Audit Report under section 12A(1)(b)
CA Tushar Doctor
Audit report under section 12A(1)(b)
1.
Income of a charitable trust is exempt as per
section 11, 12. One of the conditions for availing
exemption is that accounts of the trust should
be audited if its income (without giving effect to
provisions of sections 11 & 12) exceeds exemption
"‰
for registration, provides that accounts of the trust
should be audited.
Where total income before the exemptions
u/ss. 11 and 12 of the trust exceeds the
maximum amount not chargeable to tax; i.e.,
` 1,80,000 (A.Y. 2012-13), in order to get exemption
u/ss. 11 and 12, the accounts have to be audited by
\
section 2 of Section 288, who will give his report in
Form 10B.
AAS 28 – The Auditor’s Report on Financial
Statements states that the auditor’s report should
be appropriately addressed as required by the
circumstances of the engagement and applicable
laws and regulations.
The audit report consists of 4 paragraphs.
*", 9V#
and loss account
The auditor should ensure agreement between the
>
have to exhibit a true and fair view.
2.2 Information and explanations
The audit report has to state that all information
If the income of the trust/institution referred and explanations which, to the best of the auditor’s
to in clause (iv), (v), (vi) or (via) of Sec.10(23C) knowledge and belief, were necessary for the
without giving effect to the provisions of these purpose of audit have been obtained. The auditor
clauses exceeds the maximum amount not should maintain proper working papers to show
chargeable to tax, such trusts will have to get their that the information and explanations obtained by
him from the institution are adequate.
Explanation below sub-section (2) of Section 288.
(As provided in the Taxation (Amendment) Act, The form requires the auditor to report that
2006) in form 10BB.
proper books of account have been maintained
2.
The audit report is to be given in Form no. and proper returns have been received from
10B. Report is to be furnished along with the return branches not visited by the auditor. Books of
of income. The auditor should comply with the requirements of the AAS 28 – The Auditor’s Report Act. Therefore, the books of account have to be
so written that they can lead to the preparation
on Financial Statements.
96
Income Tax Review August 2012
SS-V-86
Special Story –
of the financial statements showing a true and
fair view. The books of account should conform
to the requirements of section 44AA wherever
applicable. Likewise for branch returns, the auditor
should check the branch returns as may be deemed
necessary by him to enable him to express such an
opinion.
given by him in the annexure. (A reference to the
annexure is made at serial no (ii) of Form No. 10B).
The expression "subject to the comments given
below:" used in the sentence dealing with the
auditor’s report on the maintenance of proper
books of account and proper branch returns
indicates the qualifications which the auditor
should specify immediately below the paragraph.
A plain reading of the above requirement indicates
that the comments of the auditor are required to be
given just above the paragraph commencing with
“In my/our opinion……..” However, a reference to
foot-note 3 in the prescribed form would indicate
that the auditor’s negative report or qualifying
report can relate to any part of the report. In other
words, while the form of audit report is prescribed,
it is not possible to adhere to it absolutely in the
same form in which it is given. Under appropriate
circumstances the auditor has to indicate the
X
The various particulars in the annexure should
be based on the audited financial statements.
The auditor may also verify minutes book of the
governing body, past income-tax records, copy of
the trust deed/bye-laws/memorandum of articles,
as the case may be in order to give the details
asked for.
2.3 Opinion about the true and fair view
The prescribed form requires the auditor to
report on the truth and fairness of the financial
statements. As most trusts are not well organized,
the auditor must apply his usual checks & also
obtain management representations as to the
completeness and value of the entries in the books
of account in respect of assets, liabilities, income
and expenditure. As this report is an expression
of opinion about the truth and fairness of general
purpose financial statement, the auditor should
follow all the AASs in conducting the audit. The
auditor has to give his report in Form 10B.
There is no specific requirement for the auditor
to certify the correctness of the particulars in
the annexure to Form 10B. But he must affix his
signature at the end of the particulars, implying
thereby that the auditor is taking the responsibility
for verifying the correctness of the particulars
SS-V-87
3.
Annexure to the audit report
The annexure to the audit report contains a
statement of particulars to be given under three
parts.
