CIT v. British Paints India Ltd.

188 ITR 44Supreme Court of India1991#447 most cited

What is CIT v. British Paints India Ltd. authority for?

The Assessing Officer has a duty to examine whether an assessee's books of account truly disclose the correct income and is not bound to accept the accounting system regularly employed by the assessee or methods followed in earlier years. Each assessment year is a distinct and self-contained unit for tax purposes.

204

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2008 to 2026.

Also referred to as

CIT v. British Paints India Ltd. · 188 ITR 44 · Section 145 · Section 144 · Assessing Officer duty · method of accounting · books of account scrutiny · true income · assessment year distinct · valuation methods · SC 1991

Sections most often in play

Section 143(3)Section 144Section 145(3)Section 271(1)(c)Section 37(1)Section 115JBSection 153ASection 142(1)
Read the full judgment

Issues it is cited on

section 80hhcwritten down valuesection 145section 40(a)(i)interest u/s 234bprofits and gains of business or professionsection 145(3)section 127section 115jadvance taxbook profitspenalty u/s 271(1)(c)

Judgments citing CIT v. British Paints India Ltd.

Daman Metallic Oxides, Mumbai vs. Asst CIT 24(3), Mumbai

Appeal of the assessee is partly allowed

ITA 613/MUM/2015[2008-09]Status: DisposedITAT Mumbai19 Oct 2016AY 2008-09

Bench: Shri Sanjay Garg () & Shri Ashwani Taneja ()

Section 143(3)Section 263

…t, where the difference in income followed a consistent though incorrect method of valuation of closing stock, so that its effect neutralized in the succeeding year, the argument was found not valid by the apex court in CIT v. British Paints India Ltd. (1991) 188 ITR 44 (SC). The direction by the ld. CIT, therefore, for including the amount of VAT refund accrued to it is to be upheld. We decide accordingly.” Thereafter, the Assessing Officer passed order u/s 143(3) in 6 I.T.A. No.613/Mum/2015 pursuance to the revision order u/s 263 of CIT. In the fresh assessment order so passed, the Assessing Officer carried ou…

DCIT, New Delhi vs. M/S. Hcl Comnet Ltd., New Delhi

In the result this ground is dismissed

ITA 6142/DEL/2012[2009-10]Status: DisposedITAT Delhi19 Aug 2016AY 2009-10

Bench: Shri S.V. Mehrotra : & Shri C.M. Garg :

For Appellant: Shri Ajay Vohra Sr. Adv. &For Respondent: Shri A.K. Saroha CIT(DR) &
Section 143(3)Section 195Section 263Section 40Section 9(1)(vii)

…ee is following a regular method of accounting but the effect of which is not deducing true profits from business, then it cannot be said that correctness of method can be ignored by AO, as has been held by Hon’ble Supreme Court in the case of British Paints 188 ITR 44, wherein it has been held as under: “that even if the assessee had adopted a regular system of accounting, it was the duty of the Assessing Officer under section 145 of the Income-tax Act, 1961, to consider whether the correct profits and gains could be deduced from the accounts so maintained. If he was of the opinion that the correct profits coul…

Hcl Comnet Ltd., New Delhi vs. DCIT, New Delhi

In the result this ground is dismissed

ITA 5898/DEL/2012[2009-10]Status: DisposedITAT Delhi19 Aug 2016AY 2009-10

Bench: Shri S.V. Mehrotra : & Shri C.M. Garg :

For Appellant: Shri Ajay Vohra Sr. Adv. &For Respondent: Shri A.K. Saroha CIT(DR) &
Section 143(3)Section 195Section 263Section 40Section 9(1)(vii)

…ee is following a regular method of accounting but the effect of which is not deducing true profits from business, then it cannot be said that correctness of method can be ignored by AO, as has been held by Hon’ble Supreme Court in the case of British Paints 188 ITR 44, wherein it has been held as under: “that even if the assessee had adopted a regular system of accounting, it was the duty of the Assessing Officer under section 145 of the Income-tax Act, 1961, to consider whether the correct profits and gains could be deduced from the accounts so maintained. If he was of the opinion that the correct profits coul…

