# P. N. KRISHNA IYER v. COMMISSIONER OF INCOME-TAX, KERALA

- **Citation:** [1969] 1 S.C.R. 943
- **Court:** Supreme Court of India
- **Decided:** 1968-09-03
- **Bench:** J. C. Shah, V. Ramaswami, A. N. Grover
- **Source:** https://unisonlegal.in/judgment/supreme-court-of-india/p-n-krishna-iyer-v-commissioner-of-income-tax-kerala-4542
- **Pages:** 8

## Headnote

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Indian Income-tax Act, 1922, s. 3 and
s.
33B-Hindu
undivided
family business taken over by
company~Karta appointed . Governing
Director-Salary, Commissioner 'sitting fee' of Governing Director whether assessable in hands of Hindu undivided family-Principles for dtciding--Commissioner's powers under. s. 33B-Scope of.
The appellant, on partition of joint family property between himself
and his brothers, got as his share the family's motor transport business
which had been established by his efforts, along with 'the workshop, stores,
agency, cinema companies etc.'
The Hindu undivided family c~nsisting
of the appellant and his sons tran·sferred the motor transpo'rt busmes~ to
a private limited company; the company credited the account of
the
family in its books with the value of the asscls of the business taken over
by it.
With family money !he appellant purchased 100 shares. of the
company and was appointed-according to tne terms of the Articles of
ASsociation-as its Governing Director for hfe. at a salary of Rs. 3,000
per month with 15% commission on net profits. He was also in lieu of
his experienc~ and his serviecs to the business, allotted 4,880 fully paid np
shares of the company; the dividend from these, when declared,
was
credited to the account o.f the Hindu undivided family.
In proceedings
for assessment the Income-tax Officer brought to tax in the assessment year
1954-55 the remuneration received by the appellant from the com~any
together with the commission, sitting fee, and income from property business and other sources as the separate income of
tile
appellant.
The
Appellate Assistant Commissioner modified the order and in carrying out
his directions the Income-tax Officer included the income from property
business and other sources in the income of the Hindu undivided family
and made corresponding modifications in the assessment of the appellant
as an individual.
But the Commissioner of Income-tax being of the
opinion that the order of the Income-tax OfBcer was prejudicial to the
revenue revised the said order under s. 33B of the Income-tax Act, 1922
and included the appellant's income from salar:;, commission and 'silting
fee' in the total income of the Hindu undivided family.
The Trfounal
reversed the order of the Commissioner.
In reference the High Court
upheld the order of the Commissioner.
The appel1ant in his capacity
as karta of the family appealed to the Supreme Court and contended :
(i) that the Commissioner had no power under s. 33B to revise the order
of the Income-tax Officer after it had been carried in appeal to the Appellate Assistant Commissioner, n.o'r could he tcvbe an order made by the
Income-tax Officer in pursuance of the direction by the Appellate Ass13tant
Commissioner; (ii) that the salary, commission and 'sitting fee' were his
individual income and not that of the Hindu Undivided Family;
HELD : (i) There was no ground for holding that the Commissioner
had attempted to revise the order of the Appellate Assistant Commissioner.
In computing the income of the appellant as an individual the Appellate
.A·ssistant Commissioner had directed ce'rtain mod1ftcations to be rnade,
and pursuant thereto the asses.sments of the appellant and of the llindu
undivided family of which the appellant was the karta were rectified.
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• 944
St;PREME conn REPORTS
(1969] I S.C.R
The oi:der of assessment of the Hindu undivided famil 1 was never chalA
fengcd in appeal.
·1ne (~ommissioncr had DO\\'Cr to revise the order of
the Income-tax Officer which had not been appealed from. [947 D-1'1
Modification in the order of th~ Income-tax Offic~·r in ~o far as it
related to the assessment of the appellant as an individual was a .:onsequential order made in order to avoid double
as'V...~s1aent· of ~h~ ~ante
income.
Therefore, the fact that the asi;essn1cnt of tl!e appellant a.; an
individual had become final before th~ order of the Commissioner <lid
B
not bar the exercise of the

## Text

A
P. N. KRISHNA IYER
v.
