By Sri K v. Aravind, Advocate

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23 DAY OF FEBRUARY 2017| BEFORE THE HON’BLE MR.JUSTICE RAGHVENDRA S. CHAUHAN Writ Petition Nos.1339(1342/2017 (7(IT} Between Flipkart India Private Limited|A Company incorporated under the ©Companies Act, 1956 and validly existing |under the Companies Act, 2013.Having its office at:Vaishnavi Summit, No.6/B,.-[th]Main, 8O Feet Road,$[ra]Block, Koramangala Industrial Layout,Bengaluru-560034, Through its duly authorized signatoryMr. R. Rama Chandra....Petitione(By Sri K. G. Raghavan, Senior Counsel forsri Arun Sri Kumar, Advocate) | And 1.|The Assistant Commissioner of Income TaxCircle 3(1) (1), BMTC Building, 80 Feet Road,Koramangala, Bengaluru-S60095. «|The Principal Commissioner of Income Tax-3BMTC Building, 80 Feet Road,Koramangala,Bengaluru-S60095. 3.)The Commissioner of Income Tax (Appeals)-3BMTC Building, 80 Feet Road,Koramangala, Bengaluru-S60095. |...Respondent (By Sri K. V. Aravind, Advocate) These Writ Petitions are filed under Articles 226 & 227 of theConstitution of India praying to directions in the nature of certiorarior any other writ, order or direction of like nature to declare theimpugned Orders dated 23.11.2016 passed by the Respondent No.1.and the impugned Order in review dated 04.01.2017 passed by therespondent No.2 as null and void and hold it to be contrary to theprovisions of the Act and / or call for, examine the records in relationto and quash the impugned Orders being illegal and arbitrary. These Writ Petitions coming on for preliminary hearing in ~B’|sroup this day, the Court made the following : ORDER The petitioner has challenged the order dated 23.11.2016)(Annexure-A), passed by the Assistant Commissioner of Income,Tax, whereby the learned Assistant Commissioner has refused|to stay the collection of demand for the Assessment Year2014-15, and has directed the petitioner to deposit 15% of the|disputeddemand,amountingTORs.3,37,11,514/-|by|00.12.2016. The petitioner has also challenged another order,also dated 23.11.2016 (Annexure-B), whereby again the|learned Assistant Commissioner has refused to stay the|collection of demand for the Assessment Year 2015-16, and|has directed the petitioner to deposit 15% of the disputed|demand, amounting to Rs.22,92,02,561/- by 9.12.20106.|Lastly, the petitioner has challenged the order dated 25.1.2016, whereby the Prl.Commissioner of Income Tax (Prl. CIT’ forshort), has confirmed the order dated 23.11.2016, passed bythe Assistant Commissioner, and has directed the petitioner todeposit 15% of the total disputed demand amount within onemonth from the date of receipt of the order. 2. Briefly the facts of the case are that the petitioner is a}Private Limited Company, incorporated under the CompaniesAct, 1956. The petitioner entered the E-Commerce sector; it isengagedinter aliain the business of wholesale distribution otbooks, mobiles, media, computers, gaming consoles, and other|related accessories. The petitioner submitted its Income Tax|Return on 11.10.2014, for the Assessment Year 2014-15,wherein it declared a loss of Rs.3,58,81,84,343/-. Accordingto the petitioner, in order to enter the E-commerce sector, and|in order to secure a market, the petitioner is selling the goods|at prices lower than the purchase price. Thus, ever since the|beginning of its business in the year 2011, it has been sufferinglosses for the Assessment Years 2012-13, 2013-14, 2014-15,|and also for the Assessment Year 2015-16. 3. On 28.10.2016, the petitioner’s Income Tax Return forthe Assessment Year 2014-15 was selected for scrutiny undersection 143(2) of the Income Tax Act, 1961 (Act’ for short).Meanwhile, for the Assessment Year 2015-16, the petitionerfiled its Income Tax Return on 10.9.2015, wherein it haddeclared that again it suffered a loss of Rs.7,96,34,36,865/-.On 28.10.2016, two separate assessments orders were passed,namely for the Assessment Year 2014-15, and 2015-16. FortheAssessment|Years2014-15,aynamountOT|Rs.5,01,86,62,282/- was added, whereas, tor the AssessmentYear 2015-16, an amount of Rs.12,04,07,98,537/- was added.The balance tax payable by the petitioner was determined to beRs.28,94,96,028/- for the Assessment Year 2014-15, andRs.1,36,99,99,033/- for the Assessment Year 2015-16. Thepetitioner was directed to deposit the said amount within aperiod of thirty days. 4. Challenging both the Assessment Orders, thepetitioner filed Appeals before the Commissioner of Income Tax(Appeals) (CIT (A)’ for short). Moreover, while filing theappeals, it filed two separate