TMI Blog2014 (8) TMI 162X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee cannot be allowed to claim deduction of the amount in reassessment proceedings – Decided against assessee. Reopening of assessment u/s 147 r.w section 148 – Held that:- In the absence of copy of letter submitted by the assessee before the AO requesting the AO to consider the return already filed by the assessee on 02/05/2005 as the return filed in compliance to this notice - the assessee has submitted chronology of relevant dates and events and the original return of income was filed on 02/05/2005 but the same was treated as non-est - even the original return filed by the assessee on 02/05/2005 was treated as non-est and non est return cannot be considered as a valid return at any point of time – the return of income filed by the assessee in compliance to notice issued by the AO u/s 148 has to be treated as not in conformity with law and non est and the AO was not required to issue notice u/s 143(2) of the Act – Decided against Assessee. Contribution made to LIC under Group Gratuity Insurance Scheme – Scheme not approved by CIT – Held that:- There is specific provision for deemed approval u/s 12AA(2) that the order in respect of the application for registration u/s 12A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... siness - The eligible business of the assessee is infrastructure development by way of development of industrial area or plot for providing the same to entrepreneurs for setting up of industrial unit for the industrial development of the city - earning of interest income is not an eligible business of the assessee company. The assessee company has mixed its both the activities by way of granting installments in respect of premium, such interest income cannot be considered as income of eligible business for the purpose of computing deduction allowable to the assessee u/s 80IA of the Act - interest income is not an income derived from the eligible business and the provisions of sub section 1 of section 80IA - only profit derived from developing and operating and maintaining industrial park is eligible for deduction and interest income cannot be said to be an income on account of development or operation or maintenance of industrial park/ Special Economic Zone - Interest income is in respect of making available the finance and the assessee company is engaged in the business of financing also and the assessee has mixed its both the activities and thereby claiming deduction u/s 80IA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th law after providing due and reasonable opportunity of being heard to both the parties. and being a subordinate Appellate Authority, the CIT(A) was under a statutory obligation to deal with and decide the issue on merits thereof. 4. BECAUSE in view that the appeal not being not arising out of the impugned assessment , reflects upon the proprietary of the CIT(A) in complying with the direction given by the Hon'ble ITAT vide order dated 05.02.2010 passed in ITA No.116/Luc/07 in the case of U.P. State Industrial Development Corporation Ltd vs. Asstt. Commissioner of Income Tax - VI, Kanpur. 5. BECAUSE the sums aggregating ₹ 3,78,67,703/- represented 'waiver of interest' as granted by the Board of Directors of the appellant in exercise of its power to do so and such waiver having been approved during the previous year relevant to the assessment year 2001-02, the sum in question represented the legitimate 'outgoing' of the business of the appellant was liable to be excluded from the income of the appellant in the year under appeal. 6. BECAUSE keeping in view the finding given by the Assessing Officer himself, while completing the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Assessing Officer in the assessment order for assessment year 2002-03 that the liability has crystallized during the assessment year 2001-2002, deduction is allowable in the present year. Reliance was placed by him on the judgment of Hon'ble Delhi High Court rendered in the case of Commissioner of Income-tax Vs Jai Parabolic Springs Ltd. as reported in [2008] 306 ITR 42 (Del) wherein it was held that there was no prohibition on the powers of the Tribunal to entertain additional ground which, according to the Tribunal, arose in the matter and for the just decision of the case. He submitted that in view of this judgment, the CIT(A) was not justified in holding that in view of this judgment of Hon'ble Apex Court rendered in the case of Goetze (India) Ltd. Vs Commissioner of Income-tax [2006] 284 ITR 323 (SC), the assessee cannot raise this issue without filing revised return of income. 4. As against this, Learned D.R. of the Revenue supported the order of learned CIT(A). 