# M/S Bindal Smelting Pvt. Ltd. Revisionist v. Commissioner of Trade Tax Lucknow

- **Citation:** (2022) 7 ILRA 958
- **Court:** High Court of Judicature at Allahabad
- **Decided:** 2022-07-04
- **Case number:** Sales/Trade Tax Revision No. 2 of 2005
- **Bench:** Alok Mathur
- **Source:** https://unisonlegal.in/judgment/allahabad-high-court/m-s-bindal-smelting-pvt-ltd-revisionist-v-commissioner-of-trade-tax-lucknow-48683
- **Pages:** 8

## Headnote

A. Tax Law - U.P. Trade Tax Act, 1948 -
Section 4(A) - The Eligibility Notification lay
down
conditions
for
seeking
benefit
of
Exemption Notification, which have to be
fulfilled and are mandatory in nature and have
to be strictly complied with by the dealer if he
wishes to claim exemption. In case any of the
conditions are not fulfilled, same would disentitle the dealer from being granted benefit
under the said notification.

B. Tax Law - Central Sales Tax Act-
Section 10 - Cannot be imposed unless
there is an element of mens rea and the
goods
have
been
purchased
under
bonafide belief or under mistake of fact.
Revision dismissed. (E-12)

List of Cases relied upon:-

## Text

958 INDIAN LAW REPORTS ALLAHABAD SERIES
before passing of decree and this view has
also been upheld by the this Court in the
matter of Kisan Udyog vs. United Bank of
India; 1989 0 Supreme(All) 233. Relevant
paragraph No. 4 of the said judgment is
quoted below:-

"4 . In the instant case the plaintiff
has filed a suit for the recovery of Rs. 52479/-
together with interest at the rate of 13% per
annum. This amount has been claimed in
view of the alleged advance having been
made. It is alleged on behalf of the plaintiff
that the defendants executed an agreement. In
any case it is for the plaintiff to satisfy the
court that the amount is due and is
recoverable from the defendants. No doubt,
the defendants may resist the claim in the
Court. However, if by such a refusal to frame
issues a serious prejudice is being caused to
the plaintiff or the defendants then it is
always expedient for the trial court to
exercise its jurisdiction in framing such issues
to facilitate the parties to adduce evidence in
the light of pleadings on the basis of which
issues were framed. In the instant case I do
not find that any prejudice would be caused
to the defendant applicant. It is the
discretionary power of the trial court to frame
additional issues if it finds it necessary for
determining the list between the parties but
merely refusal to frame additional issues does
not give a right to the parties to prefer a
revision as by such refusal Jo frame such
additional issues neither the rights nor the
obligations of the parties are adjudicated
upon. As no right or obligation of a party is
determined by refusal to frame additional
issues it cannot be held to be deciding a case
so as to attract the expression "case which has
been decided."

18. Therefore, it is upon the Court to
have a new point of determination before
pronouncing the judgment, if so required and
there is no illegality in the observations made
by the Court below in the impugned order.

19. From the perusal of impugned
order, it is very much clear that SCC Court
has rightly held that in the light of Order L
Rule 1 of Code, 1908, there is no provision
for framing issues and provisions of Order
XIV Code, 1908 shall not be applicable. It is
also held that in impugned order, revisionistdefendant has not claimed himself to be the
owner of property and co-owner/landlord
may also have the right to file suit for
eviction, therefore, there is no issue of title
between tenant and landlord before SCC
Court. On facts too, there is no illegality in
the order impugned. It has been rightly held
in the impugned order that point of
determination was framed on 06.03.2018
agreed between the parties and after closer of
evidence, filing of such application is nothing
but an attempt to linger on the proceeding.

20. Therefore, in the light of discussions
made here-in-above about the law and facts, I
found no good reason to interfere in the
impugned order. Revision lacks merit and is
accordingly, dismissed.

No order as to costs.
----------
(2022)07ILR A958
REVISIONAL JURISDICTION
CIVIL SIDE
DATED: LUCKNOW 04.07.2022

BEFORE

THE HON'BLE ALOK MATHUR, J.

Sales/Trade Tax Revision No. 2 of 2005

M/S Bindal Smelting Pvt. Ltd.
 ...Revisionist
Versus
Commissioner of Trade Tax Lucknow
 ...Opposite Party
7 All. M/S Bindal Smelting Pvt. Ltd. Vs. Commissioner of Trade Tax Lucknow
959
Counsel for the Revisionist:
P. Agrawal

Counsel for the Opposite Party:
C.S.C.

