M/s Baba Educational Society (Regd), Moga V. The Income Tax Officer-I, Moga

ITA 366/ASR/2014

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 5137 (ITAT-AMRITSAR)
• Duration Of Justice: 4 year(s) 7 month(s) 26 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-01-2019
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Next Hearing Date: 10-01-2019
• Assessment Year: 2010-2011
• Appeal Filed On: 04-06-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: ALOK KUMAR LD
• Assessee Lawyers: P N ARORA LD
• Keywords: Retrospective amendment; Condonation of delay
• Section: 12A; 12AA; 147; 11

Judgement Text

IN THE INCOME TAX APPELLATE TRIBU NAL AMRITSAR BENCH, AMRITSAR BEFORE SH. SANJAY ARORA, ACCOUNTANT MEMBER AND SH. N.K.CHOUDHRY, JUDICIAL MEMBER ITA NO.1318(CHD)/2012 ASSESSMENT YEAR:2009-10 BABA AMARNATH EDUCATIONAL SOCIETY, SATYA YOG NIWAS GILL ROAD, MOGA. [PAN:AAAAB 7523L] VS. INCOME TAX OFFICER-I MOGA. (APPELLANT) (RESPONDENT) ITA NO.366(ASR)/2014 ASSESSMENT YEAR:20 10-11 BABA AMARNATH EDUCATIONAL SOCIETY (REGD.) SATYA YOG NIWAS GILL ROAD, MOGA. [PAN:AAAAB 7523L] VS. INCOME TAX OFFICER-I MOGA. (APPELLANT) (RESPONDENT) ITA NO.638(ASR)/2014 ASSESSMENT YEAR: 2009-10 INCOME TAX OFFICER-I MOGA VS. BABA AMARNATH EDUCATIONAL SOCIETY (REGD.) SATYA YOG NIWAS GILL ROAD, MOGA. [PAN:AAAAB 7523L] (APPELLANT) (RESPONDENT) APPELLANT BY: SH. P.N.ARORA (LD. ADV.) RESPONDENT BY: SH. AL OK KUMAR (LD. DR) DATE OF HEARING: 16.01.2019 DATE OF PRONOUNCEMENT: 31.01 .2019 ORDER PER BENCH: ITA NOS.1318/CHD/2012 & 366 /ASR/2014 (ASST. YEARS: 2009-10 & 20 10-11) ITA NO.638 /ASR/2014 (ASST. YEAR 2009-10) 2 THE ASSESSEE TRUST (HEREINAFTER CALLED AS THE APPELLANT ) BY WAY OF ITA NOS.1318/CHD/2013 & 366/ASR/2014 CHALLE NGED THE ORDERS DATED 19.10.2012 & 31.03.2014 PASSED BY THE LD. CIT(A)-I & II, LUDHIANA, FOR ASST. YEARS: 2009-10 & 2 010-11 RESPECTIVELY, WHEREBY THE LD. CIT(A) UPHELD THE AD DITION MADE BY THE ASSESSING OFFICER. THE REVENUE DEPARTMENT ALSO FILED AN APPEAL I.E. I TA NO.638/ASR/2014 WHILE CHALLENGING THE ACTION/ORDER DAT ED 21.08.2014 PASSED BY THE LD. CIT(A)-II, LUDHIANA, WHE REBY THE LD.CIT(A) DELETED THE PENALTY OF RS.1,25,90,681/- FO R A.Y.2009- 10 IMPOSED BY THE ASSESSING OFFICER. 2. AS THE ITA NO.1318/CHD/2012 & ITA NO.366/ASR/2014 INVOLVED THE SIMILAR AND IDENTICAL ISSUE, THEREFORE, FO R THE SAKE OF CONVENIENCE AND BREVITY, THE FACTS OF ITA NO.1318 OF 2 012 HAVE BEEN TAKEN INTO CONSIDERATION AND DECISION OF THE SAME SH OULD ALSO BE APPLICABLE MUTATIS MUTANDIS TO ITA NO.366/ASR/2014. 