AYODHYA FLOUR MILLS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-1(3), CHENNAI

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ITA 3703/CHNY/2025Status: DisposedITAT Chennai02 July 2026AY 2014-1514 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had discharged its primary burden by providing documentary evidence for the share transaction. The Revenue failed to rebut this evidence with positive material.

What were the facts?

The assessee sold shares for Rs. 1.20 crores, which the AO treated as unexplained income from other sources. The CIT(A) upheld this addition, stating the assessee failed to prove the genuineness of the transaction.

What were the issues?

Whether the addition of Rs. 1.20 crores as unexplained income was justified when the assessee provided documentary evidence for the share transaction and the Revenue failed to rebut it.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 144B,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, CHENNAI

Before: SHRI ABY T VARKEY & SHRI S. R. RAGHUNATHA

Hearing: 10.06Pronounced: 02.07.2026

आयकर अपीलीय अधिकरण, ‘बी’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI श्री एबी टी वर्की, न्याययर्क सदस्य एवं श्री एस. आर. रघुनाथा, लेखा सदस्य के समक्ष BEFORE SHRI ABY T VARKEY, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.3703/Chny/2025 निर्धारण वर्ा / Assessment Year: 2014-15 Ayodhya Flour Mills Pvt.Ltd. The Income Tax Officer 3/11, Seshachala vs. Corporate Ward 1(3) Gramini Garden Street Chennai. Sathangadu, Chennai – 600 119 [PAN: AAACV2495B] (प्रत्यर्थी/Respondent) (अपीलधर्थी/Appellant) अपीलधर्थी की ओर से/Appellant by : Shri. Vikram Vijaya Raghavan, Advocate प्रत्यर्थी की ओर से/Respondent by : Shri. E.Elango, JCIT सुिवधई की तधरीख/Date of Hearing : 10.06. 2026 घोर्णध की तधरीख/Date of Pronouncement : 02.07.2026 आदेश /O R D E R PER S. R. RAGHUNATHA, AM : The present appeal has been preferred by the assessee against the order dated 3.11.2025 passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “the Ld. CIT(A)”], arising from the assessment order dated 23.12.2019 passed by the Income Tax Officer, Corporate Ward 1(3) Chennai [hereinafter referred to as “the AO”], u/s.147 r.w.s. 143(3) r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the Assessment Year 2014-15. 2. The grounds of appeal raised by the assessee are as follows: 1. The Order of the CIT (Appeals)-NFAC is contrary to law and facts of the case.

:-2-: ITA. No:3703/Chny/2025

2.

The CIT(Appeals) erred in upholding the reopening of the assessment, despite the fact that the original return was only processed under section 143(1), and the reopening was based solely on the report of the DDIT (Inv.), Kolkata without any independent application of mind. 3. The CIT(Appeals) erred in confirming the addition of ₹1,20,00,000/- as "Income from Other Sources", without properly appreciating the evidences demonstrating that the purchase and sale of shares of Gallant Udyog Ltd. were genuine and duly supported by documents. 4. The CIT(Appeals) failed to appreciate that the Appellant had sufficient available bank balance on the date of purchase of shares, and the entire payment of 1.20 crores was made through normal banking channels from accounted funds. 5. The CIT(Appeals) failed to consider that the allotment of shares by Gallant Udyog Ltd. and the subsequent sale of the same shares to Mrigaya Trade Link Pvt. Ltd. were duly recorded in the statutory filings of the respective companies and reflected in their financial statements. 6. The CIT(Appeals) erred in disregarding the fact that the transactions were properly accounted for, audited by statutory auditors, and supported by contract notes, bank statements, share allotment details, and ROC filings. 7. The CIT(Appeals) failed to appreciate that the Ld. AO had issued a reference to ITO Ward 4(2), Kolkata for cross-verification, but without waiting for the verification report, the AO concluded incorrectly and prematurely-that the sum of 1.20 crores represented accommodation entries. 8. The CIT(Appeals) misapplied the decision of the Hon'ble Supreme Court in PCIT v. NRA Iron & Steel (P) Ltd., which is not applicable to the Appellant's case where both the source of investment and the identity of the counterparties are fully evidenced, and the transactions are duly routed through banking channels. 9. Without prejudice, the CIT(A) ought to have appreciated that in any event, the Appellant paid through Banking Channels Rs.1.20 crores and showed it as investment; further they received the same amount through Banking channels confirmed by the payer in lieu of investment. Thus, there is no question of any amount being treated as unexplained income. 10. For all the above grounds, and such other grounds as may be urged at time of hearing, Appellant prays the additions be deleted & appropriate relief be granted.

