TMI Blog2016 (1) TMI 1472X X X X Extracts X X X X X X X X Extracts X X X X ..... stified in interpreting the seized paper to be a purchase of property by assessee and others. The seized paper is, therefore, clearly dumb document and did not lead to anywhere so as to make any addition against the assessee. We, accordingly, set aside the orders of authorities below and delete the entire additions. - ITA No. 456,457 & 458/CHD/2014 And ITA No. 462/CHD/2014 - - - Dated:- 5-1-2016 - Shri Bhavnesh Saini Judicial Member And Ms. Rano Jain, Accountant Member For the Department : Shri Sushil Kumar. For the Assessee : Shri Sudhir Sehgal. ORDER PER BHAVNESH SAINI,JM This order shall dispose off all the above cross appeals for assessment years mentioned above having the identical issues. 2. We have heard ld. Representatives of both the parties, perused the findings of authorities below and considered the material available on record. The appeals are decided as under. ITA 462/2014 (Assessee's Appeal : A.Y. 2005-06) ITA 456/2014 (Departmental Appeal : A.Y. 2005-06) 3. Both the cross appeals are directed against the order of ld. CIT(Appeals)-I, Ludhiana dated 11.02.2014 for assessment year 2005-06. The cross appeals ar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ard to alleged investment of ₹ 18,27,000/- in property which has been taken from the first part of the page and even the word plot of property has been used. However, with regard to second alleged transaction, only the word Chandigarh Plot has been used without giving any location or extent of the property. It cannot be made out whether it is a transaction of purchase or sale which has been presumed as transaction of purchase by the Assessing Officer. The word year 3-4 has been used on the top of loose page but Assessing Officer made addition in assessment year 2005-06. The Assessing Officer merely presumed it to be investment. The interpretation of the Assessing Officer is wrong without corroborating with any transaction or property without having any document, agreement or purchase or Sale Deed in the seized record. The Assessing Officer made additions in respect of other names also without any reasons. It was, therefore, submitted that these are dumb documents. It was submitted that the seized documents should be read in totality. The assessee has already surrendered additional income of ₹ 15 lacs in assessment year under appeal out of total surrender of ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... investment in any property was found during the course of search. PB-18 is statement recorded of the assessee on the date of search. The ld. counsel for the assessee referred to several questions from his statement particularly question No. 53 and question No. 58 and submitted that no questions have been asked to assessee regarding the seized paper relating to assessment year under appeal i.e. 2005-06. The questions referred to some diary or Annexure A-1 and A-6 of the diary, which may be relevant for assessment year 2010-11. PB-29 is statement of assessee recorded on 21.02.2010 in which he has surrendered ₹ 4 Cr in all the assessment years. PB-2 is bifurcation of the surrendered income in several years. The ld. counsel for the assessee submitted that in the seized paper, there is no mention of any plot or purchase of any property. No evidence of investment in property was found. Addition is made merely on presumptions. The seized papers have only rough notings and as such dumb document. No corroborative evidence was found of investment in any property. The Assessing Officer has not given any benefit of the surrendered amount of ₹ 15 lacs. The rough notings contain the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sidered the remand report filed by the Assessing Officer. The documents seized could not be treated as dumb document as assessee explained the document. The assessee did not retract from his statement of making surrender. Therefore, Assessing Officer was justified in making the additions. 13. We have considered the rival submissions. The copy of the seized paper is reproduced in the appellate order relevant on this issue. Copy of the same is also filed at page 11 of the Paper Book. The details are already noted above. The Assessing Officer, considering the seized papers, interpreted the seized document in his own way holding it to be regarding purchase of property by assessee and others. However, no such fact has been mentioned in the seized paper because the seized paper did not contain mentioning of any purchase of property by assessee and others. No evidence of actual investment in any property was found during the course of search. The so called purchase of property by assessee or others did not found exist. The seized paper contain on the top of it year 2003-04 . Therefore, seized paper could not be considered in assessment year 2005-06. No area or location of any property ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he contents of the documents. The Tribunal allowed the appeal filed by the assessee. On a reference : Held, that the assessee was found to be in possession of loose slips and not of any valuable articles or things. Neither the possession nor the ownership of any jewellery mentioned in the slips was proved. Therefore, the Tribunal had rightly held that the provisions of section 69 A of the Act were not applicable. The Tribunal also held that if the assessee failed to explain the contents of the slip, it was for the Revenue to prove on the basis of material on record that they represented transactions of sales or stock-in-hand before making any addition on this score. The assessee had duly explained that these were rough calculations and the assessee's explanation had not been rebutted by any material evidence. Therefore, the order of the Tribunal could not be said to be perverse. 