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TMI Blog2022 (6) TMI 144X X X X Extracts X X X X X X X X Extracts X X X X ..... orts Pvt. Ltd. [ 2013 (12) TMI 1116 - DELHI HIGH COURT] has also been extensively considered by the co ordinate Bench in paragraph no. 2.19. Therefore, the decision of the co ordinate Bench binds us. Therefore, we respectfully following the same hold that the order passed under section 153A of the Act is not valid. Accordingly, we allow the appeal of the assessee on this ground. - ITA No. 1291/Mum/2018 & 1292/Mum/2018 - - - Dated:- 29-4-2022 - SHRI PRASHANT MAHARISHI, AM AND SHRI AMARJIT SINGH, JM Assessee by: Shri N.M. Porwal, Adv Revenue by: Shri Dr. Mahesh Akhade, CIT DR ORDER PER PRASHANT MAHARISHI, AM: 01. Both these appeals are having similar grounds and issues in these appeals which have been argued by both the parties raising similar arguments and therefore are disposed of by this common order. 02. ITA No 1291/M/2018 is filed by M/s Balaji Bullion commodities ( India) Pvt Limited for A.Y. 2009 10 against the order of The Learned Commissioner of Income tax ( A) 47, Mumbai dated 29/12/2017. 03. Grounds in ITA no. 1291/Mum/2018 are as under : 1. The order of the assessing officer is erroneous on the facts and in the law. On the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... taxable income. Looking to the facts and in the circumstances of your Appellant's case the said disallowance made by the Ld. A.O. is incorrect and invalid and ought to be deleted. 10. On the facts and in the circumstances of the case and in law, the Ld. A. O. erred in making addition of Rs.19,35,83,500/- on account of Alleged Negative Stock as taxable income. Looking to the facts and in the circumstances of your Appellant's case the said disallowance made by the Ld. A.O. is incorrect and invalid and ought to be deleted. 11. On the facts and in the circumstances of the case and in law, the Ld. A. O. erred in not allowing the Exemption under section 10AA. Looking to the facts and in the circumstances of your Appellant's case the said disallowance made by the Ld. A.O. Is incorrect and invalid and ought to be deleted. 12. In reaching to the conclusion and making the aforesaid additions / disallowances, the learned A. O. omitted to consider relevant factors, considerations, principles and evidences while he was overwhelmed, influenced and prejudiced by irrelevant considerations and factors. 13. The entire assessment is based on assumptions, pre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g a sum of Rs.15,60,000/- out of Remuneration paid to Director under section 37 of the IT Act, 1961. Looking to the facts and in the circumstances of your Appellant's case the said disallowance made by the Ld. A.O. is incorrect and invalid and ought to be deleted. 8. On the facts and in the circumstances of the case and in law, the Ld. A. O. erred in making an addition of Rs.94,05,116/- on account of Alleged Excess purchase of Platinum bar. Looking to the facts and in the circumstances of your Appellant's case, the said addition made by the Ld. A.O. is incorrect and invalid and ought to be deleted. 9. On the facts and in the circumstances of the case and in law, the Ld. A. O. erred in disallowing a Capital Loss of Rs. 2,39,82,000/-. Looking to the facts and in the circumstances of your Appellant's case the said disallowance made by the Ld. A.O. is incorrect and invalid and ought to be deleted. 10. On the facts and in the circumstances of the case and in law, the Ld. A. O. erred in disallowing Compensation paid of Rs.35,00,000/-. Looking to the facts and in the circumstances of your Appellant's case the said disallowance made by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A.O. is incorrect and invalid and ought to be rectified. 18. In reaching to the conclusion and making the aforesaid additions/ disallowances, the learned A.O. omitted to consider relevant factors, considerations, principles and evidences while he was overwhelmed, influenced and prejudiced by irrelevant considerations and factors. 19. The entire assessment is based on assumptions, presumptions, surmises and guesswork and hence bad in law and void. 20. The assessment is made in gross violation of principles of natural justice and hence bad in law and void. 21. The learned A. O. erred in imposing Interest under section 234B and 234C of the IT Act, 1961. 22. The learned A. O. erred in initiating penalty proceedings u/s. 271 (1) (c) of the Income Tax Act, 1961. 23. Any other ground or grounds as may be urged at the time of hearing. 06. Assessee in ITA No 1292 is a company engaged in trading in gold bar, gold jewellery, cut and polished diamonds in manufacturing of gold jewelry etc. For impugned assessment year assessee filed return of income on 21/9/2009 declaring a total income of ₹ 6,755,462/ . 