{"id":218717,"date":"1996-01-19T00:00:00","date_gmt":"1996-01-18T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/the-madhya-pradesh-vs-additional-commissioner-of-on-19-january-1996"},"modified":"2016-05-28T00:57:54","modified_gmt":"2016-05-27T19:27:54","slug":"the-madhya-pradesh-vs-additional-commissioner-of-on-19-january-1996","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/the-madhya-pradesh-vs-additional-commissioner-of-on-19-january-1996","title":{"rendered":"The Madhya Pradesh … vs Additional Commissioner Of … on 19 January, 1996"},"content":{"rendered":"
Supreme Court of India<\/div>\n
The Madhya Pradesh … vs Additional Commissioner Of … on 19 January, 1996<\/div>\n
Equivalent citations: 1996 SCC (2) 541, \t JT 1996 (1)\t487<\/div>\n
Author: A A.M.<\/div>\n
Bench: Ahmadi A.M. (Cj)<\/div>\n
           PETITIONER:\nTHE MADHYA PRADESH CO-OPERATIVEBANK LIMITED, JABALPUR\n\n\tVs.\n\nRESPONDENT:\nADDITIONAL COMMISSIONER OF INCOMETAX MADHYA PRADESH, BHOPAL\n\nDATE OF JUDGMENT:\t19\/01\/1996\n\nBENCH:\nAHMADI A.M. (CJ)\nBENCH:\nAHMADI A.M. (CJ)\nHANSARIA B.L. (J)\n\nCITATION:\n 1996 SCC  (2) 541\t  JT 1996 (1)\t487\n 1996 SCALE  (1)511\n\n\nACT:\n\n\n\nHEADNOTE:\n\n\n\nJUDGMENT:\n<\/pre>\n
\t\t\t    WITH
\n\t     CIVIL APPEAL NO. 1196 (NT) OF 1992
\nMadhya Pradesh Rajya Sahkari
\nBank Maryadit, Bhopal
\nV.\n<\/p>\n
Commissioner of Income Tax, Jabalpur
\n\t\t\t    WITH
\n\t     CIVIL APPEAL NOs. 2211-12 OF 1996
\n\t (Arising out of SLP (C) 5813 & 14 of 1982)
\n(The Madhya Pradesh Co-operative
\nBank Limited
\nV.\n<\/p>\n
The Additional Commissioner of
\nIncome Tax
\n\t\t      J U D G M E N T
\nAHMADI, CJI
\n     Special leave granted in SLP (C) Nos. 5813-14 of 1982.
\n     The assessee  in all  these  cases\t is  a\tCo-operative
\nSociety registered  under the  Madhya  Pradesh\tCo-operative
\nSociety registered  under the  Madhya  Pradesh\tCo-operative
\nSocieties (Amalgamation)  Act, 1957, hereinafter called `the
\nAct’. While  framing assessment\t for the relevant assessment
\nyears in  question, the\t Income tax Officer, included in the
\ntaxable income of the assessee interest earned on securities
\nearmarked against  reserves and interest earned on Provident
\nfund deposits.\tThe assessee  contended that it was entitled
\nto the\tbenefit of  Section 81\tof the\tIncome Tax Act as in
\nforce at all material times. The Income Tax Officer rejected
\nthis  claim  of\t exemption  from  tax  put  forward  by\t the
\nassessee. Since the assesee’s contention did not find favour
\nat the\thigher levels  also, including\tthe reference to the
\nHigh Court, the assessee has approached this Court.\n<\/p>\n
     Section  81   of  the   Income-Tax\t Act  on  which\t the
\nassessee’s case is based read thus at all material times:\n<\/p>\n
     “Income  of   co-operative\t societies  –
\n     Income Tax shall not be payable by a co-
\n     operative society —\n<\/p><\/blockquote>\n
     (i) in  respect of the profits and gains
\n     of business carried on by it, if it is –\n<\/p><\/blockquote>\n
     (a) a society engaged in carrying on the
\n     business of  banking or providing credit
\n     facilities to its members;\n<\/p><\/blockquote>\n
     xxx\t\txxx\t\t  xxx
\n\t  Provided that, in the case of a co-
\n     operative society\twhich is also engaged
\n     in activities other than those mentioned
\n     in this clause, nothing contained herein
\n     shall apply  to that part of its profits
\n     and gains\tas is  attributable  to\t such
\n     activities\t and   as   exceeds   fifteen
\n     thousand rupees.”\n<\/p><\/blockquote>\n
On a  plain reading  of this provision it becomes clear that
\nevery income  of a  society carrying  on banking business is
\nnot exempt  from the  payment of  tax. Only  the income from
\nbanking business  is exempt  from tax. The question which we
\nare required  to answer\t is whether the income from interest
\naccruing on  government securities  ear-marked\tfor  Reserve
\nFund\/Provident Fund  can be said to be income derived by the
\nassessee from  the business of banking within the meaning of
\nSection 81 to qualify for exemption. This question arises in
\nthe backdrop of the following facts.\n<\/p>\n
     The assessee  is an  Apex Body controlling all District
\nco-operative banks. It is registered under the provisions of
\nthe co-operative  Societies Act, 1912 read with Section 6 of
\nthe Act.  The assessee\tfiled returns for the relevant years
\nclaiming that  the entire  income was  from banking business
\nand, therefore,\t exempt from  tax under\t Section 81  of\t the
\nIncome Tax Act. The Income Tax Officer rejected the claim in
\nregard to  interest being  exempt under\t the said provision.