4.1
Amount of income applied during the
previous year
Here the term “income” means income in
commercial sense and not total income as per
income tax assessment (i.e., sec 2(45) of Income
Tax Act). In other words, from the total receipts
the expenses necessary for earning that income
have to be deducted. The net amount that remains
would be available for distribution or application
for charitable purposes. Capital expenditure is
also application of income. The word “applied”
need not necessarily imply that the amount
should be actually spent. Even if an amount is
irretrievably earmarked and allocated for the
charitable or religious purpose(s), it would amount
to application. [CIT vs. Radhaswami Satsang Sabha
(1954) 25ITR 472, 522-3 (All); CIT vs. H.E.H. The
Nizam's Charitable Trust (1981) 131 ITR 497, 501- 02
(AP)]. For the purpose of determining the income
available for application for charitable purposes,
should the gross income be taken or the net income
after deducting all expenses incurred to earn the
income. Refer the judgement of the Supreme Court
in CIT vs. Programme for Community Organisation
[2001] 248 ITR 1. A charitable trust can accumulate
15% of its income. Here it is 15% of gross income
& not net income.
Agricultural Income: However, the agricultural
income will not form part of total income for
purpose of computing accumulation of income in
Income Tax Review August 2012
97
Audit Report under section 12A(1)(b)
excess of 15% of total income as laid down under
section 11, CIT vs. Nabhinandan Digambar Jain (2002)
257 ITR 91 (MP).
Even when the whole of the capital expenditure
may be treated as an application of income
towards charitable or religious purposes for
the purposes of section 11, the trust may also
claim depreciation in respect of the assets used
by it for its purposes on the basis of normal
commercial principles following the Circular No.
5-P (LXX-6) of 1968 dated 19th June, 1968 issued
by the CBDT.
The CBDT by its Circular No.100 dated 24th
January, 1973 (F.No.195/1/72-IT (A.1.) also
observed that repayment of loan originally taken
?
to an application of income for charitable and
religious purposes within the meaning of the Act.
It also observed in that circular that where the
object of the trust is advancement of education and
it grants scholarship loans to students for higher
?
granting of such loans, even if interest-bearing,
will amount to application of income for charitable
purposes. It was held in CIT vs. Janambhumi Press
Trust (2000) 242 ITR 457(Kar) that where the
assessee trust constructed a building out of its
accumulated income as well as from borrowed
funds, and later earned rental income from the
said building, a part of which was utilized for the
repayment of the borrowed funds, such repayment
of debt was treated to be as application of income
for purpose of section 11.
In respect of voluntary contributions made with a
corpus of the trust or institution, the conditions
regarding application of income to such receipts
will not apply.
The auditor has to report at serial no. 1 of part I
(of Annexure) details of income applied. He must
verify here whether income is correctly computed
& verify the amount actually applied during
that year. Also verify the anonymous donations.
Hence, it would be advisable for the auditor to get
appropriate management representation.
In the case of CIT vs. Institute of Banking Personnel
Selection 264 ITR 110 (Bom), the Bombay High
Court held that income derived from the trust
property is to be computed on commercial
principles. Accordingly, adjustment of expenses
incurred by the trust for charitable purpose in
the earlier years against the income earned by
the trust in the subsequent year will have to be
regarded as application of income of the trust in
the subsequent year. The High Court has also
held that the depreciation debited in the books
should be treated as expenditure for this purpose.
The concept of commercial income necessarily
envisages deduction of depreciation on assets of
the Trust. Section 11 provides that the income
of the trust is to be computed on commercial
basis i.e. as per normal accounting principles.
Normal Accounting principles clearly provide for
deducting depreciation to arrive at income.
In the case of CIT vs. Maharana of Mewar Charitable
Foundation (1987) 164 ITR 439, the Rajasthan High
Expenditure by way of payment of tax out of Court has considered the Circular dated 24th Jan,
current year’s income has to be considered as 1973 of CBDT where CBDT has considered the
application for charitable purposes because the question to whether "where a trust incurs a debt
payment has been made to preserve the corpus, for the purpose of the trust, the repayment of the
the existence whereof is essential for the trust itself. debt would amount to an application of income for
[CIT vs. Janaki Ammal Ayya Nadar Trust (1985) 153 the purpose of trust." According to said circular, if
ITR 159 (Mad)].
the trust wants to spend more money on charitable
and religious purpose, then, in a particular year,
Amount of excess application of the last year can it can take a loan and the said loan can be repaid
X out of the income of the subsequent year & the
year. [CIT vs. Matriseva Trust (2000) 242 ITR 20 repayment of the said loan amount out of the
Mad.]
income of the subsequent year would amount to
98
Income Tax Review August 2012
SS-V-88
Special Story –
application of income for charitable & religious
purpose under section 11(1)(a) of the Act. Also in
recent decision of 2009 in the case of DDIT (E) vs.
