Commissioner Of Income-Tax, Excess Profits Tax, Hyderabad, Andhra Pradesh v. V. Jagan Mohan Rao & Ors

726 COMMISSIONER OF INCOME-TAX, EXCESS PROFITS TAX, HYDERABAD, ANDHRA PRADESH V. JAGAN MOHAN RAO & ORS. July 31, 1969 [J.C. SHAH, ACTING C.J., V. RAMASWAMI AND A.. N. GROVER, JJ.] Indian Income-tax Act, 1922, s. 34 and s. 10(2) (xv )-Decision of Privy Council settling legal dispute-Whether constitutes 'definite infor-mation' within meaning of s. 34--Purchase of mill by assessee-Vendor's sons disputing his right to sell-Assessee paying sons a consolidated sum for release of their claims-Sum so paid whether allowable business expenditure under s. 10(2)(xv). The assessee purchased a spinning mill in 1941 from a vendor claiming to be its sole proprietor. In a suit filed by the venddr's sons the trial court had held that the suit property including the aforesaid spinning mill was the vendor's self-acquired property. When the assessee purchased the mill an appeal against the trial court's judgment was pending in the High Court. The High Court decided that the property was not the self-acquired pro-perty of the vendor but was coparcenary property in which the sons had two thirds interest. The vendor filed an appeal before the Privy Council. During its pendency the assessee entered into a compromise with the venddr's sons whereby they agreed to release their two thirds interest in the mill and its profits for a sum of Rs. 1,15,000. The compromise was certified by the High Court. In 1947 the Privy Council decided that the property including the spinuing mill was the self-acquired property of the vendor. On receipt of this decision which finally determined the rights of the parties and assessee's ownership of the mill, the Income-tax Officer issued a notice under s. 34 of the Indian Income-tax Act, 1922 for the assessment year 1944-45 and assessed the income fl;pm the mill for that year and for the two subsequent assessment years in the hands of the assessee. The assessee's objection that the decision of the Privy Council was not 'definite information' within the meaning of s. 34 was rejected as also the assessee's claim that the sum of Rs. 1,15,000 paid to the vendor's sons in pursuance of the compromise should be set off as an expense against the income from the mill for the year in question. The Appellate Assistant Commissioner and the Tribunal upheld the Income-tax Officer's order. The High Court in reference held that the notice under s. 34 was valid but that the payment of Rs. 1,15,000 was made partly towards acquisition of a capital asset and partly towards the discharge of the claim for profits and the part apportionable towards the profits was allowable as revenue expenditure. The assessee as well as the Revenue appealed to this Court. HELD : (i) In Maharaia Kumar Kamal Singh's case this Court held that the word information in s. 34( 1) (b) included information as to. the true and correct state of the law, and so would cover information as to relevant judicial decisions. It was further held that even in a case where a return had been submitted, if the Income-tax Officer had erroneously failed to tax a part of the assessable income, it was a case when that part of the income had escaped assessment. The decision of the Privy Council was therefore held to be information within the meaning of s. 34(1) (b). The principle laid down in Maharaja Kumar Kcmal Singh's case governed the present case and it must be held that the proceedings initiated under s. 34 for the assessment year 194445 were legally valid. [732 G-733 BJ 11r · A Maharaja Kuniar Kania! Singh v. Co1nn1issioner of Incon1e-tax, 35 l.T.R. !, followed and applied. Kcmakhya Narain Singh's case, 14 I.T.R. 6, referred to. — ATaST HT HAATH-HT ATTA,—SAITSTS, STH WSaT|TATA| dto WTA ASA UTA SIT PK AT . (Commissioner ofIncome Tax, Excess Profits Tax, Hyderabad, Andhra Pradesh.; OVS. V. Jagan Mohan Rao and Others) (31 qarg, 1969) (mnt ger srrenfaat Bo ato arg, Ato ato Trea IT Yo To Taz) feat genet daa daz, 1922, ater 34 wie aret 10 (2)(xv)— fates faare a7 met are fret aifeas ar fafeera—art ag eet 340 materia ‘fafeaa gaat’ (definite information) % ? —faatfeat arefart ar aa—favat & gat 8 fear att B vaw afeare a gathtfreffedt srer gat at, sah ara at stg & fee gw ahaa witet aera fear aaa Fa ware eer uf, TT 10(2)(xv)*wedla Agaa RITaeaa Z ?