Mis. Bhor Industries Ltd vs The Commissioner Of Income-Tax, Bombay

Rewritten Version Notice: This is a rewritten version of the original judgment.

Court: supreme-court

Case Number: Civil Appeals Nos. 158 to 164 of 1960

Decision Date: 12 January 1961

Coram: M. Hidayatullah, J.L. Kapur, J.C. Shah

In the matter titled Mis Bhor Industries Ltd. versus The Commissioner of Income‑Tax, Bombay, a judgment was delivered on 12 January 1961 by the Supreme Court of India. The opinion was authored by Justice M. Hidayatullah, with Justices J. L. Kapur and J. C. Shah forming the bench. The case is reported in 1961 AIR 1100 and 1961 SCR (3) 409. The appellant, Mis Bhor Industries Ltd., was a private company limited by shares that had been incorporated in 1944 in the former State of Bhor, with its registered office located in Bhor. All of the company’s shareholders were residents of British India at the material times. By operation of the States Merger (Governors’ Provinces) Order, 1949, the State of Bhor was merged into the Province of Bombay effective 1 August 1949. The provisions of the Indian Income‑Tax Act, 1922, were extended to the merged State with effect from 1 April 1949. Under section 60A of that Act, the Central Government was empowered to remove any difficulty in the application of the law to merged States by issuing general or special orders granting exemptions or other modifications. Accordingly, the Central Government issued the Merged States (Taxation Concessions) Order, 1949. Paragraph 12 of that Order provided that “the provisions of S. 23A of the Indian Income‑Tax Act shall not be applied in respect of the profits and gains of any previous year ending before the first day of August 1949, unless the State law contains a provision corresponding thereto.” The total world income of Mis Bhor Industries Ltd. for the years 1946 and 1947 was Rs 6,57,084 and Rs 7,80,125 respectively, and for those years the company declared dividends of Rs 2,580 and Rs 1,140. For the assessment years 1947‑48 and 1948‑49, which corresponded to the account years 1946 and 1947, the Income‑Tax Officers assessed the company as a non‑resident. In the assessment year 1947‑48, the officer held that the assessable income of the company in British India for 1946, after deducting taxes, must be deemed to be distributed among the shareholders in proportion to their shareholdings under section 23A of the Act. For the account year 1947, the officer held that the total world income less taxes was deemed to be distributed, with the portion attributable to income earned in Bhor State being excluded except for the purpose of rate calculation. While computing the “deemed dividends,” the Income‑Tax Officer did not deduct the interest charged to the company under section 18A(8) from the assessable income, nor did he deduct the income‑tax and super‑tax under section 23A(1). The company thus contested the assessment on these grounds.

In this case the shareholders advanced several arguments. First they contended that paragraph twelve of the Merged States (Taxation Concessions) Order, 1949, barred the Income‑tax Officer from issuing an order under section 23A of the Income‑tax Act with respect to the profits and gains of the accounting years that ended on 31 December 1946 and 31 December 1947, because those years were previous years that terminated before 1 August 1949. Second they maintained that, regardless of the first argument, the interest payable under section 18A(8) should have been deducted together with the income‑tax before the notional dividends were calculated. A further submission was made that the deemed dividends were considered to have been declared and received in Bhor State; consequently, unless another legal fiction was superimposed on the fiction created by section 23A to deem the dividends as received in the taxable territories, the dividends could not be taxed in the hands of the shareholders. The shareholders also sought to invoke the protection of section 14(2)(C) for the entire amount of the balance that was deemed to be distributed. The Court then recorded its holdings. First, it held that the phrase “any previous year” in paragraph twelve of the Merged States (Taxation Concessions) Order, 1949, did not encompass all years that ended before 1 August 1949; rather, it referred only to a single previous year that would be a previous year for the assessment year 1949‑50, and that to obtain the exemption the year must finish before 1 August 1949. Second, the Court observed that the legal fiction created by section 23A of the Indian Income‑tax Act, 1922, which treats dividends that ought to have been distributed as actually distributed, overrode any issues of when the dividend accrued or was received, and that anything deemed to be distributed was also deemed to have accrued and been received by the person to whom it was deemed to be distributed. Third, the Court clarified that section 14(2)(C) of the Act saved only that portion of income which was not assessable in the taxable territories because it accrued in the State, and it did not interfere with the operation of section 23A on the assessable income of the company, which, by virtue of the application of the Indian Income‑tax Act even before the Act was extended to the State after the merger, was assessable under the Act. Fourth, the Court concluded that the wording of section 18A(8) indicated that the interest was recoverable along with the tax but retained its character as interest, and because section 23A authorised deduction solely of income‑tax and super‑tax, no deduction could be permitted for the interest under that provision. The judgment was rendered in the Civil Appellate Jurisdiction under Civil Appeals Nos. 158 to 164 of 1960. It arose from the judgment and order dated 8 October 1958 of the Bombay High Court in income‑tax appeals numbered 7505, 7506, 5046 to 5048, 5149 and 5150 of 1956‑57. Counsel for the appellants included senior members of the bar, while counsel for the respondent also appeared.

