The Commissioner Of Income-Tax-I Chennai v. M/S.chakiat Agencies Pvt.ltd., Chennai

In the High Court of Judicature at Madras Coram :- The Honourable Mr.Justice K.RAVIRAJA PANDIANandThe Honourable Mr.Justice P.P.S.JANARTHANA RAJA Tax Case (Appeal) Nos.361, 362, 491 and 492 of 2004 The Commissioner of Income-tax-IChennai. ...Appellant in all AppealsVs. M/s.Chakiat Agencies Pvt.Ltd.,Chennai... Respondent in all Appeals TAX CASE (Appeals) filed under Section 260 of the Income TaxAct, 1961 against the order of the Income Tax Appellate Tribunal,Madras 'C' Bench, dated 30.4.2003 made in I.T.A.Nos.1952, 1953,1954/Mds/2000 and 57/Mds/2000. and against the Order of theCommissioner of Income Tax (Appeals) X, Chennai-34 in ITA No.80 &81/2000-2001, and ITA No.82/2000-2001 dated 14.9.2000 and ITANo.178/99-2000 dated 20.10.99 and against the Assessment order ofthe Joint Commissioner of Income-Tax, Spl.Range-IV, Chennai-34dated 16.3.2000, in PAN/G.I.No.62-C and dated 24.3.99 inPAN/GIR.No.46-066-CX-3861 and dated 15.3.2000 in PAN/GI No.62-C/97-98. For Appellant : Mrs.Pushya Sitaraman Senior Standing CounselFor Respondent : Mr.V.S.Jayakumar COMMON JUDGMENT (Judgment of the Court was delivered by K.RAVIRAJA PANDIAN,J.) The revenue is on appeal against the order of the Income TaxAppellate Tribunal, Madras 'C Bench dated 30.4.2003 made inI.T.A.Nos.1952, 1953, 1954/Mds/2000 and 57/Mds/2000 by formulatingthe following questions of law: "1. Whether on the facts and circumstancesof the case, the Tribunal was right in holdingthat the re-assessment proceedings to deny thebenefit of Section 80-O was only a change ofopinion? https://hcservices.ecourts.gov.in/hcservices/2. Whether in the facts and circumstances of the case, the Tribunal was right in holding thatthe assessee is entitled to the benefit ofSection 80-O when admittedly no amount wasreceived in foreign exchange? 3. Whether in the facts and circumstances ofthe case, the benefit of Section 80-O would alsobe available to a shipping agent?" "1. Whether on the facts and circumstancesof the case, the Tribunal was right in holdingthat the re-assessment proceedings to deny thebenefit of Section 80-O was only a change ofopinion? https://hcservices.ecourts.gov.in/hcservices/2. Whether in the facts and circumstances of the case, the Tribunal was right in holding thatthe assessee is entitled to the benefit ofSection 80-O when admittedly no amount wasreceived in foreign exchange? 3. Whether in the facts and circumstances ofthe case, the benefit of Section 80-O would alsobe available to a shipping agent?" 2. The assessee was a private limited company. The relevantassessment years are 1994-95 to 1997-98. For the assessment years1994-95 and 1995-96 the assessee filed its return on 9.11.1994admitting certain income. Subsequently, a revised return has beenfiled on 9.1.1996 explaining the reason by way of note enclosingthe revised return claiming deduction under Section 80-O of theAct, which is based on the decision of the Delhi Bench of theTribunal in the case of CAPTAIN K.C.SAIGAL VS. ITO (53 TTJ 564) andthe Circular of CBDT No.731 dated 20.12.1995. The originalassessment for the said two assessment years were completed underSection 143(3) of the Act by allowing deduction under Section 80-Oas claimed by the assessee. Later on notice under Section 148 wasissued by the assessing officer for both the years and re-assessment was completed by disallowing the claim of deductionunder Section 80-O which was allowed in the original assessment forthe reason that the service rendered by the assessee would notentitle him deduction under Section 80-O and the assessee did notbring convertible foreign exchange. In respect of the remainingtwo assessment years, even in the original assessment order itself,the claim has been rejected by the assessing officer for the verysame reasonings. Aggrieved by that orders, the assessee filedappeals before the Commissioner of Income-tax (Appeals), whichended in dismissal. On further appeal to the Income-tax AppellateTribunal, the Tribunal allowed the appeal of the assessee for theassessment years 1994-95 and 1995-96 on the ground that the re-assessment was not in accordance with Section 147 and was made onchange of opinion. In respect of the other two assessment yearsalso, the Tribunal allowed the assessee's appeal on the ground thatthe activity of the assessee comes within the purview of Section80-O as decided by the Delhi Bench in CAPTAIN K.C.SAIGAL VS. ITO(53 TTJ 564) and the receipt of commission in foreign exchange inIndia itself cannot deny the benefit to the assessee in view of thejudgment of the Supreme Court in the case of J.B.BODA AND CO. PVT.LTD. VS. CENTRAL BOARD OF DIRECT TAXES reported in (1997) 223 ITR271. The correctness of the same is now canvassed in this appeal. 