AGNI STEELS PRIVATE LIMITED,ERODE V. COMMISSIONER OF INCOME TAX (APPEAL), DELHI

ITA 2297/CHNY/2024

AI Insights

Agni Steels Private Limited appealed against the order of the Learned Commissioner of Income Tax (Appeals), which had confirmed the re-computation of the claim of deduction under Section 80IA of the Income Tax Act, 1961. The primary contention was regarding the apportionment of directors' remuneration between the eligible unit (wind energy generation) and non-eligible units, which affected the deduction claim under Section 80IA. The Tribunal examined the methodology used for apportioning the directors' remuneration and found merit in the appellant's argument that the apportionment should be based on the turnover ratio of the eligible unit to the total turnover of the company.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 107024 (ITAT-CHENNAI)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-01-2025
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Assessment Year: 2020-2021
• Other Referred Cases: Rajasthan State Mines Ltd vs DCIT
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: S. SUNDAR RAJAN
• Assessee Lawyers: N. ARJUN RAJ
• Keywords: Principle of natural justice
• Section: 80IA

Judgement Text

"आयकर अपीलीय अिधकरण, ‘ए’ \u0001यायपीठ, चे\tई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI \u0001ीएबीटी. वक , \u000bाियकसद\u0011 एवं एवं एवं एवं \u0001ीमनोजक ुमारअ\u0019वाल, लेखासद\u0007क ेसम\u001d BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRIMANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No. 2297/Chny/2024 िनधा\u000bरणवष\u000b/Assessment Year: 2020-21 Agni Steels Private Limited, No.58/1, Avvaiyar Street, Teachers Colony, Erode – 638 011. v. DCIT, Circle-1, Erode. [PAN:AABCA7819F] (अपीलाथ\u000e/Appellant) (\u000f\u0010यथ\u000e/Respondent) अपीलाथ\u000e क\u0012 ओर से/ Appellant by : Mr. N. Arjun Raj, Advocate \u000f\u0010यथ\u000e क\u0012 ओर से /Respondent by : Mr. S. SundarRajan, JCIT सुनवाईक\u0012तारीख/Date of Hearing : 01.01.2025 घोषणाक\u0012तारीख /Date of Pronouncement : 31.01.2025 आदेश / O R D E R PER ABY T. VARKEY, JM: This is an appeal preferred by the assessee private limited company against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter in short \"the Ld.CIT(A)”), Delhi, dated 05.07.2024 for the Assessment Year (hereinafter in short \"AY”) 2020-21. 2. The revised grounds of appeal raised by the assessee is as under: 1. The order of the NFAC, Delhi dated 05.07.2024 vide DIN ITBA/NFAC/S/250/2024 Assessment Year is contrary to law, fact and in circumstances of the case. 2. The NF AC, Delhi erred in confirming the apportionment of directors' remuneration between the eligible an company and consequently erred in confirming the re claim of deduction under Section 80IA of the Act being the eligible unit in the computation of taxable total income without assigning proper reason justification. 3. The NFAC, Delhi failed to appreciate that the claim of deduction under Section 801A of the Act was correct on all facets, including the charging of claim of expenditure incurred, more precisely remuneration paid to its directors, more fully reflected in the ROI filed, thereby vitiating the disputed addition made in its entirety and further ought to have appreciated that the methodology adopted by the Assessing Officer for allocating the disputed expenses is not sustainable both on f 4. The NFAC, Delhi failed to appreciate that there was no effective/proper opportunity given before passing the impugned order as well as before passing the effect giving order including non granting of personal hearing and ought to have appreciated that any order passed in violation of the principles of natural justice is nullity in law. 5. The Appellant craves leave to file additional grounds/arguments at the time of hearing. 