3.

The brief facts of the case emanating from the records are that the assessee is a company, filed its original return of income for A.Y.2014-15 on 29.11.2014, declaring total income of Rs.57,09,850/-. The return was

:-3-: ITA. No:3703/Chny/2025 processed u/s.143(1) of the Act and later scrutinized u/s.143(3) of the Act, with the assessment completed on 04.03.2016 accepting the returned income.

4.

With the specific information was received from the DDIT(Inv.), Kolkata, indicating that the assessee had received Rs.1,20,00,000/- from M/s.Mrigaya Tradelink Pvt. Ltd. as an accommodation entry, disguised as proceeds from the sale of shares in M/s.Gallant Udyog Ltd. Accordingly, the case was reopened u/s.147 of the Act after recording reasons and obtaining approval from the competent authority. Notice u/s.148 was issued on 28.03.2019. During reassessment, the assessee claimed the amount represented sale proceeds of 1,00,000 shares of Gallant Udyog Ltd. (purchased in F.Y. 2012-13 at Rs. 120 per share, i.e., face value Rs. 10 + premium Rs. 110) sold to Mrigaya Tradelink Pvt. Ltd. in F.Y. 2013-14 at cost (no gain/loss). The AO examined the bank statements, which revealed layered transactions indicative of accommodation entries. A reference was made to the ITO, Ward 4(2), Kolkata, for verification, but without awaiting the report (due to time constraints), the AO concluded the transaction lacked genuineness and added Rs.1,20,00,000/- as income from other sources u/s.69A of the Act.

5.

On appeal by the assessee, the Id.CIT(A) dismissed the appeal, holding that the assessee failed to prove the identity, creditworthiness, and genuineness of the transaction, relying on Hon’ble Supreme Court decisions in PCIT vs. NRA Iron & Steel (P) Ltd. [2019] 103 taxmann.com 48 (SC) and PCIT vs. NR Portfolio (P) Ltd. (as confirmed by SC).

6.

Aggrieved by the order of the ld.CIT(A), the assessee filed the present appeal before us.

The ld.AR for the assessee assailing the action of the ld.CIT(A) in confirming the addition, submitted that the assessee had furnished all the details available with them to prove the transactions are genuine and made through the banking

:-4-: ITA. No:3703/Chny/2025 channel. The ld.AR explained the transactions with the following supporting documents as detailed below:

- During the financial year 2012-13, the assessee acquired 100,000 shares of M/s.Gallant Udyog Ltd. (Hereinafter called “Company”) @ Rs.120/ per share through Rights Issue offered by the Company as per the provisions of Section 81(1A) of the Companies Act, 1956. Confirmation from the Company in this regard is enclosed in Annexure “A”. The payment for this is evidenced from the Bank entries dated 11.03.2013 vide Cheque Nos. 239143, 239144 & 239145. Extract of Bank Statement for the relevant date enclosed in Annexure “B”.

