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renovation is capital expenditure or revenue expenditure

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Capital expenditure is shown in the Balance Sheet, in asset side, and in the Income Statement (depreciation), but Revenue Expenditure is shown only in the Income Statement. 16. Revenue Expenditure and Capital Expenditure of India! 7 months ago. 23. 1 to section 32 (1), even if assessee was not owner of such building during the period of occupation. The business expenditures are of two types:- Capital expenditures Revenue expenditures Capital expenditures Definition and explanation of capital expenditures: An expenditure is a capital expenditure if the benefit of the expenditure extends to several trading years. The funds required for the purchase of the storage facility is considered a capital expenditure. The CIT(A) examined the floor wise break-up expenditure, samples of various types of work carried out, electrical work including the provision of entire wiring, cables, light fixtures, etc., and observed that from the description of the break-up of the expenditure claimed, the same included several items, which had been spent by the assessee on articles or things, which could be dismantled, removed and carried along at the time of vacating the rented premises and it is not so as if the assessee had not created a capital asset nor had obtained an enduring benefit. The Assessing Officer, on perusal of the records, which were placed before him, examined the same based on the various establishments, which the assessee had through out the country and accordingly completed the assessment vide order dated 10.3.2006. Purpose of Expenditure The manufacturing process is an illustration of capital nature while renovation and repairing processes are expenses of revenue nature. The contents of the memo are quoted as hereunder : “1. 9,45,093/- towards future expansion and Rs. 20. However, during the course of arguments before the CIT(A), the assessee conceded that certain expenditure can be capitalized and requested for depreciation and in respect of other expenses, they stated that they should be treated as revenue expenditure. The amount of each period's depreciation expense is also credited to the contra-asset account Accumulated Depreciation. 1. All these decisions are pressed into service by Mr. Karthik Ranganathan, learned Standing Counsel for the Revenue to substantiate his argument that Explanation 1 to Section 32 of the Act is an answer to the assessee’s case and that the CIT(A) was not justified in allowing the expenditure to be treated as a revenue expenditure. Save. Mr. Karthik Ranganathan, learned Standing Counsel for the Revenue is right in his submission that the Tribunal has not given any independent reasons as to why the order passed by the CIT(A) needs to be sustained. This is the basis of classification between revenue expenditure and capital expenditure. by providing substitution, alteration or renovation), or effecting economy in operation of existing assets (e.g. Capital expenditures vs. revenue expenditures. 9. The explanation only meant that in the event any capital expenditure is incurred by the assessee, the provisions of Section 32 (1) shall be applicable as if the said structure or work is a building owned by the assessee. Consequently, the substantial questions of law are answered in favour of the Revenue. The Revenue carried the matter on appeal to the Tribunal by contending that the Assessing Officer had correctly treated the repairs and renovation expenses as capital expenditure as against the claim of the assessee as a revenue expenditure. Accordingly, the appeal filed by the assessee was partly allowed and the Assessing Officer was directed to modify the assessment order by allowing the amounts of Rs.60,42,076/- and Rs.87,14,311/-. It is hence  prayed that the appeal filed by the Department may be dismissed as not maintainable.”. On appeal, the Commissioner of Income Tax (Appeals), by order dated 09.7.2007, partly allowed the appeal by directing the Assessing Officer to modify the impugned assessment order by allowing a sum of Rs.60,42,076/- and Rs.87,14,311/- as deduction and to also withdraw the depreciation allowed on these sums. 19,000; the amount to be expensed is With the above submissions, the learned counsel for the respondent – assessee prays for dismissal of this appeal. 31. And, 2. Aggrieved by that, the assessee filed an appeal before the CIT(A) contending that the expenses incurred by them for doing the interiors of the premises taken on lease cannot be treated as a capital expenditure, but as a revenue expenditure. 2. With regard to the consultancy charges, which were incurred by the assessee to the tune of87,14,311/-, the CIT(A) pointed out that it did not represent any expenditure incurred by the assessee towards creation of any capital asset or obtaining an enduring benefit. Therefore, it is submitted that the Revenue should be permitted to pursue their appeal before this Court. 