Vildirect: IncomeTax-caselaws-1989-VIL-44-SC-DT

1989-VIL-44-SC-DT

Equivalent Citation: Other Citation: [1990] 183 ITR 43 (SC), 1989 AIR 1707, 1989 (2) SCR 994, 1989 (2) Suppl. SCC 642

Supreme Court of India

C.A. 2697 OF 1989

Date: 02.05.1989

ELECTRONICS CORPORATION OF INDIA LIMITED

COMMISSIONER OF INCOME-TAX AND ANOTHER

BENCH

M. N. VENKATACHALAIAH., R. S. PATHAK. and RANGANATH MISRA.

JUDGMENT

(In Writ Petition No. 105 of 1987)

WAGHRAY J. -Messrs. Electronics Corporation of India Limited seeks a direction in the nature of mandamus to the Income-tax Officer (respondent No. 2) and the Commissioner of Income-tax (respondent No. 1) to issue a "No objection certificate" because the Commissioner has, by his order dated December 23, 1986, declined to instruct the Income-tax Officer to issue it.

The facts lie in a narrow compass. The petitioner entered into a memorandum of understanding with a Norwegian company at Paris, which was followed up by an agreement dated May 2, 1986, at Hyderabad. In terms of the said agreement, the Norwegian company is to provide technical know-how and technical services including facilities for training of personnel of ECIL in connection with the manufacture of computers in consideration of the Norwegian currency NOK 32 millions which is said to be approximately equal to Rs. 575 lakhs. 85 per cent. of the consideration is to be paid from credit provided by the Norwegian authorities and the balance 15 per cent. to be paid out of free foreign exchange made available by the State Bank of India, London Branch. It is not in dispute that the said agreement has been approved by the Reserve Bank of India as well as the Central Government. The petitioner approached the second respondent, the Income-tax Officer, for grant of a "No objection certificate" as contemplated by section 195(2) of the Income-tax Act, 1961, to enable it to make the remittance of the instalments due without any obligation to deduct any income-tax at source. No formal application appears to have been filed before the Income-tax Officer, but, as he had expressed his inability to comply with the request, the company made a detailed application dated December 23, 1986, to the Commissioner of Income-tax. The Commissioner, after hearing counsel for the petitioner has, by his letter dated December 23, 1986, declined to issue any instructions sought for by the petitioner, to the Income-tax Officer. He pointed out to the provisions of sections 9(1)(vii) and 195 of the Income-tax Act, 1961, and observed that the aforesaid payment is income which is deemed to accrue or arise in India and was liable to deduction of tax at source.

In this writ petition, the correctness of the conclusion of the Commissioner and also the validity of section 9(1)(vii) of the Act are questioned and the relief as aforesaid is prayed for. Respondent No. 1 has filed a counter-affidavit and opposed the writ petition. A reply also has been filed on behalf of the petitioner.

Sri Ranganathachari, learned counsel for the petitioner, has raised the following contentions:

(1) Parliament is not competent to enact clause (vii) of sub-section (1) of section 9 as it has an extra-territorial operation without any nexus between the person sought to be taxed and the country seeking to tax and also involves the fiction of deemed income arising in India.

(2) Even after the introduction of clause (vii) to sub-section (1) of section 9 by the Finance Act of 1976 with effect from June 1, 1976, the requirement of business connection of the foreign company is necessary and the ratio of the Supreme Court decision in Carborandum Co. v. CIT [1977] 108 ITR 335 continues to apply.

(3) After the introduction of the Explanation by the Finance (No. 2) Act of 1977 with effect from April 1, 1977, the aforesaid clause in section 9(1) creates invidious discrimination between companies which had entered into foreign collaboration agreements prior to April 1, 1976, and those after that date and it is, therefore, violative of article 14.

We have heard counsel for the petitioner and standing counsel for the Department.

Point No. 1 : Before considering the contentions, it is useful to notice, in brief, certain relevant legislative provisions. The Indian Income-tax Act, 1922, was passed by the Indian Legislature in exercise of its power conferred by the British Parliament under the Government of India Act 1915-1919, later replaced by the Government of India Act, 1935. Section 99(1) of the Government of India Act, 1935, which conferred the legislative power reads as follows :

"99. Extent of Federal and Provincial laws.-(1) Subject to the provisions of this Act, the Federal Legislature may make laws for the whole or any part of British India or for any Federal State and a Provincial Legislature may make laws for the Province or for any part thereof."

