CIT v. Reliance Utilities & Power Ltd.

313 ITR 340High Court2009#10 most cited

What is CIT v. Reliance Utilities & Power Ltd. authority for?

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

2,118

judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. Reliance Utilities and Power Ltd. · Section 14A · Rule 8D · interest free advances · disallowance of interest expenditure · own funds · interest-free funds

Also reported as

178 Taxmann 13513 DTR 237178 Taxmann.com 135284 CTR 414

Sections most often in play

Section 14ASection 36(1)(iii)Section 143(3)Section 115JBSection 8DSection 10(34)Section 143(2)Section 37(1)

Issues it is cited on

interest free advancesdisallowance of interest expendituresection 36(1)(iii)disallowance under section 14acommercial expediencydisallowance u/s 14asection 14abook profitssection 115jsection 36(1)section 36section 115jb

Judgments citing CIT v. Reliance Utilities & Power Ltd.

Eknath Ramkrisnanrao Salve, Parbhani vs. Income-Tax Officer, Ward - 1(4), Parbhani

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1290/PUN/2018[2011-12]Status: DisposedITAT Pune19 Dec 2019AY 2011-12
For Appellant: Shri Nikhil PathakFor Respondent: Shri Abhijit Chaudhuri

…the Assessing Officer, based on the ad-hoc rate of 12%, estimated the profit and disallowed the proportionate interest debited to the Profit and Loss Account. The Hon’ble Bombay High Court’s judgement in the case of CIT vs. Reliance Utilities and Power Ltd., 313 ITR 340 (Bom) also helps the assessee and in favour of the principle of presumption with reference to the interest free funds. In my view, the said decision is directly applicable to the facts of the present case. There is no dispute on the fact on the availability of interest free funds amounting to Rs.65,77,899/-. Further, there is no dispute about 20,…

DCIT- CC-5(1), Mumbai vs. Hubtown Ltd., Mumbai

In the result, cross objection filed by the assesee is treated as allowed for statistical purpose

ITA 2764/MUM/2018[2013-14]Status: DisposedITAT Mumbai13 Dec 2019AY 2013-14

Bench: Shri G. Manjunatha & Shri Ravish Sooddcit, Cc-5(1) Vs. M/S. Hubtown Ltd. Room No.1928 19Th Floor Akruti Trade Centre, 6Th Floor Air India Building, Nariman Point Road No.7, Marol-Midc Mumbai-400 021 Andheri(E) Mumbai-400 093

Section 143(3)Section 14ASection 80Section 80I

…sesee has own funds amounting to Rs 1,658.28 crores, which exceeds the value of the investment of Rs. 594.29 crores. In this regard, he relied upon the decision of Hon’ble jurisdictional High Court of Bombay in the case of CIT vs. Reliance Utilities Power Ltd 313 ITR 340 (bom) and CIT vs HDFC Bank Ltd. (366 ITR 505(bom). The assesee has also relied upon the decision of Hon’ble Supreme Court, in the case of CIT vs Reliance Industries Limited 410 ITR 466 (SC). The Ld. AR, further submitted that in respect of disallowances of expenditure under Rule 8D(2)(iii), the disallowances may be restricted to the extent of exe…

Jsw Cement Ltd, Mumbai vs. DCIT 5 (3)(1), Mumbai

In the result, appeal of the assessee is treated as allowed

ITA 5387/MUM/2018[2013-14]Status: DisposedITAT Mumbai12 Dec 2019AY 2013-14

Bench: Shri Pawan Singh (Jm) & Shri S Rifaur Rahman (Am)

Section 143(3)Section 14A

…vance for non-business purpose, have been made out of own funds and that borrowed funds have not been used for the purpose of investment. The assessee relied upon the decision of Hon’ble jurisdictional High Court in CIT vs Reliance Utilities & Power Pvt Ltd 313 ITR 340 (Bom) and CIT vs HDFC Bank Ltd 366 ITR 505 (Bom). 3 ITA 5387 & 5388/Mum/2018 JSW Cement 3. The reply of the assessee was not accepted by AO. The AO invoked the provisions of Rule 8D(2)(ii) and made disallowance of Rs.12,70,089/- on account of interest expenditure. The AO, after giving set off of suo moto disallowance, made the addition accordi…

