Judgement - Tat No. 502 of 2019 - Standard Chartered Insurance Agency Limited-Vs-commissioner of Domestic Taxes

REPUBLIC OF KENYA
IN THE TAX APPEALS TRIBUNAL

APPEAL NO 502 OF 2019
STANDARD CHARTERED INSURANCE

AGENCY LIMITED……………………………………….………….…. APPELLANT
-VERSUS-
COMMISSIONER OF DOMESTIC TAXES…………………………..RESPONDENT
JUDGEMENT
BACKGROUND
1. The Appellant is a limited liability company duly incorporated in Kenya

under the Companies Act (Cap 486) Laws of Kenya whose principal
activity is provision of bancassurance services.
2. The Respondent is appointed under and in accordance with Section 13

of the Kenya Revenue Authority Act, Cap 469 of the Laws of Kenya.
Kenya Revenue Authority, KRA, is charged with the responsibility of
among others, assessment, collection, accounting and the general
administration of tax revenue on behalf of the Government of Kenya.
3. The Respondent conducted a compliance check on the Appellant’s tax

affairs for the years of income 2015 to 2018 and as a result
communicated preliminary findings vide its letter to the Appellant dated
17th May, 2019 to which the Appellant did not respond.
Judgement: TAT No. 502 of 2019 – Standard Chartered Insurance Agency Ltd –vs- Commissioner of Domestic Taxes Page | 1
4. The Respondent thus issued a notice of assessment on 11th July, 2019 with
a tax demand of Kshs. 87,210,617/= comprising Corporation Income
Tax (CIT), Excise Duty (ED) and Withholding Tax (WHT), inclusive of
penalties and interest.
5. The Appellant objected to the entire assessment vide its letter of 9th
August, 2019.
6. The Respondent reviewed the objection together with the supporting

documents availed by the Appellant and issued its Objection Decision
on 4th October, 2019. The tax was revised downwards to Kshs.
79,285,945/= as here below:
Tax head Period Principal Penalties Interest totals

tax
Ksh Ksh Ksh Ksh Ksh
CIT 2015- 11,217,171 2,243,434 3,365,151 16,825,757
2017
WHT 2015- 9,514,492 475,561 1,090,560 11,080,613
2018
ED 2016- 48,535,975 2,426,799 416,801 51,379,575
2017
Total tax 69,267,639 5,145,794 4,872,512 79,285,945
demanded
7. The Appellant being dissatisfied with the Respondent’s Objection

