{"id":205077,"date":"1975-10-06T00:00:00","date_gmt":"1975-10-05T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/mandyala-govindu-co-vs-commissioner-of-income-tax-on-6-october-1975"},"modified":"2015-11-02T20:14:52","modified_gmt":"2015-11-02T14:44:52","slug":"mandyala-govindu-co-vs-commissioner-of-income-tax-on-6-october-1975","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/mandyala-govindu-co-vs-commissioner-of-income-tax-on-6-october-1975","title":{"rendered":"Mandyala Govindu & Co vs Commissioner Of Income Tax, … on 6 October, 1975"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Mandyala Govindu & Co vs Commissioner Of Income Tax, … on 6 October, 1975<\/div>\n
Equivalent citations: 1975 AIR 2284, \t\t 1976 SCR (2) 131<\/div>\n
Author: A Gupta<\/div>\n
Bench: Gupta, A.C.<\/div>\n
           PETITIONER:\nMANDYALA GOVINDU & CO.\n\n\tVs.\n\nRESPONDENT:\nCOMMISSIONER OF INCOME TAX, ANDHRA PRADESH\n\nDATE OF JUDGMENT06\/10\/1975\n\nBENCH:\nGUPTA, A.C.\nBENCH:\nGUPTA, A.C.\nKRISHNAIYER, V.R.\nFAZALALI, SYED MURTAZA\n\nCITATION:\n 1975 AIR 2284\t\t  1976 SCR  (2) 131\n 1976 SCC  (1) 248\n\n\nACT:\n     Registration of  firms-Income Tax\tAct, 1922-Sec.\t26A-\nWhether share  of partners  in loss  to be  mentioned in the\nPartnership  Deed-Sec.\t 13(b)\tof  Partnership\t Act-In\t the\nabsence of  contract regarding\tshare in  loss-Whether to be\nborne equally or proportionate to profit.\n\n\n\nHEADNOTE:\n     The appellant assessee is a firm, having three Partners\nand one\t minor admitted\t to the benefits of the partnership.\nOne of\tthe partners  has 31%  share and  the remaining\t two\npartners and  the minor have 23% share each in the profit of\nthe firm  but the  partnership deed  is silent\tabout  their\nshares in  the losses.\tClauses 9  of the  partnership\tdeed\nprovides that the partners are bound to act according to the\nprovisions of  the Indian  Partnership Act. The firm applied\nfor registration  under s.  26A of  the Income Tax Act, 1922\nwhich was refused by the Income Tax officer.\n     The High  Court in a reference under s. 66(1) held that\nunless the  instrument r of partnership specified the shares\nof the\tpartners not  only in  the profits  but also  in the\nlosses, the firm would not be entitled to registration under\ns. 26A.\t The High  Court negatived  the\t contention  of\t the\nassessee that  clause 9\t of  the  instrument  indicated\t how\nlosses were to be apportioned between the partners.\n     On appeal\tby special  leave it  was contended  by\t the\nappellant:\n     (1) S.  26A does  not require  that the  instrument  of\npartnership  must  specify  the\t respective  shares  of\t the\npartners  in   the  losses  and\t it  is\t sufficient  if\t the\nproportion in which the losses are to be shared is otherwise\nascertainable.\n     (2) Assuming  that s.  26A does  require mentioning the\nproportion of  losses  in  the\tinstrument  of\tpartnership,\nclause 9  of  the  instrument  read  with  s  13(b)  of\t the\nPartnership Act satisfies that requirement.\n     Dismissing the appeal,\n^\n     HELD: (1)\tA firm whether registered or unregistered is\nan assessee  under the\tAct and\t can do\t business  as  such.\nHowever, registration  under s. 6A confers on the partners a\nbenefit to  which they\twould not have been entitled but for\ns. 26A and such a right being a creature of a statute can be\nclaimed only in accordance with the statute which confers it\nand the\t person who  seeks relief  under s.  26A must  bring\nhimself strictly  within its  terms before  he can claim the\nbenefit of it. [133D-E]\n     Rao Bahadur Revulu Subba Rao and others v. Commissioner\nof Income-Tax, Madras,<\/a> (1956) 30 I.T.R. 163, relied on.