|| faerifedt1941 H ow fata Few Hag fra (spinning mill) aetet |feta mA aTat fet BT THATA eacaaTd aatar ar| fast F Gat arrqiza feu ae we are & fare eararaa A afafratfcs fear ar fe are-aafa| frat TyFa ware faa ot nfae 2%, faaa atenfaa acta t 1 aa fratfedta fer @aS aa fare arated } feats H fees cH ales yea eae—afeag ft) sea rararea & fafasar Pear fe dof fetar at earfta ft) sea rararea & fafasar Pear fe dof fetar at earfta rararea & fafasar Pear fe dof fetar at earfta & fafasar Pear fe dof fetar at earfta fafasar Pear fe dof fetar at earfta Pear fe dof fetar at earfta dof fetar at earfta fetar at earfta at earfta earfta dof,nat & afew vearfaat afar 2 fret qatar a-frere fea@ 1 frre a fray —afeag ft) sea rararea & fafasar Pear fe dof fetar at earfta ft) sea rararea & fafasar Pear fe dof fetar at earfta rararea & fafasar Pear fe dof fetar at earfta & fafasar Pear fe dof fetar at earfta fafasar Pear fe dof fetar at earfta Pear fe dof fetar at earfta dof fetar at earfta fetar at earfta at earfta earfta dof, MAST AT AAAT-BT AFA To Fo HTT AeA Taleo TAearat] 743 0 aifireramet ua atta ee ati sae afeaa tea H ctaa faaifedt 4fanart % gat & ara vam aaata fear frase arr F1,15,000%0at uta& faq faa Har acar al-faere fea ate cae ara sist B fae aera at ac|anatafrat fe sea cafe eararersy frat warg aren sarfue fat wt fear afaa gar) 2, 1947 famar B, at frat carina aifear aafe & fafresra 2 t ea_—fafasaa at orfer oe fart ceraret & afsarat ate fasifeat & fat & carfaesal afam eq & aaarfea fear, seer afrarads 1944-45 & fagiza ay Ffag dfeaa gaa daa Dae, 1922 at ore 34} geta cw atita ae Pear ax“ge ag aut gaa ane at faatem act & fa faa a gf ara ar fralfedt & ag aut gaa ane at faatem act & fa faa a gf ara ar fralfedt & aut gaa ane at faatem act & fa faa a gf ara ar fralfedt & gaa ane at faatem act & fa faa a gf ara ar fralfedt & ane at faatem act & fa faa a gf ara ar fralfedt & at faatem act & fa faa a gf ara ar fralfedt & faatem act & fa faa a gf ara ar fralfedt & act & fa faa a gf ara ar fralfedt & & fa faa a gf ara ar fralfedt & fa faa a gf ara ar fralfedt & faa a gf ara ar fralfedt & a gf ara ar fralfedt & gf ara ar fralfedt & ara ar fralfedt & ar fralfedt & fralfedt & &aqfaatcar fear) faetfedt at ae mofe fe frat aifee at fafasae arer34% gafeata ‘fifeaa gaan’ (definite information) a aa faaifedt atagStar fe aaale & aq F fasat & gai at daca 1,15,000 to at uate atmena agfore fer & eg ara Boag H wT A ga fear ara arfee, cesTfet Taaetos ogee (atte) ate afacer a aTaet afarth aT meaaay var| faa Heea eararaa a ufafaatfeafeat fe are 34 H gelaara atfes fafrarea &, freq 1,15,000 © ar data ama: Got aifer Hasta¥.fa site wma: anitfac ara % sentaa & faq fear qar ate arat waTas ATT UH eaT HR STH Agata art fratfeat ale used few 4at aaa & ater aT7 “ge ag aut gaa ane at faatem act & fa faa a gf ara ar fralfedt & ag aut gaa ane at faatem act & fa faa a gf ara ar fralfedt & aut gaa ane at faatem act & fa faa a gf ara ar fralfedt & gaa ane at faatem act & fa faa a gf ara ar fralfedt & ane at faatem act & fa faa a gf ara ar fralfedt & at faatem act & fa faa a gf ara ar fralfedt & faatem act & fa faa a gf ara ar fralfedt & act & fa faa a gf ara ar fralfedt & & fa faa a gf ara ar fralfedt & fa faa a gf ara ar fralfedt & faa a gf ara ar fralfedt & a gf ara ar fralfedt & gf ara ar fralfedt & ara ar fralfedt & ar fralfedt & fralfedt & & 11r · The contention that only two thirds of the income could be said to have escaped assessment because the one-third share of the vendor could have been validly assessed the Income-tax Officer on the basis of the B High Court's judgment, could not be accepted. When once valid pro-ceedings are started under s. 34(1) (b) read with s. 22(2) the previous under-assessment is set aside and the whole assessment p1:roccedings start afresh. The Income-tax Officer then has not only the jurisdiction but the duty to levy tax on the entire income that has escaped assessment in that year. [733 C-E] (ii) It is well-established that where money is paid to perfect a title c or as consideration 'for getting rid of a defect in title or a threat of litiga-tion the payment would be a capital payment and not a revenue payment. 11oney paid in consi<leration of the acquisition of a source of profit or income is capital expenditure both on principle and authority. [733 F-G] Atherton v. British Insulated and Helsby Cables Ltd. [1926] A.C. 205, 213 and Commissioner of Taxes v. Nchanga Consolidated Copper Mines Ltd. [1964] A.C. 948, referred to. D It was rrue that in the present case the High Court took into conside-ration the income from the mill in testing whether the offer made by the purchaser of Rs. 1,15,000 for the release of the claim of the plaintiffs \Vas a fair offer. But that did not mean that the sons of the vendor were· given as a result of the compromise a share in the profits of the assessee. It was clear from the circumstances of the ca1e that the payment was made by the asse·ssee in order to perfect his title to a capital ·asset, and E no portion of it could therefore could be set off against the profit. [735 CJ CIVIL APPELLATE JURISDICTION : Civil Appeals Nos. 893 to 892 and 1381 to 1386 of 1966. Appeals from the judgment and order dated December 7, 1962 of the Andhra Pradesh High Court in Case Referred No. 24 of F 1956. D. Narsaraju, P. Ramrao, K. R. Chaudhuri and K. Rajendra Chaudhuri, for the appellants (in C.As. Nos. 893 to 898 of 1966) and the respondents (in C.As. Nos. 1281 to 1386 of 1966). Jagdish Swarup, Solic;itor-General, S. K. Aiyar and R. N. Sach-they, for the respondent (in C.As. Nos. 893 to 898 of 1966) and G the appellant (in C.As. Nos. 1381 to 1386 of 1966). The Judgment of the Court was delivered by Ramaswami, J, The assessee who 1s the Kartha of a Hindu Undivided Family was assessed in that status for the relevant H assessment years, 1944-45, 1945-46, 1946-47 not only to income-tax but also to excess profits tax. On February l, 1941 he pnr-chased from Randhi Appalaswamy (hereinafter referred to as the vendor) a spinning mill known as Sri Satyanarayana Spinning (0afafaatfea—(i) aererar Hae HAT fagwat[A][ ST][ qaTAaAT][ FT][ zg]afufaatfoa feat fr arer 34 (1)(at) % ay ‘information’ (qaat) wee % ay ‘information’ (qaat) wee ay ‘information’ (qaat) wee ‘information’ (qaat) wee (qaat) wee wee He_fafr at adt alk art feafa at afeafaa & ate gafaq gat gana eariaafafasaal & are A qaaT AT areal| ag wt afafratica far sar fae 8a areasot faa facet vega at veal, afe araee afeard a fraht oe ew faa facet vega at veal, afe araee afeard a fraht oe ew facet vega at veal, afe araee afeard a fraht oe ew vega at veal, afe araee afeard a fraht oe ew at veal, afe araee afeard a fraht oe ew veal, afe araee afeard a fraht oe ew afe araee afeard a fraht oe ew araee afeard a fraht oe ew afeard a fraht oe ew a fraht oe ew fraht oe ew oe ew ewAMI yT a STA TTA st at Ae Var Aaa gia frat wear BT ag aTfratem far art & ae wat eti wa: fret aif H fafterae wT a 34 (1)(4) wateata gaat (information) afafaaited fear TAT | AIUAT FATTana fag hare & afeafas fear aaa ATA BT aE glates BIT ae_—oafafratfca fear aren arfar fir fate ay 1944-45 & fer are 