Decision lodged its notice of intention to appeal and filed its
Memorandum of Appeal and Statement of Facts on 15th November,
2019.
8. Upon service, the Respondent filed its Statement of Facts, being the
Response on 11th December, 2019.
THE APPEAL
9. The Appeal is premised on the following grounds: -
a) THAT the Respondent, in confirming CIT assessment amounting to Kshs.
16,825,757/=, failed to consider documentary evidence produced by
the Appellant during the field review and various meetings held
between the Appellant and the Respondent’s audit team. This is
notwithstanding the fact that the documentary evidence supported the
Appellant’s position that the expenses in question were wholly and
exclusively incurred in the production of the Appellant’s income.
b) THAT the Respondent erred in law and in fact by purporting to
disallow, for tax purposes, bona fide expenses incurred by the Appellant
in the conduct of its business contrary to express provision of the Income
Tax Act, CAP 470 (ITA) which provide for the deduction of expenditure
incurred wholly and exclusively in the production income in ascertaining
the total income chargeable to tax within any given year of income.
c) THAT the Respondent alleges that the Appellant incorrectly amortized
computer software utilized within the period under review over a 36-
month period as opposed to a 60 month’s period as provided in the
Income Tax Act, without due regard to the fact that the Appellant did
not claim capital allowances with respect to computer software utilized
within the period under review. Indeed, the Appellant does not have
any assets, inclusive of computer software, in its books.
d) THAT the Respondent erred in law and in fact by purporting to disallow
pre-incorporation expenses incurred in years of income 2012, 2013 and
2014 contrary to clear provisions under Section 15(2) of the Income Tax
Act.
e) THAT the Respondent failed to consider the payment arrangements
within Standard Chartered Group, in which the Appellant is a member
in dealing with various suppliers in confirming its WHT assessment
amounting to Kshs. 11,080,612/=. The Group’s approach is that the back
office operational and administrative costs are paid by the Appellant’s
parent company, Standard Chartered Bank of Kenya and withholding
tax is accounted for by the Bank. The costs are subsequently recharged
to the various group entities to which they relate, including the
Appellant.
f) THAT the Respondent erred in law and in fact by confirming WHT with
respect to reimbursement of costs which are outside the ambit of WHT
as per the provisions of the Income Tax Act (ITA).
g) THAT the Respondent erred in law and in fact by contending that the
Appellant ought to have accounted for and remitted WHT at the point
of accrual of expenses, as opposed to at the material time, that WHT is
due upon actual payment, as decided by the High Court of Kenya in
Republic v Kenya Revenue Authority ex-parte Fintel Limited HC Misc.
Civil application No. 1768 of 2004.
h) THAT the Respondent misinterpreted the nature of fees charged by the
Appellant to various insurance service providers (ISP) without due
regard to the contractual arrangements between the Appellant and the
various ISPs, and consequently arrived at a misinformed conclusion that
fees earned by the Appellant do not fall within the ambit of commissions
earned from insurance premiums or premium based or related
commissions, which are expressly exempt from excise duty by virtue of
Part II of the First Schedule to the Excise Duty Act (EDA) 2015, as read
together with Paragraph 4, Part II of the First Schedule to the EDA 2015.
On this basis, the Respondent assessed excise duty of Kshs.
51,379,575/=, inclusive of penalties and interest.
10. In conclusion, the Appellant avers that the Respondent’s demand for
CIT, WHT and Excise Duty amounting to Kshs. 79,285,945/= inclusive
of penalties and interest, is neither supported in law or in fact and
therefore prays that the same be set aside.
THE RESPONSE
11. On CIT, the Respondent states that the Appellant was accorded
reasonable opportunity to be heard. The Respondent requested the
Appellant to provide documentation in support of expenses, inter alia,
accommodation and training costs, foreign related party costs and
miscellaneous expenses. Further, the Respondent sought from the
Appellant proof that the said expenses were wholly and exclusively
incurred in the production of the Appellant’s income in question as per
the provisions of Section 15 of the Income Tax Act. The unsupported
expenses were disallowed.
12. Further, the Appellant claimed tax credits under Section 42 of the
Income Tax Act and stated that they related to manual withholding tax
credits not captured on itax. The Appellant however did not provide
physical certificates during compliance review and at objection state
despite numerous requests by the Respondent through letters, emails
and phone calls. The Respondent disallowed the amounts claimed in
absence of the physical certificates.
13. The Respondent submitted that Sections 58 and 59 of the Tax

Procedures Act, (TPA) requires a taxpayer to produce documents and
information to enable the Commissioner to ascertain the correct tax
liability of a taxpayer. According to the Respondent, this ground of
appeal is in bad faith as the Appellant was given enough opportunity at
objection stage to provide records. The Appellant is in breach of the
mandatory provisions of the law by failing to maintain proper records.
In light of the provisions of the above Sections, all claims must be
supported by documentary evidence. In addition, the Appellant
contravened Section 34 of the Excise Duty Act 2015, (EDA) which
requires a taxpayer to keep records of its transactions for tax purposes.
14. The Respondent averred that the onus of proving the expenses lay with
the Appellant and it could not satisfactorily prove that the expenses were
incurred in the generation of income. Even given ample opportunity to
provide such documentation the Appellant could not support its claim
of expenses.
15. In response to ground 3 of the Memorandum of Appeal, the Respondent
examined the Appellant’s records and ascertained that the Computer
Software were amortized in 36 months contrary to the Second Schedule
of the Income Tax Act that provides for 60 days amortization period on
Computer Software (Unit Trust Systems OTS).
16. In response to ground 4, the Respondent states that it called for records
from the Appellant on several occasions. The Appellant did not avail
documents nor give explanations for costs relating to 2012-2014 during
which the Appellant had not been incorporated. In absence of
documentation to show otherwise, the full amount assessed on pre-
incorporation expenses remains due and payable. Contrary to its
assertion, the Appellant was given ample time and opportunity to be
heard by providing documents which it failed to do.
17. On WHT, in response to grounds 5, 6 and 7 of the Memorandum of

