This weekly round-up analytically summarizes the key stories of the Customs, Excise, and Service Tax Appellate Tribunal ( CESTAT ) reported at taxscan.in, from June 02 , 2024 to June 08, 2024.
In a recent case, the Chennai bench of the Customs, Excise & Service Tax Appellate Tribunal ( CESTAT ) has held that laying up of cables alongside roads does not amount to ‘Manpower, Recruitment or Supply Agency Services’.
A two-member bench of Sulekha Beevi C S, Member (Judicial) and Vasa Seshagiri Rao, Member (Technical) observed that the appellant is undertaking work of trenching and laying cable for the areas allotted to them. There is no supply of labour by the appellant as the wages to the labourers are paid by the appellant. The amount received from BSNL is for trenching and laying of cable alongside the road.
The Bangalore bench of the Customs, Excise & Service Tax Appellate Tribunal ( CESTAT ) directed the Commissioner to reduce the redemption fine under the Customs Act, 1962 as the delay of consignment occurred due to the non-availability of the vessel.
Considering the unforeseen circumstances explained by the appellant, the two-member Dr D M Misra, Member (Judicial) and Mrs R Bhagya Devi, Member (Technical) directed to reduce the redemption fine to Rs.8,00,000/- (Rupees Eight Lakhs Only) and partially allowed the appeal.
The Chennai bench of the Customs, Excise, and Service Tax Appellate Tribunal ( CESTAT ) ruled that Sweet Pearl, which contained 99% maltitol crystals, is classifiable under the CTH of polyhydric alcohols, thereby setting aside the customs demand.
The two member bench of the tribunal comprising M. Ajith Kumar ( Technical member) and P. Dinesh ( Judicial member) concluded that the classification declared by the appellant deserves to be upheld since Revenue has not justified reclassification of the impugned goods under CTH 2106 and therefore, CESTAT set aside the impugned order and allowed the appeal.
The Chennai bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) ruled that the demand for service tax cannot be sustained under the construction of residential complex services and commercial/Industrial construction service.
The bench found that the decision laid down by the tribunal in the case of Real Value Promoters Pvt. Ltd.(supra) would be squarely applicable. The said decision has been followed by the tribunal in the case of Jain Housing & Construction Limited (supra) and was upheld by the apex court reported in by dismissing the department appeal. The two member bench of the tribunal comprising Vasa Sesha Giri Rao (Technical member) and Sulekha Beevi C.S (Judicial member) considered the opinion that the demand cannot sustain and required it to be set aside. Accordingly, the impugned order was set aside. The appeal was allowed.
The Bangalore Bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) held that the imports made for replacement of aircraft are eligible for customs duty exemption which is intended for servicing, maintenance or repair.
A Two-Member Bench comprising DM Misra, Judicial Member and R Bhagya Devi, Technical Member observed that “since the benefit is being extended to the parts of aircrafts owned by Government of India, these terms must be understood in terms of their usage and practice. Therefore, in order to understand its true meaning under the said Notification, reference must be made to the Aircraft Rules, 1937.” “The contention of the Revenue is that these goods are meant for replacement and upgradation, which cannot be considered as an activity of servicing, repairing or maintenance and therefore, the appellant is not eligible for the benefit of the Notification No. 12/2012- Cus., dated 17-3-2012, is devoid of merit.”
The Chennai Bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) allowed re-credit of customs duty in the advance authorisation strips and commented that the appellant cannot be worse off by reason of filing an appeal.
A Single Member Bench of CS Sulekha Beevi (Judicial) observed that “The appellant has paid the penalty and does not contest the same. So, the observation made by the Commissioner (Appeals) that since goods have been confiscated and penalty imposed, redemption fine has to be imposed is erroneous. Further, there is no appeal filed by the Department against the order of the Adjudicating Authority who refrained from imposing redemption fine. The Commissioner (Appeals) ought not to have imposed redemption fine in an appeal filed by the importer.” The Bench relied on the judgment in Jaswal Neco Ltd, wherein the Apex Court held that the appellant cannot be worse off by reason of filing an appeal.
