AJAY WADHWA W-107, GREATER KAILASH-1 NEW DELHI Mb 9818653331 41554222 AND 41554243.

AJAY WADHWA AJAY WADHWA W-107, GREATER KAILASH-1 W-107, GREATER KAILASH-1

NEW DELHINEW DELHIMb 9818653331Mb 9818653331

41554222 AND 4155424341554222 AND 41554243

APPEALSAPPEALS

22

Appeal before Commissioner of Appeal before Commissioner of Income-taxIncome-tax

Section 246A – Appealable ordersSection 246A – Appealable orders Section 248 – Appeal by person Section 248 – Appeal by person

denying denying liability to tax liability to tax Section 249 – Form of appeal and Section 249 – Form of appeal and

limitation limitation Section 250Section 250 - Procedure in appeal- Procedure in appeal Section 251 – Powers of CIT(A)Section 251 – Powers of CIT(A)

IssuesIssues Payment of admitted tax – SectionPayment of admitted tax – Section 249(4)249(4)

Unless good and sufficient cause otherwise dismissal Unless good and sufficient cause otherwise dismissal in limine. in limine.

Pending refund/direction of Court to be given effect to Pending refund/direction of Court to be given effect to while calculating tax. Nokia Corporation 292 ITR 22 while calculating tax. Nokia Corporation 292 ITR 22 (Del)(Del)

Tax does not include interest. Manojkumar Tax does not include interest. Manojkumar Beriwal 217 CTR 407 Bom. If law denying remedy-Beriwal 217 CTR 407 Bom. If law denying remedy-courts would save remedy if possible by interpretive courts would save remedy if possible by interpretive process. Tax doesn’t include interest S 2(43). process. Tax doesn’t include interest S 2(43).

Curable defect-Insufficient funds- sufficient causeCurable defect-Insufficient funds- sufficient cause82 TTJ 284 (Ahd).82 TTJ 284 (Ahd).Endeavor Industries 43 SOT 322 HYD- huge refund Endeavor Industries 43 SOT 322 HYD- huge refund due to assessee and he also paid tax after filing of due to assessee and he also paid tax after filing of appeal-adjustment permitted.appeal-adjustment permitted.

2.2. Curing of irregularity – Curing of irregularity – – Appellants Appellants signature – unsigned memo - Rajendra signature – unsigned memo - Rajendra

kumar Maneklal Sheth 213 ITR 715 (Guj), kumar Maneklal Sheth 213 ITR 715 (Guj), – 276 ITR 1 (Del): Rule 45- Memo signed by AR-276 ITR 1 (Del): Rule 45- Memo signed by AR-

procedural irregularity-curable-liberal interpretation.procedural irregularity-curable-liberal interpretation.

3.3. Power of enhancement Power of enhancement CIT A has no power to enhance by discovering CIT A has no power to enhance by discovering new source of income, not mentioned in return, new source of income, not mentioned in return, or considered in asstt, or considered by AO.or considered in asstt, or considered by AO.Sardari Lal 251 ITR 864 (Del) FB, CIT v Union Sardari Lal 251 ITR 864 (Del) FB, CIT v Union

Tyres Tyres 240 ITR 556 Del,240 ITR 556 Del, – Net loss converted to profit by rejecting books and Net loss converted to profit by rejecting books and

estimating high GP rate-CIT A sought to enhance by estimating high GP rate-CIT A sought to enhance by taxing unexplained investment-impermissible. CIT v. taxing unexplained investment-impermissible. CIT v. Rai Bahadur Hardunoy 66 ITR 443(SC)Rai Bahadur Hardunoy 66 ITR 443(SC)

– Nibheram Daluram 127 ITR 491 Something in AO to Nibheram Daluram 127 ITR 491 Something in AO to show he applied mind to subject matter with a view show he applied mind to subject matter with a view to its taxability or non taxabilityto its taxability or non taxability

– Base decision: Shapoorji Pallonji Mistry 44 ITR 891 SCBase decision: Shapoorji Pallonji Mistry 44 ITR 891 SC

– Taxing remittances from abroad- 23 SOT 227 Taxing remittances from abroad- 23 SOT 227 CochCoch

– AO taxes notional income-CIT A deletes notional AO taxes notional income-CIT A deletes notional income and disallows expenses – not valid 49 income and disallows expenses – not valid 49 ITD 534 ITD 534

4. Inherent power to stay4. Inherent power to stay

Paulsons Litho Works v. ITO (1994) 208 ITR 676 Paulsons Litho Works v. ITO (1994) 208 ITR 676 (Mad)(Mad)

5. Condonation of delay5. Condonation of delay..

Wrong legal advise, compelling reasons, illness….Wrong legal advise, compelling reasons, illness….