D. Gupta appeared for the respondent. The judgment was entered on 12 January 1961 and was delivered by Justice Hidayatullah. The seven appeals had been filed on a certificate issued by the High Court of Bombay, challenging the judgment and order of that Court dated 8 October 1958, which had arisen from a reference made by the Income‑tax Appellate Tribunal, Bombay. The first appellant was Bhor Industries Ltd., a company that had been incorporated in 1944 in the former Bhor State and that maintained its registered office in the town of Bhor. The company carried on the business of dyeing, printing and bleaching cloth, and also performed cloth proofing and related activities within Bhor State. The remaining five appellants were the shareholders of that company, which was a private company limited by shares at all material times. The matters before the Court concerned the company’s account years 1946 and 1947. For the assessment year 1947‑48 the company’s total income was reported as Rs 4,32,542, of which Rs 2,24,542 accrued in Bhor State, giving a total world income of Rs 6,57,084. For the assessment year 1948‑49 the total income was Rs 4,32,709, the income accruing in Bhor State was Rs 3,47,416, and the total world income amounted to Rs 7,80,125. The company held general meetings in Bhor on 17 August 1947 and on 19 August 1948, at which it declared dividends of Rs 2,580 and Rs 1,140 respectively for the account years 1946 and 1947. Bhor State merged with the Province of Bombay by virtue of the States Merger (Governors’ Provinces) Order, 1949, which came into force on 1 August 1949. By the Taxation Laws (Extension to Merged States and Amendment) Act, 1949, which received the Governor‑General’s assent on 31 December 1949, the Indian Income‑tax Act was extended to the merged states effective 1 April 1949. That Act also introduced section 60A, which authorised the Central Government, when it considered it necessary or expedient, to issue general or special orders granting exemption, rate reduction or other modifications in order to avoid hardship, anomaly or difficulty in the application of the Income‑tax Act to merged states. Exercising that power, the Central Government issued the Merged States (Taxation Concessions) Order, 1949. For the assessment years 1947‑48 and 1948‑49, corresponding to the company’s account years 1946 and 1947, the Income‑tax Officers assessed the company as a non‑resident and held that it was not a public company within the meaning of section 23A of the Indian Income‑tax Act. The Officer who decided the assessment for the year 1947‑48 applied section 23A and held that the assessable income of the company in British India for 1946, after deducting taxes, must be deemed to be distributed among the shareholders in proportion to their holdings. Accordingly, the Officer calculated the deemed distribution for 1946 as follows: total income of Rs 4,32,542, taxes of Rs 1,89,237, leaving an amount available for distribution of Rs 2,43,305; from this amount a dividend of Rs 2,580 had been declared, leaving a balance of Rs 2,40,725. For the year 1947, the Officer took the total world income less taxes as the amount available for distribution, computing total income of Rs 4,32,709, income in Bhor State of Rs 3,47,416, total world income of Rs 7,80,125 and taxes of Rs 2,43,399, which yielded an amount available for distribution of Rs 5,36,726. From that sum a dividend of Rs 1,140 was declared, leaving a balance of Rs 5,35,586. The Officer then apportioned the balance among the shareholders as on 19 August 1948, arriving at a per‑share amount of Rs 539.9. He further divided this amount in the proportion that the total income bore to the income earned in Bhor State and taxed the former in the hands of the shareholders, while the balance was included and considered only for the purpose of rate calculation.

