M/s.H.A.Kader Pondicherry v. The Union of India

Constitution of India to issue a writ of certiorari or any otherorder or direction in the nature of writ calling for the records ofthe respondent leading to the issue of the notice No.302338/98-2000/CTO-IW dated 28.9.99 and the order No.302338/99-2000 / CTO-IWdated 5.10.99 and quash the same as ultra vires and unconstitutionaland void abinitio.W.A.No.77 of 2000 is filed under Clause 15 of the Letters Patentagainst the order dated 18.11.1999 made in W.P.No.18498 of 1999.W.P.No.2991 of 2001 is filed under Article 226 of theConstitution of India for the issue of a Writ of Certiorari callingfor the records of the respondent leading to the issue of the orderNo.302338/99-2000, dated 12.1.2001 and the notice and demandNo.302338/99-2000 dated 12.1.2001 and to quash the same as ultravires, unconstitutional and void ab initio.For Petitioner in W.P.Nos.18038 of 1999 and 2992 of 2001 / appellant in W.A.No.77 of 2000:Mr.Perumbulavil RadhakrishnanFor Respondents-1 to 3 in W.P.Nos.18038 of 1999, 2992 of 2001 and W.A.No. 77 of 2000 :Mr.T.P.ManoharanSpecial Government Pleader (Puducherry)-----ORDER(Order of the Court was made by CHITRA VENKATARAMAN,J.)In W.P.No.18038 of 1999 the petitioner seeks the issue of a Writof Certiorari to call for the notification in G.O.Ms.No.21/99/F-2,dated 30.3.1999 made by the Union Territory of Pondicherry and toquash the same as ultra vires, unconstitutional and void ab initio.On notice, the respondents have filed a counter affidavit.2. The case of the assessee herein is as follows:The petitioner is a firm who are stockists of cigarettes forI.T.C. The petitioner is an assessee under the provisions of thePondicherry General Sales Tax Act. It is seen from the recordsplaced before this Court that under G.O.Ms.No.51/96/F.2 dated 21stSeptember, 1996, the Government of Pondicherry issued a notificationunder Section 19 of the Pondicherry General Sales Tax Act as regardsthe liability on turnover tax, payable under Section 4-A of the said https://hcservices.ecourts.gov.in/hcservices/ Act. The notification reads as follows:" GOVERNMENT OF PONDICHERRYFINANCE DEPARTMENT(G.O.Ms.No.51/96/F.2, dated 21st September 1996.)NOTIFICATIONIn exercise of the powers conferred by sub-sections (1) and (2) of section 19 of the PondicherryGeneral Sales Tax Act, 1967 (Act No.6 of 1967), andin supersession of the notifications issued underG.OMs.No.25/92/F.6, dated 22nd June 1992 andG.O.Ms.No.38/92/F.6, dated 29th September 1992 of theFinance Department, Pondicherry, save as respectsthings done or omitted to be done before suchsupersession, the Lieutenant-Governor, Pondicherry,having been satisfied that it is necessary so to doin the public interest, hereby with immediate effect--(i) exempts from payment of turnover tax under theprovisions of section 4-A of the said Act, alldealers except the dealers in alcoholic beveragesexcluding arrack pattai and toddy;(ii) exempts from payment of turnover tax under theprovisions of section 4-A of the said Act, thedealers in alcoholic beverages excluding arrackpattai and toddy, whose turnover does not exceedrupees five crores per annum; and(iii) reduces the turnover tax from 3 per cent to 0.5per cent, in respect of the dealers in alcoholicbeverages excluding arrack pattai and toddy, whoseturnover exceeds rupees five crores per annum. "3. The sum and substance of the notification is that it seeks toexempt all dealers, other than those dealing in alcoholic beveragesexcluding arrack, pattai and toddy, from payment of turnover tax asprovided for under Section 4-A of the Pondicherry General Sales TaxAct. However, as regards dealers in alcoholic beverages excludingarrack pattai and toddy, it fixed a turnover limit for the grant ofexemption that those dealers whose turnover does not exceed rupeesfive crores per annum alone are exempted from payment of tax. Asregards dealers dealing in alcoholic beverages excluding arrack,pattai and toddy having turnover above rupees five crores, they wouldhave to pay a reduced rate of tax at 0.5% as against 3% rate ofturnover tax under Section 4A of the Act. The said notificationunderwent an amendment under G.O.Ms.No.21/99/F.2 dated 30th March 1999whereby, under Clause (i), while retaining exemption to all dealersfrom payment of tax, it excluded apart from dealers in alcoholicbeverage excluding arrack, pattai and toddy; also brought in dealersin cigarettes and timber under the exclusion clause. After Clause https://hcservices.ecourts.gov.in/hcservices/ (iii) in the original notification, it inserted a further clause asClause (iv), exempting from payment of turnover tax under Section 4-A, dealers in cigarettes and timber whose total turnover does notexceed Rs.50 lakhs per annum. In respect of dealers in cigarettesand timber whose