TMI Blog2018 (8) TMI 60X X X X Extracts X X X X X X X X Extracts X X X X ..... essee. Accordingly, in facts and circumstances of the case when the addition was made by the AO purely on ad hoc estimation and without any tangible material, the same is not sustainable and consequently is liable to be deleted. Hence we delete the addition made by the Assessing Officer and sustained by the ld. CIT(A) on this account. Accordingly, ground No. 1 of the assessee’s appeal is allowed and ground No. 1 of the revenue’s appeal is dismissed. Interest chargeable U/s 234B after giving the credit of the amount in the PD account - cash seized during the search and seizure action is available for adjustment against the advance tax liability and consequently chargeability of interest U/s 234B - Held that:- Accordingly in view of the binding precedents as well as the CBDT circular, we do not find any error or illegality in the impugned order qua this issue. Hence, this ground of revenue’s appeal is dismissed. Addition made by the Assessing Officer on account of cash deposits in the bank account of employees of the assessee - Held that:- in absence of any documentary evidence of operating of the bank accounts by the assessee, the mere availability of cheque books with the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... und as per the revised fund flow statement. Moreover when we have already decided the issue of jewellery in favour of the assessee, then the question of disallowance on account of short fall of fund and making excess investment does not arise. Accordingly, in view of the facts and circumstances of the case, we do not find any error or illegality in the impugned order of the CIT(A). Hence, the grounds No. 1 and 2 raised in the revenue’s appeal is dismissed. - ITA No. 919/JP/2016, ITA No. 932/JP/2016, ITA No. 920/JP/2016, ITA No. 933/JP/2016, ITA No. 921/JP/2016, ITA No. 934/JP/2016, ITA No. 922/JP/2016, ITA No. 935/JP/2016, ITA No. 923/JP/2016, ITA No. 936/JP/2016 And ITA No. 924/JP/2016 - - - Dated:- 30-7-2018 - SHRI VIJAY PAL RAO, JM AND SHRI VIKRAM SINGH YADAV, AM ITA No. 937/JP/2016 And ITA No. 938/JP/2016 For The Assessee : Shri P.C. Parwal (CA) For The Revenue : Smt. Rolee Agarwal (CIT-DR) ORDER PER: BENCH These are set of six cross appeals filed by the assessee and the revenue for the A.Ys. 2007-08 to 2012-13 and an appeal filed by the revenue for the A.Y. 2013-14 directed against the respective orders of the ld. CIT(A) arising from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2009-10 45,40,510 1,32,75,966 + 8,32,800 22,75,060 + 8,32,800 2010-11 1,30,94,390 26,84,725 + 29,75,859 11,84,725 + 29,75,859 2011-12 3,20,29,420 82,59,551 82,59,551 2012-13 3,00,06,860 69,54,913 69,54,913 2013-14 14,87,160 2,16,92,730 Nil Since the ld. CIT(A) has allowed part relief to the assessee, therefore, both the assessee as well as the revenue are aggrieved by the impugned orders of the ld. CIT(A) and filed cross appeals for the A.Ys. 2007-08 to 2012-13. For the A.Y. 2013-14, the ld. CIT(A) has deleted the addition made by the Assessing Officer, therefore, the revenue has filed the appeal against the impugned order of the ld. CIT(A). 4. In the appeals for A.Y. 2007-08, the assessee as well as the revenue have raised following grounds in the cross appeals: Grounds of assessee s appeal: 1. The ld. CIT(A) has erred on facts and in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stallments of ₹ 120/- each. Likewise for a loan of ₹ 20,000/-, there will be 100 equal installments of ₹ 240/- each total amounting to ₹ 24,000/-. Thus, the Assessing Officer estimated the income from interest ranges from 60% to 72% as it was also disclosed by one of the assessee s employee Shri Mahaveer Prasad Sharma in his statement recorded U/s 132(4) of the Act on 31/7/2012. Since the seized record contains the entries of finance activity w.e.f. 19/6/2009 therefore, prior to the said date, there was no material disclosing any income on this activity. The Assessing Officer took the balance sheet as on 30/09/2009 showing capital of ₹ 8,72,54,810/- and estimated the undisclosed income for the period 01/4/2006 to 17/06/2009. The assessee in the return of income, declared the income from the finance scheme on estimated basis which was not accepted by the Assessing Officer and found to be on lower side considering the fund involved in the financing business prior to 01/4/2006. The Assessing Officer accordingly took opening balance of ₹ 8.00 crores as on 01/4/2006 and on said capital, the Assessing Officer estimated interest income for the A.Y. 2007 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e said period. Thus, the income declared is more than the investment found for these periods. Hence, the ld AR has submitted that the assessee has given all relevant details supporting the claim of the assessee alongwith the fund flow statement that the addition made by the Assessing Officer and sustained by the ld. CIT(A) on estimation basis without any tangible material is not justified and the same may be deleted. 