Royal Airways – 98 TTJ 665 (Del)/ 98 ITD 259Royal Airways – 98 TTJ 665 (Del)/ 98 ITD 259

Concord of India Insurance Co. 118 ITR 507 (SC)Concord of India Insurance Co. 118 ITR 507 (SC)

law of limitation not to destroy rights of parties, law of limitation not to destroy rights of parties, Mst Katiji 62 CTR 23 SC, Mst Katiji 62 CTR 23 SC,

6. CIT(A) – Decision of Tribunal – binding6. CIT(A) – Decision of Tribunal – binding

Article 141 of Constitution - Doctrine of stare Article 141 of Constitution - Doctrine of stare decisis decision , CIT v. Godavari Devi 113 ITR 589 decisis decision , CIT v. Godavari Devi 113 ITR 589 (Bom).(Bom). ITAT anywhere has to respect High Court though ITAT anywhere has to respect High Court though of difference state particularly if no contrary of difference state particularly if no contrary decision of any other High Court against 232 ITR decision of any other High Court against 232 ITR 771 (Del)771 (Del) Kamlakshi Finance 1992 Suppl (1) SCC 648Kamlakshi Finance 1992 Suppl (1) SCC 648Eagle Flask Industries 72 ITD 455 PuneEagle Flask Industries 72 ITD 455 PunePrasad & Co 45 TTJ 282 HydPrasad & Co 45 TTJ 282 HydRikhabchand 81 TTJ 964 PuneRikhabchand 81 TTJ 964 Pune

7. Prosecution of appeal7. Prosecution of appeal

(i)(i) Adjournments, power of attorneyAdjournments, power of attorney(ii)(ii) Paper bookPaper book(iii) Written submissions(iii) Written submissions(iv) Additional evidence applications (iv) Additional evidence applications

APPEAL EFFECTAPPEAL EFFECT No appeal against order of CIT A if tax effect 3 No appeal against order of CIT A if tax effect 3

lakhs or less, 10 lakhs or less against Tribunal lakhs or less, 10 lakhs or less against Tribunal order, Rs 25 lakhs or less if appeal against order order, Rs 25 lakhs or less if appeal against order of High Court. Instruction No 3 of 9of High Court. Instruction No 3 of 9thth February February 2011. 2011.

Except where revenue audit objection accepted Except where revenue audit objection accepted by Deptt, prosecution, constitutional validity, by Deptt, prosecution, constitutional validity, CBDT Circular decided against.CBDT Circular decided against.

Binding on tax authorities.Binding on tax authorities. Tax effect excludes interest.Tax effect excludes interest. Applies to pending appeals also and not only Applies to pending appeals also and not only

fresh appeals.fresh appeals.

Admission of additional evidence – Admission of additional evidence – Rule 46ARule 46A

Situations under which additional evidence maybe Situations under which additional evidence maybe admitted by the CIT (A):admitted by the CIT (A):

AO refuses to admitAO refuses to admit

Appellant prevented by sufficient cause to produce Appellant prevented by sufficient cause to produce evidence called for by AOevidence called for by AO

Appellant prevented by sufficient cause any evidence Appellant prevented by sufficient cause any evidence relevant to ground of appealrelevant to ground of appeal

where the AO has made the order appealed against where the AO has made the order appealed against without giving sufficient opportunitywithout giving sufficient opportunity

* * * * * * * * * ** * * * * * * * * *99

Interest of justice – Prabhavati S. Shah 231 ITR 1, 68 TTJ 722 Interest of justice – Prabhavati S. Shah 231 ITR 1, 68 TTJ 722 (Rajkot). (Rajkot).

