Rajasthan High Court - Jodhpur
Devarsa Gas Chem.Limited,Pali vs State And Ors on 10 October, 2023
Author: Nupur Bhati
Bench: Nupur Bhati
[2023:RJ-JD:32009]
HIGH COURT OF JUDICATURE FOR RAJASTHAN AT
JODHPUR
S.B. Civil Writ Petition No. 3460/2001
1. Devarsa Gas Chem.limited, Prakash Bhawan, Near Town Hall
Pali.
----Petitioner
Versus
1. State of Rajasthan through Collector, Pali.
2. The Accounts Officer (Income) Board of Revenue, Ajmer.
3. Deputy Collector-cum-Sub-Divisional Officer Pali.
----Respondents
For Petitioner(s) : Mr. Aditya Gupta
For Respondent(s) : Mr. R.D. Bhadu
HON'BLE DR. JUSTICE NUPUR BHATI
JUDGMENT
Reserved on:- 27/09/2023 Pronounced on:- 10/10/2023
1. The instant writ petition has been preferred by the petitioner under Article 226 of the Constitution of India with the following prayers:-
(i) the impugned order dated 05/09/2000 passed by the respondent no.2 may kindly be quashed and set-aside.
(ii) That impugned order dated 20/6/2001 (Annex.13) passed by respondent no.3 may kindly be quashed and set-
aside.
(iii) That the case of the writ petition may be awarded to the petitioner.
(iv) Any other appropriate writ order or direction may kindly be issued in favour of the petitioner which this Hon'ble Court deems just and proper.
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2. Brief facts of the case are that the petitioner is a company registered under The Companies Act 2013 and was registered as a small scale industry and was also issued a certificate of registration dated 30.05.1994 (Annexure-1) by the Joint Director District Industries Centre, Department of Industry. Thereafter the petitioner filed an application for conversion of the khatedari agricultural land situated at khasra No. 428/1 admeasuring 14 bighas in village Gajangarh, Gram Panchayat Chotila, Tehsil Rohit, District Pali from agricultural to non agricultural purpose for industrial purpose for establishment of Liquified Petroleum Gas (L.P.G.) refilling/bottling plant. The Petitioner deposited the charges for conversion of Rs. 9700/- and Rs 2,494/- for conversion vide challan no.524 dated 1/1/1994 and challan no. 5637 dated 23/11/1994 respectively. The aforesaid application was duly processed under the The Rajasthan Land Revenue (Conversion of Agricultural Land for Non-Agricultural Purposes in Rural Areas) Rules, 1992 (Hereinafter referred top as the Rules of 1992) and the Prescribed Authority (Deputy Collector, Pali), passed the conversion order dated 25/11/1994 (Annexure-2), wherein the land stood converted for industrial purpose for establishment of industry i.e. for Liquified petroleum gas (L.P.G.) refilling/bottling plant, in accordance with the Rules of 1992.
3. Thereafter the petitioner was served with a Notice by Deputy District Collector Pali dated 24.10.1996 (Annexure-3) stating therein that upon site inspection petitioner was liable to pay an additional amount of a sum of Rs. 3,33,875/- in 10 days failing which the amount would be realised by way of attachment. An oral (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (3 of 17) [CW-3460/2001] inquiry was made in the office of respondent No.2 Accounts Officer (Income) Board of Revenue and the petitioner was informed that exparte inspection was made and the Collector has objected that since some L.P.G gas in big containers as well as cylinders were found lying at the site and the land in question seemed to be used for commercial purpose and the rate of conversion was paid as per Industrial use thus a demand and penalty order dated 24.10.1996 (Annexure-3) was issued by respondent No.2.
4. Thereafter the petitioner challenged the notice of demand dated 24.10.1996 (Annexure-3) by filing a writ petition before this Hon'ble Court which was registered as SBCWP No.4036/1996 and the same was allowed vide order dated 12.05.2000 (Annexure-4) wherein the Notice of demand dated 24.10.1996 was quashed and direction was given to respondent no.2 to allow the petitioner to raise all contentions raised in the petition and hear the petitioners in person and pass appropriate orders after hearing the petitioners. Further the respondents also filed their reply and placed reliance upon various circulars that the petitioner unit can only be established after paying charges at commercial rates. Thereafter respondent No.2 issued a Notice dated 01.07.2000 calling the petitioner to plead its case and in pursuance of the aforesaid Notice the petitioner company filed reply dated 27/06/2000 (Annexure-8) challenging the jurisdiction of respondent No.2 and 3.
