DY COMMISSIONER OF INCOME TAX, CEN.CIRCLE-4(1), MUMBAI vs. SMT. RASILA S. MEHTA, MUMBAI

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ITA 1181/MUM/2023Status: DisposedITAT Mumbai19 February 2025AY 1992-9329 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal, considering the facts in totality and relying on the coordinate bench decision in Sudhir S. Mehta (ITA No. 417/Mum/2023), held that the AO could not provide specific information/details collected from companies on which additions were made, which is a violation of natural justice. The Tribunal noted that the Bombay High Court in Hitesh S. Mehta (ITA No. 2499 of 2013) upheld the direction to provide third-party information to the assessee for explanation, stating that failure to do so amounts to condemning without a proper hearing. Similar views were taken in other coordinate bench decisions. Consequently, the Tribunal found merit in the assessee's argument that additions based on incomplete or unverified third-party information are not justified. The Tribunal set aside the order of the CIT(A) on the issue of unexplained investments (Ground No. 2) and directed the AO to delete the addition of Rs. 5,10,025/-. The judgment indicates that the Tribunal considered the grievance in detail and applied principles of natural justice and established precedents. The operative direction is the deletion of the addition. The judgment does not explicitly state findings on all grounds raised by the assessee or the revenue's grounds.

What were the facts?

These are cross-appeals filed by the assessee and the revenue for Assessment Years (AY) 1992-93 and 1993-94. The assessee, Ashwin S. Mehta (L/H of Late Rasila S. Mehta), is a notified person under the Special Court (Trial of Offences relating to transactions in Securities) Act, 1992, with all assets attached and vested in the Custodian. The assessment proceedings have a long procedural history, involving multiple remands by the Tribunal and the High Court. The Assessing Officer (AO) made additions based on information from the Custodian, companies, dividend details, and investment accounts. The CIT(A) deleted some additions and sustained others. The assessee is aggrieved by the rejection of books of accounts, confirmation of additions for unexplained investments and receipts, enhancement of income for unexplained bank receipts and differences in a partner's accounts, confirmation of profit from a partnership firm, and disallowance of interest expenses. The revenue is aggrieved by the deletion of additions by the CIT(A).

What were the issues?

1. Whether the CIT(A) erred in rejecting the assessee's books of accounts and holding that they do not stand admitted (Assessee's Ground No. 1)? The assessee contends that the CIT(A) erred in law and facts. The revenue's contention is not recorded. 2. Whether the CIT(A) erred in confirming the addition of Rs. 5,10,025/- on account of alleged unexplained investments of the appellant (Assessee's Ground No. 2)? The assessee argues that the AO failed to provide specific information from third parties, violating natural justice, citing the Bombay High Court's decision in Hitesh S. Mehta. The revenue's contention is not recorded. 3. Whether the CIT(A) erred in confirming the addition of Rs. 40,385/- on account of alleged unexplained receipts (Assessee's Ground No. 3)? The assessee contends that the CIT(A) erred in law and facts. The revenue's contention is not recorded. 4. Whether the CIT(A) erred in enhancing the income by Rs. 77,451/- on account of unexplained receipts in the bank account, without complying with Section 251 of the Act (Assessee's Ground No. 4)? The assessee argues that the CIT(A) erred in law and facts. The revenue's contention is not recorded. 5. Whether the CIT(A) erred in confirming the addition on account of profit from partnership firm, M/s. Sunrise Enterprises, of Rs. 2,52,075/- (Assessee's Ground No. 5)? The assessee contends that the CIT(A) erred in law and facts. The revenue's contention is not recorded. 6. Whether the CIT(A) erred in allowing deduction of interest expense only to the extent of Rs. 14,92,800/- as against Rs. 2,40,00,000/- claimed (Assessee's Ground No. 6)? The assessee contends that the CIT(A) erred in law and facts. The revenue's contention is not recorded. 7. Whether the CIT(A) erred in enhancing the assessed income by Rs. 20,83,911/- on account of difference in the balance in the books of account of Late Mr. Harshad S. Mehta for AY 1992-93, without complying with Section 251 of the Act (Assessee's Ground No. 7)? The assessee argues that the CIT(A) erred in law and facts. The revenue's contention is not recorded. 8. Whether the CIT(A) erred in not appreciating that interest u/s. 220(2) was incorrectly computed by the AO (Assessee's Ground No. 8)? The assessee contends that the CIT(A) erred in law and facts. The revenue's contention is not recorded.

Which sections of the Income-tax Act were involved?

Section 251,Section 220(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SHRI SAKTIJIT DEY, HONBLE & SHRI NARENDRA KUMAR BILLAIYA, HONBLE

For Appellant: Shri Dharmesh Shah & Ms. Mitali Parekh, A/Rs
For Respondent: Shri Dr. P. Daniel – Spl. Counsel
Hearing: 12/02/2025Pronounced: 19/02/2025

Heard together (2 matters)

I.T.A. No. 380/Mum/2023
I.T.A. No. 1182/Mum/2023

Read from the judgment's own cause title. This page is filed under one of them.

