THE HIGH COURT OF DELHI AT NEW DELHI
% Judgment delivered on: 16.05.2014
+ W.P.(C) 1208/2013 & CM No.2299/2013
COMMISSIONER OF INCOME TAX (C)-III ... Petitioner
versus
SH. GOPAL GUPTA ... Respondent
Advocates who appeared in this case:
For the Petitioner : Mr N.P. Sahni with Mr Nitin Gulati
For the Respondent No.1 : Mr Parag Tripathi, Sr Advocate with
MrVivek Kohli, Mr Shwetank Tripathi,
Mr Kunal Bahri and Ms Shivambika Sinha.
CORAM:-
HON'BLE MR JUSTICE BADAR DURREZ AHMED
HON'BLE MR JUSTICE SIDDHARTH MRIDUL
JUDGMENT
BADAR DURREZ AHMED, J (ORAL)
1. This writ petition, which has been filed by the Commissioner of
Income Tax, impugns the order dated 21.05.2012 passed by the
Income Tax Settlement Commission under Section 245D(4) of the
Income Tax Act, 1961. It is also directed against the order dated
20.11.2012 passed by the Settlement Commission. The respondent
No.1 had approached the Settlement Commission by way of a
W.P.(C)1208/2013 Page 1 of 21
settlement application in respect of assessment years 2003-2004 to
2009-2010.
2. Two points have been urged in this writ petition in the context
of the contention of the Revenue that the respondent No.1 had not
made a full and true disclosure and therefore the impugned orders
were liable to be quashed and set aside. The first point pertains to the
transaction concerning the property at Motia Khan, Karol Bagh in
respect of which the respondent No.1 alongwith his wife Smt. Vineeta
Gupta had declared a sum of Rs.7.6 crores as undisclosed investment.
Insofar as that issue concerning the property at Motia Khan is
concerned, it has been dealt with by us in a recent decision in the case
of the respondent No.1's wife Smt. Vineeta Gupta in WP(C) 829/2013
(Commissioner of Income Tax v. Vineeta Gupta) decided on
06.05.2014. That decision would cover the point taken in the present
petition with regard to the transaction concerning the property at
Motia Khan even insofar as the respondent No.1 herein is concerned.
The other issue which has been raised by the Revenue/petitioner is
with regard to five receipts of cash totalling to Rs.6.00 crores which
were found during the search operation which took place on
W.P.(C)1208/2013 Page 2 of 21
15.01.2009 at the premises of respondent No.1. The five receipts are
of Rs.2.00 crores and four others of Rs.1.00 crore each. The said
receipts were photocopies. The respondent No.1 has stated that
although the said receipts representing Rs.6.00 crores were receipts of
loans received by the respondent No.1, the same had been disclosed as
income before the Settlement Commission. The stand taken by the
Revenue that the said sum of Rs.6.00 crores is not the principal
amount of loans received by respondent no.1 but only the interest
received by respondent No.1 on much larger loans extended by
respondent No.1 to five persons on 07.11.2008. As per the Revenue,
the receipts disclosed the rate of interest @1.25%. Since the Revenue
has taken the stand that the amounts received by respondent No.1
constituted interest payments, the total principal amount would
amount to Rs.80.00 crores. The Revenue has contended that while the
receipt of Rs.6.00 crores by way of interest has been disclosed to the
Settlement Commission, the principal amount of Rs.80.00 crores by
way of investment has not been disclosed and therefore the respondent
No.1 has not made a full and true disclosure of his income even before
the Settlement Commission which is a mandatory requirement under
W.P.(C)1208/2013 Page 3 of 21
Section 245C of the Income Tax Act, 1961. Consequently, the
impugned order was liable to be set aside on this ground alone.
3. One of the receipts dated 07.11.2008 which has been
reproduced in the impugned order dated 21.05.2012 is also set out
herein below:-
"Dated 07.11.2008
RECEIPT
I, Sri Gopal Gupta, owner of M/s. Flakes 'N'
Flavourz here by confirm the Receipt of Rs.20000000/-
(Rupees Two Crore only) from Mr.Ankit Agarwal, Delhi
on 07.11.08 A/c Account of interest payable @1.25% for
six months through Mr.Suresh Bansal.
