TMI Blog2023 (10) TMI 594X X X X Extracts X X X X X X X X Extracts X X X X ..... le their tax returns accordingly. Any misdemeanour to suppress the income in guise of donation if established is enough to invoke the charge of suppression for that period - the appellant has suppressed the fact that they have received consideration for the provision of these services and collected the same from the participants in residential and non residential camps by reflecting the same as donation on the receipts and the book of accounts. This suppression was clearly with the intent to evade payment of service tax. - Order of Commissioner against the appellant / assessee sustained. Penalties - HELD THAT:- The penalties under Section 76 and 77 are for the violation done and are absolute in nature if certain violations are attributable to the appellant. In the present case undoubtedly appellant had failed to take registration as required even though he was providing the taxable services. It is also the fact that they were not paying service tax and not filing the returns as required under provisions of Service Tax law, i.e Chapter V of Finance Act, 1994 and Service Tax Rules, 1994. For the contraventions of these provisions penalty imposed on the appellant under Sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tstanding amount of Service Tax. However, the total amount of the penalty payable in terms of this section shall not exceed the amount of Service Tax payable upto 09.05.2008. iv. I further, impose a penalty of Rs. 4,94,33,027/- (Four Crore Ninety Four Lac Thirty Three Thousand and Twenty Seven Only) under Section 78 of the Finance Act, 1994 for their failure to pay Service Tax by suppressing the value of taxable service also various acts of omission and commission. v. I also impose a penalty under Section 77 for their failure to take registration in accordance with the provisions of Section 69/ rules made thereunder at the rate of two hundred rupees for every day during which such failure continued, starting with the first day after the due date, till the date of actual compliance; 2.1 The appellant is engaged in activity of providing services relating to health fitness by way of teaching yoga and meditation. During the relevant period in dispute appellant had not taken any registration, which is requisite under the Finance Act, 1994 as amended. They were not paying any service tax on the services provided by them. 2.2 Based on the intelligence that appellan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d to meet various costs such as food, lodging, medicines, medical tests, etc. and education regarding yoga was free of cost? Whether the amount received as donation was charity and such amount does not form consideration for providing any health and fitness service? When the fact regarding such alleged service/or activity was known to the department then extended period of limitation is available to the department for issuance of the show cause notice? Whether the appellant was entertaining a bona fide belief that the alleged activity was not a taxable service in the facts where the department made a thorough investigation during 2002 to 2005 for the same activities and on contest the department did not take any action to raise a demand of service tax? When the alleged activity was known to public in general as the same was highly publicized activity, then the department was unaware about same activity, so, whether the demand under extended period of limitation can be raised? Whether penalties imposed are sustainable in the facts and circumstances of the case and benefit of Section 80 is not available? The activities of the appellant are not taxabl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and non-residential camps were also telecasted all the activities of the trust in relation to organization of these camps was well within the knowledge of public atlases including Department. Hence, extended period could not have been invoked. In support of the above proposition that extended period could not have been invoked, reliance is placed on following judgments:- Shriram Chits Pvt. Ltd. [2023 (69) G.S.T.L. 397 (Tri.Hyd.)] upheld by dismissing the Civil Appeal filed by the department as reported at 2023 (69) G.S.T.L. 338 (SC); DCM Textiles [2012 (26) S.T.R. 359 (Tri.-Del.)]; Hindalco Industries Ltd. [2003 (161) ELT 346 (Tri.