5. Thereafter the petitioner received a Communication dated 14/09/2000 (Annexure-11) along with a copy of decision directing (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (4 of 17) [CW-3460/2001] the authorities to pass appropriate orders in pursuance to the decision given by respondent No. 2 vide its order dated 05/09/2000 (Annexure-12). Thereafter the respondent No.3 passed an order dated 20/06/2001 (Annexure-13) raising a demand of Rs 1,81,875/- and directed the petitioner to deposit the aforesaid demand within a period of 7 days. Thus after receipt of the aforesaid order dated 20/06/2001 the petitioner made a representation dated 27/06/2001 (Annexure- 14) to the respondent No.2 while sending a copy to respondent No.3 as well Thereafter communication dated 22/08/2001 (Annexure-15) was issued by respondent no 2. wherein the petitioner was directed to deposit the sum of Rs 1,81,875/- by 05/09/2001 failing which the property of the petitioner unit would be attached and auctioned.
6. Aggrieved by the order dated 05/09/2000 (Annexure-12) passed by the respondent No.2 and order dated 20/06/2001 (Annexure-13) passed by respondent no.3, the petitioner preferred this writ petition.
7. Learned counsel for the petitioner submitted that the order dated 05/09/2001 passed by Accounts Officer (income) Board of Revenue Ajmer is without jurisdiction and the land of the petitioner was converted while taking conversion charges applicable for industrial purposes under the Rajasthan Land Revenue (Conversion of Agricultural land for Non- Agricultural Purposes in Rural Areas) Rules 1992, vide order dated 25/11/1994 (Annexure-2) by the respondent No. 3. Thereafter the respondent No.3 has issued a communication dated 24/10/1996 (Annexure-3) (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (5 of 17) [CW-3460/2001] wherein the petitioner was asked to deposit a sum of Rs 3,33,875 without issuing a notice to him.
8. Learned counsel for the petitioner further Submitted that respondent No.3 or any other authority does not have any jurisdiction to review the order of conversion of land passed by a competent authority under the Conversion Rules of 1992 and the earlier order dated 24/10/1996 (Annexure-3) and the order dated 05/09/2000 (Annexure-12) are quasi judicial in nature and as such the original order of conversion cannot be reviewed as there is no specific provision conferring such jurisdiction on the respondents, thus the review of the original order of conversion dated 24/10/1996 (Annexure-3) passed by the respondents is without jurisdiction and is liable to be quashed.
9. Learned counsel for the petitioner also submitted the respondent no.3 while passing the order of conversion dated 25/11/1994 under the Rules of 1992 had applied the rates of conversion for industrial purposes and the said charges have been duly paid by the petitioner and the land has been accordingly converted and recorded in the revenue records and the impugned action on the part of the respondent in seeking to recover additional demand on account of difference of conversion charges and penalty treating the land to be for commercial purposes is against the Rules of 1992.
10. Learned counsel for the petitioner further submitted that a bare perusal of the Certificate of Registration as well as the averment made in the petition does not leave any ambiguity that (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (6 of 17) [CW-3460/2001] the land in question held by the petitioner company is being used for industrial purposes as the petitioner has set up an industry and it is carrying out its industrial activity namely LPG filling and bottling of cylinders which is a manufacturing activity which has also been held by this Hon'ble Court vide order dated 08.02.2001.
