Ramaswami, C.J.

(1) In this case the assesses, Maharajadhiraj of Darbhanga, floated a private limited company called "The Newspapers and Publications Limited" (hereinafter referred to as the Company) having an authorised capital of Rs. 25,00,000/- made up of 25,000 shares of Rs. 100/- each. The first paragraph of the Memorandum of Association of the Company states as follows: -

"As a first operation to acquire, purchase, take over or agree to take over by private treaty or in any other lawful manner whosoever as a going concern the undertakings now being carried on under the names and styles of the "Indian Nation" and the Aryavarta newspapers and the Indian Nation Press along with all or any of the stock-in-trade, rights, assets, interests, liabilities and obligations of the said undertakings with all their advantages, goodwill, licenses and privileges as standing on ...... and pay for such rights and privileges in cash or in shares or partly in cash and partly in shares of the company (as may be agreed upon between the parties), and to carry on the said business along with other business mentioned in the other succeeding sub-Clauses of this clause of the Memorandum of Association."

In pursuance of the above object the Company took over with effect from the 30th September, 1948, the business of publication of the two newspapers Indian Nation "Aryavarta as a going concern along with its assets and liabilities. The consideration for the transfer was Rs. 32,50,000/-to be satisfied by the allotment to the Maharajadhiraj of fully paid up shares of the requisite amount. Though a formal deed of sale was not immediately drawn up, the agreement was followed by the actual delivery of possession to the Company of the movable and immovable assets. To place the transaction on a proper basis, a sale deed was executed on the 1st June, 1950, and registered on the 12th August, 1950, on stamp paper of Rs. 8,435/10/- confirming the transaction which had already been effected on the 30th September, 1948. In consideration of the sale made on the 30th September, 1948, of the business, with its assets and liabilities, the Company passed a resolution on the 6th November, 1948, allotting 12,500 fully paid up shares of Rs. 100/-each to the assessee. The assessee also paid in cash for a further allotment of 12,500 share of Rs. 100/- each. As desired by the assessee, however, 24,950 shares were allotted in the name of the assessee himself and the balance of 50 shares was allotted in the names of his nominees as follows: - (1) Raja Bahadur Vishweshara Singh -- 10 shares. (2) Pundit Girindra Mohan Misra -- 10 shares. (3) Kumar Ganganand Singh -- 10 shares, (4) Pundit Vaidyanath Jha -- 10 shares, (5) Mr. G. P. Danby -- 10 shares. The sale-deed dated the 1st June, 1950, recites that the value of the movables was determined after due and proper assessment to be Rs. 8,41,000/ - and the consideration thereof was satisfied by the allotment of 80,410 fully paid up shares of the Company. The machinery and plant of the business were included amongst the movables. As regards the immovable properties, the sale-deed recites that they were valued at Rs. 4,09,000/- which was satisfied by the allotment of 4,090 shares. According to the records of the assessee, the original cost of the building was Rs. 49,270/-, and the original cost of the machinery and plant was Rs. 2,30,552/-. The written down value of the building on the 3oth September, 1948, was Rs. 29,669/-, and the written down value of the plant and machinery on the same date was Rs. 119,368/-. Since the value, according to the bale-deed; of the movable and immovable properties was in excess of the written down value, the Income-tax Officer held that the assessee was liable to be taxed on the difference between the two amounts, namely, the sum of Rs. 1,30,785/-, under the second proviso to Section 10 (2) (vii) of the Indian Income-tax Act. The Income-tax Officer also noticed that the assessee himself in his account books took credit for a net profit of Rs. 2,50,000/-out of the transaction and credited the amount to his capital account. The assessee took the matter in appeal and contended that since he practically owned all the shares of the limited company, there was no material difference between the vendor and the vendee and the transaction was not in reality a sale. The appellate Assistant Commissioner rejected the contention, holding that since the Company was a separate legal entity, it could not be identified with the assessee in his individual capacity. The assessee made a further appeal to the Income-tax Appellate Tribunal, but the appeal was dismissed.

