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Hungerford Investment Trust Ltd. (In Liquidation) Vs. Income-tax Officer, Companies Dist. Iv and ors. - Court Judgment

LegalCrystal Citation
SubjectDirect Taxation
CourtKolkata High Court
Decided On
Case NumberAppeal No. 211 of 1972
Judge
Reported in[1984]146ITR73(Cal)
ActsIndian Income Tax Act, 1922 - Sections 30(1), 31(3) and 34(3)
AppellantHungerford Investment Trust Ltd. (In Liquidation)
Respondentincome-tax Officer, Companies Dist. Iv and ors.
Advocates:P.T. Sanyal, Adv.
Cases ReferredS.C. Prashar v. Vasantsen Dwarkadas
Excerpt:
- .....trust ltd., having its registered office at singapore, malaya, holds all the shares of m/s. turner morrison and co. ltd., a company incorporated in india. an order under section 23a, before its amendment in 1955, was passed by the ito in the case of m/s. turner morrison and co, ltd., and proceedings were taken under section 34 by the ito in order to tax the dividend deemed to have been declared u/s, 23a in favour of m/s. hungerford investment trust ltd., for the assessment years 1949-50, 1950-51 and 1951-52. the hungerford investment trust ltd. filed a return. it appears that the ito obtained approval of the commissioner on 24th march, 1954, and thereafter issued the notice under section 34 in the name of m/s. turner morrison and co. ltd., agents of m/s. hungerford investment.....
Judgment:

R.N. Pyne, J.

1. This appeal is directed against the judgment and order of P.K. Banerjee J. dated January 31, 1972, reported as Hunger-ford Investment Trust Ltd. v. ITO : [1976]102ITR314(Cal) , dismissing the appellant's application made under Article 226 of the Constitution challenging the notices under Section 34 and Section 23(2) of the Indian I.T. Act 1922, for the assessment years 1949-50, 1950-51 and 1951-52. The relevant facts of this case may briefly be stated :

The appellant, M/s. Hungerford Investment Trust Ltd., having its registered office at Singapore, Malaya, holds all the shares of M/s. Turner Morrison and Co. Ltd., a company incorporated in India. An order under Section 23A, before its amendment in 1955, was passed by the ITO in the case of M/s. Turner Morrison and Co, Ltd., and proceedings were taken under Section 34 by the ITO in order to tax the dividend deemed to have been declared u/s, 23A in favour of M/s. Hungerford Investment Trust Ltd., for the assessment years 1949-50, 1950-51 and 1951-52. The Hungerford Investment Trust Ltd. filed a return. It appears that the ITO obtained approval of the Commissioner on 24th March, 1954, and thereafter issued the notice under Section 34 in the name of M/s. Turner Morrison and Co. Ltd., agents of M/s. Hungerford Investment Trust Ltd., for the year 1949-50. Though the approval was made as aforesaid the notice under Section 34 was issued against Hungerford Investment Trust Ltd. Return was filed by Turner Morrison & Co. Ltd., as agents of Hungerford Investment Trust Ltd., and the status was shown as non-resident. For the year 1950-51 the notices were issued on Hungerford Investment Trust Ltd. for the income in respect of dividend deemed to have been declared under Section 23A ; similarly for 1951-52 also notice was served on Hungerford Investment Trust Ltd. M/s. Turner Morrison and Co. Ltd., as agents of the appellant, filed return mentioning the name of the assessee as M/s. Hungerford Investment Trust Ltd. and the address given was of Singapore. Thereafter, it appears, that the appellant was not finally assessed but M/s. Turner Morrison and Co. Ltd. was, however, assessed. The ITO assessed M/s. Turner Morrison and Co. Ltd. as agent of Hungerford Investment Trust Ltd. and taking the status as nonresident. Being aggrieved by the said assessment order M/s. Turner Morrison and Co. Ltd. preferred an appeal to the AAC who disposed of the same infavour of M/s. Turner Morrison and Co. Ltd. In so far as the assessments for the years 1949-50, 1950-51 and 1951-52, the AAC set aside the assessments against M/s. Turner Morrison and Co. Ltd. with the following observations and directions.

