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DISPLAY OF NAME AND NATURE OF BUSINESS DOES NOT AMOUNT TO ADVERTISEMENT: SUPREME COURT

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In precedence of the case Bharti Airtel Vs. State of Madhya Pradesh the High Court of Madhya Pradesh declared the demand notices sent to the appellant for the payment of advertisement tax to be valid. This was challenged in the Hon’ble Supreme Court.

The appellant is a dealer of Hyundai passenger cars in Indore. He had a sign board outside the premise of the showroom displaying the business name and address of the place. Respondent number 2 issued a notice demanding Rs. 2,03,850 as advertisement tax under Section 189-A of the Municipal Act, 1965. The appellant contested that a sign board merely displaying the name of the business does not amount to “advertisement”. The objective behind putting up the sign board was only to inform the public about the business and what it deals in. The appellant filed a writ petition under article 226 of the Constitution of India but the High Court referred to the verdict given in the Bharti Airtel case and dismissed the petition. The appellant received notices to pay advertisement tax not only for the shop located within the jurisdiction of the Indore municipal corporation but also for the one located outside its jurisdiction.

The counsel for appellant contends that the facts in the Bharati Airtel case are not analogous to this case. This case deals with the issue whether a third party or a tax agency collect advertisement tax. Whereas in the present case, the issue is whether displaying the name and nature of the business amounts to advertisement. The counsel for appellant further contends that if tax is levied for the same it would be violative of article 19(1)(A) and 19(1)(G) of the Constitution.

The Indore municipal authority under sec 132(6)(1) of the municipal corporation act contends that it has rightfully demanded the advertisement tax from the appellant. The particular section states that the corporation can levy any tax contingent upon any special or general order taken by the state government, namely, ‘a tax on advertisement other than advertisements published in newspapers’ (Sub-clause (l)).

The court referred to the case of ICICI Bank and Another Vs. Municipal Corporation of Greater Bombay (2005) 6 SCC 404 which held that ‘advertisement’ must have a commercial aspect to it. It must attract the attention of the people in order to persuade them to engage in the activity of buying. Advertisement aims at providing information and is of a good or service. However, only displaying the name of the company does not amount to advertising unless it is a trade mark or trade name.

The hon’ble supreme court states that the sign board entailed the name of the business which itself is indicative of the kind of product the appellant deals with. Solely displaying the name of the enterprise or the business would not amount to advertising unless the enterprise in question in some way persuades the customer to purchase. Display boards and name boards are essential for the purposes of identification. If they are counted as advertisements, it would be impossible for customers to even identify such businesses. The context and circumstances must be taken into account.

In this case, the legislative provisions do not permit the municipal corporation to levy tax on sign boards. The objective of sign board is just to convey information about the kind of products dealt with by a business enterprise. The name of the business enterprise of the appellant shows what car he deals in and nothing more. It does not cause the public to purchase the products.

The Hon’ble court further stated that both the parties had objections to the demands made and they hastily rushed to the High Court under its extra ordinary jurisdiction. However, the court does not support the dismissal of the petition by the High Court. The outcome of the case remains unchanged and the first respondent was asked to review the objections filed by the appellant within eight weeks. In case, they decide against the appellant they cannot enforce the demands for another eight weeks. The appellants have the liberty to challenge any decision given by the Commissioner.

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Judgement Analysis written by- Rashi Hora.

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NON-ADHERENCE TO PROCEDURAL LAWS IS THE PRIMARY REASON BEHIND PENDENCY OF CASES AND JUDICIAL DELAY: SUPREME COURT.

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In the present case, the Hon’ble Supreme Court deals with the selection of the legal representative of the deceased Mrs. Urmila Devi. In 1982, a sale deed carried out by Shri Mangal Singh was challenged in court by late Urmila Devi praying to declare the same null and void by asserting ownership of the properties; and an order to possess the property in question with costs. The case was still at its primal stage when Mrs. Urmila Devi died. Hence, Mr. Manoj Kumar Jain filed an application to be the legal heir.