-Del.)]; Zee Media Corporation Ltd. [2008 (18) GSTL 32 (All.)]; M/s. Mount Everest Breweries Limited [FINAL ORDER NO. 50802/2023 dated 03.07.2023]; Anand Nishikawa Co. Ltd. [2005 (188) E.L.T. 149 (S.C.)]; Cosmic Dye Chemical [1995 (75) E.L.T. 721 (S.C.)]; Uniworth Textiles [2013 (288) E.LT. 161(S.C.)]; Padmini Products [1989 (43) ELT 195 (SC)]; Chemphar Drugs Liniments [1989 (40) ELT 276 (SC)]; Continental Foundation Jt. Venture [2007 (216) ELT 177 (SC)]; ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ery cleverly taking the consideration received by use of these donation coupons in order to get exemption from payment of service tax. Appellant neither registered themselves with the Department nor paid any service tax, a case for suppression is clearly made out against them. Accordingly, extended period of limitation cannot be invoked. Contention of the appellant that the investigation/inquiries were made in the year 200405 by the department against DYM in which Shri Balkrishna were Secretary General do not obligate the charge of suppression made against the appellant. Charge of suppression is to be examined on the facts of which case and the view taken in the present case when all the evidences pointed that the appellant has wilfully disguised the consideration received as donation, charge of suppression established against them extended period of limitation has been rightly invoked for the confirmed demand. As extended period of limitation has been invoked penalties under Section 78 of the Act are justified. Commissioner has given appropriate reasons for imposition of penalties under Section 76 and also the demand of interest under Section 75. Appeal needs t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ' attracts Service tax. Therefore, it is necessary to understand as to what the yoga means in terms of definition of health and fitness service in view of claims of notice and the noticee. It is observed that the meaning of Yoga as described in Wikipedia, (the free encyclopaedia) is as under: a. Yoga (Sanskrit, P li: jaoga/yoga) is a commonly known generic term for physical, mental and spiritual disciplines which originated in ancient India. Specifically, yoga is one of the six stika ( orthodox ) schools of Hindu philosophy. It is based on the Yoga Sutras of Patanjali. Various traditions of yoga are found in Hinduism, Buddhism, Jainism and Sikhism . The website further details that in contemporary times, the physical postures of yoga are used to alleviate health problems, reduce stress and make the spine supple. Yoga is also used as a complete exercise programme and physical therapy routine. 4.10 Essentially, Yoga means union of the mind, body and spirit with the Divine and while this refers to a certain state of consciousness both individual and Universal, it is also a method to help one reach that goal. The teaching of Yoga philosophy can be summarized in 5 p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r, included in the definition. Thus, it is clear that yoga of all sorts is included in the definition of health and fitness service . Moreover, had it been the case, the provision would have been made in the statute itself, as had been done in the case of massage (excluding therapeutic massage). Accordingly, the contention of noticee runs contrary to the statutory definition of the 'health and fitness service' and therefore cannot be accepted. 4.13 In this regard, it is observed that the services of Health and Fitness Services, which came under service tax net with effect from 16-08-2002. Accordingly, a Circular F. No. B11/1/2002-TRU, dated 01-08-2002 was issued by the Board on the issue pertaining to Health and fitness services. The said circular has inter alia clarified as under: 3. Health and fitness services are provided by clubs, fitness centers, health saloons, hotels, gymnasium and massage centers. The services which fall under this category might be for weight reduction and slimming, physical fitness exercise, gyms, aerobics, yoga, meditation, reiki, sauna and steam bath, Turkish bath, sun bath and massage for general well being. However, therapeutic mass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at Maharishi Dayanand Gram, Delhi Haridwar NH, Near Bhadarabad, Haridwar is a health club and fitness centre or not. ii. It is an admitted fact that M/s Patanjali Yog Peeth Trust is an organization interalia carrying out the activities of teaching yoga at the above said place. The notice has alleged that M/s Patanjali Yogpeeth Trust is covered under the ambit of 'any establishment', as provided under health club and fitness centre, subject to the condition that they must be providing the services of health and fitness. Since they are providing services of health and fitness by teaching Yoga, therefore it is to be decided whether they would come under the ambit of 'any establishment within the meaning of health club and fitness centre. iii. The meaning of Establishment is not defined in the Finance Act, 1994 therefore the dictionary meaning has to be seen. The meaning of establishment under various dictionaries is as under: a. Accurate and Reliable dictionary (a free English-English online dictionary) i. establishment - an organization founded and united for a specific purpose. ii. establishment a public or private building structure (business or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ees for attending the Yog -Science camps. The fees collected from participant ranges from Rs. 7000/- onwards and the facilities provided during the camp varies with the amount of entry fees such as AC Rooms, sitting in front row.etc. Thus, it is amply clear that noticee is charging the said fees in the name of donation in rendering the teaching of Yoga. Accordingly, the receipt of money for providing the above said services is nothing but consideration . 