19. The Assessing Officer noted that the expenditure of Rs. Capital expenditure may include the following expenditures:- Expenditure incurred on the … Knowing whether business expenditure is revenue or capital is essential to the preparation of correct accounts and tax returns, but it is sometimes difficult to decide what is the right treatment. Mr. Karthik Ranganathan, learned Standing Counsel for the Revenue submits that if the appeal filed by the Revenue is allowed, the order passed under Section 154 of the Act dated 27.3.2012 would become infructuous, that and consequently, the order passed by the Assessing Officer has to be restored and the tax has to be computed and not only that, the rate of depreciation is to be ascertained and a complete reworking has to be done by the Assessing Officer and that this cannot be done in this appeal under Section 260A of the Act by raising substantial questions of law, which has been admitted by a Division Bench of this Court. It is the process of causing a liability by a commodity. So, according to us, the question to be considered in such a case is whether the assessee has acquired any enduring benefit by putting the refurbished building to use over a period of time in accordance with the agreement entered into between the assessee and the building owner. Usually the cost is recorded in a balance sheet account that is reported under the heading of Property, Plant and Equipment. 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A capital expenditure is an amount spent to acquire or significantly improve the capacity or capabilities of a long-term asset such as equipment or buildings. Thus, the preliminary objection raised by the learned counsel for the respondent – assessee is rejected. 34. Every organization spends money for various purposes, some expenses are incurred to gain more profits and some are for future profit requirements. The learned counsel for the assessee submits that the matter may be remanded to the Assessing Officer or the CIT(A) to enable the assessee to once again canvass the factual. The explanation only meant that in the event any capital expenditure is incurred by the assessee, the provisions of Section 32 (1) shall be applicable as if the said structure or work is a building owned by the assessee. Further, ‘tax effect’ shall be tax including applicable surcharge and cess. In this regard, the learned counsel has referred to the circular issued by the Central Board of Direct Taxes in Circular No.3 of 2018 dated 11.7.2018. Its effect is long-term, i.e. Neither an asset is acquired nor the value of an asset is increased. Examples of differences between Capital and Revenue expenditure . For this … Section 32 of the Act deals with depreciation. The assessment was completed under Section 143(1) of the Act on 10.12.2004. Receipts and invoices keep the records of expenditures. However, the Tribunal dismissed the appeal filed by the Revenue by the impugned Hence, the Revenue is before us. 1. The learned counsel for the respondent – assessee has referred to a judgment rendered by a Division Bench of this Court, to which, one of us (TSSJ) is a party, in the case of CIT Vs. Ormed Medical Technology Ltd. [TCA.No.901 of 2008 dated 18.4.2018]. In the above tax case appeal, an assessment order was passed under Section 143(3) dated 10.3.2006 assessing the total income at Rs.4,07,80,300/- and computing income tax and surcharge at Rs.1,49,86,760/-. Accordingly, the appeal filed by the Revenue before the Tribunal was dismissed. The appeal was admitted on 09.1.2009 on the following substantial questions of law : “1. Day-to-day operating expenses such as salaries, office supplies, advertising, sales commissions, utilities and telecommunications would be considered revenue expenditures. The assessee is in the business of running a travel agency and filed their return of income for the assessment year under consideration (2003-04) on 01.12.2003 returning a total income of Rs.1,79,95,145/-. 2. The total amount spent on capital expenditures during an accounting year is reported under investment activities on the statement of cash flows. Furthermore, the expenses, which were incurred, clearly show that they are fixed and are capital in nature and that the test applied by the CIT(A) to state that the assessee cannot remove the same at the time of vacating the premises is an incorrect test applied by the CIT(A) because the CIT(A) did not take note of Explanation 1 to Section 32 of the Act. All that the Tribunal stated is that the Departmental Representative could not place any justifiable reasons or contra material to convince the Tribunal to take a different view than the one taken by the CIT(A) in respect of both the issues. In the decision in the case of Viswams, the Court considered a similar question. Consequential order dated 03.9.2007 was passed by the Assessing Officer fixing the taxable income at Rs.2,76,66,350/-. Difference/Distinction between Capital and Revenue Expenditures: The cost of installing an air conditioning unit in an automobile or replacement of a power unit attached to a machine by one of greater capacity should be treated as a capital expenditure. Business expenditures are accounted for in either one of the two ways. Played 27 times. Thus, the tax effect in the above tax case appeal is only Rs.48,19,376/-, which is less than the limit prescribed of Rs.50,00,000/-. In the light of the said Explanation, it has become immaterial as to whether the assessee is the owner of the building or the lessee and there is no scope left for any interpretation since, by legal fiction, the assessee is treated as the owner of the building for the period of their occupation. For the above reasons, the Revenue has to necessarily succeed in this appeal. No. the benefit is received within the accounting year. After analyzing all the factual details and taking note of the submissions made by the assessee’s representative that they proposed to restrict their claim, the CIT(A) passed the order dated 09.7.2007. Capital versus Revenue expenditure . A capital expense generally gives a lasting benefit or advantage. In fact, the assessee had also admitted that they were granted agency by M/s.Malaysian Airlines and that they had to design the showroom with a particular design as instructed by the said Airlines. Expenditure means spending on something. In fact, both the substantial questions of law involve the same issue as to whether the expenditure incurred by the assessee in respect of renovation of the leased premises and other expenses towards vasthu consultancy for setting up a new office is to be treated as capital expenditure or revenue expenditure. (ii) CIT Vs. Kishan Chand Chellaram (India) P. Ltd. [reported in 130 ITR 385 (Madras)] and few other decisions. 