34 & getmice at 1s wraatat fafa: wa at (at) % ay ‘information’ (qaat) wee % ay ‘information’ (qaat) wee ay ‘information’ (qaat) wee ‘information’ (qaat) wee (qaat) wee wee He sot faa facet vega at veal, afe araee afeard a fraht oe ew faa facet vega at veal, afe araee afeard a fraht oe ew facet vega at veal, afe araee afeard a fraht oe ew vega at veal, afe araee afeard a fraht oe ew at veal, afe araee afeard a fraht oe ew veal, afe araee afeard a fraht oe ew afe araee afeard a fraht oe ew araee afeard a fraht oe ew afeard a fraht oe ew a fraht oe ew fraht oe ew oe ew ew agian Hart waa fag ara Aras aTZaa (Maharaja Kumar KamalSingh Vs. Commissioner of Income tax) 35 WTRO zo Ito1 BT ATA.fear war aie Ba ary PRAT TAT 744 eae aTareT faorr afar [1970] 2 BAe fto qo algoTATA array fag & Aras array fag & Aras fag & Aras & Aras Aras (Kamakhya Narain Singh’s Case) 14 go ato 6 at fafase frat TAT) ato 6 at fafase frat TAT) 6 at fafase frat TAT) at fafase frat TAT) fafase frat TAT) frat TAT) TAT) TATA array fag & Aras array fag & Aras fag & Aras & Aras Aras (Kamakhya Narain Singh’s Case) 14 go ato 6 at fafase frat TAT) ato 6 at fafase frat TAT) 6 at fafase frat TAT) at fafase frat TAT) fafase frat TAT) frat TAT) TAT)oe ae seta ealare Tel al ST aad fe ais oat afar ere fawar|at un-frers aa A sea eqraraa & fagia B® avear< ox fafraraa:fratfeafear aT aaa at, gafeare Fae a-faere araartAiae ser ar awar 3fa ag faaier a BE AS J1 AT TH ATATT 22 (2) F ara afer yrer 34 (1)(at) & setts fata araaral area HC at al faa qdaa safestated Ht feat stat & ate arqal frateq-ardardl face area Ad 2 Ht feat stat & ate arqal frateq-ardardl face area Ad 2 feat stat & ate arqal frateq-ardardl face area Ad 2 stat & ate arqal frateq-ardardl face area Ad 2 & ate arqal frateq-ardardl face area Ad 2 arqal frateq-ardardl face area Ad 2 face area Ad 2 area Ad 2 Ad 2 2 aaappar satan Borata aa afastfcat a aat ¢ afew sear aden Aare ated Ht feat stat & ate arqal frateq-ardardl face area Ad 2 Ht feat stat & ate arqal frateq-ardardl face area Ad 2 feat stat & ate arqal frateq-ardardl face area Ad 2 stat & ate arqal frateq-ardardl face area Ad 2 & ate arqal frateq-ardardl face area Ad 2 arqal frateq-ardardl face area Ad 2 face area Ad 2 area Ad 2 Ad 2 2 aa fe ag ga ard ara ge HC aT aaaa at at ga ae fate agers A (ii) 48 ae aeatica & fe sat za at afeqat aaa F fac ar ew Ffrat afe at et Ht aT Yaaharsht at grat & gaa H fa wa ar dara fearamg gat dara Got dara star, tses Tar aefeat art ar aaataSoit & sfanaeaet dadast feara aie sary dat srefe agit yada aan fate geqses qe erst Ffaca fafate (Atherton7s,British Insulated and Halesby Cables Ltd.) (1926) go to 205, 213 atHT aaa aaa dat aratfeses erat aera fafate (Commissioner ofTaxes Vs. Nehanga Consolidated Copper Mines Ltd.) (1964)Uo, ao948 fafese faa 77) Mills, Rajahmundry for a sum of Rs. 54, 7 31. The purchase w~s made at a period when there was litigation between the wns of the vendor and the vendor in respect of the spinning mill and other properties. The sons had filed a suit against the father, the vendor, claiming the schedule properties including the mill as joint family properties and for partition of the same. The vendor claimed that the properties were his self-acquired properties. The District Judge, Rajahmundry held that the properties were the self-acquired properties of the vendor and dismissed the suit cf the plaintiffs. Against the judgment of the District Judge an appeal was filed in tl1e M<idras High Court, being A. S. No. J 75 of 1938. While the appeal was pending, on February 1, 194 1 the assessee purchased the mill from the vendor who purported tc ·.