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Aashirwad Films vs Union Of India & Ors on 18 May, 2007

14. As mentioned already, though the statue originally intended to collect EDC only from the 'Distributors' of electricity as given under Section 11 3(1) of the 1981 Act, as per the CG Act No. 28 of 2014, 28 of 2004, Section 3(1-a) was introduced in similar terms, demanding Cess from the 'Producers' of electricity as well. The rate is also common, as on date, by virtue of the CG Act No. 10 of 2010. This being the position, there is no unreasonable classification and both the 'Producers' and the 'Distributors' are required to satisfy the EDC to the requisite extent, though the matter is still pending consideration before the Apex Court in respect of the validity of Section 3(1-a) of the 1981 Act. As it stands so, the reliance sought to be placed by the Apex Court in Ram Prasad Narain Sahi v. The State of Bihar {AIR 1953 SC 215, paragraphs 15 and 18}, Kunnathat Thathunni Moopil Nair v. The State of Kerala and Another {AIR 1961 SC 552, paragraphs 8 to 10}, S.K.Dutta, Income Tax Officer v. Lawrence Singh Ingty, {AIR 1968 SC 658, paragraphs 8, 10 and 15}, State of Kerala v. Haji K. Kutty Naha & Others {AIR 1969 SC 378, paragraph 5}, Aashirvad Films v. Union of India {(2007) 6 SCC 624 , paragraphs 12 to 15, 18, 25 and 27} and State of Andhra Pradesh v. Nalla Raja Reddy {(1967) 3 SCR 28, paragraphs 21 and 25} asserting the necessity to have a rational classification and the existence of discriminatory provisions, are not attracted to the case in hand.
Supreme Court of India Cites 22 - Cited by 43 - S B Sinha - Full Document

State Of Andhra Pradesh & Anr vs Nalla Raja Reddy & Ors on 28 February, 1967

16. It was further contended by the learned counsel for the Petitioners that the enactment is unreasonable and arbitrary, inasmuch as there is no mechanism for issuing any prior notice, hearing, assessment, appeal etc. with regard to the fixation of liability. It is also pointed out that there is no quasi-judicial forum before which the person facing the demand of such kind can approach. The absence of any machinery or mechanism as above will make the taxation unconstitutional. Support is sought to be drawn by the verdict passed by the Apex Court in Kunnkathat Thathunni Moopil Nair (supra) {paragraph 9} and Nalla Raja Reddy (supra) {paragraph 22 and 23} wherein the Apex Court held that, if a taxing statute does not provide for 13 redressal i.e. notice, opportunity of hearing, taxing authority, procedure for assessment, redressal mechanism, then, such statute is unconstitutional.
Supreme Court of India Cites 10 - Cited by 138 - K S Rao - Full Document

The Commissioner, Hindu Religious ... vs Sri Lakshmindra Thirtha Swamiar Of Sri ... on 16 April, 1954

21. There is a contention for the Petitioners that the levy of Cess is virtually a tax in disguise and that no tax can be levied without any authority of law, by virtue of mandate under Article 265 of the Constitution of India. There is also a contention that in case of any Cess, there must be co-relation between levy and the services rendered (cess or fee) revealing the 'quid- pro-quo'. The verdicts passed by the Apex Court in Commissioner, Hindu Religious Endowments v. Sri Lakshmindra Tirtha, Swamiar of Sri Shirur Mutt, {AIR 1954 SC 282, paragraph 44 to 51}, Jaora Sugar Mills (P) Ltd. v. State of Madhya Pradesh, {AIR 1966 SC 416, para 19}, Om Prakash Agarwal v. Giri Raj Kishore {AIR 1986 SC 726, paragraphs 7, 10 to 12} and 16 Chandrakant Krishnarao Pradhan v. Jasjit Singh, Collector of Customs, Bombay, {AIR 1962 SC 204, paragraph 13} are sought to be pressed into service in this regard.
Supreme Court of India Cites 67 - Cited by 618 - B K Mukherjea - Full Document

Jaora Sugar Mills (P) Ltd vs State Of Madhya Pradesh And Others on 19 April, 1965

