| S.No | Name | Date of Order | Subject | Actions |
|---|---|---|---|---|
| 1 | Best Road Carriers vs. Principal Commissioner of CGST, Alwar | 05-06-2026 | Whether a transporter who merely transports goods by road without issuing a consignment note is a Goods Transport Agency (GTA) liable to service tax, or a Goods Transport Operator (GTO) covered under the negative list under Section 66D(p) of the Finance A | View Download |
BACKGROUNDThe appellant is engaged in the activity of transportation of goods by road. The department received third-party TDS data from the Income Tax Department showing gross receipts of Rs. 16,90,38,430/- by the appellant under Sections 194C/194H/194I/194J of the Income Tax Act. The department issued summons requiring the appellant to submit Income Tax Returns, TDS Returns, Balance Sheet, 3CD, Trial Balance and service-wise receipts chart. The appellant did not comply. The department alleged that the appellant had rendered taxable services without discharging service tax liability and issued Show Cause Notice No. 54/2016 dated 09.09.2019 proposing recovery of service tax of Rs. 2,08,93,150/- along with interest and penalties. The demand was confirmed by the Principal Commissioner vide Order-in-Original dated 06.01.2022, holding the appellant to be a GTA. Being aggrieved, the appellant filed the present appeal before CESTAT.COURT OBSERVATIONS (VERBATIM)On the statutory definition and twin conditions for GTA (Para 4.2):"It is clear that to be called 'Goods Transport Agency' a person should fulfill two conditions, namely: a) It should provide service in relation to transport of goods by road; b) It should issue consignment note, by whatever name called."On the distinction between GTA and GTO — from Jaikumar Fulchand Ajmera (Para 4.3):"We observe that since GTA definition has used the words, 'in relation to', it means that for being a GTA, it should provide service to a person in relation to transportation of goods by road in a goods carriage. The service provided is a single composite service which may include various intermediary and ancillary services such as loading/unloading, packing/unpacking, transshipment, temporary warehousing. For the service provided, GTA issues a consignment note and the invoice issued by the GTA for providing the said services includes the value of intermediary and ancillary services. In such a case, the intermediary or ancillary activities are to be treated as part of GTA service... Whereas GTO is the activity simpliciter for transport of goods by roads without issuance of Consignment Note, irrespective transporter being GTA or not."On the definition of GTA remaining unchanged under negative list regime (Para 4.4):"We also observe that the definition of GTA remained the same even after introduction of negative list regime. Service being determined by issuance of consignment note under the statute, it is not within the ambit of a subordinate legislation to create the class of taxable persons by imposing a condition that would, perforce, bring such persons within the tax net."On undisputed facts establishing appellant as GTO (Para 4.5):"(i) Appellant is not registered under Carriage by Road Act, 2007 and hence, is not a GTA; hence, is not at all required to issue a 'consignment note'; (ii) Appellant charges 'mere freight', as agreed, but does not charge 'gross freight'; (iii) Appellant engages merely in the service of providing transportation of goods by road but does not provide the services 'in relation thereof'..."On the Schedule of Responsibilities further establishing GTO character (Para 4.5):"a. Loading of the consignment is done by Safexpress personnel in the vehicles. b. The delivery must be done within transit time and the appellant shall ensure to maintain the same despite various unavoidable causes of delay. c. All waybills as well as transit documents are provided by Safexpress and carried by the appellant. d. Appellant is not responsible for any damage to the property unless it is caused out of his own negligence like rash driving of the driver. e. Appellant will submit the waybills, permits, transit passes etc. at the destination with the due endorsements. f. Unloading of the consignment is done by the recipient at destination."On the final conclusion (Para 5):"Since under GTA it is only such of these services which are in relation to transport of goods by road which are taxable and not the actual transport of goods by road itself. And that appellant has not rendered any service in relation to transport of goods by road like loading/unloading nor even for reimbursing for damage and not issuing the consignment note except mere transport of Goods by road. No evidence to the contrary is produced by the department. Resultantly we hold that appellant's activity is wrongly held to be taxable service of Goods Transport Agency."FINAL VERDICTThe CESTAT set aside the Order-in-Original and allowed the appeal, holding that the appellant is a Goods Transport Operator (GTO) and not a Goods Transport Agency (GTA). The activity of mere transportation of goods by road without issuance of a consignment note and without rendering ancillary services is covered under the negative list under Section 66D(p)(i) of the Finance Act, 1994 and is not liable to service tax. 👍 | ||||
