Commissioner Of Income-Tax, West Bengal v. Allahabad Bank Limited

722 COMMISSIONER OF INCOME-TAX, WEST BENGAL ALLAHABAD BANK LIMITED February 14, 1969 [J.C. SHAH, V. RAMASWAMI AND A. N. GROVER, JJ.] Finance Acts, 1956 ant( 1951-Explanation to Paragraph D of Part JI-Definition 'of 'share prtmium account'; whether such account liable to be included in the paid-up-capital for computing rebate of super tax-i! to qualify for inclusion it is sufficient if ii is an identifiable separate account within the reserves--Companies Act, 1956, •· 78 (3) r.w.s. 78(1) -Effect of. In proceedings for assessment to tax for each of the assessment years 1956-57 and 1957-58, the Income Tax Officer reduced the rebate in super-tax admissible to the respondent under the Finance Acts of 1956 and 1957 on the view that the respondent bank, which was a public limited company, had distributed dividends exceeding 6% of its paid-up-capital. In reducing the rebate the Income Tax Officer excluded an amount re-presenting share premium received by the company. The Appellate Assistant Commissioner held that the company's share premium was liable to be added to its capital in computing the reduction in the rebate in super-tax and directed modification of the order of assessment The Appellate Tribunal in appeal, as well as the High Court, on a reference, agreed with this view. In the appeal to this Court, it was contended on behalf of the appellant that the amount representing share premium was not to be added to the share caJ)ital because ( 1) the expression "share premium account" in the definition of ''paid-up capital" in the Explanation to Paragraph D of Part II of the Finance Acts of 1956 and 1957 means an account apart from the rP.Sel'ves maintained by the company; and ( 2) in view of the proVi-sions of s. 78 (3) read withs. 78(1) of the Companies Act, 1956, the respondent company was bound to maintain a separate share premium account outside the reserves and to transfer the share premium into that accow1t which the -respondent company had failed to do. HEW : A share premium account is liable to bti included in the pai<1-u1> capital for the purpose of computing rebate if it is maintained as a separate account. But the Explanation to paragraph D of Part II of the Finance Acts of 1956 and 1957 does not contemplate that the account must be kept apart from the reserves. If within the reserves it is an identifiable separate account, the share premium will qualify for inclusion in the paid-up capital. [~28 HJ Although Uhder the Companies Act 1 of 1956 there was an express provision that the share p'remium a¢ount shall be maintained· in a sepa-rate account and by virtue of Sch. VI of the Act the share premium has to be shown in the balance sheet under the head "Liabilities" as part of the share capital and not of reserves, on that account it cannot be assum· ed t.hat if the share premium is maint.ained as a separate account within .the reserves, reduction in the rebate in super-tax is liable to be computed after excluding share premium. [728 CJ In any event with respect to tbe assessment year 1956-57 the .