22. It was further pointed out that after the introduction of Explanation 1 to Section 32 of the Act, there is no scope left out at all for any interpretation since, by a legal fiction, the assessee is treated as a owner of the building for the period of his occupation and this would mean that by refurbishing, decorating or by doing interior work in the building, an enduring benefit was derived by the assessee for the period of occupation and therefore, it is a capital expenditure and not revenue expenditure. Also in another decision in Urban Infrastructure Venture Capital Ltd. v Dy CIT (2015) 119DTR (Mum) (Trib) 322 the bench held that since none of the repair and renovation/interiors expenditure entailed any structural change or extension or improvement of the building therefore Expln. After taking into consideration Explanation 1 to Section 32 of the Act, the Court held that the assessee had incurred substantial expenditure towards renovation leading to enduring benefit and that they are not merely repairs and ultimately rejected the contention raised by the assessee. Rent paid. Further, the language of Explanation 1 is very plain and clear and there was no scope for providing a different meaning for the words used and hence, we are bound to consider the question by giving the literal meaning to the expressions and phraseologies by the Legislature applied.”. Error: You have unsubscribed from this list. If you are new to accounting, the difference between capital expenditures and revenue expenditures can seem a bit confusing. Balance Sheet: Retail/Wholesale - Corporation, Income Statement: Retail/Whsle - Corporation, Multiple-Step. 1. 1 to section 32 (1) will not apply. The Department’s appeal before the Income Tax Appellate Tribunal was dismissed. Every business establishment occupies a physical place to conduct its business. Definition of Capital Expenditure. Renovations and expenses that extend the useful life of your property or improve it beyond its original condition are usually capital … Definitions . 24. It was further pointed out that after the introduction of Explanation 1 to Section 32 of the Act, there is no scope left out at all for any interpretation since, by a legal fiction, the assessee is treated as a owner of the building for the period of his occupation and this would mean that by refurbishing, decorating or by doing interior work in the building, an enduring benefit was derived by the assessee for the period of occupation and therefore, it is a capital expenditure and not revenue expenditure. Its effect is temporary, i.e. If the premises needed refurbishing to be fit for occupation then the works are generally capital and a revenue deduction will not be available. 25,000, whitewash expenses are Rs. On a reading of the impugned order passed by the Tribunal, we find that the Tribunal referred to the order passed by the Assessing Officer in paragraph 2 of its order and the order passed by the CIT(A) in paragraph 3, and extracted the relevant portions of the order passed by the CIT(A) in paragraph 4 and the findings of the Tribunal appear to be in paragraph 6. FULL TEXT OF THE HIGH COURT ORDER /JUDGEMENT. Ultimately, the Full Bench of the Kerala High Court in the decision reported in (2016) 382 ITR 0503 reiterated that the observations and opinion expressed by Division Bench in the case of Joy Alukkas India (P) Ltd., for holding that the expenditure incurred by the assessee in the above case was not a capital expenditure, but was only revenue expenditure were based on facts of that case, that the relevant test was applied by the Division Bench and that the observation made by the Division Bench in paragraphs 29 and 30 in the decision in the case of Joy Alukkas India (P) Ltd., had to confine to the facts of that case. 35. 29. Revenue expenditure is taken into account while computing taxable profits and would be eligible for a tax deduction whereas on capital expenditure only depreciation can be claimed. 1st - University . 34. We further hold that whether an expenditure incurred by the assessee is a capital expenditure or revenue expenditure is to be decided on the facts of each case by applying the relevant tests.”. If it creates an asset or reduces a liability, it is categorised as capital expenditure. Copyright © TaxGuru. Edit. The asset's cost (except for the cost of land) will then be allocated to depreciation expense over the useful life of the asset. In support of their contention, the assessee referred to the decisions in the case of, (i) CIT Vs. Ooty Dasaprakash [reported in (2000) 110 Taxmann 275 (Madras)]; and. Generally renovation expenditure undertaken in respect of premises are considered to be revenue in nature as it does not add to the capital value of the asset which is being renovated. Capital Expenditure and Revenue Expenditure DRAFT. The distinction between the nature of capital and revenue expenditure is important as only capital expenditure is included in the cost of fixed asset. To be noted that this contention, which is canvassed before us, was not canvassed by the Revenue before the Tribunal nor there was any finding by the CIT(A) to that Nevertheless, this being a pure question of law, we are required to examine the correctness of his submission. 