A. Tax Law - U.P. Trade Tax Act, 1948 -
Section 4(A) - The Eligibility Notification lay
down
conditions
for
seeking
benefit
of
Exemption Notification, which have to be
fulfilled and are mandatory in nature and have
to be strictly complied with by the dealer if he
wishes to claim exemption. In case any of the
conditions are not fulfilled, same would disentitle the dealer from being granted benefit
under the said notification.

B. Tax Law - Central Sales Tax Act-
Section 10 - Cannot be imposed unless
there is an element of mens rea and the
goods
have
been
purchased
under
bonafide belief or under mistake of fact.
Revision dismissed. (E-12)

List of Cases relied upon:-

1. Commissioner of Income-tax, Amritsar Vs
Straw Board Manufacturing Co. Ltd., [1989]
Supp. 2 S.C.C. 523

2. Bajaj Tempo Ltd. Bombay Vs Commissioner of
Income-tax, Bombay City - III, Bombay, [1992]
3 S.C.C. 78

3. Akross Synthetics Pvt. Ltd. Vs Commissioner
of Trade Tax, U.P., Lucknow, (2008) 13 VST 504
(All)
(Delivered by Hon'ble Alok Mathur, J.)

1. Heard Sri Pradeep Agrawal, learned
counsel for the revisionist as well as Sri Rohit
Nandan Shukla, learned counsel for the
opposite party.

2. Present revision under Section 11 of
the U.P. Trade Tax Act, 1948, has been
preferred assailing order dated 05.11.2004,
passed by the Commercial Tax Tribunal, U.P.,
Lucknow (hereinafter referred to as "the
Tribunal"), on the following questions of law
:-

i) Whether the learned Tribunal was
justified in not considering the decision of this
Hon'ble Court in the case of Kanhaiya
Beverages Pvt. Ltd. wherein it has been
specifically held that the ownership of the land
in the name of the Promotor Director can be
considered to be the land of the unit and the
grant of eligibility certificate can not be
refused.

ii) Whether the learned Tribunal
was justified in not considering the fact that
the final registration with the Industries
Department was in continuation of the
provisional registration granted in 1996 and
2001.

iii) Whether the learned Tribunal
was justified in twisting the fact of the case
and without proper appreciation of fact has
recorded the perverse finding which has
vitiated the law.

iv) Whether the learned Tribunal
was justified in holding that the plot no.F-63
allotted in favour of Ajay Kumar Gupta
Promotor Director in 1994 will not be deemed
to be the plot of the unit until it is registered in
the name of unit.

v) Whether the learned Tribunal was
justified in holding that the registration of the
plot in the name of unit and the amendment in
the registration certificate of the Industries
Department are the material dates and as such
the applicant is not entitled to exemption under
Section 4-A of the Act in view of notification
no. 3867 dated 22.12.2001.

vi) Whether the Tribunal was
justified in not considering the basic legislative
intent of the provisions of Section 4-A
granting incentives for promoting growth and
development should be liberally construed.

vii) Whether the learned Tribunal
was justified in ignoring the law laid down
by the Apex Court as well as by this
960 INDIAN LAW REPORTS ALLAHABAD SERIES
Hon'ble Court and passed the impugned
order
on
the
basis
of
extraneous
consideration
which
has
vitiated
the
findings recorded in the impugned order.

3. The revisionist is a smelting unit
being run on Plot number 64 Industrial
Area Surajpur Site B Greater Noida and
had applied under Section 4 [a] of the UP
Trade Tax Act (hereinafter referred to as
"the Act") for grant of exemption from
payment of trade tax under facility
available to a newly set up industry. The
said application was duly considered by
the
Divisional
Level
Committee
constituted in this regard, and rejected on
the ground that the applicant did not
fulfill the conditions laid down in the
notification
dated
22/12/2001.
The
application for review was also rejected
and
consequently
the
revisionist
approached the Full Bench of the
Tribunal which rejected the appeal by
means of the order dated 05/11/2004,
which has been assailed before this court
in the present revision.

