Commissioner Of Income Taxtrichy v. M/S.amman Steel & Alliedindustries, Silambudayanpattinagamangalam, Trichy

IN THE HIGH COURT OF JUDICATURE AT MADRAS CORAM THE HONOURABLE MR. JUSTICE R.SUDHAKARAND THE HONOURABLE MR. JUSTICE R.KARUPPIAH Commissioner of Income TaxTrichy. ...Appellant in all the appeals- Vs - M/s.Amman Steel & AlliedIndustries, SilambudayanpattiNagamangalam, Trichy....Respondent in all the appeals Appeals filed under Section 260-A of the Income Tax Act againstthe order dated 23.08.2011 passed by the Income Tax AppellateTribunal, Madras 'C' Bench, Chennai, made in ITA Nos.2058 to2060/Mds/2010, against the order of Commissioner of Income Tax,(Appeals) Tiruchirapalli, dated 21.09.2010, in ITA No. 655; 656;657/07-08 and 149/07-08 and arising out of the Assessment orders ofDeputy Commissioner of Income Tax, Chennai IV (I/C) Trichirapalli,dated 10.12.2007 in PAN/GIR No. , dated 27.12.2006 inPAN/GIR No. , and dated 27.12.2006, in PAN/GIR No.AAMFS4876Jdated 10.12.2007. For Appellant: Mr. J.Narayanaswamy Aggrieved by the order passed by the Tribunal in dismissing theappeals filed by it, the Revenue is before this Court by filing thepresent appeals. In these appeals, the following questions of laware sought to be canvassed before this Court :- “i) Whether the Tribunal was right in holding that the turnover determined by the Commissioner of Central https://hcservices.ecourts.gov.in/hcservices/ Excise in his de novo adjudication proceedingsconsequent to the remand order of the CESTAT can beadopted for the purpose of determining the unaccountedturnover of the assessee for the relevant years? ii) Whether the Tribunal was right in holding thatwhen no deduction was sought on the expenditure, theprovisions of Section 40A (3) cannot be applied whenthe assessable income was arrived by applying apercentage rate on the unaccounted turnover?” 2. The assessment in these appeals is relatable to the assessmentyears 2002-2003, 2003-2004 and 2004-2005. The facts, in a nutshell,are as hereunder :- The respondent/assessee is alleged to be engaged in the businessof manufacture and sale of steel ingots and billets. Therespondent/assessee filed return of income for the above assessmentyears. It appears that the Central Excise Department conducted asearch of the premises of the assessee on 24.6.04 and in the courseof the said search, incriminating documents and evidence were seized,which were found in the computer and floppy disks. On the basis ofthe seized materials, the Central Excise Department issued a showcause notice in which it was alleged that the assessee indulged inevading central excise duty by making unaccounted purchase of rawmaterials, by suppressing production, indulged in clandestine removalof bars and rods without issue of invoice and without payment ofduty. In the course of investigation, it was found that the assesseewas purchasing ingots and billets from certain persons and it wasfound to be unaccounted purchase. Based on the abovesaid show causenotice, the Assessing Officer concluded that the documents seizedindicate collection of sale proceeds of unaccounted bars/rods byassessee in cash and unaccounted sale proceeds collected by cash.The Assessing Officer, based on the show cause notice issued by theCentral Excise Department and the documents in support of the showcause notice, estimated the gross profit at 16.36% and, accordingly,demanded tax on the same. The assessee, aggrieved by the said order,moved the Appellate Authority, viz., the CIT (Appeals) by filing anappeal. 3. It was contended by the assessee before the CIT (Appeals) thatthe show cause notice and the papers seized by the Central ExciseDepartment cannot be the basis for addition/disallowance under theIncome Tax proceedings. The CIT (Appeals), accepting the contention,primarily directed the assessing officer to collect the materialsseized by the Central Excise department and further directed theassessing officer to make independent enquiries on theadditions/disallowances made and submit a report. 4. Pursuant to the said order, the assessee filed objectionsbefore the assessing officer during the remand proceedings and thesame was dismissed by the assessing officer, who submitted a remandreport to the CIT (Appeals) and sought enhancement of income. 5. In the meanwhile, the show cause notice issued by the CentralExcise Department came to be adjudicated by the Commissioner ofCentral Excise and against the said order, the assessee moved theCESTAT. The Tribunal, after elaborately discussing the merits of thecase, came to hold that there was some inherent lacunae in theadjudication order and, therefore, set aside the adjudication orderand remanded the matter to the Commissioner of Central Excise for denovo consideration. After remand, the Commissioner of Central Exciseconsidered the matter and passed de novo order redetermining thedemand. 