3. IN BRIEF THE FACTS OF THE CASE ARE THAT THE APPELLANT HAD FILED ITS RETURN OF INCOME DECLARING TAXABLE INCOME AT RS. (NIL). DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER NOTED THAT THE APPELLANT HAD RECEIVED CORPUS DO NATIONS OF RS.3,69,00,000/- WHICH WERE CLAIMED AS EXEMPT U/S 11(1)( D) OF THE INCOME TAX ACT 1961 (HEREINAFTER CALLED AS THE ACT) .THE AO ASKED THE APPELLANT TO EXPLAIN AS TO WHY IN VIEW OF T HE AMENDED PROVISIONS OF SEC.2(24) OF THE ACT, CORPUS DONATIONS RECEIV ED BY THE APPELLANT MAY NOT BE TREATED AS INCOME OF THE APP ELLANT ON NON-REGISTRATION U/S 12A OF THE ACT. THE APPELLANT HA D CLAIMED THAT THE SAID DONATIONS WERE RECEIVED FROM VARIOUS EDUCA TIONAL INSTITUTIONS AS SUCH WERE IN THE NATURE OF CAPITAL RECEIP TS. THE ITA NOS.1318/CHD/2012 & 366 /ASR/2014 (ASST. YEARS: 2009-10 & 20 10-11) ITA NO.638 /ASR/2014 (ASST. YEAR 2009-10) 3 APPELLANT ALSO ENCLOSED COPY OF THE SANCTION LETTERS GIVEN BY THE SAID TRUSTS/SOCIETIES/INSTITUTIONS IN SUPPORT OF THEIR CONTENTION, HOWEVER, THE ASSESSING OFFICER WHILE RELYING UPON THE D ECISION OF THE APEX COURT IN THE CASE OF U.P. FOREST CORPORATION & ANR. VS. DEPUTY COMMISSIONER OF INCOME TAX, DECLINED TO GIVE RELIEF TO THE ASSESSEE BY REFERRING AND RELYING UPON THE PROVISION I.E. SEC.2(24), 11(1), 12A AND 13 OF THE ACT AND FURTHER H ELD THAT CORPUS DONATIONS ARE IN THE NATURE OF INCOME UNDER TH E AMENDED PROVISION OF SEC.2(24) OF THE ACT AND SUCH CORPUS DONATIO NS ARE ELIGIBLE FOR EXEMPTIONS U/S 11(1)(D) BUT SUBJECT TO THE CONDITION THAT THE TRUST OR SOCIETY IS REGISTERED U/S 12A OF THE ACT. AS THE APPELLANT IS NOT REGISTERED U/S 12A FOR THE RELEVANT A SSESSMENT YEAR, THEREFORE, THE CORPUS DONATIONS TO THE TUNE OF RS.3,70,42,310/- REQUIRES TO BE ADDED IN THE INCOME OF THE ASSESSEE. THE APPELLANT ASSAILED THE ASSESSMENT ORDER BEF ORE THE LD. CIT(A), WHO CATEGORICALLY HELD THAT THE APPE LLANT IS NEITHER REGISTERED U/S 12A OF THE ACT, NOR YET EVEN AP PLIED FOR REGISTRATION FOR THE FINANCIAL YEAR 2008-09, THEREFOR E, THE EXEMPTION AS PROVIDED IN SEC.11(1)(D) WOULD NOT BE AV AILABLE TO THE VOLUNTARY CONTRIBUTION RECEIVED BY THE APPELLANT . FINALLY THE LD. CIT(A) CONFIRMED THE ADDITION ON THE BASIS OF NON- REGISTRATION OF THE APPELLANT U/S 12AA OF THE ACT. 4. WE HAVE HEARD THE RIVAL SUBMISSIONS OF THE PARTIES AN D PERUSED THE MATERIAL AVAILABLE ON RECORD. IT IS ADMITT ED FACT THAT DURING THE ASSESSMENT YEARS 2009-10 & 2010-11, THE APPEL LANT HAD NO REGISTRATION U/S 12AA OF THE ACT. IT IS BROUGHT TO OUR KNOWLEDGE THAT THE APPELLANT VIDE APPLICATION SOUGHT REGISTRATION U/S 12A OF THE ACT ON 20.12.2010 (W.E.F. 14.08.2008 BEING THE DATE