applications before the learned Assistant Commissioner for keeping the demand in abeyance.However, by two orders, dated 23.11.2016, the respondentNo.1, the learned Assistant Commissioner directed thepetitioner to deposit 15% of the disputed demand amounting toRs.3,37,11,5914/- for the Assessment Year 2014-15, and todeposit Rs.22,92,02,561/- for the Assessment Year 2015-16. Oo. since the petitioner was aggrieved by both the orders|dated 23.11.2016, directing it to deposit 15% of the disputeddemand amount, it filed two Review Petitions before thePrl. CIT, respondent No.2. However, by orders dated28.11.2016 and 25.1.2017, the Prl. CIT has rejected thepetitioner’s Review Petitions, and has confirmed the orderdated 23.11.2016. Hence these petitions before this Court. 6. Mr. K. G. Raghavan, the learned Senior Counsel for|the petitioner, has raised the following contentions:-Firstly, although Section 246 of the Act, and Section|240A of the Act deal with appelable orders, neither of thesections impose any liability upon the assessee for depositingany amount before filing the appeals. The issue with regard to the amount to be deposited, and the power to stay the demandfor depositing, was dealt with by the Circular InstructionNo.1914, dated 2.2.1993 (Circular No.1914’ for short). TheCircular No.1914 deals with “Collection and Recovery of theIncome Tax“a Instruction No.2-B of Circular No.1914 alsodeals with the “stay Petitions*, which could be filed before theAssessing Officer, while an appeal is to be filed before the|Appellate Authority. Instruction No.2-C of Circular No.1914deals with the “Guidelines for staying the demand“, Accordingto the learned Senior Counsel, a decision in the matter of stay|of demand shall normally be taken by the Assessing Ofticer,|who is the immediate superior. However, a higher superiorauthority is empowered to interfere with the decision of the|Assessing Officer in certain extraneous circumstances, namely|if the assessment order appears to be “unreasonablyhighpitched7? oe °where genuine hardship is likely to be causedto the assessee”. Moreover, according to Instruction No.2-C ofCircular No.1914, certain guidelines have been provided by thesaid Circular, which clearly demarcate the circumstances in|which the stay can be granted. secondly, the Circular No.1914 was partially modified by|the Circular dated 29.2.2016. However, the Circular No.1914was never superceded, in toto, by the subsequent Circulardated 29.2.2016. The partial modification merely relates tostreamlining the process of granting stay, and for standardisingthe quantum of lumpsum payment required to be made by theassessee as a pre-condition for stay of disputed demand beforethe CIT (A). Furthermore, according to the learned SeniorCounsel, while Instruction No.4(A) in Circular dated 29.2.2016seems to prescribe the minimum percentage that would berequired to be deposited by the assessee as 19% of thedisputed demand, but Instruction Nos.4(B)(a), and 4(B)(b)|sufficient discretionary power to either ask for a higher amountthan 15%, or a lower amount than 19%, respectively. Thediscretion is bestowed upon the Assessing Officer. But, in casethe Assessing Officer were to demand less than 15%, he isrequired to seek the permission from the Prl. CIT. Moreover,according to Instruction No.4(C) of the said Circular, in casethe assessee is aggrieved by the fact that the Assessing Officerhas stayed the demand of 15% of the disputed demand should be deposited, but the assessee is still aggrieved, then theassessee would be free to approach the Prl. CIT for reviewing|the decision of the Assessing Officer. Thirdly, in the present case, by order dated 23.11.2016,the Assessing Officer had directed the petitioner to deposit15% of the disputed demand amount for the Assessment Year2014-15, and for the Assessment Year 2015-16, despite therequest of the petitioner that less than 19% of the disputeddemand amount should be required from the petitioner. Sincethe petitioner was aggrieved by both the orders dated23.11.2016, the petitioner had approached the Prl. CIT.However, without examining the inter-relationship betweenCircular No.1914, and the Circular dated 29.2.2016, the |Prl. CIT has dismissed the petition filed by the petitioner.According to the learned Senior Counsel, although the processfor granting of stay was streamlined, and standardized byCircular dated 29.2.2016, but it could not mean thatInstruction No.2-B(ii) contained in Circular No.1914, namelydealing with the situation of “unreasonably highpitcheddealing with the situation