Delhi District Court
M/S Tata Steel Ltd vs New Delhi Municipal Council on 21 November, 2023
IN THE COURT OF SH.GAURAV RAO, ADJ-03 / NEW
DELHI DISTRICT, PATIALA HOUSE COURTS, NEW
DELHI.
HTA No. 87/17
CNR No. DLND01-015177-2017
M/s Tata Steel Ltd.
(Earlier known as Tata Iron & Steel Co. Ltd.)
A company incorporated under the Companies Act,
having its office at 7th Floor, Jeevan Bharti building,
Connaught Place, New Delhi-110001
Through its Authorised Signatory
Mr. Sateesh Singh,
Chief Resident Executive (Delhi)
.....Appellant
Versus
New Delhi Municipal Council
Through its Chairman,
Palika Kendra,
Sansad Marg,
New Delhi-110 001.
....Respondent
Date of institution : 17.11.2017
Date on which reserved for judgment : 21.11.2023
Date of decision : 21.11.2023
Decision : Appeal allowed
JUDGMENT
1. The present appeal has been filed u/s 115 of the NDMC Act 1994 challenging the assessment order dated HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 1/19 21.06.2017 bearing no. A.O. No. 611/D.D(TAX)/2016 (hereinafter referred to as the impugned order).
Appeal/appellant's version
2. It is the appellant's case that it is a company incorporated under the Companies Act, having its office at the above address and Mr. Sateesh Singh, Chief Resident Executive (Delhi) is its Authorised Signatory, who is fully conversant with the facts of the present case and is competent & empowered to sign, institute and contest the present appeal for and on its behalf.
2.1 It is its case that it is the owner & assessee of Residential Flat No. A-3 & CPS S-14, 5th Floor, Girdhar Apartments, Firoj Shah Road, New Delhi (hereinafter referred to as the flat).
2.2 It is its case that it purchased the flat measuring 1604 Sq. feet alongwith common parking space measuring 60 sq. feet from its builder for a total consideration of Rs. 18,00,000/- vide agreement dated 29.07.1985.
2.3 It is its case that the construction of building consisting of more than 100 flats at plot no. 28, Firoj Shah Road, New Delhi was commenced by its builder in 1981 and it was completed in 1986, thereafter the possession of the flat was HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 2/19 handed over to it and since then the same is under its self occupation for residential purposes.
2.4 It is its case that the rateable value of the flat was fixed by the respondent for the years 1986-87 onwards on the basis of the consideration paid for the flat by it to the builder, although it should have been assessed on the basis of cost of land at the commencement of construction plus cost of construction basis, as laid down by Hon'ble Supreme Court.
2.5 It is its case that aggrieved by the said illegal & unjustified fixation of rateable value, it filed a House Tax Appeal bearing no. 349/1990 against the same before Ld. A.D.M., under Section 84 of the then prevailing Punjab Municipal Act, which appeal was allowed vide order dated 21.08.1990 and the assessment was set-aside/quashed.
2.6 It is its case that while dealing with the assessment of the flats in the very same building, namely Girdhar Apartments, in W.P.(C) no. 4204/1995 titled N.D.M.C. Vs. L&T Ltd decided on 14.03.1996, the Division Bench of Hon'ble High Court of Delhi directed the N.D.M.C. to assess the flats on the basis of cost of land at the commencement of construction plus cost of construction and it also directed N.D.M.C. to arrive at the rateable value after assessing the cost of construction to be determined by an independent valuer and the cost of the land to be determined by reference to the data made available by HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 3/19 evidence of comparable transactions involving similar types of land.
2.7 It is its case that similarly while dealing with the assessment of some other flats in the very same building namely Girdhar Apartments, the Hon'ble High Court of Delhi has again directed the N.D.M.C. to assess the flats on the basis of cost of land at the commencement of construction plus cost of construction, vide order dated 19.09.2002 in W.P.(C) 4118/2001 titled "Straw Products Ltd. vs. NDMC", order in W.P.(C) no. 2903/1995 titled "S.L. Sharma v/s N.D.M.C. and order dated 08/02/2002 in W.P.(C) 81/2003 titled w M / S J. K. Indusries Ltd. vs N.D.M.C.".
