w w w . L a w y e r S e r v i c e s . i n



M/s. Mulberry Silks Limited (formerly M/s. Shakashambana Silks Exports (P) Ltd.), 'Mulberry House', Rep.by its Director R.K. Bothra v/s Settlement Commission (IT & WT), Additional Bench, Ministry of Finance, Chennai & Others


Company & Directors' Information:- L & T FINANCE LIMITED [Amalgamated] CIN = U65990MH1994PLC083147

Company & Directors' Information:- S P FINANCE PRIVATE LIMITED [Active] CIN = U65990MH1979PTC021790

Company & Directors' Information:- V L S FINANCE LIMITED [Active] CIN = L65910DL1986PLC023129

Company & Directors' Information:- R T EXPORTS LIMITED [Active] CIN = L51900MH1980PLC022582

Company & Directors' Information:- MULBERRY SILKS LIMITED [Active] CIN = U85110KA1982PLC005007

Company & Directors' Information:- L R N FINANCE LIMITED [Active] CIN = U65921TN1992PLC089288

Company & Directors' Information:- S M FINANCE LTD [Active] CIN = L65999TG1984PLC004526

Company & Directors' Information:- J R D FINANCE LTD [Active] CIN = L65999WB1993PLC058107

Company & Directors' Information:- B R D FINANCE LIMITED [Active] CIN = U65910KL1995PLC009430

Company & Directors' Information:- T C I FINANCE LIMITED [Active] CIN = U65920MH1973PLC017042

Company & Directors' Information:- A. V. B. FINANCE PRIVATE LIMITED. [Active] CIN = U65993DL1992PTC049818

Company & Directors' Information:- S M L FINANCE LIMITED [Active] CIN = U65910KL1996PLC010648

Company & Directors' Information:- R B A EXPORTS PVT. LTD. [Active] CIN = U27109WB1989PTC047383

Company & Directors' Information:- S B FINANCE PVT LTD [Strike Off] CIN = U65921TG1988PTC008268

Company & Directors' Information:- K H EXPORTS INDIA PRIVATE LIMITED [Active] CIN = U19129TN1985PTC011821

Company & Directors' Information:- INDIA FINANCE LTD. [Active] CIN = L65110WB1984PLC050214

Company & Directors' Information:- J J FINANCE CORPORATION LTD [Active] CIN = L65921WB1982PLC035092

Company & Directors' Information:- G V S FINANCE PVT LTD [Strike Off] CIN = U65921TG1988PTC008269

Company & Directors' Information:- N W EXPORTS LIMITED [Amalgamated] CIN = U99999MH1946PLC004840

Company & Directors' Information:- G T P FINANCE LIMITED [Active] CIN = U65921TZ1991PLC003149

Company & Directors' Information:- K B EXPORTS PRIVATE LIMITED [Active] CIN = U70200DL1998PTC096113

Company & Directors' Information:- U V EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2014PTC264761

Company & Directors' Information:- A B EXPORTS PRIVATE LIMITED [Active] CIN = U51398DL1996PTC223961

Company & Directors' Information:- S R K FINANCE PRIVATE LIMITED [Active] CIN = U65910UP1994PTC016038

Company & Directors' Information:- S V T EXPORTS PRIVATE LIMITED [Strike Off] CIN = U60231KA2009PTC050975

Company & Directors' Information:- S R S EXPORTS PRIVATE LIMITED [Active] CIN = U52311PB1995PTC017081

Company & Directors' Information:- T R B EXPORTS PRIVATE LIMITED [Active] CIN = U35999PB1994PTC014312

Company & Directors' Information:- R N FINANCE LIMITED [Active] CIN = U74899DL1988PLC034289

Company & Directors' Information:- M H K EXPORTS PRIVATE LIMITED [Active] CIN = U18101DL2009PTC188043

Company & Directors' Information:- J R D FINANCE LTD [Active] CIN = U65999WB1993PLC058107

Company & Directors' Information:- P R EXPORTS LTD [Active] CIN = U51909WB1981PLC034199

Company & Directors' Information:- M J EXPORTS PRIVATE LIMITED [Active] CIN = U17100MH1972PTC015802

Company & Directors' Information:- S AND S SILKS LIMITED [Active] CIN = U18101DL1992PLC047629

Company & Directors' Information:- L N FINANCE LTD [Active] CIN = U65923WB1991PLC052876

Company & Directors' Information:- R K FINANCE LTD [Active] CIN = L65921WB1983PLC035896

Company & Directors' Information:- R R EXPORTS PVT. LTD. [Active] CIN = U51909WB1987PTC041982

Company & Directors' Information:- A B R EXPORTS PRIVATE LIMITED [Converted to LLP] CIN = U51909KA1975PTC002912

Company & Directors' Information:- V P C L FINANCE LIMITED [Active] CIN = U65920TG1996PLC023172

Company & Directors' Information:- K T EXPORTS (INDIA) PRIVATE LIMITED [Active] CIN = U51900MH2000PTC129260

Company & Directors' Information:- B. N. EXPORTS PRIVATE LIMITED [Active] CIN = U01111WB2007PTC114463

Company & Directors' Information:- J S M FINANCE PVT LTD [Active] CIN = U74140MP1995PTC009542

Company & Directors' Information:- M N R EXPORTS PRIVATE LIMITED [Active] CIN = U51909WB1997PTC085123

Company & Directors' Information:- I & D FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1991PTC021369

Company & Directors' Information:- G C S EXPORTS PRIVATE LIMITED [Active] CIN = U51909AS2005PTC007825

Company & Directors' Information:- J L K EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2004PTC126448

Company & Directors' Information:- O B S EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1980PTC010840