After the advent of Independence and the adoption of the Constitution, we are a sovereign Republic. The Constitution, in Chapter I of Part XI, deals with the legislative relations between the Union and the States. Article 246 provides for the subjects in three Lists regarding which the Union Parliament and the State Legislature can make laws. Article 245 which is relevant reads as follows:

"245. (1) Subject to the provisions of this Constitution, Parliament may make laws for the whole or any part of the territory of India, and the Legislature of a State may make laws for the whole or any part of the State.

(2) No law made by Parliament shall be deemed to be invalid on the ground that it would have extra-territorial operation."

There was no provision corresponding to article 245(2) in the Government of India Acts. Our Parliament is the legislature of a sovereign nation, while the Indian Legislature created under the Acts of British Parliament was having its legislative competence only in respect of specified territories. The Income-tax Act, 1961, is a post-Constitution law made by Parliament in exercise of its power under List-I, item 82. Section 4(1) of the Act is the charging section. Section 4(2) provides for deduction at source of income-tax where it is deductible under the provisions of the Act. The scope of the total income under the Act is dealt with in section 5, sub-section (2) of which is relevant:

"5. (2) Subject to the provisions of this Act, the total income of any previous year of a person who is a non-resident includes all income from whatever source derived which (a) is received or is deemed to be received in India in such year by or on behalf of such person ; or

(b) accrues or arises or is deemed to accrue or arise to him in India during such year."

Section 6 deals with "Residence in India" and, according to the definition in section 2(30), a "non-resident" means a person who is not a "resident". The Norwegian Company is a "non-resident" for the purposes of the Act. Income deemed to accrue or arise in India is dealt with in section 9. The next relevant provision is the portion of section 9(1)(vii) which reads as follows :

"9. (1) The following incomes shall be deemed to accrue or arise in India - . . .

(vii) income by way of fees for technical services payable by (a) the Government; or

(b) a person who is a resident, except where the fees are payable in respect of services utilised in a business or profession carried on by such person outside India or for the purposes of making or earning any income from any source outside India; or

(c) a person who is a non-resident, where the fees are payable in respect of services utilised in a business or profession carried on by such person in India or for the purposes of making or earning any income from any source in India:

Provided that nothing contained in this clause shall apply in relation to any income by way of fees for technical services payable in pursuance of an agreement made before the 1st day of April, 1976, and approved by the Central Government.

Explanation 1.-For the purposes of the foregoing proviso, an agreement made on or after the 1st day of April, 1976, shall be deemed to have been made before that date if the agreement is made in accordance with proposals approved by the Central Government before that date.

Explanation 2. -For the purposes of this clause, 'fees for technical services' means any consideration (including any lump sum consideration) for the rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head 'Salaries'."

Then, reference has to be made to section 195 which provides for deduction of tax at source:

"195(1) Any person responsible for paying to a non-resident, not being a company, or to a company which is neither an Indian company nor a company which has made the prescribed arrangements for the declaration and payment of dividends within India, any interest, not being 'interest on securities', or any other sum, not being dividends, chargeable under the provisions of this Act, shall, at the time of payment, unless he is himself liable to pay any income-tax thereon as an agent, deduct income-tax thereon at the rates in force :

Provided that nothing in this sub-section shall apply to any payment made in the course of transactions in respect of which a person responsible for the payment is deemed under the proviso to sub-section (1) of section 163 not to be an agent of the payee :

Provided further that the deduction of income-tax from any sum, being income chargeable under the head 'Capital gains' relating to capital assets other than short-term capital assets, paid to a company which is neither an Indian company nor a company which has made the prescribed arrangements for the declaration and payment of dividends within India, shall be of an amount equal to the amount of income-tax on such sum calculated in accordance with the provisions of clause (i) of section 115.

(2) Where the person responsible for paying any such sum chargeable under this Act, other than interest on securities, dividend and salary to a non-resident, considers that the whole of such sum would not be income chargeable in the case of the recipient, he may make an application to the Income-tax Officer to determine, by general or special order, the appropriate proportion of such sum so chargeable, and upon such determination, tax shall be deducted under sub-section (1) only on that proportion of the sum which is so chargeable ......."