Appeal, the Respondent states that the Appellant failed to account for
and remit WHT with respect to management and professional services
procured within the period and review. Sections 10 and 35 of the
Income Tax Act, as read together with the Third Schedule to the same
Act, requires a taxpayer to account for WHT at the point of accrual of
the cost in the financial statements. The Respondent was justified in
charging WHT on professional and management fees incurred by the
Appellant as WHT is deductible upon payment of a taxable amount.
This is in view of the tax point: “paid” defined to include crediting that
is accrual of the amount payable in the books.
18. Further, the Appellant stated that the fees charged as training fees related
to trainings and accommodation which does not attract WHT.
However, the Appellant did not provide any invoices in support of this
claim.
19. On ED, in response to ground 8 of the Memorandum of Appeal, the

Appellant alleged that due to the nature of their business, all their
income are insurance premiums, premium based or premium related
which are exempt from excise duty by dint of Part 2(4) of the First
Schedule of the EDA. The Respondent was unable to confirm these
allegations since the Appellant did not avail the necessary
documentation to enable verification of this claim.
20. The Respondent avers that the invoice charged by the parent company
for the payment of insurance and freight costs is only prima facie
evidence of the value of the service rendered and not actual proof of
payment. The Parent Company is not an insurance company and even
if it were, the same should be subjected to the Arm’s Length Principle.
21. According to the Respondent, Section 54(1) of the Income Tax Act
requires any person carrying out business to keep records of all receipts
and expenses, goods acquired and vouchers among other records which
in the opinion of the Commissioner are adequate for purposes of
computing tax.
22. In view of the above, the Respondent maintains that the taxes of Kshs.
79,285,945/= are due and payable by the Appellant as was
communicated to the Appellant in the respective Objection Decision
issued.
23. Consequently, the Respondent contends that the Appeal lacks merit and
ought to be dismissed with costs.
ISSUES FOR DETERMINATION
24. The Tribunal has carefully studied the parties pleadings and submissions
and is of the respectful view that the issues that call for its determination
are as hereunder: -
a) Whether the Respondent erred in law and fact in its tax assessment
in respect to Corporation tax?
b) Whether the Respondent erred in law and fact in its tax assessment
in relation to Withholding tax?
c) Whether the Respondent erred in law and fact in its tax assessment
by subjecting related insurance commission income to Excise duty
contrary to the provisions of the Excise Duty Act 2015?
ANALYSIS AND FINDINGS
25. It is to these issues that the Tribunal will turn within as hereunder: -
a) Whether the Respondent erred in law and fact in its tax assessment in
respect to Corporation tax?
26. The Respondent states that the Appellant incurred various expenses in
the years of income 2015-2017 that have not been supported as having
been incurred wholly and exclusively in the production of income. As a
result, the Respondent disallowed the expenses totaling Kshs.
40,179,638/= for tax purposes; namely;
a) Unsupported expenses
b) Disallowed foreign cost recharges
c) Disallowed training aid accommodation costs.
27. In addition to the above, the Respondent further disallowed manual