DCIT, New Delhi vs. M/S. Hcl Comnet Ltd., New Delhi

In the result this ground is dismissed

ITA 5651/DEL/2012[2006-07]Status: DisposedITAT Delhi19 Aug 2016AY 2006-07

Bench: Shri S.V. Mehrotra : & Shri C.M. Garg :

For Appellant: Shri Ajay Vohra Sr. Adv. &For Respondent: Shri A.K. Saroha CIT(DR) &
Section 143(3)Section 195Section 263Section 40Section 9(1)(vii)

…ee is following a regular method of accounting but the effect of which is not deducing true profits from business, then it cannot be said that correctness of method can be ignored by AO, as has been held by Hon’ble Supreme Court in the case of British Paints 188 ITR 44, wherein it has been held as under: “that even if the assessee had adopted a regular system of accounting, it was the duty of the Assessing Officer under section 145 of the Income-tax Act, 1961, to consider whether the correct profits and gains could be deduced from the accounts so maintained. If he was of the opinion that the correct profits coul…

ACIT, New Delhi vs. M/S. Hcl Comnet Ltd., New Delhi

In the result this ground is dismissed

ITA 321/DEL/2012[2004-05]Status: DisposedITAT Delhi19 Aug 2016AY 2004-05

Bench: Shri S.V. Mehrotra : & Shri C.M. Garg :

For Appellant: Shri Ajay Vohra Sr. Adv. &For Respondent: Shri A.K. Saroha CIT(DR) &
Section 143(3)Section 195Section 263Section 40Section 9(1)(vii)

…ee is following a regular method of accounting but the effect of which is not deducing true profits from business, then it cannot be said that correctness of method can be ignored by AO, as has been held by Hon’ble Supreme Court in the case of British Paints 188 ITR 44, wherein it has been held as under: “that even if the assessee had adopted a regular system of accounting, it was the duty of the Assessing Officer under section 145 of the Income-tax Act, 1961, to consider whether the correct profits and gains could be deduced from the accounts so maintained. If he was of the opinion that the correct profits coul…

Hcl Comnet Ltd., New Delhi vs. CIT, New Delhi

In the result this ground is dismissed

ITA 5907/DEL/2010[2006-07]Status: DisposedITAT Delhi19 Aug 2016AY 2006-07

Bench: Shri S.V. Mehrotra : & Shri C.M. Garg :

For Appellant: Shri Ajay Vohra Sr. Adv. &For Respondent: Shri A.K. Saroha CIT(DR) &
Section 143(3)Section 195Section 263Section 40Section 9(1)(vii)

…ee is following a regular method of accounting but the effect of which is not deducing true profits from business, then it cannot be said that correctness of method can be ignored by AO, as has been held by Hon’ble Supreme Court in the case of British Paints 188 ITR 44, wherein it has been held as under: “that even if the assessee had adopted a regular system of accounting, it was the duty of the Assessing Officer under section 145 of the Income-tax Act, 1961, to consider whether the correct profits and gains could be deduced from the accounts so maintained. If he was of the opinion that the correct profits coul…

Suman Kadam, Thane vs. ITO WD 2(4), Thane

In the result, the assessee’s appeal is partly allowed for statistical purposes, and the Revenue’s appeal is allowed for statistical purposes

ITA 2777/MUM/2014[2008-09]Status: DisposedITAT Mumbai08 Aug 2016AY 2008-09

Bench: Shri Sanjay Arora, Am & Shri Pawan Singh, Jm आयकर अपील सं./I.T.A. No. 2777/Mum/2014 ("नधा"रण वष" / Assessment Year: 2008-09) Suman Kadam Ito, Ward 2(4), बनाम/ Vardaan, 6Th Floor, S/1, Narmada Apartment, Cabin Cross Road, Bhayandar (E), Ashar I. T. Park, Road No. 16-Z, Vs. Thane-401 105 Wagle Indl. Estate, Thane-400 604 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Afipk 3600 D (Assessee) (Revenue) : आयकर अपील सं./I.T.A. No. 3256/Mum/2014 ("नधा"रण वष" / Assessment Year: 2008-09) बनाम/ Ito, Ward 2(2), Suman Kadam Thane-400 604 Thane-401 105 Vs. (Revenue) : (Assessee) : Shri Vijay Shah Assessee By Revenue By : Shri Debabrata Baidya सुनवाई क" तार"ख / : 12.5.2016 Date Of Hearing घोषणा क" तार"ख / : 08.8.2016 Date Of Pronouncement आदेश / O R D E R Per Sanjay Arora, A. M.: These Are Cross Appeals, I.E., By The Assessee & The Revenue, Arising Out Of The Order By The Commissioner Of Income Tax (Appeals)-2, Thane (‘Cit(A)’ For Short) Dated 27.2.2014, Partly Allowing The Assessee’S Appeal Contesting Its Assessment U/S.143(3) Of The Income Tax Act, 1961 (‘The Act’ Hereinafter) For The Assessment Year (A.Y.) 2008-09 Vide Order Dated 31.12.2010. 2

