2025 INSC 743 REPORTABLE

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NO.14318 OF 2015

Shital Fibers Limited …Appellant

versus

Commissioner of Income Tax …Respondent

with

CIVIL APPEAL NOS. 14295/2015, 14299/2015,

14297/2015, 14301/2015, 14304/2015, 14305/2015,

14309/2015, 14324/2015, 14319/2015, 14313/2015,

14323/2015, 14314/2015, 14322/2015, 14320/2015,

14337/2015, 14339/2015, 14340/2015, 14346/2015,

14347/2015, SLP (C) No. 19698/2014, SLP(C) No.

36539/2014, SLP (C) 9723 of 2018 and SLP (C) No. 28934

of 2019

J U D G M E N T

ABHAY S. OKA, J.

1.This group of appeals/petitions has been referred to a

Bench of three Judges in view of the Order dated 10

th

December, 2015 in Assistant Commissioner of Income Tax,

Bangalore v. Micro Labs Limited

1

which records difference

of opinion between two Hon’ble Judges of this Court.

2.For the sake of convenience, we are referring to facts of

the case in Civil Appeal No. 14318 of 2015. We may note here

1 (2015) 17 SCC 96

Civil Appeal No.14318 of 2015 etc. Page 1 of 20

that some of the appeals in the group have been disposed of

by the Order dated 01

st

August, 2024 due to low tax effect.

FACTUAL ASPECT

3.We are referring to the facts of the case in Civil Appeal

No. 14318 of 2015. Appellant is a company which filed a

return declaring net taxable income at Rs. 46,99,293/- for the

Assessment Year 2002-03. The appellant claimed deductions

under Section 80-HHC and 80-IA of the Income Tax Act, 1961

(for short ‘the IT Act’). The return was accepted on 31

st

October, 2002. Reassessment proceedings under Section 147

of the IT Act were initiated in respect of the said Assessment

Year by the order dated 10

th

December 2008 by the Assistant

Commissioner of Income-Tax, Range II, Jalandhar. Reliance

was placed by the Revenue on the decision of Income Tax

Appellate Tribunal (for short ‘ITAT’), Chennai (Special Bench)

in the case of ACIT v. Rogini Garments

2

. In the said Order

dated 10

th

December, 2008, under Section 147 of the IT Act, it

was observed that a deduction of Rs. 90,43,347/- was

claimed by the appellant under Section 80-IB on the total

profit of Rs. 4,19,40,609/-. The appellant claimed a deduction

of Rs. 1,76,90,799/- under Section 80-HHC.

4.The return filed by the appellant was processed under

Section 143(1)(a) and a statutory notice under Section 148 of

the IT Act was served upon the appellant. Based on the

judgment dated 17

th

July, 2008 of the jurisdictional ITAT, in

2 (2007) SCC OnLine ITAT 159

Civil Appeal No.14318 of 2015 etc. Page 2 of 20

ITA Nos.320 and 321, Amritsar Bench in respect of appellant’s

case for the assessment year 2003-04 and 2004-05, a fresh

notice under Section 143(2) was served upon the appellant.

5.We may note here that in the case of ACIT v. Rogini

Garments

2

, ITAT held that in order to prevent the taxpayers

from taking undue advantage of existing provisions of the IT

Act by claiming repeated deductions in respect of the same

amount of eligible income, in-built restriction was introduced

by enacting Sub-section (9) of Section 80-IA with effect from

1

st

April, 1999.

6.The appellant filed response to the notice under Section

143(2). The appellant relied upon the decision of Madras High

Court in the case of SCM Creations v. ACIT

3

wherein it was

held that Sub-section (9) of Section 80-IA does not bar

computation of deductions provided under different

provisions of the IT Act. But, it merely restricts the

allowability of deductions to the extent of profits and gains of

business. However, by the Order dated 12

th

March, 2009,

Additional Commissioner of the Income Tax rejected the

argument of the appellant and deductions claimed by the

appellant under Section 80-IA and 80-HHC were disallowed.

7.The appeal preferred by the appellant against the said

Order was dismissed by Commissioner of Income Tax

(Appeals). In appeal preferred by the appellant before the ITAT,

the appellant was unsuccessful. Thereafter, an appeal was

3 304 ITR 319

Civil Appeal No.14318 of 2015 etc. Page 3 of 20

preferred before the Punjab and Haryana High Court which

came to be dismissed by the impugned judgment and order.

