T.M.A. Pai Foundation v. State of Karnataka

8 SCC 481Reported decision2002#1404 most cited

What is T.M.A. Pai Foundation v. State of Karnataka authority for?

Educational institutions are not commercial activities, and collecting fees for betterment and growth does not automatically disqualify them from being considered educational. Fees collected for value-added courses, training, or hostel facilities can be eligible for exemption under Section 11 if applied towards the institution's infrastructure.

81

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2026.

Also referred to as

TMA Pai Foundation v. State of Karnataka · Section 2(15) · Section 11 · educational activity · commercial activity · generating funds · betterment and growth · value added course fees · training · hostel fees · infrastructure · exemption

Sections most often in play

Section 2(15)Section 11Section 11(4)Section 234ASection 234BSection 32Section 10(23C)Section 12

Issues it is cited on

section 10(22)section 11(4)section 35acsection 115bbcsection 35aanonymous donationsection 2(45)advancement of general public utilitysection 60section 11(4a)section 10(23c)(vi)rectification under section 154

Judgments citing T.M.A. Pai Foundation v. State of Karnataka

Confrere Educational Society, Noida vs. ITO (Exemption), Noida

In the result, the appeal of the assessee is allowed

ITA 4464/DEL/2017[2012-13]Status: DisposedITAT Delhi19 Jun 2023AY 2012-13

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharma

Section 12ASection 250Section 251Section 56

…urat, (1980) AIR 387 SC. (ii) Ms Mohini Jain Vs. State of Karnataka and Others, (1992) AIR 185 SC. (iii) Unnikrishnan J.P. & Ors. etc. vs. State of Andhra Pradesh & Ors. (1993) AIR 2178 SC (iv) TMA Pai Foundation & Ors. vs. State of Karnataka & Ors., (2002) 8 SCC 481 (v) Islamic Academy of Education & Anr. Vs. State of Karnataka & Ors. (2003) 6 SCC 697. (vi) PA Inamdar & Ors. State of Maharashtra & Ors. (2005) AIR 3226 SC.” 5. Ld. CIT (A) also discussed the provisions of Section 10(23C)(iv) & (v) and observed that, once the income of Educational institution are exempted u/s.10(23C), then legislature does not…

Assistant Commissioner of Income Tax (Exemptions) vs. Ahmedabad Urban Development Authority

C.A. No.-021762-021762 - 2017Supreme Court19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

…titution, and it was urged that KIADB was an extension of the Karnataka Government. The board exercises power of eminent domain and it performs governmental functions. Its activities, therefore, cannot 44 (1980) 2 SCC 322 45 1989 (3) SCR 1038 46 (2002) 8 SCC 481 47 (1973) 4 SCC 194 48 “It is considered necessary to make provision for the orderly establishment and development of Industries in suitable areas in the State. To achieve this object, it is proposed to specify suitable areas for Industrial Development and establish a Board to develop such areas and make available lands therein for establishme…

M/S New Noble Educational Society vs. The Chief Commissioner of Income Tax 1

The appeals are hereby dismissed, without order on costs

C.A. No.-003795-003795 - 2014Supreme Court19 Oct 2022

Bench: HON'BLE THE CHIEF JUSTICE

Section 10

…regarded as an activity that is charitable in nature. Education has so far not been regarded as a trade or business where profit is the motive. (State of Bombay v. R.M.D. Chamarbaugwala, AIR 1957 SC 699; T.M.A. Pai Foundation v. State of Karnataka, (2002) 8 SCC 481 : AIR 2003 SC 355; Islamic Academy of Education, (2003) 6 SCC 697). Section 2(15) of the Income-tax Act defines “charitable purpose” to include “education”. The sense in which the word “education” has been used in section 2(15) is the systematic instruction, schooling or training given to the young in preparation for the work of life. It also…

Jt. Comm of Income Tax(OSD) (E) -2(1), Mumbai vs. Maharashtra State Road Transport Corporation, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1500/MUM/2022[2014-15]Status: DisposedITAT Mumbai20 Sept 2022AY 2014-15
Section 11Section 12ASection 2(15)

…ke it a non-educational activity so as to go out of the definition of 'education' contained in Sec. 2(15) of the Act. In this context, we may refer to the judgment of the Hon'ble Supreme Court in the case of T.M.A. Pai Foundation vs State of Karnataka, (2002) 8 SCC 481, wherein the Hon'ble Supreme Court has also recognised the necessity for the educational institution to generate funds for its betterment and growth. In the case of American Hotel & Lodging Association, 301 ITR 86 (SC), the Hon'ble Supreme Court was dealing with an entity engaged in providing world-recognised curriculum for all hospitality educatio…