8. On the other hand, the ld CIT DR has submitted that the opening balance of ₹ 8.00 crores as on 01/4/2006 is not in dispute and therefore, the Assessing Officer has estimated the interest income by considering the said amount by taking a backward calculation of fund available with the assessee deployed under 100 days scheme. The Assessing Officer has duly given rebated on account of ill health of assessee during the period and therefore, estimation made by the Assessing Officer is not without any basis but it is very well passed on the scientific method of computing the income by taking the opening balance of ₹ 8.00 crores as on 01/4/2006 and then computing the backward estimation of income from that date downwards, therefore, the Assessing Officer has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 153A for the A.Y. 2007-08 to 2009-10 are falling in the category of reassessment as original assessment as on the date of search were not pending and therefore, in absence of abetment of assessments the orders passed by the Assessing Officer are in the nature of reassessment pursuant to the search and seizure action U/s 132 of the Act. It is settled proposition of law that in the reassessment proceedings U/s 153A of the Act, the Assessing Officer can assessee an income based on seized material. In absence of any seized material regarding the interest income for the year under consideration, no addition can be made on estimated basis. It is an undisputed fact that the material found during the search and seizure action contains the entries w.e.f. 19/6/2009 and therefore, prior to the said period, no record or material was found to disclose or indicate any income on account of interest on the scheme. Only fact which can be ascertained from the documents is that the assessee was engaged in the business activity of finance under the scheme known as 100 days scheme. However, in absence of any seized material, the Assessing Officer cannot make an addition on estimate basis. The assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act after giving the credit of the amount in the PD account. 12. Aggrieved by the order of the ld. CIT(A), the revenue has raised this issue before the ITAT. The ld CIT-DR had submitted that as per explanation-2 to Section 234B of the Act, no adjustment is allowed of seized cash against the tax liability, therefore, the ld. CIT(A) has committed error in allowing the relief on account of interest chargeable U/s 234B of the Act. 13. On the other hand, the ld AR of the assessee has submitted that the ld. CIT(A) has decided this issue by following various decisions on this point. The explanation-2 to Section 132B of the Act has been introduced in the statute by the Finance Act, 2013 w.e.f. 01/6/2013, therefore, the said explanation is applicable prospectively and is not application for the assessment year under consideration. The ld AR has also referred to the CBDT Circular No. 20/2017 dated 12/06/2017 and submitted that the CBDT has clarified that prior to 01/6/2013, the seized/requisitioned cash can be adjusted against the advance tax liability as held by the various courts and the department has accepted the judgments including the judgment of Hon ble Punjab Haryana H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pported by learned Departmental Representative, the liability towards advance tax does not form a part of the expression 'existing liability' appearing in s. 132B(l)(i) of the Act. In our considered opinion, even liability to pay advance tax is per the statutory provisions and we find no plausible reason to ascribe a restricted meaning to the expression 'existing liability' appearing in s. 132B(1)(i) of the Act, as being contended by the Revenue. The argument set up by the Revenue is that the expression 'existing liability' is referred in the context of the IT Act, 1961. The WT Act, 1957, The Expenditure tax Act, 1987, the GT Act, 1958, and the Interest-tax Act, 1974, and since in the other statutes, there is no concept of advance tax, therefore the expression 'existing liability' used in s. 132B(1)(i) cannot be understood to mean advance tax liability under the IT Act, 1961. In our considered opinion, interpretation placed by the Revenue is misplaced and would lead to absurd results. 