Whether discount received from various newspaper agencies be leviable to service tax when service tax paid on total receipts from customers?

PJ/Case Study/2012-13/46

Prepared by:-CA Neetu Sukhwani &
Kavita Thanvi

CASE STUDY

Introduction:

The assessee was issued with a show cause notice alleging that they have evaded the service tax of Rs. 43,09,577/- during the financial year 2006-07 to 2010-11 on payment received against rendering the service under the category of service 'Advertisement Services’ by willfully suppressing and not disclosing material facts, fraudulently in contravention of the provisions of Section 66, 67, 68 and 70 of Finance Act, 1994, read with Rules 6 and 7 of the Service Tax Rules, 1994. It was held that the assessee has provided advertisement services to Dainik Bhaskar and Rajasthan Patrika and others and received a consideration of 15% on account of sale of the advertisement which is liable to service tax while the assessee has discharged their service tax liability on the basis of the difference between the receipts from their customer and the amount paid to the newspaper agencies on the contention that service tax on 15% is not payable as there are instances where there is no profit to the assessee. Moreover, service tax stands paid on the total receipts collected by the assessee from their customers and paying service tax again on the difference between the receipts and price paid for purchasing the space in the newspapers will amount to double taxation.

M/S SHIVRATAN ADVERTISING [OIO NO. 26/ST/JPR-II/2013, DT. 19.02.2013]

Relevant Legal Provisions:

Definition of Taxable service:-
Section 65 (105) (e): “Taxable Service” means any service provided or to be provided to any person by an advertising agency in relation to advertisement, in any manner.”

Definition of Advertising Agency:-

Section 65(3):“Advertising agency" means any person engaged in providing any service connected with the making, preparation, display or exhibition of advertisement and includes an advertising consultant and in terms of Section 65(2) of the Act, "advertisement" includes any notice, circular, label, wrapper, document, hoarding or any other audio or visual representation made by means of light, sound, smoke or gas;

Section 78 Penalty for suppressing value of taxable services-

Where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded, by reason of —
(a) fraud; or
(b) collusion; or
(c) wilful mis-statement; or
(d) suppression of facts; or
(e) contravention of any of the provisions of this Chapter or of the rules made thereunder with intent to evade payment of service tax, the person, liable to pay such service tax or erroneous refund, as determined under sub-section (2) of section 73, shall also be liable to pay a penalty, in addition to such service tax and interest thereon, if any, payable by him, which shall not be less than, but which shall not exceed twice, the amount of service tax so not levied or paid or short-levied or short-paid or erroneously refunded:…………………”;

Provided also that if the penalty is payable under this section, the provisions of section 76 shall not apply.

Issue Involved:

The issue involved in this case was that-

Whether discount received from various newspaper agencies be leviable to service tax when service tax paid on total receipts from customers?

Brief Facts:

The assessee, M/s Shivratan Advertising are registered under Section 69 of Finance Act, 1994 read with Rule, 4 of the Service Tax Rules, 1994 for discharging their service tax liability under the category of service 'Advertisement Services'. It appears that assessee has evaded the payment of service tax amounting to Rs. 43,09,577/- (Service Tax- Rs. 4190424/- + Ed. Cess- Rs. 83808/- + S. H. Ed. Cess Rs. 35345/-) during the financial year 2006-07 to 2010-11 on payment received against rendering the service under the category of service 'Advertisement Services’ by willfully suppressing and not disclosing material facts, fraudulently in contravention of the provisions of Section 66, 67, 68 and 70 of Finance Act, 1994, read with Rules 6 and 7 of the Service Tax Rules, 1994. On getting an information that the assessee is providing taxable services under the category of "Advertisement Services" to various firms/persons/organizations but are short paying or not paying Service Tax to the Government as compared to the receipts from various newspapers, the details/documents related to the case were called for from assessee by the office of the Deputy Commissioner, Central Excise Division, Jodhpur vide letter dated 10.01.2012 and vide letter dated 6.2.2012. The assessee vide letter dated 16.02.2012 submitted the copies of the Balance Sheets, Profit and loss account and the Service tax returns along with the duty paying documents. On examination of the details and the documents provided by the assessee i.e. Profit and Loss account, Balance Sheet and ST-3 returns and specimen Invoice No. 702305813 dated 27.11.2009, it was observed that assessee has provided advertisement services to Dainik Bhasker and Rajasthan Patrika and others and received a consideration of 15% on account of the sale of the advertisement as per the specimen invoices No. 702305813 dated 27.11.2009 issued by the Dainik Bhasker, where under it is clearly mentioned that discounted amount of Rs. 59997.92 was given to assessee which comes to approximate 15% of the total sale of the advertisement. It is the general practice in the advertisement services there is an incentive of 15 % of the sale of advertisement which is received by the advertisement companies on account of advertisement services provided by them. Hence, the taxable value, for the period from 2006-07 to 2010-11, has been calculated on the basis of the above said specimen invoice No. 702305813 dated 27.11.2009 issued by the News agency M/s Dainik Bhasker to assessee.