OF FORMATION OF THE SOCIETY) FOR THE A.YS. 2009-1 0 2010-11, ITA NOS.1318/CHD/2012 & 366 /ASR/2014 (ASST. YEARS: 2009-10 & 20 10-11) ITA NO.638 /ASR/2014 (ASST. YEAR 2009-10) 4 HOWEVER THE LD. CIT(E) REJECTED THE REQUEST FOR REGIST RATION FOR A.YS.2009-10 TO 2010-11 DUE TO THE APPLICATION BEI NG FILED BEYOND THE PRESCRIBED TIME LIMIT AND THEREAFTER THE A PPELLANT APPROACHED THE CBDT FOR CONDONATION OF DELAY FOR CONSI DERATION OF REGISTRATION FOR THE SAID ASSESSMENT YEARS. THE CBDT AF TER CONSIDERING THE APPLICATION OF THE APPELLANT VIDE ITS O RDER DATED 14.11.2014 CONDONED THE DELAY U/S 119 OF THE ACT FOR A .YS. 2009-10 TO 2010-11. 4.1 IT ALSO EMERGED THAT THE APPELLANT HAS ALREADY BEEN GRANTED REGISTRATION U/S 12AA OF THE ACT VIDE ORDER DA TED 09.02.2012 PASSED BY THE LD. CIT(E), LUDHIANA W.E.F. A.Y.2011 - 12 AND ON 09.02.2012, APPEALS QUA ADDITIONS FOR THE A .YS. 2009- 10 & 2010-11 WERE PENDING BEFORE THE LD. CIT(A) AN D ARE STILL PENDING FOR ADJUDICATION BEFORE THIS BENCH, THEREFORE , THE QUESTION ARISE AS TO WHETHER THE SAME CAN BE TREATED AS CONTINUATION OF THE ASSESSMENT PROCEEDINGS OR NOT. 4.2 AS IN THE INSTANT CASE, THE LEGAL GROUND IS INVOLVE D QUA APPLICABILITY OF PROVISO OF SEC.12A (2) WHICH WAS INSER TED W.E.F 1 ST OCTOBER, 2014, THEREFORE, WE FEEL IT IMPERATIVE T O DEAL THE LEGAL ISSUE FIRST. FOR THE SAKE OF CONVENIENCE AND CLARI TY THE PROVISIONS OF SEC.12A ARE REPRODUCED HEREIN BELOW. SEC.12A (1). THE PROVISIONS OF SECTION 11 AND SECTION 12 SHALL NOT APPLY IN RELATION TO THE INCOME OF ANY TRUST OR INSTITUTION UNLESS TH E FOLLOWING CONDITIONS ARE FULFILLED, NAMELY: (A) THE PERSON IN RECEIPT OF THE INCOME HAS MADE A N APPLICATION FOR REGISTRATION OF THE TRUST OR INSTITUTION IN THE PRE SCRIBED FORM AND IN THE PRESCRIBED MANNER TO THE [***] COMMISSIONER BEF ORE THE 1ST DAY OF JULY, 1973, OR BEFORE THE EXPIRY OF A PERIOD OF ONE YEAR FROM THE DATE OF THE CREATION OF THE TRUST OR THE ESTABLISHM ENT OF THE INSTITUTION, [WHICHEVER IS LATER AND SUCH TRUST OR INSTITUTION IS REGISTERED UNDER SECTION 12AA ] : ITA NOS.1318/CHD/2012 & 366 /ASR/2014 (ASST. YEARS: 2009-10 & 20 10-11) ITA NO.638 /ASR/2014 (ASST. YEAR 2009-10) 5 [PROVIDED THAT WHERE AN APPLICATION FOR REGISTRATION OF THE TRUST OR INSTITUTION IS MADE AFTER THE EXPIRY OF THE PERIOD AFORESAID, THE PROVISIONS OF SECTIONS 11 AND 12 SHALL APPLY IN REL ATION TO THE INCOME OF SUCH TRUST OR INSTITUTION, (I) FROM THE DATE OF THE CREATION OF THE TRUST OR T HE ESTABLISHMENT OF THE INSTITUTION IF THE [***] COMMI SSIONER IS, FOR REASONS TO BE RECORDED IN WRITING, SATISFIED TH AT THE PERSON IN