Gujarat High Court
M/S. Svm Cera Ltd vs Union Of India on 3 January, 2025
Author: Bhargav D. Karia
Bench: Bhargav D. Karia
NEUTRAL CITATION
C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025
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IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
R/SPECIAL CIVIL APPLICATION NO. 17565 of 2024
FOR APPROVAL AND SIGNATURE:
HONOURABLE MR. JUSTICE BHARGAV D. KARIA
and
HONOURABLE MR.JUSTICE D.N.RAY
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Approved for Reporting Yes No
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M/S. SVM CERA LTD. & ANR.
Versus
UNION OF INDIA & ANR.
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Appearance:
MR HASIT DAVE(1321) for the Petitioner(s) No. 1,2
MR ANKIT SHAH(6371) for the Respondent(s) No. 1,2
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CORAM:HONOURABLE MR. JUSTICE BHARGAV D. KARIA
and
HONOURABLE MR.JUSTICE D.N.RAY
Date : 03/01/2025
ORAL JUDGMENT
(PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA)
1. Heard learned advocate Mr. Hasit Dave for the petitioners and learned advocate Mr. Siddharth Dave for learned advocate Mr. Ankit Shah for the respondents appearing on advance copy.
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2. By this petition, under Article 227 of the Constitution of India, the petitioner has challenged the Order-in-original dated 24.09.2024 passed by the respondent No.2- Commissioner of Central Excise and CGST- II, Vadodara.
3. Brief facts of the case are as under:
3.1 The petitioner is engaged in the manufacture of Ceramic Glaze Mixture (Frit) falling under Chapter 32 of the Schedule to the Central Excise Tariff Act,1985. The DGCEI, on the basis of the inquiry, made an investigation in the Year 2008 and issued a show-cause notice dated 27.03.2010 which was replied by the petitioner and such show-cause notice was adjudicated by the then Commissioner of Central Excise and Customs, Surat-II vide Page 2 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined the Order-in-original dated 08.01.2013 holding as under:
"(i) Confirmed and ordered recovery of Central Excise duty amounting to Rs. 2,93,95,281/[Rupees Two Crore Ninety Three Lakhs Ninety Five Thousand Two Hundred Eighty One only) short paid by M/s SVM Cera Tea Limited by way of undervaluation under proviso to sub-section (1) of Section 11A.
(ii) Confirmed and ordered recovery of Central Excise duty amounting to Rs.7,25,92,302/(Rupees Seven Crores Twenty Five Lakhs Ninety Two Thousand and Three Hundred Two only] not paid by M/s SVM Cera Tea Limited by way of clandestine removal under proviso to sub-Section (1) of said Section 11A of Central Excise Act.
(iii) Appropriated the amount of Rs.
25,00,000/[Rupees Twenty Five Lakhs) paid by M/s. SVM during the investigation against the aforesaid demand of duty amounting to Rs. 10,19,87,583/(i.e. 2,93,95,281/- Rs.7,25,92,302/-).
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(iv) Ordered recovery of Interest as applicable rate on the above duty, mentioned at Sr. No. (i) &
(ii) above, under the provisions of Section 11AB of the Central Excise Act, 1944.
(v) Imposed Penalty amounting to Rs. 10,19,87,583/-on M/s SVM Cera Tea Limited under the provisions of Section 11 AC of the Central Excise Act, 1944 and Rule 25 of Central Excise Rules, 2002.
(vi)In terms of proviso to Section 11AC ibid in case, the duty amount alongwith interest and the reduced penalty amount is paid within 30 days of the receipt of the order, then the amount of penalty shall be:
reduced to 25% of the amount confirmed at S.No. (v) above.
(vii) There shall be no penalty on Shri K. M. Bhandari."
3.2 Being aggrieved by the aforesaid order, the petitioner filed Excise Appeal No. 10320/2013 and cross appeal was also filed by the department being Excise Page 4 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined Appeal No. 10999/2013 before CESTAT, Ahmedabad.
