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Facts
This consolidated judgment addresses multiple appeals from various assessees and the Revenue for different assessment years, primarily concerning additions made by the Assessing Officer (AO) and sustained by the CIT(A). The additions relate to alleged bogus purchases (often involving 'Ahartiyas' or commission agents), unexplained cash deposits during demonetization, unexplained cash found during search operations, and inventory discrepancies based on loose sheets and tax audit reports.
Held
The Tribunal held that for alleged bogus purchases, if sales are not disputed and books are accepted, only the gross profit embedded in such purchases should be added, not the entire purchase value. It also confirmed the deletion of additions where cash deposits during demonetization were proven to be internal bank transfers. Furthermore, the Tribunal deleted additions based solely on uncorroborated loose slips found during search, emphasizing their lack of evidentiary value without supporting material.
Key Issues
1. Whether the entire value of alleged bogus purchases can be disallowed or only the gross profit embedded therein. 2. Whether additions for cash deposits during demonetization are justified if they are internal bank transfers. 3. Whether additions for unexplained cash and inventory discrepancies based on uncorroborated loose sheets found during search are sustainable.
Sections Cited
Section 37(1), Section 69A, Section 69B, Section 115BBE, Section 68, Section 44AB, Section 131, Section 153A, Section 153C, Section 132(4A), Section 292C(1)
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Income Tax Appellate Tribunal, DELHI
Before: DR. B.R.R. KUMAR & SH. YOGESH KUMAR US
per Audit report is 102 quintal while as per Inventory records the quantity of Matar flour is 332.8 quintal. This means difference of 69.2 quintal has been sold out of books. ii. Similar is the observation in case of Moong and Besan. iii. The quantity of Chilka Churi as per Audit report is 1235 quintal while as pers Inventory records the quantity of Chilka Churi is 410.3 quintal. This means the stock as per Audit report is short by 824.7 quintal. However, there is another item appearing in the Inventory records and that is Chani Kant refraction. The quantity of Chani Kant refraction is 825.5 quintal which is very close to short stock of Chilka churi. But there is no evidence that Chani Kant refraction is same as Chilka Churi and both have the same valuation so that can be clubbed together.
He has also checked the Audit reports of earlier years and found that no item in the name of Chani Kant refraction appear there.
Therefore, stock of Chani Kant refraction is considered as excess stock not appearing in the audit report and thus not forming the part of closing stock. However, the valuation of Chani Kant & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 48 refraction is taken as Rs.2000/-per quintal which is the then market price. AO has also not given any. reason/justification behind taking this price as Rs.10,000/- per quintal, This results into the addition of Rs.16,51,000/(825.5*2000) on account of undisclosed investment in the stock.
Accordingly addition of Rs.l,15,83,000/- is restricted to Rs.16,51,000/- as unexplained investment u/s 69B r.w.s.
115BBE of the I.T. Act, 1961 for the relevant A.Y. 2018-19 by the ld. CIT(A).
ENHANCEMENT: In view of the shortage of stock which has been considered as sales out of books and as discussed above, the GP on these sales is calculated as under by the ld. CIT(A):
Accordingly addition of Rs.1,62,648/- was made by ld. CIT(A) on account of undisclosed sales for the relevant AY 2018-
Against this both the parties are in appeal before us. & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 49 At this juncture, the ld. AR submitted that owing to the small quantum of the addition, the ground is not being pressed hence dismissed.
Next ground in the case of M/s. Paramanand and Sons Food Products Pvt. Ltd. in in assessee’s appeal is with regard to enhancement of income in view of shortage of stock.
Since we have given direction while adjudicating the issue relating to addition made on account of alleged variation of physical inventory of stock as compared to tax audit report, this ground is not required to be adjudicated independently and the assessee will get consequent relief. Ordered accordingly.
Next ground for our consideration in revenue’s appeal in the case of Shri Devesh Mittal (Prop. M/s. Mittal Enterprises) in in assessment year 2018-19 is with regard to deletion of addition of Rs.9,15,27,773/- on account of hand written note and I Phone images.
