Advocate Sanat Mehta, The Saint Among Professionals (Rare Vintage Photos)

Eminent Tax Lawyer V. H. Patil has paid rich tribute to the late Sanat P. Mehta. His professional efficiency, integrity, sense of fair play, professional co-operation and brotherhood coupled with his personal qualities of hard work, humility, honesty and punctuality have made him a revered figure and role model for all professionals, Vijay Patil says

“Trimurthis” of the legal profession

If today, in the tax professional field in Mumbai if there is more professional efficiency, integrity, more fair play, more professional co-operation and professional brotherhood, as against other professional fields, the entire credit must go to the three great stalwarts of our tax profession, Shri R. J. Kolah, Shri N. A. Palkhivala and Shri S. P. Mehta. Any one of these outstanding and ideal professional leaders was sufficient to put the tax profession on the right track. However, we were very fortunate to have amongst us all these three at one and the same time. They laid down a sound professional tradition to the future generation. During their illustrious career they lived as per the fine traditions set by them. They were so great and outstanding professionals that during their life time they became ideals for us to follow.

{(Click for larger image) L-R: D. M Harish, Y.P Trivedi, Sanat Mehta, S. E. Dastur, V. H. Patil & Sudhir Mehta)}

It is normally believed that to be a real successful man in the temporal world, one has to compromise on certain basic principles, but these three great professionals showed us that one need not compromise on principles to become a successful professional. Their success in the tax field was undoubtedly great. However, this success was achieved by them by following ideal professional path without compromising on any of the basic ethics and principles that govern ideal professional’s life. Professional idealism was ingrained in them.

Though there were certain common features in these three great professional leaders because of their temperament and the nature of their contribution these three great leaders, the “Trimurthis” of our profession, can be called:

Mr. Palkhivala as Lord Brahma. Mr. S. P. Mehta as Lord Vishnu and Mr. R. J. Kolah as Lord Mahesh.

Mr. Palkhivala had great originality and creative spirit in abunance and because of these qualities he made great contribution to the making and development of tax laws and tax administration of this country. One can certainly call him — the Brahma of the tax laws. Shri R. J. Kolah’s intolerance towards anything which was wrong is well known and considering his fighting spirit against any injustice noticed, one could compare him to Lord Shiva. Considering Shri Mehta’s fatherly outlook towards his professional colleagues and his pleasant and peaceful nature, one can certainly call him Lord Vishnu of our profession. We know that “Shantkara” is one of the attributes of Lord Vishnu. While sleeping on the serpent he is still very calm and collective. That was the nature of Shri S. P. Mehta. Therefore he deserves the title of Lord Vishnu of our profession.

Shri S. P. Mehta popularly known as “Sanatbhai” was such a charming personality that any person coming in contact with him would always remember him. The meeting which one had with him would always leave a pleasant experience on that person. He had a charming face which was a real abode of peace and that tinge of smile on his serene face that would always leave a deep impression on the person who came in contact with him.

Gentleman’s spirit

Sanatbhai was gentleness personified. He was gentle to the core. He was gentle in his action, in his speech, in his behaviour and in his arguments. The dominating feature of his arguments as a counsel was a gentle persuasion. He was not dramatic in his arguments — still less there was any showmanship in it. His arguments might not have attracted a common crowd, but as far as the judges were concerned his persuasive reasoning had a great impact on them. He had the skill of a surgeon as he did not believe in the knife of the butcher. I remember him always telling us that persuasiveness is the best form of advocacy and he used to tell us that while arguing we must concentrate on the judges and not on the public who came to listen.

Gentleman to the core in the professional field his life was dominated by a gentleman’s spirit. His advice was that one has to be fair as a counsel, fair to the court, fair to the opponent and fair to the client. He never believed in encashing on the shortcomings and ignorance of his opponent or the court. I have so many times withnessed Sanatbhai pointing out the cases against him when the same were not known either to the other side or to the judges. He always used to say that one has to win on merits and not on the weakness of the other side. This attitude is quite significant because in the tax field it is quite often that the other side is not up to the mark either in case laws or in recent development in the laws, particularly when some non tax legal issues crop in a tax appeal.