For the assessment year 1947‑48, the Income‑tax Officer determined that the amount available for distribution after deducting taxes was Rs 2,43,305. From this sum a dividend of Rs 2,580 was declared, leaving a balance of Rs 2,40,725 as the amount that was deemed to be distributed. For the following assessment year 1948‑49, covering the account year 1947, the Officer first added the total income earned in British India, which was Rs 4,32,709, to the income earned in Bhor State, amounting to Rs 3,47,416. This aggregation produced a total world income of Rs 7,80,125. After subtracting the taxes payable, which were Rs 2,43,399, the Officer arrived at an amount of Rs 5,36,726 that was considered available for distribution as a dividend. From this amount a dividend of Rs 1,140 was declared, leaving a balance of Rs 5,35,586 as the amount deemed to be distributed. The Officer then apportioned this balance among the shareholders as of 19 August 1948, calculating a distribution of Rs 539.9 per share. He further divided the per‑share amount in proportion to the relationship between the total world income and the income attributable to Bhor State. The portion related to the total world income was taxed in the hands of the shareholders, whereas the portion corresponding to the Bhor State income was only included for the purpose of determining the tax rate. To illustrate this method, the Tribunal cited the case of one shareholder, Pushpakumar M. D. Thackersey, who held ninety shares. The share of Rs 5,35,586 attributable to his shareholding amounted to Rs 50,211. This sum was split in the previously explained ratio, resulting in Rs 27,851 being actually brought to tax and Rs 22,360, which represented the share of Bhor State income of Rs 3,47,416, being merely taken into account for rate calculation.

The two Income‑tax Officers, in computing these deemed dividends, did not deduct the interest payable by the Company under section 18A(8) from the assessable income, even though income‑tax and super‑tax were deducted under section 23A(1). The Company and its shareholders challenged these assessments by filing appeals with the Appellate Assistant Commissioner, but those appeals were dismissed. Subsequent appeals to the Tribunal were also rejected. The appellants contended that section 23A was not applicable to the Company, that a fictional distribution of dividends could not be taxed in the shareholders’ hands because section 23A did not apply to them, and that the Company and shareholders should have been protected by the Merged States (Taxation Concessions) Order, 1949, in the same manner as the Company. They also argued that the interest charged under section 18A(8) should have been deducted when determining the balance of the amount available for distribution. The Department and the Tribunal rejected all of these contentions. At the request of the Company and the shareholders, the Tribunal prepared a statement of the case and referred three questions to the High Court for determination. The first question asked whether paragraph 12 of the Merged States (Taxation Concessions) Order, 1949, barred the Income‑tax Officer from issuing an order under section 23A in the case of the assessee company concerning its profits and gains of the preceding year ended 31 December 1946 or 31 December 1947.

The Tribunal had referred three specific questions to the High Court for determination. The first question asked whether, with respect to the profits and gains of the previous year that ended on 31 December 1946 or 31 December 1947, paragraph 12 of the Merged States (Taxation Concessions) Order, 1949, barred the Income‑tax Officer from issuing an order under Section 23A. The second question inquired whether, when an order under Section 23A was made concerning the profits and gains of the year 1946/1947, the assessable income for that previous year should be reduced not only by the amount of income‑tax and super‑tax payable by the company but also by the amount of interest charged in accordance with Section 18A. The third question considered the order passed by the Income‑tax Officer under Section 23A in relation to the Company’s profits of the year 1947, which had apportioned a sum of Rs 17,641 to the shareholder Pushpakumar as his proportionate share of the distribution made under Section 23A, and asked, having regard to the provisions of Section 14(2)(c), whether that sum of Rs 17,641 had been properly included in his total income for the purpose of levying tax upon it. The third question was representative, because similar queries arose for other shareholders, differing only in the amount involved. The Tribunal explained that the amount of Rs 17,641 replaced an earlier figure of Rs 50,211 due to certain directions issued by the Tribunal. In disposing of the reference, the High Court added a further sub‑question to the first question, namely whether paragraph 12 of the Merged States (Taxation Concessions) Order, 1949, precluded the Income‑tax Officer from making any order under Section 23A that would affect the assessee shareholders with respect to their profits and gains for the assessment year 1949‑50. The High Court answered the original first and second questions, as well as its added sub‑question, in the negative, and answered the third question in the affirmative. Subsequently, the High Court granted a certificate under Section 66A of the Income‑tax Act, and the present appeals were filed. The parties have now raised before this Court the same contentions that were before the High Court. The Company challenges the applicability of Section 23A to the two assessment years 1947‑48 and 1948‑49, while the shareholders contest the application of Section 23A both to the Company and to themselves for the assessment year 1949‑50. Both the Company and the shareholders argue that interest levied under Section 18A(8) should have been deducted in addition to the income‑tax in order to determine the surplus that was actually available. The shareholders further claim that they are entitled to the benefit of Section 14(2)(c) in respect of the entire amount of the balance deemed to have been distributed. It is necessary to recall that the Indian Income‑tax Act became applicable to Bhor State on 1 April 1949, and that prior to the merger there was no income‑tax legislation in force in Bhor State, a situation that also obtained in many other Indian States that merged with the Provinces in British India. The fact that income‑tax is charged in an assessment year on the income, profits or gains of the previous year would have