4.18 In the light of discussion as in above said paras, I am of the view that the noticee has admittedly rendered the activity of teaching yoga, which falls under the health and fitness service. As the definition of above said service includes the activity of Yoga as a taxable service, therefore the noticee is liable to pay the service tax amounting to Rs. 4,94,33,027/- (Four Crore Ninety Four Lac Thirty Three Thousand and Twenty Seven Only) in respect of services of health and fitness rendered by them during the period from 01.10.2006 to 31.03.2011, as demanded in the instant SCN, under proviso to Section 73(1) of the Finance Act, 1994. 4.19 As regards charging of interest, since the demand of service tax stands confirm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... evidence laid before me, I find that the assessee had not taken into account the consideration received by them for rendering taxable service for the purpose of payment of service tax and thereby refrained from paying their tax liabilities. The nonpayment of service tax on the above said services was a deliberate, conscious attempt to suppress the material fact of receipt of consideration against services rendered by the noticee so as to avoid payment of due service tax as envisaged under Section 68 in utter disregard of Law. Thus, such an act in defiance of law had rendered them liable for stringent penal action in terms of provisions of Section 78 of the Act, ibid for suppression, concealment and furnishing of incorrect value of taxable service with an intent to evade payment of service tax. In the light of above said discussion, the noticee is liable for penalty under Section 78 of the Finance Act, 1994. 4.25 Further, the noticee has pleaded that penalty under Section 76 78 are not imposable simultaneously and has cited a number of case law. 4.26 I have seen the case laws cited by the noticee. However, I find that Hon'ble Kerala High Court in the case of ACCE, v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation, massage (excluding therapeutic massage) or any other like service. Thus, what is covered under the definition of health and fitness service' is basically the services for physical well being and the definition specifically mentions yoga as the service meant for physical well being. Therefore, we are of the prima facie view that the various yoga courses, residential as well as non- residential, being organized by the appellant are for general physical well being and there is nothing on record to prove, that these courses are meant for specific element. In view of this, we do not accept the appellant's plea that their services are not covered by the definition of health and fitness service. Beside this, there is also no dispute that the appellant, which are a trust, are covered by the definition of health, club and fitness centre as this definition covers any establishment including a hotel or a resort providing the health and fitness service. We also of prima facie view that there is no substance in the appellant's plea that the amounts being charged by them in respect of residential courses are not for yoga courses but are the amount charged only for food and a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lowing questions of law arise: I. Whether ld. ITAT erred in law in holding that assessee is entitled to exemption u/s 11 12 of the Income Tax Act, 1961? II. Whether ld. ITAT has erred in law in allowing capital expenditure though the assessee has no legal right on the land on which capital expenditure has been incurred? III. Whether ld. ITAT has erred in law and on the facts of the case in holding that the corpus donations received by the assessee in the form of immovable properties will not be liable to tax? 13. The appeal is admitted, restricted to the above questions of law. 4.6 Word Donation has roots in Latin word donationem give as a gift from Sanskrit danam offering, present a voluntary gift, to give without wanting anything in exchange, a voluntary and anonymous financial gift. As per general understanding A donation is a gift - usually one of a charitable nature. A donation is a voluntary transfer of property (often money) from the transferor (donor) to the transferee (donee) with no exchange of value (consideration) on the part of the recipient (donee). The recipient gives nothing in exchange for the donated money/ property. 4.7 Fee, or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... noticee-company, Shri Shyamvir Singh Saini in his statements dated 17.10.2011 and 17.11.2011. The entire submission made by the appellant in their defence is contrary to the Income Expenditure Statement which is part of their balance sheet for the period 2010-11. The relevant extract from the said statement is reproduced below: Schedule No Current Year Previous Year 2010-11 2009-10 1 2 3 4 5 I Income Donation Received 11 800026159.91 559026871.31 Patient Treatment Charges 22723603.00 6637023.00 Interest Income 12 1129205.63 271922.35 Other Incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any other donations. The entire case of the revenue is that these amounts received as donation for the camps are nothing but consideration charge from the participants for the taxable service provided by the appellant in these residential and non residential camps. 