Full Judgment Text
- 1 -
NC: 2026:KHC:14103
RP No. 41 of 2026
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
TH
DATED THIS THE 9 DAY OF MARCH, 2026
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
REVIEW PETITION NO.41 OF 2026
BETWEEN:
1. THE PR. COMMISSIONER OF INCOME TAX-1
BMTC BUILDING, 80 FEET ROAD,
TH
6 BLOCK, KORAMANGALA,
BANGALORE-560 095.
2. THE ASST. COMMISSIONER OF INCOME-TAX,
ND
ROOM NO.215, 2 FLOOR,
BMTC BUILDING, 80 FEET ROAD,
TH
6 BLOCK, KORAMANGALA,
BANGALORE-560 095.
…PETITIONERS
(BY SRI. RAVI RAJ Y.V, ADVOCATE)
AND:
AIRBUS INDIA PVT LTD.,
TH
HAVING OFFICE AT 4 FLOOR,
XYLEM PLOT NO.4 AND 4A,
BANGALORE-560 048.
DYAVASANDRA INDUSTRIAL AREA,
MAHADEVAPURA POST, WHITEFIELD ROAD,
REPRESENTED BY ITS HEAD OF TAXATION,
SOMYAJIT MALLICK.
…RESPONDENT
(BY SRI. T. SURYANARAYANA, SENIOR COUNSEL APPEARING FOR
SMT. TANMAYEE RAJKUMAR, ADVOCATE)
THIS REVIEW PETITION IS FILED UNDER SECTION 114 R/W
ORDER 47 RULE 1 OF CPC 1908, PRAYING TO ALLOW THE REVIEW THE
ORDER DATED 28.10.2025 PASSED BY THIS HON’BLE COURT IN WP
NO.24690/2025.
THIS PETITION, COMING ON FOR ORDERS , THIS DAY, ORDER
WAS MADE THEREIN AS UNDER:
Digitally
signed by
MADHURI S
Location:
High Court
of Karnataka
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RP No. 41 of 2026
HC-KAR
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, petitioners seek the following reliefs:
“i) Review the order dated 28.10.2025 passed by
this Hon’ble Court in W.P.No.24690/2025.
ii) To pass such other suitable orders as this
Hon’ble Court deems fit to be granted in the facts and
circumstances of the case in the interest of justice and
equity.”
2. Heard learned counsel for the petitioners and learned
counsel for the respondent and perused the material on record.
3. Learned counsel for the petitioners would reiterate the
various contentions urged in the petition and submits that the final
order dated 28.10.2025 contains an error apparent on the face of
the record inasmuch as the CBT Circular No.19 of 2024 comprising
of Guidance Note 2/2024, in particular, FAQ No.47 has not been
considered by this Court since the same was not brought to the
notice of this Court at the time of disposal of the petition. It is
submitted that having regard to the ITAT Order dated 05.08.2022
passed by the Tribunal, the said Circular would have the effect of
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RP No. 41 of 2026
HC-KAR
rejecting the claim of the respondent – writ petitioner, who was not
entitled to the relief sought for in the writ petition and as such, the
order dated 28.10.2025 passed in W.P.No.24690/2025 deserves to
be set aside and the writ petition deserves to be restored to the file
of this Court.
4. Per contra, learned Senior Counsel for the respondent
– writ petitioner would invite my attention to the material on record
including the final order passed by this Court in order to point out
that having regard to the undisputed fact that Form No.1 under the
DTVSV Scheme was filed on 20.12.2024, to which the Review
petitioners issued Form No.2 on 04.01.2025, in pursuance of which
the respondent – writ petitioner filed a rectification application dated
21.01.2025 which preceded the issuance of OGE (order giving
effect) dated 26.03.2025 passed by the department / Revenue,
which was made the basis to issue the revised impugned Form
No.2 subsequently on 28.07.2025 coupled with the fact that as on
that date, the appeal in ITA No.130 of 2023 was pending before
this Court having been filed on 23.03.2023, this Court was fully
justified in passing the impugned order directing consideration of
the rectification application filed by the respondent earlier to
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RP No. 41 of 2026
HC-KAR
issuance of the impugned Form No.2 by passing the said final
order, which does not warrant interference by this Court in the
present petition.
