KARTHIK VR THONDAIMAN,TRICHY vs. ITO, WARD-1, PUDUKKOTTAI

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ITA 1581/CHNY/2026Status: DisposedITAT Chennai10 September 2026AY 2016-1716 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the notice under Section 148 was issued beyond three years, approval from the PCCIT was mandatory as per Section 151 of the Act. The approval obtained from the PCIT was not in conformity with the statutory requirement, rendering the notice invalid.

What were the facts?

The assessee filed a return of income for AY 2016-17. A notice under Section 148 was issued on 26.07.2022, which was beyond three years from the end of the assessment year. The approval for this notice was obtained from the Principal Commissioner (PCIT) instead of the Principal Chief Commissioner (PCCIT).

What were the issues?

The key issue was the validity of the notice issued under Section 148 of the Income Tax Act, 1961, due to the incorrect authority granting the necessary approval beyond the prescribed time limit.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 151,Section 147,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRIS.R.RAGHUNATHA

Hearing: 15.07.2026

आयकरअपील�यअ�धकरण ’बी’ �यायपीठ,चे�नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI �ी मनुकुमारिग�र, �ाियक सद� एवं �ी एस. आर. रघुनाथा लेखासद� BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRIS.R.RAGHUNATHA, ACCOUNTANT MEMBER

आयकर अपील सं./ITA No. 1581/Chny/2026 �नधा�रण वष�/Assessment Year: 2016-17 Karthik VR Thondaiman, v. The ITO, 4D/4 Pudukottai Palace Wared-1, Pudukkottai, Compound, Collectorate Road, Tamil Nadu-622002 Cantonment Tiruchirapalli, Tamil Nadu-620001 [PAN: ALIPK 6185 B] (अपीलाथ�\Appellant) (��यथ�\Respondent)

अपीलाथ� क ओर से/ Appellant by : Mr. S. Girish Kumar, Advocate ��यथ� क ओर से /Respondent by : Mr. Shiva Srinivas, CIT सुनवाई क तार�ख/Date of Hearing : 15.07.2026 घोषणा क तार�ख /Date of : 10.09.2026 Pronouncement आदेश / O R D E R PER MANU KUMAR GIRI, JM:

This appeal has been preferred by the assessee against the order dated 09.03.2026 passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”), for the Assessment Year (“AY”) 2016–17.

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 2 ::

2.

The assessee is an individual who filed his return of income for AY 2016–17 on 28.02.2018, declaring a total income of Rs.49,98,990/-. Subsequently, a notice under Section 148A(b) of the Income Tax Act, 1961 (“the Act”) was issued on 17.05.2022, followed by an order under Section 148A(d) of the Act dated 26.07.2022. Thereafter, pursuant to the proceedings initiated under Section 148A and on the basis of the information available with the Department, notice under Section 148 of the Act was issued to the assessee on 26.07.2022. During the course of reassessment proceedings, the assessee was afforded various opportunities to furnish explanations and supporting material in respect of the information available with the Assessing Officer (“AO”). However, the AO, vide order passed under Section 147 read with Section 144B of the Act, completed the reassessment proceedings on 12.05.2023 by making an addition of Rs.8,88,03,000/- towards capital gains arising from the sale of immovable property.

2.1 Aggrieved by the aforesaid assessment order, the assessee preferred an appeal before the Ld. CIT(A). The Ld. CIT(A), however, dismissed the appeal. Being further aggrieved, the assessee has preferred the present appeal before this Tribunal challenging the order passed by the Ld. CIT(A).

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 3 ::

3.

The Ld. Authorized Representative (“Ld. AR”) appearing on behalf of the assessee submitted that, vide Ground No. 4, the assessee has challenged the validity of the notice issued under Section 148 of the Act on the ground that the same was issued after expiry of the period of three years from the end of the relevant assessment year without obtaining the requisite approval from the competent authority prescribed under Section 151 of the Act. According to the Ld. AR, since the notice under Section 148 was issued beyond the period of three years, the AO was required to obtain the approval of the Principal Chief Commissioner of Income Tax (“PCCIT”); however, the approval in the present case was obtained from the Principal Commissioner of Income Tax (“PCIT”).

The Ld. AR further submitted that, if the aforesaid legal ground is decided in favour of the assessee, the remaining grounds relating to both the legal validity of the proceedings and the merits of the additions would become purely academic in nature. Accordingly, we deem it appropriate to first adjudicate upon the aforesaid legal issue.

4.

