# COMMISSIONER OF INCOME-TAX, DELHI v. S. TEJA SINGH

- **Citation:** [1959] Supp. 1 S.C.R. 394
- **Court:** Supreme Court of India
- **Decided:** 1959
- **Case number:** Civil Appca.l No. 122 of 1957
- **Bench:** T. L. Venkatarama Aiyar, P. B. Gajendragadkar, A. K. Sarkar
- **Source:** https://unisonlegal.in/judgment/supreme-court-of-india/commissioner-of-income-tax-delhi-v-s-teja-singh-1542
- **Pages:** 11

## Headnote

I ncome-tax-P enalty-N ew assessee-F ailure to send estimate
of tax-Absence of notice t-0 the assessee-Competency of Income-tax
Officer to levy penalty-Indian Income-tax Act, r922 (XI of r922),
ss. r8A(3), r8A(9), 22, 23, 28.
The respondent who had not been assessed to income-tax
prior to the assessment year 1948-49 made suo motu returns on
July 4, 1949, showing an income of Rs. 4,494 and Rs. 31,646
respectively, for the assessment years 1948-49 and 1949-50, but
failed to send an estimate of the tax on his income as provided
in s. 18A(3) of the Indian Income-tax Act, 1922. The Incometax Officer took action under s. 28 read withs. l8A(9) of the Act
and imposed a penalty on him for the years 1948-49 and 1949-50.
(1) S.C.R .. SUPREME COURT REPORTS
395
The Appellate Tribunal held that the order imposing the penalty
was ultra vires on the ground that s. 28 would, in terms, ar;ily
only when a person failed to furnish the return when he was required so to do by notice under s. 22 or s. 34 of the Act, and that
there could be no such notices with reference to estimates of tax
on income to be ·Sent under s. 18A(3). The High Court, on reference, agreed with the view of the Tribunal.
Held, that in view of the legal fiction contained in s. 18A(9)
of the Act that when an assessce has failed to comply with
s. 18A(3) he "shall be deemed to have failed to furnish the
return of his total income and the provisions of s. 28, so far as
may be, shall apply accordingly ", the failure to send an estimate
of the tax under s. 18A(3) should be treated as failure to furnish
return of income under s. 22.
Accordingly, it was cori1petent to
the Income-tax authorities to impose a penalty under s. 28 read
withs. 18A(9)(b) where there has been a failure to comply with
s. 18A(3).
The relevant provisions of the Indian Income-tax Act, 1922~
are set out in the judgment.

## Text

394
SUPREME COURT REPORTS
[1959] Supp.
r95B
his administrative capacity. It follows from this conclusion that all considerations flowing from the basic
Gullapalli
idea of the proceedings before the State Government
Nageswara Rao
d
l
h
h JI
f
and 011.,,.
being of a quasi-ju icia c aracter, are w o y out o
v.
the way. ·It must, therefore,' be held tha~ the order of
Andhra' Prade<h the State ·Government, impugned in this. case, is not
State Road Trans- open to any interference by the courtR. I would, thereport Corporation fore, dismiss the petition with costs.
and Another
·
Sinha ].
November 5.
ORDER
In view of the opinion of the majority the order approving the scheme is hereby quashed and a direction
issued to the 'first respondent to forbear from taking
over any of the routes in which the petitioners are
engaged in transport business. This will not preclude
the State Government from making the necessary enquiry in regard to the objections filed by the petitioners in accordance with law.
The petitioners will
have liberty to file additional objections, if any. The
parties to bear their own costs.
COMMISSIONER OF INCOME-TAX, DELHI
v.
S. TEJA SINGH
(T. L. VENKATARAMA AIYAR, P. B. GAJENDRAGADKAR
and A. K. SARKAR, JJ.)
I ncome-tax-P enalty-N ew assessee-F ailure to send estimate
of tax-Absence of notice t-0 the assessee-Competency of Income-tax
Officer to levy penalty-Indian Income-tax Act, r922 (XI of r922),
ss. r8A(3), r8A(9), 22, 23, 28.
The respondent who had not been assessed to income-tax
prior to the assessment year 1948-49 made suo motu returns on
July 4, 1949, showing an income of Rs. 4,494 and Rs. 31,646
respectively, for the assessment years 1948-49 and 1949-50, but
failed to send an estimate of the tax on his income as provided
in s. 18A(3) of the Indian Income-tax Act, 1922. The Incometax Officer took action under s. 28 read withs. l8A(9) of the Act
and imposed a penalty on him for the years 1948-49 and 1949-50.