07. Search seizure action u/s 132 (1) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s categorically held that he does not have warrant mentioning the name and address of the assessee as well as the copy of the panchnama prepared on the conclusion of the search at the premises of the assessee. He categorically stated that he has verified from his office record and h it is seen that the above documents are not available. The only material available is pertaining to the survey action u/s 133A of the act on assessee on 31/10/2009. Thereafter he referred to paragraph number 2.19 of the order wherein the coordinate bench has categorically held that there is no panchnama drawn by the revenue against the present assessee which is an admitted position. Thereafter the coordinate bench held that the search proceedings in the case of the present assessee got vitiated due to non-preparation of the panchnama in the name of the assessee which evidences conclusion of the search and which effectively decides against who the revenue has conducted search so much so actions are required to initiate assessment proceedings u/s 153A of the act for the last six years again the persons searched within the stipulated time u/s 153B of the act. He therefore referred to the finding of the coo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... milarly consequent to that such assessments were also framed for assessment year 2004 05 till assessment year 2007 08 u/s 153A of the income tax act. Assessment orders passed u/s 153A of the income tax act for assessment year 2004 05 till assessment year 2007 08 were challenged by assessee before the coordinate bench in ITA number 2183, 2184 2186/M/2013 which was decided by coordinate bench on 31/10/2016. By that order, it was held as Under:- 2.1. During hearing, the ld. counsel for the assessee, Shri Manish Sanghvi, strongly advocated that panchnama does not contain the name of the assessee for which our attention was invited to the panchnama, prepared in the name of Shri Manoj Punamiya Group , by asserting that under the Income Tax Act, 1961, there is no concept of group. It was canvassed that the inventory of accounts, books, etc, prepared on 24/12/2009, and prohibitory orders u/s 132(3) of the Act were also only in the name of Shri Manoj Punamiya alone and not the present assessee. It was clarified that the assessee has no nexus with the premises searched/surveyed by the Department. It was empathetically contended that none of the documents, claimed to be seiz ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... her was executed to the assessee nor any search was initiated against the assessee, pursuant to such warrant, and further the panchnama does not contain the name of the assessee. 2.4. We have considered the rival submissions and perused the material available on record. The facts, in brief, are that the assessee company, at the relevant time, was engaged in the business of trading/manufacturing recycled plastic grinding, recycled plastic, agglomerates, platinum bars, silver Ignots, Gold bar, Gold jewellery, cut and polish diamonds, recycled plastic granules, etc. The assessee declared income of Rs.4,325/- in its return filed on 20/10/2004, accompanied by audited statement of accounts, which was accepted by intimation u/s 143(1) of the Act dated 01/07/2005. 2.5. An action u/s 132 of the Act was carried out at the residential premises of one Shri Manoj Punamiya (in his individual/personal capacity) on 31/10/2009 and thereafter on 24/12/2009, wherein, seventeen papers, were claimed to be found and seized. The copy of panchanama along with inventory of papers, found and seized, is matter of record. Pursuant to said action, notice u/s 153A was issued on 27/12/2010. The asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) was duly prepared by the DIT(Inv.)-II, Mumbai on 31-10-2009 which carries the name of the assessee company and is placed at page 58-59 of paper book and was executed on 31-10-2009 . The said search warrant is executed on the premises Flat No. 504, Wing A, Vardhman Heights , Byculla(East), Mumbai which is residential premises of Mr Manoj B Punamia. The said search warrant carries the name of the assessee company. The said search warrant was seen by Mrs Lata Punamia on 31-10- 2009 who is wife of Mr. Manoj B. Punamia and was not director of the assessee company on the date of search . The search commences with the execution of search warrant and concludes with the drawing of Panchnama. However, we have observed that Panchnama were not drawn in the name of the assessee company as it carries the name of Manoj B. Punamia Group which are placed at paper book page 9-19. Search is a serious invasion in the life of the tax-payer and cannot be concluded in a casual manner. The Revenue has drawn search warrant in the case of the assessee