9911796707
TMI Blog1997 (2) TMI 187X X X X Extracts X X X X X X X X Extracts X X X X ..... that of Shri K. Prahlad Rai Agrawal. Later on it was explained by the assessee that Shri K.P. Rai is the father-in-law and Shri Prahladrai Agrawal and Shri K.P. Rai is the name of the same person. The assessee further explained that it was an interest free loan and the sum of Rs. 1,00,000 was remitted by demand draft payable on the State Bank of India, Nagpur, from the State Bank of India, Hyderabad, on 11-4-1981. The assessee was asked by the Assessing Officer to produce Shri K.P. Rai personally but he failed to do so. The Assessing Officer found that the signatures on the confirmatory letters were not of Shri K.P. Rai/Prahladrai Agrawal. The Assessing Officer after scrutiny of the evidence came to the conclusion that the onus which lay on the assessee to prove the genuineness of the credit was not discharged. Hence he added the same under section 68 of the Income-tax Act. On appeal before the CIT(A), the assessee has taken the following arguments:-- "(a) M/s. K. Prahladrai is a firm in Hyderabad. (b) The appellant's father Shri K. Prahlad Rai is a partner in the said firm. (c) The firm advanced Rs. 1,00,000 to the appellant through an account payee demand draft on the St ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7 at 11 A.M. in the office of the IAC, Assessment-I, Third Floor, Aayakar Bhawan, Basheerbagh, Hyderabad. The assessee was also directed to remain present on the said date, time and place. The Assessing Officer on 7-12-1987 personally visited Hyderabad and Shri P.R. Gupta/K. Prahlad Rai did not attend the office in spite of personal service of the summons. However, his son Shri Rajendrakumar Gupta attended and stated that Shri K.P. Gupta/K. Prahlad Rai was sick and was bed ridden due to paralysis and was not in a position to comply with the summons to give any statement. No medical certificate was filed in support by it. At that time Shri Vijaykumar Kabra, C.A., showed acknowledgement No. 3401 dated 24-7-1982 of the ITO, H-2 Ward, Hyderabad, showing that return of income for assessment year 1982-83 was filed and it was the last assessment as the firm was closed thereafter. A commission was issued to I.T.I. and a questionnaire was given to him and the counsel of the assessee accompanied him and after executing the commission, the report in the shape of replies was filed on 9-12-1987 duly signed by P.R. Gupta/K. Prahladrai. The Income-tax Inspector as Commissioner reported that he wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was never adequate cash balance to make available amount to the tune of Rs. 1 lakh. After enquiries, it is also found that Shri Prahladrai has not adequate financial resources as he was not assessed to Income-tax as Individual, and his only source of income was of the HUF consisting of rental income of about Rs. 10,000 per annum which is just adequate to meet the expenses of the family. Summons were issued in his name, with copy to you, requiring his attendance at Aayakar Bhawan, Hyderabad on 7-12-1987, when his son appeared and pleaded that Shri Prahlad Rai was sick and bed-ridden due to paralysis. He was given a questionnaire calling for certain details. On 9-12-1987, Shri Rajendrakumar, son of Shri Prahlad Rai attended and filed replies to the questions duly signed by Shri Prahlad Rai. It was brought to his notice that enquiries reveal that Shri Prahlad Rai was not actually bed-ridden and he could attend the office in compliance with the summons. Alternatively, it was suggested that the statement will be recorded at his residence. Shri Rajendrakumar agreed to bring Shri Prahlad Rai to the Office on 11-12-1987 at 11A.M. positively. On the said date and time, none attended and it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e onus which lay on him and had adopted dilatory tactics and deliberately failed to produce the said creditor and ultimately when he failed in his mission then on advice arrested the further proceedings of the case by making a request for issue of commission. The Assessing Officer after considering the entire matter and conduct of the assessee and his father-in-law concluded that the material witness was being with held for ulterior motive so he rejected his request and framed the assessment and thereby added the same as income of the assessee from undisclosed sources under section 68 of the Income-tax Act. 4. On appeal before the CIT(A), the authorised representative for the assessee almost repeated the same submissions which were advanced before the Assessing Officer. He contended that the assessee had discharged the onus which lay on him by showing that the amount in question had been received by account payee draft by filing confirmatory letter