Sree Krishna Electricals v. State of Tamil Nadu

23 VST 249Supreme Court of India2009#1373 most cited

What is Sree Krishna Electricals v. State of Tamil Nadu authority for?

Penalty for furnishing inaccurate particulars is not attracted merely because some items are not included in the tax return or the return contains incorrect statements, provided these transactions are fully incorporated and reflected in the assessee's account books.

83

judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 2015 to 2026.

Also referred to as

Sree Krishna Electricals · section 271(1)(c) penalty · furnishing inaccurate particulars · deletion of penalty · disclosure in account books · items not included in return · incorrect statements in return · true and full disclosure · section 274 · section 276C

Sections most often in play

Section 271(1)(c)Section 143(3)Section 14ASection 274Section 276CSection 250Section 115JBSection 142(1)

Issues it is cited on

section 276csection 276section 270a(6)(a)section 40a(2)(a)section 115jcsection 270a(6)true and full disclosuredeletion of penaltyagency pepenalty under section 271(1)(c)section 24(a)section 92d

Judgments citing Sree Krishna Electricals v. State of Tamil Nadu

Deputy Commissioner of Income Tax, Circle-1, Aurangabad vs. Prabha Farms Private Limited, Aurangabad

In the result, the appeal filed by the Revenue is dismissed

ITA 1748/PUN/2024[2013-14]Status: DisposedITAT Pune16 May 2025AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1748/Pun/2024 िनधा"रण वष" / Assessment Year : 2013-14 Dcit, Circle-1, Vs. Prabha Farms Private Aurangabad. Limited, Akash, Paithan Road, Aurangabad- 431005. Pan : Aaccp3782D Appellant Respondent C. O. No.07/Pun/2025 (Arising Out Of Ita No.1748/Pun/2024) िनधा"रण वष" / Assessment Year : 2013-14 Prabha Farms Private Vs. Dcit, Circle-1, Limited, Aurangabad. Akash, Paithan Road, Aurangabad- 431005. Pan : Aaccp3782D Appellant Respondent Revenue By : Shri Arvind Desai Assessee By : Shri N. R. Agrawal Date Of Hearing : 24.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment

For Appellant: Shri N. R. AgrawalFor Respondent: Shri Arvind Desai
Section 143(3)Section 2(14)Section 271(1)(c)

…Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu [2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

Superfine Hotels Private Limited, Jaipur vs. Deputy Commissioner of Income Tax, Circle-6, Jaipur

In the result, appeal of the assessee is partly allowed

ITA 1502/JPR/2024[2015-16]Status: DisposedITAT Jaipur22 Apr 2025AY 2015-16
For Appellant: Shri S.L. Poddar, Adv. &For Respondent: Shri P.P. Meena, CIT
Section 250Section 271(1)(c)Section 35A

…ssessee will invite penalty under s.271(1)(c). That is clearly not the intendment of the legislature. The Tribunal, as well as, the CIT(A) and the High Court have correctly reached this conclusion.—Sree Krishna Electricals vs. State of Tamil Nadu &Anr. (2009) 23 VST 249 (SC) applied; Reliance Petroproducts (P) Ltd. (judgment dt. 23rd Oct., 2007 of the Gujarat High Court in Tax Appeal No. 1149 of 2007) affirmed. (3) DEPUTY COMMISSIONER OF INCOME TAX vs. RENU AGARWAL IN THE ITAT JAIPURITA No. 764/JP/2015(2017) 185 TTJ 0036 (Jp) ((UO)) Levy of Penalty u/s.271(1)(c)—Deletion—AO levied penalty u/s 271(1)(c) in respect…

Cornerstone Ondemand Limited, Mumbai vs. ACIT(It)-2(1)(1), Mumbai

ITA 5677/MUM/2024[2019-20]Status: DisposedITAT Mumbai28 Mar 2025AY 2019-20

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

Connerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-2(1)(1), Mumbai

ITA 3753/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

Cornerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-2(1)(1), Mumbai

ITA 3752/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Mar 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

Cornerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-2(1)(1), Mumbai

ITA 3751/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

Cornerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-291)(1), Mumbai

ITA 3747/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Mar 2025AY 2015-16

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

M.P. Veerachandra Chettiyar, Kadavanthara vs. ITO, Ward-1(5), Range-1, Non Corporate Ward-1(50, Kochi

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 557/COCH/2024[2014-15]Status: DisposedITAT Cochin27 Jan 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2014-15