2.8 It is its case that during the hearing for re-fixation of rateable value, the Assessing Officer of the N.D.M.C. proposed to its counsel to take the value of the flat at Rs. 5 lakhs and to assess the same accordingly. It is its case that although this valuation was also illegal and excessive, yet it agreed to this valuation in order to decide the long pending controversy, however, even then the Assessing Officer failed to assess the the flat according to this valuation also.
2.9 It is its case that the respondent issued a notice dated 27.03.2002 under Section 72 of the NDMC Act to it thereby proposing to increase the alleged existing rateable value of Rs.
HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 4/19 1,59,700/- to Rs. 8,66,100/- which notice was duly objected to by it by filing objections dated 22.04.2002.
2.10 It is its case that the respondent has issued the impugned order thereby assessing the flat at the rateable value of Rs. 4,84,400/- w.e.f. 01-04-2001 on the basis of alleged comparable rent.
2.11 It is its case that no notice was received for attending the hearing of the assessment of flat and the respondent has passed the impugned order ex-parte without affording any opportunity of hearing to it and as such it is against the principles of natural justice.
2.12 It is its case that the impugned order is patently unlawful, illegal, uncalled for, unwarranted, without jurisdiction, malafide, arbitrary, against the facts of the case, without application of mind, highly excessive, unjust, unfair, unreasonable and liable to be set-aside/quashed.
2.13 It is its case that that the impugned order is contrary to law & facts of the case and the same is not legally sustainable.
2.14 It is its case that the impugned assessment order is based on surmises & conjectures and was passed without application of mind.
HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 5/19 2.15 It is its case that the respondent erred in not appreciating that when the assessment and rateable value for the year 1986-87 onwards has been set-aside by the court of Ld. A.D.M. vide order dtd. 21/08/1990 in H.T.A. no. 349/1990, then the same is non-est and there is no existing rateable value as alleged in the notice u/s 72 of N.D.M.C. Act and in the impugned order and this rateable value cannot be acted upon or revised for subsequent years unless & until it is re-fixed and further increase in the same by the respondent is illegal, unjustified & unsustainable.
2.16 It is its case that the respondent erred in assessing the flat on the basis of alleged comparable rent and failed to appreciate the settled law that the self occupied properties have to be assessed on the basis of cost of land at the commencement of construction plus cost of construction and as such the flat cannot be assessed on the basis of the alleged comparable rent.
2.17 It is its case that the respondent further erred in not appreciating the settled law laid down by Hon'ble Supreme Court of India in the cases of (1) Dewan Daulat Rai Kapoor v/s N.D.M.C. reported in AIR 1980 SC541; (2) Dr. Balbir Singh v/s M.C.D. reported in AIR 1986 SC 345; (3) India Automobiles Ltd. V/s Calcutta Municipal Corporation & Another reported in (2002) 3 SCC 388 and (4) State Trading Corpn. India Ltd v/s N.D.M.C. HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 6/19 2.18 It is its case that the respondent further erred in observing that completion certificate was granted in 1993 and as such the building is outside the purview of D.R.C. Act and that as admittedly the building was completed in 1986 as such it is within the purview of D.R.C. Act.
2.19 It is its case that Assessing Authority failed to appreciate that if the building was completed in 1993, then how the flat was assessed by the respondent from 1986-87 onwards.
2.20 It is its case that the respondent further erred in observing that as per judgement of Supreme Court in the case of S.T.C. v/s N.D.M.C., all properties outside the purview of D.R.C. Act, are to be assessed on average rent and not on standard rent and that in the said case law it was clearly laid down that where the building is self- occupied, the annual rent will have to be fixed as laid down by Supreme Court in the case of Dewan Daulat Rai Kapoor and in the case of India Automobiles Ltd. on the basis what the landlord might reasonably expect to get from a hypothetical tenant.