Govindu Naicker Estate (Mad) 227 CTR 283 it was
held that repayment of loan is to be treated as
application under Section 11.
Where a capital asset is transferred and entire
net consideration is utilized to acquire a new
capital asset, the whole of capital gains is deemed
to have been applied for charitable/religious
purposes. If part of the net consideration is used to
acquire a new capital asset, then the capital gains
equal to the amount, if any, by which the amount
so utilized exceeds the cost of the transferred
asset, will be deemed to have been applied for
charitable/religious purposes [Section 11(1A)].
Also refer Instruction 883 dt. 24-9-1975.
fall in the application of income & whether the
conditions stated in clause (2) of the explanation
to section 11(1) are satisfied. He must verify the
resolution passed by the governing body for
exercising the option. Also he must ensure that
Q
& keep a copy for his record. He must ensure
that investments are made as per sec 11(5) within
prescribed time. If the option is exercised, the same
must be reported by the accountant at serial no.
2 of Part I of Annexure. He has to also report the
amount for which the option has been exercised at
serial no. 2 of Part I of Annexure.
4.3
1.
Income set apart for application
As stated earlier 85% of the income is to be
applied to charitable/religious purposes.
Balance 15% can be accumulated. No
permission needs to be obtained for the
same. At serial no. 3 of Part I of Annexure,
the amount of income accumulated is to be
mentioned if the amount does not exceed
15%. If it exceeds 15% the excess amount
2.
The auditor can ask the management of the
assessee to certify the amount so set apart
for general (permitted) accumulation.
4.4
1.
Exemption under section 11(1)(c)
Under section 11(1)(c), income derived from
property held under trust –
No. 5-P (LXX, 6) dt. 19-6-1968 — The income of the
trust is to be computed in the commercial sense;
i.e., "book income". Even when the trust derives
income from property, or dividends, such income
will be computed on actual commercial basis and
not under provisions relating to income from
house property or income from other sources.
4.2
Income deemed to have been applied & its
investment in the prescribed manner.
In order to avail exemption 85 per cent of the
income derived during the year has to be applied
to charitable or religious purposes. But sometimes
it may not be possible. This may be due to the fact
that the income has not been received during the
previous year or for any other reason. In case of
shortfall, the institution can still get the exemption
provided it exercises the option for accumulation
given in clause (2) of Explanation under section
11(1).
To avail the benefit of deemed application of
income the person in receipt of the income should
exercise an option in writing before the expiry
of the time allowed under section 139(1) for
furnishing the return of income.
The auditor should check from the income-tax
computation statement whether there is any short
M
would be exempt if there is a Board’s order
and
~
€
day of April, 1952, the income may
be applied for charitable or religious
purposes, outside India.
(ii)
in case of the trust created on or after
the day of April 1952, income should
be applied outside India for such
purpose which tends to promote
international welfare in which India
is interested. The amount so spent
Income Tax Review August 2012
99
Audit Report under section 12A(1)(b)
should be reported at serial no. 4 of
Part I of Annexure.
2.
The auditor should verify here the copy
of Board’s order exempting the relevant
income; the date of creation of the trust &
the purpose for which the amount has been
applied.
before completion of assessment, the assessee will
be entitled for exemption. Similar inference may
also be drawn from the judgement of Apex Court
in CIT vs. Nagpur Hotel Owners Association 247ITR
201 (SC).