For Respondent: Smt. Divya Ravindran
Section 56(2)(vii)

…ment. “...per contra, the learned counsel appearing for the assessee relying on the decisions of the Supreme Court in Cement Marketing Co. of India Limited Vs. Asst. Commissioner of Sales Tax (1980, 45 STC 197 and Sree Krishna Electricals V. State of TN 2009, 23 VST 249(SC) and the decision of this Court, in Kollannur Agencies V Asst. Commissioner (Asst.) 1991, 80 STC 177 argued that the Tribunal acted illegally in sustaining the penalty order and there is no ground to impose the penalty on ground referable to any contumacious conduct. Reference was also made to Sultan gold International V. State of Kerala 2012 (…

ACIT, Amravati Circle, Amravati vs. Chandrapur Dist Central Co-Op Bank Ltd, Chandrapur

In the result, appeal filed by the Revenue is dismissed

ITA 398/NAG/2023[2014-15]Status: DisposedITAT Nagpur18 Sept 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandeep Salonkhe
Section 271(1)(c)Section 36Section 36(1)Section 36(1)(viia)

…accepted by AO for any reason, the assessee will invite penalty under s. 271(1)(c). That is clearly not the intendment of the legislature 11. In this behalf the observations of this Court made in Sree Krishna Electricals vs. State of Tamil Nadu & Anr. (2009) 23 VST 249 (SC) as regards the penalty are opposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales-tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the return. However, the said transactions were reflected in the accounts of the assessee…

Deputy Commissioner of Income Tax, Amravati & Chandrapur Circle, Amravati vs. Chandrapur District Central Co-Op Bank Ltd., Chandrapur

In the result, appeal filed by the Revenue is allowed for statistical purposes

ITA 89/NAG/2022[2018-19]Status: DisposedITAT Nagpur21 Aug 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Kailash C. Kanojiya
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

…accepted by AO for any reason, the assessee will invite penalty under s. 271(1)(c). That is clearly not the intendment of the legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals vs. State of Tamil Nadu & Anr. (2009) 23 VST 249 (SC) as regards the penalty are opposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales-tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the return. However, the said transactions were reflected in the accounts of the assessee…

ACIT, Chandrapur Circle, Chandrapur vs. Chandrapur Distt. Central Co-Op Bank Ltd, Chandrapur

In the result, appeal filed by the Revenue is allowed for statistical purposes

ITA 399/NAG/2019[2015-16]Status: DisposedITAT Nagpur21 Aug 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Kailash C. Kanojiya
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

…accepted by AO for any reason, the assessee will invite penalty under s. 271(1)(c). That is clearly not the intendment of the legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals vs. State of Tamil Nadu & Anr. (2009) 23 VST 249 (SC) as regards the penalty are opposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales-tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the return. However, the said transactions were reflected in the accounts of the assessee…

Assistant Commissioner of Income Tax, Chandrapur Circle, Chandrapur vs. M/S Chandrapur District Central Co-Oprative Bank Limted, Chandrapur

In the result, appeal filed by the Revenue is allowed for statistical purposes

ITA 241/NAG/2018[2013-14]Status: DisposedITAT Nagpur21 Aug 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Kailash C. Kanojiya
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

…accepted by AO for any reason, the assessee will invite penalty under s. 271(1)(c). That is clearly not the intendment of the legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals vs. State of Tamil Nadu & Anr. (2009) 23 VST 249 (SC) as regards the penalty are opposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales-tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the return. However, the said transactions were reflected in the accounts of the assessee…

Akar Laminators Limited, Ahmedabad vs. Deputy Commissioner of Income Tax, Circle 1(1)(1), Ahmedabad

In the result the appeal filed by the assessee is allowed

ITA 600/AHD/2023[2001-02]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2001-02

Bench: This Tribunal & The Case Was Set-Aside Vide Order Dated 01.08.2014 In Ita No. 858 & 927/Ahd/2005 & Accordingly Assessment Was Finalized U/S. 143(3) R.W.S. 254 Of The Act & The Total Loss Was Determined At (-) Rs.22,47,26,293/- After Making Following Additions/Disallowances:

Section 143(3)Section 144Section 271Section 271(1)(c)Section 274

…Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 389/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…odara Urban Development Authority the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 388/AHD/2023[2009-10]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2009-10

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…odara Urban Development Authority the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 386/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2014-15

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…odara Urban Development Authority the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