Company & Directors' Information:- S M M EXPORTS PRIVATE LIMITED [Active] CIN = U51398DL1999PTC098793

Company & Directors' Information:- A AND F SILKS LIMITED [Strike Off] CIN = U17116KA1996PLC019899

Company & Directors' Information:- G T N EXPORTS LIMITED [Not available for efiling] CIN = U51909KL1996PLC010047

Company & Directors' Information:- R P R EXPORTS PRIVATE LIMITED [Under Process of Striking Off] CIN = U15499TN1997PTC039167

Company & Directors' Information:- A O V EXPORTS PRIVATE LIMITED [Active] CIN = U74999DL2002PTC114617

Company & Directors' Information:- L N FINANCE PVT LTD [Active] CIN = U65929AS1992PTC003766

Company & Directors' Information:- T P D FINANCE LIMITED [Strike Off] CIN = U67120RJ1994PLC008051

Company & Directors' Information:- L M J EXPORTS PRIVATE LIMITED [Active] CIN = U51109WB1994PTC065438

Company & Directors' Information:- S D R EXPORTS PVT LTD [Active] CIN = U51909WB1993PTC058739

Company & Directors' Information:- R G L FINANCE COMPANY PRIVATE LIMITED [Active] CIN = U74899DL1983PTC015809

Company & Directors' Information:- K P EXPORTS PVT LTD [Active] CIN = U17222RJ1980PTC002086

Company & Directors' Information:- S K B FINANCE LIMITED [Amalgamated] CIN = U65999WB1996PLC082317

Company & Directors' Information:- M A R EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1992PTC046991

Company & Directors' Information:- J V FINANCE PRIVATE LIMITED [Strike Off] CIN = U74899DL1985PTC067873

Company & Directors' Information:- L C J FINANCE PVT. LTD. [Active] CIN = U65921WB1995PTC068809

Company & Directors' Information:- R B B R EXPORTS LIMITED [Active] CIN = U51900MH2004PLC095395

Company & Directors' Information:- D V EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2004PTC126430

Company & Directors' Information:- H L T FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921DL1996PTC078128

Company & Directors' Information:- FINANCE HOUSE (INDIA) PRIVATE LIMITED [Active] CIN = U74899DL1964PTC004280

Company & Directors' Information:- FINANCE HOUSE (INDIA) PRIVATE LIMITED [Active] CIN = U65100DL1964PTC004280

Company & Directors' Information:- T T FINANCE LIMITED [Amalgamated] CIN = U67120DL1986PLC023168

Company & Directors' Information:- M M V R FINANCE LIMITED [Active] CIN = U65921TZ1997PLC007705

Company & Directors' Information:- D B FINANCE PRIVATE LIMITED [Active] CIN = U65191TN1989PTC016705

Company & Directors' Information:- G T EXPORTS PVT LTD [Strike Off] CIN = U74899DL1988PTC031057

Company & Directors' Information:- P T EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL1996PTC079851

Company & Directors' Information:- C H P FINANCE PVT LTD [Active] CIN = U65921PB1992PTC012788

Company & Directors' Information:- G S EXPORTS PRIVATE LIMITED [Active] CIN = U52322MH2005PTC154073

Company & Directors' Information:- D. F. EXPORTS PRIVATE LIMITED [Active] CIN = U51909WB2009PTC135506

Company & Directors' Information:- R A G EXPORTS PRIVATE LIMITED [Active] CIN = U63040PB1998PTC021522

Company & Directors' Information:- T W EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL1991PTC045854

Company & Directors' Information:- M C BOTHRA & COMPANY PVT LTD [Active] CIN = U17222WB1989PTC047676

Company & Directors' Information:- S L B P FINANCE PRIVATE LIMITED [Active] CIN = U74899DL1990PTC041694

Company & Directors' Information:- M R D EXPORTS PRIVATE LIMITED [Active] CIN = U51900MH1994PTC078469

Company & Directors' Information:- R S FINANCE PVT LTD [Active] CIN = U65191WB1988PTC044144

Company & Directors' Information:- A K EXPORTS PVT LTD [Amalgamated] CIN = U51909DL1993PTC185233

Company & Directors' Information:- I C FINANCE PRIVATE LIMITED [Active] CIN = U65921UP1989PTC011236

Company & Directors' Information:- N. K. SILKS (INDIA) PRIVATE LIMITED [Active] CIN = U17120MH2009PTC192572

Company & Directors' Information:- S S B I EXPORTS PRIVATE LIMITED [Active] CIN = U51100GJ2000PTC037695

Company & Directors' Information:- P S P C EXPORTS PRIVATE LIMITED [Active] CIN = U19201TN1995PTC032123

Company & Directors' Information:- K AND K EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC068805

Company & Directors' Information:- N T EXPORTS PRIVATE LIMITED [Strike Off] CIN = U05005WB1998PTC087900

Company & Directors' Information:- V K FINANCE PVT LTD [Strike Off] CIN = U67120WB1991PTC052140

Company & Directors' Information:- K H EXPORTS PRIVATE LIMITED [Amalgamated] CIN = U19119TN1987PTC014484

Company & Directors' Information:- C K K EXPORTS PRIVATE LIMITED [Active] CIN = U51909MH2005PTC151252

Company & Directors' Information:- V K V EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2011PTC227775

Company & Directors' Information:- C AND N FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921DL1998PTC094290

Company & Directors' Information:- B M D EXPORTS PRIVATE LIMITED [Active] CIN = U51100GJ2004PTC045212

Company & Directors' Information:- C D R FINANCE LIMITED [Strike Off] CIN = U65910TG1995PLC022237

