{"id":148330,"date":"1999-05-05T00:00:00","date_gmt":"1999-05-04T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999"},"modified":"2018-10-12T10:40:35","modified_gmt":"2018-10-12T05:10:35","slug":"ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999","title":{"rendered":"M\/S. Electronics Corporation Of … vs Secretary,Revenue … on 5 May, 1999"},"content":{"rendered":"
Supreme Court of India<\/div>\n
M\/S. Electronics Corporation Of … vs Secretary,Revenue … on 5 May, 1999<\/div>\n
Author: Bharucha<\/div>\n
Bench: Bharucha S.P. (J), Kirpal B.N. (J), Rajendra Babu, S. (J), Quadri, S.S.M. (J), Shah, M.B. (J)<\/div>\n
           PETITIONER:\nM\/S.  ELECTRONICS CORPORATION OF INDIA LTD.\n\n\tVs.\n\nRESPONDENT:\nSECRETARY,REVENUE DEPARTMENT,GOVT.OF ANDHRA PRADESH AND ORS.\n\nDATE OF JUDGMENT:\t05\/05\/1999\n\nBENCH:\nB.N.Kirpal, S.P.Bharucha,S.R.Babu,Syed Shah Mohammed Quadri\n\n\n\n\nJUDGMENT:\n<\/pre>\n
      BHARUCHA, J.  :\n<\/p>\n
      Under  challenge\tis the principal judgment and  order
\ndated 30th July, 1982 of the High Court of Andhra Pradesh in
\nthe  case  of Electronics Corporation of India Ltd.   (Civil
\nAppeal\tNo.142\tof  1983)  and\t the  orders  following\t the
\nprincipal  judgment  and order in the cases of\tM\/s.   Parel
\nInvestment and Trading Co.  Limited (Civil Appeal No.3937-38
\nof   1990)  and\t Hindustan   Shipyard  Ltd.   (Civil  Appeal
\nNos.3939-41 of 1990 and 3393 of 1991).\n<\/p>\n
      It  is enough to set out the facts pertaining to Civil
\nAppeal\tNo.142 of 1983 filed by the Electronics\t Corporation
\nof  India Ltd.\t(the appellant company) in as much as  the
\nsame issue of law is involved in all the appeals and all the
\nappellants are companies registered under the Companies Act.\n<\/p>\n
      The  Andhra Pradesh Non Agricultural Lands  Assessment
\nAct, 1963 (the Act) defined owner to include any person
\nfor  the time being receiving or entitled to receive whether
\non  his\t own  account  or as agent,  or\t trustee,  guardian,
\nmanager,  receiver for another person or for any  religious,
\neducational  or charitable purpose, rent or profits from the
\nnon  agricultural  land or for the structure constructed  on
\nsuch   land,  in  respect  of\twhich  the  word  is  used.
\nConsequent  upon  amending Act 28 of 1974, with effect\tfrom
\n1st  July,  1974, the definition of owner was amended  and
\nthe  following, so far as is relevant here, was added:\tand
\nalso  includes\tin  respect of the land owned by  the  State
\nGovernment  or the Central Government (i) the lessee, if the
\nland  has  been\t leased\t out  by  that\tGovernment  for\t any
\ncommercial,  industrial\t or other non  agricultural  purpose
\n………  Section 3 is the charging section of the Act and
\nprovides  for  the  levy of assessment on  non\tagricultural
\nland, to be paid by the owner of such land.  Section 12 of
\nthe  Act  sets out the categories of land to which  the\t Act
\ndoes  not apply.  Prior to amending Act 28 of 1974, the\t Act
\ndid  not apply to land owned by the State Government or\t the
\nCentral\t Government.   Thereafter, it did not apply to\tland
\nowned  by  the\tState Government or the\t Central  Government
\nother  than  (i)  the land leased out for  any\tcommercial,
\nindustrial or other non agricultural purpose ……….\n<\/p>\n
      In  1963\tthe  State of Andhra Pradesh had  granted  a
\nlarge area of land to the Department of Atomic Energy of the
\nCentral Government.  In 1964 the Department of Atomic Energy
\ngave  220.25  acres  (the  said\t  land)\t thereout  to  the
\nappellant   company.   On  1st\t October,  1978,  the  first
\nrespondent issued to the appellant company notices of demand
\nfor  non-agricultural assessment on the said land under\t the
\nAct.  For the period 1970-71 to 1973-74 the sum demanded was
\nRs.1,91,189.68.\t  For the period 1974-75 to 1978-79 the\t sum
\ndemanded was Rs.11,98,826.32.\n<\/p>\n
      The  appellant  company filed a writ petition  in\t the
\nHigh  Court of Andhra Pradesh impugning the said notices  of
\ndemand.\t The contention of the appellant company in the writ
\npetition, as set out in the judgment and order under appeal,
\nwas  that it was the lessee of the said land which  belonged