\nThere is  no dispute, and indeed there can be none, that the
\nassessee is  engaged in\t carrying on the business of banking
\nwhich, inter alia, includes the activity of providing credit
\nfacilities to  its members. In the course of its business it
\nreceives deposits  and makes advances to borrowers at a rate
\nof interest  higher than what it pays on deposits. A part of
\nthese  deposits\t are,  however,\t invested  in  the  form  of
\ngovernment securities  with the\t State Bank  of India or the
\nReserve Bank. Under Section 44 of the Co-operative Societies
\nAct, the assessee is required to invest or deposit its funds
\nto maintain  a cover  to the  extent necessary\tand  further
\nprovides that  the Reserve  Fund of  the  Society  shall  be
\ninvested and  utilised as may be laid down by the Registrar,
\nwhich  it   does  by   investing  in  government  securities
\npurchased with the bank’s funds. The question is whether the
\ninterest earned\t by the\t assessee from government securities
\nplaced with  the State\tBank or the Reserve Bank can qualify
\nfor exemption under Section 81 of the Income Tax Act?\n<\/p>\n
     Before we\tproceed to answer this question we may refer
\nto the\tM.P. Government’s  instructions\t No.CR\t25\/26  dated
\nOctober 7,  1960 which,\t insofar as  it concerns Apex banks,
\nreads as under:\n<\/p>\n
     “(C) APEX BANK
\n     The Reserve  Fund of the Apex Bank shall
\n     be fully  invested outside\t its business
\n     in Government securities. No part of its
\n     reserve fund  should be  utilised as its
\n     working capital.\n<\/p><\/blockquote>\n
     3. All investments of Reserve fund shall
\n     be specially  marked  as  “Reserve\t Fund
\n     Investment”   and\t  shall\t  be\tshown
\n     separately in the annual balance sheets.