14. It may be stated here that in assessment year 2005-06, assessee was a partner in the firm and has no other independent source of income. Later on, he has become Director in the company. Therefore, there is no question of making any undisclosed investment in any alleged property. Further, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of Ravi Kumar (supra) will be relevant and findings on this issue will also be relevant for the purpose of deciding the remaining grounds in the cross-appeals. 16. On ground No. 4 in assessee's appeal, assessee challenged the addition of ₹ 5 lacs as against addition of ₹ 72,12,850/- on account of unexplained investment in property. The revenue on the same issue has raised ground No. 3 in departmental appeal challenging the restricting of the addition of ₹ 72,12,850/- to ₹ 5 lacs. 17. Briefly the facts of the case are that the assessee challenged the addition of ₹ 72,12,850/- made by Assessing Officer on the basis of the seized document at page 16, back-side of Annexure A-5. The said impugned seized documents are reproduced in the appellate order (PB-12). The Assessing Officer has made the impugned addition on the basis of following observations : Inderjit Brar Advance 10 lac Plots ₹ 19,42,500/- Plots ₹ 25,20,000/- Plots ₹ 21,36,000/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or for given amount. The documents and the recording thereof throws upon different possibilities which definitely requires corroboration in the form of some Agreement to Sell or some other title document to corroborate the facts stated therein. The ld. CIT(Appeals) also noted that it is vital issue to decide whether the documents found and seized contain record of transactions of purchase/sales of immovable properties warranting the conclusion that the said purchase/sales had been done outside the books of account. 18(i) The ld. CIT(Appeals), on consideration of the seized paper found that the seized paper did not contain any description and the seized paper is not sufficiently descriptive and speaking one to arrive at the conclusion of investment in property. The ld. CIT(Appeals), following the decisions of the various Benches of the Tribunal and other decisions held that the document found during the course of search must be speaking one and without any second interpretation and must reflect all the details about the transaction of the assessee in relevant assessment year. The ld. CIT(Appeals), accordingly, found investment of ₹ 5 lacs against H.P. could be considered t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... necessary in order to make out a case against the assessee. Further, no enquiry have been conducted by the Assessing Officer in order bring the truth on record with regard to any transaction carried out by the assessee. Thus, there is no basis, what-so-ever to make any addition against the assessee. There is no basis to consider HP is assessee who has made investment in property. 20. Considering the facts and circumstances of the case and above discussion, we do not find any justification even to sustain the addition of ₹ 5 lacs. In view of the above discussion, we set aside the orders of authorities below and delete the entire addition. 21. In the result, ground No. 4 of appeal of the assessee is allowed and ground No. 3 of appeal of the revenue is dismissed. 22. On ground No. 5, assessee challenged the addition of ₹ 16,72,000/- on account of unexplained investment in property. The Assessing Officer made addition of ₹ 16,72,000/- on the basis of seized document at page No. 15 of Annexure A-5 (PB-13). The seized paper is reproduced in the earlier order. The Assessing Officer, on consideration of the seized paper observed, This paper shows that Bhucho l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... contained financial year 2003-04 therefore, at the most, profit could be added of ₹ 87,000/- in financial year 2003-04. On the other hand, ld. DR relied upon orders of authorities below and submitted that whole amount of unexplained investment shall have to be added as sale consideration in the year under consideration. 