{(Click for larger image) Eminent tax lawyers V. H. Patil and S. E. Dastur dance with joy to the loud cheers of Ashok Kotangale, Atul Jasani, Y. P. Trivedi and others}

Helpful nature

As stated above during his life time, Sanatbhai was a fatherly figure to the most of his professional colleagues, particularly to one who was junior to him. He showered his affection on one and all as a senior professional and that shower of love made no distinction on the basis of age, language, caste, creed etc. He was always very helpful in guiding his professional juniors. I have seen many times, while the juniors were arguing, though he was not concerned with a particular case he would give them useful tips and instructions which were required when he just happened to be present in that court. His guiding hand was available to everybody who sought his guidance. Due to his affectionate nature and the love he showered on his professional colleagues he has made a place for himself in the hearts of most of the professional colleagues who came in contact with him. It is a fact that unfortunately we have not made any monument in his memory — possibly that was not needed because he continued to dwell in the hearts of most for the colleagues who were fortunate enough to come in contact with him.

Humility personified

The humility which Shri Sanathbhai possessed was something amazing. He was not at all conscious of his learning or knowledge – still less of his goodness. It is said “Vidya Vinayene Shobhate.” Shri Sanatbhai was a shining example of it. While in conference or while discussing with anybody, particularly with his juniors he was always discussing on equal terms. We, juniors were always free to discuss with him. Without keeping in mind his knowledge or seniority, he would always appreciate the point made by the other person with whom he had a discussion, irrespective of who that person was. I personally had experiences of making Shri Sanatbhai change his views. He always appreciated the logic in other’s arguments and was ready to change his own views. Sanatbhai was always open for learning. He was always a student. He was ready to learn new things and ever ready to reconsider his own views. Because of this attitude it was a great pleasure to discuss any issue with him. I personally had a great pleasure of discussing so many legal and other issues on one to one basis. I have seen that even though the point put forward by the other person in the course of discussion was stupid or unarguable, still he bore him with patience and understanding and would point out so gently and politely the shortcomings of other’s arguments that the other side would have to accept it without any sense of reluctance.

Precise and concise arguments

Shri Sanatbhai in his arguments was very precise, concise, brief and to the point and at the same time very effective. He never believed in going round and round in lengthy arguments. He was always to the point on the issue and would hit the nail on the head. In fact, sometimes Shri Sanathbai was so brief and so direct to the point that sometimes members would find it difficult to follow him. I have taken this point from him in a bad way, particularly no doubt like him I am very brief in my arguments, but not precise and concise as Shri Sanatbhai was. In fact, one of the members had commented that Mr. Patil is sometimes so brief that he finishes the arguments before one could follow the points made by him. That was not the case with Shri Sanatbhai. He was no doubt brief and concise but he was also very effective. He would straightaway come to the point and deal with it so effectively and briefly that within no time the issue would become very clear. Normally, a case which would take a couple of hours and if Mr. Sanatbhai was to argue it would be over within half an hour. But this briefness and conciseness in his arguments, not only did not diminish the effectiveness of his arguments but it enhanced the same. I had hardly seen a counsel who was so brief and yet so effective like Shri Sanatbhai.

{(Click for large image) Dance away the blues: V. H. Patil with Advocates and CAs)}

Role model for juniors

A special note has to be made as regards his attitude to other person in his chamber, whether a junior or the staff working with him. There was absolutely a homely atmosphere in his Chamber, I have never seen Shri Sanatbhai firing any of the juniors or his staff. In fact, as a junior I never got any scolding or firing from him, not that I did not commit any mistakes or did not deserve any firing or scolding, but Shri Sanatbhai never believed in it. In fact, he would always point out the mistake which one had committed in such a cordial and effective way that the other person would realise his mistake and correct it, which possibly he would not have done if there was scolding or firing. Here also, his nature of persuading others was his key word. Therefore, he always gently pointed out a mistake and corrected it. He was so good, so kind and so affectionate to those who were working with him to the point of that being his weakness. I remember one specific instance to illustrate his very affectionate outlook towards his staff and juniors. One of the staff members — rather his chauffeur was very rude to everybody and used to create a lot of problems. Once I was so fed up with that person that I requested Sanatbhai to call him and give him a thorough firing so that he may learn a lesson. I narrated all the misdeeds that he was committing. Shri Sanatbhai quietly listened to me and told me that he would call him and fire him. I was glad that the chauffeur would get a nice firing. I immediately called him and then Shri Sanatbhai told him not to do such things again and that too, gently and that man was allowed to go. I told Shri Sanatbhai “What is this?”

