AI Insights
The case involves Shree B. R. Steels, a proprietorship concern, which filed three writ petitions against the Additional Commissioner of Commercial Tax, Raipur, challenging the re-assessment orders under the Entry Tax Act, 1976. The petitioner was initially not subjected to entry tax for purchases of M.S. steel scrap from BALCO, as these were considered tax-paid purchases. However, subsequent re-assessments treated these purchases as local goods, liable for entry tax, leading to the imposition of tax and penalties for the assessment years 2000-2001, 2001-2002, and 2002-2003. The petitioner contested these re-assessments, arguing that the steel scrap was not a manufactured product and thus not liable for entry tax. The court examined whether the re-assessment was validly based on a change of opinion or if it constituted an illegal reopening of the assessment.
Appeal Details
Counselvise Citation
[2014] 140 COUNSELVISE.COM (IT) 742609 (HC-CHHATTISGARH)
Assessee PAN
Bench
Appeal Number
CRN Number
Appellant
Respondent
Appeal Type
Others
Pronouncement Date
05-06-2014
Assessment Year
misc
Judgement Text
"•jnasejig^e 4JBOS!uei|!AfiueA xei leiojaaiLUOo ^o J9UOISSILULU03 |euo!}ippv (l.) / / siuepuo^sey snsieA ('O'O) leiiqg (tseg) JEBBN njq9N /f/ -ON ssnoH jo luspisaj sjesA ot^ inoqe psBy uier fejLjpog sye~[ o/s uiep Aasfues jotsudojd q6nojqi ujeouoo di^sjoiaudojd B ('O'O) !B|!L|g '^fMoqo lUEMeqqo Bu!p|ing JE^BQ a}isoddo eaje |eu}snpu| iqBi-i Ot'l. '8 9 t^l. •ON toid sissts 'y'a ssj4S .0<. •\"'r^ ^..^ ...(^&^- ,...--'^.^ '.--^ ^^y^ '..^' ;s 3> Sf^-' Jauojiiied 900Z AO^^I^ -ON (1) uo!»i»ad^UM undsviia ±v •HUVOIS±±VHHO 3un±v3ianrjo ±unooHOIH 3H±NI s^\" ;r;1 •^ &^ ^ Petition under Articles 226/227 of the Constitution of India forLJssyance ofsyitabje^directions^rders orwritsincludina writs in the nature of mandamus certiorari etc. i . ^ t- y HIGH COURT OF CHHATTISGARH : BILASPUR (Single Bench: Hon'ble Shri Manindra Mohan Shrivastava, J.l WRIT PETITION(T)N0.4775 of 2006 PETITIONER RESPONDENTS Shree B. R. Steels Versus Additional Corainissioner of Commercial Tax, Raipur and others WRIT PETITION(T)N0.5448 of 2006 PETITIONER RESPONDENTS Shree B. R. Steels Versus Additional Comniissioner of Commercial Tax, Raipur and ofhers WRIT PETITION(T)N0.5449 of 2006 PETITIONER RESPONDENTS Shree B. R. Steels Versus Additional Commissioner of Commercial Tax, Raipur and others Writ Petitiott under Artlcle 226/227 ofthe Constitution oflndja FOR PRONOUNCMENT OF ORDER ON5^UNE.2014 Sd/- Manindra Mohan Shrivastava Judge f^3!ifi. ^?i, f. i :Y;^S&^^\" , 'f- ^&^y HIGH COURT OF CHHAmSGARH : BILASPUR WMT PETITION(T)N0.4775 of 2006 PETITIONER RESPONDENTS Shree B. R. Steels Versus Additional Commissioner of Commercial Tax, Raipur and others WRIT PETITION(T)N0.5448 of 2006 PETITIONER RESPONDENTS Shree B. R. Steels Versus Additional Commissioner of Commercial Tax, Raipur and others WRIT PETITION(T)N0.5449 of 2006 PETITIONER RESPONDENTS Shree B. R. Steels Versus Additional Commissioner of Commercial Tax, Raipur and others Writ Petition under Article 226/227 ofthe Constitution oflndia (Sinele Bench: ilon'ble ShrLManindra Mphan Shnvastava, J.) Present:- \"Shri Neelabh Dubey, counsel for the respective petitioner. Shri Sumesh Bajaj, Government Advocate for the State. ORDER (Pronounced on this ^?-\"Uay ofJune, 2014) This common order shall govern disposal of Writ Petition (T) Nos.4775, 5448 & 5449 of 2006 involving identical issues based on similar facts for consideration between the same parties in respect of different assessment years. The petitioner in these three writ petitions, a proprietorship concern registered with the Commercial Tax Department, has filed three writ petitions aggrieved by the 53 orders, by which, he has been re-assessed to tax under the provisions of Entry Tax Act, 1976 (hereinafter referred to as \"the Act\"). 2. In all the three writ petitions, the petitioner is aggrieved by order of re-assessment passed on different dates in respect of assessment years 2001-2002, 2002-2003 and 2003-2004. In all the cases, initially, at the time of assessment, fhe petitioner was not subjected to any entry tax in respect of purchase of M.S. iron and r\"' \"'• - _ - .--_.' steel scrap from Bharat Aluminiura Company (In short \"BALCO\")- respondent No.4. Later on, in all three cases, re-assessment notice purporting to be under Section 28(1) of the Conirnercial Tax Act, 1994 (In short \"the Act of 1994\") read with Section 13 of the Act was issued and re-assessment proceedings were drawn. I. In W.P.