Delhi District Court
Dr. Chander Prakash & Anr. vs . Shri K.C. Meena & Ors. on 21 May, 2020
Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18
IN THE COURT OF SHRI TARUN YOGESH
ADDL. DISTRICT JUDGE03: SOUTH WEST DISTRICT:
DWARKA COURTS: NEW DELHI
Regular Civil Appeal No. 71/2018
CNR No. DLSW010157042018
In the matter of:
1) Dr. Chander Prakash
Flat No. 49, Ground Floor,
Pocket1, Sector6, Dwarka,
New Delhi110075
2) Dr. Rajneesh Mohan Siwan
Flat No. 46, Third Floor,
Pocket1, Sector5, Dwarka,
New Delhi110075 .....Appellants
Versus
1) Shri K.C. Meena
Dy. Accessor & Collector
MCD, SDMC, SouthZone,
R.K.Puram, Sector9,
New Delhi110022
2) Shri M.S.A. Khan,
Assessor & Collector,
Municipal Corporation of Delhi
SDMC Civic Centre,
Minto Road
New Delhi110002.
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Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18
3) The Assistant Assessor & Collector,
MCD, SDMC, SouthZone,
R.K. Puram, Sector9,
New Delhi110002.
4) The Commissioner,
Municipal Corporation of Delhi,
4th Floor, SDMC, Civic Centre,
Minto Road,
New Delhi110002. ....Respondents
Date of Institution of Appeal : 28.08.2018
Date on which judgment was pronounced : 21.05.2020
: JUDGMENT :
1. Present appeal under Section 96 CPC assailing judgment and decree dated 31.07.2018 passed by Ld. JSCCcumASCJcumGuardian Judge, SouthWest District, Dwarka Courts, Delhi has been taken up for judgment in view of order No. 7306 to 7363/DJ/NK/DWK/ 2020 dated 04.05.2020 of Ld. District & Sessions Judge, SouthWest District, Dwarka Courts, New Delhi pursuant to directions passed by Hon'ble High Court of Delhi communicated through the Ld. Registrar General vide Letter No. R123/RG/DHC/2020 Dated 30.04.2020.
2. Brief facts set out in the plaint are narrated below:
2.1 Plaintiffs Dr. Chandra Prakash and Dr. Rajneesh Mohan Siwan have filed suit impugning Assessment Order dated 09.06.2003 raised by MCD by applying "purchase price" formula and disputing its legality on the ground that impugned order was passed without Page No. 2 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.RCA No. 71/18
mandatory notice to plaintiffs (transferee) in contravention of principles of natural justice.
2.2 It is averred that Flat No. D7/7018, Vasant Kunj, New Delhi was purchased by plaintiffs vide registered sale deed dated 31.07.2002 and house tax of Rs.3,136/ for the year 20022003 and 20032004 was paid by previous owner Shri Anil Kumar Marwah vide receipt dated 29.07.2002 and 01.08.2003 respectively.
2.3 Plaintiffs being owner continued to pay house tax of the flat under Self Assessment Scheme till June 2010 when the property was sold to Shri Sahil Bhandari and his wife Mrs. Aysha Malhotra vide registered sale deed dated 22.06.2010 and present owners upon contacting MCD officials for mutation of property in their names in MCD Records were informed about arrears of Rs.22,745/ plus interest on account of house tax of the flat up to the year 20032004 which was required to be paid before mutation of property in their name. 2.4 Plaintiffs being bound to pay house tax till the date of conveyance of property were contacted by present owners to settle the matter with MCD authorities to facilitate/initiate mutation proceedings in their favour and plaintiff No.1 Shri Chandra Prakash for himself and as attorney for his son Dr. Rajnessh Mohan Siwan entered into protracted correspondence with MCD authorities disputing arrears of house tax against the flat up to 20032004. Copy of Assessment Order dated 09.09.2003 passed by Asst. Assessor & Collector, South Zone MCD for additional house tax due up to 20032004 was received by plaintiff No.1 who thereafter sent a detailed application dated 17.11.2011 addressed to Page No. 3 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18Dy. Assessor & Collector (Defendant No.1) with copy of Assessor & Collector, MCD (Defendant No.2) contending inter alia that impugned Assessment Order was in contravention of principle of parity evolved by Hon'ble Supreme Court of India Balbir Singh & Ors. Vs. MCD & Ors AIR 1985 SC 339 which was reiterated by Hon'ble Apex Court in Lt. Col. P.R. Choudhary (Retd.) Vs. MCD (2000) 4 SCC 577 and followed by Hon'ble High Court of Delhi in MCD Vs. Dhunishaw Framroz Daruwala 100 (2002) DLT 679.