In the circumstances described, the extension of the Indian Income‑Tax Act to the States that had merged with the Provinces caused individuals who were resident in those merged States to become liable to tax on income that, but for the extension, either would not have been taxable at all or would have been taxed at a lower rate. Recognising that such a situation could create hardships and anomalies, the Extension Act itself conferred on the Central Government a power to remove them. Section 60A was inserted into the Income‑Tax Act for this purpose and it provided that, if the Central Government considered it necessary or expedient to avoid any hardship or anomaly or to remove any difficulty arising from the extension of the Act to the merged States, it could, by a general or special order, make an exemption, reduce the rate, or otherwise modify the income‑tax liability in favour of any class of income, or with respect to the whole or any part of the income of any person or class of persons. The Concessions Order of 1949 was issued under this authority. The Court’s attention was directed specifically to paragraph 12 of the Concessions Order, which the Company and the shareholders relied upon in their appeals. Paragraphs 4, 5 and 6, although mentioned in the arguments, were not the focus of the present consideration because they dealt with income arising in an Indian State that had not been taxed in the cases before the Court. Paragraph 12 provided that section 23A of the Indian Income‑Tax Act would not apply to the profits and gains of any previous year ending before the first day of August 1949 unless the law of the State contained a corresponding provision. The text of paragraph 12 read: “The provisions of section 23A of the Indian Income‑tax Act shall not be applied in respect of the profits and gains of any previous year ending before 1st day of August, 1949, unless the State law contains a provision corresponding thereto.” By reading the Extension Act, section 60A and the Concessions Order together, the Court derived the operative position. The Indian Income‑Tax Act became applicable to the merged States from the assessment year 1949‑50, that is, from 1 April 1949 to 31 March 1950, and it covered the corresponding previous years. A difficulty that was likely to arise stemmed from the fact that the merger with the Province of Bombay took effect on 1 August 1949 rather than on 1 April 1949. To preserve the benefit of the exemption under section 14(2)(c), paragraphs 5 and 6 of the Order were applied to the exempted income, thereby making the State rate applicable to that income. In a similar vein, previous years ending after 31 March 1948 were to be assessed to Indian income‑tax, but any excess of the tax computed at Indian rates over the tax computed at State rates was to be granted as a rebate. Moreover, the profits and gains of companies for any previous year ending before 1 August 1948 that were earned in an Indian State were saved from the operation of section 23A unless the State law contained a provision corresponding to that section.

In this matter, the Court noted that the State of Bhor did not possess any provision that corresponded to section 23A of the Indian Income‑tax Act. It was essential to remember that the Income‑tax Officer, in the order he issued under section 23A, did not try to distribute the income earned in Bhor State by the shareholders of the Company as a dividend; his order was limited solely to the British Indian income. The Court further observed that, in fact, the State of Bhor had no law imposing income‑tax, and consequently the Income‑tax Officer was powerless to pass any order taxing income that arose within Bhor.

According to the definition contained in section 2(5A) of the Indian Income‑tax Act, a company that was formed under an enactment of an Indian State was regarded as a “company” for the purposes of the Act. This definition made it possible for the Income‑tax Officer, exercising the powers granted by section 23A, to declare that the income of such a company, when it accrued or arose within the taxable territory, was deemed to be distributed among its shareholders. The Court recorded that the Department’s right to issue an order under section 23A(1) of the Indian Income‑tax Act had not been challenged before the Tribunal, nor had it been the subject of any decision in the High Court.

The argument advanced on behalf of both the Company and its shareholders was that paragraph 12 of the Concessions Order saved the profits and gains—whether generated in Bhor State or in British India—from the operation of section 23A, thereby indirectly granting the shareholders the same benefit. Paragraph 12 of the Concessions Order, however, depended on whether a company was being assessed under the Indian Income‑tax Act for its profits and gains in an Indian State for any previous year that ended before 1 August 1949.