6. In the interregnum, the assessee, pursuing the appeal beforethe CIT (Appeals), contended that the very basis for determining thegross profit was the show cause notice and the adjudication order,which has now been set aside and the matter remanded to theCommissioner of Central Excise for de novo adjudication and in suchcircumstances, pleaded that on the finding of the Tribunal and thematerials filed in support thereof, the demand for tax proposedcannot be justified, as those evidences were found to be unreliableand inadmissible in evidence. Nevertheless, it was submitted that inview of the remand order, nothing survives for consideration for thepurpose of determining the income as unaccounted transaction. Onthe said submission, the CIT (Appeals) came to the conclusion thatthe Assessing Officer, without conducting an independent enquiry,either at the time of assessment or during the remand proceedings, asdirected by the CIT (Appeals), has simply relied upon the documentsretrieved in the course of the proceedings initiated by the CentralExcise Department as gospel truth and, therefore, held that theincome should be brought to tax based on cogent material and evidenceand the order of the assessing officer merely placing reliance on theshow cause notice, without making an independent enquiry, pursuant tothe remand order, cannot be sustained. The CIT (Appeals) furtherheld that the turnover was re-determined by the Commissioner ofCentral Excise in the de novo order and since the direction as givenby the CIT (Appeals) in the remand proceedings having not beencarried out, the CIT (Appeals) adopted the re-determined turnover asunaccounted turnover of the assessee by modifying the rate of grossprofit after giving deduction towards power and labour charges. Thefindings of the CIT (Appeals), for better clarity, are extractedhereinbelow :- “22. I have considered the rival contentions. I amof the considered opinion that any income can be “22. I have considered the rival contentions. I amof the considered opinion that any income can be brought to tax based only on cogent materialbuttressed by evidence. IN the present instance theAssessing Officer cannot claim to have any evidence tosustain the additions. He speaks at length only aboutthe allegations contained in the show cause and someof them in material not worthy of admission inevidence. Under these circumstances I am inclined tohold that the turnover determined by the Commissionerof Central Excise in his de novo order giving effectto the directions of the Tribunal shall be theunaccounted turnover of the appellant for the relevantyears. The gross profit on this turnover shall bedetermined as under and added to the income returned.On the rate of gross profit I am in agreement with thecontention of the AR that the power and labour chargeshave to be deducted in arriving at the rate of grossprofit. Accordingly the rate of gross profit had beenworked and I direct the income as per the followingtable be adopted and added to the income returned andbalance addition made by the AO shall stand deleted. 7. On the question of disallowance under Section 40A (3) of theAct, purchase of steel ingots from various persons in cash, thequantum of purchases alleged in the assessment order is based on theshow cause notice issued by the Central Excise Department. On thesaid issue, the assessee contended that when the income is estimatedby estimating the turnover no further expenditure can be separatelyconsidered. Reliance was placed by the assessee on the judgment ofthis Court in CIT – Vs – Mohammed Dhurabudeen (4 DTR 218). The CIT(Appeals) held that since the basis of the additions itself is atfault, they are not valid and, therefore, the disallowance on thesaid income is not sustainable. 8. Aggrieved by the said order of the CIT (Appeals), theDepartment preferred appeals before the Tribunal. The Tribunal, onconsideration of the entire matter and on considering the allegationsraised in the show cause notice, issued by the Central Excise 8. Aggrieved by the said order of the CIT (Appeals), theDepartment preferred appeals before the Tribunal. The Tribunal, onconsideration of the entire matter and on considering the allegationsraised in the show cause notice, issued by the Central Excise Department, which came to be finally decided by the CESTAT by way ofremand and the further de novo adjudication by the Commissioner ofCentral Excise, held that the CIT (Appeals) has rightly ordered thatturnover as determined by the Commissioner of Central Excise in thede novo adjudication order shall be the unaccounted turnover of theappellant for the relevant years and, accordingly, the gross profitwas worked out. The Tribunal further took note of the fact that sucha conclusion drawn by the CIT (Appeals) is correct since merereliance on the show cause notice issued by the Central ExciseDepartment is of no avail and the