TMI Blog2010 (4) TMI 1092X X X X Extracts X X X X X X X X Extracts X X X X ..... nge at the relevant time. The payment of sale consideration has also flown from the bank account of the broker where the fund came through clearing, not in cash. The decisions of the lower authorities are influenced by the general observation of the Investigation Wing that arose a suspicion turned into conclusive proof in the minds of the authorities that everybody who has sold the shares at a high price has converted his unaccounted money through accommodation entries. This approach does not have any leg to stand. Hon'ble Supreme Court in the case of Umacharan Shaw Bros. vs. CIT [ 1959 (5) TMI 11 - SUPREME COURT] has clearly laid down that suspicion howsoever strong cannot take place of proof. From the entire appreciation of evidence, I noted that AO has failed to establish that the assessee has introduced her own unaccounted money in the shape of alleged sale proceeds of shares. Hon'ble Supreme Court in the case of Kishinchand Chellaram vs. CIT [ 1980 (9) TMI 3 - SUPREME COURT has observed that the amount cannot be assessed as undisclosed income of assessee in the absence of positive material brought by the Revenue to prove that the amount in fact belonged to a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dings of the authorities below are based purely on conjectures, surmises, suspicion and hypothesis and are liable to be set aside. 3. The grounds of appeal raised by the Revenue are as under : (1) That the learned CIT(A)-II, Agra has erred in law and on facts in directing the AO to tax out of the total amount of unexplained income of the assessee of ₹ 12,19,538, the amount of ₹ 5,98,000 received through draft dt. 20th Jan., 2001 only in the asst. yr. 2001-02 and to bring to tax the remaining amount in the asst. yr. 2002-03 ignoring the fact that the assessee has followed mercantile system of accounting and accordingly she herself has claimed deduction under s. 54F of the IT Act on the total amount of alleged capital gain in the year under consideration, (2) That the decision of the learned CIT(A)-II, Agra being erroneous in law and on facts deserves to be quashed and that of the AO deserves to be restored, (3) That the appellant craves leave to add or alter any or more ground or grounds of appeal as may be deemed fit at the time of hearing of appeal. 4. Briefly stated, the facts of the case are that the assessee filed her return of income, as an indivi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns, the learned AO inferred that the case of the assessee regarding genuineness of the share transaction was not established. The evidences so collected by him were confronted to the assessee and she was also required to produce the share broker and the representative of the company along with its books of accounts. The learned AO also directed the assessee to be personally present for further investigation. Thereafter, various query letters were sent to the assessee. Assessee furnished the present address of M/s Sudev Industries Ltd. as 247, Sector 19, Noida (UP). It was also submitted to counter the evidence with regard to enquiries conducted from the Jaipur Stock Exchange that trading of share was done through Madhya Pradesh Stock Exchange, Indore and not through Jaipur Stock Exchange. It was further explained that the number of bank draft issued by the State Bank of Indore, Branch Green Park, New Delhi is 389058 dt. 20th Jan., 2001 for an amount of ₹ 5,98,500 and D.D. No. 276880, dt. 8th Aug., 2001 for an amount of ₹ 6,17,993. Learned AO with a view to verify the above contention of the assessee made enquiries from M/s Sudev Industries at its present address given b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed no P.K. Jain existing at Jaipur. However it is noticed that Shri P.K. Jain was registered share broker in Jaipur Stock Exchange. (6) From Jaipur Stock Exchange it is inquired that there is no trading of shares of M/s Sudev Industries Ltd. during the period under consideration. (7) The assessee on being informed filed the rate of shares quoted in Madhya Pradesh Stock Exchange which means that the shares alleged to have been sold from Madhya Pradesh Stock Exchange. (8) On enquiries conducted from Madhya Pradesh Stock Exchange it is noticed that during the period trading of 200 shares was made. The shares alleged to have been sold by the assessee are not registered with Madhya Pradesh Stock Exchange and the trading of 200 shares was made under permitted category. As the assessee has claimed the sale of 17,000 shares of the company the trading of 200 shares cannot be trading of shares held by the assessee. (9) Meanwhile enquiries were conducted from M/s Sudev Industries Ltd. at the given address'Sector 19, Noida and it is noticed that the shares are still in the name of the assessee. (10) The assessee has never furnished any detail about name