The petitioner's contention is that our Parliament is not competent to enact section 9(1)(vii) as it has extra-territorial operation by creating a fiction of income accruing in India without any nexus between the "non-resident" sought to be taxed and our country seeking to tax it. According to him, the Norwegian company does not have any office in India, nor does it have any business activity in this country. It is further contended that the payments made to the Norwegian company was not liable to Indian income-tax and, consequently, the petitioner was not obliged to deduct any payment towards advance tax from the amount being paid by it. Reliance is placed on a decision of the Privy Council in Wallace Brothers and Co. Ltd. v. CIT [1948] 16 ITR 240 and that of the Federal Court in A. H. Wadia v. CIT [1949] 17 ITR 63. Reference is also made to the judgment of the Supreme Court reported in Carborandum Co. v. CIT [1977] 108 ITR 335 and the opinion of the learned author and jurist, Sri N. A. Palkhivala, in his commentary in his book the Law and Practice of Income-tax, 7th Edition (Vol. I), at page 209. It is contended that as the petitioner was not obliged to deduct any amount towards advance tax, it is entitled to a certificate as contemplated by section 195(2) of the Act.

Standing counsel for the Revenue has, on the other hand, supported the action of the Commissioner and contended that the petitioner is obliged to make a deduction of advance tax from any payments made to the Norwegian company towards fees for technical services as it is obliged to do so as contemplated by section 195(1) of the Income-tax Act.

The undisputed facts are : The agreement was entered into between the petitioner and the foreign company at Hyderabad. Clauses 1.6, 1.7, 1.8 define technical know-how, technical services and training. Clause 1.11 defines manufacturing territory as India and clause 1.12 states territory as India and some other countries. Clauses 14, 14.1 and 14.2 provide for consideration to be paid by the petitioner for rendering technical services, etc., by the Norwegian company. The technical know-how, technical services and technical personnel for imparting training to the employees of the petitioner-company and the other facilities are for the purpose of being utilised by the petitioner in its business of manufacture in India and its sales activities in India and other countries. By clause 22.1, the agreement is to be governed and interpreted in accordance with the laws of India. Other clauses in the agreement like 1.12, 2.1, 2.3, 2.4 and 2.5 put certain fetters on the petitioner-company regarding the utilisation of the know-how, etc., and excluding its exploitation in named territories. There are other provisions contemplating damages and resolution of disputes by arbitration.

All the three cases (i.e., of the Privy Council, the Federal Court and our Supreme Court) relied upon by the petitioner deal with the provisions of the Indian Income-tax Act, 1922. In the Privy Council case, the assessee-company was having its head office at London, but it was also a partner in a firm carrying on business at Bombay. The controversy was whether the income of the assessee-company which accrued beyond British India was also liable to tax along with its income as a partner in the firm at Bombay. The company's appeal to the Privy Council against the judgment of the High Court in India holding that it was liable to tax was dismissed. While considering sections 4A(c) and 4(1)(b)(ii) of the Indian Income-tax Act, 1922, the Privy Council noticed that the legislative power of the Indian Legislature was derived from section 99(1) of the Government of India Act, 1935. It further observed that, in accordance with the pattern of the income-tax legislation in the United Kingdom, sufficient territorial connection like residence is implicit in the power to legislate conferred by the British Parliament. In view of article 245(2) of the Constitution and also the facts of the present case stated above, the aforesaid observations of the Privy Council are not of any assistance to the petitioner.

In the Federal Court case reported in A. H. Wadia v. CIT [1949] 17 ITR 63, the five judges who heard the case have delivered separate opinions. The provisions of the Indian Income-tax Act, 1922, read with the Government Trading Taxation Act, 1926, fell for interpretation. The controversy was about the liability to tax of certain income accruing in British India of the Ruler of the native State of Gwalior (referred to as the Durbar) represented by his agent in Bombay. The Ruler of a native State was not a resident of British India. The competence of the Indian Legislature to enact the law for taxing persons who are not residing within British India without any business connection or territorial nexus was discussed while considering the provisions of the Indian Income-tax Act, 1922, and the Government Trading Taxation Act. But, no provision of the Act was held to be ultra vires. Certain observations in the opinions even go against some of the contentions of the petitioner now raised. In view of article 245(2) of the Constitution and the provisions of the Indian Income-tax Act with which we are now concerned, the observations in this case will not help the petitioner.

