Madras High Court
D.K.Sadasivam vs The Commercial Tax Officer on 21 January, 2025
Author: Anita Sumanth
Bench: Anita Sumanth
2025:MHC:577
W.P.Nos. 2061 & 2062 of 2012
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 21.01.2025
CORAM :
THE HONOURABLE DR.JUSTICE ANITA SUMANTH
and
THE HONOURABLE MR.JUSTICE G. ARUL MURUGAN
W.P.Nos.2061 & 2062 of 2012
and M.P.Nos. 1 & 1 of 2012
D.K.Sadasivam .. Petitioner
In both WPs
vs
1.The Commercial Tax Officer,
Commercial Tax Department,
Palakode Town & Taluk,
Dharmapuri District.
2.The Assistant Commissioner,
Commercial Tax Department
Palakode Town & Taluk,
Dharmapuri District.
3.The District Collector,
Dharmapuri District.
4.The Tamilnadu Industrial Investment
Corporation Limited,
No.692, Anna Salai,
Nandanam, Chennai – 600 035.
5.The Tamilnadu Industrial Investment
Corporation Limited,
No.1, Pennagaram Road,
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W.P.Nos. 2061 & 2062 of 2012
Dharmapuri – 636 702.
6.M/s.Jayam Food Processing Industries,
No.12, Sigaralhalli Division,
Nallanur, Pennagaram,
Dharmapuri. .. Respondents
In both WPs
Prayer in W.P.No. 2061 of 2012: Petition filed under Article 226 of the
Constitution of India praying to issue a writ of certiorari calling for the
records of the 1st respondent pertaining to the demand notice dated
12.01.2012, in respect of the property situate in S.Nos. 7/10, 7/11 and
13/1 in Sigarahalli Village, Pennagaram Taluk, Dharmapuri District and
quash the same.
Prayer in W.P.No. 2062 of 2012: Petition filed under Article 226 of the
Constitution of India praying to issue a writ of mandamus forbearing the
respondents 1and 2 from in anyway attaching or alienating the petitioner’s
property measuring an extent of acre 4.02 situate in S.Nos. 7/10, 7/11 and
13/1 in Sigarahalli Village, Pennagaram Taluk, Dharmapuri District.
For Petitioner : Mr.P.Valliappan
Senior Counsel
Mr.T.Deeraj
(in both WPs)
For Respondents : Mr.G.Nanmaran,
Special Government Pleader
for R1 and R2
No appearance for R3 to R6
(in both WPs)
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W.P.Nos. 2061 & 2062 of 2012
COMMON ORDER
(Order of the Court was made by Dr. ANITA SUMANTH.,J)
These two Writ Petitions have been filed by an individual, the
successful purchaser of the property at S.Nos. 7/10, 7/11 and 13/1 in
Sigarahalli Village, Pennagaram Taluk, Dharmapuri District (subject
property). The prayer in W.P.No.2061 of 2012 is for a Certiorari calling
for and quashing demand notice dated 12.01.2012 issued by the
Commercial Taxes Officer, Dharmapuri District/R1, in respect of the
subject property.
2. The prayer in W.P.No.2062 of 2012 is for a mandamus
forbearing R1 as well as the Assistant Commissioner of the Commercial
Taxes Department, Dharmapuri District/R2 from in any way attaching or
alienating the subject property. The District Collector is arrayed as R3.
The Tamil Nadu Industrial Investment Corporation at Chennai and
Dharmapuri is arrayed as R4/R5 (hereinafter referred to either as TIIC or
as R4/R5) and one Jayam Food Processing Industries is arrayed as R6
(hereinafter referred to either as R6 or assessee).
3. R3 to R6 are unrepresented before us and we have heard the
detailed submissions of Mr.P.Valliappan, learned Senior Counsel
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W.P.Nos. 2061 & 2062 of 2012
appearing for Mr.T.Deeraj, learned counsel for the petitioner and
Mr.Nanmaran, learned Special Government Pleader for R1 and R2.
Counters have been filed on behalf of R1/R2 as well as R4/R5.
4. From the pleadings as well as the submissions made by learned
counsel, the following facts emerge. R4/R5 had provided financial
assistance to R6 for setting up of a manufacturing project for fried gram.