Company & Directors' Information:- C B EXPORTS PVT LTD [Strike Off] CIN = U17115DL1980PTC010566

Company & Directors' Information:- V A A EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909MH2006PTC166078

Company & Directors' Information:- J R FINANCE LIMITED [Active] CIN = U65921PB1996PLC017699

Company & Directors' Information:- I C S FINANCE LIMITED [Strike Off] CIN = U65921TZ1987PLC001991

Company & Directors' Information:- J B EXPORTS PRIVATE LTD [Active] CIN = U51109DL1984PTC017683

Company & Directors' Information:- D H EXPORTS PRIVATE LIMITED [Active] CIN = U18101MH2004PTC089360

Company & Directors' Information:- G M EXPORTS PVT LTD [Active] CIN = U51909GJ1982PTC005771

Company & Directors' Information:- N AND D EXPORTS PRIVATE LIMITED [Amalgamated] CIN = U74899DL1993PTC051946

Company & Directors' Information:- D D S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65910DL1996PTC076165

Company & Directors' Information:- K V L FINANCE LIMITED [Strike Off] CIN = U65191TN1989PLC016715

Company & Directors' Information:- D A S FINANCE PVT LIMITED [Strike Off] CIN = U65921PB1993PTC012888

Company & Directors' Information:- A EXPORTS PRIVATE LIMITED [Active] CIN = U14101DL2003PTC122819

Company & Directors' Information:- U B FINANCE PRIVATE LIMITED [Strike Off] CIN = U74899DL1992PTC051300

Company & Directors' Information:- V L G FINANCE PRIVATE LIMITED [Strike Off] CIN = U65910AP1997PTC027952

Company & Directors' Information:- E M S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921TZ1986PTC001789

Company & Directors' Information:- J V S EXPORTS PVT LTD. [Active] CIN = U17115WB1989PTC046846

Company & Directors' Information:- T D M FINANCE COMPANY PRIVATE LIMITED [Active] CIN = U65923KL1997PTC011601

Company & Directors' Information:- S. F. FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65921PB1996PTC018702

Company & Directors' Information:- D S L FINANCE PRIVATE LIMITED [Active] CIN = U65921TG1996PTC023898

Company & Directors' Information:- P C EXPORTS PRIVATE LIMITED [Active] CIN = U28920KA1990PTC010772

Company & Directors' Information:- G D EXPORTS PVT LTD [Active] CIN = U51909WB1989PTC047967

Company & Directors' Information:- S R K C FINANCE LIMITED [Amalgamated] CIN = U65999TZ1989PLC002445

Company & Directors' Information:- M M P EXPORTS PRIVATE LIMITED [Active] CIN = U18101DL1997PTC087416

Company & Directors' Information:- R K N FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1997PTC038377

Company & Directors' Information:- I B S EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2002PTC117784

Company & Directors' Information:- H A FINANCE PRIVATE LIMITED [Strike Off] CIN = U65993DL1987PTC027064

Company & Directors' Information:- V V A FINANCE LTD [Active] CIN = U65993WB1984PLC037171

Company & Directors' Information:- Y B FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921CH1996PTC017745

Company & Directors' Information:- T S L EXPORTS LTD. [Strike Off] CIN = U51223WB1990PLC050436

Company & Directors' Information:- M L K EXPORTS PRIVATE LIMITED [Active] CIN = U52322UP2004PTC029369

Company & Directors' Information:- M S P EXPORTS PRIVATE LIMITED [Active] CIN = U51226KA1975PTC002926

Company & Directors' Information:- L & G EXPORTS PVT LTD [Strike Off] CIN = U29191WB1975PTC030351

Company & Directors' Information:- C & A EXPORTS PVT LTD [Strike Off] CIN = U24119WB1978PTC031538

Company & Directors' Information:- A B M EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL2006PTC146367

Company & Directors' Information:- H D EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909PB1998PTC021887

Company & Directors' Information:- A AND F EXPORTS PRIVATE LIMITED [Strike Off] CIN = U18101KA1995PTC017466

Company & Directors' Information:- S C J EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1993PTC053804

Company & Directors' Information:- A D EXPORTS PVT LTD [Active] CIN = U70101WB1991PTC053651

Company & Directors' Information:- D G EXPORTS PVT LTD [Active] CIN = U51909WB1996PTC079352

Company & Directors' Information:- S P J EXPORTS PVT. LTD [Strike Off] CIN = U27106WB1989PTC046733

Company & Directors' Information:- HOUSE OF EXPORTS LTD. [Strike Off] CIN = U51109WB1983PLC036496

Company & Directors' Information:- S R J EXPORTS PVT LTD [Strike Off] CIN = U51909CH1988PTC007989

Company & Directors' Information:- N D T HOUSE (INDIA) PRIVATE LIMITED [Strike Off] CIN = U33110MH2000PTC126194

Company & Directors' Information:- M S R FINANCE PVT LTD [Strike Off] CIN = U65191TN1989PTC016789

Company & Directors' Information:- A P EXPORTS PRIVATE LIMITED [Active] CIN = U17115TZ1988PTC002223

Company & Directors' Information:- S N H EXPORTS PRIVATE LIMITED [Active] CIN = U51101MH2007PTC176084

Company & Directors' Information:- P L A EXPORTS PRIVATE LIMITED [Active] CIN = U51900MH1974PTC017700

Company & Directors' Information:- S S P FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1987PTC014526

Company & Directors' Information:- AT EXPORTS PRIVATE LIMITED [Active] CIN = U51909WB2016PTC216254

Company & Directors' Information:- R N M EXPORTS PRIVATE LIMITED [Active] CIN = U13209WB2004PTC097636