In the Supreme Court case reported in Carborandum Co. v. CIT [1977] 108 ITR 335, the applicability and interpretation of the provisions of section 4(1)(c) read with section 42 of the Indian Income-tax Act, 1922, came up for consideration. It was held that, in respect of a person who is not a resident in the taxable territories, income which is deemed to accrue or arise from a business carried on in India wholly or in part is liable to tax. It is pointed out that a business connection must be established before any such income of a non-resident is liable to tax under that provision. The validity of any statutory provision on the ground of legislative competence did not arise. The provision similar to the one now under consideration was not on the statute book then. This case also does not help the petitioner. The opinion of the learned author and jurist, Sri N. A. Palkhivala, in his book The Law and Practice of Income Tax, 7th Edition (Vol. I), page 209, is also relied upon by counsel for the petitioner. Several examples cited by the learned author are of payments made by an Indian to a non-resident outside India in respect of transactions also made outside India. Sub-clause (vii) deals with payment of fees for technical services and know-how paid to a non-resident by an Indian for use in its business in India. The facts in this case show that the payment is made by the Indian company to a foreign company towards fees for technical services and know-how which has to be used by the Indian company in its business in India. It is well-known that, for the purpose of the Income-tax Act, the fiction of income deemed to arise in the country where tax is levied is not uncommon. For taxing the fees for technical services paid to the non-resident for exploiting the know-how in business in India, it cannot be said that there is no territorial connection with India for invoking the fiction. The rapid development in technical and industrial fields and growing importance of technical services and know-how in international trade cannot be lost sight of. In fact, the world has shrunk for business and industry. It is also being realised that there is need to control and regulate the multi-national companies with capacity to operate in several countries. The narrow tests of territorial nexus evolved by the courts in England may not be suitable for application by a developing country like ours in the developments which are taking place. The language and spirit of article 245(2) is clear. The courts will be slow in striking down a law made by Parliament merely on the ground of extra-territorial operation. It is well-known that our country had entered into agreements with several other nations providing for double taxation relief and if there is a real apprehension of deterrence to foreign collaboration, it will be expected that the Government will take suitable action. We are not able to agree with the contention of the petitioner that the impugned provisions are beyond the legislative competence of Parliament. One more aspect which has to be kept in view is that the writ petition has been filed at the stage of deduction of advance tax by the petitioner-company.

Point No. 2 : As already pointed out, the Supreme Court decision in Carborandum Co.'s case [1977] 108 ITR 335 considered the provisions of section 4(1)(c) read with section 42 of the Indian Income-tax Act, 1922, and, on the language of the provisions, held that a business connection in India is necessary for taxing any income of a non-resident deemed to arise in India. The Income-tax Act, 1961, was amended by the Finance Act, 1976, by adding certain clauses in section 9(1) including clause (vii) (extracted above) by which the fees for technical services paid by an Indian to a non-resident and used in the Indian firm in India is deemed to be income arising in India. Section 9(1)(i) of the present Act is analogous to section 4(1)(c) of the 1922 Act. In view of the clear language of the new clause added in 1976, it cannot be said that the conditions of section 9(1)(i) alone make the income of a non-resident liable to tax. Counsel for the petitioner has referred to a decision of the Karnataka High Court reported in VDO Tachometer Werke, West Germany v. CIT [1979] 117 ITR 804 in support of his case that, even after the amendment, the earlier law as enunciated by the Supreme Court in Carborandum Co.'s case [1977] 108 ITR 335 has to be applied. We are not able to see any such ratio in this decision. This point is also held against the petitioner.