The High Court relied upon its own decision in the case of

Friends Casting (P) Ltd. v. Commissioner of Income Tax

4

.

The High Court took the view that Sub-section (9) of Section

80-IA bars claim for deduction under any other provision of

Chapter VI-A, if deduction under Section 80-IA has been

allowed. In fact, a decision of Bombay High Court in the case

of Associated Capsules (P) Ltd. v. Deputy Commissioner of

Income Tax and Anr

5

was also referred. However, the High

Court did not agree with the view taken by Bombay High

Court. In addition, the High Court relied upon a decision of

Delhi High Court in the case of Great Eastern Exports v.

Commissioner of Income Tax

6

.

SUBMISSIONS

8.Learned senior counsel appearing for the appellant

invited our attention to Chapter VI-A. He pointed out that

there are 33 different provisions under the heading ‘C’ of

Chapter VI-A which includes Section 80-HHC, 80-IA, 80-IAB,

80-IB etc. He pointed out that it is possible for the assessee to

claim deductions under each of 33 sections. He submitted

that legislature has allowed each eligible assessee to claim

deductions through 33 provisions under heading ‘C’ of

Chapter VI-A. He submitted that the real issue is the extent of

4 (2011) 50 DTR Judgments 61

5 (2011) SCC Online Bombay 27

6 (2010) SCC OnLine Del 4195

Civil Appeal No.14318 of 2015 etc. Page 4 of 20

deduction allowable separately under Section 80-IA and

Section 80-HHC and the extent of deduction allowable

through each provision and overall deduction allowable by

adding them up.

9.Learned counsel invited our attention to the opinion

expressed by Anil R. Dave, J. He pointed out that heading ‘C’

deals with profit and income related deductions. He pointed

out that Section 80-A(1) provides that in computing total

income of assessee, there shall be allowed from gross total

income of an assessee in accordance with and subject to the

provisions of this Chapter, the deductions specified in Section

80-C to 80-U. He pointed out that the residue after

deductions is the total income on which income tax is levied.

It was submitted that the upper limit of profit applies under

the heading ‘C’ only in view of Sub-section (9) of Section 80-

IA.

10.Learned senior counsel invited our attention to the view

taken by Dipak Misra, J (as he then was) and submitted that

the said view is a correct view for the reasons recorded

therein.

11.Learned Additional Solicitor General appearing for the

Revenue supported the view taken by Anil R. Dave, J. He

submitted that the learned Judge rightly held that if an

assessee claims any deduction under the provisions of

Section 80-IA and/or 80-IB, he cannot claim any deduction to

the extent of such profits and gains which had been claimed

Civil Appeal No.14318 of 2015 etc. Page 5 of 20

and allowed under the provisions of Section 80-HHC. The

reason being Section 80-HHC is included in heading ‘C’ of

Chapter VI-A of the IT Act. He submitted that the profits in

respect of which deduction was allowed under Section 80-

HHC had also been previously allowed under Section 80-IB.

CONSIDERATION

12.Under Section 4 of the IT Act, Income Tax is chargeable

on the total income of an assessee for previous year. Chapter

II of the IT Act deals with the ambit of total income. Chapter

III deals with incomes which do not form part of the total

income at all. Chapter IV deals with the computation of total

income under different sources. Chapter V deals with income

of other persons which are to be included in the assessee’s

total income. Chapter VI provides for aggregation of income

from different sources or set off or carry forward of loss to the

next assessment year. Chapter VI-A specifically deals with

deductions to be made in computing the total income. Thus,

the gross total income of the assessee is worked out by

applying various provisions upto and inclusive of stage of

Chapter VI.

13.Chapter VI-A deals with deductions to be made in

computing income. Chapter VI-A contains Sections 80-A to

80-U. It has five heads, head ‘A’ – General, ‘B’ – Deductions in

respect of certain payments, ‘C’ – Deductions in respect of

certain incomes, ‘CA’ – Deductions in respect of other incomes

and ‘D’ – Other deductions.