In a recent case, the Delhi Bench of Customs, Excise, and Service Tax Appellate Tribunal (CESTAT) has held that mere filing of an appeal to challenge the order of the Tribunal or the High Court before the Apex Court is not really a valid ground to ignore or disregard the orders of the Tribunal, unless and until the same are stayed, suspended, or finally set aside.
The single bench of Binu Tamta (Judicial Member) has held that once the issue has been decided by the Tribunal that the appellant is entitled to the refund, the authorities below have no jurisdiction to order the recovery of the refunded amount unless the order of the Tribunal granting the refund is stayed or set aside by a higher forum. The tribunal held that the authorities below have absolutely no regard for the orders passed by the tribunal, though, as per the judicial discipline, they are binding on them and they are required to follow the same. There have been decisions after decisions by the Tribunal and also by the Apex Court, specifically conveying that the orders by the Tribunal are binding on the lower authorities and there is no reason to differ from the same.
The New Delhi bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) has held that exemption on service tax is allowable in respect of GTA services if are used in the export of goods and allowed the exemption to HEG Ltd.
A two-member bench comprising Justice Dilip Gupta, President and Hemambika R Priya, (Technical) observed that the appellant has complied with the notification condition and set aside the demand of duty and interest upheld in the impugned order. Further, it was held that the penalty under section 78 is imposed when there is a wilful intention to evade the payment of tax. The delay in filing the return for claiming the exemption cannot be termed as a wilful intention to evade payment of duty. The CESTAT set aside the penalties imposed under section 78 of the Act. While allowing the appeal, the Tribunal upheld the penalty under section 77 is upheld for failure to file the returns in time.
The Chennai Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) held that the assessable value of shampoo sachet is to be done under Section 4 of the Central Excise Act, 1944.
A Two-Member Bench comprising Vasa Seshagiri Rao, Technical Member and CS Sulekha Beevi observed that “Further, in the appellant’s own case vide Final Order N0.40032/2020 dated 28.01.2020, the Tribunal followed the above decision to set aside the demand raised under Section 4A and held that the determination of assessable value is to be done under Section 4 of the Central Excise Act, 1944. Following the decision of the Tribunal in the appellant’s own case for the earlier period, we are of considered opinion that the demand under Section 4A cannot sustain.”
The New Delhi bench of the Customs Excise & Service Tax ( CESTAT ) observed that the Customs Broker cannot be liable for the shifting of the client’s premises and the omission of the client to inform the authority and set aside the penalty imposed. It was found that once verification of the address is complete if the client moves to a new premises and does not inform the authorities or does not get his documents amended, such act or omission of the client cannot be held against the Customs Broker.
A two member bench of Ms Binu Tamta, Member (Judicial) and Mr P V Subba Rao, Member (Technical) held that the responsibility of the Customs Broker under Regulation 10(n) does not include keeping continuous surveillance on the client to ensure that he continues to operate from that address and has not changed his operations. Therefore, once verification of the address is complete as discussed in the above paragraph, if the client moves to a new premises and does not inform the authorities or does not get his documents amended, such act or omission of the client cannot be held against the Customs Broker.
The Chennai bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) has held that the liability under Works Contract Service would be taxable only from 1.7.2010 and set aside the demand of Commercial Complex Service ( CCS ).
Insofar as the penalty under RIPS is concerned, the two-member bench of P Dinesha, Member (Judicial) and M. Ajit Kumar, Member (Technical) held that the issue involved interpretation in as much as, the High Court of Delhi held that there was no liability to service tax insofar as the renting of immovable property was concerned and therefore, an amendment was brought in, to overcome the above judgement. The CESTAT held that the penalties imposed on the appellant also cannot sustain and set aside the impugned orders, insofar as the penalty is concerned and allow the appeals to this extent also.
In a recent case, the Chennai bench of the Customs, Excise And Service Tax Appellate Tribunal ( CESTAT ) held that the transaction of sale of shares cannot be considered as an activity promoting the business of the purchaser of shares and set aside the service tax demand under Business auxiliary service ( BAS ).