\n     The Reserve Fund deposits at every level
\n     shall carry the maximum rate of interest
\n     which a  Central bank  or Apex bank pays
\n     on fixed  deposits for longest period or
\n     3% whichever  is higher.  No part of the
\n     Reserve Fund  deposits  shall  be\tdrawn
\n     without the  previous  sanction  of  the
\n     Registrar, in  the case  of  Apex\tbank,
\n     Central Banks  and Large Sized Societies
\n     and  in   the  case   of  other  primary
\n     societies without\tthe permission of the
\n     Deputy Registrars.\t Such approval can be
\n     given when the amount is either required
\n     to meet  losses, or, when the society is
\n     to\t be  wound  up.\t These\teventualities
\n     will, however, be very rare.”\n<\/p><\/blockquote>\n
Obviously as  per the  above instructions  no  part  of\t the
\nReserve Fund  can be utilised as working capital nor can any
\npart of\t the Reserve  Fund deposits be withdrawn except with
\nthe permission\tof the\tRegistrar to  meet losses  or at the
\ntime of\t winding up  and not otherwise. In the circumstances
\nthe Revenue  contends that  the securities  relating to\t the
\nReserve Fund  can never\t be considered to be the circulating
\nor working  capital of\tthe bank  or its  stock-in-trade  to
\nqualify for  exemption under  Section 81  of the  Income Tax
\nAct.\n<\/p>\n
     Insofar as\t interest on  Provident\t Fund  deposits\t are
\nconcerned, admittedly  the same\t was included  in the Profit
\nand  Loss   Account  of\t  the  Bank.  It  appears  from\t the
\nobservations in\t paragraph 11  of the appellate order of the
\nTribunal that even the assessee’s counsel found it difficult
\nto justify the claim and said that it ought not to have been
\nincluded in the Profit and Loss Account of the Bank since it
\nbelonged to  the Provident  Fund  as  the  bank\t was  merely
\nholding those  deposits as  Trustees. The  tribunal did\t not
\nexamine this  contention, and  in our opinion rightly, since
\nthe same  was not  agitated before the authorities below and
\nno foundation  was laid for the same. The Tribunal held that
\nsince the  interest earned  therefrom was  included  in\t the
\nProfit and  Loss Account  of the  assessee and\twas shown as
\nearnings, it was liable to tax since it did not form part of
\nthe assessee’s\tstock-in-trade or  circulating\tcapital\t and
\ncould not,  therefore,\tbe  described  as  income  from\t the
\nbusiness of  banking to qualify for exemption. The Tribunal,
\ntherefore, held\t that this  income was\tliable to  tax.\t Mr.
\nSalve, the  learned Senior Counsel for the assessee with his
\nusual  fairness\t  stated  that\t in  the   absence  of\t the
\nfoundational facts,  the Tribunal  was justified in refusing
\nto examine  the contention  of the assessee’s counsel and he
\nwas not in a position to assail the Tribunal’s approach. He,
\ntherefore, did\tnot press the contention under this head. We
\nare, therefore, left with the first contention only, namely,
\nwhether interest  on government\t securities  earned  by\t the
\nassessee is  exempt from  tax under Section 81 of the Income
\nTax Act.\n<\/p>\n
     There can be no doubt that the object of section 81 was
\nto encourage  the co-operative\tmovement in  the country  by
\nproviding tax  exemption to  those co-operatives  engaged in
\nactivities set\tout in\tclauses (a) to (f) thereof. One such
\nactivity is  the carrying  on of  the business of banking or
\nproviding credit facilities to its members by a co-operative
\nsociety. The  section, therefore,  provides that  income-tax
\nshall not be payable by a co-operative society in respect of
\nthe profits  and gains\tof business  carried on by it, if it
\narises from  the business  of banking  or  providing  credit
\nactivities for\tits members. However, if such a co-operative
\nsociety also  engages itself  in activities  other than\t the
\nbusiness of  banking  or  providing  credit  facilities\t the
\nprofits derived\t from such business shall not be exempt from
\ntax if it exceeds rupees fifteen thousand. It is, therefore,
\nobvious that  the entire  income derived  by a\tco-operative
\nsociety from  the business  of banking\tor providing  credit
\nfacilities to  its members is exempt from income tax, but if
\nthat society  also engages  itself in any other activity and
\nearns profit therefrom, the income so derived becomes liable
\nto assessment  and payment  of income  tax if it exceeds the
\nceiling amount.\t The normal  banking activity  is to receive
\ndeposits and utilise such deposits by advancing loans, etc.,
\nto borrowers.  Since the  rate at  which interest is paid to
\ndepositors is  lower than  the rate  charged from borrowers,
\nthe difference\tin the rates generates income for the banks.