\nto  the Union of India and, since the property of the  Union
\nof  India  could  not,\tby  virtue of  Article\t285  of\t the
\nConstitution,  be taxed by a State legislature, the Act\t did
\nnot  apply  to\tthe said land and,  accordingly,  no  demand
\nthereunder  could  be made upon the petitioner, which is  a
\nlessee\tof the Union of India.\tIt is stated that an area of
\napproximately\t1,000  acres  was   granted  by\t the   State
\nGovernment to the Department of Atomic Energy, Government of
\nIndia,\tand  that the Department of Atomic Energy, in  turn,
\nleased\tout  an\t extent of 280.25 acres\t to  the  petitioner
\ncorporation for establishing its plant and machinery.  It is
\nfurther\t contended  that  out of the extent granted  to\t the
\npetitioner an extent of 29 acres is covered by buildings, an
\nextent\tof  12 acres by roads, and the rest of the  area  is
\nmeant  for  future expansion.  It is also submitted that  an
\nextent\tof  14.25  acres  is  being  used  for\tagricultural
\npurposes.\n<\/p>\n
      The  response on behalf of the State Government to the
\nwrit  petition\twas  contained in an affidavit\tmade  by  N.
\nJanakiramulu.\tThe tenor of the affidavit was that the\t Act
\nhad  been  amended by Act 28 of 1974 and that, thereby,\t the
\nappellant  company had become liable to pay non agricultural
\nassessment upon the said land.\n<\/p>\n
      The  High\t Court, by the principal judgment and  order
\n(which\tis  reported in AIR 1983 AP 239), held that  Article
\n285  was  not  attracted and that the State  Government\t was
\nentitled to levy and collect the non agricultural assessment
\nfrom  the appellant company so long as it continued to be  a
\nlessee\tof  the\t Central Government in respect of  the\tsaid
\nland.  It clarified that the assessment could be levied only
\nupon  land which was actually used for any of the  specified
\npurpose,  namely,  commercial,\tindustrial   or\t any   other
\nnon-agricultural  purpose,  including  residential  purpose.
\nWhat  extent  of the said land was so used and what was\t the
\nappropriate  rate applicable was a matter for the  assessing
\nauthority to decide.  The appellant company was permitted to
\nfile  an  appeal  to the appellate authority under  the\t Act
\nagainst\t the  impugned demands, wherein it would be open  to
\nthe appellant company to establish the actual extent of land
\nused  for the aforesaid purposes.  The applicable rate could
\nalso be ascertained in such appeal.\n<\/p>\n
      It  is  against the principal judgment and order\tthat
\nall the appeals are really directed.\n<\/p>\n
      The  first submission of Mr.  Adhyaru, counsel for the
\nappellant  company, was that, in fact, the appellant company
\nwas  not  a lessee of the Union of India in respect  of\t the
\nsaid  land  and that there was no lease in its favour.\t The
\nsubmission is quite the reverse of the case of the appellant
\ncompany\t in  its  writ\tpetition.    It\t is,  therefore,  an
\nimpermissible  submission,  and\t we   indicated\t to  learned
\ncounsel when he made it that we declined to entertain it.\n<\/p>\n
      Article  285(1)  of  the Constitution of\tIndia,\tupon
\nwhich  reliance\t has been placed by the learned counsel\t for
\nthe appellant company, reads thus :\n<\/p>\n
      285(1)  The  property of the Union shall, save in\t so
\nfar  as Parliament may by law otherwise provides, be  exempt
\nfrom all taxes imposed by a State or by any authority within
\na State.\n<\/p>\n
      In  learned counsels submission, the property of\tthe
\nappellant  company was the property of the Union of India in
\nas  much as the appellant company was a Government  company,
\nits  shares  being wholly owned by the Union of India.\t The
\nsaid land was, therefore, the property of the Union of India
\nand  the  legislature  of the State of\tAndhra\tPradesh\t was
\nbarred\tby  the provisions of Article 285 from imposing\t any
\ntax,  including non-agricultural assessment, on the property
\nof  the\t Union\tof  India.  Learned  counsel  supported\t the
\nsubmission  by reference to Article 265, which provides that
\nno  tax shall be levied or collected except by authority of