3. The sole issue is in respect of denial of claim of deduc of the Income Tax Act, 1961 (hereinafter in short ‘the Act’) to the tune of Rs.1,09,56,575/- by re the eligible unit (wind remuneration incurred durin 4. The brief facts are that the assessee private limited company engaged in the business of manufacture of steel and wind energy generation during the year under consideration Income (RoI) on 26.11.2020 Later, the RoI was selected for scrutiny and the AO noted that assessee ITA No. 2297/Chny/20 Agni Steels Private Limited :: 2 :: The order of the NFAC, Delhi dated 05.07.2024 vide DIN ITBA/NFAC/S/250/2024-25/1066453197(1) for the above mentioned Assessment Year is contrary to law, fact and in circumstances of the case. 2. The NF AC, Delhi erred in confirming the apportionment of directors' remuneration between the eligible and non eligible units of the appellant company and consequently erred in confirming the re-computation of the claim of deduction under Section 80IA of the Act being the eligible unit in the computation of taxable total income without assigning proper reason 3. The NFAC, Delhi failed to appreciate that the claim of deduction under Section 801A of the Act was correct on all facets, including the charging of claim of expenditure incurred, more precisely remuneration paid to its ore fully reflected in the ROI filed, thereby vitiating the disputed addition made in its entirety and further ought to have appreciated that the methodology adopted by the Assessing Officer for allocating the disputed expenses is not sustainable both on facts and in law. 4. The NFAC, Delhi failed to appreciate that there was no effective/proper opportunity given before passing the impugned order as well as before passing the effect giving order including non granting of personal hearing and appreciated that any order passed in violation of the principles of natural justice is nullity in law. 5. The Appellant craves leave to file additional grounds/arguments at the time The sole issue is in respect of denial of claim of deduc of the Income Tax Act, 1961 (hereinafter in short ‘the Act’) to the tune of re-quantifying the expenses incurred in rela the eligible unit (wind-mill) due to allocation of the director remuneration incurred during the assessment year under consideration. brief facts are that the assessee private limited company engaged in the business of manufacture of steel and wind energy generation during the year under consideration and filed its Return of Income (RoI) on 26.11.2020 at a total income of Rs.11,94,00,690/ the RoI was selected for scrutiny and the AO noted that assessee /Chny/2024 (AY 2020-21) Agni Steels Private Limited The order of the NFAC, Delhi dated 05.07.2024 vide DIN &Order No. 25/1066453197(1) for the above mentioned Assessment Year is contrary to law, fact and in circumstances of the case. 2. The NF AC, Delhi erred in confirming the apportionment of directors' d non eligible units of the appellant computation of the claim of deduction under Section 80IA of the Act being the eligible unit in the computation of taxable total income without assigning proper reasons and 3. The NFAC, Delhi failed to appreciate that the claim of deduction under Section 801A of the Act was correct on all facets, including the charging of claim of expenditure incurred, more precisely remuneration paid to its ore fully reflected in the ROI filed, thereby vitiating the disputed addition made in its entirety and further ought to have appreciated that the methodology adopted by the Assessing Officer for allocating the disputed 4. The NFAC, Delhi failed to appreciate that there was no effective/proper opportunity given before passing the impugned order as well as before passing the effect giving order including non granting of personal hearing and appreciated that any order passed in violation of the principles 5. The Appellant craves leave to file additional grounds/arguments at the time The sole issue is in respect of denial of claim of deduction u/s. 80IA of the Income Tax Act, 1961 (hereinafter in short ‘the Act’) to the tune of quantifying the expenses incurred in relation to llocation of the director’s g the assessment year under consideration. brief facts are that the assessee private limited company is engaged in the business of manufacture of steel and wind energy filed its Return of at a total income of Rs.11,94,00,690/-. the RoI was selected for scrutiny and the AO noted that assessee company had paid director nothing to eligible unit for which the deduction has been claimed u/s. 80IA of the Act. The AO 142(1) of the Act which was replied to by the assessee dated 30.08.2022 (refer e-proceedings response wherein the assessee brought to the notice of the AO that the income realized on power generation was to the tune of Rs.2,23,45,392/ assessee claimed direct expenses incurred in respect of wind mill to the tune of Rs.1,04,13,697/ Nature of expenditure Insurance paid on Windmill Unit Operation and Maintenance charges Interest on term