21. There is a contention for the Petitioners that the levy of Cess is virtually a tax in disguise and that no tax can be levied without any authority of law, by virtue of mandate under Article 265 of the Constitution of India. There is also a contention that in case of any Cess, there must be co-relation between levy and the services rendered (cess or fee) revealing the 'quid- pro-quo'. The verdicts passed by the Apex Court in Commissioner, Hindu Religious Endowments v. Sri Lakshmindra Tirtha, Swamiar of Sri Shirur Mutt, {AIR 1954 SC 282, paragraph 44 to 51}, Jaora Sugar Mills (P) Ltd. v. State of Madhya Pradesh, {AIR 1966 SC 416, para 19}, Om Prakash Agarwal v. Giri Raj Kishore {AIR 1986 SC 726, paragraphs 7, 10 to 12} and 16 Chandrakant Krishnarao Pradhan v. Jasjit Singh, Collector of Customs, Bombay, {AIR 1962 SC 204, paragraph 13} are sought to be pressed into service in this regard.
Supreme Court of India Cites 22 - Cited by 49 - P B Gajendragadkar - Full Document

Om Parkash Agarwal Etc.Etc vs Giri Raj Kishori & Ors. Etc.Etc on 28 January, 1986

21. There is a contention for the Petitioners that the levy of Cess is virtually a tax in disguise and that no tax can be levied without any authority of law, by virtue of mandate under Article 265 of the Constitution of India. There is also a contention that in case of any Cess, there must be co-relation between levy and the services rendered (cess or fee) revealing the 'quid- pro-quo'. The verdicts passed by the Apex Court in Commissioner, Hindu Religious Endowments v. Sri Lakshmindra Tirtha, Swamiar of Sri Shirur Mutt, {AIR 1954 SC 282, paragraph 44 to 51}, Jaora Sugar Mills (P) Ltd. v. State of Madhya Pradesh, {AIR 1966 SC 416, para 19}, Om Prakash Agarwal v. Giri Raj Kishore {AIR 1986 SC 726, paragraphs 7, 10 to 12} and 16 Chandrakant Krishnarao Pradhan v. Jasjit Singh, Collector of Customs, Bombay, {AIR 1962 SC 204, paragraph 13} are sought to be pressed into service in this regard.
Supreme Court of India Cites 21 - Cited by 55 - E S Venkataramiah - Full Document

Municipal Committee, Hoshiarpur vs Punjab State Electricity Board & Ors on 19 October, 2010

25. The Petitioners attack Annexure P/1 order referring to the violation of the principles of natural justice as well, in so far as no notice or opportunity of hearing was given; nor any assessment was made as to the determination of the quantum of liability, unlike in the case of assessment of tax under various statutes. The fixation of liability towards the EDC is clear and certain, by virtue of the rate/quantum mentioned under Section 3(1) of the 1981 Act. The liability of the Distributor to satisfy the Cess at the above rate with respect to number of units and the necessity to file return under Rule 7(1) of the Rules, 1949 before the Electrical Inspector are also clear and definite. Since the number of units sold/supplied/ used by the Distributor is clearly within the knowledge of the Distributor and since the 'rate per unit' is also clearly stipulated in the statute itself, the rest is for the Petitioner/Distributor to show the relevant figures in the return to be filed before the Electrical Inspector after satisfaction of the duty in terms of Rule 3 of the Rules, 1949. There is no ambiguity/obscurity in any manner and the statute does not envisage issuance of any notice as to the fixation of liability. This is something like the satisfaction of the tax payable in respect of motor vehicles under the Motor Vehicles Taxation Act and such other similar statutes. When the statute is a 'self-contained' one as to the rate and the manner of satisfaction, fixing the extent of liability upon the Distributor, the alleged violation of the principles of natural justice with reference to non-issuance of 19 notice or opportunity of hearing is not correct or sustainable and is unfounded. This being the position, the reliance sought to be placed on Kothari Filament v. Commissioner of Customs {(2009) 2 SCC 198 paragraph 15}, Municipal Committee, Hosiarpur v. Punjab State Electricity Board, {(2010) 13 SCC 216, paragraphs 31 to 36}, Kesar Enterprises Limited v. State of Uttar Pradesh, {(2011) 13 SCC 711, paragraphs 23, 30 to 36} and Swadeshi Cotton Mills Ltd. Union of India, {(1981) 1 SCC 664, paragraphs 21 to 45} in respect of the violation of principles of natural justice is quite out of context and is not applicable.
Supreme Court of India Cites 38 - Cited by 132 - B S Chauhan - Full Document
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