11. Learned counsel for the petitioner further submitted that the respondent No.3 seems to have swayed away by the circular of the government and certain orders of conversion passed by the conversion authorities in case of M/s Hindustan Petroleum and Bharat Petroleum wherein the land alloted to them have been converted after taking commercial charges. He also submitted that the orders have been passed by the revenue authorities in different cases and the petitioner and respondent No.2 were not fully aware of the facts of those cases and even if the said corporation land have been converted after taking commercial charges but it does not dilute the rights of the petitioner company to claim that the charges be taken for Industrial conversion only. Those orders do not bind the petitioner as they are passed by parallel authorities and not by the appellate authority and orders of executive authorities can not be taken as precedent and thus the petitioners cannot be compelled to pay the conversion charges at commercial rates dehors the Rules of 1992.
12. Learned counsel or the petitioner further submitted that the Respondent No.2 has given its finding in the order dated 05/09/2000 that the activity carried out by the petitioner comes within the definition of commercial activity and thus held that the (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (7 of 17) [CW-3460/2001] conversion charges be levied as per the commercial rates only and the order is not a speaking order thus the order dated 05/09/2000 is illegal and is liable to be quashed. He also submitted that the levy of penalty in the present case is also illegal and arbitrary as the petitioner had established the plant after getting the land duly converted and all the facts were disclosed to the respondents and the order has been passed after visiting the factory premises and moreover, the levy of penalty besides recovering difference of amount between commercial rates and industrial rates is also illegal and arbitrary. He further submitted that in the present case the penalty in question has been levied under Rule 15 of the Rules of 1992 without considering the fact that the petitioner was not at fault.
13. Learned counsel for the petitioner also submitted that the contention of the respondents that some gas cylinders and gas containers were found on the spot cannot be treated to be used for commercial purpose of the industrial activity and storing of the same does not negate the use of land for industrial purpose and moreover when the plant for LPG refilling and bottling is established and thus some process is being carried on the site, as big containers and small cylinders are required to be kept there as inventory and thus the storage of any of these cylinders and big containers is a part of the industrial use of land and cannot be segregated by mentioning it as commercial use.
14. Learned counsel for the petitioner further submitted that the land in question is situated at a distance of 25 kms from the town (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (8 of 17) [CW-3460/2001] Pali and thus there is no possibility of carrying out any commercial activity there as the petitioner has his retail outlets in the town of Pali and other cities of Rajasthan thus the demand raised by the respondents is illegal and without jurisdiction. In support of his submissions, learned counsel for the petitioner placed reliance on the judgment passed by this Hon'ble Court in the case of Devarsa Gas Chem Pvt. Ltd. Vs Rajasthan Taxation Tribunal & Ors reported in (2001) 2 RLW 1257; The relevant portion of the judgment is reproduced here as under:-
"2. The petitioner has been licensed to carry on business of filling and selling Liquefied Petroleum Gas (LPG) as a parallel marketer as per Section 2 of the Liquefied Petroleum Gas (Regulation of Supply and Distribution) Order, 1993 (herein after the 'Order of 1993'). The activities of petitioner consisted of purchasing in bulk the liquefied petroleum gas from the bulk manufacturer of liquefied petroleum gas, in the present case Hindustan Petroleum Ltd. and packing the LPG in marketable cylinders and to sell it to end users of the gas.
17. It is a matter of common knowledge that liquefied petroleum gas is a highly inflammable article and tends to catch fire when it comes in contact with air. Obviously, therefore, packing of air along with LPG in the cylinders to be marketed to consumers has definite connotation and a scientific reason, that has been explained by the petitioner that it is because of mixture of air alone that LPG becomes usable by consumers as fuel gas. It could not be used as fuel in liquid form but admixturing of air with LPG is essential for making it marketable for end consumer use, as part of process of filling gas cylinders with LPG for use by consumers as fuel gas. If that be so, the conclusion is not far to reach that the petitioner is engaged in the process to bring the commodity in marketable condition. That may be the last lap of manufacturing process to complete, rendering (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (9 of 17) [CW-3460/2001] the LPG as marketable commodity and, if that conclusion is reached, it can not be said to a case of mere 'repacking.'
