# Hyundai Engineering & Construction Ltd. Revisionist/ v. Commissioner of Trade Taxes, U.P., Lucknow

- **Citation:** (2019) 3 ILRA 797
- **Court:** High Court of Judicature at Allahabad
- **Decided:** 2019-09-16
- **Case number:** Trade Tax Revision No. 236 of 2006
- **Bench:** Saumitra Dayal Singh
- **Source:** https://unisonlegal.in/judgment/allahabad-high-court/hyundai-engineering-construction-ltd-revisionist-v-commissioner-of-trade-taxes-44804
- **Pages:** 8

## Headnote

A. Tax Law-Entry Tax - U.P. Tax on Entry of
Goods Act, 2001- Section 4 - Whether
import of machinery into a local area from
outside India is liable to payment of entry
tax? Held: Yes in the light of SC judgment
in Civil Appeal Nos. 3381-3340 of 1998,
decided on 09.10.2017. (Para 11)
B. Tax Law-Entry Tax - U.P. Tax on Entry
of Goods Act, 2007 - Assessment -
Sections 4(1), 4(3) and 4(6) - Each
Assessment Year is a separate and
independent unit of assessment. Unless
specifically provided by the legislature or
necessarily implied, subsequent facts or
events
arising
in
preceding
or
succeeding assessment years, have no
bearing on either the taxable event or
the consequent tax liability that may
arise during any assessment unit/year.
The subsequent event of sale or re-sale
of the machinery by way of export sale
was unconnected to the taxing event.
Question: Whether resale of goods in the
course of exports out of the territory of India
in Assessment Year 2004-05 would make an
assessee not liable to pay Entry Tax on that
machinery imported into India in Assessment
Year 2000-01 and whether the benefit of
section 4(6)(ii) of the U.P. Tax on Entry of
Goods Act, 2007 can be availed by the
assessee? (Para 13, 14, 15, 18)
C. Tax Law-Entry Tax - U.P. Tax on Entry
of Goods Act, 2007 - Reversal of Tax -
Section 5 does not provide for reversal of
798 INDIAN LAW REPORTS ALLAHABAD SERIES
entry tax liability for a belated export of
goods on which the liability of payment
of entry tax had already arisen. (Para 16)
Revision dismissed (E-4)

Precedent followed: -

## Text

3 All. Hyundai Engineering & Construction Ltd. Vs. Commissioner of Trade Tax, U.P., Lucknow
797
the company from shops and stalls is
income received from property and falls
under the specific head described in
Section 9 being income from property.

36. Thus, the finding recorded by the
Assessing Officer after examining all the three
agreements found that the assessee did not
indulge in any kind of recurring, systematic
and in organized manner, business activity and
having only one employee rightly assessed the
receipts under the heading 'income from house
property and income from other sources'.

37. Having considered the case in
depth and the findings recorded by the
authorities
below,
we
are
of
the
considered opinion that as the appellantassessee did not carry out any systematic,
recurring and in organised manner, any
business activity nor there was any
volume,
frequency,
continuity
and
regularity of transactions, and only one
person was employed by him for the
management and look after of the leased
property, the taxing authorities had rightly
held the receipts to be income from house
property and income from other sources
and not business income.

38. In our considered view the
appeal
lacks
merit
and
is
hereby
dismissed.

39. The question of law as framed
are hereby answered in favour of the
Revenue and against the assessee.
----------

(2019)11ILR A797

REVISIONAL JURISDICTION
CIVIL SIDE
DATED: ALLAHABAD 16.09.2019
BEFORE
THE HON'BLE SAUMITRA DAYAL SINGH, J.
Trade Tax Revision No. 236 of 2006

Hyundai Engineering & Construction Ltd.
 ...Revisionist/Petitioner
Versus
Commissioner of Trade Taxes, U.P.,
Lucknow ...Respondent

Counsel for the Revisionist:
Sri K.N. Kumar, Sri Vishnu Kesarwani

Counsel for the Respondent:
C.S.C.