2.5 Legality of Assessment Order was also challenged on the ground that in it was passed without mandatory notice to plaintiffs whose names were recorded as transferee in MCD records which is evident from Composition Fee Receipt dated 26.06.2003 and defendants were requested to communicate early decision vide aforesaid application followed by another application dated 24.11.2011 under RTI Act 2005. 2.6 Interim Reply dated 14.12.2011 informing that matter had been referred to Law department of Property Tax Department followed by Demand Notice No. Tax/RKP/SZ/9684 dated 24.01.2012 issued by Asst. Assessor & Collector reiterating demand of Rs.22,745/ plus penalty and interest on the basis of impugned Assessment Order and threatening attachment of property in case of nonpayment of the amount within 30 days was received by plaintiffs and legal notice dated 31.01.2012 was served upon defendants No.1 to 3 for their arbitrary, wrongful and illegal action with copy to Commissioner, MCD (Defendant No. 4) for information and necessary action. Defendants, however, instead of withdrawing demand notice sent Reply No. TAX/SZ/2012/1125 dated 06.02.2012 Page No. 4 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18informing that matter was subjudice and the case would be decided after the verdict of the Hon'ble Supreme Court of India. 2.7 Since plaintiffs' requests for passing reasoned order upon application dated 17.11.2011 challenging legality of Assessment Order dated 09.09.2003 and withdrawing Demand Notice dated 24.01.2012 were not acceded by defendants so plaintiffs left with no option paid Rs.22,745/ through cheque No. 212302 dated 21.02.2012 under protest and thereafter filed suit for permanent and mandatory injunction for restraining defendants/MCD (i) from recovering illegal demand of house tax; (ii) from enforcing their demand notice dated 24.01.2012; (iii) for directing MCD authorities to collect house tax in accordance with law; (iv) for refunding the excess amount paid to MCD and (v) to mutate the ownership of flat in the name of Shri Sahil Bhandari and Smt. Ayesha Malhotra.
3. Defendants were served and filed application under Order VII Rule 11 read with Section 151 CPC and Section 169 of DMC Act disputing jurisdiction of Civil Court and requesting for rejection of plaint on the ground that Assessment Order could be challenged before the Municipal Tax Tribunal constituted under the DMC Act and jurisdiction of civil court is barred by Section 169 of DMC Act. Submissions were heard and defendant's application was disposed off vide order dated 04.04.2012 followed by order dated 22.09.2012 modifying the earlier order to the extent that no appeal is filed or pending against impugned Assessment Order.
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RCA No. 71/184. Matter was listed for further proceedings but written statement was not filed despite direction and defendants' right to file written statement was closed on 21.05.2013.
