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"Therefore, the word 'undertaking' must be defined as 'any business or any work or project which one engages in or attempts as an enterprise analogous to business or trade".

Similarly in R.C. Cooper v. Union of India, , in the context of challenge to Banks nationalisation the Supreme Court in para-40 of the judgment while defining the word 'undertaking' used in Section 4 of Act 22 of 1969 held that, 'the expression 'undertaking' in Section 4 of Act 22 of 1969 clearly means a going concern with all its rights, liabilities and assets as distinct from various rights and assets which compose if. In a judgment from Andhra Pradesh being Radhakrishna Rice and Oil Mill Contractors v. APSEB, 1969 (1) APLJ 462, some persons were contesting the payment of electricity charges towards Vijayawada Municipality which had supplied the power from 1-5-1956 to 21-12-1961. In between, the Andhra Pradesh Electricity supply (Acquisition) Act, 1954 came and the State Government took over the undertaking and it was contended before the High Court that since the Government had not supplied the power to the petitioners from 1-5-1956 to 21-12-1961 they were not empowered to demand the amount even if they were due to the Municipality. The Court refused this argument on interpretation of the Act and held that since the undertaking had been taken over by the Government, therefore that would mean they had taken undertaking of all their assets and liabilities. The Court rejected the argument on arrears of consumption charges due from the consumers to the Municipality could not be effectively be acquired under Electricity Undertakings (Acquisition) Act. The Court was of the view that even the arrears which were due to the Municipality could be recovered on taking over of the undertakings in terms of A.P. Electricity Supply Undertakings (Acquisition) Act. In Ma Kyin Hone v. Ong Boon Hock, AIR 1937 Rangoon 47, it was held that "the undertaking include lands, buildings machinery, lines of supply, goodwill etc., in fact everything which appertains to the supply of electricity under the licence". In the Patna High Court judgment Murli Prasad v. Parasnath Prasad, , however a distinction was made and it was stated by the Court while interpreting the same Act i.e., Indian Electricity Act, 1910 that, if the concern is not a running one then the plant, machinery, other material constituting the undertaking become ordinary goods.