In terms of Section 65 (105) (e) of Finance Act, 1994, any service provided or to be provided to any person by an advertising agency in relation to advertisement is taxable service. Thus, the services provided by assessee in this case comes under the purview of 'Advertisement Services' and is a taxable service under sub clause (e) of the Section 65(105) of the Finance Act, 1994, Therefore, Service Tax was payable on the service provided by the assessee under Section 68 of the Finance Act, 1994 read with Rule 6 of the Service Tax Rules, 1994. The assessee were also required to assess the tax correctly and file ST-3 returns under Section 70 of the Finance Act, 1994 read with Rule 7 of the Service Tax Rules, 1994. On scrutiny of the records, submitted by the assessee, i.e. Balance Sheets, Profit & Loss account and ST-3 returns of assessee, it was found that assessee had short paid the service tax during the year 2006-07 to 2010-11.

The assessee was intimated by the Deputy Commissioner, Central Excise, Jodhpur vide letter dated 17.2.2012 that as per the records submitted by assessee the gross sales for the period 2006-07 to 2010-11 which amounts to Rs. 32,36,36,304/- and on this value the 15% commission which is received by assessee is eligible for the taxable services, which works out to be Rs. 4,85,45,446/-, but the assessee have paid service tax of Rs. 11,82,920/-, on the self assessed value of Rs. 1,08,38,260/. The assessee were required to pay the service tax of Rs. 54,92,497/- instead of Rs. 11,82,920/-. Thus, the assessee was requested to deposit the remaining amount of service tax immediately. A summon dated 01.03.2012 was issued to assessee calling them for their statement on 06.03.2012 before Superintendent(AE), Central Excise Division, Jodhpur under section 14 of the Central Excise Act 1944, which is applicable in Service Tax matters vide Section 83 of Finance Act 1994. In compliance, Shri Rajesh Mathur, Proprietor appeared and tendered his statements, wherein he admitted short payment of service tax and assured that the remaining amount of the service tax would be recalculated by them and would be deposited within 10 days. He did not reply satisfactorily on commission of 15% received by him from various news agencies, but he further stated that due to the competition in the field they forward the benefit of the commission towards the customers by way of discounts. He stated that the 15% criterion is not applicable to them as they did not have any written agreement/contract with the news agencies in respect of the receipt of the 15% of the commission amount. He also stated that they are liable for service tax on the amount of the receipts and payment made by them in respect of the sale and purchase of the advertisements. The assessee vide their letter intimated Division office, Jodhpur on 26.3.2012 that they had re-calculated the Service tax liability and interest on such short paid service tax. In this regard they submitted the account payee cheque dated 25.3.2012 for the amount of Rs. 12,65,121/- constituting Rs. 8,46,750/- as Service tax and Rs. 4,18,371/- as interest there upon. The cheque was deposited in the Govt. account for the realization of the dues. The assessee appears to have re-calculated the Service Tax on the basis of the sale and purchase of the advisement, whereas the Service Tax is to be calculated on the basis of the commission received @ 15% on the sale of the advertisement as shown in their Profit and loss account. Thus, the assessee appears to have short paid Service Tax amounting to Rs. 34,62,827/- including Education Cess and Secondary & Higher Education Cess, which appears recoverable from them under proviso to Section 73(1) of the Finance Act, 1994 invoking the extended period. They also appears liable to pay interest at the appropriate rate under Section 75 ibid. Besides, they appears liable for penalty under Section 76, 77 & 78 of the Finance Act, 1994 for contravention of the provision of Rules 6 & 7 of the Service Rules.