1
Rupee
revenue
stamp
Sd/-
(Sr. Gopal Gupta)"
4. The entire controversy in this case centers around the
interpretation given to the receipt. As per the Revenue, the receipt
indicates an amount by way of interest whereas as per the respondent
No.1 it was not received by way of interest and was the principal
amount of loan which was received by the respondent No.1 which he
W.P.(C)1208/2013 Page 4 of 21
has disclosed as his income before the Settlement Commission
because the lender would not come forward to confirm the cash loans.
Before the Settlement Commission, the Revenue raised the following
contentions on this issue:-
"11. During the hearing the learned CIT(DR) has raised
the contentions on this issue as under:-
i. During the search, the documents were
seized which showed that Shri Gopal Gupta
received interest of Rs. 6 crore on the loans given
for six months. These documents, are
acknowledgement receipts signed by Shri Gopal
Gupta having received the amount. If the reverse
calculation is done, it indicates that Shri Gopal
Gupta advanced cash loan of Rs. 80 crores to
five persons on 7.11.2008 for a period of six
months. CIT(DR) further contended that the
counsel of the applicant could not produce any
evidence to show that loans were received by Sri
Gopal Gupta. No confirmation from the persons
who are mentioned in the documents have been
submitted.
CIT(DR) also drew attention to the statement of
the applicant which was recorded under section
132(4) of the Income Tax Act, 1961, and
specially his answer to Q. No. 33 which is
reproduced below :-
"I have gone through the pages shown by
you. I am unable to recollect right now the
exact nature of these receipts. I will have
to go through my records and consult the
concerned accountants to furnish the
required details asked by you. I shall
W.P.(C)1208/2013 Page 5 of 21
submit the same as and when required in
due course of time"
From the above' CIT(DR) has contended that the
applicant was giving evasive replies.
Considering that the transaction was executed on
07.11.2008 and search took place on 15.01.2009,
this was an afterthought. However only in the
statement recorded in the month of June, 2009
he submitted that it was actually a loan received
by him for a period of six months. It is important
to note that the word "loan" has not been
mentioned on the documents seized during the
search. As such, the explanation given by the
applicant is clearly an afterthought. Even during
the statement under section 132(4) of the Act,
the applicant had given the evasive reply.
(iii) The applicant has not disowned the
documents and the contents. The presumption
u/s. 132(4A) of the Income Tax Act, 1961 has not
been rebutted by him. The reference is placed on
the decision of the Hon'ble Delhi High Court in
the case of Smt. Urmila Gambhir."
5. On behalf of the respondent No.1, the submissions made before
the Settlement Commission were as under:-
"12. During the course of hearing the learned AR has
submitted as under:-
i) The receipts represent the money borrowed by
the applicant, Mr. Sri Gopal Gupta from different
persons through a common broker Shri Suresh
Bansal.
W.P.(C)1208/2013 Page 6 of 21
ii) The language of the receipts is cryptic
and gives an impression that the receipts were on
account of receipt of interest on some loan given.
Whereas in actuality the receipts are in respect of
money received as a loan totaling to Rs. six
crores at an interest of 1.25 p.m. taken for 6
months.
iii) The residential house, all the business
premises and all the lockers of the applicant have
been covered by the Income Tax Department and
nothing has been found to indicate that any sum
was advanced to the persons mentioned on the
receipts on interest. Had it been so the applicant
would have also preserved such papers
(documents on strength of which normally a loan
is given to secure it) along with these receipts. It
is very unnatural that the applicant is preserving
the photocopy receipts (of interest received) issue
by him and does not preserve the original
documents on the strength of such he could secure
the repayment without which he could not have
recovered the amount advanced, if any. It is
submitted that no addition can be made merely by
presuming or by assuming that the applicant
would have advanced the sum without there
being any document to show the same and the
document being relied upon is only a photocopy
and the language of which is cryptic.
v) The wording of the photocopy of the
receipts is such which is as in the case of a person
taking a loan i.e. identification of the borrower,
his business particulars, amount of loan, period
for which the loan is taken and the rate of interest
and name of person from whom loan is taken is
mentioned on such a receipt.
W.P.(C)1208/2013 Page 7 of 21
vi) The Department has option to make
necessary enquiries from the broker Mr. Suresh
Bansal whose address has been given and
approach to the Commission in case of any
misrepresentation of facts to make the settlement
void.