4. Sri Pradeep Agarwal counsel for
the
revisionist
submitted
that
the
application for exemption under Section
4 of the Act was rejected on two grounds,
firstly that the adjacent plot number F 63
was transferred to the revisionist after the
due date prescribed in the exemption
notification dated 22.12.2001, and also
that Sri Ajay Kumar Gupta who was the
director of the revisionist and also lessee
of plot number 63 did not have any right
to transfer the same in favour of the
revisions and hence the land was illegally
and improperly transferred in name of the
revisionist, and secondly the machinery
used by the revisionists was not new
machinery as prescribed in the exemption
notification but old machinery which had
been used thereby dis-entitling them for
the benefit of the said exemption.

5. The first ground for rejection of the
application for exemption was that plot
number F 63 was allotted in favour of Sri
Ajay Kumar Gupta who was the promoter
Director
of
the
revisionist
firm
on
17/01/1994
by
U.P.
State
Industrial
Development
Corporation
(hereinafter
referred
to
as
"the
UPSIDC")
and
subsequently it was is said to have been
transferred to the revisionist by means of an
agreement to sell dated 25/11/99. The
UPSIDC granted permission to Sri Ajit
Kumar Gupta to transfer the plot number F
63 by means of its letter dated 17/12/2001
In favour of the revisionist and it was
subsequently registered with the Industries
Department on 25/03/2002.

6. The above facts were considered by
the Tribunal and while dismissing the
appeal, recorded a finding that Sri Ajay
Kumar Gupta could not have transferred
the said land in favour of the revisionist
prior to 17.12.2001 as the lease agreement
clearly stipulated In clause 4(j) that
"licensee will not directly or indirectly
transfer, assign, sale, encumber or part with
his interest under or benefit of this
agreement or any part thereof in any
manner whatsoever without the previous
consent in writing of the grantor and it shall
be open for the grantor to refuse such
consent or grant the same subject to such
conditions and may be laid down by the
grantor in that behalf"

7. The Tribunal was of the considered
view that in light of the aforesaid
restrictions the land could not have been
transferred in favour of the revisionist. It
also rejected the existence and validity of
the agreement to sell and that Sri Ajay
7 All. M/S Bindal Smelting Pvt. Ltd. Vs. Commissioner of Trade Tax Lucknow
961
Kumar Gupta was not the owner of the said
land and therefore could not have executed
an agreement to sale, which was also an
unregistered document, and the original
was never brought on record, and the same
was never produced before the Divisional
Level
Committee
along
with
the
application for exemption and its very
existence was therefore held to be doubtful.
In light of the above facts the Tribunal
rejected the contention of the applicant
holding that plot number F 63 was not
validly transferred to the revisionist and
hence the conditions mentioned in the
notification Dated 22.12.2001 were not
fulfilled and therefore did not find any fault
with the findings recorded by the division
level committee rejecting the application of
the revisionist.

8. Sri Pradeep Agarwal assailing the
findings of the Tribunal submitted that
according
to
the
notification
dated
22.12.2001, Clause (b) all the conditions
provided that the "unit has obtained land
from any source".

9. The notification dated 22nd
December, 2001 is reproduced hereinafter:-

"UTTAR
PRADESH
SHASAN
KAR AVAM NIBANDHAN ANUBHAG-2
The Governor is pleased to order the
publication
of
the
following
English
translation of Government Notification No.
KA.NI. -2-3867/XI -9(116)/94 - U.P. Act -
15-48 - Order -(74)- 2001 dated :
December
22,
2001,
for
general
information:

NOTIFICATION No. KA.NI. -23867/XI -9(116)/94 - U.P. Act -15-48 -
Order -(74)- 2001 Dated : Lucknow :
December 22, 2001 WHEREAS the State
Government is of the opinion that for
promoting the development of certain
industries in the State, it is necessary to
grant exemption from, or reduction in rate
of, tax to new units and also to units which
have
undertaken
expansion
or
diversification:

NOW, THEREFORE, in exercise
of the powers under Section 4-A of the
Uttar Pradesh Trade Tax Act, 1948 (Act
No.XV of 1948), the Governor is pleased to
declare that subject to the conditions and
restrictions referred to in Section 4-A of the
said Act and in notifications issued from
time to time thereunder and subject to the
fulfilment on March 31, 2000, by the
concerned unit the conditions specified in
this notification,-

(a) in respect of any goods
manufactured in a new unit whose date of
starting production falls on or after April 1,
2000 but no later than December 31, 2001,
no tax shall be payable, or as the case may
be, the tax shall be payable at the reduced
rate, by the manufacturer thereof on the
turnover of sales of such goods from the
date of first sale or the date following the
expiration of six months from the date of
starting production whichever is earlier.

