It//s. Reactive Metals Of lndia Limited v. THE HON'BLE SRI JUSTICE NARSING RAO NA.NDIKONDA

Order

(pter Hon'ble Sri Justice Narsing Rao Nandikonda) This Tzx Revision Case is preferred by r-he petitioner under Section 34 of the Telangana Value Added Tex Act, 2005 (for short, the VAT Act, 2005J against the order, dated

24.04.2007 in T.A.No.459 of 2006 passed by the learned Sales Tax Appellate Tribuna-l, Andhra Pradesh, Hyderab;ld (for short, the Tribunal').

2. He,ard Ms.Akruti Agarwal, learned counsel representing firi Karthik Ramana Puttamreddy, lea-rned counsel for the petitioner and Sri Swaroop Oorilla, learned Special Government Pleader appearing for the respondent.

3. Th,: petitioner, M/s. Reactive Metals of ,lndia Limited is a VAT dealer under the provisions of the VAT Act, 2005. It was also a dealer under the repealed APGST Act. The petitioner is an assessee on the rolls of the Commercial Tax Officer, Basheerbagh. Section 13 (2)(a) read '*,ith Rule 37 of the VAT Act, 2005, pro'uides for Sales Tax Credit in respect c,f stock held in any form in the State (vide Amendment) by Act 339/2006 with effect frorn 01.04.2006. It is state{ that as per the said I i ! t i i 4 i t i I \ I ! I I T * It I i $ i & 1 ,i ! e 2 g 2 PSK,J&NNR,J Trevc-27-2O07 provisions, the dealer, who is entitled to claim such credit, is required to file an application in Form 115 giving details of the stock purchased during the period from l"t April, 2OO4 to 31"t March 2005 and lying stock as on 31"t Mach 2005 together with bills and the amount of tax paid thereon. The petitioner is required to disclose the seller's n€une, description of the goods, closing stock, corresponding invoice numbers, date, value of the goods and the rate of APGST paid and the amount claimed for refund. The application has to be filed within ten (10) days from the date of introduction of the VAT Act, 2005 and thereafter the Assessing Authority is required to process the application and sanction it in Form 116. If there was ariy restriction or deny of credit, the Assessing Authority is required to issue a notice in Form 117 and thereafter, pass a detailed order giving reasons for restriction in Form 126.

4. The petitioner-company applied for Sales Tax Credit as per Section 13(2)(a) read with Rule 37 of the VAT Act, 2OO5 and claimed a sLlm of Rs.28,98 ,236 / -. Basing on the observations made by the Assistant Commissioner (CT), VAT Management Unit, Abids Division, the Commercial Tax Officer, Basheerbagh issued a notice in VAT 117 stating that the claim of the petitioner is restricted to an amount of Rs.5,13,175/- as against Rs.28,98,236/-. It is further stated that the petitioner f '\r 3 PSK,J&NNR,J frevc 27 2OO7 claimed sale:; tax relief on the following goods viz., steel, cement and electrice[ items, which are found in the negative list, for which the iilnount involved is Rs.7,99,800/-. Further, the inputs used in construction of buildings are held to be not eligible for Sales Tax relief.

5. Pursuant to the said notice, the petitioner submitted objections or) 09.O9.2005 stating that the restrictions made by the Commer,:ial Tax Officer are iltegal and unjust. He further stated that the material used in construction of building i.e., bricks, sand, paints including bore-well and labour charges together cons;titutes an arnoLlnt of Rs.20,08, 16 | f -, on which no credit is claimed. Therefore, the petitioner requested to allow the credit o1' Rs.2O,98,436 (+) Rs.85,793/- torvards coal and Rs.6,52,8421 - towards steel and cement. The Assessing Authority iss;ued rejection proceedings, dated O1.10.2OO5 in Form VAT 126, without considering the obje,:tions, dated

09.O9.2005, liled by the petitioner, which reads thus: (I'orm VAT 117 issued on O1.O9.2OO5 Assessee filed objections on O9.O9.2OO5. These are not considered. Hence, rejected and approved for Rs.513175.OO. As per ACCT VAT MGMT UNIT' I Vide CASE l\to.VMU-I I 05-06 I 1 1, dated 1O.O8.2OO5.

