ANNEXURE – GSTAM – VIII

WORKING PAPERS

Date of preparation: 21.04.2021 W/P No.: 02/2020-21

I. DETAILS OF AUDIT

1. Name of the Principal place of Legal Name & Trade Name

business. M/s. Neon Cables Pvt. Ltd., Rajkot
2. Address Yamuna Industrial Area, Survey No. 22,
Behind Satyanarayan Weigh Bridge, Gondal
Road, Highway, Village : Vavdi - Rajkot –
360004, Gujarat
3. GSTIN 24AAECN2629K1ZF (SMALL - Category)
4. Period covered in present Audit July – 2017 to March – 2019
5. Date of Audit __________
6. Date of submission of Audit _________ (Draft Audit Report)
Report
7. Draft Audit Report No.
8. Details of the Audit Group Allotted to Audit Group – 03
1. Shri Jatin N. Kundalia, Superintendent
2. Shri Manoj Kumar Tanwar, Inspector.
9. Major audit objections in earlier First Audit under GST.
IAD reports.
10 Major CERA Observations in the Not available
. past

II. NATURE OF BUSINESS OPERATION OF THE TAXABLE PERSON

1. Brief description of the main goods being supplied in the proforma given below:

Sr. Description of outward HSN Exemption Rate of Tax

No. supplies Notification CT ST IGST Cess
availed
1. -
2.

The taxpayer is in the business of manufacturing and supplying of Wires and

Cables.

2. Details of principal inputs and capital goods used by the taxable person:

Details of Principal Inputs/ Capital Goods

Sr. Input Materials/ Capital HSN Exemption Rate of GST
No Goods Notification CT ST IGST Cess
.
1
2
3
4

Page 1 of 12
3. Brief details of the revenue for the last three financial years in the proforma given
below:

Total ITC availed (In Rs.) Total GST Payment (In Rs.)
Total
Year CGST SGST IGST CESS Rs. Cash Thru ITC From
2017- 0 962452 IGST
18 482406 1137700 CGST
96822
(From 835012 835012 0 2638245 791988 835012 SGST
1
July to 0 0 Cess
Mar) 1274394 2935164 Total
0 908531 IGST
0 1144975 CGST
2018- 90276
1253371 1253371 0 3409504 0 1024389 SGST
19 2
0 0 Cess
0 3077895 Total

III. DESK REVIEW AND AUDIT PLAN:

(PROCEDURE/ FORMATS SEPARATE FOR GOODS AND SERVICES)

PART – A: GOODS
Date of Preparation: 22.04.2021

1. The Auditor should check whether the Taxable person Master File is available in
MIS Section and whether the same is complete. If not, the auditor should
complete the same as far as possible from the information available in the office.
Go through the information available in Taxable person Master File. Identify and
mention (with justifications), the areas or issues which merit inclusion in the Audit
Plan.

The Taxable person i.e. – Legal Name & Trade Name: M/s. Neon Cables Pvt.
Ltd., Rajkot has not been audited under erstwhile law of Central Excise Regime.
Therefore, master File of the said taxable person is not available in MIS Section.
However, the same has been prepared on the basis of the information submitted
by the said taxable person. Ongoing through the information available, the areas
which merit verification have also been incorporated in the Audit Plan.

2. Obtain and study other documents mentioned in Annexure – GSTAM – III and
conduct examinations as illustrated therein. List out the documents studied:

Sr. Name of the document/ report Period Remarks

No From To
.
1. Audited Balance Sheet April - 2017 March,2019 --
2. Trial Balance Sheet April- 2017 June, 2017 --
3. Trial Balance Sheet July - 2017 March,2018
4. Form 26 AS July – 2017 March,2019 --
5. GSTR-9 July-2017 March,2019

Page 2 of 12
3. RATIO ANALYSIS OF DATA BASE:

Work out some of the important financial ratios as mentioned in Para 5.6.6 and
Annexure – IV. Mention the important indicators, which required to be included in the
Audit Plan.