From the foregoing facts, the services provided by assessee to different private agencies/firms/persons/organizations appears leviable to Service Tax under the category of 'Advertisement Services' and it appears that assessee has short paid Service Tax amounting to Rs. 34,62,827/- (inclusive of Cess) leviable on the services of Advertisement Service, which was provided by them during the period 01.04.2006 to 31.03.2011. Though, assessee has obtained Service Tax Registration and has filed returns within the stipulated time as provided under the law but they have short paid the Service tax. The assessee never brought the fact to the notice of the Department that they were assessing Service Tax on the basis of the sale and purchase of the advisement and it could only be detected on detailed scrutiny of their records. Being self assessment procedure it is the liability of the assessee to pay the service tax on the correct taxable value, whereas in this case the assessee has contravened the provisions by not assessing the taxable value of services with the Balance sheet/Profit & Loss account i.e. gross receipts shown in the Profit & Loss account. It clearly shows the intention of the assessee to conceal/suppress the facts from the department with intent to evade/short payment of Service Tax. Thus, the assessee appears to have willfully suppressed the information with intent to evade the payment of Service Tax. Thus, Service Tax of Rs. 34,62,827/- (inclusive of Cess) short paid by the assessee is recoverable form them by resorting to extended period of limitation under proviso to Section 73(1) of the Act along with interest at appropriate rate under section 75 of the Finance Act 1994. The assessee appears liable for penalty under Section 76 of Finance Act, 1994 for their failure of Service Tax in contravention of the provisions of Section 68 of the Act read with Rule 6 of the Rules. They also appear liable for penalty under Section 77 for contravention of Section 70 of the Act read with Rule 7 of the Rules. The assessee also appear liable for penalty under Section 78 of the Act for short payment of Service Tax by willfully suppressing the taxable value and facts with intent to evade the payment of Service Tax and contravention of the provisions of the Act and Rules made there under. On the ground of these facts, the assessee was issued with a Show Cause Notice.

Assessee’s Contention:- The assessee made following contentions before the adjudicating authority:

The assessee contended that in the impugned show cause notice, it is alleged that they are receiving the 15% commission from news agencies on which service tax is payable. In this respect, it is submitted that they are not receiving any commission from news agencies; rather they are merely engaged in purchase and sale of advertisements; the return of which is “profit” on which they are duly paying the service tax. In this regard, they submit that the advertisement space is purchased from the news agency at certain price which is sold to their clients at some higher amount, the balance being their profit. They are engaged in purchase and sale of advertisement space in the newspapers and sometimes they do not receive any profit at all. This is clear by the fact that sometimes they are selling the advertisement in the same rate in which it is purchased. As such, it is clear that the said amount is nothing but profit arising out of purchase and sale and it would be improper to call it as a commission. This is the mechanism on which the advertisement agency works. Some portion of discount offered by the news agencies is to be passed on the client due to cut-throat competition in the market. This is the general practice adopted in the market and no one is paying the service tax on the so called discount. This is correct also because how can one pay the tax on the amount which is not received at all. As such, the contention of the impugned show cause notice demanding the service tax on the discount is not sustainable and is liable to be set aside.

In continuation to above, it is submitted that it is simply a case of purchase and sale where the profit is earned by them. There are also the cases where even no profit is being earned by them and where the profit is earned, the service tax is duly paid on the same. As such, the contention of impugned show cause notice is not sustainable.

Without prejudice to above, it is submitted that even if it is accepted for the sake of argument also that they are engaged in providing the services, then too, they are providing the same to the individuals or firms or companies, etc. They are not providing any services to the news agencies. In this respect, they take an opportunity to discuss the definitions of advertising agency and taxable service thereof.

The analysis of definitions of ‘Taxable Service’ and ‘Advertising Agency’ make it ample clear that the taxable service means any service provided by an “Advertising agency” in relation to advertisement to any person. The term “Advertising agency” means any person who is engaged in providing any service related to making preparation, display or exhibition of advertisement. Here, whenever any person needs to publish an advertisement, he approaches the advertising agency which drafts the advertisement for that person. In other words, the alleged advertising services are provided to that person, not to the news agencies as contended in the impugned show cause notice. This is further clarified by the fact that they are not receiving any amount from the news agencies, rather they are paying them. If the news agencies were service recipients, they would have paid them. But this is not the case here. The service recipient is the person seeking the advertising services as above, as such the contention of the impugned show cause notice that they are providing the advertising services to the news agencies is itself void ab intio and is liable to be quashed.