(T)No.4775 .of 2006, re-assessment order was passed on 16-01-2006 for the period 01-04-2000 to 31-03-2001 by the Assistant Commissioner, Commercial Tax, Durg. A revision was preferred by the writ petitioner before the Additional Commissioner, Commercial Tax, which was dismissed on 29-05-2006. II. In W.P.(T)No.5449 of 2006, re-assessment order was passed on 16-01-2006 for the period 01-04-2001 to 31-03-2002 by the Assistant Commissioner, Commercial Tax, Durg. A revision was preferred by the writ petitioner before fhe Additional Commissioner, Commercial Tax, which was dismissed on 29-05-2006. III. In W.P.(T)No.5448 of 2006, re-assessment order was passed on 13-01-2006 for the period 01-04-2002 to 31-03-2003 by the .^^••3'\"~s^? -,/f^s's^f%. f 1 g. \"3t^, 11 ^ &. y / .yf=:y^f Assistant Commissioner, Commercial Tax, Durg. A revision was preferred by the writ petitioner before the Additional Commissioner, Conimercial Tax, which was dismissed on 29-05-2006. 3. The petitioner during different period as indicated hereinabove had purchased M. S. steel scrap from BALCO, Korba and claimed it as tax paid purchases made from registered dealer. On such purchases, no tax was claimed to be payable by the petitioner and assessment was initially made treating those purchases as tax paid and no tax was levied. This was so because at the time of origmal assessment made, the respondents did not impose tax in the inatter of purchase of M. S. steel scrap frora seller i.e. BALCO, who did not make any endorsement in the sale invoices that they were local goods and not tax paid. However, later on, in each of the fhree cases, the respondent authorities issued notices under Section 28(1) of the Act of 1994 in Form-47. Petitioner filed his reply in response to re-assessment notice in each case. In sum and substance, the reply ofthe petitioner was that the notices were vague and there was no indication in the notices as to on what basis, re-assessment proceedings were being initiated. There was no indication in the notice that assessnient had been opened either because there was under assessraent or it was a case of escapement or concealment or whether goods were now being treated as local goods in the hands of BALCO.The petitioner, in its objection/reply to re-assessment notice stated that at the tune of origuial assessment proceedings, all invoices made from BALCO 62- were reflected in the retums and also in the statement during assessment, on which basis, assessment was made. The petitioner presumed that the assessing authority has initiated re-assessment proceeduigs on change of opinion that the petitioner was liable for payment of entiy tax in respect of purchases of M. S. steel scrap made by it from. BALCO. The petitioner also objected to proposed penalty by stating that as the seller-BALCO had not made any endorsement in the invoices that the M. S. steel scrap purchased by fhe petitioner are local goods and are not tax paid, the omission is not attributable to the petitioner, as such, no entiy tax on goods is leviable. 4. The assessing authority, however vide order dated 16-01-2006, 16-01-2006 and 13-01-2006 passed in re-assessment for three different assessment years held that the M. S. steel scrap piu-chased by the petitioner were wrongly indicated as tax paid though in respect of such purchases, the petitioner was liable to pay entry tax, and therefore, such purchases had escaped assessment for the purpose of leyy of entry tax. In the re- assessment proceedings drawn by the respondents in the aforesaid three different assessment years, entry tax and penalty was levied on the petitioner as follows:- I. For assessment year 2000-2001, entry tax of Rs.22,820/- as also penalty of Rs.22,820/- were levied. II. For assessment year 2001-2002, entry tax of Rs.1,61,385/- as also penalty ofRs.l,61.385/- were levied. ^^\"\"^''\"'''''^^. f &. I - li'^ '%.Kk.^ III. For assessment year 2002-2003, entry tax of Rs.5,34,652/- as also penalty of Rs.5,29,549/- were levied. Revisions preferred in each of the cases were dismissed by the Additional Commissioner, Commercial Tax, Raipur giving rise to these three writ petitions involving identical issue for consideration. 