Civil Appeal No.14318 of 2015 etc. Page 6 of 20

14.Section 80 A under the Heading ‘A – General’ provides

that in computing the total income of an assessee, there shall

be allowed from his gross total income, in accordance with

and subject to the provisions of this Chapter VI, the

deductions specified in Section 80-C to 80-U. Section 80-AB

provides that where any deduction is required to be made or

allowed under any Section included in Chapter VI-A under the

heading ‘C’ in respect of any income of the nature specified in

that Section which is included in the gross total income of the

assessee, then, notwithstanding anything contained in that

Section, for the purposes of computing the deduction under

that Section, the amount of income of that nature as

computed in respect of the provisions of IT Act (before making

any deduction under Chapter VI-A) shall alone be deemed to

be the amount of income of that nature which is derived or

received by assessee and which is included in his gross

income.

15.Sub-section (5) of Section 80-B defines gross total

income as the total income computed in accordance with

provisions of the IT Act, before making any deduction under

Chapter VI-A. At this stage, we may note that under Section

4(1), which is the charging section, income tax is chargeable

on total income of the previous year. Sections 80-A and 80-AB

refer to gross total income and not total income as

contemplated by Section 4(1). As stated earlier, Sections 80-C

to 80-GGC under heading ‘B’ provide for deductions in respect

of certain payments. In this case, we are concerned with

Civil Appeal No.14318 of 2015 etc. Page 7 of 20

deductions under Sections 80-HHC and 80-IA and 80-IB

under Heading ‘C’.

16.The relevant part of Section 80-HHC is reproduced

below:

“80-HHC.Deduction in respect of profits

retained for export business.—(1) Where

an assessee, being an Indian company or a

person (other than a company) resident in

India, is engaged in the business of export

out of India of any goods or merchandise to

which this section applies, there shall, in

accordance with and subject to the

provisions of this section, be allowed, in

computing the total income of the assessee,

a deduction to the extent of profits, referred

to in sub-section (1-B) derived by the

assessee from the export of such goods or

merchandise:

Provided that if the assessee, being a holder

of an Export House Certificate or a Trading

House Certificate (hereafter in this section

referred to as an export house or a trading

house, as the case may be), issues a

certificate referred to in clause (b) of sub-

section (4-A), that in respect of the amount

of the export turnover specified therein, the

deduction under this sub-section is to be

allowed to a supporting manufacturer, then

the amount of deduction in the case of the

assessee shall be reduced by such amount

which bears to the total profits derived by

the assessee from the export of trading

goods, the same proportion as the amount

Civil Appeal No.14318 of 2015 etc. Page 8 of 20

of export turnover specified in the said

certificate bears to the total export turnover

of the assessee in respect of such trading

goods.

(1-A)* * *

(1-B) For the purposes of sub-sections (1)

and (1-A), the extent of deduction of the

profits shall be an amount equal to—

(i) eighty per cent thereof for an assessment

year beginning on the 1st day of April, 2001;

(ii) seventy per cent thereof for an

assessment year beginning on the 1st day of

April, 2002;

(iii) fifty per cent thereof for an assessment

year beginning on the 1st day of April, 2003;

(iv) thirty per cent thereof for an assessment

year beginning on the 1st day of April, 2004.

and no deduction shall be allowed in respect

of the assessment year beginning on the 1st

day of April, 2005 and any subsequent

assessment year.

…………………………………”

Section 80-HHC provides for a deduction in respect of profits

retained for export business. The provision is applicable to a

company or a person engaged in business of export out of

India of any goods or mercantile to which the Section applies.

In computing the total income, the assessee is entitled to

Civil Appeal No.14318 of 2015 etc. Page 9 of 20

deduction to the extent of percentage of profits set out in Sub-

section (1B) of Section 80-HHC.

17.Section 80-IA deals with deductions in respect of profits

and gains from industrial undertakings or enterprises

engaged in infrastructure development etc. Sub-section (1)

provides that when the gross total income of an assessee

includes any profits and gains derived by an undertaking or

an enterprise from any business referred to in Sub-section (4),

in computing total income, the assessee will be entitled to

deduction of an amount equal to hundred per cent of profits

and gains derived from such business for ten consecutive

years.

18.Section 80-IB deals with deductions in respect of profits

and gains from certain industrial undertakings other than

infrastructure development undertakings. The deduction

under said provision is applicable when gross total income of

an assessee includes any profit or gain derived from any

business mentioned in various Sub-sections of Section 80-IB.

An assessee is entitled to a deduction from such profits and

gains of an amount equal to such percentage and for such

number of assessment years as specified in the Section.

