* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ INCOME TAX APPEAL NO. 320/2012
Reserved on: 17th July, 2014
% Date of Decision: 25th August, 2014
COMMISSIONER OF INCOME TAX ..... Appellant
Through Ms. Suruchi Aggarwal, Sr. Standing
Counsel.
Versus
M/S NAVODAYA CASTLES PVT LTD. ..... Respondent
Through Mr. Ved Jain and Mr. Pranjal
Srivastava, Advocates.
CORAM:
HON'BLE MR. JUSTICE SANJIV KHANNA
HON'BLE MR. JUSTICE V. KAMESWAR RAO
SANJIV KHANNA, J.:
Revenue in this appeal, which relates to assessment year 2002-
03, has raised the following substantial question of law:-
"Whether the ITAT fell into error in upholding
the deletion of Rs.54 lakh, which was directed to be
added back by virtue of section 68 of the Income
Tax Act on the ground that assessee has discharged
the onus of proving the identity and credit-
worthiness of the share subscriber and the
genuineness of the subscription?"
ITA No. 320/2012 Page 1 of 20
2. The appeal arises out of the impugned order dated 31st October,
2011, passed by the Income Tax Appellate Tribunal, upholding the
order passed by the Commissioner of Income Tax (Appeals) deleting
addition of Rs.54,00,000/- made under Section 68 of the Income Tax
Act, 1961 (Act, for short), by the Assessing Officer on account of share
application.
3. The assessee, a company, had filed their return of income for the
assessment year 2002-03 declaring loss of Rs.1,58,035/- on 20th
October, 2002, which was processed under Section 143(1) of the Act.
Subsequently, on the basis of a report submitted by the Investigation
Wing that the assessee was a recipient of accommodation entries in
form of share application money/share capital/share premium, notice
under Section 147 read with Section 148 of the Act was issued and
served on 25th March, 2009. The assessee, in response, pleaded that
the return filed earlier under Section 139 (1) on 20 th October, 2002,
may be considered as a return, filed pursuant to the said notice. In
response to the assessee's letter dated 18th April, 2009, reasons
recorded for issue of notice under Section 147/148, were
communicated to the respondent assessee on 2nd September, 2009.
ITA No. 320/2012 Page 2 of 20
4. Authorized representative of the assessee appeared on 9 th
September, 2009, and sought adjournment for providing documents,
evidence etc. in response to the notice under Section 143(2), which was
issued on 2nd September, 2009. The case was adjourned to 11th
September, 2009, but no one attended the proceedings and belatedly on
14th September, 2009, request for adjournment was made on the
ground that authorized representative was ill. To give further
opportunity, proceeding was adjourned to 22nd September, 2009, and
other details were sought. On 22nd September, 2009, again request for
adjournment was made. On the said date, a questionnaire along with
notice under Sections 142(1) and 143(2) was issued, fixing the hearing
on 8th October, 2009. On 8th October, 2009, authorized representative
of the respondent-assessee once again requested for time on the ground
that the requisite information was under preparation/compilation. The
assessee was required to furnish details of shareholders who were
allotted shares in the year under consideration, their confirmations,
copy of the income tax returns, bank accounts, copy of share certificate
issued, allotment letter etc. The case was adjourned to 22 nd October,
2009, but the said hearing yet again remained unattended. Belatedly,
on 17th November, 2009, part information was furnished by the
ITA No. 320/2012 Page 3 of 20
authorized representative. Further details were required to be
furnished.
5. On 17th November, 2009, the assessee raised objection to re-
opening and submitted that reasons for re-opening were merely
surmises and conjectures. It was stated that the five amounts
aggregating to Rs. 47,00,000/-, which were mentioned twice in the list
prepared by the Investigation Wing, did not relate them. However, the
assessee accepted that they had received six amounts aggregating to
Rs.54,00,000/- as per the details given below:-
Bene- Bene- Ficiary Valueof lnstru Date On Name of a/c Bank Branch of A/c No. of
Ficiary Bank Branch Entrytaken - ment Which Account from entry giving Entry
Bank No.by Entry which Bank giving
Name. Which taken Holder of Entry entry Account.
Entry Giving given
taken
A/c
HDFC Rejender 700000 972521 7.3.02 Sekhawati SBP Daryaganj 50111
Bank Nagar Finance
Mkt.,ND P.Ltd.