Company & Directors' Information:- G P EXPORTS PRIVATE LIMITED [Active] CIN = U51900MH1983PTC030202

Company & Directors' Information:- S R B EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL1998PTC093624

Company & Directors' Information:- A M D EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1994PTC062322

Company & Directors' Information:- A K C L EXPORTS LIMITED [Strike Off] CIN = U51311RJ1994PLC008631

Company & Directors' Information:- ON THE HOUSE PRIVATE LIMITED [Active] CIN = U70101WB2000PTC091842

Company & Directors' Information:- S S EXPORTS (INDIA) PVT LTD [Active] CIN = U17121WB1985PTC038437

Company & Directors' Information:- I FINANCE COMPANY LIMITED [Active] CIN = U67110DL2011PLC212268

Company & Directors' Information:- P. J. EXPORTS PRIVATE LIMITED [Active] CIN = U74992GJ2007PTC049876

Company & Directors' Information:- R G EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1989PTC034616

Company & Directors' Information:- V B EXPORTS PVT LTD [Strike Off] CIN = U51909WB1988PTC044947

Company & Directors' Information:- M M EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1989PTC036407

Company & Directors' Information:- R C L EXPORTS (INDIA) PRIVATE LIMITED [Active] CIN = U51909DL2005PTC143513

Company & Directors' Information:- C D HOUSE INDIA PRIVATE LIMITED [Strike Off] CIN = U74899DL1995PTC068483

Company & Directors' Information:- A T EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1986PTC026511

Company & Directors' Information:- M K V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51101TZ2000PTC009170

Company & Directors' Information:- V I P EXPORTS PRIVATE LIMITED [Active] CIN = U52397MH2007PTC174922

Company & Directors' Information:- N B T EXPORTS PRIVATE LIMITED [Active] CIN = U65990MH1982PTC028147

Company & Directors' Information:- H AND Z FINANCE PRIVATE LIMITED [Active] CIN = U67190MH1995PTC093153

Company & Directors' Information:- F M EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909MH2003PTC138934

Company & Directors' Information:- D R EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1975PTC007859

Company & Directors' Information:- Y AND K FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U74899DL1985PTC019837

Company & Directors' Information:- A G R EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1994PTC060903

Company & Directors' Information:- M. G. EXPORTS PRIVATE LIMITED [Strike Off] CIN = U18101DL2008PTC176295

Company & Directors' Information:- G T B EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL2004PTC129698

Company & Directors' Information:- M J R EXPORTS PVT LTD [Strike Off] CIN = U51909KL1994PTC007902

Company & Directors' Information:- S L P FINANCE PRIVATE LTD. [Strike Off] CIN = U65923DL1985PTC021970

Company & Directors' Information:- G N EXPORTS PRIVATE LIMITED [Under Process of Striking Off] CIN = U00061KA1988PTC008899

Company & Directors' Information:- V M FINANCE LIMITED [Strike Off] CIN = U65910PB1996PLC018339

Company & Directors' Information:- D S K FINANCE LIMITED [Strike Off] CIN = U65910UP1988PLC010317

Company & Directors' Information:- S K C EXPORTS PRIVATE LIMITED [Strike Off] CIN = U52599TN1994PTC027533

Company & Directors' Information:- N K EXPORTS PRIVATE LIMITED [Strike Off] CIN = U52311MH2000PTC129489

Company & Directors' Information:- G B V FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65110UP1988PTC010219

Company & Directors' Information:- B H FINANCE PRIVATE LIMITED [Strike Off] CIN = U65922KA1995PTC018390

Company & Directors' Information:- A M EXPORTS LIMITED [Strike Off] CIN = U51109PB1996PLC017635

Company & Directors' Information:- M .R .S . FINANCE LIMITED [Strike Off] CIN = U65929DL1995PLC067184

Company & Directors' Information:- B G EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909CH1996PTC018711

Company & Directors' Information:- H D FINANCE LTD [Strike Off] CIN = U67120DL1986PLC023675

Company & Directors' Information:- E V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U52321TN1994PTC029590

Company & Directors' Information:- M K V EXPORTS PRIVATE LIMITED [Not available for efiling] CIN = U51410TN1999PTC043250

Company & Directors' Information:- P R K FINANCE P LTD [Strike Off] CIN = U65191TN1995PTC033478

Company & Directors' Information:- M G M EXPORTS PVT LTD [Strike Off] CIN = U51909WB1980PTC032489

Company & Directors' Information:- D AND A EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1989PTC038349

Company & Directors' Information:- P. S. EXPORTS PRIVATE LIMITED [Strike Off] CIN = U17121DL2007PTC164402

Company & Directors' Information:- S R W EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2003PTC121393

Company & Directors' Information:- H. H. HOUSE PRIVATE LIMITED [Converted to LLP] CIN = U45201DL1981PTC012646

Company & Directors' Information:- P A V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1994PTC057134

Company & Directors' Information:- T M EXPORTS PVT LTD [Active] CIN = U51909WB1988PTC045226

Company & Directors' Information:- T AND C FINANCE LIMITED [Strike Off] CIN = U67120RJ1996PLC012576

Company & Directors' Information:- J B I EXPORTS PRIVATE LIMITED [Active] CIN = U17100MH1997PTC105972

Company & Directors' Information:- P B M EXPORTS PVT LTD [Active] CIN = U51909PB1989PTC009359

Company & Directors' Information:- W S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65192UP1996PTC020243

Company & Directors' Information:- H T EXPORTS PRIVATE LIMITED [Active] CIN = U52322KA1982PTC004661

Company & Directors' Information:- N D EXPORTS PVT LTD [Converted to LLP and Dissolved] CIN = U51909GJ1993PTC019292