<:ompany was being assessed to tax for the previous year of the company ending on C,I.T. v. ALLAHABAD BANI: (Shah. I.) A December, 1955, when the Companies Act of 1956 was not in for~. During that period the eompany was governed by Act 7 of 1913 which contained no provision analogous to s. 78. of the 1956 Act. (727 C-DJ C1v1L APPELLATE JURISDICTION: Civil Appeals Nos. 701 and 702 of 1968. Appeals from the · judgments and orders dated December B I 7, 1963 and April 6, 1965 of the Calcutta High Court in. Income-tax References Nos. 87 of 1960 and 30 of 1962 respecuvely. S. T. Desai, S. C. Manchanda and B. D. Sharma, for the appellants (in both the appeals). Sachin Chaudhuri, Sukumar Mitra and D. N, Mukherjee, c for the respondent (in both the appeals) . The Judgment of the Court was delivered by HAH saad, aaaATTSATAso ‘SaTetate FH=~ fataes (Commissioner of Income-tax, West Bengal Allahabad Bank Limited)_ (10 weatt, 1969) (FaTo Ho Ato Ae, ato TWaeareat Iz U0 Uo Taz) faa afafran, 1956 ate fae fetta, 1957—art 24 AT[a] eTeasdtertu—‘share premium account’ (sa sitfiaa Bat) at afeareat;aa ta Sa at afrar at free at aaa wet F fg aarectt Tait A|afrafea feat ot are g—amt aftatod fag art & for gan alga ata|% fag amt cata 8 fe ag arial & orate ow aa gan Sat|g—arrtt afafran, 1956 at arer78(1) & ara aise are 78 (3)TART TAT||| 1956-57 WIZ 1957-58 H et UH fratea as F far ae & faster aartatientF arree atiaax a faa afefrar, 1956 atx fra afafram, 1957e adit meaat al aaa afeaeF faeat ga gfe& aq at fear fe genetaa 3, i fe un ata fafats aeott 8, aodt aaree Got & ae wfrea B aftearaia at farefeat ati fae ay we wea A aaa ofhay F egal arcgrea sit fwan afsa wea are cae at wvataa at fear ata agamgm * ag atafratfee fear fe weadt & aie iifaaa at afeax A fete ataul at aaa aa aae gaat Get FH sitet ara aT ate ag free fear fefrafey ata A sorafea frat are1 ater H acter afewey 4 gar freefeu aA It Sea eATaTAT A ea wa A agate wae TTI Sa aaa Hae BLA IT aad? at wit a ag acta a ag feam sifaang afaa wea are can ia ist H ad HIS) oat A aah (1) factafaftan, 1956 att faa ufafaay,1957 4 at 2acy ® eqettacay Aamradt gat at afearer Hsin Afsan Far’ qe B tar er afada Foeraat arer vet 7g arefafaat & fued Z, ga (2) wert afafaaa, 1956 atara78(1)aa ofet ser 78 (3) % sqaeat at afte & yeaa seaarcfataat a wat oe gee ae fkan wer cea ait ain Sifean at va weqo oats wea & far ateq ot freq geaelf weadl & ter aay frat ufafratica—ag sifsan tar at fae at area eza & sataa Fe facwareT Tait H afeafaa fear at aware afe wa gam war H eq F ca aa@| feeq faa afafaan, 1956atx fa afefran, 1957 a 2 ® 4aaTITS F ag Zena al g fe war arefefaal & fae war sar arfzcate arefataat # wat ae cm afiaa yam wer 2 at ae sifase aadquit Ho aftafad far aa & faw size Zitat mafa arqdt afafran,1956 (1956 #1) & afiaca tar afacqadvrara fear age fe am sifaaa war gaa wer} wT F car mua Wieafatraa at aaqaTBH ATaTT IT TeAATA H Ha TfAAT H ‘abilities’ (arfaedi)wig e mele aa ost Fant F eT HR a fH oarefafaat F wo F eta fearaTstat Tl Sa BRUT ag arcane wal BT aT aad fH afk am stfrad aarfafaat & Wat gay war F eT A war mare a afar dH fae Fr artat aaa aa sifran et agatsa at FH owas oT aa BI faateay FG 1956-57 H taryFH arqdi qe fearax, 1955 at, wa fHaerdt afafaaa, 1956 sae azt ar, aareea at ary qa ag & fau ax fraifeafear at tar ar) se prerafe % eter Heady gz eftera arodig daz, 1913(1913 &1 7) ay ear ar faae seq afafara, 1956 Ft ae 78 H age atssraeq qat aT| fafas aitet afsatitar: 1968 at Wo 701 aie 702 aret fafa adtet| BAM:1960 % Fo87 Att1962 # Ho 30 ara araar faemal FPAPA Boa eTaTATFH arta17 fearax, 1963 wie 6 ata, 1965 arafaatal att areal & fees ate| FATTfauta earatfrafaSo ato mre + fear | ~aTatfacia ate—- qarerare ta fates un cite fafaes aeaat 2 1 gata aaa oe aToat aarea aa gait 30,50,000 ead at at faaa at ot aTMiT Bay gait &fart ft parecdt 2 1 sara, 1954 a qa stfmaaoe ae ard feu & age aadwT H sree sitfiras car 45,50,000 we at 1 1955 site 1956 B at cH Ferag Ft Hrqdl F araia FH eH 5,49,000 wad ar face fear| 1956-57 Att 1957-58 F ex cH fratem ay & fa fratey artarfeatH+ qrant aifeax * fra afafran, 1956 Falta agate afsac at fae 761,000 wy ga gfe & wa ax feu fe arctt A godt aarae gat B aeosfema & afar