HDFC Old 1000000 13.3.02 D.K.Ispat & SBP - 50090
Rajender Timber Ltd. do-
Nagar, ND
HDFC --do-- 650000 13.3.02 Kuberso Sales SBP - 50084
P.Ltd. do-
HDFC --do-- 1200000 14.3.02 Dinanath S - 50103
Luhariwal BP do--
Spinning Mills
Ltd.
HDFC -do-- 850000 33834 16.3.02 Technocom Innovatiy Wazirpur 220
Associates P.Ltd. e
ITA No. 320/2012 Page 4 of 20
HDFC --do-- 1000000 18.3.02 Chintpuri Credits SBP DG 50058
Total 5400000
6. The assessee did not appear in the proceedings held on 25 th
November, 2009. However, the Assessing Officer wrote a detailed
questionnaire for information and compliance and fixed the hearing on
2nd December, 2009.
7. Summons under Section 131 of the Act were sent to the alleged
shareholders and they were asked to furnish details on 10th December,
2009. Directors/Principal officers were required to personally come
and depose. The summons, as per the assessment order, were received
back unserved. At the same time, the assessee filed details and
confirmations of the alleged share capital. Earlier on 8th December,
2009, a detailed show cause notice was issued, fixing the hearing on
14th December, 2009. The assessee was asked to produce the
shareholders along with their books of accounts to substantiate its
claim of genuineness of the cash credits. In fact on 10th December,
2009, authorized representative had appeared and he was apprised that
the summons issued to the shareholders under Section 131 had been
received back unserved in five cases and he was requested to provide
the present postal address of the parties. In the meanwhile, the
ITA No. 320/2012 Page 5 of 20
Assessing Officer managed to get hold of the bank statements of the
shareholders, who had allegedly made deposits by way of cheques and
pay orders. The assessment order specifically records that huge cash
deposits in lacs were being regularly deposited in the said accounts and
then pay orders/cheques were issued to the respondent assessee.
8. On 14th December, 2009, authorized representative appeared and
stated that the assessee was unable to produce directors or principal
officers of the six shareholder companies pleading that they were not
shareholders now and seven years had passed since the transactions
took place. The assessment order records and mentions about the
transactions recorded in the bank accounts of the shareholder/entry
operator companies to show and establish that there was immediate
deposit of cash and then issue of cheques. It was further mentioned
that these companies were under control of one Mahesh Garg and his
group, who were operating various accounts. The Assessing Officer
made addition of Rs.54,00,000/- under Section 68 of the Act and
Rs.1,08,000/- as commission paid for procuring the said shares being
2% of Rs.54,00,000/-.
9. Commissioner of Income Tax (Appeals) deleted the aforesaid
additions on merits. However, he upheld the issuance of notice under
Section 147/148 of the Act. He observed that the respondent assessee
ITA No. 320/2012 Page 6 of 20
had submitted various letters/documents in support of genuineness of
the transactions towards share capital subscribed, but this was rejected
by the Assessing Officer without adducing even a single instance of
infirmity and shortcoming. The said evidence was in the form of share
application forms, copy of bank statements of the share subscribers
from where the share application amount was paid, confirmation of the
companies towards investment in share capital, certificate of
incorporation with copy of memorandum and articles of association,
copy of PAN card, ITR etc. Thus, it was held that the assessee was
able to prove the identity of the shareholders, genuineness of the
transactions and there was no room for doubt and suspicion. The
Assessing Officer, it was observed, had not made any inquiries
regarding the fact that assessee had been given accommodation entries
and had routed their undisclosed income in the guise of share
application money. Reference was made to several decisions of the
Delhi High Court in support.
10. Revenue preferred an appeal before the tribunal and cross-
objections were filed by the assessee. Appeal of the Revenue has been
dismissed. The cross objections filed by the respondent assessee to re-
opening were disposed of as infructuous, observing that they have
become academic and did not require adjudication.
ITA No. 320/2012 Page 7 of 20
11. We have heard the Senior Standing counsel for the Revenue,
who has relied upon decisions of the Delhi High Court in
Commissioner of Income Tax Vs. Nova Promoters and Finlease (P)
Ltd. [2012] 342 ITR 169 (Delhi), Commissioner of Income Tax Vs.