Company & Directors' Information:- S A C FINANCE COMPANY PVT LTD [Active] CIN = U65999WB1985PTC039002

Company & Directors' Information:- G D EXPORTS PVT LTD [Under Liquidation] CIN = U51900WB1973PTC028662

Company & Directors' Information:- M C B HOUSE PRIVATE LIMITED [Active] CIN = U52335DL1999PTC099967

Company & Directors' Information:- G G S EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL1981PTC011624

Company & Directors' Information:- R T EXPORTS PVT LTD [Active] CIN = U51909WB1989PTC047639

Company & Directors' Information:- C G EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1990PTC039074

Company & Directors' Information:- D AND D EXPORTS PRIVATE LIMITED [Strike Off] CIN = U99999DL1993PTC052633

Company & Directors' Information:- K A EXPORTS PRIVATE LIMITED [Active] CIN = U34300PB1990PTC010165

Company & Directors' Information:- IN EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1989PTC034535

Company & Directors' Information:- A 1 EXPORTS PRIVATE LIMITED [Active] CIN = U51909PB1998PTC020956

Company & Directors' Information:- S R SILKS PRIVATE LIMITED [Strike Off] CIN = U17122TN2006PTC061299

Company & Directors' Information:- S. E. EXPORTS PRIVATE LIMITED [Active] CIN = U05004UP1995PTC017843

Company & Directors' Information:- S P G EXPORTS INDIA PRIVATE LIMITED [Strike Off] CIN = U51909WB2004PTC100829

Company & Directors' Information:- U & I EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1993PTC055089

Company & Directors' Information:- J T EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL2004PTC128939

Company & Directors' Information:- S R (INDIA) EXPORTS PRIVATE LIMITED [Active] CIN = U74899DL1995PTC064392

Company & Directors' Information:- K F S EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL2001PTC110011

Company & Directors' Information:- P V S EXPORTS PRIVATE LIMITED [Active] CIN = U51900KA1976PTC003022

Company & Directors' Information:- C C FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1997PTC037805

Company & Directors' Information:- I TO N EXPORTS PRIVATE LIMITED [Strike Off] CIN = U52322DL1995PTC072744

Company & Directors' Information:- S R B FINANCE LIMITED [Strike Off] CIN = U65910UP1988PLC010045

Company & Directors' Information:- P V FINANCE PRIVATE LIMITED [Strike Off] CIN = U65993DL1987PTC027270

Company & Directors' Information:- R V S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65990KA1995PTC018436

Company & Directors' Information:- V R EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909PN1999PTC013327

Company & Directors' Information:- R AND A EXPORTS PRIVATE LIMITED [Strike Off] CIN = U99999DL1989PTC036797

Company & Directors' Information:- S R A EXPORTS INDIA PRIVATE LIMITED [Strike Off] CIN = U18101KL1992PTC006778

Company & Directors' Information:- R.K. EXPORTS LIMITED [Under Process of Striking Off] CIN = U51909GJ1994PLC023854

Company & Directors' Information:- V K EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51101TG1994PTC018557

Company & Directors' Information:- H & H EXPORTS PRIVATE LIMITED [Strike Off] CIN = U17219DL1995PTC068987

Company & Directors' Information:- S K EXPORTS PRIVATE LIMITED [Strike Off] CIN = U52100DL1969PTC005105

Company & Directors' Information:- P AND B FINANCE PVT LTD [Strike Off] CIN = U99999MH1986PTC038841

Company & Directors' Information:- B B P FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65921PB1996PTC018183

Company & Directors' Information:- P S M EXPORTS PVT LTD [Strike Off] CIN = U51900MH1981PTC024810

Company & Directors' Information:- CHENNAI FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1995PTC030934

Company & Directors' Information:- K S EXPORTS (INDIA) PVT LTD [Strike Off] CIN = U99999DL1982PTC014804

Company & Directors' Information:- G. EXPORTS PVT LTD [Active] CIN = U51909DL1989PTC034690

Company & Directors' Information:- A AND A EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL1994PTC060898

Company & Directors' Information:- A E FINANCE PRIVATE LIMITED [Active] CIN = U65999TZ1990PTC002905

Company & Directors' Information:- A K HOUSE PRIVATE LIMITED [Strike Off] CIN = U70109WB1953PTC021083

Company & Directors' Information:- D Y EXPORTS PRIVATE LIMITED [Active] CIN = U51311DL2002PTC117474

Company & Directors' Information:- S V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909KL1995PTC009740

Company & Directors' Information:- F C EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51398TG1997PTC026815

Company & Directors' Information:- L R FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65910UP1988PTC009758

Company & Directors' Information:- S B M FINANCE LIMITED [Strike Off] CIN = U65921PB1994PLC014374

Company & Directors' Information:- C M A EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74999DL1984PTC018445

Company & Directors' Information:- T A S FINANCE PVT LTD [Strike Off] CIN = U65191TN1990PTC018654

Company & Directors' Information:- S P S EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL2005PTC142414

Company & Directors' Information:- M C EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1991PTC044271

Company & Directors' Information:- R L EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1989PTC034754

Company & Directors' Information:- K. T. M. EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74999UP2005PTC031149

Company & Directors' Information:- C L EXPORTS PRIVATE LIMITED [Active] CIN = U51909WB2014PTC201763

Company & Directors' Information:- R P EXPORTS PVT LTD [Active] CIN = U52190WB1988PTC043576

Company & Directors' Information:- D AND O FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U74899DL1993PTC054788

Company & Directors' Information:- A AND N EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL2003PTC123528

Company & Directors' Information:- I I EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL2004PTC125685

Company & Directors' Information:- A S G EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2005PTC133462