| Best Road Carriers vs. Principal Commissioner of CGST, Alwar 05-06-2026 Whether a transporter who merely transports goods by road without issuing a consignment note is a Goods Transport Agency (GTA) liable to service tax, or a Goods Transport Operator (GTO) covered under the negative list under Section 66D(p) of the Finance ABACKGROUNDThe appellant is engaged in the activity of transportation of goods by road. The department received third-party TDS data from the Income Tax Department showing gross receipts of Rs. 16,90,38,430/- by the appellant under Sections 194C/194H/194I/194J of the Income Tax Act. The department issued summons requiring the appellant to submit Income Tax Returns, TDS Returns, Balance Sheet, 3CD, Trial Balance and service-wise receipts chart. The appellant did not comply. The department alleged that the appellant had rendered taxable services without discharging service tax liability and issued Show Cause Notice No. 54/2016 dated 09.09.2019 proposing recovery of service tax of Rs. 2,08,93,150/- along with interest and penalties. The demand was confirmed by the Principal Commissioner vide Order-in-Original dated 06.01.2022, holding the appellant to be a GTA. Being aggrieved, the appellant filed the present appeal before CESTAT.COURT OBSERVATIONS (VERBATIM)On the statutory definition and twin conditions for GTA (Para 4.2):"It is clear that to be called 'Goods Transport Agency' a person should fulfill two conditions, namely: a) It should provide service in relation to transport of goods by road; b) It should issue consignment note, by whatever name called."On the distinction between GTA and GTO — from Jaikumar Fulchand Ajmera (Para 4.3):"We observe that since GTA definition has used the words, 'in relation to', it means that for being a GTA, it should provide service to a person in relation to transportation of goods by road in a goods carriage. The service provided is a single composite service which may include various intermediary and ancillary services such as loading/unloading, packing/unpacking, transshipment, temporary warehousing. For the service provided, GTA issues a consignment note and the invoice issued by the GTA for providing the said services includes the value of intermediary and ancillary services. In such a case, the intermediary or ancillary activities are to be treated as part of GTA service... Whereas GTO is the activity simpliciter for transport of goods by roads without issuance of Consignment Note, irrespective transporter being GTA or not."On the definition of GTA remaining unchanged under negative list regime (Para 4.4):"We also observe that the definition of GTA remained the same even after introduction of negative list regime. Service being determined by issuance of consignment note under the statute, it is not within the ambit of a subordinate legislation to create the class of taxable persons by imposing a condition that would, perforce, bring such persons within the tax net."On undisputed facts establishing appellant as GTO (Para 4.5):"(i) Appellant is not registered under Carriage by Road Act, 2007 and hence, is not a GTA; hence, is not at all required to issue a 'consignment note'; (ii) Appellant charges 'mere freight', as agreed, but does not charge 'gross freight'; (iii) Appellant engages merely in the service of providing transportation of goods by road but does not provide the services 'in relation thereof'..."On the Schedule of Responsibilities further establishing GTO character (Para 4.5):"a. Loading of the consignment is done by Safexpress personnel in the vehicles. b. The delivery must be done within transit time and the appellant shall ensure to maintain the same despite various unavoidable causes of delay. c. All waybills as well as transit documents are provided by Safexpress and carried by the appellant. d. Appellant is not responsible for any damage to the property unless it is caused out of his own negligence like rash driving of the driver. e. Appellant will submit the waybills, permits, transit passes etc. at the destination with the due endorsements. f. Unloading of the consignment is done by the recipient at destination."On the final conclusion (Para 5):"Since under GTA it is only such of these services which are in relation to transport of goods by road which are taxable and not the actual transport of goods by road itself. And that appellant has not rendered any service in relation to transport of goods by road like loading/unloading nor even for reimbursing for damage and not issuing the consignment note except mere transport of Goods by road. No evidence to the contrary is produced by the department. Resultantly we hold that appellant's activity is wrongly held to be taxable service of Goods Transport Agency."FINAL VERDICTThe CESTAT set aside the Order-in-Original and allowed the appeal, holding that the appellant is a Goods Transport Operator (GTO) and not a Goods Transport Agency (GTA). The activity of mere transportation of goods by road without issuance of a consignment note and without rendering ancillary services is covered under the negative list under Section 66D(p)(i) of the Finance Act, 1994 and is not liable to service tax. 👍 | ||||