24. We have considered rival submissions. There is no mention of sale of any property in the seized document. The paper contained financial year 2003-04, therefore, no addition could be made in assessment year 2005-06. No evidence of sale of property was found during the course of search. Shri Inderjit Brar has not been examined to prove the contents of the document so seized. No corroborative evidence was found to explain the seized paper. No evidence of earlier investment in the property stated to have been sold has been found. Therefore, seized paper did not indicate anything if assessee made any sale of property or made investment in earlier years. Therefore, the authorities below were wholly unjustified in making addition of ₹ 16,72,000/- against the assessee on the basis of the above seized paper. We, accordingly, set aside the orders of authori ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gly addition was restricted to ₹ 10,68,000/-. 28. After considering rival submissions, we are of the view entire addition is unjustified. The copy of the seized paper is reproduced in the appellate order and copy of the same is also filed in the Paper Book at page 13. It is a cancelled document as have been crossed as was found during the course of search. Therefore, cancelled document would not reveal any transaction of sale as is presumed by the Assessing Officer. No details of the property under sale have been mentioned on this paper and no person, mentioned in the document have been examined by the Assessing Officer. No corresponding corroborative evidence have been found to link the assessee with sale of the property. The ld. CIT(Appeals),while deleting part of the addition correctly observed that the addition is made on presumption because seized record did not contain any description of sale in terms of date thereof of the receipt of assessment year amount. The same reason also apply in respect of the addition sustained by the ld. CIT(Appeals). Therefore, there was no justification for ld. CIT(Appeals) to have partly confirmed the addition. The ld. CIT(Appeals) reli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ause assessee failed to explain the details of properties against which amounts have been received. 31. The assessee challenged addition before ld. CIT(Appeals) and it was submitted that it is a dumb document and no unaccounted investment or property was found. These are rough notings of proposal/projects in some immovable properties which did not materialize. The assessee and his associates are not indulged in any unaccounted transactions. The assessee has not received any amount from any Raju. 32(i) The Assessing Officer submitted remand report affirming the facts stated in the assessment order. 33. The ld. CIT(Appeals) considering the seized documents relied upon by Assessing Officer found that the same merely records certain amounts on given dates. The seized paper did not record as to what these amounts represent, whether these are purchases or sales or whether these are the receipts or payments. The ld. CIT(Appeals), therefore, found that there is no sufficient evidence on record to connect the assessee with the same and accordingly deleted the addition. 34. After considering rival submissions, we do not find any merit in this ground of appeal of the revenue. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... act that the word tender and the name of the sites have been used at various places in the diary. In order to settle the case amicably and in cooperative manner, assessee surrendered ₹ 4 Cr during the course of search. Therefore, even if same addition was to be made, it would be covered by surrender of ₹ 4 Cr. The seized paper, at the best, are only estimates which has no financial implication. It was brought to the notice of the Assessing Officer that most of the figures written in the diary were 10, 20, 30 and without any denomination and there cannot be any extrapolation by presuming that these are in lacs. Some of the pages of Annexure A-2 were confronted to the assessee during assessment proceedings of assessment year 2011-12 which were duly got verified through books of account and no addition have been made in assessment year. It was further explained before Assessing Officer that notings on document No. 40 of Annexure A-2 are inter-linked to document Nos. 43, 44 and 45 backside of Annexure A-1 and 38, 39 and 40 of Annexure A-2 and are actually duplication/triplication of notings/rough calculations which is evident from the fact that page 43, 44 and 45 backside ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o.43,44,45 backside of Annexure Al deals with same tenders and the amounts recorded are also exactly the same which again get repeated at page no.38,39,40 of Annexure A2. It is also seen that the figure of 210.35 on page 38 is the maximum figure worked out on the basis of the notings on the said document. It is also to be noted that word estimate is written on top of notings at page no.40 backside of annexure A2 and the bottom of the same page records the date 03.04.2010 on which description of payment of Rs,40,00,000 has been recorded. It is infact this description which is very eloquent that the figure 210 could be interpreted as ₹ 2,10,00,000/-. It is also to be appreciated that same payment of ₹ 40,00,000/- is