Company & Directors' Information:- H R P FINANCE PRIVATE LIMITED [Strike Off] CIN = U65921PB1995PTC015715

Company & Directors' Information:- J S EXPORTS PVT LTD [Strike Off] CIN = U18101WB1976PTC030669

Company & Directors' Information:- L B EXPORTS PVT LTD [Strike Off] CIN = U99999DL1981PTC011770

Company & Directors' Information:- G E EXPORTS PRIVATE LIMITED [Strike Off] CIN = U18101PB1999PTC022745

Company & Directors' Information:- P T R FINANCE PRIVATE LIMITED [Strike Off] CIN = U65191TN1989PTC016795

Company & Directors' Information:- N. V. EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909TG1981PTC003088

Company & Directors' Information:- A & Z EXPORTS PRIVATE LIMITED [Strike Off] CIN = U52590DL1995PTC065933

Company & Directors' Information:- C S P EXPORTS PVT LTD [Strike Off] CIN = U52321TN1987PTC015088

Company & Directors' Information:- S M S EXPORTS PVT. LTD. [Strike Off] CIN = U52599TN1989PTC017759

Company & Directors' Information:- K D EXPORTS PVT LTD [Strike Off] CIN = U51900MH1981PTC025255

Company & Directors' Information:- S H R EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51390TG1996PTC024134

Company & Directors' Information:- B & S FINANCE PVT LTD [Strike Off] CIN = U65191TN1988PTC015491

Company & Directors' Information:- I C L EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909TZ2004PTC010968

Company & Directors' Information:- B P EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51900MH1982PTC027564

Company & Directors' Information:- R U EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909PB2000PTC023628

Company & Directors' Information:- A V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909PB2010PTC034427

Company & Directors' Information:- H S B FINANCE PVT LTD [Strike Off] CIN = U67120RJ1996PTC012119

Company & Directors' Information:- S R EXPORTS PRIVATE LIMITED [Active] CIN = U72100MH2000PTC127505

Company & Directors' Information:- G AND V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U17290MH2013PTC243077

Company & Directors' Information:- J D EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51900MH1999PTC122821

Company & Directors' Information:- J N D EXPORTS PRIVATE LIMITED [Strike Off] CIN = U36912MH2012PTC233325

Company & Directors' Information:- S U K EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909MH2003PTC143006

Company & Directors' Information:- P AND A EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909MH2003PTC143381

Company & Directors' Information:- R G S T EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909TN2003PTC050349

Company & Directors' Information:- S S V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909TZ2003PTC010733

Company & Directors' Information:- G & H EXPORTS PRIVATE LIMITED [Active] CIN = U51101UP2015PTC068447

Company & Directors' Information:- CHENNAI FINANCE CO PRIVATE LIMITED [Under Process of Striking Off] CIN = U65991TN1981PTC009023

Company & Directors' Information:- K B R EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1994PTC062164

Company & Directors' Information:- S R N EXPORTS PRIVATE LIMITED [Strike Off] CIN = U00000DL2001PTC109284

Company & Directors' Information:- N A EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51101DL2007PTC163353

Company & Directors' Information:- J M EXPORTS PRIVATE LIMITED [Active] CIN = U74140DL2015PTC281567

Company & Directors' Information:- A K M EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL1996PTC075590

Company & Directors' Information:- Z A EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909DL2004PTC126237

Company & Directors' Information:- D S N EXPORTS PRIVATE LIMITED [Converted to LLP] CIN = U51909DL2005PTC138224

Company & Directors' Information:- R B T EXPORTS PRIVATE LIMITED [Active] CIN = U51909DL2015PTC286172

Company & Directors' Information:- G. A. EXPORTS PRIVATE LIMITED [Converted to LLP] CIN = U74999DL2007PTC158820

Company & Directors' Information:- T T EXPORTS PRIVATE LIMITED [Active] CIN = U51311DL2003PTC122519

Company & Directors' Information:- S. A. K. SILKS PRIVATE LIMITED [Strike Off] CIN = U17122KA2011PTC057533

Company & Directors' Information:- M. J. S. FINANCE COMPANY PRIVATE LIMITED [Strike Off] CIN = U65921PB1971PTC003049

Company & Directors' Information:- B B L EXPORTS PRIVATE LIMITED [Strike Off] CIN = U18101DL1983PTC016088

Company & Directors' Information:- R D EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74899DL1995PTC070536

Company & Directors' Information:- V AND V EXPORTS PRIVATE LIMITED [Strike Off] CIN = U15201TG2004PTC044495

Company & Directors' Information:- K R EXPORTS PRIVATE LIMITED. [Strike Off] CIN = U18101DL1986PTC022942

Company & Directors' Information:- G R EXPORTS PRIVATE LIMITED [Under Process of Striking Off] CIN = U51909KA1990PTC011271

Company & Directors' Information:- R K EXPORTS PVT LTD [Strike Off] CIN = U52322CH1980PTC004234

Company & Directors' Information:- A S EXPORTS PRIVATE LIMITED [Strike Off] CIN = U74900DL1987PTC027301

Company & Directors' Information:- A R FINANCE PVT LTD [Strike Off] CIN = U65921PB1989PTC009778

Company & Directors' Information:- N L EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909KL1999PTC013062

Company & Directors' Information:- K G FINANCE LIMITED [Strike Off] CIN = U65910TZ1982PLC001219

Company & Directors' Information:- S AND Z FINANCE PRIVATE LIMITED [Strike Off] CIN = U65923PN1997PTC106520

Company & Directors' Information:- R S EXPORTS PRIVATE LIMITED [Strike Off] CIN = U99999MH1980PTC022965