COMMISSIONER OF INCOME-TAX, KERALA
September 3, 1968
943 •
B
[J. C. SHAH, V. RAMASWAMI AND A. N. GROVER, JJ.]
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Indian Income-tax Act, 1922, s. 3 and
s.
33B-Hindu
undivided
family business taken over by
company~Karta appointed . Governing
Director-Salary, Commissioner 'sitting fee' of Governing Director whether assessable in hands of Hindu undivided family-Principles for dtciding--Commissioner's powers under. s. 33B-Scope of.
The appellant, on partition of joint family property between himself
and his brothers, got as his share the family's motor transport business
which had been established by his efforts, along with 'the workshop, stores,
agency, cinema companies etc.'
The Hindu undivided family c~nsisting
of the appellant and his sons tran·sferred the motor transpo'rt busmes~ to
a private limited company; the company credited the account of
the
family in its books with the value of the asscls of the business taken over
by it.
With family money !he appellant purchased 100 shares. of the
company and was appointed-according to tne terms of the Articles of
ASsociation-as its Governing Director for hfe. at a salary of Rs. 3,000
per month with 15% commission on net profits. He was also in lieu of
his experienc~ and his serviecs to the business, allotted 4,880 fully paid np
shares of the company; the dividend from these, when declared,
was
credited to the account o.f the Hindu undivided family.
In proceedings
for assessment the Income-tax Officer brought to tax in the assessment year
1954-55 the remuneration received by the appellant from the com~any
together with the commission, sitting fee, and income from property business and other sources as the separate income of
tile
appellant.
The
Appellate Assistant Commissioner modified the order and in carrying out
his directions the Income-tax Officer included the income from property
business and other sources in the income of the Hindu undivided family
and made corresponding modifications in the assessment of the appellant
as an individual.
But the Commissioner of Income-tax being of the
opinion that the order of the Income-tax OfBcer was prejudicial to the
revenue revised the said order under s. 33B of the Income-tax Act, 1922
and included the appellant's income from salar:;, commission and 'silting
fee' in the total income of the Hindu undivided family.
The Trfounal
reversed the order of the Commissioner.
In reference the High Court
upheld the order of the Commissioner.
The appel1ant in his capacity
as karta of the family appealed to the Supreme Court and contended :
(i) that the Commissioner had no power under s. 33B to revise the order
of the Income-tax Officer after it had been carried in appeal to the Appellate Assistant Commissioner, n.o'r could he tcvbe an order made by the
Income-tax Officer in pursuance of the direction by the Appellate Ass13tant
Commissioner; (ii) that the salary, commission and 'sitting fee' were his
individual income and not that of the Hindu Undivided Family;
HELD : (i) There was no ground for holding that the Commissioner
had attempted to revise the order of the Appellate Assistant Commissioner.
In computing the income of the appellant as an individual the Appellate
.A·ssistant Commissioner had directed ce'rtain mod1ftcations to be rnade,
and pursuant thereto the asses.sments of the appellant and of the llindu
undivided family of which the appellant was the karta were rectified.
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• 944
St;PREME conn REPORTS
(1969] I S.C.R
The oi:der of assessment of the Hindu undivided famil 1 was never chalA
fengcd in appeal.
·1ne (~ommissioncr had DO\\'Cr to revise the order of
the Income-tax Officer which had not been appealed from. [947 D-1'1
Modification in the order of th~ Income-tax Offic~·r in ~o far as it
related to the assessment of the appellant as an individual was a .:onsequential order made in order to avoid double
as'V...~s1aent· of ~h~ ~ante
income.
Therefore, the fact that the asi;essn1cnt of tl!e appellant a.; an
individual had become final before th~ order of the Commissioner <lid
B
not bar the exercise of the ('ommissioncr's pO\\'Cr un<lcr :-.. 338. [947 1~-G]
(ii) Income received hy a _n1ember of a i'i1ndu un<l;vi<lcd family from
a firm or a l"'Ompany in which the funds of th~ llindu undividerl f1.1mi1y
are invested. even thou.~h the income may be partiall) traceable to personal exertion of che member. is taxable as the income of th-: Hin<lu undivided fan1ily. if ir is earned hv detriment to the far1ily funds or \Vith
the aid or assistance of rho.;;e funds; otherv.'is·~ it is taxal··lc as the mc.:nJbcr's
C
separat~ income. [949 GJ
Case la\\" referred to.