Mr. Manoj Kumar Jain presented a duly registered will before the court executed by Mrs. Urmila Devi and witnessed by the current appellant Mr. Yashpal Jain. He prayed before the court to be substituted as the legal representative of Mrs. Urmila Devi. He also claimed to be her legatee according to the will. The defendants by way of presenting a registered adoption deed stated that Mr. Yashpal is adopted. The trial court ruled in favour of Mr. Manoj Jain. The order was challenged by the legal heirs of Mangal Singh by means of a civil revision petition before the district judge. In the course of the revisional proceedings, Mr. Manoj mentioned that he does not wish to proceed with application filed by him to be the legal representative of Mrs. Urmila Devi. On the basis of the proceedings, the judgement given by the trial court was overruled. The district judge directed the trial court to accept the application of condonation of delay and impleadment of a legal representative by Mr. Yashpal. Mr. Yashpal filed an application for the same as well as to dismiss the abatement of suit. The trial court allowed the same and hence ruled in favour of Mr. Yashpal Jain being the legal representative of the plaintiff. 

The legal representatives of the aggrieved party filed a civil revision application before the district judge. The judge upheld the verdict of the trial court and dismissed the petition. The defendants moved to the high court challenging the orders passed by both, the trial court and the revisional court. The high court overruled the impugned orders and rejected the application by the current appellant, relying on the initial order passed by the trial court which substituted Mr. Manoj Kumar Jain as the legal representative on the strength of the registered will and directed the courts to conclude the proceedings within 9 months. The appellants were aggrieved by the orders of the high court filed the present appeal.

The counsel for the petitioner contended that the high court has made a mistake by overruling the orders of the trial court and revisional court taken after careful consideration. The lower courts have also taken diligence of the fact that Mr. Yashpal Jain is the sole living representative of Mrs. Urmila Jain and the stressed on the aforementioned fact that the defendants had pleaded to substitute the appellant in the suit pertaining to the sale deed of property by Mangal Singh. In the instance case the defendants can be seen contradicting their own stance.

The defendants contend that the appellants had not filed a counter-affidavit. On the basis of the doctrine of non-traversal this would amount to admission. The defendants mention two instances wherein the current appellant had supported Mr. Manoj Kumar Jain and his will. The appellant cannot plead ignorance for the delay.

In response to issue one the court has contended that the application filed by the defendants in regard to the writ proceedings is the very reason that the trial court and revisional court substituted Mr. Yashpal as the legal representative. The defendants cannot contend that the appellant had filed two affidavits admitting and confirming Mr. Manoj Kumar Jain as the legal representative. The affidavits were mere proof of the appellant being a signatory to the will. It did not intend to substantiate or prove any other fact to any effect.

On non-traversal of writ petition claims, the records state that Mr. Manoj himself filed an application along with an affidavit expressing his disinterest in continuing the application of being the legal representative. If the orders of the high court to not implead Yashpal Jain as the legal representative were to be sustained then the then this implies that the estate of the deceased would not be represented and the case would eventually be closed. Hence, the Hon’ble Supreme Court quashed the order of the high court and upheld the verdict given by the trial court and revisional court.

The hon’ble supreme court took cognizance of the fact that the case is ancient and long standing. In addition to the property suit, the death of Mrs Urmila devi brought in a plethora of suits to determine her legal representative. The current stage of the property suit is unknown but it is said to have been moving at a “snail’s pace” since her death. There are numerous causes for the delay. The hon’ble court mentioned that it is due this very reason that the general public becomes cynical of the justice delivery system. The court delves deeper into the numerous reasons for delay in delivering justice. Inconsistencies in the law, hefty paperwork, leniency in granting adjournments for no justifiable reason, misuse of the provisions of the CPC and CrPC are some of the reasons. The government has taken steps, formulated policies and amended laws to clear the backlog but it has only resulted in poor results. The amendments of the statutory laws have been unsatisfactory.  The court stresses on the fact that it is the responsibility of all the stakeholders to restrict the practices that delays the justice delivery process. The courts must introspect and come up with solutions to serve the public with an effective justice delivery system. The growth of a nation, in all aspects, depends on the strength of the judicial system. The Hon’ble court revisited the findings of various law commissions instituted over the years to find out the cause and remedies to the perpetual problem of huge pendency of cases and inefficient judicial administration. The various reports by law commissions talk about setting a time limit for both civil and criminal cases to be strictly followed by each of the courts and a plea to increase the manpower and immediate replacement in when there’s vacancy. In furtherance to the 77th report by the law commission, the 79th report provides an all- comprehensive guide for managerial judging, time bound trial procedures by trial courts, high courts and other appellate courts.