5. A perusal of the material on record will indicate that the
various contentions urged by both sides have been considered by
this Court while passing the final order, as hereunder:
“In this petition, petitioner seeks for the following reliefs:-
“a) Quashing the certificate in Form-2 dated 28.07.2025
issued by the Respondents under Section 92 of the Finance
Act (No. 2), 2024 bearing DIN 480741901280725 (Annexure 'J')
for the assessment year 2015-16;
b) Directing the Respondents to issue a fresh certificate
in Form-2 under Section 92 of the Finance Act (No. 2), 2024 for
the assessment year 2015-16, by taking into account the tax
payable at Rs. 6,51,40,540/-, i.e., one-half of the tax payable
on the transfer pricing adjustment of Rs. 13,18,94,281/- and the
disallowance under Section 40(a)(i) of the Income-tax Act, 1961
of Rs. 25,13,98,099/- determined in the final assessment order
dated 29.10.2019 (Annexure 'B') and compute the
consequential refund after taking into account all tax credits
available to the Petitioner;
c) Quashing the order dated 26.03.2025 passed by the
under Section 143(3) read with Section 254 of Income-tax Act,
1961 bearing DIN ITBA/AST/M/143(3)/2 25/1075278732(1)
(Annexure - 'H') for the assessment 2015-16 to the extent
questioned in the present petition;.
In the alternative;
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d) If the relief sought vide prayer (a), (b) and (c) are
not granted, permit the Petitioner to file an appeal / petition
before the appropriate authority, against the order dated
nd
26.03.2025 passed by the 2 Respondent for the assessment
year 2015-16, under Section 143(3) read with Section 254 of
the IT Act bearing DIN ITBA/AST/M/143(3)/2024-
25/1075278732(1); and
e) pass such other or further orders as this Hon'ble
Court may deem fit in the facts and circumstances of the case,
in the interests of justice and equity.”
2. Heard learned Senior counsel for the petitioner and
learned counsel for the respondents – revenue and perused
the material on record.
3. A perusal of the material on record will indicate
that in relation to the assessment year 2015-16, final
assessment order dated 29.10.2019 was passed by the
respondents. Aggrieved by the same, petitioner filed an
appeal which was disposed of by the ITAT vide final order
dated 05.08.2022 answering certain issues in favour of the
petitioner and remitted the matter back to the Assessing
Officer in relation to the remaining issues. Aggrieved by the
order of the ITAT insofar as answering issues in favour of the
petitioner, respondents have preferred an appeal before this
Court in ITA No.130/2023, which is pending adjudication.
4. In the meanwhile, during the pendency of the said
appeal, a scheme known as ‘Direct Tax Vivad Se Vishwas
Scheme, 2024’ (for short ‘the DTVSV scheme’) was
promulgated in July, 2024, pursuant to which, the petitioner
filed Declaration in Form-1 on 20.12.2024. In pursuance of
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RP No. 41 of 2026
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st
the same, the 1 respondent issued an order in Form-2
dated 04.01.2025 determining refund payable to the
petitioner but failed to grant credit of tax deducted at source
and advance tax which credit the petitioner, he was entitled
to claim from the respondents. Under these circumstances,
the petitioner filed an application dated 21.01.2025 before
both the respondents seeking rectification of the mistakes in
Form-2 i.e., by seeking re-computation of the refund upon
grant of credit on the appropriated tax already remitted by
the petitioner.
5. It is a matter of record and undisputed fact that the
rectification application are pending before the respondents
nd
even as on today. In the meanwhile, on 26.03.2025, the 2
respondent passed an Order Giving Effect (OGE) to the
aforesaid order dated 05.08.2022 passed by the ITAT
interalia deleting the TP adjustment and making
disallowances of the reimbursement of salary costs of
seconded employees under Section 40(i)(a) of the I.T.Act.
st
The said OGE was made the basis by the 1 respondent to
issue the impugned revised Form-2 dated 28.07.2025 by
treating the quantum involved in the appeal before this Court
only pursuant to TP adjustment and the quantum in respect
of disallowance under Section 40(a)(i) of the I.T.Act is being
reduced to ‘Nil’. Aggrieved by the impugned revised Form-2
and seeking other reliefs, petitioner is before this Court by
way of the present petition.