3. The learned counsel appearing for the revenue contendedthat as there was escapement of assessment by the grant ofdeduction under Section 80-O, the re-assessment was in accordancewith law. It was further contended by the revenue that the activityof the assessee cannot be regarded as the one stated in Section 80-O of the Act and in any event, the receipt of the amount ascommission is not in convertible foreign exchange, which is thecondition precedent for availing the benefit under the Act.https://hcservices.ecourts.gov.in/hcservices/ 3. The learned counsel appearing for the revenue contendedthat as there was escapement of assessment by the grant ofdeduction under Section 80-O, the re-assessment was in accordancewith law. It was further contended by the revenue that the activityof the assessee cannot be regarded as the one stated in Section 80-O of the Act and in any event, the receipt of the amount ascommission is not in convertible foreign exchange, which is thecondition precedent for availing the benefit under the Act.https://hcservices.ecourts.gov.in/hcservices/ 4. On the other hand, Mr.Jayakumar, learned counsel appearingfor the assessee contended that the very same set of activitycarried on by the assessee has been dealt in an identical case inthe case of CAPT.K.C.SAIGAL VS. ITO (53 TTJ 564) by the Delhi Benchof the Tribunal, wherein the activities rendered by the assesseein that case were accepted as one come within the provision 80-O ofthe Act and as a matter of fact, that order has been accepted bythe revenue and has become final. The deduction made are strictlyin compliance of the provisions of the Act, which has been approvedby the Supreme Court in the case of J.B.BODA AND CO. PVT. LTD. VS.CENTRAL BOARD OF DIRECT TAXES reported in (1997) 223 ITR 271. 5. We heard the argument of the learned counsel appearing oneither side and perused the material on record. 6. In respect of the assessment year 1994-95 and 1995-96,revision of assessment has been made. It is an admitted fact thatthe assessing officer has completed the assessment originally afterobtaining complete details as required him and as provided underthe Act. The assessee himself filed a revised return as stated inthe summation of facts on 9.1.1996 which has been scrutinised andultimately the deduction under Section 80-O has been allowed. Onthe reading of the order of the Tribunal as well as the lowerauthority, there is no reason, what so ever, has been stated by therevenue to the effect that new materials were received by theassessing officer and the assessing officer on the basis of the newmaterials based his opinion that there was escapement ofassessment. There was no material placed on record to show that theassessee had suppressed any material fact or has failed to disclosefully and truly all material facts necessary for assessment. It isalso on record that the re-opening of assessment was made by thevery same assessing officer, who passed the original assessmentorder, which is evident from the copy of the notice under Section148. Further it was observed by the Tribunal that in the saidnotice there was no mention of any fresh material that has led theassessing officer to reopen the assessment. From the above facts,it is clear that the assessing officer has taken recourse ofreopening of the assessment only due to change of his opinion aboutthe admissibility of deduction under Section 80-O, which wasoriginally allowed by the assessing officer after considering thematerials placed before him. The change of opinion cannot be areason for revision of assessment is the settled proposition oflaw. The power to reopen an assessment was conferred by theLegislature not with the intention to enable the Income-taxOfficer to reopen the final decision made against the Revenue.Where the assessing officer attempts to reopen the assessmentbecause the opinion formed earlier by him was in his opinionincorrect the reopening could not be done. Usual reference can behad to the judgment of the Delhi High Court in the case of JindalPhoto Films Ltd. Vs. Deputy CIT reported in (1998) 234 ITR 170(Delhi), Govind Chhapabhai Patel Vs. Deputy Commissioner of Income-tax reported in (1999) 240 ITR 628(Guj), GARDEN SILK MILLS LTD.VS. DCIT reported in (1996) 222 ITR 68 (Guj) and GARDEN SILK MILLShttps://hcservices.ecourts.gov.in/hcservices/PVT. LTD. VS. DCIT reported in (1999) 237 ITR 668(Guj). Hence we are of the view that the order of the Tribunal allowing the appealon the ground that the reopening is bad in law is in conformitywith the statutory provision as well as the law declared on thatprovision. Hence, the first question of law is answered inaffirmative in favour of the assessee and against the revenue. 