Shri Sanatbhai said “You wanted me to fire him, I fired him.” Then I remarked “If this is the firing, he will not improve at all.” Shri Sanatbhai just smiled and put an end to that episode. This attitude for Sanatbhai to deal affectionately and gently with all the problems of the Chamber had a very sobering effect on me as a senior in my Chamber. Many times I have restrained myself from firing my juniors when they committed a mistake only because in the nick of time I would remember Sanatbhai and I always told myself that if Sanatbhai never fired anybody, I have no right to fire my own juniors. Particularly in the later part of my career, I always remembered this quality of Shri Sanatbhai and I always tried to follow it, of course sometimes without success. As such, if today I am considered as a good boss or a good senior in my chamber the whole credit goes to my noble senior Shri Sanatbhai, not only in my role as a senior or as a head of the Chamber but in all the walks of my professional life, Shri Sanatbhai has been a guiding star. Whenever there is any problem facing me, whether small or big I always put Shri Sanatbhai in my position and always do as Shri Sanatbhai would have done in my position. With that I would get the correct solution to the problem. Without any iota of exaggeration, I can straightaway state that if any professional goodness and gentleness is in me, it is because of my worthy senior Shri Sanatbhai who always stood as a real model for me. Of course, if I have not succeeded fully in this regard, the fault is not of my senior Shri Sanatbhai but of mine. Sanatbhai’s affection for his juniors was so great that he would defend his junior against anybody, even when we juniors were at fault. Of course, afterwards he would make us realise that we were at fault but as far as the outside world was concerned, he would always defend his juniors.

Shri Sanatbhai would give credit to anybody whenever it was due. I remember many times when he used to argue, I would suggest a particular point. After arguing that point he would straightaway say that this point was suggested by his junior. I remember once when we appeared before the Commissioner, the arguments were on two points. The Commissioner told Shri Sanatbhai that he would not accept the first argument, but he would readily accept the second argument. At that time, Shri Sanatbhai smilingly told the Commissioner that he must give the credit to his junior who had brought out this point and in fact persuaded me to put forward this point, though I was not happy with the argument put forward by him, however if it has appealed to you then I think he must be right.

Simple living

Another outstanding feature in Shri Sanatbhai was his simplicity. His simplicity was without any limit. He had a simple living, simple habits and was simple in his dress. In fact, one could straightaway say “Simplicity thy name is Sanatbhai.” I remember one incident. There was an All India Conference where almost one thousand delegates had come from all over India. Shri Sanatbhai was to chair that session. I was one of the paper writers. There were about 10/12 persons on the stage including Shri Sanatbhai and myself. All of us, with the exception of Shri Sanatbhai were in suits and when Shri Sanatbhai walked in he came in a simple white bush shirt and sat in the middle of us as a Chairman. It was a real contrast with the main person in a simple bush shirt and all the others in suits. I do not recollect any occasion where he used to wear a coat even as a chairman. Except in the court he always gave a goodbye to his coat. He always wore Khadi. However, his clothes were always spotless white. I have also heard about an incidence at the first RRC meeting of the Bombay Chartered Accountants Society way back in 1950’s. The RRC was at Matheran. Shri Sanatbhai was to inaugurate it. All the persons who were on the stage were in full suits. Then, I was told, Shri Sanatbhai came in kurta and pajamas to inaugurate the Conference. When later on I had the privilege of inaugurating an RRC Conference of the Bombay Chartered Accountants Society, I followed my worthy senior by going in kurta and pajama to inaugurate the Conference.

Sense of humor, even in Court

Shri Sanatbhai had a great sense of humour. On a dry subject like taxation when the discussion is becoming dry and heavy he would add the necessary humour to make the situation light and clear. I remember one incident when Shri Sanatbhai was arguing in the High Court. The issue was whether a minor could be a partner. In that case, a minor was not admitted to the benefit of partnership, but he was directly made a partner. The person who was admitted as a partner was a sixteen year old. The department had contended that as the minor was not admitted to the benefit of partnership but was admitted as a partner, the firm was not validly constituted. When the discussion was going on Shri Sanatbhai added “My Lord, in this case as the person admitted was not a minor, but a major the question of a minor being admitted as a partner does not arise. The Hon’ble Court pointed out that the boy was sixteen years old. Then Mr. Sanatbhai replied “So, what, My Lords, see the name of the boy.” It was something like Bikamchand Jain. The Hon’ble Court said “Bikamchand Jain.” Shri Sanatbhai replied “Read it properly My Lords, it is Bikamchand Jain.” The Court said “So, what?” Shri Sanatbhai humorously replied “My Lord, Bikamchand Jain is a Marwadi and in the Marwadi community the boy attains majority at the age of 15 and not 18. Therefore he is a major and can be admitted as a partner.” The whole Court burst into laughter.