from the creditor, namely R.P. Gupta/Shri Prahlad Rai in the shape of an affidavit and the Assessing Officer was not justified in rejecting the averments in the affidavit as false merely because the GIR number quoted for assessment yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... apacity to advance the loan and the transaction was not genuine. Having considered the entire facts, the CIT(A) confirmed the order of the Assessing Officer holding that the assessee failed to discharged the onus and the addition was rightly made by the Assessing Officer. He has examined the legal point and he observed that addition is sustained under section 69 of the Income-tax Act as unexplained investment and thereafter he, dismissed the appeal of the assessee. 5. Being aggrieved by the order of the CIT(A), the assessee has come up in second appeal before the Tribunal. 6. The authorised representative for the assessee has reiterated the same arguments which were advanced before the authorities below. He contended that the firm M/s. K. Prahlad Rai was assessed by ITO, H-2 Ward, Hyderabad at GIR No. K-313 and this firm advanced Rs. 1,00,000 to Shri K. Prahlad Rai/K.P. Rai, father-in-law of the assessee and he lent this money to the assessee by way of demand draft. Proceeding further he contended that neither the Assessing Officer nor the CIT(A) has examined the entire evidence in its right perspective and, therefore, the said amount of Rs. 1,00,000 cannot be added in the ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ause section 68 of the Income-tax Act does not apply to the facts of this case as this amount was not credited in the books of account maintained by the assessee for the previous year. He also contended that section 69 of the Act also does not apply as, under that section the value of the investment made by the assessee in a financial year cannot be deemed to be the income of the assessee, if such an investment is not recorded in the books of account, if any, maintained by him and the assessee does not offer any explanation and the disputed amount was repaid by demand draft and Shri K Prahlad Rai on receipt of the same amount has deposited the same in the Bank. 7. On the other hand, the Departmental Representative, strongly relied upon the orders of the authorities below and submitted that the Assessing Officer had allowed sufficient opportunity to the assessee to produce the creditor, namely Shri Prahlad Rai Gupta and when he failed to produce him before him at Nagpur, the Assessing Officer camped for 5 days at Hyderabad and after personal service of this summons, Shri Prahlad Rai failed to appear on the date fixed on 7-12-1987 before the Assessing Officer at his home town. He a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat none of the sections 68 to 69-D are applicable to the facts of this case, the Tribunal held that once the assessee fails to explain the source of money satisfactorily in his possession, the value of that money will have to be added back to the total income of the assessee as income from undisclosed sources. As mentioned above, such additions were made under the 1922 Act and were sustained though no such provisions existed at the relevant time. The case law relied upon by the assessee did not help him in view of the facts of the case. He further placed reliance on the ratio of the decision in the case of CITv. United Commercial Industrial Co. (P.) Ltd [1991] 187 ITR 596/56 Taxman 304 (Cal.), CIT v. S. Kamaraja Pandian [1984] 150 ITR 703/18 Taxman 187 (Mad.), Nanak Chandra Laxman Das v. CIT[1983] 140 ITR 151 (All.) and Harichand Virendra Paulv. CIT[1983] 140 ITR 148/11 Taxman 134 (Punj. Har.). 8. We have considered the submissions of the parties and have gone through the orders of the authorities below and the entire material placed on record including the paper book filed by the assessee and the ratio of the decisions relied upon by the parties. In this case the following ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... abad on 11-12-1987 at 11 a.m. but on 11-12-1987 none attended and this fact was intimated to the assessee who appeared at 3.30 p.m. on 11-12-1987. The Assessing officer communicated the entire position which has emerged out till then to the assessee vide his letter dated 14-12-1987 as mentioned in pre-paragraphs. The Assessing Officer was informed by the assessee that N./s. K.P. Rai was assessed by the ITO, H-2 Ward at GIT K-313. After enquiries the Assessing Officer found that there was no such case on his GIR number K-313 in the relevant year. This fact was brought to the notice of Rajendrakumar son of K. Prahlad Rai who appeared before the ITO during his camp at Hyderabad along with Shri Vijaykumar Kabra, C.A. The authorised representative for the assessee