7. Questions of law Nos.2 and 3 can be considered together.The ingredients of Section 80-O of the Act for allowing thededuction are, "(i) that the assessee should have income by wayof royalty, commission, fees or any similar paymentreceived by the assessee from a foreign enterprise inconsideration for the use of any patent, invention,model, design, secret formula or process, or similarproperty right, or information concerning industrial,commercial or scientific knowledge, experience orskill made available or provided or agreed to be madeavailable or provided to the foreign enterprise by theassessee and (ii) the consideration for such services are tobe received in convertible foreign exchange in Indiaor having been received in convertible foreignexchange outside India is brought into India, by or onbehalf of the assessee in accordance with law for thetime being in force for regulating payments anddealings in foreign exchange." 8. In the case on hand, there is no dispute that the assesseeis a shipping agent and its activities are that on the basis ofinformation received from the parties, intending to send cargo,they used to contact the foreign ship owners, which would meet theneeds of carrying of cargo. The assessee had to ensure that theship owner should pick up the cargos and would transport it withinthe time and at the agreed rates. The information regardingavailability of cargo to ship owners and their destinations atfrequent intervals enables the ship owners to program the shipstravel touching the Indian coasts accordingly. The assessee usedto contact the ship owners whenever they send the cargo and in thatprocess they exchange various types of special information with theship owners or concerned parties. The assessee also used to contactthe ship owners and other parties on various issues beforeconclusion of agreements between them. For such services, theassessee received commission. After meeting the freight charges andother incidental expenses such as insurance and after deduction ofthe commission, the balance amount was sent to the ship owners inforeign exchange. The claim of the assessee is that they hadreceived brokerage from the foreign ship owners in considerationfor the use outside India of the information furnished by themand such information is concerning industrial, commercial orscientific knowledge, experience or skill, which would otherwiseamount to rendering technical and professional service to foreignhttps://hcservices.ecourts.gov.in/hcservices/ship owners and is entitled to deduction under Section 80-O. These services could very well be regarded as information concerningcommercial knowledge. As contended by Mr.Jayakumar, the very sameactivities in the case of CAPT.K.C.SAIGAL VS. ITO (53 TTJ 564)were regarded as one entitled for deduction under Section 80-O bythe Delhi Bench of the Tribunal and it had become final as it wasnot questioned by the revenue further in any forum. 9. It is also admitted fact that as against the order of theDelhi Tribunal in CAPTAIN K.C.SAIGAL VS. ITO (53 TTJ 564), noappeal has been taken by the revenue, which otherwise amounts thatthe revenue has accepted the reasoning given by the Delhi Tribunal. 10. The word "commercial" has been defined in Black's LawDictionary with Pronounciations, Fifth Edition as follows: "Relates to or is connected with trade andtraffic or commerce in genera; is occupied withbusiness and commerce. ... Generic term for most allaspects of buying and selling." 9. It is also admitted fact that as against the order of theDelhi Tribunal in CAPTAIN K.C.SAIGAL VS. ITO (53 TTJ 564), noappeal has been taken by the revenue, which otherwise amounts thatthe revenue has accepted the reasoning given by the Delhi Tribunal. 10. The word "commercial" has been defined in Black's LawDictionary with Pronounciations, Fifth Edition as follows: "Relates to or is connected with trade andtraffic or commerce in genera; is occupied withbusiness and commerce. ... Generic term for most allaspects of buying and selling." The word "commercial" has been denied in P.ramanatha Aiyar'sThe Law Lexicon, Reprint Edition, 1987 as follows: "That an article is to be understood in itscommercial sense, is to give it a comprehensivesense of how it is known in the general sales ortraffic of the markets. ... It means not merely thesense in which merchants understand it, but alsothe idea which buyers and sellers in the marketgenerally have of the article." 11. The Delhi High Court in the case of Mittal Corporation’scase [2005] 272 ITR 87, on the facts that the assessee receivedcommission income as buying agent of foreign enterprises, theassessee claimed deduction under Section 80-O of the Act oncommission income which was earned on providing commercialinformation to the foreign buyers. It was held that it cannot besaid that the assessee must provide ‘technical services’ even whereit receives consideration for only providing commercialinformation. The section is required to be interpreted accordingly.On the facts, the Tribunal clearly held that there is no disputethat it is commercial information which the assessee provided tothe foreign buyers and in consideration thereof, the assesseereceived commission