In support of the aforesaid contention, the Ld. AR submitted that the notice under Section 148 of the Act was issued on 26.07.2022, which was admittedly beyond the period of three years from the end of the relevant assessment year. Consequently, in terms of Section 151 of the Act, the AO was

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 4 :: required to obtain the prior approval of the PCCIT before issuing such notice. However, in the present case, the AO obtained approval from the PCIT, Madurai, instead of the PCCIT, prior to issuance of the notice under Section 148. It was, therefore, contended that the statutory requirement prescribed under Section 151 of the Act had not been duly complied with and, consequently, the notice issued under Section 148 was invalid and unsustainable in law. In support of his contention, the Ld. AR placed reliance upon the decision of this Tribunal in Meganapuram Primary Agricultural Cooperative Credit Society v. PCIT, ITA No. 895/Chny/2025, dated 19.09.2025, wherein an identical issue arose for consideration and the Tribunal decided the said legal issue in favour of the assessee. The Ld. AR relied upon the following observations of the Tribunal:-

“40. We find that the Show Cause Notice u/s.148A(b) of the Act came to be issued on 23.03.2022 in proposing to issue notice u/s.148 of the Act and as a consequence proposing to assumption of jurisdiction in terms of Section 147 of the Act. The assessee had filed its response to the said notice on 29.03.2022 and the AO had issued a letter dated 04.04.2022 in seeking further details in support of the submissions of the assessee and ultimately the order u/s.148A(d) of the Act came to be passed on 19.04.2022 by the AO, wherein the AO deemed it fit to issue notice u/s.148 of the Act. Thus, the notice u/s.148 of the Act came to be issued on 19.04.2022 for the A.Y. 2018- 19. 41. The provisions of Section 151 defines the sanctioning authority and the relevant provisions as it stood at that point in time reads as under: “151. Specified authority for the purposes of section 148 and section 148A be,— (i) Principal Commissioner or Principal Director or Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year;

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 5 :: (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three years have elapsed from the end of the relevant assessment year.]”

From a plain reading of the above provisions, the competent authority to grant / accord sanction in terms of Section 151 of the Act is determined based on the date of issuing of sanction and in the event of issuing the sanction beyond the period of three years from the end of the relevant assessment year, the same would be covered by clause (ii) to Section 151 of the Act.

42.

If the notice u/s.148 of the Act / order u/s.148A(d) of the Act is issued / passed within 3 years from the end of the relevant assessment year, the competent authority for the purpose of granting sanction in terms of Section 151 of the Act is either Principal Commissioner or Principal Director or Commissioner or Director, as the case may be.

43.

On the other hand, if the same is issued / passed after the expiry of the 3 years from the end of the relevant A.Y., the competent authority in this regard should be Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General.

44.

Now, let us examine the facts of the present case by keeping in mind the above legal position.

The Show Cause Notice in terms of Section 148A(b) of the Act came to issue on 23.03.2022 after obtaining prior approval from the office of the PCIT, Madurai – 1 and thereafter the order in terms of Section 148A(d) of the Act came to be passed on 19.04.2022 along with the notice u/s.148 of the Act being issued on the same day, i.e. 19.04.2022. We find that both the order passed u/s.148A(d) of the Act as well as the notice u/s.148 of the Act dated 19.04.2022 was issued after getting approval from the office of the PCIT, Madurai – 1. The assessment year under consideration being A.Y.2018-19, the notice u/s.148 of the Act / order passed u/s.148A(d) of the Act being issued / passed on 19.04.2022, it can be said that same were passed / issued after the expiry of 3 years from the end of the A.Y under consideration.

45.

Hence, it can be said that the notice u/s.148 of the Act was issued / order in terms of Section 148A(d) of the Act was passed without obtaining proper sanction from the competent authority as prescribed in terms of Section 151(1)(ii) of the Act.

46.

It is pertinent to note that the proviso to Section 151 of the Act contemplates exclusion of time provided to the tax payer to response to Show Cause Notice u/s.148A(b) of the Act to the date of actual passing of the order u/s.148A(d) of the Act / notice u/s.148 of the Act, which proviso reads as follows:

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 6 :: “Provided that the period of three years for the purposes of clause (i) shall be computed after taking into account the period of limitation as excluded by the third or fourth or fifth provisos or extended by the sixth proviso to sub-section (1) of section 149.”

47.

However, we find that the proviso to Section 151 of the Act was only introduced by way of Finance Act, 2023, with effect from 01.04.2023, i.e. the said amendment was introduced only after the sanction was granted on the present case / not available at the time of recording of sanction in terms of Section 151 of the Act in the case of the appellant herein.