13. It is claimed by the applicant that he has offered
additional income of Rs.6 crores on account of such
receipts as he cannot get confirmation of such loans from
Shri Ankit Agarwal and other lenders as the transactions
are unaccounted from both sides. It is argued that the
persons who advanced loans will not confirm the
unaccounted transactions on the basis of papers seized at
the premises of the applicant as such confirmation would
make him liable to tax."
6. The conclusions of the Settlement Commission on the above
issue are as under:-
"15. It is observed that there is no dispute that the
amount of Rs. six crores has been received by the
applicant on 07.11.2008. The dispute between the
applicant and the Department is that whether the five
receipts of total amount of Rs. 6 crores are on account of
loans taken by Shri Sri Gopal Gupta from the persons
mentioned in the receipts or whether the amount of Rs. 6
crores are on account of interest received by Shri Sri
Gopal Gupta on loans given by him to the said persons.
16. In our view, the words "A/c Account of interest
payable @1.25% for six months" are very important and
has to be interpreted considering the totality of
circumstances. The words used are "interest payable" and
not "interest receivable". The words "interest payable"
will be applicable to the person who has signed the receipt
W.P.(C)1208/2013 Page 8 of 21
and not to the person for whom the receipt is signed. It is
seen that the five receipts are the photocopies and not the
original receipts. Logically the original receipts will be
kept by the person who may need it to use it as a safety in
case of any default. The photocopy will be kept by the
person who wants to keep it as a matter of record and no
original record needed. In case of default, the photocopy
of the receipts will not have any legal force. In such
situation only original receipts will have legal validity. It
is a wide practice that even in cases of unaccounted
transactions, proper documents are executed in order to
put pressure of legal action on borrower so that he may
not default. Such a receipt also acts as a deterrent as any
default would seriously affect the borrower's credibility in
the market and nobody would do any business with him in
future. Therefore, if Rs.6 crores is the interest, in that case,
Shri Sri Gopal Gupta should have with him original copy
of the receipts as well as necessary documents/ papers to
support his claim in respect of amounts given as loan.
Similarly, if Rs.6 crores are loans taken by Shri Sri Gopal
Gupta on interest in that case the original receipts as well
as original papers/documents in respect of such loans
would be kept by lenders. In our view the fact that original
copy of the receipts as well as other papers/documents in
respect of Rs.6 crores were not found from the premises of
the applicant, supports the case of the applicant as when
he was keeping photocopy of the receipt, there was no
reason why he would not have kept original copy of
receipts and other papers/documents of loans with him.
After taking into account all the facts in entirety, we
are of the considered view that the amount of Rs. 6
crores as mentioned in the receipts are loans taken by
Shri Sri Gopal Gupta payable @ 1.25% interest for the
period of six months. As the applicant has already offered
Rs.6 crores as additional income, no further action is
required on this issue."
W.P.(C)1208/2013 Page 9 of 21
7. From the above it is evident that the Settlement Commission
has taken the view that the amount of Rs.6.00 crores as mentioned in
the said receipts were loans taken by respondent No.1 payable
@1.25% for the period of six months. The Settlement Commission
also took the view that, as the respondent No.1 has already offered
Rs.6.00 crores as additional income, no further action was required on
the issue.
8. We have examined the submissions made by the learned
counsel for the Revenue as well as by the learned counsel for
respondent No.1. It is evident that the Revenue seeks to interpret the
said receipts in such a way as to indicate that the amount of Rs.6.00
crores had been received by way of interest whereas the learned
counsel for respondent No.1 has relied on the interpretation placed by
the Settlement Commission that the said sum was received by way of
loans. In our view, both interpretations are possible.
9. In this backdrop, the question that arises is as to what degree, if
at all, can this Court interfere when two possible interpretations are
placed before it with regard to a document which is of vital
importance and when one of the interpretations has been accepted by
W.P.(C)1208/2013 Page 10 of 21
the Settlement Commission. In this context, Mr. Tripathi, the learned
senior counsel appearing on behalf of respondent No.1 placed reliance
on the following four decisions of the Supreme Court:-
1. R.B. Shreeram Durga Prasad v. Settlement Commission
& Another: (1989) 1 SCC 628;
2. Jyotendrasinhji v. S.I. Tripathi & Ors.: 1993 Supp (3)
SCC 38;
3. Shriyans Prasad Jain v. Income Tax Officer & Ors.:
1993 Supp (4) SCC 727; and
4. Union of India & Others v. Ind-Swift Laboratories:
(2011) 4 SCC 635.