2.21 It is its case that assessing authority further erred in taking the average rent at the rate of Rs. 25.78 sq. feet without any reason, evidence, justification & basis of the same and HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 7/19 without disclosing how this rent has been calculated or arrived at and as such the same is perverse.
2.22 It is its case that considered from any angle the impugned order is not legally & factually sustainable and the same is liable to be set aside / quashed.
Reply/respondent's version
3. It was pleaded that the present appeal is not maintainable on account being barred by limitation in terms of Section 116 (a) of the NDMC Act, 1994 and the application of condonation of delay filed by the appellant is also not maintainable as the grounds taken in the said application are not bona-fide, frivolous and do not establish sufficient cause for not preferring the appeal within the prescribed statutory period.
3.1 It was pleaded that though the appellant has submitted that its correspondence address was changed as a result of which it was unable to receive the impugned order, however, the appellant was under a duty to inform it about the change in its correspondence address and its omission with respect to such intimation is on account of its negligence solely and the appellant did not provide the new address to it because of malafide & fraudulent intentions of avoiding.
HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 8/19 3.2 It was pleaded that the Hon'ble Supreme Court in a plethora of judgments has upheld the validity of the common law principle which is comprised in the latin maxim 'commodum ex injuria sua nemohabere debet', which means convenience cannot accrue to a party from his own wrongdoings.
3.3 It was pleaded that the cause of delay in filing the present appeal is attributable to the appellant itself and as such, such delay being not bona-fide in the eyes of law cannot be allowed to be condoned.
3.4 It was pleaded that the present appeal is based on false, frivolous, fabricated, misconceived and concocted grounds and is hence not maintainable.
3.5 It was pleaded that till date the property tax calculated as per assessment order dated 21.06.2017 has not been deposited by the appellant in terms of Section 116(b) of the NDMC Act 1994 before preferring the present appeal.
3.6 It was pleaded that property tax amounting to Rs. 17,17,142/- is outstanding & payable for period up till 31.03.2018 and the appeal is liable to be dismissed on this ground solely, as no appeal is allowed to be heard or determined under Section 115 of NDMC Act, 1994 unless the amount in dispute in the appeal has been deposited by the appellant, as provided for by Section 116(b) of NDMC Act, 1994.
HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 9/19 3.7 On merits it was pleaded that the common parking space is not specifically mentioned in the agreement and as per Building Bye-laws, area of a common parking space is 23 sq. ft. It was pleaded that there is no record/proof filed providing that the flat along with common parking space has never been let out.
3.8 It was pleaded that the price paid for the flat to the builder by the appellant comprised of the cost of the land along with the cost of construction and the building is not liable to be assessed on cost basis as per the reasons stated in the impugned order.
3.9 It was pleaded that the property in H.T.A. No. 349/1990 is not related to the flat and correct state of facts were not placed before the ADM and building was given completion certificate in year 1993 which is after 01.12.1988 and as such it cannot be assessed on cost basis, it has to be assessed on expected hypothetical rent as envisaged under Section 63(1) of the NDMC Act, 1994.
3.10 It was pleaded that the assessment has been made as per Section 63(1) of the NDMC Act, 1994, which also has been upheld by the Hon'ble Supreme Court on 03.02.2016 in State Trading Corpn. India Ltd. vs. New Delhi Municipal Council AIR 2016 SC 1269.
HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 10/19 3.11 It was pleaded that the objections raised by the appellant were duly considered by it and subsequently rejected while passing the impugned order.
3.12 It was pleaded that a mere perusal of the impugned order makes it evidently clear that the case was fixed for hearing on 08.06.2017 but no one from the appellant's side appeared for the hearing and consequently, the impugned order was passed ex- parte and it was denied that impugned order is illegal or unlawful.
3.13 It was pleaded that as per the latest judgment of the Hon'ble Supreme Court in STC vs. NDMC, even the self occupied properties are to be assessed on expected hypothetical/ comparable rent.
Findings
4. I have heard the Ld. Counsels for the parties, considered the record carefully and given due consideration to the rival contentions raised at bar.