5. We have considered the rival submissions. First of all, we reproduce the relevant Para of the assessment order passed by the Assessing Officer in assessment year 2002-03 because it is the claim of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... laimed by the assessee is in respect of write off of advance premium of Tronica Housing as has been noted by the Assessing Officer on page No. 9 of the assessment order. Hence, it is seen that there is no co-relation between the escaped income and this extra claim being made by the assessee in course of reassessment proceedings. In the light of these facts, we examine the applicability of this judgment of Hon'ble Apex Court rendered in the case of Commissioner of Income-tax Vs Sun Engineering Works P. Ltd. (supra). In the case of Commissioner of Income-tax Vs Sun Engineering Works P. Ltd. (Supra), it was held by Hon'ble Apex Court that the matter not agitated in the concluded original assessment proceedings, cannot be permitted to be agitated in the reassessment proceedings unless relatable to the item sought to be taxed as escaped income. In the present case, we have noticed that the deduction now being claimed by the assessee is not in relation to the escaped income sought to be taxed by the Assessing Officer in reassessment proceedings and therefore, the assessee cannot be allowed to claim deduction of this amount in reassessment proceedings. Respectfully following this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d the '/CIT(A)'/ has erred in law and on facts in upholding an addition of ₹ 4,37,72,326/-, as had been worked out by the Assessing Officer by applying a measure of 5% to the aggregate of premia received during the year. 4. BECAUSE the CIT(A) after having accepted, that the provisions of section 14A read with Rule 8D were not applicable in the year under appeal, has grossly erred in upholding an ad hoc disallowance of ₹ 1,00,000/-, out of expenditure claimed by the appellant . 5. BECAUSE while accepting the appellant's claim under section 80IA, on receipts under the head other income , the CIT(A) should have extended the relief to such other income in relation to the Tronica City project also. 6. BECAUSE in the matter of appellant's claim for deduction under section 80 IA(4), the CIT(A) has erred in law and on facts in holding that receipts under the head interest did not form part of eligible profit and in giving direction to the Assessing Officer to re-calculate the eligible profit (after excluding the said receipts). 7. BECAUSE looking to the facts and circumstances of the case, particularly that: a) the appellan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g Officer requesting the Assessing Officer to consider the return already filed on 02/05/2005 as return filed in compliance to this notice u/s 148 is not available on record. A certified copy of the order sheet entry is available on page No. 4 to 11 of the paper book and from the same, we find that the notice u/s 148 was issued by the Assessing Officer on 25/05/2007 and thereafter notice u/s 142(1) was issued on 04/11/2008 fixing the date of hearing on 14/11/2008 and there was no compliance on this date. Again a notice u/s 142(1) was issued on 04/12/2008 and in compliance, Shri Rajesh Kanodia appeared on 11/12/2008. In the absence of copy of letter submitted by the assessee before the Assessing Officer requesting the Assessing Officer to consider the return already filed by the assessee on 02/05/2005 as the return filed in compliance to this notice, we presume in the facts of the present case that such letter was filed before the Assessing Officer on the date when Learned A.R. of the assessee appeared before the Assessing Officer for the first time i.e. on 11/12/2008. We also find that the assessee has submitted chronology of relevant dates and events on page No. 2 3 of the paper ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and in support of this contention, reliance was placed on the judgment of Hon'ble Apex Court rendered in the case of Sassoon J. David and Co. (P.) Ltd. Vs Commissioner of Income-tax [1979] 118 ITR 261 (SC). 13. As against this, Learned D.R. of the Revenue supported the order of learned CIT(A). 14. We have considered the rival submissions. We find that it is admitted position of fact that approval is not granted to the trust created by the assessee and in fact the request for approval is rejected by CIT as per his order dated 25/06/2012. Now the claim of the assessee is that since the assessee has filed a review application in August, 2012 before CIT and the same is pending, it should be considered as deemed approval. We do not find any merit in this contention of the Learned A.R. of the assessee. In this regard, reliance was placed by Learned A.R. of the assessee on the judgment of Hon'ble Allahabad High Court rendered in the case of Society for the Promotion of Education Adventure Sport Conservation of Environment vs. CIT Ors (supra). In that case, it was held by Hon'ble Allahabad High Court that if the registration is not granted by the CIT u/s 12AA within ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tself is not approved even till date and therefore, this judgment is not applicable in the facts of the present case. 15. Regarding the alternative contention of Learned A.R. of the assessee that even if this deduction is not allowable as payment towards gratuity then the same should be allowed as business expenditure u/s 37 of the Act and in support of this contention reliance was placed by Learned A.R. of the assessee on the judgment of Hon'ble Apex Court rendered in the case of Sassoon J. David and Co. (P.) Ltd. Vs Commissioner of Income-tax (supra). In our considered opinion, this judgment of Hon'ble Apex Court is not at all applicable because the ratio of the judgment is that expression wholly and exclusively used in section 10(2)(xv) of the Act does not mean necessarily. In view of this, it was held by Hon'ble Apex Court that even if there was no compelling necessity to incur such expenditure, deduction is allowable if an expenditure has been incurred for promoting the business and to earn profit. In the present case, this is not in dispute as to whether the expenditure is necessary or not. The dispute is that the payment is not to an approved gratuity fund. Mo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7800.75 lac at the end of the year and ₹ 7014.75 lac at the beginning of the year. He submitted that under these facts, no disallowance is justified in respect of interest expenditure. Regarding the disallowance in respect of administrative expenses, he submitted that the same should be reasonable. Learned D.R. of the Revenue supported the order of learned CIT (A). 21. We have considered the rival submissions. We find force in this contention of Learned A.R. of the assessee that since own interest free funds were more than the investment, no disallowance is justified out of interest expenditure but still some disallowance is justified out of administrative expenses. Out of administrative expenses, the disallowance was made by the Assessing Officer of ₹ 6,29,626/- as per Rule 8D but CIT(A) has confirmed the disallowance of ₹ 1 lac and the same is in respect of administrative expenditure in respect of managing the income accrued from these shared held as investment. In our considered opinion, the disallowance of ₹ 1 lac is not excessive and therefore, we decline to interfere in the order of CIT(A) on this issue also. Accordingly, ground No. 4 is also rejec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... usiness profit for the purpose of computing deduction allowable to the assessee u/s 80IA of the Act. Accordingly, ground No. 5 stands allowed. 25. It is submitted by Learned A.R. of the assessee regarding ground No. 6 7 that CIT(A) was not justified in directing the Assessing Officer to exclude interest received from the allottees from profit of the eligible business for the purpose of computing deduction allowable to the assessee u/s 80IA of the Act. He further submitted that as per the judgment of Hon'ble Apex Court rendered in the case of Liberty India Vs Commissioner of Income-tax [2009] 317 ITR 218 (SC), it was held by Hon'ble Apex Court that source of first degree is eligible for deduction u/s 80IA of the Act. He submitted that the CIT(A) was not justified in directing the Assessing Officer to exclude interest income from the business profit for the purpose of computing deduction allowable to the assessee u/s 80IA of the Act. He placed reliance on the judgment of Hon'ble Apex Court rendered in the case of Topman Exports Vs Commissioner of Income-tax [2012] 342 ITR 49 (SC) in respect of deduction allowable u/s 80HHC of the Act and submitted that therein it was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 16 ITR 325). In this case, the question was whether interest received on arrears of rent payable in respect of land used for agricultural purpose was income derived from land? It was answered by the Hon'ble Supreme Court that- The interest clearly is not rent. Rent is o technical conception, its leading characteristic being that it is payment in money or in kind by one person to another in respect of the grant of a right to use land. Interest payable by statute on rent in arrear is not such a payment. It is not part of the rent nor is it an accretion to it though it is received in respect of it. Equally clearly the interest on rent is revenue, but in their lordships' opinion it is not revenue derived from land. It is no doubt true that without the obligation to pay rent and rent is obviously derived from land there could be no arrears of rent and without arrears of rent there would be no interest but the affirmative proposition that interest is derived from land does not emerge from this series of facts. All that emerges is that as regards the interest land rent and nonpayment of rent stand together as causae sine quibus non. The source from which the interest is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as it was not rent or revenue derived from land, but money payable under a constraint imposing a personal liability. 