-:!! the same as the sole owner. In A. S. No. 175 of 1938 the Madr'" High Court held that the properties of the vendor were not hi; self-acquired properties but were joint family properties in which the plaintiffs had a two thirds share. Against this judgment the vendor preferred an appeal to the Privy Council. While that appeal was pending the assessee had submitted returns for the relevant assessment years. However, before the assessments were taken up the asscssee entered into a compromise with the plaintiffs on September 7, 1945 by virtue of which he got a release of the interest of the vendor's sons on payment of Rs. 1, 15,000. While the appeal was pending before the Privy Council the plaintiffs had applied to the High Coun for recovery of their share of the profits. The High Court appointed the assessee as the Receiver directing him to deposit the profits in the High Court. The assessec depo-sited a sum of Rs. 1,09,613 for the year 1944-45, Rs. 31,087 for the year 1945-46 and Rs. 4,775 for the year 1946-47. Under the compromise the assessec was entitled to withdraw these amount~ on payment of Rs. 1, 15,000. The Privy Council decided the appeal on July 2, 1947 reversing the order of the High Court and restoring that of the District Judge holding that Appalaswamy was the absolute owner of the mill and the sons had no right, title or interest therein. On receipt of the Privy Council's decision which finally determined the rights of the panics and the owner-ship of the assessee in the mill, the Income-tax Officer issued on March 2, 1948 a notice under s. 34 pf the Income-ta~ Act in respect of Rs. 1,09,613 received by the assessee as lease income of the mill. It was contended for the assessec (I) tha· the pro-ceedings initiated under s. 34 of the Act for the ye2. 1944-45 assessment were invalid in law as there was no new information leading to the discovery that income had escaped assessment, (2) that in any event the assessce was entitled to set c.J the sum of Rs. 1,15,000 paid to the sons of Appalaswamy under the com-promise: approv~ by. the High Cou~ .for releasing their rights. 1f any, m the mill agamst the assessee s mcome from the mill. Th~ meas gfe ada ara Hesse carraa a fra B ge aa a agea eet A fasrera fear fe ar sat are arfeal Bart at fatesfaq stag1,15,000 %o a seataar sfaa seardar fii faq gaat waae vat at fe fopat ae gat at area & Gaeaed faaifedt & anit FH assia 3 fear var at) area at ofefeafaal & ag eqee ar fe fratfedt arcwary, gait afer Te aaa BH BT ofeqat sara ¥ Ferg feat qatar atx gafaagat feet a arr at ara & a gare adt fear ot axa aT ate ae saferetra-az AAAao do WTA Aer Ta [alo wraearet] 745 fafas adtet afxatzat: 1966 at deat 893 8898 ate 1381 F 1386 are fata wate 1956 % fafase wat to 24% are sae sea earaTaT F ade7 fearat, 1962 are facta ate artefrog aha aadait So ATATY, Go WAWA, Ho AILoAta aie Ho THR AtAToe| aaterreit at site a (1966 af Fo 893% 898 ett fafa artett Ht) ote meafaat ataa(19664% do 1381 & 1386arreft farfarer arteit 3) meat at att &adel order eT, UAo Ho WaT AX(1966 at Ho 893 F 398WIto Uto aaa:areat fata adtet 4) ait<.oeatte at ate 2B||(1966 at Ho 1381 F 1386.areit fafarer ate #)a-|| raraTaa at farafafaa fata cararfirafa dro traearat A fear 1 caratfaaia Trace — faatftat ar ot ferg afaam pera @l pul %, Gara fate avi+1944-45,1945-46,1946.47 & fac ga afaaa faahua daa gaatOR fre. afer afar a fare at feat aa ari| aaa, 1941 A sadey seqerearay seqerearay(sit geet gat qa fara & wr A fafase 2) &54,731 %o at utr ¥ un wars faa (spinning mill). ater faaar arast aeraraaa feat faa, MATa ari ag wy Wa qaT qt fear qarma fe frre gat atx farar & ate wag fer ate mer araferal ataaaret FHTAT fear ar aa frat eT ag aTgalaveit A far arcfeal B fees at A ara fe far fe areataar ar, ap farae at«\ grat at, ag erat feat awar or fe A afauce Fera ay arafaat Fi arega®fara ® faq wt fear var ari fama a ag erat feat ar fe & arafaaisaat catia (self acquired) arafaat gi fat rararite, warded Fag ey seqerearay seqerearay 746 A Im:ome-tax Officer rejected these contentions and