PER NARENDRA KUMAR BILLAIYA, AM: I.T.A. No. 380/Mum/2023 & I.T.A. No. 1181/Mum/2023, are cross appeals by the assessee and the revenue for AY 1992-93 and I.T.A. No. 462/Mum/2023 & I.T.A. No. 1182/Mum/2023 are cross-appeals for AY 1993-94. 2. All these appeals were heard together and are disposed off by this common order for the sake of convenience and brevity.

3.

I.T.A. No. 380/Mum/2023 & I.T.A. No. 1181/Mum/2023; AY 1992-93. Representatives were heard at length. Case records carefully perused and the relevant documentary evidences duly considered in light of Rule 18(6) of the ITAT Rules, 1963. 4. The grievance of the assessee read as under:- "

1.

The Ld. CIT(A) has erred in law and in facts in rejecting the books of accounts and holding that the same do not stand admitted.

2.

The Ld. CIT(A) has erred in law and in facts in confirming the addition of Rs. 5,10,025/- on account of alleged unexplained investments of the appellant.

3.

The Ld. CIT(A) has erred in law and in facts in confirming the addition of Rs. 40,385/- on account of alleged unexplained receipts.

4.

The Ld. CIT(A) has erred in law and in facts in making addition of Rs. 77,451/- by enhancing the income to that extent on account of unexplained receipts in the bank account. The Ld. CIT(A) has not complied with the provisions of 251 of the Act while making the said enhancement.

5.

The Ld. CIT(A) has erred in law and in facts in confirming the addition on account of profit from partnership firm, M/s. Sunrise Enterprises of Rs. 2,52,075/-.

6.

The Ld. CIT(A) has erred in law and in facts in allowing the deduction of interest expense only to the extent of Rs. 14,92,800/- as against the aggregate amount of Rs. 2,40,00,000/- claimed by the appellant.

7.

The Ld. CIT(A) has erred in law and in facts in enhancing the assessed income of the appellant by Rs. 20,83,911/- on account of difference in the balance in the books of account of Late Mr. Harshad S. Mehta for A.Y. 1992-93. The Ld. CIT(A) has not complied with the provisions of s. 251 of the Act while making the said enhancement.

8.

The Ld. CIT(A) has erred in law and in facts in not appreciating that interest u/s. 220(2) of the Act was incorrectly computed by the Ld. A.O.

9.

The appellant craves leave to add to, amend, alter or delete all or any of the foregoing grounds of appeal.”

5.

Ground No. 2 relates to the addition of Rs. 5,10,025/- on account of alleged unexplained investments of the assessee. Briefly stated the facts of the case are that the assessee is a notified person under the Special Court (Trial of Offences relating to transactions in Securities) Act, 1992 and all assets including bank accounts were attached and vested in the hands of the Custodian appointed under the said Act. The original assessment was completed on 28/02/1995 determining the total income at Rs. 23,43,22,140/-. The quarrel travelled up to the Tribunal and the Tribunal vide order dated 28/04/2006 in ITA No. 400/Mum/2004, set aside the assessment to be re-framed de novo in accordance with law. Thereafter, in compliance with the order of the Tribunal, the proceedings were initiated and order was framed u/s 144 r.w.s 254 of the Act determining the total income at Rs. 24,65,02,868/-. The quarrel again went up to the Tribunal and the Tribunal vide order dated 07/06/2013 in ITA No. 583/M/2012 again set aside the assessment and restored the issues to the file of the AO. Pursuant to the order of the Tribunal re- assessment proceedings were initiated.

6.

The AO found that in the original assessment order as well as the consequent assessment order, the addition of Rs. 21,86,46,178/- was made on account of unexplained investment and trading in shares which was based upon the information gathered from the Custodian appointed under the Special Court Act, 1992, various companies issuing shares dealt in by the assessee, dividend account and investment in shares accounts by the assessee, shares seized from various premises of the group, client of the group and contract notes. The status of the additions can be understood from the following chart:- Sr. No. Particulars/source of addition Amount of addition (Rs.) Additions deleted by Id. CIT(A) (Rs.) Additions sustained by Id. CIT(A) (Rs.) 1 Custodian Letter dated 29.10.1993 6,27,750 6,27,750 2 Company letters received u/s 133(6) 63,67,586 59,36,861 4,30,725 3 Dividend details/warrants 82,42,720 81,63,420 79,300 Total 1,52,38,056 1,47,28,031 5,10,025

7.

On identical set of facts in one of the group cases, namely, Sudhir S. Mehta, Co-ordinate Bench in ITA No. 417/Mum/2023 & ITA No. 1179/Mum/2023 had considered the grievance in details and held as under:- "

15.

Considering the facts in totality, we are of the view that even in the third round of litigations, the AO could not provide the specific information/details collected from the companies on the basis of which the impugned additions have been made, am in complete violation of the principles of natural justice.

16.