\nlaw,  and  to  Article 366(28), which says  that  taxation
\nincludes  the  imposition  of  any tax\tor  impost,  whether
\ngeneral\t or  local  or special, and tax shall  be  construed
\naccordingly.\n<\/p>\n
      Learned  counsel\tthen referred to Article  289  which
\ndeals  with the exemption of property and income of a  State
\nfrom Union taxation and reads thus :\n<\/p>\n
      289(1)  The  property and income of a State shall\t be
\nexempt from Union taxation.\n<\/p>\n
      (2) Nothing in clause (1) shall prevent the Union from
\nimposing,  or authorising the imposition of, any tax to such
\nextent,\t if any, as Parliament may by law provide in respect
\nof  a  trade  or business of any kind carried on by,  or  on
\nbehalf\tof,  the  Government of a State, or  any  operations
\nconnected  therewith,  or any property used or occupied\t for
\nthe  purposes  of  such\t trade or business,  or\t any  income
\naccruing or arising in connection therewith.\n<\/p>\n
      (3)  Nothing in clause (2) shall apply to any trade or
\nbusiness,  or  to  any\tclass of trade\tor  business,  which
\nParliament  may\t by  law  declare to be\t incidental  to\t the
\nordinary functions of Government.\n<\/p>\n
      Our  attention  was  drawn by learned counsel  to\t the
\njudgment  of  this Court on Article 289, namely,  New  Delhi
\nMunicipal  Council vs.\tState of Punjab & Ors.\t1997(7)\t SCC\n<\/p>\n
339.   In  construing  Article 289, reference  was  made  to
\nArticle\t 285  and it was said in the majority judgment\tthat
\nArticle\t 285 imposed a ban, which was absolute and emphatic
\nand there was no way in which a State Legislature could levy
\na  tax upon the property of the Union of India. Article 289
\nwas different by reason of clauses 2 and 3 thereof.\n<\/p>\n
      In the next case cited by learned counsel, namely, Air
\nIndia Statutory Corporation & Ors.  vs.\t United Labour Union
\n&  Ors.,<\/a> 1997(9) SCC 377, this Court was dealing with  which
\nwas   the  appropriate\tGovernment  in\trelation   to\tan
\nestablishment  pertaining  to an industry carried on by\t or
\nunder  authority of the Central Government and it was  held
\nthat  the  statutory  corporation,  Air India,\twas  such  a
\nindustry  and the appropriate Government for the  purposes
\nof the Contract Labour (Regulation and Abolition) Act, 1970,
\nwas  the Central Government.  Reliance was placed by learned
\ncounsel\t upon the propositions enunciated in paragraph 26 of
\nthe majority judgment, thus:\n<\/p>\n
      (1)   The\t  constitution\tof   the   corporation\t or
\ninstrumentality\t or  agency  or\t  corporation  aggregate  or
\ncorporation sole is not of sole material relevance to decide
\nwhether\t it  is by or under the control of  the\t appropriate
\nGovernment under the Act.\n<\/p>\n
      (2)  If  it  is  a statutory  corporation,  it  is  an
\ninstrumentality\t or agency of the State.  If it is a company
\nowned  wholly or partially by a share capital, floated\tfrom
\npublic\texchequer, it gives indicia that it is controlled by
\nor under the authority of the appropriate Government.\n<\/p>\n
      In  our view, neither has Article 285 any\t application
\nto  these  appeals nor are we concerned with whether or\t not
\nthe  appellants are controlled by or under the authority  of
\nthe Central Government.\n<\/p>\n
      With effect from 1st July, 1974, Section 12 of the Act
\nwas  amended so that it now applied to land which was  owned
\nby  the Central or a State Government and was leased out for
\nany   commercial,  industrial  or   other   non-agricultural
\npurpose.   With\t effect\t from that date, by  reason  of\t the
\namendment  of Section 2(j), an owner included a lessee\tof
\nland  owned by the Central or a State Government if the land
\nwas  leased  out  by  such   Government\t for  a\t commercial,
\nindustrial or other non- agricultural purpose.\tBy virtue of
\nSection 3, the obligation to pay non-agricultural assessment
\non the leased land lay upon the owner lessee.\n<\/p>\n
      It  is  the case of the appellant company in its\twrit
\npetition  that it is the lessee of the Department of  Atomic
\nEnergy\tof  the Union of India in respect of the said  land.