company as set out above, but conclusion of the search is reflected by the Panchnama, which has not been drawn against the assessee. The Revenue has dr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income for six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made. (2) If any proceeding initiated or any order of assessment or reassessment made under sub-section (1) has been annulled in appeal or any other legal proceeding, then, notwithstanding anything contained in sub-section (1) or section 153, the assessment or reassessment relating to any assessment year which has abated under the second proviso to sub-section (1), shall stand revived with effect from the date of receipt of the order of such annulment by the 9[Principal Commissioner or Commissioner: Provided that such revival shall cease to have effect, if such order of annulment is set aside. Explanation.-For the removal of doubts, it is hereby declared that,- (i) save as otherwise provided in this section, section 153B and section 153C, all other provisions of this Act shall apply to the assessment made under this section; (ii) in an assessment or reassessment made in respect of an assessment year under this section, the tax shall be chargeable at the rate or rates as applicable to such assessment year. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made. 2.11. From the aforesaid provision, it is clear that the first requirement is valid initiation of search. The Revenue has executed warrant of authorization in the name of the assessee company on 31-10-2009 which is placed at paper book page 58-59. The panchnama was prepared in the name of Shri Manoj Punamiya Group, prohibitory order u/s 132(3) was also in the name of Shri Manoj Punamiya alone, no material was unearthed by the department linking the assessee with the premises so searched by the department and no document was seized from the flat of Shri Manoj Punamiya which belongs to the assessee company. It is also seen that the premises searched did not belong to the assessee company as the same is residential premises of Mr. Manoj B Punmia . The assessee company was also subjected to survey action u/s 133A of the Act at its business premises on 31-10-2009 simultaneously. 2.12. Now, we shall discuss certain case laws. The Hon ble Delhi High Court in the case of CIT v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m a summons under sub-section (1) of section 37 of the Indian Income-tax Act, 1922 (11 of 1922), or under sub-section (1) of section 131 of this Act, or a notice under sub-section (4) of section 22 of the Indian Income-tax Act, 1922, or under sub-section (1) of section 142 of this Act was issued to produce, or cause to be produced, any books of account or other documents has omitted or failed to produce, or cause to be produced, such books of account or other documents as required by such summons or notice, or (b) any person to whom a summons or notice as aforesaid has been or might be issued will not, or would not, produce or cause to be produced, any books of account or other documents which will be useful for, or relevant to, any proceeding under the Indian Income-tax Act, 1922 (11 of 1922), or under this Act, or (c) any person is in possession of any money, bullion, jewellery or other valuable article or thing and such money, bullion, jewellery or other valuable article or thing represents either wholly or partly income or property which has not been, or would not be, disclosed for the purposes of the Indian Income-tax Act, 1922 (11 of 1922), or this Act (hereinafte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ness; (iv) place marks of identification on any books of account or other documents or make or cause to be made extracts or copies therefrom; (v) make a note or an inventory of any such money, bullion, jewellery or other valuable article or thing : [Provided that where any building, place, vessel, vehicle or aircraft referred to in clause (i) is within the area of jurisdiction of any [Principal Chief Commissioner or] Chief Commissioner or[Principal Commissioner or] Commissioner, but such [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner has no jurisdiction over the person referred to in clause (a) or clause (b) or clause (c), then, notwithstanding anything contained in section 120, it shall be competent for him to exercise the powers under this sub-section in all cases where he has reason to believe that any delay in getting the authorisation from the [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner] having jurisdiction over such person may be prejudicial to the interests of the revenue : Provided further that where it is not possible or practicable to take physical poss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... icer may, where it is not practicable to seize any such books of account, other documents, money, bullion, jewellery or other valuable article or thing, for reasons other than those mentioned in the second proviso to sub-section (1), serve an order on the owner or the person who is in immediate possession or control thereof that he shall not remove, part with or otherwise deal with it except with the previous permission of such officer and such officer may take such steps as may be necessary for ensuring compliance with this sub- section. Explanation.