Point No. 3 : Clause (vii) of section 9(1) was introduced by the Finance Act, 1976, with effect from June 1, 1976. Later, by the Finance (No. 2) Act of 1977, the proviso and Explanations have been introduced to the said clause with effect from April 1, 1977. The effect of the 1977 amendment is that any payment made towards fees for technical service pursuant to any agreement prior to April 1, 1976, and approved by the Central Government is saved from the applicability of clause (vii). Apparently, this 1977 amendment was made to save the payments that may be made pursuant to the agreements entered into prior to April 1, 1976, i.e., the financial year in which the 1976 amendment was made. This clarifies that the 1976 amendment does not have retrospective effect regarding agreements already entered into. It is, however, contended by counsel for the petitioner that by introducing the said proviso by the 1977 Act, the entire sub-clause (vii) has become discriminatory as it makes an invidious discrimination between persons having agreements prior to April 1, 1976, and those entered into later. We are not able to agree with counsel for the petitioner that clause (vii) suffers from any vice of discrimination. The 1977 amendment merely restricts the application of the 1976 amendment to agreements entered into after April 1, 1976. This, certainly, is a reasonable classification and we do not see any illegality in making such a classification. If at all, there may be a complaint that the proviso saving the earlier agreements is bad, but the petitioner's complaint is not that the proviso is bad, but that the entire clause is invalid. The third contention of the petitioner is also rejected.

As a result, the writ petition is dismissed. We, however, make no order as to costs.

An oral application for leave to appeal to the Supreme Court is made by counsel for the petitioner under section 261 of the Income-tax Act. We do not think that any question of general importance requiring the consideration of the Supreme Court as contemplated by article 133 of the Constitution arises in this case.

Leave is refused.

The petitioner preferred petitions for special leave to the Supreme Court under article 136 of the Constitution of India to appeal against this judgment as well as the judgment dated July 1, 1987, in W. P. No. 8737 of 1987.].

N. A. Palkhivala, Senior Advocate (Ranganathachari, P. A. S. Rao, Miss Ruby Anand and D. N. Misra, Advocates of J. B. Dadachanji and Co, Advocates, with him), for the appellant.

S. C. Manchanda, Senior Advocate (B. B. Ahuja and Miss A. Subhashini, Advocates, with him), for the respondents.

JUDGMENT OF THE SUPREME COURT

The judgment of the court was delivered by

PATHAK C. J. I.-Special leave granted.

These appeals by special leave are directed against the dismissal by the Andhra Pradesh High Court of writ petitions filed by the appellant.

The appellant, Messrs. Electronics Corporation of India Ltd., entered into a memorandum of understanding with a Norwegian company at Paris. This was followed by an agreement dated May 2, 1986, executed at Hyderabad. Under that agreement, the Norwegian company was to provide technical know-how and technical services, including facilities for the training of personnel, to the appellant in connection with the manufacture of computers. The consideration for the technical know-how and technical services was represented by Norwegian currency NOK 32 millions equivalent to about Rs. 575 lakhs. Eighty-five per cent. of the consideration was to be paid from credit provided by the Norwegian authorities and the balance fifteen per cent. was to be paid out of free foreign exchange made available by the State Bank of India, London Branch. It is not in dispute that the agreement had received the careful consideration of the Reserve Bank of India and of the Central Government.

The appellant approached the Income-tax Officer for the grant of a "No objection certificate" as contemplated under section 195(2) of the Income-tax Act, 1961, to enable it to remit the instalments due without any obligation to deduct any income-tax at source, but the request was denied. On December 23, 1986, the appellant made an application to the Commissioner of Income-tax for a direction to the Income-tax Officer, but the Commissioner rejected the application. The Commissioner took the view that having regard to section 9(1)(vii) and section 195 of the Income-tax Act, 1961, the payment constituted income which was deemed to accrue or arise in India and was liable to deduction of tax at source.

The appellant filed a writ petition against the order of the Commissioner and assailed the constitutional validity of section 9(1)(vii) of the Act. It was urged before the High Court that Parliament was not competent to enact section 9(1)(vii) of the Act inasmuch as the provision possesses extra-territorial operation without any nexus between the person sought to be taxed and the country seeking to tax. It was further contended that, even after the introduction of section 9(1)(vii) by the Finance Act of 1976, with effect from June 1, 1976, the requirement of a business connection of a foreign company was required and the case was governed by Carborandum Co. v. CIT [1977] 108 ITR 335 (SC). It was also urged that, after the introduction of the Explanation by the Finance (No. 2) Act of 1977, with effect from April 1, 1977, section 9(1)(vii) creates an invidious discrimination among companies which had entered into a foreign collaboration agreements prior to April 1, 1976, and those who have done so after that date, and that, therefore, article 14 was violated. The High Court repelled all the contentions of the appellant and dismissed the writ petition. A similar writ petition was filed by the appellant against an order of the Commissioner of Income-tax declining to direct the grant of a "No objection certificate" in relation to disbursement made under a licence agreement with Messrs. Control Data Indo-Asia Company, U. S. A., and the writ petition was dismissed by the High Court for the reasons which had found favour with it in the earlier case.

