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M. Murali Mohan Vs. State (income-tax Officer, Nalgonda) - Court Judgment

SooperKanoon Citation

Subject

Direct Taxation

Court

Andhra Pradesh High Court

Decided On

Case Number

Criminal Miscellaneous Petition No. 231 of 1986

Judge

Reported in

[1987]168ITR729(AP)

Acts

Income Tax Act, 1961 - Sections 277 and 278

Appellant

M. Murali Mohan

Respondent

State (income-tax Officer, Nalgonda)

Appellant Advocate

Naram Bhaskar Rao, Adv.

Respondent Advocate

N.V.S.R. Gopala Krishnamacharyulu, Adv.

Excerpt:


.....therefore, the insured and the insurer have no escape but to discharge the said award as directed. undisputedly, in this case as deduced for proved facts, the vehicle in question was not properly maintained by the owner and despite faulty brake system, the claimant had undertaken the hazardous journey to his peril at the behest of and at the instruction of the owner. the owner is therefore, tortfeasor. section 168: [v. gopala gowda & jawad rahim, jj] insurers limit of liability - held, it is well settled that the liability of the insurance company for payment of compensation can be statutory or contractual. is for the insurance company to show that the insurance policy was a statutory policy and not a contractual policy to restrict its liability. that issue was neither raised before the tribunal nor is raised in this appeal requiring decision. thus, if at all the insurer has any valid ground to restrict its liability, it can proceed against the insured but firstly it has to discharge the award as required under section 149 (1) of the act. where the owner/insured has failed to maintain the vehicle as per prescribed safety standards and has caused the claimant to drive the..........officer, nalgonda, found that in collusion with the second accused, he had introduced fictitious purchases of yarn of rs. 75,000 for the manufacture of bandage cloth by him and on that basis a sum of rs. 75,000 was added to the income declared by the petitioner. on appeal against the said assessment, the appellate assistant commissioner, hyderabad, by his order dated january 27, 1984, set aside the orders passed by the income-tax officer and directed him to redo the assessment. after the assessment order was passed, the income-tax officer filed a complaint with the approval of the commissioner of income-tax against the petitioner and another person for offences under sections 277 and 278 of the income-tax act and sections 193 and 196, ipc. summonses were issued in c.c. no. 94 of 1984, and thereafter the petitioner filed crl. m.p. no. 1524 of 1984, stating that the prosecution does not subsist in view of the setting aside of the order of the income-tax officer. this order was dismissed by the special judge and on revision the metropolitan sessions judge confirmed the same. learned counsel for the petitioner, sri n. bhaskar rao, contends that the assessment order in respect.....

Judgment:


Rama Rao, J.

1. This petition is to quash the proceedings of the Special Judge for Economic Offences, Hyderabad, in Crl. M.P. No. 1524 of 1984, in C.C. No. 94 of 1984, confirmed by the Metropolitan Sessions Judge, Hyderabad. The facts arising in this petition may be briefly stated :

For the assessment year 1980-81, the petitioner field the return under the Income-tax Act admitting a total income of Rs. 15,481. On scrutiny of the books of account, the Income-tax Officer, Nalgonda, found that in collusion with the second accused, he had introduced fictitious purchases of yarn of Rs. 75,000 for the manufacture of bandage cloth by him and on that basis a sum of Rs. 75,000 was added to the income declared by the petitioner. On appeal against the said assessment, the Appellate Assistant Commissioner, Hyderabad, by his order dated January 27, 1984, set aside the orders passed by the Income-tax Officer and directed him to redo the assessment. After the assessment order was passed, the Income-tax Officer filed a complaint with the approval of the Commissioner of Income-tax against the petitioner and another person for offences under sections 277 and 278 of the Income-tax Act and sections 193 and 196, IPC. Summonses were issued in C.C. No. 94 of 1984, and thereafter the petitioner filed Crl. M.P. No. 1524 of 1984, stating that the prosecution does not subsist in view of the setting aside of the order of the Income-tax Officer. This order was dismissed by the special judge and on revision the Metropolitan Sessions Judge confirmed the same. Learned counsel for the petitioner, Sri N. Bhaskar Rao, contends that the assessment order in respect of which the prosecution was launched is not subsisting as it was set aside and, therefore, the prosecution proceedings are not maintainable. It is not in dispute that the assessment order was set aside. But, however, the learned Metropolitan Sessions Judge held that the criminal proceedings can icontinue irrespective of the fact whether the assessment is set aside. It may be stated that this approach of the learned judge is erroneous. When the assessment itself is set aside by the appellate authority, it cannot be said that the assessment still continues in the eye of law and when the assessment order itself is not in existence, the question of maintaining the prosecution does not arise. The Metropolitan Sessions Judge also held that the revision is not maintainable. This technical objection need not be considered as the High Court has ample power under section 482, Crl. PC, to quash the original order itself. In this view, the proceedings in C.C. No. 94 of 1984, on the file of the Special Judge for Economic Offences are quashed. The criminal miscellaneous petition is allowed.


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