M/S. Bcc Enterprises (India) Ltd., Indore vs. The ITO-1(4), Indore

In the result, appeal of the assessee is partly allowed

ITA 279/IND/2017[2013-14]Status: DisposedITAT Indore09 Dec 2019AY 2013-14

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2013-14

Section 143(2)Section 143(3)Section 14A

…ds have been applied for making such investment then it should be presumed that BCC Enterprises (India) Ltd interest free funds have been applied for making such investment. 23. Hon’ble Bombay High Court in case of CIT vs. Reliance Utilities & Power Limited (313 ITR 340) has categorically held that “if there are funds available both, interest free and over draft and/or loans are taken, then a presumption would arise that investments would be out of the interior free fund generated or available with the company, if the interest free funds are sufficient to meet the investments. In the instant case said presumptio…

DCIT - 3(3)(1), Mumbai vs. Saurashtra Fuels Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue is hereby ordered to be dismissed

ITA 5038/MUM/2018[2012-13]Status: DisposedITAT Mumbai09 Dec 2019AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No.5038/Mum/2018 (निर्धारण वर्ा / Assessment Year: 2012-13) Dcit-3(3)(1) बिधम/ M/S. Saurashtra Fuels Pvt. Room No.609, 6Th Floor, Ltd. Vs. Aayakar Bhavan, M.K. 93-C, Mittal Towers, Road, Mumbai-400020. Nariman Point, Mumbai- 400021. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacs7271G (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri V. Vinod Kumar (Sr. Ar) Assessee By: Shri B. V. Jhaveri सुनवाई की तारीख / Date Of Hearing: 04/12/2019 घोषणा की तारीख /Date Of Pronouncement: 09/12/2019 आदेश / O R D E R Per Amarjit Singh, Jm: The Revenue Has Filed The Present Appeal Against The Order Dated 18.06.2018 Passed By The Commissioner Of Income Tax (Appeals) -8, Mumbai [Hereinafter Referred To As The “Cit(A)”] Relevant To The A.Y.2012- 13. 2. The Revenue Has Raised The Following Grounds: -

For Appellant: Shri B. V. JhaveriFor Respondent: Shri V. Vinod Kumar (Sr. AR)
Section 115JSection 143(1)Section 143(2)Section 14A

…s 14A read with Rule 8D stating that Assesses own funds were more than investment made relying on Hon'ble Bombay High Court's decision in the case of HDFC Bank Ltd (366 ITR 505)(Bom) and also in the case of CIT vs A.Y.2012-13 Reliance Utilities and Power Ltd (313 ITR 340)(Bom) whereas the Hon'ble Supreme Court in para 42 of their decision in the case of M/s Maxopp Investment Ltd vs. CIT in Civil Appeal No. 104-109 of 2015 dated 12- 022018, have upheld the principle of apportionment in cases where the assessee has mixed funds and interest has been paid and when the judgment by Hon'ble Bombay High Court in the case…

Modern Insulators Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Circle-6, Jaipur

In the result, appeal of the assessee is allowed

ITA 74/JPR/2019[2014-15]Status: DisposedITAT Jaipur05 Dec 2019AY 2014-15
For Appellant: Shri Madhukar Garg (CA)For Respondent: Smt. Runi Pal (JCIT)
Section 14A

…nterest expenditure is not called for. The Hon’ble Jurisdictional High Court in case of CIT vs. Deepak Veg Pro Ltd. (supra) as well as various judgments including the judgment of Hon’ble Bombay High Court in case of CIT vs. Reliance Utilities & Powers Ltd. 313 ITR 340 (Bombay) as well as in the case of CIT vs. HDFC Bank Ltd 366 ITR 505 (Bombay) has upheld the finding of the Tribunal that once the assessee’s own interest free funds are more than investments in tax free securities, then the presumption would be raised that the investments made by the AO would 7 ITA No. 74/JP/2019. M/s. Modern Insulators Ltd.,…

Kiri Industries Ltd., Ahmedabad vs. The ACIT., Circle-4, Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 3085/AHD/2013[2009-10]Status: DisposedITAT Ahmedabad04 Dec 2019AY 2009-10
For Appellant: Shri T.P. HemaniFor Respondent: Shri Santosh Karnani, Sr. D.R
Section 143(2)Section 143(3)Section 14ASection 234BSection 271(1)