A. Tax Law-Entry Tax - U.P. Tax on Entry of
Goods Act, 2001- Section 4 - Whether
import of machinery into a local area from
outside India is liable to payment of entry
tax? Held: Yes in the light of SC judgment
in Civil Appeal Nos. 3381-3340 of 1998,
decided on 09.10.2017. (Para 11)
B. Tax Law-Entry Tax - U.P. Tax on Entry
of Goods Act, 2007 - Assessment -
Sections 4(1), 4(3) and 4(6) - Each
Assessment Year is a separate and
independent unit of assessment. Unless
specifically provided by the legislature or
necessarily implied, subsequent facts or
events
arising
in
preceding
or
succeeding assessment years, have no
bearing on either the taxable event or
the consequent tax liability that may
arise during any assessment unit/year.
The subsequent event of sale or re-sale
of the machinery by way of export sale
was unconnected to the taxing event.
Question: Whether resale of goods in the
course of exports out of the territory of India
in Assessment Year 2004-05 would make an
assessee not liable to pay Entry Tax on that
machinery imported into India in Assessment
Year 2000-01 and whether the benefit of
section 4(6)(ii) of the U.P. Tax on Entry of
Goods Act, 2007 can be availed by the
assessee? (Para 13, 14, 15, 18)
C. Tax Law-Entry Tax - U.P. Tax on Entry
of Goods Act, 2007 - Reversal of Tax -
Section 5 does not provide for reversal of
798 INDIAN LAW REPORTS ALLAHABAD SERIES
entry tax liability for a belated export of
goods on which the liability of payment
of entry tax had already arisen. (Para 16)
Revision dismissed (E-4)

Precedent followed: -

1. St. of Kerala & ors. Vs Fr. William
Fernandez, Civil Appeal Nos. 3381-3400 of
1998, decided on 09.10.2017 (SC) (Para 11)

2. P.M. Mohd. Meerakhan Vs CIT, (1969) 2
SCC 25 (Para 13)
Precedent cited:
1. Polestar Electronic (Pvt.) Ltd. Vs Additional
Commissioner, Sales Tax & ors., (1978) 1 SCC
636 (Para 6)
2. Director of Entry Tax & ors.s Vs Mahindra &
Mahindra & anr., J.T. 2001 (5) S.C. 544 (Para
8)

Trade Tax Revision against the judgment
and order dated 07.12.2005 passed by
Trade Tax Tribunal in Second Appeal No.
192 of 2003 for Assessment Year 200001.

(Delivered by Hon'ble Saumitra Dayal
Singh, J.)

1. Heard Sri K.N. Kumar and Sri
Vishnu Kesarwani, learned counsel for
the assessee-revisionist and Sri B.K.
Pandey, learned counsel for the Staterespondent.

2. The present revision filed by the
assessee arises from the order passed by
the Trade Tax Tribunal, Allahabad dated
07.12.2005 in Second Appeal No.192 of
2003 for A.Y.2000-01 (Entry Tax). By
that order, the Tribunal dismissed the
appeal filed by the assessee and affirmed
the assessment and demand of entry tax
on machinery imported by the assessee
during the A.Y. 2000-2001, but exported
outside the country in the year 20042005.

3. Undisputed facts of the case are
that the assessee is an engineering
concern. It was awarded contract to
construct a stay wired bridge over the
river Yamuna, at Allahabad. For the
purposes of executing that contract, the
assessee imported into the country and the
local area, Allahabad, machineries of
value Rs.1,30,30,000/-, during the A.Y.
2000-01. The machinery thus imported
were amenable to levy on entry tax under
the U.P. Tax on Entry of Goods Act 2001
(hereinafter referred to as Old Act). The
assessee, at the relevant time, also
deposited entry tax on such machinery.
Undisputedly, it made use of those
machinery in execution of aforesaid
contract awarded to it. After its successful
completion, the assessee sold those
machineries in the course of export trade
to a purchaser at South Korea.

4. Though the revision was admitted
without reference to any question of law,
however, at the time of hearing the
following questions of law have been
pressed:

"(i) Whether under the facts and
circumstances
mentioned
above,
the
learned Trade Tax Tribunal Bench,
Allahabad was correct
in applying
Section 4, and read with the Explanation
appended thereto (added by amending
Act 10 of 2005)?

(ii)
Whether
machinery
imported from outside India during A.Y.
2000-2001 are covered by Section 4 of
the Old Act, as amended by the Act No.
10 of 2005?
3 All. Hyundai Engineering & Construction Ltd. Vs. Commissioner of Trade Tax, U.P., Lucknow
799

(iii) Whether under the facts
and circumstances mentioned above, the
Revisionist is not liable to pay entry tax
under Section 4 (6) (ii) of the Entry Tax
Act, 2007, since it re-sold the goods in the
course of export out of the territory of
India?"