The deed of hypothecation-cum-mortgage was executed qua R6 and R4 on
11.07.1991 in respect of the subject property admeasuring a total extent of
4.13 acres by way of security for the financial assistance extended. Out of
the total extent of 4.13 acres, 11 cents had been acquired by the
Government for widening of the road.
5. The Encumbrance Certificate that has been placed on record
reflects the creation of the charge on the subject property even as early as
on 11.07.1991/15.07.1991. There appears to have been defaults by R6 in
repayment of the financial facilities to TIIC and hence TIIC, invoking its
power under Section 29 of the State Financial Corporations Act, 1951 (in
short ‘SFC Act’), took possession of the subject property exercising the
power to sell.
6. Auction sale notice was issued on 24.09.2003 by TIIC offering
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W.P.Nos. 2061 & 2062 of 2012
various units held by TIIC for public auction through sealed tender. Item 3
thereof refers to the subject property and reads thus:
Name of the Location Activity Details of
Branch Assets
Dharmapuri Sigralahalli Mfr. of Fried Land 4.13
Branch Village Grams acres &
Konangihalli, Building
3. Jayam Near 21419 Sq.ft.
Food Thalapallam ACC Roof
Processing Village, 477 Sq.ft.
Unit Pennagaram TK RCC roofing
2978 sq.ft.
Aluminium
sheet roof
open well
8500 sq.ft.
drying yard
822 sq.ft.
MTR
Security
shed &
compound
wall with
Machinery
7. Our attention is specifically drawn by the learned Special
Government Pleader to the conditions in that auction sale notice to the
effect that ‘the assets of the following industrial units are offered for sale
‘AS IS WHERE IS CONDITIONS’ through public auction/sealed
tender at our branch offices’. Thus, according to him, the incident of
auction sale carried with it the liability to sales tax arrears as well.
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W.P.Nos. 2061 & 2062 of 2012
8. This would brings us to the rival claim of the Commercial Taxes
Department as put forth by the learned Special Government Pleader. He
would submit, relying on the counter filed, that the assessee has been in
arrears of sales tax in respect of periods 1993-94 to 1996-97 of a total
amount of Rs.4,61,29,779/-. The break-up is as follows:
Year Amount of arrears
1993-94 Rs.2282473.00
1994-95 Rs.11614553.00
1995-96 Rs.24587195.00
1996-97 Rs.764558.00
Total Rs.46129779.00
9. According to learned SGP, it is the Commercial Taxes
Department that is entitled to first claim upon the assets of the assessee, as
those arrears would constitute crown debts over which the Commercial
Taxes Department would hold priority and first charge.
10. In this regard, he would rely on the provisions of Section 24 of
the Tamil Nadu General Sales Tax Act, 1959 (in short ‘TNGST Act’),
specifically sub-sections (1) and (2) thereof as well as a slew of decisions
as follows:
(i) R.M.Arunachalam v Commissioner of Income-Tax, Madras1
(ii) Punjab Urban Planning and Development Authority and others
1 (1997) 7 SCC 698
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W.P.Nos. 2061 & 2062 of 2012
v Raghu Nath Gupta and others2
(iiv) United Bank of India v Official Liquidator and others3
(iv) State Tax Officer v Rainbow Papers Limited4
(v) R.S.Raghunath v State of Karnataka and another5
(vi) State Bank of Bikaner and Jaipur v. National Iron and Steel
Rolling Corporation and Others6 .
11. Learned Senior Counsel for the petitioner compares the
provisions of Section 24 of the TNGST Act and Section 26 E of the
Securitisation and Reconstruction of Financial Assets and Enforcement of
Security Interest Act, 2002 (SARFAESI Act) pointing out that Section
26E that deals with priority to secured creditors commences with the non-
obstante clause, as per which, notwithstanding anything contained in any
other law for the time being in force, after the registration of security
interest, the debts due to a secured creditor shall be paid in priority over all
other debts and all revenues, taxes, cesses and other rates payable to the
Central or State Government or local authority.
12. In this context, learned counsel for the petitioner would rely on a
decision of the Division Bench of this Court in the case of The Assistant
2 (2012) 8 SCC 197
3 (1994) 1 SCC 575
4 (2023) 9 SCC 545
5 (1992) 1 SCC 335
6 (1995) 96 STC 612 (SC)
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W.P.Nos. 2061 & 2062 of 2012
Commissioner (CT), Anna Salai III, Assessment Circle, Chennai v the
Indian Overseas Bank and others7 to the effect that it is the financial
corporation/financial institution that would hold priority in respect of the
debts.