(2) Under Section 66 (2) of the Indian Income-tax Act the Income-tax Appellate Tribunal has stated a case on the following question of law:-

"Whether under the facts and circumstances of the case the amount of Rs. 1,30,785/- (Rupees one lakh thirty thousand seven hundred and eighty-five) only being the excess of sale proceeds of the building, plant and machinery over the written down value thereof could in law be termed to be income profits and gains of the petitioner "

(3) The argument presented on behalf of the assessee is that the transaction of the 30th September, 1948, was not a sale by the appellant to the newly floated private limited company. It was submitted that in substance the assessee owned practically all the shares of the Company and it was open to the High Court to lift the veil of corporate entity and look behind the same in order to see who were the real parties to the transaction. It was submitted that the Company was not distinct and separate from the assessee himself and that the present case comes within the doctrine that no man can make a profit out of himself. I see no warrant for accepting the submission made on behalf of the assessee. From the juristic point of view the Company is a legal personality entirely distinct from its members, and the Company is capable of enjoying rights and of being subjected to duties which are not the same as those enjoyed or borne by its members. An illustration of the principle is the decision of the Court of Appeal in John Foster and Sons, Ltd. v. Commrs. of Inland Revenue, (1894) I QBD 516. In that case there was a deed between eight partners composing a firm of the first eight parts, and a limited company of the ninth part, and there was a recital in the deed that the partners were desirous that their business should be reconstructed as a limited company, and had agreed that the whole of the undertaking, property, and liabilities of the firm should be transferred to a company, to be formed of all the partners in the firm exclusively, for the purpose of taking over the same; and that there should be allotted amongst the partners, in proportion to their shares in the partnership, the whole of the shares in the Company. The deed then recited that such a company had been registered, and that all its shares were taken and held by the partners in specified proportions; and it was thereby witnessed that, "in pursuance of the said arrangement, and for the purpose of giving effect to the said scheme, and of vesting the real estate of the partnership in the company, the eight partners conveyed and assigned to the company ail the real estate and trade-marks of the partnership. It was held by the Court of Appeal in these circumstances that the deed was a transfer of property from individuals to a corporation in consideration of "stocks or securities" within the meaning of Section 71 of the Stamp Act, 1870, and that accordingly it was a "conveyance on sale" chargeable with an ad valorem duty within the schedule to the Act; and it was nonetheless so because the eight partners who conveyed the property were also the individuals who constituted the corporation. At p. 527 of the report Lindley, L. J., states:-

"Now, the document in this case is an indenture made between eight gentlemen of the first eight parts, and John Foster and Sons, Limited (hereinafter called the company) of the 9th part. Pausing there for a moment : although the persons of the first eight parts may be, and were members, and the only members, of John Foster and Company, Limited, John Foster and Company Limited, is not those eight individuals; John Foster and Company Limited, is a corporation. We have accordingly two parties, one party consisting of several individuals, and the other party consisting of a corporation. Whether they are or are not the members, or the only members of the corporation, is wholly immaterial. The corporation, is a totally different person from them in any capacity you choose to assign to them except a corporate one."

At p. 529 of the report Kay, L. J., observed as follows; -

"Now, that there was a conveyance is beyond all question. The persons who are named as vendors in the deed have divested themselves of their property in the subject of that conveyance, and all that property is vested in an entirely independent and separate body -- namely, a corporation. Suppose that corporation had consisted of altogether different persons, no one for a moment would doubt that this was a conveyance on salt. Suppose there had been one person in it different, there is nothing that I have heard in the argument which induces me to suppose that even, in that case it could have been doubted that this was a conveyance on sale. But the argument, as I understand it, is this -- that the individual corporators who composed that corporation were, in fact, the very identical persons who were conveying this property to the corporation, and the corporation bad no other property except this which it took under its conveyance; and that, as the only value of the shares and debentures was derived from this very property which the individual corporators were conveying to the corporation, the conveying partners either got no consideration for that which they conveyed, other than part of the property actually conveyed, or they got no consideration at all. Now, I do not fellow that argument in the least. I think it is a fallacy from beginning to end. In the first place, a corporation is a different thing from the individuals who compose it; and, secondly, the shares and debentures of a corporation are not the same thing as the property which that corporation owns."