arate ar faaeq fear ar| fae ae aa A oraae orfHat Ameget aret area sit Afra st 45,50,000 eat at cam aefeaad aret area sit Afra st 45,50,000 eat at cam aefeaad area sit Afra st 45,50,000 eat at cam aefeaad sit Afra st 45,50,000 eat at cam aefeaad Afra st 45,50,000 eat at cam aefeaad st 45,50,000 eat at cam aefeaad 45,50,000 eat at cam aefeaad eat at cam aefeaad at cam aefeaad cam aefeaad aefeaadaia aera age A ae afatraifes fear fie wea H sit Pfear aAafar at fede al wat Bt ATA HLT TAT 30,50,000 wat at Gait FY GSTSTAT aT sit ag fate fear fe frat aaa at sorafea fear sre1 aterafaatay + adler aera aged & agua wae AT Shah, J. The Allahabad Bank Ltd. is a public limited com-pany. The paid-up share capital of the Company other than capital entitled to a dividend at .t fixed rate was at the relevant time Rs. 30,50,00U The Company had issued· before January l, D 1954, shares at premium and the premium received in cash ag-gregated to Rs. 45,5(\000. In each of the account years 1955 and 1956 the Company distributed Rs. 5,49,000 as dividend. In proceedings for assessment for each of the assessment years 1956-57 and 1957-:i8 the Incom~-tax Officer reduced by Rs. 61,000 the rebate in super-tax admissible under the Finance E Acts 1956 on the view that the Company had distributed dividend exceeding 6% of its paid-up capital. In reducing the rebate the Income-tax Officer did not take into consideration share premium amounting to Rs. 45,50,000 received by the Company. The Appellate Assistant Commiss10ner held that the Com-pany's share premium was liable to be added to the capital of F Rs. 30,50,000 in computin~ the reduction in the rebate in super-tax, and directed modification of the order of assessment. The Appellate Tribunal agreed with the Appellate Assistant Com-missioner. The Tribunal then submitted a statement of the case and sub-mitted the following question in respect of the year 1956-57 to 0 the High Court of Calcutta : "Whether on the facts and in the circumstances of the case, the ainount of Rs. 4S,50,000 should be added to the paid-up capital of the assessee as on 1st January, 1955, for the purpose of allowing rebate to the assessee under Paragraph D of Part II of the First Schedule to H the Indian Finance Act, 1956." A similar question relating to the assessment year 1957-58 was also referred by the Tribunal. The High Court of Ca[1]·•1tta agreed with the. Tribunal and held that in determining the reduction in rebate in super-tax admissible to the Company the share premium maintained by the ·Company within the reserves was liable to be included in the paid-up capital. The Finance Act, 1956 prescribed the rate of super-tax in Part II. Paragraph D (in so far as it is relevant) enacted : "In the case of every company- capital, not being dividends payable at a fixed rate- at the rate of two annas per rupee at the rate of three annas per rupee; on that part of the said dividends which exceeds 6 per cent but does not exceed 10 per cent of the paid-up capital; on that part of the said dividends which exceeds 10 per cent of the paid-up capital; Provided further that of this Explanation :-For the Purposes of Paragraph D Part- ( i) the expression "paid-up capital" means the paid-up capital (other than capital entitled to a divi-dend at a fixed rate) of the Company as on the D first day of the previous year relevant to the assessment for the year ending on 31st day of March, 1957, increased by any premiums receiv-ed in cash by the company on the issue of its shares, standing to the credit of the share pre-mium account as on the first day of the prevmus year " In the Finance Act of 1957 also