Another incident which I vividly remember in a case where Shri Sanatbhai was attending before the Tribunal. In that case, the assessee was a Maharaja who had won some prize in hunting. The issue was whether the prize won was taxable as income? The issue to be decided was whether hunting was an occupation of the Maharaja or whether the Maharaja was going for hunting occasionally and, as such, whether the prize won by the Maharaja was not taxable. The Hon’ble Tribunal asked Mr. Sanatbhai whether his client’s occupation was hunting or he was hunting on holidays. Shri Sanatbhai replied “Sir, my client is a Maharaja for whom life itself is a holiday.” I can multiply such incidents where a very light sense of humour of Shri Sanathbai was reflected again and again.

Sharp memory

Another personal incident that I remember is, unlike me Shri Sanatbhai was always tidy and careful and he would rarely forget things. Untidiness and foregetfulness were always with me and because of my forgetfulness, Shri Sanatbhai always used to call me “Mr. Professor.” Once, both of us had gone to the department for appearing before the Appellate Authority. When the matter was over and we got out, Shri Sanatbhai forgot to pick up his brief and left it on the table. I quietly picked it up, thinking that I had a point to make. Afterwards I told Shri Sanatbhai that he had forgotten the brief and that I had brought it, Shri Sanatbhai quietly replied “In the company of a Professor like you, what else can I do, but to forget things.” So the whole thing recoiled on me.

Encouragement to juniors

As I have narrated above, the concern and care shown by Shri Sanatbhai towards his juniors was something very remarkable. When I left his Chamber to start my own practice he was very much worried whether I could really cope up with the independent practice and succeed. Therefore, he said “Vijay, you can have your own practice, but in the evenings come to the office for a couple of hours so that by your leaving, the Chamber may not suffer. Though he covered it by saying that the Chamber may suffer, the real idea was to see that I had sufficient work to begin with my independent practice. Even after I was in full-fledged practice he would always make enquiries as to how I was doing or whether any help was required etc. He had always desired that we juniors must come up fast. When I was still a raw junior at that time Shri Sanatbhai remarked that one of the junior counsels was very much heard in the public by way of writing articles, giving lectures etc. As I had concentrated on learning, I had not bothered about writing articles or giving lectures. Once Shri Sanatbhai remarked “Vijay what is this, I am hearing so much about the other persons, but I am not hearing anything about my juniors”. That really touched me. I decided that whatever maybe my view of thinking, I should make my senior happy. So I switched my gear and began to give lectures and write articles left and right. After one year I asked Shri Sanatbhai as to whether he was hearing my name as a speaker or as writer of articles. Shri Sanatbhai humorously replied “Earlier I was not hearing your name but now I am hearing your name too many times, more than necessary”. When he replied, though on his face there was humour, I could find a sense of contentment that his junior was doing well. Such affectionate and fatherly care was always there in him. Therefore, I began to work harder so that I would succeed in the profession, if not for my own sake, but to give happiness to Shri Sanatbhai. Therefore, I was very happy that I was achieving satisfactory progress in the profession that would make Shri Sanatbhai happy. It is not only the professional practice but in professional conduct also I am guided by Shri Sanatbhai’s wishes and attitude. I would always see that as an Advocate or afterwards, my actions should not fall outside the professional etiquette circle which was drawn by my worthy senior. He is my idol, my inspiration and my model. During my career while introducing me as a speaker or as a chairman unnecessary compliments are showered on me but one compliment given by my senior colleague while introducing me will always be cherished by me. While introducing me he said “Mr. Patil’s humility, honesty, fair play, learning etc. are so great that he is a real chela of his senior who is known for all these qualities.” Of course, though I was quite aware that this compliment was most undeserving one, still it thrilled me to my bones that I was introduced as an ideal chela of my worthy guru.

End of an era

I am supposed to write about the contribution of Shri Sanatbhai to our profession. Well, the contributions is so great and so multifarious that I cannot compile it in a para or two, but I will narrate an incident which will clearly illustrate the real contribution made by Shri Sanatbhai towards the profession. When Shri Sanatbhai passed away, one of the Commissioners of the Income-tax Department, remarked “Mr. Patil with the passing away of Shri Sanathbai, the era of tax profession dominated by gentlemen like Sanatbhai has come to an end.” Mind you, this remark was made when Mr. Palkhivala and Mr. Kolah were still alive. Of course, I was stupid enough to burst out by saying “No Sir, as long as I am there it will not come to an end” without realising the responsibility that it carried to follow the legacy of Shri Sanatbhai. This incident illustrated the contribution made by Shri Sanatbhai to the profession.