\n     (2) In  the case of a registered firm the share of each\npartner in  the profit\tor loss\t is  added  to\tor  set\t off\nagainst, as  the case  may be,\tto the\tother income  of the\npartner. Thus,\tthe loss,  if any,  affects  the  assessment\nproceedings and.  therefore, Income  Tax officer has to know\nwhat are  the respective  shares of the partners in the loss\nbefore allowing the firm to be registered. [134-C-D]\n     (3) There\tis a  conflict of  opinion amongst  the High\nCourts whether it is essential for registration under s. 26A\nthat the  shares of  the partners  must be  specified in the\npartnership deed.  It is  not necessary\t to decide  for\t the\npurpose of  this appeal\t which of  the conflicting  views is\ncorrect because\t in the\t present case the appeal is bound to\nfail on any view. It is not disputed and cannot\t be disputed\nthat the  Income Tax Officer before allowing the application\nfor\n132\nregistration must  be in  a position to ascertain the shares\nof the\tpartners in  the losses.  even if  s.  26A  did\t not\nrequire\t this\tto  be\t specified  in\t the  instrument  of\npartnership. [135E-F]\n     (4)  The\tcontention  that   clause  9  brings  in  by\nimplication s.\t13 (b)\tof  the\t Partnership  Act  and\tthus\nspecifies the  shares of  the  partners\t in  the  losses  is\nuntenable. s.  13(b) makes the partners liable to contribute\nequally to  the losses\tonly when they are entitled to share\nequally in  the profits.  ID this  case the  shares  of\t the\npartners are not equal. The case of K. Pitchiah Chettiar. v.\nG. Subramaniam\tChettiar I.L.R.<\/a>\t 58 Mad. 25 and In re Albion\nLife Assurance Society, 16 Ch. Div. 83, 87, applied. [135 G-\nH]\n     The law stated in these cases in the context of section\n253(2) of  the contract\t Act applies  equally to s. 13(b) of\nthe Partnership\t Act which  is in  identical terms.  In\t the\nabsence\t of  any  indication  to  the  Contrary,  where\t the\npartners  have\tagreed\tto  share  the\tprofits\t in  certain\nproportions, the  presumption is that the losses are also to\nbe shared in like proportions. The other rule that where the\nshares in  the profits are unequal the losses must be shared\nin the\tsame proportions  as profits  in the  absence of  an\nagreement as  to how  the losses are to be apportioned, also\ndoes not  apply to this case since there is a minor admitted\nto the\tbenefits of  the  partnership.\tEven  if  the  adult\npartner bear  the losses  in proportion\t to their respective\nshares in  the profits,\t the amount  of loss  in the minor's\nshare would still remain undistributed. Whether the partners\nbetween themselves  will bear  this loss  equally or  to the\nextent of their own individual shares, is not even suggested\nin the instrument of Partnership. TD There is, therefore, no\nmeans of  ascertaining in this ease how the losses are to be\napportioned. [136-H, 137A-C]\n\n\n\nJUDGMENT:\n<\/pre>\n
     CIVIL APPELLATE  JURISDICTION: Civil  Appeal No.  63 of
\n1971.\n<\/p>\n
     Appeal by\tSpecial Leave  from the\t Judgment and  order
\ndated the  19th February  1970 of  the Andhra  Pradesh\tHigh
\nCourt in R.C. No. 50 of 1966.\n<\/p>\n
     S.\t T.   Desai  and  K.  Rajendre\tChoudhary,  for\t the
\nAppellant
\n     G. C. Sharma and S. P. Nayar, for the Respondent.
\n     The Judgment of the Court was delivered by
\n     GUPTA, J.\tThis appeal  by special\t leave\tis  directed
\nagainst an  order of  the High\tCourt of  Andhra Pradesh  at
\nHyderabad answering  in the  negative and  in favour  of the
\nrevenue the  following question\t referred to  it under\tsec.