\nThe said land, therefore, is of the ownership of the Central
\nGovernment  and,  being leased out to the appellant  company
\nfor  an industrial and commercial purpose, is land to  which
\nthe  Act  applies.  By virtue of the amended  definition  of
\nowner under Section 2(j) of the Act, the appellant company
\nis  the owner of the said land and, by virtue of Section  3,
\nis liable to pay non-agricultural assessment thereon.\n<\/p>\n
      A\t clear\tdistinction must be drawn between a  company
\nand  its  shareholder, even though that shareholder  may  be
\nonly one and that the Central or a State Government.  In the
\neye of the law, a company registered under the Companies Act
\nis  a  distinct legal entity other than the legal entity  or
\nentities that hold its shares.\n<\/p>\n
      In  Western  Coalfields  Limited\t vs.   Special\tArea
\nDevelopment  Authority, Korba & Anr.,<\/a> 1982(1) SCC 125,\tthis
\nCourt reviewed earlier judgments on the point.\tIt held that
\neven though the entire share capital of the appellant before
\nit  had been subscribed by the Government of India, it could
\nnot be predicated that the appellant itself was owned by the
\nGovernment  of\tIndia.\t Companies, it was said,  which\t are
\nincorporated  under  the  Companies Act,  have\ta  corporate
\npersonality  of\t their\town,  distinct\t from  that  of\t the
\nGovernment  of\tIndia.\t The  lands  and  the  buildings  in
\nquestion  in  that  matter were vested in and owned  by\t the
\nappellant.   The  Government of India only owned  the  share
\ncapital.\n<\/p>\n
      In Rustom Cavasjee Cooper vs.  Union of India,<\/a> 1970(1)
\nSCC  248,  it  was  held, A company  registered\t under\tthe
\nCompanies  Act is a legal person, separate and distinct from
\nits  individual members.  Property of the company is not the
\nproperty  of the shareholders.\tA shareholder has merely  an
\ninterest  in  the  company  arising under  its\tArticles  of
\nAssociation,  measured by a sum of money for the purpose  of
\nliability, and by a share in the distributed profit.\n<\/p>\n
      In  Heavy\t Engineering  Mazdoor Union  vs.   State  of
\nBihar,<\/a> 1969(1) SCC 765, this Court held that an incorporated
\ncompany\t has a separate existence and the law recognises  it
\nas  a  juristic\t person,  separate  and\t distinct  from\t its
\nmembers.\n<\/p>\n
      We  are,\tin the premises, left in no doubt  that\t the
\nState  Government  was\tentitled  to  levy  non-agricultural
\nassessment  upon  the  said  land and recover  it  from\t the
\nappellant company.\n<\/p>\n
      Learned counsel then submitted that, in any event, the
\nrecovery  of  non agricultural assessment in respect of\t the
\nsaid  land  could not have been effected from the  appellant
\ncompany\t by  reason of the application of the  principle  of
\npromissory estoppel.  In this behalf he referred to a letter
\ndated 7th February, 1967 addressed by the Under Secretary to
\nthe  Government of India to the Secretary of the  Government
\nof  Andhra Pradesh, Industries Department, in regard to\t the
\ntransfer of land to the Department of Atomic Energy for the
\nlocation  of  the Electronics Plant and other  plants.\tThe
\nletter\tstated\tthat  it  had\tbeen  agreed  by  the  State
\nGovernment  that this land would be exempt from the levy  of
\ntax  under  the Act irrespective of whether the plants\tare
\nmanaged\t  departmentally  or  through\ta   Public   Section
\nUndertaking.   The  letter  requested  that  notifications
\nexempting the lands already handed over to the Department of
\nAtomic\tEnergy\tor to be handed over in future from levy  of
\ntax  under  Andhra Pradesh Act 14 of 1963, while vesting  in
\nthe Department of Atomic Energy or in public sector projects
\nwould  also require to be issued. The issuance of the  same
\nwas,  therefore, requested.  In reply, the Deputy  Secretary
\nof  the Government of Andhra Pradesh, Industries Department,
\nstated\ton 17th October, 1967 that no separate notification
\nis  required  exempting the land given to the Atomic  Energy
\nDepartment  for\t establishment of Atomic Energy\t Complex  at
\nHyderabad  from payment of non-agricultural assessment under
\nthe  A.P.   Non- Agricultural Assessment Act so long as\t the
\nunits  are run by the Government of India in Public Sector.
