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Facts
The assessee, engaged in BPO services, filed its return for AY 2022-23 claiming a deduction under Section 80JJAA. The CPC processed the return and proposed an adjustment, disallowing the deduction. The assessee's appeal against the intimation was dismissed by the CIT(A) on the grounds that the intimation merged with the subsequent assessment order.
Held
The Tribunal held that the doctrine of merger does not apply when the subject matter of the intimation was not examined in the subsequent assessment order. The Tribunal also noted that the CIT(A) had not adjudicated on the issue of condonation of delay in filing the audit report and the scope of adjustments permissible under Section 143(1).
Key Issues
Whether the CIT(A) was correct in dismissing the appeal as infructuous due to the doctrine of merger. Whether the adjustments made by CPC under Section 143(1) were valid and whether the delay in filing the audit report was condonable.
Sections Cited
143(1), 143(3), 144B, 80JJAA, 80AC, 246A(1)(a), 119(2)(b), 234B, 234C, 139(1)
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Income Tax Appellate Tribunal, MUMBAI BENCH “E” MUMBAI
Before: SHRI SANDEEP GOSAIN & SHRI OM PRAKASH KANT
This appeal by the assessee is directed against order dated 18.02.2025 passed by the Ld. Commissioner of Income-tax (Appeals)- National Faceless Appeal Centre, Delhi National Faceless Appeal Centre, Delhi [in short [in short ‘the Ld. CIT(A)’] for assessment year 2022 ] for assessment year 2022-23, raising following grounds following grounds:
The Order of the Learned Addl./ JCIT (A) is not justified in 1. The Order of the Learned Addl./ JCIT (A) is not justified in 1. The Order of the Learned Addl./ JCIT (A) is not justified in law and on facts and law and on facts and circumstances of the case.
2. As regards merger of intimation with assessment order: 2. As regards merger of intimation with assessment order: 2. As regards merger of intimation with assessment order: 2.1. The Learned Addl./ JCIT (A) has erred in dismissing the 2.1. The Learned Addl./ JCIT (A) has erred in dismissing the 2.1. The Learned Addl./ JCIT (A) has erred in dismissing the appeal [filed against appeal [filed appeal [filed against against section section 143(1), dated 16.03.2023 section 143(1), dated 16.03.2023 143(1), dated 16.03.2023 intimation) as infructuous on the incorrect premise tha intimation) as infructuous on the incorrect premise tha intimation) as infructuous on the incorrect premise that intimation merges with subsequent assessment order passed intimation merges with subsequent assessment order passed intimation merges with subsequent assessment order passed under section 143(3) r.w.s. 144B, dated 23.09.2023, when the under section 143(3) r.w.s. 144B, dated 23.09.2023, when the under section 143(3) r.w.s. 144B, dated 23.09.2023, when the said deduction was not subject matter of scrutiny assessment said deduction was not subject matter of scrutiny assessment said deduction was not subject matter of scrutiny assessment under section 143(3). under section 143(3). 2.2. The Learned Addl./ JCIT (A) has failed to appre 2.2. The Learned Addl./ JCIT (A) has failed to appre 2.2. The Learned Addl./ JCIT (A) has failed to appreciate that the cause of action i.e., denial of deduction under section the cause of action i.e., denial of deduction under section the cause of action i.e., denial of deduction under section 80JJAA is arising from intimation under section 143(1) and not 80JJAA is arising from intimation under section 143(1) and not 80JJAA is arising from intimation under section 143(1) and not under order under section 143(3) and the said intimation is under order under section 143(3) and the said intimation is under order under section 143(3) and the said intimation is independently appealable under section 246A(1)(a) of IT Act. independently appealable under section 246A(1)(a) of IT Act. independently appealable under section 246A(1)(a) of IT Act.
