ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. IMPERIAL SPIRITS PRIVATE LIMITED, PALAKKAD

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ITA 3612/CHNY/2025Status: DisposedITAT Chennai09 June 2026AY 2014-1517 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that sales promotion expenses were incurred wholly and exclusively for business purposes and are allowable. It further held that for Section 41(1) to apply, there must be a clear remission or cessation of liability, which was not demonstrated in this case as the liabilities continued to be acknowledged in the books.

What were the facts?

The Revenue appealed against the CIT(A)'s order deleting additions made under Section 41(1) (cessation of liability) and disallowing interest expenses. The assessee filed cross-objections challenging the confirmation of disallowance of sales promotion expenses.

What were the issues?

Whether sales promotion expenses are deductible and whether outstanding liabilities constitute cessation of liability under Section 41(1) when they are still acknowledged in the books.

Which sections of the Income-tax Act were involved?

Section 41(1),Section 36(1)(iii),Section 37(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI SS VISWANETHRA RAVI & MS. PADMAVATHY.S&

For Respondent: Mr. L.Christopher Vasanth, JCIT

आदेश / O R D E R

PER PADMAVATHY.S, A.M: This appeal by the Revenue and the Cross Objections (COs) by the assessee against the order of the Commissioner of Income Tax, Appeal, Chennai-20 (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 12.09.2025 for Assessment Year (AY) 2014-15.

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2.

The grounds of appeal of the Revenue are as under: “1. The Order of the learned Commissioner of Income Tax (Appeals) is erroneous on facts and in law.

2.

The Ld. CIT(A) erred in deleting the addition made by the AO of Rs. 12,01, 055/- & Rs. 2,40,00, 000/- for AY 2014-15 on account of cessation of liability w/s 41(1) of the Act & disallowance of interest expenses claimed respectively.

3 The Ld.CIT(A) ered in failing to note that the liabilities in question had been outstanding for a long period and were not paid within the year under consideration & Section 41(1) mandates that any liability which is written off or no longer required to be paid in the normal course is to be treated as income.

4.

The Ld. CIT(A) erred in failing to note that during the course of assessment, at the hearing held on 05.12.2016, the assessee's authorized representative has agreed to these old creditors as credits no longer required to pay, which the Assessing Officer has recorded in paragraph no. 3 of the assessment order.

5.

The Ld.CIT(A) erred in failing to take cognizance of the fact that merely because the assessee had large reserves does not negate the proposition that borrowed funds, which carry explicit interest liability, were utilized in providing interest-bearing advances, drawing proportionate disallowance under section 36(1)(ii) when the assessee failed to prove to the contrary

6.

The order of the Ld. CiT(A) is not acceptable for reliance on the decision of the Hon 'ble Supreme Court in CIT V. Reliance Industries Ltd. [2019] 410 /TR 466 (SC) as being misplaced because in the referred case. the issue pertained to interest-free funds being adequate to cover the investments whereas in the present case, substantial borowed funds with explicit interest liability were actually advanced, creating a clear nexus between borrowing and expenditure.

7.

For these grounds and any other ground including amendment of grounds that may be raised during the cOurse of appeal proceedings, the Order of the Ld CIT (Appeals) may be set aside and that of the Assessing Officer may be restored.”

3.

The Cross objections of the assessee are as under: “The Respondent above named respectfully submits the following Cross Objections against the appeal filed by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals) dated 12.09.2025 passed u/s 250 of the Income-tax Act, 1961.

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I. REGARDING DISALLOWANCE OF SALES PROMOTION EXPENSES

1.

The Ld. CIT(A) erred in confirming the disallowance of Sales Promotion Expenses to the extent of Rs. 33,98,524 by erroneously concluding that such expenses were not for business purposes.

2.

The Learned CIT(A) failed to appreciate that the Respondent, being engaged in the business of manufacture and sale of Indian Made Foreign Liquor (IMFL), is required to undertake extensive brand promotion and market development activities to maintain brand visibility and market presence in a highly regulated and competitive industry. 3. The Learned CIT(A) failed to properly appreciate that the impugned payments were made to specialized agencies, including M/s Vintage Spirits, pursuant to valid service agreements for carrying out market surveys, brand promotion and related marketing activities.