5. Plaintiff No.1 Dr. Chandra Prakash has deposed as PW1 by tendering his affidavit Ex.PW1 in evidence whereas PW2 Shri Ramesh Kumar, Head Clerk, MCD, R.K. Puram, South Zone, New Delhi being summoned witness has filed attested copies of following documents:
i. House Tax paid receipt dated 29.07.2002 of Rs.3,136/ for the year 20022003 Ex.PW2/1;
ii. House Tax paid receipt dated 01.08.2003 of Rs.3,136/ for the year 20032004 Ex.PW2/2;
iii. Letter No. Tax/RKP/RTI/2011/303 dated 03.11.2011 Ex.PW2/3; iv. Letter No. Tax/SZ/2011/176 dated 09.08.2011 Ex.PW2/4; v. Application dated 17th November 2011 Ex.PW2/5; vi. Letter No. Tax/SZ/2011/260 dated 05.10.2011 Ex.PW2/6; vii. Copy of Assessment Order dated 09.09.2003 Ex.PW2/7; viii. Receipt of composition fee dated 26.06.2003 Ex.PW2/8; ix. Legal notice dated 31.01.2012 Ex.PW2/9; x. Reply of legal notice vide letter No. Tax/SZ/2012/1125 dated
06.02.2011 Ex.PW2/10;
xi. House Tax receipt dated 24.06.2002 of Rs.3,136/ Ex.PW2/11 pertaining to property / Flat No. 7/7010, Vasant Kunj; xii. House Tax receipt dated 01.08.2003 of Rs.3,136/ Ex.PW2/12 pertaining to property / Flat No. 7/7009, Vasant Kunj;
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RCA No. 71/18xiii. Attested copy of demand notice under Section 154(i) of the DMC Act 1957 dated 24.01.2012 issued to Mr. Anil Kumar Marwah & Ors. Ex.PW2/13.
6. No other witness was examined on record and plaintiffs' evidence was closed on 02.05.2017.
7. Advocate Shri S.D. Sharma for plaintiff and Advocate Shri Sameer Chugh for defendant SDMC addressed their submissions and written submissions followed by supplementary written submissions on behalf of plaintiffs were taken on judicial record.
8. Ld. Trial Court after considering their submissions and case laws cited by counsels has noted that Assessment Order dated 09.09.2003 referred as Ex.PW2/2 was assessed by MCD department in view of change of ownership of the flat after assessing its actual value and Demand Notice under Section 154 of DMC Act, 1957 Ex.PW2/13 was issued by the Department as per procedure of assessment of tax on various kind of properties as mentioned in Chapter VIII of the Act.
9. Ld. Trial Court has also observed that plaintiff during evidence has relied upon documents (correspondence) with the department and no document was placed on record which would show that Assessment Order and Demand Notice issued by MCD are against the actual facts or figure.
10. Case laws cited by plaintiffs in support of their contention disputing Assessment Order and Demand Notice in contravention of principle of parity laid down in MCD Vs. Dhunishaw Framroz Daruwala 100 (2002) DLT 679; Balbir Singh & Ors. Vs. MCD & Ors AIR 1985 SC Page No. 7 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18339 and Lt. Col. P.R. Choudhary (Retd.) Vs. MCD (2000) 4 SCC 577 were considered and following questions have been settled by Ld. Trial Court for adjudicating the dispute:
(i) Whether the assessment by MCD in accordance with 1994 byelaws applying the purchase price method in Assessment Order dated 09.09.2003 is legal?
(ii) Whether plaintiff are entitled to refund from MCD for any excess tax charged and paid?
11. Judgment of Hon'ble Supreme Court of India titled MCD & Anr. Vs. M/s Mehra Sons Jewellers Pvt. Ltd. Civil Appeal No. 6718 of 2004 wherein Hon'ble Apex Court has held that assessment made after the year 1994 should be governed by the Delhi Municipal Corporation (Determination of Rateable Value) Byelaws, 1994 and principles laid down in Balbir Singh's case and P.R. Choudhary's case would have no relevance has been discussed in para 16 to 18 of the judgment and plaintiffs' suit was dismissed by holding that Assessment Order dated 09.09.2003 in accordance with 1994 Bye Laws is legal and proper and plaintiffs are therefore not entitled for refund of tax deposited with MCD.
12. Aggrieved by the judgment and decree, plaintiffs (appellants) have filed appeal assailing judgment inter alia on grounds (A) to (H) raised in memorandum of appeal for setting aside impugned judgment and praying for reliefs as prayed in the suit.
13. Trial Court record has been summoned from concerned court and reply opposing appeal as malafide, vexatious and without jurisdiction Page No. 8 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18has been filed by respondent for seeking dismissal of appeal with heavy compensatory cost.