5. In such facts, the assessee
claimed that the entry of that machinery
into the local area Allahabad during the
assessment year 2000-01 was nontaxable, since the machineries had not
been
brought
into
the
local
area,
Allahabad from within the country but
from outside the country. That claim was
rejected. During the pendency of the
present revision, the U.P. Tax On Entry of
Goods Into Local Areas Act, 2007
(hereinafter referred to as a New Act) was
enforced. The assessee has thus relied on
the provisions of Section 4(6)(ii) of the
New Act to contend that in any case,
upon export of the disputed machinery,
no tax liability survived as sub-section 6
of Section 4 overrides the charging
provisions under Section 4(1) and 4(3) of
the New Act.

6. Also, it has been submitted, for
the purposes of export of machinery, no
time limit is prescribed under sub-clause
(ii) of sub section 6 of Section 4 of the
New Act. Therefore, the fact that the
assessee exported the machinery later i.e.
during
the
A.Y.
2004-05,
was
inconsequential to the claim made by the
assessee. Reliance has been placed on a
decision of a Supreme Court in the case
of Polestar Electronic (Pvt.) Ltd. Vs.
Additional Commissioner, Sales Tax and
Others (1978) 1 SCC 636 to submit that
in view of the clear language of the
statute, effect must be given to it to
declare the intention of the law giver.
Plain and natural meaning must be given
to the words used in Section 4 (6) of the
New Act and no other or further meaning
is to be discovered. Further, it is not
permissible to speculate as to what the
legislature may have intended. Nor it is
permissible to twist or bend the language
of the statute to bring the subject to tax. In
other words, it has been submitted, for the
charge of tax to arise the transaction must
naturally fall within the four corners of
the charging section. No other submission
was advanced.

7. Opposing the revision, learned
Standing Counsel would submit, whether
the case is examined, in the context of the
language of the Old Act or in the context
of the language under the New Act, (that
has been enforced with full retrospective
effect), the claim made by the assessee is
wholly unfounded. With reference to the
Old Act, it has been submitted, it was the
clear scheme of the Old Act to impose
entry tax upon entry being caused of
taxable goods, into any local area, for
their consumption, use or sale therein.
There was neither any exemption granted
to goods that had been imported from
outside the country and thereafter brought
into the local areas for such purpose, nor
there was any scheme to grant remission
from tax paid on such goods. In the
admitted facts of the case, the assessee
brought into the local area Allahabad,
machinery that fell within the description
of taxable goods under the schedule of the
Old
Act,
for
its
own
use.
The
requirements, for the charge of tax to
arise, were thus fulfilled. Tax had been
rightly imposed.

8. In the context of the New Act,
learned Standing Counsel would submit
though under that Act, sub-section 6 of
800 INDIAN LAW REPORTS ALLAHABAD SERIES
Section 4, overrides Section 4 (1) and
Section 4 (3), yet clearly, tax liability
would continue to exist on such goods as
may have been consumed, used or sold
within the local area where such goods
may have been brought from outside.
Alternatively, in any case, once the
assessee brought inside the local area
Allahabad, machinery for use and it
actually put to use such machinery during
the A.Y.2000-01, the tax liability got
crystallized at that point or in time. The
fact that the machineries were exported
outside the country after close of that
assessment year, would have no bearing
on the tax liability for the A.Y. 2000-01.
He has relied on the decision of the
Supreme Court in the case of Director of
Entry Tax and others Vs. Mahindra and
Mahindra and another J.T. 2001 (5) S.C.
544.

9. Having heard learned counsel for
the parties and having perused the record,
in the first place, under the Old Act, the
charging
Section
was
contained
in
Section 4. It read as below:

"4. Levy of Tax.- (1) There shall
be levied and collected a tax on entry of
any goods specified in the Schedule into a
local area from any place outside that
local area including a place outside the
U.P./Uttaranchal for consumption, use or
sale therein, at such rates not exceeding
five per cent of the value of the goods as
may be specified by the State Government
by notification and different rates may be
specified in respect of different goods or
different classes of goods:

Provided
that
the
State
Government may by notification amend
the schedule and upon issue of any such
notification, the schedule shall, subject to
the provisions of sub-section (6), be
deemed to be amended accordingly.