9. It is well understood that as per s. 4 of the Act, an assessee is chargeable to income-tax in respect of his total income. Sub-s. (2) of s. 4 prescribes that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1st June, 2002. Sec. 132(5) of the Act required the AO to make an enquiry and thereafter make an order to deal with the seized assets. Sec. 132(5) of the Act authorizes the AO to retain in his custody such assets as in his opinion were sufficient to satisfy the aggregate amounts referred to in cls. (ii), (iia) and (iii) of s. 132(5) and obligated him to release the remaining seized assets. In this background, the Hon'ble High Court, on the facts of the case before it, held that unless an order under s. 132(5) of the Act is passed, the AO could not direct that the assets seized be adjusted towards advance tax liability. The Hon'ble High Court specifically noted that it is only after an order under s. 132(5) is passed that the assessee can make a request that the seized amount which is sought to be released in his favour be adjusted or appropriated towards the liability to pay advance tax. Though, in the context of the present assessment year before us, the provisions of s. 132(5) are not applicable and therefore, strictly speaking, the ratio of the judgment of the Hon'ble Madhya Pradesh High Court does not apply, so however it is pertinent to observe that the Hon'ble ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iability to pay tax had arisen and the cash being seized by the department, the appellant requested the department to adjust ₹ 3 crore out of the ₹ 4,31,36,000/- seized and deposited in the PD account, it is seen that the assessee made a written request on 29.03.2010 to the Chief Commissioner of income Tax which was duly received and also to the Additional Director of income Tax Investigation, Agra, it also seen that similar request for adjustment letters were written to the DCIT Circle- 1, Agra on 29.03.2010 which was duly received in the office on the same day. Further, another letter was written to the CiT-1 on 21.03.2010. Letter dated 05/07/2010 was also written to the DC IT Central Circle stating that return of income for A.Y. 2010-11 had been filed on 30/6/10 with tax payable of ₹ 2,92,25,240/- and therefore requesting the AO once again for adjustment of tax liability with the cash lying in the PD account, in the circumstances, the assessee had done all it could do so as to ensure that cash tying in the PD account would be adjusted towards the advance tax liability. However, it seen that no action was taken on the assessee s petition by any of the authoritie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Dispute arose between the Department and the assessees with regard to adjustment of such seized/requisitioned cash against advance tax liability etc. Several Courts held that on an application made by the assessee, the seized money is to be adjusted against the advance tax liability of the assessee. Subsequently, Explanation 2 to Section 132B of the Act was inserted by the Finance Act, 2013 w.e.f. 01-06-2013, clarifying that existing liability does not include advance tax payable in accordance with the provisions of Part C of Chapter XVII of the Act. However, the dispute continued on the issue as to whether the amendment was clarificatory in nature having retrospective applicability or it has only prospective applicability. 3. Several Courts have held that the insertion of Explanation 2 to section 1328 of the Act, is prospective in nature and not applicable to cases prior to 01.06.2013.The SLPs filed by the Department against the judgement of the Hon'ble Punjab and Haryana High Court in the case of Cosmos Builders and Promoters Ltd. 1 and the Hon'ble Allahabad High Court in the case of Sunil Chandra Gupta2 , have been dismissed. Subsequently, the CBDT has also acce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he appeal of the assessee without appreciating the facts that amount lying in the PD account has to be adjusted against the existing liability of the assessee but as per explanation-2 of the section 132B of the I.T. Act 1961, it has been clarified that the existing liability does not include advance tax payable in accordance with the provisions of part-C of chapter XVII. 3. The appellant craves the right to amend alter or add to any of the grounds of appeal given above. 17. Ground No. 1 of the assessee s appeal and ground No. 1 of the revenue s appeal are common and identical to the ground No. 1 involved in the cross appeal filed for the A.Y. 2007-08, therefore, in view of our finding on this issue for the A.Y. 2007-08, ground No. 1 of the assessee s appeal stands allowed and ground No. 1 of the revenue s appeal stands dismissed. 18. The ground No. 2 of the revenue s appeal is also common to ground No. 2 of the revenue s appeal for the A.Y. 2007-08, therefore, in view of our finding on this issue for the A.Y. 2007-08, ground No. 2 of the revenue s appeal stands dismissed. 