Ruling
Ruling
No.AAR/02(CE)/2007
in
Application No.AAR/03(CE)/2007
Applicant
M/s Lhoist India Private Limited
DBS
House, Prescott Road, Fort
Mumbai-400001
Commissioner
concerned
Commissioner of Customs &
Central
Excise, Bhubaneswar-I & II
Present
for the Applicant
Mr. S. Ganesh, Senior Counsel,
M/s Sujit Ghosh, D.K. Rana
and
Sudipta Bhattacharjee, Advocates
Mr.
Pieter Jonckheer (Director of applt.)
Present
for the Commissioner
Mr. A.N. Sharma, Jt.CDR
concerned
Mr. Deepak Garg, SDR
CESTAT,
New Delhi
R
U L I N G
(By
Mrs. Chitra Saha)
In the Application filed under Section 23C of the Central Excise Act,
1944, the Applicant M/s Lhoist India Pvt. Ltd., Mumbai, has sought an advance
ruling on the following question:
"For
the purposes of Central Excise laws of India read with the Central Excise Tariff
Act, 1985, what should be the classification with respect to the finished
product (i.e. high purity burnt Lime) proposed to be manufactured by the
Applicant under the process enumerated in the facts contained in Annexure I."
2.
The applicant has submitted in Annexure I that high purity lime stone,
i.e. calcium carbonate (CaCo3) is proposed to be imported.
This lime stone would be crushed and heated to high temperatures.
During the heating the calcium carbonate would decompose into carbon
dioxide (CO2) and calcium oxide (CaO).
The carbon dioxide contained in the lime stone would escape leaving
behind calcium oxide. This calcium
oxide, referred to as lime or quick lime or burnt lime would be further crushed
to smaller sizes as per customers' requirements.
Apart from calcium oxide, the finished product, i.e. burnt lime would
also have traces of certain impurities. While
calcium oxide would comprise 94 to 96% of the product, the other
elements/compounds present in it would be magnesium oxide (MgO constituting less
than 1.5%), silicon oxide (SiO2 accounting for less than 1%), sulphur
(S which would be less than 0.05%) and R2O3 which has been
clarified by the applicant, in the course of the hearing, to be aluminum oxide
(Al2O3) which would constitute less than 0.5%.
3.
The applicant states that the two possible classifications of the high
purity burnt lime in the First Schedule (hereafter referred to as the
'tariff') to the Central Excise Tariff Act 1985 are :
2522 under Chapter 25 and 2825 in Chapter 28. Chapter 25 covers "Salt; sulphur; earths and stone;
plastering materials; lime and cement". The
Tariff head 2522 under this Chapter covers "Quick lime, slaked lime and
hydraulic lime, other than calcium oxide and hydroxide of heading 2825".
Note 1 of this Chapter reads as follows :
"Except
where their context or Note 4 to this Chapter otherwise requires, the headings
of this Chapter cover only products
which are in crude state or which have been washed (even with chemical
substances eliminating the impurities without changing the structure of the
product), crushed, ground, powdered, levigated, sifted, screened, concentrated
by flotation, magnetic separation or any other mechanical or physical process
(except crystallization), but not products that have been roasted,
calcined, obtained by mixing or subjected to processing beyond that
mentioned in each heading."
4.
It is the applicant's submission that since the burnt lime is obtained
by heating, i.e. calcining the raw material, lime stone, the finished product,
i.e. burnt lime, gets excluded from Chapter 25 by virtue of Note 1. The applicant further states that
classification of burnt lime under Chapter 25 is also ruled out as 2522
specifically excludes calcium oxide and hydroxide of heading 2825.
4.1
The applicant has referred to Chapter 28 which covers "Inorganic
chemicals, organic or inorganic compounds of precious metals, of rare-earth
metals, of radioactive elements or of isotopes." Note 1 of the said Chapter
states that the headings of this Chapter apply only to separate chemical
elements and separate chemically defined compounds, irrespective of whether or
not they contain impurities. Burnt
lime comprising predominantly of the separate chemically defined compound,
calcium oxide, which is a metal oxide, would get covered under the residuary
sub-head 2825 90 90 falling under 2825 which covers "Hydrazine and
hydroxylamine and their inorganic salts; other inorganic bases; other metal
oxides, hydroxides and peroxides."
5.