Jt. Comm of Income Tax(OSD) (E) -2(1), Mumbai vs. Maharashtra State Road Transport. Corporation, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 1496/MUM/2022[2009-10]Status: DisposedITAT Mumbai20 Sept 2022AY 2009-10
Section 11Section 12ASection 2(15)

…ke it a non-educational activity so as to go out of the definition of 'education' contained in Sec. 2(15) of the Act. In this context, we may refer to the judgment of the Hon'ble Supreme Court in the case of T.M.A. Pai Foundation vs State of Karnataka, (2002) 8 SCC 481, wherein the Hon'ble Supreme Court has also recognised the necessity for the educational institution to generate funds for its betterment and growth. In the case of American Hotel & Lodging Association, 301 ITR 86 (SC), the Hon'ble Supreme Court was dealing with an entity engaged in providing world-recognised curriculum for all hospitality educatio…

The Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 66/BANG/2018[2014-15]Status: DisposedITAT Bangalore29 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 65/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 64/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. Sri V C Charantimath, Bagalkot

In the result, the assessee’s appeals in ITA Nos

ITA 236/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. Sri.V.C.Charantimath, Bagalkot

In the result, the assessee’s appeals in ITA Nos

ITA 235/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Assistant Commissioner of Income-Tax, Central Circle-2(2), Bengaluru vs. M/S. Sri. Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkote

In the result, the assessee’s appeals in ITA Nos

ITA 234/BANG/2018[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Sri Basaveshwar Veerashaiva Vidyavardhak Sagha, Bagalkot vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, the assessee’s appeals in ITA Nos

ITA 2777/BANG/2017[2014-15]Status: DisposedITAT Bangalore29 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Sri Basaveshwar Veerashaiva Vidyavardhak Sangha, Bagalkot vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, the assessee’s appeals in ITA Nos

ITA 2776/BANG/2017[2013-14]Status: DisposedITAT Bangalore29 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

Sri Basaveshwar Veershaiva Vidyavardhak Sangha, Bagalkot vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, the assessee’s appeals in ITA Nos

ITA 2775/BANG/2017[2012-13]Status: DisposedITAT Bangalore29 Aug 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri S. Ramasubramanian, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 10Section 11Section 12ASection 35ASection 80G

…ming within s. 10(22) of the Act. We hold accordingly." 6.16 Therefore, it is obvious that the assessee society would fall within the term 'other educational institution. 6.17 The apex Court in the case of T.M.A. Pai Foundation vs. State of Karnataka (2002) 8 SCC 481 had an occasion to consider the right of the aided and unaided private educational institutions. The Constitutional Bench of the Supreme Court elaborately considered the right of establishing private educational institutions and found that collection of capitation fees being the worst part of mal- administration, can properly be subject-matter of r…

M/S. Nabadigant Educational Trust, Bhubaneswar vs. ITO, Ward-2(1), Bhubaneswar

In the result, both appeals of the assessee are dismissed

ITA 137/CTK/2016[2011-12]Status: DisposedITAT Cuttack17 May 2022AY 2011-12
For Appellant: Shri B.R.Pattnaik, ARFor Respondent: Shri M.K.Goutam, CIT-DR
Section 11Section 12ASection 13Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 143(2)Section 143(3)Section 80G

…rofit and nothing else. The Trust is created with the objective of charitable purpose for which the trust is claiming exemption u/s.11 of the Act and not for the purpose of earning profit. 5.2 In the case of T.M.A. Pai Foundation Vs. State of Karnataka (2002) 8 SCC 481, it has been categorically laid down that the decision on the fees to be charged must necessarily be left to the private educational institutions that d not seek and which are not dependent upon any funds from the Government. Each institute will be entitled to have its own fee structure. The fee structure for each institute must be fixed keeping in…

M/S. Nabadigant Educational Trust, Bhubaneswar vs. ITO, Ward-2(1), Bhubaneswar

In the result, both appeals of the assessee are dismissed

ITA 3/CTK/2015[2009-10]Status: DisposedITAT Cuttack17 May 2022AY 2009-10
For Appellant: Shri B.R.Pattnaik, ARFor Respondent: Shri M.K.Goutam, CIT-DR
Section 11Section 12ASection 13Section 13(1)(c)Section 13(1)(d)Section 13(2)(a)Section 143(2)Section 143(3)Section 80G

