Allowed

M/S Kanti Sweets v. Joint Commissioner of Commercial Taxes (Appeals)

Karnataka HC2 Sept 2022WP/8281/2019

Case brief

AI extract

What is this about?

The High Court quashed reassessment orders passed beyond the statutory limitation period under the Karnataka VAT Act for tax years 2006-2009 and remitted proceedings for the period June-October 2009 for a fresh hearing with cross-examination.

What did the court decide?

Quashed impugned orders dated 10.08.2018 and 17.12.2018 regarding tax periods April 2006 to May 2009; remitted proceedings for period June 2009 to October 2009. Costs allowed.

M/S Kanti Sweets Vs Joint Commissioner of Commercial… — Quashing and FIR | Karnataka HC (2022)

¶1

¹

¶2

IN THE HIGH COURT OF KARNATAKA, BENGALURU DATED THIS THE 3^RD DAY OF SEPTEMBER, 2022 BEFORE

¶3

THE HON'BLE MR.JUSTICE S.R.KRISHNA KUMAR

¶4

WRIT PETITION No.8281 OF 2019 (T-RES)

¶5

BETWEEN:

¶6

M/S. KANTI SWEETS # 14, CHANNABASAPPA STREET P.G.HALLI, BENGALURU - 560 003 BY ITS MANAGING PARTNER SHAILENDRA SHARMA.

¶7

…PETITIONER

¶8

(BY SRI. ARAVIND KAMATH, SENIOR COUNSEL APPEARING FOR SRI. GOVINDRAYA KAMATH.K., ADVOCATE)

¶9

AND:

¶10

JOINT COMISSIONER OF COMMERCIAL TAXES(APPEALS) SHANTINAGAR, BENGALURU - 560 027.

¶11

DEPUTY COMMISSIONER OF COMMERCIAL TAXES (AUDIT - 1.3). DGST-I 3^RD FLOOR, TTMC BUILDING

¶12

BMTC BUS STOP, YESHWANTHAPURA BENGALURU - 560 022.

¶13

…RESPONDENTS

¶14

(BY SRI. HEMA KUMAR., AGA)

¶15

THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED ORDER DTD 10.8.2018 PASSED BY THE R-2 AS PER ANNEXURE-A AND ORDERS DTD17.12.2018 ISSUED BY THE R-1 VIDE ORDERS BEARING VAT.AP.NO.108/18-19, VAT.AP.NO.109/18-19, VAT.AP.NO.110/18-19 AND VAT.AP.NO.111/18-19 RESPECTIVELY FOR AY 2006-07, 2007-08, 2008-09 AND 2009-10 IN SO FAR AS THE SAME PERTAINS TO TAX PERIODS APRIL 2006 TO MAY 2009 AS PER ANNEXURE-A1 TO A4 ON THE GROUND THAT THE RESPONDENTS LACKED INHERENT JURISDICTION TO PASS THESE ORDERS AND CONSEQUENTIALLY THE RECTIFICATION ORDERS DTD

¶16

²

¶17

21.12.2018 PASSD BY THE R-1 AS PER ANNEXURE-M1 TO M4, BY ISSUING THE WRIT OF CERTIORARI.

¶18

THIS W.P. COMING ON FOR FINAL HEARING THIS DAY, THE COURT MADE THE FOLLOWING:-

¶19

ORDER

¶20

In this petition, petitioner has sought for the following

¶21

reliefs:-

¶22

“ A) To quash the impugned order dtd10.8.2018 under, passed by the 2^nd Respondent as per Annexure-A and orders dated: 17.12.2018 issued by the 1^st Respondent vide orders bearing VAT.AP.No.108/18-19, VAT.AP.No.109/18-19, VAT.AP.No.110/18-19 and VAT.AP.No.111/18-19 respectively for AY 2006-07, 2007-08, 2008-09 and 2009-10 in so far as the same pertains to tax periods April 2006 to May 2009 as per Annxur-A1 to A4 on the ground that the respondents lacked inherent jurisdiction to pass these orders and consequentially the rectification orders dated: 21.12.2018 passed by the 1^st Respondent as per Annexures-M1 to M4, by issuing the writ of certiorari or any other writ or order in the nature of a writ.