filed a copy of the acknowledgement slip contending that the firm M/s. K.P. Raifiled return. The acknowledgement slip did not bear the stamp of the ITO and when the original slip was demanded, the same was not produced. It is notable that search and seizure operations had taken place and the department has taken certain books and record of the assessee, but it was not asserted that the present and past assessments were tak ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he aforesaid background, it is to be seen as to whether the assessee has discharged the onus which lay on him. It is settled principle of law that the assessee has to establish the identity of the creditor, capacity of the creditor to advance the loan and the genuineness of the transaction. After going through the entire evidence as discussed in pre-paragraphs, it is established that the identity of the creditor was established because the summon under section 131 was served on the creditor on the address given. Therefore, by first ingredient it is evidenced that the identity of the creditor was established. The other ingredient which the assessee is requested to establish is whether the creditor had capacity to advance the said loan. In this regard, heavy burden lay on the assessee to prove it. The Assessing Officer again asked the assessee to produce the creditor but he failed to do so. The Assessing Officer was however, aware of the fact that the assessee had filed affidavit of creditor before the CIT(A) and he was to be cross-examined with a view to verify the veracity of the averment. Therefore, he visited the place of residence of the creditor at, Hyderabad and in the summons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent. Reliance is placed on the ratio of the decision in the case of Sri Krishna v. CIT[1983] 142 ITR 618 (All.). Much stress was laid on the answers to the questionnaire, but in view of the aforesaid facts, the replies to the questions were not recorded on oath and it required corroborative evidence which had not been produced. The replies of question Nos. 19 and 20 by Shri P.R. Gupta were rightly rejected by the Assessing Officer for the reasons mentioned therein. It is further seen that the assessee had filed copy of the account of M/s. K. Prahladrai. It is notable that no reliance can be placed on it for two reasons that there are over-writings in the balance sheet of K. Prahladrai and the amount had been changed and no body had initialled it or explained it. Therefore, this paper had been rendered an illegal document and as such, it cannot be relied upon though for valid reasons the Assessing Officer had rejected it. After going through the entire material on record, we find that there is no other material on record to establish that Shri Prahladrai Gupta had capacity to advance money to the tune of Rs. 1,00,000. It is not established by cogent evidence as to wherefrom the mone ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ording the statement of Shri K. Prahlad Rai at Hyderabad was premeditated design to arrest the proceedings and it was not genuine request at all in view of the conduct of the assessee and the creditor as mentioned above. Therefore, the request for issue of commission was rightly rejected and we on the basis of the material on record hold that adequate opportunity was given to the assessee and the creditor but the assessee knowingly withheld the material evidence and did not allow the Assessing Officer to take advantage of the cross-examination and the demeanour of the witness. Therefore, we hold that the, assessee failed to discharge the burden which lay on it. 10. In the alternative the authorised representative for the assessee contended that since the amount was received by Bank draft, the transaction could not be treated as a cash credit within the scope of section 68 of the Act. This argument was considered by the CIT(A) and he held that this submission has some force. He, however, held that the said amount will legally be assessed as unexplained investment within the scope of section 69 of the Act when the assessee failed to prove this source of the same. He also held that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case. I regret that I am unable to agree with him. 2. The facts are as below: "(1) An account payee draft No. 224216 dated 11-4-1981 was purchased from State Bank of India, City Branch, Hyderabad drawn on State Bank of India, Nagpur for Rs. 1 lakh. The same was deposited in the Wardhaman Nagar Branch of Bank of Maharashtra on 14-4-1981 in the assessee's account. (2) After the assessee's account was credited in the Bank of Maharashtra a cheque was issued by the assessee to M/s. Lalchand Gajanan, a firm in which the assessee is a partner on 15-4-1981. This