For Respondent: Shri Debabrata Baidya
Section 143(3)Section 54Section 54F

…vs. Durga Prasad More [1971] 82 ITR 540 (SC)), and it is only the correct 6 ITA Nos. 2777 & 3256/Mum/2014 (A.Y. 2008-09) Suman Kadam vs. ITO income, assessable for a year, which could be brought to tax for that year (CIT vs. British Paints India Ltd. [1991] 188 ITR 44 (SC)). The purview of the A.O. is to assess the total income for the relevant year. As such, where the assessee is able to show that the income as returned is not assessable for that year, i.e., as per law; each year being an independent unit of assessment, we see no reason as to why the same could not be excluded. The onus, however, to show that…

ITO, Ward-9(1), Kolkata vs. M/S Acytelene Trexim (P) Ltd., Kolkata

In the result, Revenue’s appeal stands dismissed

ITA 1429/KOL/2012[2009-10]Status: DisposedITAT Kolkata03 Aug 2016AY 2009-10

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2009-10

Section 143(1)Section 143(2)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “C” KOLKATA Before Shri N.V.Vasudevan, Judicial Member and Shri Waseem Ahmed, Accountant Member Assessment Year :2009-10 ITO, Ward-9(1), V/s. M/s Acytelene Trexim (P) Ltd., 14, N.S. Road (4th P-7, Choringhee Square, Aayakar Floor), Clive Row, Bhawan, 5th Floor, Kolkata-700 001 Room-14, Kolkata- [PAN No.AACCA 4045 J] 700 069 अपीलाथ" /Appellant .. ""यथ"/Respondent Shri Debasish Banerjee, JCIT-SR-DR अपीलाथ" क" ओर से/By Appellant ""यथ" क" ओर से/By Respondent Shri S.M.Surana, Advocate सुनवाई क" तार"ख/Date of Hearing 20-07-2016 घोषणा क" तार"ख/Date of Pronouncement…

Anand R Bahl, Mumbai vs. DCIT RG 20(3), Mumbai

In the result, the appeals by the assessee are dismissed and that by the Revenue is allowed for statistical purposes

ITA 7706/MUM/2011[2007-08]Status: DisposedITAT Mumbai20 Jul 2016AY 2007-08

Bench: Shri Sanjay Arora & Shri Pawan Singh

For Appellant: Shri Hiten M. Vasant (AR)For Respondent: Shri B. Pruseth (DR)
Section 2(14)

…which there is no corresponding sale/receipt, would stand to be allowed only in the year of payment. The law in the matter is well settled, and case law, legion. We may, for ready reference, advert to the decisions in CIT vs. British Paints India Ltd. [1991] 188 ITR 44 (SC) and Southern Technologies Ltd. v. Jt. CIT [2010] 320 ITR 577 (at pages 608-610). The said argument by the ld. CIT(A) made qua real income is again misconceived. (A.Ys. 2007-08 & 2008-09) Anand R Behl 10.4 The question, however, that arises is if the assessee is, as claimed and accepted, following cash system of accounting, how is it that the…