which was in convertible foreign exchange. Inview of this, the claim made by the assessee cannot be denied undersection 80-O of the Act.” 12. In the case of Godrej and Boyce Mfg. Co. Ltd. Vs. Potnis(S.B.), CIT (Chief), (1993) 203 ITR 947(Bombay High Court), thepetitioners who manufactured steel and metal products entered intotwo agreements with a foreign company for establishing a plant inIndonesia. One agreement was titled "technical assistanceagreement" and the second agreement was titled "management servicehttps://hcservices.ecourts.gov.in/hcservices/agreement". Under the second agreement, a provision was made for the giving of all marketing, industrial, manufacturing, commercialand scientific knowledge, experience and skill for the efficientworking and management of the foreign company. The ChiefCommissioner of Income-tax held that the second agreement did notqualify for approval under section 80-O of the Income-tax Act,1961. On a writ petition against the order, the Court held thatthe order denying approval was not justified and was liable to bequashed. The court directed that the application should bereconsidered by the Chief Commissioner for a decision in accordancewith the law laid down by the Supreme Court in ContinentalConstruction Ltd. v. CIT [1992] 195 ITR 81], wherein it was heldthus: "It is not possible to postulate, as a generalproposition of law, that all managerial services mustnecessarily be non-technical services. It depends onthe nature of the expertise required for rendering themanagerial services. Ultimately, it would be a matterof evaluation of the factual details and a decisionagainst the background of the factual matrix of eachcase." "It is not possible to postulate, as a generalproposition of law, that all managerial services mustnecessarily be non-technical services. It depends onthe nature of the expertise required for rendering themanagerial services. Ultimately, it would be a matterof evaluation of the factual details and a decisionagainst the background of the factual matrix of eachcase." 13. In the case of Li & Fung India P. Ltd. Vs. Commissioner ofIncome-tax, (2008) 305 ITR 105, the judgment was rendered by DelhiHigh Court, wherein the assessee rendered technical servicesoutside India as buying agent and claimed deduction under section80-O of the Income-tax Act, 1961. The Assessing Officer denied thededuction claimed by the assessee on the ground that the assesseemerely rendered managerial services and not technical services andtherefore did not satisfy the requirement under section 80-O of theAct. The Commissioner (Appeals) held that the assessee was entitledto deduction. The Tribunal held that 30 per cent of the feesreceived by the assessee was towards services rendered in India andquantified 70 per cent. of fees received for deduction undersection 80-O and accordingly directed the Assessing Officer torecompute the deduction. The High Court allowed the appeal holdingthat "as long as the technical and professionalservices were rendered from India and were receivedby a foreign Government or enterprise outside India,deduction under section 80-O of the Act would beavailable to the person rendering the services evenif the foreign recipient of the services utilizedthe benefit of such services in India. Since thecontract obliged the assessee to make availableinformation and render services to the foreignclient of the nature outlined in section 80-O andCircular No. 700 dated March 23, 1995, the assesseereceived the payment which was in convertibleforeign exchange. Therefore, the assessee had to begiven the benefit of deduction available undersection 80-O of the Act. The Tribunal erred inrestricting the claim of deduction under section 80-O to 70 per cent."https://hcservices.ecourts.gov.in/hcservices/ 14. In the case of Central Board of Direct Taxes Vs. OberoiHotels (India) Pvt. Ltd, (1998) 231 ITR 148, the respondent hotelentered into an agreement with a foreign enterprise, a Nepalcompany, which owned and operated a hotel in Khatmandu. Theagreement provided for use by the foreign enterprise of therespondent's name and was to remain in force for fifteen years withan option of extension for five years. The respondent would recruitand train the requisite staff for the hotel through trainingprogrammes. The respondent would use its best efforts to advertiseand promote the business of the hotel through its existingfacilities. The respondent would make available for the hotel, itsstaff of consultants and specialists who were qualified to provideadvice in the various departments and aspects of hotel operations.Salaries and expenses of these persons would be borne or reimbursedby the foreign enterprise. The respondent was to provide trainingand instruction for key personnel for the hotel in order to preparethem to serve the hotel in the capacities for which they would betrained. The respondent was to use