(1) S.C.R .. SUPREME COURT REPORTS
395
The Appellate Tribunal held that the order imposing the penalty
was ultra vires on the ground that s. 28 would, in terms, ar;ily
only when a person failed to furnish the return when he was required so to do by notice under s. 22 or s. 34 of the Act, and that
there could be no such notices with reference to estimates of tax
on income to be ·Sent under s. 18A(3). The High Court, on reference, agreed with the view of the Tribunal.
Held, that in view of the legal fiction contained in s. 18A(9)
of the Act that when an assessce has failed to comply with
s. 18A(3) he "shall be deemed to have failed to furnish the
return of his total income and the provisions of s. 28, so far as
may be, shall apply accordingly ", the failure to send an estimate
of the tax under s. 18A(3) should be treated as failure to furnish
return of income under s. 22.
Accordingly, it was cori1petent to
the Income-tax authorities to impose a penalty under s. 28 read
withs. 18A(9)(b) where there has been a failure to comply with
s. 18A(3).
The relevant provisions of the Indian Income-tax Act, 1922~
are set out in the judgment.
CIVIL APPELLATE JURISDICTION: Civil Appca.l No.
122 of 1957.
Appeal from the order dated November 4, 1954, of
the Punjab High Court (Circuit Bench) at Delhi in
Civil Reference No. 15 of 1953.
R. Ganapathy Iyer, R. H. Dhebar and D. Gupta, for
the appellant.
P. M. Mukhi, Gopal Singh for Udhai Bhan Choudhry,
for the respondent.
P. M. Mukhi and Ganpat Rai, for Dahnia ,Jain
Aviation Ltd. (now Asia Udyog Ltd.) (Intervener).
1958. November 5. The Judgment of the Court was
delivered by
C01n1nissioner of
I nconie-tax
.v.
1"eja Singh
VENKA'l'ARAMA AIYAR, J.-This is an appeal against
Vcnk"t"rama
tho judgment of the High Court of Punjab in a referAiyar J.
cnce under s. 66(1) of the Indian Income-tax Act,
1922, hereinafter referred to as the Act.
The facts are that the respondent had not been
assessed to income-tax prior to the assessment year
1948-49. On July 4, 1949, he made suo motu returns
showing an income of Rs. 4,494 for the accounting
year 1947-48 being the previous year for the assessment year 1948-49 and an income of Rs. 31,646 for
396
SUPREME COURT REPORTS [1959] Supp.
the accounting year 1948-49 being the previous year
Commissioner of for the . assessment year 1949-50. By orders dated
Income-tax
August 25, 1949, the Income-tax Officer assessed the
v.
income for the. assessment year 1948.49 a.t Rs. 6,277
Teja Singh
and for the assessment year 1949-50 a.t Rs. 36,281.
Venkatarama
Aiyay j.
The correctness of these orders is not in question
before us. We are concerned in these proceedings with
the vires of an order, which the Income-tax Officer
made on October 9, 1950, under s. 28 read with
ss. 18A(3) and 18A(9) of the Act. It will be convenient
to set out these provisions, so fa.r as they a.re material
for the purpose of this appeal. Section 18A(3) provides
that:
"Any person who has not hitherto been assessed
~hall, before the 15th day of March in ea.ch financial
year, if his total income of the period which would be
the previous year for an assessment for the finanqia.l
year next following is likely to exceed six thousand
rupees, send to the Income-tax Officer a.n estimate of
the tax payable by him on that pa.rt of his income to
which the provisions of section 18 do not apply of the
said pi;evious year calculated in the manner la.id down
in sub-section (1), and shall pay the a.mount, on such of
the dates specified in that sub-section a.s have not
expired, by instalments which ma.y be revised according to the proviso to sub-section (2)."
Section 18A(9) is as follows:
"If the Income-tax Officer, in the course of any
proceedings in connection with the regular assessment,
is satisfied that any assessee-
(a) has furnished under sub-section (2) or subsection (3) estimates of the tax payable by him which
he knew or had reason to believe to be untrue, or
(b) has without reasonable ca.use failed to comply
with the provisions of sub-section (3),
the assessee shall be deemed, in the case referred to in
clause (a), to have deliberately furnished inaccurate
particulars of his income, and in the case referred to
in clause (b ), to have failed to furnish the return of his
total income; and the provisions of section 28, so far
as may be, shall apply accordingly:".