V. D. J)/uJnl1'atey v. ConuniJsioner of lncon1e-tal, 68 I.T.R. 365,
M. D. Dhanwa1ey v. Conunissionrr of Jnconie-tax, 6f; I.T.R. 285
and
S. RM. l'T. PL. Palainappa l'hettiar v.
Co1111nissio11~·r of
Jnro111e~tax.
68 l.T.R. 221, applied.
Jn the present case the shares 'vhich qualified the appellant to O~con1e
a member of 1hc company
v.·er~ purchased with the ·\Id ol joint farr1ily
funds.
The shares \vhich \\'Cre allotted to the ..i.ppcl.ant in lieu of his
services v.·ere also treated as shar·:s belonging hi lhe joint
fam1iy.
1."hc
entire capiral assets of the· con1pany origin;lily bl.longed
to
the
joint
family and were nladc av;:tilablc to the comp:u1y in con~1dcrat1on of a m·:re
promise to pay the amount for v.·hich the as-;ets \Vere vaiucd. The inc.umc
\\'as primarily earnc<l by utilising the joint famil~· i!')~tl~ or funcls and th:
n1ere fact that in the process of j?aininc: the advanta~c an clement of personal service or skill or labour v.'a'> invoh·c<l the char::cter of the income
v.·as on th<ll account n0t altered.
Jn C.15-.es of thi-; class the character
of the receipt must he determined bv r~fcrcnc;e t·o llS source. its rel::.tion
to rhc. assets of the family of v.·hich the rccivie11t \\'<l.S the men1ber and
the primary object \vith v.·hich the benefit
rcc~ivc<l \vas disbu'rscd
'fhc
conclu~ion of 1hc High Court that the inco1ne irun1 salary, con1n1'.ssion
and 'sitting . fee' \\'ere the indi\'idu.11 income of tilt. ;1ppcllar.t \\',is not
vitiated by anv error. ['J50 D-Fi
(iii) The question \\hcth-.:r the income \vas 1he in:on1c of the Hindu
undivided family or the individu:-il income of the app•!Tiant \\"<ls a Jinding
on a n1ixcJ ques1 ion of law an<l fact and the fin:ti :011c1usion dra\\ n from
1hc prim:iry evi<lcntiary fach 1,1,·as open to challenge be··orc the llif?h (~ourt
on the plea th<tt the relevant
principle
had
hcen
1nisapplicd
hy
the
Tribunal. [950 Cl
CIVIL APPELLATE JURISDTCTIO~
1966.
Civil Appeal :>lo. 1997 of
Appeal tw special leave from the judgment and order dated
June J 6, 1965 of the Kerala High Court in Income-tax Referred
Case ='10. 9 of I 964.
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S. T. Desai and R. ThiaRamjan. for the appellant.
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KRI~HNA IYER l'. C.l.T. (Shah, J.)
945.
D. Narsaraju, T. A. Ramachandran, R. N. Sachthey and
B. D. Sharma, for the respondent.
The Judgment o.f the Court was delivered by
Shah, J. P. N. Krishna Iyer-hereinafter called the assessee
set up in 1923 a motor transport business in the former State of
Travancore.
In 1945 there arose disputes between the assessee
and his brothers about the division of the estate of the joint family
of which they were members. The disputes were settled by
mutual agreement dated Octob.~r 23, 1951 and the motor transport business together with the "workshop, stores, agency, cinema
companies etc." were treated as the business of the joint family,
and on partition were allotted to the assessee.
An application
filed by the assessee b.efore the 1st Additional Income-tax Oillcer,
Trichur, for recording the partition was accepted.
In the meantime on July 3, 1952, a private limited company
P. S. N. Motors (Private) Ltd. was floated with the object of
taking over the motor transport business
carried on by the
assessee.
By the Articles of Association, the assessee was to be
the Governing Director of the Company for life and to draw such
remuneration and exercise such powers detailed in the agreement
to be entered into between him and the company in that behalf,
and so Jong as he held the office of Governing Director, the general management of the company's business was to remain in his
hands.
The assessee purchased 100 shares of the Company of
the face value of Rs. 100 each.