treated the whole amount of Rs. 1,15,000 as paid toward capital expenditure in acquiring an asset. The Appellate Assistant Commissioner rejected the appeal of the assessee. The Tribunal affirmed the order of the Appellate Assistant Commissioner. It held in the first place that the assessee had not disclosed the impugned source B of income from the mill in his original assessment, that the matter as to fae assessee's ownership of the mill was sub-judice and that the decision of the Privy Council constituted information not only o,f law but also as to the factum of the ownershio of the Mill and the income therefrom. The Tribunal expressed the view thnt the sum of Rs. 1,15,000 could not be allowed to be set off against the c assessee's income from the mill as it was an ex gra:ia payment to the sons of Appalaswamy who had no right, title or interest in the mill and it was paid in order to perfect a supposed defective title and as such was of capital nature. Thereafter the Income-tax Appellate Tribunal stated a case to the High Court under s. 66(2) of the In,dian Income-tax Act, 1922 on the following questions of law: "R. A. No. 779 which relates to the assessment year 1944-45: ( 1) Whether on the facts and in the circumstances of the case, in respect of the assessment year 1944-45, the, assessment made on the assessee in the status of a Hindu undivided family in respect of income received by him as Receiver could be justified notwithstanding the provisions of section 41 of the Act ? ( 2) Whether, on the facts and in the circumstances of the case, the assessment of the entire income of F Rs. 1,09,613 in the hands of the assessee is valid in the face of the compromise memo, dated 7-9-1945 approved by the Court ? ( 3) Whether, on the facts and in the circumstances of the case, the assessee is not entitled to set oJf Rs. l, 15 ,000 being the aniount paid to the minors for G releasing their rights in the prnperty from out of the amount received from the mill ? R. A. No. 780 w!)ich relates to assessment year 1945 46: Whether on the facts and in the circumstances ( n of the case, the assessment made under section 34 of the H Act is valid in law ? (2) Whether on the facts and in the circumstances of the case, in respect of the assessment year 1945-46, the assessment on the assessee in the status of a Hindu undivided family in respect of the income received by him as Receiver could be justiticd notwithslanding the provisions of Section 41 of the A ct ? (3) Whether, on the facts a .tl in the circumstance' of the case, the assessment of the entire income of Rs. 31,087 in the hands of the asses"cc i> valid in the face of the compromise memo, dated 7-9-1945 approved by the Court ? ( 4) Whether, on the facts and in the circumstances of the case, the assessee is not entitled to set oil Rs. 1, 15,000 being the amount paid to !he minors for releasing their rights in the property from out of the amoun• rec~ived from the mill ~ R.A. No. 781 which rebtcs to a-sc"mcnt year 1946-47 : ( 1) Whether, on the facts and in the .:ircumstances of the case, in respect of the assessment year I 946-47 the assessment on the assessee in the status of a Hindu undivided family in respect of income recci·1cd by him as Receiver could be justified, notwithstanding the pro-visions of section 41 of the Act ? (2) Whether, on the facts and in the circumstances of the case. the assessment of the entire income of Rs. 4,775 in the hands of the as;c"ec is valid in the face of the compromise memo, dated 7-9-1945 approved by the Court ? (3) Whether on the facts and in the circums•;mces of the case, the assessee is not entitled to set oR' Rs. 1,15,000 being the amount paid to the minors for releasing their right in the rrorerty from out or the amount received from the Mill?" 746 . afafratfea fear fe arifaat fava