¶23

B) To quash the impugned order dtd 10.8.2018 under, passed by the 2^nd Respondent as per Annexure-A and orders dated: 17.12.2018 issued by the 1^st Respondent vide orders bearing VAT.AP.No.108/18-19, VAT.AP.No.109/18-19, VAT.AP.No.110/18-19 and VAT.AP.No.111/18-19

¶24

³

¶25

respectively for AY 2006-07, 2007-08, 2008-09 and 2009-10 in so far as the same pertains to tax periods April 2006 to May 2009 as per Annxur-A1 to A4 on the ground that the respondents lacked inherent jurisdiction to pass these orders and consequentially the rectification orders dated: 21.12.2018 passed by the 1^st Respondent as per Annexures-M1 to M4, by issuing the writ of certiorari or any other writ or order in the nature of a writ and direct the 2^nd Respondent to hear the Petitioner afresh by giving reasonable opportunity of being heard and adjudicate the proceedings by independent application of mind.

¶26

C) To order for the cost of the proceedings and

¶27

D) To grant any other relief/(s) this Hon’ble Court deems fit and proper in the facts and circumstances of the case.

¶28

2. Brief facts leading to the case are as under:-

¶29

Petitioner is a partnership firm and a registered

¶30

dealer engaged in the manufacture and sale of sweets, savories and other food items. During October 2009, the premises of the petitioner was inspected by the respondents, which resulted in proceedings being initiated against the petitioner culminating in an order dated 18.12.2010 passed by the respondents under Sections

¶31

⁴

¶32

39(1) and 39(2) r/w Sections 72(2) and 36(1) of the Karnataka Value Added Tax Act, 2003 (for short ‘the KVAT Act’) creating additional demand of tax and consequential interest and penalty totally amounting to Rs.12,01,97,824/for the tax period from April 2005 to October, 2009. Aggrieved by the same, the petitioner preferred the statutory appeals before the 1^st respondent - Appellate authority. By order dated 08.08.2011, the first appellate authority allowed the appeals in relation to the period from April, 2005 to March, 2006. However, for the remaining period from April, 2006 to October, 2009, the appeals were allowed in part and the demand of the respondents was reduced.

¶33

2.1 Aggrieved by the order of the first appellate authority insofar as it relates to not fully allowing the appeal insofar as it related to the period from April, 2006 to October, 2009, the petitioner preferred a further appeal before the Karnataka Appellate Tribunal (for short ‘the KAT’). By order dated 23.05.2012, the KAT partly allowed the appeals filed by the petitioner and set aside the aforesaid orders dated 18.12.2010 and 08.08.2011 and

¶34

⁵

¶35

remitted the matter back to the prescribed authority for computation of the turnovers for the tax period from April, 2006 to October, 2009 with certain observations.

¶36

2.2 Aggrieved by the aforesaid order dated 23.05.2012, whilst the petitioner filed review petitions ST (Review) Nos.111 to 153 / 2012, the respondents-State also filed ST (Review) Nos.28 to 70 / 2013 before the KAT. By common order dated 19.08.2013, the KAT dismissed the review petitions filed by the petitioner and allowed the review petitions filed by the State and set aside the aforesaid orders dated 18.12.2010 and 08.08.2011 and remitted the matter back to the prescribed authority for concluding the reassessments afresh after following due procedure and bearing in mind the observations made in the body of the order.

¶37

2.3 Pursuant to the aforesaid order dated 19.08.2013 passed by the KAT, the respondents did not take any steps and it was only on 02.02.2018 that the 2^nd respondent issued a proposition notice for the period April, 2006 to October, 2009. The petitioner submitted replies dated 19.02.2018, 20.02.2018 and 06.03.2018 inter alia

¶38

⁶

¶39

disputing, denying and repudiating the various contentions, allegations and claim of the respondents including contending that the demand made by the respondents in the notice dated 02.02.2018 was barred by limitation and without jurisdiction or authority of law and that the same deserves to be withdrawn by the respondents. Pursuant thereto, the 2^nd respondent passed the impugned order dated 10.08.2018 enhancing the tax, interest and penalty allegedly payable by the petitioner for the period April, 2006 to October, 2009.

¶40

2.4 Aggrieved by the impugned order dated 10.08.2018, petitioner preferred statutory appeals which were rejected by the 1^st respondent vide impugned order dated 17.12.2018. Subsequently, petitioner filed rectification application before the 1^st respondent which were partially allowed vide the impugned order dated 21.12.2018. Aggrieved by the impugned orders, the petitioner is before this Court by way of the present petition.