and address of person ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the assessees. They have categorically stated that they first received cash amounts from persons who used to seek entries from them and against the cash receipts they had given them cheques/drafts. (iii) that the increase of value of shares is highly abnormal and unrealistic. In just 15 to 16 months' time the prices of these shares have allegedly increased by more than 16 times. In the instant case, the information received from M/s Madhya Pradesh Stock Exchange reveals that the trading only of 200 shares is quoted with the exchange on 14th Nov., 2000 to 17th Nov., 2000, then on 20th Nov., 2000 and again on 28th Nov., 2000 @ ₹ 36.70, ₹ 39.60, ₹ 42.76, ₹ 46, ₹ 49.60 and ₹ 72 respectively which shows the tactics of increasing the rate of shares of a particular company to get such type of persons (as assessee) benefited with the trading of only 200 shares each day in the stock exchange. In such a short period the shares of no other reputed company has increased so much. The company under reference is small timers and is not reputed and known company. Even it is not known as to what business this company is doing. The share market as a who ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... receipt of drafts as per their dates of receipts by observing that after accepting the sale proceeds of ₹ 12,19,438 as undisclosed income of the assessee, in principle, only a sum of ₹ 5,98,000 has to be added in the year under consideration as this amount was received vide draft dt. 20th Jan., 2001 and the balance amount has to be considered in asst. yr. 2002-03 because an amount of ₹ 5,98,000 was received through draft dt. 8th Aug., 2001. 8. Now, the assessee is aggrieved against entire addition and the Revenue is aggrieved against the spreading of this amount in two years and raised the above extracted grounds of appeal. 9. In effect the issue raised by both the parties are common and can be decided simultaneously. 10. We have heard the rival submissions in details and also gone through the entire pieces of evidences which are placed in the paper book of the assessee as well as the entire assessment order as well as the appellate order and have also considered the decisions relied before us. 11. First of all we have to address the grounds raised by the assessee to ascertain whether the impugned amount of ₹ 12,19,538 is actual sale considerati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned Authorised Representative has invited attention to p. 24 of paper book which was a letter written by Addl. CIT, Khand-2, Jaipur by Income-tax Inspector Shri Manohar Vijay which was directly obtained by the H.O., Firozabad by G.P. Gargh, ITO while making enquiry in relation to Shri P.K. Jain. It was informed that P.K. Jain Associates' owner Shri Jain was residing in C-9, Bapunagar which house has 3 portions, one of the portions was in occupation by one Shri Ajay Sharma during the period February, 2004 and that Shri Ajay Sharma purchased that portion of the house four years ago from Shri P.K. Jain. The Inspector has also clarified that Shri P.K. Jain was residing in this house four years back. At pp. 25 to 36 a copy of the third remand report sent by ITO is placed. From the remand report it is evident that the existence of Shri P.K. Jain, proprietor M/s P.K. Jain Associates was confirmed but as per the correspondence between the ITO and Shri P.K. Jain the transaction mentioned by the assessee was fictitious. After examining the above-mentioned evidences it can be inferred that it is an undeniable fact that the purchase of shares is not at all in dispute but the learned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng more is expected from a man in such sale transaction of shares. The main ground for suspecting the sale of these shares by the learned AO is the exorbitantly high sale price of shares and that a scam of large scale fictitious share transactions were detected by the Department. The scam which was noticed in some other company's shares cannot be relevant insofar as this case is concerned. Even the transaction with the scammers (or brokers) who were indulging in illegal activities has to be examined according to its merits. Insofar as exorbitant price of the shares at that time is concerned, it is proved on record that the sale price of share on that date was actually very high which is proved from quotation of the Madhya Pradesh Stock Exchange which is on record. The learned Authorised Representative has referred to a paper placed in the paper book, according to which, it could be seen that there is a scintillating rise and fall of the prices of shares even on the very single day. It is not an uncommon fact. Rather this is the reason why shares are purchased. The people want to become rich overnight. The assessee has sold 17,000 shares through the share broker and the selling ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 801 (SC) that apparent must be treated till it is shown that the apparent is not real. It is true that the apparent must be treated as real until there are reasons to believe that the apparent is not real. The Department cannot act unreasonably while considering the explanations of the assessee. The facts of the given case have to be examined in their totality in the light of attending circumstances. The letters written by Shri P.K. Jain, copies of which are placed on record, have to be considered in view of the fact that earlier even when the assessee tried the whereabouts of Shri P.K. Jain was not found yet he has written three letters successfully on which the signatures of Shri Jain are found to be microscopically different. There is force in the submission of learned Authorized Representative that the fact of detection of the ongoing scam in Shri P.K. Jain's case, in order to save his own skin he may have written such letters that the bank account was fictitious and it was only an accommodation entry. It is found for certain that the share broker Shri P.K. Jain Associates had actually issued the impugned drafts. The person who says that he gave accommodation entry after ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt of ₹ 14 lakhs belonged to the assessee as stated by the share broker. The assessee received ₹ 12,16,493 through D.D. whereas the amount shown as belonging to her as paid to the broker for payment of DDs. comes to ₹ 14 lakhs. The excess amount of ₹ 1,83,507 comes to nearly 15 per cent of the amount of DD prepared. So what happened to remaining amount because nobody would give such a huge commission. Whereas she had to pay tax on long-term capital gain at 10 per cent only without taking benefit of indexation. It clearly shows that no sane person could get the bogus entry in these circumstances. So the averments of the letter of Shri P.K. Jain seems to be vague and absurd and these cannot be accepted as correct. Shri P. K. Jain Associates were share broker during 2000-01 it is established clearly from the records. He was also active member of Jaipur Stock Exchange. His residence was also proved even by the independent enquiries conducted by the learned AO. So it cannot be said that the broker had not entered into share transaction with the assessee. Rather the transaction with the assessee cannot be ruled out as he was very much in active business at that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned Brother, and also discussed the same with him. However, being unable to bring myself in agreement therewith, I proceed to write my separate order, as under. 2. The only issue arising in the assessee's appeal in the present case is the non-acceptance of its claim in respect of long-term capital gain on the sale of shares, which stands treated by the Revenue as income from other sources, as in its view the assessee was unable to prove the share transaction(s) yielding the 'capital gain' under reference. 3.1 For the detailed reasons listed in the case of Baijnath Agarwal (ITA No. 133/Agra/2005), I have, vide my dissenting order dt. 10th Feb., 2009, taken a different view from that by my learned Brother, dismissing the assessee's appeal on this ground, in that case. 3.2 On the basis of the hearing, and the examination of the record, I find the facts and circumstances in the present case, as also the respective cases of the opposing parties, as very similar to that obtaining in the case of Baijnath Agarwal (supra). As such, for the detailed reasons as mentioned therein, I consider the Revenue's case as legally sustainable, so that it would stand to be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng the claim of long-term capital gain of ₹ 11,40,826 from sale of shares. That the orders and findings of the authorities below are based purely on conjectures, surmises, suspicion and hypothesis and are liable to be set aside. Grounds raised in ITA No. 101/Agra/2005 by Revenue : (1) That the learned CIT(A)-II, Agra has erred in law and on facts in directing the AO to tax out of the total amount of unexplained income of the assessee of ₹ 12,19,538, the amount of ₹ 5,98,000 received through draft dt. 20th Jan., 2001 only in the asst. yr. 2001-02 and to bring to tax the remaining amount in the asst. yr. 2002-03 ignoring the fact that the assessee has followed mercantile system of accounting and accordingly she herself has claimed deduction under s. 54F of the IT Act on the total amount of alleged capital gain in the year under consideration. (2) That the decision of the learned CIT(A)-II, Agra being erroneous in law and on facts deserves to be quashed and that of the AO deserves to be restored. 