14. Respondents' contention disputing jurisdiction of Civil Court under Section 169 of DMC Act is bereft of merit as right to institute civil suit in the matter of levy and assessment of tax has been recognized in Ganga Ram Hospital Trust Vs. Municipal Corporation of Delhi 2001 SCC OnLine DEL 622.
15. Plaintiffs' contention that rateable value of property has to be assessed on the basis of principle of parity laid down by Hon'ble Supreme Court of India in Dr. Balbir Singh's case which was reiterated by Hon'ble Apex Court in Lt. Col. P.R. Choudhary (supra) and followed by Hon'ble Delhi High Court in MCD Vs. Dhunishaw Framroz Daruwala (supra) and submissions that judgment of Hon'ble Supreme Court in MCD & Anr. Vs. Mehra Sons Jewellers Pvt. Ltd. (Supra) is violative of the law laid down by the Constitution Bench of Hon'ble Supreme Court in Central Board of Dawoodi Bohra Community & Anr. Vs. State of Maharashtra & Anr. MANU/SC/1069/2004 and Three Judges Bench in New India Assurance Co. Ltd. Vs. Hilli Multipurpose Cold Storage Pvt. Ltd. MANU/SC/1397/2015: AIR 2016 SC 86 as law laid down by the Hon'ble Apex Court in a decision delivered by a Bench of larger strength is binding on any subsequent Bench of lesser or coequal strength has been controverted by respondents on the ground that Assessment Order dated 09.09.2003 was passed in accordance with relevant Bye Laws enacted in the year 1994 and earlier judgments delivered in Dr. Balbir Singh's case; Lt. Col. P.R. Choudhary's case and Dhunishaw Page No. 9 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18Framroz Daruwala's case have been overruled by Hon'ble Supreme Court of India in MCD & Anr. Vs. Mehra Sons Jewellers Pvt. Ltd. (Supra) by following its judgment in Asst. Gen. Manager, Central Bank of India & Ors. Vs. Commissioner, Municipal Corporation for the City of Ahemdabad & Ors. (1995) 4 SCC 696 wherein it was held that where any Municipal Act itself provides the mode of determination of the annual letting value then the annual letting value has to be determined according to the terms of Municipal Act.
16. The gist of present appeal is therefore limited to the legality and validity of Assessment Order dated 09.09.2003.
17. The first part of discussion will deal with plaintiffs' contention disputing Assessment Order raised by MCD by applying purchase price formula in contravention of principle of parity laid down in Balbir Singh's case and submissions insisting that judgment of Hon'ble Surpeme Court of India in MCD & Anr. Vs. Mehra Sons Jewellers Pvt. Ltd. (supra) is per incurium as law laid down by a larger Bench is binding on any subsequent Bench of lower or coequal strength.
18. It would be apt to note at the outset that judgment of Hon'ble High Court of Delhi passed in Writ Petition titled MCD Vs. Dhunishaw Framroz Daruwala (supra) has been overruled whereas judgments of Hon'ble Supreme Court of India titled Dr. Balbir Singh Vs. MCD and Lt. Col. P.R. Choudhary Vs. MCD (supra) have been distinguished on facts by Hon'ble Supreme Court of India in MCD Vs. Mehra Sons Jewellers Pvt. Ltd. (supra) by observing that earlier judgments were dealing with a situation wherein premises were covered by the Delhi Rent Page No. 10 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18Control Act and principle of parity evolved in Balbir Singh's case would apply only because annual rent in those cases had to be fixed subject to maximum rent that could possibly be fixed in a situation were standard rent under the Delhi Rent Control Act would be the ceiling above which the amount fixed as per parameters under the Delhi Rent Control Act could not be exceeded.