| 2 | Dow Chemical International Pvt. Ltd. vs. Commissioner of State Tax, | 04-06-2026 | Whether procurement facilitation services received by an Indian company (Dow India) from its Swiss group entity (Dow Europe GmbH), functioning as a centralised procurement hub, constitute | View Download |
Background & Relevant FactsThe appellant, M/s. Dow Chemical International Pvt. Ltd. (Dow India), is an Indian company engaged in manufacturing and distributing chemical components. For streamlining its procurement operations, Dow India entered into a written Procurement Agreement dated 01.07.2021 with Dow Europe GmbH, a Switzerland-incorporated company and a related entity within the global Dow Group, functioning as a centralised procurement hub for the entire Dow Group worldwide.Under the Procurement Agreement, Dow Europe undertook a comprehensive range of activities including identification, selection and approval of foreign suppliers, negotiation of terms and conditions of procurement agreements, development of procurement strategies, reviewing and signing of contracts and purchase orders, procurement governance, supplier risk management, supplier relationship management, procurement analytics, strategic sourcing, quality audits, and spend analytics. The consideration payable to Dow Europe was structured as 3.5% of the total purchases made by Dow India — i.e., no procurement, no payment.During January 2022 to June 2022, Dow India, under the impression that services received from Dow Europe constituted "import of services" under Section 2(11) of the IGST Act, paid IGST under the Reverse Charge Mechanism (RCM) on the consideration paid to Dow Europe aggregating to Rs. 13,41,89,994/-. Subsequently, Dow India formed the view that Dow Europe was in fact an "intermediary" under Section 2(13) of the IGST Act and that the place of supply under Section 13(8)(b) was Switzerland (outside India), making the transaction non-taxable in India. Accordingly, Dow India reversed the ITC availed and filed refund applications under Section 54(1) read with Rule 89 of the MGST Act/Rules for all six months.The Adjudicating Authority rejected the refund claims. The First Appellate Authority (Joint Commissioner of State Tax, Appeals, Belapur) confirmed the rejection vide orders dated 11.09.2025, holding that Dow Europe provided services on its own account (principal-to-principal), not as an intermediary, and that the change in classification was an afterthought. Aggrieved, Dow India filed six appeals before GSTAT.Court Observations (Verbatim)"The Revenue has treated any services provided by the India Company to its counterpart outside India as intermediary service and not export of services and therefore, levied GST, holding India to be the place of supply. At the same breath, the Revenue has treated any services provided by the foreign company to an Indian Company as import of services and not intermediary services and levied GST on it, holding the place of supply to be in India. We are of the opinion that both the views cannot be taken. One view is to be taken.""We are of the considered opinion that the second consideration is not satisfied because of the fact that both the Dow Europe and Dow India are, either direct or indirect, subsidiaries of one company, i.e. 'Dow INC', which is collectively, known as 'Dow Group'. Dow Europe, a company located in Switzerland, functions as the Centralized Procurement Hub for the entire Dow Group and thereby giving a core service to the entire Dow Group located throughout the world.""We are of the opinion that the Dow Europe renders services on his own account to the service receivers located in India, and the acts of the said foreign company are those of an independent contractor, and it does not represent or bind the Indian client in the course of its services.""In that view of the matter, we are of the opinion that services received by Dow India are in the nature of an import and the place of supply shall be in India, not in Europe. Thus, it will not come within the purview of Section 13(8)(b) of the IGST Act, and definition provided in Section 2(13) of the IGST Act.""It cannot be stated that every application for refund of tax, paid to the revenue under a misconception, will be hit by the principles of action arising as an afterthought. To this extent, we disagree with the First Appellate Authority." [On the afterthought objection — GSTAT disagreed with the FAA on this limited point.]"Services provided by Dow Europe cannot be termed as 'intermediary service' and as it is not in the nature of the ancillary service, rather it is a core service provided by it to one of its sisters concerned, who is operating under the global concern, i.e., 'Dow INC'."Final VerdictAll six appeals dismissed. GSTAT held that services provided by Dow Europe GmbH to Dow India are import of services (not intermediary services), place of supply is India, and IGST under RCM was correctly paid. Refund claims rejected. Orders of the First Appellate Authority confirmed. 👎 Against Assessee. | ||||