The court also mentions delays arising due to non-adherence of procedural laws majorly in civil trials. The courts have been frivolous with the grants of adjournment without ay justifiable reason. This is the primary contributory issue that leads to delays and ultimately losing confidence of the public in the justice delivery system. The court relied upon the case of T. Arivandandam vs. T.V. Satyapal & Another AIR (1977) 4 SCC 467 which held that the answer to an irresponsible suit or litigation would be a vigilant judge. The court acknowledges the importance of maintaining cordial relationship with judges and gives a stark remark to the lawyers to refrain from frequent adjournment requests especially while dealing with cases that have been pending since decades. Under order viii rule 1(a) of CPC a defendant must submit and present the written statement within 30 or 90 days and if he fails to do so without any genuine reason then costs must be awarded to the opposite party payable by the defendant. This rule is seldom followed.

Adjournments should be given only when the request is honest and with a bonafide intention expressed by way of affidavit. Frequent grants of adjournments defeat the purpose of the legislation. It is pertinent for all the presiding officers to strictly adhere to the time schedule provided under sub-rule 1 of rule 1 of order viii. It is the responsibility of the stakeholders to ensure the same. In the case of M. Mahalingam vs. Shashikala the intention behind the legislation was duly stated. The legislation has curbed the power of the courts to grant frequent adjournments because when a case has begun the evidence must be recorded on a daily basis and only, if necessary, adjournments should be given to the following day. This ensures that only bonfide reasons should be entertained by the court and it should be strict in it dispense of adjournments.

Innumerable legislations can be enacted to ensure speedy disposal of cases but it would be of no use until it is strictly implemented by the courts and constantly monitored by committees established for the very reason. The fundamental duties mentioned in article 51 A of the constitution must be given utmost importance in light of any problems faced by the stakeholders. The citizens must always strive towards excellency for the growth of the nation. It is important for the judiciary to regain the confidence of the public in litigation a be a ‘beacon of hope”. The Hon’ble supreme court thus directs all the lower courts to strictly adhere to the rules laid down in the procedural laws ensuring the proceedings take place as scheduled. Some courts shall be controlled by Principal District Judges who, after compiling all the statistics, shall present it before the constituted committee of the high court.

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Judgement Analysis written by- Rashi Hora.

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Granting of Permanent Commission (PC) to the Short Service Commissioned Officers (SSCO’s) in the Indian Navy must be executed without any prejudices: Supreme Court

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The issue in this case was regarding the grant of Permanent Commission (PC) to Short Service Commission Officers (SSCO’s) in the Indian Navy. The conflict arose when the Policy Letters dated 26 September 2008 was issued, which stipulated that only women from certain branches (JAG, Education and Naval Architecture), would be considered for grant of PC with a prospective application.

The case of Cdr. Seema Chaudhary versus Union of India and Others evolved as an aftermath of the Union of India vs Lieutenant Commander Annie Nagaraja case. In the case of Annie Nagaraja, the Lieutenant Commander Annie Nagaraja along with other officers challenged the above Policy Letter as being discriminatory and based on unreasonable grounds. The Court noted that the statutory bar on the enrolment of women in the Indian Navy was lifted by the notifications issued in the year 1991 and 1998. Moreover, this Court held that the policy decision of the Union Government dated 25 February 1999 would govern the conditions of service of SSCOs including women officers in regard to the grant of PCs. The Court held that the impugned PL being prospective and restricting it to specified cadres was invalid. Consequently, directed that all SSCOs in the Education, Law and Logistic Cadres who were “presently in service”, shall be considered for the grant of PC.