- The following are the sources of funds for the above acquisition: Date Amount in Rs. Name of the party Nature of source 04.03.2013 69,97,511 Suryavanshi Spinning Sale of finished goods Mills Pvt. Ltd. 11.03.2013 15,39,000 Devashree Cotsyn Pvt. Sale of machineries Ltd. 11.03.2013 80,67,554 Gallant Udyog Ltd. Repayment of loan given along with interest - Prior to the above transaction, the assessee in April 2012, extended financial assistance of Rs.75 lakhs to the Company vide Cheque No.019931 dt. 03.04.2012 @ 9% interest per annum. Extract from Bank Statement enclosed in Annexure “C”. The Company has since repaid the loan in March 2013 along with interest. The receipt of interest (Rs.630,616/-) has been included in the total income of the assessee & offered to tax in the A.Y.2013-14. Relevant extract of P & L Account evidencing the interest receipt is enclosed in Annexure “D”. Further, the Company deducted tax at source u/s.194A of the Act @ 10% (Rs.63,016/-). Copy of 26AS statement of the assessee for the A.Y. 2013- 14 is enclosed in Annexure “E”. - In June 2013, the assessee sold the entire 100,000 shares of the Company to M/s.Mrigaya Trade Link Pvt. Ltd. which is an unrelated party at the same price of Rs.120/- per share. Confirmation from the Company in this regard is enclosed in Annexure “F”. Receipt of sale proceeds is evidenced from the following entries in the Bank statement: Date Amount in Rs. 05.06.2013 20,00,000 06.06.2013 40,00,000 06.06.2013 40,00,000 10.06.2013 20,00,000 120,00,000

:-5-: ITA. No:3703/Chny/2025 Date Amount in Rs. Cheque No. 06.06.2013 50,00,000 239206 06.06.2013 20,00,000 239205 10.06.2013 30,00,000 230208 11.06.2013 20,00,000 230207 Total 120,00,000 Bank statement showing the above entries enclosed in Annexure “G”. - The Company has since repaid the said loan to the assessee on 22.07.2013. Bank statement showing the credit entry for this is enclosed in Annexure “H”. The assessee earned an interest income of Rs.206,740/- on this amount which has been offered to tax in the A.Y.2014-15. Relevant extract of P & L Account and 26AS statement for the A.Y. 2014-15 are enclosed in Annexure “D” and Annexure “I” respectively. The assessee received a confirmation letter ( Annexure “J”) from the Company for having taken and repaid the loan from the assessee.

7.

The ld.AR further filed a paper book of 115 pages containing the certificate of incorporation of Mrigaya Tradelinks pvt ltd., its Memorandum and Articles of association, later annual return filed with ROC, Kolkata, Annual report for the relevant financial year 2013-14, Income tax return in ITR 6 – A.Y. 2014- 15, resolution proposing merger of the company, Hon’ble Calcutta High Court order sanctioning merger and Bank statement showing the payment made for purchase of shares. Further the ld.AR submitted that the assessee has proved with all the required documents to establish that the transactions are genuine and not the accommodation entry as alleged by the revenue. The company Mrigaya Tradelinks pvt ltd. was amalgamated with Camellia Tradelink Private limited as approved by the Hon’ble Calcutta High Court with effect from 01.04.2015 (Page No.83 – 85 of the Paper book).

8.

In view of the above, the ld.AR submitted that the assessee has submitted the entire trail of the transactions and also proved that all the transactions are made through the bank channel as explained above and hence the action of the authorities in making the addition under the head ‘income from other sources’ is erroneous and prayed for deleting the same.

:-6-: ITA. No:3703/Chny/2025 9. Per contra the ld.DR for the revenue submitted that the orders of the AO and ld.CIT(A) are well-reasoned, based on material evidence, and in accordance with law. The appeal deserves to be dismissed. The ld.AR addressed each ground raised by the assessee as under: Ground I: The Order of the CIT(Appeals)-NFAC is contrary to law and facts of the case.

10.

This is a general ground. The ld. CIT(A) has meticulously considered the facts, submissions, and applicable law. The addition is based on cogent evidence of non- genuine transactions, and no error in law or fact is apparent. This ground is liable to be rejected.

Ground 2: The CIT(Appeals) erred in upholding the reopening of the assessment, despite the fact that the original return was only processed under section 143(1), and the reopening was based solely on the report of the DDIT (Inv.), Kolkata without any independent application of mind.

a. The original assessment was completed u/s.143(3) on 04.03.2016 (not merely processed u/s.143(1) as claimed). Reopening u/s.147 is permissible if income has escaped assessment, even post-scrutiny, based on tangible material [Explanation 2 to s. 147].

b. The reasons for reopening were based on specific information from DDIT (Inv.), Kolkata, indicating accommodation entries. The AO applied independent mind, as evident from the recorded reasons provided to the Appellant on 06.06.2019. Mere reliance on investigation wing information is valid if it has a live link to escaped income

c. The Hon'ble Delhi High Court in CIT vs. Spirit Global Construction (P.) Ltd. [2023] 153 taxmann.com 641 (Delhi) (relied upon by Appellant) is distinguishable, as here the information was specific and not mechanical. The SLP dismissal by SC in that case does not aid the Appellant, as facts differ.