10.3.4 Similar is the decision of the Hon'ble Supreme Court in the following cases: i. Cambay Electric Supply v/s. CIT [113 ITR 84] ii. Liberty India v/s CIT [317 ITR 444] iii. CIT v/s Sterling Foods [237 ITR 579] iv. CIT v/s Kiran Enterprises [189 Taxman 457 (HP)] 10.3.5 In view of. the overwhelming number of decisions of the Hon'ble Supreme Court on this issue, the law in this regard is no more res-integra . Thus, it has to be held that interest earned by the appellant on installments granted in respect of Premium Payable, other interest income, other misc. receipts may have some link with the business of the appellant, yet such receipts can never be said to have been derived from such eligible business since such income have no direct nexus with the eligible business. Thus, the A.O should also have not allowed the deduction u/s.80IA on the interest earned by the appellant (on the installments granted), which now I order the A.O to withdraw the same. 27.1 From the above Paras of CIT(A), we find that a clear finding is given by CIT(A) t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Economic Zone notified by the Central Government in accordance to the scheme framed and notified by that Government for the period beginning on the first day of 1987 and ending on 31st March, 2006. Hence, only profit derived from developing and operating and maintaining industrial park is eligible for deduction and interest income cannot be said to be an income on account of development or operation or maintenance of industrial park/ Special Economic Zone. Interest income is in respect of making available the finance and particularly in the present case, the assessee company is engaged in the business of financing also and the assessee has mixed its both the activities and thereby claiming deduction u/s 80IA in respect of interest income of financing activity which is not eligible for such deduction. Hence, we decline to interfere in the order of CIT(A) on this issue also. Accordingly, ground No. 6 7 are rejected. 28. In the result, the appeal of the assessee stands partly allowed. 29. Now we take up the appeal of the Revenue for assessment year 2003-04 i.e. I.T.A. No.396/Lkw/2011. 30. Ground No. 1 of the appeal is as under: 1. The Ld. CIT(A) has erred in law and on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the paper book. 35. We have considered the rival submissions. We find that the issue involved in the present case as per this ground is in respect of interest accrued in respect of those plots which are under litigation and it is the claim of the assessee that chances of recovery of such interest is nil and the interest has not been accounted for in profit loss account and has not been declared in its income. In assessment year 2002-03 also, it is noted by the Tribunal in Para 13 that the dispute regarding interest amounting to ₹ 306.24 lac was related to the non performing assets. In that year also, the said interest was not received and it was pointed out by way of notes on accounts of the audit report that the chances of recovery are also very weak. The Tribunal has considered the provisions of section 43D of the Act and thereafter decided the issue in favour of the assessee. 36. Learned D.R. of the Revenue could not point out any difference in facts and hence, we do not find any reason to take a contrary view in the present year. Therefore, respectfully following the Tribunal decision in assessee's own case for earlier year, we do not find any reason to interf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ibution made to Udyog Bandhu without appreciating the fact that the assessee failed to submit any details with regard to the precise nature of the claim including its business nexus and also its allowability under any specific provision of the Act. 44. It was agreed by both the sides that this issue is identical to ground No. 1 raised by the Revenue in assessment year 2003-2004 and the same may be decided on similar lines. In assessment year 2003-04, this issue has been decided by us in favour of the assessee as per Para 32 of this order and accordingly in the present year also, this issue is decided in favour of the assessee. Accordingly, ground No. 1 is rejected. 