3. The Learned Addl./ JCIT (A) is not justified in denying the . The Learned Addl./ JCIT (A) is not justified in denying the . The Learned Addl./ JCIT (A) is not justified in denying the opportunity of personal hearing when a specific request was opportunity of personal hearing when a specific request was opportunity of personal hearing when a specific request was made by the Appellant in the submission filed on 20.05.2024, made by the Appellant in the submission filed on 20.05.2024, made by the Appellant in the submission filed on 20.05.2024, which is against the principles of natural justice and mandate which is against the principles of natural justice and mandate which is against the principles of natural justice and mandate of e-Appeals Scheme, 2023. ls Scheme, 2023. 4. As regards condonation of delay with respect to section 80AC 4. As regards condonation of delay with respect to section 80AC 4. As regards condonation of delay with respect to section 80AC of IT Act: 4.1. The Learned Addl./ JCIT (A) is not justified in not 4.1. The Learned Addl./ JCIT (A) is not justified in not 4.1. The Learned Addl./ JCIT (A) is not justified in not condoning the delay in filing the return of income when condoning the delay in filing the return of income when condoning the delay in filing the return of income when Appellant otherwise satisfies conditions under sec Appellant otherwise satisfies conditions under section 80JJAA. tion 80JJAA. 4.2. The Learned Addl./ JCIT (A) ought to have appreciated that 4.2. The Learned Addl./ JCIT (A) ought to have appreciated that 4.2. The Learned Addl./ JCIT (A) ought to have appreciated that the Appellant has sufficient and reasonable cause in filing the the Appellant has sufficient and reasonable cause in filing the the Appellant has sufficient and reasonable cause in filing the returns belatedly, which is condonable under section 80AC. returns belatedly, which is condonable under section 80AC. returns belatedly, which is condonable under section 80AC. 4.3. The Learned Addl./ JCIT (A) has failed to 4.3. The Learned Addl./ JCIT (A) has failed to appreciate that appreciate that under section 119(2)(b) the Board has power to authorise any under section 119(2)(b) the Board has power to authorise any under section 119(2)(b) the Board has power to authorise any income tax authority other than Joint/ Commissioner (Appeals) income tax authority other than Joint/ Commissioner (Appeals) income tax authority other than Joint/ Commissioner (Appeals) to admit the belated claim made after the expiry of specified to admit the belated claim made after the expiry of specified to admit the belated claim made after the expiry of specified period under IT Act which impliedly denotes that the Jo period under IT Act which impliedly denotes that the Jo period under IT Act which impliedly denotes that the Joint/ Commissioner (Appeals) has power to condone the belated claim Commissioner (Appeals) has power to condone the belated claim Commissioner (Appeals) has power to condone the belated claim under section 80AC. under section 80AC.
5. The Learned Addl./ JCIT (A) has failed to appreciate that the 5. The Learned Addl./ JCIT (A) has failed to appreciate that the 5. The Learned Addl./ JCIT (A) has failed to appreciate that the subject adjustment carried out by CPC being in contravention of subject adjustment carried out by CPC being in contravention of subject adjustment carried out by CPC being in contravention of Centralised Processing of Returns Scheme Centralised Processing of Returns Scheme, 2011.
Without prejudice to the above, adjustment made without 6. Without prejudice to the above, adjustment made without 6. Without prejudice to the above, adjustment made without satisfying the conditions of Section 143(1): satisfying the conditions of Section 143(1): 6.1. The Learned Addl./ JCIT (A) has failed to appreciate the 6.1. The Learned Addl./ JCIT (A) has failed to appreciate the 6.1. The Learned Addl./ JCIT (A) has failed to appreciate the CPC denied the entire deduction of Rs.14,47,95,160/ CPC denied the entire deduction of Rs.14,47,95,160/ CPC denied the entire deduction of Rs.14,47,95,160/- under section 80JJAA by purpo section 80JJAA by purportedly invoking section 80AC without rtedly invoking section 80AC without giving the proposition notice as mandated in first proviso to giving the proposition notice as mandated in first proviso to giving the proposition notice as mandated in first proviso to section 143(1)(a) thereby offending the principles of natural section 143(1)(a) thereby offending the principles of natural section 143(1)(a) thereby offending the principles of natural justice. 6.2. Without prejudice to the above, the lower authorities have 6.2. Without prejudice to the above, the lower authorities have 6.2. Without prejudice to the above, the lower authorities have failed to appreciate failed to appreciate that there is a violation of second proviso to that there is a violation of second proviso to section 143(1)(a) for the reason that CPC being an inanimate section 143(1)(a) for the reason that CPC being an inanimate section 143(1)(a) for the reason that CPC being an inanimate body cannot address the grievance of the appellants. body cannot address the grievance of the appellants. 