the hotel solely for theoperation of a first class hotel on international standards but thesame would always be and be deemed to be owned by the foreignenterprise exclusively. The respondent, however, would have arepresentation on the board of directors of the foreign enterprise.The respondent was entitled to 15 per cent. of the gross operatingprofits. The respondent was to maintain full and adequate books ofaccount and other records reflecting the results of the operationof the hotel and deliver to the foreign enterprise on or prior tothe end of each month a profit and loss statement. The respondent,as required by section 80-O of the Income-tax Act, 1961, sought theapproval of the Central Board of Direct Taxes of the agreement. TheCentral Board of Direct Taxes refused to grant approval, holdingthat the respondent, under the agreement, merely renderedmanagerial services which did not amount to technical services, andalso that the fee received by it for use of its trade name was toosmall to quantify for the purposes of section 80-O. The respondentfiled a writ petition which the Delhi High Court allowed. On appealto the Supreme Court by the Central Board of Direct Taxes, whiledismissing the appeal, the Supreme Court held that "running a well equipped modern hotel is noordinary affair. One needs a great deal of expertise,skill and technical knowledge for the purpose. Theagreement in question had to be seen as a whole and soexamined it was apparent that it provided for therendering not only of technical services for operatingthe hotel of the foreign enterprise but also providedfor professional and other services in connection withoperating of the hotel. Section 80-O was enacted withthe twin objects of encouraging the export of Indiantechnical know-how and augmentation of foreign exchangeresources of the country. Although, after the amendmentof section 80-O by the Finance (No. 2) Act of 1991 thewords "technical or professional services" had beeninserted in the place of the words "technicalhttps://hcservices.ecourts.gov.in/hcservices/services", in a matter of the present nature and the legislative intention to give relief, the term"technical services" must be interpreted to includeprofessional services also. Considering the scope ofthe agreement and the width of section 80-O, theagreement provided for "information concerningindustrial, commercial or scientific knowledge,experience or skill made available" by the respondentto the foreign enterprise for running of the hotel.Royalty, commission or fees could be in terms of apercentage of the profits earned by the foreignenterprise on account of services rendered by theIndian company. It was the substance of the case whichmattered and not the name. The Central Board of DirectTaxes was not right in not granting approval of theagreement to the respondent under section 80-O of theAct. [Since the matter related to the year 1970 the courtdid not send the matter back to the Central Board ofDirect Taxes for fresh appraisal.]After the amendment of section 80-O by the Finance (No.2) Act of 1991, the words "technical or professionalservices" have been inserted in the place of the words"technical services". The amendment was only ofclarificatory nature and the term "technical services"always included within it professional services aswell. 15. The basic purpose of section 80-O is the spread by anIndian assessee of any patent, invention, model, design, secretformula or process, or similar property right, or informationconcerning industrial, commercial or scientific knowledge,experience or skill of the assessee for use outside India and inthat process to receive income to augment the foreign exchangeresources of the country. The assessee can also make available tothe foreign enterprise, technical and professional services,expertise of which it possesses for earning foreign exchange forthe country. 16. The Central Board of Direct Taxes circular in Circular No.700 dated March 23, 1995 clarified Section 80-O by stating that aslong as the technical and professional services are rendered fromIndia and are received by foreign government or enterprise outsideIndia, deduction under Section 80-O of the Act would be avialableto the person rendering the service. Even if the foreign recepientof the service utilises the benefit of such services in India. 