A Charitable trust is entitled to accumulate its
unspent balance for multiple purposes. It is not
necessary to intimate the details and the plan of
4.5 Income accumulated in excess of the attaining the future projects to assessing officer.
In Director of Income – tax (Exemption) vs. Daulat
#
'†" +
""~‰€
Ram Education Society (2005) 278 ITR 260 (Del)
per cent of the income referred to in clause (a) or it was held that merely because more then one
clause (b) of sub-section (1) read with Explanation to that sub-section is not applied, or is not deemed plans which the assessee has for spending on such
to have been applied, to charitable or religious purposes in India during the previous year but is deny the claim of exemption u/s. 11(2).
accumulated or set apart, either in whole or in part, If the amount applied by the trust is less than 85%,
for application to such purposes in India, such the shortfall in application is not taxable in the
income so accumulated or set apart shall not be following cases —
included in the total income of the previous year
of the person in receipt of the income provided the 4.5.3 Income is accumulated up to 5 years and the
Q
following conditions are complied with namely:Form No. 10. If accumulated amount could not be
(a)
such person specifies, by notice in writing applied due to order/ injunction of the court, such
given to the Assessing Officer in the prescribed manner, the purpose for which Form No. 10 is the same as time limit for filing
the income is being accumulated or set apart return u/s 139(1) (Rule 17). However in the case
and the period for which the income is to be of CIT vs. Nagpur Hotel Owners Association [247
accumulated or set apart, which shall in no ITR 201 SC] the Hon’ble Supreme Court has held

that in the absence of reference to time limit in the
section itself, such form can be submitted any time
(b)
the money so accumulated or set apart is
before the completion of assessment.
invested or deposited in the forms or modes
4.5.3.1 The income accumulated must be applied
~†€
for the specified purpose within the period of
4.5.2 Thus even out of the mandatory ceiling limit accumulation as per application in Form 10.
Till the accumulated amount is applied, it must
institution can accumulate or set apart a portion for be invested as specified in Section 11(5). This
""~‰€
requirement of Section 11(5) is applicable also to
those trusts who are claiming exemption under
"
|–
clauses (iv), (v), (vi) and (via) of Section 10(23C).
10 is the same time limit as for filing the return
of income under section 139(1). It has been held From A.Y. 2003-04, if the accumulated income is
in Mermanjeet Trust vs. CIT 148 ITR 214 ( P& H) credited/ paid to any trust registered u/s 12AA
and Trustees of Tulsidas Gopalji Charitable Trust vs. or referred to in sub-clause (iv), (v), (vi) or (via)
CIT 207 ITR 368 (Bom)
|–"}
of 10(23C), it shall not be treated as application of
after time limit prescribed by section 139(1) but income.
100
Income Tax Review August 2012
Special Story –
4.5.3.2 In the case of dissolution of the trust, the AO
may allow the application of income in the year
in which it is dissolved by way of transfer of the
accumulation to other trust registered u/s. 12 AA
or institution referred to in Section 10(23C). [2nd
proviso to Section 11(3A)].
4.5.3.3 If there is violation of any of the conditions
relating to accumulation of income, such income
will be deemed to be income of the previous
year in which the conditions are violated or the
previous year immediately following the expiry
of the period of accumulation. However, with the
permission of the AO, u/s. 11(3A) accumulated
amount, if could not be applied for the purpose
during the specified period, can be applied on
other objects of the trust as permitted by AO.
4.6
Investment or deposit in the prescribed
manner
Income so accumulated or set apart shall not be
included in the total income of the assessee in the
previous year in which the income is received
provided the following conditions are complied
with namely: a)
the period for which the income is to be
accumulated or set apart, shall in no case

b)
the money so accumulated or set apart is
invested or deposited as per section 11(5).
At serial no. 5 of part I of Annexure the
auditor has to mention the total deemed
accumulation & general accumulation (upto
15%).
As per Form 10 investments to be made before the
expiry of 6 months from the end of the previous
year. But note that in CIT vs. Trustees of Shri
Tekchand Chandiram Trust 184 ITR 537, 540 (Bom.)
it was held that a form cannot impose a timelimit
which statute does not provide. All investments
may not be made at the time of signing form 10.
The auditor may state here that information given
at serial no. 5 of Part I of Annexure and does not
include any investments/ which the assessee
may make subsequently before the due date of
"‡#~"€
The auditor has to state at serial 6 whether the
amount of income mentioned at serial 5 has been
invested or deposited as per section 11(5). Those
investments/ deposits which do not comply with
the statutory requirements should be segregated
and shown separately.
All investments of the trust must be in modes
provided in s. 11(5). If not, they must be brought
in conformity within 1 year from the end of the
previous year in which such investments are
acquired, Contravention results in income and
wealth of the trust being taxed at maximum
marginal rate. This restriction does not apply to:
Ÿ
1-6-1973;
Ÿ
the corpus as on 1-6-1973, by way of bonus
shares;
Ÿ
X
"\‡\"#$‡
If debentures acquired after 28-2-1983 and
before 25-7-1991, exemption is denied only
in respect of income from such debentures,
provided debentures are disinvested by 313-1992.