Aligning with above paras, it is submitted that the fact that the service tax is not payable on the amount of discounts has been decided in no. of cases by the hon’ble Tribunals. Some of such cases are discussed as follows:-

C.S.T., AHMEDABAD versus POORNIMA ADVERTISING & PROMOTION PVT. LTD. [2010 (20) S.T.R. 107 (Tri. - Ahmd.)]
MCCANN ERICKSON (INDIA) PVT. LTD. Versus COMMR. OF SERVICE TAX, DELHI [2008 (10) S.T.R. 365 (Tri. - Del.)]
Euro RSCG Advertising Ltd. v. CCST, Bangalore reported in 2007 (7) S.T.R. 277 (Tribunal)

The analysis of above decisions makes it ample clear that the discounts given by the newspaper agencies are not chargeable to service tax. The facts and circumstances under which the above decisions are rendered are similar to the present case where the demand is proposed on the amount of discount. Therefore, the ratio of these decisions is squarely applicable on them and the impugned show cause notice is liable to be quashed.

They further submit that the extended period of limitation has been invoked against them on the grounds that they did not bring to the notice of the department that they are not paying the service tax on the amount of discount. In this regard it is submitted that nothing contained in the law says that the assessee is required to declare the quantum of discount availed by them. There is simple requirement of paying the service tax on the taxable amount and furnishing the ST-3 returns which is done by them. There is no column therein or under any other provision/return/document to be submitted to department which requires the complete details as to amount billed, actually received/paid, discount thereon, etc. When there is no requirement of furnishing these details, it cannot be said that non-furnishing of the same amounts to suppression. It has been held by hon’ble Gujarat High Court in the case of APEX ELECTRICALS PVT. LTD. Versus UNION OF INDIA [1992 (61) E.L.T. 413 (Guj.)] that non-furnishing of the information not required under law does not amount to suppression. Similar decision was given in the following cases:-

Gufic Pharma Vs. CCE - 1996 (85) ELT 67 (T) [Affirmed by Supreme Court at 1997 (93) ELT A186]
Prolite Engineering Co. Vs Union Of India [1995 (75) ELT 257 (GUJ.)]
Unique Resin Industries Vs. CCE - 1995 (75) ELT 861 (T)

In all the above cases, it was held that the information not required to be submitted under law, if not submitted, will not amount to suppression of facts. Thus the impugned show cause notice proposing the recovery of credit on the basis of non-furnishing of information (that was not required to be submitted under law), is not sustainable and is liable to be set aside.

Further, the extended period of limitation was not invokable in this case as there is no deliberate suppression on their part. They were simply under bonafide belief based upon above cited judgments which says that the service tax is not payable on the amount of discounts. Thus, their bonafide belief cannot be equated with harsh allegations of suppression or willful misstatement. Therefore, the extended period of limitation cannot be invoked against them. Extended period of limitation can only be invoked in case of fraud, collusion, suppression or willful misstatement. In absence of these essential ingredients, extended period cannot be invoked. This has been held in the case of Chemphar Drug & Limits reported in (2002-TIOL-266-SC-CX). Thus, in the light of said decision, extended period cannot be invoked blindly in every case. Where the assessees have been acting in the boundaries of law, the extended period cannot be invoked. Further, reliance is placed on the following judgments:-

Rainbow Industries v/s. CCE [1994 (74) ELT 3 (SC)]
Pushpam Pharmaceuticals Company Vs. CCE, Mumbai reported in (2002-TIOL-235-SC-CX ) -
PADMINI PRODUCTS vs. CCE[1989 (43) ELT 195 (Supreme Court)]

Thus, in the light of above decisions, the extended period is not invokable in case the fraud, collusion, suppression or willful misstatement is not proved. Therefore, the impugned show cause notice issued by invoking extended period of limitation is not sustainable and is liable to be quashed.