-For the removal of doubts, it is hereby declared that serving of an order as aforesaid under this sub-section shall not be deemed to be seizure of such books of account, other documents, money, bullion, jewellery or other valuable article or thing under clause (iii) of sub-section (1). (4) The authorised officer may, during the course of the search or seizure, examine on oath any person who is found to be in possession or control of any books of account, documents, money, bullion, jewellery or other valuable article or thing and any statement made by such person during such examination may thereafter be used in evidence in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty days after all the proceedings under the Indian Income-tax Act, 1922 (11 of 1922), or this Act in respect of the years for which the books of account or other documents are relevant are completed. (8A) An order under sub-section (3) shall not be in force for a period exceeding sixty days from the date of the order. (9) The person from whose custody any books of account or other documents are seized under sub-section (1) or subsection (1A) may make copies thereof, or take extracts therefrom, in the presence of the authorised officer or any other person empowered by him in this behalf, at such place and time as the authorised officer may appoint in this behalf. (9A) Where the authorised officer has no jurisdiction over the person referred to in clause (a) or clause (b) or clause (c) of sub-section (1), the books of account or other documents, or any money, bullion, jewellery or other valuable article or thing (hereafter in this section and in sections 132A and 132B referred to as the assets) seized under that sub-section shall be handed over by the authorised officer to the Assessing Officer having jurisdiction over such person within a period of sixty days from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mmissioner or] Chief Commissioner or 7[Principal Commissioner or] Commissioner, in consequence of information in his possession, has reason to believe that- (a) any person to whom a summons under sub-section (1) of section 37 of the Indian Income-tax Act, 1922 (11 of 1922), or under sub-section (1) of section 131 of this Act, or a notice under sub-section (4) of section 22 of the Indian Income-tax Act, 1922, or under sub-section (1) of section 142 of this Act was issued to produce, or cause to be produced, any books of account or other documents has omitted or failed to produce, or cause to be produced, such books of account or other documents, as required by such summons or notice and the said books of account or other documents have been taken into custody by any officer or authority under any other law for the time being in force, or (b) any books of account or other documents will be useful for, or relevant to, any proceeding under the Indian Income-tax Act, 1922 (11 of 1922), or under this Act and any person to whom a summons or notice as aforesaid has been or might be issued will not, or would not, produce or cause to be produced, such books of account or other do ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ficer were substituted. 2.15. In the present appeal, valid search was not carried out against the assessee. Conduct of search proceedings is an elaborate procedure enumerated u/s 132 of the Act which in clause-I, categorically authorizes the officer to enter and search any building, place, vessel, etc, where he has reason to belief that the books of accounts, money, bullion, jewellery or things belonging to the assessee are kept. Before us, the assessee has claimed that nothing pertaining to the assessee was recovered from the premises of Shri Manoj Punamiya, searched by the Revenue. In such a situation, the decision from Hon ble jurisdictional High Court in the Case of CIT vs M/s J.M. Trading Corporation (ITA No.589 of 2009) order dated 29/06/2009, wherein, there was categorical finding by the Tribunal that initiation of search was non- compliance of the provisions of the Act. As no valid search was conducted at the premises of the assessee as the premises occupied by the assessee was not even entered upon by the search party. In that situation, the Hon ble High Court held that the search was illegal and invalid. The ratio laid down in ACIT vs M/s S.P. Cold Storage (ITA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... preceding the assessment year relevant to previous year, in which such search is conducted or requisition is made. The legislative intent is clear from the use of expression such person in section 153A(1)(a) of the Act. The expression clearly relates to a person in respect of whom search u/s 132 has been validly initiated as per section 153A itself provides. Our view find supports from Hon ble Orissa High Court in Siksha O Anusandhan vs CIT (2011) 336 ITR 112 (Orissa). The Hon ble High Court held as under:- 8. Section 132 prescribes that the competent authorities are empowered to permit the authorized officers to enter, search, break open, seize, place marks of identification and take other steps as contemplated under sub-clauses (i) to (v). However, such powers can be exercised against a person upon fulfilment of certain conditions. Firstly, the competent authority must have information in its possession and, secondly, on the basis of such information it must have reason to believe that the conditions as stipulated in sub-clauses (a), (b) and (c) of section 132(1) of the Income-tax Act, 1961 exist. Sub-clauses (a), (b) and (c) of section 132(1) speak of any person. Sea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld that it would be a futile exercise to entertain appeals where admittedly no search warrant was issued in the case of the assessees and the Tribunal held that unless a search warrant was issued, the Assessing Officer could not invoke the provisions of section 158BC of the Income-tax Act, 1961 for initiation of block assessment proceedings against the assessees. 11. Thus, we are of the view that in absence of any search warrant in the name of an assessee, search conducted in its premises is not a valid search as contemplated under section 132 of the Income-tax Act, 1961. 12. To deal with the second question, it is also necessary to examine what is contemplated in section 153A. The relevant provisions of section 153A are quoted below : 153A. Assessment in case of search or requisition.- Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a)issue notice to such person r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 132 is a pre-requisite for invoking the provisions of this Chapter. It is axiomatic that search under section 132, as contemplated has to be a valid search. An illegal search is no search and as a necessary corollary, in such a case Chapter XIV-B would have no application. In the instant case, having come to the conclusion that the search conducted was without jurisdiction and was, thus, void ab initio, the imminent consequence would be that the provisions of Chapter XIV-B could not be invoked against the respondent, pursuant to the search of his room at Chennai. Consequently, the block assessment order could not be sustained and was, accordingly, quashed. Further, ratio laid down in CIT vs Ramesh D. Patel (2014) 362 ITR 492 (Guj.), Abhay Kumar Shroff vs CIT (2007) 290 ITR 114 (Jhar.), Spacewood Furnishers Pvt Ltd. vs DGIT (2012) 340 ITR 393 (Bom.) and CIT vs Smt. Shaila Agarwal (2012) 346 ITR 130 (All.) supports the case of the assessee. The ratio laid down by Hon ble Apex Court in Union of India vs Ajit Jain 260 ITR 80(SC), CIT vs Ms. Rohini Valia 289 ITR 328 (Del.), Jindal Stainless Ltd. Vs ACIT 120 ITD 301 (Del.), Jayantilal Damjibhai Ors. Vs DIT (2008) 219 CTR 26, als ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r who authorized the search, name and addresses of two respectable persons called to witness the search, time of commencement of search and conclusion or suspension of search, list of valuables, documents etc. found as well as seized recording of statement if any person during search and mention of any restraint order or prohibitory order, are recorded in the prescribed format and such document is known as panchnama. Panchnama is prepared even if search is temporarily suspended. Panchnama is definitely prepared at the conclusion of search. In case an order under section 132(3) is passed, then the same is mentioned in the panchnama. Normally order under section 132(3) is passed in respect of a room, shop, office or an almirah or lockers etc. Such room, locker or almirah etc. is sealed. Prohibitory order under section 132(3) is in respect of a specific portion of an area or space which can be sealed and to which legal access of entry cannot be made except with the knowledge of authorized officer. When such sealed room, almirah etc. is opened again then the same is also done in the presence of two witnesses. Such proceedings are also recorded in the panchnama at the conclusion a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entory is prepared in respect of books of account or valuable articles found in the course of search but taking of or removal of such books of account or valuable article