Addition of transactions of another assessee in the case of the assessee: & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 50 The ld. D.R. submitted that the above addition made by ld. CIT(A) deleted the addition on observing that the above addition was made on the basis of images from the mobile phone of the assessee. The assessee wrongly claimed all these entries pertain to M/s. Parmanand & Sons Food Products Pvt. Ltd. Thus, the ld. CIT(A) relied that the assessee has received the details from customers from who he has to coordinate for recovery of dues and it was wrongly observed by ld. CIT(A) that this amount is recoverable from the customers of M/s. Parmanand & Sons Food Products Pvt. Ltd., which required to be examined at the end of ld. AO and ld. CIT(A) without verifying the same deleted the entire addition the same to be reversed.
The ld. A.R. submitted that the assessee during the course of assessment proceedings it was duly explained and substantiated that the images found from his mobile had details of amount recoverable from the customers of M/s Parmanand and Sons Food Products Private Limited and none the transactions mentioned on said images were executed by him in his personal capacity. The assessee had also furnished copies of ledger account of customers from the books of account of M/s Parmanand and Sons Food Products Private Limited. The & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 51 assessee is one of the assessee of PAN Brand group and is duly engaged in family business. In this era of modernization and digitalization finding of business transactions from mobile of a person is natural and no adverse cognizance can be drawn on the basis of the same. One has to objectively look upon the nature of transactions. M/s Parmanand and Sons Food Products Private Limited was also being assessed in the jurisdiction of ld. AO himself and he has simultaneously passed assessment order in the case of M/s Parmanand and Sons Food Products Private Limited also. Thus, the ld. A.R. submitted that the ld AO cannot claim that he was unaware that the assessee was engaged in family business or was unaware about the transactions recorded in images found from his mobile. All the transactions recorded in the images found from mobile of the assessee pertained to M/s Parmanand and Sons Food Products Private Limited and were duly recorded in its books of account.
Thus, the ld. A.R. submitted that it is evident that the ld. AO has made additions of transactions entered into by M/s Parmanand and Sons Food Products Private Limited in the case of the assessee which is not tenable under the law. & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 52 47. The Ld. A.R. submitted that from the perusal of the documents which were also available before the Ld. AO during the course of assessment proceedings, it is evident that all the amounts mentioned in images found were duly recorded in the books of accounts of M/s. Parmanand and Sons Food Products Private Limited and none of the amount represent an unaccounted transaction. In view of the stated facts of the case, the ld. A.R. submitted that the no addition can be made.
We have heard the rival submissions and perused the materials available on record. The contention of the ld. A.R. is that the entries found in his mobile phone shows the details of amount recoverable from the customers of M/s. Parmanand and Sons Food Products Pvt. Ltd. which are duly accounted in their books of accounts of M/s. Parmanand & Sons Food Products Pvt. Ltd. and nowhere related to the present assessee. These entries are unsubstantiated and not supported by any material evidence to show that it is anyway related to the present assessee before us. In the present case, the image taken from the mobile phone of the assessee does not show the owning of any money, bullion, jewellery or valuable article. Being so, the lower authority is not justified in considering uncorroborated material found in the & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 53 mobile phone of assessee to make any addition. The ld. CIT(A)
categorically observed that these entries are pertaining to M/s.
Parmanand & Sons Food Products Pvt. Ltd. by verifying with the bank statement of M/s. Parmanand & Sons Food Products Pvt. Ltd. The assessee have nothing to do with these entries and he was only monitoring and coordinating the timely collection of payment from various parties on behalf of M/s. Parmanand & Sons Food Products Pvt. Ltd. and thus the ld. CIT(A) rightly deleted this addition in the hands of present assessee.
Accordingly, this ground of appeals of revenue in is dismissed.
49. In & 1855/Delhi/2022 (AY 2017- 18 & 2018-19) Assessee’s appeals in the case of M/s. Globus Agrofoods Private Limited, the Ground with regard to sustaining addition of Rs.49,21,568/- out of Rs.2,54,85,394/- and Rs.83,31,932/- out of Rs.13,67,70,799/- which has been made in the assessment years 2017-18 and 2018-19 respectively on the basis of loose sheets found during the search operation in the case of assessee.