15. Per contra learned counsel for the respondents submitted that the petitioner is seeking challenge to the orders passed by the Revenue Authorities in compliance of the directions issued by this Hon'ble Court which is only an attempt to have a second round of litigation on the same subject matter thus the writ petition is baseless and deserves to be dismissed. He further submitted that the petitioner approached this Hon'ble Court earlier raising the same grounds and averments and as per the order of the Hon'ble Court the submissions of the petitioner has been considered in detail by the respondent No.2 Accounts Officer (Income) Board of Revenue, as it is evident from the order dated 05.09.2000 (Annexure-12) wherein the questions of facts have been considered and gone into and decided after hearing the petition and the present writ petition has been filed while raising the same questions of facts and thus the present writ petition is not maintainable and deserves to be dismissed.
16. Learned counsel for the respondents also submitted that the petitioner has put the agricultural land of Khasra No.428/1 to non
-agricultural use even prior to the grant of any order permitting such conversion by the competent authority and thus the charges for conversion is petitioner's liability and that correct and proper classification of the nature of conversion i.e. whether it was for industrial purposes or for commercial purposes remains to be determined in accordance with the statute and the instructions issued thereunder. He also submitted that there arises no question (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (10 of 17) [CW-3460/2001] of any estoppel in such matters and the respondents are entitled to charge and claim the requisite charges for conversion and it is wrong on the part of the petitioner to say that the original order has been put to any review and the question of review does not arise in as much as the order permitting conversion of agricultural land for non agricultural use has not been withdrawn nor annulled and has been maintained.
17. Learned counsel for the further respondent submitted that the land in question has been put not to the use of industrial activity but the containers /cylinders are being stored and are also being supplied to the consumers. The nature of the activity and business of the petitioner makes it clear that activity of the petitioner is a commercial activity and not an industrial activity and the circulars referred in reply to the earlier writ petition by the respondent and also produced by the petitioner as Annexure 5, 6 and 7 have rightly been considered in proper perspective by the concerned authority and the omission on the part of the Sub- Divisional Officer in not changing the requisite conversion charges has been ordered to be corrected.
18. Learned counsel for the respondents also submitted that it is wrong on the part of the petitioner to say that the earlier order dated 24.10.1996 was passed by the respondent No.3 after due scrutiny into the facts and law applicable to the case. The rates of conversion for industrial purposes were wrongly applied contrary to the statutory requirements thus the additional demand is neither against the Rules of 1992 nor arbitrary. He further (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (11 of 17) [CW-3460/2001] submitted that the averments of the petitioner based on certificate of registration or the order passed by this Hon'ble Court in relation to the sales tax incentive scheme are entirely wrongly interpreted and deserve to be rejected and mere registration as a Small Scale Industrial Unit or the activity being considered to be a manufacturing process for the purpose of sales tax and incentive have no relevance for determination about the land use for the purposes of the Rules of 1992.
19. Learned counsel for the respondent also submitted that the Accounts Officer (Income) has earlier passed the order in confirmity with the Rules of 1992 and after complying with directions of this Hon'ble Court for opportunity of hearing was afforded to the petitioner and a detailed order was passed by the Accounts Officer (Income). He further submitted that an agricultural land cannot be claimed to be used for non-agricultural purposes as a matter of right by the petitioner and such conversion is always subject to the relevant provisions of the Rules of 1992. Moreover the land in question was used as a godown thus commercial activity had taken place therefore the petitioner has been rightly ordered to be charged as such. He also submitted that the challenge of the petitioner to the penalty is baseless as the petitioner had started using the land in question for non-agricultural purposes prior to any permission for such conversion thus the penalty has been rightly added to the component of conversion charges in accordance with Rule 15 of the Rules of 1992.
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20. Heard Learned Counsel for the parties; perused the material available on record and the Judgments cited at the Bar.