In the instant case, the petitioner Cdr. Seema Chaudhary is a JAG Branch officer recruited on Short Service Commission in 2007. Even after many years of service, she was denied PC due to lack of vacancies. The petitioner approached the Armed Forces Tribunal (AFT), which issued directions, considering the petitioner along with the Law Cadre officers from previous batches.

The petitioner aggrieved by the directions issued by AFT,  filed a civil appeal before the Supreme Court. The petitioner contended that considering her candidature alongside the officers of previous batches was prejudice to her appointment.

The respondents contended that such a consideration with subsequent batches was made in order to ensure that a fair opportunity was granted to all concerned officers and to widen the field of consideration.

The Supreme Court hearing the contentions of both the parties analyzed the directions issued by AFT. The court noted that by considering the candidature of the petitioner for the grant of PC along with the batches of 2011 and 2014, the AFT has deviated from the judgement passed by this court. Further, stated that to do so would amount to introducing a condition to the Lieutenant Commander Annie Nagaraja case. The court held that any directions which de-hors the judgment of the Court could not be issued.

The Court also clarified that the increase in the vacancies which is created to accommodate the petitioner shall not create any precedence for the future. The court, thus, exercised its powers under Article 142 to ensure principles of Natural Justice and Equality.

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The liability of TDS under Section 194-H can’t be extended for the ‘Payments’ made by the Assesses under ‘genuine business operations’: Supreme Court

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The issue revolving around this judgement is relating to the liability to deduct tax at source under Section 194-H of the Income Tax Act, 1961, which provides that the payer (in the present case assessee) responsible for making the payment must deduct tax from the amount paid to another person.

In the case of Bharti Cellular Limited (now Bharti Airtel Limited) versus Assistant Commissioner of Income, the Cellular mobile telephone service providers referred to as the Assesses (Appellants) contend that the discounted amount neither qualify as commission or brokerage to the franchisees/distributors, nor are the franchisees/distributors their agents.

The Revenue (Respondents) contends that the discounted amount is commission under the purview of Section 194-H which is payable to an agent by the Assesses under the franchise/ distributorship agreement between the Assesses and the franchisees/distributors.

This matter was brought before different High Courts which led to conflicting decisions. The Assesses challenged the decision of the Delhi and Calcutta High Courts which held that the assesses were liable to deduct tax at source under Section 194-H of the Act. On a contrary, the Revenue challenged the decisions of Rajasthan, Karnataka and Bombay High Courts which held that Section 194-H of the Act is not attracted under the circumstances of this case.

Subsequently, both the parties challenging the above decisions of the High Courts, appealed before the Supreme Court of India. The key issue before the Court was to interpret the Section 194-H and determine the liability of the cellular mobile service providers to deduct tax at source on the income/profit component received by their distributors/franchisees from third parties/customers.

The court fundamentally dealt with the questions of interpretation Section 194-H which further necessitated in determining the Principal-Agent relationship. Delving into the provisions of the Section the Court stated that the Section 194-H imposes the liability to deduct tax at source on “the person responsible for paying”. The provision provides that such a liability arises when income is credited or paid by the person responsible for paying. Further, the term “direct and indirect” in Explanation (i) states that the obligation vests even when the payment is made indirectly by the payer to the payee.

The Court while interpreting the term ‘acting on behalf of another person’ states that such a phrase entails the existence of a legal relationship of principal and agent, between the payer and the payee. The legal relationship of principal and agent is hence, necessary to impose the liability to deduct tax at source under Section 194-H.

The court lays down five important criteria to be considered for determining the Principal-Agent Relationship.