\nIt  was\t contended  by learned counsel\tthat  the  appellant
\ncompany had acted upon this promise.  Accordingly, the State
\nGovernment  was\t bound by its promise and was estopped\tfrom
\ngoing back upon it.\n<\/p>\n
      There  are  two short answers to this contention.\t  In
\nthe first place, there can be no estoppel against a statute.
\nIn  the\t second place, the letter dated 17th  October,\t1967
\nneeds  to  be carefully read.  It says that no\tnotification
\nwas  required  for  exempting  the   land  from\t payment  of
\nnon-agricultural assessment so long as the units are run by
\nthe  Government\t of India in Public Sector.  The  appellant
\ncompany\t is  a separate and distinct legal entity that\truns
\nits  own  industry.   The letter dated\t17th  October,\t1967
\ncannot\tbe read as promising exemption to companies,  though
\ntheir shares be held wholly by the Union of India.\n<\/p>\n
      Mr.   Dholakia,  learned\tcounsel\t  for  M\/s.    Parel
\nInvestment  and\t Trading  Co.  Limited (appellant  in  Civil
\nAppeal\tNos.3937-38  of\t 1990),\t  adopted  the\t submissions
\naforementioned.\t  He submitted that Article 285 was intended
\nto  protect  public revenues;  the shares of  the  appellant
\ncompanies being fully owned by the Central Government, their
\nfunds were public revenues.  It was, therefore, necessary to
\nread  down the provisions of Section 2(j) and Section 12  of
\nthe  Act  to  exclude therefrom all but private\t owners\t and
\nlessees\t of land.  The question of reading down comes in  if
\nit  is\tfound that these provisions are ultra vires as\tthey
\nstand.\t We  have held that these provisions are  not  ultra
\nvires  because Article 285 does not apply when the  property
\nthat  is  to be taxed is not of the Union of India but of  a
\ndistinct  and separate legal entity.  Each of the appellants
\nbeing  companies  registered under Companies Act,  they\t are
\nentities  other\t than the Union of India.  The\tquestion  of
\nreading down does not, therefore, arise.\n<\/p>\n
      The   discussion\tso  far\t  relates  to  demands\t for
\nnon-agricultural  assessment  subsequent to 12th July  1974,
\nwhen  the amendments made by Act 28 of 1974 in the Act\tcame
\ninto  effect.  The defence to the writ petition filed by the
\nappellant   company   was,  as\twe  have   already   stated,
\nexclusively based upon the amendments made by Act 28 of 1974
\nin  the Act.  These amendments have no retrospective effect.
\nNo  demand for non-agricultural assessment could, therefore,
\nhave  been made upon the appellant companies for any  period
\nprior  to 12th July, 1974.  To this extent, the demands\t are
\nquashed.\n<\/p>\n
      In  regard to demands for non-agricultural  assessment
\nsubsequent  to\t12th  July,  1974,  which  are\tupheld,\t the
\nappellant  companies  shall  be at liberty to  file  appeals
\nwithin\t8 weeks from the date of this order, wherein it will
\nbe  open to them to establish the actual extent of the\tland
\nthat  was  used\t at  the   relevant  time  for\t commercial,
\nindustrial  or\tother non-agricultural purposes.  Only\tupon
\nsuch  land can non-agricultural assessment be levied.\tWhat
\nthe  applicable\t rate  should be can also be  canvassed\t and
\ndecided in such appeals.\n<\/p>\n
      To the extent aforestated, the appeals succeed and are
\nallowed.  Orders on the appeals accordingly.  No order as to
\ncosts.<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India M\/S. Electronics Corporation Of … vs Secretary,Revenue … on 5 May, 1999 Author: Bharucha Bench: Bharucha S.P. (J), Kirpal B.N. (J), Rajendra Babu, S. (J), Quadri, S.S.M. (J), Shah, M.B. (J) PETITIONER: M\/S. ELECTRONICS CORPORATION OF INDIA LTD. Vs. RESPONDENT: SECRETARY,REVENUE DEPARTMENT,GOVT.OF ANDHRA PRADESH AND ORS. DATE OF JUDGMENT: 05\/05\/1999 BENCH: […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-148330","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nM\/S. Electronics Corporation Of ... vs Secretary,Revenue ... on 5 May, 1999 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"M\/S. Electronics Corporation Of ... vs Secretary,Revenue ... on 5 May, 1999 - Free Judgements of Supreme Court & High Court | Legal India\" \/>\n<meta property=\"og:url\" content=\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999\" \/>\n<meta property=\"og:site_name\" content=\"Free Judgements of Supreme Court & High Court | Legal India\" \/>\n<meta property=\"article:publisher\" content=\"https:\/\/www.facebook.com\/LegalindiaCom\/\" \/>\n<meta property=\"article:published_time\" content=\"1999-05-04T18:30:00+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2018-10-12T05:10:35+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/i0.wp.com\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg?fit=512%2C512&ssl=1\" \/>\n\t<meta