We find that the Co-ordinate bench in the case of Hitesh S. Mehta vs. DCIT in ITA No. 538/Mum/2012, while setting aside the issues to the file of the AO, has specifically mentioned that, "Therefore, the Assessing Officer is directed to provide copies of all information on which basis the AO wanted to made additions in the hands of the assessee. If the AO does not provide the material then the addition cannot be made. This specific direction has been upheld by the Hon'ble High Court of Bombay in ITA No. 2499 of 2013, vide order dated 07/06/2016, wherein the Hon'ble High Court, held as under:- (a) We find that the impugned order of the Tribunal on the above issue is unimpeachable The basic principle of natural justice requires that before any addition is made by the Assessing Officer, the information obtained from third party/other sources must be confirmed with the assessee with the material so obtained. This would enable the assessee to explain the correctness/incorrectness or unstainability of the evidence so obtained. In the absence of the necessary evidence sought to be relied upon by the Assessing Officer to the assessee, it would amount to condemning a person without a proper hearing."

16.

1 Similar view was taken by the Co-ordinate Bench in ITA No. 6026/Mum/2017 and ITA No. 5190/Mum/2017. The relevant findings read as under:- "So far as the second amount of Rs. 9.92,562 representing the addition made on the basis of letters filed by four companies is mentioned at serial no. 11 and 12 in para no. 9 above, we find that in the said letters details provided were incomplete as it is not clear whether the same pertain to the year under consideration. For example, the details and information provided by these companies do not explain to which other transaction related there were some flaws in the said letters. Thus, the details provided by above 4 companies do not reflect exact details to come to the conclusion the correct holding of the assessee and therefore, we find merit in the arguments of Ld. AR that the addition on the basis of said letters is not justified and cannot be said to be justified. We set aside the order of the CIT(A) on the issue and direct the AO to delete the addition."

16.

2 Similarly, the Co-ordinate Bench in the case of Pratima H. Mehta in ITA NO. 416/Mum/2023 and 1180/Mum/2023, had the occasion to consider an identical situation and the Co-ordinate Bench held as under.-

18.

AR also regards the addition made on the basis of company letters, the learned AR submitted that the enquiries were made by the AO during the course of original assessment proceedings with various companies seeking information in respect of the shareholding of the assessee. It was further submitted that although the said information so received was used to determine the shareholding in the various scripts and treated the same as unexplained, however, copies of these evidences were never provided to the assessee. In this regard, the learned AR referred to details of various letters requesting the AO/learned CIT(A) to provide the information received from the company on the basis of which addition was made. The learned AR further submitted that to the extent company letters were provided by the AO, in the third round of proceedings, assessee's explanation was accepted by the AO and the addition to an extent of Rs.1,32,13,835, was deleted. It was further submitted that during the course of proceedings before the learned CIT(A), even though several letters were provided to the assessee, the copies of letters based on which the addition of Rs.3,13,213, was sustained, were not provided to the assessee.

19.

We find that the coordinate bench of the Tribunal vide its order, in the second round of proceedings, in ITA No.2694/Mum./2012, vide order dated 30/06/2014, specifically directed the AO to provide copies of all information on the basis of which additions were made in the hands of the assessee. The coordinate bench further held that if the AO does not provide the material then the addition cannot be made. The relevant findings of the coordinate bench in the aforesaid decision, are reproduced as under:- "

5.

After considering the impugned order, various Tribunal orders in the group cases of the assessee and also the grounds raised before us, we find that in the case of Smt. Rasila S. Mehta (supra) and in other cases also, similar grounds were raised. In these cases, the Tribunal has set aside the entire matter to the file of the Assessing Officer for making fresh assessment denovo. Since the facts of the assessee's case are similar to other cases viz. Hitesh S. Mehta, Rasila S. Mehta, Jyoti H. Mehta and Pratima H. Mehta, cited above, therefore, for the sake of ready reference, the relevant findings, as given in the decision of Rasila S. Mehta, is reproduced herein below:- "3.2 Having considered the rival submissions and careful perusal of the relevant material on record, we note that the CIT(A) while deciding the matter has relied upon the order in the case of Shri Hitesh 5 Mehta, as it is evident from para 9.20 as well as para 10.1 of the impugned order. We further note that the facts in the case of the assessee as well as in the case of Shri Hitesh S. Mehta, are identical and the matter arising from the same search and seizure action u/s 132 of the Act. The co- ordinate bench of the Tribunal, while deciding the identical matter in the case of Shri Hitesh S. Mehta, has disposed off the same in Para-4 & 5 as under:-

4.

We have heard rival submissions and consider them carefully. We have also perused the copies of the order of the tribunal in case of Smt. Pratima Mehta and the assessee passed in first round.

5.

After considering all the relevant material, we found that the matter should go back to the file of the Assessing Officer to pass a fresh order. It is seen that for rejecting the books of account, the AO has not given any valid reasons as no specific defect has been pointed out in, the books of account, therefore in our view the Assessing Officer should go through the books for determining the income on the basis of books accounts" The Assessing Officer has to bring on record specific evidence or defect to prove falsity of books of accounts as no falsity has been proved in the assessment order passed by the AO. Besides this the department has to provide all the details and material on which basis the addition have been made earlier. If such material has not been provided then the correctrness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be 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material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness of such material has to be examined then in our view correctness

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