13. That decision was rendered in the context of the rival claims of
the Financial Institution and the Commercial Taxes Department, applying
Section 26E of the SARFAESI Act and holding that the debts due to any
secured creditor shall be paid in priority over all other debts and all
revenues, taxes, cesses and other rates payable to the Central Government
or State Government or local authority.
14. We are given to understand that in a Special Leave Petition filed
by Indian Overseas Bank challenging the aforesaid order, the Supreme
Court has granted an order of status quo.
15. The petitioner draws attention to Section 29 of the SFC Act
which is the basis for auction sale by TIIC, and which reads as follows:
29. Rights of Financial Corporation in case of default .-
(1)Where any industrial concern, which is under a
liability to the Financial Corporation under an agreement,
makes any default in repayment of any loan or advance or
any instalment thereof or in meeting its obligations in
relation to any guarantee given by the corporation or
7 W.P.No.2675 of 2011 etc batch dated 10.11.2016 (MHC)
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W.P.Nos. 2061 & 2062 of 2012
otherwise fails to comply with the terms of its agreement
with the Financial Corporation, the Financial Corporation
shall have the right to take over the management or
possession or both of the industrial concern, as well as the
right to transfer by way of lease or sale and realise the
property pledged, mortgaged, hypothecated or assigned to
the Financial Corporation.
(2)Any transfer of property made by the Financial
Corporation, in exercise of its powers under sub-section
(1), shall vest in the transferee all rights in or to the
property transferred as if the transfer had been made by
the owner of the property.
……………”
16. This provision makes it clear that the Financial Corporation, in
this case TIIC, would hold the right to take over the management,
possession or both, of the industrial concern along with the properties
pledged, mortgaged, hypothecated or assigned to it. Sub-Section (2) states
that any transfer of the property mortgaged to TIIC, in exercise of its
powers under sub-Section (1), shall vest in the transferee (the auction
purchaser/petitioner herein), all rights in or to the property transferred, as
if such transfer had been made by the owner of the property.
17. The attempt of the petitioner before us is to state that the non-
obstante clause under Section 26E of the SARFAESI Act would prevail
over the provisions of Section 24 of the TNGST Act that are general in
nature, and the SARFAESI Act being a Special Act would override the
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provisions of the TNGST Act.
18. In R.S.Raghunath (supra), relied upon by the learned Special
Government Pleader, three Judges of the Hon'ble Supreme Court dealt
with the validity of certain promotions made in the Transport Department
in Karnataka. They were required to examine the provisions of the
Karnataka General Service (Motor Vehicles Branch) (Recruitment) Rules,
1976 and Karnataka Civil Services (General Recruitment) Rules, 1977. In
that context, they dealt with the purpose and effect of a non-obsante clause
in the general recruitment rules which specifically provided that those rules
would not be applicable to those State Civil Services that were governed
by express provisions under any law for the time being in force.
19. When the General Rules were enforced, the Special Rules were
already holding the field and hence the application of the General Rules
were excluded to the extent of the field being occupied by the Special
Rules. Two Hon'ble Judges held that the non-obstante clause in the
General Rules would not have an overriding clause in displacing the
Special Rules and the application of the Special Rules would continue,
with one Hon'ble Judge dissenting.
20. In the course of the discussion, the Bench observes as follows:
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11..........On a conspectus of the above authorities it
emerges that the non-obstante clause is appended to a
provision with a view to give the enacting part of the
provision an overriding effect in case of a conflict. But the
non-obstante clause need not necessarily and always be co-
extensive with the operative part so as to have the effect of
cutting down the clear terms of an enactment and if the words
of the enactment are clear and are capable of a clear
interpretation on a plain and grammatical construction of the
words the non-obstante clause cannot cut down the
construction and restrict the scope of its operation. In Such
cases the non-obstante clause has to be read as clarifying the
whole position and must be understood to have been
incorporated in the enactment by the Legislature by way of
abundant caution and not by way of limiting the ambit and
scope of the Special Rules.
