Grant of leave - Life Insurance Service - demand of service tax of ₹ 412,78,78,686 for the period between October, 2010 and March, 2015 - Section 105 of FA - HELD THAT:- Leave granted.
Reopening of assessment u/s 147 - escapement of income to tax income from M/s. Reliance Petrochemicals Ltd. - HELD THAT:- Leave granted. Let it be listed along connected matters.
Liberty is granted to file additional documents which may be circulated within four weeks from today
Addition to belated employees' contribution to Provident fund - addition u/s 36(1)(va) r.w.s. 2(24) (x) - HELD THAT:- We consider that explanation to section 36(1)(va) makes it very much clear that for the purpose of clause (va) of sub-section(1) of section 36 “due date” means the date by which the assessee is required as an employer to credit the employee’s contribution to employees account in the relevant fund under any act, Rule or notification issued thereunder or under any standing order, award or contract of service or otherwise. During the relevant assessment year, if the employer has not deposited the entire amount towards employee’s contribution on or before the relevant (Due Date) under the PF Act/ESI Act, to the extent there is a short fall in deposit of the employee’s contribution/ESI contribution the assessee shall not be entitled to the deduction.
Assessee as an employee has to strictly adhere to the due date of payment as prescribed in the relevant Act i.e. Provident Fund Act. We have also perused the para 38 of Chapter VI of the Employees Provident Fund Act 1952 provide that the employer's and the employee's contribution shall be remitted within 15 days of the close of every month refer to close of the month to which the wages pertain but not to the month in which the wages are paid and contribution is deducted.
Taking into consideration, the decision of the Hon’ble Gujarat High Court in the case of CIT vs. GSRTC [2014 (1) TMI 502 - GUJARAT HIGH COURT] wherein it is held that deduction towards employee’s contribution is to be made as per the due date prescribed in the relevant act we do not find any merit in the submission of the assessee. Accordingly the appeal of the assessee is dismissed.
Addition u/s 68 - creditworthiness of the loan creditor - HELD THAT:- Assessee has been able to discharge the onus casted upon it to prove the identity, creditworthiness and genuineness of the loan creditor. For taking such a view we rely on the order in S. K. Bothra & Sons HUF Vs. ITO [2011 (8) TMI 22 - CALCUTTA HIGH COURT]and Crystal Network (P) Ltd. Vs. CIT.[2010 (7) TMI 841 - KOLKATA HIGH COURT] has observed that the creditors cannot be disbelieved merely because they did not respond to summons when all other documents to substantiate the loan transaction has been filed before the assessing authority.
The Hon’ble Calcutta High Court in CIT Vs. Dataware (P) Ltd. [2011 (9) TMI 175 - CALCUTTA HIGH COURT] has held that in case if the AO has doubt regarding the creditworthiness of the loan creditor, then the AO in turn had to seek report from the AO of the loan creditor and thereafter only draw adverse inference against the loan creditor.
AO has not made any exercise of this nature to discredit the loan creditor. The assessee has discharged the onus by placing all the documents before the AO/Ld. CIT(A); and the Ld. CIT(A) has taken note of all these facts to delete the addition which is supported by relevant material, so the impugned order warrants no interference and, therefore, we dismiss the appeal of the revenue. Thus, the appeal of the revenue and the cross objection of the assessee are dismissed.
Reopening of assessment u/s 147 - assessment time bared - non disposing the objections of assessee - HELD THAT:- The perusal of the reasons recorded for re-opening shows that the AO has not mentioned that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. Even the assessment order also makes no mention of such failure on the part of the assessment. It is also noticed that assessee has filed objection vide letter dated 21.01.2013, but these objection has not been disposed by AO at all except making mention thereon in the assessment order. The AO was required to dispose off objection, laid down by Hon'ble Supreme Court in the case of G.K.N.Drive Shafts Ltd. [2002 (11) TMI 7 - SUPREME COURT] and Garden Finance Ltd. [2003 (10) TMI 17 - GUJARAT HIGH COURT] AO is bound to dispose off objection filed by the assessee.
In absence of any averment that the assessments are sought to be re-opened by reason of failure on the part of assessee to disclose fully and truly all material facts necessary for assessment for the relevant assessment year, the very initiation of proceedings u/s.147 by issuance of notice u/s.148 after expiry of four years from the end of relevant assessment year is bad and cannot be sustained.