…nt. The ld. counsel has also placed reliance on the following decisions:- " CIT vs. Reliance Industries Ltd. 410 ITR 466. " CIT vs. Torrent Power Ltd. -363 ITR 474 (GUJ) " CIT vs. Suzlan Energy Ltd. -354 ITR 630 (GUJ) " CIT vs. Reliance Utilities & Power Ltd. 313 ITR 340 (Bom) " CIT vs. Munjal Sales Corporation 298 ITR 298 (SC) On the other hand, the ld. departmental representative has supported the order of ld. CIT(A). 5. Heard both the sides and perused the material on record. It is noticed that as per balance sheet of the assessee as on 31st March, 2009, the position of interest free fund and investment was…

Kamlesh Kanugo, Mumbai vs. ACIT 15(3), Mumbai

In the result appeal by the assessee stands partly allowed

ITA 368/MUM/2013[2009-10]Status: DisposedITAT Mumbai03 Dec 2019AY 2009-10

Bench: Shri Shamim Yahya (Am) & Shri Pawan Singh (Jm)

Section 14ASection 40

…THE INCOME TAX APPELLATE TRIBUNAL “H” Bench, Mumbai Before Shri Shamim Yahya (AM) & Shri Pawan Singh (JM) I.T.A. No. 368/Mum/2013 (Assessment Year 2009-10) Shri Kamlesh Kanungo ACIT-15(3) Vs. Office No. 18, 1st Floor Mumbai. 65/73, Habib Building C.P.Tank, Mumbai-400 004. PAN : ABBPK9675R (Appellant) (Respondent) Assessee by Shri Rajkumar Singh Department by Shri S. Michale Jerald Date of Hearing 18.09.2019 Date of Pronouncement 3.12.2019 O R D E R Per Shamim Yahya (AM) :- This appeal by the assessee is directed against the order of learned CIT(A) dated 2.11.12 and pertains to assessment year 2009-10. 2.…

Kifs Securities Pvt. Ltd., Ahmedabad vs. The ACIT, Circle-1(3), Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 63/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2013-14

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

Kifs Securities Pvt. Ltd., Ahmedabad vs. The ACIT, Circle-1(3), Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 1885/AHD/2017[2014-15]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2014-15

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

Dy.Commissioner of Income Tax Circle-1(3), Ahmedabad vs. Kifs Pvt.Ltd., Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 914/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2012-13

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

Kifs Securities Pvt. Ltd., Ahmedabad vs. The ACIT, Circle-1(3), Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 786/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2012-13

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

The Dy. CIT., Circle-3, Ahmedabad vs. Khandwala Integrated Financial Services Pvt. Ltd, Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 932/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2010-11

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

Kifs Securities Ltd., Ahmedabad vs. The Jt.CIT, Range- 3, Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 643/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2010-11

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

The ACIT, Circle-3, Ahmedabad vs. Kifs Securities Limited, Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 2882/AHD/2014[2011-12]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2011-12

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

Kifs Securities Ltd., Ahmedabad vs. The Jt.CIT, Range- 3, Ahmedabad

In the result Ground No.9 of the revenue is allowed for

ITA 2717/AHD/2014[2011-12]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2011-12

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

Section 111ASection 143(3)Section 14ASection 43B

…has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities and power Ltd. 313 ITR 340 (Bom.) is to be applied on these facts. Resultantly, we hereby confirm the findings of the ld.CIT(A) and dismiss these grounds of the Revenue [or both the years. " 20. We therefore respectfully following the above judgments and in the given facts and circumstances of the case are of the considered view that since the assessee had earned net int…

Tk Toll Road Pvt, Ltd., Mumbai vs. DCIT - 15 (3)(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 5088/MUM/2018[2015-16]Status: DisposedITAT Mumbai29 Nov 2019AY 2015-16

Bench: Shri M.Balaganesh, Am & Shri Ram Lal Negi, Jm M/S. Tk Toll Road Private Vs. Dy. Commissioner Of Limited Income Tax-15(3)(1), 361, 3Rd Floor, North Wing Room No.451, Reliance Centre Aayakar Bhavan Prabhat Colony M.K.Road, Santacruz (E) Mumbai – 400 020 Mumbai – 400 055 Pan/Gir No.Aacct6404A (Appellant) .. (Respondent)

Section 143(3)Section 14A

…vestments and hence, there cannot be any disallowance of interest under second limb of rule 8D(2) of the rules. Reliance in this regard is placed on the decision of Hon’ble Jurisdictional High court in the case of Reliance Utilities and Power Ltd. reported in 313 ITR 340 and HDFC Bank Ltd. in 366 ITR 505. 3.2. With regard to disallowance under rule 8D(2)(iii), the ld. AO worked out average value of daily balance of investments at Rs.1,31,58,801/- which are enclosed in Annexure-B to the assessment order and applied 0.5% on the same and arrived at the disallowance of Rs.65,794/-. In this regard, we find that the Co…