RECEIPT OF THE INCOME WAS PREVENTED FROM MAKING THE APPLICATION BEFORE THE EXPIRY OF THE PERIOD AFO RESAID FOR SUFFICIENT REASONS; (II) FROM THE 1ST DAY OF THE FINANCIAL YEAR IN WHICH THE APPLICATION IS MADE, IF THE [***] COMMISSIONER IS N OT SO SATISFIED:] [PROVIDED FURTHER THAT THE PROVISIONS OF THIS CLAUSE SHALL NOT APPLY IN RELATION TO ANY APPLICATION MADE ON OR AFTER THE 1ST DAY OF JUNE, 2007;] [(AA) THE PERSON IN RECEIPT OF THE INCOME HAS M ADE AN APPLICATION FOR REGISTRATION OF THE TRUST OR INSTITUTION ON OR AFTER THE 1ST DAY OF JUNE, 2007 IN THE PRESCRIBED FORM AND MANNER TO THE COMMISSIONER AND SUCH TRUST OR INSTITUTION IS REGISTERED UNDER S ECTION 12AA;] (B) WHERE THE TOTAL INCOME OF THE TRUST OR INSTI TUTION AS COMPUTED UNDER THIS ACT WITHOUT GIVING EFFECT TO [THE PROVISI ONS OF SECTION 11 AND SECTION 12 EXCEEDS THE MAXIMUM AMOUNT WHICH IS NOT CHARGEABLE TO INCOME-TAX IN ANY PREVIOUS YEAR], THE ACCOUNTS OF THE TRUST OR INSTITUTION FOR THAT YEAR HAVE BEEN AUD ITED BY AN ACCOUNTANT AS DEFINED IN THE EXPLANATION BELOW SUB- SECTION (2) OF SECTION 288 AND THE PERSON IN RECEIPT OF THE INCOME FURNISHES ALONG WITH THE RETURN OF INCOME FOR THE RELEVANT ASSESSME NT YEAR THE REPORT OF SUCH AUDIT IN THE PRES-CRIBED FORM DULY SIGNED AND VERIFIED BY SUCH ACCOUNTANT AND SETTING FORTH SUCH PARTICULARS AS MAY BE PRESCRIBED.] (C)[******] (2) WHERE AN APPLICATION HAS BEEN MADE ON OR A FTER THE 1 ST DAY OF JUNE, 2007 THE PROVISIONS OF SECTIONS 11 & 12 SHALL APPLY IN RELATION TO THE INCOME OF SUCH TRUST OR INSTITUTION FROM THE ASSESS MENT YEAR IMMEDIATELY FOLLOWING THE FINANCIAL YEAR IN WHICH SUCH APPLICAT ION IS MADE.] [PROVIDED THAT WHERE REGISTRATION HAS BEEN GRANTED TO THE TRUST OR INSTITUTION UNDER SECTION 12AA, THEN, THE PROVIS IONS OF SECTION 11 & 12 SHALL APPLY IN RESPECT OF ANY INCOME DERIVED FROM PROPERTY HELD UNDER TRUST OF ANY ASSESSMENT YEAR PREC EDING THE AFORESAID ASSESSMENT YEAR, FOR WHICH ASSESSMENT PROCEE DINGS ARE PENDING BEFORE THE ASSESSING OFFICER AS ON THE D ATE OF SUCH REGISTRATION AND THE OBJECTS AND ACTIVITIES OF SUCH TRUST OR INSTITUTION REMAIN THE SAME FOR SUCH PRECEDING ASSESS MENT YEAR: PROVIDED FURTHER THAT NO ACTION UNDER SECTION 147 SHALL BE TAKEN BY THE ASSESSING OFFICER IN CASE OF SUCH TRUST OR INSTI TUTION FOR ANY ITA NOS.1318/CHD/2012 & 366 /ASR/2014 (ASST. YEARS: 2009-10 & 20 10-11) ITA NO.638 /ASR/2014 (ASST. YEAR 2009-10) 6 ASSESSMENT YEAR PRECEDING THE AFORESAID ASSESSMENT YEAR ONLY FOR NON-REGISTRATION OF SUCH TRUST OR INSTITUTION FOR T HE SAID ASSESSMENT YEAR: PROVIDED ALSO THAT PROVISIONS CONTAINED IN THE