(2) The tax levied under SubSection (1) shall be payable by a dealer
who brings or causes to be brought into
the local area such goods, whether on his
account or on the account of his Principal
or takes delivery or is entitled to take
delivery of such goods on its entry into a
local area.

Explanation- Where the goods
are taken delivery of on its entry into a
local area or brought into a local area by
a person other than a dealer, the dealer
who takes delivery of the goods from such
person shall be deemed to have brought
or caused to have brought the goods into
the local area.

(3) No dealer who brings or
causes to be brought any goods into a
local area shall be liable to tax, if during
the assessment year the aggregate value
of such goods is less than one lakh rupees
in the case of manufacturers and one lakh
fifty thousand rupees in case of other
dealers or such larger amount as the
State Government may be notification,
specie in that behalf either in respect of
all dealers in any goods or in respect of a
particular class of such dealers:

Provided that provisions of this
sub-section shall not apply in respect of
value of the goods brought into a local
area
from
outside
Uttar
Pradesh/Uttaranchal.

(4) Notwithstanding anything
contained in sub-section (1) or subsection (2), no tax shall be levied on and
collected from a dealer who brings or
causes to be brought into a local area any
goods in respect of which tax has been
paid any other local area under the said
sub-Sections.

(5) No benefit under sub-section
(4) shall be given to a dealer unless he
3 All. Hyundai Engineering & Construction Ltd. Vs. Commissioner of Trade Tax, U.P., Lucknow
801
furnishes, to the satisfaction of the
assessing authority, such declaration or
certificate obtained from the selling
dealer in such form and manner and
within such period as may be prescribed.

(6) Every notification made
under this Section shall, as soon as may
be after it is made, be laid before each
house of the Stat Legislature/Assembly,
while it is in session, for a total period of
not less than fourteen days, extending in
its one, session or more than one
successive sessions and shall unless some
later late is appointed take effect from the
date of its publication in Gazette subject
to such modifications or annulments as
the
two
Houses
of
the
Legislature/Assembly may during the said
period agree to make, so however, that
any such modification or annulment shall
be without prejudice to the validity of
anything previously done thereunder
except that any imposition, assessment,
levy or collection of tax or penalty shall
be subject to the said modification or
annulments."

10. Also, under the schedule to that
Act, machinery valuing more than 10 lacs
was clearly under taxable. Thus, the levy
of tax on entry of machinery (valued at
more than 10 lacs) arose, no sooner the
assessee caused the entry of those goods
into the local area Allahabad from outside
that local area for use. Under the Old Act,
the subsequent Act of export of the
machinery out of the country, was wholly
irrelevant and had no bearing on the tax
liability that had otherwise arisen and got
finally attached to the transaction upon
causing entry of such machinery inside
the local area, for use. For the purposes of
clarity, it has to be stated that no
provision of the nature contained in
Section 4(6) of the Act (New Act) existed
under the Old Act.

11. In so far as it has been
contended that no liability of entry tax
arose, since the machinery had been
imported from outside the country, that
question stands squarely decided against
the assessee, by the Supreme Court in
Civil Appeal nos. 3381-3400 of 1998,
State of Kerala and others Vs. Fr. William
Fernandez decided on 09.10.2017, laying
down the following rule:

"144. In view of foregoing
discussion, we arrive at the following
CONCLUSIONS:

(i) Orissa Entry Tax Act, 1999,
Kerala Tax Act, 1994 and Bihar Tax on
Entry of Goods in Local Area for
Consumption, Use or Sale, 1993 (before
its amendment by Bihar Act, 2003 and
2006) do not exclude levy of entry tax on
the goods imported from any place
outside territories of India into a local
area for consumption, use or sale.

(ii)
All
the
Entry
Tax
Legislations questioned in these appeals
are legislations which are within the
legislative competence of the State
legislatures and do not intrude the
legislative domain of Parliament as
reserved in Entry 41 & Entry 83 of List I.

(iii) The import of goods from
any territory outside India comes to an
end when the goods enter into the custom
frontiers of India and are released for
home consumption.

(iv) After import of goods comes
to an end the State legislature has full
legislative competence to levy entry tax
under Entry 52 List II.