It is people like Shri Sanatbhai who made our profession really noble which is otherwise money minded and self centered.

Serenity & Equilibrium

Shri Sanatbhai retained his serenity and equilibrium under all circumstances. Once, I remember, Shri Sanatbhai was called to address a meeting at Andheri. It was raining heavily. As usual I was accompanying him. Somehow we managed to reach the venue in time. But the audience was hardly about 25. I was fuming that we were made to come all the way in the rain and here there was no audience. But that did not bother Shri Sanatbhai at all. He went on to deliver his talk as if there was an audience of 25,000 people. When I had a similar experience where there was hardly audience worth mentioning, to start with I was really upset. But immediately I was reminded of the above incident, and came back to normal state and delivered that talk as if there was a large crowd, thanks to my worthy senior. Another such incident I remember. We were to attend a case at Charni Road. The client had no car. Our car was also not available on that day. So we went by a taxi. While returning we did not get a taxi. A BEST bus came. Shri Sanatbhai said “Come on Vijay let us go by bus.” Before I could say yes, he boarded the bus. Of course I followed willingly. However, there was no vacant seat to sit. We travelled standing. Sanatbhai really enjoyed the standing bus ride. Another incident, once we had gone to Pune to attend a matter before the Tribunal. Our client had booked a single bedroom. The matter was soon over. We returned to our hotel. After lunch we returned to our room. There was only one bed. Shri Sanatbhai asked me “Vijay do you want to sleep? When I answered in the negative, he asked “Vijay, may I go to sleep!” Well imagine a senior asking his junior, whether he wants to sleep and after a negative answer, asking his permission to go to sleep! Another touching incident I vividly remember. A client from Nashik had accompanied Shri Sanatbhai to Delhi. The client was a young man of 25 years. After the matter was over, they returned to the hotel. Shri Sanatbhai was to remain in Delhi for another day. So the client was to return back alone. Sanatbhai enquired with him as to whether he can go back alone and whether he could go to the station alone. Even when the client told him that he knows Delhi well, Sanatbhai came down with the client, hired a taxi for him, and told the taxiwalla to take the client to the station. While narrating the incident to me, with tears in his eyes, the client remarked “Patilsab, you are known for your humility. But compared with your senior you are nowhere.” His comment I wholeheartedly accepted.

Attitude towards clients

Shri Sanatbhai’s attitude towards his clients was also exemplary. I remember him telling me “Vijay always remember that you are a trustee of your client and as you know a trustee as a matter of right cannot claim any remuneration for the services he is rendering, and even though it is without remuneration he has to give his best while serving as a trustee. Keeping this in mind while you are dealing with your client, whether to accept a particular person as a client or not is your discretion but once you accept a client you have to do your best without expecting any remuneration. The fact that a person has not paid you should not affect your performance or your duty as a lawyer trustee of your client. Shri Sanatbhai was known for his talking less. So also he never used to go on lecturing but sometimes some golden advices were falling from his slips. Of course, because of his attitude I know that Shri Sanatbhai had a lot of outstanding dues. As his junior I have also a lot of professional outstanding, but following Shri Sanatbhai’s attitude I never harass the clients or the Chartered Accountants in respect of recovery of my dues. In fact that was also the advice given by my father, who was also a lawyer.

I also remember one incident which made Mr. Sanatbhai very happy. There was a case of a client who was not well to do. I was handling the case and the matter was before the CBDT. I had studied all the papers and I was asking Mr. Sanatbhai to go and appear before the Board in Delhi. The client was insisting that I must also accompany Shri Sanatbhai to Delhi and appear along with him. I know that the financial position of the client was not in good shape. Therefore, I told them that it was not necessary that both of us should go to Delhi. It was sufficient if Shri Sanatbhai went to Delhi. Not being satisfied with my reply they requested Shri Sanatbhai to persuade me to accompany him to Delhi. Shri Sanatbhai was too glad to take me along with him to Delhi. Then he asked me to accompany him to Delhi. I explained to Shri Sanatbhai that as the financial position of the client was very bad it would be an additional burden on them. I still remember the appreciation on the face of Shri Sanatbhai. He was very happy and said “Vijay, keep this attitude in mind that your clients convenience must be one of the factors that you must always take into account.” Shri Sanatbhai always used to say “One looks at the amounts which were unrecovered, why do you not see the positive side — how much is recovered and if what is recovered is more than sufficient then why bother about the amounts which have not yet been recovered.