of “genuine hardship caused to the asSSCSSC”", was erased by the Circular dated 29.2.2016.Therefore, both these factors should have been considered by|both, the Assessing Officer, as well as by the Prl. CIT. Fourthly, in the orders dated 23.11.2016, the Assessing|Officer has opined that “no case of hardship exist”, the said)opinion is merely a conclusion, which unsupported by anyreason. Therefore, this part of the impugned orders dated23.11.2016 is a non-speaking order. Lastly, even the order dated 209.1.2017 is legallyunsustainable. For, the learned Prl. CIT has failed to see theinter-relationship between the two Circulars mentioned above.Further, the learned Prl. CIT has relied upon a judgment ofthis Court in the case oftM/s.Teleradiology Solutions Pvt.|D. DCITCircle-12(4)asOthers(WritPetitionNO.26370/2015, decided by this Court on 18.04.2016).But, the said judgment does not deal with the issue which wasraised before the Prl. CIT. Hence, the impugned orders deserveto be interfered with by this Court. ¢. On the other hand, Mr. K. V. Aravind, the learnedcounsel for the Revenue, has pleaded that the Circular dated29.2.2016 had superceded the Circular No.1914 in toto, as it|was later in time, and a new procedure was prescribed forstreamlining the process of granting of stay. According to him,the assessee would be entitled to deposit less than 15% of thedisputed demand amount, provided “where addition on the.same issue has been deleted by the Appellate Authorities inearlier years, or the decision of the Hon’ble Supreme Court, or ofthe jurisdictional High Court, was in favour of the assessee2?According to the learned counsel, the petitioner’s case does notfall in either of these two categories. ¢. On the other hand, Mr. K. V. Aravind, the learnedcounsel for the Revenue, has pleaded that the Circular dated29.2.2016 had superceded the Circular No.1914 in toto, as it|was later in time, and a new procedure was prescribed forstreamlining the process of granting of stay. According to him,the assessee would be entitled to deposit less than 15% of thedisputed demand amount, provided “where addition on the.same issue has been deleted by the Appellate Authorities inearlier years, or the decision of the Hon’ble Supreme Court, or ofthe jurisdictional High Court, was in favour of the assessee2?According to the learned counsel, the petitioner’s case does notfall in either of these two categories. secondly, Instruction No.4(A) of the Circular No.1914prescribes, as a general rule, that 19% of the disputed demandamount has to be deposited by an assessee. Therefore, boththe Assessing Officer, and the Prl. CIT were justified indirecting the petitioner to deposit 15% of the disputed demandamount. Thirdly, the petitioner is running a business concern. It| has neither made out any case that it is facing hardship, nor revealed any circumstance which would impose a hardshipupon the petitioner, in case it were to be asked to deposit 15%of the disputed demand amount. Thus, the learned counselhas supported the three impugned orders. 8. Heard the learned counsel for the parties, perused theimpugned orders, and considered the Circular No.1914, andthe Circular dated 29.2.2016. 9. Undoubtedly, the present case raises the issue of|balancing the interest of the Revenue, and the interest of anassessee. Needless to say, the Revenue does have the right torealise the assessed income tax amount trom the assessee.However, while trying to realise the said amount, the Revenuecannot be permitted, and has not been permitted by theCirculars mentioned above, to act like a Shylock. It is|precisely to balance the conflicting interests that certainsuidelines have been prescribed by Circular No.1914, andCircular dated 29.2.2016. 10. The Circular dated 29.2.2016 clearly states that the|circular is “in partial modification of Instruction No.19142? Therefore, the Circular dated 29.2.2016 does not supersede theCircular No.1914 in toto, but merely “partially modifies” theinstructions contained in Circular No.1914. 11. A comparative perusal of both the Circulars clearlyreveal that Circular No.1914 deals with collection and recovery|of the income tax, broadly divided into four parts: firstly|responsibility of the collection and recovery; secondly, the stay|petitions; thirdly, the guidelines for staying the demand;|fourthly, the miscellaneous provisions. In the second part,|namely the part dealing with the stay petitions, the relevant|portion of said part, marked as Instruction No.2-B(ili) is as|under : G2-B (ttt) :-- The decision in the matter of stay|of demand should normally be taken by Assessing|Officer/TRO and his immediate superior. A highersuperiorauthorityShouldinterferewiththedecision of the AO/TRO only in_ exceptionalcircumstances e.g. where the assessment orderappears to be unreasonably highpitched or wheregenuine hardship is likely to be caused to the|aASSCSSCECThehigherauthoritiesShoulddiscourage the assessee from filing review petitions: before them as a matter of routine or in a frivolousmanner to gain time for withholding payment oftaxes.” 