2. In view of the various reasons discussed above the assessment for 1949-50 made by the ITO on the resident company, M/s. Turner Morrison & Co. Ltd. as agents of the non-resident company, M/s. Hungerford Investment Trust Ltd., in order to tax the deemed dividend under Section 23A is set aside and the ITO is directed to make a direct assessment on the non-resident company. The assessee is the non-resident company and the ITO has wrongly adopted the alternative machinery of assessment on the resident company as agent of the non-resident company, which machinery was barred by limitation, and hence the ITO had no alternative but to make the direct assessment on the non-resident company and, therefore, the ITO is directed to make the assessment direct on the non-resident company to tax the deemed dividend under Section 23A. In connection with the assessments for the years 1950-51 and 1951-52, as stated earlier, the notices under Section 34 were validly issued taking the assessee as non-resident company directly and the returns of income were also submitted showing the assessee as non-resident company and, therefore, the proceedings are set aside from the date of issue of notice under Section 23(2) and the ITO is directed to make the assessments on the non-resident company after giving fresh opportunity to the asssessee under Section 23(2).

3. Shri P.T. Sanyal on behalf of the appellant contends that the AAC cannot give any direction to make fresh assessments directly on the nonresident company merely because the present assessment made on the resident company as agents of the non-resident company are invalid and it is stated that, according to Section 34(3), the direction can be given only in respect of the same assessee and not in respect of another assessee. In view of the reasons stated above, the assessee is the non-resident company, M/s. Hungerford Investment Trust Ltd., and in connection with the assessments for the years 1950-51 and 1951-52, the ITO initiated proceedings for direct reassessment on the non-resident company, but inadvertently in the assessment order the assessee was shown as the resident company as agents of the non-resident company and, therefore, in my opinion, the AAC is justified in giving a direction to make fresh direct assessment on the non-resident company as the assessee all throughout remains the nonresident company and the direction visualises only a change in the machinery for the assessment. Similarly, in connection with the assessment of 1949-50, though the ITO sought to adopt the machinery of assessment on the non-resident company through the resident agent, theAAC is justified in giving direction to make a direct assessment on the non-resident company as the assessee remains the non-resident company and only machinery of assessment is sought to be changed.

4. Thereafter, the respondent by letter dated 26th October, 1961, issued notices on the Hungerford Investment Trust Ltd. (in liquidation), under Section 34 of the Indian I.T. Act, and under Section 23(2) thereof for the assessment years 1949-50, 1950-51 and 1951-52. The notices were said to have been served on 28th March, 1961. Being aggrieved by the said notices the appellant challenged the same in an application made tinder Article 226 of the Constitution in the court of the first instance on various grounds as will appear from the petition of the said application. The main contention was that the ITO had no authority or jurisdiction to issue any notice under Section 34 for the assessment year 1949-50, or any notice under under Section 23(2) for the assessment years 1950-51 and 1951-52, since proceedings under Section 34 or Section 23 for any of the aforesaid three years were barred by limitation. Further, notices under Section 34 and Section 23(2) of the Act were issued on the basis of and to give effect to the directions given by the AAC in the appeals of the company, i.e., Turner Morrison and Co., Ltd. The said notices were time-barred and without jurisdiction since the AAC had no competence or jurisdiction to give any such directions against the appellant in disposing of the appeals of the said company in view of the fact that the appellant was not a party to the appeals.

5. On behalf of the respondent affidavit was filed in the court of the first instance challenging the allegation made in the petition. The relevant portion of the affidavit is to be found in paras. 4 and 6. In para. 4 it was stated that the notice was issued in pursuance of the specific direction given by the AAC dated 29th November, 1970. This appeal was made against an order of assessment made on M/s. Hungerford Investment Trust Ltd. It was further stated that M/s. Turner Morrison and Co. Ltd. was a natural agent at all material times of the Hungerford Investment Trust Ltd. and used to manage and look after the affairs of the Hungerford Investment Trust Ltd. and it was submitted that both principal and agent, namely, M/s. Hungerford Investment Trust Ltd. and Turner Morrison and Co. Ltd. were parties to the said assessment proceedings. In para. 6 it was stated that the direction and order of the AAC were binding both on the Hungerford Investment Trust Ltd. as well as Turner Morrison and Co. Ltd. The said Turner Morrison and Co. Ltd. was the agent of the Hungerford Investment Trust Ltd. In view of the provisions of Section 40(2) of the I.T. Act, the liability of both Hungerford Investment Trust Ltd. and Turner Morrison and Co. Ltd. were co-extensive. It was, therefore,submitted by the respondent that the proceedings on the notice dated 29th October, 1961, were maintainable and the notices were valid.