recorded on page no.45 backside of Annexure A-l on the same date. The presumption that the said payment has been made on account of certain tenders received and executed by the appellant makes it logical that such a payment would not be there in both financial years. It is very clear that the actual payment emanating out of the seized document at page no.40 backside of Annexure A2 has happened in F,Y.2010-11 and therefore the same could not be considered in as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as well as assessee's counsel but did not find as to how the Assessing Officer has made this addition of ₹ 233 lacs on the basis of the seized document. We have also gone through the seized paper which did not speak of the total of addition of ₹ 2,33,35,000/-. The ld. counsel for the assessee, during the course of arguments, with reference to the documents on record has been able to point out that against the date 27.03.2010, certain names have been mentioned which belong to the proposal of tenders made by the company in which assessee was one of the Directors. These figures did not reveal if assessee made any payment on 27.03.2010 of ₹ 2,33,35,000/- of which addition was made by the Assessing Officer. Further, in the same seized paper, figure of 177.35 have been mentioned on both sides which is total of four figures as explained in the explanation of the assessee. It would also not make out if these were in thousands, lacs or crores or these were in rupees. In the same seized paper, it is mentioned for estimated . None of the figures stated in the seized paper speaking out any expenditure incurred by the assessee for the impugned addition. The explanation o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... incorrectly recorded in the assessment order. The seized document is reproduced in the appellate order. On confronting with the same, assessee replied before Assessing Officer that 20, 10, 7 etc. have been noted on this page which are without any denomination and these cannot be presumed to be in lacs without date. The Assessing Officer did not accept contention of the assessee because this document find mention 30th May,2009 and noted that since assessee failed to explain the same, therefore, addition was made. 43. The assessee challenged the addition before ld. CIT(Appeals) and it was explained that the notings on this page are of 20, 10, 7 which are without denomination and it was explained that addition was made merely on presumption. There is no date on the relevant page except at the bottom of the entries. It was estimated figure only. There is no material on record to prove as to how addition of ₹ 1,87,35,000/- have been made. The presumption under section 132(4A) is rebutable. The assessee relied upon several decisions on the proposition that the document found during the course of search must be speaking one without any second interpretation. Un-corroborated loo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 377; 25,00,000/-. When these vital facts which are part of the financial record are seen with the seized document in the background, it becomes quite apparent that the writings on the impugned document had been written in the financial year 2008-09 itself. It is logical because the FDR of ₹ 40,00,000/-and margin money of ₹ 25,00,000/- which has been recorded on the impugned seized document had been put into place in the financial year 2008-09 as highlighted above. If there has been any other payment as recorded in the impugned seized document then the same is also likely to have happened in financial year 2008-09. The entirety of circumstances highlighted above make it amply clear that whatever cognizance has to be taken of these documents, it is to be in assessment year 2009-10 and not in year under consideration. The addition made in the year under consideration is therefore directed to be deleted. 44. The ld. DR relied upon order of the Assessing Officer and submitted that even if in the year 2008-09, contract was completed of 52.95% but rest of the contract was completed in assessment year under appeal. Therefore, addition was correctly made in assessment year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the basis of the material as to how this addition has been made against the assessee. Therefore, decision of Hon'ble Punjab Haryana High Court in the case of Ravi Kumar (supra) clearly applies in favour of the assessee. Merely because the date of 30.05.2009 is mentioned at the bottom of the page would not prove that assessee has made unaccounted payment/expenditure. 46. Considering the totality of the facts and circumstances in the case, it is clear that Assessing Officer made this addition merely on presumptions against the assessee. Thus, the same cannot be sustained. The ld. CIT(Appeals), on proper appreciation of the facts and material on record, correctly deleted the addition. We, therefore, do not find any merit in this ground of appeal of the revenue. The same is accordingly dismissed. 