19.In this context, now the provision of Sub-section (9) of

Section 80-IA must be considered. Sub-section (9) of Section

80-IA reads thus:

“(9) Where any amount of profits and gains

of an undertaking or of an enterprise in the

Civil Appeal No.14318 of 2015 etc. Page 10 of 20

case of an assessee is claimed and allowed

under this section for any assessment year,

deduction to the extent of such profits and

gains shall not be allowed under any other

provisions of this Chapter under the

heading ‘C.—Deductions in respect of

certain incomes,’ and shall in no case

exceed the profits and gains of such eligible

business of undertaking or enterprise, as

the case may be.”

Let us analyse Sub-section (9). It is applicable where any

amount of profits and gains of an undertaking or enterprise is

claimed and allowed under Section 80-IA. As stated earlier,

the deduction is to the extent of percentage of profits and

gains derived from certain category of businesses. Sub-section

(9) of Section 80-IA provides that the deduction to the extent

of profit or gain shall not be allowed under any other

provisions under heading ‘C’ of Chapter VI-A. It is further

provided in Sub-section (9) that in no case, the deduction

allowed under any other provision of Chapter VI-A under the

heading ‘C’ shall exceed profits and gains of such eligible

business of undertakings or enterprises, as the case may be.

20.Therefore, on plain reading of Sub-section (9) of Section

80-IA, if a deduction of profits and gains under Section 80-IA

is claimed and allowed, the deduction to the extent of such

profits and gains in any other provision under the heading ‘C’

is not allowed. The deduction to the extent allowed under

Section 80-IA cannot be allowed under any other provision

Civil Appeal No.14318 of 2015 etc. Page 11 of 20

under heading ‘C’. Therefore, if deduction to the extent of ‘X’ is

claimed and allowed out of gross total income of ‘Y’ under

Section 80-IA and the assessee wants to claim deduction

under any other provision under the heading ‘C’, though he

may be entitled to deduction ‘Y’ under the said provision, he

will get deduction under the other provisions to the extent of

(Y-X) and in no case total deductions under heading ‘C’ can

exceed the profits and gains of such eligible business of

undertaking or enterprise.

21.Sub-section (9) of Section 80-IA, on its plain reading,

does not provide that when a deduction is allowed under

Section 80-IA, while considering the claim for deduction

under any of the provision under heading ‘C’, the deduction

allowed under Section 80-IA should be deducted from the

gross total income. The restriction under sub-section (9) of

Section 80-IA is not on computing the total gross income. It

restricts deduction under any other provision under heading

‘C’ to the extent of the deduction claimed under Section 80-

IA.

22.Bombay High Court, in the case of Associated

Capsules (P) Ltd. v. Deputy Commissioner of Income Tax

and Anr

4

in paragraphs 38 and 39 held thus:

“39. Strong reliance was also placed by the

counsel for the Revenue on the Special Bench

decisions of the Tribunal in the case of Rogini

Garments (2007) 294 ITR (AT) 15 (Chennai)

Civil Appeal No.14318 of 2015 etc. Page 12 of 20

and Hindustan Mint and Agro Products P. Ltd.

(2009) 315 ITR (AT) 401 (Delhi), which are

affirmed by the Delhi High Court in the case

of Great Eastern Exports (2011) 332 ITR 14.

Reliance is also placed on decision of the

Kerala High Court in the case of Olam Exports

(India) Ltd. (2011) 332 ITR 40, which supports

the case of the Revenue.

40. We find it difficult to subscribe to the

views expressed by the Delhi High Court in

interpreting the provisions of section 80-IA(9).

In that case, in fact, the counsel for the

Revenue had argued (see paragraph 38 of the

judgment) that section 80-IA(9) applies at the

stage of allowing deduction and not at the

stage of computing deduction under other

provisions under heading C of Chapter VI-A. It

was argued that in the matter of grant of

deduction, the first stage is computation of

deduction and the second stage is the

allowance of the deduction. Computation of

deduction has to be made as provided in the

respective sections and it is only at the stage

of allowing deduction under section 80-IA(1)

and also under other provisions under

heading C of Chapter VI-A, the provisions of

section 80-IA(9) come into operation. While

accepting the arguments advanced by the

counsel for the Revenue, it appears that the

Delhi High Court failed to consider the

important argument of the Revenue noted in

paragraph 38 of its judgment. Moreover,

without rejecting the argument of the Revenue

that section 80-IA(9) applies at the stage of

Civil Appeal No.14318 of 2015 etc. Page 13 of 20

allowing the deduction and not at the stage of

computing the deduction, the Delhi High

Court could not have held that section 80-

IA(9) seeks to disturb the method of

computing the deduction provided under

other provisions under heading C of Chapter

VI-A of the Act. In these circumstances, we

find it difficult to concur with the views

expressed by the Delhi High Court in the case

of Great Eastern Exports [2011] 332ITR 14.