assessing officer has not madeindependent enquiries even pursuant to the remand order passed by theCIT (Appeals). The Tribunal further held that the assessing officermerely collected all the documents and forwarded the same with hisreport, which is not the correct procedure. The relevant portion ofthe order of the Tribunal, in our opinion, requires to be placed onrecord, for better clarity, and the same is extracted hereunder :-“14. Undisputedly and admittedly, the AssessingOfficer in this case has not made any independentenquiries. When the Hon'ble CESTAT has found thoseevidence unreliable and not a good evidence forframing assessment, the same cannot be made a basisfor making assessment under Income Tax Act. In thesecircumstances, the assessee is not required toexplain the documents in so far as income taxproceedings are concerned. It is found for a factthat neither the managing partners of the firm norany other person in-charge of the business had everadmitted on oath that all the materials seized by theCentral Excise Department could be used by th ITO inframing the assessment order. On the contrary therelevant answer of the managing partner clearlystates that the Hon'ble CESTAT had already found theretrieved data to be unreliable and requested to relyonly on the de novo order made by the Commissioner,Central Excise Department. In our consideredopinion, the the extent the Hon'ble CESTAT has foundthe documents/evidence to be unreliable, the samecannot be used in maing assessment under Income-TaxAct, specially when not even a whit of enquiry hasbeen independently made by him despite directed bythe ld. CIT (A). The assessee has clearly explainedthe electricity charges and wages and has accountedthe same completely, and similar explanation has beenaccepted by the same Assessing Officer, in his ordermade for assessment year 2002-03. The Hon'ble MadrasHigh Court in the case of CIT – Vs – Vignesh KumarJewellers, 222 CTR 79, has clearly held that the findings of another Department cannot be simplyincorporated in the assessment without anyindependent enquiry having been made. In this case,even a modicum of enquiry has not been madeindependently by the Assessing Officer. There is nocorroborating or supporting evidence available onrecord. When the main evidence on the basis of whichthe assessment was framed has been found to be notreliable by the very same Department (Central ExciseDepartment), the cumulative effect of finding givenin the assessment order, remand report and submissionof the parties, would lead to only one conclusionthat no addition can survive on the basis ofunreliable evidence. The addition made by theAssessing Officer hinges on the show cause notice ofthe Central Excise Department which has been found tobe unreliable to a greater extent. It is verystrange that the remand report was sent after a lapseof three years and that too after repeated remindershaving snet by the ld. CIT (A). In fact, theAssessing Officer has not conducted any enquiry, letalone, any independent enquiry in this case. He hassimply obtained copies of the records from CentralExcise Department and the statements recorded by themfrom four persons despite the fact that he wasspecifically directed by the ld. CIT (A) to trace thetransaction-trails from the square one upto the endto establish the generation of unaccounted income, ifany, as had been alleged. In the remand report, theAssessing Officer has canvassed even the enhancementof the addition by way of withdrawal of deductionallowed for furnace oil as explained. We areconvinced that the additions which are made solely onthe basis of the materials seized by the CentralExcise Department and which have been dubbed asunreliable by Hon'ble CESTAT, no addition can be madeby the Assessing Officer (Income Tax) in the eyes oflaw. There is no doubt about the legalk positionthat any income which is based on material evidencefound or gathered by the Assessing Officer can bebrought to tax. In the given case, there is no suchevidence available with the Assessing Officer tosustain the impugned addition. The allegations madein the show cause notice no longer survive. But wehave to accept the facts which have been found by theHon'ble CESTAT to be correct and reliable and on thebasis of which de novo assessment has been made. The turnover determined by the Commissioner of CentralExcise Department in his de novo order giving effectto the Hon'ble CESTAT's order has to be treated asunaccounted turnover of the assessee for the relevantyears. The gross profit on this turnover has to bedetermined and added to the returned income for therespective assessment years. The power and labourcharges have to be deducted in arriving at the rateof gross profit. The rate of gross profit worked outby the ld. CIT (A) is as under :- 15. Before us, the ld. AR has not disputed theaddition of the income as per the above chart. Thebalance addition made by the Assessing Officer hasbeen deleted by the ld. CIT (A). We are of theconsidered opinion that the action of the ld. CIT (A)is correct and affirm the same.” (Emphasis supplied) The Tribunal concurred with the findings of the CIT (Appeals) inrelation to Section 40A (3) and, accordingly, the appeals filed bythe Department were dismissed. Aggrieved by the said order of theTribunal, the Department is before this Court by filing the presentappeals. 