The Agent’s legal power to alter his principal’s legal relationship with a third party and the Principal’s co-relative liability to have his relations altered.

  • The degree of control by the principal over the conduct of the activities of the agent.
  • The task entrusted by the principal to the agent should result in a fiduciary relationship.
  • The Agent’s liability to render accounts of the Principal and his entitlement to remuneration for the work he performs for the principal.

Further the Courts relied on two decisions to determine what constitutes ‘commission’. In the case of Director, Prasar Bharati v. Commissioner of Income Tax, Thiruvananthapuram, the Court held that the expression ‘commission or brokerage’ is an inclusive definition and hence, must be interpreted widely.

Further, the court highlights the Delhi High Court’s decision in Commissioner of Income Tax v. Singapore Airlines Ltd., which held that tax under Section 194-H is not required to be deducted on discounted tickets sold by airlines through travel agents. The court notes that the revenue did not challenge this decision, leading to its finality. 

Further, the court rejected the contention of the Revenue relying upon the decision of this Court in Singapore Airlines Limited (supra) that assesses would be liable to deduct tax at source even if the assesses are not making payment or crediting the income to the account of the franchisee/distributor.

The court stated that in the instant case, the relationship between the Assesses and the Distributors is not a fiduciary relationship but instead is an activity carried out by an Independent Contractor. Moreover, it highlighted that the facts of each case and the authority given by ‘principal’ to the distributors must be considered while determining the relationship.

Therefore, with regard to the above observations, the Court held that the business operations of the Assesses which amounts to ‘discounted payments’, does not qualify for ‘commission’ under Section194-H of the Act. Accordingly, the appeals filed by the assesses – cellular mobile service providers, challenging the judgments of the High Courts of Delhi and Calcutta were allowed and the Assesses were not liable to deduct the tax at source under the said section.

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THE SUPREME COURT UPHELD AN ORDER SUMMONING POLICE OFFICERS IN A CORRUPTION CASE

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Case title: Gurdev Singh Bhalla vs State of Punjab & Ors.

Case no.: SPL(Crl.) appeal no. 11654 of 2013

Decided on: 05.01.2024

Quorum: Hon’ble Justice Vikram Nath

FACTS OF THE CASE:

The appellant has filed a criminal appeal with the Supreme Court of India, contesting the decision made by the High Court of Punjab and Haryana in Chandigarh on March 23, 2023, which dismissed the Criminal Revision the appellant had filed in opposition to the Special Judge’s Bathinda order of March 5, 2018, which had allowed the application under Section 319 of the Code of Criminal Procedure, 1973, summoning the appellant and three other police department officials.

Punjab Agro Food grains Corporation Ltd. of Bathinda filed a complaint against Devraj Miglani at the Phul Police Station in the District of Bathinda, which was registered as a FIR. The complaint alleged that Devraj had misappropriated paddy. The investigation of the said FIR was transferred to the Vigilance Bureau in Bathinda, where the appellant was posted as an Inspector and tasked with investigating the crime. The accused, Devraj, was arrested. He was granted police remand and then transferred to judicial custody.

And the informant in this case, Puneet Kumar Miglani, is the accused Devraj’s son. According to the informant in this case, on September 6, 2013, Head Constable Kikkar Singh approached Ms. Ritu, the accused Devraj’s niece, at her workplace, the Bathinda branch of the SBI, demanding a sum of Rs.50,000/- by handing over a slip purportedly written by the accused Devraj, indicating that the holder of the slip may be provided with the said amount. Devraj and his niece Ritu allegedly conversed on Head Constable Kikkar Singh’s mobile phone. The informant came to know of the said demand by Kikkar Singh. He went to the bank, took the slip, and after recording a conversation between his wife and his father, he presented it to the learned Magistrate, along with a complaint.

The local police were directed to register the complaint and investigate it further. Following a thorough investigation by Deputy Superintendent of Police Janak Singh, it was determined that the allegations against Head Constable Kikkar Singh were prima facie true, and a First Information Report was filed at the police station Vigilance Bureau in Bathinda. During the investigation of the aforementioned FIR, the informant, informant’s wife, Devraj, and others provided statements. Following the investigation, a police report against Head Constable Kikkar Singh only.