We are of the considered opinion that the re-opening amounts to change of opinion and there was no failure on the part of assessee to disclose all necessary for making assessment, hence, the same is bad in law, and therefore quashed. Accordingly, this legal ground of the assessee is allowed.
Restoration of appeal - appeal was dismissed for non-prosecution/default of non-appearance - case of appellant is that appearance could not be caused by the appellant on 13.11.2017 as the counsel representing the appellants was engaged by the Central Excise Department to represent them before the High Court and as such under a belief that he cannot argue the matter against the Central Excise Department in Tribunal, no appearance was caused.
HELD THAT:- There are no merits in the plea of the assessee inasmuch as there is no adjournment request made by the appellants for bringing the factual position on record and inasmuch as the appellants were unrepresented on all the 3-4 dates of hearing, but in the interest of justice, it is deemed fit to recall the order of dismissal and restore the appeals to their original number.
Rectification of mistake - Validity of assessment u/s 143 (3) read with Section 153 (D) - non-issue of notice u/s 143 (2) - HELD THAT:- Except an error appearing in depicting Section 153D in place of 153A of Income Tax Act, 1961, we perceive no error apparent on the face of record in the order as would warrant an indulgence.
Subject to correction of the said error, the review petition stands dismissed.
Additional depreciation claimed u/s 32 (1) (iia) on plants and machinery installed in the Captive Power Plant - P&M acquired and installed by assessee - HELD THAT:- Delhi Tribunal in case of NTPC Ltd. Vs. DCIT [2012 (5) TMI 127 - ITAT DELHI] wherein assessee’s claim of additional depreciation was disallowed on the ground that power/electricity generated by assessee could not be equated with an article or thing which was being manufactured in an industrial undertaking, held that if there can be sale and purchase of electric energy like any moveable object, then electric energy is covered by the definition of goods and thus admissibility of additional depreciation could not be denied to assessee merely on the ground that electricity is not an article or thing.
Now coming to the amendment which has been brought-in by the Finance Act 2012 w.e.f. A.Y. 2013-14 whereby the assessee engaged in the business of generation or generation & distribution of power have specifically been included and held eligible for claim of additional depreciation.
In our view, the said amendment cannot be held to disentitle the assessee to claim of the additional depreciation. Various Coordinate Benches have held that even prior to the amendment brought in by the Finance Act 2012, the assessees engaged in generation or generation and distribution of electricity were held eligible for additional depreciation. In this regard, reference can be drawn to the decision of NTPC Ltd. (supra).
No contrary authority has been brought to our notice. In our view, the said amendment cannot be read to negate the settled legal position that generation of electricity is akin to manufacture or production of an article or thing. The said amendment by the Finance Act 2012 gives an impetus to the view that generation of electricity is a manufacturing process. In light of above, the assessee is held entitled to the additional claim of depreciation on plants and machinery installed in the Captive Power Plant. Hence, the Ground No. 2 of appeal of the assessee is allowed.
Recovery of disputed liability in respect of the assessee from the assessee’s debtor - stay of demand - HELD THAT:- The fact of the loan given to Mr.Darmendra Bafna being the issue in dispute, the Revenue is directed to recover the disputed liability in respect of the assessee from the assessee’s debtor as recognized by the Revenue being Mr.Darmendra Bafna whose address has been provided by the assessee. The attachments in respect of the assets of the assessees, which have been done by the Revenue, shall remain unaltered.
The Bank account, if any, of the assessee which have been attached by the Revenue, shall stand lifted. It must be understood that when all the assets of the assessees have already been attached, obviously the assessee would be incapable of making any further payments as assessee would be unable to take loans by mortgaging the assets. However, the debtors of the assessee are still available and enforceable.
Recovery of disputed tax against the assessees is stayed with liberty to the Revenue to proceed with the recovery of the disputed tax in respect of the assessees from the hands of the assessee’s debtors, Mr.Darmendra Bafna of M/s Surana Corporation Limited. Till such time that the debt due to the assessees from Mr.Darmendra Bafna, has not been fully recovered as against the disputed demand against the assessee, no enforcement or encashment of the assets of the assessees shall be executed by the Department.