`
;#",,<U
1.
Investment in Government savings
certificates/other securities/ certificates
issued by Central Government under Small
Savings Schemes;
‰
‚
<Q
Savings Bank;
3.
Deposit in any account with a scheduled/
co-operative bank;
4.
Investment in units of the Unit Trust of
India;
5.
Investment in any security of the Central/
State Government;
6.
Investment in debentures whose principal
and interest are fully and unconditionally
guaranteed by Central/State Government;
Income Tax Review August 2012
101
Audit Report under section 12A(1)(b)
7.
Investment or deposit in any public
sector company (PSC); Shares of PSC
may be retained for three years and other
investments or deposits till its maturity once
PSC ceases to be a PSC;
If the income could not be spent due to non-receipt
of income, check the year of receipt. The auditor
should check that income is spent during the
previous year in which it is received or during the
previous year immediately following such year.
8.
Deposits with or investment in any bonds
\
industrial development in India;
If the income could not be applied for any other
reason, then the auditor should ensure the same
has been applied during the previous year
immediately following the previous year in which
the income was derived
9.
Deposits with or investment in any
bonds issued by an approved public
company with main object of carrying on
business of providing long-term finance
for construction/purchase of houses in
India for residential purposes or for urban
infrastructure;
10.
Investment in immovable property;
11.
Deposits with the Industrial Development
Bank of India;
12.
Any other prescribed form or mode of
investment or deposit. (for example, Units
of mutual funds referred to in s. 10(23D),
investment by way of acquiring equity
shares of a ‘depository’ prescribed).
13.
Investment in "Indira Vikas Patra" and
"Kisan Vikas Patra" are in accordance with
""~†€
– Circular No. 566, dt. 17-7-1990.
4.7 Deemed income under section 11(1B)
1.
Section 11(1B) provides that where any
income in respect of which an option is exercised
under clause (2) of the Explanation to sub-section
(i) is not applied to charitable or religious purposes
in India during the period referred to sub-clause (a)
or, as the case may be, sub-clause (b), of the said
clause then such income shall be deemed to be the
income of the person as provided therein.
2.
The auditor should checks accounts & audit
reports of earlier years & also obtain management
representation to this effect.
102
4.8 Application for non-charitable purposes
1
Where any part of the income accumulated
11(2) in any earlier year has not been applied
for charitable purposes or has ceased to remain
invested in specified securities or has not been
utilized for purposes for which it was accumulated,
then it will be treated as income in the year in
which such noncompliance occurs.
‰ §
statements and audit reports of earlier years for
ascertaining accumulations made by the trust or
institution in earlier years, application of income in
the current year out of the accumulations of earlier
year(s).
3
Many a time the auditor may not be in a
position to get all the particulars required by the
above clause. Hence, he can obtain a management
representation and thereafter verify the particulars
as given by the management and give the same
under this clause.
4
The auditor may
(a)
check the amount spent out of accumulated
income of the relevant earlier year and
whether it was spent for the same object for
which it was accumulated or not. If not, he
should mention whether the application/
permission for change of object clause was
made/obtained or not;
(b)
if the amount accumulated has ceased to
be so accumulated or was not spent for the
Income Tax Review August 2012
Special Story –
object for which it was accumulated, verify
the necessary resolution and should account
for such income accordingly;
(c)
check whether the accumulated amount has
ceased to remain invested as per section
11(5) and if any deviation is noted, report
the same;
(d)
verify the investments at the end of every
year;
(e)
examine the accounting treatment and
taxability of the accumulated surplus if
the same has not been spent or period of
accumulation has expired;
(f)
ascertain the present position of each such
accumulation and investment to verify the
following:
(i)
(ii)
(g)
5.
whether the accumulated amount has
been utilized for purposes other than
charitable or religious purposes;
whether it has ceased to be
accumulated or set apart for
accumulation thereto;
(a)
the author of the trust or the founder of the
institution;
(b)
any person who has made a substantial
contribution to the trust or institution, that is
to say, any person whose total contribution
at the end of the relevant previous year

(c)
where such author, founder or person is a
Hindu undivided family, a member of the
family;
(d)
any trustee of the trust or manager (by
whatever name called) of the institution;
(e)
any relative of any author, founder, person,
member, trustee or manager as aforesaid;
any concern in which any of the persons
referred to in clauses (a), (b), (c) (d) and (e)
has a substantial interest.