They further submit that in the impugned show cause notice it is alleged that they are also liable to pay penalty under Section 78 of the Finance Act, 1994 as they have suppressed value of taxable services. In this regard it is submitted that no penalty can be imposed under Section 78 of the Finance Act, 1994 as there was no willful suppression or intention to evade payment of service tax on their part. The impugned show cause notice has not been able to clearly establish that any of these elements were in existence in this case. On the other hand, they have proved their bona fides as categorily discussed here above. It is submitted that when no such element was there, the penalty under Section 78 of the Act is not required to be imposed on them. Thus, the charge of willful misstatement or deliberate suppression has not been proved, as such, the penal provisions cannot be invoked in the light of the judgment given inCommissioner of Central Excise v/s ESS ESS Engineers [2011 (23) S.T.R. 3 (P & H). Reliance is also placed on the following cases:-

2009 (238) ELT 3 (SC) – Rajasthan Spinning & Weaving Mills
2009 (238) ELT 209 (P&H) – J. R. Fabrics
2009 (238) ELT 226 (Mad) – Thirumala Alloys Castings
2008 (228) ELT 31 (Del) – K. P. Pouches

Therefore, extending the ratio of above decisions, no penalty is imposable as the impugned show cause notice has failed to prove that there was willful suppression on their part.

It is also submitted that for imposing penalty, presence of mens-rea is a mandatory requirement and in the absence of which imposition of penalty is unjustified, as enshrined by the Hon'ble Supreme Court in the case of Hindustan Steel Ltd v/s. State of Orissa - [1978 (2) ELT (J-159)] and number of subsequent judgments from various judicial fora based thereupon. It is submitted that none of the acts were backed up with any ulterior motive or mala fide intention to evade duty and therefore, imposition of penalty is incorrect and uncalled for based on settled position on the issue. It is further submitted that the Hon’ble Punjab & Haryana High Court, following the ratio of Apex Court judgment in Hindustan Steel Ltd. (supra), has held that mens-rea is a mandatory requirement for imposition of penalty, in support of which reliance is placed on the ratio of following judgments:

2010 (258) ELT 465 (SC) – Sanjiv Fabrics
2007 (207) ELT 27 (P &H) – UT Ltd
2007 (5) STR 251 (P & H) – Kamal Kapoor

In the above decisions, it was held that the penalty is imposable only if there was mala fide intention on part of the assessee, else it will not sustain. In the instant case, no mala fide intention is proved but they have proved their case that there was no ulterior motive. There was failure to pay the service tax only due to bonafide belief based upon above referred judgments. As such, the impugned show cause notice is not sustainable and no penalty is imposable.

It is further submitted that the impugned show cause notice is proposing to impose penalties under Section 76 as well as under Section 78 simultaneously. In this regard, they submit that the Section 76 and Section 78 are mutually exclusive provisions and penalty cannot be imposed simultaneously under the provisions of both the Sections. It is provided in section 78 of the Finance Act, 1994 that if penalty is payable under section 78 than penalty under section 76 will not leviable.

When there is clear cut provision in the Section itself then there is no dispute on the same. Hence, the show cause notice is totally erroneous and liable to be set aside. It has been held by hon’ble Punjab & Haryana High Court in the case of Commissioner of Central Excise, Chandigarh-I Vs M/s Cool Tech Corporation, Chandigarh [2011-TIOL-23-HC-P&H-ST that the penalty under section 76 & 78 are mutually exclusive and cannot be imposed simultaneously. Similar decision has been given in following cases:-

M/s Anand Agencies v/s CCE (Service Tax), Coimbatore [2010-TIOL-364-CESTAT-MAD]
M/s AR AS PV PV Motors Erode (P) Ltd v/s CCE, Salem [2010-TIOL-1241-CESTAT-MAD]:
COMMISSIONER OF C. EX., SALEM Versus PHOENIX MARKETING [2010 (19) S.T.R. 755 (Tri. - Chennai)]
SAFE TEST ENTERPRISES Versus COMMR. OF C. EX., SALEM [2010 (18) S.T.R. 172 (Tri. - Chennai)]
M/s SRI Selvam Agency Vs Commissioner of Central Excise, Salem [2010-TIOL-1616-CESTAT-MAD]

All the above decisions, including the decision given by hon’ble Punjab & Haryana High Court, say that the penalty under section 76 and 78 are mutually exclusive and therefore cannot be imposed together. As such, relying on these decisions, impugned show cause notice is liable to be quashed.