Maintainability of petition - Initiation of Corporate Insolvency Resolution Process - Corporate Debtor - Operational debt - supply of cotton bales made by the Petitioner to the Respondent/Corporate Debtor - existence of dispute or not - whether the debt is due and payable and has not yet been paid? - disputes between the Petitioner and the Respondent have been referred to mediation to M/s. Apex Cotton Agency (I) Pvt. Ltd. which is one of the dispute mechanism resolutions between the buyers and sellers arising out of dealings, contracts and transactions in respect of disputes relating to quantity and quality or the physical delivery for transactions in the cotton trading.
HELD THAT:- As already said the very fact that the Respondent issued the LC for ₹ 39,15,148/- which is far excess the claim of the M/s. SAMKIT BIO FARMS LIMITED goes to show that there was a resolution and there was an understanding - it can be said the Operational Debt due to the Petitioner and the other 2 Companies i.e., M/s. R.S. COTTMARK (INDIA) PVT. LTD. and M/s. SAMKIT BIO FARMS LIMITED has been repaid by way of encashment of LC for ₹ 39,15,148/- by M/s. SAMKIT BIO FARMS LIMITED.
Even if it is held that there is no repayment of Operational Debt due to the Petitioner and M/s. R.S. COTTMARK (INDIA) PVT. LTD. inspite of the fact that LC has been encashed by M/s. SAMKIT BIO FARMS LIMITED still the material on record goes to show that there exist a dispute between the Petitioner and the Respondent in respect of the Operational Debt claimed by the Petitioner.
This Tribunal is of the view that there exists a dispute and because of the resolution of the said dispute only, Respondent/Corporate Debtor issued LC for ₹ 39,15,148/- in favour of M/s. SAMKIT BIO FARMS LIMITED with an understanding that after encashment of LC, M/s. SAMKIT BIO FARMS LIMITED would pay amounts to the Petitioner and M/s. R.S. COTTMARK (INDIA) PVT. LTD. - the contention of the Respondent require further investigation and enquiry. It requires oral evidence even from the Company that acted as mediator in the resolution process.
Reopening of assessment u/s. 147 - validity of reason to believe - HELD THAT:- Reasons recorded clearly shows that there was no new tangible material in the hands of AO at the time of initiating reassessment proceedings u/s. 147 and at the time of issuing notice u/s. 148 therefore, it is a clear case of change of opinion on the same material which was before the AO at the time of original assessment proceedings.
No hesitation to hold that the AO did not assume valid jurisdiction to initiate reassessment proceedings and to issue notice u/s. 148 as there was no new tangible material with the AO at the time of initiating said proceedings. Therefore hold that the initiation of reassessment proceedings and issuance of notices u/s. 148 and all subsequent proceedings in pursuant thereto are bad in law being initiated without having valid jurisdiction and the same deserve to be quashed and we hold so. Accordingly, legal Ground No.1 of the assessee is allowed and consequently, initiation of reassessment proceeding u/s. 147 of the Act and notice u/s. 148 of the Act along with all subsequent proceedings and orders are quashed.
Classification of goods - peeled sliced Pineapple, put up in air tight unit container in sugar syrup - Appellant is of the view that during the entire process the basic nature of the 'pineapple' remains unchanged and it is used as 'fresh pineapple' and therefore their product should be classifiable under HSN Code 0804 - HELD THAT:- In the instant case the pineapple is peeled and cut into slices, steamed/boiled, cooked and packed in air tight containers in sugar syrup. Hence, the view of the appellant that the basic nature of their product remains unchanged is not acceptable.
In the instant case, the sugar is being used as only a sweetener and not as a preservative i.e. for the purpose of preserving the inherent nature of pineapple. Besides, products classifiable under Chapter 20 do not cover fruits which are prepared or preserved by the processes specified in Chapter 8, as per Chapter Note I(a) of Chapter 20 of Customs Tariff. Under Tariff item 0811, the fruits are cooked by steaming or boiling in water, which is also the case with the appellant's product. Under Chapter 20, the products are generally having longer shelf life and the fruits are not clearly identifiable being preparations of fruits, in case of Chapter '8' the goods have a short shelf life, once the can is opened and the fruit i.e. pineapples slices, are clearly identifiable as such.
Thus, the product supplied by the appellant is covered under Tariff Item No. 0811 and not under Tariff Item 2008.