…rofit and nothing else. The Trust is created with the objective of charitable purpose for which the trust is claiming exemption u/s.11 of the Act and not for the purpose of earning profit. 5.2 In the case of T.M.A. Pai Foundation Vs. State of Karnataka (2002) 8 SCC 481, it has been categorically laid down that the decision on the fees to be charged must necessarily be left to the private educational institutions that d not seek and which are not dependent upon any funds from the Government. Each institute will be entitled to have its own fee structure. The fee structure for each institute must be fixed keeping in…

Investor Financial Education Academy, Chennai vs. ITO (Exemption) - 4, Chennai

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

ITA 3007/CHNY/2018[2018-19]Status: DisposedITAT Chennai12 Apr 2022AY 2018-19

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri M. Rajan, CIT
Section 12ASection 2(15)Section 25Section 80G(5)(vi)

…Constitution Bench while considering various issues pertaining to educational institution, which included issue of fee structure, reservation, admission policies, etc., followed the decision in the case of T.M.A. Pai Foundation vs. State of Karnataka [(2002) 8 SCC 481] and held that every institution is free to advice its own fee structure subject to the limitation that there should be no profiteering and no capitation fee charged, directly or indirectly, or in any form. The Court further held that no profiteering does not imply that the institution cannot have reasonable surplus for future sustenance and expans…

Investor Financial Education Academy, Chennai vs. ITO (Exemption) - 4, Chennai

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

ITA 3006/CHNY/2018[2018-19]Status: DisposedITAT Chennai12 Apr 2022AY 2018-19

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri M. Rajan, CIT
Section 12ASection 2(15)Section 25Section 80G(5)(vi)

…Constitution Bench while considering various issues pertaining to educational institution, which included issue of fee structure, reservation, admission policies, etc., followed the decision in the case of T.M.A. Pai Foundation vs. State of Karnataka [(2002) 8 SCC 481] and held that every institution is free to advice its own fee structure subject to the limitation that there should be no profiteering and no capitation fee charged, directly or indirectly, or in any form. The Court further held that no profiteering does not imply that the institution cannot have reasonable surplus for future sustenance and expans…

Sunshine Educational & Development Society, Noida vs. Addl. CIT, Exemption, Ghaziabad

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

ITA 4727/DEL/2017[2010-11]Status: HeardITAT Delhi16 Dec 2021AY 2010-11

Bench: Shri N.K. Billaiya & Shri Amit Shukla

For Appellant: Shri K.P. Garg, CAFor Respondent: Shri H.K. Chaudhary, CIT DR
Section 10(23)(c)Section 11Section 11(1)Section 12ASection 143(3)Section 194Section 2(15)Section 251(2)Section 40

…urat, (1980) AIR 387 SC. (ii) Ms Mohini Jain Vs. State of Karnataka and Others, (1992) AIR 185 SC. (iii) Unnikrishnan J.P. & Ors. etc. vs. State of Andhra Pradesh & Ors. (1993) AIR 2178 SC (iv) TMA Pai Foundation & Ors. vs. State of Karnataka & Ors., (2002) 8 SCC 481 (v) Islamic Academy of Education & Anr. Vs. State of Karnataka & Ors. (2003) 6 SCC 697. (vi) PA Inamdar & Ors. State of Maharashtra & Ors. (2005) AIR 3226 SC.” 5. Ld. CIT (A) also discussed the provisions of Section 10(23C)(iv) & (v) and observed that, once the income of Educational institution are exempted u/s.10(23C), then legislature does not…

ACIT, New Delhi vs. M/S. Maharaji Education Trust, Ghaziabad

The appeal are dismissed

ITA 5138/DEL/2016[2007-08]Status: DisposedITAT Delhi13 Oct 2021AY 2007-08

Bench: Shri Kuldip Singh & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Suresh Gupta, C. AFor Respondent: Ms. Paramita M. Biswas[CIT]–
Section 11Section 12ASection 132Section 133ASection 143(1)Section 143(2)Section 143(3)Section 68Section 69Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL [ DELHI BENCH “E”: NEW DELHI ] BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER (Through Video Conferencing) ITA. No. 5138/Del/2016 (Assessment Year: 2007-08) ACIT, M/s. Maharaji Education Vs. Trust, Central Circle : 6, No. 1 – Santosh Nagar, Pratap Vihar, New Delhi. Ghaziabad – 201 009. PAN: AAATM5225F (Appellant) (Respondent) Assessee by : Shri Suresh Gupta, C. A. Department by: Ms. Paramita M. Biswas[CIT]– DR Date of Hearing : 21/09/2021 Date of pronouncement : 13/10/2021 O R D E R PER PRASHANT MAHARISHI, A. M. 1. This appeal is fi…