3.

The Ld. Authorities failed to consider that the Respondent has duly deducted TDS u/s 194C on these payments and all transactions were routed through banking channels, proving the genuineness of the expenditure.

4.

The Learned CIT(A) ought to have appreciated that the expenditure claimed by the assessee was incurred wholly and exclusively for the purpose of business and therefore allowable under section 37(1) of the Income-tax Act.

5.

The reliance placed by the Learned CIT(A) on the decision in the case of Premier Breweries Ltd. is misplaced and distinguishable on facts. In the present case, the promotional activities are aimed at generating consumer demand ("pull demand"), which ultimately drives procurement by the Government marketing corporation (KSBC), a practice widely prevalent in the liquor industry.

6.

The Learned CIT(A) further failed to appreciate that the Assessing Officer had made the disallowance merely on assumptions and surmises without bringing any material evidence on record to establish that the expenditure was either not genuine or not incurred for the purposes of business.

II. REGARDING ADDITION U/S 41(1) - CESSATION OF LIABILITY

7.

The Ld. CIT(A) erred both in law and on facts in confirming the addition of Rs. 62,64,582 u/s 41(1) by treating the following trade payables as "ceased liabilities":

M/s Armour Steel Buildings India Pvt Ltd: Rs. 5,53,937/- Light House Advisors India P Ltd: Rs. 45,09,590/- Mr. T.K. Kannan: Rs. 5,50,356/-

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Vintage Spirits: Rs. 6,50,699/-

8.

The Ld. CIT(A) failed to appreciate that for Section 41(1) to apply, there must be a "remission or cessation" of liability during the previous year. In the present case, the Respondent continues to reflect these amounts as "Liabilities" in its audited Balance Sheet, which constitutes a continuous acknowledgment of debt as per Section 18 of the Limitation Act.

9.

The Ld. CIT(A) failed to recognize that a liability does not cease to exist merely because it is outstanding for more than three years. The Assessing Officer failed to produce any evidence that the creditors have waived their claims or that the Respondent has written back these amounts to the Profit & Loss Account. In the absence of any remission or cessation of liability during the relevant year, the addition made under section 41(1) is wholly unsustainable in law and liable to be deleted.

III. SUPPORTING THE DELETION OF INTEREST DISALLOWANCE U/S 36(1)(iii)

10.

The Cross Objector submits that the Learned CIT(A) was fully justified in granting relief to the Respondent in respect of the issue relating to availability of sufficient interest-free funds, and therefore the finding of the Learned CIT(A) on this issue deserves to be upheld.

11.

The Respondent strongly supports the Ld. CIT(A)'s finding that no disallowance u/s 36(1)(iii) is warranted. The Ld. CIT(A) correctly observed that the Respondent possessed sufficient interest-free own funds (Share Capital and Reserves) amounting to Rs. 70.97 Crores as against the advances to related parties of only Rs. 13.63 Crores.

12.

The Ld. CIT(A) correctly applied the settled legal proposition laid down by the Hon'ble Supreme Court in CIT v. Reliance Industries Ltd. (410 ITR 466) which holds that if interest-free funds are greater than the investment/advances, the presumption is that the advances were made out of such interest-free funds.

13.

The Department's ground that "substantial borrowed funds with explicit interest liability were actually advanced" is purely hypothetical and lacks any direct nexus or "one-to-one" correlation between the interest-bearing loans and the interest-free advances.

IV. GENERAL GROUNDS 14. In view of the above facts and circumstances, the Cross Objector humbly prays that the disallowances sustained by the Learned CIT(A) on the first two

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issues may kindly be deleted, while the relief granted by the Learned CIT(A) in respect of the interest disallowance under section 36(1)(iii) be upheld. 15. The Cross Objector craves leave to add, amend, or alter any of the above grounds during the course of the hearing.”

4.