19. Ground No. 2 of the assessee s appeal is regarding the addition made by the Assessing O ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had produced all relevant records as source of income and deposits made in the bank accounts of these persons. Thus, merely because, the cheque books found at the place of the assessee, the deposits made in these bank accounts cannot be treated as undisclosed income of the assessee. 21. On the other hand, the ld CIT-DR has submitted that it is not a simple case of cheque book found with the assessee but the cheque books were duly signed by these persons, therefore, the assessee was operating the bank accounts of these persons for the purpose of depositing cash. He has relied upon the orders of the authorities below. 22. We have considered the rival submissions as well as the relevant material on record. The Assessing Officer has made addition of ₹ 13,26,600/- on account of cash deposits in the bank account of three persons namely Shri Rajendra Jain, Shri Ashok Sharma and Shri Mahaveer Prasad Sharma. The Assessing Officer treated the deposits made in the bank accounts of these persons as undisclosed income of the assessee on the basis of signed cheques of these persons were found during the search and seizure action at the place of the assessee. Though, the signed cheque ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e availability of cheque books with the assessee cannot be an evidence for making addition of the cash deposits in the accounts of these persons specifically when all these persons are regularly assessed to income tax. The assessee filed the return of income in support of explanation. Further the statement of one of these persons namely Shri Mahaveer Prasad Sharma was recorded by the search party U/s 132(4) of the Act and no such question was asked from the said person regarding the deposits in the bank account. Therefore, when the assessee has discharged its onus by producing the return of income of these persons wherein the declared income was sufficient to cover the deposits made in the bank accounts, then in the absence of any direct evidence or tangible material to disclose the fact that the cash deposit in the bank accounts of these persons belongs to the assessee, the addition made by A.O. is not sustainable. The said deposit is subject matter of assessment in the hands of these persons, accordingly, in the facts and circumstances of the case, we delete the addition made by the Assessing Officer on this account. 23. Grounds No. 3 and 4 of the assessee s appeal and ground ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the issue for the A.Y. 2007-08, ground No. 1 of the assessee s appeal stands allowed and ground No. 1 of the revenue s appeal stands dismissed. 26. The ground No. 2 of the revenue s appeal is also common to ground No. 2 of the revenue s appeal for the A.Y. 2007-08, therefore, in view of our finding on this issue for the A.Y. 2007-08, ground No. 2 of the revenue s appeal stands dismissed. 27. The ground No. 2 of the assessee s appeal is regarding the addition made on account of cash deposit in bank accounts of various persons. The identical issue was involved in the ground No. 2 of the assessee s appeal for the A.Y. 2008-09. The facts and circumstances are identical for both the assessment years. The assessee has produced the evidence in support of the source of cash deposit in the bank being return of income of these persons, in whose bank accounts, cash was found deposited. Accordingly, in view of our finding on this issue for the A.Y. 2008-09, the addition made by the Assessing Officer is deleted. Hence ground No. 2 of the assessee s appeal stands allowed. 28. Grounds No. 3 and 4 of the assessee s appeal and ground No. 3 of the revenue s appeal are general in nature and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee s appeal and ground No. 1 of the revenue s appeal are common and identical to the issued raised in ground No. 1 in the cross appeal filed for the A.Y. 2007-08, therefore, in view of our finding on the issue for the A.Y. 2007-08, ground No. 1 of the assessee s appeal stands allowed and ground No. 1 of the revenue s appeal stands dismissed. 31. The ground No. 2 of the revenue s appeal is also common to ground No. 2 of the revenue s appeal for the A.Y. 2007-08, therefore, in view of our finding on this issue for the A.Y. 2007-08, ground No. 2 of the revenue s appeal stands dismissed. 