The date of both trials, the trial arising out of the FIR against Devraj and the trial arising out of the FIR against Head Constable Kikkar Singh, coincided on September 29, 2014. The appellant went on to depose, supporting both the prosecution’s case and his own investigation of Devraj. On that date, in the trial against Head Constable Kikkar Singh, informant Puneet Miglani provided additional evidence as PW 1. On the specified date, he completed both his chief and cross examinations. In addition, he prepared and filed an application under Section 319 Cr.P.C. to summon the appellant and three other police officials.

The trial court dismissed the application due to a lack of sanction under both the PC Act and the Cr.P.C. The said order was successfully challenged before the High Court, and the High Court, in an order dated 23.01.2018, remanded the matter to the Trial Court for a fresh order, ignoring the issue of sanction. The High Court believed that no sanction was required. The Trial Court granted the application under Section 319 Cr.P.C. and summoned the four police officials in accordance with the remand. The appellant challenged the 05.03.2018 order in the High Court.

The high court dismissed the said revision in the impugned order dated March 23, 2023. Aggrieved, and it is now being appealed to the Supreme Court.

LEGAL PROVISIONS:

Section 319 of the Cr.P.C. deals with “Power to proceed against other persons appearing to be guilty of offence”,

406 of IPC deals with “Punishment for criminal breach of trust”,

409 of IPC deals with “Criminal breach of trust by public, servant. or by banker, merchant or agent”,

420 of IPC deals with “Cheating and dishonestly inducing delivery of property”,

457 of IPC deals with “Lurking house-trespass or house-breaking by night in order to commit offence punishable with imprisonment” and

Section 13(1)(d) of the Prevention of Corruption Act read with Section 13(2) of PC Act deals with “Criminal misconduct by a public servant”.

APPELLANTS CONTENTIONS:

He claimed that it was a pressure tactic on the part of the informant to browbeat the appellant because he had deposed against his father Devraj. The informant, was convicted in another case, so his statement should not have been relied on.

The complaint dated 06.09.2013 made no allegations against the appellant. The complaint was filed on September 6, 2013, for a demand of only Rs.50,000/-. Subsequently, in a statement issued on September 29, 2014, the four officials, one Deputy Superintendent of Police, the appellant, and two other Head Constables, allegedly demanded Rs.24 lakhs.

RESPONDANTS CONTENTIONS:

They claimed that the appellant and other police officers had not only harassed and tortured Devraj while he was in custody, but also threatened and tortured family members both mentally and physically in order to extract a large sum of money. They submitted the relevant witnesses’ statements recorded under Section 161 Cr.P.C. both during the investigation and before the Trial Court.

COURT ANALYSIS AND JUDGMENT:

After considering the submissions, the court concluded that it is clear that the informant, in his statement under section 161 Cr.P.C. recorded on 22.09.2013, narrated complete facts regarding the conduct of police officials immediately following his father’s surrender on 30.08.2013 in the case registered against him for misappropriation. The informant has consistently supported the statement under section 161 Cr.P.C. from that point forward, including during the trial.

Even Devraj and Eshaa Miglani, in statements recorded during the investigation on 15.10.2013 and 22.10.2013, respectively, provided the same information as narrated by informant Puneet Miglani on 22.09.2013. Furthermore, their statements during the trial support and align with their previous statements. All of these witnesses have unequivocally described incidents that occurred at various locations, including threats, demands for large sums of money, torture of Devraj.

The Informant gave the same statement under Section 161 Cr.P.C. and before the Trial Court on May 26, 2014, which was continued on September 29, 2014. There appears to be prima facie evidence on record to establish a triable case against the appellant. As a result, we are unlikely to challenge the contested order. Therefore, the appeal is dismissed.

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Written by – Surya Venkata Sujith

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