48.

The Ld. AR took us through the Finance Bill, 2023, wherein clause 71, proposing the said amendment to Section 151 as well the notes of clauses to Finance Bill, 2023, wherein relevant note to the said amendment reads as follows:

Clause 71 of the Bill seeks to amend the section 151 of the Income-tax Act relating to sanction for issue of notice.

It is proposed to amend clause (ii) of the said section to provide that the specified authority for the purposes of section 148 and section 148A shall be the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General, if more than three years have elapsed from the end of the relevant assessment year.

It is further proposed to insert a proviso in the said section so as to provide that the period of three years for the purposes of clause (i) shall be computed after taking into account the period of limitation as excluded by the third or fourth or fifth provisos or extended by the sixth proviso to sub-section (1) of section 149.

These amendments will take effect from 1st April, 2023.

49.

Thus, it is an irrefutable fact that the amendment brought in by Finance Act, 2023 in introducing the proviso to Section 151 of the Act by giving effect to the exclusion of time limit by operation of 3rd to 5th proviso to Section 149(1) of the Act would take effect only from 01.04.2023.

50.

Hence, it can be said that the said amendment would not come to the rescue of the revenue on the facts of the present case in view of the fact that the notice u/s.148 as well the order u/s.148A(d) of the Act being issued / passed well prior to the introduction of the said amendment, i.e. on 19.04.2022.

51.

Before us, the Ld.DR argued that the said amendment introduced by Finance Act, 2023 ought to be reckoned as clarificatory and would have retrospective applicability, thereby validating the sanction accorded by the PCIT, Madurai – 1 on the facts of the present case. He further relied on the judgment of the Hon’ble Calcutta High Court in

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 7 :: the case of Giriraj Commercial (P.) Ltd. v. Union of India reported in 169 taxmann.com 168 in support of his contentions.

52.

This argument of the ld.DR is unable to be countenanced by us for the simple reason that the said amendment was introduced specifically with effect from 01.04.2023 and the plain reading of the notes on clauses as well as the memorandum to Finance Act, 2023 leave no room whatsoever to interpret it otherwise. Moreover, we are not inclined to accept the argument of the Department since the AO could not have foreseen such an amendment while passing the order u/s.148A(d) of the Act / issuing the notice u/s.148 of the Act nor the PCIT, Madurai – 1 could have foreseen such amendment while according sanction in terms of Section 151 of the Act.

53.

Hence for the reasons discussed above, we hold that the amendment to Section 151 of the Act, introduced by Finance Act, 2023, with effect from 01.04.2023 cannot be reckoned to have retrospective applicability and on this ground we reject the argument put forth by the ld.DR.

54.

It was further argued by the ld.DR, that the approval granted by the competent authority, i.e. PCIT, Madurai – 1 to the AO for issuing the notice u/s.148A(b) of the Act vide approval dated 23.03.2022 as mandated by 1st proviso to Section 148 of the Act would suffice the requirement as per the Section 151 of the Act and as such there was no requirement for the AO to obtain approval / sanction once again by the competent authority for issuing the notice u/s.148 of the Act / passing of the order u/s.148A(d) of the Act.

55.

We find that the 1st proviso to Section 148 of the Act as per Finance Act, 2021 reads as follows:

“Provided that no notice under this section shall be issued unless there is information with the Assessing Officer which suggests that the income chargeable to tax has escaped assessment in the case of the assessee for the relevant assessment year and the Assessing Officer has obtained prior approval of the specified authority to issue such notice.”

Thus, on the facts of the present case, the Show Cause Notice u/s.148A(b) of the Act was issued upon the assessee herein only upon prior approval of the competent authority, PCIT, Madurai – 1. But whether this sanction would also be available / extended to the issuance of notice u/s.148 of the Act / passing of the order u/s.148A(d) of the Act by the AO by reckoning it was a fit case for issuance of such notice u/s.148 of the Act ?

56.

We are unable to further accept this argument of the ld.DR, because if it were to be accepted, it would result in a scenario wherein the competent authority was according sanction / approval in terms of Section 151 of the Act for issuing notice u/s.148 of the Act even prior to reply of the assessee to the Show Cause Notice u/s.148A(b) of the Act and even prior the decision of the AO in reckoning whether it was a fit case or not for issuing notice u/s.148 of the Act.

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 8 :: 57. Furthermore, if the said argument were to be accepted, then the very purpose behind introduction of provisions in Section 148A of the Act by way of Finance Act, 2021 to grant an opportunity to the tax payer to demonstrate his case for dropping the proceedings before issuing notice u/s.148 of the Act would stand defeated.