(l) S.C.R.
SUPREME COURT REPORTS
397
Then, there is a proviso which imposes a limit on the
amount of penalty, which can be levied. Section 28
of tho Act runs as follows :
(1) "If the Income-tax Officer, ...... in the course
of any proceedings under this Act, is satisfied that any
person-
( a) has without reasonable cause failed to furnish
the return of his total income which he was required to
furnish by notice given under sub-section (1) or subsection (2) of section 22 or section 34 or has without
reasonable cause failed to furnish it within the time
allowed and in the manner required by such notice, or
(b) has without reasonable cause failed to comply
with a notice under sub-section (4) of section 22 or subsection (2) of section 23, or
(c) has concealed the particulars of his incomo or
deliberately furnished inaccurate particulars of such
income,
he ... may direct that such person shall pay by
way of penalty, in the case referred to in clause (a), in
addition to the amount of the income-tax and supertax, if any, payable by him a sum not exceeding one
and a half times that amount, and in tho cases referred to in clauses (b) and (c), in addition to any tax
payable by him, a sum not exceeding one and a half
times the amount of the income-tax and super-tax, if
any, which would have been avoided if the income as
returned by such person had been accepted as the
correct income:".
The Income-tax Officer held that as the respondent
had failed to send an estimate of the tax on his income
as provided ins. 18A(3) he became liable to be proceeded against under s. 28, and accordingly imposed a
penalty of Rs. 40 for the year 1948-49 and Rs. 1,000
for the year 1949-50. On
appeal, the Appellate
Assistant Commissioner confirmed the order in so far
as it imposed a penalty for the year 1948-49 but set it
aside as regards the year 1949-50 on the ground that
by reason of the assessment for the year 1948-49 the
respondent ceased to be a new assessee for 1949-50, and
that, in consequence, s. 18A(3) had no application.
Against the order cancelling the penalty for 1949-50,
cc.m11zissionet of
Jncomeptax
v.
Teja Singh
V enleataranta
Aiyar ].
398
SUPREME COURT REPORTS [1959) Supp.
the Income-tax Officer preferred an appeal to the
Commissione. 1 Appellate Tribunal, which disagreed with the view of
Ineome·t•~
0 the Appellate Assistant Commissioner that the respondent was no longer a new assessee within s. 18A(3) of
Teja Singh
the Act, but held that the order of the Income-tax
Officer imposing a penalty under s. 28 was ultra vires,
.VenAatarama
b
h
Jd
J
J
h
v.
Aiyar ].
ecause t at section wou , in terms, app y on y w en
a person failed to furnish the return when he was
required so to da by notice under s. 22 or s. 34 of the
Act, and that there could be no such notices with
reference to estimates of tax on income to be sent
under s. 18A(3). In the result, the appeal was dismissed. On the application of the appellant, the Tribunal
referred the following question for the opinion of the
High Court:
"Whether on a true construction of Section 18A(9)
(b) read with section 28 of the Indian Income-tax Act,
1922, a penalty may be imposed for a total failure to
comply with the provisions of Section 18A(3) of the
said Act?"
The reference was heard by Bhandari, C. J., and
Falshaw, J., who agreed with the Tribunal that the
conditions as to notice laid down in s. 22(1) or s. 22(2)
must be satisfied even when action was sought to be
taken under s. 28 in respect of a failure t-0 comply
with s. 18A(3), and that as those conditions had not
been satisfied, the order imposing penalty was bad.
The appellant applied for a certificate under s. 66A(2)
of the Act, and the same was granted, and that is how
the appeal comes before us.
The sole question that a.rises for our determination
in this appeal is whether under s. 28(1) read with
s. 18A(9) of the Act, it is competent to the Income-tax
authorities to impose a penalty on a person who has
failed to comply with s. l8A(3) of the Act. In answering it in the negative, the learned Judges in the
court below w<o>re influenced almost exclusively by the
terms of s. 28 which they held did not co>er failure to
comply with s. l8A(3). Now, s. 28(1) provides for
penalty being imposed in three classes of cases which
are mentioned respectively in els. (a), (b) and (c).