¶41

⁷

¶42

Heard Sri.Aravind Kamath, learned Senior counsel appearing for the petitioner and learned AGA for the respondents and perused the material on record.

¶43

In addition to reiterating the various contentions urged in the petition and referring to the material on record, learned Senior counsel for the petitioner submits that the respondents failed to consider and appreciate that the impugned orders passed in relation to the period from April, 2006 to May, 2009 were barred by limitation, inasmuch as the same had been passed beyond the prescribed periods of 5 years, 8 years and 7 years as provided in Section 40(1) of the KVAT Act. It is submitted that even if the period, during which the aforesaid appeals and revisions were pending is to be excluded, in view of the undisputed fact that the review petitions were disposed of on 19.08.2013, the impugned order dated 10.08.2018 passed by the 2^nd respondent is hopelessly barred by limitation, since the same was passed beyond the period prescribed under Section 40(1) of the KVAT Act. It is also submitted that for the purpose of computing the period of limitation,

¶44

⁸

¶45

what is relevant is the date of passing / making the order and not mere issuance of the proposition notice and as such, the impugned order dated 10.08.2018 was barred by limitation on this ground also.

¶46

4.1 Learned Senior counsel invites my attention to the tabular column submitted by the petitioner as contained in the memorandum of petition and synopsis in order to point out that the period, during which the earlier round of litigation was pending up to 19.08.2013 when the review petitions were disposed of was excluded, despite which the impugned order dated 10.08.2018 insofar as it relates to the tax period from April, 2006 to May, 2009 is clearly barred by limitation. Insofar as the tax period from June, 2009 to October, 2009 is concerned, it is submitted that the 1^st respondent – first appellate authority has failed to consider and appreciate the material on record, in particular, the submissions and documents of the petitioner and as such, the impugned order in relation to this period also deserves to be set aside. In this regard, it is also submitted that apart from the fact that the 2^nd respondent did not have jurisdiction or authority of law to levy tax for

¶47

⁹

¶48

the said period from June 2009 to October, 2009, the impugned order for the said period is contrary to Sections 3(1) and 3(2) of the KVAT Act. Further, the 2^nd respondent committed an error in failing to provide an opportunity to the petitioner to cross-examine the witnesses despite specific request being made in this regard and as such, the impugned order is also violative of principles of natural justice and deserves to be set aside.

¶49

4.3 It is therefore submitted that the impugned order passed by the 1^st respondent deserves to be quashed. In support of his contentions, learned Senior counsel has placed reliance upon the following judgments:-

¶50

(i) Pandurang Dhondi Chougule and Ors. Vs. Maruti Hari Jadhav and others – AIR 1996 SC 153;

¶51

(ii) Harbansal Sahnia & Anr. Vs. Indian Oil Corporation Ltd., & Ors. – (2003) 2 SCC 107;

¶52

(iii) Union of India & Ors. Vs. Tantia Construction Private Limited – (2011) 5 SCC 697; (iv) Ciftech Solutions Pvt. Ltd., & Ors. Vs. State of Karnataka & Others – W.P.No.51802/2014 dated 12.08.2015;

¶53

(v) Pushkar Dress Manufacturers & others. Vs. State of Karnataka – (2018) 1 AKR 523; and

¶54

¹⁰

¶55

(vi) M/s. Infinite Builders & Developers vs.

¶56

The Additional Commissioner of Commercial Taxes – (2013) SCC Online KAR 5001;

¶57

Per contra, learned AGA for the respondents, in

¶58

addition to reiterating the various contentions urged in the statement of objections and referring to the material on record, submits that the present petition is not maintainable in view of availability of equally efficacious and alternative remedy by way of an appeal before the KAT. It is further submitted that the impugned order had been passed within the period of limitation as provided in Section 40(1) of the KVAT Act in view of exclusion of the period during which litigations were pending in the light of Section 40(3) of the KVAT Act. It is therefore submitted that there is no merit in the petition and that the same is liable to be dismissed. In support of his contentions, reliance is placed on the decision of this Court in the case of M/s.Alliance Infrastructure Project (P) Ltd., vs. The Commercial Tax Officer & Anr. – W.P.No.30531/2018 Dated 17.10.2019.