The assessee is a company and filed the return of income for AY 2014- 15 on 11.04.2015 declaring total loss of Rs.1,52,42,249/-. The case was selected for scrutiny and the statutory notices were duly served on the assessee. The A.O made a disallowance of Rs.33,98,524/- towards sales promotion expenses on the ground that the assessee is supplying goods only to M/s. Kerala State Beverages Corporation which does not require an expense for promoting its products. The A.O also made an addition u/s. 41(1) of the Act towards the following outstanding balances of sundry creditors: a) M/s. Light House Advisors India Pvt. Ltd. – Rs. 45,09,590/-. b) M/s. Armour Steel Building India Pvt. Ltd. – Rs. 5,53,937/-. c) Shri T.K. Kannan – Rs. 5,50,356/-. d) Vintage Spirits – Rs. 6,50,699/-;

5.

The A.O also disallowed interest on borrowed funds to the tune of Rs.2.40 Crorers and made addition towards long term capital gains (LTCG) of Rs.3,36,126/-. Aggrieved, the assessee filed further appeal before the CIT(A). The CIT(A) gave partial relief to the assessee by deleting the addition made u/s.41(1) of the Act towards Shri TK Kannan and Vintage Spirits and also by deleting the disallowance made u/s. 36(1)(iii) of the Act towards interest by placing reliance on the decision of Hon'ble Supreme Court in the case of CIT vs. Reliance Industries Ltd. [2019] 410 ITR 466 (SC). The Revenue is in appeal and the assessee has raised cross objections before the Tribunal against the order of the CIT(A).

Revenue's Appeal - Deletion of disallowance made u/s. 41(1) of the Act:

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(i) TK Kannan: 6. We have heard the parties, and perused the material available on record. From the perusal of the findings of the CIT(A), we notice that the CIT(A) has deleted the addition based on the factual findings that the amount outstanding as of 31.03.2014 is settled by the assessee on 02.04.2014. In this regard, the Ld. AR during the course of hearing drew our attention to the bank statement (Page 45) that findings of the CIT(A) is substantiated by the entries in the bank statement. The relevant statement is extracted hereunder:

7.

Further, we have perused the ledger account of the impugned party and find that the above payment is reflected in the accounts of the assessee. Considering this factual position, we are of the view that the addition made by the AO is not sustainable and therefore, we hold that there is no infirmity in the decision of the CIT(A).

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(ii) Vintage Spirits: 8. We have heard the parties, and perused the material available on record. We notice that the CIT(A) has given relief to the assessee based on the ledger entries of the subsequent financial year where the assessee has made payments to the impugned party. Further, the ld. AR drew our attention to the ledger account of vintage spirits for the year under consideration from the perusal of which, we notice that the balance outstanding is arising out of the running account with the said parties. The relevant extract of ledger is as under:

9.

We notice in this regard that the A.O while making the addition u/s. 41(1) of the Act has recorded a general finding that the balances are pertaining to old creditors without factually examining the ledger accounts

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and without verifying the fact that the assessee is having running account with the said party. We further notice that the CIT(A) has deleted the disallowance on the ground that the sales promotion expenses are already disallowed and making an addition under section 41(1) would amount to double addition. We are unable to agree with the deletion of addition on the said ground since from the perusal of the ledger accounts and other documentary evidences it is clear that there is no cessation of liability towards this party and that the assessee is having running account where the payments are made towards the liability. Accordingly, we hold that the AO is not correct in making the addition under section 41(1) on the ground that this part is an old creditor and for the reasons as given above we uphold the action of the CIT(A) in deleting the addition made u/s. 41(1) of the Act.

Interest disallowance u/s. 36(1)(iii) of the Act: 10. The A.O held that interest paid by the assessee to the tune of Rs.6.86 crores cannot be fully allowed for the reason that the assessee has borrowed Rs. 41.45 Crores out of which Rs.14.84 Crores was advances to related parties without interest. The AO accordingly disallowed the proportionate interest amounting to Rs.2.40 crores. The CIT(A) deleted the disallowance by holding that: 7.3.1. This ground pertains to the disallowance of interest expenses of Rs.2,40,00,000/-. During the assessment proceedings, the AO had noticed that the appellant had borrowed 41.45 crores, out of which Rs.14.84 crores was advanced to related parties. Therefore, out of the total interest expenses of Rs.6.86 crores, the AO disallowed the proportional interest expenses of Rs.2,40,00,000/-. 7.3.2. During the appeal proceedings, the appellant has submitted that it had borrowed Rs.4,36,32,504/- from its related parties and had advanced Rs.13,63,17,813/- to related parties as at the year end. The appellant has also submitted that out of the total advances of Rs.13,63,17,813/-, an amount of Rs.5,22,59,667/- was given to subsidiary M/s Imperial Spirits