6. The learned judge of the court of the first instance accepting the contention urged before him on behalf of the respondent by his judgment and order dated January 31, 1972, dismissed the said application and discharged the rule nisi. Learned judge of the court of the first instance was of the view that taking or continuation of the proceedings against the appellant pursuant to the direction of the AAC was not barred under Section 34(3) because it could not be said that M/s. Hungerford Investment Trust Ltd. could come within the mischief of the word ' 'any person' in the second proviso to Section 34(3) in its widest connotation. According to his Lordship the appellant would come within the mischief of the word 'any person' meaning thereby a person intimately connected with the assessment for the year under appeal. His Lordship observed as follows (p. 319 of 102 ITR):

'The expression 'any person', therefore, cannot be read to mean 'any person' in its widest connotation. If it is so read then the case decided in S.C. Prashar v. Vasanlsen Dwarkadas : [1963]49ITR1(SC) , will come into play. But, otherwise, the expression ' any person ' is necessarily circumscribed as held by the Supreme Court by the scope and subject-matter of the appeal or revision or that person must be one who would be liable to be assessed for the whole or the part of the income that went into the assessment for the year under appeal. There cannot be any doubt in the present case that M/s. Hungerford Investment Trust Ltd., being a non-resident company, is liable to be assessed through its agent, M/s. Turner Morrison and Co. Ltd. If that is so, it cannot be stated that M/s, Hungerford Investment Trust Ltd. comes within the mischief of the words 'any person' in its widest connotation. In other words, in my opinion, M/g. Hungerford Investment Trust Ltd. comes within the mischief of the words 'any person' meaning thereby a person intimately connected with the assessment for the year under appeal. It appears that the matter argued by Dr. Pal is not now open, and has been set at rest by a decision of the Supreme Court in Commissioner of Income-tax v. Ambala Flour Mills : [1970]78ITR256(SC) ......

Dr. Debi Pal, however, contended that the decision rendered in Commissioner of Income-tax v. Ambala Flour Mills : [1970]78ITR256(SC) , applies only to an association of persons and not a company. It is argued by Dr. Pal that the company is a different legal entity and Turner Morrison Company was deemed to be an agent of Hungerford Investment Trust Ltd. and, therefore, it is argued that Hungerford Investment Trust Ltd. comes within the meaning of 'any person' in its widest connotationand, as such, no direction can be given while disposing of an appeal preferred by Turner Morrison Company Ltd. In my opinion, Dr. Pal is not correct in his submission. It goes without saying that 'company' as used in the Income-tax Act has a much wider connotation. In the particular case the Hungerford Investment Trust Ltd. is not an Indian company but a company incorporated in Singapore and it comes within the mischief of the words 'association of persons'. Looking from that angle it is quite clear that Turner Morrison and Company Ltd. and Hunger-ford Investment Trust Ltd. are intimately connected with the assessment of the year under appeal. The Hungerford Investment Trust Ltd. filed the return and the matter was being proceeded with but in the subsequent stage the assessment was made on Turner Morrison. It further appears that Turner Morrison preferred appeals against the appellate order to the Tribunal as agent of Hungerford Investment Trust Ltd. which was subsequently withdrawn. In the premises I am of the opinion that the direction given by the Assistant Commissioner while setting aside the assessment against Turner Morrison Company cannot be said to be a direction to any person in its widest connotation.'