In the course of the hearing on 17.7.2007, the applicant has referred to
the definition of "impurities" in the Explanatory Notes (Volume I, page 261
Third Edition) on Chapter 28 of the Harmonized Commodity Description and
Commodity System (hereafter referred to as HSN Notes) to state that the presence
of the impurities magnesium oxide, aluminum oxide, silicon oxide and sulphur in
the burnt lime does not take away the product from Chapter 28 in view of the
following definition of the term "impurities" in the HSN Notes :-
"Separate
chemical elements and separate chemically defined compounds containing impurities,
or dissolved in water, remain
classified in Chapter 28.
The
term "impurities" applies exclusively to substances whose presence in the
single chemical content results solely and directly from the manufacture process
(including purification). The
substances may result from any of the factors involved in the process and are
principally the following :
(a)
Unconverted starting materials.
(b)
Impurities present in the starting materials.
(c)
Reagents used in the manufacturing process (including purification).
(d)
By-products.
It
should be noted, however, that such substances are not in all cases referred as
"impurities" permitted under Note 1(a).
When such substances are deliberately left in the product with a view to
rendering it particularly suitable for specific use rather than for general use,
they are not regarded as permissible impurities."
Since
the impurities in the final product burnt lime are all materials which were
present in the "starting materials" i.e. lime stone and since no external
substance has been added to burnt lime, the impurities fall in the category of
"permissible impurities" in the above definition, contends the counsel for
the applicant. The applicant has also clarified that small amounts of the
above materials were allowed to be left in the final product as removing them
would be expensive and uneconomical.
5.1
In conclusion, the applicant has referred to orders of Tribunal and a
judgement of the Supreme Court which have specifically excluded quick lime
obtained by calcination of lime stone from the purview of Chapter 25 on account
of the Note in that Chapter referred to above.
The First Schedule of the Central Excise Tariff Act 1985 has undergone
several amendments in the past with changes in Chapter notes and in the
descriptions of headings. The applicant claims that though the judgements cited
were given in the context of the tariff as it existed at the relevant time, the
conclusions in the said judgements still hold good in the context of the amended
tariff. The relevant decisions are
:
·
Steel Authority of India Ltd v CCE, Bhubaneshwar reported in 2004 (164)
ELT 355 (Trib.)
·
Brijbasi Lime Works v CCE, Indore reported in 1996 (88) ELT 681 (Trib.)
·
CCE, Chandigarh v Nuchem Industries (P) Ltd reported in 1999 (105) ELT
711 (Trib.)
·
CCE v Nuchem Industries Pvt Ltd reported in 1998 (99) ELT 197 SC
6.
Relying on the above case laws cited by the applicant, the Commissioners
of Customs, Central Excise and Service Tax, Bhubaneshwar I & II concur with
the conclusion of the applicant that the Chapter Note 1 precludes classification
of burnt lime under Chapter 25. They further state that high purity burnt lime
is not classifiable under any Chapter of the Central Excise tariff except
Chapter 28, and that the arguments given by the applicant in support of
classification under 2825 appear to be correct.
7.
A point put forward by the Senior Departmental Representative is that
Chapter head 2825 covers only calcium oxide which is in the pure state.
An essential physical characteristic of such pure calcium oxide is that
it is crystalline in nature. This
attribute of the product, which has not been clarified in the application, needs
to be verified, specially since the silicon oxide and aluminum oxide present in
the burnt lime are known to retard the process of crystal formation.
In response to the above, the applicant have submitted an affidavit dated
17.7.07 stating that the high purity burnt lime that they propose to manufacture
would be "crystalline in structure in a cubic system" and that the presence
of impurities does not affect/retard the crystallization of calcium oxide.
7.1
The Senior Departmental Representative has also submitted detailed
technical literature on "Lime and Lime stone" appearing on pages 343-381 in
Volume 14 of Encyclopedia of Chemical Technology by Kirk-Othmer and have
referred to extracts from Wikipedia on calcium oxide.
It appears from a reading of the above literature that calcium oxide is
known variously as lime, quick lime, burnt lime etc. and that the terms calcium
oxide and lime/quick lime are used interchangeably.