amount was credited in the capital account of the assessee in the books of the firm M/s. Lalchand Gajanan on the same day i.e. on 15-4-1981. (3) The return of income for the assessment year 1982-83 was filed on 28-4-1984 showing an income of Rs. 62,632. (4) On 17-11-1984 the assessee filed confirmation letter from M/s. K.P. Rai along with the copy of account in the books of the firm. This was signed by Shri P.R. Gupta. (5) The Assessing Officer held that the assessee had failed to prove the genuineness of the deposit of Rs. 1 lakh in the capital account. Hence he added the same as income from undisclosed sources under s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to K.K. Steel Trading Co., Secunderabad (Answer to question No. 4). (d) He affirmed that the contents of the affidavit were correct. The Assessing Officer, however, insisted that Shri P.R. Gupta should attend and Shri Gupta's son promised to bring him on 11-12-1987. 6. On 11-12-1987, according to the Assessing Officer, none attended. The assessee who attended at 3.30 P.M. was told that Shri P.R. Gupta had not attended. However, according to Shri Vijaykumar Kabra, C.A. Shri Gupta had attended along with Shri Rajendrakumar and P.R. Gupta on 11 P.M. on that date. It was submitted that they waited for quite some time but could not meet the Assessing Officer as he was not available. 7. On 14-12-1987 the Assessing Officer wrote to the assessee to produce Shri K. Prahlad Rai on 29-12-1987 at Nagpur for his examination. However, on 29-12-1987 the assessee attended before the Officer and submitted that Shri Kabra, C.A. of Shri K.P. Rai could not be contacted. He, however, requested the Assessing Officer to issue fresh summons to Shri Rai and undertook to pay the travelling expenses of Shri Rai's journey from Hyderabad to Nagpur and Nagpur to Hyderabad. It is notable that Hyderabad i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s clear that Shri K. Prahlad Rai alias P.R. Gupta had no capacity to advance money. The Assessing Officer further held that the answers to question Nos. 19 and 20 given by Shri P.R. Gupta clearly show that he was evasive. (ix) The examination of Shri Prahlad Rai's cash book shows an entry of Rs. 1 lakh representing two self cheques on 11-4-1981 for the purposes of sending demand draft of Rs. 1 lakh to Nagpur. In the so called rough ledger on page No. 10 the account of Shri Gopal Agrawal is shown with a debit balance of Rs. 1 lakh. According to the Assessing Officer it was an evidence created in support of the claim of the assessee of having borrowed Rs. 1 lakh to Shri Prahlad Rai. (x) The Assessing Officer further held that the sum of Rs. 1 lakh was not actually borrowed by the assessee but represented unaccounted money invested by him. He added the same under section 68 of the Act. 10. When the matter was taken to the CIT(Appeals) he agreed with the Assessing Officer on the following grounds:-- (1) That the assessee failed to prove the credit worthiness of Shri Prahlad alias K.P. Rai. (2) The capacity of the creditor to advance loan was to be proved by the assessee and n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a failure to exercise the jurisdiction of issuing commission particularly when a party to the proceedings requested for summoning evidence from a particular person. It was submitted that it was not Shri Prahlad Rai who had advanced money, it was the firm which had advanced money. Our attention was invited to Answers to question Nos. 9 to 14 of the questionnaire contained in pages 11 and 12 of the paper book where the creditor confirmed the factom of loan, mode of payment and when and how it was written and where money was invested after returned by the assessee. It was submitted that once the books of account of M/s. K. Prahlad Rai, Hyderabad firm were seized from the residence of Shri Prahlad Rai during the search how could be the assessee manipulated the books which were seized from him. It was also submitted that the very fact that the self cheques were drawn by Shri Prahlad Rai on 11-4-1981 confirms his capacity to advance the money. 