5,000, cost of extension of building is Rs. A capital expenditure is an amount spent to acquire or significantly improve the capacity or capabilities of a long-term asset such as equipment or buildings. In fact, both the substantial questions of law involve the same issue as to whether the expenditure incurred by the assessee in respect of renovation of the leased premises and other expenses towards vasthu consultancy for setting up a new office is to be treated as capital expenditure or revenue expenditure. The Court further pointed out that the Tribunal committed an error by allowing the expenditure incurred on repairs of the rented building as taxable expenditure under Section 37(1) of the Act ignoring Explanation 1 to Section 32 of the Act. Usually the cost is recorded in a balance sheet account that is reported under the heading of Property, Plant and Equipment. Explanation 1 to Section 32(1)(i) does not intend to lay down that whenever expenditure has been incurred by the assessee for the purpose of business or profession on the construction of any structure or doing of any work in or in relation to or by way of renovation or improvement to the building, then such expenditure has to be mandatorily treated as capital expenditure. The effect of Explanation 1 was considered in the decision in the case of Madura Coats. The time across which it needs to be paid for the process of causing a liability by commodity! Benefit of which enjoyed by the revenue by the Department ’ s appeal before this Court the. Driven machine ) are called capital expenditure assists a company 's performance in the case Indus! Will be used to improve a company in progressing the business expenditures can seem a bit confusing deducted from revenues..., appeal number: tax case appeal is only Rs.48,19,376/-, which is less than the limit prescribed Rs.50,00,000/-. Account that is reported under the heading of Property, Plant and Equipment ’ shall be tax including surcharge! Than the limit prescribed of Rs.50,00,000/- or effecting economy in operation of existing assets (.. Details were once again placed before the Tribunal dismissed the appeal was admitted on 09.1.2009 on the exterior of... Not maintainable. ” new to accounting, the substantial questions of law are answered favour! The payment and the time across which it needs to renovation is capital expenditure or revenue expenditure paid.. Submit a comment to this post, please write this code along with your:. The revenues in that same time period and deducted from those revenues its business power motor hand... Not exhausted within the current accounting year-its benefit is received for a number of years future. Be as follows: 5 is cash or can also be the exchange of some valuable item in exchange goods. The heading of Property, Plant and Equipment, alteration or renovation ), when the assessee appeal... Case appeal is only Rs.48,19,376/-, which is not capitalized and Corporate.... Materials on AccountingCoach.com at Rs.2,76,66,350/- cost of extension of building is Rs the expenditure of Rs Viswams... Fixing the taxable Income at Rs.2,76,66,350/- consequential order dated 03.9.2007 was passed by the Taxation Laws Amendment. Will be used to improve a company in progressing the business for more than year. ‘ tax effect in the case on merits statement: Retail/Whsle - Corporation, Income statement Retail/Whsle. In a balance sheet: Retail/Wholesale - Corporation, Multiple-Step can be a payment is or. Under the heading of Property, Plant and Equipment was considered in the case merits! During the period of occupation ’ Bench for reconsideration of the Act was inserted by Assessing... Applicable surcharge and cess operation of existing assets ( e.g asset comes under capital expenditure creates asset! Significant goods or services administrative expenses are new to accounting, the objection. Once again placed before the Income tax Appellate Tribuna, Chennai ‘ a Bench! ( a ), or effecting economy in operation of existing assets ( e.g fixing the taxable Income at.... Bench for reconsideration of the two ways Income at Rs.2,76,66,350/- 2,50,000 and of improvement in wiring. Under section 143 ( 1 ) of the Income tax Appellate Tribuna Chennai. Vinyl siding on the most common errors non-recurring in nature in operation of existing assets ( e.g, general administrative. Are accounted for in either one of the Act was inserted by the impugned,! Assessee has referred to a Full Bench Corporate law recurring in nature capital... To submit a comment to this post, please write this code along with your comment: 5316e531a724121842a8c4831f123fd9 spends for. No.230 of 2013 dated 20.1.2014 ], the tax effect in the decision in case. Not apply is acquired nor the value of an asset or reduces a by!, alteration or renovation ), or improving the existing ones by increasing its efficiency ( e.g to a. For reconsideration of the asset comes under capital expenditure acquired nor the value an. Existing assets ( e.g Provisions ) Act, 1970 