:-7-: ITA. No:3703/Chny/2025 d. The reopening is within four years from the end of A.Y., and no failure to disclose material facts by the Appellant is required for validity [proviso to s. 147]. This ground fails.

Ground 3: The CIT(Appeals) erred in confirming the addition of ₹1,20,00,000/- as "Income from Other Sources", without properly appreciating the evidences demonstrating that the purchase and sale of shares of Gallant Udyog Ltd. were genuine and duly supported by documents.

a. The Appellant failed to discharge the onus u/s.68/69A to prove the identity, creditworthiness of the parties (Gallant Udyog Ltd. and Mrigaya Tradelink Pvt. Ltd.), and genuineness of the transaction. Mere banking channel routing or documents like share purchase agreements, allotment letters, and ledger extracts are insufficient without substantive proof [PCIT vs. NRA Iron & Steel (P) Ltd. (supra), where SC held that PAN, ITR, and cheques do not prove genuineness if parties are shell entities].

b. Bank statements show layered entries: The shares were purchased at a premium of Rs. IIO (face value Rs. 10) without justification for such high premium in an unlisted company. The sale was at cost within a short period, indicating colourable device to introduce unaccounted funds.

c. Mrigaya Tradelink Pvt. Ltd. is identified as an entry operator based on departmental information. The Appellant's initial denial of transactions (letter dated 19.03.2019) and subsequent claim contradict, raising suspicion.

d. The Id. CIT(A) rightly applied PCIT vs. NR Portfolio (P) Ltd (Delhi HC, confirmed by SC), where similar shell company share transactions were treated as bogus. e. Evidences like ROC filings and audits are formalities; they do not prove economic substance. The transaction lacks commercial rationale, as no dividend/income was earned, and shares were sold at cost.

:-8-: ITA. No:3703/Chny/2025 Ground 4: The CIT(Appeals) failed to appreciate that the Appellant had sufficient available bank balance on the date of purchase of shares, and the entire payment of 1.20 crores was made through normal banking channels from accounted funds.

a. Sufficient bank balance proves nothing if the source is circular or unaccounted. The funds for purchase in F.Y. 2012-13 were not scrutinized here, but the receipt in A.Y. 2014-15 is unexplained. Banking channels alone do not sanctify bogus transactions [Sumati Dayal vs. CIT [1995] 214 ITR 801 (SC)].

b. The pattern suggests laundering: Funds outflow for "purchase" and inflow as "sale proceeds" without real transfer of value.

Ground 5: The CIT(Appeals) failed to consider that the allotment of shares by Gallant Udyog Ltd. and the subsequent sale of the same shares to Mrigaya Trade Link Pvt. Ltd. were duly recorded in the statutory filings of the respective companies and reflected in their financial statements.

Statutory filings (e.g., ROC returns) are self-serving and do not prove genuineness if parties are accommodation providers. In NRA Iron & Steel (supra), SC disregarded similar documents where investors were shell companies with no real business.

Ground 6: The CIT(Appeals) erred in disregarding the fact that the transactions were properly accounted for, audited by statutory auditors, and supported by contract notes, bank statements, share allotment details, and ROC filings.

Accounting entries and audits do not override tax law if the transaction is sham [McDowell & Co. Ltd. vs. CTO [1985] 154 ITR 148 (SC)]. The AO and CIT(A) rightly looked beyond form to substance

Ground 7: The CIT(Appeals) failed to appreciate that the Ld. AO had issued a reference to ITO Ward 4(2), Kolkata for cross-verification, but without waiting for the verification report, the AO concluded, incorrectly and prematurely, that the sum of 1.20 crores represented accommodation entries.

:-9-: ITA. No:3703/Chny/2025 The reference was made, but assessment must be completed within time limits u/s.153. Existing evidence (bank patterns, information from Inv. Wing) sufficed for conclusion. Non-receipt of report does not invalidate the addition [CIT vs. Kelvinator of India Ltd. [2010] 320 ITR 561 (SC)].