58.

Thus, on the facts of the present case, we find that although the sanction was granted to the AO for issuing the Show Cause Notice u/s.148A(b) of the Act, a separate sanction is to be granted for the purpose of issuance notice u/s.148 of the Act as well as the passing of the order u/s.148A(d) of the Act, in the event of the AO finding it fit to do so. Hence, we reject this argument of the ld.DR also.

59.

We further find that the Hon’ble Madras High Court in the case of Core Logistic Company v. Assistant Commissioner of Income-tax, reported in 175 taxmann.com 453, had proceeded to quash the reassessment order passed in terms of Section 147 of the Act on account of grant of sanction by the improper authority. The Hon’ble Madras High Court while quashing the said re-assessment order had held as follows:

“9. A perusal of Section 151(i) would show that, the specified authority for the purpose of issuing notice under Section 148 within a period of three years from the end of the relevant assessment year is, the Principal Commissioner or Principal Director or Commissioner or Director. Further, in terms of provision of Section 149, three year time period is fixed for issuance of 148 notice, in the event of the amount is below 50 lakhs. In the present case, the amount involved is Rs.3,65,09,748/-, which is more than 50 lakhs. 148 notice was issued on 25.07.2022, which is beyond the period of three years. So admittedly, the approval has to be obtained from the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General as defined under Section 151(ii). But, in the present case, the approval was obtained from the Principal Commissioner in terms of Section 151(i) and no approval was obtained before issuance of 148 notice in terms of provision of Section 151(ii), which is mandatory. Therefore, the notice under Section 148 was issued in the present case in violation of provision of Section 151(ii) of the Income Tax Act. In view thereof, the initiation of proceedings itself is without any jurisdiction. Hence, the same is liable to be quashed.”

60.

Thus, respectfully following the decision of the Madras High Court in the case of Core Logistic Company (supra) we hold that the sanction accorded by the authorities prescribed u/s.151(i) of the Act on the facts of the case, i.e. PCIT, Madurai – 1 for the notice issued u/s.148 of the Act dated 19.04.2022 and the order u/s.148A(d) of the Act after the expiry of 3 years from the end of the relevant assessment year as against the correct sanction to have been granted by the authorities prescribed u/s.151(ii) of the Act would vitiate the entire re-assessment proceedings initiated and completed in terms of Section 147 of the Act. The PCIT by assuming revisionary jurisdiction in terms of Section 263

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 9 :: of the Act could not have set aside a non-est re-assessment order and further could not have directed the AO to pass a fresh assessment order.” 5. Similar Co-ordinate Bench and other Benches orders are as under: I. Manish Jagdish Joshi v. CIT(DRP-3) – Income Tax Appellate Tribunal, Mumbai – ITA No. 1617/MUM/2024. II. ACIT-19(1) v. Manish Financial - Income Tax Appellate Tribunal, Mumbai – ITA No. 5055/MUM/2024. III. Keshri Rice Industries v. Circle -1(1), Raipur - Income Tax Appellate Tribunal, Raipur – ITA No. 410/RPR/2024. IV. ACIT -15(3)(2), Mumbai v. Surya Ferrous Alloys Pvt. Ltd. - Income Tax Appellate Tribunal, Mumbai – ITA No. 1406/MUM/2024. V. Mr. Krishnankutty Ramesh v. The ACIT, Non-Corporate Circle-2, Coimbatore- Income Tax Appellate Tribunal, Chennai - ITA No. 1565/CHNY/2024 dated 19.03.2025. VI. Ramu Ponnusamy Murugesan v. Circle- 1(1), Trichy - Income Tax Appellate Tribunal, Chennai - ITA No. 4020/CHNY/2025 & Ors dated 20.03.2025

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 10 :: 6. On the other hand, the Ld. DR submitted that the Assessing Officer (“AO”) had initiated the proceedings by issuing notice under Section 148A(b) of the Act within a period of three years and, therefore, was justified in obtaining the approval of the Principal Commissioner of Income Tax (“PCIT”). In support of the said contention, the Ld. DR placed reliance upon the decision of the Hon’ble Calcutta High Court in Girija Commercial (P) Ltd. v. Union of India, [2024] 169 taxmann.com 168 (Calcutta).

7.