7. It was submitted on behalf of the appellant that in view of the fact that the time-limit for completing the assessment under Section 34(3) of the Indian I.T. Act, 1922, is four years from the end of the assessment year in which the income is first assessable, no reassessment for the said three years can be made after 31st of March, 1954, 31st of March, 1955, and 31st of March, 1956, for the assessment years 1949-50, 1950-51 and 1951-52, respectively. The impugned notices given long after the time for completing the assessment are bad in law. It was further submitted that the proceedings for reassessment having been initiated for including the deemed income under Section 23A, such proceedings can only be under Section 34(1)(b) of the Act. It was further submitted that in the instant case it cannot be said that the barof limitation set out in Section 34(3) of the Indian I.T. Act, 1922, is lifted because the assessments are being made in order to give effect to the directions of the AAC given in the appeals preferred by Turner Morrison and Co. Ltd. for the assessment years 1949-50, 1950-51 and 1951-52. It was further submitted that in appeal before the AAC, Turner Morrison was the assessee. Turner Morrison was a company incorporated under the Companies Act, 1956, and Hungerford Investment Trust is a non-resident company incorporated under the laws of Singapore. Therefore, the two companies are two distinct juridical persons. If Turner Morrison is the assessee in the appeal before the AAC, Hungerford Investment. Trust cannot be also the assessee and can only be any person other than the assessee. According to the counsel, this position also has been accepted bythe learned trial judge. If any direction is given by the AAC to make any assessment upon Hungerford, such a direction is upon a person other than an assessee. According to the counsel, the second proviso to Section 34(3), in so far as it lifts the bar of limitation, in respect of the assessment of any person other than an assessee, when a finding or a direction is given, is ultra vires the Constitution offending Article 14. In this connection reliance was placed on the cases of S.C. Prashar v. Vasantsen Dwarkadas : [1963]49ITR1(SC) and CIT v. Sardar Lakhmir Singh : [1963]49ITR70(SC) . According to the counsel, the learned trial judge has held that Hungerford Investment Trust Ltd. being non-resident company is liable to be assessed through the agent, M/s. Turner Morrison and Co. Ltd. According to his Lordship, therefore, Hungerford Investment Trust comes within the mischief of the word 'any person' appearing in the second proviso to Section 34(3), meaning thereby a person who is intimately connected with the assessment for the year under appeal. In other words, Hungerford Investment Trust, according to the learned judge, comes within the mischief of 'any person' appearing in the second proviso to Section 34(3) and, therefore, is a person other than an assessee, i.e., Turner Morrison and Co. Ltd. It is submitted that this view of the learned trial judge is wrong. In the above cases, the Supreme Court has declared that the second proviso to Section 34(3) in so far as it lifts the bar of limitation in respect of the assessment of any person other than an assessee in respect of whom a finding or a direction is given is ultra vires the Constitution offending Article 14. The Supreme Court has not held that such a direction or a finding, if given in respect of any person other than the assessee, will not violate Article 14 of the Constitution, if such other person is intimately connected with the assessee. It was submitted that the above position has not been changed by the subsequent decisions of the Supreme Court in the case of ITO v. Murlidhar Bhagwan Das : [1964]52ITR335(SC) and CIT v. Ambala Flour Mills : [1970]78ITR256(SC) . The Supreme Court further pointed out that the precise question which it was cabled upon to decide in Murlidhar's case, did not appear to have been the subject of decision in Prashar's case : [1963]49ITR1(SC) . According to the counsel, the two cases referred to by the learned trial judge in his judgment, viz. : [1964]52ITR335(SC) and : [1970]78ITR256(SC) do not in any way touch or affect the law laid down by the Supreme Court in : [1963]49ITR1(SC) and : [1963]49ITR70(SC) . The two cases relied upon by the learned trial judge are distinguishable in view of the peculiar facts and issues involved in those cases. It was submitted that in : [1964]52ITR335(SC) the validity of the second proviso to Section 34(3) in respect of a direction given to any person other than an assessee could not and was not raised. The majority judges in that case, therefore, did not consider : [1963]49ITR1(SC) .

8. It was further submitted that even assuming, though not admitting that a direction can be given by the AAC in respect of any person other than an assessee under the second proviso to Section 34(3) of the Indian I.T: Act, 1922, such a direction can be only one which the AAC is authorised to give under Section. 31. The directions that the AAC can give are those falling either under Section 31(3)(b), (c) or (e) or Section 31(4). Reference was made to CIT v. Mohd. Shakoor Mohd. Bashir : [1973]89ITR57(SC) . According to the counsel, the decision has followed the earlier decision of the. Supreme Court in Murlidhar's case : [1964]52ITR335(SC) . Counsel has submitted that in : [1964]52ITR335(SC) , the Supreme Court has observed that the expression 'direction.' cannot be construed in vacuum but must be related to the directions which the AAC can give under Section 31. Under that section he can give directions, inter alia, under Section 31(3)(b), (c) or (e) or Section 31(4). The expression 'direction' in the proviso could only refer to the direction which the AAC or other Tribunal can issue under the powers conferred on him or them under the relevant provision. Beyond the power of giving directions specified in the aforesaid sub-clauses of Section 31, there is no other power under the Act for the AAC to give directions in respect of a person other than an assessee. Under the various sub-clauses of Section 31 directions can be given only in the case of an assessment of an HUF or an association of persons or of a partnership firm. In the instant case, the assessee is Turner Morrison and Co. Ltd. Hungerford Investment does not come under any of the said sub-clauses for the purpose of giving direction. Therefore, the AAC had no power to give a direction to make the assessment on Hungerford which is a person other than an assessee and, as such, the direction does not come under any of the specific sub-clauses of Section 31.