21. Relying on the above conclusion, he would urge that both the
SARFAESI Act and the TNGST Act are special enactments and the
charge created under Section 24 of the latter would be equally efficacious
to protect the interests of the Sales Taxes Department.
22. The petitioner would also rely on a decision, authored by one of
us, in Corporation Bank v The Commissioner of Income Tax Department,
Investigation Building, Chennai and others8, which is in the context of a
similar rival claim, though advanced by the Income Tax Department in that
case. We do not think that this decision has any relevance to the present
matter.
8 W.P.No.27409 of 2019 etc batch dated 21.04.2021 (MHC)
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W.P.Nos. 2061 & 2062 of 2012
23. Though some tentative arguments have been advanced by
learned counsel for the petitioner to the effect that the petitioner is a
bonafide purchaser and his rights must be so protected, this has been
countered by learned Special Government Pleader by reference to the
decision of the First Bench of this Court in R.Balasubramanian v
Additional Deputy Commercial Tax Officer III, Thoothukudi9.
24. In that case too, it was the claim of the appellant that he was a
bonafide purchaser falling within the exempted category under Section 24-
A of the TNGST Act which deals with transfers to defraud the revenue.
The Bench has, by way of a crisp order, concluded that the question of
bonafides or otherwise of a purchaser cannot be gone into in a Writ
Petition under Article 226 of the Constitution of India as that would entail
marshalling and appreciation of factual matters that is best left to a Civil
Court.
25. Hence, they hold that the proper remedy for the appellant was to
approach the Civil Court to establish his rights, particularly his claim as
bonafide purchaser. The Appellant was relegated to regular suit as held in
Padma Coffee Works V. Commercial Tax Officer, Rockfort10.
9 W.A.(MD) No. 130 of 2005 dated 07.02.2008 (MHC)
10 114 STC 494
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26. With this, the door is closed on the tentative submissions of the
petitioner in regard to the bonafide nature of the transaction. We hence
restrict ourselves in this order to the legal issue relating to priority of
charge and now proceed to discuss the decisions cited by the parties.
27. In Rainbow Papers Limited (supra), the question decided related
to priority between a charge under the Gujarat Value Added Tax Act,
2003 and one in terms of the Insolvency and Bankruptcy Code, 2016. We
are not, in this case, concerned with the aforesaid two enactments.
28. Learned Special Government Pleader next relies on the
judgment in United Bank of India (supra) to state that it is the
responsibility of the purchaser to satisfy himself about the title,
encumbrances and other particulars of the property offered for auction as
the property was brought to auction on ‘AS IS WHERE IS BASIS’.
29. We are of the considered view in the present circumstances, that
the above stipulation cannot provide guidance, or be a parameter to decide
the legal question of priority of charge.
30. The auction purchaser, as part of expected due diligence, might
well have verified the Encumbrance Certificate prior to making a bid, in
which event, such Certificate would have revealed the prior charge of
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TIIC. Hence, it also cannot be said in this case that the auction
purchaser/petitioner has not been vigilant.
31. The judgment in Punjab Urban Planning and Development
Authority (supra) also relates to the condition of ‘AS IS WHERE IS
BASIS’, which we have dealt with in the paragraphs supra.
32. In the case of National Iron & Steel Rolling Corporation and
others (supra), the Supreme Court considered the priority held by the State
Bank of Bikaner and Jaipur qua that held by the Commercial Tax Officer.
The claim of the Commercial Tax Officer rested on Section 11AAAA of
the Rajasthan Sales Tax Act, 1954 which stated that notwithstanding
anything to the contrary contained in any law for the time being in force,
any amount of tax, penalty, interest and any other sum payable by a dealer
or any person under that Act, shall be the first charge on the priority of a
dealer, or such person.
33. This judgment has been taken note of by this Court in Tamilnad
Mercantile Bank Ltd. v. Commercial Tax Officer, South Avani Moola
Veethi Circle, Madurai11 and has been distinguished noticing the
difference in language between the relevant provisions under the
11 (2009) 23 VST 151 (Mad)
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W.P.Nos. 2061 & 2062 of 2012
Commercial Taxes enactments. The critical difference is that while
Section 24 creates a charge over all other claims, it is not as categoric as
the Rajasthan Sales Tax Act, which expressly states that the charge
created under the latter enactment shall be a first charge.