Grant of Bail - Section 167(2) of the Code of Criminal Procedure - as on the expiry of 90th day i.e. on 07.07.2018 no report Under Section 173 of the Code was on record with the Magistrate - Can it be said that the investigation was complete for the purposes of Section 167(2) of the Code so as to deny the benefit to the Accused in terms of said provision?
HELD THAT:- The provision has a definite purpose in that; on the basis of the material relating to investigation, the Magistrate ought to be in a position to proceed with the matter. It is thus clearly indicated that the stage of investigation ought to be confined to 90 or 60 days, as the case may be, and thereafter the issue relating to the custody of the Accused ought to be dealt with by the Magistrate on the basis of the investigation. Matters and issues relating to liberty and whether the person Accused of a charge ought to be confined or not, must be decided by the Magistrate and not by the Police. The further custody of such person ought not to be guided by mere suspicion that he may have committed an offence or for that matter, to facilitate pending investigation.
In the present case as on the 90th day, there were no papers or the charge-sheet in terms of Section 173 of the Code for the concerned Magistrate to assess the situation whether on merits the Accused was required to be remanded to further custody. Though the charge-sheet in terms of Section 173 came to be filed on 05.07.2018, such filing not being in terms of the order passed by the High Court on 03.07.2018, the papers were returned to the Investigating Officer. Perhaps it would have been better if the Public Prosecutor had informed the High Court on 03.07.2018 itself that the period for completing the investigation was coming to a close - In the absence of any such similar provision empowering the Court to extend the period, no Court could either directly or indirectly extend such period. In any event of the matter all that the High Court had recorded in its order dated 03.07.2018 was the submission that the investigation would be completed within two months by a Gazetted Police Officer. The order does not indicate that it was brought to the notice of the High Court that the period for completing the investigation was coming to an end. Mere recording of submission of the Public Prosecutor could not be taken to be an order granting extension. We thus reject the submissions in that behalf advanced by the learned Counsel for the State and the complainant.
The Accused having shown their willingness to be admitted to the benefits of bail and having filed an appropriate application, an indefeasible right did accrue in their favour.
The Appellants are entitled to be admitted to bail in terms of Section 167(2) of the Code on such conditions as the trial Court may deem appropriate - appeal allowed.
Detention of imported goods - counsel for the Revenue contended that if the importer i.e. the IEC Holder purchases it, the goods could be released - HELD THAT:- This Court is of the opinion that since the goods have been in detention for more than a year and no irregularity of any kind whatsoever has been indicated by the DRI and furthermore, that the DRI has also expressed no objection for the release of the goods upon payment of the differential duty, if any, the imported goods should be released to the present petitioners who are undoubtedly the actual beneficiaries of the import. In the event, the petitioners deposit the differential duty, the goods shall be released within a week thereafter.
This is an unfortunate case where the respondents/Customs authorities intentionally appeared to have omitted issuing the detention certificate. After considering the application for waiver of the demurrage/detention charges, if any liability accrues, that shall be on account of the customs authorities in the circumstances of the case.
The Supreme Court of India dismissed the Special Leave Petition with delay condoned. Pending applications, if any, shall stand disposed of. (2018 (9) TMI 1861 - SC)
Non-issuance of C-Forms - HELD THAT:- The issue decided in the case of HINDUSTAN ZINC LIMITED, SOUTH WEST MINING LTD., KHETAN BUSINESS CORPORATION PVT. LTD., ARORAS JK NATURAL MARBLES LIMITED VERSUS STATE OF RAJASTHAN THROUGH THE PRINCIPAL SECRETARY, DEPARTMENT OF FINANCE, SECRETARIAT, JAIPUR, THE COMMISSIONER, COMMERCIAL TAXES DEPARTMENT, THE COMMERCIAL TAXES OFFICER [2018 (5) TMI 1871 - RAJASTHAN HIGH COURT] where it was held that the respondents are liable to issue `C' Forms in respect of the High Speed Diesel procured for mining purposes through interstate trade - petition allowed - decided in favor of petitioner.