Facts of the case are that sustaining addition of Rs.49,21,568/- out of Rs.2,54,85,394/- and Rs.83,31,932/- out & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 54 of Rs.13,67,70,799/- has been made in the assessment years 2017-18 and 2018-19 respectively on the basis of loose sheets found during the such operation. Facts in both assessment years are same. We will consider the facts in assessment year 2017-18.
The ld. CIT(A) observed that the addition of Rs.2,54,85,394/- was made on the basis of entries on loose sheets found during search operation. To ascertain the veracity of what assessee is stating the reply filed by the assessee for each entry is examined by the ld. CIT(A) in the following table: & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 55 & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 56 & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 57
The decision “Contention of the assessee is found to be correct” has been arrived by ld. CIT(A) after duly verifying: & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 58 i. Such entries recorded in Books of M/s. Parmanand & Sons Food Products Pvt. Ltd. and the assessee: ii. Supported by the Bank statement, and iii. Observing that these books of account were in the possession of the Department since 19.12.2017 i.e. from the date of search leaving no scope for making any alterations in the cash book.
Similarly, the decision “Contention of the assessee is not found to be correct” has been arrived by the ld. CIT(A) after observing that:
i. No such books of accounts were found at the time of search; ii. Transactions were not through banking channel, and iii. There is all the possibility that these entries were created to explain the seized papers.
Accordingly, addition of Rs.2,54,85,394/- made by the ld. AO u/s 69A of the Act on account of unexplained money, was restricted to Rs.49,21,568/- and this ground of appeal was partly allowed by the ld. CIT(A). Against this assessee is in appeal before us.
We have heard both the parties and perused the materials available on record. As we have already held that the addition is based on the loose slips found during the course of search action at the premises of the assessee. The ld. CIT(A) sustained partial addition in these assessment years and deleted the major addition after observing that these entries are entered in books of accounts of M/s. Parmanand and Sons Food Products Pvt. Ltd., supported by bank statements and books of accounts cannot be & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 59 audited by assessee after 19.12.2017 from the date of search as the books of accounts are with the possession of department. However, he observed that contention of the assessee is not correct that no such books of accounts are found at the time of search, transactions were not gone through the banking channel and certain entries are created to explain the seized material. Hence, he sustained addition of Rs.49,21,568/- in assessment year 2017-18 and Rs.83,31,932/- in assessment year 2018-19. In our opinion, the basis for addition is loose slips, which is having no evidentiary value under Indian Evidence Act and accordingly, we find no reason to sustain additions. Even otherwise, these loose slips cannot be relied upon without any corroborative material supporting the same and it cannot be bind the assessee unless there is supporting documents. Without any cogent material, it cannot be presumed that the alleged transaction took place. Therefore, there is no adverse inference could be drawn on the basis of these unsupported loose slips.
Further, no corroborative evidence was brought on record to confirm that the entries in seized material were actually reflects the transactions in the form of cash payment between the assessee and others. In the seized material, there was no concrete proof regarding the payment of cash loan between these parties. Even otherwise, it does not suggest the amount of involved, either in the form of cheque and cash, date transaction and other details and also there was no circumstantial evidence to suggest all these things. The department is relying on only the unsubstantiated loose slips to suggest the transactions. In our opinion, the addition made by the ld. AO only on the basis of & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 60 conjectures and surmises and presumption and money was transacted between the parties. The above conclusion drawn by the ld. AO is contrary to the elementary understanding of the contact between the parties. As per the trade practice, we cannot come to the conclusion that an assessee will transact such huge amount without a piece of paper to support the transaction. Hence, there was no reason for making such addition. In our opinion, the conclusion drawn by ld. AO is only imagination and based on conjectures and surmises.
In the case of Dreamcity Buildwell (P.) Ltd. reported in 57. [2019] 110 taxmann.com 28 (Delhi), in the identical facts, Hon’ble High Court of Delhi had deleted the additions with the following reasoning:- “15. It can straightaway be noticed that the crucial change is the substitution of the words 'books of account or documents, seized or requisitioned belongs to or belong to a person other than the person referred to in Section 153A' by two clauses i.e. a and b, where clause b is in the alternative and provides that 'such books of account or documents, seized or requisitioned' could 'pertain' to or contain information that 'relates to' a person other than a person referred to in Section 153A of the Act.