6. Aggrieved by the said rejection order of the Assessing AuLthority, the petitioner preferred an ,appeal before 7 I I I i I t i t, I t. i I I t: l I 4 PSK,J&NNR,J Trcvc_27_2007 the Appellate Deputy commissioner on or.rr.2o0s. The Appellate Deputy commissioner without providing a copy of the order for effective hearing and without giving any reasons, dismissed the appeal, by order, dated 30.06.2006.

7. With regard to purchase of machinery from Mls.Kitti Steels Limited, Hyderabad, Hyderabad, is concerned, the said seller has not paid tax on the sales effected to the petitioner and therefore, the petitioner is not eligible for sales tax relief on the corresponding purchases. similarly, in respect of purchase of coal, the Appellate Deputy commissioner relied on Rule 20 (21 (h) of the Telangana value Added Rules, 2oo5 (for short,'the VAT Rules,20O5J, which was amended on

29.L2.2o05 with retrospective effect from ol.o4.2oo5, to justify the rejection of the claim as on 01.10.2005, on which date the GO was not at all issued.

8. With regard to purchase of electrical items, the learned Appellate Deputy commissioner disallowed the claim referring to Rule 20 (21 (i) of the VAT Rules, 2005, so also the claim on building material on the ground that cement and steel are ineligible as per Rule 20 (21 (i) of the vAT Rules, 2005 and accordingly dismissed the appeal on 30.06.2006. Aggrieved by order, petitioner preferred. o==*.* ,: 2 I i I i ,l I I I 5 PSK,J&NNR,J Irevc_27 _2007 an appeal ir:L T.A.No.459 of 2006 before the learrred Sales Tax Appellate Trjbunal, Hyderabad. By the impugned order, dated 24.O4.2OO7, the learned sale Tax Appellate ',Iribunal also dismissed the appeal. Aggrieved by the saic[ order, the petitioner pr,:ferred this Tax Revision Case- g. The petitioner framed the following questions of law for adjudication of the present Tax Revision Case: i) whether the petitioner is eligible for sale tax credit in respect of purchases oJ m/Iichinery frotn M/s Kitti steels Limited., and. other good.s uiz., Coal, Electrical good.s and buildingl 'raaterial under the prouisions of tlrc VAT Act, 2005? ii) whether the Trib1.tno;l cante to the right conclusion thqt the sales tax, relief clalmed bg tttc petitioner cannot be alloued. utithout pagment of the tax o.s enuisaged under Rute- 2',7(7) of the VAT Rules, 2OOS as the petitioner did not Jile ang evidence in suppott of his cla,im?

10. Learned counsel for the petitioner submitted that the order passed by the learned Appellate Deputy Commissiont:r (CT), Secunderabad, is silent on major items of rebate i.e., tax paid on purchase of machinery from M/s. Kitt"v Steels Limited. He also submits that the tax on purchase of coal from Singareni Collieries Company Limited for an arnount of Rs.85,793 /- is also ignored and no reasons wer:e assigned in the order for disallowance. He further submittecl that cement 6 PSK,J&NNR,J Trevc-27_2OO7 and steel are used partly in fabrication of plant and partly for making huge foundations of 50 feet height plants and machinery. No cement and steel is used for building to attract disqualification.

11. He also submitted that the show cause notice is silent as to how the claim is not eligible. He further submitted that the respondent denied the claim in respect of purchase of machinery from M/s. Kitti Steels Limited, Hyderabad, as it did not pay the tax and on that ground, the petitioner cannot be denied relief of sales tax. Tribunal has disallowed the appeal to the extent of relief claimed by the petitioner in respect of the Coal and the sarne was not pressed by the petitioner and so also electrical goods. He further contended that the petitioner has submitted no objection for disallowance of tax credit to the extent of electrical goods and other inputs covered by the negative list, as such it is observed that the petitioner is dis- entitled for sales tax relief in respect of electrical goods. L2. Learned counsel for petitioner also submitted that the said sales tax input were already paid and with regard to taxes in respect of the machinery, steel and cement, it is the case of the petitioner that it has already submitted documents that it has paid taxes to the seller and thereby, he is seeking 4 "l I l E I T* I PSK,J&NNR,J f (euc_27 _2ffi7 the relief. l-earned counsel further submitted that regarding 7 cement and steel, it is the case of the petitioner that they have not utilized the sarne for construction of building and as per the Act, it is only for the building and in the present case as it is contended that the said steel and cement are prartly used for fabrication o.f plant and partly for making huge fo:-rndation of 50 feet height for plant and machinery, as such the claim of the petitioner is restricted only for purchase of Machinery, cement and steel