2. The brief facts of the case are that the assessee filed her return of income on 31st Oct., 2001 at ₹ 2,08,100 which included long-term capital gai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re amount of cheque/draft will be treated as income from undisclosed and unexplained sources. Accordingly, the AO treated the entire amount of ₹ 12,19,538 received against the sale proceed of shares as income from undisclosed and unexplained sources. 3. When the matter went before the CIT(A), the CIT(A) partly allowed the appeal of the assessee by observing as under : 5.12 Considering the above facts and the legal position it is held that the AO was justified in holding that the share transactions were sham and bogus. The same have been shown just to convert the appellant's unaccounted income into white. The alleged sale proceeds of ₹ 12,19,538 represented the assessee's undisclosed income. Thus, AO's action, in principle, is upheld. However, since in this year the assessee has received only ₹ 5,98,000 vide draft year i.e. asst. yr. 2002-03. In the result, in this year addition to the extent of ₹ 5,98,000 is confirmed. 6. In the result, the appeal is partly allowed. 4. When the matter came before the Tribunal, learned JM decided the case in favour of the assessee while the learned AM decided the case against the assessee. Learned JM ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (Agra)(Trib) 158 assessee was neither a director in the company nor related to them. He also had no control over the stock exchange. As such, he was not in capacity to manipulate or rig the share prices. Reliance on the letters of the broker M/s P.K. Jain Associates, who admits of his dubious dealings, without testing them is a fatal mistake by the Department. The averments of the letters were disputed and did not inspire credence, yet the Department simply relied on them without examining the broker and his books of accounts and without providing cross-examination to the assessee. In the absence of letters of the broker being tested by the AO it cannot be said that they are completely believable. Reliance was placed on the decision in the case of CIT vs. SMC Share Brokers Ltd. (2007) 210 CTR (Del) 353 : (2007) 288 ITR 345 (Del). The sale consideration was received through demand drafts from the account of the broker. No cash was found credited in that account prior to issue of demand draft. Money came through transfer from the account of a limited company. In that situation, the Department has also not been able to establish on the basis of positive material that the sale consid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h the assessee and also mentions that bill dt. 15th Dec., 2000 in the name of the assessee seems to be fictitious one and appears to be only an accommodation entry. In the second letter dt. 4th Aug., 2004 he states that he had issued draft to the assessee and he received the cash from the assessee. In this letter he also mentions that cash received by him was routed through some bogus account and the balance came to his current account No. 6351026 from which the draft was issued by State Bank of Indore on behalf of ABN Amro Bank. In this letter, he did not disclose all the accounts through which the cash was routed and even the name of the banker in which the current account No. 351026 exists. Vide letter dt. 28th Sept., 2004 he informed that he has received ₹ 5,00,000 from the assessee and the same was deposited in two banks on 7th Aug., 2001. Particulars of the bank accounts were not given. When further enquired vide letter dt. 22nd Nov., 2004, he gives the details of the cash alleged to have been received but still did not disclose who were the owners of these companies, who was controlling them and what connection he had with these companies. He never pointed out that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dissent order the learned AM has mainly relied on its separate order passed in the case of Baijnath Agarwal (ITA No. l33/Agra/2005). I have gone through the order of Baijnath Agarwal and noted that in his dissent order in that case the learned AM has relied on the decision of Ashok Kumar Lavania (ITA No. 112/Agra/2004). I have gone through the decision of Ashok Kumar Lavania in ITA No. 112/Agra/2004 which was decided by the Bench constituting of same learned JM and learned AM vis-a-vis the facts of the case of the assessee. In that case also the transaction of sales has not been accepted by the AO as he doubted the sale prices and also relied on the statement of Shri Ashok Gupta, director of M/s JRD Stock Brokers (P) Ltd. who stated that as a matter of fact there was no actual purchase and sale of shares as was reflected in the contract notes issued by M/s JRD Stock Brokers (P) Ltd. to the beneficiaries. In that case the assessee claimed long-term capital gain of ₹ 25,14,770 and claimed exemption under s. 54EA of the Act. The long-term capital gain was shown on account of sale of shares through the brokers. The assessee submitted the copies of bills, share certificates, contr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itnesses