(b) in respect of any goods
manufactured
in
a
unit
which
has
undertaken expansion and the date of
production in excess of the base production
falls on or before March 31, 2000, no tax
shall be payable, or as the case may be, the
tax shall be payable at the reduced rate, by
the manufacturer thereof on the turnover of
sales of the quantity of goods manufactured
in excess of the base production.

(c) in respect of any goods
manufactured
in
a
unit
which
has
undertaken diversification and the date of
production of goods of a nature different
from those manufactured earlier by such
units falls on or before March 31, 2000, no
tax shall be payable, or as the case may be,
the tax shall be payable at the reduced rate
962 INDIAN LAW REPORTS ALLAHABAD SERIES
by the manufacturer thereof on the turnover
of sales of goods, which are of a nature
different from those, manufactured by the
unit earlier:

Provided that the unit intending
to claim tax relief under this notification
shall intimate in writing accordingly to the
assessing authority within 20 days from the
date of this notification.

CONDITIONS

(a) the unit is registered/licensed
under Industry Department or unit has
obtained letter of intent or letter of will
from Government of India;

(b) the unit has obtained land
from any source;

(c) the unit has applied for a term
loan from any regular Financial Institution.

By order (T. George Joseph)
Pramukh Sachiv"

10. Admittedly the provisions for
exemption from Sales Tax have been
introduced in the Act for the purpose of
increasing the production of goods and for
promoting the development of industries in
the State. In fact, when the scheme called
"Grant of Sales-tax Exemption Scheme 1982
to industrial units under Section 4-A of the
Sales-tax Act" was originally framed, it was
expressly stated that the Government granted
the facility of exemption in order to
encourage
the
capital
investment
and
establishment of industrial units in the State.
The Scheme contained various rules for grant
of such exemption. The Section itself has
referred to the purpose for which the
Government could grant such exemption.
Sub-Section (1) of Section 4-A prescribes the
maximum period for which the exemption
could be granted as 7 years. As per the
section, such exemption should commence
from the date of first sale by such
manufacture if such sale takes place within
six months from the date of starting
production and in any other case from the
date following the expiration of six months
from the date of starling production. The
expression "date of starting production" has
been defined in the explanation as the date on
which any raw material required for use in
the manufacture or packing of the goods is
purchased for the first time. The term "new
unit" used in the Section has also been
defined in the explanation. The revisionist has
submitted that it fulfilled the relevant
conditions at the time when it applied for
exemption. Such period was to be reckoned
from the dale of first sale if such sale took
place not later than six months from the date
starting production and in other cases from
the date following the expiration of six
months from the date of starting production
subject to the condition that the unit had not
discontinued production of such goods for a
period exceeding six months at a stretch in
any assessment year.

11. Sri Pradeep Agarwal, learned
counsel for the revisionist submitted that
the provision of the exemption notification
deserve liberal consideration and the
revisionist was validly transferred the land,
which was already alloted to its DirectorPromotor and there is no illegality in the
same. He relied on the agreement to sell
and submitted that the plot was transferred
prior to the cut off date prescribed in the
exemption notification, and hence he
fulfilled all the conditions as laid down in
the said notification. With regard to the old
machinery, it was submitted that the same
was not used in the manufacturing process
and hence has assailed the findings
recorded by the authority below and urged
this Court to set aside the judgment of the
Tribunal.

12. Learned counsel appearing for the
Revenue
has
supported
the
findings
7 All. M/S Bindal Smelting Pvt. Ltd. Vs. Commissioner of Trade Tax Lucknow
963
recorded by the authorities below and
prayed that the revision deserves to be
dismissed.

13.

Considering
the
above
submissions, it is necessary to interpret the
exemption notification and to analyze its
provisions in order to determine as to
whether the conditions laid down would be
directory or mandatory.

14. In Commissioner of Income-tax,
Amritsar v. Straw Board Manufacturing
Co. Ltd., [1989] Supp. 2 S.C.C. 523, the
Supreme Court held that in taxing statutes,
provision for concessional rate of tax
should be liberally construed. So also in
Bajaj
Tempo
Ltd.
Bombay
v.
Commissioner of Income-tax, Bombay
City - III, Bombay, [1992] 3 S.C.C. 78, it
was held that provision granting incentive
for promoting economic growth and
development in taxing statutes should be
liberally construed and restriction placed on
it by way of exception should be construed
in a reasonable and purposive manner so as
to advance the objective of the provision.