loan Windmill TNEB Expenses And thus claimed deduction u/s. Rs.1,19,31,695/- from the eligible unit i.e. wind Rs.2,23,45,392/- minus satisfied was of the view that the salary of director was paid for operations of the company which includes business of the wind mill/eligible unit also; and according to him ITA No. 2297/Chny/20 Agni Steels Private Limited :: 3 :: company had paid director’s fee of Rs.12,30,00,000/- but has apportioned it for which the deduction has been claimed u/s. O issued show cause notice dated 26.08.2022 u/s. 142(1) of the Act which was replied to by the assessee dated 30.08.2022 response acknowledgment page 34 & 35 od PB wherein the assessee brought to the notice of the AO that the income realized on power generation was to the tune of Rs.2,23,45,392/ assessee claimed direct expenses incurred in respect of wind mill to the tune of Rs.1,04,13,697/- as under: ure of expenditure Amount in Rs. Remarks Insurance paid on Windmill 2,91,220/- Specifically expended for insuring the eligible unit Operation and 22,21,412/- Specifically spent on the eligible unit alone 60,59,042/- Interest on the loan borrowed specifically for the purpose of purchasing the eligible unit. Windmill TNEB Expenses 18,42,023/- Specifically expended for the electricity units generated out of the eligible unit claimed deduction u/s. 80IA of the Act to the tune of rom the eligible unit i.e. wind minus Rs.1,04,13,697/-). However, the AO being not satisfied was of the view that the salary of director was paid for ompany which includes business of the wind and according to him, salary paid to the director is /Chny/2024 (AY 2020-21) Agni Steels Private Limited but has apportioned it for which the deduction has been claimed u/s. issued show cause notice dated 26.08.2022 u/s. 142(1) of the Act which was replied to by the assessee dated 30.08.2022 page 34 & 35 od PB), wherein the assessee brought to the notice of the AO that the income realized on power generation was to the tune of Rs.2,23,45,392/- and the assessee claimed direct expenses incurred in respect of wind mill to the Specifically expended for insuring the eligible unit Specifically spent on the eligible unit alone Interest on the loan borrowed specifically for the of purchasing the Specifically expended for the electricity units generated out of the eligible 80IA of the Act to the tune of rom the eligible unit i.e. wind-mill (i.e. . However, the AO being not satisfied was of the view that the salary of director was paid for the whole ompany which includes business of the wind salary paid to the director is common expenditure of the company net profit as per provisions of section 80IA of the Act, the ass bound to consider the proportion of these common expenditure. Thereafter, he cited the decision of Jaipur Bench of this Tribunal in the case of Rajasthan State Mines Ltd vs DCIT considered the fact that the director of 91.83% of the gross total income for the year as salary, same percentage of deduction claimed u/s. 80IA of the Act amounting to Rs.1,09,56,575/- (91.83% of Rs.1,19,31,368/ of the Act and added back to the taxable income of the assessee. Thus, the deduction allowed u/s. 80IA of the Act was to the tune of Rs.9,74,793/- (i.e. Rs.1,19,31,695 the assessee preferred an appeal before the Ld.CIT(A) to uphold the same. Aggrieved by the aforesaid decision of the Ld.CIT(A), the assessee is before us and has raised the revised grounds of appeal which are reproduced (supra). 5. We have heard both the parties and perused the records. The assessee is a private limited company of manufacturing of steel and under consideration and had filed RoI declaring total income of Rs.11,94,00,690/-. The assessee had claimed de ITA No. 2297/Chny/20 Agni Steels Private Limited :: 4 :: common expenditure of the company; and consequently, while calculating net profit as per provisions of section 80IA of the Act, the ass bound to consider the proportion of these common expenditure. Thereafter, he cited the decision of Jaipur Bench of this Tribunal in the asthan State Mines Ltd vs DCIT in ITA No. 704/JP/2018, considered the fact that the director of the assessee company received 91.83% of the gross total income for the year as salary, same percentage of deduction claimed u/s. 80IA of the Act amounting to (91.83% of Rs.1,19,31,368/-) was disallowed u/s. 80IA and added back to the taxable income of the assessee. Thus, allowed u/s. 