45. Ground No. 2 is as under: 2. The Learned. CIT(A) has erred in law and on facts in deleting the addition made on account of income from accrued interest without appreciating the fact that the assessee had not disclosed interest income amounting to ₹ 1,34,53,232/-deemed to have accrued during the current year. 46. It was agreed by both the sides that this issue is identical to ground No. 2 raised by the Revenue in assessment year 2003-2004 and the same may be decided on similar lines. In assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... out of group gratuity scheme 61,97,718 (ii) Income under the head business and profession @5% of accumulation of premium during the year, as worked out at ₹ 87,54,46,528 4,38,98,192 (iii) Disallowances out of expenditure, on adhoc basis 1,00,000 (ix) Disallowances out of prior period expenses 36,53,718 to the income already assessed under section 143(1) are beyond the letter and law, as amended from time to time. WITHOUT PREJUDICE TO THE AFORESAID 4. BECAUSE the CIT(A) has erred in law and on facts in upholding the disallowance of ₹ 61,97,718/- representing the contribution actually made to Life Insurance Corporation of India under 'Group Gratuity Insurance Scheme' as had been framed by it (LIC), on the grounds that the scheme of Group Gratuity Scheme has not been approved by the Commissioner of Income-tax. 5. BECAUSE Group Gratuity Insurance Scheme as formulated by Life Insurance Corporation of India with general approval of the Government of India constituted an approved fund and no further/separate approval by the CIT was not needed, for the purposes of admissibility of the same as deduction under section 40A(7) of the 'Act'. 6. BECAUSE ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r different context and on the facts dissimilar to that of the appellant . 13. BECAUSE the order appealed against is contrary to the facts, law and principles of natural justice. 51. Regarding ground No. 1,2 3 in respect of validity of reassessment proceedings, it was submitted that this issue is identical to ground No. 1 of modified/concise grounds of appeal raised by the assessee in assessment year 2003-04 and hence, the same may be decided on similar lines. In assessment year 2003-04 this issue has been decided by us against the assessee as per Para 10 of this order and accordingly in the present year also, this issue is decided against the assessee and accordingly ground No.1,2 3 are rejected. 52. Regarding ground No. 4 5 also, it was submitted that this issue is identical to ground No. 2 of modified/concise grounds of appeal raised by the assessee in assessment year 2003-04 and hence, the same may be decided on similar lines. In assessment year 2003-04 this issue has been decided by us against the assessee as per Para 14 to 16 of this order and accordingly in the present year also, this issue is decided against the assessee and ground No. 4 5 are rejected. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... interest written off while other items of prior period expenditure would stand disallowed while income recognized by the appellant would remain income of the year under reference. 57.1 From the above Para of CIT(A), we find that in respect of balance amount after excluding ₹ 25,76,358/- from the total claim, a clear finding is given by CIT(A) that Learned A.R. of the assessee could not lead any evidence regarding allowability of these expenses in the year under consideration. Before us also, no evidence has been brought on record to show that these expenses have crystallized during this year. Hence, on this aspect, we do not find any reason to interfere in the order of CIT(A). In respect of ₹ 25,76,358/-, which is in respect of interest accrued but written back, it is noted by CIT(A) that the Assessing Officer is directed to call for details of the interest amount written off and if he is satisfied that the conditions of section 36(2) of the Act have been met by the assessee company in this regard, he should allow the interest written off while other items of prior period expenditure would stand disallowed. Considering all these facts, we do not find any reason to i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... turned income and the assessed income , as had been contested in appeal before him. WITHOUT PREJUDICE TO THE AFORESAID 2. BECAUSE there was no accrual or receipt of any income chargeable to tax out of premia received/receivable from the entrepreneurs at the time of allotment of industrial sites and sheds to them and the CIT(A) has erred in law and on facts in upholding an addition of ₹ 5,16,27,653/- as had been worked out by the Assessing Officer, by applying a measure of 5% to the aggregate of such premia. 3. BECAUSE the CIT(A) has erred in law and on facts in upholding the disallowance of ₹ 39,57,629/- representing the contribution made to Life Insurance Corporation of India under 'Group Gratuity Insurance Scheme' as had been framed by it (LIC), on the grounds that the scheme of Group Gratuity Scheme has not been approved by the Commissioner of Income-tax. 4. BECAUSE Group Gratuity Insurance Scheme as formulated by Life Insurance Corporation of India with general approval of the Government of India constituted an 'approved fund' and no further/separate approval by the CIT was needed, for the purpose of admissibility of the same ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... against the assessee. Accordingly, this ground of the assessee is rejected. 