N.R. Portfolio Pvt. Ltd., 206 (2014) DLT 97 (DB) (Del) and
Commissioner of Income Tax-II Vs. MAF Academy P. Ltd., 206
(2014) DLT 277 (DB) (Del). The aforesaid decisions mentioned above
refer to the earlier decisions of Delhi High Court in Commissioner of
Income Tax Vs. Sophia Finance Ltd., [1994] 205 ITR 98 (FB)(Delhi),
CIT Vs. Divine Leasing and Finance Limited [2008] 299 ITR 268
(Delhi) and observations of the Supreme Court in CIT Vs. Lovely
Exports P. Ltd. [2008] 319 ITR (St.) 5 (SC).
12. The main submission of the learned counsel for the assessee is
that once the assessee had been able to show that the shareholder
companies were duly incorporated by the Registrar of Companies, their
identity stood established, genuineness of the transactions stood
established as payments were made through accounts payee
cheques/bank account; and mere deposit of cash in the bank accounts
prior to issue of cheque/pay orders etc. would only raise suspicion and,
it was for the Assessing Officer to conduct further investigation, but it
ITA No. 320/2012 Page 8 of 20
did not follow that the money belonged to the assessee and was their
unaccounted money, which had been channelized.
13. As we perceive, there are two sets of judgments and cases, but
these judgments and cases proceed on their own facts. In one set of
cases, the assessee produced necessary documents/evidence to show
and establish identity of the shareholders, bank account from which
payment was made, the fact that payments were received thorough
banking channels, filed necessary affidavits of the shareholders or
confirmations of the directors of the shareholder companies, but
thereafter no further inquiries were conducted. The second set of cases
are those where there was evidence and material to show that the
shareholder company was only a paper company having no source of
income, but had made substantial and huge investments in the form of
share application money. The assessing officer has referred to the bank
statement, financial position of the recipient and beneficiary assessee
and surrounding circumstances. The primary requirements, which
should be satisfied in such cases is, identification of the
creditors/shareholder, creditworthiness of creditors/shareholder and
genuineness of the transaction. These three requirements have to be
tested not superficially but in depth having regard to the human
probabilities and normal course of human conduct.
ITA No. 320/2012 Page 9 of 20
14. Certificate of incorporation, PAN number etc. are relevant for
purchase of identification, but have their limitation when there is
evidence and material to show that the subscriber was a paper company
and not a genuine investor. It is in this context, the Supreme Court in
CIT Vs. Durga Prasad More [1971] 82 ITR 540 (SC) had observed:-
"Now we shall proceed to examine the validity of
those grounds that appealed to the learned judges.
It is true that the apparent must be considered real
until it is shown that there are reasons to believe
that the apparent is not the real. In a case of the
present kind a party who relies on a recital in a
deed has to establish the truth of those recitals,
otherwise it will be very easy to make self-
serving statements in documents either executed
or taken by a party and rely on those recitals. If
all that an assessee who wants to evade tax is to
have some recitals made in a document either
executed by him or executed in his favour then
the door will be left wide open to evade tax. A
little probing was sufficient in the present case to
show that the apparent was not the real. The
taxing authorities were not required to put on
blinkers while looking at the documents produced
before them. They were entitled to look into the
surrounding circumstances to find out the reality
of the recitals made in those documents."
15. Summarizing the legal position in Nova Promoters and
Finlease (P) Ltd.(supra), and highlighting the legal effect of section 68
of the Act, the Division Bench has held as under:-
"32. The tribunal also erred in law in holding
Assessing Officer ought to have proved that the
monies emanated from the coffers of the assessee-
ITA No. 320/2012 Page 10 of 20
company and came back as share capital. Section 68
permits the Assessing Officer to add the credit
appearing in the books of account of the assessee if
the latter offers no explanation regarding the nature
and source of the credit or the explanation offered is
not satisfactory. It places no duty upon him to point
to the source from which the money was received by
the assessee. In A. Govindarajulu Mudaliar v CIT,
(1958) 34 ITR 807, this argument advanced by the
assessee was rejected by the Supreme Court.