\nThe banks may have to maintain certain reserves to meet with
\nemergencies, e.g.  a spurt  in withdrawals by depositors for
\ndiverse reasons.  Investments which  permit  withdrawals  at
\nshort notice  would, therefore, be a part of the requirement
\nof  banking   business\tand   interest\taccruing   on\tsuch
\ninvestments would  be outside  the tax-net. That is why this
\nCourt in Bihar State co-operative bank Ltd. vs. Commissioner
\nof Income  tax (1960)  39 ITR  114 (SC),  while dealing with
\nincome derived\tby way of interest on short-term deposits by
\nthe bank,  held that  it  was  income  from  normal  banking
\nbusiness and  was, therefore,  exempt from  the liability to
\npay income-tax.\t This Court  held that since the society was
\nengaged in banking activity, its normal business was to deal
\nin money  and credit  and, therefore,  the money laid out in
\nthe form  of short-term\t deposit  did  not  cease  to  be  a
\ncirculating capital  and interest  earned thereon  cannot be
\nother than income generated from the business of banking and
\nwas,  therefore,   exempt  from\t  tax.\tThe  same  view\t was
\nreiterated in  Commissioner of\tIncome Tax  vs. Bombay State
\nCo-operative bank,  Ltd. vs.  Commissioner  of\tIncome\tTax,
\nKerala (1975) 101 ITR 87 (Kerala) and Commissioner of Income
\nTax, Orissa  vs. Orissa\t State Co-operative  Housing  Corpn.
\nLtd.<\/a> (1976)  104 ITR  157 (Orissa).  The  Privy\t Council  in
\nPunjab Co-operative Bank Ltd. vs. Commissioner of Income Tax
\n(1940) 8  ITR 635 also held that bankers have always to keep
\nsufficient cash\t or readily  realisable securities  to\tmeet
\nwith any  probable demand of depositors in the normal course
\nof banking  business and  such funds,  counsel argued, would
\nreally form  part of  the bank’s  circulating  capital\tand,
\ntherefore, interest earned thereon would be exempt from tax.\n<\/p>\n
     Placing  strong  reliance\ton  the\t aforesaid  line  of
\nreasoning, counsel  for the  assessee argued,  that interest
\nearned on  government securities  placed with the State Bank
\nor Reserve  Bank would be income earned by the bank from its
\ncirculating capital  and in any case in the normal course of
\nbanking business  and cannot therefore be brought to tax. It
\nwas said  that the  government securities  form part  of the
\nbank’s stock-in-trade and any income earned thereon would be
\noutside the  tax-net.  Counsel\tfor  the  revenue,  however,
\ndistinguished the decisions relied on by the assessee mainly
\non the\tground that the bank’s funds were utilised in short-
\nterm deposits  or in  government securities  which could  be
\neasily encased\tto meet\t with  a  probable  sudden  rush  of
\ndepositors and, therefore, the fund employed for the purpose
\nnever went  out of  circulation but was kept apart to meet a
\nprobable eventuality  and, therefore, a business obligation.
\nHe pointed  out that in the case of Reserve Fund Investments
\nno part of the deposits was permitted to be withdrawn unless
\nthe money  was required to meet losses or the society had to
\nbe wound  up and  that too  with the  Registrar’s permission
\nonly. Therefore, he submitted, these securities could not be
\nutilised as  a working capital nor did they form part of the
\ncirculating capital  or stock-in-trade of the bank and hence
\nthe interest earned thereon and shown as forming part of the
\nincome of the society cannot qualify for exemption.\n<\/p>\n
     Counsel for  the revenue  did not\tjoin  issue  on\t the
\nproposition that if circulating capital or stock-in-trade of
\na co-operative\tbank is\t invested  in  securities,  interest
\nearned thereon\twould be  income from  banking business\t and
\nwould, therefore,  qualify for\texemption. However,  can the
\ninvestment in  securities of  the Reserve Fund be said to be
\ninvestment of circulating capital or stock-in-trade, more so
\nwhen it\t is noticed that the co-operative bank does not have
\nan absolute  and  unfettered  right  to\t withdraw  the\tsame
\nwhenever it  liked? We\thave noticed  that the\tco-operative
\nbank  is   legally  obliged   to  place\t certain  government
\nsecurities  with  the  State  bank\/Reserve  bank  and  these
\nsecurities cannot be withdrawn by the said bank at its sweet
\nwill  and  can\tonly  be  withdrawn  in\t certain  situations
\nreferred to  earlier. That  is because the investment of the
\nReserve Fund  in securities is not to meet with the probable
\neventuality to pay off the depositors should they demand the
\nsame. It  is, therefore,  difficult to\tcomprehend how\tsuch
\ngovernment  securities\trelating  to  Reserve  Fund  can  be
\nconsidered the bank’s stock-in-trade or circulating capital.