Radashir Jewellery Co. P.Ltd, Mumbai vs. Asst CIT Cir 8(3), Mumbai

ITA 7066/MUM/2013[2008-09]Status: DisposedITAT Mumbai08 Jul 2016AY 2008-09

Bench: S/Sh.Rajendra & C.N. Prasadआयकर अपील अपील संसंसंसं./I.T.A./7066/Mum/2013,िनधा"रण िनधा"रण वष" वष" /Assessment Year: 2008-09 आयकर आयकर आयकर अपील अपील िनधा"रण िनधा"रण वष" वष" Radhashir Jewellery Co.Pvt. Ltd. Acit , Circle-8(3) Aayakar Bhavan, 2Nd Floor, M.K. Road Army Navy Press Building, Plot No.118 Road No.18, Midc Vs. Mumbai-400 020. Mumbai-400 093. Pan:Aadcr 2944 L (अपीलाथ" /Appellant) (""यथ" / Respondent) Revenue By:Shri Inder Solanki Assessee By: Shri Vijay Mehta सुनवाई की तारीख / Date Of Hearing: 03.05.2016 घोषणा की तारीख / Date Of Pronouncement: 08.07.2016 आयकर अिधिनयम,1961 की धारा 254(1)के अ"ग"त आदेश Order U/S.254(1)Of The Income-Tax Act,1961(Act) लेखा सद" राजे" के अनुसार Per Rajendra, Am- Challenging The Order Dated 11.09.2013 Of The Cit(A)-15,Mumbai,The Assessee Has Filed The Present Appeal Raising Various Grounds Of Appeal.Assessee-Company, Engaged In The Business Of Manufacturing/Exporting Diamond Studded Jewellery, Filed Its Return Of Income On 24.09.2009.During The Assessment Proceedings, The Ao Found That The Assessee Had Entered Into Following International Transactions (It.S) With Its Associate Enterprises(Ae.S): Sn. Transaction Amount(Rs.) Method 1 Tnmm Sale Of Diamond Studded Jewellery (Receipt) 16,31,34,795/- 2 Purchase Of Cut & Polished Diamond (Paid) 90,46,660/- Tnmm 3 Purchase Of Findings (Paid) 8,20,390/- Tnmm

For Appellant: Shri Vijay MehtaFor Respondent: Shri Inder Solanki
Section 143(3)Section 254(1)

…submitted that the AO had made the addition without considering the details submitted by it and he did not make any attempt to analyze the same,that the reliance of the AO on the decision of the Hon'ble Supreme Court in the case of British Paints India Ltd. (188 ITR 44) was out of context,that from the statements submitted to the AO,vide letter dated 19.12.2011,the assessee had already added the overhead charges in valuing the closing stock of Finished Goods and Work-in-progress. 6.3After considering the submissions of the assessee,the FAA held that closing stock of gold of 4572 grams which was valued at Rs.532…

Mr. Sandeep Mangla, New Delhi vs. ITO, New Delhi

In the result, appeal of the assessee is partly dismissed on ground no

ITA 2099/DEL/2010[2006-07]Status: DisposedITAT Delhi01 Jul 2016AY 2006-07

Bench: Sri C.M.Garg, Jm & Sri O.P. Kant, Am Ita No. 2099/Del./2010 : Asstt. Year : 2006-07

For Appellant: Sh. Suresh Gupta, CAFor Respondent: Smt. Anima Barnwal, Sr. DR
Section 143(2)Section 40A(3)Section 68Section 69

…estate. Then the AO proceeded to estimate income from the property business. 9. From the impugned appellate order para 6.1, we note that the CIT(A) placing reliance on the judgment of Hon’ble Supreme Court in the case of CIT vs. British Paints India Limited 188 ITR 44(SC) held that it is the duty of the AO consider whether or not the books disclosed the true state of accounts and the correct income. The CIT (A) further noted that the assessee appellant faiUto give proper and correct details of sales, purchase, expenses and supporting evidence thereof resulting into invoking of provisions of section 145(3) of th…

M/S. Honda Siel Power Products Ltd., Gautam Budh Nagar vs. DCIT, New Delhi

In the result, both the appeals of the assessee-company are partly allowed for statistical purposes

ITA 551/DEL/2014[2009-10]Status: DisposedITAT Delhi13 Apr 2016AY 2009-10

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: S/Sh. Neeraj Jain, AdvFor Respondent: Sh. Armendra Kumar, CIT/ DR
Section 143(3)Section 144CSection 2Section 92B