\n66(1)  of   the\t Indian\t Income-Tax  Act,  192\t(hereinafter
\nreferred to as the Act).\n<\/p>\n
\t  “Whether the\tAssessee is entitled to registration
\n     under Section  26A of  the Income-Tax Act, 1922 for the
\n     assessment year 1961-62.”<\/p><\/blockquote>\n
     The assessee  is a\t firm. The instrument of partnership
\nwas executed  on January  S, 1959  but the  application\t for
\nregistration under sec. 26A remained undisposed of until the
\nassessment for the year 1961-62 was taken up. The instrument
\nshows  that   three  persons,  Mandyala\t Narayana,  Mandyala
\nVenkatramaiah, Mandyala\t Srinivasulu and  a minor,  Mandyala
\nJaganmohan  who\t was  admitted\tto  the\t benefits  of\t the
\npartnership, held  the following  shares:  Narayana  31\t per
\ncent, Venkatramaiah  23 per  cent, Srinivasulu\t23 per cent,
\nand minor Jaganmohan 23 per cent: Clause 2 of the instrument
\nwhich sets out the
\n133<\/span>
\nshares of  the partners\t add that  the profits\tof the above
\npartnership  A\t business  shall   be  divided\tand  enjoyed
\naccording to  the shares  specified above.  ”  There  is  no
\nclause in  the instrument specifying the proportion in which
\nthe three  adult partners  were to share the losses, if any.
\nHaving set  out all  the terms\tof agreement, the instrument
\ncloses with clause 9 which states:\n<\/p>\n
\t  “We (the  partners) are  bound to act according to
\n     the above\tmentioned stipulations and also according to
\n     the provisions of the Indian Partnership Act….”<\/p><\/blockquote>\n
     The  High\tCourt  was  of\tthe  view  that\t unless\t the
\ninstrument  of\tpartnership  specified\tthe  shares  of\t the
\npartners not only in the profits hut also in the losses, the
\nfirm would  not be  entitled to registration under sec. 26A,
\nand  negatived\tthe  contention\t raised\t on  behalf  of\t the
\nassessee that  clause 9\t of  the  instrument  indicated\t how
\nlosses were  to be  apportioned between\t the  partners.\t The
\ncorrectness of\tthis decision is challenged by the appellant
\nfirm.\n<\/p>\n
     It is  not that  a firm  to be  able to  trade must  be
\nregistered  under   sec.  26A.\t A   firm,   registered\t  or
\nunregistered, is  an assessee  under  the  Act\tand  can  do
\nbusiness as  such.  However,  registration  under  sec.\t 26A
\n“confers on  the partners  a benefit”,\tas would appear from
\nthe provisions\tof sec.\t 23 (5)\t of the\t Act, “to which they
\nwould not have been entitled but for section 26A, and such a
\nright being  a creature\t of the statute, can be claimed only
\nin accordance  with the\t statute which\tconfers\t it,  and  a
\nperson who seeks relief under section 26A must bring himself
\nstrictly within its terms before he can claim the benefit of
\nit”: Rao Bahadur Ravulu Subba Rao and others v. Commissioner
\nof Income-tax,\tMadras.<\/a>(1) The\tquestion  in  this  case  is
\nwhether in  the absence\t of  a\tspecific  statement  in\t the
\ninstrument as  to the  proportion in which the partners were
\nto share the losses, the requirement of sec. 26A can be said
\nto have been satisfied. Sec 26A reads:\n<\/p>\n
\t  “26A. (1)  Application may  be made to the Income-
\n     tax officer on behalf of any firm, constituted under an
\n     instrument of  partnership\t specifying  the  individual
\n     shares  of\t  the  partners\t for  registration  for\t the
\n     purposes of this Act and of any other enactment for the
\n     time being\t in force  relating to\tincome-tax or super-
\n     tax.\n<\/p><\/blockquote>\n
\t  (2) The  application shall  be made by such person
\n     or persons,  and at  such times  and shall contain such
\n     particulars shall\tbe in  such form, and be verified in
\n     such manner,  as may  be prescribed;  and it  shall  be