6. A perusal of the material on record including the
st
aforesaid Form-2 will indicate that the 1 respondent clearly
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HC-KAR
fell in error in issuing the impugned Form-2 on the basis of
the OGE dated 28.07.2025, based on Annexure-H the OGE
dated 26.03.2025 , which is clearly illegal and impermissible
in law and so also, since the rectification applications filed by
the petitioner are still pending consideration, I deem it just
and appropriate to set aside the impugned Endorsement and
dispose of this petition by issuing certain directions for
disposal of the rectification application filed by the petitioner.
7. In the result, I pass the following:-
ORDER
(i) Petition is hereby allowed.
(ii) The impugned certificate at Annexure-J in Form-2
dated 28.07.2025 issued by the respondents is hereby
quashed.
(iii) The respondents are directed to consider the
rectification application at Annexure-G dated 21.01.2025 filed
by the petitioner after granting credit of appropriated tax
already paid by the petitioner in accordance with law and
without reference to the order giving effect to at Annexure-H
dated 26.03.2025 as expeditiously as possible within an outer
limit of three months from the date of receipt of a copy of this
order.”
6. In my considered opinion the order under review
cannot be said to suffer from any illegality or infirmity nor can the
same be said to contain any error apparent on the face of the
record warranting interference by this Court in exercise of its limited
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HC-KAR
review jurisdiction under Section 114 read with Order XLVII Rule 1
CPC and as such, the said contention urged by the petitioners
cannot be accepted.
7. I have given my anxious consideration to the
submissions made by the learned counsel for the review petitioners
and perused the material on record including the impugned order in
the light of the decisions of the Apex Court in (i) Shri Ram Sahu
vs. Vinod Kumar Rawat – Civil Appeal No.3601/2020 dated
03.11.2020, (ii) S.Murali Sundaram vs. Jothibai Kannan – (2023)
SCC Online SC 185 (iii) S.Madhusudhan Reddy vs. V.Narayana
Reddy – Civil Appeal Nos.5503-04/2022 dated 18.08.2022 and
the recent judgment of the Apex Court in the case of (iv) Sanjay
Kumar Agarwal vs. State Tax Officer –2023 SCC Online SC
1406, wherein it is held as under:-
16. The gist of the afore-stated decisions is that:—
(i) A judgment is open to review inter alia if there is a
mistake or an error apparent on the face of the record.
(ii) A judgment pronounced by the Court is final, and
departure from that principle is justified only when
circumstances of a substantial and compelling character
make it necessary to do so.
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HC-KAR
(iii) An error which is not self-evident and has to be
detected by a process of reasoning, can hardly be said to
be an error apparent on the face of record justifying the
court to exercise its power of review.
(iv) In exercise of the jurisdiction under Order 47 Rule
1 CPC, it is not permissible for an erroneous decision to be
“reheard and corrected.”
(v) A Review Petition has a limited purpose and
cannot be allowed to be “an appeal in disguise.”
(vi) Under the guise of review, the petitioner cannot be
permitted to reagitate and reargue the questions which
have already been addressed and decided.
(vii) An error on the face of record must be such an
error which, mere looking at the record should strike and it
should not require any long-drawn process of reasoning on
the points where there may conceivably be two opinions.
(viii) Even the change in law or subsequent
decision/judgment of a co-ordinate or larger Bench by itself
cannot be regarded as a ground for review.
8. Insofar as reliance placed upon the Circular
No.19/2024 dated 16.12.2024 by the review petitioners, though the
said Circular was not brought to the notice of this Court, having
regard to the findings recorded by this Court while allowing the
petition and directing consideration of the rectification application,
which was filed by the respondent – writ petitioner on 21.01.2025
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earlier to the impugned Form No.2 issued subsequently on
28.07.2025 coupled with the fact that the appeal filed by the review
petitioners / department / revenue was pending before this Court in
ITA No.130/2023, the Circular will not come to the aid of the review
petitioners to seek review of the order passed by this Court, which
is otherwise correct and proper in law. Under these circumstances,
I do not find any merit in the petition and the same is hereby
dismissed.