5. Leamed counsel for the petitioner contended that the petitioner purchased M. S. Steel scrap from BALCO. The BALCO purchased plant and machinery and building structural and when caused entry of those items into local limits, the entry tax was paid by the BALCO on plant and machinery and building structural. The steel scrap were generated during the course of repair and maintenance/dism.antling of structural, plant and machinery/civil structural. The scrap so generated can neither be said to be generated by manufacturing process nor can be said to be purchase of goods as specified in Schedule II m a local area so as to qualify as local goods ih relation to local area and liable for levy of entry tax. The scrap is not a manufactured product out of the goods which have been purchased. It is only a scrap. Therefore, the BALCO while selling those M. S. Steel scrap rightly did not make any endorsement in the invoices/bills that they are local goods and not tax paid under fhe provisions of Section 7(1) of the Act. These invoices did not contain any such endorsement as required under Section 7(1) of the Act, which clearly meant that the BALCO had sold and the petitioner purchased M. S. Steel scrap, which were already tax paid by the BALCO. As such, there was no liability on the part of the petitioner to again make payment of entry tax while purchasing those items from BALCO. Initially, at the time of making original assessment When retums were submitted before the assessing authority, despite specific details submitted which included the quantity and the nature of itera purchased by the petitioner from BALCO and all fhe invoices open to scrutiny by the assessing authority which did not contain any specification as it being local goods not tax paid, the assessing authority did not hold that such purchase of M. S. Steelscrap were local goods by treating it to be a new commercial commodity out of any process of manufacturing. But later on, the aufhorities changed fheir opinion that the M. S. Steel scrap purchased by the petitioner from BALCO were local goods different from iron and steel purchased by BALCO and brought into local area. According to him, the power conferred on the assessing authority to carry out re-assessment under Section 28(1) of the Act of 1994 read with Section 13 of the Act did not empower fhe assessing authority to open assessment on change of opinion. He further submits that the present one is not a case where purchase of M. S. Steel scrap has been either under assessed or escaped assessment or assessed at lower rate or deduction has been wrongly made from their account. In the absence of any such contingencies, re-assessment was not permissible under the law only because fhere is a change of opinion. In support of his submission, leamed counsel for the petitioner relied upon decisions in the case of Sales Tax Offlcer, ^ Ganjain, and another vs. Uttareswari Rice Mills, (1972) 30 STC 567, C. Sathirdju and Sons v. State of Andhra Pradesh, (1998) 111 STC 703, Suburban Industrles Kalinga Private Umited and another v. Sales Tax Officer, Bhubaneswar and another, (1993) 90 STC 280, State of Andhra Pradesh vs. Ampro Food Products Limited, (1995) 96 STC 617 and Madhya Pradesh Industries Ltd. vs. Income Tcuc Officer, Special Investigation Circle 'B' Nagpur, (1965) 57 ITR 637. 6. Learned counsel for the petitioner furfher argued that in any case in view of the authoritative pronouncement of the Supreme Court ih the case of Grasim. Industries Liniited vs. Union of Jndia, J.T. (12) SC 89, metal scrap generated during the process of repair and maintenance of the machinery of a manufacturing plant, cannot be said to be a by-product as a result of manufacturing activity in relation to production of any product. He . further submits that in the case of M.P. Traders and Agents, Indore vs. Commissioner of Sales Tcix, (1996) 23 Cur.T.J. 320, the Division Bench of High Court of Madhya Pradesh has clearly held that the scrap is not a product under any manufacturing process out of the goods, which have been purchased. It does not involve process of manufacturing. The scrap is like a waste product and not materially different from the basic goods which had been used by the BALCO. Therefore, under these circumstances, the orders of re-assessment passed by the assessing officer and ^ confirmation of such re-assessment order by the revisional authority are illegal and unsustainable in law. 7. Per contra, learned State counsel submits that the present is not a case of change of opinion but a case where purchase of steel scrap escaped assessraent on entry tax and it was because factually incorrect mformation was placed before the assessing authority at the time of original assessment that entry tax has already been paid whereas no such tax was paid. Learned State counsel submits that though at the time of purchasing plant and machinery and other items and causing its entry in the local area, BALCO pays entry tax, the steel scrap which are generated are different from those items purchased and brought to the local area by the BALCO. The steel scrap are generated during the process of manufacturing and have different identity than the plant and machinery and building structural, therefore, they