15. Before us, the ld. AR has not disputed theaddition of the income as per the above chart. Thebalance addition made by the Assessing Officer hasbeen deleted by the ld. CIT (A). We are of theconsidered opinion that the action of the ld. CIT (A)is correct and affirm the same.” (Emphasis supplied) The Tribunal concurred with the findings of the CIT (Appeals) inrelation to Section 40A (3) and, accordingly, the appeals filed bythe Department were dismissed. Aggrieved by the said order of theTribunal, the Department is before this Court by filing the presentappeals. 9.LearnedstandingcounselappearingfortheDepartment/appellant submitted that the Tribunal erred in holdingthat the materials seized by the Central Excise Department cannot bethe basis to conclude that the assessee had undisclosed income forthe purpose of making addition/disallowance. Learned counsel furthersubmitted that the assessee maintained a 2[nd] set of account bookswhere falsification of entries was found and, thereby, concealment ofincome is evident from the materials seized by the Central ExciseDepartment. Further, the large scale unaccounted purchase,suppressed sales, which are evident from the documents seized by theCentral Excise Department, have not been appreciated by the Tribunalin its proper perspective. Further, it is contended by the learnedstanding counsel for the Department/appellant that the assessing officer, during the remand proceedings, had recorded statements ofthe respondent/assessee, wherein admissions as to the veracity of thecontents of the seized materials are available, which have not beenappreciated in proper perspective by the CIT (Appeals) as well as theTribunal. Learned standing counsel, placing reliance on the decisionreported in 290 ITR 702 (Commissioner of Income Tax – Vs – HynoupFood & Oil Industries P. Ltd.) submitted that the payment in cash forexpenditure not being disputed by the assessee, the Assessing Officeris justified in ordering disallowance under Section 40A(3) of theAct, which has not been considered by the Tribunal in its properperspective and, therefore, the order passed by the Tribunal, in itsentirety, is liable to be interfered with. 10. Heard Mr.Narayanaswamy, learned standing counsel appearingfor the appellant/Revenue and perused the materials available onrecord as also the decision relied on by the learned counsel for theappellant. 11. We have considered the facts in issue. Here is a case wherethe entire assessment order is based on materials found in the showcause notice issued by the Central Excise Department. Thereafter,the adjudication order passed by the Commissioner of Central Excisecame to be set aside by the CESTAT and on remand a de novo order waspassed by the Commissioner of Central Excise redetermining thedemand. The CIT (Appeals) has ordered that the said amount should betreated as unaccounted turnover of the assessee for the relevantyears and gross profit on this turnover should be determined andadded to the income returned. The procedure adopted by the CIT(Appeals), as stated above, is the logically correct way ofdetermination of the unaccounted turnover. The reasoning of the CIT(Appeals) and the computation thereof being logically correct, theDepartment cannot have any grievance on the order passed by the CIT(Appeals), which has also been confirmed by the Tribunal. In theabsence of any independent enquiry by the Assessing Officerconcerned, as ordered by the CIT (Appeals), the question of placingreliance on the demand made by the Central Excise Department in itsshow cause notice, which has been redetermined in the finaladjudication order passed by the Commissioner of Central Excise inthe de novo proceedings, does not arise for consideration. 