• The trigger for the above change was a series of decisions under Section 153C, as it stood prior to the amendment, which categorically held that unless the documents or material seized 'belonged' to the Assessee, the assumption of jurisdiction under Section 153C of the Act qua such Assessee would be impermissible. The legal position in this regard was explained in Pepsi Foods (P.) Ltd. v. Asstt. CIT [2014] 367 ITR 112 (Del)where in para 6 it was held as under: '6. On a plain reading of Section 153C, it is evident that the Assessing Officer of the searched person must be "satisfied" that inter alia any document seized or requisitioned "belongs to" a person other than the searched person. It is & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 61 only then that the Assessing Officer of the searched person can handover such document to the Assessing Officer having jurisdiction over such other person (other than the searched person). Furthermore, it is only after such handing over that the Assessing Officer of such other person can issue a notice to that person and assess or reassess his income in accordance with the provisions of Section 153A. Therefore, before a notice under Section 153C can be issued two steps have to be taken. The first step is that the Assessing Officer of the person who is searched must arrive at a clear satisfaction that a document seized from him does not belong to him but to some other person. The second step is -after such satisfaction is arrived at - that the document is handed over to the Assessing Officer of the person to whom the said document "belongs". In the present cases it has been urged on behalf of the petitioner that the first step itself has not been fulfilled. For this purpose it would be necessary to examine the provisions of presumptions as indicated above. Section132 (4A) (i) clearly stipulates that when inter alia any document is found in the possession or control of any person in the course of a search it may be presumed that such document belongs to such person. It is similarly provided in Section 292C (1) (i). In other words, whenever a document is found from a person who is being searched the normal presumption is that the said document belongs to that person. It is for the Assessing Officer to rebut that presumption and come to a conclusion or "satisfaction" that the document in fact belongs to somebody else. There must be some cogent material available with the Assessing Officer before he/she arrives at the satisfaction that the seized document does not belong to the searched person but to somebody else. Surmise and conjecture cannot take the place of "satisfaction'. • In the present case the search took place on 5th January 2009. Notice to the Assessee was issued under Section 153 C on 19th November 2010. This was long prior to 1st June, 2015 and, therefore, Section 153C of the Act as it stood at the relevant time applied. In other words, the change brought about prospectively with effect from 1st June, 2015 by the amended Section 153C (1) of the Act did not apply to the search in the instant case. Therefore, the onus was on the Revenue to show that the incriminating material/documents recovered at the time of search & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 62 'belongs' to the Assessee. In other words, it is not enough for the Revenue to show that the documents either 'pertain' to the Assessee or contains information that 'relates to' the Assessee. • In the present case, the Revenue is seeking to rely on three documents to justify the assumption of jurisdiction under Section 153 C of the Act against the Assessee. Two of them, viz., the licence issued to the Assessee by the DTCP and the letter issued by the DTCP permitting it to transfer such licence, have no relevance for the purposes of determining escapement of income of the Assessee for the AYs in question. Consequently, even if those two documents can be said to 'belong' to the Assessee they are not documents on the basis of which jurisdiction can be assumed by the AO under Section 153C of the Act. • As far as the third document, being Annexure A to the statement of Mr. D. N. Taneja, is concerned that was not a document that 'belonged' to the Assessee. Admittedly, this was a statement made by Mr. Taneja during the course of the search and survey proceedings. While it contained information that 'related' to the Assessee, by no stretch of imagination could it be said to a document that 'belonged' to the Assessee. Therefore, the jurisdictional requirement of Section 153C of the Act, as it stood at the relevant time, was not met in the present case. • For the aforementioned reasons, this Court concludes that the ITAT committed no legal error in holding that the AO had wrongly assumed jurisdiction under Section 153C qua the Assessee. The ITAT, rightly, therefore, set aside the order of the CIT (A), which had held the contrary.”