11A. It was further submitted that the Department does not deny that the loan was received by account payee draft drawn on State Bank of India, Hyderabad and the facts mentioned in the affidavit of Shri K. Prahlad Rai alias P.R. Gupta have not be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... they could have explained the sources of the drafts and the circumstances in which they were remitted to the assessee. I am of the opinion that taking into consideration all the aspects of the case, the failure of the Assessing Officer to exercise his legal jurisdiction resulted in failure of justice and as such his order cannot be sustained in this regard. The assessee filed an affidavit of the creditor who accepted that he had advanced loan by a draft. He also confirmed the grant of loan. He also confirmed that he had received money back and also indicated the person to whom he had given that money later on. I am of the opinion that the extent of the onus of proof placed under section 69 is not absolute but is based on preponderance of probabilities. In my view the assessee has discharged the burden cast on him. 15. It is notable that the Department has nowhere disputed that the money was received by account payee draft purchased by the creditor from the State Bank of Hyderabad. As held by the Supreme Court in the case of CIT v. Daulat Ram Rawatmull [1973] 87 ITR 349 the onus of proving that the apparent was not the real was on the party who claimed it to be so. The Department ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. Whether adequate opportunity of hearing and leading evidence was provided to the assessee?" THIRD MEMBER ORDER 1. A difference of opinion having arisen between the Members who originally heard this appeal, the matter has come to be referred to me by the President under section 255(4) of the Income-tax Act. The points of difference are as under: "1. Whether on the facts and in the circumstances and evidence on record, the addition was legally sustainable or not? 2. Whether the assessee has discharged his onus of proof placed under section 69 of the Act? 3. Whether adequate opportunity of hearing and leading evidence was provided to the assessee?" 2. The assessee is an individual. For the assessment year 1982-83 (year ending Diwali 1981), the assessee had share income from two firms including M/s. Lalchand Gajanan, Nagpur. The assessee had received draft No. 224216 dated 11-4-81 which was purchased from State Bank of India, City Branch, Hyderabad, for Rs. 1,00,000. The same was deposited by the assessee in the Wardhaman Nagar Branch of the Bank of Maharashtra on 14-4-81 in the assessee's account. On 15-4-81 the assessee issued a cheque of Rs. 1,00,000 in favour of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions given by the Assessing Officer. This was done and the copy of the questions and answers is placed on record. The Income-tax Inspector, however, reported that Shri K. Prahlad Rai was quite alright and was in a position to comply with the summons. Shri Rajendrakumar, the son of Shri K. Prahlad Rai agreed to bring his father to the office at Hyderabad on 11-12-87. According to the Assessing Officer K. Prahlad Rai did not attend his office on that day though it was later disputed from the assessee's side that Shri K. Prahlad Rai had attended the office at 3.30 p.m. The Assessing Officer vide order dated 29-1-88 again held that the amount of Rs. 1,00,000 was not actually borrowed by the assessee but represented the unaccounted money invested by him and addition of Rs. 1,00,000 was accordingly made under section 68 of the Act. 5. The assessee preferred an appeal and the CIT (Appeals-I), Nagpur, vide order dated 27-8-92 in the second round of litigation confirmed the addition though under section 69. 6. The assessee preferred an appeal before the Tribunal. The learned Judicial Member who wrote the leading order accepted that the identity of the creditor stood established. He, how ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year 1982-83 had been filed by the firm M/s. K.P. Rai on 20-7-82 but the Assessing Officer made no attempts to trace the same. It was also noted that there was search at the premises of M/s. K.P. Rai and its partners on 26-6-86 when all the books of account had been seized by the Income-tax Authorities. He gave credence to the theory of strained relationship between the assessee and his father-in-law. He further opined that the Assessing Officer should have accepted the assessee's request to issue commission to the ITO Hyderabad to examine Shri K.P. Rai at Hyderabad particularly when there was still time for passing the assessment order up to 31-3-88 and that there was no hurry in passing the order on 29-1-88. According to him, the department had nowhere disputed that the money was received by Account Payee Draft purchased by the creditor from the State Bank of Hyderabad. He thus came to the conclusion that the department failed in its duty to issue commission and examine the creditor and hence the addition of Rs. 1,00,000 made by the Assessing Officer and sustained by the CIT (Appeals) should be deleted. 