The results of Ratio analysis may be summarised in the following table:

RATIO 2017-18 (July-Mar) 2018-19 FY

3
(a) ITC availed : Total GST 26,38,245/-: 34,09,504/- : --
payment 42,09,558/- 21,69,364/-
(b) Inward Supply Value: 1,40,51,379/- 1,87,74,032/- : --
Outward Supply Value as 2,05,56,801/- 1,70,99,407/-
per P&L Account
(c) ITC availed on Capital 1,440/- : 55,195/- 4,320/- : 24,000/- --
Goods purchased during the
years: Addition to Capital
Goods
(d) Other Income: Outward 8,24,885/- : 4,60,843/- : --
Supplies as per P&L 2,05,56,801/- 1,70,99,407/-
Account
(e) Power consumption/ fuel Not Applicable Not Applicable --
consumption (Qty.):
production quantity as per
P&L Account
(f) Gross Profit: Gross Sales as (For full FY) 12,17,872/- --
per P&L Account 20,70,922/- : 1,70,99,407/-
2,55,50,145/- [7.12% GP ]
[8.11% GP ]
No bifurcation/ data for
audit period available.
(g) Production of Goods: Scrap 2,04,44,364/- : 1,70,71,687/- : --
1,12,437/- 27,720/-
(h) Input-output ratio as per Not Applicable Not Applicable --
norms
(i) ITC availed on inward 26,38,245/-: 34,09,504/- --
supply to Total inward 1,40,51,379/- 1,87,74,032/-
supply : 18.78% 18.16 %
(j) Quantity of Actual Not Applicable Not Applicable --
production to installed
capacity

IMPORTANT OBSERVATIONS OF THE AUDITOR (LEADING TO INCLUSION IN

AUDIT PLAN)

Sr. Analysis Description Results of Analysis Auditor’s Remarks

No Performed
.
1. Quantum of GST paid Payment of GST through Eligibility of the ITC to be
through ITC ITC is 70% and 100% to verified.
the total payment of GST
in FY 2017-18 and FY
2018-19 respectively.
2. Quantum of approx. ITC Total ITC availed is Eligibility of the ITC to be
available on total approx. 18.78% and verified.
purchases 18.16% in the FY 2017-
18 and FY 2018-19
respectively of the total

Page 3 of 12
 inward supply value.

3. Mention changes in the law and rates of tax pertaining to the outward supplies
made and inward supplies since previous audit.

- The present audit is the first audit of the taxpayer under CGST Act. Thus, the
changes in law and rates of tax pertaining to the outward supply do not have
any relevance/ comparison with previous audit. However, it was observed
that there was no change in rates of taxes within the audit period.

4. Mention details of Anti-evasion cases booked in recent past or are in progress

and past audit objections, which have not been settled so far, by way of taxable
person acceptance, adjudication, appeals etc.

- As per documents available, no information related to anti-evasion is

available. Further, the taxpayer was audited in Central Excise Regime for the
period from April-2013 to March, 2017 where the following audit observation
were notice which were settled at the time of audit :
- Non-payment of Service tax on GTA services under RCM.
- Non-payment of Service Tax on Advocate Services under RCM.
- Penalty for obtaining Service Tax Registration.

5. Give details of important areas (pertaining to the goods supplied, rate of tax,
exemption notification and ITC availment on inward supplies to be included in the
Audit Plan with reasons thereof.

- The area related to proper payment of GST on existing rate alongwith

availment of exemption notification, if any, has been identified and mentioned
at Sl. No. 6 of the Audit Plan. Further, the area related to verification of the
correctness and entitlement towards availment of ITC on inward supplies, has
also been identified and mentioned at Sr. No.7 of the Audit Plan.

6. REVENUE RISK ANALYSIS:

Date of preparation: 22.04.2021

a. Perform the Revenue Risk Analysis, covering a period of at least one year or a
minimum of one return, for GST payable and paid. The GST payable may be
derived by determining the taxable outward supplies from Profit and Loss
Account and other supporting documents and reconciling with taxable persons
records. The existing GST rate may be applied to this to arrive at GST payable.
This may be compared with total GST paid as per monthly return. Mention results
indicating possible problem areas and mention issues to be included in the Audit
Plan.