80IA of the Act was to the tune of (i.e. Rs.1,19,31,695 minus Rs.1,09,56,575/ the assessee preferred an appeal before the Ld.CIT(A) who was pleased to uphold the same. Aggrieved by the aforesaid decision of the Ld.CIT(A), the assessee is before us and has raised the revised grounds of appeal which are reproduced (supra). We have heard both the parties and perused the records. The assessee is a private limited company, which is engaged in the business of manufacturing of steel and generation of wind energy during the year under consideration and had filed RoI declaring total income of . The assessee had claimed deduction u/s. 80IA of the /Chny/2024 (AY 2020-21) Agni Steels Private Limited while calculating net profit as per provisions of section 80IA of the Act, the assessee is bound to consider the proportion of these common expenditure. Thereafter, he cited the decision of Jaipur Bench of this Tribunal in the in ITA No. 704/JP/2018, and the assessee company received 91.83% of the gross total income for the year as salary, therefore, the same percentage of deduction claimed u/s. 80IA of the Act amounting to ) was disallowed u/s. 80IA and added back to the taxable income of the assessee. Thus, allowed u/s. 80IA of the Act was to the tune of Rs.1,09,56,575/-). Aggrieved, who was pleased to uphold the same. Aggrieved by the aforesaid decision of the Ld.CIT(A), the assessee is before us and has raised the revised grounds We have heard both the parties and perused the records. The which is engaged in the business wind energy during the year under consideration and had filed RoI declaring total income of duction u/s. 80IA of the Act in respect of its wind mill/eligible unit to the tune of Rs.1,19,31,695/ During the assessment proceedings, in response to the query raised by the AO the assessee brought to generation was to the tune of Rs.2,23,45,392/ specifically allocated the expenses to the tune of Rs.1,04,13,697/ (details of which is given supra in the chart) u/s. 80IA to the tune of Rs.1,19,31,695/ that the director of the assessee company has shown to have been paid salary of Rs.12.30 crores was of the opinion that assessee has not apportioned anything of the salary given deduction has been claimed deduction claimed u/s. 80IA observing “considering the fact that the director of the company received 91.83% of the gross total income for the year as salary, same percent of deduction claimed u/s. 80IA of the Act amounting to Rs.1,09,56,575/ (i.e. 91.83% of Rs.1,19,31,368/ added back to the taxable income of the assessee” Ld.CIT(A) has upheld the same. However, impugned action of the Ld.CIT(A)/AO for various reasons. First of all, we do not understand how the AO has reduced the deduction claimed by the assessee from Rs.1,19,31,368/ Rs.1,09,56,575/-). The only reason for the AO to reduce the deduction is ITA No. 2297/Chny/20 Agni Steels Private Limited :: 5 :: its wind mill/eligible unit to the tune of Rs.1,19,31,695/ During the assessment proceedings, in response to the query raised by the AO the assessee brought to his notice that income realized on power n was to the tune of Rs.2,23,45,392/- and the assessee has specifically allocated the expenses to the tune of Rs.1,04,13,697/ (details of which is given supra in the chart) and thus claimed deduction u/s. 80IA to the tune of Rs.1,19,31,695/-. The AO taking note of the fact that the director of the assessee company has shown to have been paid salary of Rs.12.30 crores was of the opinion that assessee has not anything of the salary given to eligible unit for which the has been claimed u/s. 80IA of the Act. Hence, he claimed u/s. 80IA and disallowed/added Rs.1,09,56,575/ considering the fact that the director of the company received 91.83% of the gross total income for the year as salary, same percent of deduction claimed u/s. 80IA of the Act amounting to Rs.1,09,56,575/ (i.e. 91.83% of Rs.1,19,31,368/-) is disallowed u/s. 80IA of the Act and added back to the taxable income of the assessee”. On appeal the Ld.CIT(A) has upheld the same. However, we do not countenance impugned action of the Ld.CIT(A)/AO for various reasons. First of all, we do not understand how the AO has reduced the deduction claimed by the assessee from Rs.1,19,31,368/- to Rs.9,74,793/- (Rs.1,19,31,368 minus ). The only reason for the AO to reduce the deduction is /Chny/2024 (AY 2020-21) Agni Steels Private Limited its wind mill/eligible