“application of income”

Judicial DoctrinesDiversion vs ApplicationDiversion vs Application1,603 judgments

The decision most relied on for application of income is Maxopp Investment Ltd. v. CIT (402 ITR 640), cited in 1,596 judgments on BharatTax.

Leading authorities on application of income

Maxopp Investment Ltd. v. CIT

402 ITR 640 · 2018 · Supreme Court

1,596

citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT

328 ITR 81 · 2010 · High Court

1,183

citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

CIT v. Max India Ltd.

295 ITR 282 · 2007 · Supreme Court

1,162

citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Godrej & Boyce Manufacturing Company Ltd. v. DCIT

394 ITR 449 · 2017 · Supreme Court

683

citing judgments

Expenditure can only be disallowed under Section 14A if the income is exempt and not part of the total income. The Assessing Officer must first record dissatisfaction with the assessee's accounts or computation before proceeding to make a disallowance under Section 14A or applying Rule 8D.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Olari Little Flower Kuries (P.) Ltd. v. UOI

440 ITR 26 · 2022 · High Court

614

citing judgments

The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.

Dilip N. Shroff v. JCIT

291 ITR 519 · 2007 · Supreme Court

565

citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya

216 ITR 660 · 1995 · High Court

511

citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing application of income

Mckinsey Global Capabilities and Services Private Limited (Mgcs) [Mgsipl Now Merged With Mgcs], Haryana vs. Additional / Joint / Deputy / Assistant Commissioner of Income Tax / Income-Tax Officer, Delhi

Appeal is allowed

ITA 5314/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Jan 2026AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 5314/Del/2025 : Asstt. Year : 2018-19 Mckinsey Global Capabilities & Vs Cit(A)/Nfac, Services Pvt. Ltd. (Mckinsey Global Delhi Services India Pvt. Ltd.), 3Rd Floor, Block-Iii, Vatika Business Park, Sector-49, Sohna Road, Gurgaon-12201 (Appellant) (Respondent) Pan No. Aaccm2356G Assessee By : Sh. Nikhil Tiwari, Ca Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 15.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025–26/1077218408(1) Dated 19.06.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Nikhil Tiwari, CAFor Respondent: Ms. Ankush Kalra, Sr. DR

Section 143(3)Section 37(1)Section 80G

aforesaid provision is given in the Explanatory Memorandum to the Finance (No.2) Bill, 2014 and is reproduced as under; “CSR expenditure, being an application of income, is not incurred wholly and exclusively for the purposes of carrying on business, As the application of income is not allowed as deduction ... legislative intent and the rationale of disallowance of CSR expenditure referred to in section 135 of the Companies Act, that such expenditure is application of income and not incurred for the purposes of business. We are of considered view that this in itself justifies the grant of deduction

Holy Family School, Mumbai vs. ITO Exemption, 1(3), Mumbai

In the result, appeal filed by the assesse bearing ITA No

ITA 5902/MUM/2025[2012-13]Status: DisposedITAT Mumbai14 Jan 2026AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

Section 11Section 11(1)Section 11(1)(a)Section 12ASection 13(8)Section 143Section 143(3)Section 147Section 148Section 2(15)

total income at Rs. 68,29,660/-. The said addition comprised disallowance of capital expenditure amounting to Rs.32,95,282/- claimed as application of income under section 11(1) of the Act and denial of accumulation of income amounting to Rs. 35,34,377/- claimed at 15% under section ... hall receipt amount to Rs.7140478/- as business income in that sequence denying the sum of Rs.32,95,282/- being capital expenditure claimed as application of income and disallowance of deduction U/s 11(1)(a) of the Act amount to Rs. 35,34,377/-. Further the Ld. AR contended that

ACIT, Circle-7(1), Delhi vs. Fis Global Business Solutions India Private Limited, Delhi

In the result, the appeal of the revenue as well as cross objection of the assessee are dismissed

ITA 5002/DEL/2025[2020-21]Status: DisposedITAT Delhi14 Jan 2026AY 2020-21

Bench: Shri C.N. Prasad & Shri Naveen Chandra[Assessment Year: 2020-21] Dcit Vs. Fis Global Business Solutions New Delhi India Private Limited S-405, Lower Ground Floor, Greater Kailash, Part Ii New Delhi Pan No.Aaach2851H Appellant Respondent Co. No. 213/Del/2025 (In Ita No.5002/Del/2025) [Assessment Year: 2020-21] Fis Global Business Vs. Dcit Solutions India Private New Delhi Limited S-405, Lower Ground Floor, Greater Kailash, Part Ii New Delhi Pan No.Aaach2851H Appellant Respondent Revenue By Ms. Ankush Kalra, Sr. Dr Assessee By Sh. Vishal Kalra, Advocate Ms. Reema Grewal, Ca Sh. Kashish Gupta, Advocate Date Of Hearing 18.11.2025 Date Of Pronouncement 14.01.2026