This oxide is a white caustic and alkaline crystalline solid that finds
extensive use in different fields. While
the most primitive use of calcium oxide has been in the building and the
construction industry, it is also used for more sophisticated purposes such as
for manufacture of chemicals, steel, paper, glass etc. The literature also indicates that calcium oxide is most
commonly manufactured by calcining lime stone (CaCo3) in kilns at
high temperatures. The heat
chemically decomposes the lime stone into calcium oxide and carbon dioxide.
Quick lime has varying strengths of calcium oxide.
In USA, in the relatively pure chemical limes, the concentration of
calcium oxide ranges between 93.25 to 98% and the concentration is less in lime
manufactured outside USA (page 346 and 367 of Kirk-Othmer Encyclopedia.)
8.
Both the applicant as well as the Commissioners have relied on the note
in Chapter 25 to rule out classification of burnt lime obtained by calcination
of lime stone, in that Chapter. The
judgement of the Supreme Court in case of Nuchem Industries cited in this regard
upholds a decision of the Tribunal to the effect that quick lime obtained by the
process of calcination falls outside the scope of Chapter 25 by virtue of the
Chapter note referred to above and that quick lime is not exigible to Central
Excise duty.
8.1
The judgement of the Supreme Court pertains to demands for duty for the
period 1985 to '89. The Central
Excise Tariff has undergone substantial amendments since then.
Chapter head 25.05 and the relevant note in Chapter 25 during 1986-89
read as follows :-
"25.05
2505.00
Mineral substances, not elsewhere specified
(including
clay, earth colours, natural abrasive, sulphur, slate and stone), lime; plasters
with a basis of calcium sulphate, whether or not coloured, but not including
plasters specially prepared for use in dentistry"
Note
2
"Heading
Nos.25.01, 25.03 and 25.05 cover only products which have been washed (even with
chemical substances, eliminating the impurities without changing the structure
of the product) crushed ground, powdered, levigated, sifted, screened, or
concentrated by floatation, magnetic separation or other mechanical or physical
processes (except crystallization) but not products that have been roasted
calcined or obtained by mixing."
At present, Chapter head 2522 and Note 1 of the said Chapter read as
follows :-
"Heading 2522 -
Quicklime, slaked lime and hydraulic lime, other than calcium oxide and
hydroxide of heading 2825.
252210 00
Quick lime
252220 00
Slaked lime
252230 00
Hydraulic lime"
Note 1
"Except
where their context or Note 4 to this Chapter otherwise requires, the headings
of this Chapter cover only products which are in crude state or which have been
washed (even with chemical substances eliminating the impurities without
changing the structure of the product), crushed, ground, powdered, levigated,
sifted, screened, concentrated by floatation, magnetic separation or any other
mechanical or physical process (except crystallization), but not products that
have been roasted, calcined, obtained by mixing or subjected to processing
beyond that mentioned in each heading."
9.
A reading of the above indicates that while Chapter head 25.05 earlier
mentioned only "lime" in general terms, without mentioning its different
varieties, including quick lime, the present tariff heading clearly mentions
quick lime while excluding its predominant constituent viz. calcium oxide.
When the present tariff specifically includes quick lime which is being
manufactured and bought and sold in the market, such a product cannot be said to
be non-excisable, though the rate of duty is nil at present.
The fact that the product is obtained by calcination, a process debarred
by Note 1 of Chapter 25, will not take away the quick lime from the purview of
this Chapter as the said note has been amended after the judgement of the
Supreme Court, and now begins with the preface "Except where the context or
Note 4 to this Chapter otherwise requires....".
In the context of the present tariff which specifically mentions "quick
lime" which can only be obtained by calcining lime stone, the said Chapter
note cannot be held to exclude the said product from Chapter 25, as such an
interpretation would render the entry "2522 1010 - quick lime" redundant. The above conclusion is in conformity with HSN Note on Note 1
(page 210) which refers to goods, including quick lime, which remain covered
under Chapter 25 despite having been subjected to processes not provided for by
Note 1. With the amendments in the
tariff, the conclusions in the judgement in case of Nuchem Industries etc. no
longer hold good. Note 1 of Chapter
25 does not rule out classification of quick lime, which is another name for
burnt lime under Chapter 25 of the existing tariff.
10.