3.3 The CESTAT, by order dated 25.10.2023, disposed of both the appeals holding as under:
"4. On careful consideration of the submission made by both the sides and perusal of record, we find that the appellant in the reply raised specific issue that certain documents relied upon/non relied upon were not provided to the appellant. The appellant also requested for cross-examination of the witnesses whose Statements were heavily relied upon to confirm the charge of clandestine removal and consequential demand of Excise duty. We find that from the entire adjudication order the Adjudicating Authority has not given any heed to the request of the appellant in as much as they have specifically asked to provided relied upon/ Non relied upon documents and cross examination of the witnesses. We prima facie find that the case is mainly based on statements of various persons. it is statutory mandate in terms of Section 35D of the Central Excise Page 5 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined Act, 1944 that the Adjudicating Authority that it ts incumbent upon the Adjudicating Authority to examine/cross examine the witnesses before accepting the statements of those witnesses as evidence for adjudication of the case. in the present case even despite retraction by the witnesses the adjudicating authority has not granted the cross examination of the witnesses. In this fact the entire order of the Adjudicating Authority based on mainly statements of the various persons, without allowing cross examination, is not sustainable. Accordingly, we are of the view that the adjudicating authority must allow the cross-examination of the witnesses and also provide the documents required by the appellant, if not earlier provided. We find that the adjudicating authority has gravely erred in violating the principles of natural justice. Therefore, the order without following the principle of natural justice cannot be sustained as held by the Apex Court in number of judgments.
5 We are therefore of the view that entire matter needs to be reconsidered. Hence, we set aside the impugned order and remand the matter to the Adjudicating authority for passing a fresh de-novo order, Since the matter is very old of the Page 6 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined period 2004-05 to 2007-08 it is expected from the Adjudicating Authority to pass the de novo order within a period of three months from date of this order. Needless to say that after making all efforts for providing all documents and allowing the cross examination, the Learned Adjudicating Authority is net precluded from passing a de-novo order on the basis of the records available. The appeals are allowed by way of remand to Adjudicating authority. MA also stands disposed of)"
3.4 Pursuant to the remand, the respondent No.2 proceeded further with the adjudication process and after hearing the representative of the petitioner and considering the submissions made on behalf of the petitioner, passed the following order:
"ORDER
(i) I confirm the demand of Central Excise duty of Rs.
7,25,92,302/-. (Rupees Seven Crores Twenty Five Lakhs Ninety Two Thousand Three Hundred Two only) not paid on Ceramic Glaze Mixture (called as Page 7 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined frit) clandestinely cleared by them as detailed in Annexure F-5 to the show cause notice and order the same to be recovered from M/s. SVM Cera Tea Ltd., Ankleshwar under the provisions of Section 11A of the Central Excise Act, 1944, by invoking extended period of 5 years as per proviso to sub-section (1) of Section 11A ;
(ii) I also confirm the demand of Central Excise duty amounting to Rs. 4,64,64,274/(Rupees Four Crores Sixty Four Lakhs Sixty Four Thousand Two Hundred Seventy Four only) not paid by them on Ceramic Glaze Mixture (called as frit) by way of undervaluation, as detailed in AnnexureF-1 to F-4 to the show cause notice, and order the same to be recovered from M/s. SVM Cera Tea Ltd., Ankleshwar under the provisions of Section 11-A of the Central Excise Act, 1944 by invoking extended period of 5 years as per proviso to sub-section (1) of said Section 11A.
(iii) I hereby order to appropriate the amount of Rs. 25,00,000/[Rupees Twenty Five Lakhs only} paid, by M/s. SVM Cera Tea Ltd, Ankleshwar during the investigation, against the aforesaid demand of total Rs. 11,90,56,576/-.
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(iv) I order to recover the interest on the amount of duty confirmed above from M/s. SVM Cera Tea Ltd, Ankleshwar under the provisions of Section 11-AB of the Central Excise Act, 1944.
(v) I impose Penalty of Rs.
11,90,56,576/on M/s. M/s. SVM Cera Tea Ltd, Ankleshwar under Section 11- AC of the Central Excise Act, 1944 read with Rule 25 of Central Excise Rules'2002. However, in terms of the first proviso to Section 11AC of the Central Excise Act, 1944, where such duty as determined under sub-section (2) of Section 114, and the interest payable thereon under Section 11AB, is paid within thirty days from the date of communication of this order, the amount of penalty liable to be paid by them under this section shall be twenty-five percent of the duty j so determined. In terms of the second proviso to Section 11AC of the Central Excise Act, 1944, the benefit of such reduced penalty under the first proviso shall be available if the amount of penalty so determined has | also been paid within the period of thirty days referred to in that proviso."