Bonafide impression that AO satisfied with reply as no query raised: Bonafide impression that AO satisfied with reply as no query raised: HLS Asia 121 TTJ 340 Del.HLS Asia 121 TTJ 340 Del.technical considerations are pitted against the cause of substantial technical considerations are pitted against the cause of substantial justice it is the cause of substantial justice that must prevail. Collector justice it is the cause of substantial justice that must prevail. Collector Land Katji, 167 ITR 471 (SC)Land Katji, 167 ITR 471 (SC)Assessee was prevented by sufficient cause in not appearing due to Assessee was prevented by sufficient cause in not appearing due to confusion relating to jurisdiction of Assessing Officer - additional confusion relating to jurisdiction of Assessing Officer - additional evidence produced by assessee were justified- evidence produced by assessee were justified- [2014] 41 taxmann.com [2014] 41 taxmann.com 282 (Punjab & Haryana) CIT Vs Safari Bikes Ltd.282 (Punjab & Haryana) CIT Vs Safari Bikes Ltd.No infirmity in the admission of the new evidence by theCIT(A) as the No infirmity in the admission of the new evidence by theCIT(A) as the interest of the quasi-judicial proceedings is to render justice and not to interest of the quasi-judicial proceedings is to render justice and not to deny justice by declining to admit new evidence. Income-tax Officer v. deny justice by declining to admit new evidence. Income-tax Officer v. Bhagwan Dass, Contractor (ITAT- Chandigarh)Bhagwan Dass, Contractor (ITAT- Chandigarh)Additional evidence which is in the interest of justice and renders Additional evidence which is in the interest of justice and renders assistance to the authority in passing order, may be admitted. Dwarka assistance to the authority in passing order, may be admitted. Dwarka Prasad v. ITO 63 ITD 1Prasad v. ITO 63 ITD 1

1010

Draft Application under Rule 46ADraft Application under Rule 46A

Date – 05.05.2014

The Commissioner of Income-tax (Appeals)-31,

A.R.A. Centre,

E-2, Jhandewalan Extn,

New Delhi – 110055 

Sub: M/s ABC Ltd - A.Y. 2012-13 – Additional evidence u/r 46A of the Income-tax Rules, 1962

May it please your honour,

I. The appellant humbly prays for admission of the following additional evidence in respect of Ground Nos. 4 and 5 taken before your honour:-

Ground no 1 - Regarding Foreign Travel: 

a) Details and bills and vouchers from PB 1 to 192 

b) Regarding Local Travel: 

c) Details and bills and vouchers from PB 193 to 311

1111

Ground No 2- Regarding Contest expenses:Details and Bills and vouchers from PB 312 to 443

II. Assessee was prevented by sufficient cause to produce evidence called for by the AO:

(i) It is respectfully prayed that during the course of assessment proceedings, the Assessing Officer had sought details of expenses relating to foreign and inland travel and contest expenses in respect of A.Y. 1998-99 which were promptly filed. However, the copies of invoice of air tickets, stay in hotels, bills of inland travel etc could not be furnished during the course of assessment proceedings

(ii) It was explained to the Assessing Officer that the matter is more than 20 years old and therefore, it would not be possible for the company to locate records relating to travel undertaken by its employees and so also the contest expenses. However, the Assessing Officer did not consider the plea of the assessee and proceeded to make huge additions under the head ‘Traveling’ and contest expenses for want of vouchers.

(iii) It is respectfully submitted that besides the matter being more than 20 years old, the management of the company has changed hands and even the offices from which the company was functioning, has changed on at least 3-4 occasions. Your honour will also appreciate that the company is not expected in law to keep records exceeding 6 previous assessment years and it would be impossible to maintain vouchers over a span of 20 years and above.

(iv) However, since the Assessing Officer was not satisfied with the details of expenses and only wanted the original vouchers, the company has since deployed a number of employees to look into the various records of the company and go as far back as possible. With great efforts, the vouchers relating to travel and contest expenses have been located and are being enclosed herewith for your kind consideration.

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III. The case of the appellant falls under clause (c) of Rule-46A(1) of the Income-tax Rules, 1962 whereby it can be stated that the appellant was prevented by sufficient cause from producing the evidence which the AO wanted as there was hardly any time to get the said evidence and the appellant was also not sure whether the said evidence could be made available at all or not.

IV. Your honour will further appreciate that this evidence is crucial and its consideration and appraisal would render the substantial justice to the appellant.