- The present audit being the first audit under GST and for one year and nine
months i.e. from July-2017 to March-2019, therefore, the complete year is
available for conducting the revenue risk analysis. Therefore, after applying
the existing GST rate to the outward supplies for the FY 2018-19, the
revenue risk analysis for GST payable and paid is as follows:

Rate Of TOTAL
GST Taxable Value CGST SGST IGST CESS TAX
5% 0 0 0 0 0 0
12% 0 0 0 0 0 0
10,36,90 10,36,90 10,04,08
18% 1,70,99,406 7 7 1 0 30,77,895
28% 0 0 0 0 0 0
0.10% 0 0 0 0 0  
Total Rs. 0 0 0 0 0 0

Page 4 of 12
 - Value of outward taxable supplies - Rs.1,70,99,406/-
- Rate of outward tax liability – 18%
- Total GST payment liability during the FY 2018-19 – Rs. 30,77,893/-
- Actual GST payment during the month of FY 2018-19 – Rs.30,77,895/-
- Difference (Excess) in payment of GST during the said period - Rs. 2/-
b. Perform the Revenue Risk Analysis, covering a period of at least one year for
ITC utilization and availment and record your conclusions as to the potential
revenue loss. Value of Inward supplies purchased as per the expenditure
statement in the Profit and Loss account and other records as prescribed under
section 35(1) may be used for working out ITC available and compare it with ITC
available in ITC credit ledger (ITC PMT – 01). Mention results indicating possible
problem areas and mention issues to be included in the Audit Plan.

- The present audit being the first audit under GST and for one year and nine
months i.e. from July-2017 to March-2019, therefore, the complete year is
available for conducting the revenue risk analysis. Therefore, after applying
the existing GST rate to the Inward supplies for the FY 2018-19, the revenue
risk analysis for ITC available is as follows:

- Value of inward taxable supplies - Rs. 1,87,74,032/-

- Rate of inward tax liability – 18%
- Total ITC available during the FY 2018-19 – 33,79,326/-
- Actual ITC availed during the month of FY 2018-19 – Rs. 34,09,504/-
- Difference (Excess) in availing ITC during the said period – Rs.30,178/-

Further, the area related to verification of the correctness and entitlement

towards availment of ITC on inward supplies, has also been identified and
mentioned at Sr. No.7 of the Audit Plan.

7. TREND ANALYSIS:

Undertake analysis of trends as illustrated in Para 5.6.9 or other trends as

deemed relevant. Mention issues to be included in the Audit Plan.
The results of Trend Analysis may be summarised in the following table.

(Ratios marked with * are to be determined only in case the registered person is into
manufacture)
Year 2017-18 2018-19
(July-March, 2018)
Cost of production of major 2,20,50,029/- (For Full 1,56,33,424/-
finished goods (as per cost record) year)
*
Quantity of inputs consumed in the 100831.00 kgs Not applicable
production of finished goods *
Value of inputs consumed in the 1,40,51,379/- 1,87,74,032/-
production of finished goods *
Value of outward supplies 2,55,50,145/- (For Full 2,88,84,969/-
Year)
Difference in ITC taken & ITC Not Applicable Not Applicable
available on purchase of raw
materials
Job Work Income as per P&L 0 0
Account or Trial balance
Inter unit transfers/ sales to related No Inter Unit transfers No Inter Unit
party as per Balance Sheet as per Balance Sheet. transfers as per
Taxpayer Balance Sheet.
Taxpayer
Gross operating profit vis-à-vis (For full FY) 12,17,872/-
sales 20,70,922/- : 1,70,99,407/-

Page 5 of 12
 2,55,50,145/- [7.12% GP ]
[8.11% GP ]
No bifurcation/ data for
audit period available.
GST paid by debit in Electronic 29,35,164/- : 21,69,364/- :
Credit Ledger vis-à-vis GST paid 12,74,394/- 0/-
by debit in Electronic Cash Ledger
GST paid by debit in ‘Electronic 29,35,164/- : 21,69,364/ :
Credit Ledger’ vis-à-vis Total GST 42,09,558/- 21,69,364/- =
paid 70% paid by Credit 100% paid by
Credit
Production of finished goods/ 3,78,25,974/- : Not available/-
outward supplies * 2,55,50,145/-
(Value for Full year)

Production of scrap/ production of 1,12,437/-: 27,720/- :

finished goods 2,04,44,364/- 1,70,71,687/-
Production of outward taxable 2,20,50,029/- (For Full 1,56,33,424/- : 0
supplies/ vis-à-vis exempted year) : 0
supplies *
Outward supplies made for home 2,05,56,801/- : 0 1,70,99,407/- :
consumption Vs export supplies 0
Value of outward supplies made to No outward supplies to No outward
related person vis-à-vis total value related person supplies to
of supplies related person
Movement of inward supplies vis- Not applicable Not applicable
à-vis total production *
Movement of inward supplies/ Not applicable Not applicable
goods manufactured on job-work
vis-à-vis total production *
Input output ratio as per norms Not available. Not available.