\n     dealt with\t by the Income-tax officer in such manner as
\n     may be prescribed.”\n<\/p><\/blockquote>\n
The required  particulars are  specified in rules 2 and 3 of
\nthe Rules  framed under\t the Act and the form of application
\nincluding the Schedule annexed to rule 3. Paragraph 3 of the
\nForm requires the partners to `’certify that the profits (or
\nloss if any) ” of the relevant period were or will
\n     (1) (1956) 30 I. T. R. 163.\n<\/p>\n
134<\/span><\/p>\n
be, as\tthe case  is, ‘`divided\t or credited,  as  shown  in
\nSection 8 of the Schedule”. In Section 8 of the Schedule are
\nto be  recorded the “particulars of the apportionment of the
\nincome,\t profits   or  gains  (or  loss)  of  the  business,
\nprofession or  vocation in  the previous  year\tbetween\t the
\npartners who in that previous year were entitled to share in
\nsuch income,  profits or gains (or loss)”. Note (2) appended
\nto this\t Schedule states  that if any partner is entitled to
\nshare in  profits but  is  not\tliable\tto  bear  a  similar
\nproportion of  any losses, this fact should be indicated. It
\nis clear  therefore that  the application  for\tregistration
\nwhich has  to be  made in  the prescribed  form must include
\nparticulars of\tthe apportionment  of the  loss, if  any. It
\ndoes not appear to have been considered in this case whether
\nthe application\t for registration  made by the firm conforms
\nto the\tprescribed rules;  the dispute\tis confined  to\t the
\nquestion  whether   sec.  26A  requires\t the  instrument  of
\npartnership to specify the individual shares of the partners
\nin the profits as well as the losses of the business.\n<\/p>\n
     Section 23(5)  of the Act provides different procedures
\nin the\tassessment of  a registered  firm and a firm that is
\nunregistered. Without  going into  details, in the case of a
\nregistered firm\t the share  of each  partner in\t the  firm’s
\nprofits is  added to  his other income and he is assessed on
\nhis total income which includes his share of the profits and
\nthe tax\t payable  by him is determined accordingly. There is
\na proviso which lays down that “if such share of any partner
\nis a  loss it  shall be\t set off against his other income or
\ncarried\t forward   and\tset   off  in  accordance  with\t the
\nprovisions of  section 24”.  Thus, the loss, if any, affects
\nthe  assessment\t proceeding  and  therefore  the  Income-tax
\nofficer has  to know  what are\tthe respective shares of the
\npartners in  the losses\t before\t allowing  the\tfirm  to  be
\nregistered. It\tis not\tdisputed that the Income-tax officer
\nmust be\t in a  position to  ascertain how  losses are  to be
\napportioned; the  question is  whether it is a condition for
\nregistration  under   sec.  26A\t  that\tthe   instrument  of
\npartnership  must  specify  the\t respective  shares  of\t the
\npartners in  the losses. According to the appellant sec. 26A
\nhas no\tsuch requirement.  The appellant  contends that sec.
\n26A does  not require  specification of the shares in losses
\nin the instrument of partnership and it is sufficient if the
\nproportion in which the losses are to be shared is otherwise
\nascertainable,\tand   that,  assuming  the  section  did  so
\nrequire,  clause   9  of   the\tinstrument   satisfies\tthat
\nrequirement.\n<\/p>\n
     The contention  that clause  9 specifies the respective
\nshares of the partners in the losses is obviously untenable.
\nThis clause  says  that\t the  partners\tare  “bound  to\t act
\naccording to  the provisions of the Indian Partnership Act”;
\nthat they  are in  any case,  and  it  is  not\tclear  which
\nprovision of the Partnership Act indicated the proportion in
\nwhich the  partners were  to bear  the losses  in this case.