are local goods , inanufactured by BALCO and at the time of sale of such M. S. Steel scrape by BALCO to the petitioner, the sale invoices ought to contain the endorsement as \"local goods tax not paid as required under Section 7(1) of the Act. The invoices did not contain any such endorsement and it was incorrectly stated before the assessing authority that the.goods are tax paid. On this factually incorrect information made before the assessing officer, entiy tax in respect of purchase of metal scrap was not levied by the assessing authority. Later on, it came to the notice and knowledge of the assessing authority that the M.S. steel scrap are different commercial cominodity produced during the process of manufacture; such raetaJ scrap are different items. Therefore, re- assessment notice under Section 28 was given to the petitioner and the re-assessment of those raetal scrap piirchased have been held in respect of local goods, and therefore, the petitioner was rightly held Uable for payment of entry tax in respect of purchase of such M. S. Steel scrap. Learned State coiinsel relying upon the order passed by the Board of Revenue, M. P. Gwalior in the case of Raj Enterprises Fastners Pvt. Ltd., Indore vs. Coinmissioner of Commerciat Tax., Madhya Pradesh, (1999) 32 VKN 155 submits that metal scrap are by product and fall under a different category and they cannot be treated as tax paid. Leamed State counsel relied upon the judgment of the Supreme Court in the case of State of Tamil Nadu v. Pya.re lal Malhotra, (1976) 37 S.T.C. (S.C.) 319, in which, the Supreme Court held that M. S. steel scrap ;, _ are generated out of manufacturing process and are different and distinct, and therefore, the aufhority rightly opened the assessment in exercise of power under Section 28(1) of the Act of 1994 and levied entry tax in respect of M. S. steel scrap purchased by the petitioner from the BALCO which earlier had escaped assessment on incorrect factual information that the goods were tax paid. 8. It is not in dispute that the petitioner during three assessment years purchased M. S. Steel scrap from BALCO. The orders passed by the Assessing authority at the first instance in three cases and placed on record also show that initiaUy when the 15. 10 assessraent was made, the return submitted by the petitioner included details with regard to nature and quantity of items piirchased by the petitioner during relevant assessment years. The details of invoices issued by fhe BALCO admittedly did not contain any endorsement of such sold items being local goods tax not paid under the provisions of Section 7(1) of the Act. The petitioner purchased M. S. steel scrap from the BALCO. The BALCO while selling those M. S. steel scrap, the petitioner did not declare the M. S. steel scrap as local goods and for this reason, no endorsement as required under Section 7(1) ofthe Actwas made. 9. Under Chhattisgarh Entry Tax Act, 1976, entry tax is leviable on the entry of goods in the local area for the consumption, use or sale therein. Section 3 of the Act deals with incidence of taxation. Entry tax is leviable on the entry in the course of business of a dealer of goods specified in Schedule II into local area for consumption, use and sale fherein. Such tax is liable to be paid by every dealer liable to tax under the Sales Tax Act who has effected entry of such goods. Sub section (l)(b)(i) of Section 3 of the Act however provides that no tax under sub section (1) shall be levied in respect of goods specified in Schedule II other than local goods purchased from a registered dealer on which entry tax is payable or paid by the registered dealer. 10. Section 7 of the Act provides that every registered dealer who, in the course of his business, manufactures, produces or grows any goods speciiled in Schedule II in a local area and sells such local ^-••\"'\"\" ^^^ ff'' s\"f--A.^ fCY^ I ^v 1 fi '\"S f! \"•*•> '^SiSK'^'S1^^''' r goods to any of the registered dealer, the sale documents shall mention that such goods are local goods and no enfay tax has been paid on them. 11. The statutoiy scheme upon conjoint reading of Section 3/7 of the Act reveals that the incidence of taxation is not sale and purchase but fhe entry of goods into local area and the tax is to be paid by the dealer who has effected entry of goods. It is only when a dealer who has effected entry of goods and paid entry tax and then in the course of his business, manufactures, produces or grows any goods specified in Schedule II in fhat local area and while effecting sale of such goods endorses in the sale document that such goods are local goods and no entry tax has been paid on them that the piirchaser is liable for payment of entiy tax on such localgoods. 