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and Wines Pvt Ltd for business expediency, which is an allowable advance in the course of commercial expediency. Further, the appellant has submitted that it had reserves/surplus of Rs.30,72,80,794/- and had share capital of around Rs.40,24,21,295/- for the year under consideration. Thus, the appellant has contended that the loan was advanced out of the appellant’s own funds of Rs.70,97,02,089/-. The appellant has further submitted that the impugned advance has been made out of interest free funds available with the appellant and there was no question of disallowing interest u/s 36(1)(iii) of the Act. Furthermore, the appellant has submitted that loans and advances to related parties for the preceding year was Rs.9,09,34,271/- and the same had reduced to Rs.4,36,32,509/- for the year under consideration.

7.3.3. I have perused the assessment order and the submissions made by the appellant in the appeal proceedings. On perusal of the assessment order, it is seen that the AO has made a very cryptic addition without justifying how the borrowed funds have been diverted to the related parties. The AO has not shown any corelation between the borrowed funds and the amount advanced to the related parties, especially when the appellant had own funds of around Rs.70 crores. On perusal of the balance sheet for the year under consideration, it is noted that the appellant had reserves/surplus of Rs.30,72,80,794/- and share capital of around Rs.40,24,21,295/-. Meaning thereby, the availability of interest free funds for the year under consideration is Rs.70,97,02,089/-, whereas the loan advanced to the related parties was only Rs.13,63,17,813/-. It is a settled principle that a presumption would arise that the investment would be out of the interest free funds generated or available with the company. In this regard, it is observed that this exact issue came before the Hon’ble Supreme Court in the case of CIT v. Reliance Industries Ltd. [2019] 410 ITR 466 (SC), wherein it was held as under:

6.

The appeals by the Revenue raise the following questions: 1. Whether the High Court is correct in holding that interest amount being interest referable to funds given to subsidiaries is allowable as deduction under Section 36(1)(iii) of the Income Tax Act, 1961 (for short 'the Act') when the interest would not have been payable to banks, if funds were not provided to subsidiaries; ……. 7. Insofar as the first question is concerned, the issue raises a pure question of fact. The High Court has noted the finding of the Tribunal that the interest free funds available to the assessee were sufficient to meet its investment. Hence, it could be presumed that the investments were made from the interest free funds available with the assessee. The Tribunal has also followed its own order for Assessment Year 2002-03.

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8.

In view of the above findings, we find no reason to interfere with the judgment of the High Court in regard to the first question. Accordingly, the appeals are dismissed in regard to the first question. As per the above decision, when there is sufficient interest free funds available with an assessee, that will be sufficient to meet the investment made to its subsidiaries/related parties and no disallowance u/s 36(1)(iii) of the Act is warranted. In the present case, the appellant had sufficient own funds to the tune of Rs.70,97,02,089/- and the advances to the related parties were only Rs.13,63,17,813/-. Therefore, following the ratio of the Hon’ble Supreme Court in the case of Reliance Industries Ltd. (supra), it is held that the loan advance to the related parties has to be considered to be out of own funds and no disallowance of interest expenses is called for. Accordingly, the AO is directed to delete the disallowance of Rs.2,40,00,000/- and this ground of appeal is allowed.”

11.

The Ld. DR in this regard submitted that the relief given by the CIT(A) is based on the decision of the Hon'ble Supreme Court which is distinguishable since in the said decision the relief was given towards investments made whereas in the present case the assessee has extended advances. Accordingly, the Ld. DR submitted that the CIT(A) is not correct in deleting the disallowance.

12.

The Ld. Authorized Representative (AR) of the assessee, on the other hand, submitted that the assessee has sufficient own funds and therefore no disallowance u/s. 36(1)(iii) is warranted.

13.