Venkatarama Iyer, J., speaking for the court
observed as under (@ page 810): -
"Now the contention of the appellant is that
assuming that he had failed to establish the case put
forward by him, it does not follow as a matter of law
that the amounts in question were income received
or accrued during the previous year, that it was the
duty of the Department to adduce evidence to show
from what source the income was derived and why it
should be treated as concealed income. In the
absence of such evidence, it is argued, the finding is
erroneous. We are unable to agree. Whether a
receipt is to be treated as income or not, must
depend very largely on the facts and circumstances
of each case. In the present case the receipts are
shown in the account books of a firm of which the
appellant and Govindaswamy Mudaliar were
partners. When he was called upon to give
explanation he put forward two explanations, one
being a gift of Rs. 80,000 and the other being receipt
of Rs. 42,000 from business of which he claimed to
be the real owner. When both these explanations
were rejected, as they have been it was clearly upon
to the Income-tax Officer to hold that the income
must be concealed income. There is ample authority
for the position that where an assessee fails to prove
satisfactorily the source and nature of certain
amount of cash received during the accounting year,
the Income-tax Officer is entitled to draw the
inference that the receipt are of an assessable
ITA No. 320/2012 Page 11 of 20
nature. The conclusion to which the Appellate
Tribunal came appears to us to be amply warranted
by the facts of the case. There is no ground for
interfering with that finding, and these appeals are
accordingly dismissed with costs."
(emphasis supplied)
Section 68 recognizes the aforesaid legal position.
The view taken by the Tribunal on the duty cast on
the Assessing Officer by section 68 is contrary to the
law laid down by the Supreme Court in the judgment
cited above. Even if one were to hold, albeit
erroneously and without being aware of the legal
position adumbrated above, that the Assessing
Officer is bound to show that the source of the
unaccounted monies was the coffers of the assessee,
we are inclined to think that in the facts of the present
case such proof has been brought out by the
Assessing Officer. The statements of Mukesh Gupta
and Rajan Jassal, the entry providers, explaining their
modus operandi to help assessee's having
unaccounted monies convert the same into accounted
monies affords sufficient material on the basis of
which the Assessing Officer can be said to have
discharged the duty. The statements refer to the
practice of taking cash and issuing cheques in the
guise of subscription to share capital, for a
consideration in the form of commission. As already
pointed out, names of several companies which
figured in the statements given by the above persons
to the investigation wing also figured as share-
applicants subscribing to the shares of the assessee-
company. These constitute materials upon which one
could reasonably come to the conclusion that the
monies emanated from the coffers of the assessee-
company. The Tribunal, apart from adopting an
erroneous legal approach, also failed to keep in view
the material that was relied upon by the Assessing
Officer. The CIT (Appeals) also fell into the same
error. If such material had been kept in view, the
ITA No. 320/2012 Page 12 of 20
Tribunal could not have failed to draw the
appropriate inference.
16. In the said case, the Division Bench had also examined the
decision of the Supreme Court in Lovely Exports P. Ltd. (supra) and
other cases in which the assessee had succeeded. It was noticed that in
the case of Lovely Exports P. Ltd. affidavits/confirmations of
shareholders were filed and income tax record numbers of the
shareholders were made available, but the Assessing Officer, who had
sufficient time, failed to carry out inquiry and examination. reference
was made to the observations in Divine Leasing (supra) to the effect
that there cannot be two opinions on the aspect that the pernicious
practice of conversion of unaccounted money through the masquerade
or channel of investment as share capital must be firmly excoriated by
the Revenue, but when there is preponderance of evidence to show
absence of culpability, the assessee should not be harassed by the
Revenue. A delicate balance must be maintained between the two
interests. In Divine Leasing (supra), the following proposition was
elucidated:-
"In this analysis, a distillation of the precedents yields the
following propositions of law in the context of Section 68
of the IT Act. The assessed has to prima facie prove (1) the
identity of the creditor/subscriber; (2) the genuineness of
ITA No. 320/2012 Page 13 of 20
the transaction, namely, whether it has been transmitted
through banking or other indisputable channels; (3) the
creditworthiness or financial strength of the
creditor/subscriber. (4) If relevant details of the address or
PAN identity of the creditor/subscriber are furnished to the
Department along with copies of the Shareholders Register,
Share Application Forms, Share Transfer Register etc. it
would constitute acceptable proof or acceptable
Explanation by the assessed. (5) The Department would not
be justified in drawing an adverse inference only because
the creditor/subscriber fails or neglects to respond to its
notices; (6) the onus would not stand discharged if the
creditor/subscriber denies or repudiates the transaction set
up by the assessed nor should the AO take such repudiation
at face value and construe it, without more, against the
assessed. (7) The Assessing Officer is duty-bound to
investigate the creditworthiness of the creditor/subscriber
the genuineness of the transaction and the veracity of the
repudiation."