Section 143(2)Section 37(1)

aforesaid provision is given in the Explanatory Memorandum to the Finance (No.2) Bill, 2014 and is reproduced as under: "CSR expenditure, being an application of income, is not incurred wholly and exclusively for the purposes of carrying on business, As the application of income is not allowed as deduction ... legislative intent and the rationale of disallowance of CSR expenditure referred to in section 135 of the Companies Act, that such expenditure is application of income and not incurred for the purposes of business. We are of considered view that this in itself justifies the grant of deduction

Dy. Commissioner of Income Tax, Cgo Complex, Hapur Chungi vs. Kanpur Development Authority, Motijheel, Kanpur

ITA 4580/DEL/2025[2012-13]Status: DisposedITAT Delhi14 Jan 2026AY 2012-13

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 143(3)Section 2Section 2(15)

though no such charge can be created and the income can only be applied after the taxation. This this expense is declared as application of income and not accepted as the charge against the taxable income. Accordingly, the same is being treated as payment made for nonbusiness purposes and added

Dali Kundu Educational Trust, Murshidabad vs. Deputy Director, CPC, Bengaluru

Appeal of the assessee stands allowed

ITA 646/KOL/2025[2024-25]Status: DisposedITAT Kolkata12 Jan 2026AY 2024-25

Bench: Shri George Mathanआयकर अपील सं/Ita No.646/Kol/2025 (नििाारण वर्ा / Assessment Year :2024-2025) Dali Kundu Educational Trust, Vs Dy. Director, Cpc, Bengaluru/ Salar, Murshidabad, Ito, Ward-2(1), Exemption, West Bengal-742401 Durgapur Pan No. :Aabtd 4874 A (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : None राजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 12/01/2026 घोषणा की तारीख/Date Of Pronouncement : 12/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 07.03.2025 Passed By The Ld.Addl/Jcit(A)-5, Mumbai, For The Assessment Year 2024-2025. 2. None Represented On Behalf Of The Assessee. A Perusal Of The Ground Raised By The Assessee Shows That The Return Filed By The Assessee Has Been Processed & An Intimation 143(1) Of The Act Has Been Issued On The Assessee Wherein The Application Of Income As Claimed By The Assessee Has Been Denied & The Total Receipts Of The Assessee Has Been Treated As The Income Of The Assessee. 3. It Was Put To The Ld.Sr Dr As To How The Total Receipts Could Be Treated As The Income Of The Assessee & If At All The Registration U/S.12A Of The Act Was To Be Denied Then The Business Income Of The Assessee Should Have Been Computed.

For Appellant: NoneFor Respondent: Shri Abhijit Adhikary, Sr. DR

Section 12ASection 143(1)

filed by the assessee has been processed and an intimation 143(1) of the Act has been issued on the assessee wherein the application of income as claimed by the assessee has been denied and the total receipts of the assessee has been treated as the income of the assessee

M/S. Clc Tanners Association, Twenty Four Parganas South vs. D.C.I.T., Circle - 1(1) Exemption, Kolkata

In the result, appeal of the assessee is allowed

ITA 2474/KOL/2024[2018-2019]Status: DisposedITAT Kolkata12 Jan 2026AY 2018-2019

Bench: Shri George Mathanआयकर अपील सं/Ita No.2474/Kol/2024 (नििाारण वर्ा / Assessment Year. :2018-2019) M/S Clc Tanners Association Vs Ito Ward-2(2), Kolkata Calcutta Leather Complex, Cetp Po Karaidanga, Parganas(South) West Bengal-743502 Pan No. : Aaccc 7323 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Sunil Surana, Ar राजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 12/01/2026 घोषणा की तारीख/Date Of Pronouncement : 12/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 15.10.2024 Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-2019. 2. It Was Submitted By The Ld.Ar That The Assessee Is A Trust Which Is Is Entered Into A Tripartite Agreement With The Government Of West Bengal Ad The Bot Agency Of Calcutta Leather Companies For Various Works. It Was Submission That The During The Impugned Assessment Year The Assessee Had Claimed Depreciation Of Rs.40,48,460/- In Its Return Of Income. The Ao Had Disallowed The Assessee’S Claim Of The Depreciation On The Ground That The Depreciation Cannot Be Granted In Respect Of Assets. The Acquisition Which Have Been Claimed As Application Of Income. The Ld.Ar Drew My Attention To Various Pages Of The Paper Book, Most Specifically At Page 28 Which Is The Copy Of The Fixed Assets, Which Reads As Follows:-