17. It is an undisputed fact that the assessee has renderedcommercial service as stated in the summation of facts to theforeign shipping owner and for the use of such information outsideIndia by the foreign ship owner received commission in convertibleforeign exchange. Hence, the rendering of the commercial serviceand receiving commission in foreign exchange by the assessee wouldentitle the assessee to the benefit of Section 80-O. Foreignhttps://hcservices.ecourts.gov.in/hcservices/exchange earned is foreign exchange saved. Mere deduction of the commission in foreign exchange before sending the entireconsideration in foreign exchange to the foreign ship owners andgetting it back from the ship owners in convertible foreignexchange after sending the entire amount would not change thecharacter of receiving the commission in foreign exchange. Withreference to the condition of receiving income in foreign exchangein order to come under Section 80-O, the claim of the assessee isthat the brokerage is either directly received from the foreignship owners in convertible foreign exchange or in the alternativethe Indian parties making payment of freight charges in foreigncurrency deduct the amount of brokerage in terms of foreigncurrency and the same is received by the assessee through theBankers after converting the said deduction in foreign currencyinto rupees, which according to the assessee, is as good asreceiving the payment in convertible foreign exchange as theoutflow of foreign currency from India is restricted to thatextent. The decision of the Supreme Court in the case of J.B.BODAAND CO. PVT. LTD. VS. CENTRAL BOARD OF DIRECT TAXES reported in(1997) 223 ITR 271 is in favour of the assessee. In that case, theOil and Natural Gas Commission had insured all their offshore oiland gas exploration and production operations with an Indianinsurance company. In respect of this risk, the appellant, areinsurance broker, contacted a company in London who were brokersfor placement of reinsurance business. The appellant furnished allthe details about the risk involved, the premium payable, theperiod of coverage and the portion of the risk sought to bereinsured. The London brokers contacted various underwriters andafter getting confirmation about the portion of the risk theforeign reinsurers were prepared to undertake, informed theappellant about such reinsurance coverage. Thereafter the Indianceding company handed over the total premium to be paid by it tothe foreign reinsurance company, to the appellant for onwardtransmission. The appellant applied to the Reserve Bank of Indiafor permission with a statement showing the total reinsurancepremium payable to the foreign parties, and after deducting thebrokerage due to the appellant for technical services rendered, asthe balance to be remitted to the London brokers. The appellantsought the approval of the Central Board of Direct Taxes in termsof section 80-O of the Income-tax Act, 1961, on the ground that thereinsurance brokerage retained in India under agreement with theLondon brokers amounted to receipt of income in convertible foreignexchange. The Central Board of Direct Taxes refused approval. Whenthe matter was taken to the Supreme Court, the Supreme Courtallowed the appeal by holding that the remittance to the foreignreinsurance company was made through the Reserve Bank of India inconformity with the agreement between the appellant and the foreignreinsurers, and that the remittance statement filed along with theapplication to the Reserve Bank showed that the amount due to theforeign reinsurers as also the brokerage due to the appellant andthe balance due to the foreign reinsurers were expressed andremitted in U.S. dollars. The entire transaction effected throughthe medium of the Reserve Bank of India was expressed in foreignexchange and in effect the retention of the fee due to thehttps://hcservices.ecourts.gov.in/hcservices/appellant for the services rendered was in U.S. dollars. This was receipt of income in convertible foreign exchange. A formalremittance to the foreign reinsurers first and thereafter receiptof the commission from the foreign reinsurer was unnecessary.Moreover, the Central Board had by circular dated December 20,1995, clarified the real scope and impact of section 80-O statingthat the receipt of brokerage by a reinsurance agent in India fromthe gross premia before remittance to his foreign principal wouldalso be entitled to the deduction under section 80-O of the Act.The Apex Court further observed that a two-way traffic isunnecessary. To insist on a formal remittance first and thereafterto receive the commission from the foreign reinsurer, will be anempty formality and a meaningless ritual, on the facts of thiscase". In view of the said judgment, this contention also fails. 18. For the above said reasons, the second and third questionsof law are also answered in affirmative and against the revenue.The appeals are dismissed. Sd/Asst.Registrar /true copy/ Sub Asst.Registrar raa/uskTo1.The Asst.RegistrarIncome Tax Appellate Tribunal, Rajaji Bhavan, III Floor,Besant Nagar, Madras-90 2.The Commissioner of Income Tax-2Chennai. 3.The Commissioner of Income Taxes(Appeals)121, Mahatma Gandhi Salai,Chennai-3. 4.The Joint Commissioner of Income Tax, Special Range IV, Chennai-34 1 CC To Mr.V.S.Jayakumar, Advocate, SR NO.9623 2 CC To Mrs.Pushya Sitaraman, Advocate, SR NO.9590,9591 sgl(co)pmk.23.4.2009. https://hcservices.ecourts.gov.in/hcservices/