47. In the result, departmental appeal is dismissed. ITA 458/2014 (Departmental Appeal : A.Y. 2011-12) 48. This appeal by revenue is directed against the order of ld. CIT(Appeals)-I Ludhiana dated 11.02.2014 for assessment year 2011-12. We have heard ld. Representatives of both the parties and perused the material available on record. 49. On ground No. 1, revenue chall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st the disclosure made by assessee during the course of search. His findings in Appellate Order in para 8 are reproduced as under : 8. I have considered the facts of the case, the basis of addition made by the Assessing Officer, the arguments' of the AR on the issue and also closely examined the seized record on which the impugned addition had been based. The -perusal of remand report of the Assessing Officer on the issue clearly shows that no comment whatsoever has been given on the issue highlighted by the undersigned and the Assessing Officer has merely stuck to the observations as made in the assessment order without really justifying the same. In fact, the correct reading of the seized document means that on a project of ₹ 805 lacs which is part of financial record of the company 0.5% has been paid which does not stand accounted for. The figure of 805 and 0.5% are both clearly recorded on the seized document and no interpolation is called for. Therefore the resultant figure does not comes to ₹ 40,00,000/- but only ₹ 4,00,000/-. The working leads to the conclusion that the total unaccounted payment on this seized document is ₹ 10,6 lacs and not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... spite the fact no such figure have been mentioned in the seized paper. The Assessing Officer in the assessment order noted the total amount paid of 106 which did not find mention of any lacs or crores in the seized paper. Therefore, decision in the case of Girish Chaudhry (supra) squarely apply in favour of the assessee. There is also no mention if any bribe has been paid by the assessee in the seized paper. The ld. CIT(Appeals), on examining the projects executed by the assessee, rightly came to the conclusion that 0.5% has been paid which has not been accounted for. Since in assessment year 2010-11, the ld. CIT(Appeals) allowed set off of the disclosure of ₹ 8 lacs on the issue of payement to Bindu and no second appeal have been preferred in assessment year 2010-11 therefore, there is no infirmity in the order of ld. CIT(Appeals) in giving set off of the part addition on this issue out of the disclosure made by the assessee of ₹ 4 Crores. In the totality of the facts and circumstances and in the light of the fact that Assessing Officer has failed to prove the basis of making the above addition, clearly supports the findings of ld. CIT(Appeals) that addition of ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on this page and the Assessing Officer has simply totaled 19+23 = 42 written on page No. 45 and totaled the same by taking figure of 27 and 23 on page 44 backside which even if taken as correct, comes to 92 only. Thus, there is a totaling error and addition is made merely on presumption. There is no denomination on page 45 with the words 19 + 23. Therefore, addition is made on presumption taking it to be lacs. It was further clarified before Assessing Officer that notings on document No. 43 backside Annexure A-1 i.e. OGVL 27 lacs and CRF 23 lacs, Malout, Fazilka are inter-linked to document No. 43 and 45 backside of Annexure A-1 and 38, 39 and 40 of Annexure A-2 which are actually duplication/triplication of the notings/rough calculations which is evident from the fact that abovesaid documents are being separately enclosed to prove the contention. It was also submitted that the backside is dealing with some tenders and these figures have been repeated. It was submitted that 210.35 is taken as 2,10,35,000/- without any basis, at the most, would be covered by surrender already made by assessee. The Assessing Officer in the remand report justified the addition made by the Assessing Of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... criminating documents and other unaccounted assets found during the course of search operation which has to be reduced by the amount of disclosure made under section 132(4) to come to the net figure of taxable assessed income. The Assessing Officer is therefore directed to give credit of ₹ 3.61 crore on this ground. 57. The ld. DR relied upon order of the Assessing Officer and submitted that it is not explained by ld. CIT(Appeals) how the addition is covered by the surrendered amount. On the other hand, ld. counsel for the assessee reiterated the submissions made before authorities below and submitted that in assessment year 2010-11, ld. CIT(Appeals) allowed set off of the addition of ₹ 8 lacs against the disclosure made by assessee in which, no departmental appeal have been filed, therefore, department has taken a contrary view in assessment year under appeal. 