Sd/-
(S.R.KRISHNA KUMAR)
JUDGE
SV
List No.: 2 Sl No.: 28
NC: 2026:KHC:14103
RP No. 41 of 2026
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
TH
DATED THIS THE 9 DAY OF MARCH, 2026
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
REVIEW PETITION NO.41 OF 2026
BETWEEN:
1. THE PR. COMMISSIONER OF INCOME TAX-1
BMTC BUILDING, 80 FEET ROAD,
TH
6 BLOCK, KORAMANGALA,
BANGALORE-560 095.
2. THE ASST. COMMISSIONER OF INCOME-TAX,
ND
ROOM NO.215, 2 FLOOR,
BMTC BUILDING, 80 FEET ROAD,
TH
6 BLOCK, KORAMANGALA,
BANGALORE-560 095.
…PETITIONERS
(BY SRI. RAVI RAJ Y.V, ADVOCATE)
AND:
AIRBUS INDIA PVT LTD.,
TH
HAVING OFFICE AT 4 FLOOR,
XYLEM PLOT NO.4 AND 4A,
BANGALORE-560 048.
DYAVASANDRA INDUSTRIAL AREA,
MAHADEVAPURA POST, WHITEFIELD ROAD,
REPRESENTED BY ITS HEAD OF TAXATION,
SOMYAJIT MALLICK.
…RESPONDENT
(BY SRI. T. SURYANARAYANA, SENIOR COUNSEL APPEARING FOR
SMT. TANMAYEE RAJKUMAR, ADVOCATE)
THIS REVIEW PETITION IS FILED UNDER SECTION 114 R/W
ORDER 47 RULE 1 OF CPC 1908, PRAYING TO ALLOW THE REVIEW THE
ORDER DATED 28.10.2025 PASSED BY THIS HON’BLE COURT IN WP
NO.24690/2025.
THIS PETITION, COMING ON FOR ORDERS , THIS DAY, ORDER
WAS MADE THEREIN AS UNDER:
Digitally
signed by
MADHURI S
Location:
High Court
of Karnataka
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RP No. 41 of 2026
HC-KAR
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, petitioners seek the following reliefs:
“i) Review the order dated 28.10.2025 passed by
this Hon’ble Court in W.P.No.24690/2025.
ii) To pass such other suitable orders as this
Hon’ble Court deems fit to be granted in the facts and
circumstances of the case in the interest of justice and
equity.”
2. Heard learned counsel for the petitioners and learned
counsel for the respondent and perused the material on record.
3. Learned counsel for the petitioners would reiterate the
various contentions urged in the petition and submits that the final
order dated 28.10.2025 contains an error apparent on the face of
the record inasmuch as the CBT Circular No.19 of 2024 comprising
of Guidance Note 2/2024, in particular, FAQ No.47 has not been
considered by this Court since the same was not brought to the
notice of this Court at the time of disposal of the petition. It is
submitted that having regard to the ITAT Order dated 05.08.2022
passed by the Tribunal, the said Circular would have the effect of
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RP No. 41 of 2026
HC-KAR
rejecting the claim of the respondent – writ petitioner, who was not
entitled to the relief sought for in the writ petition and as such, the
order dated 28.10.2025 passed in W.P.No.24690/2025 deserves to
be set aside and the writ petition deserves to be restored to the file
of this Court.
4. Per contra, learned Senior Counsel for the respondent
– writ petitioner would invite my attention to the material on record
including the final order passed by this Court in order to point out
that having regard to the undisputed fact that Form No.1 under the
DTVSV Scheme was filed on 20.12.2024, to which the Review
petitioners issued Form No.2 on 04.01.2025, in pursuance of which
the respondent – writ petitioner filed a rectification application dated
21.01.2025 which preceded the issuance of OGE (order giving
effect) dated 26.03.2025 passed by the department / Revenue,
which was made the basis to issue the revised impugned Form
No.2 subsequently on 28.07.2025 coupled with the fact that as on
that date, the appeal in ITA No.130 of 2023 was pending before
this Court having been filed on 23.03.2023, this Court was fully
justified in passing the impugned order directing consideration of
the rectification application filed by the respondent earlier to
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RP No. 41 of 2026
HC-KAR
issuance of the impugned Form No.2 by passing the said final
order, which does not warrant interference by this Court in the
present petition.