13. The learned Speciai Government Pleader appearing for the respondent submitted that mere furnishing of the invoices does not suffrce without there being no proof of payment of freight charges or acknowledgment of taking of delivery of gc'ods, toll receipts or payment. He also contended that mere production of invoice or the paynrent r,vithout showing the: actual physical movement of goods, the genuineness of transaction by furnishing the del-zrils such as taking delivery of goods, and freight charges does not suffice and the details of the vehicle which have delivere,cl the goods, particulars have also to be furnished. In the absence of the sarne, the petitioner is not entitled to say that they have purchased the s€une. 8 PSK,J&NNR,J Trcvc_zl_2OO7 L4. A perusal of the order, dated 30.06.2006 passed by the Appellate Deputy Commissioner (CT), Secunderabad with regard to building material is concerned, learned counsel for the petitioner contended that cement and steel are used partly for fabrication of plant and partly for making huge foundations of 50 feet height plant and machinery only. No cement or steel is used for construction of building to attract disqualification and the Tribunal has held that the same are not eligible for input tax credit as per Sub Rule 20 (21 (i) of the VAT Rules,

2005. To get more clarity on the s€une, Rule 20 (21 (i) of the VAT Rules 2005 is extracted as under. Rule 2O of the VAT Rules, 2OO5 After the commencem.ent of ttrc Act, where any dealer gets registered a.s a VAT dealer or uthere the authoritg prescribed registers any dealer as a VAT dealer under Rule 11 (1), such dealer shall be etigible for input tax credit as prouided under sub- section (2)(b) of Section 73. The claim shall be made on Form VAT 118 uithin 1O dags from the date of receipt of VAT registration. Tte goods on which the input tax credit is claimed or allowed shall be auatlable in stock on the effectiue date of VAT regi"stration. The doanmentary euidence for such claim shall be on ttrc basis of a tax tnuotce tssued bg a VAT dealer for the purchnses made and ttrc input tax credit alloued on Form VAT 119 s?nlt be claimed on the first return to be submitted by such dealers. Tte prescribed authorttg shnll i.ssue such Form VAT 119 within 10 dags of receipt of FormVAT 118. 2(il Tte followtng stnll be the items not eligible for input tax credit as specifted in,- Any input used in construction or mqintenance of ang buildings including factory or offtce buildings, unless the deqler is in tte busrness of etcecating works contracts and has not opted for composition. 1 i' i. t I t t I & T I I I I I I E I t I s r :i :: I i i . : I, t I I 9 PSK,J&NNR,J f(evc_27 _2007 The Tribuna.l did not believe the version of 1.he petitioner. Therefore, the onus on the part of the petitioner under section 16(1) of the 'VAT Act, 2005 was not discharged b1 producing the documents s;o as to claim input tax credit or the -.rales tax relief. For the sake of convenience, Section 16(1) of the'VAT Act, 2005 is extracted belo'ur,:

16. (I.l The burden of proving that any sale or purch;ase effected by a dealer is not liable to any tax or is liable to be taxed at a reduced rate or eligible for input tax credit shall lie on the dealer. Since the A ssessing Authority of the petitioner is also the Assessing Authority of the said seller and as the seller has not paid the tax on the sales effected to the petitioner, the Tribunal held that the petitioner is not eligible to claim Sales Tax Relief for the reason that the petitioner has not producecl any material evidence to prove its case. The petitioner filed c,nly Photostat copies of the documents, which do not contain any date. Therefore, the Tribunal disbelieved the case of the petitioner as it failed to prorre the case for granting sales Tax Relief in terms of the statutory provisions. Therefore, the learned Sales Tax Appellate Tribunal, Andhra Pradesh, Hyderabad vide order, dated 24.04.2007, in T.A.No.459 of 2006 confirmed the order passed by' the learned Appellate Deputy commissioner (cr), SecunderabaC Division. 1 10 PS(J&NNR,J frevc 27 2OO7