property=\"og:image:width\" content=\"512\" \/>\n\t<meta property=\"og:image:height\" content=\"512\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/jpeg\" \/>\n<meta name=\"author\" content=\"Legal India Admin\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:creator\" content=\"@legaliadmin\" \/>\n<meta name=\"twitter:site\" content=\"@Legal_india\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Legal India Admin\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"15 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#article\",\"isPartOf\":{\"@id\":\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999\"},\"author\":{\"name\":\"Legal India Admin\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea\"},\"headline\":\"M\/S. Electronics Corporation Of … vs Secretary,Revenue … on 5 May, 1999\",\"datePublished\":\"1999-05-04T18:30:00+00:00\",\"dateModified\":\"2018-10-12T05:10:35+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999\"},\"wordCount\":2936,\"commentCount\":0,\"publisher\":{\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#organization\"},\"articleSection\":[\"Supreme Court of India\"],\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"CommentAction\",\"name\":\"Comment\",\"target\":[\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#respond\"]}]},{\"@type\":\"WebPage\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999\",\"url\":\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999\",\"name\":\"M\/S. Electronics Corporation Of ... vs Secretary,Revenue ... on 5 May, 1999 - Free Judgements of Supreme Court & High Court | Legal India\",\"isPartOf\":{\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#website\"},\"datePublished\":\"1999-05-04T18:30:00+00:00\",\"dateModified\":\"2018-10-12T05:10:35+00:00\",\"breadcrumb\":{\"@id\":\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\/\/www.legalindia.com\/judgments\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"M\/S. Electronics Corporation Of … vs Secretary,Revenue … on 5 May, 1999\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#website\",\"url\":\"https:\/\/www.legalindia.com\/judgments\/\",\"name\":\"Free Judgements of Supreme Court & High Court | Legal India\",\"description\":\"Search and read the latest judgements, orders, and rulings from the Supreme Court of India and all High Courts. A comprehensive database for lawyers, advocates, and law students.\",\"publisher\":{\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#organization\"},\"alternateName\":\"Free judgements of Supreme Court & High Court of India | Legal India\",\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\/\/www.legalindia.com\/judgments\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Organization\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#organization\",\"name\":\"Judgements of Supreme Court & High Court | Legal India\",\"alternateName\":\"Legal India\",\"url\":\"https:\/\/www.legalindia.com\/judgments\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/\",\"url\":\"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg\",\"contentUrl\":\"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg\",\"width\":512,\"height\":512,\"caption\":\"Judgements of Supreme Court & High Court | Legal India\"},\"image\":{\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/\"},\"sameAs\":[\"https:\/\/www.facebook.com\/LegalindiaCom\/\",\"https:\/\/x.com\/Legal_india\"]},{\"@type\":\"Person\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea\",\"name\":\"Legal India Admin\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/image\/\",\"url\":\"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"contentUrl\":\"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g\",\"caption\":\"Legal India Admin\"},\"sameAs\":[\"https:\/\/www.legalindia.com\",\"https:\/\/x.com\/legaliadmin\"],\"url\":\"https:\/\/www.legalindia.com\/judgments\/author\/legal-india-admin\"}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"M\/S. Electronics Corporation Of ... vs Secretary,Revenue ... on 5 May, 1999 - Free Judgements of Supreme Court & High Court | Legal India","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999","og_locale":"en_US","og_type":"article","og_title":"M\/S. Electronics Corporation Of ... vs Secretary,Revenue ... on 5 May, 1999 - Free Judgements of Supreme Court & High Court | Legal India","og_url":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999","og_site_name":"Free Judgements of Supreme Court & High Court | Legal India","article_publisher":"https:\/\/www.facebook.com\/LegalindiaCom\/","article_published_time":"1999-05-04T18:30:00+00:00","article_modified_time":"2018-10-12T05:10:35+00:00","og_image":[{"width":512,"height":512,"url":"https:\/\/i0.wp.com\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg?fit=512%2C512&ssl=1","type":"image\/jpeg"}],"author":"Legal