The issue for decision is the classification of burnt lime having 94-96%
of calcium oxide and some impurities. Burnt
lime is also known as quick lime and comprises predominantly of calcium oxide,
which occurs in varying strengths. The Encyclopedia of Kirk-Othmer mentions that
the purer varieties of quick lime available in USA have calcium oxide ranging
between 93.25% to 98%. "Quick
lime" is specifically included under 25.22 of the tariff, while its main
constituent, "calcium oxide", is classifiable under 2825 90 90 which covers
metal oxides. The description of
25.22 under which quick lime falls, however, specifically excludes calcium oxide
of Chapter head 28.25 The question
that now arises is which is the quick lime comprising mainly of calcium oxide
that is classifiable under Chapter 25 and when does such quick lime get excluded
from Chapter 25 on account of being calcium oxide of Chapter 28.
11.
Chapter 28 is a part of Section VI of the Tariff which covers "Products
of the chemical or allied industries". The
Chapter 28 itself covers "Inorganic chemicals, organic or inorganic compounds
or precious metals, of rare earths metals, of radioactive metals, of
isotopes." Calcium oxide is
classifiable as a metal oxide under 2825 90 90.
Chapter Note 1 clarifies, inter alia, that this Chapter applies only to
separate chemical elements and separate chemically defined compounds, whether or
not containing impurities.
11.1
Chapter 25 which includes quick lime, on the other hand, forms a part of
Section V which covers "Mineral products".
The said Chapter encompasses "Salt; sulphur; earths and stone;
plastering materials; lime and cement" and Note 1 of this Chapter clarifies
that this Chapter covers only such of the above products which are in the crude
state or which have been subjected to some elementary processes such as washing,
crushing, grinding, powdering, etc. As
mentioned earlier, the product quick lime has varying strengths of calcium
oxide. While the quick lime which
is a less pure form of calcium oxide, is used in buildings, for white washing,
cement manufacture etc., the purer versions with higher concentrations of
calcium oxide find more sophisticated uses in steel making, manufacture of
chemicals, paper, etc. From a
reading of the descriptions of goods in the Section, Chapter head etc. above ,
it would appear that the quick lime which is more akin to the "mineral
product" lime in a relatively crude form, than to a "separate chemically
defined compound", would merit classification under Chapter 25 whereas the
purer versions containing higher concentrations of the separately defined
chemical compound - calcium oxide and with very few impurities would get
classified as metal oxide under Chapter 28.
It is relevant to mention here that Note 1 in Chapter 28 states that this
Chapter contains separate chemically defined compounds, whether or not
containing impurities. The
applicant, has also referred to the Explanatory Notes on HSN to show that the
impurities present in their burnt lime, do not take away the product from the
purview of Chapter 28. The burnt
lime proposed to be used in the manufacture of steel and
comprising of 94-96% of calcium oxide and permissible impurities, is more
akin to the "separate chemically defined compound" - calcium oxide than to
the mineral product lime in the crude state and would therefore merit
classification as a metal oxide under 2825 90 90 of Chapter 28.
12.
The structure of the Central Excise Tariff is based on the
internationally accepted nomenclature in Harmonized System of Nomenclature (HSN).
Supreme Court in the case of CCE, Shillong versus Wood Crafts Products
Limited 1995 (77) E.L.T. 23 (SC) has held that when the tariff entry is
patterned on HSN, disputes relating to tariff classification must, as far as
possible, be resolved with reference to the HSN Explanatory Notes.
In the instant case, Explanatory Note on Chapter 25.22 supports the above
classification. HSN Note states
that the quick lime falling in 25.22 is an impure calcium oxide obtained by
calcining lime stone containing little or no clay and that the said heading
excludes purified calcium oxide which falls under 28.25 (page 223).
Note of 28.25 (page 302) similarly clarifies that this heading covers
only calcium oxide in the pure state in which there is practically no clay (emphasis
supplied), iron oxide, magnesium oxide, etc.
The applicant has already clarified by referring to HSN Notes that the
impurities in their burnt lime fall within the category of permissible
impurities.
13.
To sum up, the burnt lime proposed to be manufactured by the applicant,
which is in a crystalline form, contains 94-96% of the separately defined
chemical compound calcium oxide and contains less than 1% of silicon oxide, less
than 1.5% magnesium oxide, less than 0.05% of sulphur and less than 0.5% of
aluminum oxide, is classifiable under sub head 2825 90 90 of Chapter 28 of the
First Schedule to the Central Excise Tariff
Act 1985.