Clause (b) deals with cases where there has been failure.
(1) S.C.R. SUPREME COURT REPORTS
399
to produce documents or accounts or other evidence
z95a
which the assessee ha.d been required to produce under Commissioner of
s. 22(4) ors. 23(2) of the Act, and that is not relevant
Income-tax
for the purpose of the present discussion.· Then, there
v.
a.re els. (a.) and (c), a.nd they have reference, stating it
Teja Singh
in plain language, cl. (a) to failure to make a return
Venkatarama
and cl. (c) to making false return. Now, the learned
Aiyar J.
Judges observe that if an estimate of the tax is furnished under s. 18A(3) and that is deliberately inaccurate, that will fall under s. 28(1Xc) read withs. 18A
(9)(a) and penalty could be imposed under that section,
but that that could not be done when there is failure
to furnish an estimate as required by s. 18A(3), because sub-s. (1) of s. 28 would apply only when a person
failed to furnish the return when he had been required
to do so. by notice under s. 22(1) ors. 22(2) ors. 34, or
ha.d failed to furnish it within the time allowed and in
the manner required by the notice, and that there
could be no such notice with reference to s. 18A(3).
Say the learned Judges:
" In the first place, a person who fails to send an
estimate under section 18A(3) cannot be said to have
failed to furnish the return of his total income which
he was required to furnish in response to a notice issued
under section 22 or section 34 ; secondly, the said
person cannot be said to have failed to furnish it
within the time allowed and in the manner required
by such notice, for, estimates under section 18A(3)
must be furnished before the 15th March in the financial year immediately preceding the year ,of assessment whereas the returns required by the notices
under sections 22 a.nd 34 can be furnished at later
dates."
With respect, the error in this reasoning lies in this
that it fails to give due effect to the fiction contained
in s. 18A(9)(b) of the Act.
Under that provision,
when an a.ssessee has failed to comply with s. 18A(3)
he" shall be deemed to have failed to furnish the
return of his total income a.nd the provisions of section
28, so far as ma.y be, shall apply accordingly." In
other words, by a legal fiction the faihre to send an
estimate of the tax under s. 18A(3) is treated as a
400
SUPREME COURT REPORTS [1959] Supp.
'958
failure to furnish return of income under s. 22. It is a.
Commission., of necessary implication of this fiction that the estimate
Income-tax
of ta.x on the income to be submitted under s. 18A(3)
v.
is, in fact, different from the return to be furnished
1'eja Singh
under s. 22, a.nd to appreciate the full significance of
this fiction, it is necessary to examine what the disVenkatarama
Aiyar J.
tinction is.
Under s. 3 of the Act, the tax is pa.ya.hie
on the income of the previous year. A statement of
that income can be furnished only a.fter that year ends,
a.nd s. 22 enacts provisions as to when it is to be furnished in the assessment year. ·sub-sections (1) and (2)
provide for notices being given and the assessee is
required to file his statement of income within the
period provided therein, and it is this statement that
is termed "return". Section 18A(3), however, relates
to the sending of a statement of tax on the income of
the accounting year before the 15th day of Ma.rch of
that year itself, and that statement is termed not a.
return but an estimate, and quite rightly, because in
the very nature of it, it ca.n only be that. A person
who sends an estimate under s. 18A(3) has also to send
a return of his income for the accounting year under
s. 22, and sub-ss. (4) and (5) of s. 18A provide for adjustment of advance tax pa.id under s. 18A(3) towards
the tax as finally computed under s. 23.
Thus, there
is a clear dist.inction between a return .of income under
s. 22, which can only be during the year of assessment
a.nd an estimate of tax on income under s. 18A(3),
which can only be in the year of account.
It is in the light of this distinction that the effect of
the legal fiction enacted in s. 18A(9)(b) that when a
person fails to send an estimate of tax on his income
under s. 18A(3) he shall be deemed to have failed to
furnish return of his income, will have to be judged.