A two member bench of Ms Sulekha Beevi C S, Member (Judicial) and Mr Vasa Seshagiri Rao,Member (Technical) observed that the Tribunal itself in the appellant’s case had considered the very same issue and held that the demand could not be sustained as there is no provision of services. It was observed that “Whatever be the circumstances under which the shares were sold or the premium of the shares was fixed between the parties, the transaction of sale of a share in no way can be considered as an activity promoting the business of the purchaser of the shares. It is indeed the Sale of Shares and, therefore, the demand on this count cannot sustain and requires to be set aside, which we hereby do.” The CESTAT modified the impugned order to the extent of setting aside the demand, interest and penalties imposed under Business Auxiliary Services.
The Delhi Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) held that Benefit of section 28(5) Of Customs Act available when reduced penalty of 15% of BCD amount was paid within thirty days of receipt of Show Cause Notice ( SCN ).
The tribunal relied upon the decision of Gujarat High Court in the case of Prakash Diamond Pvt. Ltd. Vs. Union of India observed that “if the last date of a period within which an act is to be performed is a holiday, then the last date would be extended to the immediate next working day and the act would be said to be in compliance, if the same is performed on the immediately next working day by invoking the provisions of Section 10 of the General Clauses Act.” A Two-Member Bench comprising S.K. Mohanty, Member (Judicial) and P.V. Subba Rao (Technical Member) held that appellant would be liable to pay the reduced amount of penalty at the rate of 15%, which they have already complied with.
The Delhi Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) held that due to typographical error occurring in the bills of entry regarding Ambers of Internal Remote Electrical Tilt Switches ( iRET ) Switches imported penalty shall not be imposed.
However the bench confirmed that there was a typographical error in the Bills of Entry and the invoices which has resulted in the audit objection, the SCN and the impugned order. Thus, if there is a discrepancy between what is stated to have been imported in the documents and the Bill of Entry and what is actually imported, duty can be charged on what is actually imported and not on what is said to have been imported. A Two-Member Bench comprising Justice Dilip Gupta, (President) and P.V. Subba Rao (Technical Member) allowed the appeal filed by the appellant.
The Bangalore bench of the Customs Excise and Service Tax Appellate Tribunal (CESTAT), in the absence of evidence of the taxpayer’s authorization as a customs broker under Section 146 of the Customs Act, has reduced the penalty to Rs. 25,000.
The two member bench of the tribunal comprising P.A Augstian ( Judicial member) and Pullela Nageswara Rao ( Technical member) concluded that the impugned order was modified and appeal is partially allowed by setting aside revocation of Courier License and enforcement of Bond and Bank Guarantee executed in connection with the Registration/Issue of Courier License. In view of the discussion at Para 9 (supra), the penalty imposed on the appellant under Section 117 of the Customs Act, 1962 is set aside. The penalty imposed on the appellant under Regulation 14 of the Courier Imports and Exports (Electronic Declaration and Processing) Regulations, 2010 was reduced to Rs. 25,000/-(Rupees Twenty Five Thousand only)
The Bangalore bench of the Customs Excise and Service Tax Appellate Tribunal (CESTAT) has ruled that builders, promoters, developers, or any such persons constructing a residential complex shall be liable to pay service tax.
However, since the required documents as proof of payment of service tax as well as non-collection of same from the buyers was not produced by way of documents, their refund claim was rejected by the original authority as well as by the first appellate authority. The single member bench of the tribunal comprising Pullela Nageswara Rao (Technical member) concluded that the required documents are not brought on record even in the appeal before this Tribunal and the appellant has not appeared for hearing on the last three occasions. Accordingly, the appeal filed by the appellant was dismissed.
The Bangalore bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) has set aside the penalty under Section 117 of the Customs Act, 1962, citing no import of prohibited or restricted goods.
The two member bench of the tribunal comprising P.A Augustin ( Judicial member ) and Pullela Nageswara Rao ( Technical member) concluded that the appeal was allowed by setting aside revocation of courier license and enforcement of Bond and Bank guarantee executed in connection with registration/license. Penalty imposed on the appellant under Section 117 of the Customs Act, 1962 was set aside.