12. In the present case, the BALCO while effecting entry of plant and machinery and building sfa-uctural into the local area paid entiy tax and this is the factual position which has not been disputed by any of the parties before the Court. Once those iron and steel items have been subjected to entry tax, the steel scrap which are being generated out of repair and maintenance of those plant and machinery and building structural, in the absence of any endorseraent niade in the sale document by the seUer-BALCO, would not create .any liability for payment of entry tax by its purchaser i.e. the petitioner. Present is not a case where fhe BALCO has treated or declared M. S. steel scrap manufactured by ^p 12 it being goods specified in Schedule II in a local area and endorsement to that effect in the sale document that they are local goods but not tax paid. In the absence of any such declaration by BALCO, there was no liability cast on the petitioner under Section 3 of the Act to pay entry tax in respect of purchases of M. S. steel scrap made by it from BALCO. 13. When fhe petitioner submitted its retum in respect of different assessment year before the assessmg officer, as the original order of assessment goes to show, fhe petitioner declared the nature and quantity of material purchased by it. The bill invoices issued by the BALCO during transaction of sale and purchase of M. S. steel scrap, did not contain any endorsement that they are local goods not tax paid so as to require the petitioner to pay entry tax. Therefore, the petitioner in his submission before the authority at the time of assessment rightly subinitted that the goods were tax paid. It was the burden of the Revenue, as held in the case of Mohan Singh and Sons vs. Commissioner of Sales Tax, Madhya Pradesh, (1996) 29 VKN 243 that such goods are local goods. However, the assessing authority during the course of original assessnient, despite all such details subinitted before it, did not form any opinion that the M. S. steel scrap which were purchased by the petitioner from BALCO were different items manufactured by BALCO within the local area and thus, the local goods within the meaning of its definition as provided in Clause (f) of Sectibn 2 of the Act. Obviously at the time of assessment, the ^t 13 opinion formed by the authority was that the M. S. steel scrap purchased by the petitioner were not local goods as they are not different than the items namely plant and machinery and building structural which were brought into the local area by the BALCO and already tax paid. 14. However, later on, the assessing authority changed its opinion, which is reflected from the unpugned orders of re- held that M. S. steel scrap are different products and qualified as local goods manufactured by BALCO. On this ehange of opinion, the assessing authority in the re-assessment proceedings proceeded to leyy entry tax as also penalty on the petitioner. Re- assessment was also affirmed by the revisional authority. 15. Once on facts, it is held that the basis for re-assessment is t change of opinion, it has to be held that such re-assessinent is unpermissible under the law, in view of the weU settled legal position laid down in the case of Sales Tcix Officer, Ganjam and another (supra), while examining ambit and scope of re- assessment under,Section 12(8) of the Orissa Sales Tax Act, which is pari materia provisions contained in Section 28(1) of the Act of 1994. It was held that existence of a reason that the turn over of dealer escaped assessment or has been under assessed is a condition precedent to issuance of notice of re-assessment under 1 ^''^J 1 1 '\"5%1 1 %y^-^.^/ ^' ^.^*\" 14 r Section 12(8) of the Act and the existence of such reason is sine qua non for the issuance of notice. In the case of Ritu Investments Private Liinited vs. Deputy Coinmissioner of Income Tax, dealing with the power of re- assessment of assessing authority under Section 147 of the Income Tax Act, it has been held that change of opinion cannot clothe the assessing officer with the jurisdiction to initiate the proceeding under Section 147 of the Act. It has been further held that an error of judgment does not confer such a jurisdiction on the assessing officer. Dealing with the provisions contained in Section 19 of fhe Madhya Pradesh General Sales Tax Act, 1958, which is pari materia of Section 28(1) ofAct of 1994 involved in the present case. Having application in the present case, the High Court of Madhya Pradesh in the case of Bisher SSotors Ltd. and Anr. Vs. State of M.P. and