15. No doubt, the contention of the petitioner is that the steel and the cement are used for fabrication of plant or for setting up foundations of plant and machinery, but not for construction of any building. In such case, under section 16 of the VAT Act, 2005 the burden of proof is on the petitioner to prove the same by producing documentary evidence that they are not liable to pay any tax. No doubt, the burden is on the petitioner, but once the petitioner discharges its initial burden, then the burden shifts on to the respondent to prove the same 'as false' by producing documents. In the present case, the petitioner has discharged its burden by producing relevant documents. Therefore, it is for the respondents to produce evidence to disprove the s€une. However, the respondent has not produced any such document to substantiate their claim. In such circumstances, it cannot be said that the petitioner did not discharge its burden. In view of aforesaid reasons, this Bench is of the opinion that the ground raised by the respondents that the petitioner is not entitled for the input tax credit in respect of cement and steel is unsatisfactory and not in accordance with the said Ru1es.

16. Coming to the entitlement of input tax credit in respect of purchase of machinery from M/s. Kitti Steels 11 PSK,J&NNR,J frevc_27 _2007 Limited, I{yderabad, the learned Appellate Deputy Commissioner (CT) it was in the impugned order held as under "Rs,15,85,261/- the said q.mount according to the apuellant are that purchases are made from M/ s Kitti Steel Limited., uttth respect to this turnouer the assessing authority in Para wise remarks to Para NO. (5) stated that the dealers haue effected Jturchases of machitery from M/ s Kitti Steels Ltd, who is also an a:;sessed on the roll:; of comntercial Tax Officer Baslrcerbagh haue ltetzrt uerifi.ed and it wa.s found that no taxes haue been paid towarcls the said sales bq lvt/s Kitti steels Ltd, Hence, ttrc dealers are not,zligiblefor the STI'! claimed by thent on the purchases effected frorr' M/ s Kitti Steels L,td., h'ence, it uiew of this factual position statetT bg the Assessrng Auth<trity, I opined that the appellant is nol elillible for in put tax credit. Hence, accordingly, 1 dismiss the appazl on this score." L7. Further in the backdrop of the facts stated above, this Bench feels it necessary to discuss about the settled law in respect of ttre assessment of tax is concerned. The erstwhile High Court of Andhra Pradesh, Hyderabad in Harsh Jewellers v. Commercial Tax Officer & othersr at paragra.ph Nos.4 & 5 it was held a:s under: "4. The oboue principle is afortiori applicable since Section 13 (1)of the 2OO;i Act ertitles lruput tax credit to the VAT deater fiir the tax charged in respect of all purcha.ses of taxable goods, made bg that dealer duing the tax peiod. The failure on the part of tu|/ s Karat 24 to file- returns or remit the tax component of the sales made to the petitioner cannot per se be a ground to deng ITC credit. The impugned order of assessment does not assert that the i.nuoices produced bg the petitioner are fraudulent or haue not been. issued bg M/ s Karat 24 or that the purchaser did not in fact obtain the inuoices from the registered dealer. It is also not disputed and in fact it is conceded in the order o/ assessment that the regyistration of M/s Karat 24 was cancelled on 28-2-2O10 i.e., <tJler the transachon in question occurred, whereunder the petitioner purchase'-d bullion from the registered dealer and has prociuced. the uouchers.

5. For the aforesaid reasons and following the jud.gments of this court supra, the urit petition is allowed. The impugneci ord.er of 'w.P.No.3891 of 2012, dated ,r.*r# 1,2 PSK,J&NNR,I Trcuc 27 2OO7 assessmerlt dated 21-1-2012 and ttrc demand of penaltg interest proceedings dated 23-1-2012 isszed bg the 1st respondent are quashed. It is howeuer open to the 7st respondent to po,ss cL reuised order of assessment, if there be ang material on the ba.sis of uthich the Input tax credit could be denied, except on the ground. that M/ s Karat 24, despite being a registered dealer on the releuqnt date, did not remit the tax. TLe utrit petition is allowed as aboue, afier hearing the learned counsel for the petitioner and the leqrned Special Gout. Pleader for Comrnerctal Taxes. Ttere shatl howeuer be no order as fo cosfs. " 18. In case of Anil Rice Milt v State of U.p. & others2, while dealing with on similar issue, the High Court of Allahabad at paragraph Nos.15 & 16 held as under: "15. Sinilarly, fhis CourT in the co,se of the Commisstoner Commercial Tox Vs. M/ s Ramway Foods Ltd. (supra) ho"s held that the primary responsibilitg of claiming the benefit is upon tLrc dealer to proue o.nd establish the actual phgsical mouement of goods, genuineness of transactions, etc. and if the dealer fails to proue the achtal physical mouement of goods, the benefit cannot be granted. 16. Thi"s Court while dismissing the Wit Tox No.1a21/2022 (M/s Shiu Trading l/s. Stqte of U.P. and 2 others), decided on 28.1 1.2023 justified the proceedings initiated under Section 74 of U.P.G.S.T. Act as the petitioner tlrcreof failed to discharge its onus to proue and establish begond doubt actual transaction of phgsical mauement of goods o.s utell as genuineness of transaction".