We have heard the rival submissions and carefully perused the material available on record. As regards the legal issue raised by the assessee challenging the validity of the statutory notice issued by the AO under Section 148 of the Act on the ground that the requisite sanction under Section 151 of the Act had not been obtained from the competent authority, we note that the notice under Section 148 was issued on 26.07.2022. It is an undisputed fact that the said notice was issued beyond a period of three years from the end of the relevant assessment year. Consequently, in terms of Section 151 of the Act, the AO was required to obtain the prior approval of the Principal Chief Commissioner of Income Tax (“PCCIT”) before issuance of the notice under Section 148.

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 11 :: 8. In the present case, however, the AO obtained approval from the Principal Commissioner of Income Tax (“PCIT”), Madurai, prior to issuing the notice under Section 148. Accordingly, the approval so obtained was not in conformity with the statutory requirement prescribed under Section 151 of the Act. The notice issued under Section 148, therefore, suffers from a jurisdictional infirmity and is liable to be held invalid in law.

9.

We further note that the contention advanced by the Revenue on this issue has already been considered by the Tribunal in Meganapuram Primary Agricultural Cooperative Credit Society (supra). In the said decision, the Tribunal, inter alia, held that, having regard to the statutory scheme of Section 148A of the Act, the AO is required to obtain the requisite sanction from the competent authority under Section 151 of the Act at the appropriate stage while initiating proceedings under Section 148A. Such sanction constitutes a sine qua non for the valid exercise of jurisdiction at the respective stages contemplated under Section 148A of the Act.

10.

We further observed that accepting the contention of the Ld. DR would effectively defeat the legislative intent underlying the introduction of Section 148A of the Act, which confers upon the assessee an opportunity to explain its case and demonstrate why reassessment proceedings ought not to be initiated before issuance of notice under Section 148 of the Act.

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 12 :: 11. In this context, we also take note of the decisions of the Hon’ble Bombay High Court in Ramesh Bachulal Mehta v. ITO, [2025] 177 taxmann.com 606 (Bombay), and M/s. Vodafone Idea Limited v. DCIT, W.P. No. 2768 of 2022, order dated 06.02.2024, wherein an identical issue was considered. The Hon’ble High Court held that even where notice under Section 148A(b) of the Act has been issued within a period of three years, if the subsequent notice under Section 148 is issued beyond the period of three years, the requisite approval is required to be obtained from the PCCIT in accordance with Section 151(ii) of the Act.

12.

Applying the ratio laid down by the Hon’ble Bombay High Court in Ramesh Bachulal Mehta v. ITO (supra) and M/s. Vodafone Idea Limited v. DCIT (supra), we find that, in the assessee’s case, the impugned notice under Section 148 was issued on 26.07.2022, which is admittedly beyond three years from the end of the relevant assessment year. We further find that the approval preceding the issuance of the said notice was obtained from the PCIT, Madurai, and not from the PCCIT. The relevant extract of the notice under Section 148 is reproduced below:

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 13 ::

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 14 ::

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 15 ::

13.

In view of the aforesaid facts and circumstances, we are of the considered view that, before issuance of the notice under Section 148 of the Act, the AO was statutorily required to obtain the prior approval of the PCCIT in terms of Section 151(ii) of the Act. Accordingly, respectfully following the judicial precedents referred to hereinabove, we hold that the reassessment notice issued by the AO under Section 148 for Assessment Year 2016–17 on 26.07.2022, beyond the period of three years from the end of the relevant assessment year, with the approval of the PCIT instead of the PCCIT, is not sustainable in law and is accordingly invalid.

14.

Consequently, the reassessment proceedings and the assessment order arising therefrom, being founded upon the aforesaid invalid notice, cannot be sustained in law and are liable to be quashed. Accordingly, the assessment proceedings are hereby quashed.

15.

Since the assessee’s appeal stands allowed on the aforesaid legal ground, the remaining grounds of appeal have become academic in nature. Accordingly, the same are not adjudicated upon.

ITA No. 1581/Chny/2026 (AY 2016-17) Karthik VR Thondaiman Vs ITO W-1 :: 16 :: 16. In the result, the appeal filed by the assessee is allowed. Order pronounced on the 10th day of September, 2026, in Chennai.

Sd/- Sd/- (एस. आर. रघुनाथा) (मनु कुमार िग�र) (S.R.RAGHUNATHA) (MANU KUMAR GIRI) लेखा सद*य/ACCOUNTANT MEMBER �या�यक सद*य/JUDICIAL MEMBER चे�नई/Chennai, +दनांक/Dated: 10th September 2026 SNDP, Sr. PS आदेश क ��त,ल-प अ.े-षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF SANDE Digitally signed by EP SANDEEP KUMAR KUMA Date: 2026.09.17 R 12:08:26 +05'30'

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