10. In R.B. Shreeram Durga Prasad (supra) the Supreme Court
observed that in the exercise of power of judicial review of a decision
of the Settlement Commission, the Court is concerned with the
legality of procedure followed and not with the validity of the order.
The Supreme Court also placed reliance on the English decision in the
case of Chief Constable of the North Wales Police v. Evans: (1982) 1
WLR 1155. The Supreme Court observed that judicial review is not
concerned with the decision but with the decision making process.
W.P.(C)1208/2013 Page 11 of 21
11. In Jyotendrasinhji (supra) the Supreme Court placed reliance
on its decision in the case of R.B. Shreeram Durga Prasad (supra)
and observed that the scope of enquiry, whether by the High Court
under Article 226 or by the Supreme Court under Article 136 remains
the same and the question to be examined is whether the order of the
Commission is contrary to any of the provisions of the Act and if so,
has it prejudiced the petitioner/appellant apart from the ground of bias,
fraud and malice, which of course, constitute a separate and
independent category. The Supreme Court was concerned with the
question of interpretation which had been placed by the Commission
in respect of trust deeds which were the subject matter before the
Settlement Commission. The Supreme Court observed that the
Commission had interpreted the trust deeds in a particular manner and
even if the interpretation placed by the Commission on the said deeds
was not correct, it would not be a ground for interference since a
wrong interpretation cannot be regarded as a violation of the
provisions of the Income Tax Act. The exact words used by the
Supreme Court were as under:
"16. It is true that the finality clause contained in
Section 245-I does not and cannot bar the jurisdiction of
W.P.(C)1208/2013 Page 12 of 21
the High Court under Article 226 or the jurisdiction of this
Court under Article 32 or under Article 136, as the case
may be. But that does not mean that the jurisdiction of this
Court in the appeal preferred directly in this Court is any
different than what it would be if the assessee had first
approached the High Court under Article 226 and then
come up in appeal to this Court under Article 136. A party
does not and cannot gain any advantage by approaching
this Court directly under Article 136, instead of
approaching the High Court under Article 226. This is not
a limitation inherent in Article 136; it is a limitation which
this Court imposes on itself having regard to the nature of
the function performed by the Commission and keeping in
view the principles of judicial review. Maybe, there is also
some force in what Dr Gauri Shankar says viz., that the
order of the Commission is in the nature of a package deal
and that it may not be possible, ordinarily speaking, to
dissect its order and that the assessee should not be
permitted to accept what is favourable to him and reject
what is not. According to learned counsel, the
Commission is not even required or obligated to pass a
reasoned order. Be that as it may, the fact remains that it is
open to the Commission to accept an amount of tax by
way of settlement and to prescribe the manner in which
the said amount shall be paid. It may condone the defaults
and lapses on the part of the assessee and may waive
interest, penalties or prosecution, where it thinks
appropriate. Indeed, it would be difficult to predicate the
reasons and considerations which induce the Commission
to make a particular order, unless of course the
Commission itself chooses to give reasons for its order.
Even if it gives reasons in a given case, the scope of
enquiry in the appeal remains the same as indicated above
viz., whether it is contrary to any of the provisions of the
Act. In this context, it is relevant to note that the principle
of natural justice (audi alteram partem) has been
incorporated in Section 245-D itself. The sole overall
limitation upon the Commission thus appears to be that it
W.P.(C)1208/2013 Page 13 of 21
should act in accordance with the provisions of the Act.
The scope of enquiry, whether by High Court under
Article 226 or by this Court under Article 136 is also the
same -- whether the order of the Commission is contrary
to any of the provisions of the Act and if so, has it
prejudiced the petitioner/appellant apart from ground of
bias, fraud and malice which, of course, constitute a
separate and independent category. Reference in this
behalf may be had to the decision of this Court in R.B.
Shreeram Durga Prasad and Fatechand Nursing Das v.
Settlement Commission (IT and WT) [(1989) 1 SCC 628 :
1989 SCC (Tax) 124 : (1989) 176 ITR 169] which too was
an appeal against the orders of the Settlement
Commission. Sabyasachi Mukharji, J., speaking for the
Bench comprising himself and S.R. Pandian, J. observed
that in such a case this Court is "concerned with the
legality of procedure followed and not with the validity of
the order". The learned Judge added "judicial review is
concerned not with the decision but with the decision-
making process". Reliance was placed upon the decision
of the House of Lords in Chief Constable of the N.W.