12. This Court is of the considered view that the finding of theCIT (Appeals) as well as the Tribunal that merely on the basis of theshow cause notice issued by the Central Excise Department,determination of tax under the Income Tax Act cannot be made, as itis not incumbent on the income tax authorities to take intoconsideration only the materials made available by the Central ExciseDepartment, but the authorities are bound to make an independent enquiry, before passing any order, which enquiry has not happened inthe present case. There is no provision to simply incorporate thedemand made in the show cause notice issued under the Central ExciseLaws for the purpose of computation of tax under the Income Tax Laws.The provisions under the two laws, viz., the Central Excise Act andthe Income Tax Act, operate in two different fields. Without therebeing an independent enquiry by the concerned taxing authorities thedemand made under the provisions of Central Excise Act cannot beincorporated as such, more so when the notice of demand has beenmodified by the adjudicating authority. The above view of this Courtis further fortified by the decision of the Supreme Court in K.T.M.S.Mohammed & Ors. – Vs – Union of India (AIR 1992 SC 1831), wherein theSupreme Court while considering the scope of the provisions ofForeign Exchange Regulation Act and the Income Tax Act, held asunder:- “24. Needless to emphasise that the Foreign ExchangeRegulation Act and the Income-tax Act are twoseparate and independent special Acts operating intwo different fields. 25. This court in Rao Bahadur Ravulu Subba Rao v.CIT [1956] 30 ITR 163; AIR 1956 SC 604; [1956] SCR577 (headnote of 30 ITR 163 ) has pointed out : "The Indian Income-tax Act is a self-containedcode exhaustive of the matters dealt with therein,and its provisions show an intention to departfrom the common rule, qui facit per alium facitper se." 26. Further, in Pannalal Binjraj v. Union of India[1957] 31 ITR 565 AIR 1957 SC 397; [1957] SCR 233, ithas been observed thus (at pages 583, 584 of 31ITR) : "It has to be remembered that the purpose of theAct is to levy income-tax, assess and collect thesame. The preamble of the Act does not say so interms, it being an Act to consolidate and amendthe law relating to income-tax and super tax butthat is the purpose of the Act, as disclosed inthe preamble to the first Indian Income-tax Actof 1886 (Act II of 1886). It follows, therefore,that all the provisions contained in the Act havebeen designed with the object of achieving thatpurpose." Coming to the Foreign Exchange Regulation Act, it isa special law which prescribes a special procedure forinvestigation of breaches of foreign exchangeregulations. Vide Shanti Prasad Jain v. Director ofEnforcement [1963] 33 Comp Cas 231; [1963] 2 SCR 297. The proceedings under the Foreign Exchange RegulationAct are quasi-criminal in character. It is pellucidthat the ambit, scope and intendment of these two Actsare entirely different and dissimilar.” The above decision of the Supreme Court is squarely applicable tothe facts of the present case and, therefore, we have no hesitationto hold that the method adopted by the CIT (Appeals) with regard totaxation under the Income Tax Act, as affirmed by the Tribunal, isthe correct method of determining the income based on the unaccountedturnover. Coming to the Foreign Exchange Regulation Act, it isa special law which prescribes a special procedure forinvestigation of breaches of foreign exchangeregulations. Vide Shanti Prasad Jain v. Director ofEnforcement [1963] 33 Comp Cas 231; [1963] 2 SCR 297. The proceedings under the Foreign Exchange RegulationAct are quasi-criminal in character. It is pellucidthat the ambit, scope and intendment of these two Actsare entirely different and dissimilar.” The above decision of the Supreme Court is squarely applicable tothe facts of the present case and, therefore, we have no hesitationto hold that the method adopted by the CIT (Appeals) with regard totaxation under the Income Tax Act, as affirmed by the Tribunal, isthe correct method of determining the income based on the unaccountedturnover. 13. The next question raised by the appellant/Revenue relates todisallowance under Section 40A (3) of the Act. For betterappreciation of the issue, Section 40A (3) of the Act is extractedhereinbelow :-“40A. Expenses or payments not deductible in certaincircumstances.*********(3)(a) Where the assessee incurs any expenditure inrespect of which payment is made in a sum exceedingtwenty thousand rupees otherwise than by an accountpayee cheque drawn on a bank or account payee bankdraft, no deduction shall be allowed in respect ofsuch expenditure;(b) where an allowance has been made in theassessment for any year in respect of any liabilityincurred by the assessee for any expenditure andsubsequently during any previous year (hereinafterreferred to as subsequent year) the assessee makespayment in respect thereof, otherwise than by anaccount payee cheque drawn on a bank or account payeebank draft, the payment so made shall be deemed to bethe profits and gains of business or profession andaccordingly chargeable to income-tax as income of thesubsequent year if the amount of payment exceedstwenty thousand rupees: Provided that no disallowance shall be made and nopayment shall be deemed to be the profits and gainsof business or profession under this sub-sectionwhere any payment in a sum exceeding twenty thousandrupees is made otherwise than by an account payeecheque drawn on a bank or account payee bank draft,in such cases and under such circumstances as may beprescribed, having regard to the nature and extent ofbanking facilities available, considerations ofbusiness expediency and other relevant factors. Provided that no disallowance shall be made and nopayment shall be deemed to be the profits and gainsof business or profession under this sub-sectionwhere any payment in a sum exceeding twenty thousandrupees is made otherwise than by an account payeecheque drawn on a bank or account payee bank draft,in such cases and under such circumstances as may beprescribed, having regard to the nature and extent ofbanking facilities available, considerations ofbusiness expediency and other relevant factors. 