Company & Directors' Information:- H S N FINANCE PVT LTD [Strike Off] CIN = U67120PB1993PTC013900

Company & Directors' Information:- G N FINANCE PVT LTD [Strike Off] CIN = U65990MH1981PTC024294

Company & Directors' Information:- I & K EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909PN2008PTC132158

Company & Directors' Information:- A K EXPORTS PVT LTD [Strike Off] CIN = U99999DL1978PTC008988

Company & Directors' Information:- S M D L EXPORTS PVT LTD [Strike Off] CIN = U51909DL1975PTC007846

Company & Directors' Information:- A O G EXPORTS PRIVATE LIMITED [Strike Off] CIN = U51909PB1997PTC019454

Company & Directors' Information:- C S FINANCE PRIVATE LIMITED [Strike Off] CIN = U65910GJ1987PTC009799

    W.P. No. 33412 of 2006

    Decided On, 26 May 2020

    At, High Court of Judicature at Madras

    By, THE HONOURABLE MR. JUSTICE R. MAHADEVAN

    For the Petitioner: Mallika Srinivasan, Advocate. For the Respondents: R2 & R3, Pushya Sitaraman, Standing Counsel for Income-tax Dept.



Judgment Text


(Prayer: Writ Petition filed under Article 226 of the Constitution of India, praying for issuance of a Writ of Certiorarified Mandamus to call for the records in No.561/ KNK/1/29/2001-IT dated 30.03.2005 on the file of the first respondent, quash the same to the extent of which it has declined to compute and allow the relief under Section 80-HHC of the Income Tax Act and direct the said respondent to compute and allow the said relief.)

1. The petitioner is a company registered under the Companies Act on 21.10.1982 under the name and style of M/s.Shakashambana Silk Exports (P) Limited and subsequently the name has been changed to M/s.Mulberry Silks Limited. It is stated in the affidavit filed in support of this writ petition that the petitioner is engaged in the business of import and local purchase of yarn and export and local sales of yarn and fabrics produced on local power looms. The promoters of the company acquired controlling interest in another company known as M/s.H.C.Pharma (P) Ltd., which name was subsequently changed to M/s.Mulberry Silk International (P) Ltd. ('MSIL' in short) in 1994, with the intention of setting up an independent sophisticated fabric weaving unit. In January 1999, there was a consequential search in the premises of the petitioner and in the course of search, it was noticed that there was stock deficit of imported yarn to the extent of Rs.2,22,41,057/-. It is stated by the petitioner that he had invested a sum of Rs.4,84,88,500/- in MSIL as on 31.03.1997. The original share capital of the company was invested by the Directors and the members of the family. Pursuant to the search, the assessing authority had initiated assessment proceedings under Chapter XIV-B of the Income Tax Act. Thereafter, the petitioner filed returns for the block period 01.04.1988 to 31.03.1998 and 01.04.1998 to 25.01.1999, on 02.08.1999. The petitioner also filed an application for settlement before the Settlement Commission on 16.06.2001, for the assessment years 1995-96 and 1996-97. In respect of assessment year 1995-96, the petitioner disclosed an income of Rs.12,11,980/- and in respect of assessment year, the petitioner disclosed an income of Rs.1,33,08,280/- before the Settlement Commission. A revised statement of facts was filed before the Settlement Commission on 15.03.2002. Pursuant to the revised offer, the petitioner declared an income of Rs.43,52,900/- for the assessment year 1995-96 and Rs.1,90,69,056/- for the assessment year 1996-97. On 15.03.2002, the Settlement Commission accepted the settlement application filed by the petitioner. On 30.03.2005, the Settlement Commission passed a final order in the settlement application holding that the undisclosed income offered by the petitioner in the block assessment did not affect in any way the export profits of the petitioner and consequently, there is no need for re-computing the deduction under Section 80HHC.

2. Challenging the proceedings dated 30.03.2005 of the Settlement Commission, by which the petitioner's request for re-computing the deduction under Section 80HHC has been declined, the present writ petition has been filed.

3. The learned counsel for the petitioner has submitted that the Settlement Commission, having determined the total income from business including the income from the unaccounted sale of imported yarn which formed part of the petitioner's business, ought to have determined the relief under Section 80HHC of the Income-tax Act in accordance with the statutory provisions. The Settlement Commission is a Body created under the Income-tax Act and hence it is bound by the provisions of the Act. No valid reason has been given by the Settlement Commission in support of its refusal to do so. Even though the Settlement Commission has unequivocally determined the total income from business and has also found that the income so determined represented income from business, but it has erroneously held that the determination of such income did not affect the export profits and hence the relief under Section 80HHC is not required to be computed. The learned counsel for the petitioner, finally stating that the impugned order has resulted in additional tax liability in excess of the tax lawfully due under the provisions of the Act, prayed for allowing the prayer as sought for in this writ petition.

4. A counter affidavit has been filed on behalf of the respondents 2 and 3, in which it is stated that the Settlement Commission has passed the impugned order only after considering the peculiar facts and circumstances involved in the petitioner's case, for which detailed reasons have been given in the impugned order.

5. Reiterating the averments made in the counter affidavit filed on behalf of the respondents 2 and 3, the learned standing counsel for the respondents 2 and 3 / Department, has submitted that the Settlement Commission has dealt with the matter in a proper perspective and has given a finding that the explanation offered by the petitioner at the time of search on the two crucial issues, viz.huge stock deficit found and the ownership of shares in MSIL, was materially different from the one offered much later, just prior to the completion of the block assessments. The learned counsel has also submitted that the petitioner has no satisfactory explanation for the contradictory stands taken at various stages and before the various authorities. Stating so, the learned standing counsel prayed for dismissing the writ petition.