Others, , 2005(1) M.P.L.J. 408 has held that change of opinion cannot be made a basis to cariy out re-assessment in the garb that the tum over has escaped assessment. The Orissa High Court in the case of Naba Bharat Ferro Alloys Ltd. and Anr. Vs. State of Orissa and Ors., 2010(1) OLR 976 has also held that change of opinion could not be made a basis to make re- assessment. The Hon'ble Supreme Court in the case of Commissioner of Income Tax v. Kelvinator oflndia Ltd., (2010) 320 ITR 561 (SC) examining ambit and scope of power of re-assessment under Section 147 in respect ofincome escaping assessment held thus: 15 ^ \"On going through the changes, quoted above, made to Section 147 of the Act, we find that, prior to Direct Tax Laws (Amendment) Act, 1987, re-opening could be done under above two conditions and fulfillment of the said conditions alone conferred jurisdiction on the Assessing Officer to make a back assessment, but in section 147 of the Act [with effect from 1st April, 1989], they are given a go-by and only one condition has reinained, viz., that where the Assessing Officer has reason to believe that income has escaped assessment, confers jurisdiction to re- open the assessment. Therefore, post-lst April, 1989, power to re-open is much wider. However, one needs to give a schemadc interpretation to the words \"reason to believe\" failing which, we are afraid, Section 147 would give arbitrary powers to the Assessing Officer to re-open assessments on the basis of \"mere change of opinion\", which cannot be per se reason to re-open. We must also keep in mind the conceptual difference between power to review and power to re-assess. The Assessing Officer has no power to review; he has the power to re-assess. But re- assessment has to be based on fulfillment of certain pre- condition and if the concept of \"change of opinion\" is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of \"change of opinion\" as an in-built test to check abuse of power by the Assessing Officer.\" 16. In the facts of present case, re-assessment proceedings have been drawn by the assessing authority on the ground that the purchase has escaped assessnient, is clearly illegal and unsustainable in law in view of the authoritative pronouncement of ^ 16 the Supreme Court in the case of Comm.issioner of Income Tdx (supra). 17. Upon scrutiny of order passed by the assessing authority at the time of assessment and re-assessment in the facts and circumstances of the present case and having held in discussions hereinabove that the raain operative reason for re-assessment was change of opuiion rather than purchase of M. S. steel scrap by the petitioner from the BALCO having escaped assessment, applying well settled legal position laid down in plethora of decisions cited above, I am of the considered opinion that the re-assessment carried out by the assessing authority was impermissible under Section 28(1) of the Act of 1994. 18. For yet another reason, the order of re-assessment levying entry tax on purchase of M. S. steel scrap by the petitioner from BALCO by holding it to be local goods manufactured out of any manufacturing process and being by-product different from plant and machinery and building structural has to be held illegal and unsustainable in law in View of the decision of the Supreme Court in the case of Grasint Indtistries Limited (supra). The issue requiring consideration was whether inetal scrap was waste generated while repairing of worn out machinery or parts of cement manufacturing plant and amounts to manufacture and thereby exigible to excise duty. The Supreme Court, after examining the nature of the process, out of which, M.S. scrap was generated held thus:- f. &.^ 1>
Other Referred Cases
Sales Tax Officer, Ganjam, and another vs. Uttareswari Rice Mills, C. Sathirdju and Sons v. State of Andhra Pradesh, Suburban Industries Kalinga Private Limited and another v. Sales Tax Officer, Bhubaneswar and another, State of Andhra Pradesh vs. Ampro Food Products Limited, Madhya Pradesh Industries Ltd. vs. Income Tax Officer, Special Investigation Circle 'B' Nagpur, Grasim Industries Limited vs. Union of India, M.P. Traders and Agents, Indore vs. Commissioner of Sales Tax, Raj Enterprises Fastners Pvt. Ltd., Indore vs. Commissioner of Commercial Tax, Madhya Pradesh, State of Tamil Nadu v. Pyare lal Malhotra, Mohan Singh and Sons vs. Commissioner of Sales Tax, Madhya Pradesh, Bisher Motors Ltd. and Anr. Vs. State of M.P. and Others, Commissioner of Income Tax v. Kelvinator of India Ltd.
Laws Referred To
Chhattisgarh Entry Tax Act, 1976, Commercial Tax Act, 1994
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