(v)
The
Original
Package
Theory as developed by the American
Supreme Court in case of Brown vs. State
802 INDIAN LAW REPORTS ALLAHABAD SERIES
of Maryland(supra) is not applicable in
this country and the imported goods are
not exempted from entry tax till it reaches
to the factory premises/destination of its
consumption, use or sale.

(vi) Non inclusion of custom
duty in the definition of purchase value in
the statute of entry tax is not an indicator
of the fact that legislature never intended
to levy entry tax on imported goods.

(vii) Entry tax legislation are
fully covered by Entry 52 List II and the
submission that essence of Entry 52 is
octroi which can be levied only by local
authorities and State has no legislative
competence to impose entry tax under
Entry 52 List II is fallacious.

(viii) A plant imported in
knocked out condition is fully covered
with the definition of machinery and
equipment under Part II of Schedule of
the Orissa Act, 1999."

12. In so far as, the New Act is
concerned, Section 4 (1), (3) and (6) of
that Act read as below:

"Section 4. Levy of tax:

(1)
For
the
purpose
of
development of trade, commerce and
industry in the State, there shall be levied
and collected a tax on entry of goods
specified in the Schedule into a local area
for consumption, use or sale therein, from
any place outside that local area, at such
rate not exceeding five percent of the
value of the goods as may be specified by
the State Government by notification and
different rates may be specified in respect
of different goods or different classes of
goods;

Provided
that
the
State
Government may by notification amend
the schedule and upon issue of any such
notification, the Schedule shall, subject to
the provisions of sub-section (10), be
deemed to be amended accordingly.

(3) The tax levied under subsection (1) shall be payable by a dealer
who brings or causes to be brought into
the local area such goods, whether on his
account or on the account of his principle
or takes delivery or is entitled to take
delivery of such goods on its entry into a
local area.

Provided
that
the
State
Government, may by notification, permit
any
Power
Project
Industrial
Unit
engaged in generation, transmission and
distribution, having aggregate capital
investment of Rs. One thousand crore or
more to own the liability of payment of
tax of other dealers on the entry of such
goods into a local area from any place
outside that local area as are used and
consumed by the said unit subject to such
conditions as may be specified in the
notification.

(6) Notwithstanding anything
contained in sub-section (1) or subsection (3), no tax shall be levied on and
collected from a dealer, who brings or
causes to be brought into a local area any
goods which are,-

(i) Consigned without using
them in the local area to any place
outside the State; or

(ii) sold or resold either in the
course of inter-state trade or commerce
or in the course of export out of the
territory of India;

Explanation- Section 3, Section
5 and Section 6 A of the Central Sales
Tax Act, 1956 shall apply for the purpose
of determining whether or not any goods
has been sold by a dealer in the course of
inter-state trade or commerce or in the
course of export out of the territory of
India:
3 All. Hyundai Engineering & Construction Ltd. Vs. Commissioner of Trade Tax, U.P., Lucknow
803

Provided that where at the time
of entry of goods into a local area, the
quantity or value of goods to be sold
within such local area for the purpose of
being taken outside the State without
consumption, use or sale in such local
area, is not ascertainable, the dealer shall
pay the amount of tax on the value of total
quantity of goods and after the goods are
consigned or sold outside or in the course
of, export, the dealer may claim refund or
adjustment of the amount so paid as tax in
the month in which such goods are
transferred outside the State or sold in the
course of inter-State trade or commerce
or the course of export, in respect of such
goods, in the manner provided in Section
5 of this act."

13. In the context of the New Act, it
is seen, each assessment year is a separate
and independent unit of assessment of
entry tax liability. As principle applicable
to taxing statutes it was recognised in the
context of the Income Tax Act in P.M.
Mohd. Meerakhan v. CIT, (1969) 2 SCC
25, wherein it was held:

"8 ... Under the Income Tax Act
for the purpose of assessment each year is
a self-contained unit and in the case of a
trading adventure the 14. profits have to
be computed in the manner provided by
the statute ... "

14. Same principle is applicable in
this case case as well. Thus tax liability
may arise in each unit/assessment year
only
with
respect
to
taxable
event/transaction completed therein. The
same has to be assessed for that
assessment year. Also, it has to be
discharged or recovered, as the case may
be, with reference to that assessment year
only.

