cited Larger Bench decision and cited decision of the Hon ble Bombay High Court holding that payment by Cenvat credit is as good as by cash. It can be seen that no ratio has been laid down by the Tribunal that separate penalties cannot be imposed on the company and the director. In the special facts of the said case, no penalties have been imposed on the managing director and executive director of the appellant company. 9.1 Learned counsel has also relied on the decision of the Tribunal in the case of Sanghi Industries Ltd. v. CC (EP), Mumbai - 2012 (277) E.L.T. 365. In the said decision, the Tribunal has observed as follows :- 6.11 Coming to the penalty, we notice that a penalty of ₹ 1 crore has been imposed on the importer M/s. Sanghi Industries Ltd. and penalties of ₹ 20 lakhs each have been imposed on the Managing Director and Director of the appellant firm. We are of the view that separate penalties - one on the importing firm an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat in the case of M/s. Weston Components Ltd. v. Commissioner of Customs, New Delhi (supra), the goods were released to the assessee on an application made by it and on the execution of a bond by the assessee and in those circumstances, the Hon ble Apex Court held that the mere fact that the goods were released on the bond being executed would not take away the power of custom authority to levy redemption fine. A reading of the judgment/order of the Hon ble Apex Court in M/s. Weston Components Ltd. v. Commissioner of Customs, New Delhi (supra), would show that the Apex Court has taken the view that redemption fine can be imposed even in the absence of the goods as the goods were released to the appellant on an application made by it and on the appellant executing a bond. Since the goods were released on a bond the position is as if the goods were available. The ratio of the above decision cannot be understood that in all cases the goods were permitted to be cleared initially and later proceedings were taken for under-valuation or other irregularity, even then redemption fine could be imposed. We are, therefore, not inclined to accept the contention raised by the appellant on this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be good law on the point. It may be noted contextually that the dismissal, by the apex Court, of the SLP filed by M/s. Venus Enterprises did not have the effect of enhancing the precedent value of the High Court s decision in that case. 11. It is nobody s case that a binding judicial authority on the question of imposability of fine under Section 125 of the Customs Act in lieu of confiscation of goods not available for confiscation would not be applicable where the similar question arises as to whether a fine could be imposed under Rule 25 of the Central Excise Rules, 2002 (read with Section 34 of the Central Excise Act) in lieu of confiscation of excisable goods not available for confiscation. 5.9 Since appellants have short paid the duty at the time of clearance the demand for interest under Section 28AB to is justified. In case of P V Vikhe Patil SSK [2007 (215) ELT 23 (Bom)] Hon ble Bombay High Court has stated as follows: 10.So far as interest u/s. 11AB is concerned, on reference to text of Section 11AB, it is evident that there is no discretion regarding the rate of interest. Language of Section 11AB(1) is clear. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deposited the duty prior to issuance of the show cause notice, no penalties could have been imposed on them in view of the decision of Bombay High Court in case of PadamShri V V Patil SSK [2007 (215) ELT 23 (Bom)] 8.The ratio laid down in the matter of Rashtriya Ispat Nigam Ltd. v. Commissioner of Central Excise, Visakhapatnam - 2003 (161) E.L.T. 285 (Tri.-Bang.), relied upon by learned Counsel for assessee, which view was confirmed by the Hon ble the Apex Court while dismissing the appeal of the department, that in case the duty is paid before issuance of show cause notice, no penalty u/s. 11AC is imposable, was a decision of the Tribunal at Bangalore dated 13-11-2002. Taking into consideration the hierarchy of authorities under the Central Excise Act, 1944 i.e. Assessment Officer conducting enquiry and determining the duty evaded or short paid, Commissioner (Appeals) and thereafter CESTAT, it can safely be said that this was a decision regarding the non-payment of duty of the period prior to insertions by Amendment Act No. 14/2001 with effect from 11-5-2001 by which sub-sections (2A), (2B) and (2C) are inserted in the main Act. Naturally, the Explanation (1) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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