The Bangalore bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) has dismissed the Revenue’s appeal, ruling that the pole shoe is an internal part of Wind Operated Electricity Generators ( WOEG ) and is eligible for excise duty exemption.
The two member bench of the tribunal comprising DM Misra ( Judicial member ) and R, Bhagya Devi (Technical member) found merit in the appeal filed by the revenue. Consequently, the impugned order was upheld and the revenue’s appeal being devoid of merit is liable for dismissal. Since, CESTAT have decided the appeal on merit, other ancillary issues like reversal of cenvat credit and quantification of demand etc. become academic; hence not analysed. Revenue’s appeal dismissed.
The Chennai bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) ruled that the waste product such as bagasse is not an excisable goods.
The two member bench of the tribunal comprising M. Ajith Kumar (Technical member) and P. Dinesh (Judicial member) observed that the waste product was not a manufactured product to be considered as a final product for the purpose of Cenvat Credit Rules. Consequently, no credit is required to be reversed. Rule (6) of Cenvat Credit Rules as it stood then, could be invoked only in case of products which were excisable in nature, which are manufactured and not waste products that emerge on account of the process of manufacture of a different product. Accordingly, the ground raised by the appellant was allowed.
The Chennai Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) held that royalty not includable in transaction value of imported raw materials to demand differential customs duty.
A Two-Member Bench comprising Vasa Seshagiri Rao, Technical Member and CS Sulekha Beevi, Judicial Member observed that “In view of aforesaid discussions and the judicial precedents cited above, we are inclined to hold that Royalty payment is not includible in the transaction value of imported raw materials. Thus, the issue of inclusion of Royalty payment in the transaction value of the imported raw materials is decided in favour of the Appellant and we order so accordingly.”
The Chandigarh Bench of Customs, Excise, and Service Tax Appellate Tribunal ( CESTAT ) has held that a redemption fine is not imposable when the minimum import price paid on prime pre-painted steel coils and quashed the penalty under the Customs Act, 1962.
The single bench of S. S. Garg (Judicial Member) has observed that the appellant has already paid the Minimum Import Price (MIP) for the goods as fixed vide Notification No. 38/2015-2020 dated 05.02.2016 issued by the DGFT, by which impugned goods cannot be imported with a value less than the MIP. The CESTAT held that in the order passed by the Commissioner (Appeals), sufficient reasons have not been given for imposing the redemption fine and penalty. There was no attempt by the appellant to mis-declare the description or transaction value. Once the confiscation is set aside, the question of the imposition of a penalty under Section 112(a) does not arise.
The Chennai Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) quashed re-determination of MRP of laptops imported by Acer India supplied with laptop bag by the Customs Department.
A Two-Member Bench comprising Vasa Seshagiri Rao, Technical Member and CS Sulekha Beevi, Judicial Member observed that “The methodology adopted by adjudicating authority is to deduct the negotiated price of the backpack (Rs.225/-) from the Purchase order price. The Purchase order Price or bid price is inclusive of items which are not imported. Further, the department has no case that such backpack can be obtained at Rs.225/- from market. All these factors would lead to the conclusion that the redetermined MRP cannot be sustained. Consequently, the demand of differential duty also cannot be sustained and require to be set aside. Ordered accordingly.”
The Chennai Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) quashed the denial of excise duty exemption on molasses captively consumed in rectified spirit and extra neutral alcohol ( ENA ).
A Two-Member comprising of M Ajit Kumar, Technical Member and P Dinesha, Judicial Member observed that “The only issue to be considered by us is, “whether the Revenue is justified in denying the benefit of exemption Notification No.67/95 dated 16.3.1995?” We agree with the contention of the Advocate that this Bench has considered almost identical issue, in their own case, to hold that the denial of exemption Notification No.67/95 was incorrect, for the reasons discussed therein, by also relying upon an earlier order of Chennai Bench in the case of Sri Ambika Sugars Ltd.”
The Chennai Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) quashed penalty imposed on Customs Broker ( CB ) in the absence of mens rea.