WHT credits claimed by the Appellant in its Corporation tax self-
assessment returns for the years of income 2015-2016 in the sum of Kshs.
963,094/= and Kshs. 792,339/=, respectively on the basis that the
Appellant failed to avail the manual WHT certificates in support of the
amounts claimed.
28. The Respondent further averred that the Appellant was accorded a
reasonable time and opportunity to be heard, in vain. It stated further
that it requested the Appellant to provide the documentation in support
of its expenses in vain.
29. On the issue of the Appellant’s claim on tax credits under Section 42 of
the Income Tax Act, the Respondent submitted that the Appellant failed
to provide the physical WHT certificates during the compliance review
and at objection stage despite previous requests through letters, emails
and phone calls and it was left with no option other than disallowing
the amounts claimed.
30. The Tribunal notes that Section 54(A) of the Income Tax Act requires a
taxpayer carrying on business to maintain records of all the transactions
carried out. It states: -
“A person carrying on a business shall keep records of all receipts and
expenses, goods purchased and sold and accounts, books, deed,
contracts and vouchers which in the opinion of the Commissioner, are
adequate for the purpose of computing tax. (1A) For the purpose of
this section, the carrying on of business includes any activity giving rise
to income other than employment income”
31. Moreover, Section 15(1) of the Income Tax Act provides for allowable
deductions when ascertaining income for tax purposes. It states:-
“For the purpose of ascertaining the total income of a person for a year
of income there shall, subject to section 16, be deducted all expenditure
incurred in that year of income which is expenditure wholly and
exclusively incurred by him in the production of that income, and
where under section 27 any income of an accounting period ending on
some day other than the last day of that year of income is, for the
purpose of ascertaining total income for a year of income, taken to be
income for a year of income, then the expenditure incurred during that
period shall be treated as having been incurred that year of income”.
32. The Tribunal seeks guidance from Section 59 of the Tax Procedures Act
on the issue of production of documents and information to enable the
Respondent to ascertain the correct tax liability of a taxpayer. The same
provides as follows:-
“59 (1) For the purposes of obtaining full information in respect of the
tax liability of any person or class of persons, or for any other purposes
relating to a tax law, the Commissioner or an authorized officer may
require any person, by notice in writing to-
(a) produce for examination, at such time and place as may be specified
in the notice, any documents (including in electronic format) that are
in the person’s custody or under the person’s control relating to the
tax liability of any person;
(b)furnish information relating to the tax liability of any person in the
manner and by the time as specified in the notice; or
(c) attend, at the time and place specified in the notice, for the purpose
of giving evidence in respect of any matter or transaction appearing
to be relevant to the tax liability of any person”
33. In the case of Republic –vs- Commissioner for Domestic taxes & Anor
Exparte: Stocham Rozen (K) Ltd {2015} eKLR, the court, while canvasing
a similar issue stated thus:-
“.....taxable income is that income that has accrued minus the allowable
deduction that the said deductions from the accrued income must be
those that are allowable under Section 15(1) and (2)………..”
34. The Appellant submitted that due to its unique global internal payout
mechanisms through which costs incurred by Standard Chartered Group
and in particular back end operational and administrative costs, are at
first instance borne by the Appellant’s present Company, that is, the
bank, following which they are recharged to the respective group
entities that the costs relate to. It went further to argue that based on
the fact that recharge is internal, it is not unusual to have some
descriptions in the general ledger being generic. It is on this basis that the
Respondent’s audit team which conducted the review mutually agreed
with the Appellant’s team to sample a few entries and reviewed the
underlying documentation with a view to validating that the expenses
were wholly and exclusively incurred in production of taxable income.
35. Though the Tribunal agrees with the Appellant’s assertion that the
disallowed costs could have been incurred wholly and inclusively
towards the production of its income, it maintains that the same must
be supported by documentary evidence. The onus lay with the
Appellant, having been given reasonable opportunity to do so. Indeed
the law is clear on the burden of proof in tax matters as provided for in
the Tax Procedures Act.
“Section 56(1) of the Tax Procedures Act under the General provisions
relating to objections and appeals provides that in any proceedings
under this part, the burden shall be on the taxpayer to prove that a tax
decision is incorrect”
36. The Appellant averred that through the Alternative Dispute Resolution
(ADR) process it provided the requested documentation in support of
the costs and further that the Respondent failed to undertake a further
review of additional documents made available by the Appellant. This
is averred to by the witness statement of one, Isaac Njoroge, dated 3rd
February, 2021 and filed on 4th February, 2021 which was duly adopted
by the Tribunal during the proceedings upon consent of the parties
herein. In its response to the issue, the Respondent vide its Statement of
Facts filed on 11th December, 2019 at Paragraph 14 averred that despite
several requests, the Appellant failed to produce the required
documentation. The Respondent annexed various correspondence with
the Appellant marked as KRA 5 and 6. The Tribunal has perused the
same and notes that indeed there was various correspondence
exchanged between the parties. For instance, vide the emails dated 9th
May 2019 and 20th September 2019, the Respondent requested for an
explanation for the 2012-2013 invoices claimed under foreign costs and
a demonstration of the disallowed foreign costs recharges of Kshs.
8,058,467/= in 2017. Moreover, in the email of 9th May 2019, the
Respondent requested for supporting documents and clarification for,
among others,
a) Training and accommodation costs which has been charged to
employees who appear not to be mapped/seconded to SCIAL
b) Recharge on software, provide software agreement
c) On cross border transactions, to demonstrate that the charge relates
to employees mapped to SCIAL
d) Financial status for years of income 2015, 2016 and 2017
37. The Tribunal notes that nothing could have been easier than the
Appellant providing the requested documentation either to the
Respondent or to the Tribunal during the proceedings to disprove the
Respondent’s tax decision.
38. In view of the foregoing, the Tribunal makes a finding that the Appellant
has not demonstrated to its satisfaction that the said costs were wholly
and exclusively incurred in the production of its taxable income.
39. Consequently, the Respondent did not err in law and fact in its tax
assessment herein in respect to Corporation tax.
b) Whether the Respondent erred in law and fact in its tax assessment in
relation to Withholding tax.
40. The Appellant contended that the manual WHT credits arose through
its bancassurance business, being the insurance premium commissions
earned by the Appellant. The Appellant further averred that the
respective insurance service providers, (IPS) that withheld against its
income failed to upload the corresponding WHT credits onto the itax
platform. It further stated that WHT was accounted for on the
Management and Professional fees vide the Group’s global internal cost
allocation mechanism through which the Bank accounts for WHT on
qualifying payouts made by the bank and its related parties inclusive of
the Appellant and thereafter recharges the costs to the applicable entity,
which account for the re-imbursement of costs and are therefore not
subject to WHT in Kenya.
41. It is worth noting that the Appellant, while making its above averment,
relied on the High Court Case of Republic –vs- KRA exparte Fintel Ltd
in Hc. Msc. App No. 1768 of 2004, hereinafter referred to as the Fintel
Case to the effect that that terms “payout” and “paid” are determined
to refer to the actual payment or settlement of an obligation and
therefore the Appellant accounted for WHT on technology fees
expenses at the point of actual payout to the respective service
providers.
42. We note that on the same breath, through its witness, one Simon
Njoroge, vide the Statement filed on 4th February 2021, the Appellant
conceded that at the time of the transactions, the determination of the
High Court in the said Fintel case had not yet been overturned by the
Court of Appeal, and therefore was the applicable law of the land. The
Tribunal will dissuade the Appellant from the said averment noting that
the relevant and applicable law is the Court of Appeal decision in the
said Fintel case and not the High court decision despite the period the
transactions took place.
43. Having carefully perused the correspondence exchanged by the parties,