At this point, we rely on the order of the Tribunal in the case of ACIT Vs. Manchukonda Shyam in ITA 87/Viz/2020 dt.23.09.2020 wherein the Tribunal at paras 6 and 6.1 has held as under :
“6. We have heard both the parties, gone through the orders of the authorities below. Shri Lanka Anil Kumar is an employee of M/s Navaratna Estates Ltd. A search u/s 132 was conducted & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 63 in the residence of Shri Lanka Anil Kumar and certain sums were found in whatsapp messages in digits. When asked to explain, Shri Anil Kumar stated that the amounts were written in thousands represent lakhs and the total sum of Rs.1,05,00,000/-was taken as loan from the assessee in cash for his business purposes. When confronted with the assessee, he explained that the amounts mentioned in thousands are correct and the total amount would be in the range of Rs.5,000/- and Rs.10,000/- given to Shri Anil Kumar to meet the petty cash or miscellaneous expenses from M/s Navaratna Estates during registration of properties. A search u/s 132 was conducted in the case of Shri Lanka Anil Kumar as well as the assessee and the survey u/s 133A was conducted in the case of M/s Navaratna Estates. No evidence was found by the department either in the premises of the assessee or in the premises of M/s Navaratna Estates, having given loan to Sri Anil Kumar to the extent of Rs.1,05,00,000/-. In the search proceedings in the residence of Shri Anil Kumar also, no evidence with regard to unaccounted investment or expenditure representing the loan supposed to be taken from the assessee was found. Merely on the basis of the statement given by Shri Lanka Anil Kumar, which was subsequently retracted, the AO made the addition on the presumption that the assessee had advanced the sums to Shri Lanka Anil Kumar without bringing any evidence on record. The AO has neither given opportunity to the assessee to cross examine the third party nor disproved the explanation given by the assessee. As found from the order of the AO Sri Lanka Anil Kumar is an employee of M/s Navaratna Estates and drawing the salary of Rs.25000/- per month. He explained that the sums mentioned in the whatsapp messages were related to the amounts given to Sri Lanka Anil Kumar in the range of Rs.5,000/- to Rs.10,000/- to meet the petty cash and miscellaneous expenses. No evidence was found with regard to the investment made by Shri Anil Kumar in his own business out of the loans stated to have given by the assessee. In the above facts and circumstances there is no reason to disbelieve the statement given by the assessee that the payments were given for meeting petty cash or miscellaneous expenses. The Ld.CIT(A) following the decisions of Hon’ble Jurisdictional High Court as well as this Tribunal held that on the basis of notings and loose sheets found from third parties and the statement of third parties, the additions cannot be made without having corroborative / independent evidences. For the sake of clarity and convenience, we extract relevant part & Ors. Kwality Techmech Pvt. Ltd. & other connected matters 64 of the order of Ld.CIT(A) in para No.6.2 of page No.13 which reads as under : “6.2. I have considered the assessment order and submissions of the appellant. It is seen that the addition made by the AO is solely based on the social media (whatsapp) messages exchanged between the appellant and Mr. Anil Kumar, an employee of M/s Navaratna Estates. A statement u/s.132 recorded from Mr. L, Anil Kumar during the course of Search during which Mr. L. Anil Kumar was questioned and he explained the nature and 'details of messages exchanged by him with the appellant. The messages contain details of transactions in digits. Those were explained to be in lakhs of rupees and the transaction was loans advanced by the appellant to Mr.L. Anil Kumar whereas the appellant explained the same to be in thousands of rupees which were given for miscellaneous expenses. Mr.L. Anil Kumar also took similar stand in his assessment proceedings and said that the statement given during Search was under duress. The AO has not brought on record any evidences as to utility of such amount nor any other corroborative evidence to support the findings. Such evidences(Messages) without any supporting/corroborative along with admission of third person cannot be, basis for AO to come to conclusion and make addition in the assessment order. The low or the issue is laid down by the jurisdictional High Court, and followed by ITAT consistently in the following cases.