a similar scheme of granting rebate of super-tax and reduction therein in the conditions set out in the Act, was adopted. (ii) meget aret area sit Afra st 45,50,000 eat at cam aefeaad aret area sit Afra st 45,50,000 eat at cam aefeaad area sit Afra st 45,50,000 eat at cam aefeaad sit Afra st 45,50,000 eat at cam aefeaad Afra st 45,50,000 eat at cam aefeaad st 45,50,000 eat at cam aefeaad 45,50,000 eat at cam aefeaad eat at cam aefeaad at cam aefeaad cam aefeaad aefeaadfro sae ora afracer e araearfare”sega featate saTHT STaaTaTery FT 1956-57 ae & arace F freafefas set fafese fot Cay ATAemt six ofefeafratATAT 45,50,000 waa atwan at areata fact afafaam, 1956 at cam gga & art 2 Fag& ata fratfedl a fede agara wea ® satorare fratfcd at varectgait H Ha fie ae 1 saath, 1955 aT A, sitetara arfar 1” afaace y frat ag1957-58 & araeg HF aah ware ar cH ate Tet ATfafzse fear at HaHe seq eararaaFX afanca a aaafa sae atosc ag afafraticr frat fe wert at agi afeec F fees at at armaaan wt Fo arefafsatB ax seal sre <a ae aa Mfsad Ht TATgett afeerfere frat afeerfere frat fratsaaTaT. gett afeerfere frat afeerfere frat fratsaaTaT faa afafran, 1956 % wit 2 # afer at ax fafea at we 2) argH (sat ah aa Gara 2) ag afafrafaa fear vot 3 *In the case of every company— RateOn the whole of total incomeSix annas and nine pies in rupee. Provided that-— (i) a rebate at the rate of five annas per rupee of the totalincome shall be allowed in the case of any company which— (a) in respect of its profitsliable to tax under theIncome-tax Act for the year ending on the 3lst day ofMarch,1957, has made the prescribed arrangements forthe declaration and payment within the territory of Indiaof the dividends payable out of such profits and for thededuction of super-tax from dividends inaccordance withthe provisons of sub-section (3D) of section 18 of that Act,and *ferel Fag ga wart dt erat aCat arqdt at ear A atgz ad al ag ofa erat TEU WT Tz (i) gt ma gt oie mA of wa at at & fae feetaera Bl GAT A Hae at are fraa— (%) 31Hrd,1957 at ame eta are ad H fu aaaafafaan & seit ee} arfacaredia ast ara & aeaee F dtcHtd aan ta artFH 8 wedta usadta F Hac sea arateaaa & far qar va afafaan st are18 a sears (34)% wraedl S agare aaaFa afenx at watt & fac falsesau feu zt, qar (ii) a rebate at the rate of four annas per rupee of thetotal incomeshall be allowedin the case of any Companywhichsatisfiedcondition(a) but not condition (b) of thepreceding clause;| Provided further that— (i) the amount of the rebate under clause (i) or x x Xof the preceding proviso shall be reduced by the sum, if any,equal to the amount or the aggregate of the amounts as thecase may be, computed as hereunder:— (a) xxxx (b) in addition, in the case of a company referred to inclause (ii) of the preceding proviso which has distributed toits share-holders during the previous year ‘dividends in excessof six per cent of its paid-upcapital’ not being dividendspayable at a fixed rate— on that part of the said dividandsatthe rate oftwowhich exceeds 6 per cent but doesannas per rupee.not exceed 10 per cent of the paid-up capital; on that part of the said dividendsat the rate of threewhich exceeds 10 per cent of theannas per rupee;paid-up capital; (ii) ga arr IT TT TAeT aT eT a Pea Peatbelt araat at amr H agara at reat faa qaadh ave at ad(=) at gfee we at at freq wa (@) a1 afte FFT aT; qua ag wt fr— (i) qaadh regen % aos (i) Axx x FAA fraz at FHte ae uta, af ae A, a AA aafwa aarfeafe wea atcea HB aT ® strat et, PA HT a TUM— (#)XXx (a) cam afofear qdadl teae F ave (ii) F fafasefeet aecdt at am & feat ga ad & ctea aaa srarfealat aad ane wt * ag sfowa & safes araFr,sit faaa ex