Sd/-
(Chitra
Saha)
Member
Per
P.V. Reddi, J (Hon'ble Chairman)
:-
Broadly, I am in agreement with what the learned Member has said.
The justification for this addenda is only to supply emphasis to certain
thoughts already reflected in her order.
1.
The applicant calls the product to be manufactured by it as "high
purity burnt lime". The trade
name of that finished product, according to the applicant, is
steel grade lump lime which is mostly used in the steel industry.
It is known as high purity burnt lime for the reason that it will have
high calcium oxide content of 94 to 96%. According
to the applicant, burnt lime/quick lime available in the domestic market in
India usually has 75-85% purity in terms of calcium oxide content and in the
case of industrial grade, it is 85-90%.
The end use of the proposed product is primarily in steel industry.
2.
Wikipedia (the free Encyclopedia) refers to the fact that calcium oxide
is "commonly known as burnt lime, caustic lime or quick lime". The applicant also states that burnt lime is otherwise known
as Quick lime. In Encyclopedia of
Chemical Technology by Kirk-Othmer, it is stated that the component of calcium
oxide ranges between 93.25 and 98% in "Commercial quick limes".
3.
Limes of various descriptions contain predominantly calcium oxide.
But, some have comparatively less percentage and some have more.
The various expressions, viz, quick lime, burnt lime, pebble lime
(physical shape of quick lime) are often used as inter-changeable expressions. They broadly go by the description and belong to the genus of
calcium oxide.
4.
If Quick lime stands alone in Chapter 25 without any qualification or
exclusionary words, the product of the applicant would squarely fit into it.
By using the nomenclature 'high purity burnt lime', it cannot be
taken out of the category of quick lime.
But, the task of classification is made difficult for the reason that the
Heading 2522 excludes from the purview of quick lime calcium oxide of the
Heading 2825. Heading 2825, among
others, cover 'metal oxide'. Calcium
oxide being a metal oxide, it comes under Heading 2825.
More specifically, calcium oxide is to be brought under the residual
Entry tariff item 2825 90 90 - "other" and it is liable to duty @ 16%.
Thus we have quick lime in Chapter 25 and calcium oxide in Chapter 28.
As already noted, quick lime is a common name for calcium oxide.
The overlapping commodities with interchangeable nomenclature are thus
placed in two separate chapters. Quick
lime suffers no duty at present whereas calcium oxide attracts duty at 16%. Then, how to understand these apparently similar items?
Where and how to draw the dividing line between the two? That is the
puzzling question before us. The
only solution seems to be to distinguish them from the stand point of the degree
of purity and their uses. That is
what has been done by the learned Member in para No. 11.1 of her ruling.
5. Burnt lime containing
practically nothing but calcium oxide with negligible quantities of impurities
such as clay remaining in it and which is utilized for sophisticated industrial
uses ought to be classified under the heading 2825 (T.I. 2825 90 90).
In the case of applicant's product, the calcium oxide content is said
to be as high as 95%. It may not be
the calcium oxide in purest form, which is not known to be manufactured in our
country. Yet, the product burnt
lime to be manufactured by the applicant is calcium oxide with little or
negligible impurities. It can be
legitimately classified as calcium oxide under Heading 2825 as it is almost
pure. When we are called upon to
distinguish calcium oxide from quick lime, this type of product which contains
the calcium oxide - an inorganic compound, in almost pure state, should be relegated to Heading 2825. The Commentary/Explanatory notes in HSN referred to by
the learned Member at paragraph 12 also lend support to this view point.
6.
The first attempt of the applicant was to keep out quick lime and burnt
lime from the purview of Ch. 25#
That was sought to be done by
taking recourse to Note 1 to Ch. 25 and the decision of the
Supreme Court in Collector of
Central Excise vs. Nuchem Industries*.
The Supreme Court while interpreting the then existing Note 2 to Ch. 25
held that Quick lime and hydrated lime obtained by calcination would fall
outside the scope of Ch. 25. That
conclusion was arrived at by the Supreme Court when the relevant Entry in Ch. 25
referred to 'lime' in general terms but not specifically Quick lime.
For the reasons stated by the learned Member in para 9, the ratio
of that decision cannot be applied to the interpretation of the Heading and the
Note as recast. With specific
inclusion of Quick lime in Ch. 25 as an excisable commodity.