15. We find that the object of granting
exemption from payment of sales tax has
always been for
encouraging capital
investment and establishment of industrial
units for the purpose of increasing
production of goods and promoting the
development of industry in the State.

16. The exemption notification dated
22.12.2001,
was
also
subject
to
consideration before this Court in the case
of Akross Synthetics Private Limited Vs.
Commissioner
of
Trade
Tax,
U.P.,
Lucknow, (2008) 13 VST 504 (All), where
this Court has held as follows :-

"13. Perusal of the Notification
No. KA-NI-2-2591, dated August 24, 2000
and the Notification No. KA-NI-2-3867,
dated December 22, 2001 reveals that in
both the notifications there was a condition
that the unit should apply for term loan
from any regular financial institution: As
per notification dated August 24, 2000 this
condition was to be fulfilled on January 17,
2000 and as per Notification No. KA-NI-23867, dated December 22, 2001 this
condition was to be fulfilled on March 31,
2000. Admittedly, the applicant had not
applied for term loan prior to March 31,
2000. The term loan was applied after May
26, 2000 by the applicant-company much
after March 31, 2000. In the circumstances,
the
applicant
could
not
fulfil
the
requirement of the notification for the grant
of exemption. It is nobody's case that the
term loan was sanctioned in pursuance of
the applications moved in the year 1994.
The term loan was sanctioned in pursuance
of the application moved by the company
much after March 31, 2000.

14. The "new unit" established
after March 31, 1990 is defined by the
Explanation II to section 4A of the Act,
which says that the new unit after March
31, 1990 means a factory or workshop set
up by a dealer after such date and
satisfying the conditions laid down under
this Act or Rules or Notifications made
thereunder with regard to such factory or
workshop and includes an industrial unit
manufacturing the same goods at any other
place in the State or an industrial unit
manufacturing any other goods on, or
adjacent to the site of an existing factory or
workshop but does not include.

15. The above definition provides
that only those units which fulfil the
conditions laid down in the notifications
issued under the Act or Rules are said to be
"new units" and eligible for exemption
under section 4A of the Act. Thus,
fulfilment of" conditions mentioned in the
964 INDIAN LAW REPORTS ALLAHABAD SERIES
notifications is mandatory and to be strictly
complied with.

16. In the case of Novopan India
Ltd., Hyderabad v. Collector of Central
Excise and Customs, Hyderabad reported
in 1994 Supp (3) SCC 606, apex court held
as follows:

"16. We are, however, of the
opinion that, On principle, the decision of
this court in Mangalore Chemicals, [1991]
83 STC 234 (SC); 1992 Supp (1) SCC 21
and in Union of India v. Wood Papers Ltd.,
[1991] 83 STC 251 (SC); 1990 SCC (Tax)
422 referred to therein-- represents the
correct view of law. The principle that in
case of ambiguity, a taxing statute should
be construed in favour of the assessee--
assuming that the said principle is good
and
sound--does
not
apply
to
the
construction of an exception or an
exempting provision; they have to be
construed strictly. A person invoking an
exception or an exemption provision to
relieve him of the tax liability must
establish clearly that he is covered by the
said provision. In case of doubt or
ambiguity, benefit of it must go to the State.
This is for the reason explained in
Mangalore Chemicals, [1991] 83 STC 234
(SC); 1992 Supp (1) SCC 21 and other
decisions,
viz.,
each
such
exception/exemption
increases
the
tax
burden on other members of the community
correspondingly. Once, of course, the
provision is found applicable to him, full
effect must be given to it. As observed by a
Constitution Bench of this court in Hansraj
Gordhandas v. H.H. Dave, [1969] 2 SCR
253; AIR 1970 SC 755, that such a
notification has to be interpreted in the
light of the words employed by it and not
on any other basis. This was so held in the
context of the principle that in a taxing
statute,
there
is
no
room
for
any
intendment, that regard must be had to the
clear meaning of the words and that the
matter should be governed wholly by the
language of the notification, i.e., by the
plain terms of the exemption."

17. In the case of State Level
Committee v. Morgardshammar India Ltd.
reported in [1996] 101 STC 1 (SC); [1996]
UPTC 213; the apex court held that section
4A of the Act provides for exemption from
tax and is to be construed strictly.