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Abhijit Adhikary, Sr. DR

depreciation on the ground that the depreciation cannot be granted in respect of assets. The acquisition which have been claimed as application of income. The Ld.AR drew my attention to various pages of the paper book, most specifically at page 28 which is the copy of the fixed assets, which ... page 27 for the impugned assessment year which reads as follows:- 3 4. It was submission that the assessee has not claimed application of income in respect of the assessee required. It was submission that the assessee is entitled to claim of depreciation. The Ld.AR also drew my attention

Holy Cross Church, Mumbai vs. Income Tax Officer Exemption Ward 1(3), Mumbai

In the result, appeal of the assessee bearing ITA No

ITA 5515/MUM/2025[2023-24]Status: DisposedITAT Mumbai09 Jan 2026AY 2023-24

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Ms. Vasanti B. Patel a/w Shri M.A. GoelFor Respondent: Shri Ritesh Misra (CIT DR)

Section 11Section 11(2)Section 11(3)Section 143(1)Section 250

delay would result in genuine hardship to the assessee, especially when there is no dispute regarding the charitable nature of activities or the application of income. The issue is squarely covered by the judgment of the Hon’ble Jurisdictional High Court in St. Thomas High School (supra) as well

Changlang Community Resource Management Society, Changlalng vs. ITO(Exemption), 2(4), Shillong

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

ITA 181/GTY/2025[2016-17]Status: DisposedITAT Guwahati08 Jan 2026AY 2016-17

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI LAXMI PRASAD SAHU (Accountant Member)

Section 11Section 11(1)(a)Section 11(2)Section 12ASection 143(1)Section 143(1)(a)Section 250

income as per section 11(1)(a) is Rs. 88,39,472/- and further the application of income towards objects the societies are Rs. 6,49,97,092/-. Accordingly, as per the computation, there is no any other income for the year under consideration. He also referred to page

Income Tax Officer(E) Ward- 2(4), New Delhi, Civic Centre New Delhi vs. Prakash Sewa Trust, Paschim Vihar

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 12ASection 143(3)

ensure the proper utilization of these donations raised serious concerns regarding the validity of the exemption claim. Inter-charity donation is permissible as application of income but it is to be ensured that inter-charity donation is given for the objects for which the donor trust is created. In other ... diverted income, violated the objects of the trust, or applied income for non-charitable purposes. The AO has the authority to assess the application of income independently of the registration status, and where misuse or misapplication is found, the exemption may be denied, and income brought to tax accordingly

Rcs Associates Charitable Trust, Shimla vs. Income Tax Officer Exemption, Solan

The appeal stand allowed for statistical purposes

ITA 769/CHANDI/2025[2024-25]Status: DisposedITAT Chandigarh06 Jan 2026AY 2024-25

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.759/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2023-24) & 2. आयकरअपीलसं. / Ita No.769/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2024-25) Rcs Associates Charitable Trust Ito Exemption 74/1, Lower Bazar, Shimla Income Tax Office बनाम/ Vs. Himachal Pradesh - 171001 New Bypass Road, Kathed, Solan (Hp) - 173208 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aabtr-8127-N (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Vishal Mohan (Sr. Advocate) A/W Sh. Praveen Sharma (Advocate) – Ld. Ars (Virtual Mode) ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 23-12-2025 घोषणाकीतारीख /Date Of Pronouncement 06-01-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeal Before Us For Assessment Years (Ay) 2023-24 & 2024-25. First, We Take Up Appeal For Ay 2023-24 Which Arises Out Of An Order Ld. Addl. Cit / Joint Cit (Appeals)-9, Mumbai [Cit(A)] Dated 26-03-2025 In The Matter Of An Intimation Issued

For Appellant: Sh. Vishal Mohan (Sr. Advocate) a/w Sh. PraveenFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR

Section 11Section 139(1)Section 143(1)Section 143(1)(a)

computation of income reveals that as against aggregate income of Rs.309.83 Lacs, the assessee claimed application of income for charitable purposesin India for Rs.271.89 Lacs. The remaining amount of Rs.37.93 Lacs was claimed to be accumulated or set apart for application in subsequent years.The total income was thus computed ... Rs.264.82 Lacs and income accumulated or set apart was quantified at Rs.46.47 Lacs. However, in column 27(c) of this Form, the application of income to the extent of Rs.222.83 Lacs was shown to applied out of income of earlier previous years. By considering this form and the return