ot aaa aria at z, farce fray g—ae aaa Roa aTKT and Gt eae6 larofetsfirra & fee & fara ca sfame & afew veh ge;| TAT eT Age araiate sa aT ge HY aaa Got HeaAt TA aftsfana a afas 2;aqaal et a Explanation :—For the purposes of Paragraph D of this part— The reduction in rebate in super-tax depended upon the pro-portion which the dividend distributed bore to the paid-up capital. F If the Company distributed dividends exceeding 6% of its paid-up capital as defined in the explanation, the rebate was liable to be reduced to the extcmt provided in the second proviso. In the rele-vant years of account, the share premium formed an identifiable part of the reserves of the Company but was not shown in a separate share premium account apart from the reserves. G The Commissioner contends : ( 1 ) that the expression "share premium account" in the definition of "paid-up capital" in the Explanation to Paragraph D of Part II of the Finance Acts 1956 and 1957 means an account apart from the reserves main-tained by the Company; and (2) that in any event since the enactment of the Companies Act, 1956 "share premium" not maintainable as a separate account cannot be taken into consideration in dealing with the claim for rebate in the payment of super-tax and reduction in the rate thereof. Counsel for the Commissioner relied upon s. 7 8 ( 3) read with s. 78(1) of the Companies Act l of 1956, and submitted that the Company was bound to maintain a separate share premium account outside the reserves and transfer into that account the share pre-mium and since the Company failed to do so, in determining the paid-up capital within the meaning of the Expianation to Paragraph D of the Finance Acts 1956 and 1957 the share premium within the reserve could not be taken into account. The relevant clauses of s. 78 of the Companies Act I of 1956 provide:- "(1) Where a company issues shares at a premium, whether for cash or otherwise, a sum equal to the aggregate amount or value of the premiums on those shares shall be transferred to an account, to be called "the share premium account"; and the provisions of this Act relating to the reduc-tion of the share capital of a company shall, except as provided in this section, apply as if the share premium account were paid-up share capital of the Company. (3) Where a company has passed a resolution autho-rising the issue of any shares at a premium, this section shall apply as if the shares had been issued after the commencement of this Act : Provided that any pari of the premiums which has been so aoolied that it does not at the com-mencement of· this Act form an identifiable part of the company's reserves within the meaning of Schedule VI, shall be disregarded in determining the sum to be included in the share premium account." Clause (1 ) is in terms prospective : it requires a Company to transfer premiums received in cash or otherwise on shares to the share premium account. By clause (3) any premium received prLor to the coming into force of the Companies Act, 1956 less that part of the premium which had been so applied so that it did not, at the commencement of the Act, form an identifiable part of the Company's reserves, had also to be transferred to the share jlremium account as if the shares had been issued after the commencement of the Act. Section 78 was apparently borrowed from s. 56 of the English Companies 1948 (11 & 12 Geo. 6 ch. 38.) Before the Companies Act of 1956 there was provision in the Indian Com- C.I.T. V. ALLAHABAD BANI: (Shah, J.) A panies Act 1913 which required a Company to maintain a separate share premium account. After the coming into force of