We have heard the parties, and perused the material available on record. From the perusal of the financial of the assessee (page 56 of paper book), we notice that the assessee is having own funds to the tune of Rs. 70,97,02,089/- and that the assessee has advanced loans to related parties to the tune of Rs. 13,63,17,813/-. The Hon'ble Supreme Court in the case of Reliance Industries (supra) has laid down the ratio that own funds are available to meet its investment in subsidiaries no disallowance u/s. 36(1)(iii)

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is warranted. In our considered view the said ratio is applicable to assessee's case also since the assessee has advanced loans to related parties and that the assessee's own funds are more than the amount advanced to related parties. Accordingly, we hold that there is no infirmity in order of the CIT(A) in deleting the disallowance u/s. 36(1)(iii) of the Act.

Assessee's C.O - Sales Promotion Expenses: 14. The Ld. AR submitted that the only ground on which the sales promotion expenses is disallowed is that the assessee-company is supplying goods only to M/s. Kerala State Beverages Corporation (KSBC) which is Govt. body and therefore the assessee is not required to spend any amount for promoting its products or to procure orders for supply of liquor. The Ld. AR in this regard drew our attention to the copy of agreement entered into with the party with whom the assessee has entered into the marketing agreement to argue that the agreement clearly specify the nature of service to be rendered by the marketing agent. The Ld. AR further drew our attention to the annexure to the agreement (page 10 of paper book) where the products to be promoted by the market agent and the invoices raised by the marketing agent to submit that the sales promotion expenses paid specifically towards products promoted and based on the rates agreed as per the agreement. Accordingly, the Ld. AR argued that the contention that there is no agreement for sales promotion expenses merely because the assessee is supplying to a Govt. agent cannot be sustained. The Ld. AR in this regard relied on the decision of the Coordinate Bench in the case of DCIT vs. M/s.Empee Breweries Ltd., (I.T.A. Nos. 2647, 2648 and 2649/Mds/2014 dated 25.03.2015) where it is held that –

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36.

The Assessing Officer has raised a preliminary objection that the expenditure incurred by the assessee is not required because he assessee is supplying its products to TASMAC. We find that the Assessing Officer has failed to understand that the assessee is not alone supplying its products to TASMAC, there are several producers also supplying the very same goods to TASMAC. Therefore, it is the business necessity of the assessee to take care of the sales promotion of its products. It appears that the very same Assessing Officer has allowed similar kind of expenditure in the case of Empee Distilleries Ltd., a sister concern of the assessee. Therefore, denying the sales promotion claim of the assessee on the ground that it is not for the purpose of business is no correct and justified. The Assessing Officer has accepted the agreement in so far as del credre commission is concerned, but in the very same agreement, not accepting for the purpose of sales promotion expenses is not justified having the assessee submitted all details before the Assessing Officer.

15.

The Ld. DR on the other hand argued that the assessee has not submitted any supporting evidence to substantiate that the services as mentioned in the agreement are indeed rendered by the marketing agent. Accordingly the ld DR supported the orders of the lower authorities.

16.

We have heard the parties, and perused the material available on record. From the perusal of the order of the CIT(A) we notice that the CIT(A) has held the impugned payments to be in the nature of commission and has also held the same to be non-genuine on the ground that the amount as reflected in the party account is less than the amount claimed by the assessee as a deduction (refer para 7.1.4 from page 7 & 8 of CIT(A) order). The CIT(A) has also placed reliance on the decision of the Hon'ble Kerala High Court in the case of CIT vs. Premier Breweries Ltd [(2005) 279 ITR 51 (Kerala)]. On perusal of the said decision we notice that the Hon'ble High Court has upheld the disallowance after recording findings facts peculiar to the said case and therefore in our view the same cannot be applied without

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establishing that the facts in assessee's case are identical. We notice from the perusal of the clauses in the agreement that the marketing agent is required render certain specific services towards sales promotion and the annexure to the agreement contains the list of products to be promoted. The invoices raised by the marketing agent also supports the contention that the sales promotion charges are paid towards the same products as mentioned in the agreement at the rates as agreed. Further, the disallowance only based on the reason that the assessee is supplying to the KSBC cannot be accepted since the allowability of expenditure under section 37(1) cannot be determined on the basis of the identity of the customer alone. It is submitted by the ld AR that in the liquor industry, sales promotion and brand-building activities play a significant role in sustaining market demand, strengthening consumer preference and enhancing the visibility and acceptability of products in a highly competitive market. It is further submitted that the assessee's business ultimately depends upon consumer demand and market recognition of its brands, and expenditure incurred towards promotion of such products cannot be regarded as unrelated to its business merely because the sales are routed through Government-controlled procurement or distribution channels. It is a well settled proposition that the test to be applied is whether the expenditure was incurred on grounds of commercial expediency and whether it bears a nexus with the assessee's business. Once the expenditure is incurred for promoting the assessee's products, maintaining market presence and augmenting business prospects, its deductibility cannot be denied merely on the premise that Government agencies do not require sales promotion without bringing any factual finding on record on that count. Further in our view, questioning genuineness merely for the difference in the amount claimed without considering the other evidences is not tenable. In view of these