…l/2000 & ITA No.3734/Del/2002) [Del ITAT] Reliance, is also placed on the following decisions, wherein it has been held that the provision made by the assessee towards obsolete and slow moving items was allowable deduction: • CIT v. British Paints India Ltd.: 188 ITR 44 (SC) • CIT v. Hindustan Zinc Ltd.: 291 ITR 391(SC) • ChainrupSampatram v. CIT: 24 ITR 481 (SC) • Hotline Tele Tube and Components Limited: 175 Taxman 286 (Del. HC) • CIT v. Hughes Communication India Ltd.: 215 Taxman 136 (Del. HC) 55 ITA Nos.551/Del./2014 & 636/Del./2015 • CIT v Becton Dickinson India (P.) Ltd.: 214 Taxman 636 (Del. HC) • CIT v…

DCIT vs. Sri. Chamundeshwari Sugar Ltd

In the result, appeal of the Revenue is treated as allowed for statistical purpose

ITA 1538/BANG/2013[1990-91]Status: DisposedITAT Bangalore18 Mar 2016AY 1990-91

Bench: Shri. Abraham P. George & Shri. Vijay Pal Raoi.T.A No.1538/Bang/2013 (Assessment Year : 1990-91) Deputy Commissioner Of Income Tax, Circle – 12(1), Bangalore .. Appellant V. M/S. Sri Chamundeshwari Sugar Ltd, No.76, Ulsoor Road, Bangalore 560 042 .. Respondent Pan : Aaccss004R Assessee By : Vikram Vijayaraghavan, Advocate Revenue By : Shri. Sunil Kumar Agarwala, Jcit Heard On : 08.03.2016 Pronounced On : 18.03.2015 O R D E R Per Abraham P. George:

For Appellant: Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. Sunil Kumar Agarwala, JCIT
Section 269

…lisable value to cost or market value, whichever was lower was to be accepted since the assessee had followed the new method consistently thereafter. As per the CIT (A) by virtue of the judgment of Hon’ble Apex Court in the case of CIT v. British Paints Ltd, [188 ITR 45], valuation of stock at cost or market price whichever was lower was an accepted method of valuation. Further as per the CIT (A), change in method of valuation was approved by the Board of Directors of the assessee. He thus deleted the addition made by the AO. 10. Now before us, Ld. DR submitted that the Hon’ble jurisdictional High Court had in t…

ACIT, New Delhi vs. M/S Dlf Ltd., New Delhi

ITA 3061/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

…that assesse is required to offer its profit for taxation on consistent method of accounting and not at the whims and fancies of the assesse. For this argument, he relied on the decision of Hon’ble Supreme Court in the case of CIT vs. British Paints Limited – 188 ITR 44 (SC). He further submitted that it is not the simple plots of land which are sold by the assesse but are developed plots of land and, therefore, provisions of Accounting Standard – 7 and 9 both are applicable. He further stated that all risk and reward of the plot of land passes to the buyer, according to the Guidance Note issued by the ICAI, even…

Dlf Ltd., New Delhi vs. Addl. CIT, New Delhi

ITA 2677/DEL/2011[2006-07]Status: DisposedITAT Delhi11 Mar 2016AY 2006-07

Bench: Shri A.T. Varkey & Shri Prashant Maharishi

Section 133ASection 142Section 143(2)Section 144Section 146Section 250

…that assesse is required to offer its profit for taxation on consistent method of accounting and not at the whims and fancies of the assesse. For this argument, he relied on the decision of Hon’ble Supreme Court in the case of CIT vs. British Paints Limited – 188 ITR 44 (SC). He further submitted that it is not the simple plots of land which are sold by the assesse but are developed plots of land and, therefore, provisions of Accounting Standard – 7 and 9 both are applicable. He further stated that all risk and reward of the plot of land passes to the buyer, according to the Guidance Note issued by the ICAI, even…