Note 1 (corresponding to the then Note 2) cannot be invoked to exclude
Quick lime from Ch. 25. The
prefatory words in Note 1 "except where the context otherwise
requires" (inserted subsequent to
the period with which the Supreme Court and CEGAT
was concerned) assume importance. Note
1 obviously does not come into play where calcined product is specifically
inserted as an excisable commodity though the rate of duty is nil.
The learned Senior Counsel for the applicant has practically conceded
this position. In sum, I would
like to clarify that the applicant's product
falls outside Ch. 25 not because Quick lime goes out of Ch. 25 on account of Note 1 but because of exclusion clause
contained in Heading 2522.
7.
It is interesting to note that at the relevant point of time when the
Supreme Court decided the matter, lime was subjected to duty at 12% whereas now
Quick lime attracts nil duty. The
reason for granting duty relief to Quick lime seems to be based on its
non-commercial use and the class of consumers.
8.
This is perhaps a rare case in which the applicant has come forward to
pay duty for its product under Tariff Item 2825 90 90 instead of claiming duty
relief available for quick lime. Apparently,
the applicant being convinced of the correct classification, would like to avert
the risk of availing the benefit on the strength of decisions rendered in a
different context and then facing a backlash at a later stage.
Sd/-
(P.V.
Reddi)
Chairman
Per
Shri A. Sinha (Member) :-
I have perused the ruling prepared by the learned Member and entirely
agree with the conclusions reached therein.
I have also gone through the note of the Hon'ble Chairman, succinctly
spelling out the rationale behind the ruling.
I also agree with the same as well as the reasoning given by the learned
Member.
Sd/-
(A.
Sinha)
Member
Pronounced
by the Authority in the open Court on this 30th day of
August, 2007.
Registered /A D
F.
No. AAR/03(CE)/2007
Dated
30th August, 2007
(A)
This copy is certified to be a true copy of the Ruling and is sent to :-
1.
M/s
Lhoist India Private Limited, DBS House, Prescott Road, Fort,
Mumbai-4000012.
2.
Commissioner of Central Excise, Customs & Service Tax, Bhubaneswar-I
& II.
3.
Member(C.E), Central Board of Excise & Customs, North Block, New
Delhi.
4.
Mr.A.N. Sharma, Jt. Chief Departmental Representative, Customs, Excise
& Service Tax Appellate Tribunal, West Block-2, R.K.Puram, New Delhi-66.
5. Guard File
(Krishna
A. Mishra)
Additional
Commissioner
Registered /A D
F.
No. AAR/03(CE)/2007
Dated
6th September, 2007
(A)
This copy is certified to be a true copy of the Ruling and is sent to :-
1.
M/s
Lhoist India Private Limited, DBS House, Prescott Road, Fort,
Mumbai-4000012.
2.
Commissioner of Central Excise, Customs & Service Tax, Bhubaneswar-I
& II.
3.
Member(C.E), Central Board of Excise & Customs, North Block, New
Delhi.
4.
Mr.A.N. Sharma, Jt. Chief Departmental Representative, Customs, Excise
& Service Tax Appellate Tribunal, West Block-2, R.K.Puram, New Delhi-66.
5. Guard File
(Krishna
A. Mishra)
Additional
Commissioner
(B)
In view of the
provisions contained in Rule 25 of the Authority for Advance Rulings (Procedure)
Regulations, 2005, permission of the Authority is accorded for publication of
the Advance Ruling. Copy of the Advance Ruling is forwarded to:
1.
Centex Publications Pvt. Ltd., 1512-B, Bhishma Pitamah Marg, Opp. ICICI
Bank of Defence colony, New Delhi-110 003
2.
Deeparchie Publications, M-93, Marg-46, Saket, New Delhi-110 017
3.
Excise & Customs Cases, B-37, Sector-1, Noida-201301 (U.P.)
4.
Cen-Cus Publications, A-252, Shivalik, New Delhi-110 017
5.
Taxindiaonline.com Private Limited., B-XI/8183, Vasant Kunj, New
Delhi-110 070
6.
Taxmann Allied Service Pvt. Ltd, 59/32, New Rohtak Road, New Delhi-110005.
7.
www.allindiantaxes.com, 803, Kirti Shikhar, District Centre,
Janakpuri, New Delhi-110058
(Krishna
A. Mishra)
Additional
Commissioner