The ACIT(E), Circle-2, Ahmedabad vs. Vadodara Urban Development Authority, Vadodara

In the result, the appeal filed by the Revenue in ITA No

ITA 379/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad28 Feb 2024AY 2011-12

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 12ASection 22Section 271(1)(c)

…odara Urban Development Authority the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. 11. In this behalf the observations of this Court made in Sree Krishna Electricals v. State of Tamil Nadu[2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings in Tamil Nadu General Sales Tax Act, the Court had found that the authorities below had found that there were some incorrect statements made in the Return. However, the said transactions were reflected in the accounts of the assessee. Thi…

The DCIT-1(3)(1) Mumbai, Mumbai vs. M/S Fern Infrastructure Pvt Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 1402/MUM/2022[2012-13]Status: DisposedITAT Mumbai08 Feb 2023AY 2012-13

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 139Section 143Section 154Section 271(1)Section 271(1)(c)Section 32

…essee will invite penalty under s. 271(1)(c). That is clearly not the intendment of the legislature. The Tribunal, as well as, the CIT(A) and the High Court have correctly reached this conclusion.-Sree Krishna Electricals vs. State of Tamil Nadu & Anr. (2009) 23 VST 249 (SC) applied; Reliance Petroproducts (P) Ltd. (judgment dt. 23rd Oct., 2007 of the Gujarat High Court in Tax Appeal No. 1149 of 2007) affirmed. (Paras 9, 10 & 12) Conclusion: Merely because the assessee claimed deduction of interest expenditure which has not been accepted by the Revenue, penalty under s. 271(1)(c) is not attracted; mere making of…

Shree Sainath Sarvajanik Sewa Mandal Trust, Una vs. ITO, Exemption Ward, Surat

In the result, the appeal of the Revenue is dismissed

ITA 204/SRT/2021[2016-17]Status: DisposedITAT Surat22 Jul 2022AY 2016-17

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.204/Srt/2021 ("नधा"रणवष" / Assessment Years: (2016-17) (Physical Court Hearing) Shree Sainath Sarvajanik Sewa Vs. The Ito, Exemption Ward, Mandal Trust, Surat. N.H. No.8, Near Ganesh Sisodra, Unn-396445, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aafts7802P (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri J. K. Chandnani, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 12/05/2022 घोषणाक"तार"ख/Date Of Pronouncement : 22/07/2022 आदेश / O R D E R Per Dr. A. L. Saini: The Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2016-17, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), [In Short ‘Ld. Cit(A)’] National Faceless Appeal Centre (In Short ‘Nfac), Delhi, In Appeal No. Itba/Nfac/S/250/2021-22/1036051308(1) Dated 30.09.2021, Which In Turn Arises Out Of A Penalty Order Passed By Assessing Officer U/S 271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As The ‘Act’).

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri J. K. Chandnani, Sr. DR
Section 11(6)Section 271(1)Section 271(1)(C)Section 271(1)(c)

…the Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c). That is clearly not the intendment of the Legislature. In this behalf the observations of this court made in Sree Krishna Electricals v. State of Tamil Nadu [2009] 23 VST 249 as regards the penalty are apposite. In the aforementioned decision which pertained to the penalty proceedings under the Tamil Nadu General Sales Tax Act, the court had found that the authorities below had found that there were some incorrect statements 204/SRT/2021/AY. 2016-17 Shree Sainath Sarvajanik Sewa Mandal Trust made in the return. Howeve…

R.Palanisamy, Tiruppur vs. ITO, Tiruppur

In the result, the appeal filed by the assessee is allowed

ITA 1211/CHNY/2015[2010-2011]Status: DisposedITAT Chennai24 Jun 2022AY 2010-2011

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Ms. Joshita Jothi, C.AFor Respondent: Shri G. Johnson, Addl.CIT
Section 143(3)Section 271(1)(c)

…आयकर अपीलीय अिधकरण, ‘डी’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी महावीर "संह, उपा"य" एवं "ी मनोज कुमार अ"वाल, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.:1211/CHNY/2015 िनधा"रण वष" /Assessment Year:2010-11 Shri R. Palanisamy, The Income Tax Officer, No.45, Pushpa Nagar, v. Ward 1(2), Kangayam Road, Tirupur. Tirupur – 641 604. PAN: AKQPP 8270M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Ms. Joshita Jothi, C.A. ""यथ" क" ओर से/Respondent by : Shri G. Johnson, Addl.CIT…