32. Ground No. 2 of the assessee s appeal is regarding disallowance of expenses found recoded in the seized material. This ground is common for A.Y. 2010-11, 2011-12 and 2012-13. During the course of search and seizure action, certain incriminating documents were found containing the entries of transaction of 100 days finance scheme. The seized material also contains the entries of expenditure pertaining to A.Y. 2010-11, 2011- 12 and 2012-13 of ₹ 29,75,859/-, ₹ 82,59,551/- and ₹ 69,54,914/- respectively. The assessee in the return of income has claimed these expenses agains ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oks of accounts of these two companies. 34. On the other hand, the ld DR has submitted that the assessee has claimed the expenditure, which is found to be already recorded in the books of account. The Assessing Officer as well as ld. CIT(A) has given the finding of fact that these expenses are already recorded in the regular books of account and claimed against the income recorded in the books of account. Therefore, the claim of the assessee would be a double deduction of the same expenditure one against the income recoded in the books and again against the undisclosed income found during the search and seizure action. He has relied on the orders of the authorities below. 35. We have heard the rival submissions and perused the relevant material available on the record. There is no dispute that the amount of expenditure as claimed by the assessee against the undisclosed income for these three assessment years i.e. 2010-11 to 2012-13 were found recorded in the seized material. The undisclosed income offered by the assessee is also based on the same seized material and therefore, once the income and expenditure both are recorded in the same material, which is found and seized du ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aim of expenditure which is recorded under common heads is required further examination and verification. Accordingly in the facts and circumstances, we set aside this issue to the record of Assessing Officer for conducting a proper enquiry of the details of the expenditure and to find out whether any part of the expenditure which is found in the seized material has been claimed in the books of account and then only to that extent the claim of the assessee can be disallowed. Needless to say that the assessee to be given an appropriate opportunity of hearing before deciding this issue. 36. Ground No. 3 of the assessee s appeal is regarding the addition made on account of sale of jewellery by mother-in-law of the assessee treating the same as undisclosed income. During the course of search and seizure action, the bills relating to sale of jewellery was found and seized as annexure AS-39. In the statement U/s 132(4) of the Act, the assessee explained these bills pertains to sale of jewellery by Smt. Saraswati Devi Sharma, mother in law of the assessee. In the post search statement dated 19/10/2012, the assessee further explained that because of ill health, his mother in law Smt. Sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... her savings and stridhan. (iii) Smt. Saraswati Devi along with her husband and only son was residing at Shastri Nagar, Jaipur. However due to her ill health, in the last two years before her death on 18.08.2009 she was residing with her daughter Smt. Kalawati Sharma, wife of assessee at Vaishali Nagar. Smt. Kalawati Sharma and the assessee were taking care of her as she was suffering from heart and kidney problem. In these circumstances, Smt. Saraswati Devi had brought with her all the jewellery and valuables to the residence of assessee and developed a close affection towards her daughter and her grandchildren. (iv) Due to her falling health, she decided to dispose off her jewellery and valuables and accordingly, sold most of her jewellery/valuables through the assessee in the month of April and May 2009 and deposited the same in her bank account with Central Bank of India, Vaishali Nagar, Jaipur. The assessee s wife Smt. Kalawati Sharma was nominee in this bank account. In this bank account which was opened on 15.09.2008 she deposited her savings and also the sale proceeds of the jewellery. This amount remained in her bank account for four months. Thereafter, from this bank ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le of jewellery by Smt. Saraswati Devi and the subsequent gift made by her to the family members of the assessee is fully verifiable. The order of lower authorities holding that gift so made by Smt. Saraswati Devi is an application of undisclosed income of assessee is thus erroneous and on surmises and conjectures. Hence, the same be directed to be excluded from application of income in the fund inflow / outflow statement. 