12. The third part, marked as 2-C’, deals with)GGuidelines for staying the demand”“, This part stipulates the.conditions under which the demand can be stayed; it also dealswith certain conditions which the Assessing Officer is free to |impose upon the assessee. | 13. However, interestingly, the Circular No.1914 doesnot standardize the quantum of lumpsum payment required tobe made by the assessee, as a pre-condition of stay of disputed|demand before CIT (A). Since the Circular No.1914 is silent on |this aspect, the vacuum has been filled up by Circular dated|29..9.9O16. The relevant extract of Circular dated 29.2.2016 isas under: before them as a matter of routine or in a frivolousmanner to gain time for withholding payment oftaxes.” 12. The third part, marked as 2-C’, deals with)GGuidelines for staying the demand”“, This part stipulates the.conditions under which the demand can be stayed; it also dealswith certain conditions which the Assessing Officer is free to |impose upon the assessee. | 13. However, interestingly, the Circular No.1914 doesnot standardize the quantum of lumpsum payment required tobe made by the assessee, as a pre-condition of stay of disputed|demand before CIT (A). Since the Circular No.1914 is silent on |this aspect, the vacuum has been filled up by Circular dated|29..9.9O16. The relevant extract of Circular dated 29.2.2016 isas under: i’In order to streamline the process of)grant of stay and standardize the quantum of lumpsum payment required to be made by the assessee|as a pre-condition for stay of demand disputed|before CIT (A), the following modified guidelines are| being issued in partial modification of InstructionNo. 1914: (A) In a case where the outstanding demand is.disputed before CIT (A), the assessing officer shallgrant stay of demand till disposal offirst appeal on|payment of 15% of the disputed demand, unless|the case falls in the category discussed in para (B)hereunder.| (B) In a situation where, (a) the assessing officer is of the viewthat the nature of addition resulting inthe disputed demand is such _ thapayment of a lump sum amount higher|than 15% is warranted (e.g. in a casewhere addition on the same issue has|been|confirmedbyappellateauthorities in earlier years or the|decision of the Supreme Court orjurisdictional High Court is in favour ofRevenue or addition is based onscredible evidence collected in asearchor survey operation, etc.) or, (b) the assessing officer is of the viewthat the nature of addition resulting inthe disputed demand is such that payment of a lump sum amount lower|than 15% is warranted (e.g. in a casewhere addition on the same issue has|been deleted by appellate authoritiesin earlier years or the decision of thesupreme Court or jurisdictional HighCourt is in favour of the assessee,|etc.), the assessing officer shall refer|the matter|tothe administrativePr.CIT/ CIT, who after considering allrelevant|factsShall|decidethequantum/proportion of demand to be|paid by the assessee as lump sum|payment for granting a stay of the|balance demand. (C) In a case where stay of demand is granted by|the assessing officer on payment of 15% of the|disputed demand and the assessee is Stillaggrieved, he may approach the jurisdictionaladministrative Pr.CIT/CIT for a review of thedecision of the assessing officer. (D) The assessing officer shall dispose of a staypetition within 2 weeks offiling of the petition. If a}reference has been made to Pr.CIT/ CIT under para4 (B) above or a review petition has been filed bythe assessee under para 4 (C) above, the same Shall also be disposed of by the Pr.CIT/CIT within|2 weeks of the assessing officer making such|reference or the assessee filing such review, as thecase may be. (E) In granting stay, the Assessing Officer may.impose such conditions as he may think fit. Hemay, inter alia,- (i) require an undertaking from the|assessee that he wul cooperate in the|early disposal of appeal failing which|the stay order will be cancelled; (uw) reserve the right review the order|passed after expiry of reasonable|period (say 6 months) or yy theassessee has not co-operated in the|early disposal of appeal, or where a|subsequentpronouncementbyahigher appellate authority or Court|alters the above situations; (ui) reserve the right to adjust refunds|arising, if any, against the demand, to|the extent of the amount required forgranting stay and subject to. theprovisions of section 245.” (E) In granting stay, the Assessing Officer may.impose such conditions as he may think fit. Hemay, inter alia,- (i) require an undertaking from the|assessee that he wul cooperate in the|early disposal of appeal failing which|the stay order will be cancelled; (uw) reserve the right review the order|passed after expiry of reasonable|period (say 6 months) or yy theassessee has not co-operated in the|early disposal of appeal, or where a|subsequentpronouncementbyahigher appellate authority or Court|alters the above situations; (ui) reserve the right to adjust refunds|arising, if any, against the demand, to|the extent of the amount required forgranting stay and subject to. theprovisions of section 245.” 14. Instruction No.4 uses the words “|partial modificationof Instruction No.1914*. Thus, obviously Circular dated29.2.2016 has leit Instruction No.2-B(iii) contained in Circular|No.1914 absolutely untouched. In fact, Circular dated29.2.2016 merely prescribed the percentage of the disputeddemand that needs to be deposited by the assessee. 15. According to Instruction No.4(A) of Circular dated|29.2.2016, it is a general rule, that 19% of the disputeddemand should be asked to be deposited. But, according toInstruction No.4(B)(a) of the Circular dated 29.2.2016, thedemand can be increased to more than 19%; according toInstruction No.4(B)(b) of the Circular dated 29.2.2016, thepercentage can be lower than 15%, provided the permission ofthe Prl. CIT is sought by the Assessing Officer. However, incase the Assessing Officer does not seek the permission fromthe Prl.CIT, and in case the assessee is aggrieved by thedemand of 15% to be deposited, the assessee is free toindependently approach the Prl. CIT. The assessee would be free to request the Pri. CIT to make the percentage of disputeddemand amount to be less than 15%. 16. It is true that Instruction No.4 (B)(b) of the Circular|dated 29.2.2016, gives two instances where less than 19% canbe asked to be deposited. However, it is equally true that thefactors, which were directed to be kept in mind both by theAssessing Officer, and by the higher superior authority,contained in Instruction No.2-B(ii) of Circular No.1914,_ still|continue to exist. For, as noted above, the said part of Circular|No.1914 has been left untouched by the Circular dated29.2.2016. Therefore, while dealing with an application filed|by an assessee, both the Assessing Officer, and the Prl. CIT,|are required to see if the assessee’s case would fall underInstruction No.2-B(iii) of Circular No.1914, or not? Both the|Assessing Officer, and the Prl. CIT, are required to examinewhether the assessment is “unreasonably highpitched2? ”. whether the demand for depositing 195% of the disputeddemand amount “would lead to a genuine hardship being|caused to the assessee” or not? 17. A bare perusal of the two orders, both dated23.11.2016, Annexures-A’ and “B’, clearly reveal that theAssessing Officer has relied upon Instruction No.4(B)(b) of the|Circular dated 29.2.2016, and has concluded that since thepetitioner’s case does not fall within the two illustrations giventherein, therefore, it is not entitled to seek the relief that less|than 15% should be demanded to be deposited by it. Moreover,the Assessing Officer has jumped to the conclusion that thepetitioner’s finances do not indicate any hardship in this case.However, the Assessing Officer has not given a single reason fordrawing the said conclusion. Since the petitioner has beenconstantly claiming that it has suffered loss from the veryinception of its business, from 2011 to 2016, the least that theAssessing Officer was required to do was to elaborately discussas to whether “genuine hardship” would be caused to the}petitioner in case the petitioner were directed to pay 19% of thedisputed demand amount or not? Yet the Assessing Officer hasfailed to do so. Therefore, this part of the order, naturally,|suffers from being a non-speaking order. Hence, the said|orders are legally unsustainable. 