For the same reason, we find it difficult to

subscribe to the views expressed by the Kerala

High Court in the case of Olam Exports [2011]

332ITR 40.

41. In the result, we hold that section 80-IA(9)

does not affect the computability of deduction

under various provisions under heading C of

Chapter VI-A, but it affects the allowability of

deductions computed under various

provisions under heading C of Chapter VI-A,

so that the aggregate deduction under section

80-IA and other provisions under heading C of

Chapter VI-A do not exceed 100 per cent. of

the profits of the business of the assessee.

Our above view is also supported by the

Central Board of Direct Taxes Circular No. 772

dated December 23, 1998 ((1999) 235 TR (St.)

35), wherein it is stated that section 80-IA(9)

has been introduced with a view to prevent

the taxpayers from claiming repeated

deductions in respect of the same amount of

eligible income and that too in excess of the

eligible profits. Thus, the object of section 80-

IA(9) being not to curtail the deductions

Civil Appeal No.14318 of 2015 etc. Page 14 of 20

computable under various provisions under

heading C of Chapter VI-A, it is reasonable to

hold that section 80-IA(9) affects allowability

of deduction and not computation of

deduction. To illustrate, if Rs.100 is the profits

of the business of the undertaking, Rs. 30 is

the profits allowed as deduction under section

80-IA(1) and the deduction computed as per

section 80HHC is Rs. 80, then, in view of

section 80-IA(9), the deduction under section

80HHC would be restricted to Rs. 70, so that

the aggregate deduction does not exceed the

profits of the business.”

23.Hence, we find that the view taken by the Bombay High

Court is correct. Dipak Misra, J (as he then was), in

paragraphs 47 and 48 of the decision in the case of

Assistant Commissioner of Income Tax, Bangalore v.

Micro Labs Limited

1

approved the view taken by Bombay

High Court in the aforesaid case. Paragraphs 47 and 48 read

thus:

“47. It is in the context of Section 80-HHC

that sub-section (9) of Section 80-I has come

up for interpretation. There is no dispute that

sub-section (9) of Section 80-I would be

applicable as the assessee would be entitled to

deduction under Section 80-IA as well as

under Section 80-HHC. The contention of the

Revenue is that the said sub-section mandates

that deduction under Section 80-HHC has to

Civil Appeal No.14318 of 2015 etc. Page 15 of 20

be computed not only on the profits of

business as reduced by the amounts specified

in clause (baa) and sub-section (4-B) of

Section 80-HHC but by also reducing the

amount of profit and gains allowed as a

deduction under Section 80-IA(1) of the Act. In

other words, the gross total income eligible for

deduction under Section 80-HHC would be

less or reduced by the deduction already

allowed under Section 80-IA. Thus, the gross

total income eligible for deduction would not

be the gross total income as defined in sub-

section (5) of Section 80-B read with Section

80-B, but would be the gross total income

computed under sub-section (5) of Section 80-

B read with Section 80-AB less the deduction

under Section 80-IA. An example will make

the position clear. Supposing an assessee has

gross total income of Rs 1000 and is entitled

to deduction under Sections 80-IA and 80-

HHC and the deduction under Section 80-IA

is Rs 300, then the gross total income of

which deduction under Section 80-HHC is to

be computed would be Rs 700, and not Rs

1000.

48. On the other hand, the case of the

assessee is that the gross total income would

not undergo a change or reduction for the

purpose of Section 80-HHC. The two

deductions will be computed separately,

without the deduction allowed under Section

80-IA being reduced from the gross total

income for computing the deduction under

Section 80-HHC. The reason being that sub-

Civil Appeal No.14318 of 2015 etc. Page 16 of 20

section (9) of Section 80-IA does not affect

computation of deduction under Section 80-

HHC, but postulates that the deduction

computed under Section 80-HHC so

aggregated with the deduction under Section

80-IA does not exceed the profits of the

business.”