6.3. Without prejudice to the above, the Learned Addl./ JCIT (A) 6.3. Without prejudice to the above, the Learned Addl./ JCIT (A) 6.3. Without prejudice to the above, the Learned Addl./ JCIT (A) has failed to appreciate that has failed to appreciate that the adjustment made by the CPC the adjustment made by the CPC in section 143(1) intimation does not specify the clause/ sub in section 143(1) intimation does not specify the clause/ sub in section 143(1) intimation does not specify the clause/ sub- clause under which such adjustment is made and does not clause under which such adjustment is made and does not clause under which such adjustment is made and does not adduce any reasons for making such adjustment. adduce any reasons for making such adjustment. 6.4. Without prejudice to the above, the CPC is not justifie 6.4. Without prejudice to the above, the CPC is not justifie 6.4. Without prejudice to the above, the CPC is not justified in invoking invoking section section 143(1)(ii) 143(1)(ii) when when the the pre pre-conditions conditions for for application of the said clause did not exist in the instant case in application of the said clause did not exist in the instant case in application of the said clause did not exist in the instant case in as much there was no incorrect claim made in return, which is as much there was no incorrect claim made in return, which is as much there was no incorrect claim made in return, which is apparent from any information in the return. apparent from any information in the return. 6.5. Without prejudi 6.5. Without prejudice to the above, the CPC is not justified in ce to the above, the CPC is not justified in proposing to make a disallowance of Rs.9,29,03,608/ proposing to make a disallowance of Rs.9,29,03,608/ proposing to make a disallowance of Rs.9,29,03,608/- under section 143(1)(a)(ii) by considering Form 10DA for a different section 143(1)(a)(ii) by considering Form 10DA for a different section 143(1)(a)(ii) by considering Form 10DA for a different Assessment Year. Assessment Year. 6.6. Without prejudice to the above, the CPC is not justified in 6.6. Without prejudice to the above, the CPC is not justified in 6.6. Without prejudice to the above, the CPC is not justified in denying the entire claim of Rs.14,47,95,160/ the entire claim of Rs.14,47,95,160/- made under made under section 80JJAA vide intimation under section 143(1), when the section 80JJAA vide intimation under section 143(1), when the section 80JJAA vide intimation under section 143(1), when the CPC proposed under section 143(1)(a)(ii) to make a disallowance CPC proposed under section 143(1)(a)(ii) to make a disallowance CPC proposed under section 143(1)(a)(ii) to make a disallowance of Rs.9,29,03,608/ of Rs.9,29,03,608/-.
As regards levy of interest: 7. As regards levy of interest: 7.1. The Learned CPC is not 7.1. The Learned CPC is not justified in levying interest of justified in levying interest of Rs.35,63,056/ Rs.35,63,056/- under section 234B.
7.2. The Learned CPC is not justified in levying interest of Rs. 7.2. The Learned CPC is not justified in levying interest of Rs. 7.2. The Learned CPC is not justified in levying interest of Rs. 21,75,197/- [25,69,652 [25,69,652-3,94,455) under section 234C. 3,94,455) under section 234C. 7.3. The Learned CPC is not justified in levying the aforesaid 7.3. The Learned CPC is not justified in levying the aforesaid 7.3. The Learned CPC is not justified in levying the aforesaid interests, when the impugned adjustment ests, when the impugned adjustment is not tenable. tenable.
Briefly stated, facts of the case are that facts of the case are that during relevant period during relevant period the assessee was engaged in the business of BPO services. For the engaged in the business of BPO services. For the engaged in the business of BPO services. For the year under consideration A.Y. 2022 year under consideration A.Y. 2022-23, the assessee assessee filed its return of income declaring total income at Rs. 50,07,07,258/ f income declaring total income at Rs. 50,07,07,258/- after f income declaring total income at Rs. 50,07,07,258/ claiming deduction of Rs. 14,47,95,160/ claiming deduction of Rs. 14,47,95,160/- u/s. 80JJAA of the Act. u/s. 80JJAA of the Act. The ld. Central Processing Centre(C entral Processing Centre(CPC) processed the return of processed the return of income and proposed to make adjustment income and proposed to make adjustment by way of order dated by way of order dated 23.12.2022 passed u/s. 143(1)(a)(ii) u/s. 143(1)(a)(ii) of the Income-tax Act,1961( In tax Act,1961( In short the Act) by taking into account the amount of deduction by taking into account the amount of deduction by taking into account the amount of deduction claimed in ITR vis-à à-vis amount certified by tax auditor in Form vis amount certified by tax auditor in Form 10DA of the immediately previous year. 10DA of the immediately previous year. Despite filing objections Despite filing objections against such an adjustment ainst such an adjustment made by the CPC and filing CPC and filing rectification application, the assessee could not succeed. Later, the rectification application, the assessee could not succeed. Later, the rectification application, the assessee could not succeed. Later, the case was selected for for scrutiny under CASS and assessment order under CASS and assessment order was passed u/s. 143(3) r.w.s. 144B on 23.09.2023. was passed u/s. 143(3) r.w.s. 144B on 23.09.2023.