9. On behalf of the respondent it has been submitted that the undisputed facts in this case are : (a) The appellant was the assessee. (b) The income which was the subject-matter of the assessment for the three assessment years involved was the income of the appellant, being the deemed dividend under Section 23A of the Indian I.T. Act, 1922, before its amendment in 1955. (c) The said income was assessable for the assessment years 1949-50, 1950-51 and 1951-52.

10. For the assessment years 1950-51 and 1951-52 proceedings for direct reassessment on the appellant (non-resident company) were initiated by the ITO but inadvertently the assessment order was passed in the name of Turner Morrison and Co., as agent of the non-resident company. For the assessment year 1949-50 notice under Section 34 of the said Act was issued in the name of Turner Morrison and Co. as agent for the appellant-company on April 5, 1954, which, was beyond the period of limitation. Thus, the appellant-company was the assessee in the proceedings for all the three assessmentyears. But the ITO committed an irregularity at the last stage, of the reassessment proceedings for the assessment years 1950-51 and 1951-52 and at the initial stage of the proceedings for the assessment year 1949-50.

11. Therefore, the AAC was quite competent to give necessary directions to the ITO under Section 31(3)(b) of the Indian I.T. Act, 1922, for a proper assessment of the assessee. Relying on the case of CIT v. Kanpur Coal Syndicate : [1964]53ITR225(SC) , it has been submitted that the AAC has plenary powers in disposing of an appeal. The scope of his power is conterminous with that of the ITO. He can do what the ITO can do and also direct him to do what he has failed to do.

12. It has been further submitted that in any event, the appellant falls within the expression 'any person' in the second proviso to Section 34(3) of the Indian I.T. Act, 1922, and the said expression 'any person' cannot be accepted in its widest connotation. That person must be one who would be liable to be assessed for the whole or part of the income that went into the assessment of the year under appeal or revision. In this connection reliance . was placed on the decision of the Supreme Court in ITO v. Murlidhar Bhagwan Das : [1964]52ITR335(SC) , Counsel has submitted that the scope of the expression ' any person ' was fully explained by the Supreme Court in that case at p. 346 (of 52 ITR) thus :

' Modification or setting aside of assessment made on a firm, joint Hindu family, association of persons, for a particular year may affect the assessment for the said year on a partner or partners of the firm, member or members of the Hindu undivided family or the individual, as the case may be. In such cases though the latter are not eo nomine parties to the appeal, their assessments depend upon the assessments on the former. The said instances are only illustrative. It is not necessary to pursue the matter further. We would, therefore, hold that the expression 'any person' in the setting in which it appears must be confined to a person intimately connected in the aforesaid sense with the assessments of the year under appeal.'

13. It was submitted that in all subsequent cases the Supreme Court followed the above principles laid down in Murlidhar Bhagwan Das's case : [1964]52ITR335(SC) . According to the counsel, the only point that arose for consideration in all these cases was whether the person in respect of whom the finding was arrived at or the direction was given by the AAC under the second proviso to Section 34(3) of the Indian I.T. Act, 1922, was the person to whom the income which was the subject-matter of the assessment belonged or who was intimately connected with the person whose assessment was set aside by the AAC and not a total stranger to the said assessment. The Supreme Court did not at all go into the question whether the direction of the AAC was given in an appeal filed by the assessee concerned. Reference was made to the decisions of the Supreme Court in the cases of Daffadar Bhagat Singh and Sons v. ITO : [1969]71ITR417(SC) , CIT v. Ambala Flour Mills : [1970]78ITR256(SC) , Rangalal Jajodia v. CIT : [1971]79ITR505(SC) and CIT v. Vadde Pullaiah and Co. : [1973]89ITR240(SC) .