4.9 The demand has been made on the amounts received by the trust in the garb of donation. Annexure 1 to the Show Cause Notice whereby the amount of demand has been worked out is reproduced below: Period Amount of Camp Donations (In Rs) Value taxable Service Rate of Service tax, Education Cess Higher Education Cess Service Tax (In Rs) Education Cess (In Rs) Higher Education Cess (In Rs) Total (In Rs) 01.10.06 - 10.05.07 148301133.8 132128593.9 12% + 2% 15855431 317109 0 16172540 11.05.07 - 23.02.09 254166461.2 226207245.7 12% + 2% + 1% ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Total Amount as per Books of Accounts Coupons Donation General Donation 2006-07 From 01.10.2006) 5538171 99936219 3441845 1000 108917235 2007-08 1245000 86962528 7878630 29373611 125459769 2008-09 22899200 72137521 713854 62251316 158001891 2009-10 0 0 0 29604372 29604372 01.04.10 to 30.09.10 7126930 0 0 2879375 10006305 1.10.10 to 31.03.11 7000 0 0 1568505 1575505 Total 36816301 259036268 12034329 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se answers also show that donations were received by way of cheques out of which substantial money was ploughed back or returned to the donors in cash. The facts thus clearly show that those were bogus donations and that the registration conferred upon it under Sections 12AA and 80G of the Act was completely being misused by the Trust. An entity which is misusing the status conferred upon it by Section 12AA of the Act is not entitled to retain and enjoy said status. The authorities were therefore, right and justified in cancelling the registration under Sections 12AA and 80G of the Act. 12 The High Court completely erred in entertaining the appeal under Section 260A of the Act. It did not even attempt to deal with the answers to the questions as aforesaid and whether the conclusions drawn by the CIT and the Tribunal were in any way incorrect or invalid. 4.11 The fact that in case of sister concern in which Shri Acharya Balkrishna was Secretary General certain investigations/ enquiries were being made will not make the appellant immune from the charge of suppression etc., required to be establish for invoking the extended period of limitation. Each case and each period has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... shall be excluded in computing the aforesaid period of one year or five years as the case may be. 16. The termini from which the period of one year or five years has to be computed is the relevant date which has been defined in sub-section (3)(ii) of Section 11A of the Act. A plain reading of the said definition shows that the concept of knowledge by the departmental authority is entirely absent. Hence, if one imports such concept in subsection (1) of Section 11A of the Act or the proviso thereunder it would tantamount to rewriting the statutory provision and no canon of interpretation permits such an exercise by any Court. If it is not open to the superior court to either add or substitute words in a statute such right cannot be available to a statutory Tribunal. 17. The proviso cannot be read to mean that because there is knowledge the suppression which stands established disappears. Similarly the concept of reasonable period of limitation which is sought to be read into the provision by some of the orders of the Tribunal also cannot be permitted in law when the statute itself has provided for a fixed period of limitation. It is equally well settled that it is n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ha Rectifier [2011 (263) E.L.T. 655 (S.C.)], Hon ble Supreme Court observed as follows: 12. Submission was also made regarding use of the extended period limitation contending inter alia that such extended period of limitation could not have been used by the respondent. The aforesaid contention is also found to be without any merit as the appellant has not obtained L-4 licence nor they had disclosed the fact of manufacturing of the aforesaid goods to the department. The aforesaid knowledge of manufacture came to be acquired by the department only subsequently and in view of nondisclosure of such information by the appellant and suppression of relevant facts, the extended period of limitation was rightly invoked by the department. 