we are in agreement with the Respondent that despite requests, the
Appellant failed to provide the requisite documentation to counter the
Respondent’s tax decision. Specifically, in the email dated 5th September,
2019, the Respondent in its KRA annextures 5 and 6 requested for the
following documents inter alia,
“…tax credits, copies of the manual withholding tax certificates,
breakdown of the assessments charged as indicated by the Appellant
that do not attract withholding tax;” and further in the email of 9th
September 2019 where the Respondent requested for a demonstration
of how WHT has been accounted for by SCBK Ltd for training fees,
audit fees, legal fees, technology fees, software fees, recharge fees and
foreign professional fees, noting that the demonstration provided by
RM on management fees was actually understood and taken into
account by the Respondent.
44. In view of the foregoing, we find that the Respondent was justified in
disallowing WHT Credits claimed by the Appellant.
45. Consequently, the Respondent did not err in law and fact in its tax
assessment in relation to Withholding tax.
c) Whether the Respondent erred in law and fact in its tax assessment by
subjecting insurance commission to Excise duty contrary to the
provisions of the Excise Duty Act 2015?
46. The Appellant argued that its principal activity is insurance business and
the insurance premium commissions earned ought not to be subjected
to excise duty pursuant to the Excise Duty Act 2015. It stated that it earns
administrative fees and commissions, marketing fees commissions,
upfront fees commissions and fixed access fee and commissions.
According to the Appellant, these are premium based or related
commissions and therefore are exempted from excise duty pursuant to
Paragraph 4, Part II of the First Schedule to the Excise Duty Act as read
together with the definition of “Other fees” under Part III of the First
Schedule to the said Act.
47. Having perused the evidence of the Appellant’s witness, one Simon
Ngure, vide the witness statement filed on 4th February 2021, the
Tribunal notes that in Paragraphs 9 and 10, he stated that in providing
bancassurance services, the Appellant may from time to time provide
ancillary or incidental services to the various ISPs, including
administration and marketing services. He further stated that the said
services are ancillary because the same is dependent on the Appellant
providing its core business and they are intrinsically linked to the
Appellant’s principal business.
48. The Respondent in its argument stated that the Appellant failed to
provide the requisite documentation that would have enabled it to
verify the claims that the items brought to charge were not excisable and
it therefore properly brought the same to tax.
49. It was further argued by the Respondent that the invoices charged by
the parent company for the payout of insurance and foreign costs is only
prima facie evidence of the value of some services rendered and not
actual proof of payment. Moreover, the parent company is not an
insurance company and even if it were, the same should be subjected to
the Arm’s Length principle.
50. Therefore, the invoices received by the Appellant comprise “Other fees”
for purposes of Paragraph 4 of Part II of the First Schedule to the Excise
Duty Act and are not exempt as alleged by the Appellant.
51. We have perused the Appellant’s Statement of Facts on the issue and
specifically Appendix C at pages 72-101 where it provided a sample of
the contractual agreement between it and an ISP. At page 98-99 of the
same the ISP refers to various categories of payments. It provides that
SCIAL is entitled to the following payments;
1. Commission
2. Profit share
3. Administrative fee
4. Marketing allowance
5. Miscellaneous
52. According to the Appellant, at Paragraph 63 of its Statement of Facts, it