A Single Member Bench of P Dinesha, ( Judicial ) observed that “I have gone through both the orders relied upon by the rival parties; in the case of M/s. Seaswan Shipping and Logistics, the issue relates to the penalty under Section 114 of the Customs Act and hence, the ratio of said order is not squarely applicable to the facts of this case although the penalty under Section 114 has been upheld on the customs broker for alleged violations therein. In the case of M/s. Max Miller Agencies this Bench has considered an almost similar issue and after considering several judicial pronouncements has found it proper to delete penalty imposed for violations of regulation in 10 (d) and 10 (e).”
The Bangalore Bench of the Customs, Excise and Service Tax Appellate Tribunal ( CESTAT ) held that the Manufacture of display material falls under ‘Trading Advertising material’ thereby attracting nil rate of duty.
A Two-Member Bench comprising DM Misra, Judicial Member and R DM Misraevi, Technical Member observed that “Applying the meaning of ‘Furniture’ as explained by the Hon’ble Supreme Court to the case in hand, it cannot be construed that the display material which has been supplied by the appellant after procuring skeleton- fabricated frames and affixing/pasting the printed material on the same in their premises would result into ‘manufacture’ of furniture. On the other hand, the purpose and object of the supply of the said printed materials on the procured frames by the appellant would safely be considered as for the primary purpose of advertisement and covered under the scope of Tariff Subheading 4911 1090 as ‘Trading Advertising material’.
The Allahabad Bench of Customs, Excise, and Service Tax Appellate Tribunal ( CESTAT ) has held that Dish TV is entitled to 100% credit as the set top boxes satisfy the definition of ‘Inputs’.
The two-member bench of P. K. Choudhary ( Judicial Member ) and Sanjiv Srivastava (Technical Member) has observed that the set-top boxes satisfy the definition of inputs as they are goods used by the output service provider for the provision of the output services. There cannot be any fallacy in the stands taken by the appellant in taking the entire credit at the time of receipt of these set-top boxes as inputs.
The Allahabad bench of the Customs, Excise & Service Tax Appellate Tribunal ( CESTAT ) abated the appeal under Rule 22 of the Custom, Excise & Service Tax Appellate Tribunal Procedure Rules, 1982, as no application was made by official liquidator appointed by the National Company Law Tribunal ( NCLT ) in the matter for the continuance of the appeal before tribunal even after expiry of more than five years from the date of the NCLT order.
A two-member bench of Mr P K Choudhary, Member (Judicial) and Mr Sanjiv Srivastava, Member (Technical) observed that undisputedly in terms of the order dated 20.09.2018, the National Company Law Tribunal has directed for winding up of the appellant company and have appointed official liquidator in the matter. No application as per Rule 22, has been made by the official liquidator appointed by the NCLT in the matter for the continuance of the appeal before tribunal even after expiry of more than five years from the date of the NCLT order. The CESTAT held that “ appeal abates in terms of Rules 22 of Custom, Excise & Service Tax Appellate Tribunal Procedure Rules, 1982. “
The Bangalore bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) reduced the penalty to 5 lakhs for the attempted improper export of confiscated goods under Section 113 of the foreign exchange Regulation Act, 1947. The bench considered other penalization faced by the appellant.
However, the two member bench of the tribunal comprising D.M Misra (Judicial member) and R. Bhagya Devi (Technical member) taking into consideration the fact that all the DEPB licenses were cancelled and the DEPB credit of Rs.98,54,987/- was denied, and the exporter having penalised, it would be fair to reduce the penalty to Rs.5, 00,000/- on each of the Appellants. Accordingly, the penalty stands reduced to Rs.5, 00,000/- on appellant 1 (Surendran) and Rs.5, 00,000/- (rupees five lakhs only) on appellant 2 (Ashok Shukla) Rs.5, 00,000/-. Accordingly, appeals were partially allowed.
The Bangalore bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) has ruled that the renting of immovable property, including vacant land owned by a corporation, falls within the scope of taxable service.