38. On the other hand, the ld CIT DR has relied on the orders of the authorities below and submitted that the Assessing Officer has raised certain questions such as Smt. Saraswati Devi Sharma never filed return of income or net wealth and in absence of any evidence to show her holdings such a huge quantity of jewellery, the claim of the assessee cannot be accepted. She had four daughters and one son and therefore, it is beyond human probability that a mother would give entire belongings and wealth only to one daughter excluding other three daughters and one son. Signed cheque book found with the assessee clearly shows that the assessee has manipulated and has channelized his undisclosed income through sale of jewellery. 39. We have considered the rival subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the place of assessee. Accordingly, in view of the above facts and circumstances of the case, we are of the considered opinion that when the seized material itself shows the source of amount deposited in the bank account of Smt. Saraswati Devi Sharma by cheque and subsequent transfer from her account to the account of assessee, the same cannot be treated as undisclosed income of the assessee. Accordinlgy, we delete the addition made by the Assessing Officer on this account. 40. Grounds No. 4 and 5 of the assessee s appeal and ground No. 3 of the revenue s appeal are general in nature and does not require any adjudication. 41. Now we take the cross appeals for the A.Y. 2011-12. In these appeals the assessee as well as the revenue have raised following grounds of appeal: Grounds of assessee s appeal: 1. The ld. CIT(A) has erred on facts and in law in confirming the action of A.O. is not allowing the expenses of ₹ 82,59,551/- claimed by the assessee in earning the interest income of ₹ 3,86,42,943/- by holding that the same is recorded in the regular books of account. 2. The assessee craves to amend, alter and modify any of the grounds of appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... PD account has to be adjusted against the existing liability of the assessee but as per explanation-2 of the section 132B of the I.T. Act 1961, it has been clarified that the existing liability does not include advance tax payable in accordance with the provisions of part-C of chapter XVII. 2. The appellant craves the right to amend alter or add to any of the grounds of appeal given above. 46. Ground No. 1 of the assessee s appeal is common and identical to the issued raised in ground No. 2 in the cross appeal filed by the assessee for the A.Y. 2010-11, therefore, in view of our finding on the issue for the A.Y. 2010-11, this ground of assessee s appeal stands disposed of and set aside to the record of the Assessing Officer for the same terms. 47. The main solitary ground raised by the revenue is regarding the adjustment of seized cash against the tax liability. This ground of revenue s appeal is also common to ground No. 2 of the revenue s appeal for the A.Y. 2007-08, therefore, in view of our finding on this issue for the A.Y. 2007-08, ground No. 1 of the revenue s appeal stands dismissed. 48. Grounds No. 2 and 3 of the assessee s appeal and ground No. 2 of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f ₹ 2,42,29,675/- for the A.Y. 2009-10 and 2010- 11 respectively. The deletion made by the ld. CIT(A) have not been challenged by the revenue, therefore, after deletion of these amounts, the alleged excess investment computed by the Assessing Officer will not survive. 54. Having considered the rival submissions as well as the relevant material on record, we note that the Assessing Officer has made this addition on the basis of a revised fund flow statement prepared after considering the various additions made in the earlier years and thereby the Assessing Officer arrived to the amount of ₹ 22,25,416/- as an opening cash balance on 01/4/2012. It is pertinent to note that this opening cash balance was worked out by the Assessing Officer by considering the investment by the assessee as application of undisclosed income on account of sale of jewellery and investment in shares as well as other items of addition made by the Assessing Officer. The ld. CIT(A) has considered this issue in para 3.1.2 as under: 3.1.2 I have duly considered assessee's submission and carefully gone through assessment order. I have also taken a note of factual matrix of the case as well ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 80000000 83850000 84583400 81618013 64887600 96441528 24232510 add : income as above 6000000 12000000 17000000 17299094 38642943 35404242 0 Less: Relief allowed in estimated income -2000000 -7000000 -11000000 -1500000 0 0 0 Total 84000000 88850000 90583400 97417107 103530543 131845770 24232510 Less: Drawings -150000 -240000 -300000 -480240 -1441583 -672367 0 Less: Application of income as above 0 -4026600 -28615173 -56278942 -5647432 -106940893 -23918142 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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