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4. Learned advocate Mr. Hasit Dave for the petitioner submitted that the order passed by the respondent No.2 is in flagrant breach of the principle of natural justice as the opportunity to cross-examine the witnesses was not provided though it was directed by the CESTAT that failure to provide the opportunity to cross-examine the witnesses would be in violation of principle of natural justice. 4.1 Learned advocate Mr. Dave invited the attention of the Court that the CESTAT, in order of remand, has directed the respondent No.2 to make all efforts of providing all documents and allowed the cross-examination and thereafter, passed a de novo order on the basis of the records available.
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NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined 4.2 It was submitted that the respondent No.2 granted only one opportunity of cross-examination by issuing the notice to Ten witnesses to be remained present on 21.08.2024 i.e. five witnesses at 11.45 am and another five witnesses at 3.30 p.m. It was submitted that usually three opportunities are given to the witnesses to remain present. However, the respondent No.2 did not provide any further opportunity for cross- examination of the witnesses resulting into breach of principle of natural justice.
4.3 Learned advocate Mr. Dave submitted that though the petitioner demanded various documents from the respondent No.2 pursuant to the direction Page 11 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined issued by the CESTAT, the respondent No.2, without considering the request made by the petitioner for documents required by the petitioner to defend the show-cause notice, contrary to the direction issued by the CESTAT, brushed aside such demand in para 7.1 of the impugned Order-in- original by observing that the show-cause notice with all relied upon documents were supplied to the petitioner and therefore, the request made by the petitioner is nothing but a delay tactic.
4.4 It was further submitted that in spite of the fact that in similar demand raised by the Excise Department being dropped by the CESTAT in nine other cases and the though the order of the CESTAT being confirmed by the High Court by dismissing appeals filed by the Page 12 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined department, respondent No.2 ignored such facts and order of the higher authorities and confirmed the demand in case of the petitioner. It was therefore, submitted that the impugned Order-in-original passed by the respondent No.2 is therefore, liable to be quashed and set aside on all the three counts i.e. (i) no adequate opportunity to cross-examine the witnesses was provided; (ii) respondent No.2 ignored the directions issued by the CESTAT for providing documents sought by the petitioner and; (iii) in the identical facts, the CESTAT allowed the appeals of the similarly situated assessees, the respondent No.2 ignored the same and proceeded to adjudicate the show-cause notice by raising the demand. Page 13 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025
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5. On the other hand, learned advocate Mr. Siddharth Dave for the respondent- authority submitted that there is alternative efficacious remedy available to the petitioner to challenge the impugned Order-in-original before the CESTAT raising all the contentions which are raised in this petition. It was submitted that respondent No.2 has followed the direction issued by the CESTAT by making suitable observations in the impugned order regarding supply of the documents as well as documents sought by the petitioner as well as the request for cross-examination made by the petitioner. Learned advocate Mr. Dave invited the attention of the Court to the observation made by the respondent No.2 in Paragraph No. 4.1.1 to point out that Page 14 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined learned advocates appearing for the petitioner requested to decide the matters on the lines of the judgement of the Tribunal in case of similar 13 parties and as per the additional submission filed by the petitioner as none of the witnesses remained present on 21.08.2024 pursuant to the notice issued by respondent No. 2 for cross-examination and accordingly, respondent No.2 proceeded for adjudication of the show-cause notice. It was submitted that if the petitioner is aggrieved by the impugned order on merits, the only remedy available to the petitioner is to prefer an appeal before the CESTAT. In support of his submissions, reliance was placed on the decision of this Court in case of Pramodgiri Premgiri Goswami vs. Union of India reported in 2024(0) AIJEL-HC 248470 Page 15 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined wherein, in similar facts, this Court relegated the petitioner to file appeal before the CESTAT for raising all the contentions which are raised before this Court.