IMPORTANT OBSERVATIONS OF THE AUDITOR (LEADING TO INCLUSION IN

AUDIT PLAN)

Sr. Analysis Results of Analysis Performed Auditor’s Remarks

No Description
.
1. Payment of GST The payment of GST through Availment and utilization of
through ITC Cash is 30 % and 0% of the ITC is to be verified.
total GST payment for the FY
2017-18 and 2018-19
respectively. Thus, major
portion is through ITC.
2. TRANS-1 The taxpayer has carried Entitlement and correctness
forward Balance of of the transitioned credit is
Rs.3,02,688/- through TRAN- to be verified.
1. However to be verified at
the time of audit.

8. FINANCIAL AND TAX ACCOUNTING INFORMATION:

Date of Preparation: 22.04.2021

a. Obtain audited Balance Sheet and Profit and Loss Account and Trial Balance.
Review any notes in the Balance Sheet/ Profit and Loss Account. If unit is a
division of a company, check if internal financial statements are prepared for the
unit before consolidation with other related units. Work out purchase value of

Page 6 of 12
 inward supplies to value of outward supplies ratio and compare with ITC ratio.
Obtain a copy of last two reports. Mention issues to be included in the Audit Plan.

- Obtained the audited Balance Sheet for the FY 2017-18 and FY 2018-19 and
it was observed that the unit is not a division of any company but is the Pvt.
Ltd., Company. Therefore, the consolidation of the financial statements with
other related units does not arise. Further, as per the information provided
under the GST Registration Certificate in Form GST REG – 06, the taxpayer
has declared no additional place of business. The ratio as desired is not
applicable as the taxpayer is a Pvt. Ltd. Company and has no other division

b. Identify all business activities like supply of goods/ supply of services like repair,
service activities and major source of ‘Other Income’. Mention issues to be
included in the Audit Plan.

- As per the information/ documents provided/ submitted by the taxpayer, it

appeared that they are engaged in the manufacture of Wires and Cables and
are not engaged in providing in any type of taxable services. However,
ongoing through the Trial Balance Sheet for the Audit Period i.e. from July-
2017 to March-2018 and Audit report for the FY 2018-19, it was observed
that they had booked income related as mentioned below under the
accounting head Other Income i.e. “Indirect incomes”. In order to verify the
liability of payment of GST on any of the type of income accounted under the
accounting income “Indirect Income”, the area has been identified and
mentioned at Sr. No. 2 of the Audit Plan:

2017-18
Direct Incomes (July to 2018-19
March)
Interest on Recurring Deposit 37 885 0
Interest Subsidy 7 87 000 4 52 715
Kasar 0 8 128
Total Rs. 8 24 885 4 60 843

c. Compare total turnover as per profit and loss account with the corresponding
figures submitted to the department in the returns for three years. Mention
discrepancies to be included in the Audit Plan.

- The present audit being the first audit of the taxpayer under the CGST Act, no
previous figures are available. However, the total turnover as per the Trial
Balance Sheet for the FY 2017-18 (From July-2017 to March-2018) and Audit
Report for FY 2018-19 is as under :

Period TO as per TO as per Difference

TB/Audit Report GSTR 9
2017-18 2,05,56,802/- 2,05,56,802 --
(July-March, 2018
2018-19 1,70,99,407/- 1,70,99,407/- --

Thus, prima facie, there is no difference in turnover, however the area has
been identified and mentioned at Sr. No. 1 of the Audit Plan.

Page 7 of 12
GATHERING INFORMATION ABOUT TAXABLE PERSON AND THE SYSTEM
FOLLOWED BY HIM

Date of Preparation: ___________ (on date of audit)

i. INTERVIEWS
(i) Person(s) Interviewed, their designation and dates of interview.

Shri _________________________________________

Give the gist of interviews especially in respect of -

i. Related ventures, business with these ventures and annual volume of

such transactions –

ii. Relationships with the unit and its owners/ shareholders –

iii. The head office/ registered office of the unit, location of its operations and
location of its accounting records

iv. Whether company is an ancillary unit or independent unit of production –

v. Internal controls in the unit –

vi. Any organizational or systemic changes that have occurred since last
audit

Mention issues to be included in the Audit Plan.