58. We have considered rival submissions and do not find any justification to interfere with the order of ld. CIT(Appeals). The assessee explained that there is a totaling error even in the findings of the Assessing Officer which have not been explained. The ld. CIT(Appeals) also found that there are cer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... figures of 1000, 200, 500 have been taken as 10 lacs, 2 lacs and 5 lacs without any basis. The figure of 3.67 + 3 has been taken as ₹ 6.7 lacs and accordingly made the addition which is merely on presumption. It was also explained that totaling of the alleged payment have been made taking the figures from right and left on the page despite the fact that there are cuttings and over-writings on the figures. The additions have been made merely on presumption and alternatively, the entire addition is covered by surrender of ₹ 4 Cr. The Assessing Officer in the remand report justified the addition made by Assessing Officer. 60. The ld. CIT(Appeals), considering the seized paper and material on record, deleted the entire addition. His findings in para 18 of the appellate order are reproduced as under : 18. I have considered the facts of the case, the basis of addition made by the Assessing Officer, the arguments of the AR on the issue and also closely examined the seized record on which the impugned addition had been based. It is seen that the figure of 6.67 records the description as B/G refunded. The Assessing Officer has taken it as unaccounted investment by the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be unaccounted income or expenditure of assessee. The description in this paper is not self speaking and would not lead to any purpose. There are cuttings and over writings in seized paper. Further, in the seized paper, it is mentioned as tender purpose which clearly shows that it relates to the company of the assessee, in which assessee was a Director. Therefore, no addition can be made in the hands of the assessee individually. There is also no basis for making the additions without any denomination in the seized paper. 10 has been assumed as 10 lacs, therefore, decision of Delhi High Court in the case of Girish Chaudhry (supra) squarely applies in favour of the assessee. The document is not self speaking and is without any corroborative evidence on record. The ld. CIT(Appeals), therefore, correctly held it to be a dumb and non-speaking document. The decision in the case of Ravi Kumar (supra) also apply in favour of the assessee. 61(i) In the totality of the facts and circumstances, we do not find any merit in this ground of appeal of revenue. The same is, accordingly, dismissed. 62. On ground No. 4, revenue challenged restricting the addition of ₹ 34.19 lacs on a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year in which search had taken place and therefore could not be said to be old entries for which failing memory could be taken as an excuse. The document therefore cannot be termed as dumb as sufficient description has been recorded thereon so as to determine their accountability or otherwise. However, apart from these entries, the rest of the entries on this paper do not convey any exact meaning say account CDS to Ajitpai Singh does not convey whether it is a payment or it is receipt or what? Similar is the situation with respect to adjustment of Patiala account. The description written as BG issue also cannot be presumed to be an unaccounted payment as this description has already been discussed by the undersigned with reference to another addition earlier. Therefore, the addition under this head to the tune of ₹ 29,00,000/- is confirmed. However, the credit for disclosure made for the year under consideration has to be given for the above addition. 65. After considering rival submissions, we do not find any merit in this ground of appeal of the revenue. The assessee is not in appeal. Revenue challenged the part addition deleted by ld. CIT(Appeals) and also in appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the impugned seized document that the appellant has received an amount of ₹ 54,00,000/- from one Bindu and the assessee has claimed that same cannot be taxable income as it is only an amount received and not paid. The onus on the assessee in this regard is much more than this as having .written this document in the same financial year in which search took place. The reasons for receiving payment to the tune of ₹ 54,00,000/- from Bindu have not been specified. It is also possible that it is on account of sales effected to Bindu or receipt of an amount already lent to Bindu. Here it would be important to relate another recording in the seized document at page no. 100 of Annexure A5 wherein amount of ₹ 10,00,000/- has been paid to Bindu. When both these entries are taken together it shows that there is a regular exchange of funds between appellant and Bindu and in the absence of any logical explanation by the assessee, an amount of ₹ 54,00,000/- could be treated as amount received by the assessee on account of amount earlier paid to Bindu, Since ₹ 10,00,000/- has been treated as unaccounted income of the appellant for assessment year 2010-11, an amount ..... X X X X Extracts X X X X X X X X Extracts X X X X
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