Juniors expected to be well prepared at all times

Shri Sanatbhai always insisted that the junior must be on his toes. He must prepare the case as if he himself is arguing and not just help the senior. At the beginning of my career, I was not knowing that Shri Sanatbhai used to test his juniors. When the matter was about to be heard, at that time, he would tell his junior to argue the matter. I had to undergo a similar test in the High Court matter. It was a writ petition for admission when the judges came to the court and they were about to sit in the chairs. Shri Sanatbhai told me “Vijay you argue this matter.” Stupidly or otherwise I never lacked in self confidence. I accepted the challenge and argued and the matter was decided in our favour. The joy of Shri Sanatbhai was unbound. He said “Vijay you are the first person to accept the challenge successfully. All others said “No Sir, I am not ready to argue.” I give this same advice and quote the above incident to my juniors but unfortunately not with much success.

Honesty & integrity

The honesty and integrity of Shri Sanatbhai in all walks of life, particularly in payment of taxes was something extraordinary. Today when tax rates are 30-35% it is not something great to be an honest taxpayer, but when we were asked to pay a tax of 97.75% and along with wealth tax liability many times the rate would be going, more than hundred per cent — income-tax and wealth tax together, it would be an extraordinary thing to comply with such tax laws. I never saw Shri Sanatbhai complaining against such high rates of taxes. In fact, he was so particular about tax payment that if a particular expenditure was for the purpose of profession was debatable he would just not claim such expenditure while computing his income.

One incident that I clearly remember, Shri Sanatbhai had impressed his annuity deposit with the characteristic of HUF. The issue was whether the provisions of S. 64(2) would be applicable. The Hon’ble Tribunal held that the provisions would not be applicable because the partition of Shri Sanatbhai (HUF) who was the only co-parcener in the HUF was not possible. Therefore, to determine his share or his children’s share for the purpose of S. 64(2) was not possible. Unfortunately the Department was not satisfied with the decision and took the matter to the High Court. Then Sanatbhai voluntarily offered that h e would be paying the tax as if provisions of S. 64(2) would be applicable if the Department withdrew the reference.

Punctuality

Shri Sanatbhai was always very particular about his timings. I do not remember he being late any time. If the Tribunal was to start at 11.15 a.m. he would always be present in the Tribunal at 10.45 a.m. Similarly, when there was a matter in the High Court which starts at 11.00 a.m. he would be present in the Court by 10.45 a.m. In the beginning I was finding it difficult to be in the Court or in the Tribunal before Shri Sanatbhai. Though he was time conscious, he was not perturbed by others not coming in time for their appointment with him.

The real integrity and character of a tax counsel is normally measured by its recognition by the department. The integrity of Sanatbhai was so much accepted by the department that many times the department relied on the opinion of Shri Sanatbhai for coming to a particular conclusion. The department was convinced that Sanatbhai would never give a convenient opinion to suit his client. Whatever opinion was given was with a firm conviction. The recognition by the department of the counsel’s integrity for a fair opinion is something rare and Sanatbhai had such a recognition.

ITAT has become a ‘Model Tribunal’ due to the stalwarts

Today, the Income-tax Tribunal has many good traditions. In fact, it is no mean achievement that the Income tax Tribunal is treated as a model Tribunal. It has a proper judicial approach for which it was constituted. The reason for the establishment and continuation of this tradition of the Income-tax Tribunal is mainly because of the great contribution made by persons like Shri Sanatbhai, Shri Palkhivala and Shri Kolah. The sheer personality and character of these persons was so great that it was bound to impress the persons before whom they would appear. Therefore, one has to give credit to the three stalwarts for establishing the ideal tradition not only in the Bar but on the Bench too.

It maybe added that today there is cordial relationship between the Bench and the Bar in the Tribunal which is something rare. This is also because of the noble tradition set by these three stalwarts.

On we, the tax practitioners lies the great burden of carrying on the great legacy which we were fortunate to inherit from these three great leaders of our bar. It is a much cherished legacy which if kept intact and followed, much of the ills of tax administration particularly on the Appellate side could be removed.

Let me add, let the blessings of these three undisputed outstanding leaders of our profession guide us on the right path and lead us to the path of ideal professionalism which they had intended us to achieve.