4.13 In the case of Mehta Co [2011 (264) E.L.T. 481 (S.C.)], Hon ble Apex Court has held as follows: 22. Consequently, we propose to look into the first issue in the light of the background facts as stated hereinbefore. The specific case of the appellant is that the respondent having manufactured the excisable goods covered under different chapter headings, removed them without payment of proper duty of excise and that from the afore ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the authorities concerned who need to take a certain decision depending on such information. It is not the case of the appellants that they have been paying applicable service tax on getting registered and have been submitting regular returns to service tax authorities. It is not the case of the appellants that the material information available in the form of various contracts/agreements and balance sheets/ledgers have been submitted to the Department suo motu by the appellants. It is only after investigation has been initiated, the necessary documents were submitted. Thus, the information available in the public domain is of no avail. We find that Learned Adjudicating Authority has rightly relied upon in the case of CCE, Calicut v. Steel Industries Kerala Ltd., 2005 (188) E.L.T. 33 (Tri. - Bang.) wherein it is held at Para 3 as under : 3. We find that in the case of Maruti Udyog Ltd. v. CCE, New Delhi, 2001 (134) E.L.T. 269 , the Tribunal has upheld the invocation of the extended period of limitation when the assessees did not declare waste and scrap of iron and steel and aluminium and availment of credit therein either in their classification list or modvat declaration ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he period 1-4-2006 to 31-3-2007. Even in this period, a demand of Rs. 69,132/- is for the period 1-4-2006 to 30-9-2006 and the remaining demand is for the period 1-10-2006 to 31-32007. I find from the chronological sequence of events submitted by the appellant along with the appeal that, department, as early as 12-7-2007 asked the details of overseas payments towards external commercial borrowings for three years. Certain details were furnished by the appellant on 22-8-2007. Thereafter, on 27-8-2007 department informed the appellant, that they are liable to pay Service Tax under Banking and Financial Services as recipient of the service. The appellants, however, did not follow the directions of the department. In the meantime, similar issue relating to convertible alternative reference securities and letter of credit also came up for which the appellant made payments on 12-10-2007 and on 4-12008. Since the appellant did not pay the service tax on the MLA and Agent Bank s service under consideration, the department issued summons to Shri Praveen Sood, an officer of the appellant. The department again asked the appellant for furnishing the details on 21-7-2008 and from the chronology ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... second one is its own balance sheet and profit and loss account. The authority recorded that the appellant failed to explain the difference. Therefore, the disclosure being found to be faulty, adjudication was completed on the basis of figures appearing in its financial statements. The authority did not give any concession on the statutory dues. It comes out from Para 8 9 of the appellate order at page 10. 8. So far as the contention of the appellant in respect of time bar issue and also adjudication under Section 73 is concerned, the appellate authority dealt with the issue in para 10 and he found that one of the element like suppression, which is essential ingredient in Section 73 is present. Therefore, he held that the proceeding was well within time. When he found all these aspects, he made the appellant liable to pay penalty also. He did not give any concession in respect of penalty. 9. We do agree with the ld. Appellate Authority in the matter of the discrepancy noticed by him in respect of the considerations received and appearing in different manner in two different statutory documents. While the ST 3 return was statutory document under Finance Act, 1994, the ba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he escaped duty was the result of deception by the assessee by adopting a means as indicated in Section 11AC. 19. From the aforesaid discussion it is clear that penalty under Section 11AC, as the word suggests, is punishment for an act of deliberate deception by the assessee with the intent to evade duty by adopting any of the means mentioned in the section. 20. At this stage, we need to examine the recent decision of this Court in Dharamendra Textile (supra). In almost every case relating to penalty, the decision is referred to on behalf of the Revenue as if it laid down that in every case of non-payment or short payment of duty the penalty clause would automatically get attracted and the authority had no discretion in the matter. One of us (Aftab Alam, J.) was a party to the decision in Dharamendra Textile and we see no reason to understand or read that decision in that manner. In Dharamendra Textile the court framed the issues before it, in paragraph 2 of the decision, as follows: 2. A Division Bench of this Court has referred the controversy involved in these appeals to a larger Bench doubting the correctness of the view expressed in Dilip N. Shroff v. Joint Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lysed the legal position in the correct perspectives. The reference is answered......... . 