Aggrieved by this adjustment made by the CPC, the assessee Aggrieved by this adjustment made by the CPC, the assessee Aggrieved by this adjustment made by the CPC, the assessee challenged it before the CIT(A) who challenged it before the CIT(A) who held that the appeal filed the appeal filed against intimation u/s. 143(1) dated 16.03.2023 is infructuous on against intimation u/s. 143(1) dated 16.03.2023 is infructuous on against intimation u/s. 143(1) dated 16.03.2023 is infructuous on the premise that intimation merges with subsequent assessment the premise that intimation merges with subsequent assessment the premise that intimation merges with subsequent assessment order passed u/s. 143(3) r.w.s. 144B dated 23.09.2023 passed u/s. 143(3) r.w.s. 144B dated 23.09.2023. The passed u/s. 143(3) r.w.s. 144B dated 23.09.2023 relevant extract of the CIT(A)’s order is as under: relevant extract of the CIT(A)’s order is as under:-
“4. It is seen from the above that the intimation u/s 143(1) of 4. It is seen from the above that the intimation u/s 143(1) of 4. It is seen from the above that the intimation u/s 143(1) of the I.T. Act, 1961 dated 16.03.2023, against which the the I.T. Act, 1961 dated 16.03.2023, against which the the I.T. Act, 1961 dated 16.03.2023, against which the appellant has filed the present appellant has filed the present appeal, has been subsequently appeal, has been subsequently merged in the subsequent assessment order u/s 143(3) r.w.s. merged in the subsequent assessment order u/s 143(3) r.w.s. merged in the subsequent assessment order u/s 143(3) r.w.s. 144B of the I.T. Act, 1961 dated 07.03.2024, and the total 144B of the I.T. Act, 1961 dated 07.03.2024, and the total 144B of the I.T. Act, 1961 dated 07.03.2024, and the total income income income determined determined determined in in in the the the 143(1) 143(1) 143(1) intimation intimation intimation as as as Rs. Rs. Rs. 64,55,02,420/ 64,55,02,420/- has been determined as total income asses has been determined as total income assessed in the said assessment order also. The remedial option in the said assessment order also. The remedial option in the said assessment order also. The remedial option available to the appellant was, to have filed an appeal against available to the appellant was, to have filed an appeal against available to the appellant was, to have filed an appeal against the said assessment order u/s 143(3) r.w.s. 144B, as the the said assessment order u/s 143(3) r.w.s. 144B, as the the said assessment order u/s 143(3) r.w.s. 144B, as the present appeal has become infructuous. It is submitted by the present appeal has become infructuous. It is submitted by the present appeal has become infructuous. It is submitted by the appellant in i appellant in its response made on 20.05.2024 that the ts response made on 20.05.2024 that the appellant has filed an appeal on 01.05.2024 against the said appellant has filed an appeal on 01.05.2024 against the said appellant has filed an appeal on 01.05.2024 against the said assessment order u/s 143(3) r.w.s. 144B dated assessment order u/s 143(3) r.w.s. 144B dated 07.03.2024. 07.03.2024.
To conclude, in view of the merger of intimation u/s 143(1) in To conclude, in view of the merger of intimation u/s 143(1) in To conclude, in view of the merger of intimation u/s 143(1) in the subsequent assessment order subsequent assessment order u/s 143(3) r.w.s. 144B, as u/s 143(3) r.w.s. 144B, as discussed in detail above, the present appeal of the appellant detail above, the present appeal of the appellant against the addition against the addition made in the intimation u/s 143(1) dated made in the intimation u/s 143(1) dated 16.03.2023, is treated as 16.03.2023, is treated as infructuous. Accordingly, the present infructuous. Accordingly, the present appeal is dismissed appeal is dismissed.”