19. Hon'ble Supreme Court of India has taken note of following three different groups of cases which were dealt by the Hon'ble Apex Court :
i. First group of cases wherein Municipal Acts of the States define annual value to be the hypothetical rent that a landlord could reasonably be expected to receive if his property was let out to a hypothetical tenant and such hypothetical rent could not exceed the standard rent fixed on fixable under the Rent Control Statute;
ii. Second group of cases where language of the particular Municipal Corporation Act contains a non obstante clause and standard rent under the particular Rent Statute of that particular state could not be taken to be the maximum rent which could possibly be fetched by a hypothetical landlord from a hypothetical tenant and iii. Third category of cases wherein the Municipal Act read with the Bye Laws itself provide the mode of determination of the annual value and it is unnecessary to go to the provisions of the Rent Act of the State.
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20. Para 12 and 13 of MCD & Anr. Vs. Mehra Sons Jewellers Pvt. Ltd. being relevant are extracted herein below for reference:
"12. The present appeals before us refer to assessment year post 1994 and are said to be in a factual scenario where after the amendment of 1988 to the Delhi Rent Control Act, the Delhi Rent Control Act does not apply either for the reason that the rent fixed is more than Rs. 3,500/ per month or that the property has been newly constructed and is exempt from its provisions for a period of 10 years. In situations such as the above, an instructive judgment of this Court is contained in Govt. Servant Coop. House Building Society Ltd. Vs. Union of India. In this judgment, this Court noticed the 1988 amendment to the Delhi Rent Control Act and various judgment referred to hereinabove and concluded as under: (SCC p.386, para 8) "8. Therefore, the annual rent actually received by the landlord, in the absence of any special circumstances, would be a good guide to decide the rent which the landlord might reasonably expect to receive from a hypothetical tenant. Since the premises in the present case are not controlled by any rent control legislation, the annual rent received by the landlord is what Page No. 12 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.RCA No. 71/18
a willing lessee, uninfluenced by other circumstances, would pay to a willing lessor.
Hence, actual annual rent, in these
circumstances, can be taken as the annual
rateable value of the property for the
assessment of property tax. The municipal
corporation is, therefore, entitled to revise the rateable value of the properties which have been freed from rent control on the basis of annual rent actually received unless the owner satisfies the municipal corporation that there are other considerations which have affected the quantum of rent."
13. Having regard to the aforesaid statement of law, we are of the opinion that the Division Bench of the Delhi High Court in Daruwala case, is not correctly decided for the simple reason that the appeal falls within the exception created by the Central Bank judgment, namely, cases where the Municipal Corporation of a particular State itself lays down as to how annual value is to be determined.
We, therefore, hold that for assessments made after the 1994 Byelaws came into existence, such assessments shall be governed by these Byelaws alone and the principles laid down in Balbir Singh Page No. 13 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18case and P.R. Chaudhary case, would have no relevance in such a situation. We answer Question 1 accordingly."
21. Since subject property in the present case bearing Flat No. D7/7018, Vasant Kunj, New Delhi is not covered under the Delhi Rent Control Act so principle of parity evolved in Balbir Singh's case which was reiterated in Lt.Col. P.R. Choudhary will not apply to premises wherein annual rent is not fixed as maximum rent which could possibly be fixed in a situation where standard rent under the Delhi Rent Control Act could not be exceeded. Assessment of rateable value of subject property will therefore be governed by the Delhi Municipal Corporation (Determination of Rateable Value) Byelaws, 1994.
22. The second contention disputing Assessment Order dated 09.09.2003 on the ground that impugned order was passed without mandatory notice to plaintiffs in violation of principles of natural justice was however left out by Ld. Trial Court in the impugned judgment.
23. Appellants have referred to Tax Paid Receipt dated 29.07.2002 for the year 20022003 and Tax Paid Receipt dated 01.08.2003 for the year 20032004 for reiterating their contention that Assessment Order in violation of statutory requirement in terms of Section 123C(5) of DMC, 1957 Act is void.
24. Respondents on the other hand have stated that property was initially assessed on the purchase price of Rs.2,90,300/ and rateable value was fixed at Rs.26,130/ per annum w.e.f. 12.06.1990 and Rs.24,680/ per annum w.e.f. 01.04.1994 vide order dated 12.03.1997. It Page No. 14 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18is also averred that the property was sold out on 30.07.2002 and rateable value of the flat was fixed at Rs.28,600/ per annum w.e.f. 23.07.2002 and Rs.85,000/ per annum w.e.f. 30.07.2002 after notice under Section 126 of DMC Act was issued proposing to enhance the rateable value at Rs.2,00,000/ per annum w.e.f 01.04.2002.