The Tata Power Co. Ltd, Mumbai vs. ACIT 2(3), Mumbai

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue are dismissed

ITA 3452/MUM/2012[2006-07]Status: DisposedITAT Mumbai29 Nov 2019AY 2006-07

Bench: Shri M.Balaganesh, Am & Shri Ram Lal Negi, Jm

Section 143(3)Section 14A

…ded exempt income and hence, there cannot be any disallowance of interest on borrowed funds u/s.14A of the Act. Reliance in this regard was placed on the decision of Hon’ble Jurisdictional High Court in the case of Reliance Utilities and Power Ltd reported in 313 ITR 340 (Bom). We find that with regard to disallowance of indirect expenses, the Co-ordinate Bench of this Tribunal in assessee’s own case for A.Y.2001-02 vide its order dated 09/09/2011 in page 32 in para 9 had remanded this issue to the ld. AO for fresh consideration. The ld. AO vide order dated 09/01/2013 in giving effect proceedings to the said Trib…

Rajkumar Devansh (HUF), Mumbai vs. Addl. CIT RG-12(2), (Now Assessed With ACIT-17(2)), Mumbai

In the result, appeal of the assessee is allowed for statistical purpose

ITA 700/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Nov 2019AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rehman, Hon'Ble

For Appellant: Shri Dharmesh ShahFor Respondent: Jothilakshmi Nayak
Section 14ASection 36(1)(iii)

…36(1)(iii) is warranted. Reliance was placed on the decision of the Hon'ble Supreme Court in the case of Reliance Industries Ltd in CA.NO. 10 of 2019 dated 02.01.2019, decision of the Hon'ble Bombay High Court in the case of Reliance Utilities and Power Ltd [313 ITR 340]. 4. On the other hand, Ld. DR strongly supported the orders of the authorities below. 5. We have heard the rival submissions and perused the orders of the authorities below. We have gone through the balance sheet and profit & loss account and find that there is merit in the submission of the Ld. counsel for the assessee. Therefore, in view of…

DCIT, CC- 4(1), Cr- 4 Pr. CIT (C) -2, Mumbai vs. Pratima H. Mehta, Mumbai

In the result, appeal of the revenue is dismissed as not maintainable and appeal of the assessee is allowed

ITA 6228/MUM/2018[2014-15]Status: DisposedITAT Mumbai27 Nov 2019AY 2014-15

Bench: Shri Mahavir Singh , Jm & Shri M.Balaganesh, Am Deputy Commissioner Of Vs. Smt. Pratima H Mehta Income Tax 44-A, Madhuli Central Circle – 4(1), Dr. A.B.Road, Mumbai, Central Range – 4 Worli, Mumbai – 400 018 Pr. Cit(C)-2, Mumbai Pan/Gir No. Abapm8226G (Appellant) (Respondent) .. Smt. Pratima H Mehta Vs. Deputy Commissioner Of Income 44-A, Madhuli Tax Dr. A.B.Road, Central Circle – 4(1), Worli, Mumbai – 400 018 Mumbai, Central Range – 4 Pr. Cit(C)-2, Mumbai Pan/Gir No. Abapm8226G (Appellant) .. (Respondent)

Section 143(3)Section 57

…IN THE INCOME TAX APPELLATE TRIBUNAL “C”, BENCH MUMBAI BEFORE SHRI MAHAVIR SINGH , JM & SHRI M.BALAGANESH, AM Deputy Commissioner of Vs. Smt. Pratima H Mehta Income Tax 44-A, Madhuli Central Circle – 4(1), Dr. A.B.Road, Mumbai, Central Range – 4 Worli, Mumbai – 400 018 Pr. CIT(C)-2, Mumbai PAN/GIR No. ABAPM8226G (Appellant) (Respondent) .. Smt. Pratima H Mehta Vs. Deputy Commissioner of Income 44-A, Madhuli Tax Dr. A.B.Road, Central Circle – 4(1), Worli, Mumbai – 400 018 Mumbai, Central Range – 4 Pr. CIT(C)-2, Mumbai PAN/GIR No. ABAPM8226G (Appellant) .. (Respondent) Revenue by Dr. P. Daniel Assessee by Shri D…