averred that different players give various terms to the various categories
of commissions and for this reason, the Appellant reports the total
amount as one-line item in its financial statements.
53. The Tribunal having carefully studied the Appellant’s pleadings,

documentation and submissions notes that notwithstanding that there
might be non-excisable items, the burden lies on the Appellant to prove
the same. The Appellant has failed to demonstrate to the satisfaction of
the Tribunal by way of documentary evidence on the said non-excisable
items having failed to specifically isolate them. Indeed, Section 56 of the
Tax Procedures Act referred to elsewhere in this Judgement is instructive
on the burden of proof in tax matters. It squarely lies on the Appellant.
54. In view of the foregoing, the Tribunal makes a finding that the Appellant
charged and earned administrative fees, marketing fees and other fees
from various ISPs or underwriters which forms part of “Other fees” as
envisaged under Paragraph 4 of Part II of the First Schedule of the Excise
Duty Act, 2015. Noting that there was no documentary evidence that
the excise duty was accounted for, the Respondent properly brought to
charge the said income.
55. Consequently, the Respondent did not err in fact and law in subjecting
the related insurance commission income to Excise duty.
FINAL DECISION
56. The upshot of the foregoing is that the Appeal has no merit and the
Tribunal makes the following ORDERS: -
a) The Appeal is hereby dismissed.
b) The Respondent’s Tax Assessment vide its Objection Decision dated
4th October, 2019 for the sum of Kshs. 79,285,945/= is hereby
upheld.
57. Orders accordingly.
DATED and DELIVERED at NAIROBI this 1st day of April, 2021.
JOSEPHINE K. MAANGI
CHAIRPERSON
GEOFFREY KARUU TANVIR ALI

MEMBER MEMBER
PATRICIA M. ANAMPIU DELILAH K. NGALA

MEMBER MEMBER

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Judgement - Tat No. 502 of 2019 - Standard Chartered Insurance Agency Limited-Vs-commissioner of Domestic Taxes

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REPUBLIC OF KENYA

IN THE TAX APPEALS TRIBUNAL

STANDARD CHARTERED INSURANCE

COMMISSIONER OF DOMESTIC TAXES…………………………..RESPONDENT

1. The Appellant is a limited liability company duly incorporated in Kenya

2. The Respondent is appointed under and in accordance with Section 13

3. The Respondent conducted a compliance check on the Appellant’s tax

6. The Respondent reviewed the objection together with the supporting

Tax head Period Principal Penalties Interest totals

7. The Appellant being dissatisfied with the Respondent’s Objection

13. The Respondent submitted that Sections 58 and 59 of the Tax

17. On WHT, in response to grounds 5, 6 and 7 of the Memorandum of

19. On ED, in response to ground 8 of the Memorandum of Appeal, the

ISSUES FOR DETERMINATION

ANALYSIS AND FINDINGS

27. In addition to the above, the Respondent further disallowed manual

43. Having carefully perused the correspondence exchanged by the parties,

52. According to the Appellant, at Paragraph 63 of its Statement of Facts, it

53. The Tribunal having carefully studied the Appellant’s pleadings,

57. Orders accordingly.

GEOFFREY KARUU TANVIR ALI

PATRICIA M. ANAMPIU DELILAH K. NGALA

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