21. From the above, we fail to see how the decision in Dharamendra Textile can be said to hold that Section 11AC would apply to every case of non-payment or short payment of duty regardless of the conditions expressly mentioned in the section for its application. 22. There is another very strong reason for holding that Dharamendra Textile could not have interpreted Section 11AC in the manner as suggested because in that case that was not even the stand of the revenue. In paragraph 5 of the decision the court noted the submission made on behalf of the revenue as follows : 5. Mr. Chandrashekharan, Additional Solicitor General submitted that in Rules 96ZQ and 96ZO there is no reference to any mens rea as in section 11AC where mens rea is prescribed statutorily. This is clear from the extended period of limitation permissible under Section 11A of the Act. It is in essence submitted that the penalty is for statutory offence. It is pointed out that the proviso to Section 11A deals with the time for initiation of action. Section 11AC is only a mechanism for computation and the quantu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for the period prior to 10.05.2008 cannot be faulted as it is based on the decisions of High Courts as referred in the impugned order. Hon ble Gujarat High Court has in case of Port Officer [2010 (257) E.L.T. 37 (Guj.)] held as follows: 10. A plain reading of Section 76 of the Act indicates that a person who is liable to pay service tax and who has failed to pay such tax is under an obligation to pay, in addition to the tax so payable and interest on such tax, a penalty for such failure. The quantum of penalty has been specified in the provision by laying down the minimum and the maximum limits with a further cap in so far as the maximum limit is concerned. The provision stipulates that the person, who has failed to pay service tax, shall pay, in addition to the tax and interest, a penalty which shall not be less than one hundred rupees per day but which may extend to two hundred rupees for everyday during which the failure continues, subject to the maximum penalty not exceeding the amount of service tax which was not paid. So far as Section 76 of the Act is concerned, it is not possible to read any further discretion, further than the discretion provided by the legislatur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act, and that, therefore, the Appellate Tribunal was not justified in cancelling the penalties levied for the two assessment years. 4. Learned Counsel for the assessee has addressed an exhaustive argument before us on the question whether a penalty imposed under Section 271(1)(a) of the Act involves the element of mens rea and in support of his submission that it does he has placed before us several cases decided by this Court and the High Courts in order to demonstrate that the proceedings by way of penalty under Section 271(1)(a) of the Act are quasi criminal in nature and that, therefore, the element of mens rea is a mandatory requirement before a penalty can be imposed under Section 271(1)(a). We are relieved of the necessity of referring to all those decisions. Indeed, many of them were considered by the High Court and are referred to in the judgment under appeal. It is sufficient for us to refer to Section 271(1)(a), which provides that a penalty may be imposed if the Income Tax Officer is satisfied that any person has without reasonable cause failed to furnish the return of total income, and to Section 276C which provides that if a person wilfully fails to furni ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... them on the taxable services provided by them by the due date and hence demand of interest on the delayed payment of service tax is justified. Hon ble Bombay High court has in case of P V Vikhe Patil SSK [2007 (215) ELT 23 (Bom)]. stated as follows: 10. So far as interest u/s. 11AB is concerned, on reference to text of Section 11AB, it is evident that there is no discretion regarding the rate of interest. Language of Section 11AB(1) is clear. The interest has to be at the rate not below 10% and not exceeding 36% p.a. The actual rate of interest applicable from time to time by fluctuations between 10% to 36% is as determined by the Central Government by notification in the Official Gazette from time to time. There would be discretion, if at all the same is incorporated in such notification in the gazette by which rates of interest chargeable u/s. 11AB are declared. The second aspect would be whether there is any discretion not to charge the interest u/s. 11AB at all and we are afraid, language of Section 11AB is unambiguous. The person, who is liable to pay duty short levied/short paid/non-levied/unpaid etc., is liable to pay interest at the rate as may be determined b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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