21. This court observes that the petitioner company Devarsa Gas chem. Ltd falls under the definition under Section 2(e)"Industrial Purpose" of The Rajasthan Land Revenue (Conversion of Agricultural Land for Non-Agricultural purposes in Rural Areas) Rules, 1992 and not under the definition of Section 2(b) "Commercial purpose" and the order dated 05.09.2000 passed by the respondent No.2 and the order dated 20.06.2001 passed by respondent No.3 for demanding conversion charges applicable for commercial purposes from the petitioner is not applicable to the case of the petitioner as the petitioner got the conversion of the land in question for carrying out an industrial activity for establishment of liquefied petroleum gas refilling/bottling plant for which the petitioner was also issued a certificate of registration for small scale industry dated 30.05.1994 by the Joint Director, District Industries Centre, Department of Industry. Moreover in the Registration Certificate dated 30.05.1994 the "nature of activity" is clearly mentioned in serial No.6 and under sub clause 2 "processing" LPG filling Bottling plant, the petitioner's company is registered. Section 2(b) and 2(e) of The Rajasthan Land Revenue (Conversion of Agricultural Land for Non-Agricultural purposes in Rural Areas) Rules, 1992 is reproduced here as under.
(b) 'Commercial purpose' means the use of any premises for any trade or commerce or business which shall include a shop, commercial establishment, bank [x x x] office, dhaba (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (13 of 17) [CW-3460/2001] (whether pucca or temporary structure), show-room, cinema, petrol pump, weigh bridge, godown or any other commercial activity [and shall also include the use thereof partly for residential and partly for commercial purposes], [but shall not include anything included in tourism units.]
(e) 'Industrial purpose' means the use of any premises or workshop or an open area for any industry [including Information Technology Industry] whether a small or medium or large scale unit [or a Tourism unit] and shall include a brick kiln or a kiln but shall not include any premises used for a purpose as defined in clause (b).
22. This Court further observes that the bottling LPG is a complex process and involves purchasing of bulk quantity of LPG from oil refineries and LPG importers and then transporting the same in tanker lorries to factory which is unloaded there and stored in large storage tanks and thereafter filled in smaller cylinders which involves expertise and special knowledge and also involves strict controls of the parameters like pressure and temperature.
23. This court further finds that in case of Devarsa Gas Chem Pvt. Ltd. Vs Rajasthan Taxation Tribunal & Ors reported in (2001) 2 RLW 1257; and The Hon'ble Apex Court in the case of Commissioner Of Income Tax 1 vs M/S. Hindustan Petroleum corporation limited reported in (2017) 15 SCC 254 observed that LPG filling/bottling falls under the category of manufacturing process.
The relevant portion of the Judgment rendered by this Court in the case of Devarsa Gas Chem Pvt. Ltd. Vs Rajasthan Taxation Tribunal & Ors is reproduced here as under:-
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[2023:RJ-JD:32009] (14 of 17) [CW-3460/2001] "21. We are, therefore, of the opinion that in the facts as found by the Tribunal, only reasonable conclusion possible to arrive at is that filling of gas cylinders with LPG, by transferring it from bulk storage admixturing it with proportionate amount of air to make it marketable is a manufacturing process and can not be termed as process of repacking only of any goods, as envisaged in Entry-6 of Annx. B of the Incentive Scheme of 1987. The Tribunal has obviously erred in not taking into consideration the effect of finding about process reached by it on the marketability of the commodity which is an essential ingredient of manufacturing."
The relevant portion of the Judgment rendered by the Hon'ble Apex court in the case of Commissioner Of Income Tax 1 vs M/S. Hindustan Petroleum corporation limited is reproduced here as under:-
21. Keeping the aforesaid distinction in mind, let us take note of the process of LPG bottling that is undertaken by the assessees herein and about which there is no dispute. It has come on record that specific activities at assessees' plant include receiving bulk LPG vapour from the oil refinery, unloading the LPG vapour, compression of the LPG vapour, loading of the LPG in liquefied form into bullets, followed by cylinder filling operations. The stages of these activities are as under:
(a) Bulk LPG is received in the bottling plant through road tankers/rail wagons;
(b) The LPG is unloaded into spheres/bullets through LPG compressors which use variable levels of pressure for suction, unloading and vapour recovery;
(c) Refilling/bottling of LPG in cylinders by compressing the same into liquid form; and
(d) Capping, fixing of seals and safety valves prior to storage and loading of filled cylinders.