5. A perusal of the material on record will indicate that the
various contentions urged by both sides have been considered by
this Court while passing the final order, as hereunder:
“In this petition, petitioner seeks for the following reliefs:-
“a) Quashing the certificate in Form-2 dated 28.07.2025
issued by the Respondents under Section 92 of the Finance
Act (No. 2), 2024 bearing DIN 480741901280725 (Annexure 'J')
for the assessment year 2015-16;
b) Directing the Respondents to issue a fresh certificate
in Form-2 under Section 92 of the Finance Act (No. 2), 2024 for
the assessment year 2015-16, by taking into account the tax
payable at Rs. 6,51,40,540/-, i.e., one-half of the tax payable
on the transfer pricing adjustment of Rs. 13,18,94,281/- and the
disallowance under Section 40(a)(i) of the Income-tax Act, 1961
of Rs. 25,13,98,099/- determined in the final assessment order
dated 29.10.2019 (Annexure 'B') and compute the
consequential refund after taking into account all tax credits
available to the Petitioner;
c) Quashing the order dated 26.03.2025 passed by the
under Section 143(3) read with Section 254 of Income-tax Act,
1961 bearing DIN ITBA/AST/M/143(3)/2 25/1075278732(1)
(Annexure - 'H') for the assessment 2015-16 to the extent
questioned in the present petition;.
In the alternative;
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RP No. 41 of 2026
HC-KAR
d) If the relief sought vide prayer (a), (b) and (c) are
not granted, permit the Petitioner to file an appeal / petition
before the appropriate authority, against the order dated
nd
26.03.2025 passed by the 2 Respondent for the assessment
year 2015-16, under Section 143(3) read with Section 254 of
the IT Act bearing DIN ITBA/AST/M/143(3)/2024-
25/1075278732(1); and
e) pass such other or further orders as this Hon'ble
Court may deem fit in the facts and circumstances of the case,
in the interests of justice and equity.”
2. Heard learned Senior counsel for the petitioner and
learned counsel for the respondents – revenue and perused
the material on record.
3. A perusal of the material on record will indicate
that in relation to the assessment year 2015-16, final
assessment order dated 29.10.2019 was passed by the
respondents. Aggrieved by the same, petitioner filed an
appeal which was disposed of by the ITAT vide final order
dated 05.08.2022 answering certain issues in favour of the
petitioner and remitted the matter back to the Assessing
Officer in relation to the remaining issues. Aggrieved by the
order of the ITAT insofar as answering issues in favour of the
petitioner, respondents have preferred an appeal before this
Court in ITA No.130/2023, which is pending adjudication.
4. In the meanwhile, during the pendency of the said
appeal, a scheme known as ‘Direct Tax Vivad Se Vishwas
Scheme, 2024’ (for short ‘the DTVSV scheme’) was
promulgated in July, 2024, pursuant to which, the petitioner
filed Declaration in Form-1 on 20.12.2024. In pursuance of
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RP No. 41 of 2026
HC-KAR
st
the same, the 1 respondent issued an order in Form-2
dated 04.01.2025 determining refund payable to the
petitioner but failed to grant credit of tax deducted at source
and advance tax which credit the petitioner, he was entitled
to claim from the respondents. Under these circumstances,
the petitioner filed an application dated 21.01.2025 before
both the respondents seeking rectification of the mistakes in
Form-2 i.e., by seeking re-computation of the refund upon
grant of credit on the appropriated tax already remitted by
the petitioner.
5. It is a matter of record and undisputed fact that the
rectification application are pending before the respondents
nd
even as on today. In the meanwhile, on 26.03.2025, the 2
respondent passed an Order Giving Effect (OGE) to the
aforesaid order dated 05.08.2022 passed by the ITAT
interalia deleting the TP adjustment and making
disallowances of the reimbursement of salary costs of
seconded employees under Section 40(i)(a) of the I.T.Act.
st
The said OGE was made the basis by the 1 respondent to
issue the impugned revised Form-2 dated 28.07.2025 by
treating the quantum involved in the appeal before this Court
only pursuant to TP adjustment and the quantum in respect
of disallowance under Section 40(a)(i) of the I.T.Act is being
reduced to ‘Nil’. Aggrieved by the impugned revised Form-2
and seeking other reliefs, petitioner is before this Court by
way of the present petition.