Denial of deduction u/s 10B - deduction to the assessee on sales made to other EOUs - HELD THAT:- Identical issue has been considered by the Hon’ble Karnataka High Court in the case of Pr.CIT Vs. M.S.International Stone India P.Ltd [2018 (6) TMI 1478 - KARNATAKA HIGH COURT]and TATA ELXSI LTD. [2007 (10) TMI 630 - ITAT BANGLORE] ultimately held that sales made to other EOU would be considered to be in the ambit of “deemed export”. Thus we allow this common ground raised by the assessee in all three years. AO shall grant deduction to the assessee on sales made to other EOUs by treating them as “deemed export”.
Addition made on account of suppression of sales and on account of under valuation of closing stock - AO has made reference to large number of information transmitted to him by the Custom & Excise authorities - HELD THAT:- We have confronted the ld.DR whether any steps have been taken during this period of nine years by the AO for collecting any other conclusive material. The DR was unable to supply any other information. Therefore, we are of the view that a roving inquiry cannot be allowed in the affairs of the assessee endlessly. It was for the Revenue to bring concrete material on the record on which any liability can be fastened upon the assessee. The Revenue failed to bring any evidence. We could appreciate the request of the ld.CIT-DR for remitting the file to the AO if after the order of the ld.CIT(A) in the year 2010 the Revenue was able to lay its hand on any material which could be produced before the Tribunal by way of additional evidence. It appears that proceedings remained dormant even after the order of the CIT(A) when additions have been deleted. No efforts have been made to collect any further information for justifying the challenge to the order of the CIT(A). In such situation, we cannot remit the issue to the file of the AO for re-investigation. We do not find any merit in these grounds of appeal. They are rejected.
Production or manufacturing - segregation of scrap from mixed metal scrap - deduction u/s 10B and/or section 80I - HELD THAT:- As decided in assessee's own case [2014 (4) TMI 484 - GUJARAT HIGH COURT] activities undertaken by the assessee in segregating the scrap and carrying out process activities all that would amount to manufacture of article or thing whose export would entitle it for grant of deduction under section 10B as well as whose sales would entitle the assessee to claim deduction under section 80IB.
Replacement of old machineries with new one - nature of expenditure - revenue or capital expenditure - HELD THAT:- Appeal allowed in favour of assessee as relying on assessee owncase [2018 (5) TMI 1902 - ITAT SURAT] replacement of old machine with any new one will not constitute bringing into existence of new asset of enduring benefit to the assessee. Reliance placed in the case of Sri Mangayarkasi Mills (P) Ltd [2009 (7) TMI 17 - SUPREME COURT] by Revenue is not applicable, as in that case replacement of old machinery with new machinery was treated as capital expenditure, whereas, in the instant case, there is replacement of damaged part of Turbine and machinery, hence, facts are distinguishable. Therefore, the appeal of the revenue dismissed.
Carbon credit income - taxability as capital receipt - HELD THAT:- We find that the ITAT has held in A.Y. 2009-10 [2018 (5) TMI 1902 - ITAT SURAT] in the case of the assessee that carbon credit is capital receipts not taxable to tax, hence, written off by the assessee of the same in A.Y. under consideration on the ground of receivable written off is not legally tenable, hence, the findings of CIT (A) is upheld. This grounds of appeal is therefore, dismissed.
Disallowance of expenditure incurred towards Corporate Social Responsibility (CSR) - allowable revenue expenses - HELD THAT:- Identical issue has come up before the tribunal in assessment year 2009-10 as held the expenditure has been incurred on account of various relief materials like food items, kerosene, blankets etc. to the flood affected people of Bihar. Therefore, this expenditure has been incurred on behest of the State Government of Gujarat as the assessee is a public undertaking of Gujarat Government. The assessee is conscious of its corporate social responsibility and makes contributions in the ordinary course of its business towards socially useful activities and in view of very nature the expenditure incurred for corporate social responsibility is allowable as business expenditure as it was incurred for making the image of the company and towards its social responsibility reliance placed on the decision in the case of Shri Venkata Satyanarayana Rice Mills Contractors Co. vs. CIT [1996 (10) TMI 2 - SUPREME COURT] wherein contribution to the public welfare fund at the instance of the Government Authorities was allowed as the deduction on the ground that it was motivated by commercial contribution - Appeal of the Revenue is dismissed.