FIRST AND SECOND PROVISO SHALL NOT APPLY IN CASE OF ANY TRUST OR INS TITUTION WHICH WAS REFUSED REGISTRATION OR THE REGISTRATION GRANTED TO IT WAS CANCELLED AT ANY TIME UNDER SECTION 12AA.] 4.3 THE SIMILAR AND IDENTICAL ISSUE HAS ALSO BEEN DEALT BY CO- ORDINATE BENCHES IN THE BELOW MENTIONED CASES . (I) SAI WIRAN WALI EDUCATIONAL TRUST VS DY. CIT, CIRCLE- II, JALANDHAR (I.T.A NO.10 (ASR)/2017, DECI DED ON 11/08/2018) (II) TILLA BABA FARID RELIGIOUS & CHARITABL E SOCIETY V. ITO (EXEMPTIONS), ITA NO.621 (ASR)/20 15 & 91(ASR)/2017, DECIDED O N 20-04-2018 (III) ST. JUDES CONVENT SCHOOL, NOKADAR VS. ACIT, I TA NO.749(ASR)/2013 (ITAT, AMRITSAR) (IV) SREE SREE RAMKRISHNA SAMITY VS. DCIT, CIRCLE-2 , SILIGURI, ITA NO.1680-1 685/2012 (ITAT, KOLKATA) (V) SHYAM MANDIR COMMITTEE, KHATUSHYAM JI VS. ACIT, CIRCLE SIKAR (ITAT, JAIPU R) (VI) SNDP YOGAM VS. ADIT (EXEMPTION), RANGE-4, KOCHI, I ITA NO.503-506 & 569/COCH/ 2014 (ITAT, COCH) 4.4 ALL THE CO-ORDINATE BENCHES IN THE AFORESAID CASES CATEGORICALLY HELD THAT AMENDMENT MADE BY FINANCE ACT, 2014 BY INSERTING A PROVISO IN SEC.12A OF THE ACT SHALL BE CON STRUED RETROSPECTIVELY IN OPERATION BECAUSE THE LEGISLATORS IN THEIR WISDOM HAVE BROUGHT THIS PROVISO TO PREVENT GENUINE HA RDSHIP WHICH COULD BE CAUSED ON THE ASSESSEE(S) DUE TO NON- REGISTRATION U/S 12A OF THE ACT. 4.5 EVEN OTHERWISE THE APEX COURT IN THE CASE OF 'CIT VS. VATIKA TOWNSHIP PVT. LTD. [2014] 236 ITR 466(SC) CLEA RLY HELD 'IF A LEGISLATION CONFERS A BENEFIT ON SOME PERSONS BUT WITHOUT ITA NOS.1318/CHD/2012 & 366 /ASR/2014 (ASST. YEARS: 2009-10 & 20 10-11) ITA NO.638 /ASR/2014 (ASST. YEAR 2009-10) 7 INFLICTING A CORRESPONDING DETRIMENT ON SOME OTHER PERSO N OR ON THE PUBLIC GENERALLY, AND WHERE TO CONFER SUCH BENEFIT APPEARS TO HAVE BEEN THE LEGISLATOR'S, OBJECT, THEN THE PRESUMPTI ON WOULD BE THAT SUCH A LEGISLATION, GIVING IT A PURPOSIVE CONSTR UCTION, WOULD WARRANT IT TO BE GIVEN A RETROSPECTIVE EFFECT'. 4.6 THE BENEFIT OF SEC. 11/12 AS WELL AS 10(23C)(III AD) OF THE ACT WAS DENIED TO THE ASSESSEE SOCIETY ON THE GROUND THAT T HE ASSESSEE IS NOT REGISTERED U/S. 12AA OF THE ACT. WE HAVE AL READY OBSERVED THAT THE APPELLANT GOT REGISTRATION U/S 12A A OF THE ACT W.E.F. 09-02-2012 AND AS ON THAT DATE THE APPEAL AGA INST THE QUANTUM WAS PENDING BEFORE THE LD. CIT(A) WHICH WAS D ECIDED ON 10-10-2012 AND AGAINST WHICH THE APPEAL IS STILL PE NDING FOR ADJUDICATION BEFORE THIS BENCH AND HENCE THE ASSESSMENT PROCEEDINGS CAN BE CONSTRUED AS CONTINUING AND PENDING. 