V. Reliance is placed on:a) The Hon'ble Delhi High Court’s judgment in the case of CIT v. Virgin Securities and Credits P. Ltd (2011) 332 ITR 396 (Del) wherein the Hon'ble Court held that the CIT(A) should admit the additional evidence if he finds that the same is crucial for the disposal of the appeal. It may be appreciated that the Assessing Officer rejected the claim of the expenditure on the ground that vouchers could not filed. Hence vouchers are crucial piece of evidence for rendering substantial justice. The same has been found after great efforts and it is accordingly prayed that they may be admitted.

b) Reliance is also placed on the Hon'ble Delhi High Court’s judgment in the case of Chandrakant Chanu Bhai Patel 202 Taxman 262 wherein it has been held that if additional evidence is without any blemish and in order to advance the cause of justice, the same ought to be admitted.

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c) It has been held that the judicial authorities must passed orders effectively and the objective is to unfold the actual controversy and apprise the correct facts so that there is no miscarriage of justice. Therefore, if the documents sought to be produced are of such a nature that they render assistance to the authorities in passing order or are required to be admitted for any other substantial cause, it would be the duty of the appellate authority to admit them. This proposition was law upheld by the Hon’ble Tribunal in the case of Abhay Kumar Shroff V/s. Income-tax Officer 63 ITD 144(Pat) where in, the Tribunal admitted additional evidence even when not even a whisper of the same was made before the first appellate authority.

d) The Hon’ble Mumbai High Court in the case of Smt. Prabhavati S. Shah V/s. CIT, 231 ITR 278 held that if the assessee had been informed by the ITO in the course of the assessment proceedings that he was not inclined to accept the loans as genuine because of the non availability of the creditors, the assessee could have tried to satisfy him about the genuineness of the loan by producing other evidence. Therefore, the additional evidence sought to be filed under Rule 46 A was admissible.

e) The Hon’ble Supreme Court in the case of Collector Land Katji, 167 ITR 471 (SC) have held that when technical considerations are pitted against the cause of substantial justice it is the cause of substantial justice that must prevail.

In view of the aforesaid it is prayed that the aforesaid additional evidence may kindly be admitted.

Thanking you,Yours faithfully

XYZ 1414

GROUNDS OF APPEAL AND BRIEF GROUNDS OF APPEAL AND BRIEF FACTSFACTS

To be specific and brief.To be specific and brief.

Can give alternative ground without prejudice.Can give alternative ground without prejudice.

Facts need not be very elaborate but must fill up the Facts need not be very elaborate but must fill up the columns.columns.

Should narrate that detailed submissions shall be filed at Should narrate that detailed submissions shall be filed at the time of hearing before Your Honoursthe time of hearing before Your Honours..

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Sample index of Paper bookSample index of Paper bookBefore The Commissioner of Income tax (A)- I, New Delhi

Block Period 1.4.96 to 17.10.2002 IT Appeal No – 123/11-12 SA

 Sh. ABC, vs. ACIT,560, Katra Ishwar Bhawan, Central Circle – 25,Khari Baoli, Delhi. New Delhi.

PAPER BOOK

1616

S.No. Particulars Page No.

1. Addition on account of Unaccounted personal expenses incurred by the assessee as per the Personal diary seized during the course of search:(a) Return of Income of Smt. Harsha Khanna and husband Sh. Pradeep Khanna for the block assessment years.

1-14

S.No Particulars Page no

2. Copy of Order Sheet15-17

3. Notice u/s 158BC dated 20.05.2003 18

4. Copy of notice u/s section 142(1) dated 07.10.2004 19-21

5. Reply to notice dated 13.10.2004 furnished to the A.O

22-25

6. Analysis of cash flow 26

1717

This is to certify that the above documents and material have already been furnished to the authorities.

Authorized Representative

Paper BookPaper Book Paper book containing pleadings and evidences Paper book containing pleadings and evidences

placed before assessing officer, be filed. describe placed before assessing officer, be filed. describe every document well in the paperbook, number every document well in the paperbook, number serially, advert attention of CIT(A) to the relevant serially, advert attention of CIT(A) to the relevant replies and documents, if paperbook large bind it replies and documents, if paperbook large bind it spirally, attach all relevant documents filed before spirally, attach all relevant documents filed before the AO on the issue along with written submissions the AO on the issue along with written submissions on the subject. on the subject.