TDS u/s 194H - non deduction of tds on discount given to the dealers - HELD THAT:- Identical issue has come up before the tribunal in assessment year 2009-10 not possible to accept the contention of the revenue that the definition of ‘commission or brokerage’ as contained in Explanation to section 194H is so wide that it would include any payment receivable, directly or indirectly, for services in the course of buying or selling of goods and that, therefore, the discount availed of by the stamp ve,ndors constitutes commission or brokerage within the meaning of section 194H. Appeal of the Revenue is dismissed.
Accrual of income - Addition on account of Insurance Claim Lodged - whether assessee follows mercantile system of accounting A.O. has correctly added insurance claim lodged by the assessee on accrual basis? - HELD THAT:- This amount was accordingly offered to tax for the A.Y. 2013-14. This shows that actual receipt is far less than claim, hence accrual amount is not certain. Therefore, the mere lodging claim with insurance company does not result in accrual of income to the assessee unless it is settled by the insurance company. CIT(A) has held that mere lodging of insurance claim on the basis of surveyors assessment does not result into accrual of income of the assessee. There is a change of accounting policy in respect of insurance claim by the assessee but there is no change in method of accounting employed by the assessee. We are in agreement with the findings recorded by the CIT(A), accordingly same is upheld, this ground of Revenue is therefore dismissed which is also supported by the case laws relied by the assessee as mentioned above. - Decided against revenue.
Addition on account of agriculture income as unexplained cash credits u/s. 68 - HELD THAT:- AO held that to avail production of agriculture produce shown by the assessee the expenses are quite low the assessee has not produce anything on record to establish that how he could obtain such a high yield by spending less on expenses related to agricultural income. AO also noted that no supporting evidence to support receipts on account of agricultural income or bills in support of agriculture related expenses such as fertilizers seeds, pesticides, labour etc. were submitted which again supports the allegation and stand of the AO. Before us also the ld. AR could not show us any documentary evidence supporting the fact of expending amounts on agriculture activity and for procurement of agriculture crop therefore, the appellant could not negate the allegations and contention of the AO.
AR could not show us any contrary situation or facts to compel us to hold that the observations of the authorities below are not sustainable. In this situation, we are inclined to hold that the addition made by the AO and confirmed by the CIT(A) is quite justified and based on cogent reasons and we are unable to see any valid reason to interfere with the same. Hence, the conclusion drawn by the authorities below is uphold and consequently sole ground of assessee being devoid of merits is dismissed by upholding the addition - Decided against assessee
Addition u/s 68 - huge cash deposit made in the bank account operated by assessee were not explained and the primary onus of proving the source were not discharged by the assessee - HELD THAT:- When the impugned deposits have been considered in the hands of respective account holders for making additions u/s. 68 of the Act then, the same amount cannot be added to the income of the assessee in the same AY 2011-12 on the same allegations and thus, we are inclined to hold that the ld. CIT(A) was right in deleting the entire amount of addition made by the AO u/s. 68 of the Act. Therefore, we are unable to see any ambiguity, perversity or any other valid reason to interfere with the conclusion drawn by the ld. CIT(A) and hence, we uphold the same.
Addition u/s 69 - HELD THAT:- Neither the AO nor the DR has controverted the fact that the addition has been made by the AO by treating the amount deposited to the bank account owned by the assessees’ brother Shri Samir Kumar as income of the assessee. In fact, the amount of ₹ 8,64,267/- was representing the maturity value of insurance policy of M/s. Bajaj Alliance Insurance standing in the name of appellant’s brother Shri Samir Kumar therefore, the same was deposited to the account of assessee’s brother and such amount cannot be treated as unexplained income of the assessee u/s. 69 of the Act thus, the CIT(A) was right in deleting the addition.
Addition on account of unaccounted bank interest which was not shown in the computation of income - HELD THAT:- When the accounts were opened in the names of family members of the assessee and assessee was power of attorney to operate these accounts and the AO could not bring any material on record to show that the assessee was real owner and beneficiary of these accounts and the cash deposits made therein were in fact amounts belonging to the assessee then, the interest earned in such accounts cannot be treated as income in the hands of the assessee. - Decided in favour of assessee.
Manufacture or production - Whether the compressed natural gas produced by the appellant, having different name, character and use from natural gas can be said to be covered by the phrase manufacture or production? - HELD THAT:- Permission is granted to file additional documents.
Learned counsel appearing for the respondent-Assessee submits that the issue involved in this appeal is covered by some decision of this Court. If that be so, list the matter for final hearing in the next month.
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