• K. V. Lakshmi Savitri Devi Vs ACT 148 ITJ 517 (Hyd). • K. V. Lakshmi Savjtri Devi Vs ACIT ITTA 563 of 2017 (AP)(HC) • Jawahar Bhai Atmaram Hathiwala Vs ITO 128 ITJ 36 (Ahd) • DCIT Vs B. Vijaya Kumar & 931 of 2009 (Hyd). • CIT Vs R. Nalini Devi ITTA 232 of 2013 (A. P) • CIT Vs P. V Kalyana Sundaran (2007) 294 ITR 49 • Venkata Rama Sai Developers Vs DCIT ITA 453/Vizag/2012. • P. Venkateshwar Rao Vs DCIT ITA 25/825/Vizag/2012.
The ratio laid down is that solely on the basis evidences such as notings in loose sheets found with third parties and the statement of third parties, additions cannot be made without corroborative evidences and independent enquiries. Applying the above ratio to & Ors. Kwality Techmech Pvt. Ltd. & other connected matters
65 the facts of the case, it is held that the addition made is not warranted, the same is deleted.”
6.1. No evidence was found by the department to establish that assessee has given loans to Shri Lanka Anil Kumar during the course of search and no evidence was found regarding utilization of purported advances by Shri Lanka Anil Kumar. Shri Anil Kumar also subsequently retracted from the statement and clarified that he has not received any cash loans from the assessee. Addition was made merely on the basis of whatsapp messages and the statement recorded from section 132(4) from Shri Lanka Anil Kumar which was subsequently retracted. Therefore we are of the view that the addition made by the AO is unsustainable and the Ld.CIT(A) rightly deleted the addition. Accordingly, we do not see any reason to interfere with the order of the Ld.CIT(A) and the same is upheld. The appeal of the revenue on this ground is dismissed.”
Accordingly, in view of the above discussion, we delete the addition made in all these assessment years towards unaccounted transactions based on the uncorroborated loose slips. These grounds of appeals of the assessee in both assessment years are allowed.
In the result, the appeals are disposed of as follows:
Sl. Name of Assessmen Assessee’s Result Revenue’s Result No. the t year appeal (ITA No.) appeal (ITA No.) assessee M/s. 2012-13 718/Del/2022 Partly 930/Del/2022 Dismissed Parmanan Allowed for d and Statistical Sons Food purposes Products Pvt. Ltd. 1 -do- 2013-14 719/Del/2022 -do- 931/Del/2022 Dismissed -do- 2014-15 720/Del/2022 -do- 932/Del/2022 Dismissed -do- 2015-16 721/Del/2022 -do- 933/Del/2022 Dismissed -do- 2016-17 722/Del/2022 -do- 934/Del/2022 Dismissed -do- 2017-18 980/Del/2022 -do- 1329/Del/2022 Dismissed -do- 2018-19 981/Del/2022 -do- 1330/Del/2022 Partly & Ors. Kwality Techmech Pvt. Ltd. & other connected matters
66 Allowed for Statistical purposes M/s. 2015-16 714/Del/2022 Partly 939/Del/2022 Dismissed Globus Allowed for Agrofoods Statistical Private purposes Ltd. 2. -do- 2016-17 715/Del/2022 Partly 940/Del/2022 Dismissed Allowed for Statistical purposes -do- 2017-18 1854/Del/2022 -do- 2419/Del/2022 Dismissed -do- 2018-19 1855/Del/2022 -do- 2420/Del/2022 Dismissed M/s. 2016-17 711/Del/2022 Partly -- -- Kwality Allowed for Techmech Statistical 3. Private purposes Ltd. -do- 2017-18 712/Del/2022 -do- 937/Del/2022 Dismissed -do- 2018-19 713/Del/2022 -do- 938/Del/2022 Dismissed Shri 2014-15 -- -- 941/Del/2022 Dismissed Devesh Mittal (Prop. M/s. Mittal Enterprise s 4. -do- 2015-16 -- -- 942/Del/2022 Dismissed -do- 2016-17 716/Del/2022 Partly 943/Del/2022 Dismissed Allowed for Statistical purposes -do- 2017-18 717/Del/2022 -do- 944/Del/2022 Dismissed -do- 2018-19 -- -- 1332/Del/2022 Dismissed
Order pronounced in the open court on 30th MAY, 2024.