\nit  is\t clearly  understood   in  banking   parlance\tthat
\ncirculating capital is that which is put into circulation or
\nturned over  to earn  profits. Government  securities coming
\nout of Reserve Fund which cannot be easily encased and which
\ncan  be\t utilised  only\t when  the  contingencies  mentioned
\ntherein arise cannot be considered to be circulating capital
\nor stock-in-trade.  It is  more or  less in  the nature of a
\nfixed asset  of the society, being out of circulation for an
\nindefinite period.  It is,  so to  say, at arm’s length from
\nthe normal banking business, to be utilised on the happening
\nof certain  events,  events  which  may\t virtually  bring  a
\ncessation of the business. If that be the purpose and object
\nof setting  a p\t art the  funds in  the form  of  government
\nsecurities and\tthe like,  it cannot be reasonably contended
\nthat the funds placed in cold storage continue to constitute
\nthe  bank’s   stock-in-trade  or  circulating  capital.\t The
\nlearned counsel\t for the  revenue was,\ttherefore, right  in
\ncontending that the case law cited at the Bar by the learned
\ncounsel for  the assessee  cannot come\tto the rescue of the
\nassessee.\n<\/p>\n
     We may  make a  brief reference  to two  more cases  to
\nwhich our attention was drawn by the learned counsel for the
\nrevenue. The  first case  is of\t Commissioner of Income Tax,
\nLucknow vs.  U.P. Cooperative Federation Ltd.<\/a> (1989) 176 ITR
\n435 (SC). In that case, the Apex Co-operative Society, which
\nwas expected  to regulate  the supply of sugar, coal, cloth,
\netc., to  its members,\thad received  two sums,\t namely\t (i)
\nRs.9,000\/- as  interest on  cash security deposit with a co-
\noperative  sugar   factory  for\t carrying  on  sugar  agency
\nbusiness; and  (ii) Rs.51,295\/- as interest on amounts which
\nit had\tadvanced to  its members since they were not able to
\narrange for  the entire\t finance needed\t to lift the stocks.
\nThis Court  held that  the first  amount did not qualify for
\nexemption because  it represented  only interest on security
\ndeposit and  could not\tbe mixed up with other sums received
\nin the\tcourse of business. Even the learned counsel for the
\nassessee did not press for exemption so far as that claim is
\nconcerned. The\tsecond claim  was allowed on the ground that
\nthe money  had to  be  provided\t to  run  the  business\t and
\ngenerate profit\t and the  funding  was,\t therefore,  in\t the
\nnature of  `investment’ within\tthe meaning  of the relevant
\nprovision, in  that, the money was ultimately to be utilised
\nby the\tmember society\tfor  the  purchase  of\tstocks.\t The
\ndistinction  is\t  obvious,  namely,   where  the   money  is
\nultimately to  be used for business purpose, either directly
\nor through  the\t member-bank,  the  interest  thereon  would
\nqualify for  exemption and not otherwise. The second case to
\nwhich our  attention was drawn is of Assam Co-operative Apex
\nMarketing Society,  Ltd. vs.  CIT (Addl.) (1993) 201 ITR 338
\n(SC). In  that case  the  appellant  was  appointed  as\t the
\nprocuring agent\t for paddy  by\tthe  Assam  Government.\t The
\nmembers of  the appellant  were primary\t marketing societies
\nand societies  at the  village\tlevel,\twith  membership  of
\nagriculturists, being  the members  of the  former. Thus  no
\nagriculturist was  the direct  member of  the appellant. So,
\nthe produce was received by the village level societies from
\nits agriculturist-members  and was  then passed\t on  to\t the
\nprimary\t societies  which  in  turn  made  it  over  to\t the
\nappellant.  A  Commission  was\tcharged\t for  the  procuring
\nactivity which\twas divided between the three, the appellant
\nand the\t village society each taking 19 paise in a rupee and
\nthe remaining  62 paise\t went to  the primary  society.\t The
\nquestion  was\twhether\t the   appellant’s  share   in\t the
\ncommissioner could  be brought\tto tax. The Tribunal as well
\nas the\tHigh Court  on reference  held that the assessee was
\nnot entitled  to  exemption  and  this\tCourt  affirmed\t the
\nfinding on the following line of reasoning.\n<\/p>\n
     “A reading\t of clause  (i) of section 81
\n     shows that the idea and intention behind
\n     the said  clause was  to encourage basic
\n     level  societies\tengaged\t in   cottage
\n     industries,    marketing\t agricultural
\n     produce of its members and those engaged
\n     in purchasing and supplying agricultural
\n     implements,  seeds,   etc.,   to\ttheir
\n     members   and    so   on.\t  The\twords
\n     `agricultural produce  of\tits  members’
\n     must be  understood consistent with this
\n     object and\t if so\tunderstood, the words
\n     mean the  agricultural produce  produced
\n     by\t the   members.\t it\tis   not   so
\n     understood, even  a co-operative society
\n     comprising\t   traders     dealing\t   in
\n     agricultural produce  would also  become
\n     entitled to  exemption which could never
\n     have been\tthe intention  of Parliament.