Police v. Evans [(1982) 1 WLR 1155 : (1982) 3 All ER
141] . Thus, the appellate power under Article 136 was
equated to power of judicial review, where the appeal is
directed against the orders of the Settlement Commission.
For all the above reasons, we are of the opinion that the
only ground upon which this Court can interfere in these
appeals is that the order of the Commission is contrary to
the provisions of the Act and that such contravention has
prejudiced the appellant. The main controversy in these
appeals relates to the interpretation of the settlement deeds
-- though it is true, some contentions of law are also
raised. The Commission has interpreted the trust deeds in
a particular manner. Even if the interpretation placed by
the Commission on the said deeds is not correct, it would
not be a ground for interference in these appeals, since a
wrong interpretation of a deed of trust cannot be a
violation of the provisions of the Income Tax Act. It is
W.P.(C)1208/2013 Page 14 of 21
equally clear that the interpretation placed upon the said
deeds by the Commission does not bind the authorities
under the Act in proceedings relating to other assessment
years.
17. In view of the above, though it is not necessary,
strictly speaking, to go into the correctness of the
interpretation placed upon the said deeds by the
Commission, and it is enough if we confine ourselves to
the question whether the order of the Commission is
contrary to the provisions of the Act, we propose to, for
the sake of completeness, examine also whether the order
of the Commission is vitiated by any such wrong
interpretation?"
(underlining added)
12. The next decision which was relied upon by Mr. Tripathi was
that of Shriyans Prasad Jain (supra) wherein the Supreme Court
again placed reliance on R.B. Shreeram Durga Prasad (supra) and
Jyotendrasinhji (supra) and observed as under:-
"19. Mr Poti, learned counsel for the Revenue, is right in
submitting that in this appeal this Court would not go into
questions of the fact or review the findings of fact
recorded by the Commission. As pointed out by this Court
in Jyotendrasinhji v. S.I. Tripathi [1993 Supp (3) SCC
389: (1993) 201 ITR 611] this Court can interfere with the
Commission's order only if it is found to be "contrary to
any of the provisions of the Act". To the same effect is the
earlier decision of this Court in R.B. Shreeram Durga
Prasad and Fatehchand Nursing Das v. Settlement
Commission [(1989) 1 SCC 628 : 1989 SCC (Tax) 124 :
(1989) 176 ITR 169] ."
(underlining added)
W.P.(C)1208/2013 Page 15 of 21
13. It is apparent that the power of interference under Article 226 is
limited. It is evident that this Court under Article 226 can only
interfere with the Settlement Commission if it is found to be contrary
to the provisions of the Act and that even if the Court disagrees with
an interpretation placed by the Settlement Commission on a document,
it cannot substitute its view in place of that of the Settlement
Commission unless and until the interpretation given by the
Settlement Commission is clearly arbitrary and perverse.
14. The last decision relied upon by Mr. Tripathi was that of Union
of India & Others v. Ind-Swift Laboratories Limited (supra) in which
the Supreme Court observed as under:-
"22. An order passed by the Settlement Commission could
be interfered with only if the said order is found to be
contrary to any provisions of the Act. So far as the
findings of fact recorded by the Commission or question
of facts are concerned, the same is not open for
examination either by the High Court or by the Supreme
Court. In the present case the order of the Settlement
Commission clearly indicates that the said order,
particularly, with regard to the imposition of simple
interest @ 10% per annum was passed in accordance with
the provisions of Rule 14 but the High Court wrongly
interpreted the said Rule and thereby arrived at an
erroneous finding. So far as the second issue with respect
to interest on Rs. 50 lakhs is concerned, the same being a
factual issue should not have been gone into by the High
W.P.(C)1208/2013 Page 16 of 21
Court exercising the writ jurisdiction and the High Court
should not have substituted its own opinion against the
opinion of the Settlement Commission when the same was
not challenged on merits."