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discussion and considering the facts pertaining to the impugned issue we are of the view that the sales promotion expenditure, having been incurred wholly and exclusively for the purposes of the assessee's business, is allowable as a deduction. The AO is directed to delete the disallowance made in this regard. Disallowance u/s. 41(1) of the Act sustained by the CIT(A): 17. We have heard the parties, and perused the material available on record. The Ld. AR drew our attention to the ledger account of M/s. Light house Advisors India Pvt. Ltd., for the year under consideration which is extracted below;

18.

The Ld. AR further submitted that the CIT(A) has sustained the addition made by A.O based on the entries passed during the FY 2017-18 where the assessee has transferred the outstanding balances to another party

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through journal entry. The Ld. AR argued that as of 31.03.2014 the liability has not seized to exist and the ledger extract substantiates the fact that the assessee is having a running account with the party. The ld. AR also argued that subsequent settlement of balance otherwise than by actual payment cannot be construed as cession of liability.

19.

With regard to M/s. Armour Steel Building India Pvt. Ltd., the Ld. AR submitted that as per the ledger account as extracted herein below, the assessee has made payment to the said parties during the year under consideration and therefore there is no question of cession of liability towards this party:

20.

The Ld. Departmental Representative (DR), on the other hand, submitted that the A.O has made the addition based on the submissions of the assessee admitting to the said addition.

21.

We have heard the parties, and perused the material available on record. From the perusal of the above ledger accounts it is clear that the assessee is having a regular transaction with the party and that the assessee is also making payments to the party. For invoking the deeming income of 41(1) of the Act the Revenue must demonstrate that the liability, in respect of which deduction had been allowed in an earlier year, stood remitted or ceased during

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the relevant previous year and that the assessee derived a corresponding benefit. In our view so long as the liability continues to be acknowledged in the books and there is no evidence of waiver, settlement, write-back, or extinguishment in law, no income can be brought to tax under section 41(1). In the present case as already stated, the assessee has acknowledged the liability of both the parties as of 31.03.2014 in the books of accounts and the AO/CIT(A) has not brought on record to demonstrate that there is a cessation for the year under consideration. In our view, the settlement of the liability in subsequent AY i.e. in AY 2017-18, otherwise than by payments cannot be construed as cessation of liability for the year under consideration. Further we are unable to accept the argument that the assessee has agreed for the addition under section 41(1), when it is clearly substantiated by the assessee that transactions are entered into with these parties in regular course and that the assessee has been making payments to these parties. In view of these discussions, we are of the view that the lower authorities are not correct in treating the outstanding balance from M/s. Light house Advisors India Pvt. Ltd., and M/s. Armour Steel Building India Pvt. Ltd., as income under section 41(1) of the Act. 22. In result the appeal of the revenue is dismissed and the cross objections of the assessee are allowed. Order pronounced on 09th day of June, 2026 at Chennai.

Sd/- Sd/- (यस यस िव�ने� रिव) (पदमावती यस) (SS Viswanethra Ravi) (Padmavathy.S) �याियक �याियक सद�य �याियक �याियक सद�य सद�य / Judicial Member सद�य लेखा लेखा सद�य लेखा लेखा सद�य सद�य /Accountant Member सद�य चे�नई/Chennai, �दनांक/Dated: 09th June, 2026. EDN, Sr. P.S

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आदेश क� �ितिल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकर आयु!/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF Digitally signed by EJTADA DURGA EJTADA DURGA NARESH NARESH Date: 2026.06.11 17:32:11 +05'30'

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