The respondent contends that its effect is only to place
the estimate to be sent under s. 18A(3) on the same
footing a.s the return under s. 22 for purposes of s. 28,
· and that that does not abrogate the other conditions
la.id down in that section on which alone action could
be taken thereunder and penalty imposed, and one of
those conditions is the issue of notice under s. 22(1) or
s. 22(2). But it must be noted thats. 18A(9) (b) does
(I} S.C.R. SUPREME COURT REPORTS
401
not merely say ~hat an estimate under s. 18A(3) shall
I958
be deemed to be a. return. It enacts that the failure c
-. -.
d
t.
t .
d
"th
ISA(a) . t
ommissioner of
to sen an es 1ma e m a.ccor a.nee WI
s.
IS o
Income-ta;r
be deemed to be a failure to make a return.
Now,
v.
there can be no failure to make a. return, unless notice
Teja Singh
had been issued under s. 22(1) or s. 22(2) and there has
been a default in complying with that notice. ThereVenk•tarama
fore, the fiction that the failure to send an estimate is
Aiyar J.
to be deemed to be a failure to send a return necessarily involves the fiction that notice had been issued
under s. 22, and that had not been complied with. It
is a rule of interpretation well settled that in construing the scope of a legal fiction it would be proper and
even necessary to assume all those facts on which
alone the fiction can operate. The following oft-quoted observations of Lord Asquith in East End Dwellings
Oo. Ltd. v. Finsbury Borough Council (1) may appropriately be referred to :
"If you are bidden to treat an imaginary state of
affairs as real, you must surely, unless prohibited from
doing so, also imagine as real the consequences and
incidents which, if the putative state of affairs had in
fa.ct existed, must in~vitably have flowed from or
accompanied it. One of these in this case is emancipation from the 1939 level of rents.
The statute says
that you must imagine a certain state of affairs; it
does not say that having done so, you must cause or
permit your imagination to boggle when it comes to
the inevitable corollaries of that state of affairs."
The fiction under s. 18A(9) (b) therefore that failure to
send an estimate under s. 18A(3) is to be deemed to
be a failure to send a return must mean that all those
facts on which alone there could be a failure to send
the return must be deemed to exist, and it must accordingly be taken that by reason of this fiction, the notices
required to be given under s. i22 must be deemed to
have been given, and in that v~}V. s .. 28 would apply
on its own terms.
\
Some argument was addressed to us based on the
use of the definite article "the" qualifying the word
(1) [1952] A.C. 109, 132.
51
•
402
SUPREME COURT REPORTS [1959] Supp.
i95~
"return" in s. 18-A(9)(b). It was said that that expresCommissioner of sion meant the return which is to be furnished under
Income-lax
s. 22, and that that requires that there must have been
v.
a notice issued under s. 22(1) or s. 22(2), before action
Teja Siflgh
could be taken under s. 28. In the view expressed above
that the fiction enacted in s. 18-A(9)(b) involves the
Venkatarama
fiction that notices had been issued under s. 22(1) or
A~r~
d
s. 22(2), this contention oes not call for further consideration.
It was finally argued that a fiscal statute and especially one imposing a. penalty, should be Btrictly construed and that if the words of the enactment be not sufficiently explicit to reach the subject, the Revenue must
fail, and the following observations in Vestey's (Lord)
Executors v. Inland Revenue Commissioners(') were relied on in support of this position :
"Parliament in its attempts to keep pace with the
ingenuity devoted to tax avoidance may fall short of
its purpose.
That is a misfortune for the taxpayers
who do not try to avoid their share of the burden, and
it is disappointing to the Inland Revenue. But the
court will not stretch the terms of taxing Acts in order
to improve on the effOJ.'ts of Parliament and to stop gaps
which are left open by the statutes. Tax avoidance is
an evil, but it would be the beginning of much greater
evils if the courts were to overstretch the language of
the statute in order to subject to taxation people of
whom they disapproved."
These observations would be in point if the language
of the enactment left us in any doubt as to what the
legislature meant. But can that be said of s. 18-A(9)(b)?
Its object avowedly is to assimilate the position of a
person who has failed to send the estimate under
s. 18-A(3) to that of a person who has failed to furnish
the return under s. 22, and that object is sought to be
achieved by enacting the fiction which is contained in
s. 18-A(9)(b). And if, on the principles laid down in
East End Dwellings Co. Ltd. v. Finsbury Borough Council ('), the true effect of that fiction is that it imports
that notice had been issued under s. 22, then the conditions prescribed in s. 28 of the Act are satisfied and
(1) (1949] l All E.R. II08, II20.
(2) (1952] A.C. 109, 132.