34. In the case of Tamilnad Mercantile Bank Ltd (supra), the rival
claims were by the Commercial Taxes Department and by the Banking
Institution. The assessee/respondent in that case had defaulted in payment
of tax and proceedings for recovery had been initiated as against the
property by the respondent in a sale under the provisions of the
SARFAESI Act.
35. The Court took note of the following judgments and discussed
the same in detail. i) E.T. & T.D. Corpn. Ltd. V. State of Rajasthan12, ii)
Dena Bank V. Bhikhabhai Prabhudas Parkesh and Co. and others13, iii)
State Bank of Bikaner & Jaipur V. National Iron and Steel Rolling
Corporation and others (supra), iv) Central Bank of India V. State of
Tamil Nadu14, v) Thane Janata Bahakari Bank Ltd. V. Commissioner of
Sales Tax and others15, vi) CST V. Radhakrishnan16, vii) Dattathreya
12(1999) 115 STC 545
13120 STC 610
14113 STC 145
15148 STC 32
16AIR 1979 SC 1588
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Sankar Mote and others V. Anand Chinthaman Datar and others17 and
viii) ICICI Bank Ltd. (formerly Bank of Madura Ltd.) V. Official
Liquidator, Liquidator of Vibrant Investments and Properties Ltd.18.
36. The relevant dates, being the date of creation of equitable
mortgage by deposit of title deeds in the Bank were noted as being
February, 1984. There is a finding of the Court that the orders of
assessment were passed only thereafter and hence the Court holds that
when the law in favour of the Bank had fructified even prior to the demand
being raised under the provisions of the TNGST Act, it is the anterior
charge created by the Bank that would prevail.
37. From a study of the above cases, it emerges that in matters of
the present nature, and in an era prior to the SARFAESI Act and Recovery
of Debts due to Banks and Financial Institutions Act, 1993, the relevant
factor would be to ascertain which of the contesting entities had registered
the charge first or, in other words, in which case, the charge was anterior.
17(1974) 2 SCC 799
182005 (1) CTC 758
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38. Section 26E was inserted by Act 44 of 2016, with effect from
24.01.2020. Hence, in our considered view the dates of registration of
charges is what should prove paramount in such circumstances, in a
decision relating to ascertainment of prior charge. Before us, the admitted
position is the charges registered by the TIIC are of 1991 vintage, whereas
the charges registered by the Commercial Taxes Department are of the
year 2005.
39. This can be determined simply by verifying the Encumbrance
Certificate which has been provided to us by the parties in their
compilation. A perusal of the Encumbrance Certificate sets out very
clearly that it is the TIIC which had registered the charge as early as on
11.07.1991 and 15.07.1991, whereas the charge registered by the
Commercial Taxes Department is only on 13.04.2005/18/04.2005. The
two entries in the Encumbrance Certificate are extracted below:
Certificate of Encumbrance on Property
TIIC:
Sl. Description of v/bfh/eh- Nature & Name of Vol.No DNo
No Prop./ DOE & Value/ Executants bjhFjp /P. M
t/ brhj;J gjpt[ ehs; jz;ik & vGjp No. vz;/
v tptuk; / DOR kjpg;g[ bfhLj;jth; gf;fk; Yr
z; (Survey No & (E)/ /Mz;
Area) Claimants L
– vGjp
th';fpath;
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(C)
4 S.F.No.7/10 11/07/1991 Mortgage (E) b$ak; 674 636
S.F.No.7/11 15/07/199 deed g[l;g[uhr!; 411 1991
S.F.No.13/1 without ,z;l!;ohp!;
possession ghh;l;dh;
(E)
fpUc&;zrhkp
1 Mh;
(E) b$ak; 2
nf
(C) brd;id
jkpH; ehL
bjhHpy;
KjyPl;L
fHfk;
Sigaralahalli
brhj;jpd;
jd;ik
HOUSE SITE
Commercial Taxes Department:
Sl.N Description of v/bfh/eh- Nature & Name of Vol.No DNo
o Prop./ DOE & Value/ Executants bjhFjp / M
t/ brhj;J gjpt[ ehs; jz;ik vGjp P. No. vz;/
vz; tptuk; (Survey / DOR & kjpg;g[ bfhLj;jth; gf;fk; Yr
No & Area) (E)/ Claimants /Mz;
– vGjp L
th';fpath;
(C)
1 S.F.No.7/10 13/04/2005 Others (E) b$ak; 854 2
S.F.NO.7/11 18/04/2005 g[l;g[uh!rp'; 43 2005
S.F.NO.13/1 ,z;l!;l;hP!;
(C) Jiz
tzpf thp
mYtyh;
ghyf;nfhL
Sigaralahalli
brhj;jpd;
jd;ik
AGRICULTURA
L LAND
40. The provisions of Section 24(1) and (2) of the TNGST Act
provide for creation and priority of charge and are extracted below:
Section 24. Payment and recovery of tax: (1) Save as
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otherwise provided for in sub-section(2) of section 13, the tax
assessed or has become payable under this Act from a dealer
or person and any other amount due from him under this Act
shall be paid in such manner and in such installments, if any
and within such time as may be specified in the notice of
assessment, not being less than twenty-one days from the date
of service of the notice. The tax under sub-section (2) of
section 13 shall be paid without any notice of demand. In
default of such payments the whole of the amount outstanding
on the date of default shall become immediately due and shall
be a charge on the properties of the person or persons liable
to pay the tax or interest under this Act.