total turnover is more than Rs.50 lakhs, a reductionin rate of tax from 3% to 1% was granted under Clause (v). Thus, byreason of this amendment made by G.O.Ms.No.21/99/F.2 dated 30th March1999, while dealers dealing in cigarettes and timber are excludedfrom getting absolute unconditional exemption claim, dealers dealingin cigarettes and timber are granted conditional exemption restrictedto the dealers having a total turnover upto Rs.50 lakhs and thosedealers dealing in cigarettes and timber having a total turnoverexceeding Rs.50 lakhs would have to pay turnover tax at theconcessional rate of 1%.4. The petitioner herein challenges the said notification on theground that cigarettes are declared as goods of special importance,as per Section 14 of the General Sales Tax Act. Cigarettes areliable to additional duty of excise under the Second Schedule to theAdditional Duties of Excise (Goods of Special Importance) Act, 1957.Since the same is levied by the Central Government, the States arethus estopped from the levy of sales tax on cigarettes and that theUnion Territory of Pondicherry has no legislative competence toimpose additional sales tax to the tune of 1% under Section 4-A. Thepetitioner further contends that Section 9 of the Pondicherry GeneralSales Tax Act provides statutory exemption from payment of tax inrespect of the scheduled goods. That being the case, the exemptionunder Section 9 has to be read into the levy under Section 4A(2).Consequently, the question of the State withdrawing the exemption, inexercise of the powers conferred under Section 19, does not arise.5. The assessee further contends that given the fact that theAdditional Duties of Excise (Goods of Special Importance) Act, 1957replaces the sales tax levied, the levy of turnover tax cannot occupythe field of the Additional Duties of Excise Act. Consequently, theentire exercise is contrary to the provisions of the Constitution.6. Countering the said claim, the respondent, in their counteraffidavit, contended that given the definition of "total turnover"under the provisions of the Act and that the levy of turnover taxunder Section 4-A is on the total turnover of the dealer, even theexempted turnover would also fall for consideration under the conceptof total turnover. Apart from that, the additional duties of exciseunder the Additional Duties of Excise (Goods of Special Importance)Act, 1957, by itself, does not tie the hands of the State Governmentfrom levying the turnover tax. Considering the fact that Section 4-Ais a code by itself, the liability to pay turnover tax arises https://hcservices.ecourts.gov.in/hcservices/ irrespective of whether the assessee is liable to pay any sales taxor not and that includes the goods suffering duties of additionalexcise. Thus all that the Central Act states is that, wherever theState collects tax under the local enactment, the benefit ofadditional excise levied would not enure to the benefit of the saidState. The counter further states that the Government had issued thenotification in exercise of its powers under Section 19 of the Act.Given the fact that the State Legislature has the competence to grantexemption/reduction in the rate of tax in public interest subject tosuch restrictions and conditions, there is nothing illegal in thesaid Government Order giving exemption and concessional rate of taxon the total turnover limit, subject to the conditions specifiedtherein.7. Quite apart, the additional excise duty is levied by theCentral Government. The Pondicherry Government administration is notgetting any revenue so collected under the additional excise dutyenactment. Thus there is no repugnancy between Section 4-A of thePondicherry General Sales Tax Act and Section 14(iv) and Section 15of the Central Sales Tax Act. So too as regards the levy ofadditional duty and excise under the Additional Duties of Excise(Goods of Special Importance) Act, 1957. In the light of the above,there are no merits in the writ petition.8. Learned counsel appearing for the assessee/petitioner pointedout that on the admitted position that cigarettes attract additionalduty of excise under the Central enactment, the levy of turnover taxunder Section 4-A is an unconstitutional levy. He further pointedout that considering the fact that Section 9 of the PondicherryGeneral Sales Tax Act exempts goods specified under the ThirdSchedule, the question of bringing any exempted turnover underSection 4-A does not arise. Thus the levy under Section 4A of thePondicherry General Sales Tax Act is repugnant to the above-saidprovision as well as in violation of the Additional Duties of Excise(Goods of Special Importance) Act, 1957. In the circumstances,learned counsel seeks a Writ of Certiorari to quash the notificationas unconstitutional and arbitrary.9. Per contra, while