the Com-panies Act 1 of 1956 a share premium account had to be maintained and the share premium could not be used otherwise than for the specific purposes mentioned in s. 7 8 ( 2) . (i) the expression ‘paid-up capital’ means the paid-upcapital (other than capital entitled to a dividend at a fixedrate) of the Company as on the first day of the previousyear relevant to the assessment for the year ending on 31stday of March, 1957, increased by any premiums received incash by the company on the issue of its shares, standing tothe credit of the share premium account as on the first dayof the previous year x x x” 1957 & faa afafaay & a afafran 3% srafaa wat & ayant afsat a fedeAR sae etl Hoe HA areft set care AY Ua eam AMaTE TE AA afar F fate at at gg age wx fae at at faafee arate arwaad Git tar) afe arqay > err Haar ofcarfra aga anceGat & gz ofima & afee arate faafea feu at ai faz & feeig TTAHasafera ara ae at at or aadt Aty GATT sat at A sig Afrawert et arefafaat er afastr arr ar eg ga arefiaftat & fase qTae atfaay rare afm agi fear aar ay| aged + ae ae fear fa— (1) faa afafara, 1956 atx fra afafaaa,1957 & urd 2eo | FeqectawFX‘ware gatoat ofearst Fatawtfhay war gz ¥ dar ser afta & St asradt aver wdt ataictaicat & fart 3; gar eT ELI— EH WET FH ep T yataal F far — (i) area si az 8 31 art, 1957 A aera art ater ao % faafey & fae gene qa ae} cam fea at weqat at(faa at at aie & ater q's & Pret) tet ares q's faredBe ERT aI set ae fee aT ox aay HF greg wtfiara atefau ay diafasa 2 at gt adh sam faoy wire ae FWAT Al xxx” _(2)arait affirms, 19563 afaftama & qua & feetWt eat A gam gal F ST HAW HA art am Sfaa’axafaat % darFH fae car saat ax F at % fac feo agara aX Hrgatat Hea aaa fase at fear ar awa| agaFH ssaa sradtMfafiay,1956 (1956 #11) aAra 78 (1) % ma fea are 78 (3) aT gaara feat ate og fafea fearfe eer aiefafaata sat ca gay ao afm war waa ate dmwfaae at ge ag Harafea wetHB far ara at ale dfs weadl Fver aa feat, va: faa ofafaaa,1956 atx faa ufafran,1957 % dara easdlaeyFH galeaia aaa qo ar waa wat arf &weatd aT a a Sfman at war Haddy fear a wat1 aryafatqza, 1956 (1956 #1) FY ater 78 B Fara Swel H ag vaaleaa A— * feedl Hag ca wart st aHaT F— “(1) sat ate aeodt aet ay, ae vache fae ay serewryat ar attgs agiva welse Mifareat ga cae aTsas yeah quat at ufs st‘sie wif ae ae ma aawarAF neafta ax fear searaur ga afafaan FW sqaey aradyat a Gait aT wat a arated JF ga aa F aa seafeaa H fear,re ary att arat aie Mifaae car eral at are aT TST aT The plea raised by the Commissioner that the Company failed B to comply with the statutory injunction contained in Cl. ( 1) of s. 78 and on that account the premium received were not "standing to the credit of the share premium accounts within the meaning of the Explanation to Paragraph D in the Finance Act 1956 may be rejected on a simple ground. In the assessment year 1956-57 the Company was being asses-c sed to tax in respect of the previous year of the Company ending on December 31, 1955. In the calendar year 1955, the company was governed by the Indian Companies Act 7 of 1913 which con-tained no provision analogous to s. 78 of the Companies Act I of 1956. The Companies Act was before the Parliament during the year 1955, but the Company was on that account not obliged to D transfer to a separate share premium account independent of the reserve the premiums received prior to January I, 1955. The Companies Act came into force on April 1, 1956 : it had no re-trospective operation. Since there was no obligation upon the Com-pany to maintain a separate share premium account in the pre-vious year corresponding to the assessment year 1956-57, the share E premium