Ground 8: The CIT(Appeals) misapplied the decision of the Hon'ble Supreme Court in PCIT v. NRA Iron & Steel (P) Ltd., which is not applicable to the Appellant's case where both the source of investment and the identity of the counterparties are fully evidenced, and the transactions are duly routed through banking channels.

The case is squarely applicable: In NRA Iron & Steel, SC upheld additions where share premium investors were shell entities, despite banking and documents. Here, counterparties fit the shell profile, high premium, quick sale at cost, no commercial logic.

Ground 9: Without prejudice, the CIT(A) ought to have appreciated that in any event, the Appellant paid through Banking Channels Rs.1.20 crores and showed it as investment; further they received the same amount through Banking channels confirmed by the payer in lieu of investment. Thus, there is no question of any amount being treated as unexplained income.

This is circular reasoning. If the transaction is bogus, the receipt is unexplained u/s 68/69A, regardless of banking. The "confirmation" from payer (a suspected entry operator) lacks credibility.

Ground 10: For all the above grounds, and such other grounds as may be urged at time of hearing, Appellant prays the additions be deleted & appropriate relief be granted.

General prayer. No relief is warranted..

Further, the ld.DR submitted - The Appellant has not produced live evidence like affidavits from directors of Gallant Udyog Ltd. or Mrigaya Tradelink Pvt. Ltd., or explained the premium rationale.

:-10-: ITA. No:3703/Chny/2025 - Penalty u/s 271(1)(c) initiation is separate and not appealable here.

11.

In view of the above the ld.DR prayed that the appeal be dismissed, and the orders of the AO and Id.CIT(A) be upheld.

12.

We have heard the rival contentions, perused the orders of the lower authorities and carefully examined the material placed on record, including the paper book filed by the assessee. The core issue for our consideration is whether the sum of Rs.1,20,00,000/- received by the assessee from M/s. Mrigaya Tradelink Pvt. Ltd. towards sale of shares of M/s.Gallant Udyog Ltd. could be treated as unexplained income and brought to tax under the provisions of the Act.

13.

We note that the addition has been made primarily on the basis of information received from the Investigation Wing, Kolkata alleging that the impugned receipt represented an accommodation entry. However, except such information and certain observations regarding the movement of funds through banking channels, no independent material has been brought on record by the AO to establish that the transaction entered into by the assessee was sham, fictitious or merely a conduit for introducing its own unaccounted money. It is a settled proposition of law that suspicion, however strong, cannot take the place of evidence. The addition must ultimately rest upon cogent material demonstrating the falsity of the transaction and not merely upon conjectures arising from investigative inputs.

14.

From the documents placed before us, it is evident that the assessee had subscribed to 1,00,000 shares of M/s.Gallant Udyog Ltd. during Financial Year 2012-13 pursuant to a rights issue. The payment for acquisition of shares was made through account payee cheques and the sources of funds utilized for such investment have been explained through documentary evidence. The assessee has also demonstrated that it had prior financial dealings with M/s.Gallant

:-11-: ITA. No:3703/Chny/2025 Udyog Ltd., including advancing loans and receiving repayment thereof along with interest, which interest income was admittedly offered to tax in the respective assessment years and is corroborated by Form 26AS and other records. These facts have not been disproved by the Revenue through any contrary material.

15.

The records further reveal that during the relevant previous year the assessee sold the aforesaid shares to M/s.Mrigaya Tradelink Pvt. Ltd. at the very same price at which they were acquired. The consideration aggregating to Rs.1,20,00,000/- was received through normal banking channels in identifiable instalments. The assessee has placed on record the corporate documents of the purchaser company, including certificate of incorporation, annual filings, income-tax return, financial statements, bank statements evidencing payment, and subsequent amalgamation approved by the Hon'ble Calcutta High Court. The Revenue has not disputed the existence of the purchaser company nor has it brought any material to establish that the monies received by the assessee had actually emanated from the coffers of the assessee itself.

16.