We have carefully examined the orders passed by the lower carefully examined the orders passed by the lower carefully examined the orders passed by the lower authorities, perused the material placed on record, and considered authorities, perused the material placed on record, and considered authorities, perused the material placed on record, and considered the submissions advanced on behalf of the appellant as well as the the submissions advanced on behalf of the appellant as well as the the submissions advanced on behalf of the appellant as well as the Revenue. The appellant has raised multiple grounds of appeal
, Revenue. The appellant has raised multiple grounds of appeal
, Revenue. The appellant has raised multiple grounds of appeal, numbered 1 to 7. Grounds Nos. 1 to 6 pertain to the scope and to 7. Grounds Nos. 1 to 6 pertain to the scope and to 7. Grounds Nos. 1 to 6 pertain to the scope and authority of the Centralized Processing Centre (CPC) to effect an authority of the Centralized Processing Centre (CPC) to effect an authority of the Centralized Processing Centre (CPC) to effect an adjustment under Section 143(1) of the Act adjustment under Section 143(1) of the Act by disallowing a claim by disallowing a claim of deduction amounting to of deduction amounting to ₹14,47,95,160/- under Section 80JJAA, under Section 80JJAA, by reference to Form 10DA for a different assessment year. Ground ence to Form 10DA for a different assessment year. Ground ence to Form 10DA for a different assessment year. Ground No. 7 is consequential in nature and relates to interest charged No. 7 is consequential in nature and relates to interest charged No. 7 is consequential in nature and relates to interest charged under Sections 234B and 234C of the Act. under Sections 234B and 234C of the Act.
4.1 It is observed that in the present case, the CPC initially It is observed that in the present case, the CPC initially It is observed that in the present case, the CPC initially proposed an adjustment under Sect proposed an adjustment under Section 143(1)(a)(ii) of the Act, ion 143(1)(a)(ii) of the Act, disallowing a sum of disallowing a sum of ₹9,29,03,608/- claimed under Section claimed under Section 80JJAA, ostensibly based on a comparison with claims made in a 80JJAA, ostensibly based on a comparison with claims made in a 80JJAA, ostensibly based on a comparison with claims made in a different assessment year. Subsequently, the final intimation order different assessment year. Subsequently, the final intimation order different assessment year. Subsequently, the final intimation order under Section 143(1) disallowed the e under Section 143(1) disallowed the entire claim of ₹ ₹14,47,95,160/- . The appellant contended that the . The appellant contended that the ld. CIT(A) erred in dismissing the erred in dismissing the appeal as infructuous on the premise that the intimation under appeal as infructuous on the premise that the intimation under appeal as infructuous on the premise that the intimation under Section 143(1) had merged with the assessment order subsequently Section 143(1) had merged with the assessment order subsequently Section 143(1) had merged with the assessment order subsequently passed.
4.2 We find merit in We find merit in the submission of the learned authorised the submission of the learned authorised representative of the appellant that the doctrine of merger, as representative of the appellant that the doctrine of merger, as representative of the appellant that the doctrine of merger, as judicially settled, does not operate where the subject matter in judicially settled, does not operate where the subject matter in judicially settled, does not operate where the subject matter in question has not been dealt with in the later order. In the instant question has not been dealt with in the later order. In the instant question has not been dealt with in the later order. In the instant case, the issue relating to the claim under Section 80JJAA was not elating to the claim under Section 80JJAA was not elating to the claim under Section 80JJAA was not examined in the regular assessment order. Accordingly, there is no examined in the regular assessment order. Accordingly, there is no examined in the regular assessment order. Accordingly, there is no basis to conclude that the intimation stood merged with the basis to conclude that the intimation stood merged with the basis to conclude that the intimation stood merged with the subsequent assessment order. subsequent assessment order.