The Court explained that, with the application of the Indian Act to an Indian State, the income of a company situated in that State became liable to Indian income‑tax starting with the assessment year 1949‑50. For assessment years preceding that, the company’s income earned in the Indian State was exempt without needing the assistance of the Concessions Order. The exemption created by the Concessions Order was intended to operate only with respect to those profits and gains which, but for the exemption, would have been included in the assessment year 1949‑50 and in subsequent years.

With respect to paragraph 12, the Court observed that it provided an exemption from the operation of section 23A for the income of “any previous year” that ended before 1 August 1949. The date 1 August 1949 was selected because the merger of the State with the Provinces took place on that day. The Court clarified that the word “any” did not refer to all previous years that ended before that date; rather it referred to a single previous year in relation to the assessment year 1949‑50, provided that that previous year also ended before 1 August 1949. Consequently, “any previous year” meant only one specific year—namely, the previous year applicable to the assessment year 1949‑50, which had to terminate before the specified August date in order to qualify for the exemption.

In this case, the Court observed that paragraph 12 of the Concessions Order applied only to a single previous year whose financial year terminated before 1 August 1949. Consequently, the exemption did not extend to any other earlier years, and the reference in paragraph 12 to the date by which a previous year must end was therefore essential. The Court explained that the provision was intended to cover income, profits and gains of those particular previous years that might give rise to anomalies because the merger of the State occurred on 1 August 1949 while the Income‑Tax Act became effective on 1 April 1949. Because the Order expressly named the terminus of the relevant previous year, the Court could not accept the appellants’ argument that all previous years prior to the stated date were included in paragraph 12. The Court therefore limited the application of the paragraph to one previous year only, namely the year that ended before 1 August 1949. The previous years relevant to the present dispute ended on 31 December 1946 and 31 December 1947 respectively. For the Company, the only year fitting the description in paragraph 12 was the year ending 31 December 1947. To that year, the provisions of section 23A were not applicable, and the profits and gains earned in Bhor State were therefore protected. The position that existed for the assessment year 1947‑48 consequently also applied to the assessment year 1948‑49 with respect to the Company, meaning that its Bhor State profits could not be taken into account for the operation of section 23A. However, the Court noted a different situation concerning the Company’s income earned in British India, which formed part of its total income in the taxable territory. The Court held that it was not contested that this income would be subject to section 23A where the dividend distribution fell below the percentage specified in that section. Thus there was no distinction between the assessment years 1947‑48 and 1948‑49, and the method of calculation used for the first year was also applicable to the second. Accordingly, the answer to the first part of the first question had to be modified to reflect the previous year ending 31 December 1947. The appellants further contended that interest charged to the Company under section 18A(8) should have been deducted together with income‑tax before the notional dividends were computed. The Court quoted section 18A(8) in full: “Where, on making a regular assessment, the Income‑tax Officer finds that no payment of tax has been made in accordance with the foregoing provisions of the section, interest calculated in the manner laid down in sub‑section (6) shall be added to the tax as determined on the basis of regular assessment.” The Court affirmed that the wording of the sub‑section was clear.

In the Court’s analysis, it was observed that the provision required interest to be added to the tax as determined, and there was no indication that the interest should be treated as tax. Consequently, the interest retained its character as interest, although it was recoverable together with the tax. The Court noted that section 29 of the Income‑tax Act draws a clear distinction between tax, penalty and interest. Because section 23A permits deduction only of income‑tax and super‑tax, no deduction was permissible in respect of this interest. The Court therefore held that the High Court had correctly answered Question No. 2.

Turning to the shareholders, who were all residents of the taxable territories, the Court observed that paragraph 12 of the Concessions Order did not, in its terms, protect them. Section 23A required that dividends equal at least sixty per cent of the Company’s assessable income after deduction of income‑tax and super‑tax be paid. When the assessable income had been determined and the necessary deductions made, the failure to distribute dividends in accordance with section 23A invoked a statutory fiction. This fiction applied to the portion of profits and gains that were taxable as assessable income in the taxable territories and that ought to have been distributed.