¶59

I have given my anxious consideration to the rival

¶60

submissions.

¶61

¹¹

¶62

Before adverting to the rival contentions, it is necessary to refer to Section 40 of the KVAT Act, 2013, which is extracted as hereunder:-

¶63

40. Period of limitation for assessment .- [(1) An assessment under section 38 or re-assessment under Section 39 of an amount of tax due for any prescribed tax period shall not be made after five years after the end of the prescribed tax period.

¶64

Provided that an assessment or reassessment relating to any tax period upto the period ending 31^st day of March, 2007 shall be made within a period of eight years after the end of the prescribed tax period.

¶65

Provided further that an assessment or reassessment relating to any tax period commencing from the 1^st day of April, 2007 upto the period ending 31^st day of March, 2012 shall be made within a period of seven years after the end of the prescribed tax period.

¶66

(2) Notwithstanding anything contained in subsection (1), if any tax is, not paid by a dealer who has failed to get registered though liable to do so or fraudulently evaded attracting punishment under Section 79, an assessment or reassessment may be made within eight years from the end of the prescribed tax period.

¶67

Provided that an assessment or reassessment relating to any tax period up to the period ending 31^st day of March, 2007 shall be made under this sub-

¶68

¹²

¶69

section within a period of ten years after the end of the prescribed tax period.]

¶70

(3) In computing the period of limitation specified for assessment or re-assessment, as the case may be under this Act, the period taken for disposal of any appeal against an assessment or other proceeding by the appellate authority, a tribunal or competent court shall not be taken into account in computing such period for assessment or reassessment as the case may be.

¶71

The material on record discloses that the tax periods which are the subject matter of the impugned orders, the period during which proceedings were pending between the parties till culmination of the same before the KAT on 19.08.2013 when the review petitions filed by the petitioner as well as the State were disposed of and the period of limitation prescribed under Sections 40(1) and 40(3) are not in dispute and the same have been correctly tabulated and stated in paragraphs 13 to 15 in the memorandum of writ petition. It is well settled that taxing / fiscal statutes have to be interpreted and construed strictly as held in several judgments of the Apex Court and this Court including the case of Commissioner of Customs

¶72

¹³

¶73

vs. Dilip Kumar & Co. & others – (2018) 9 SCC 1,

¶74

wherein it was held as under:-

¶75

54. In Govind Saran Ganga Saran v. CST [Govind Saran Ganga Saran v. CST1985 Supp SCC 205 : 1985 SCC (Tax) 447] , this Court pointed out three components of a taxing statute, namely, subject of the tax; person liable to pay tax; and the rate at which the tax is to be levied. If there is any ambiguity in understanding any of the components, no tax can be levied till the ambiguity or defect is removed by the legislature. [See Mathuram Agrawal v. State of M.P. [Mathuram Agrawal v. State of M.P., (1999) 8 SCC 667] ; Indian Banks' Assn. v. Devkala Consultancy Service [Indian Banks' Assn. v. Devkala Consultancy Service, (2004) 11 SCC 1 : AIR 2004 SC 2615] and Consumer Online Foundation v. Union of India [Consumer Online Foundation v. Union of India, (2011) 5 SCC 360] .]

¶76

55. There is abundant jurisprudential justification for this. In the governance of rule of law by a written Constitution, there is no implied power of taxation. The tax power must be specifically conferred and it should be strictly in accordance with the power so endowed by the Constitution itself. It is for this reason that the courts insist upon strict compliance before a State demands and extracts money from its citizens towards various taxes. Any ambiguity in a taxation provision, therefore, is

¶77

¹⁴

¶78

interpreted in favour of the subject/assessee. The statement of law that ambiguity in a taxation statute should be interpreted strictly and in the event of ambiguity the benefit should go to the subject/assessee may warrant visualising different situations. For instance, if there is ambiguity in the subject of tax, that is to say, who are the persons or things liable to pay tax, and whether the Revenue has established conditions before raising and justifying a demand. Similar is the case in roping all persons within the tax net, in which event the State is to prove the liability of the persons, as may arise within the strict language of the law. There cannot be any implied concept either in identifying the subject of the tax or person liable to pay tax. That is why it is often said that subject is not to be taxed, unless the words of the statute unambiguously impose a tax on him, that one has to look merely at the words clearly stated and that there is no room for any intendment nor presumption as to tax. It is only the letter of the law and not the spirit of the law to guide the interpreter to decide the liability to tax ignoring any amount of hardship and eschewing equity in taxation. Thus, we may emphatically reiterate that if in the event of ambiguity in a taxation liability statute, the benefit should go to the subject/ assessee. But, in a situation where the tax exemption has to be interpreted, the benefit of doubt should go in favour of the Revenue, the aforesaid conclusions are expounded only as a prelude to