A significant aspect which merits consideration is that the assessee is not claiming any exempt capital gain or artificial loss arising out of the transaction. The shares were purchased for Rs.1.20 crores and sold for the very same amount. Therefore, no tax advantage or abnormal gain accrued to the assessee from the transaction. In such circumstances, the allegation that the assessee introduced its own unaccounted money in the guise of sale proceeds becomes considerably weakened, particularly when the source of investment and the receipt of sale consideration stand supported by relevant documentary evidence.

17.

We further find force in the contention of the assessee that the AO himself had considered it necessary to seek verification from the jurisdictional Assessing Officer at Kolkata in respect of the concerned entities. However,

:-12-: ITA. No:3703/Chny/2025 before any verification report could be received, the AO proceeded to conclude that the transaction was non-genuine solely on the basis of assumptions arising from the investigation report. Once a specific verification mechanism had been initiated by the Department itself, principles of fairness required that the outcome thereof be obtained and confronted to the assessee before drawing any adverse inference. The absence of such verification assumes greater significance when the assessee had produced voluminous documentary evidence in support of its claim.

18.

The reliance placed by the lower authorities on the decision of the Hon'ble Supreme Court in PCIT v. NRA Iron & Steel (P) Ltd. requires careful examination. In the said case, the investor companies were found to be paper entities lacking creditworthiness and the assessee failed to establish the genuineness of the share capital transactions despite repeated opportunities. The facts before us stand on a materially different footing. Here, the assessee has explained the source of investment, the allotment of shares, the transfer of shares, the identity of the purchaser, the banking trail of payments and has also furnished statutory records evidencing the existence and functioning of the concerned entities. No material has been brought by the Revenue to demonstrate that the documentary evidence furnished by the assessee is fabricated or false. Therefore, the ratio of NRA Iron & Steel (P) Ltd. cannot be mechanically applied without examining the factual matrix of the present case. Equally, the mere fact that the shares were issued at a premium or that the purchaser was allegedly identified in some investigation as an entry provider cannot, by itself, justify the impugned addition in the absence of any direct evidence linking the assessee with any accommodation entry arrangement. The law requires the Revenue to establish with some degree of certainty that the apparent transaction is not real. No statement of any director, shareholder, broker or intermediary has been brought on record. No opportunity of cross- examination was afforded to the assessee in respect of any adverse material. No enquiry results from Kolkata have been placed before us. In such

:-13-: ITA. No:3703/Chny/2025 circumstances, the addition rests predominantly upon suspicion and surmises rather than legally admissible evidence.

19.

Having regard to the totality of the facts and circumstances, we are of the considered view that the assessee has discharged the primary burden cast upon it by producing documentary evidence establishing the acquisition of shares, source of investment, transfer of shares, identity of the purchaser and receipt of consideration through banking channels. Once such evidence was produced, the burden shifted upon the Revenue to rebut the same by bringing positive material on record. In the absence of such rebuttal, the impugned addition cannot be sustained merely on the basis of generalized investigation reports and presumptions. Accordingly, we hold that the authorities below were not justified in treating the sum of Rs.1,20,00,000/- received by the assessee as unexplained income. The addition made by the AO and sustained by the ld.CIT(A) is directed to be deleted. The grounds raised by the assessee are allowed.

20.

In the result, the appeal of the assessee stands allowed.

Order pronounced in the open court on 02nd July, 2026 at Chennai.

Sd/- Sd/- (एबी टी वर्की ) (एस. आर. रघुिधर्थध) (ABY T VARKEY) (S. R. RAGHUNATHA) न्याययर्क सदस्य/Judicial Member लेखधसदस्य/Accountant Member चेन्िई/Chennai, ददिधंक/Dated, the 02nd July, 2026. Devadas

:-14-: ITA. No:3703/Chny/2025 आदेश की प्रनतललपप अग्रेपर्त/Copy to: 1. अपीलधर्थी/Appellant 2. प्रत्यर्थी/Respondent 3.आयकर आयुक्त/CIT– Chennai/Coimbatore/Madurai/Salem 4. पवभधगीय प्रनतनिधर्/DR 5. गधर्ा फधईल/GF Digitally signed by DEVADAS DEVADAS GOPALANACHARY GOPALANACHARY Date: 2026.07.07 18:20:55 +05'30'

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