Section 23A, as it stood before the 1955 amendment, specified that sixty per cent of the assessable income, reduced by the amount of income‑tax and super‑tax payable, must be distributed, and further provided that any undistributed portion, subject to certain conditions, would be deemed to have been distributed as dividends among the shareholders. The Court reiterated that the benefit of paragraph 12 was unavailable with respect to these deemed (or fictional) dividends insofar as the assessable income of the Company was concerned.

It was contended that the deemed dividends would be considered declared in Bhor State and received there, and that without an additional layer of fiction superimposed on the fiction created by section 23A, such deemed dividends could not be taxed in the hands of the shareholders. The Court acknowledged that the section indeed implied a fiction; however, if that fiction were given effect, the income must be deemed distributed to the shareholders, and this fiction would override any questions of accrual or receipt in the taxable territories. Accordingly, anything deemed to be distributed must also be deemed to have accrued to and been received by the person to whom it is deemed distributed, referring to sections 4(1)(a) and 4(1)(b)(i) and (ii).

The Court noted that paragraph 12 of the Concessions Order saved the Company with respect to income in Bhor State for the assessment year 1948‑49 for the corresponding prior year ending before 1 August 1949, but it did not preserve the operation of section 23A concerning the assessable income of the Company in the taxable territories and the distribution of dividends from that income. In the Court’s opinion, the High Court was right in

The Court held that the dividends deemed to have been distributed out of the assessable income of the Company in the taxable territories were correctly assessable in the total income of the shareholders who were resident in those taxable territories. The Court noted that no issue had been raised concerning the method of calculating the deemed‑distributed dividends, and therefore it expressed no opinion on that aspect of the case. The shareholders identified as appellants 2 to 6 sought to rely on the benefit provided by section 14(2)(o) of the Act, which states: “14(2). The tax shall not be payable by an assessee‑ (c) in respect of any income, profits or gains accruing or arising to him within an Indian State, unless such income, profits or gains are received or deemed to be received in or are brought into British India in the previous year by or on behalf of the assessee, or are assessable under Section 12‑B or Section 42.” The Court reiterated that the statutory fiction incorporated in section 23A causes the dividends that ought to have been distributed to be treated as actually distributed, and that this fiction overwhelms any question of accrual or receipt. Accordingly, section 23A makes dividends payable out of British Indian income chargeable to the shareholders. Paragraph 4 of the Concessions Order together with section 14(2)(c) saved for the shareholders only the income of the Company that arose outside the taxable territories, namely the income earned in Bhor State. Those provisions did not alter the operation of section 23A with respect to the assessable income of the Company that, by virtue of the Indian Income‑Tax Act even before the Extension Act, was subject to Indian taxation. Consequently, dividends payable from that portion of income attracted section 23A, and section 14(2)(c) was inapplicable. Section 14(2)(c) saved solely the portion of income that was not assessable in the taxable territories because it accrued in the State. The Income‑Tax Officer, when assessing the shareholders’ income for the assessment year 1949‑50, should have deducted the income that accrued in Bhor State while applying section 23A to the remaining income. The Officer, in effect, performed that deduction, although he employed a method that was not contested and whose correctness could not be reviewed. The Court answered the first question in the negative, with the qualification that section 23A applied only to the portion of income earned in British India and not to the income earned in Bhor State. The Court answered the second question in the negative and answered the third question in the affirmative. Because the question framed and answered by the High Court became redundant after the answer to the first question, that question and its answer were set aside as unnecessary. Accordingly, the appeals failed, save for a minor modification to the answer to the first question, and, subject to that modification, the appeals were dismissed.

In this case, the Court directed that the parties who had filed the appeals were required to pay all costs associated with those appeals. The order specified that the appellants were responsible for the entire expense of the proceedings, including any costs that had been incurred by the revenue authorities or the tribunal in connection with the appeals. In addition, the Court ordered that only a single hearing fee would be payable for the conduct of the hearing of the appeals. The provision of one hearing fee meant that the standard fee applicable to a hearing was to be charged only once, and no additional fees for multiple hearings would be imposed. Having made these financial orders, the Court concluded the matter by dismissing the appeals. The dismissal indicated that the Court did not find any merit in the appellants’ contentions and therefore upheld the previous determinations. Accordingly, the appeals were discarded and the orders of the lower authority remained in force. This final disposition reflected the Court’s determination that the appeals should not proceed further and that the appellants bore the financial burden of the proceedings. The Court’s order was effective immediately and no further procedural steps were required from the parties.