6. On the other hand, the learned Standing Counsel for the respondents 2 and 3, has submitted that the significant cause of action of the present case, arises in the State of Karnataka and hence this Court should not entertain this writ petition.

7. Heard the learned counsel on either side and perused the papers.

8. The learned counsel for the petitioner has contended that no valid reason has been given by the Settlement Commission to come to the conclusion that the relief under Section 80HHC is not required to be computed. But, in the impugned order, the Settlement Commission has held that the entire income offered by the petitioner in the block assessment admittedly represented profits derived from sale of imported goods in the local market and admittedly such sale took place purely on cash and carry basis without the imported goods reaching the petitioner's factory / godown and no records were maintained by the petitioner in respect of such sales. The Settlement Commission has also held that the proceedings by the DRI officials in this case began as early as in May 1996 and the income tax search was only in January 1999 and that if the factual position had emerged clearly in the course of the investigations by the DRI, it would have been natural for the petitioner herein to own up the same before the income tax authorities at the time of search. The Settlement Commission has further held that no satisfactory explanation has been given by the petitioner in this connection, for the contradictory stands taken at various stages and before the various authorities. Only in these circumstances, the Settlement Commission went on to state that it would not be possible to them to give a clear finding that the entire investment in shares in MSIL has been made by the petitioner. It has also been held that even otherwise, the Commission would be exceeding its jurisdiction if any directions are issued in respect of the cases which are not before it.

9. But, this Court is not inclined to go into the merits of the case since the petitioner herein and the assessing authorities are at Bangalore and merely because the order under challenge had been passed by the Chennai Bench of the Settlement Commission, the cause of action cannot be said to arise within the territorial jurisdiction of this Court, when the events leading to the filing of the proceedings before the Chennai Bench of the Settlement Commission and the parties to such proceedings are outside the territorial jurisdiction of this Court and hence it would not be appropriate to entertain this writ petition by this Court.

10. In this connection, it would be appropriate to refer to the order passed by this Court in W.P.No.31537 of 2016 dated 22.11.2017, wherein, while considering the contention of the learned counsel for the petitioner therein that since the Settlement Commission had not decided the matter on merits, one more opportunity may be given to the petitioner therein to go before the Settlement Commission, this Court has analysed the issue and held that even though there was no specific reason given by the Settlement Commission to show that there was no true and full disclosure of the petitioner's duty liability therein, it was true that the authorised representative engaged by the petitioner therein, did not extend full cooperation and further there has been change of the authorised representative and therefore, that there was every justification on the part of the Settlement Commission for having refused to entertain the application.

11. In the case of Kusum Ingots & Alloys Ltd. v. Union of India, reported in (2004) 168 ELT 3 (SC), one of the questions considered by the Hon'ble Supreme Court was regarding Forum Conveniens and it was pointed out that even if a small part of cause of action arises within the territorial jurisdiction of the High Court, the same by itself may not be considered to be a determinative factor compelling the High Court to decide the matter on merits and in appropriate cases, the Court may refuse to exercise its discretionary jurisdiction by invoking the doctrine of Forum Conveniens.

12. At this juncture, it would be appropriate to refer to the decision of the High Court of Delhi, in the case of R.T.Industries v. Income-tax Settlement Commission, reported in [2018] 98 taxmann.com 236 (Delhi). Paragraph-45 of the said judgment, reads as under:

“45. Lastly, we would like to deal with the objection with regard to territorial jurisdiction. A five-Judges Bench of this Court in Sterling Agro Industries Ltd. v. Union of India [W.P.(C)No.6570 of 2010, dated 1-8-2011] has drawn a distinction between cause of action jurisdiction and doctrine of forum conveniens. It has been observed that if a miniscule part of the cause of action has accrued within the jurisdiction of the Court, a writ petition would be maintainable before the said High Court. However, the expression “cause of action” must be understood in the light of the decision of the Supreme Court in Alchemist Ltd. v. State Bank of Sikkim [2007] 1 SCC 335, which means material essential or integral part of the cause of action. Therefore, even if a small part of cause of action had arisen within the jurisdiction of a court, the writ petition before the said court would be maintainable. In the context of the present case, we need not dilate further on the said issue for what is impugned and challenged before us is the order of the Settlement Commission under Section 245D (1), which is an order passed without having the views of the Revenue. Principal Bench of the Settlement Commission located and functions from Delhi. The order was passed in Delhi. In the context of the present writ petition, we would record that notice in this writ petition was issued by a Division Bench of this Court on 19th May 2017. In these circumstances, it would not be appropriate to invoke doctrine of forum conveniens.”

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13. It would also be appropriate to refer to one another decision of the High Court of Delhi, in the case of West Coast Ingots (P) Ltd. v. Commissioner of C.Ex., New Dehi, reported in 2007 (209) E.L.T. 343 (Del.), wherein the petitions filed against the orders passed by the Settlement Commission, New Delhi were rejected, holding that the significant part of cause of action cannot be said to arise within the territorial jurisdiction of High Court at Delhi, merely because the order under challenge had been passed by a Tribunal located within its territorial jurisdiction, when the events leading to the filing of the proceedings before such Tribunal and the parties to such proceedings are outside the territorial jurisdiction of the Court. This stand has been taken since both the parties therein were located at Goa. 14. Taking note of the principles enunciated in the above decisions and taking note of the fact that the petitioner herein and the assessing authorities are at Bangalore, as already observed above, it would not be appropriate for this Court to entertain this writ petition and accordingly the writ petition is dismissed, however, leaving it open to the petitioner to approach the High Court of Karnataka, for appropriate relief. No costs.
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