(underlining added)
15. From the above it is evident that the Supreme Court observed
that the High Court ought not to gone into a factual issue while
exercising writ jurisdiction and should not have substituted its opinion
against the opinion of the Settlement Commission. From all these
decisions it is abundantly clear that the scope of review under Article
226 of the Constitution insofar as an order passed by the Settlement
Commission under Section 245 D (4) of the Income Tax Act is
concerned, is a very limited one. This Court certainly cannot
substitute its view in place of the Settlement Commission particularly
on point of interpretation of a particular document. Interference can
only be made if there is a fault in the decision making process and not
with the decision itself. Even if this Court feels that it would have
arrived at a different decision, it cannot interfere with the conclusion
arrived at by the Settlement Commission because this Court does not
sit in appeal over the decision of the Settlement Commission.
W.P.(C)1208/2013 Page 17 of 21
16. In this context, it is to be seen that the only point urged by the
learned counsel for the Revenue is that the interpretation placed on the
receipts was erroneous. The interpretation which has been placed by
the Settlement Commission on the documents in question, first of all,
results in a finding of fact which, as we have seen, cannot be
interfered with. And, secondly, the interpretation is not so outlandish
to be categorized as arbitrary or perverse so as to call for interference.
We make it clear that the interpretation sought to be placed by the
Revenue may be a possible interpretation but, so, too, would be the
interpretation placed by the Settlement Commission which has also
been espoused by the learned counsel for respondent No.1. In such a
situation no interference with the Settlement Commission's order is
warranted.
17. Mr. Sahni, the learned counsel appearing for the Revenue,
referred to a decision of this Court in Omaxe Limited & Another v.
Deputy Commissioner, Income Tax, WP (C) 1451/2013, decided on
15.04.2014. In particular, he placed reliance on the observations of a
Division Bench of this Court in para 16 thereof which deals with the
issue of misrepresentation which, according to the said decision,
W.P.(C)1208/2013 Page 18 of 21
would mean failure to disclose material or facts which are germane
and relevant. We do not see as to how that decision would advance
the cause of the Revenue inasmuch as there are no foundational facts
in the present case to establish misrepresentation on the part of
respondent No.1. In this context, it may be pointed out that the case of
the Revenue that there was misrepresentation or that the respondent
No.1 had not given a full and true disclosure is based on an
interpretation of the said receipts. Its case is that since the said
receipts were of the amounts representing interest and not of the
principal amount, the respondent No.1 had not disclosed the principal
amount and thereby had indulged in suppression and non-disclosure.
The question of misrepresentation or suppression or concealment is
premised on the interpretation that the receipts were of amounts
representing interest payments and not of the loans taken by
respondent No.1. That interpretation has not been accepted by the
Settlement Commission and therefore the entire foundation of the
argument that the respondent No.1 had indulged in misrepresentation
and not made a full and true disclosure falls to the ground.
W.P.(C)1208/2013 Page 19 of 21
18. Lastly, Mr. Sahni submitted that although it had not been
specifically raised in the writ petition that the respondent No.1 had not
submitted information as required by the assessing officer at the time
of assessment proceedings, he referred to the statement of facts (SOF)
and the Rule 9 report submitted by the Commissioner of Income Tax
and in particular to serial No.9 thereof wherein this aspect has been
mentioned. It has been pointed out that the Commissioner of Income
Tax had referred to various questionnaires issued by the assessing
officer to the respondent No.1 during the assessment proceeding and
that the Commissioner of Income Tax had stated that the respondent
had not submitted information as asked for in such questionnaires.
The response of the respondent No.1 is also indicated and as per the
respondent No.1 he had appended copies of the replies to all the
questionnaires raised by the assessing officer. In this context, we may
also note the submission of the respondent No. 1 before the Settlement
Commission, which we have already reproduced above, to the effect
that the Department had the option to make necessary enquiries from
the broker Mr. Suresh Bansal, whose address had already been given
and, in case any misrepresentation of facts was found it could request
W.P.(C)1208/2013 Page 20 of 21
the Commissioner to make the settlement void. In the wake of this
submission, there was no contrary finding or contrary argument raised
before the Settlement Commissioner on behalf of the Revenue.
Consequently, the submission of Mr. Sahni on this aspect of the matter
is also not tenable. In any event, it is not sufficient to warrant any
interference with the orders of the Settlement Commission.
19. In view of the foregoing discussion, the writ petition is
dismissed. There shall be no order as to costs.
BADAR DURREZ AHMED, J
SIDDHARTH MRIDUL, J
MAY 16, 2014
ns
W.P.(C)1208/2013 Page 21 of 21
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