Rcs Associates Charitable Trust, Shimla vs. Income Tax Officer (Exemption), Solan

The appeal stand allowed for statistical purposes

ITA 759/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh06 Jan 2026AY 2023-24

For Appellant: Sh. Vishal Mohan (Sr. Advocate) a/w Sh. PraveenFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR

Section 11Section 139(1)Section 143(1)Section 143(1)(a)

Icici Securities Limited, Mumbai vs. Principal Commissioner of Income Tax, Mumbai -4, Mumbai

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

ITA 3766/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Jan 2026AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(3)Section 144BSection 263Section 36(1)(iii)Section 37(1)Section 80G

there is no restriction under section 80G to the effect that the contribution should be voluntary and that the CSR spend is an application of income which is eligible for deduction from the gross total income of the assessee as per the provisions of section 80G.  The word "donation

Shri Rajesh Ravindran Charity Trust, Ahmedabad vs. The CIT(Exemption), Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 34/AHD/2025[NA]Status: DisposedITAT Ahmedabad05 Jan 2026

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri S. N. Divatia & Shri Samir VoraFor Respondent: Shri Prathvi Raj Meena, CIT.DR

Section 80GSection 80G(5)Section 80G(5)(ii)Section 8G(5)

crucial. A trust or a fund can be of a composite character having both charitable and religious purposes. It is only if the application of income of such fund or trust of religious purposes exceeds 5% of total income, that such trust or fund would be treated as religious

Income Tax Officer (Exemptions) Ward, Kolhapur vs. The New Miraj Education Society, Miraj, Dist. Sangli

In the result, the appeal of Revenue is dismissed

ITA 928/PUN/2025[2021-22]Status: DisposedITAT Pune01 Jan 2026AY 2021-22

Bench: Shri Rama Kanta Panda, Vice- & Ms. Astha Chandra

For Appellant: Shri C.H. Naniwadekar, CAFor Respondent: Shri Udaya Bhaskar Jakke, CIT

Section 11Section 12ASection 143(1)

institution should be in Form No. 10B. The annexure to Form No. 10B requires the auditor to certify as to the application of income for charitable or religious purposes and the non- application or non- use of income or property for the benefit of the persons referred ... based on the statement of the managing trustees. The balance sheet and income and expenditure statement would necessarily contain the particulars of the application of income and non-use of income or property. The certificate of the auditor only affirms the statements contained in the balance sheet and income

Centre for E-Governance, Bangalore vs. DCIT, Exemption, Circle-1, Bangalore

ITA 936/BANG/2025[2021-22]Status: DisposedITAT Bangalore31 Dec 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

For Appellant: Shri S Parthasarthi, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)

Section 11Section 11(1)(a)Section 12ASection 2(15)

stated that any activity rendered in relation to trade, commerce or business for a fee or consideration, irrespective of the nature or application of income, shall not be considered charitable unless the two statutory conditions are satisfied. The AO emphasised that the assessee’s receipts from such commercial activities

Mitsui Kinzoku Components Pvt Ltd, Rewari vs. Income Tax Officer, ITO Ward Two

In the result, appeal of the assessee is allowed

ITA 3912/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 115Section 143(3)Section 237Section 239

dated 11 April 1955 to grant relief to the Appellant, stating that this circular is not applicable since it was issued before the application of Income Tax Act, 1961 2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in fact

Mitsui Kinzoku Components Pvt Ltd, Rewari vs. Income Tax Officer, ITO Ward Two

In the result, appeal of the assessee is allowed

ITA 3911/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 115Section 143(3)Section 237Section 239

Mitsui Kinzoku Components India Pvt Ltd, Rewari vs. Income Tax Officer, ITO Ward Two

In the result, appeal of the assessee is allowed

ITA 3910/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 115Section 143(3)Section 237Section 239

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income Tax, Circle 16(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 351/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR

Section 143(3)Section 37(1)Section 40

rejected. 8. Per contra, Id. CIT, DR submitted that payments made to retired partners cannot be regarded as diversion but is an application of income since it is made from the income of the firın. Ld. DR placed reliance on the orders of the authorities below. In the course ... Supra) wherein the payments made to the retiring partners were held to be out of self imposed obligation being gratuitous and hence an application of income. In this decision, the claim of the assessee was disallowed. To this effect, Id. Counsel for the assessee had referred to the decision

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income Tax, Circle 16(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 350/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Dec 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR

Section 143(3)Section 37(1)Section 40