4.1 As far as the contention regarding non payment of the base year property tax is concerned and the arguments of the Ld. Counsel for the defendant that in the absence of payment/deposit the appeal is not maintainable as per Section 116 (b) of the NDMC Act 1994 is concerned, suffice would be to HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 11/19 say that Ld. Counsel for the appellant has placed on record receipt dated 20.05.2019 bearing no. 164820 vide which the property tax for the base year was duly paid. Hence the arguments of Ld. Counsel for the respondent as regards non maintainability of the appeal on the said ground stands rejected being meritless.
4.2 As regards the arguments regarding delay in preferring the present appeal is concerned, the appellant's application seeking condonation of delay is already on record. It is the appellant's case that it did not receive the impugned order as it had shifted its address around one year back and it was only when the appellant went to the respondent's office for attending hearing in respect of some other property that it came to know about the impugned order. Furthermore it is the appellant's case that the impugned order was received only on 17.10.2017 and thereafter the present appeal has been filed in time. The delay thus stands duly explained, more so when the respondent could not bring anything on record to contradict the appellant's case. Moreover the law is well settled that if the appeal can otherwise succeed on merits, same should not be dismissed solely on the ground of delay or any such technicalities. Therefore the delay in filing the appeal stands condoned.
4.3 Though several grounds were raised in the appeal to challenge the impugned order, however, during the course of arguments, Ld. Counsel for the appellant while relying upon HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 12/19 Order XLI Rule 2 of Code of Civil Procedure 1908 and Ved Marwah & Ors. Vs. New Delhi Municipal Council & Ors. 248 (2008) DLT 781 confined the grounds of appeal, the arguments only on the aspect of limitation. It was argued by Ld. Counsel for the appellant that similar to the facts of the above case, there is inordinate delay in finalizing assessment list viz-a-viz the notice. Ld. Counsel argued that the notice, on the basis of which the impugned order is based was issued on 27.03.2002 whereas the impugned order was passed only on 21.06.2017 i.e. after a gap of almost 15 years for the assessment year 01.04.2001 onwards. It was argued by Ld. Counsel for the appellant that in view of law laid down in Ved Marwah (supra) the impugned order is liable to be set aside.
4.4 It is an admitted position that the impugned assessment order dated 21.06.2017 has been passed in respect of notice dated 27.03.2002 issued under Section 72 of the Act. Although, the Act does not specify any period of limitation for finalizing the assessment but this does not imply that respondent is at liberty to sleep over the matter for a period of almost 15 years. It is expected that after issuance of notice, respondent should finalize the assessment within a reasonable period. There is absolutely no justification whatsoever for this inordinate delay between the issuance of notice and the passing of the impugned assessment order.
HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 13/19 4.5 The Hon'ble High Court of Delhi in Ved Marwah (supra) has observed that the proceedings initiated pursuant to Section 72 of the NDMC Act should be concluded in a reasonable period of not more than three years. In the said matter, notices for revising the assessment list were issued over a decade prior to passing of the final orders by the NDMC. The Hon'ble High Court observed that the inordinate delay was unreasonable and quashed the assessment orders. It was observed as under:-
"Analysis and Conclusions
13. The notices for revising the assessment list in all these cases were issued over a decade prior to the passing of final orders. In one case, it was 16 years; in others, it was 14 years. In two cases, the same property was subject to multiple notices for later periods, without finalization of rateable value, for the previous year. Clearly, the finalization of these cases after inordinate delay of 14 to 16 years was plainly unreasonable. Where such open ended power-like in the present case, in Section 72 was conferred upon a statutory authority, i.e. a sales tax authority official in Punjab, the Supreme Court had outlined the correct approach in State of Punjab & Ors. v. Bhatinda District Co-op Milk P. Union Ltd 2007 (11) SCC 363 with respect to the limitations to exercise of such power. It was held that:
"5. In respect of the assessment for the year ending 31.3.2000, the assessment proceedings were completed relying on the return filed by the appellant on 20.3.2001. Indisputably, in terms of Section 11 of the 1948 Act, a period of three years has been prescribed as a period of limitation as contained under sub- section (3) of Section 11 for completing assessment from the last date for filing of return. Sub-section (6) of Section 11 reads as under :