Past history-an important evidence-but to be used Past history-an important evidence-but to be used carefully at this stagecarefully at this stage

Details given in past assessment can be made part Details given in past assessment can be made part of paper bookof paper book

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Written submissionsWritten submissions

– Start with “May it please Your Honour” or “Dear Start with “May it please Your Honour” or “Dear Sir” Sir”

– Submissions to be ground wiseSubmissions to be ground wise– Must state briefly what AO statesMust state briefly what AO states– Counter facts point wiseCounter facts point wise– Give case law and explain how it applies to your Give case law and explain how it applies to your

issue, issue, – Take copies of judgments reported in ITR, CTR, Take copies of judgments reported in ITR, CTR,

TTJ, SOT and others, give reference of PB folio.TTJ, SOT and others, give reference of PB folio.– Answer to query only if very sure on facts or law.Answer to query only if very sure on facts or law.

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Sample written submissionsSample written submissions

Dated – 05.05.2014

The Commissioner of Income-tax (Appeal)-II,Laxmi NagarDelhi – 110092 Sub: Appeal in the case of Mr. XYZ- A.Y. 2007-08 - Filing of submissions –

Regarding

 May it Please Your Honour,

The appeal for A.Y. 2007-08 has been filed against the assessment orders dated 30.12.2009 passed by ACIT, Central Circle-1 New Delhi u/s , 143(3) of the Income-tax Act, 1961. Details of income returned and assessed are given below:-

2020

A.Y. Income returned (Rs.)

Income assessed (Rs.)

2007-08 8,66,980 41,91,92,951

2. The details of additions made for A.Y. 2007-08 are given below:- (STATEMENT OF GROUND IN DISPUTE/AMOUNTS AND FACTS)

2121

Particulars Amount in Rs.

Share capital 2,18,74,410

Investment in ABCPvt.Ltd

16,98,38,020

Unexplained Cash30,95,190

Investment in Farms from Overseas Bank A/C

28,47,533

Unexplained Jewellery

1,20,73,114

3. Regarding addition of Rs. 2,18,74,410 as unexplained share capitalBrief Facts:

(i) The Assessing Officer sought evidence to prove the identity and creditworthiness of the persons related with the increase in the share capital, along with the genuineness of the transaction. The appellant gave complete details of shareholders to whom the shares were allotted giving interalia, their address, the number of shares allotted and the amount paid by them. The assessee also furnished the confirmation from the share holders, FIPB approval authorizing the company to raise share capital, copies of certificate of incorporation of foreign companies, copy of FIRC, copy of Form No. 2 filed with ROC etc.

(ii) The Assessing Officer has merely stated that the details furnished by the assessee do not prove the creditworthiness of the persons from whom the share capital has been raised and hence the addition of Rs. 2,18,74,410 as unexplained share capital has been made.(ALLEGATION OF AO)

4. Submissions:(i) During the course of assessment proceedings, the appellant gave the following

details/evidences to establish the genuineness of the share capital:- Details of share holders along with the number of shares applied for and

allotted (p.28 & 33/PB) Copy of ledger account of share capital (p. 23/PB) Comprehensive confirmation of Remittance (p. 51-52/PB) -This is a

confirmation by Admin Management Inc, one of the directors of M/s XYZ Holdings Ltd who have confirmed having remitted share capital US$ 550000/- to the appellant company towards subscription for equity shares to be issued in the manner directed by the Foreign Investment Promotion Board of India.

2222

FIPB approval dated 16.09.1998 and amendments - (p.40-45) share capital has been received as per the approval received by the

Government of India, the Department of Economic Affairs, FIPB. Foreign Collaboration approval - Request for increase in paid up capital of

Rs. 5 crores (p. 46/PB) Memorandum and Article of Association of M/s XYZ Co. Ltd. duly notarized by

the Dy. Governor of British Virgin Islands (p. 85-102/PB) - This clearly establishes the existence of foreign share holders as a company registered in British Virgin Islands

Copy of the Certificate of Incorporation (p. 35-39/PB) Certificate of Foreign Inward Remittance (p. 48-50/PB)

Your honour will appreciate that in view of the documents described above, the genuineness of the share capital so introduced stands duly established.

(ii) The following Circular and case laws cited herein would also show that the appellant company has gone far beyond the normal burden of proof required to be discharged for establishing the bonafide of the share capital. In fact, nothing more can possibly be filed for establishing the share capital.