14. On the issue relating to disallowance under Section 40A (3)of the Act, the same was considered by the CIT (Appeals) by holdingthat income has been arrived at an estimate of turnover and computedapplying the gross profit and, therefore, no expenditure shall beallowed, since the gross profit applied would take care of the amountincurred by purchases, etc. The CIT (Appeals), to justify the saidstand, drew strength from the decision of this Court in MohammedDhurabudeen's case (supra), wherein this Court has held thus :-“The question for consideration is when nodeduction was sought and allowed under S. 40A (3),was there any need to go into S. 40A (3) and Rule 6DD(j). We see force in the view taken by the Tribunalthat when the income of the assessee was computedapplying the GP rate and when no deduction wasallowed in regard to purchases of the assessee, therewas no need to look into the provisions of Section40A (3) and Rule 6DD (j). No disallowance could havebeen made in view of the provisions of S. 40A (3)read with Rule 6DD (j) as no deduction was allowed toand claimed by the assessee in respect of purchases.When the GP rate is applied, that would take care ofeverything and there was no need for the A.O. to makescrutiny of the amount incurred on the purchases bythe assessee.”15. Following the ratio laid down by this Court in the abovesaiddecision, the CIT (Appeals) held that the additions made underSection 40A (3) of the Act are to be deleted since the basis of theadditions had been faulted and are no more valid and since the incomeis estimated, no disallowance on this account can be made. The saidview of the CIT (Appeals) has been affirmed by the Tribunal. 16. This Court has already held in the former portion of theorder, that the assessment order came to be passed only on the basisof the show cause notice issued by the Central Excise Department andno independent enquiry has been conducted by the Assessing Officer.Further, the ratio of the decision of the Supreme Court in K.T.M.S.Mohammed's case (supra), clearly applies to the facts of the presentcase. Such being the case, in the absence of any independent enquiryby the Assessing Officer, the disallowance sought to be made underthe Income Tax Act, by the Assessing Officer, on the basis of theshow cause notice, issued under the Central Excise Act cannot besustained. When the assessable income was arrived at by applying apercentage rate, as held by this Court in Mohammed Dhurabudeen's case(supra), the said exercise would take care of everything and there is no need for the Assessing Officer to make scrutiny of the amountincurred on the purchases by the assessee for the purposes ofdisallowance. Therefore, this Court is of the considered view thatthe order of the Tribunal in concurring with the CIT (Appeals) onthis issue is justified and this Court finds no reason to differ withthe same. 17. In view of the above findings and reasoning as recordedabove, this Court is of the considered view that no question of law,much less substantial question of law arises for consideration inthese appeals. 18. In the result, these appeals fail and the same are dismissed.Consequently, connected miscellaneous petitions are also dismissed. Sd/-Assistant Registrar(CS-III) //True Copy// Sub Assistant Registrar GLNTo1. Commissioner of Income TaxTrichy. 2. Income Tax Appellate Tribunal'C' Bench, Chennai. 17. In view of the above findings and reasoning as recordedabove, this Court is of the considered view that no question of law,much less substantial question of law arises for consideration inthese appeals. 18. In the result, these appeals fail and the same are dismissed.Consequently, connected miscellaneous petitions are also dismissed. Sd/-Assistant Registrar(CS-III) //True Copy// Sub Assistant Registrar GLNTo1. Commissioner of Income TaxTrichy. 2. Income Tax Appellate Tribunal'C' Bench, Chennai. 3. The Deputy Commissioner of Income Tax,Circle IV, Trichirapalli. 4. The Assistant Registrar,Income Tax Appellate Tribunal,Rajaji Bhavan, III Floor,Besant Nagar, Chennai - 90. 1 CC to Mr. J.Narayanaswamy, Advocate SR.No. 7445 TS (CO)PSI (10.04.2015) T.C.A. NOS. 1048 TO 1050 OF 2014 https://hcservices.ecourts.gov.in/hcservices/