account maintained as an identifiable account within the reserves qualified for being included in the paid up capital within the meaning of this expression in the Explanation to Paragraph D Part II of the Finance Act. 1956. For the assessment year 1956-57, therefore rebate in ,uper-tax was liable to be reduced, if the Company had distributed dividend F exceeding six per cent of the paid-up capital inclusive of share pre-miums maintained as an identifiable account. The contention raised by the Commissioner must therefore fail in respect of the-assessment year 1956-57. Counsel for the Commissioner contends that in any event in the Finance Act 2 of 1957 the expression "share premium account" G has only the meaning ascribed thereto in the Companies Act, !956, and in respect of the assessment year 1957-58, reduction in the rebate must be computed without talcing into account the share premium which was maintained by the Company in the year of 1ccount 1956 within the reserve. H Under the Finance Act 2 of 1957 rebate in super-tax is liable to be reduced in the case of Companies which have, inter a/ia, dis-tributed to the shareholders in the previous year dividends in excess of 6 per ceint of the paid-up capital not being dividend payable at . a fixed rate. The expression "paid-up capital" is also defined in substantially the same terms as under the Finance Act, 1956. Vasu GuptaAdvocate avs (1)ufavraetl 2; gadfedt aradi 3 ag ater atag2fhae aa aevealHar aaa oer sie fran atsie Mfraan wear FRAR BTaus (3) F ae Hell afta, 1956 & wae ea a gs areafret sitftrr att, frat afr ar saat art aa at fear ITTfaoat aa sare sentfte frat war a freefe ag afafas es reerat srr aT orefefaatar afasta wma at ah, sir Sfaan war Fwafer STAT stat ga ae afefae F sree TAs ca asag ere 2 fs are 78 deve H aepiie baz, 1948 (11 ate 12—faate wear 38) at ara s6 & Ht Tee araafefad, 19568Ye efoert arate taz, 1913 4% ate tar saara adt ar frat far.wert Tag ater sl are athe ae cH gaa ae Mirra Fear wa i Heat—afatrra, 1956 (1956 a 1) ¥ saat aX Foenqae fer FerwT Isase a ae sary st are 78 (2) A afwa fafatece gator fame & fart sata & fac saat val feat or aaar 21 mgFst ag ad feat ar fs eet aT 78 Faw (1). awrafae A amee aT agIAT FAH aeer Ws aese AT (3) wat fret aeot & ate dar caer ofta fear a fraSfrarn oe ath aim ort weeferg ofr fear va at atTe TIT UA AY stat at & ay ee afafran & srew atwad are fae ww a;| qeg wimaat & feel Va ara at, freer gt ware seater fearwaaf& ag ge afafran & sree aA ox gage 6 F wakataprod ataufetaat ar afaata art a at, aa ofaare eer F afeafaaat are arent Ute aaarhear et A Ste at aT| ora sia faa afafaan, 1956 % Ger ah eqectara F gaara ‘aa ahhawart ¥ war’ (standing to the credit of the share premium) 7Z} 4, Ba URarya arate ara fear ST axa Zi fratem ay1956-57FH aweqt gt31fearaz,1955 at varaat arr ga at & araeq H axfasiferfear atcerar1 wavSyag 1955 H werd oz afteqa aradig tac, 1913(1913 a1 7)ary Zaran faaasrqtt afafsay, 1956 (1956 st 1)at ar 78% aay argsaa tataT a1955 HF eer ofefran sag & faarersta ar fagga are Fare 2 grat,1955 & gd ora Pfaaat a arefadt Bcara faett gua am afaan aera waa aa e fac ara ad aarqdt ufaframlava,1956at saa gu, saat ate yaaa) sarawat atiafs faster ay1956-57 *areq qa agFH arqdt oe arsarena aa atfa az san aa wifian war tai gafanarefafaat &WITT MART Taye VT FT tart Tar aa wifsan war faaafafraa,1956HAT2 F TTTFFe eqedlaca A we we H watt aaed GilFafenfaa feuwrt # alr ar wa:fratea ag 1956-57 &fau afaact F feaeFt wat aT areat afe ara a afata care ecard ae aa afaaal afza aadgat ar gesfama & ofan araia facfta fear dari gafac fasten ag1956-57 Baraey F aged gry si 1 sala wana sat arfe| aged Fe Hseaet