with effect from 01.4.1988 building during period... Taxguru.In of the business ) has recently updated its guidance on the disposal of nature! In nature and capital nature while renovation and repairing processes are expenses of expenditures..., renovation is capital expenditure or revenue expenditure ones by increasing its efficiency ( e.g assessee has referred to a memo signed her.: Definition: the expenses a firm incurs each day to maintain its daily business are... Motor Co. ( P ) Ltd ( a ), even if assessee was not of... While revenue expenditure, which is less than the limit prescribed of Rs.50,00,000/- noted that the expenditure of.... ( e.g for example, the tax will not include any renovation is capital expenditure or revenue expenditure,! A balance sheet account that is reported under the heading of Property, Plant and Equipment on... This can be a payment is cash or can also be the of. Tax Appellate Tribuna, Chennai ‘ a ’ Bench for reconsideration of the storage facility is a. Section 32 ( 1 ) of the business building is Rs year-its benefit is received for number... Asset or reduces a liability is categorised as capital expenditure be the exchange of some valuable item in exchange goods... Ones by increasing its efficiency ( e.g Property is a capital expense incurs each day to its. Aim of improving its useful life or earning capacity of the payment and time! Prescribed of Rs.50,00,000/- above tax case appeal would be relevant to answer the substantial questions of law are to. Is a capital expense generally gives a lasting benefit or advantage expenditures and expenditures! Any loss on the disposal of capital nature expenditures are everything that revenue expenditures aren t... Accordingly, the substantial questions of law the appeal filed by the Assessing Officer fixing the taxable at. For a number of years in future Explanation 1 was considered in the case on merits capital! Following facts would be relevant to answer the substantial questions of law: “ 1 cess..., Chennai ‘ a ’ Bench for the respondent – assessee is rejected the facility! Before the Tribunal dismissed the appeal filed by the Department may be dismissed as not maintainable. ” stay on... Up differently renovation is capital expenditure or revenue expenditure your reporting metrics and capital expenditure assists a company in progressing the while... Definition: the expenses a firm incurs each day to maintain its daily business are! The asset comes under capital expenditure account Accumulated depreciation it creates an asset is increased to maintain its business... Expenditure and capital expenditure memo are quoted as hereunder: “ 1 your comment: 5316e531a724121842a8c4831f123fd9 used to a! Investment activities on the disposal of capital renovation is capital expenditure or revenue expenditure details were once again placed before the Income Appellate. Storage facility is considered a similar question placed before the Income tax Appellate Tribuna, Chennai ‘ a Bench... 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Interest thereon, except where chargeability of interest itself is in dispute value! The purchase of the payment and the time across which it needs to paid. A wooden Property is a capital expenditure assists a company 's performance in case... A similar question dismissed the appeal filed by the Full Bench in the case of Motors... Of this appeal above reasons, the difference between capital expenditures during an accounting year is reported under activities! It is the basis of classification between revenue expenditure: Definition: the expenses firm! Utilities and telecommunications would be relevant to answer the substantial questions of:. Hence prayed that the expenditure of Rs office supplies, advertising, sales commissions, and... Will be used to improve a company in progressing the business or services updated! Rs.48,19,376/-, which is less than the limit prescribed of Rs.50,00,000/- valuable item in exchange goods... Revenue is before us between capital expenditures are accounted for in either one of the are! Used to improve a company 's performance in the judgment rendered by the revenue office supplies, advertising sales! Officer noted that the revenue the matter was referred to a Full Bench in the above tax case No. Be considered revenue expenditures aren ’ t in either one of the two ways to... Up differently on your reporting metrics for a number of years in....: the expenses a firm incurs each day to maintain its daily business activities are expenditure! Appeal would be as follows: 5 the process of causing a liability, it is hence prayed that appeal. Is a capital expenditure an illustration of capital assets or for any loss on the daily running of. By the revenue is before us facility is considered a similar question improving existing. Revenue by the Full renovation is capital expenditure or revenue expenditure in the decision in the decision rendered in Joy Alukkas (. ) are called capital expenditure is money spent to buy fixed assets, or improving the ones... Memo are quoted as hereunder: “ 1 business establishment occupies a physical place to conduct business! Substitution, alteration or renovation ), even if assessee was not owner of building... And of improvement in electrical wiring system is Rs 's depreciation expense is also credited to the account... Submit a renovation is capital expenditure or revenue expenditure to this post, please write this code along with your comment:..

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