| Dow Chemical International Pvt. Ltd. vs. Commissioner of State Tax, 04-06-2026 Whether procurement facilitation services received by an Indian company (Dow India) from its Swiss group entity (Dow Europe GmbH), functioning as a centralised procurement hub, constituteBackground & Relevant FactsThe appellant, M/s. Dow Chemical International Pvt. Ltd. (Dow India), is an Indian company engaged in manufacturing and distributing chemical components. For streamlining its procurement operations, Dow India entered into a written Procurement Agreement dated 01.07.2021 with Dow Europe GmbH, a Switzerland-incorporated company and a related entity within the global Dow Group, functioning as a centralised procurement hub for the entire Dow Group worldwide.Under the Procurement Agreement, Dow Europe undertook a comprehensive range of activities including identification, selection and approval of foreign suppliers, negotiation of terms and conditions of procurement agreements, development of procurement strategies, reviewing and signing of contracts and purchase orders, procurement governance, supplier risk management, supplier relationship management, procurement analytics, strategic sourcing, quality audits, and spend analytics. The consideration payable to Dow Europe was structured as 3.5% of the total purchases made by Dow India — i.e., no procurement, no payment.During January 2022 to June 2022, Dow India, under the impression that services received from Dow Europe constituted "import of services" under Section 2(11) of the IGST Act, paid IGST under the Reverse Charge Mechanism (RCM) on the consideration paid to Dow Europe aggregating to Rs. 13,41,89,994/-. Subsequently, Dow India formed the view that Dow Europe was in fact an "intermediary" under Section 2(13) of the IGST Act and that the place of supply under Section 13(8)(b) was Switzerland (outside India), making the transaction non-taxable in India. Accordingly, Dow India reversed the ITC availed and filed refund applications under Section 54(1) read with Rule 89 of the MGST Act/Rules for all six months.The Adjudicating Authority rejected the refund claims. The First Appellate Authority (Joint Commissioner of State Tax, Appeals, Belapur) confirmed the rejection vide orders dated 11.09.2025, holding that Dow Europe provided services on its own account (principal-to-principal), not as an intermediary, and that the change in classification was an afterthought. Aggrieved, Dow India filed six appeals before GSTAT.Court Observations (Verbatim)"The Revenue has treated any services provided by the India Company to its counterpart outside India as intermediary service and not export of services and therefore, levied GST, holding India to be the place of supply. At the same breath, the Revenue has treated any services provided by the foreign company to an Indian Company as import of services and not intermediary services and levied GST on it, holding the place of supply to be in India. We are of the opinion that both the views cannot be taken. One view is to be taken.""We are of the considered opinion that the second consideration is not satisfied because of the fact that both the Dow Europe and Dow India are, either direct or indirect, subsidiaries of one company, i.e. 'Dow INC', which is collectively, known as 'Dow Group'. Dow Europe, a company located in Switzerland, functions as the Centralized Procurement Hub for the entire Dow Group and thereby giving a core service to the entire Dow Group located throughout the world.""We are of the opinion that the Dow Europe renders services on his own account to the service receivers located in India, and the acts of the said foreign company are those of an independent contractor, and it does not represent or bind the Indian client in the course of its services.""In that view of the matter, we are of the opinion that services received by Dow India are in the nature of an import and the place of supply shall be in India, not in Europe. Thus, it will not come within the purview of Section 13(8)(b) of the IGST Act, and definition provided in Section 2(13) of the IGST Act.""It cannot be stated that every application for refund of tax, paid to the revenue under a misconception, will be hit by the principles of action arising as an afterthought. To this extent, we disagree with the First Appellate Authority." [On the afterthought objection — GSTAT disagreed with the FAA on this limited point.]"Services provided by Dow Europe cannot be termed as 'intermediary service' and as it is not in the nature of the ancillary service, rather it is a core service provided by it to one of its sisters concerned, who is operating under the global concern, i.e., 'Dow INC'."Final VerdictAll six appeals dismissed. GSTAT held that services provided by Dow Europe GmbH to Dow India are import of services (not intermediary services), place of supply is India, and IGST under RCM was correctly paid. Refund claims rejected. Orders of the First Appellate Authority confirmed. 👎 Against Assessee. | ||||