\n     The agricultural produce produced by the
\n     agriculturist can legitimately be called
\n     agricultural produce in his hands but in
\n     the  hands\t  of  traders,\tit  would  be
\n     appropriate  to   call  it\t agricultural
\n     commodities;  it\twould  not   be\t  his
\n     agricultural  produce.  Accordingly,  it
\n     must be held in this case that since the
\n     agricultural  produce  marketed  by  the
\n     assessee  was   not   the\t agricultural
\n     produce produced by its members, namely,
\n     the primary  co-operative\tsociety,  the
\n     assessee cannot claim the benefit of the
\n     said exemption.”<\/p><\/blockquote>\n
     The  learned   counsel  for   the\tassessee   tried  to
\ndistinguish both  these cases but in our opinion the purport
\nof the\tdecisions is  obvious. However,\t even if  we were to
\nagree with  learned counsel for the assessee that both these
\ncases had  no application to the f acts of these appeals, it
\nwould make no difference because we have on first principles
\ncome to\t the conclusion,  for reasons  set out hereinbefore,
\nthat the  interest on  government securities placed with the
\nState Bank  of India\/Reserve  bank of  India, cannot qualify
\nfor exemption  under Section  81 (now  Section 80  P) of the
\nIncome Tax Act.\n<\/p>\n
     Before we\tpart, we  must take  note  of  Shri  Salve’s
\ncontention that the proviso to section 81 would apply in the
\ncase of\t that co-operative society alone which is engaged in
\nan activity other than those mentioned in clauses (a) to (f)
\nwhich not  being so  as regards\t the appellants, the proviso
\nhas no\tapplication; and  so, no  part of its profit of gain
\ncan attract  income tax.  We do\t not think  this to  be\t the
\ncorrect reading\t of the\t proviso, notwithstanding the use of
\nthe word  “also”. According to us, what the proviso seeks to
\nconvey is  that even  if a  co-operative society  is engaged
\nonly in the business of banking, but part of its activity is
\nnot attributable  to engagement\t in  such  activity,  income
\nderived from that part of activity would become taxable. And
\nas held\t above, the  income derived  from the  investment in
\nGovernment  securities\t placed\t with\tthe  State  bank  of
\nIndia\/Reserve  bank  of\t India\tcannot\tbe  regarded  as  an
\nessential part\tof its banking activity inasmuch as the same
\ndoes   not    form   part    of\t  its\t stock-in-trade\t  or
\nworking\/circulating capital.  Therefore, we  see no force in
\nMr. Salve’s premises.\n<\/p>\n
     For the  above reasons we see no merit in these appeals
\nand dismiss the same with costs.<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India The Madhya Pradesh … vs Additional Commissioner Of … on 19 January, 1996 Equivalent citations: 1996 SCC (2) 541, JT 1996 (1) 487 Author: A A.M. Bench: Ahmadi A.M. (Cj) PETITIONER: THE MADHYA PRADESH CO-OPERATIVEBANK LIMITED, JABALPUR Vs. RESPONDENT: ADDITIONAL COMMISSIONER OF INCOMETAX MADHYA PRADESH, BHOPAL DATE OF JUDGMENT: 19\/01\/1996 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-218717","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nThe Madhya Pradesh ... vs Additional Commissioner Of ... on 19 January, 1996 - 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\/the-madhya-pradesh-vs-additional-commissioner-of-on-19-january-1996\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"The Madhya Pradesh ... vs Additional Commissioner Of ... on 19 January, 1996 - 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