On August 18, 1952,
th<>
assessee was appointed by the Company Governing Director with
an office allowance of Rs. 3,000 per mensem and a commission
of 15 per cent. on the net profit. On the same day the Directors
approved the purchase from the Hindu undivided family of the
assessee of assets (but not the liabilities) of the transport business
valued at Rs. 8,01,074/1/4. In the books of the Company credit
entries were posted in the name of the Hindu undivided family.
On August 18, 1952, the Directors passed certain resolutions
relating to the repayment of the amount due to the Hindu undivided family.
On September 28, 1952, the Company passed a
special resolution that in consideration of the "valuable services"
rendered by the assessee in the promotion of the Company and
of the "large sacrifices" made by him in agreeing to place his
servic.es at the disposal of the company and the benefit that the
company received on account of his "long experience, goodwill
and reputation in this line of business," the assessee be allotted
4880 fully paid up shares of the Company.
The Income-tax Officer brought to tax in the assessment year
1"954-55 the remuneration received by the assessee from
the
Company together with the commission, "sitting fee" and income
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946
SlJPRE\IE COURT REPORTS
[1969) J SC.R.
from property, business and other sources as the separate income
A
of the assessec.
The Appellate Assistant Commissioner modified
that order, and directed that income other than the income from
salary, commission and '"sitting fee" received from the Company
be included in the assessment of the Hindu undivided family. The
Income-tax Officer then carried out the direction and
included
the income from prop.~rty, business and other sources in the total. B
income of the Hindu undivided family and made corresponding
modifications in the assessment of the assessec as an individual.
But the Commissioner of Income-tax being of the opinion that
the order passed by the Income-tax Officer was wrong and prejudicial to the inter_ests of revenue revised the order of the lncometax Officer exercising power under s. 33H of the Income-tax Act.
1922, and included the income from
sabry,
commission
and
"sitting fee" <iggregatin!! to Rs. 43,240 in the total income of the
Hindu undivided family.
Jn appeal against the order, the Tribunal reversed the order of the Commissioner and ordered that the
three items be excluded from the assessment of the Hindu undivided family.
At the instance of the Commissioner of Income-tax, the following question was referred by the Tribunal to the High Court of
Kerala:
Whether on the facts and in the circumstances of
the case, the Tribunal was justified in holding that the
income from salary, commission and sitting
fees obtained by Sri P. N. Krishna
Iyer from
M/s P.S.N.
Motors (Private) Ltd., Trichur, represented his individual income and not the income of the
Hindu undivided family of which he is the karta '?"
At the instance of the asscssee the followin)!
question also was
referred by the Tribunal :
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"Whether the
Commissioner has
jurisdiction
to
revise the order of the Income-tax Officer in view of
the decision of the Appdlatc Assistant
Commissioner
in appeals for the assessment years 1954-55 to 1957-58
in the assessment of Sri P. N. Krishna Iyer in the status
of an individual .,..
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The High Court answered the question referred at the instance of
the Commissioner in the negative and· the question referred at
the instance of the assesscc in the affirmative.
The assessee has
appealed to this Court with special leave granted by this Court.
The question relating to jurisdiction of the Commissioner to
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revise the order of the Income-tax Officer presents little difficulty•
Suh-section (I) of s.
33B of the Income-tax
Act,
1922,
provides :
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KRISHNA IYER V. C.I.T. (Shah, J.)
"The Commissioner may call for and examine the
record of any proceeding under this Act and if he considers that any order passed therein by the Income-tax
Officer is erroneous in so far as it is prejudicial to the
interests of the revenue, he may
pass such order thereon as the circumstances of the case
justify, including an order enhancing or modifying the
assessment, or cancelling the assessment and directing
a fresh assessment."
947
Counsel for the assessee urged that the Commissioner has no
power under s. 33B to revise an order of the Income-tax. Officer
after it had been carried in appeal to the Appellate Assistant
Commissioner, and also urged that an order passed by an Income-tax Officer in pursuance of a direction by the Appellate
Assistant Commissioner could not be revised by the Commissioner
in exercise of the power under s. 33B. But in our judgment there
is no ground for holding that the Commissioner has attempted to
revise the order of the Appellate Assistant Commissioner. In
computing the income of the
assess.o.,e
as an individual, the
Appellate Assistant Commissioner had directed certain modifications to be made, and pursuant thereto the assessments of the
assessee and of the Hindu Undivided family of which the assessee
was the karta were rectified. The order of assessment of the
Hiudu Undivided family was never challenged in appeal to the
Appellate Assistant Commissioner.