8. M. Mani, the learned counsel for the assessee submitted that there was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... P. Rai and other relevant facts. It was submitted that the assessee had no power to enforce the attendance of a witness and that the Assessing Officer had all the powers to enforce the attendance of the witness. It was submitted that in this background of the case, the request made by the assessee when there was still ample time for completing the assessment that commission be issued to the ITO Hyderabad for recording the statement of Shri K. Prahlad Rai was absolutely reasonable and justified, because Hyderabad was situated about 500 Km. away from Nagpur. This opportunity was, however, denied to the assessee. 10. It was submitted that M/s. K.P. Rai did not take any legal proceedings against the assessee for recovery of Rs. 1,00,000 because the assessee always acknowledged that it would repay the amount and never repudiated the same. It was also pointed out that the loan of Rs. 1,00,000 was ultimately returned by Account Payee Draft on 17-10-87 and was further utilised by M/s. K.P. Rai by advancing it to another concern. It was also submitted that the Assessing Officer in the assessment order had relied on some seized record, but the assessee was not confronted with the same and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... equate opportunity had been allowed to the assessee to lead the necessary evidence and discharge the onus. It was submitted that the Assessing Officer not only fixed the matter a number of times but also visited Hyderabad to record the statement of Shri K. Prahlad Rai to ferret out the truth. It was submitted that the assessee had agreed that Shri K. Prahlad Rai be summoned from Hyderabad and that he would pay the diet money. It was submitted that later on the assessee took a position that instead of summoning him, a commission be issued to ITO Hyderabad for recording the statement of Shri K. Prahlad Rai. It was submitted that looking to the conduct of the creditor, the Assessing Officer could very well infer that this was a case of abusing the process of law by procrastinating and prolonging the matter. It was pointed out that the Assessing Officer gave further opportunities on 29-12-1987, 18-1-1988 and 28-1-1988 and only thereafter completed the assessment on 29-1-1988. It was, therefore, submitted that an adequate opportunity had been allowed to the assessee. 14. As regards the acknowledgement slip, it was submitted that the original had never been produced, that the acknowled ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd from that account the assessee issued a cheque to M/s. Lalchand Gajanan and that is how M/s. Lalchand Gajanan gave credit of Rs. 1,00,000 in the capital account of the assessee in its books of account on 15-4-1981. 16. It is true that the assessee's case was fixed a number of times. There is, however, no evidence on record to show that the case was fixed more than once because of the assessee's default. The Assessing Officer was justified in recording the statement of Shri K. Prahlad Rai with a view to determining the veracity of his affidavit. It was commendable that he even went to Hyderabad and stayed there for five days to make the necessary enquiries and to record the statement of Shri K. Prahlad Rai. He was quite fair in sending his Inspector to the residence of Shri K. Prahlad Rai to elicit the answers to certain questions when it was brought to his notice that Shri K. Prahlad Rai was bed ridden. If Shri K. Prahlad Rai did not turn up on 11-12-1987, as per the Assessing Officer's version, it could not be said to be on account of the assessee's failure. Under the law the assessee has no power to enforce the attendance of a witness. That power is vested in the authorities ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had closed down its business and assessment year 1982-83 was the last year. When the Assessing Officer went to make enquiries in 1987 it is quite possible that the same GIR No. might have been allotted to some other assessee. 18. The balance-sheet of M/s. K.P. Rai also showed that a sum of Rs. 1,00,000 had been advanced to the assessee as the name of the assessee appeared in the asset side of the balance-sheet and the amount of Rs. 1,00,000 was clearly indicated against his name. There is no cutting in the balance-sheet because the cutting, if any, is in the figure of "4" in the total of Rs. 2,49,367.58 which is the total of the liability side and the figure "4" has been changed to "5". There is no cutting in the total of the asset side. 19. The premises of M/s. K.P. Rai had been searched by the Income-tax Authorities on 26-6-1986 when books of account etc. had been taken into possession by the department. In such a situation it was very easy for the department to have looked into the seized record of M/s. K.P. Rai and found out the truth. It seems that the Assessing Officer did go into some of the seized records of the said firm but this evidence was not confronted to the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