64. It was also agreed by both the sides that ground No. 2 of the assessee's appeal is identical to ground No. 6 of the assessee's appeal for assessment year 2004-05 and hence, the same can be decided on similar lines in the present year also. In assessment year 2004-05, this issue has been decided against the assessee as per Para 53 of this order and accordingly in the present year also this issue is decided against the assessee. Accordingly, this ground of the assessee is rejected. 65. It was agreed by both the sides that ground No. 3 4 of the assessee's appeal are identical to ground No. 4 5 of the assessee's appeal for assessment year 2004-05 and hence, the same can be decided on similar lines in the present year also. In assessment year 2004-05, this issue has been decided against the assessee as per Para 52 of this order and accordingly in the present year also, this issue is decided against the assessee. Accordingly, these grounds of the assessee are rejected. 66. Regarding ground No. 5, it was submitted by Learned A.R. of the assessee that even if ground No. 3 4 are d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .3.7 and 10.3.8 the CIT(A) has noted such receipts in respect of one project and therefore, this issue was raised by the assessee by way of ground No. 5 in assessment year 2003-04 that similar treatment should be given in respect of the similar receipt of other project. He also submitted that in assessment year 2003-04, there is appeal of the Revenue also in I.T.A. No.396/Lkw/2011 but no ground has been raised by the Revenue in that year against this decision of CIT(A) that these receipts are eligible for deduction u/s 80IA of the Act. He submitted that under these facts, this issue should be decided in favour of the assessee. 70. Learned D.R. of the Revenue supported the orders of the authorities below but he could not controvert these submissions of Learned A.R. of the assessee that in assessment year 2003-04, similar issue was decided by CIT(A) in favour of the assessee and no ground has been raised by the Revenue in appeal before the Tribunal in that year. Under these facts, we are of the considered opinion that in the present year also, the assessee deserves to succeed because the Revenue cannot take a different view in assessment year 2003-04 and than a contrary view in as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... jected. 77. Ground No. 3 is as under: 3. The Learned CIT(A) has erred in law and on facts in deleting the addition of ₹ 25,38,497/- made u/s 14A without appreciating the fact that the substantive law u/s 14A was already in existence retrospectively and its provisions (2) (3) and rule 8D are clarificatory in nature and were merely introduced to clarify the mode of calculation of expenses incurred in relation to exempted income. 78. Both the sides agreed that this issue is identical to ground No. 3 raised by the Revenue in assessment year 2004-05 and the same can be decided on similar lines in the present year also. In assessment year 2004- 05, this issue has been decided in favour of the assessee as per Para 48 of this order and accordingly in the present year also this issue is decided in favour of the assessee because no difference in facts can be pointed out by the Learned D.R. of the Revenue. Accordingly, this ground of the Revenue is rejected. 79. In the result, the appeal of the Revenue stands dismissed. 80. Now we take up the appeal of the assessee for assessment year 2006-07 i.e. I.T.A. No.384/Lkw/2011. 81. Both the sides agreed that ground No. 1, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me is not eligible for this deduction and on this issue, we do not find any reason to interfere in the order of CIT(A). This ground is rejected. 88. Regarding ground No. 9, 10 11, it was submitted by Learned A.R. of the assessee that these expenses have crystallized in the present year and, therefore, deduction is allowable in the present year. 89. Learned D.R. of the Revenue supported the order of learned CIT(A). 90. We have considered the rival submissions. We find that it is noted by CIT(A) in his order that part of the amount claimed by the assessee is in respect of interest accrued but written back. Regarding this amount, it is held by CIT(A) that the Assessing Officer is directed to call for the details of interest amount written off and if he is satisfied that the conditions of section 36 (2) are fulfilled by the assessee, he should allow the deduction in respect of interest written off. Regarding the balance amount, it was held by CIT(A) that in the present case, evidence is lacking in this regard that the liability to pay this expenditure has crystallized in the present year. Before us also, no evidence has been brought on record to show that the liability has c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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