unit to the tune of Rs.1,19,31,695/-. During the assessment proceedings, in response to the query raised by notice that income realized on power and the assessee has specifically allocated the expenses to the tune of Rs.1,04,13,697/- and thus claimed deduction ng note of the fact that the director of the assessee company has shown to have been paid salary of Rs.12.30 crores was of the opinion that assessee has not to eligible unit for which the . Hence, he reduced the and disallowed/added Rs.1,09,56,575/- by considering the fact that the director of the company received 91.83% of the gross total income for the year as salary, same percentage of deduction claimed u/s. 80IA of the Act amounting to Rs.1,09,56,575/- is disallowed u/s. 80IA of the Act and . On appeal the we do not countenance the impugned action of the Ld.CIT(A)/AO for various reasons. First of all, we do not understand how the AO has reduced the deduction claimed by the (Rs.1,19,31,368 minus ). The only reason for the AO to reduce the deduction is on account of the fact that the director of the assessee paid salary to the tune of Rs.12.30 crores. According to the AO, the director of the assessee company received 91.83% of the year as salary and therefore he disallowed 91.83% claimed u/s. 80IA of the Act i.e. Rs.1,19,31,368/ Rs.9,74,793/-. The said findings of the L factual inaccuracies and reduce the deduction claimed note that as per section 80IA of the Act, the expenses relatable to eligible business which are directly or computation of profit and gains of an eligible business. Therefore, assessee’s contention that the director of the assessee company didn’t had any role of supervision or op cannot be accepted, evidence/materials to presume so. In presumption is that the director of the assessee company is managing the affairs of its steel company as well as according to us, apportionment of salary of the director needs to be made and accordingly we find force in the alternative submission of the AR that the director’s salary/cost needs to be allocated in the ratio of turnover for the purpose of determining the eligible pr ITA No. 2297/Chny/20 Agni Steels Private Limited :: 6 :: on account of the fact that the director of the assessee company has been salary to the tune of Rs.12.30 crores. According to the AO, the director of the assessee company received 91.83% of the total income of the year as salary and therefore he disallowed 91.83% of the deduction claimed u/s. 80IA of the Act i.e. Rs.1,19,31,368/- and allowed only . The said findings of the Ld.CIT(A)/AO is riddled with inaccuracies and therefore Ld.CIT(A)/AO erred in their finding to reduce the deduction claimed u/s. 80IA of the Act. Having said so note that as per section 80IA of the Act, the expenses relatable to eligible which are directly or indirectly have to be consid computation of profit and gains of an eligible business. Therefore, assessee’s contention that the director of the assessee company didn’t had any role of supervision or operational control over the wind unless assessee is able to bring materials to presume so. In the absence of the same, the presumption is that the director of the assessee company is managing the pany as well as that of the wind-mill. apportionment of salary of the director needs to be made and accordingly we find force in the alternative submission of the AR that salary/cost needs to be allocated in the ratio of turnover for the purpose of determining the eligible profit u/s.80IA of the Act. The /Chny/2024 (AY 2020-21) Agni Steels Private Limited company has been salary to the tune of Rs.12.30 crores. According to the AO, the the total income of of the deduction and allowed only d.CIT(A)/AO is riddled with therefore Ld.CIT(A)/AO erred in their finding to u/s. 80IA of the Act. Having said so, we note that as per section 80IA of the Act, the expenses relatable to eligible indirectly have to be considered for computation of profit and gains of an eligible business. Therefore, the assessee’s contention that the director of the assessee company didn’t erational control over the wind-mill ee is able to bring relevant absence of the same, the presumption is that the director of the assessee company is managing the mill. Therefore, apportionment of salary of the director needs to be made and accordingly we find force in the alternative submission of the AR that salary/cost needs to be allocated in