25. Though appellants have adverted to Section 123C(5) of DMC Act, 1957 in Ground 'H' of the memorandum of appeal but impugned Assessment Order was passed for the period w.e.f. 23.07.2002. Revision of assessment of annual value as per unit area method under Section 123C of DMC Act effective from 01.08.2003 will therefore not apply and enhancement of rateable value and assessment thereupon under clause 47 of Section 2 of DMC Act, 1957 (omitted w.e.f. 01.08.2003) will be governed by Section 126 of DMC Act providing Amendment of Assessment list (replaced w.e.f. 01.08.2003).
26. Para seven of the plaint disputing legality of assessment order on the ground that it was passed without mandatory notice to plaintiffs has not been controverted as defendants' right to file written statement was closed. Moreover, it is pertinent to note that attested copy of letter No. Tax/SZ/2011/176 dated 09.08.2011 mentioning notice under Section 126 DMC Act dated 26.03.2003 has been filed on record by PW 2 Shri Ramesh Kumar, Head Clerk, MCD, R.K. Puram, New Delhi and referred as Ex.PW2/4 but neither office copy of purported notice nor any suggestion about service of notice under Section 126 of DMC Act was put to plaintiff Dr. Chandra Prakash (PW1) for impeaching his testimony with Page No. 15 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18respect to mandatory notice during his crossexamination recorded on 28.02.2017 and 02.05.2017.
27. Section 126 of DMC Act which has been revealed w.e.f. 01.08.2003 is extracted herein under for better appreciation of the point in issue:
"126. Amendment of assessment list. - (1) The Commissioner may, at any time, amend the assessment list--
(a).......
(b) ......
(c).......
(d) by increasing or reducing the adequate reasons the amount of any rateable value and of the assessment thereupon; or
(e) ........
(f) ........
(g) ........
Provided that no person shall by reason of any such amendment become liable to pay any tax or increase of tax in respect of any period prior to the commencement of the year [in which the notice sub section (2) is given].
(2) Before making any amendment under sub section (1) the Commissioner shall give to any person affected by the amendment, notice of not less than Page No. 16 /17 DOD:21.05.2020 Dr. Chander Prakash & Anr. Vs. Shri K.C. Meena & Ors.
RCA No. 71/18one month that he proposes to make the amendment and consider any objections which may be made by such person."
28. Since mandatory notice under Section 126(2) of DMC Act, 1957 was not given to plaintiffs by Commissioner, MCD so Assessment Order dated 09.09.2003 pursuant to amendment of assessment list for enhancing the rateable value and assessment thereupon for the year 20022003 is invalid and unenforceable.
29. Plaintiffs having paid Rs.22,745/ through cheque No. 212302 dated 21.02.2012 pursuant to Demand Notice under Section 154(1) of DMC Act dated 24.01.2012 are therefore entitled to refund of the amount and judgment dated 31.07.2018 dismissing plaintiffs' suit is reversed by restraining defendants from realizing and enforcing illegal demand of house tax pursuant to Demand Notice No. Tax/RKP/52/9684 dated 24.01.2012 in respect of Flat No. D7/7018, Vasant Kunj, New Delhi and directing refund of Rs.22,745/ paid under protest in response to demand notice pursuant to Assessment Order which is invalid and unenforceable.
30. Decreesheet be prepared accordingly.
31. Trial Court Record by sent back along with copy of judgment.
32. Appeal file be consigned to record room after due compliance. Digitally signed TARUN by TARUN YOGESH YOGESH Date: 2020.05.23 14:13:38 +0530 Announced in the open Court (Tarun Yogesh) On 21.05.2020 ADJ03/South West Dwarka / New Delhi Page No. 17 /17 DOD:21.05.2020