6. A perusal of the material on record including the
st
aforesaid Form-2 will indicate that the 1 respondent clearly
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HC-KAR
fell in error in issuing the impugned Form-2 on the basis of
the OGE dated 28.07.2025, based on Annexure-H the OGE
dated 26.03.2025 , which is clearly illegal and impermissible
in law and so also, since the rectification applications filed by
the petitioner are still pending consideration, I deem it just
and appropriate to set aside the impugned Endorsement and
dispose of this petition by issuing certain directions for
disposal of the rectification application filed by the petitioner.
7. In the result, I pass the following:-
ORDER
(i) Petition is hereby allowed.
(ii) The impugned certificate at Annexure-J in Form-2
dated 28.07.2025 issued by the respondents is hereby
quashed.
(iii) The respondents are directed to consider the
rectification application at Annexure-G dated 21.01.2025 filed
by the petitioner after granting credit of appropriated tax
already paid by the petitioner in accordance with law and
without reference to the order giving effect to at Annexure-H
dated 26.03.2025 as expeditiously as possible within an outer
limit of three months from the date of receipt of a copy of this
order.”
6. In my considered opinion the order under review
cannot be said to suffer from any illegality or infirmity nor can the
same be said to contain any error apparent on the face of the
record warranting interference by this Court in exercise of its limited
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RP No. 41 of 2026
HC-KAR
review jurisdiction under Section 114 read with Order XLVII Rule 1
CPC and as such, the said contention urged by the petitioners
cannot be accepted.
7. I have given my anxious consideration to the
submissions made by the learned counsel for the review petitioners
and perused the material on record including the impugned order in
the light of the decisions of the Apex Court in (i) Shri Ram Sahu
vs. Vinod Kumar Rawat – Civil Appeal No.3601/2020 dated
03.11.2020, (ii) S.Murali Sundaram vs. Jothibai Kannan – (2023)
SCC Online SC 185 (iii) S.Madhusudhan Reddy vs. V.Narayana
Reddy – Civil Appeal Nos.5503-04/2022 dated 18.08.2022 and
the recent judgment of the Apex Court in the case of (iv) Sanjay
Kumar Agarwal vs. State Tax Officer –2023 SCC Online SC
1406, wherein it is held as under:-
16. The gist of the afore-stated decisions is that:—
(i) A judgment is open to review inter alia if there is a
mistake or an error apparent on the face of the record.
(ii) A judgment pronounced by the Court is final, and
departure from that principle is justified only when
circumstances of a substantial and compelling character
make it necessary to do so.
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RP No. 41 of 2026
HC-KAR
(iii) An error which is not self-evident and has to be
detected by a process of reasoning, can hardly be said to
be an error apparent on the face of record justifying the
court to exercise its power of review.
(iv) In exercise of the jurisdiction under Order 47 Rule
1 CPC, it is not permissible for an erroneous decision to be
“reheard and corrected.”
(v) A Review Petition has a limited purpose and
cannot be allowed to be “an appeal in disguise.”
(vi) Under the guise of review, the petitioner cannot be
permitted to reagitate and reargue the questions which
have already been addressed and decided.
(vii) An error on the face of record must be such an
error which, mere looking at the record should strike and it
should not require any long-drawn process of reasoning on
the points where there may conceivably be two opinions.
(viii) Even the change in law or subsequent
decision/judgment of a co-ordinate or larger Bench by itself
cannot be regarded as a ground for review.
8. Insofar as reliance placed upon the Circular
No.19/2024 dated 16.12.2024 by the review petitioners, though the
said Circular was not brought to the notice of this Court, having
regard to the findings recorded by this Court while allowing the
petition and directing consideration of the rectification application,
which was filed by the respondent – writ petitioner on 21.01.2025
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earlier to the impugned Form No.2 issued subsequently on
28.07.2025 coupled with the fact that the appeal filed by the review
petitioners / department / revenue was pending before this Court in
ITA No.130/2023, the Circular will not come to the aid of the review
petitioners to seek review of the order passed by this Court, which
is otherwise correct and proper in law. Under these circumstances,
I do not find any merit in the petition and the same is hereby
dismissed.
Sd/-
(S.R.KRISHNA KUMAR)
JUDGE
SV
List No.: 2 Sl No.: 28