Further, they submit that on the basis of decisions cited here above they were under bonafide belief that no service tax is payable on the amount of discounts. Since they has acted under bonafide belief, penalty is not imposable as held by the highest court of India – Hon’ble Supreme Court in the case of COMMISSIONER OF CENTRAL EXCISE, TRICHY Versus GRASIM INDUSTRIES LTD. [2005 (183) E.L.T. 123 (S.C.)]. In this case it is held that where the act of assessee is based on the interpretation taken by the Tribunal, penalty cannot be imposed as the act is based on bona fide belief. Therefore, penalty cannot be imposed on them for the charge of suppression of facts as they have acted under bonafide belief based on certain decisions. As such, the impugned show cause notice is not legally sustainable and is liable to be set aside.

Reasoning of the Additional Commissioner (Adjudicating Authority):-

The Commissioner held that the assessee have contested the proposed service tax on discount of 15% shown in invoices issued by the service receiver among other averments. Before examining the issues involved, it is essential to discuss the activities under taken by the assessee. It is apparent that the assessee is rendering services of advertisement services to Dainik Bhasker and Rajasthan Patrika and others and received a discount of 15% on the prices of advertisement space in their newspaper, in turn, the assessee sold these bought out advertisement space to the clients with variable incentives out of the received discount of 15% due to market conditions prevailing at the time of transaction and received actual consideration (by receiving the consideration from the clients and subtracting the consideration giving out to the Dainik Bhasker and Rajasthan Patrika & others) and paid service tax thereon. Now, it is very essential to refer the "Advertising agency services as defined under Section 65(3)) of the Finance Act, 1994. From the definitions of the of "Advertising agency services, and the activity undertaken by the assessee, they observe that the services provided by the assessee are very much covered in the definitions of the of "Advertising agency services and the service tax is recoverable on the consideration received by the assessee on rendering the said services which is further evidenced from the fact that the assessee had not contested the leviability of service tax on the said services. Further, they also observe that as per the provisions of Section 67(3) of the Finance Act, 1994, the assessee is required to pay service tax on the consideration received towards the taxable service before, during or after provision of such service as such the assessee received the net consideration by receiving the consideration from the clients and subtracting the consideration giving out to the Dainik Bhasker and Rajasthan Patrika & others is termed as the taxable value for the purpose of levying the service tax in the instant case. Thus, they are of the confirmed view that the service tax is recoverable from the assessee receiving net consideration by receiving the consideration from the clients and subtracting the consideration giving out to the Dainik Bhasker and Rajasthan Patrika & others by rendering services under the category of "Advertising agency services. Further, they also observe that the show cause notice has also proposed penal action under Section 76, 77 and 78 of the Finance Act, 1994 for contravention of provisions of Section 66, 67, 68 and 69 of the Finance Act, 1994 read with Rule 4 and 6 of the Service Tax Rules, 1994. Since the assessee had deposited the applicable service tax along with interest for the period covered in the show cause notice, it was found in force in the averments made by the assessee that they had deposited service tax along with interest thereon on their own on 25.03.2012 before the issuance of the show cause notice and informed the department on 26.03.2012 before service of show cause notice by the department as such covered under Section 73(3) of the Finance Act , 1994 which prescribed that when the person has voluntarily deposited the amount of service tax payable by him and amount of interest due thereon and has informed to this effect to the department no show cause notice shall be issued to him and the proceedings shall be deemed to be concluded against the assessee. Thus, they observe that in the instant case the assessee had deposited the Service tax and interest thereon before issuance of show cause notice , they have substantially complied with the provisions of Section 73(3) of the Finance Act, 1994, hence, no penalty be imposed in terms of provisions of Section 73(3) of the Finance Act, 1994.

Decision: Show cause notice was discharged.

Conclusion:The inference that can be drawn from this case is that in case of sale and purchase of advertisement space, the difference, in simple terms be called as profit is only liable to service tax under the category of ‘Advertising Services’ and service tax cannot be demanded by applying an average percentage of discount rate offered by the newspaper agencies on the amount paid to the newspaper agencies by the assessee.

***********

Comments

PJ/CASE STUDY/2012-13/46
16 March 2013

Post a Comment

Query

Comments

PJ/CASE STUDY/2012-13/46 16 March 2013

Post a Comment

Query

PJ/CASE STUDY/2012-13/46
16 March 2013