The Commissioner revised
the order passed by the Income-tax Officer insofar as it related
to the Hindu Undivided family. It is true that in consequence of
the order of the Commissioner, the salary, commission and the
"sitting fee" received by the assessee had to. be excluded from the
total income of the assessee. But the Commissioner had power
to revise the order passed by the Income-tax Officer which had
not been appealed from. Modification in the order of the Incometax Officer insofar as it related to the assessment of the assessee
was consequential upon that order : it was made to prevent
double taxation of the same income. It is true that the assessment of the assessee as an individual had become final before the
order of the Commissioner, but that did not bar the exercise of
jutisdiction by the Commissioner under s. 33B (1). The question referred at the instance of the assessee was, therefore, rightly
answered by the High Court.
'
Turning to the other question, the relevant facts which are undisputed may be recapitulated. Rs. 10,000 paid by the assessee
for purchasing 100 shares of the Company belonged to the undivided family and were not from the personal fund of the
assessee.
The Company took over the assets belonging to the
familv ~nd merelv credited the family with rupees eight lakhs
odd. The Company valued the services rendered by the assesseil
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948
SUPREME co1:RT REPORTS
[1969] J SC.R.
in "the promotion of the Company and the very large sacrifice;
A
he had made in agreeing to place his services at the disposal of
the Company and the immense benefit that the Company received
on account of his long experience, goodwill and reputation in this
line of business", at rupees five lakhs and allotted to the assessec
4,880 fully paid up shares of the Company of the face value of
Rs. I 00 each.
Dividends from the shares standing in ihe name
B
:>f the assessee were credited not the personal
account of the
as;essee but to the account of the Hindu Undivided family.
In the view of the Tribunal the income from salary, commi,,-
sion and "sitting fee" earned by the assessee
was
his separate
income, because the transport bminess was "built up
with
the
sole effort of the assessec··. The High Court held tha1 the business
was at the partition of 1951 treated as the business of the
joim
fomily of the assessee and his brothers and was
allotted to
th-~
asscssee as an item of the family property; that the
assets
of
lhc business were on that account the assets of the Hindu
Undivided family of the assessce and his sons, that those assets were
made a\'ailable to the Company without receiving any cash considerntion. that the shares initially purchased by the assessec we.:e
purchas.~d with the aid of the family funds, and that the shares
allotted to the-;1ssessec were also treated as helonginR to the family
and to the assessec.
Whether remuneration earned by a member of a Hindu Undivided farnily as an officer of a company or a finn. in which the
assets of the Hindu undivided familv have eiU1er been invested
or the office has been acquired with· the aid of the funds of the
family is the income of the family or the individual income of the
member has arisen in ~~veral cases before this Court : Commissioner of Income-tax v. Kal11 Rab11 !,al Chand('); Piyare Lal
Adishwar I.al v. Commissin11er of l11come-ta.d');
Marh11ra
Prasad v. Commissionrr o.f lnconw-tax('); S. RM. CT. Pf,.
l'alaniapf'a Chettiar v. Commissioner of Income-tax('); V. D.
f)ftm11mter v. Commissinn<'r of Income-tax('); and M.
D
T>han\\'afe:r v. Cnmmiuioner o.f Income-tax('); No useful pur
pose will be served by making an ana)ysis of the earlier cases.
because in our view three rec.~nt judgments of this Court lay
down the principles which govern this class of cases. In V. D.
Dhanwater'.1· case(') V the Karta of a Hindu undivided familv
contributed to the capital of a firm out of the funds of the family.
Under the agreement of partnership the general management and
supervision of the partnership business was to be in the hands of
V. and he was to be paid a monthly remuneration out of the gross
earnings of the partnership business.
V joined the partnership
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(1)
)7 l.T.R.12.'.
(2)
40 1.T.R.17
o
(])
(,() l.T.R. 428.
(41
68 1.T.R. rn.
<51
68 l.T.R. 165.