14. The main point that falls for determination is whether the reassessments against the appellant were barred by limitation. According to the Revenue, the reassessments are not barred by limitation because of the second proviso to Section 34(3) of the Act. According to the appellant the second proviso has no application in view of the fact that the Turner Morrison and Co. Ltd. and the Hungerford Investment Trust Ltd. are two separate legal entities.

15. In the case of S.C. Prashar v. Vasantsen Dwarkadas : [1963]49ITR1(SC) , it has been held by the Supreme Court that the provisions of the second proviso to Section 34(3) of the Indian I.T. Act, 1922, is ultra vires of Article 14 of the Constitution of India in so far as they authorise the assessment or reassessment of 'any person' other than the assessee after the period of limitation specified in Section 34 in consequence of an order to give effect to a finding or direction given in an appeal.

16. It appears that in a later decision of the Supreme Court in the case of ITO v. Murlidhar Bhagwan Das : [1964]52ITR335(SC) , the Supreme Court explained the connotation of the expression 'any person' in the proviso as follows (p. 346):

'The words 'any person', it is said, conclude the matter in favour of the Department. The expression 'any person' in its widest connotation may take in any person, whether connected or not with the assessee, whose income for any year has escaped assessment; but this construction cannot be accepted, for the said expression is necessarily circumscribed by the scope of the subject-matter of the appeal or revision, as the case may be. That is to say, that person must be one who would be liable to be assessed for the whole or a part of the income that went into the assessment of the year under appeal or revision. If so construed, we must turn to Section 31 to ascertain who is that person other than the appealing assessee who can be liable to be assessed for the income of the said assessment year. A combined reading of Section 30(1) and Section 31(3) of the Act indicates the cases where persons other than the appealing assessees might be affected by orders passed by the Appellate Assistant Commissioner. Modification or setting aside of assessment made on a firm, joint Hindu family, association of persons, for a particular year may affect the assessment forthe said year on a partner or partners of the firm, member or members of the Hindu undivided family or the individual, as the case may be, In such cases, though the latter, are not eo nomine parties to the appeal, their assessments depend upon the assessments on the former. The said instances are only illustrative. It is not necessary to pursue the matter further. We would, therefore, hold that the expression 'any person' in the setting in which it appears must be confined to a person intimately connected in the aforesaid sense with the assessments, of the year under appeal.'

17. In the case of CIT v. Ambala Flour Mills : [1970]78ITR256(SC) , the Supreme Court relied upon 'the decision reported in Murlidhar Bhagwan Das : [1964]52ITR335(SC) .

18. It, therefore, appears that if the expression 'any person' in the proviso is read in the widest sense then it will be hit by the decision of the Supreme Court in S.C. Prashar v. Vasantsen Dwarkadas : [1963]49ITR1(SC) . On the contrary if the expression 'any person' means a person intimately connected with the assessee then it will not be hit by the decision of the Supreme Court in S.C. Prashar's case : [1963]49ITR1(SC) .

19. In our view the learned judge of the court of the first instance rightly came to the finding that Hungerford Investment Trust Ltd. came within the mischief of the words 'any person' meaning thereby a person intimately connected with the assessment under appeal. We respectfully agree with the 'finding of the learned judge of the court of the first instance as also with his reasonings for such finding. As M/s. Hungerford Investment Trust Ltd. being a non-resident company is liable to be assessed through its agent, Turner Morrison and Co. Ltd., it cannot but be said that Hungerford Investment Trust comes within the expression 'any person' in the sense of a person being intimately connected with the assessee. In the facts and circumstances of this case as stated hereinbefore we are of the opinion that the appellant, Hungerford Investment Trust Ltd., being intimately connected with Turner Morrison and Co. Ltd., the second proviso to Section 34(3) would apply and the reassessments are not barred by limitation. We also respectfully agree with the view of the learned judge of the court of the first instance that Hungerford Investment Trust Ltd. comes within the mischief of the words 'association of persons' and the reasons for the said view. As in our view the appellant is a person intimately connected with the assessee, direction for reassessment was validly given by the AAC and in this connection the arguments advanced by the Revenue appear to have a good deal of force.

20. In the aforesaid view of the matter the appeal fails and it is dismissed. There will, however, be no order as to cost.

21. I agree.


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