¶79

¹⁵

¶80

better understand jurisprudential basis for our conclusion. We may now consider the decisions which support our view.

¶81

While dealing with Section 40 of the KVAT Act, the co-ordinate Bench of this Court in the case of Ciftech Solutions Pvt. Ltd., vs. State of Karnataka – W.P.No.51802/2014 & connected matters dated

¶82

12.08.2015 , held as under:-

¶83

21. It is well settled that no statute shall be construed to have a retrospective operation until its language is such that would require such a conclusion. The exception to this Rule is enactments dealing with procedure. The law of limitation being a procedural law, is retrospective in operation in the sense that it will also apply to proceedings pending at the time of enactment as also to proceedings commenced thereafter. However, where the right to such action is barred under the law of limitation in force before the new provision came into operation and a vested right has accrued to another, the new provision cannot revive the barred right or take away the accrued vested right.

¶84

22. Keeping these principles in mind, when the amended provisions are perused namely, the two provisos to sub-section (1) of Section 40 introduced by Act No.17/2012 would indicate that any assessment or re-assessment relating to any tax

¶85

¹⁶

¶86

period up to the period ending 31.03.2007 shall be made within a period of eight years after the end of the prescribed tax period. In other words, any assessment or re-assessment proceedings relating to the period 31^st March, 2007 if commenced, shall be concluded within a period of eight years after the end of prescribed tax period.

¶87

Re: W.P.NO.51802/2014

¶88

23. For the assessment year 2006-07, prescribed authority issued a proposition notice dated 25.11.2013 on the ground that he desires to satisfy himself that the returns filed for the tax period 200607 under the CST Act, 1956 are in accordance with prescribed Rules. Thereafter, re-assessment order came to be passed on 25.03.2014 (Annexure-A) which has been questioned as one barred by limitation prescribed under Section 40 of the Act and without jurisdiction. For the tax period ended on March, 2007, the limitation for assessment under Section 38 or re-assessment under Section 39 was five years which was to end on 31.03.2012. By Act No.12/2011 the words “four years” found in clause (a) of sub-section (1) was substituted with the words “five years”. Thus, the period of four years has got enlarged to five years and as per sub-section (1) of Section 40, the limitation existed upto 31.03.2012. sub-section (1) of Section 40 was substituted by Act No.17/2012 whereunder two provisos to sub-section (1) was added, whereby the period of limitation was extended to eight years and seven years respectively

¶89

¹⁷

¶90

as provided under the said provisos. This amendment was further substituted by Act No.54/2013 which indicates that sub-section (1) of Section 40 is deemed to have been substituted with effect from 1^st April, 2005 itself. The said amendment would authorise making of assessment or reassessment before the expiration of eight years from the end of the particular assessment year. Thus, it would be immaterial if the period of assessment or reassessment under unamended provision had expired. What is to be looked into is, the completion of the assessment or re-assessment under the provisos to sub-section (1) of Section 40 which is to be done before the expiration of eight years of that particular assessment year. Thus, the assessment for the year 2006-07 could be re-opened upto 31.03.2015. In other words, such assessment or re-assessment under Section 38 or Section 39 will have to be completed within eight years of the particular assessment year.

¶91

As stated supra, the actual period of limitation for

¶92

the purpose of enabling the 2^nd respondent to pass the impugned order dated 10.08.2018 is clearly and undisputedly indicated in the tabular column averred by the petitioner in the present petition and the same, if read in conjunction and juxtaposition with Sections 40(1) and 40(3) of the KVAT Act, excluding the period spent in litigation

¶93

¹⁸

¶94

culminating in the order dated 19.08.2013 passed by the KAT disposing of the review petitions filed by the petitioner as well as the State, it is abundantly clear that the impugned order dated 10.08.2018 passed by the 2^nd respondent in relation to the tax period from April, 2006 to May, 2009 is hopelessly barred by limitation and the same deserves to be quashed.