of the Department. The Department has got statements of these brokers which are used against the assessee. Irrespective of the fact that the statements were recorded at the back of the assessee and that the assessee was or was not afforded opportunity for cross-examination, when overwhelming documentary evidences are produced by the assessee, the burden shifts on the Revenue to explain away them. Every time the statements cannot help the Department. How the above-mentioned evidences could be ignored ? The Revenue has to give reasons for rejecting them. These are important documents, some of them arise under the provisions of the Companies Act. The brokers were never confronted with the evidences produced by the assessee. The apparent has to be treated as a real unless proved otherwise. Long ago Hon'ble Supreme Court has laid this law while rendering the celebrated decision in the case of CIT vs. Daulatram Rawatmull (1964) 53 ITR 574 (SC). The assessee has countered the statements of brokers by way of his duly sworn-in affidavit. We have examined the entire evidences placed in the paper book of the assessee. (12) In the case of ITO vs. Smt. Kusumlata (2006) 105 TTJ ( ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t is established that the assessee acquired the shares to earn proit. There is no evidence except speculation that this profit is not from the sale of shares. The AO has failed to establish his case and to discharge the requisite burden cast on him. The Authorised Representative has filed the requisite quotation of 18th July, 1996 along with the requisite proof of transactions of 9,000 shares along with transfer of share certificate. Therefore, in the given facts and circumstances of the case, the CIT(A) has correctly come to the conclusion that the assessee has dealt in these shares and these transactions cannot be held bogus. The deletion of addition of ₹ 4,99,062 is confirmed.' (13) The above decision clearly helps the case of the assessee. (14) Credence cannot be given to the statements of the persons who themselves admit and have dubious dealings as against the documentary evidences produced by the assessee. (15) Moreover, when purchases have not been doubted or disputed by the Revenue in this case, the decision of Hon'ble Punjab Haryana High Court relied by learned Authorised Representative in the case of CIT vs. Anupam Kapoor (2007) 212 CTR (P H) 491 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any has directly confirmed to the AO the purchase of the shares by the assessee in reply to the notice issued under s. 133(6). The learned AM was also the party to that decision. I noted that in this case the AO has doubted the sale consideration because the share price has increased tremendously. I noted that in the case of Ashok Kumar Lavania (supra) also the assessee has purchased the shares @ ₹ 4 per share and sold @ ₹ 65 to ₹ 84 per share. In that case also the broker has not accepted the transaction but on the basis of the evidence the Tribunal has accepted the transaction to be genuine one as there was no corroborative evidence to support the statement of the broker. In this case, I noted that the statements of the broker couldn't be given any credence as he has stated differently vide different letters. Earlier he denied the transaction being entered into. Subsequently he has accepted that he has issued the draft after receiving the cash. Again he said that the cash was routed through some bogus account but he accepted that the draft has been made from his account. Subsequently, again he pointed out that he received cash of ₹ 9,00,000 and ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... were never examined by the AO himself cannot be held to be sufficient to come to the finding that the transaction was not genuine and more so when there are other material and evidences to support the transaction. 13. Hon'ble Delhi High Court in the case of CIT vs. SMC Share Brokers Ltd. (supra) also observed as under : There is no doubt that the statement of Manoj Agarwal had evidentiary value but weight could not be given to it in proceedings against the assessee without it being tested under cross-examination. In the absence of statement being tested, it cannot be said that it should be believed completely to the prejudice of assessee. 14. Under these facts, I am of the opinion that the case of the assessee is duly covered by the Division Bench of this Tribunal in the case of Ashok Kumar Lavania in ITA No. 112/Agra/2004 which has been decided by the Bench constituting of the same very learned Members. Judicial discipline demands that on the similar facts the Bench is bound to follow its earlier decisions. The principles of judicial discipline require that the order of the Co-ordinate Bench has to be followed. 