In terms of CBDT Circular No. 05, dated 20-02-1969, “Money brought into India by non-residents for investment or other purposes is

not liable to Indian income tax. The question of assessment to tax arises only when there is no evidence to show that the amount, in question, in fact represents such remittance”

2323

The Delhi Bench of the Tribunal in the case of DCIT v. Finlay Corporation Ltd (2004) 84 TTJ (Del) 788 has held as follows:-“As regards the question whether there is any conflict between provisions of section 5(2) and provisions of s.68 or s. 69, it is settled legal position that burden is on the Revenue to prove that income of an assessee falls within the net of taxation. Once it is so proved, then the burden is on the assessee to prove that such income is exempt from taxation.

The above findings of the Tribunal have been followed in the case of Saraswati Holdings Corporation Inv. V. DDIT (2007) 111 TTJ 334 (Del) wherein it was held that money brought in India by the assessee non-resident through banking channels for investment in shares could not be brought to tax as unexplained cash credit u/s 68 of the Income-tax Act, 1961 (p. 31/PB2).

The Tribunal followed the observation made by the Hon'ble Supreme Court in the case of UOI v. Azaadi Bachao Andolan (2005) 263 ITR 706 (SC).

The source of the source is not required to be established. In the case of TOLA RAM DAGA 59 ITR 632 it was held as under:I.  If third party confirms her deposit then assessee can’t be compelled to establish the source of her deposit.II.   Section 34 of the evidence act says that entries in books of account to be true.III.  Even if the deposit is from wife assessee not to have private knowledge of the source unless department establishes that he had knowledge.

  2424

In the case of ORIENT TRADING CO 49 ITR 723 BOM it was held that in a case where the entry stands in the name of the third-party, the assessee satisfies the income tax officer as to the identity of the third-party and also supplies such other evidence which will primafacie show that the entity is not fictitious, the initial burden which lies on him can be said to have been discharged. It will not thereafter be for the assessee to explain further how or in what circumstances the third-party obtained money in whole or why he came to make a deposit of the same with the assessee.

RAVALI TRADING 220 CTR 622 RAJ. It was held that once the existence of the creditors is proved and persons own the credits which are found in the books of the assessee, the assessees onus stands  discharged and the latter is not further required to prove the source from which the creditors would have acquired the money deposited with him and, therefore, the addition under section 68 cannot be sustained in the absence of anything to establish that the sources of the creditors deposit flew from the assessee itself.

Similar ratio was laid down in the case of LATE MANGILAL AGARWAL 300 ITR 372 (RAJ). S HASTIMAL 49 ITR 273 (MAD), NABADWIP CHANDRA ROY 44 ITR 591 (ASSAM), S N GANGULY 24 ITR 16 (PAT).

In the case of Nemi Chand Kothari – 264 ITR 254(Gau)-In this case the creditors didn’t show the creditworthiness of the sub creditors. It was held that the addition was not justified in hands of assessee as once the identity & fact that cheque was received is proved – onus shifts on the AO.

2525

The Delhi Bench of the Tribunal in the case of DCIT v. Finlay Corporation Ltd (2004) 84 TTJ (Del) 788 has held as follows:-

“As regards the question whether there is any conflict between provisions of section 5(2) and provisions of s.68 or s. 69, it is settled legal position that burden is on the Revenue to prove that income of an assessee falls within the net of taxation. Once it is so proved, then the burden is on the assessee to prove that such income is exempt from taxation. Section 5(2) being charging section, the burden is on the Revenue to prove that the income of the non-resident falls within the ambit of such section. On the other hand, the legislature has case the onus on the assessee to explain the source of money falling within the ambit of s. 68 or s. 69.

(iii) Treating the share capital as income is without any legal or factual basis and is merely the figment of the imagination of the Ld. Assessing Officer. Huge tax liability has been foisted upon the appellant in respect of some entries in the said two documents and the learned assessing officer has completely ignored the fundamental and basic principles of jurisprudence and natural justice. (MUST WRITE ABOUT OPPORTUNITY , NATURAL JUSTICE, ONUS, CONFIRMATION)

In view of the aforesaid and since the appellant company’s case is fully covered by the case laws as discussed above, the Ld. CIT(A) is requested to delete the addition.

Thanking you,Yours faithfully,

XYZ2626

Maintain diary of case lawsMaintain diary of case laws

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