supporting the notification, learnedSpecial Government Pleader appearing for the Pondicherry Government,placed reliance on the definition of "total turnover" in Section 2(r)of the Pondicherry Sales Tax Act and Section 4-A, which is a code byitself, as regards the levy of turnover tax and submitted that goingby the definition of "total turnover", irrespective of the exemptionfrom the levy of the General Sales Tax provisions, the entire totalturnover would go in for chargeability of turnover tax under Section4-A. He further pointed out to the provisions of the AdditionalDuties of Excise (Goods of Special Importance) Act, 1957, that as per https://hcservices.ecourts.gov.in/hcservices/ the said Act, the State would be debarred from levying tax under theState enactment, if it is in receipt of additional duties of exciselevied by the Central Government. As far as PondicherryAdministration is concerned, it has not been in receipt of anycollection of additional duties of excise on cigarettes. In thelight of the above, the question of reading any unconstitutionalityin the notification does not arise.10. Given the fact that the State is competent to levy turnovertax under Section 4-A of the Pondicherry General Sales Tax Act and togrant exemption under Section 19 either absolutely or subject toterms and conditions and that Section 9 specifies goods included inthe Third Schedule exempted from payment of any tax under the Act, noexception could be taken to the notification issued by theGovernment. He also placed reliance on the decisions reported in(1998) 7 SCC 237 (Sun Oil Company (P) Ltd. Vs. State of W.B.) and(2010) 11 SCC 1 (Union of India Vs. Madras Bar Association), thatwhen the statute is clear in what it intends to levy, nothing can beread into the provisions of the Act. 11. Learned Special Government Pleader also placed before thisCourt, the decision of a learned single Judge of this Court inW.P.No.15808 of 1999, dated 08.10.1999 (M/s.Lakshmi Agencies, Yanam,by its Managing Partner Vs. Union Territory of Pondicherry andanother), wherein this Court had an occasion to consider thenotification in G.O.Ms.No.21/99/F2 Finance dated 30.3.1999. ThisCourt rejected the plea on the ground that when the Act provides thelevy of turnover tax and the exemption contemplated under Section 9is subject to restrictions and conditions as may be prescribed andthe Government prescribes the conditions in public interest, the samecannot be challenged. He submitted that the said decision of thisCourt has not been challenged so far.12. Heard learned counsel appearing on both sides and perusedthe material on record.13. As already noted, the notification originally introduced inthe year 1996 and the subsequent notification of the year 1999 aremade in exercise of the powers conferred on the State under subsections (1), (2) and (3) of Section 19 of the Pondicherry GeneralSales Tax Act. Section 19 is a specific provision enabling the Stateto make notifications in public interest granting exemption orreduction in rate of tax in respect of any tax payable under thePondicherry General Sales Tax Act. Sub Section (2)(b) of Section 19states that exemption from tax or reduction in the rate of taxnotified under sub section (1) may be subject to such restrictionsand conditions as may be specified in the notification. Thus giventhe fact that the State has the competency to grant exemption or https://hcservices.ecourts.gov.in/hcservices/ reduction of rate of tax, either absolute or subject to conditions orwith restrictions as may be specified in the notification, thechallenge to the notification would arise only in such case where theState itself has no authority to levy tax or that the conditionsimposed therein are contrary or repugnant to the provisions of theAct or the Constitution. 14. Section 2 of the Pondicherry General Sales Tax Act definesamong other things, "turnover" - Section 2(s), "total turnover" -Section 2(r) and "taxable turnover" – Section 2(q). For the purposeof this case, it is enough if we refer to the definition of "taxableturnover" as defined under Section 2(q) and "total turnover" asdefined under Section 2(r). The said definitions read as follows:" 2(q)'taxable turnover' means the turnoveron which a dealer shall be liable to paytax as determined after making suchdeductions from his total turnover and insuch manner as may be prescribed, but shallnot include the turnover of purchase orsale in the course of inter-State trade orcommerce or in the course of export of thegoods out of the territory of India or inthe course of import of the goods into theterritory of India. 