- Based upon the above information, no such fresh issues were noticed,
which were required to be included in the Audit Plan.

EVALUATION OF INTERNAL CONTROLS

(Please refer Para 5.7.1, 5.7.2 and Annexure – VI)

Date of Preparation: __________ (on Date of Audit)

i. Perform a walkthrough for the sales/ records maintained. Trace a
sample of transactions (all types, including those on Credit) from
source documents through the GST account. Mention any new
area need to be included in the Audit Plan or whether the extent of
verification of the issue already identified in the Audit Plan needs to
be modified.

ii. Perform a walkthrough of the purchase system (including capital

assets). Trace a sample of transactions, of all types, including
Credits, from source documents through GST account. Examine
specifically system for purchase, rejection, short supply etc.
Mention any new area need to be included in the Audit Plan or
whether the extent of verification of the issue already identified in
the Audit Plan needs to be modified.

iii. Perform a walkthrough of any other system (e.g. Stores Journal

Entries, ITC accounting etc.). Trace a sample of transactions of all
types from source documents through the GST account. Mention
any new area need to be included in the Audit Plan or whether the
extent of verification of the issue already identified in the Audit Plan
needs to be modified.

Page 8 of 12
 iv. Perform a walkthrough of the process of compiling GST Return for
one month, tracing from the tax return amounts backwards through
to their sources. Check supplies as per outward supply account in
ledger with value shown in monthly return. Mention any new area
need to be included in the Audit Plan or whether the extent of
verification of the issue already identified in the Audit Plan needs to
be modified.

v. Evaluate the soundness of level of internal control of each of the

following areas/ sub-systems and grade them as good, acceptable
or poor in the following format:

In case quantum of data/ information to be analysed is voluminous, apply ABC

analysis (please refer para 5.7.2)

Name of area/ sub system Grade Problem areas, if

(good/ acceptable/ any
poor)
Sales --
Purchase --
Tax Accounting --
Posting to General Ledger and --
Journals (specially of higher value
transactions)
Recording of invoice --
Recording of cash sales and --
purchases
Credit/ Debit and their --
documentations
Other expenditures --
Recording of and availment of ITC --
Accounting of scrap/ wastes --
Account adjustments --
Others --

vi. Any other relevant information gathered by the auditor during the
course of Evaluation of Internal Control. Mention any new area
need to be included in the Audit Plan or whether the extent of
verification of the issue already identified in the Audit Plan needs to
be modified.
AUDIT PLAN:

(Please see para 5.8 and Annexure – VII)

Date of Preparation:

Audit Plan approved by: The Joint Commissioner, CGST Audit Commissionerate,
Rajkot.

i. The Audit Plan must be based on the issues identified in the previous steps
as to be verified during the conduct of audit and must be specific in the
following format (also given in Annexure – VII):

Sr. Subject Specific Records/ Coverage Selection

No. Issue Documents Period Criteria
Code
The Audit Plan is available on note sheet page no.’s II and III of F. No.
VI(a)/08-54/Circle-I/AG-03/2020-21

Page 9 of 12
 IV. AUDIT VERIFICATION AT THE UNIT:
A. OUTWARD SUPPLY/ SALES INFORMATION:

Date of Preparation: ____________ (Date of Audit)

i. Indicate marketing/ clearance pattern in the following proforma: -

Sr. Nature of Sale/ Transfer etc. Yes No If yes, * Practice of

No description valuation
. of product followed by the
(s) taxable
person.
1. Direct supply by the registered Cotton
person Dress
2. Supply through the depot/
distributors/ consignment agents/
Marketing intermediaries.
3. Inter Unit Transfers (not amounting
to supply)
4. Inter Unit Transfers (amounting to
supply)
5. Self (Captive) consumption
6. Supply to U.N. and other aided
projects
7. Inward supplies received and job
work done
8. Inward supplies/ semi-processed
material sent for job work outside
9. Outward supplies made from Job
workers premises directly to the
customers

ii. Examine selected recipient’s ledger (customer) to find out any amounts other
than those shown in Tax invoices are realised (Check Debit Note and journal
vouchers also).

iii. Identify other revenues as reported in the financial statements (Incomes other
than from sales). Mention such other revenues which may form part of the
assessable value.