18. A bare perusal of the order dated 25.1.2017 alsoreveals that the Prl. CIT has failed to appreciate the co-relationbetween Circular No.1914, and Circular dated 29.2.2016. ThePrl. CIT has tailed to notice the fact that the latter Circular hasonly “partially modified“ the former Circular, and has not.totally superceded it. The Prl. CIT has also ignored the factthat Instruction No.2-B(iii) contained in Circular No.1914continues to exist independently of and in spite of the Circular|dated 29.22.2016. Therefore, it has failed to consider the issuewhetherthe.assessmentorders suffers{rom|beingGunreasonably highpitched”, or whether “any genuine hardshipwould be cqused to the assessee” in case the assessee were|required to deposit 15% of the disputed demand amount ornot? Thus, the Prl. CIT has failed to apply the two importantfactors mentioned in Circular No.1914. 19. Most curiously, the Prl. CIT has relied upon the case of|M/s.Teleradiology Solutions Pvt. Ltd.,(supra), withoutrealizing that the issue whether an assessee can be directed topay 1o% of the disputed demand amount, and under what|circumstances he can be so directed, and under what circumstances less than 15% of the disputed demand amountcould be asked for, these issues were not even involved in thecase oftM/s.Teleradiology Solutions Put. Ltd.,(supra).Despite the fact that totally different issues were raised in thesaid case, the Prl. CIT has blindly applied the order passed inthe said case to the present case. Considering the fact thatthis blind appreciation of a precedent is a frequent occurrence,in catena of cases, the Hon’ble Supreme Court has clearlyopined that a judgment should not be read as a provision oflaw. A judgment is confined to the facts and circumstances ofits own case. It is only when the facts and circumstances intwo cases are similar that the ratio of the former case becomesapplicable to the latter case. But without realizing this aspectof rule otfstare decisis,the Prl. CIT has erred in applying theTeaSON»ngiveninM/s.TeleradiologySolutionsPut.Ltd.,(supra). Therefore, even the impugned order dated|29.1.2017 is legally unsustainable. 20. Mr. K. G. Raghavan, the learned Senior Counsel for|the petitioner, has also pleaded before this Court that anotheranxiety and the pain of the petitioner is that, despite the fact| that appeals have been filed against the Assessment Orderdealing with Assessment Year 2012-13, and 2013-14, they arestill pending before respondent No.3; the respondent No.3 is |yet to decide the appeals. The learned Senior Counsel submitsthat the issues in the said appeals are similar to the issuesthat have been raised by the petitioner in the present appeals,VIS-GQ-VI, Assessment Year 2014-15, and 2015-16. Since the|legal issues are the same, since the appeals of the subsequentassessment years can easily be decided if the appeals of theprevious assessment years were to be decided, the learnedsenior Counsel seeks directions from this Court to respondentNo.3 to decide the appeals of the Assessment Year 2012-13,and 2013-14, within a limited time frame.| 21. To this request made by the learned Senior Counsel,the learned counsel for the Revenue submits that respondentNo.3 is over-burdened with large number of appeals to bedecided. Therefore, a limited time frame should not be imposedupon the respondent No.3 by this Court. Therefore, the learned counsel opposes the prayer made by the learned SeniorCounsel. 22. Needless to say, appeals cannot be Kept in an)animated suspension over a long period of time. Keeping anyappeal pending will adversely affect not only the interest of theassessee, but also adversely affects the interest of the Revenue,and, therefore, of the nation at large. Thus, it will be in the|interest of justice if the appeals filed by the petitioner for the|Assessment Year 2012-13, and 2013-14 were to be decided asexpeditiously as possible by respondent No.3. learned counsel opposes the prayer made by the learned SeniorCounsel. 22. Needless to say, appeals cannot be Kept in an)animated suspension over a long period of time. Keeping anyappeal pending will adversely affect not only the interest of theassessee, but also adversely affects the interest of the Revenue,and, therefore, of the nation at large. Thus, it will be in the|interest of justice if the appeals filed by the petitioner for the|Assessment Year 2012-13, and 2013-14 were to be decided asexpeditiously as possible by respondent No.3. 23. For the reasons stated above, this Writ Petition is,hereby,allowed.The twin orders dated 23.11.2016, and the|order dated 25.1.2017, are set aside. The case is remandedback to the Prl. CIT to again decide the Review Petitions filed bythe petitioner. 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