(6)
68 l.T.R. 285.
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KRISHNA IYER v. C.l.T. (Shah, /.)
949
as representing the family and he became a partner on account
of the investments of the joint family assets in the capital of the
partnership and that the remuneration received by V was only an
increased share of the profits paid to him as
representing the
family. This Court (Hegde, J. dissenting) held that the remuneration paid to V was directly related to the investments from the
assets of the family in the partnership business and "there was
real and sufficient connection between the investment from
the
joint family funds and the remuneration paid to V". The salary
naid to V was therefore assessable as the income of the Hindu
Undivided family.
In M. D. Dhanwatey's case( 1 ) the facts were parallel to the
c
facts in V. D. Dhanwatey's case(") and salary receive
by the
karta of the Hindu Undivided famliy was treated as income of
the family.
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In S. RM. CT. PL. Palaniappa Chattiar's case(') the karta
of a Hindu Undivided family acquired 90 out of 300 shares in a
transport company with the funds of the family.
In course of
time he became the managing director of the Company. As
managing director the karta was entitled to salary and commission on the net profits of the company, and was entrusted with
central over the financial and administrative affairs of the company. The only qualification under the articles of association for
the office of a director was the holding of not less than 25 shares
in his own right.
lt was held that the shares were acquired by
the family not with the object that the karta should become the
managing director, but in the ordinary course of investment, and
there was no real connection between the investment of joint
family funds in the purchase of the shares and th.e appointment
of the karta as managing director of the company. The remuneration of the managing director, it was held, was not earned on
account of any detriment to the joint family assets,
and the
amounts received by the karta as managing director's remuneration, commission and "sitting fee" were not assessable as the income of the Hindu Undivided family .
Income received by a member of a Hindu Undivided family
from a fim1 or a company in which the funds of the Hindu undivided family are invested, even though the income may be partially traceable to personal exertion of the member, is taxable as
the income of the Hindu Undivided family,
if it is earned by
detriment to the family funds or with the aid or assistance of those
funds; otherwise it is taxable as the member's separate income.
Counsel for the assessee contended that the Tribunal had
found that the business of Mis P.S.N. Motors was built up "by
0~ 68 1.T.R. 285.
(2)
6P. 1.T.R. 365,
(3) 68 r:1 R 211.
Lt Sup. C.T./69-14
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950
SUPREME COURT REPORTS
(1969] ! S.C.R.
the sole exertions" of the assessee and when the business was converted into a private limited company the shares therein were
allotted to the assessce in view of "the valuable services rendered"
by him in the promotion of the company and the "large sacrifices" he had made in agreeing to place bis services at the disposal
of the Company and '"the immense benefit" that the Company received "on account of his long experience, goodwill and reputation in the iine of business", and, therefore, the salary, commission and "sitting fee" were in consideration of the services which
the asscssee rendered and were not attributable to the fact that
the family had contributed to the main capital of the Company.
Counsel said that this was a finding of fact which was binding
upon the High Court. But this Court in
V.
D.
Dhanwatey'.r
case (') ha> held that the question whether the income was the
income of the Hindu undivided family or the individual income
was a finding on a mixed question of law and fact, and the final
conclusion drawn from the primary cvidentiary facts was open to
challenge on the pica that the relevant principle had been misapplied by the Tribunal.
The shar~s which qualified the asscssec to become a member
of the Company were purchased with the aid of joint family funds.
The shares which were allotted to the assessee in lieu of his services were also treated as shares belonging to the joint famil).
TI1e entire capital assets of the Company originally belonged to
the joint family and were made available to the Company in consideration of a mere promise to pay the amount for which the
assets were valued. The income was primarily earned by utilising the joint family assets or funds and the mere fact that in the
process of gaining the advantage an clement of personal service or
skill or labour was involved did not alter the character of the
income.
In cases of this class the character of the receipt must
be determined by reference to its source, ib relation to the assets
of the familv of which the recipient was the member,
and the
primary object with which the benefit received was disbursed.
The conclusion of the High. Coun cannot be said to be vitiated
by any error.
The appeal fails and is dismissed with costs.
-i
G.C.
Appeal dismissed.
•
(I) bS l.T.R. 36':.
A
B
c
D
E
F
•