15. I have also been nominated as Third Member in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Hon'ble Punjab Haryana High Court in the case of CIT vs. Anupam Kapoor (2007) 212 CTR (P H) 491 : (2008) 299 ITR 179 (P H) has also observed as under : The Tribunal was right in rejecting the appeal of the Revenue by holding that the assessee was simply a shareholder of the company. He had made the investment in a company in which he was neither a director nor was he in control of the company. The assessee had taken shares from the market, the shares were listed and the transaction took place through a registered broker of the stock exchange. There was no material before the AO, which could have lead to a conclusion that the transaction was simpliciter a device to camouflage activities to defraud the Revenue. No such presumption could be drawn by the AO, merely on surmises and conjectures. 18. In the stock exchange when the transaction is entered into, the assessee is not aware of the buyer of the shares. He enters into transaction only through a share broker. Therefore, the observation of the AO that the assessee could not identify the buyer cannot be the basis of regarding the transaction to be non-genuine one. I also noted that the AO has been influenced with the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s available R on record, there is no averment, much less any evidence, with the Revenue in this regard. While there may be enough grounds with the AO to carry out the impugned verification exercise to test the efficacy of the transactions resulting in long-term material gains in the hand of the assessee but there is no cogent material or evidence to indicate that the impugned sale proceeds reflected unaccounted income of the assessee. 20. It was the duty of the AO to bring on record sufficient evidences and materials to prove that the documents filed by the assessee were bogus, false or fabricated and the long-term capital gain shown by him was actually his income from undisclosed sources. The only material to support such conclusion of the lower authorities is either the findings of the DDI in general investigations or the twisting statements of M/s P.K. Jain Associates which remain untested by the AO himself. None of the judicial precedents supports the case of the Revenue. While making addition as income from undisclosed sources, burden on the Department is very heavy to establish that the alleged receipt was actually income of the assessee from the undisclosed sources. Jo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /2004 (Delhi Bench 'SMC'); (ii) Dilip Gargh vs. ITO'ITA No. 470/Agra/2004; (iii) Gopal Prasad Agarwal vs. Asstt. CIT'ITA No. 128/Agra/2004. 22. I also noted that the case of the assessee is duly covered by the decision of the Third Member in the case of Smt. Sunita Oberoi vs. ITO, ITA No. 273/Agra/2004; asst. yr. 1995-96, dt. 7th Aug., 2009, (2009) 30 DTR (Agra)(TM)(Trib) 474, in which on difference of opinion on the question under the similar circumstances whether the assessee can be said to have discharged her burden to prove the genuineness of the transaction in shares of M/s Prasidh Exports Ltd. and M/s K.L.P. Finance Ltd. or that the burden had shifted on the Revenue that can be held to have not discharged by them, the decision to uphold accepting of alleged profit on alleged share of M/s Prasidh Exports Ltd. and M/s K.L.P. Finance Ltd. as income from other sources instead of assessee has claimed the capital gain is a correct decision or not. The Hon'ble Third Member has held as under : The only reason to make the addition is that confirmation from the share brokers could not be filed by the assessee and summons issued to the said persons were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ence on record, I am of the considered view that the action of the CIT(A) was not correct in confirming the assessment of ₹ 12,19,538 as the income from undisclosed sources as against the sale consideration of shares declared by the assessee. The CIT(A) was not justified in rejecting the claim of long-term capital gain of the assessee from sale of shares. I accordingly direct the AO to assess the income declared from the sale of shares under the head income from long-term capital gain. Thus, the ground Nos. 1 and 2 of assessee's appeal should be allowed. Ground No. 3 of assessee's appeal is consequential in nature, does not require any adjudication. So far the ground No. 1 of Revenue's appeal is concerned, the same should stand dismissed as infructuous in view of my decision on ground Nos. 1 and 2 of assessee's appeal. Ground No. 2 in Revenue's appeal is also consequential in nature and should stand dismissed. 24. The matter will now go before the regular Bench for deciding the appeal in accordance with the majority opinion. p.k. bansal, a.m. : 13th April, 2010 In these cases the difference arose ..... X X X X Extracts X X X X X X X X Extracts X X X X
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