18. In the case of Kartar Rolling
Mills v. Commissioner of Central Excise,
New Delhi reported in (2006) 4 SCC 772,
apex court held that the exemption
notification is to be construed strictly.

19. In view of the above, for the
claim of exemption it is necessary to
comply with the conditions mentioned
under the provisions of section 4A of the
Act and the notifications issued thereunder.
It is on the dealer; who claims the
exemption to establish that the conditions
of the notifications are fulfilled. If any of
the condition is not fulfilled, the exemption
cannot be allowed. As referred hereinabove
dealer was not able to fulfill the conditions
of the notifications on the day on which it
was required to be fulfilled and, therefore,
the exemption has rightly been refused: In
the circumstances, no interference is called
for.

20. In the result, revision fails
and is accordingly, dismissed."

16.

Considering
the
aforesaid
judgments with regard to the manner of
interpretation
of
the
Exemption
Notification, it is noticed that the Eligibility
Notification lay down conditions for
seeking benefit of Exemption Notification,
which have to be fulfilled and are
mandatory in nature and have to be strictly
complied with by the dealer if he wishes to
claim exemption. In case any of the
conditions are not fulfilled, same would
7 All. M/S Indian Farmers Fertilizer Cooperative Limited Aonla Vs. Commissioner of
 Commercial Tax Lucknow, U.P.
965
dis-entitle the dealer from being granted
benefit under the said notification.

17. Applying the aforesaid to the facts of the
present case, it is noticed that even though the land
did not belong to the Promotor/Director of the
revisionist firm, but the same was sought to be
transferred to the revisionist and that transfer can
be said to have been completed on 17.01.2001,
when UPSIDC directed for transfer of plot no. F63 in favour of the revisionist firm. It cannot be
said that prior to 17.01.2001, the land was
transferred in favour of the revisionist. The validity
of the agreement to sell dated 25.11.1999, has
been doubted by the Tribunal as the original copy
was never produced before the Tribunal nor were
the documents produced before the Divisional
Level Committee, which was considering the case
of the revisionist firm. Even before this Court no
material has been placed so as to doubt the
correctness of findings recorded by the Tribunal
and hence there is no material before this Court to
interfere with the concurrent findings of
authorities below that the condition required for
transfer of land was not completed prior to last
date i.e. 31.01.2000.

18. In this view of the matter, for the reasons
recorded above, no interference is required with
the findings recorded by the Tribunal that the land
was not transferred prior to cut off date prescribed
in the exemption notification dated 22.12.2001.

19. The second contention raised by learned
counsel for the revisionist that old machinery was
not used in the process of manufacture and it is
only 'accessories', and on this basis has assailed the
findings recorded by the Tribunal.

20. It is noticed that findings of the Tribunal
were based upon the spot inspection report, where
the manufacturing process was carefully observed
and it has been recorded that 'cranes' were used for
lifting of boxes and was also used in the process of
manufacture. Hence it cannot be said that findings
of the Tribunal are perverse or without any
material.

21. Per contra in this regard it has only been
submitted on behalf of revisionist that transformer,
voltage stabilizer, motor and blower and EOT
Crane are not used in the process of manufacture.
The said spot inspection report has not been
disputed by the revisionist at any stage of the
proceedings and categorical finding has been
recorded in the spot inspection with regard to use
of old machinery which was found to be used in
the manufacture process, hence revisionist would
not be entitled for the benefit of the Exemption
Notification.

21. It is also noticed that one of the
condition required for grant of exemption was that
the unit should be registered with the Industries
Department and both the plots were jointly
registered with the Industries Department on
21.03.2001, which is clearly beyond 31.03.2000,
which is cut-off date, and consequently for all the
aforesaid reasons, it is noted that revisionist did not
fulfill the conditions before the cut-off date fixed
and hence is not entitled for exemption.

22. No question of law arise for
adjudication in this revision. Accordingly
present revision is dismissed.
----------
(2022)07ILR A965
REVISIONAL JURISDICTION
CIVIL SIDE
DATED: LUCKNOW 04.07.2022

BEFORE

THE HON'BLE ALOK MATHUR, J.

Sales/Trade Tax Revision No. 7 of 2011

M/S Indian Farmers Fertilizer Cooperative
Limited Aonla ...Revisionist
Versus
Commissioner
of
Commercial
Tax
Lucknow, U.P. ...Opposite Party