at carfaa arafaat % ate gaa arfeatRare at aries az fear) far caravan } facia } fase agra geaSqTaTaa HUH UR HT AT TE TT 1938 A To UA wo 175 Mt adaaa afeaa & a fe 1 wat 1941, at faatfeal & fawar & fat ata fear i> fatar a faa at gate caara carl F eTFH azar areafaa fear ary1938 @% Go Wao Fo175 F ware seq eqraraa A ae afufaifea fearfe farar at aecfaat eaisa aeafaat ad ot freq afrae afta arateot fart arfeat ar at-fagre am ariga fauta & faeg fava featHae o adit ati sa atte & afar wat & ater fasted a gaa.faatem astfag faacfaat sega ax dtot faeg faatzala area farog at fratfeet7 faaraz, 1945 at areal & ary wR aABlAT Hefat faa arse 7x GF 1,15,000 to ® Mara ae fakarh gai F fea atfaafen sree at Te1 oot ota feet aifaetFS anet aftaa gt at fa arfaatSoar Fe at ae st agel F fae seq eqrataq & wate fear|seq rararaa a faaifedt at featae F eT F fage fear ae va ariat sea marae Hoar wa wT fader fearfratftat 7 1944-45Batefry 1,09,613 %o At, 1945-46 ® at fare 31,084 eo at afte 1946-47Sat F faq 4,775 eo st uf sarees) amala ® aqarx fraifedt1,15,000 %o & dara ae gawant wt afar aa aT ewTT AT I fret aif12 Gere, 1947 at adhe or fafaway fear ate Fea ayaTATT F Aree atsare feat car fret earareite a area at searafaa we fear ax ag afafaaieafear fe aorsearat fat ar arise earat at ate gal at sar arg afear<,am at fea vat at frat atfae ar fafrrar sree att oe frase aren gerard& afrare att far a fraifedt & carfkea ar afar era gear fearwat, araaHe oafraret F 2 ars,1948 wT fret an T at we BTAfaaifedt rer srea 1,09,613 to Ht ataa, aH afafran 1961 at ater 34e att ua atfer aril feari fraifedt at ate tag aia awe fa(1) 1944-45 & ag & fratey & fac afafar a are 34 Bate greenal 1g ardtarel fafa: ware at aaifs ae ve wet att arg af araaét ot fa oma fate & ge 782; (2) wae aac A Palisa waHT SHAT AM fH ay Tea AAIAT are agatfad aaa Farrar geqarearstae gat at fart & gaa afer at, afe arg a, fay fe e faa dea1,15,000 eo at ufa at faa A & fraifedt a ora & gar a & 1 araafaard + gt sala at Tage Ht feat HIT 1,15,000 to A ay ty AAKT WT Aaa A-HT WFAA To Ato Try Alaa ela [HATo TAKA] 747 at ua sifer afaea ace A got era Aa daa cen ara fear) wees ATHyy. — (aart) F frerifeth at ata at artaR ez fear | afrae 3 TAAH AAT(atta) Bara a afaghe at | saa sera: ag afafratfer fearfr fatterant ya fata ¥ fra & ora e orafra ata at sme aet feat ar, fe.| fret & fraifedtt & earfaee ar araan errareita ar, aie ae fefrat aiferer arfafrray a Sart fafa azar (information) at afer fae # carfaes azgat at art ar at are 8 araftra gearat art afaae sag AT‘ae feat fe 1,15,000 &o at uf at fae & fraifedt at arr 2 are Telweer feat at amet ar aif ag at aerareardy & gat at fora fre F argafer, en ar fet aét a, aaaaqet dart (ex-gratia payment) aT axng dara frat safc afeqal ee at afegeh avaitfare fear mar ar akgafa ag gsiina safe at at)aerate alaae atta afsaca 4 efsaagray aga ae,1922 at mer 66(2)& ata aaa at fate & freafafadweit ox sea ara at Sfirer frat. eerser ate te 779 St frailty ag 1944-45 & arafeat x— 0) aor ane & aotovers ge ate afefeataat # Fraterat 1944-45 at arac fraffedt arer fetae Ber H ea aay% vat fag afaacs gera at QfaaaF fee ae faaica at afafrayat arer 41otaedi & HA ge wt eaalfaa seca at awa? (2) aar aaa & eat & arare oe ate ofefeafaat A fraifedtH ata 3 1,09,613 to Manca ory at frat eararaa areaaafer arte 7 faaeat,1945are aratar aaa & aA aefafaerea 8?|a|| (3) aaT amet a aol arare ae ate ofefeafiet # fraifeatga ara ar aware adi 3 fe ae fear B sea wea FF 1,15,000 koBT EAT HC T TY Vat THA Ss aT fs arafe # aanest } afaardi Afrafen & fa waaeat at dae wt TEs ?-: used. atte Fo 780 wt fratca ag 1945-46 & arated 1) arr are & aed & arare oz ae afefeafeat afefraray aren 34% ae fear var fratem fafa atgfe & wr gh 748 seaaH arate frig afzat = [1970]2 eH fito qe (2) Far arate Feat F arart oe ste afefeafaal F faateaay 1945-46 st aaa faaifed era Relat F wr F oa gra *