19. In case of Arise India Limited and Ors. v. Commissioner of Trade & Taxes, Delhi & ors3, while dealing with on the similar issue, the High Court of Delhi at paragraph Nos.53 & 54 it was held as under: "53. In light of the aboue legal position, the Court herebg lnlds thst the expression ,dealer or class of dealers ocanrring in Section 9 (2) (g) of tlrc DVAT Act should be interpreted as rwt including a purchasing dealer who has bona fide entered into purchase transactions uith validly registered selling dealers uho haue issued tax inuoices in accordance utith Section 5O of the Act uhere there is no mismatch of tte transqctions in Annentres 2A and 28. Unless the expression ,dealer or class of dealers in Section 9 (2) "read down in the qboue mclnner, the entire prouision would (g) is have to be held to be uiolatiue of Article 14 of the Con"stitution. 'lzozty 130 GSTR 17G ' *.0 (c) "o.ztoo of 201s, dated 26.10.20r.7 13 PSK,J&NNR,J Ircvc 27 2@7

54. The result of such reading down would be that the Department is prechtded from inuoking Section 9 (2) (d of the DVAT to cleny ITC to a purchasing dealer wlp ha.s bona fide entered into ct purchase transqct'ion uith a registered selling dealer who ha,s issued a tax inuoice reflecting the TIN number. In the euent that tle selling dealer ltas failed to deposit the tax collected by Nm from the purchasing dealer, the remedy for the Department wouid be to proceed against the defaulting sellhtg dealer to recouer such tax and not deng the purchasing dealer the ITC. Where, hotueuer, the Departnt.ent is able to come ccross rttqterial to sltou, that the purchasing dealer and the sellirtg dealer acted in collusiott then tlrc Departm.ent caru proceed under Secfion 4OA of the DVAT Act."

20. A perusal of the record would clearl.v show that there was actual purchase of goods from Mis.Kitti Steels Limited, Hydr:rabad, which was also reflected in rhe concerned books. It is the case of the Assessing officer r-:rat M/s.Kitti Steels Limited, Hyderabad, neither paid taxes r:ror filed the returns, whir:h is clearly evident from the finrlings of the Assessing Officer.

21. The contention of the petitioner is that the appelrate authority i.e., Deputy commissioner dismissed the appeal arbitrarily relying on the para-\ /ise remarks subnritted by the Assessing Authority even without providing the petitioner a copy of the appeal for effective hearing. The Assessing Authority of the petitior:er is also the Assessing Authoritl. of the said seller and since the said seller has not paid the tax on the sales effected to the petitioner, the Appellate Authorit}, i."., Deputy commissioner held that the petitioner is not eligible for the sales tax relief on the corresponding purchases. L4 P5K,J&NNR,J Trevc_2l_20o7

22. [t is pertinent to mention that the learned Tribunal has observed that since the seller has not filed returns or paid the taxes, the transaction between the seller and the petitioner itself is doubtful. It is not the case of the respondent- department that at any point of time there is dispute with regard to business dealing between the petitioner and M/s.Kitti Steels Limited, Hyderabad, and the petitioner has also produced the 'Sale Bills' together with delivery challans before the Tribunal to substantiate its claim that the seller has effected sales and collected charges and sales tax from the petitioner. Further the petitioner has also filed the ledger extracts of M/s.Kitti Steels Limited during the period OL.O4.2OO4 to 31.03.2005 to show there erre transactions between the petitioner and M/s. Kitti Steels Limited, Hyderabad, and the petitioner also made payments for the same. [n view of the above, learned counsel for the petitioner contended that the Tribunal ought to have believed the version of the petitioner that the petitioner had purchased machinery from M/s. Kitti Steels Limited, Hyderabad, and paid charges and taxes accordingly.