| 3 | Sterling & Wilson Pvt. Ltd. vs. Commissioner, Odisha Commissionerate of CT & GST & Ors. | 11-02-2026 | Demand due to mismatch between GSTR-1 and GSTR-3B – Sections 73, 74, 75(2), 112 of the CGST Act, 2017 and Section 34(2) of the CGST Act. | View Download |
Facts:The appellant was issued a demand under Section 74 of the CGST/OGST Act for FY 2018-19 alleging short payment of tax of ₹27,06,634 due to mismatch between tax liability reported in GSTR-1 and GSTR-3B. The first Appellate Authority held that there was no intention to evade tax and converted the proceedings from Section 74 to Section 73, confirming tax and interest and reducing penalty to 10% of the tax amount. Aggrieved by the order, the appellant filed a second appeal before the GST Appellate Tribunal.Court Decision:The Tribunal held that once the Appellate Authority concluded that the ingredients of fraud, suppression, or wilful misstatement required under Section 74 were not established, the matter could not be finally decided by the appellate authority itself under Section 73. In view of Section 75(2) of the CGST Act, the proper officer who issued the original notice must determine the tax liability treating the notice as one issued under Section 73.The Tribunal observed that the transactions were disclosed through debit notes and credit notes in the books of account but were not correctly reflected in periodic returns. Therefore, the orders of the proper officer and the first Appellate Authority to the extent they treated the case under Section 73 were set aside and the matter was remanded to the proper officer for fresh determination after giving the appellant opportunity to produce documents and amend returns.Cases Referred by Court:• V.S. Products vs. Additional Commissioner (Appeals)• Commissioner of Customs (Import), Mumbai vs. Dilip Kumar & Company & Ors.• Hamida vs. Md. Khalil | ||||
| Sterling & Wilson Pvt. Ltd. vs. Commissioner, Odisha Commissionerate of CT & GST & Ors. 11-02-2026 Demand due to mismatch between GSTR-1 and GSTR-3B – Sections 73, 74, 75(2), 112 of the CGST Act, 2017 and Section 34(2) of the CGST Act.Facts:The appellant was issued a demand under Section 74 of the CGST/OGST Act for FY 2018-19 alleging short payment of tax of ₹27,06,634 due to mismatch between tax liability reported in GSTR-1 and GSTR-3B. The first Appellate Authority held that there was no intention to evade tax and converted the proceedings from Section 74 to Section 73, confirming tax and interest and reducing penalty to 10% of the tax amount. Aggrieved by the order, the appellant filed a second appeal before the GST Appellate Tribunal.Court Decision:The Tribunal held that once the Appellate Authority concluded that the ingredients of fraud, suppression, or wilful misstatement required under Section 74 were not established, the matter could not be finally decided by the appellate authority itself under Section 73. In view of Section 75(2) of the CGST Act, the proper officer who issued the original notice must determine the tax liability treating the notice as one issued under Section 73.The Tribunal observed that the transactions were disclosed through debit notes and credit notes in the books of account but were not correctly reflected in periodic returns. Therefore, the orders of the proper officer and the first Appellate Authority to the extent they treated the case under Section 73 were set aside and the matter was remanded to the proper officer for fresh determination after giving the appellant opportunity to produce documents and amend returns.Cases Referred by Court:• V.S. Products vs. Additional Commissioner (Appeals)• Commissioner of Customs (Import), Mumbai vs. Dilip Kumar & Company & Ors.• Hamida vs. Md. Khalil | ||||
| 4 | Cargotec India Pvt. Ltd. vs. Commissioner of GST & Central Excise | 19-05-2025 | Whether refund of unutilized CENVAT Credit under Rule 5 of the CENVAT Credit Rules, 2004 on export of IT Software Services can be denied on the grounds of (i) services rendered from unregistered premises, and (ii) absence of nexus between input services a | View Download |