India Admin","twitter_card":"summary_large_image","twitter_creator":"@legaliadmin","twitter_site":"@Legal_india","twitter_misc":{"Written by":"Legal India Admin","Est. reading time":"15 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"Article","@id":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#article","isPartOf":{"@id":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999"},"author":{"name":"Legal India Admin","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea"},"headline":"M\/S. Electronics Corporation Of … vs Secretary,Revenue … on 5 May, 1999","datePublished":"1999-05-04T18:30:00+00:00","dateModified":"2018-10-12T05:10:35+00:00","mainEntityOfPage":{"@id":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999"},"wordCount":2936,"commentCount":0,"publisher":{"@id":"https:\/\/www.legalindia.com\/judgments\/#organization"},"articleSection":["Supreme Court of India"],"inLanguage":"en-US","potentialAction":[{"@type":"CommentAction","name":"Comment","target":["https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#respond"]}]},{"@type":"WebPage","@id":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999","url":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999","name":"M\/S. Electronics Corporation Of ... vs Secretary,Revenue ... on 5 May, 1999 - Free Judgements of Supreme Court & High Court | Legal India","isPartOf":{"@id":"https:\/\/www.legalindia.com\/judgments\/#website"},"datePublished":"1999-05-04T18:30:00+00:00","dateModified":"2018-10-12T05:10:35+00:00","breadcrumb":{"@id":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#breadcrumb"},"inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999"]}]},{"@type":"BreadcrumbList","@id":"https:\/\/www.legalindia.com\/judgments\/ms-electronics-corporation-of-vs-secretaryrevenue-on-5-may-1999#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/www.legalindia.com\/judgments\/"},{"@type":"ListItem","position":2,"name":"M\/S. Electronics Corporation Of … vs Secretary,Revenue … on 5 May, 1999"}]},{"@type":"WebSite","@id":"https:\/\/www.legalindia.com\/judgments\/#website","url":"https:\/\/www.legalindia.com\/judgments\/","name":"Free Judgements of Supreme Court & High Court | Legal India","description":"Search and read the latest judgements, orders, and rulings from the Supreme Court of India and all High Courts. A comprehensive database for lawyers, advocates, and law students.","publisher":{"@id":"https:\/\/www.legalindia.com\/judgments\/#organization"},"alternateName":"Free judgements of Supreme Court & High Court of India | Legal India","potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/www.legalindia.com\/judgments\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Organization","@id":"https:\/\/www.legalindia.com\/judgments\/#organization","name":"Judgements of Supreme Court & High Court | Legal India","alternateName":"Legal India","url":"https:\/\/www.legalindia.com\/judgments\/","logo":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/","url":"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg","contentUrl":"https:\/\/www.legalindia.com\/judgments\/wp-content\/uploads\/sites\/5\/2025\/09\/legal-india-icon.jpg","width":512,"height":512,"caption":"Judgements of Supreme Court & High Court | Legal India"},"image":{"@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/logo\/image\/"},"sameAs":["https:\/\/www.facebook.com\/LegalindiaCom\/","https:\/\/x.com\/Legal_india"]},{"@type":"Person","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/0bfdffe9059fb8bb24a86d094609c5ea","name":"Legal India Admin","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/www.legalindia.com\/judgments\/#\/schema\/person\/image\/","url":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/4faa9d728ed1af3b73d52225c7f12901ac726fe6f7ea0a3348a1d51f3a930987?s=96&d=mm&r=g","caption":"Legal India Admin"},"sameAs":["https:\/\/www.legalindia.com","https:\/\/x.com\/legaliadmin"],"url":"https:\/\/www.legalindia.com\/judgments\/author\/legal-india-admin"}]}},"modified_by":null,"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"jetpack_likes_enabled":true,"jetpack-related-posts":[],"_links":{"self":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts\/148330","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/comments?post=148330"}],"version-history":[{"count":0,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/posts\/148330\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/media?parent=148330"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/categories?post=148330"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.legalindia.com\/judgments\/wp-json\/wp\/v2\/tags?post=148330"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}