23. It is also pertinent to mention that in the order, dated 30.06.2006 passed by the Appellate Deputy Commissioner (CT), it is specifically stated that the i \f 15 PSK,J&NNR,J kevc_27_20o7 appellant/pr-'titioner has made purchases for {ill amount of Rs.15,85,26L /- from M/s.Kitti steel Limited and ',;r,ith respect to this turnover, the Assessing Authority in para-r,r-rse remarks to Para No.5 srtates that the dealers have effectecl purchase of machinery from M/ s.Kitti steels Limited rrmounting to Rs.15,95,26't 1-. The records of M/s.Kitti steels i,imited, u,hich is also an assesses on the rolls of commerciaLl rax officer, Basheerbagh., have been verified and it was founcl that no taxes have been paid towards the said sales by M/ s.Kitti Steels Limited. on the said ground, the clairrr of the petitioner/ap,pellant was rejected stating that the petitioner is not eligible for the STR claimed on the purchases effected from M/s.Kitti Steels Limited. This would clearly shiow that the respondents have records that the petitioner purchased machinery from M/ s.Kitti Steels Limited for an amount of Rs.15,85,261/-.

24. In Anil Rice Mills, cq_se (supra), the Hon,ble supreme court at Paragraph No.15 while discussirrg the case of commissioner, commercial rax v. Ramway Food Limited+ has held that the primar.v responsibility of claiming the benefit is upon the dealer to prove and establish that the actual movement of goods, genuineness of transaction etc., and if the 4 (2024) 13O GSTR 147 't6 (i' PSl(J&NNR,J Trevc-27_2OO7 dealer fails to prove the actual physical movement of goods, the benefit cannot be granted.

25. In fact, in the instant case, the Assessing Authority in para-wise remarks has admitted that the petitioner had purchased machinery from M/s. Kitti Steels Limited, therefore, the necessity of proving again by the petitioner that it has purchased machinery from M/s.Kitti steels Limited does not arise. It is also an admitted fact that M/s.Kitti Steels Limited has not remitted the bills, which have been collected from the petitioner. [n view of the sarne and in the law laid down by the Honble Supreme court in the judgments cited above, it is clear that the respondents are bound to recover the taxes by tracking the seller i.e., M/s.Kitti Steels Limited, instead of questioning of petitioner and putting it in hardship.

26. In view of the above observations, this Bench is of the opinion that petitioner is entitled for Sales Tax Credit in respect of purchase of machinery from M/s. Kitti Steels Limited, Hyderabad, and other goods viz., Coal, Electrical goods and building material under the provisions of the VAT Act, 2OO5 and the first question of law framed by this Bench is answered in favour of petitioner and the second question of law framed is answered against the respondents. \ / :i I t i I i I t t 77 PSK,J&NNR,J frevc_27_2ffi7

27. l\ccordingly, the order, dated 30.06.2006 in Appeal No.A/25 /o-t)6 /v, passed by the Appellate Deputy commissioner (cr) secunderabad Division and confirmed by the learned Sales Tax Appetlate Tribunal, An<lhra pradesh, Hyderabad in T.A.No.459 of 2006, dated 24.o4.2oo7 are liable to be set asicle and accordingly set aside.

24. \ /ith the above observations, the Tax Revision case is allowed. T'here shall be no order as to costs. Miscellaneous petitions, if any, pending in this Tax Revision Casr: shall stand closed. . MOHD.ISMAIL S P TY REGISTRAR I 1 To, /TRUE COPY// SECTION OFFICER

1. The Sales Tax Appellate Tribunal, Andhra Prades Hyderabad 2. The Appellate Dy.Commissioner (CT) Sec'bad Divisiorr. Hyderabad 3. The Commercial Tax Officer, Basheerbagh, Hyderabad 4. One CC to Sri Karthik Ramana Puftaramreddy, Advocate (OPUC) 5. One GC to Siri Swaroop Oorilla , Advocate (OPUC) 6. Two CD Copies ks /PSL % t I i I i l HIGH COURT DATED:24rc212025 3 E .,{ TREVC.No.Z7 ot 2007 ut'1l mi 7 -1, * * SF,) - .-,.it'9 Allowing the Tax Revision Gase Without costs. \Lt b,