A. L. Smith, L. J., the third member of the Court of Appeal, also expressed a similar view. The same principle underlies the decision of the Court of Appeal in Ryhope Coal Co., Ltd. v. Foyer, (1881) 7 QBD 485. The leading case on "this-topic is Salomon v. Salomon and Co., 1897 AC 22 in which the House of Lords refused to identify a Company with its controlling share-holders so that" the latter could claim the preferential rights of a bond-holder against the Company to the detriment of its genuine creditors. "It has become the fashion", said Lord Macnaghten, "to call companies of this class one-man companies. That is a taking nickname, but it does not help one much in the way of argument. If it is intended to convey the meaning that a company which is under the absolute control of one person is not a company legally incorporated, although the requirements of the Act of 1862 may have been complied with, it is inaccurate and misleading. If it merely means that there is a predominant partner posses sing an overwhelming influence and entitled practically to the whole of the profits, there is nothing in that that I can see contrary to the true intention of the Act of 1862 or against public policy or detrimental to the interests of the creditors. If the shares are fully paid up, it cannot master whether they are in the hands of one or many. If the shares are not fully paid, it is as easy to gauge the solvency of an individual as to estimate the financial ability of a crowd." Lord Halsbury stated as follows:-

"Either the limited company was a legal entity or it was not. If it was, the business belonged to it and not to Mr. Salomon. If it was not, there was no person and no thing to be an agent at all. It is impossible to say at the same time that there is a company and that there is not."

The principle of Salomons case has been reaffirmed by the House of Lords in Commrs. of Inland Revenue v. John Sansom, (1921) 8 Tax Cas 20. In that case all the shares of a limited company save one were owned by one man, Mr. Sansom, who had turned his timber business into a company. The company never distributed any dividends, but it made loans to Mr. Sansom at different times, without security and without interest. The company went into voluntary liquidation. The loans were not repaid, but were taken into account when Mr. Sansom received his share of the assets in the liquidation. It was sought to charge Mr. Sansom with super-tax on the loans. The special commissioners of income-tax, however, discharged the assessment on the ground that the company was a properly constituted legal entity, that it had power to make loans to such persons, and on such terms, as it should think fit, and that it did make such loans to Mr. Sansom. On appeal to the Kings Bench Division, Rowlatt, J., ordered the case to he remitted to the special commissioners on the ground that they had not found as a fact that the business had been carried on by the company or that it had really been carried on by the assessee to the exclusion of the company. The assessee appealed against Rowlatt his order remitting the case to the special commissioners. The Court of Appeal set aside the order of Rowlatt, J., on the ground that the existing findings of the commissioners involved, the view that the business was the property of the company, and, therefore, negatived the possibility that the company was carrying on, as agent for Mr. Sansom, a business which belonged to Mr. Sansom. The same view has been expressed by the Judicial Committee in a later case, E. B. M. Co., Ltd. v. Dominion Bank, (1937) 3 All ER 555. In that case a bank accepted a document as an additional security for an advance to three partners, who, in addition to and apart from the partnership, were directors of a limited company. The document in question charged the companys interest in certain bonds which had been deposited with the bank to meet any judgment which might be obtained against the company in them impending litigation. The document was signed by the three partners and the companys seal was affixed thereto, accompanied by the signature of one of the partners as President and of another as secretary of the company. No resolution was ever passed, either by the company or by the directors, authorising the creation of the charge. The partners held all the shares in the company except two which were held by two other directors of the company. The litigation against the company was concluded substantially in the companys favour, and the bank claimed the balance of the proceeds of sale by the bonds in reduction of the partners indebtedness. It was held in these circumstances by the Judicial Committee that as the company, acting through its directors, and not by its shareholders in general meeting, had purported to apply its property for the benefit of those directors, the transaction was unenforceable, and the Court would not inquire whether the company had derived any benefit from it. The bank was therefore, bound to account to the company for the balance of the proceeds of sale of the bonds. At p. 564 of the report Lord Russell of Killowen states as follows.

"Their Lordships are unable to support the decision in favour of the bank upon the grounds suggested by Riddell, J. A. They believe it to be of supreme importance that the distinction should be clearly marked, observed and maintained between an incorporated companys legal entity and its actions, assets, rights and liabilities on the one hand, and the individual share-holders and their actions, assets, rights and liabilities on the other hand, Masten, J. A., (whose judgment was concurred in by Latchford, C. J. A. and Fisher, J. A.) was of opinion that the company was not a sham or cloak for the three partners, and did not act as agent for them. He drew attention (and rightly, as their Lordships think) to the grave risk of introducing confusion into the settled principles of company law."