It is contended by learned counsel for the appellant that section 9(1)(vii) of the Income-tax Act is ultra vires inasmuch as it enables the levy of income-tax on the Norwegian company in the one case and the American company in the other in circumstances which appear to show that the statute operates extra-territorially without the need for any nexus between anything done in India and the person sought to be taxed. Section 9(1)(vii) declares :

"9. (1) The following incomes shall be deemed to accrue or arise in India-...

(vii) income by way of fees for technical services payable by (a) the Government; or

Explanation.-For the purposes of this clause, 'fees for technical services' means any consideration (including any lump sum consideration) for the rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration for any construction, assembly, mining or like project undertaken by the recipient or consideration which would be income of the recipient chargeable under the head 'Salaries'."

It seems that the Revenue is proceeding on the basis that the foreign company is liable to tax and that, therefore, the petitioner is obliged to deduct at source the tax payable by the foreign company. We are informed that the services are rendered by the foreign company in the nature of training abroad to personnel belonging to the appellant, and that payment to the foreign company is also effected abroad. The Revenue rests its case on section 9(1)(vii)(b) of the Act and the question is whether, on the terms in which the provision is couched, it is ultra vires.

Now, it is perfectly clear that it is envisaged under our constitutional scheme that Parliament in India may make laws which operate extra territorial. Article 245(1) of the Constitution prescribes the extent of laws made by Parliament. They may be made for the whole or any part of the territory of India. Article 245(2) declares that no law made by Parliament shall be deemed to be invalid on the ground that it would have extra-territorial operation. Therefore, a parliamentary statute having extra-territorial operation cannot be ruled out from contemplation. The operation of the law can extend to persons, things and acts outside the territory of India. The general principle, flowing from the sovereignty of States, is that laws made by one State can have no operation in another State. The apparent opposition between the two positions is reconciled by the statement found in British Columbia Electric Railway Co. Ltd. v. King [1946] AC 527, 542 (PC):

"A Legislature which passes a law having extra-territorial operation may find that what it has enacted cannot be directly enforced, but the Act is not invalid on that account, and the courts of its country must enforce the law with the machinery available to them."

In other words, while the enforcement of the law cannot be contemplated in a foreign State, it can, none the less, be enforced by the courts of the enacting State to the degree that is permissible with the machinery available to them. They will not be regarded by such courts as invalid on the ground of such extra-territoriality.

But the question is whether a nexus with something in India is necessary. It seems to us that, unless such nexus exists, Parliament will have no competence to make the law. It will be noted that article 245(1) empowers Parliament to enact laws for the whole or any part of the territory of India. The provocation for the law must be found within India itself. Such a law may have extra-territorial operation in order to subserve the object and that object must be related to something in India. It is inconceivable that a law should be made by Parliament in India which has no relationship with anything in India. The only question then is whether the ingredients, in terms of the impugned provision, indicate a nexus. The question is one of substantial importance, specially as it concerns collaboration agreements with foreign companies and other such arrangements for the better development of industry and commerce in India. In view of the great public importance of the question, we think it desirable to refer these cases to a Constitution Bench, and we do so order.

Admin Notes (TMI):

From the para no 14 in the case of GVK INDUSTRIES LTD. [2015 (2) TMI 730 - SUPREME COURT ]

"When the matter came up for consideration before a two-Judge Bench of this Court, which taking note of the far-reaching issues of constitutional purport and the fact that they were earlier referred to in the case of Electrical Corporation of India Ltd. (supra), which was ultimately withdrawn, it, by order dated 28.11.2000, referred the instant matter to a larger Bench. On 13.7.2010, the matter again came up for consideration before a three-Judge Bench and vide its order of the same date, the matter was referred to the Constitution Bench, which answered the reference as per decision on 1.3.2011 reported in (2011) 4 SCC 36 = 2011 (3) TMI 1 - SUPREME COURT OF INDIA."

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