2(r)"total turnover" means the aggregateturnover in all goods of a dealer at allplaces of business in the State, whether ornot the whole or any portion of suchturnover is liable to tax, including theturnover of purchase or sale in the courseof inter-State trade or commerce or in thecourse of export of the goods out of theterritory of India or in the course ofimport of the goods into the territory ofIndia. "15. Section 3 is the charging provision relating to payment ofgeneral sales tax under the Act. Section 4-A deals with levy ofturnover tax. The notification with which we are concerned hereinrelates to exemption from payment of turnover tax. Section 4-A ofthe Pondicherry General Sales Tax Act reads as follows:"4A. Levy of turnover tax – (1) Notwithstandinganything contained in this Act or the Rules madethereunder, every dealer shall pay turnover taxat the rate of three per cent on the totalturnover:Provided that no tax under this sectionshall be payable on that part of such turnover https://hcservices.ecourts.gov.in/hcservices/ which relates to, --(a) sale or purchase of goods in the course ofinter-State trade or commerce;(b) sale or purchase of goods in the course ofexport out of the territory of India or sale orpurchase in the course of import into theterritory of India;(c) all amounts falling under the head 'freight',when specified and charged for by the dealerseparately without including such amounts in theprice of the goods sold;(d) all amounts falling under the head 'chargesfor packing materials and cost of labour', whenspecified and charged for by the dealerseparately without including such amounts in theprice of the goods;(e) all amounts allowed as discount, providedthat such discount is allowed in accordance withthe regular practice of the dealer or is inaccordance with the terms of a contract oragreement entered into in a particular case andprovided also that the accounts show that thepurchaser has paid only the sum originallycharged less discount;(f) all amounts allowed to purchasers in respectof goods returned by them to the dealer when thegoods are taxable on sales provided that thegoods were returned within a period of threemonths from the date of delivery of the goods andthe accounts show the date on which the goodswere returned and the date on which and theamount for which refund was made; and(g) all amounts received from the sellers inrespect of goods returned to them by the dealer,when the goods are taxable on the purchase valueprovided that the goods were returned within aperiod of three months from the date of deliveryof the goods and the accounts show the date onwhich the goods were returned and the date onwhich and the amount for which refund wasreceived.(2) The provisions of this Act and the Rules madethereunder shall, so far as may be, apply inrelation to the assessment, collection or refundof the turnover tax, as they apply in relation tothe assessment, collection or refund of tax underother provisions of this Act.(3) Notwithstanding anything contained in Section https://hcservices.ecourts.gov.in/hcservices/ 25, no dealer shall collect from his purchaserthe turnover tax payable by him under thissection. "16. Section 4A starts with a non-obstante clause thatnotwithstanding anything contained in the Act or the Rules madethereunder, every dealer under the Act has to pay turnover tax at therate of 3% on the total turnover. The Section contains a proviso toexclude inter-state sale, sale in the interest of the country ofIndia or import into the territory of India, freight chargesseparately specified and turnover not includible in the totalturnover. As already seen, "total turnover", as defined underSection 2(r), means the aggregate turnover of a dealer in all goodsi.e., the amount for which goods are bought or sold, as given underthe definition of "turnover" under Section 2(s). In contrast toSection 3, the charging Section, which levies general sales tax onthe taxable turnover, levy of turnover tax is on the total turnoverof the dealer as computed in accordance with the definition of "totalturnover" under the Act. Thus going by the said definition,irrespective of the liability to pay general sales tax, thechargeability under the provisions of Section 4-A arises on theentire total turnover irrespective of whether the turnover is liableto tax at all or not, under the General Sales Tax levy, i.e., everyturnover which is comprised in the total turnover other than thosespecifically excluded falls for consideration under Section 4-A ofthe Pondicherry General Sales Tax Act.17. Section 9 is a specific provision which deals with the goodsspecified under the Third Schedule on which an exemption is granted.Thus in substance, the Third Schedule merely catalogues the goodswhich are exempted. Section 9, by itself, does not impose anycondition or restriction for granting the exemption. There are noRules which prescribe restrictions or conditions. However, the saidSection states that the exemption shall be subject to suchrestrictions and conditions as may be prescribed and the dealer whodeals in the goods specified under the Third Schedule shall not beliable to pay any tax under the Act in respect of such goods. Giventhe fact that the State is conferred the delegated legislativeauthority to issue notification in public interest grantingexemption/reduced rate of tax either absolutely as regards thedealers or goods or both or subject to such restrictions andconditions, goods falling under the Third Schedule may also come forconsideration under Section 19 for granting exemption/ reduced rateof tax, subject to conditions and restrictions. 