6. Considering the submissions made by both the learned advocates for the respective parties, it is true that the CESTAT has remanded the matter to the respondent No.2 to supply the documents sought for by the petitioner as well as to provide the opportunity of cross-examination of the witnesses in compliance with the provisions of section 9D of the Central Excise Act,1944. The respondent No.2, pursuant to the order of remand made by the Tribunal, issued the notice to 10 witnesses to remain present on 21.08.2024, however, on 21.08.2024, none of the ten Page 16 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined witnesses remained present nor any request was made for adjournment, or any submissions were made by any of the witnesses. The respondent No.2 therefore, recording the statement made by learned advocates appearing for the petitioner for hearing, proceeded to adjudicate the show- cause notice. Paragraph No. 4.1.1 of the impugned order reads as under:
"4.1.1 Accordingly, on 21.08.2024, when the matter was posted for cross- examination, none of the above persons appeared nor have submitted any request for adjournment or submitted any submission. Shri K.V. Subrahmanyam Advocate and - Shri K.M. Bhandari CEO, appeared and requested to decide the matter on the lines of judgment by Tribunal in case of similar 13 parties and as per their additional submission today. Shri K.M. Bhandari ji stated that he joined company in April 2007 an case pertains to 2003-04 - 2007-08. He is just an employee and having no interest in company except for salary. Appointment letter copy produced by him and taken on record."Page 17 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025
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7. With regard to supply of the documents and providing cross-examination, respondent No.2 has observed in Paragraph Nos. 7.1 and 7.2 as under:
"7.1 Accordingly, in view of the above directions, noticee was asked vide this office letter dated 14.05.2024 to specifically list the documents needed which department is to supply. They supplied list on 31.07.2024 during the PH in the form of written submission and it was noticed that the list only contained the documents already supplied to them as RUD. There is no dispute on the receipt of show-cause notice along with all RUDs by the noticee, therefore this request seems to be a delaying tactic only. In view of the above discussion, it is evident that the spirit of the Tribunal's judgment has been completely followed and there is no fresh document, which still needs to be provided to them.
7.2 With regard to Cross examination of the witnesses, during the course of personal hearing on 31.07.2017, the cross examinations of 10 witnesses was allowed Page 18 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined as detailed above in para 4 to 4.1.1. However, none of the witnesses responded to the notices issued to them for appearing on 21.08.2024. In fact, in some of the cases, the notices sent to their address available on records appears to be either closed or shifted. Since, matter is very old pertaining to the period 2004-05 to 2007-08 accordingly, after allowing their request for cross examination, the remand proceeding is proceeded with based on records available as agreed to as well by the noticee detailed in para 4.1.1 above. Therefore, this direction of the Hon'ble Tribunal is waived"
in view of the request of the noticee only; who wishes to conclude the matter without further wait on the basis of available records on merit."
8. With regard to issue of following the decision of the CESTAT in similar cases, the respondent no.2 has observed as under:
"11.3 In this regard, I also find that the noticee in their submission placed reliance on the decision of Hon'ble Tribunal in case of Belgium Glass & Ceramics Pvt. Ltd. v. Commissioner reported in 2015 (5} Page 19 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined TMI 528-CESTAT for setting aside the demand of central excise duty. The noticee contended that all the cases are based on similar investigation conducted in the analogous manner relating to clandestine removal is based on excess fuel consumption and undervaluation would be covered by the aforesaid final order of the Hon'ble Tribunal. They also claimed that revenue filed appeal before the Hon'ble High Court of Gujarat who dismissed the appeals filed by the Revenue as reported in Commissioner v. Belgium Glass & Ceramics Pvt. Ltd. - 2017 (356) ELT A 46 (Guj.).
11.3.1 On considering their above plea, I find that the said matter is sub-judice before Hon'ble Supreme Court by way of Departmental Civil Appeal No. 003133 - 003135 / 2018 Registered on 19-03-2018 along with 7 other tagged appeals.