"_If upon information which has come into his possession, the Assessing Authority is satisfied that any dealer has been liable to pay tax under this Act in respect of any period but has failed to apply for registration, the Assessing Authority shall, within five years after the expiry of such period, after giving the dealer a reasonable opportunity of being heard, proceed to assess to the best of his judgment, the amount of tax, if any, due from the dealer in respect of such period and all subsequent periods and in case where such dealer has willfully failed to apply for HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 14/19 registration, the Assessing Authority may direct that the dealer shall pay by way of penalty, in addition to the amount so assessed, a sum not exceeding one and a half times that amount. Section 21 of the said Act provides for revision. Section 21 of the Act with which we are concerned herein reads as under :
"21. Revision-(1) The Commissioner may of his own motion call for the record of any proceedings which are pending before, or have been disposed of by any authority subordinate to him, for the purpose of satisfying himself as to the legality or propriety of such proceedings or order made therein and may pass such order in relation thereto as he may think fit. (2) The State Government may by notification confer on any Officer the powers of the Commissioner under sub-section (1) to be exercised subject to such conditions and in respect of such areas as may be specified in the notification. (3) A Tribunal, on application made to it against an order of the Commissioner under sub-section (1) within ninety days from the date of communication of the order, may call for and examine the record of any such case and pass such orders thereon as it thinks just and proper.
(4) No order shall be passed under this section which adversely affects any person unless such person has been given a reasonable opportunity of being heard".
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15. Sub-section (1) of Section 11 empowers the Commissioner to extend the period of three years for passing the order of assessment where for reasons are required to be recorded in writing subject, however, to the maximum period of five years. Ordinarily, therefore, a period of three years has been prescribed for completion of the assessment in terms of the provisions of the Act. We may also notice that in cases where an assessment order is to be reviewed, the same should be done within a period of one year.
16. A bare reading of Section 21 of the Act would reveal that although no period of limitation has been prescribed therefor, the same would not mean that the suo-moto power can be exercised at any time.
17. It is trite that if no period of limitation has been prescribed, statutory authority must exercise its jurisdiction within a reasonable period. What, however, shall be the reasonable period would depend upon the nature of the statute, rights and liabilities thereunder and other relevant factors.
18. Revisional jurisdiction, in our opinion, should ordinarily be exercised within a period of three years having regard to the purport in terms of the said Act. In any event, the same should HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 15/19 not exceed the period of five years. The view of the High Court, thus, cannot be said to be unreasonable.Reasonable period, keeping in view the discussions made hereinbefore, must be found out from the statutory scheme. As indicated hereinbefore, maximum period of limitation provided for in sub-section (6) of Section 11 of the Act is five years.
14. Bhatinda (supra) was noticed and followed subsequently in Ram Prakash (supra). In a more recent decision Ram Karan (D) by LRs v. State of Rajasthan 2014 (8) SCC 282, it was held that:
"38. State of Punjab & Ors v Bhatinda District Co- op Milk P. Union Ltd (supra) this Court held that if no period of limitation has been prescribed, statutory authority must exercise its jurisdiction within a reasonable period. However, what shall be the reasonable period would depend upon the nature of the statute, rights and liabilities thereunder and other relevant factors. In the present case, neither any objection was raised nor was any application filed by vendors for restoration of land in their favour. The suit was filed by the Tehsildar, Viratnagar after more than 31 years. No ground is shown to file such petition after long delay nor it was mentioned as to whether the vendors i.e. original landholders made any application for restoration of land in their favour.
39. In view of the matter, we hold that the suit being filed beyond the reasonable period was fit to be dismissed. The Additional Collector rightly dismissed the suit being barred by limitation."
15. In the present case, the finalization of assessment list or its revision, after over 12 years in all the cases, cannot be countenanced. It is clearly unreasonable and arbitrary and calls for interference.