the ratio of turnover for ofit u/s.80IA of the Act. The assessee has filed a chart allocating the ratio of turnover for the purpose of determining the eligible profits of the S.No Particulars 1 Total turnover of the appellant 2 Total turnover of the eligible unit 3 Extent of eligible unit turnover 4 Disputed Director’s remuneration 5 Extent to be allocated to eligible unit turnover 6 Director’s remuneration to be allocated to eligible unit 7 Total claim of deduction u/s. 80 per return of income 8 Restricted claim of deduction u/s. 80 after the above allocation 9 Revised disputed addition as per alternate plea 6. In the light of the aforesaid discussion, we note that the total turnover of the assessee is more than Rs.538 crores and the turnover of the eligible unit/wind 0.41%. The director’s remuneration is ratio of the turnover for the purpose of determining the eligible profit will be Rs.5,10,124/-. In such claimed deduction u/s. 80IA of the Act to the tune of Rs.1,19,31,695/ we direct the AO to restrict the claim of deduction u/s. 80IA of the Act after the above apportionment minus Rs.5,10,124/-). Thus, the addition made by the AO is restricted to ITA No. 2297/Chny/20 Agni Steels Private Limited :: 7 :: assessee has filed a chart allocating the ratio of turnover for the purpose of determining the eligible profits of the wind mill as under: Total turnover of the appellant Rs.538,78,85,550/ turnover of the eligible unit Rs.2,23,45,392/ Extent of eligible unit turnover Disputed Director’s remuneration Rs.12,30,00,000/ Extent to be allocated to eligible unit Director’s remuneration to be allocated unit Rs.5,10,124/ Total claim of deduction u/s. 80-IA as per return of income Rs.1,19,31,695/ Restricted claim of deduction u/s. 80-IA after the above allocation Rs.1,14,21,571/ Revised disputed addition as per alternate plea Rs.5,10,124/ In the light of the aforesaid discussion, we note that the total turnover of the assessee is more than Rs.538 crores and the nover of the eligible unit/wind-mill is only Rs.2.23 crores, which is only 0.41%. The director’s remuneration is Rs.12.30 crores and the allocated of the turnover for the purpose of determining the eligible profit will . In such a factual scenario, even though assessee has claimed deduction u/s. 80IA of the Act to the tune of Rs.1,19,31,695/ we direct the AO to restrict the claim of deduction u/s. 80IA of the Act after the above apportionment to Rs.1,14,21,571/- (i.e. Rs.1,19,31,695/ . Thus, the addition made by the AO is restricted to /Chny/2024 (AY 2020-21) Agni Steels Private Limited assessee has filed a chart allocating the ratio of turnover for the purpose wind mill as under: Rs.538,78,85,550/- Rs.2,23,45,392/- 0.41% Rs.12,30,00,000/- 0.41% Rs.5,10,124/- Rs.1,19,31,695/- Rs.1,14,21,571/- Rs.5,10,124/- In the light of the aforesaid discussion, we note that the total turnover of the assessee is more than Rs.538 crores and the total mill is only Rs.2.23 crores, which is only Rs.12.30 crores and the allocated of the turnover for the purpose of determining the eligible profit will even though assessee has claimed deduction u/s. 80IA of the Act to the tune of Rs.1,19,31,695/-, we direct the AO to restrict the claim of deduction u/s. 80IA of the Act (i.e. Rs.1,19,31,695/- . Thus, the addition made by the AO is restricted to Rs.5,10,124/- and the assessee gets directed to be deleted. 7. In the result, appeal filed by the assessee Order pronounced on the Sd/- (मनोज क ुमार अ\u0019वाल (MANOJ KUMAR AGGARWAL लेखासद\u0007य/ACCOUNTANT MEMBER चे\u0003ई/Chennai, \u0005दनांक/Dated: 31st January, 2025 JPV, Sr.PS आदेशक\r\u000eितिलिपअ\u0014ेिषत/Copy to 1. अपीलाथ\u0014/Appellant 2. \u0015\u0016थ\u0014/Respondent 3. आयकरआयु\u001b/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय\u0015ितिनिध/DR 5. गाड\u000bफाईल/GF ITA No. 2297/Chny/20 Agni Steels Private Limited :: 8 :: and the assessee gets a relief of Rs.1,04,46,451/ In the result, appeal filed by the assessee is partly allowed Order pronounced on the 31st day of January, 2025, in Chennai. अ\u0019वाल) MANOJ KUMAR AGGARWAL) /ACCOUNTANT MEMBER Sd/ (एबी टी. (ABY T. VARKEY \tयाियकसद\u0007य/JUDICIAL MEMBER January, 2025. Copy to: Chennai / Madurai / Salem / Coimbatore. /Chny/2024 (AY 2020-21) Agni Steels Private Limited a relief of Rs.1,04,46,451/- which is partly allowed. , in Chennai. Sd/- . वक ) ABY T. VARKEY) /JUDICIAL MEMBER Chennai / Madurai / Salem / Coimbatore. "