In paragraphs 53 and 54 of the same decision, it is held

thus:-

“53. The first part of sub-section (9) of Section

80-IA refers to the computation of profits and

gains of an undertaking or enterprise allowed

under Section 80-IA in any assessment year

and the amount so calculated shall not be

allowed as a deduction under any other

provisions of this Chapter. It is in this context

that the Bombay High Court has rightly

pointed out that there is a difference between

allowing a deduction and computation of

deduction. The two have separate and distinct

meanings. Computation of deduction is a

stage prior and helps in quantifying the

amount, which is eligible for deduction. Sub-

section (9) of Section 80-IA does not bar or

prohibit the deduction allowed under Section

80-IA from being included in the gross total

income, when deduction under Section 80-

HHC(3) of the Act is computed. In this context

it has been held that the expression “shall not

be allowed” cannot be equated with the words

“shall not qualify” or “shall not be allowed in

computing deduction”. The effect thereof

Civil Appeal No.14318 of 2015 etc. Page 17 of 20

would be that while computing deduction

under Section 80-HHC, the gross total income

would mean the gross total income before

allowing any deduction under Section 80-IA or

other sections of Part C of Chapter VI-A of the

Act. But once the deduction under Section 80-

HHC has been calculated, it will be allowed,

ensuring that the deduction under Sections

80-HHC and 80-IA when aggregated do not

exceed profits and gains of such eligible

business of undertaking and enterprise.

54. As I find, the legislature has used the

expression “shall not qualify” in Sections 80-

HHB(5) and 80-HHD(7), but the said

expression has not been used in sub-section

(9) of Section 80-IA. The formula prescribed in

sub-section (3) of Section 80-HHC is a

complete code for the purpose of the said

computation of eligible profits and gains of

business from exports of mercantiles and

goods. It has reference to total turnover,

turnover from exports in proportion to profits

and gains from business in clause (a) and so

forth under clauses (b) and (c) of Section 80-

HHC(3) of the Act. In case the gross total

income is reduced or modified taking into

account the deduction allowed under Section

80-IA, it would lead to absurd and unintended

consequences. It would render the formula

under sub-section (3) of Section 80-HHC

ineffective and unworkable as highlighted in

para 30 of the decision in Associated Capsules

(P) Ltd. [Associated Capsules (P) Ltd. v. CIT,

2011 SCC OnLine Bom 27 : (2011) 332 ITR 42

(Bom)] with reference to clause (b) of Section

Civil Appeal No.14318 of 2015 etc. Page 18 of 20

80-HHC(3). Even when I apply clause (a) and

calculate eligible deduction under Section 80-

HHC, it would give an odd and anomalous

figure. To illustrate, I would like to expound on

the earlier example after recording that the

gross total income of Rs 1000 was on assumed

total turnover of Rs 10,000 which includes

export turnover of Rs 5000 and the deduction

allowable under Section 80-IA was 30% and

the deduction allowable under Section 80-

HHC was 80% of the eligible profits as

computed under Section 80-HHC(3). The

stand of the Revenue is that without alteration

or modification of the figures of total turnover

and the export turnover, the gross total

income would undergo a reduction from Rs

1000 to Rs 700 as Rs 300 has been allowed as

a deduction under Section 80-IA. This would

result in anomaly for the said figure would not

be the actual and true figure or the true gross

total income or profit earned on the total

turnover including export turnover and,

therefore, would give a somewhat unusual and

unacceptable result. There is no logic or

rationale for making the calculation in the

said impracticable and unintelligible manner.”

24.In view of what we have held above, we find that the

interpretation made by the Bombay High Court in the case of

Associated Capsules (P) Ltd. v. Deputy Commissioner of

Income Tax and Anr

4

appears to be logical and correct.

Civil Appeal No.14318 of 2015 etc. Page 19 of 20

25.We accordingly, answer the reference and direct the

Registry to place the appeals/petitions before appropriate

Bench.

……………………………..J.

(Abhay S. Oka)

……………………………..J.

(Ahsanuddin Amanullah)

..…….……………………..J.

(Augustine George Masih)

New Delhi;

May 20, 2025.

Civil Appeal No.14318 of 2015 etc. Page 20 of 20