17. In view of the above reasoning, it is held the impugned final orders of assessment and the demands issued are clearly unreasonable and void. They are hereby quashed. Consequently, it is held that the NDMC is at liberty to rework the assessments in respect of the properties that are the subject matter of these proceedings, by issuing fresh notices for the periods commencing from 3 years prior to the date on which the final notices were issued, and finalize the assessments within reasonable time. In the event of grievance on the part of the assessee to such fresh assessment orders, it is open to them to approach the appellate tribunal; provided they deposit the amount towards the tax liability for the base year."
4.6 While quashing the order, it granted liberty to NDMC to rework the assessment by issuing fresh notice for the HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 16/19 period commencing from three years prior to the date on which final notices were issued. NDMC was further directed to finalize the assessment within a reasonable time.
4.7 Though Ld. Counsel for the respondent contended that the grounds now argued by the appellant do not form part of the memorandum of appeal, were never raised in the appeal and therefore same cannot be entertained by the court at this stage, however, I find no merits in the same. It is no longer res integra that purely legal issues which go to the root of the matter can be raised, entertained at any stage more so when the additional grounds so raised do not require going into fresh facts and can be decided on the basis of facts and materials already available on record. Furthermore the court's power to decide the appeal cannot be restricted/confined to the grounds of objection set forth in the memorandum of appeal. The only requirement of law is that the opposite side should be granted sufficient opportunity to contest the case on the additional/fresh grounds so raised. The said opportunity was duly granted to the respondent. Even otherwise the respondent is well aware of the law laid down in Ved Marwah's case (supra). Reliance may also be placed upon the law laid down in Tarini Kamal Pandit and ors Vs. Prafulla Kumar Chaterjee (dead) by LRs MANU/SC/0587/1979, The National Textile Corporation Ltd. Vs. Naresh Kumar Badri Kumar Jagad and ors MANU/SC/1028/2011, Rakesh Sharma Vs. Lakshmi Sharma MANU/DE/1246/2002, National Thermal Power Co. Ltd. 229 ITR 383, Jute Corporation of India 187 HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 17/19 ITR 688 and CIT vs. Pruthvi Brokers and Shareholders Pvt. Ltd. (2012) 349 ITR 336 (Bom.) 4.8 Though Ld. Counsel for the respondent also argued that the judgment in Ved Marwah's case (supra) was passed in peculiar set of circumstances and the same has no application in the present case and that the directions issued in Ved Marwah's case (supra) cannot be uniformly applied in all the cases for setting aside the assessment order merely because of the delay between the issuance of notice and the finalization of the assessment, however, I find no merits in his arguments. The reason for setting aside of assessment order in Ved Marwah's case (supra) was the inordinate delay in passing the assessment order viz-a-viz the notice issued u/s 72 of the Act as is the case in the present matter. Furthermore the above order of the Hon'ble High Court of Delhi was assailed vide Special Leave Petition No.25403/2018 titled as New Delhi Municipal Council Vs. Pearey Lal & Sons (P) Ltd and anr but the same was dismissed by the Hon'ble Supreme Court of India vide order dated 01.08.2023. Resultantly, the findings in Ved Marwah's case (supra) have attained finality.
4.9 In the case at hand there is an inordinate delay on the part of NDMC in finalizing the assessment. The initial notice under Section 72 of the NDMC Act was issued on 27.03.2002 while the final assessment order was passed on 21.06.2017 There was a time gap of almost 15 years between the issuance of notice HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 18/19 and the finalization of the assessment. Relying on the observations made in Ved Marwah's case (supra), the delay is certainly inordinate and arbitrary. This, in itself, is a sufficient ground for setting aside the impugned order. The impugned is bad in law. Accordingly, the appeal is allowed and the impugned order is set aside. In terms of the observations made in Ved Marwah's case (supra), respondent is at liberty to rework the assessment by issuing fresh notice for the period commencing from three years prior to the date on which final notices were issued and finalize the assessment within a reasonable time.
4.10 File be consigned to the Record Room after due compliance.
Announced in the open Court on 21st November 2023 (Gaurav Rao) ADJ-03/New Delhi District, Patiala House Courts, Delhi HTA No. 87/17 M/s Tata Steel Ltd. Vs. New Delhi Municipal Council 19/19