18. Entry 25 of the Third Schedule deals with tobacco and allits products. Cigarettes being products of tobacco, fall under theSecond Entry. Even though learned counsel appearing for thepetitioner submits that by reason of Section 9, cigarettes, being a https://hcservices.ecourts.gov.in/hcservices/ product of tobacco, would qualify for exemption, given the fact thatSection 9 merely lists out in the Third Schedule, goods as exemptedgoods from payment of any tax and that the same are subject toconditions and restrictions as may be prescribed, the conditionprescribed through the notification under Section 19(1) and (2),hence, has to read into the same that the exemption is not anunqualified one, but subject to the conditions stated in thenotification. Thus while Section 9 has to be read as referable toexemption from payment of any tax under the Act as regards the goodsmentioned in the Third Schedule subject to conditions andrestrictions, the same has to be read with reference to theconditions and restrictions imposed under Section 19. In so holding,we are in entire agreement with the view expressed by the learnedsingle Judge in the order dated 08.10.1999 in W.P.No.15808 of 1999(M/s.Lakshmi Agencies, Yanam, by its Managing Partner Vs. UnionTerritory of Pondicherry and another).19. As regards the contention based on the Additional Duties ofExcise (Goods of Special Importance) Act, 1957, we do not find anyrepugnancy between the notification and the Additional Duties ofExcise (Goods of Special Importance) Act, 1957. The assesseecontends that the State has no competence to bring cigarettes withinthe ambit of turnover tax. The said argument rests on the premisethat cigarettes attract the provisions of the Additional Duties ofExcise (Goods of Special Importance) Act, 1957, that when once thereis an additional duty of excise leviable on the assessee, therecannot be a levy of turnover tax. We do not find any justificationto accept the said contention. The proviso under the Second Scheduleto the Additional Duties of Excise (Goods of Special Importance) Act,1957, reads as follows:"2. Tobacco – During the financial yearscommencing on the 1st day of April, 1984, thereshall be paid to each of the states specified incolumn 1 of the Table below such percentage ofthe net proceeds of additional duties levied andcollected during that financial year in respectof tobacco, after deducting therefrom a sum equalto 2.192 per cent of the said proceeds as beingattributable to Union territories, as is set outagainst it in column 2:Provided that if during that financial yearthere is levied and collected in any State a taxon the sale or purchase of tobacco by or underany law of that State, no sums shall be payableto that State under this paragraph in respect ofthat financial year, unless the CentralGovernment by special order otherwise directs.TABLE https://hcservices.ecourts.gov.in/hcservices/ ---------------------------------------------- StatePercentage---------------------------------------------- 1 2----------------------------------------------Andhra Pradesh8.011Assam2.297Bihar7.219Gujarat6.013Haryana2.785Himachal Pradesh0.734Jammu and Kashmir0.744Karnataka6.081Kerala 4.019Madhya Pradesh6.419Maharashtra 13.506Manipur0.185Meghalaya0.171Nagaland0.084Orissa3.456Punjab4.268Rajasthan4.365Sikkim0.034Tamil Nadu7.707Tripura0.256Uttar Pradesh 12.544West Bengal9.091----------------------------------------------4. Sugar, tobacco and fabrics. -- During each ofthe financial years commencing on and after the1st day of April, 1985, there shall be paid toeach of the States specified in column 1 of theTable below such percentage of the net proceedsof additional duties levied and collected duringthat financial year in respect of the goodsdescribed in column 3 of the First Schedule afterdeducting therefrom a sum equl to 2.391 per centof the said proceeds as being attributable toUnion territories, as is set out against it incolumn 2:Provided that if during that financial yearthere is levied and collected in any State a taxon the sale or purchase of sugar, tobacco, cottonfabrics, silk fabrics, woollen fabrics and man-made fabrics or one