- Various Income other than sales have been reported under the accounting
head titled as “Indirect Incomes” in the Trial Balance Sheet / Audit Report for
the Audit Period. The area has been identified and mentioned at Sr. No. 2 of
the Audit plan.

B. INWARD SUPPLY (INPUTS)/ PURCHASE INFORMATION:

Date of Preparation: ____________ (Date of audit)

a. Goods

I. List major suppliers, inward supply of goods purchased and indicate

annual volume in Rupees. Whether, there are inward supplies purchased
from related units?

II. Examine selected creditor’s account (supplier) for each major input to find
out any purchase returns, short supply, rejection of goods etc. and its
impact on ITC availment.

Page 10 of 12
 III. Study the purchase details of major capital goods acquired and in the
course of or furtherance of business.

b. Services

I. List major input services on which credit has been availed.

II. Examine selected ‘credit accounts’ for each major input services to verify
whether payment has been made prior to availment of credit.

III. Examine whether any input services may have been used in the exempted
services.

IV. Examine whether any taxable services have been received from a service
provider located outside India and verify whether GST due on such
transactions if any, has been paid.

C. OTHER INFORMATION:

Date of Preparation: ____________ (Date of Audit)

I. Study whether any goods are captively consumed. Mention issues to

be included in the Audit Plan.

II. Study whether any supplies are made to distinct persons, inputs/
partially processed intermediates sent for job work or received for job
work. Study the valuation and ITC availment in such cases. Mention
issues to be included in the Audit Plan.

III. Any other relevant information gathered by the auditor during the
course of gathering information about taxable person, and systems
followed by him and study of financial documents. Mention issues to be
included in the Audit Plan.

V. VERIFICATION AS PER AUDIT PLAN:

(Please see Chapter 5)

A. Carry out verification as per Audit Plan. The result of verification of each of
the issues should be mentioned in the format below, whether or not there
is any detection of discrepancy/ audit point. The verification reports in
respect of issued verified which was not part of the original Audit Plan but
verified later should also be mentioned at the end.

VI. Proforma of a Verification Report

As per separate sheets attached.

Sr. Description V. P. No. Date

No.
i. Name of the auditor verifying the
issue
ii. Issue involved in brief
iii. Ref. No. of the Audit Plan
iv. Documents verified
v. Brief account of the process and
extent of verification
vi. Auditor’s observation and conclusion
in brief
vii. Quantification of revenue involved, if
any (also give the calculation sheet)

Page 11 of 12
 viii. Documents relied upon to support the
conclusion
ix. Party’s agreement : Yes/ No
x. If yes: In
writing/ oral
xi. Amount of recovery, if any

Signature of the auditor

Supervisor’s remarks and signature.

POST VERIFICATION

(to be filled up before leaving the taxable person’s unit)

Date of Preparation: __________ (Date of Audit)

A. Indicate information provided and specific actions suggested to the taxable

person to improve future compliance. Where the taxable person is in agreement
with the suggestions, request a commitment in writing and include it in the Audit
Report. If the taxable person is unwilling to give a written undertaking, obtain a
verbal commitment. Mention results.

B. SUMMARY OF AUDIT RESULTS:

Provide an outline of all objections, which involve short/ non levy of tax, amounts
(say under section 76 of the CGST Act), irregular availment/ utilization of credit and
non-payment of interest due. Details of objections of technical/ procedural in nature
without involving revenue/ credit/ interests/ amounts should also be mentioned.
Indicate whether the taxable person has agreed to the objections and if so, has
made spot payment (if so details thereof). The summarised objections are to be
uploaded in the audit utility and a draft audit report is to be generated for discussion
during the Monitoring Committee Meeting.

ON CONCLUSION FAR IS REQUIRED TO BE SENT IN PROFORMA GST ADT –

02 TO THE AUDITEE WITHIN 30 DAYS.

Manoj Kumar Tanwar,

Inspector,
Group-03.

Jatin N Kundalia,
Superintendent
Name/ Designation – As indicated in Part I, point no. 8.
Group No.: AG 03.
Place: Rajkot (Circle – I - Rajkot)
Date: _____________ (Date of audit).

Page 12 of 12