It is also well established that a person veiled by the mask of corporate personality cannot be allowed to pierce the veil himself for his own benefit. In other words, the owner of all the shares in a limited company cannot claim to be treated as if he were identical with the limited company in order to promote his own benefit or advantage. This view is supported by a decision of the House of Lords in Macaura v. Northern Assurance Co., Ltd., 1925 AC 619, in which a corporator holding all the shares of a limited company insured against fire the timber belonging not to him but In the company. The corporator insured the timber in his own name and not in the name of the company. It was held by the House of Lords that he had no insurable interest in the timber.

(4) It is true that in certain exceptional cases the Court is entitled to lift the veil of corporate entity and to pay regard to the economic realities behind the legal facade, or legal mask. The 1st exception is where there is fraud or improper conduct. For example, the Courts will not allow company promoters to conceal the profits which they are making by operating through dummy companies (In Re Darby, (1911) I KB 95) and will insist that disclosure of profits must be made not to a board of dummies but to the members, actual and intended. Perhaps the best illustration of this class of cases is afforded by Gilford Motor Co. v. Horne, (1933) Ch 935. In that case Home, a former employee of the plaintiffs, had covenanted not to solicit its customers. He formed a company to carry on his business and it Undertook the solicitation. An injunction was granted against both with him and the company to restrain them. The company was described in the judgment of the Court of Appeal as "a mere cloak or sham". On the basis of rather similar principles the Court will pay regard to the substance rather than to the form in deciding whether an agreement is void as conflicting with public policy. A good illustration is afforded by the decisions on restraint of trade. The leading case of Nordenfelt v. Maxim Nordenfelt Guns and Ammunition Co., 1894 AC 535 establishes that a covenant in restraint of trade is normally valid when entered into by the seller of goodwill (as opposed to an employee), and that for this purpose a covenant by a share-holder and managing director on a sale by the company is treated as a covenant by a seller and not subjected to the stricter rules applying to an employee. In Connors Bros. Ltd. v. Connors, (1940) 4 All ER 179 the Judicial Committee extended this rule to the case of covenant entered into by the managing director on the sale by him and others of a controlling interest in the share capital of the company. Again the Courts will look behind the facade of the company and its place of registration in order to determine its residence. For this purpose the test laid down has long been the place of its "central management and control". Normally this place will be that where the board of directors function, but it might, no doubt, be the place of business of the, managing director (especially if he held a controlling interest), or that of a parent company. The question of residence is important mainly in connection with taxation Union Corporation v. I. R. C., (1952) 1 All ER 646, but it may also govern enemy status (Daimler Co., Ltd v. Continental Tyre and Rubber Co., (1916) 2 AC 307) or subjection to the jurisdiction of English or foreign Courts.

(5) Apart from, these exceptions the strict formalism of Salomons case, 1897 AC 22 still prevails, and I think the principle laid down in that case must govern the decision of the present case which is not covered by any of the well known exceptions to the application of that rule. In my opinion it is not possible, in the circumstances of this case, to ignore or disregard the mask of corporate; entity or to analyse the economic realities behind the transaction of sale. In my opinion the Income-tax Tribunal has correctly taken the view that the limited Company is a separate juridical person and so there was a transaction of sale between the assessee and the limited Company and the assessee is liable to be taxed for the excess of sale proceeds over the written down value under the second proviso to Section 10 (2) (vii) of the Indian Income-tax Act,