15. Of its own, neither that taxable
event nor the tax liability arising thereon
continue, cascade or escape or telescope
into
the
following
year.
Unless
specifically provided by the legislature or
necessarily implied, subsequent facts or
events arising in preceding or succeeding
assessment years, have no bearing on
either the taxable event or the consequent
tax liability that may arise during any
assessment unit/year. Such legislature
intent and necessary intendment do not
exist. For that reason, the subsequent
event of export of machinery during the
A.Y. 2004-05 (after it had been made use
of during A.Y. 2000-01), would not have
any bearing on the taxing event that arose
in the year 2000-01 and stood completed
in that year itself.

16. Moreover, the scheme of the
New Act is very clear. Provisions
granting reversal of entry tax liability and
exemption from entry tax liability are
separately provided for under the New
Act. Thus, for any liability that may have
arisen and which the statute intended to
reverse has been specifically provided for
by means of Section 5 of the New Act. At
present such claim/s do not exist. Such
claim/s, if any, having not been raised
before the Tribunal, are not being dealt
with here.

17. In so far as sub-section 4 (6) of
the Act are concerned, it is true that the
legislature provided separate conditions
under Section 4(6)(i) and (ii) for the levy
of tax in different circumstances. Further,
it is also true that the condition of 'nonuse' of the goods was not a statutory precondition under sub-clause 2 of subsection 6 of Section 4 of the Act. Yet, that
difference in legislative intent would
remain
extraneous
and
therefore
804 INDIAN LAW REPORTS ALLAHABAD SERIES
irrelevant to the claim made by the
assessee, in this case. It is so, because
here the taxing event (entry of machinery
into the local area Allahabad), took place
and stood completed and concluded
during the A.Y. 2000-01 itself.

18. The subsequent event of sale or
re-sale of the machinery by way of export
sale was unconnected to that taxing event.
In any case, it took place much after close
of the A.Y. 2000-01. Therefore, that
separate event/transaction had no bearing
on
the
taxable
event
that
stood
irreversibly concluded. Therefore, the
consequent
tax
liability
remained
unaffected by the subsequent export of
the machinery.

19. Thus, the legal basis of the claim
raised by the assessee is found nonexistent. There is nothing to doubt the
existence of the tax liability and its
crystallization at the end of the A.Y.
2000-01. It also did not get diluted or
wiped out upon occurrence of export of
the machinery, in subsequent assessment
year.

20. In view of the above, questions
of law raised by the assessee are
answered thus: the factual and legal basis
of the claim raised by the assessee having
arisen more than three years after the
close of the assessment year 2000-01, the
same is wholly unfounded. The taxable
event occurred in and tax liability arose
upon the assessee having caused the entry
of machinery for use in the local area
Allahabad, during the A.Y. 2000-01. It
got crystallized on 31st March, 2001. The
event of subsequent export of machinery
outside the country during the A.Y. 200405, had no bearing on the unit of
assessment being the A.Y. 2000-01.

21. In view of the above, there is no
merit in the revision. It is accordingly,
dismissed. Costs easy.
----------
(2019)11ILR A804

APPELLATE JURISDICTION
CIVIL SIDE
DATED: ALLAHABAD 17.10.2019

BEFORE
THE HON'BLE BHARATI SAPRU, J.
THE HON'BLE ROHIT RANJAN AGARWAL, J.

Income Tax Appeal No. 251 of 2013
connected with
Income Tax Appeal Cases No. 268 of
2013, 269 of 2013, 221 of 2016, 242 of
2016 and 243 of 2016

Commissioner of Income Tax, Varanasi
 ...Appellant
Versus
M/s Poorvanchal Vidyut Vitaran Nigam
Ltd., Varanasi ...Respondent

Counsel for the Appellant:
S.S.C.I.T., Sri Manish Goyal, Sri R.K.
Upadhyay

Counsel for the Respondent:
Sri Ashish Bansal, Sri S.K. Garg

A. Income Tax Law-Income Tax Act,
1961 - Section 32, 260A - Whether the
ITAT is justified in law and facts in
holding that the assessee was entitled to
claim depreciation on the fixed assets
acquired on transfer scheme 2003 which
was not yet finalized/ascertained on the
fact that the actual assets are not
identifiable and not being used as well
as
their
full
title
have
not
been
transferred to the assessee?

U.P. Transfer of Distribution Undertaking
Scheme, 2003 provided for transfer of all the
assets and liabilities to four distribution
companies made after division of UPPCL.
Though the task of determination of item wise