or more of them by or underany law of that State, no sums shall be payableto that State under this paragraph in respect of https://hcservices.ecourts.gov.in/hcservices/ that financial year, unless the CentralGovernment by special order otherwise directs. "20. Thus, the Additional Duties of Excise (Goods of SpecialImportance) Act, 1957, contemplates that where in the financial year,there is a levy and collection of tax under a State Law on the saleor purchase of tobacco by or under any law of that State, the saidState shall not be entitled to any share as regards the collection ofadditional duties and excise. Thus while Additional Duties of Excise(Goods of Special Importance) Act, 1957 does not bar the State fromlevying any tax and collecting the same in respect of the goodsattracting additional duties of excise, all that it bars herein isthat by reason of levy and collection of tax by that State, under theState law, the said State is not entitled to receive its share on thelevy and collection of additional duties of excise by the Centre.Thus the State is prohibited from getting its share in the benefit ofadditional duties and excise, unless the Central Government, byorder, otherwise directs. Thus the prohibition as regards goodssuffering additional duty of excise operates on a totally differentfield, referable to the rights of the State to receive its share inthe collection and it has no relevance at all to the State exercisingits authority to tax sales or purchases under Entry 54, List II ofthe Constitution. Even though the assessee pointed out that theRevenue had not given the details as to whether the Union Territoryof Puducherry had or had not received its share under the additionalduties of excise, yet, as rightly pointed out by the learned SpecialGovernment Pleader, the counter affidavit, in paragraph 14,specifically states that the Pondicherry Administration is notgetting any contribution from the additional duties of excisecollected by the Central Government under the Act of 1957. In thelight of the above, we do not find any ground to accept the plea ofthe petitioner herein on the challenge made to the notification.Consequently, we hold that the notification issued by the PondicherryAdministration is perfectly constitutional and there is no repugnancybetween the Additional Duties of Excise (Goods of Special Importance)Act, 1957 and the notification issued by virtue of Section 19(1) ofthe Pondicherry General Sales Tax Act. 21. Going by the definition of "total turnover" as defined underSection 4-A of the Pondicherry General Sales Tax Act, we have nohesitation in rejecting the plea of the petitioner. In view of theabove, W.P.No.18038 of 1999 stands dismissed. 22. W.A.No.77 of 2000 is preferred as against the order dated18.11.1999 in W.P.No.18498 of 1999, wherein, this Court had rejectedthe assessee's writ petition based on the order dated 08.10.1999 inW.P.No.15808 of 1999 (M/s.Lakshmi Agencies, Yanam, by its Managing https://hcservices.ecourts.gov.in/hcservices/ Partner Vs. Union Territory of Pondicherry and another). We agreewith the view of the learned single Judge in the order dated08.10.1999 in W.P.No.15808 of 1999 on the validity of thenotification. Thus in the light of the order passed by this Courtrejecting the prayer of the writ petitioner on the challenge made tothe notification, we have no hesitation in rejecting the writ appeal,thereby confirming the view of this Court in W.P.No.15808 of 1999.Consequently W.A.No.77 of 1999 stands rejected.23. As far as W.P.No.2991 of 2001 is concerned, the said writpetition relates to the challenge made to the assessment orderpassed, relating to the assessment year 1999-2000 under AssessmentOrder No.75 dated 12.1.2001. In the light of the order passed inW.P.No.18038 of 1999, the said writ petition, challenging theassessment order, stands dismissed. Having regard to the fact thatthe petitioner has approached this Court immediately after thereceipt of the assessment order dated 12.1.2001, in fitness ofthings, we grant the assessee four weeks' time to file an appeal,from the date of receipt of the order of this Court, if the assesseedesires to file an appeal as against the order of assessment. 24. In the result, W.P.No.18038 of 1999, W.A.No.77 of 2000 andW.P.No.2991 of 2001 stand dismissed. No costs. ConnectedW.M.P.No.26244 of 1999 also stands dismissed. Sd/- Asst.Registrar. /true copy/ Sub Asst.Registrar.ksvTo1. The Secretary to Government (Finance) Union of India Union Territory of Pondicherry, Pondicherry.2. The Commissioner Commercial Tax Pondicherry. https://hcservices.ecourts.gov.in/hcservices/

3. The Commercial Tax Officer (IW) Pondicherry.1 cc to M/s. Perumbulavil Radhakrishnan, Advocate, Sr. 41756W.P.No.18038 of 1999W.A.No.77 of 2000 andW.P.No.2992 of 2001RJ (CO)kk 29/7