4.3 It is further noted that the return of income It is further noted that the return of income was filed belatedly was filed belatedly on 23.12.2022. The audit report in Form 10DA, as required under on 23.12.2022. The audit report in Form 10DA, as required under on 23.12.2022. The audit report in Form 10DA, as required under Section 80JJAA(2)(c), was filed on 19.12.2022, four days prior to Section 80JJAA(2)(c), was filed on 19.12.2022, four days prior to Section 80JJAA(2)(c), was filed on 19.12.2022, four days prior to the filing of the return. While the CPC has not expressly stated the the filing of the return. While the CPC has not expressly stated the the filing of the return. While the CPC has not expressly stated the reasons for disallowance of the deduc reasons for disallowance of the deduction, it appears that the tion, it appears that the adjustment was made by invoking clause (v) of Section 143(1)(a), adjustment was made by invoking clause (v) of Section 143(1)(a), adjustment was made by invoking clause (v) of Section 143(1)(a), taking the view that the return was not filed within the due date taking the view that the return was not filed within the due date taking the view that the return was not filed within the due date prescribed under Section 139(1) read with Section 80AC. prescribed under Section 139(1) read with Section 80AC. prescribed under Section 139(1) read with Section 80AC.
4.4 The appellant submitted that the delay in f The appellant submitted that the delay in f The appellant submitted that the delay in finalizing the accounts and obtaining the statutory audit resulted in a accounts and obtaining the statutory audit resulted in a accounts and obtaining the statutory audit resulted in a corresponding delay in filing the audit report. However, it was corresponding delay in filing the audit report. However, it was corresponding delay in filing the audit report. However, it was emphasized that the audit report was nevertheless available at the emphasized that the audit report was nevertheless available at the emphasized that the audit report was nevertheless available at the time of processing the return under Section 143(1), and that no time of processing the return under Section 143(1), an time of processing the return under Section 143(1), an prejudice was caused to the Revenue by the belated filing. It is prejudice was caused to the Revenue by the belated filing. It is prejudice was caused to the Revenue by the belated filing. It is further submitted that the delay was neither deliberate nor further submitted that the delay was neither deliberate nor further submitted that the delay was neither deliberate nor avoidable and occurred due to genuine reasons beyond the avoidable and occurred due to genuine reasons beyond the avoidable and occurred due to genuine reasons beyond the appellant’s control. 4.5 Upon perusal of the appellate order, we fin Upon perusal of the appellate order, we find that the CIT(A) d that the CIT(A) has not adjudicated on the issue of condonation of delay in filing has not adjudicated on the issue of condonation of delay in filing has not adjudicated on the issue of condonation of delay in filing the audit report, nor has he addressed the specific grounds raised the audit report, nor has he addressed the specific grounds raised the audit report, nor has he addressed the specific grounds raised in relation to the applicability and scope of adjustments permissible in relation to the applicability and scope of adjustments permissible in relation to the applicability and scope of adjustments permissible under Section 143(1) of the Act. I under Section 143(1) of the Act. In our considered view, these n our considered view, these issues go to the root of the matter and require proper adjudication. issues go to the root of the matter and require proper adjudication. issues go to the root of the matter and require proper adjudication.
5. In the circumstances, and in the interest of justice, we In the circumstances, and in the interest of justice, we In the circumstances, and in the interest of justice, we consider it appropriate to set aside the impugned appellate order consider it appropriate to set aside the impugned appellate order consider it appropriate to set aside the impugned appellate order and remand the matter to the file o and remand the matter to the file of the CIT(A) for de novo f the CIT(A) for de novo consideration. The CIT(A) shall examine the issues raised, including consideration. The CIT(A) shall examine the issues raised, including consideration. The CIT(A) shall examine the issues raised, including the claim for deduction under Section 80JJAA, the alleged delay in the claim for deduction under Section 80JJAA, the alleged delay in the claim for deduction under Section 80JJAA, the alleged delay in filing of the audit report, and the validity of the adjustment under filing of the audit report, and the validity of the adjustment under filing of the audit report, and the validity of the adjustment under Section 143(1), and shall Section 143(1), and shall dispose of the appeal after affording due dispose of the appeal after affording due opportunity of hearing to the appellant. opportunity of hearing to the appellant.
6. In view of the above, the grounds raised by the appellant are In view of the above, the grounds raised by the appellant are In view of the above, the grounds raised by the appellant are restored for adjudication before the CIT(A). adjudication before the CIT(A).
7 In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes.
Order pronounced in the open Court on nounced in the open Court on 30/06/2025. /06/2025.