17. Nova Promoters and Finlease (P) Ltd. (supra) after referring to
the dismissal of SLP against Divine Leasing case (supra) observed as
under:-
"...............So understood, it will be seen that
where the complete particulars of the share
applicants such as their names and addresses, income
tax file numbers, their creditworthiness, share
application forms and share holders' register, share
transfer register etc. are furnished to the Assessing
Officer and the Assessing Officer has not conducted
any enquiry into the same or has no material in his
possession to show that those particulars are false
and cannot be acted upon, then no addition can be
made in the hands of the company under sec.68 and
ITA No. 320/2012 Page 14 of 20
the remedy open to the revenue is to go after the
share applicants in accordance with law. We are
afraid that we cannot apply the ratio to a case, such
as the present one, where the Assessing Officer is in
possession of material that discredits and impeaches
the particulars furnished by the assessee and also
establishes the link between self-confessed
"accommodation entry providers", whose business it
is to help assessees bring into their books of account
their unaccounted monies through the medium of
share subscription, and the assessee. The ratio is
inapplicable to a case, again such as the present one,
where the involvement of the assessee in such modus
operandi is clearly indicated by valid material made
available to the Assessing Officer as a result of
investigations carried out by the revenue authorities
into the activities of such "entry providers". The
existence with the Assessing Officer of material
showing that the share subscriptions were collected
as part of a pre-meditated plan a smokescreen
conceived and executed with the connivance or
involvement of the assessee excludes the
applicability of the ratio. In our understanding, the
ratio is attracted to a case where it is a simple
question of whether the assessee has discharged the
burden placed upon him under sec.68 to prove and
establish the identity and creditworthiness of the
share applicant and the genuineness of the
transaction. In such a case, the Assessing Officer
cannot sit back with folded hands till the assessee
exhausts all the evidence ormaterial in his
possession and then come forward to merely reject
the same, without carrying out any verification or
enquiry into the material placed before him. The
case before us does not fall under this category and
it would be a travesty of truth and justice to express
a view to the contrary."
18. Lovely Exports Pvt. Ltd. (supra) was also considered and
ITA No. 320/2012 Page 15 of 20
distinguished in N.R. Portfolio Pvt. Ltd. (supra) and it was held that
the entire evidence available on record has to be considered, after
relying upon CIT Vs. Nipun Builders and Developers, [2013] 350 ITR
407 (Delhi), wherein it has been held that a reasonable approach has to
be adopted and whether initial onus stands discharged would depend
upon facts and circumstances of each case. In case of private limited
companies, generally persons known to directors or shareholders,
directly or indirectly, buy or subscribe to shares. Upon receipt of
money, the share subscribers do not lose touch and become
incommunicado. Call money, dividends, warrants, etc. have to be sent
and the relationship remains a continuing one. Therefore, an assessee
cannot simply furnish some details and remain quiet when summons
issued to shareholders remain un-served and uncomplied. As a general
proposition, it would be improper to universally hold that the assessee
cannot plead that they had received money, but could do nothing more
and it was for the Assessing Officer to enforce shareholders'
attendance in spite of the fact that the shareholders were missing and
not available. Their reluctance and hiding may reflect on the
genuineness of the transaction and creditworthiness of the creditor. It
would be also incorrect to universally state that an Inspector must be sent
to verify the shareholders/subscribers at the available addresses, though
ITA No. 320/2012 Page 16 of 20
this might be required in some cases. Similarly, it would be incorrect
to state that the Assessing Officer should ascertain and get addresses
from the Registrar of Companies' website or search for the address es
of shareholders themselves. Creditworthiness is not proved by
showing issue and receipt of a cheque or by furnishing a copy of
statement of bank account, when circumstances requires that there
should be some more evidence of positive nature to show that the
subscribers had made genuine investment or had, acted as angel
investors after due diligence or for personal reasons. The final
conclusion must be pragmatic and practical, which takes into account
holistic view of the entire evidence including the difficulties, which the
assessee may face to unimpeachably establish creditworthiness of the
shareholders.