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22. Thus, after the bottling activities at the assessees' plants, LPG is stored in cylinders in liquefied form under pressure. When the cylinder valve is opened and the gas is withdrawn from the cylinder, the pressure falls and the liquid boils to return to gaseous state. This is how LPG is made suitable for domestic use by customers who will not be able to use LPG in its vapour form as produced in the oil refinery. It, therefore, becomes apparent that the LPG obtained from the refinery undergoes a complex technical process in the assessees' plants and is clearly distinguishable from the LPG bottled in cylinders and cleared from these plants for domestic use by customers.
23. It may be relevant to point out that keeping in view the aforesaid process, the ITAT arrived at the specific findings in support of its decision, which are as under:
23.1. There is no dispute that the LPG produced in the refinery cannot be directly supplied to the consumer for domestic use because of various reasons of handling, storage and safety.
23.2 LPG bottling is a highly technical and complex activity which requires precise functions of machines operated by technically expert personnel.
23.3. Bottling of LPG is an essential process for rendering the product marketable and usable for the end customer.
23.4. The word 'production' has a wider connotation in comparison to 'manufacture', and any activity which brings a commercially new product into existence constitutes production. The process of bottling of LPG renders it capable of being marketed as a domestic kitchen fuel and, thereby, makes it a viable commercial product."
24. This Court also observes that from the definition of "Commercial Purpose" as laid down under the Section 2(b) of The Rajasthan Land Revenue (Conversion of Agricultural Land for Non-Agricultural purposes in Rural Areas) Rules, 1992 it is found that the activities would be considered as commercial where "any trade or (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (16 of 17) [CW-3460/2001] commerce or business which shall include a shop, commercial establishment, bank [x x x] office, dhaba (whether pucca or temporary structure), show-room, cinema, petrol pump, weigh bridge, godown or any other commercial activity" and the activity undertaken by the petitioner apparently does not fall under this definition. This Court Further observes that as per the definition of "Industrial purpose" as laid down under Section 2 (e) of The Rules of 1992 it is seen that the activity would be considered for Industrial Purpose "if the use any premises or workshop or an open area for any industry [including Information Technology Industry] whether a small or medium or large scale unit [or a Tourism unit] and shall include a brick kiln or a kiln but shall not include any premises used for a purpose as defined in clause (b)"
and undoubtedly the industry of the petitioner is a Small Scale Industry as mentioned in the Registration Certificate dated 30.05.1994 issued by the Joint Director, District Industries Centre, Department of Industry while also mentioning in it the nature of activity as LPG filling/bottling. This Court also observes that as held by this Court in the case of Devarsa Gas Chem Pvt. Ltd. Vs Rajasthan Taxation Tribunal & Ors reported in (2001) 2 RLW 1257; the bottling of LPG gas cylinders is considered as manufacturing activity and all the activities mentioned in definition under Rule 2(b) of The Rules of 1992 like shop, bank, office, dhaba, show-room, cinema etc cannot be said to be a manufacturing activity as they are selling the final product which might have been purchased from a third party and also cannot fall in the definition of Industrial purpose. Moreover, the Petitioner is (Downloaded on 12/11/2023 at 07:26:34 AM) [2023:RJ-JD:32009] (17 of 17) [CW-3460/2001] buying the raw product which is thereafter filled and bottled thus cannot be said to be falling in the definition of Commercial particularly when the filling bottling of LPG has been held to be a manufacturing activity as held in the case of Devarsa Gas (Supra) and thus the order dated 05.09.2000 (Annexure-12) by which commercial charges has been levied is not sustainable.
25. As an upshot of the discussion made herein above, the present writ petition is allowed and the order dated 05.09.2000 (Annexure-12) and 20.6.2001 (Annexure-13) passed by the respondent No.2 The Accounts Officer (Income) Board of Revenue, Ajmer and respondent No.3 Deputy Collector-cum-Sub-Divisional Officer Pali, are quashed and set aside.
26. Stay application as well as all other pending applications, if any, also stand disposed of accordingly.
(DR. NUPUR BHATI),J /Devesh Thanvi/ (Downloaded on 12/11/2023 at 07:26:34 AM) Powered by TCPDF (www.tcpdf.org)