DCIT, New Delhi vs. M/S Vic Enterprises Pvt. Ltd., New Delhi

ITA 2863/DEL/2010[2006-07]Status: DisposedITAT Delhi22 Dec 2015AY 2006-07

Bench: Shri I.C. Sudhir & Shri L.P. Sahu Assessment Year: 2006-07 Deputy Cit, Vs. Vic Enterprises Pvt. Ltd., 4Th Floor, Punjabi Bhawan, Circle-17(1), New Delhi. 10-Rouse Avenue, New Delhi. (Pan: Aaacv0132B) (Appellant) (Respondent) Assessment Year: 2008-09 Asstt. Cit, Vs. Vic Enterprises Pvt. Ltd., 4Th Floor, Punjabi Bhawan, Circle-17(1), New Delhi. 10-Rouse Avenue, New Delhi. (Pan: Aaacv0132B) (Appellant) (Respondent)

For Appellant: Shri MP Rastogi, AdvFor Respondent: Shri Sumit Chandra Sharma, CIT- DR
Section 111ASection 143(3)Section 14A

…10(38). 10.2 The AO relied on the following case laws: , . • CIT vs. Associated Industrial Development Co. Ltd. 82 ITR 586 (Se) • Karampura Development Co. Ltd. Vs. CIT 44 ITR 362 (Se) • Dalmiya cements Ltd. vs. CIT 12 ITR 50 (Patna) • CIT vs. British Paints 188 ITR 44, 49 (SC). 11.1 The main contentions of the AR as gathered from the various submissions made are as under: • Shares of Dabur India Ltd. have been held as investment is by the assessee as a promoter for controlling interest for over two decades. This position was accepted by the Department up to A.Y. 2005-06. • The intention of the assessee is of pa…

Commissioner of Income Tax(C)-III vs. Svp Industries Ltd

ITA/495/2013HC Delhi03 Sept 2014
Section 3

…Rs. 3,04,39,626/- for the following reasons: “6. Excise duty in closing stock It is noticed that excise duly has not been included in the value of closing stock in compliance to the verdict of the Hon'ble SC in the case of C1T Vs British Paints Ltd. (188 ITR 44SC) holding that valuation of stock only at the actual cost of raw material/ finished goods and not taking into account the overhead charges is not a correct mode of valuation. Excise and custom duties' payable by the manufacture are manufacturing expenses and should go into calculation of production cost and closing inventory should includ…

The Commissioner of Income-Tax vs. M/S Glowtronics Ltd

ITA/750/2006HC Karnataka03 Aug 2012

Bench: B.V.PINTO,D.V.SHYLENDRA KUMAR

Section 145Section 260Section 260ASection 80H

…e Tribunal was correct in reversing the finding of the Assessing Officer which was confirmed by the CIT(Appeal) that Electron Guns and Electron Gun Heaters should be valued at Rs.36 and Rs.2.75 that is the cost as held by the Apex Court in British Paints (188 ITR 44) and section 145 of the Act. 2. Whether the Tribunal was correct in not taking into consideration the facts like the assessee treating the return goods on-par with other salable goods both in its accounts and exercise register and that the assessee’s methods of accounting had not 4 been found fault with further the earlier assessment years…

M/s. De vs. ons Pvt. Ltd

ITA/296/2006HC Delhi29 Nov 2010
Section 133(6)Section 271

…an assessee to adopt a hybrid system of accounting. It is also trite law that where a method of accounting has been consistently followed in the past, it may still be rejected by the Department. In Commissioner of Income-tax vs. British Paints (1991) 188 ITR 44, the Supreme Court observed that there was no estoppels in the matter of method of accounting consistently followed by the assessee and the Assessing Officer is not bound by the method followed in the earlier years, if 2010:DHC:5727-DB ITA No.367/2004 & 296/2006 Page 20…

M/S De vs. Ons Pvt Ltdvs.Commissioner of Income Tax &

ITA - 367 / 2004HC Delhi19 Nov 2010
Section 133(6)Section 271

…an assessee to adopt a hybrid system of accounting. It is also trite law that where a method of accounting has been consistently followed in the past, it may still be rejected by the Department. In Commissioner of Income-tax vs. British Paints (1991) 188 ITR 44, the Supreme Court observed that there was no estoppels in the matter of method of accounting consistently followed by the assessee and the Assessing Officer is not bound by the method followed in the earlier years, if 2010:DHC:5593-DB ITA No.367/2004 & 296/2006 Page 20…