¶95

As rightly contended by the learned Senior counsel for the petitioner, the provisions of Section 40 and its amendments of the KVAT Act in relation to the subject tax period have been considered by this Court in Ciftech’s case supra, consequently, I am of the considered opinion that the impugned order passed by the 2^nd respondent is barred by limitation and the 2^nd respondent did not have jurisdiction or authority of law to pass the impugned order beyond the prescribed period of limitation and as such, the impugned order deserves to be quashed on this ground also.

¶96

Insofar as the contention urged by the learned AGA that the petition against the impugned order passed

¶97

¹⁹

¶98

by the 1^st respondent – appellate authority is not maintainable in view of availability of a further appeal before the KAT is concerned, in the light of the well settled principle of law that the issue / question of limitation concerns the jurisdiction of the 2^nd respondent to pass the impugned order as held in several judgments including the judgment of the Apex Court in the case of Pandurang Dhondi Chougule & Ors. vs. Maruti Hari Jadhav – AIR 1966 SC 153 and in view of my finding above that the impugned order is barred by limitation in relation to the period from April 2006 to May, 2009, I am of the considered opinion that the present petition, in the peculiar / special facts and circumstances is maintainable and the said contention of the respondents cannot be accepted.

¶99

Insofar as the impugned order in relation to the tax period from June 2009 to October 2009 is concerned, as rightly contended by the learned Senior counsel for the petitioner, in addition to the fact that the claim of the petitioner including the submissions and documents produced by it have not been considered or appreciated,

¶100

²⁰

¶101

the 2^nd respondent committed an error in failing to provide an opportunity to the petitioner to cross-examine the witnesses, despite specific request being made in this regard and as such, adopting a justice oriented approach and in order to provide one more opportunity to the petitioner to put forth its contentions and documents and also cross-examine the witnesses, I am of the view that the impugned order deserves to be set aside and the matter be remitted back to the 2^nd respondent for reconsideration afresh in respect of the aforesaid period from June, 2009 to October, 2009.

¶102

In the result, I pass the following:-

¶103

ORDER

¶104

(i) Petition is hereby allowed.

¶105

(ii) The impugned orders dated 10.08.2018 at Annexure-A passed by the 2^nd respondent as well as the impugned orders dated 17.12.2018 at Annexures- A1 to A4 and the impugned rectification orders at Annexures-M1 and M4 dated 21.12.2018 passed by the 1^st respondent – appellate authority, insofar as it relates to the period from

¶106

²¹

¶107

April, 2006 to May, 2009 are hereby quashed and consequently, all demand notices, penalty notices etc., issued pursuant thereto, are also hereby quashed.

¶108

(iii) The impugned orders dated 17.12.2018 at Annexures- A1 to A4 and the impugned rectification orders at Annexures-M1 and M4 dated 21.12.2018 passed by the 1^st respondent – appellate authority insofar as it relates to the period from June, 2009 to October, 2009 are hereby set aside and the matter is remitted back to the 1^st respondent for reconsideration afresh in accordance with law as expeditiously as possible, after providing sufficient and reasonable opportunity to the petitioner in this regard.

¶109

(iv) Liberty is reserved in favour of the petitioner to produce additional pleadings, documents etc., to the respondents, who shall consider and pass appropriate orders in accordance with law.

¶110

Srl.

M/S Kanti Sweets v. Joint Commissioner of Commercial Taxes (Appeals)

Case brief

What is this about?

What did the court decide?

M/S Kanti Sweets v. Joint Commissioner of Commercial Taxes (Appeals)

Case brief

What is this about?

What did the court decide?

What the court decided

A compact analysis

Issues for consideration

Cases cited

Statutes considered

Parties & counsel

Coram

Case details

Similar cases

Shri Dinesh Kumar B Vs the State of Karnataka

Dheeraj Acharya Y Vs State of Karnataka

Jayasimha Vs State of Karnataka

Jsw Steel Limited Vs the Union of India

Pan Synthetics Private Limited Vs Additional/Joint/Deputy/Assistant Commissioner of Income Tax/Income-Tax Officer

Siddhartha Vihar Trust Vs State of Karnataka