11.3.2 Further, I also find that each offence case based on the evidence brought on record needs to be weighed against the counter evidence adduced by the litigant assessee in their defence and thereafter the final conclusion can be drawn. It is in this context, I hold that the evidence discussed above not only at the end of the noticee but when the same were correlated with the incriminating Page 20 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined evidence found at the end of their buyers are getting matched, makes no room for any other conclusion as drawn. above in relation to both clandestine removal and undervaluation resulting into evasion of central excise duty running into crores. Moreover, when the same were duly corroborated with the corresponding statements of the authorized personnel of the respective assessees who have not only explained the incriminating documents but also admitted about their contumacious conduct in such an evasion. As against the same, the noticee's submission are merely based on theoretical pleas without controverting the above factual evidence which are treated by them as stray instances or no evidence at all. The facts of the relied upon cases, the evidence thereto, their gravity and corresponding defence adopted by those litigant assessees are not before me to draw a parallel. Infact, I also find that had the entire investigation and its manner of conduct was so similar then they would have succeeded in their appeal which is not the case on hand. Hence, it proves beyond doubt that each offence case is distinct even though based on the same modus operandi yet each thread of evidence when put against the controverting evidence in defence which unfortunately is lacking jn Page 21 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined this case on hand, results into knitting of open and shut case against the noticee. Accordingly, such a reliance is not helping their case and is distinguishable on the facts and circumstances discussed above thread barely."
9. From the above observations made by the respondent No.2 in the impugned Order-in- original, it appears that the respondent No.2 has taken into consideration all the grievances of the petitioner with regard to the violation of principle of natural justice which are again reiterated in this petition. Be that as it may, we are not inclined to entertain this petition on the ground of breach of principle of natural justice in view of the above observation made by respondent No.2 which may be considered by the CESTAT in the appeal which may be filed by the petitioner under Page 22 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined section 35E of the Central excise Act,1944.
10. This Court, in case of Pramodgiri Premgiri Goswami vs. Union of India (supra), in similar situation, has observed as under:
"59. It also appears from the record that after the hearing which took place on 12.10.2021 and submission of reply on behalf of the petitioner, no further hearing was scheduled by the adjudicating authority and the impugned order was issued on 29.11.2021 without deciding the request of the petitioners to grant cross- examination.
60. The decision relied upon by the petitioners in support of the request for cross-examination resulting into violation of principle of natural justice as well as there are also decisions relied upon on behalf of the respondent that whether to grant cross-examination to the petitioners is a matter of discretion of the adjudicating authority which can be considered in the Order-in-Page 23 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025
NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined original. Thus, there are two sets of decisions appearing on the record of these petitions wherein in one of the set it is held that granting of cross-examination is violation of principle of natural justice whereas on the side of the respondent, the decision cited clearly shows that when there is an alternative efficacious remedy is available to the petitioner, such ground can be taken by the appellate authority as the appellate authority is nothing but an continuation of the original proceedings.
61. Therefore, it would be necessary to refer to the various decisions vis-a-vis facts emerging from the record as to in the facts of the case whether the petitioners can raise such issue of cross- examination, supply of documents before the appellate authority or not."
11. Needless to say, that we have refrained ourselves from going into the merits so as to enable the petitioner to raise all the contentions which are raised in this petition otherwise the right of the petitioner would be jeopardized by any Page 24 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025 NEUTRAL CITATION C/SCA/17565/2024 JUDGMENT DATED: 03/01/2025 undefined observations to be made by this Court on merits.
12. In view of the foregoing reasons, the petition is not entertained though it may be maintainable under Article 226 of the Constitution of India with liberty to the petitioner to approach CESTAT challenging the impugned Order-in-original. We also observed that the time spent by the petitioner before this Court to be considered as bona fide by the CESTAT, if the petitioner file appeal before the Tribunal in accordance with law within four weeks from today without raising issue of delay. The petitioner is at liberty to raise all the contentions which are raised in this petition before the CESTAT which shall be considered in accordance with law.
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13. With the aforesaid observations, the petition is disposed of. No order as to costs.
(BHARGAV D. KARIA, J) (D.N.RAY,J) JYOTI V. JANI Page 26 of 26 Uploaded by JYOTI V. JANI(HC00213) on Wed Jan 22 2025 Downloaded on : Fri Jan 31 21:48:22 IST 2025