BACKGROUND The appellant, a 100% Export Oriented Unit operating under the Software Technology Parks Scheme, was registered for providing Information Technology Software Services under the Finance Act, 1994. The appellant filed refund claims of unutilized CENVAT Credit under Rule 5 of the CENVAT Credit Rules, 2004 in respect of export of services for two quarters — April to June 2011 and July to September 2011. During April 2011, the appellant had shifted its premises from Adyar to Taramani, and the service tax registration for the new premises was amended only on 05.01.2012. The Original Authority sanctioned only a small portion of the refund and rejected the balance on two grounds — first, that the services were rendered from unregistered premises, and second, that there was no nexus established between the input services and the output service. The Commissioner (Appeals) upheld the rejection. The appellant then approached CESTAT Chennai. CRUCIAL COURT OBSERVATIONS (Verbatim)On Unregistered Premises:"There is no mention in the said Rules that service tax can be availed only in a registered unit. Moreover, in the circumstances cited by the appellant he could have been facilitated by examining the actual input/output details of CENVAT Credit from the records maintained by the appellant. There is no allegation that the appellant was asked for data which he refused to provide. Hence this finding in the impugned order must be set aside with consequential relief."On Nexus Between Input and Output Services:"I find that the OIO's are very cryptic and do not discuss as to why the input services cannot be corelated to the output. As stated by Hon'ble Justice Krishna Iyer in Organo Chemical Industries & Anr vs UOI [1979 AIR 1803 / 1980 SCR (1) 61], 'The inscrutable face of a sphinx is ordinarily incongruous with a judicial or quasi-judicial performance.' Hence the order merits being set aside on this ground alone.""The Commissioner (Appeals) has tried to improve upon the order of the Original Authority by discussing the law without examining the facts of use/non-use of each input service with the output. Further, I find that the judgment and Circular cited by the appellant also cover the issue in their favour." FINAL VERDICT CESTAT set aside the impugned orders and allowed both appeals, holding that registration of premises is not a mandatory pre-condition under Rule 5 of the CENVAT Credit Rules for claiming refund, and that a cryptic order rejecting nexus without examining facts is legally unsustainable. Consequential relief directed as per law. 👍 | ||||
| Cargotec India Pvt. Ltd. vs. Commissioner of GST & Central Excise 19-05-2025 Whether refund of unutilized CENVAT Credit under Rule 5 of the CENVAT Credit Rules, 2004 on export of IT Software Services can be denied on the grounds of (i) services rendered from unregistered premises, and (ii) absence of nexus between input services aBACKGROUND The appellant, a 100% Export Oriented Unit operating under the Software Technology Parks Scheme, was registered for providing Information Technology Software Services under the Finance Act, 1994. The appellant filed refund claims of unutilized CENVAT Credit under Rule 5 of the CENVAT Credit Rules, 2004 in respect of export of services for two quarters — April to June 2011 and July to September 2011. During April 2011, the appellant had shifted its premises from Adyar to Taramani, and the service tax registration for the new premises was amended only on 05.01.2012. The Original Authority sanctioned only a small portion of the refund and rejected the balance on two grounds — first, that the services were rendered from unregistered premises, and second, that there was no nexus established between the input services and the output service. The Commissioner (Appeals) upheld the rejection. The appellant then approached CESTAT Chennai. CRUCIAL COURT OBSERVATIONS (Verbatim)On Unregistered Premises:"There is no mention in the said Rules that service tax can be availed only in a registered unit. Moreover, in the circumstances cited by the appellant he could have been facilitated by examining the actual input/output details of CENVAT Credit from the records maintained by the appellant. There is no allegation that the appellant was asked for data which he refused to provide. Hence this finding in the impugned order must be set aside with consequential relief."On Nexus Between Input and Output Services:"I find that the OIO's are very cryptic and do not discuss as to why the input services cannot be corelated to the output. As stated by Hon'ble Justice Krishna Iyer in Organo Chemical Industries & Anr vs UOI [1979 AIR 1803 / 1980 SCR (1) 61], 'The inscrutable face of a sphinx is ordinarily incongruous with a judicial or quasi-judicial performance.' Hence the order merits being set aside on this ground alone.""The Commissioner (Appeals) has tried to improve upon the order of the Original Authority by discussing the law without examining the facts of use/non-use of each input service with the output. Further, I find that the judgment and Circular cited by the appellant also cover the issue in their favour." FINAL VERDICT CESTAT set aside the impugned orders and allowed both appeals, holding that registration of premises is not a mandatory pre-condition under Rule 5 of the CENVAT Credit Rules for claiming refund, and that a cryptic order rejecting nexus without examining facts is legally unsustainable. Consequential relief directed as per law. 👍 | ||||