\nCounsel for  the appellant  refers  to\tsec.  13(b)  of\t the
\nPartnership Act in this connection.\n<\/p>\n
Sec. 12(b) reads:\n<\/p>\n
\t  “Subject to contract between the partners-\n<\/p><\/blockquote>\n
\t  (a)  x\t x\t\t x\t\t  x\n<\/p><\/blockquote>\n
\t  (b)  the partners are entitled to share equally in
\n\t       the  profits  earned,  and  shall  contribute
\n\t       equally to  the losses  sustained by the firm
\n\t       :”\n<\/p><\/blockquote>\n
135<\/span><\/p>\n
We shall refer to sec. 13(b) in more detail when we consider
\nthe other  contention of  the appellant,  but assuming\tthat
\nthis provision\thas any relevance to the facts of this case,
\nwhich it has not, bringing in by implication sec. 13(b) from
\na  general  statement  that  the  partners  are\t to  act  in
\naccordance with\t the Partnership  Act  does  not  amount  to
\nspecification of the partners’ shares in the losses, and the
\ninstrument of  partnership, it must therefore be held, fails
\nto comply  with sec. 26A of the Act, were this a requirement
\nof that section.\n<\/p>\n
     The other contention of the appellant is that it is not
\nessential for  registration under  sec. 26A  of the Act that
\nthe shares  of the  partners in the losses must be specified
\nin the\tpartnership deed.  In  support\tof  this  contention
\nreliance is  placed mainly  on two  decisions,\tone  of\t the
\nMysore High  Court: R.\tSannappa and Sons v. Commissioner of
\nIncome-tax, Mysore  (1) and  the other of the Allahabad High
\nCourt: Hiralal\tJagannath Prasad  v. Commissioner of Income-
\ntax, U.P.  (2) on behalf of the revenue it is claimed on the
\nauthority of a decision of the Gujarat High Court, Thacker &
\nCo. v.\tCommissioner of\t Income-tax, Gujarat  (3), that\t the
\nshares\tin   the  profits   and\t losses\t  have\tboth  to  be
\nspecifically stated  in the  instrument of.  partnership  in
\norder to comply with the conditions laid down in sec. 26A to
\nobtain registration.  The view\ttaken by  the  Gujarat\tHigh
\nCourt appears to have been followed by the Kerala High Court
\nin the\tfollowing cases\t among others:\tC. T. Palu & Sons v.
\nCommissioner of\t Income-tax, Kerala  (4) and Commissioner of
\nIncome-tax, Kerala  v. Ithappiri & George<\/a> (5), There is thus
\na conflict  of opinion\tin the\tHigh Courts on the point. It
\nwill not  be necessary,\t however, for  the purpose  of\tthis
\nappeal to  consider at\tany length  the conflicting views of
\nthe different  High Courts  and decide which view is correct
\naccording to  us because on the facts of the case the appeal
\nis bound  to fail  on any view. It is not, and it cannot be,
\ndisputed that  the Income-tax  officer before  allowing\t the
\napplication for\t registration  must  be\t in  a\tposition  to
\nascertain the  shares of  the partners in the losses even if
\nsec. 26A  did not  require the\tshares in  the losses  to be
\nspecified in  the instrument of partnership. Counsel for the
\nappellant argues  that clause  9 of the instrument refers to
\nsec. 13(b)  of\tthe  Partnership  Act  by  implication\tand,
\naccordingly, in\t the absence  of any contrary indication, it
\nmust be\t held that  the partners  are liable  to  share\t the
\nlosses equally.\t The argument  is not  based  on  a  correct
\nappreciation of the scope of sec. 13(b) and the facts of the
\ncase. Sec.  13(b), it  seems plain to us, makes the partners
\nliable to  contribute equally  to the  losses only when they
\nare entitled  to share\tequally in the profits. In this case
\nthe shares  of the partners are not equal. In the absence of
\nany indication\tto the\tcontrary, where\t the  partners\thave
\nagreed to  share the  profits in  certain  proportions,\t the
\npresumption is that the losses are also to be shared in like
\nproportions. Jessel  M. R.  states the\tprinciple in  In  re
\nAlbion Life Assurance Society (G) as follows:\n<\/p>\n
     (1) [1967] 66 I.T.R. 27.\t   (2) [1967] 66 I.T.R. 293.
\n     (3)[1966] 61 I.T.R. 540.\t   (4) [1969] 72 I T. R. 641
\n     (5) [1973] 88 L.T.R. 332.\t    (6) 16 Ch. Div. 83 (87).\n<\/p><\/blockquote>\n
10-L1276SCI\/75
\n136<\/span>
\n\t  “It is said, as a general proposition of law, that
\n     in ordinary  mercantile partnerships  where there\tis a
\n     community of profits in a definite proportion, the fair
\n     inference is  that\t losses are to be shared in the same
\n     proportion.”\n<\/p>\n
In the\tcase before us the partners having unequal shares in
\nthe profits, there can be no presumption that the losses are
\nto be equally shared between them
\n     Sec.  13(b)   of  the   Indian  Partnership  Act,\t1932
\nreproduces the provisions of the repealed sec. 253(2) of the
\nIndian Contract\t Act,  1872.  In  K.  Pitchiah\tChettiar  v.