(iii)
whether the corresponding investment
is in tact or has ceased to remain
invested in any approved form;
(f)
(iv)
whether the period for which it was
accumulated has expired or not. If it
has expired whether the accumulated
portion has been used for the purpose
for which it was accumulated within
that period or in the year immediately
following the expiry thereof and
The auditor has to report at serial no. 1 to 8 of
Part II of the Annexure details of transactions
amounting to utilization of the income or
properties of the institution for the benefit of a
specified category of persons. The auditor must
obtain management representation in respect of
persons referred to in section 13(3) on which he can
rely and also obtain a management representation
on the following transactions undertaken with the
Z
prepare a detailed chart as given in
Schedule I of revised return Form No.3A
in order to have effective control over such
accumulations and investments.
Application or use of income or
_ referred to in section 13(3)
Exemption is not available under section 11
or 12 in respect of any part of income or any
9
property of the institution used or applied
referred to in sub-section (3) of section 13. As
per proviso to section 13(2)(g) any application
of income or property upto ` 1000/- in favour
of the specified persons would not disentitle
the institution from exemption. They are as
follows:
Š
persons
“
other property of the trust
<
persons.
Income Tax Review August 2012
103
Audit Report under section 12A(1)(b)
e.
f.
+
Trust – (1997) 228 ITR 292 (PH), CIT vs. Devradhan
Madhavallal Genda Trust – (1998) 230 ITR 714(MP).
& compensation received
The Supreme Court in the case of CIT vs. Nagpur
Purchase of shares, security or other
Hotel Owners’ Association 247 ITR 201, inferred
that the audit report cannot be filed after the
Sale of share, security or other property to assessment is completed. –
g.
Diversion of any income or property in
h.
Application of income or property in any
other manner for the benefit of specified
persons
i.
Medical or educational services made
8.
Debatable issues
The law relating to taxation of charitable trusts
has several debatable issues. As a result different
views may be possible. The assessee & auditor may
have different views. In such a case auditor should
state both the view points and also the relevant
information in order to enable the tax authority to
take a decision in the matter.
9.
Regarding charging appropriate audit fees
please
consider them as your corporate clients,
6. Investments held at any time
give
them
best of services – advice – your time
during the previous year(s)
and accordingly charge them at fair rate. Generally
in concerns in which persons a tendency is seen to neglect them, since they are
referred to in section 13(3) have a charitable organization and because of the other
substantial interest
commitment with your clients and to oblige the
The aforesaid reporting has to be done at part III client, this work is accepted unwillingly (without
of the Annexure. Also report here nominal value of mentioning such feelings in so many words). That
investments & income therefrom.
is not the right attitude. As on today practically all
laws (like service tax, MVAT, profession tax, labour
The auditor should obtain a list of concerns in
laws, wealth tax, TDS, etc) are applicable to a trust.
which the persons referred to in section 13(3) have
Hence, they require proper attention and thorough
got substantial interest & verify if any investments
consultation on a regular & frequent basis. For
have been made in those concerns. The auditor
client it could be one of the activities and that also
of his area of charity but for a true professional this
the concern and calculate the percentage of the
is his bread-butter and Jam. For charging one can
institution’s investment in that concern.
refer to institutes scale of fees prescribed for metro
as well as for non-metro and also one can refer the
7. Furnishing of audit report
"'!
142 (2A), which provisions and form prescribed
that the audit report should accompany the there in (i.e. Form No. 6B) is nothing but mini –
return itself. A charitable trust is entitled to version of tax audit. The time prescribed there also
claim exemption from income-tax, even if the is six months like tax audit date of six months after
audit report is submitted before completion of the year end. There the minimum rate is ` 3,750/assessment or in course of appellate proceedings. per hour and maximum is ` 7500/- per hour and it
Refer CIT vs. Hardeodas Agarwala Trust (1992) \X
198 ITR 511 (Cal). CIT vs. Shahzedanand Charity (i.e. articled clerks) also.
104
Income Tax Review August 2012
)