Therefore, the two member bench of the tribunal comprising D.M Mishra (Judicial member) and R. Bhagya Devi (Technical member) set aside the demand for the extended period and restricted it to the normal period of limitation. Therefore, since the demand except for telecom services are barred by limitation, the matter was being remanded for redetermination of the taxes based on tribunal observations under each category. While redetermining the same, the written submissions dated 19.10.2023 filed by the appellant with regard to the factual errors and duplication of taxes need to be considered. An opportunity of being heard was to be provided before redetermination of the demands to the appellants. All penalties are set aside, accordingly, appeal was allowed by way of remand.
The Chennai bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) remanded the case to the adjudicating authority, stating that the municipality is liable to pay service tax under Renting of Immovable Property Services and other related services.
Further considered opinion, that in the interest of justice, these matters also require to be remanded to the Adjudicating Authority to consider afresh the issue as to whether Municipality is liable to pay service tax under renting of immovable property services and other services. It is to be noted that some of the amounts falling within the demand pertain to fees and charges collected for carrying out functions specifically listed in 12th Schedule. Further, all these services are carried out as per the provisions of Coimbatore City Municipal Corporation Act, 1981. The State (Tamil Nadu) has bestowed the local authority vide the above enactment to carry out certain functions and services in consequence to Article 243X read with Article 243W of the constitution. These issues have to be examined in detail. If the activities are in discharge of sovereign right / function, the levy of service tax cannot be attracted. Accordingly, the two member bench of the tribunal comprising Vasa Sesha Giri Rao (Technical member) and Sulekha Beevi CS (Judicial member) concluded that the impugned orders were set aside. The appeals were allowed by way of remand to the Adjudicating Authority
The Chennai bench of the Customs Excise and Service Tax Appellate Tribunal ( CESTAT ) granted relief to Tata Steel Downstream by permitting the adjustment of their Service Tax liability from credit, in accordance with Rule 6(3) of the Service Tax Rules, 1994
The bench found that the appellant was not contesting the service tax excess paid in respect of 2nd and 3rd supplementary invoices. Further the single member bench of the tribunal comprising Vasa Sesha Giri Rao (Technical member) affirmed the decision of the lower appellate authority holding that the appellant is eligible for adjustment of the service tax liability on the subsequent supplementary invoice raised against the excess service tax paid on the original supplementary invoices which were not paid by their customer Viz., M/s. Tata Steel Limited. Further found that the appellant has submitted Chartered Accountant’s Certificate to the effect that they have canceled 3 supplementary invoices raised originally and that they have not received any consideration in respect of these invoices. Accordingly, the impugned Order-in-Appeal dated 28.10.2022 was not sustainable and ordered to be set aside. The appeal was allowed with consequential relief.
The Chennai bench of the Customs Excise and Service Tax Appellate Tribunal (CESTAT) has directed that the municipality is liable to pay service tax under Renting of immovable property services and remanded the case to the adjudicating authority.
The two member bench of the tribunal comprising Vasa Sesha Giri Rao (Technical member) and Sulekha Beevi C.S (Judicial member) observed that these matters also require to be remanded to the adjudicating authority to consider afresh the issue as to whether Municipality is liable to pay service tax under renting of immovable property Services as well as other demands on the basis of the above observations and judgements rendered by jurisdictional High Court. Further, services are carried out as per the provisions of Panchayat Act, Municipalities Act etc. by which State has bestowed the local authority to carry out such functions and services. These issues require to be examined. If sovereign functions, the levy of tax cannot be attracted.
The Chennai bench of the Customs, Excise, and Service Tax Appellate Tribunal ( CESTAT ) deemed the service tax demand on landowner shares in a residential complex under construction as unsustainable.
Further, the two member bench of the tribunal comprising Vasa Sesha Giri Rao ( Technical member ) and Sulekha Beevi C.S ( Judicial member ) observed that the tribunal in the case of Srinivasa Shipping & Property Developers Ltd. ( supra ) on a similar set of facts and issues had held that the demand under residential complex services cannot sustain. CESTAT held that the demand raised under construction of residential complex services cannot sustain. Accordingly, the impugned order was set aside. The appeal was allowed.
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