(6) On behalf of the assessee reference was made by learned Counsel to the decision of the Supreme Court in Kikabhai Premchand v. Commr. of Income-tax (Central) Bombay, (1953) 24 ITR 506 [LQ/SC/1953/85] : (ATR 1953 SC 509) [LQ/SC/1953/85] in support of his argument. In that case the assessee was a dealer in silver and shares and he was the sole owner of the business. The assessee maintained his accounts according to the mercantile system and valued his stock at cost price both at the beginning and at the end of a year. During the relevant year of account the assessee withdrew some silver bars and shares from the business and settled them on certain trusts in which he was the managing trustee. In his books of account the assessee credited the business with the cost price of the bars and shares so withdrawn. The Income-tax Authorities held that the assessee derived income from the stock-in-trade thus transferred and assessed him on a certain sum being the difference between the cost price of the silver bars and shares and their market value at the date of their withdrawal from the business. The Appellate Tribunal and the High Court upheld the action of the Income-tax Authorities, but the Supreme Court held that no income arose to the assessee as a result of the transfer of shares and silver bars to the trustees. In my opinion, the principle laid down in this case has no application to the present case. In the Supreme Court case the crucial facts were that there was no sale by the assessee to the trustees and moreover the Income-tax Department accepted as correct the entry in the books of account of the assessee and also accepted the system of accounts adopted by the assessee. It is manifest that the material facts of the present case are different and the principle laid down by the Supreme Court is of no avail to the assessee in the present case. On behalf of the assessee reference was also made to the decision of the Privy Council in Doughty v. Commr. of Taxes, 1927 AC 327. In that case two partners carrying on business in New Zealand 33 general merchants and drapers sold the partnership business to a limited company in which they became the only share-holders. The sale was of the entire assets, including goodwill, the consideration being fully paid shares, and an agreement by the company to discharge all the liabilities. The nominal value of the shares being more than the sum to the credit of the capital account of the partnership in its last balance sheet, a new balance sheet was prepared showing a larger value for the stock in trade. The Commissioner of Taxes treated the increase in value so shown as a profit on the sale of the stock in trade, and assessed the appellant upon it for income-tax under the Land and Income-tax Act, 1916, of New Zealand. In these circumstances it was held by the Judicial Committee that the assessment was wrongly made because if the transaction was to be treated as a sale there was no separate sale of the stock and no valuation of it as an item forming part of the aggregate sold. It was conceded by Lord Phillimore, who delivered the opinion of the Judicial Committee that if the business be purely one of buying and selling, a profit made by the sale of the whole of the stock, if it stood by itself, might well be assessable to income-tax. But upon the facts Lord Phillimore held the view that it was a "slump transaction" and no sum could be pitched upon as the actual price of the stock. It is manifest that in the present case there is no question of any "slump transaction" and the principle laid down by the Judicial Committee has no application. Lastly, learned Counsel for the assesses relied strongly upon the decision of the Bombay High Court in Commr. of Income-tax, Bombay City v. Sir Homi Mehtas Executors, (1955) 28 ITR 928 [LQ/BomHC/1955/154] : (AIR 1956 Bom 415 [LQ/BomHC/1955/154] ). In that case the assesses and his sons formed a private limited company and transferred to that company shares in several joint stock companies which the assessee had held jointly with his sons, for Rs. 40,97,000/- which was the market value of the shares at that time. It was found that these shares had cost to the assessee only Rs. 30,45,027/- and the Income-tax Authorities levied income-tax on the difference between the market price and the cost price of the shares on the ground that the assessee had made a profit to that extent by this transaction. It was held by Chagla, C. J. and Tendolkar, J., in these circumstances that though the assessee and his sons on the one hand and the private limited company formed by them were distinct entities, there was in reality no sale because Sir Homi Mehta and his sons as individuals were selling the shares to themselves constituted as a different legal entity, and so the principle that a vendor cannot make profit out of himself must be applied to the case. It is true that this decision supports the argument of the assessee, but with the greatest respect to the learned Judges of the Bombay High Court I think that this case has not been correctly decided and I express my dissent from that decision for the reasons I have already given.

(7) I shall then proceed to consider the argument addressed on behalf of the assessee that in any event there was no cash receipt and the assessee merely received fully paid up shares of the Company in consideration of the sale. It was submitted on behalf of the assessee that the second proviso to Section 10 (2) (vii) of the Indian Income-tax Act does not apply to a case in which the sale proceeds were given in the shape of paid up shares and not in terms of cash. I am unable to accept this argument as correct. Profits in the legal sense are received in the shape of money or moneys worth. It is well established by numerous authorities that income received in kind as well as in cash and receipt of anything equivalent of cash is receipt of Income. In California Copper Syndicate Ltd. v. Harris, (1905) 5 Tax Cas 159 a company which was formed for acquiring and reselling properties sold certain property for fully paid shares in another Company and it was held that the difference between the purchase price of such property and the value of the shares for which the property was exchanged was a profit assessable to income-tax. It was contended on behalf of the Company that there was no realised profit, since the shares had not been sold. Lord Trayner dealt with the contention as follows: -

"A profit is realised when the seller gets the price he has bargained for. No doubt here the price took the form of fully paid-up shares in another company, but, if there can be no realised profit, except when that is paid in cash, the shares were realisable and could have been turned into cash, if the appellants had been pleased to do so."