\nG.Subramaniam Chettiar<\/a>(1), Ramesam J. explained the scope of
\nsec. 253 (2) of the Indian Contract Act, 1872:\n<\/p>\n
\t  “Section 253(2)  of the  Indian Contract  Act lays
\n     down that all partners are entitled to share equally in
\n     the profits  of  the  partnership\tbusiness,  and\tmust
\n     contribute equally\t towards the losses sustained by the
\n     partnership. As  I read  the section,  it lays down two
\n     presumptions with which the Court should start. The two
\n     presumption are  clubbed in  one sub section. The first
\n     is, if  no specific  contract is  proved, the shares of
\n     the partners  must be  presumed to\t be  equal.  In\t the
\n     present case the plaintiff alleged unequal shares which
\n     were not denied by the defendants. So the parties being
\n     agreed on their pleadings as to the shares possessed by
\n     them  in  the  profits,  there  is\t no  scope  for\t the
\n     application  of  this  first  presumption.\t The  second
\n     presumption  is   that  where   the  partners   are  to
\n     participate in  the  profits  in  certain\tshares\tthey
\n     should  also  participate\tin  the\t losses\t in  similar
\n     shares. Now  the section  says that  both should  be in
\n     equal shares  but implies\tthat if\t unequal shares\t are
\n     admitted by  the partners\tas to  profits that  applies
\n     equally  to   losses.  In\tthe  absence  of  a  special
\n     agreement, that  this should  be the  presumption\twith
\n     which one\tshould start  is merely\t a matter  of common
\n     sense and\tin India one has only to rely on section 114
\n     of the Evidence Act for such a principle.”\n<\/p><\/blockquote>\n
The law\t stated here  in the  context of  sec. 253(2) of the
\nContract Act,  1872 applies  equally to\t sec. 13(b)  of\t the
\nPartnership Act,  1932: the  two provisions are in identical
\nterms. On  the facts  of the present case, and having regard
\nto the\tscope of  sec. 13(b),  the section  has plainly\t  no
\napplication.\n<\/p>\n
     (1) I. L. R. 58 Mad. 25 (28).\n<\/p>\n
137<\/span><\/p>\n
     The other rule that where the shares in the profits are
\nunequal, the A losses must be shared in the same proportions
\nas the profits if there is no agreement as to how the losses
\nare to\tbe apportioned, does not also apply to this case. In
\nthis case  even if  the adult  partners bear  the losses  in
\nproportion to  their respective\t shares in  the profits, the
\namount of  loss in  the minor’s\t share\twould  still  remain
\nundistributed. Will  the   partners between  them bear\tthis
\nloss equally,  or to  the extent  of  their  own  individual
\nshares ?  To this  the instrument  of partnership  does\t not
\neven suggest  an answer.  There is  therefore  no  means  of
\nascertaining  in   this\t case  how  the\t losses\t are  to  be
\napportioned.\n<\/p>\n
     For the  reasons stated  above, the appeal fails and is
\ndismissed with costs.\n<\/p>\n
\t\t  P.H.P.Appeal dismissed.\n<\/p>\n
138<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Mandyala Govindu & Co vs Commissioner Of Income Tax, … on 6 October, 1975 Equivalent citations: 1975 AIR 2284, 1976 SCR (2) 131 Author: A Gupta Bench: Gupta, A.C. PETITIONER: MANDYALA GOVINDU & CO. Vs. RESPONDENT: COMMISSIONER OF INCOME TAX, ANDHRA PRADESH DATE OF JUDGMENT06\/10\/1975 BENCH: GUPTA, A.C. BENCH: GUPTA, A.C. […]<\/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-205077","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nMandyala Govindu & Co vs Commissioner Of Income Tax, ... on 6 October, 1975 - 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\/mandyala-govindu-co-vs-commissioner-of-income-tax-on-6-october-1975\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Mandyala Govindu & Co vs Commissioner Of Income Tax, ... on 6 October, 1975 - 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