19. In N.R. Portfolio Pvt. Ltd. (supra), it has been held as under:-
"18. In the remand report, the Assessing Officer
referred to the provisions of Section 68 of the Act
and their applicability. The word "identity" as
defined, it was observed meant the condition or fact
of a person or thing being that specified unique
person or thing. The identification of the person
would include the place of work, the staff, the fact
that it was actually carrying on business and
recognition of the said company in the eyes of
public. Merely producing PAN number or
assessment particulars did not establish the identity
of the person. The actual and true identity of the
ITA No. 320/2012 Page 17 of 20
person or a company was the business undertaken by
them. This according to us is the correct and true
legal position, as identity, creditworthiness and
genuineness have to be established. PAN numbers
are allotted on the basis of applications without
actual de facto verification of the identity or
ascertaining active nature of business activity. PAN
is a number which is allotted and helps the Revenue
keep track of the transactions. PAN number is
relevant but cannot be blindly and without
considering surrounding circumstances treated as
sufficient to discharge the onus, even when payment
is through bank account.
19. On the question of creditworthiness and
genuineness, it was highlighted that the money no
doubt was received through banking channels, but
did not reflect actual genuine business activity. The
share subscribers did not have their own profit
making apparatus and were not involved in business
activity. They merely rotated money, which was
coming through the bank accounts, which means
deposits by way of cash and issue of cheques. The
bank accounts, therefore, did not reflect their
creditworthiness or even genuineness of the
transaction. The beneficiaries, including the
respondent-assessee, did not give any share-dividend
or interest to the said entry operators/subscribers.
The profit motive normal in case of investment, was
entirely absent. In the present case, no profit or
dividend was declared on the shares. Any person,
who would invest money or give loan would
certainly seek return or income as consideration.
These facts are not adverted to and as noticed below
are true and correct. They are undoubtedly relevant
and material facts for ascertaining creditworthiness
and genuineness of the transactions.
30. What we perceive and regard as correct position
of law is that the court or tribunal should be
convinced about the identity, creditworthiness and
genuineness of the transaction. The onus to prove
ITA No. 320/2012 Page 18 of 20
the three factum is on the assessee as the facts are
within the assessee's knowledge. Mere production of
incorporation details, PAN Nos. or the fact that third
persons or company had filed income tax details in
case of a private limited company may not be
sufficient when surrounding and attending facts
predicate a cover up. These facts indicate and reflect
proper paper work or documentation but
genuineness, creditworthiness, identity are deeper
and obtrusive. Companies no doubt are artificial or
juristic persons but they are soulless and are
dependent upon the individuals behind them who
run and manage the said companies. It is the persons
behind the company who take the decisions, controls
and manage them."
20. Now, when we go to the order of the tribunal in the present case,
we notice that the tribunal has merely reproduced the order of the
Commissioner of Income Tax (Appeals) and upheld the deletion of the
addition. In fact, they substantially relied upon and quoted the decision
of its coordinate bench in the case of MAF Academy P. Ltd., a
decision which has been overturned by the Delhi High Court vide its
judgment in C.I.T vs. MAF Academy P.Ltd [ (2014) 206 DLT 277). In
the impugned order it is accepted that the assessee was unable to
produce directors and principal officers of the six shareholder
companies and also the fact that as per the information and details
collected by the Assessing Officer from the concerned bank, the
Assessing Officer has observed that there were genuine concerns about
ITA No. 320/2012 Page 19 of 20
identity, creditworthiness of shareholders as well as genuineness of the
transactions.
21. In view of the aforesaid discussion, we feel that the matter
requires an order of remit to the tribunal for fresh adjudication keeping
in view the aforesaid case law. The question of law is, therefore,
answered in favour of the Revenue and against the respondent-
assessee, but with an order of remit to the tribunal to decide the whole
issue afresh. One of the reasons, why we have remitted the matter is
that the cross objections of the respondent-assessee questioning notice
under Section 147/148 were dismissed as infructous and even if we
decide the issue on merits in favour of the Revenue, the cross
objections would got revived and require adjudication. The appeal is
accordingly disposed of.
(SANJIV KHANNA)
JUDGE
(V. KAMESWAR RAO)
JUDGE
AUGUST 25th, 2014
NA
ITA No. 320/2012 Page 20 of 20
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