4.7 WHILE RESPECTFULLY FOLLOWING THE DICTUM OF THE APEX COURT AS WELL AS THE CO-ORDINATE BENCHES, WE ARE OF THE CONSID ERED OPINION THAT THE ISSUE IS SQUARELY COVERED BY THE AFOR ESAID DECISIONS, THEREFORE, WE DO NOT HAVE ANY HESITATION TO HELD THAT PROVISO TO SEC.L2A(2) WHICH WAS ADDED BY FINANCE ACT, 20 14 SHALL BE RETROSPECTIVE IN OPERATION. THERE IS NOTHING E ITHER ON RECORD OR OTHERWISE BROUGHT ON RECORD BY THE LD. DR TO THE EFFECT THAT THERE IS ANY CHANGE IN THE OBJECTS AND ACTIVITIES OF ASSESSE/TRUST FOR THE PRECEDING ASSESSMENT YEARS INVOLVED. HENCE, WE ARE INCLINED TO HELD THAT REGISTRATION GRANTE D TO THE ASSESSEE BY THE CIT(E) VIDE LETTER DATED 09-02-2012 SHAL L BE EFFECTIVE FROM 10-08-2008 BEING THE DATE OF FORMATIO N OF SOCIETY AND THE ASSESSEE SHALL BE ENTITLED TO GET THE BENEFIT OF REGISTRATION FOR A.YS. 2009-10 AND 2010-2011 AS WELL, AGAINST ITA NOS.1318/CHD/2012 & 366 /ASR/2014 (ASST. YEARS: 2009-10 & 20 10-11) ITA NO.638 /ASR/2014 (ASST. YEAR 2009-10) 8 WHICH APPEALS ARE UNDER CONSIDERATION. CONSEQUENTLY WE SE T ASIDE THE IMPUGNED ORDER PASSED BY THE ID. CIT(A) AS WE LL AS ASSESSMENT ORDER AND DELETE THE ADDITION, BY ALLOWING T HE ASSESSEE'S APPEAL. 5. . IN VIEW OF THE ORDER PASSED IN ITA NO. 1318/CHD/2012, ITA NO.366/ASR/2014 ALSO STANDS ALLOWED. 6. ITA NO. 638/ASR/2014, WHILE DISPOSING APPEAL OF THE ASSESSEE I.E. ITA 1318/CHD/2012, THE ORDERS PASSED BY THE AUTHORITI ES BELOW ARE SET ASIDE, CONSEQUENTLY THE PENALTY ORDER CANNOT SU RVIVE AND THEREFORE THE APPEAL OF REVENUE FILED AGAINST THE D ELETION OF PENALTY ORDER, IS ALSO LIABLE TO BE DISMISSED, HENC E STANDS DISMISSED. 7 . IN THE RESULT, ASSESSEE'S APPEALS ARE ALLOWED AND REV ENUE'S APPEAL IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 31.01.2019. SD/- SD/- (SANJAY ARORA) (N.K.CHOUDHRY) ACCOUNTANT MEMBER JUDI CIAL MEMBER DATED: 31.01.2019 /PK/ PS. COPY OF THE ORDER FORWARDED TO: (1) BABA AMARNATH EDUCATIONAL SOCIETY, SATYA YOG NIWAS GILL ROAD, MOGA) (2) THE ITO-1, MOGA (3) THE CIT(A)-I & II LUDHIANA (4) THE CIT CONCERNED (5) THE SR DR, I.T.A.T., AMRITSAR TRUE COPY BY ORDER FILENAME: BABA AMARNATH EDUCATIONAL SOCIETY, 1318, 366 & 638 -14 DIRECTORY: D:\DOCUMENT\NKC ORDERS 2018 TEMPLATE: C:\USERS\ETC PARMOD\APPDATA\ROAMING\MICROSOFT\TEMPLATES\NORMAL.D OT TITLE: IN THE INCOME TAX APPELLATE TRIBUNAL SUBJECT: AUTHOR: RAHUL PRABHAKAR KEYWORDS: COMMENTS: CREATION DATE: 1/23/2019 5:07:00 PM CHANGE NUMBER: 209 LAST SAVED ON: 2/6/2019 12:00:00 PM LAST SAVED BY: ETC PARMOD TOTAL EDITING TIME: 350 MINUTES LAST PRINTED ON: 2/6/2019 12:00:00 PM AS OF LAST COMPLETE PRINTING NUMBER OF PAGES: 9 NUMBER OF WORDS: 2,301 (APPROX.) NUMBER OF CHARACTERS: 13,118 (APPROX.)