is not practicable. The authorized officer may issue a restraint order under the proviso to section 132(1). Such restraint is deemed to be a seizure as per the said proviso. Hence, in such a case, the preparation of inventory and panchnama would be relevant and any action of the authorized officer lifting the restraint order would, in our opinion, be irrelevant. The reason is that whatever the search partly was required in law to do had been done and nothing more was required. The restraint order is passed not because anything was to be done but because it was not practicable to take physical possession and remove the material to a safe place at the relevant time. As held by the Hon ble Bombay High Court in the case of CIT v. Mrs. Sandhya P. Naik [2002] 253 ITR 534, the authorized officer cannot keep the search proceedings in operation by passing a restraint order under section 132(3) so as to circumvent the provisions of section 132(3), read with section 132(5). However, the situation would be different where a p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be strictly construed as under: The counsel for the appellants are justified in their contention that the provision relating to limitation need to be strictly construed. In the case of K.M. Sharma v. ITO [2002] 254 ITR 772/122 Taxman 426 (SC), this principle is laid down in the following words: f 13. Fiscal statute, more particularly a provision such as the present one regulating period of limitation must receive strict construction. The law of limitation is intended to give certainty and finality to legal proceedings and to avoid exposure to risk of litigation to litigant for indefinite period on future unforeseen events. Proceedings, which have attained finality under existing law due to bar of limitation cannot be held to be open for revival unless the amended provision is clearly given retrospective operation so as to allow upsetting of proceedings, which had already been concluded and attained finality. 2.19. The Hon ble Delhi High Court has in the case of MDLR Resorts Private Limited v. CIT (2013) 40 taxmann.com 365(Delhi) has held the defect in the panchanama as curable and not affecting the validity of search but has also held in the said judgment as under: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ument the return of the seized articles or the removal of seals. But, the panchnama that is mentioned in Explanation 2(a) to section 158BE is a panchnama which documents the conclusion of a search. Clearly, if a panchnama does not, from the facts recorded therein, reveal that a search was at all carried out on the day to which it relates, then it would not be a panchnama relating to a search and, consequently, it would not be a panchnama of the type which finds mention in the said Explanation 2(a) to section 158 BE. Incidentally in the instant appeal , there is no panchnama drawn by the Revenue against the present assessee which is an admitted position. Keeping in view the facts and circumstances of the case, we are of considered view that the search proceedings in the case of present assessee got vitiated due to non-preparation of the panchnama in the name of the assessee which evidences conclusion of the search and which effectively decides against whom the Revenue has conducted search so much so further actions are required to initiate assessment proceedings u/s 153A of the Act for the last six years against the person so searched within the time stipulated u/s 153B of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... framed. Further, the learned Departmental Representative was specifically asked whether the order of the co ordinate Bench has been contested before the higher Forum and if not or if it is not reversed, why it should not be followed. The learned Departmental Representative merely relied upon the orders of the lower authorities. Further, the decision relied upon by the learned Departmental Representative in case of MDLR Resorts Pvt. Ltd. vs. CIT has also been extensively considered by the co ordinate Bench in paragraph no. 2.19. Therefore, the decision of the co ordinate Bench binds us. Therefore, we respectfully following the same hold that the order passed under section 153A of the Act is not valid. Accordingly, we allow the appeal of the assessee on this ground. 017. As all other grounds becomes redundant in view of the decision of the co ordinate Bench as the assessment order passed under section 153A of the Act has become invalid. Hence, those are dismissed. 018. The facts in the case of both the above appeals are identical. Therefore, ITAs no. 1291 and 1292/Mum/2018 are allowed accordingly. 019. In the result, both the appeals are allowed. Order pronounced in the o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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