The same principle has been enunciated by the House of Lords in Westminster Bank, Ltd. v. Osier, 1933 AC 139, where the bank surrendered certain holdings of National War Bonds in exchange for other Government securities, and the Crown claimed tax on the excess value of the substituted over the original securities. The question was whether these transactions were the equivalent of a realisation of the original holdings and it was held by the House of Lords that they were such an equivalent. "The exchange effected in the present case," said Lord Buckmaster in the course of his judgment, "was in fact the exact equivalent of what would have taken place had instructions been given to sell the original stock and invest the proceeds in the new security." The bank, therefore, in effect realised its profit, for it had received it in moneys worth of a definitely ascertained amount. The principle has been reiterated by the House of Lords in a recent case, Gold Coast Selection Trust, Ltd. v. Humphrey, (1948) 2 All ER 379. In that case a trust company acquired concessions for land considered likely to bear gold, and on July, 28, 1934, agreed to sell it to the M. Company in consideration of "the sum of 800,000, which shall be paid and satisfied by the allotment and issue to the vendor of 3,200,000 shares of 5 shillings each credited as fully paid up." On November 30, 1934, the shares were duly allotted. The books of the trust company showed the cost to themselves of the occasions to have been 107,875. The question arose what figure, if any, ought to be included in the profits and gains of the trust for the year ending April 5, 1935. It was held by the House of Lords that although inability to realise in a commercial sense an asset such as a block of shares in the year of receipt might be a reason for reducing its valuation, it was not correct to say that for that reason it could not be valued in money for income-tax purposes in that year. In the course of his speech Viscount Simon observed as follows:

"In my view, the principle to be applied is the following: In cases such as this, when a trader in the course of his trade receives a new and valuable asset, not being money, as the result of sale or exchange, that asset, for the purpose of computing the annual profits or gains arising or accruing to him from his trade, should be valued as at the end of the accounting period in which it was received, even though it is neither realised or realisable till later. The fact that it cannot be realised at once may reduce its present value, but that is no reason for treating it, for the purposes of income-tax, as though it had no value until it could be realised. If the asset takes the form of fully paid shares, the valuation will take into account not only the terms of the agreement, but a number of other factors, such as prospective yield, market ability, the general outlook for the type of business of the company which has allotted the shares, the result of a contemporary prospectus offering similar shares for subscription, the capital position of the Company, and so forth. There may also be an element of value in the fact that the holding of tile shares gives control of the company. If the asset is difficult to value, but is none the less of a money value, the best valuation possible must be made. Valuation is an art, not an exact science. Mathematical certainty is not demanded, nor, indeed, is it possible."

(8) Lastly it was submitted on behalf of the assessee that the accounting year in this case was the period from the 1st October 1948, to the 30th September, 1949, and since the sale took place on the 30th September, 1948, the assessed could not be taxed under the provisions of Section 10(2) (vii) of the Indian Income-tax Act. I do not think there is any substance in this argument. Before the Income-tax authorities it was never the case of the assessee that the relevant account year in this case was not the Fasli year 1356 but the period from 1st October, 1948 to the 30th September 1949. No such argument was also put forward on behalf of the assessee when the case went to the Supreme Court. I rind that the Income-tax Appellate Tribunal has observed in the statement of the case that the accounting year of this transaction is the Fasli year 1356, namely the period from 19th September, 1948 to the 7th September, 1949 and it is not open to the assessee in this reference to go behind this statement of fact made by the Income-tax appellate Tribunal. I also notice that in his application under Section 66(2) of the Indian Income-tax Act the assesssee admitted that the sale took place in the relevant accounting year, namely, 1356 Fasli. In my opinion there is no substance in the contention put forward on behalf of the assessee on this point.

(9) For these reasons I hold that in the circumstances of this case the amount of Rs. 1,30,785/- being the excess of sale proceeds of the building, plant and machinery, over the written down value thereof, was rightly taxed as income in the hands of the assessee tinder Section 10(2) (vii) of the Indian Income-tax Act. I would accordingly answer the question referred by the Income-tax Appellate Tribunal against the assessee and in favour of the Income-tax Department. The assessee must pay the costs of this reference. Hearing fee Rs. 250/-.