(2) Any tax assessed on or has become payable by, or
any other amount due under this Act from a dealer or person
and any fee due from him under this Act, shall, subject to the
claim of the government in respect of land revenue and the
claim of the Land Development Bank in regard to the
property mortgaged to it under section 28(2) of the Tamil
Nadu Co-operative Land Development Banks Act, 1934(Tamil
Nadu Act X of 1934), have priority over all other claims
against the property of the said dealer or person and the
same may without prejudice to any other mode of collection
be recovered:-
(a) as land revenue, or
(b) on application to any Magistrate by such
Magistrate as if it were a fine imposed by him:
41. Section 24(1) states that a charge is created on raising of a
demand of tax that is, on the passing of an order of assessment. Though
copies of the assessment orders are not before us, a copy of order dated
19.09.2001 passed by the Tamil Nadu Taxation Special Tribunal in
T.P.No.221 of 2001 filed by R6 has been placed before us at pages 9 to 11
of compilation dated 17.11.2020.
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42. From a perusal thereof, it is clear that the assessment orders
have been passed in 1994. In any event, seeing as the periods of
assessment commence from 1993-94 onwards, the demands, and
consequently, the charges could have been created only thereafter. The
discussion in the paragraphs supra make the position clear that the charge
created by TIIC is prior in time. Hence, such charge of TIIC/R4/R5 would
take precedence and we hence have no hesitation in holding that it is the
TIIC that would hold priority of charge.
43. Learned Special Government Pleader has made reference to the
agreements entered into by R6 with the appropriate authority qua the
deferral of tax payable under the Sales tax Act. It is consequent upon the
defaults by the assessee in adhering to the deferral scheme that orders of
assessment have come to be passed raising demands under the TNGST
Act. However, it is unnecessary for us to delve into this aspect of the
matter to decide the question of priority of charge as between the financial
institution and the Commercial taxes Department.
44. In view of the discussion as above, the prayers in the Writ
Petitions are allowed, demand notice dated 12.01.2012 is quashed and
mandamus as sought for is issued, forbearing R1 and R2 from in any way
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attaching, alienating or interfering with the ownership of the petitioner in
the subject property.
45. These Writ Petitions are allowed. No costs. Connected
Miscellaneous Petitions are closed.
[A.S.M., J] [G.A.M., J]
21.01.2025
Index:Yes
Speaking Order
Neutral Citation:Yes
sl
To
1.The Commercial Tax Officer,
Commercial Tax Department,
Palakode Town & Taluk,
Dharmapuri District.
2.The Assistant Commissioner,
Commercial Tax Department
Palakode Town & Taluk,
Dharmapuri District.
3.The District Collector,
Dharmapuri District.
4.The Tamilnadu Industrial Investment
Corporation Limited,
No.692, Anna Salai,
Nandanam, Chennai – 600 035.
5.The Tamilnadu Industrial Investment
Corporation Limited,
No.1, Pennagaram Road, Dharmapuri – 636 702.
https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/03/2025 02:18:30 pm )
W.P.Nos. 2061 & 2062 of 2012
https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/03/2025 02:18:30 pm )