(1) S.C.R. SUPREME COURT REPORTS
403
penalty could be imposed under that section for failure
r95B
to comply with s. 18-A(3), on tho clear language of Commissioner of
that enactment itself without straining or overstretchIncome-tax
~lli
~
We must now refer to an aspect of the question,
Teja Singh
which strongly reinforces the conclusion stated above.
Venkatarama
On the construction contended for by the respondent,
Aiyar J.
s.18-A(9)(b) would become wholly nugatory, as ss. 22(1)
and 22(2) can have no application to advance estimates to be furnished under s. 18-A(3), and if we accede
to this contention, we must hold that though the legislature enacted s. 18-A(9)(b) with the very object of
bringing the failure to send estimates under s. 18-A(3)
within the operation of s. 28, it signally failed to achieve its object. A construction which leads to such a
result must, if that is possible, be avoided, on the
principle expressed in the maxim, "ut res magis. valeat
quam pereat". Vide Curtis v. Stovin(1) a.nd in particular the following observations of Fry, L. J., at
page 519:
"The only alternative construction offered to us
would lead to this result, that the plain intention of
the legislature has entirely failed by reason of a slight
inexactitude in the language of the section. If we were
to adopt this construction, we should be construing
the Act in order to defeat its object rather than with
a view to carry its object into effect".
Vide also Craies on Statute Law, p. 90 and Maxwell on
The Interpretation of Statutes, Tenth Edn., pp. 236-237.
"A statute is designed", observed Lord Dunedin in
Whitney v. Commissioners of [nl,and Revenue (2), "to be
workable, and the interpretation thereof by a court
should be to secure that object, unless crucial omission
or clear direction makes that end unattainahle".
We are accordingly of opinion that it was competnnt
to the Income-tax authorities to impose a penalty
under s. 28 read withs. 18-A(9)(b) where there has been
a failure to comply with s. 18-A(3).
In the result, we set aside the order of the court
below and answer the reference in the affirmative.
(1) [1889] 22 Q.B.D. 513.
(2) [1925] ro Tax Cas. 88, uo.
•
404
SUPREME COURT REPORTS [1959] Supp.
x958
The appellant will have his costs here and in the court
Commissioner of below·
ln,omeo/ax
Appeal allowed.
•
v.
-Teja Singh
V enkataram a
Aiyar ] .
November 7.
THE SPECIAL LAND ACQUISITION OFFICER,
BANGALORE
v.
T. ADINARAYAN SETTY
(JAFER IMAM, S. K. DAS and J. L. KAPUR, JJ.)
Land Acquisition-Principles of valuation-Exemplars, use
of-Land Acquisition Act, I894 (l of I894), ss. II and 23.
Certain land belonging to the respondent was compulsorily
acquired by the Government for a maternity hospital.
Most of
the land consisted of building sites but there was a building on a
small portion of the land and a portion was low lying-land. The
Special Land Acquisition Officer held, on the basis of the value of
sites previously sold by the respondent, that the market value of
the land was Rs. IO/- per sq. yard and awarded a sum of
Rs. l,41,169/- to the respondent as compensation. He did not
give any compensation for the low lying land or for the building.
Against this award the respondent raised an objection and a
reference was made to the District Judge. The District Judge
accepted the rate of Rs. IO/- per sq. yard as fair, reduced the
amount of deductions for providing electric installations by
Rs. lO,ooo/- and allowed a sum of Rs. 10,000/- for the low lying
area at the rate of Rs. 3/- per sq. yard, thereby increasing the
amount of compensation by Rs. 20,000/-. Not being satisfied the
respondent appealed to the High Court. The High Court held
that the rate of compensation for the land except the low lying
portion, should be Rs. 13/8/- per sq. yard and for the low lying
portion it should be Rs. 8/8/- per sq. yard. It further awarded
a sum of Rs. 7,000/- for the building. In arriving at the figure
of Rs. 13/8/- the High Court took into account only four sale
transactions which had been made by the respondent at the rates
of Rs. 12, 15, 14 and 7/8/- per sq. yard but did not take into consideration two other, transactions which had been made by the
respondent at the rates of Rs. 6/8/- and Rs. 10 per sq. yard. . It
calculated the average of the four transactions to be Rs. 12/2/-
per sq. yard and then took a second average between Rs. 15/-,
..