TMI Blog2014 (9) TMI 30X X X X Extracts X X X X X X X X Extracts X X X X ..... combination with its use enhanced or even that it can be such a tool without which the main machinery may even become disfunctional, as in the case of a drilling machine, which is not of much use without a drilling bit. In a situation of such nature, drilling machine or drilling bit or blade or any other such accessory may even assume the role of being a part of the main machinery. It is, therefore, we are of the opinion that there cannot be a generalization or an examination de hors the particular product in combination with the machinery with which makes use of the goods or product. - Order of tribunal set aside - Decided in favor of Revenue. Levy of entry tax on drill-bits which are also called as machinery tools and wear parts such as drill-bits, reamers, cutters, etc. - Held that:- The fact of the notified goods coming into local area and the purpose for which it is brought are both significant and it is a combined operation of the two, which completes the charges in respect of the specified goods. Therefore, assuming that use, application or consumption, etc., takes places not at the entry point but later cannot make any difference to the charge so long as the purpose fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... use, consumption or sale. The Tribunal so opined and reversed the orders of the assessing authority and the first appellate authority, who had taken the view that these goods brought into the local area by the assessee for use, consumption or sale, attract the tax as goods covered under entry 52 of the First Schedule to the Act. Five appeals before the Tribunal related to the assessment years 2001-02, 2002-03, 2003,04, 2004-05 and 2005-06. This court at the time of admission of these revision petitions had formulated the following questions of law for examination, which arise out of the order of the Tribunal questioning the correctness or otherwise are required to be examined: (i) Whether the Tribunal was justified in allowing the appeal of the respondent particularly in the facts and circumstances of the case? (ii) Whether the Tribunal is right in holding that the part and accessories are consumable contrary to the view taken by the honourable Supreme Court in the case of Addison Co. [2009] 23 VST 5 (SC)? 3. The assessee is a company, engaged in manufacture and sale of machines and machine tools. It has its manufacturing unit at Chennai and causes entry of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... honourable Supreme Court in the order of February 26, 2009 (Addison Co. Ltd. v. State of Karnataka [2009] 23 VST 5 (SC)) ray of hope was left behind for the assessee by further observing that contention which was sought to be raised before the Supreme Court to the effect that subject goods are consumables and therefore not accessories/parts of machines, if it is so, could be raised before the assessing authority and if so raised the assessee has to examine it in accordance with law, has been pressed into service by the assessee for taking up such contentions based on the observations of the Supreme Court in the pending appeals before the Tribunal, relating to the assessment years 2001-02, 2002-03, 2003-04, 2004-05 and 2005-06. 8. The assessee had gone through the stages of the assessing authority and the first appellate authority which had opined that the assessee was liable in respect of the goods in question for payment of tax under the Act as they had opined so for the earlier assessment years and the assessee nevertheless had been pursuing the matter by way of further appeal before the Tribunal and such appeals were pending before the Tribunal. The judgment of the honourab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... i and the revision petitioner is represented by Smt. Sujatha, learned Additional Government Advocate. 12. These revision petitions have been heard together with other revision petitions involving the question of taxability or otherwise of items or goods which are similar in nature, like chipper knives, cutters, drill bits, etc., in CRP No. 147 of 2011, machine tools like drill bits, reamers, cutters, etc., in CRP No. 295 of 2010 and CRP No. 333 of 2010, drill bits, reamers, cutters, taps, etc., in CRP No. 294 of 2010 and CRP No. 338 of 2010, drill bits, reamers, taps and cutters, etc., in CRP No. 235 of 2010 and CRP No. 289 of 2010, twist drills, cutters, reamers, taps, etc., in CRP No. 293 of 2010 and CRP Nos. 334-337 of 2010, drill bits, reamers, cutters, etc., in CRP Nos. 292 and 308-309 of 2010 and in CRP Nos. 165 and 166 of 2011. 13. The learned counsel appearing for the assessee have put forth several contentions calling in aid several judgments of the honourable Supreme Court and this court and also other High Courts. 14. Submissions of Smt. Sujatha, learned Additional Government Advocate appearing for the revision petitioner-State in all these petitions are firstly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the KST Act; that this provision has been totally misunderstood by the Tribunal by calling in aid entry I, Part M of the Second Schedule to the KST Act wherein also the contents of the entry are similar or identical and with reference to this entry, namely, as it occurs in entry 1(f)(iii)(a) and (iii)(e) of Part M of the Second Schedule reads as machinery (all kinds) and parts and accessories thereof except those fall under other items of same nature and those specified elsewhere and this in combination with sub-entry (iii)(e) of the very entry used in industrial machinery such as twisted drills, grinding wheels, etc., having been made separate entry and going out of the scope of generic entry 1(iiia) and this manner of understanding and interpreting entry 52 of the First Schedule to the Act should be applied. In view of this interpretation in that section 2(B) of the Act is an exercise totally uncalled for. The Schedules in the two enactments are totally different that by process of incorporating or attributing the meaning of sub-entry cannot be created in the Schedule to the Act by a reasoning of this nature to understand the scope of entry 52 of the First Schedule to the Act wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ainst such submissions made on behalf of the State-revision petitioner, Smt. Radhika Sriranjani, learned counsel appearing for the assessee, has stoutly defended the case of the respondents. Learned counsel has drawn our attention to the fact that in the wake of the observations made by the Supreme Court enabling the assessee to raise contentions of the nature as to whether the goods in question were consumables. Therefore, whether it can be described as accessories or not being available to the assessee in the wake of the observations of the Supreme Court. In the order of the Supreme Court in the case of the very assessee that was fully demonstrated before the Tribunal and as can be seen from paragraph 28 of the order of the Tribunal, the Tribunal being fully satisfied with the demonstration made before the Bench of the Tribunal by displaying the goods in respect of which tax has been levied, such as drilling bits, cutter, sharp and wild edges and their longevity being very less when put into use and attributable to be answered as consumables and applying the judgment of the honourable Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC), the question is necessari ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... judgment of the Supreme Court were pressed into service and therefore the assessee contended that the goods which the assessee dealt with being in the nature of consumables, it cannot be brought to tax. 22. We have noticed that the question of legality of rectifying the assessment orders for five assessment years in question, is not an issue before us as the Tribunal having affirmed the correctness of the order of rectification and the assessee having not pursued the matter, the subject-matter of revision petition is only the question relating to the taxability or otherwise of the goods of the assessee under the provisions of the Act corresponding to assessment years 2001-02 to 2005-06. 23. We have considered the submissions made at the Bar by Smt. S Sujatha, learned Additional Government Advocate appearing for the petitionerRevenue and Smt. Radhika Shriranjani MD, learned counsel for the respondent-assessee. 24. In our considered opinion, the only aspect which if at all could be examined to determine the tax liability and in respect of the products for the subsequent assessment years is on the aspect of liability in respect of the goods which are in the nature of consumab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , etc. The Tribunal has committed a mistake in this regard in understanding the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) as an authority for the present purpose and for examination of taxability or otherwise of the product, visa-vis, entry 52 of Schedule I of the Act. The taxability of a particular product under a taxing enactment is dependent on the scope of the charging section, subject-matter of charge and the event happening of which attracts the liability for payment of tax. Identification of the person responsible for payment of tax is yet another aspect of a fiscal statute. 30. There are different taxing enactments having different purposes and subjecting to tax different type of goods, events, transactions and the like. The judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) was a case arising in the context of examination of taxability or otherwise of a product and the product therein being described as raw material and as to whether particular tool bits or drilling bits used can be characterized as one within the scope of the phrase raw material . The question arose in the context of levy o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iew that the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) can never be considered as an authority for the purpose of deciding the question as to whether the product is one taxable under entry 52 of the Schedule I to the Act. 36. For the same reason, we also hold that the question as to whether it is a36 consumable or not is of no significance and the fact that the Supreme Court permitted the assessee to raise a contention of this nature, if so advised before the authority will not in any way alter the situation either on fact or in law insofar as the present assessee is concerned, particularly, as the very products were subject-matter of decision of this court and the Supreme Court. The products whether it also fits into description of raw material or a consumable does not make much difference insofar as the present examination is concerned. The Tribunal having heavily relied upon the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC), for reversing the view taken by the lower authorities and going into great detail about the nature of the product and other things and a personal examination of the produc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to submit that this decision constitutes an authority for holding that tool bids, cutters, blades used along with other machinery forms part or accessory of the machinery and therefore is taxable under entry 52 of Schedule I to the Act and the products in the case of Addison Co. Ltd. v. State of Karnataka [2008] 14 VST 182 (Karn) and in the present case being of the like nature, of like use, it should be taken that the taxability of such goods in the hands of the assessee is concluded in terms of the judgment of the Supreme Court. 45. That apart, learned Additional Government Advocate has also contended that the Tribunal has committed an error in placing reliance on the judgments of the Supreme Court to submit that the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) is not an authority for the present purpose; that the Tribunal has gone wrong in assuming that the judgment constituted an authority and also in understanding that the order of this court in the case of Addison Co. Ltd. [2008] 14 VST 182 (Karn) as well as affirming judgment of the Supreme Court in the case of very assessee may not lay down the correct law as the judgment of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n be termed as an accessory or component and the test being that without the component the final product being not of any real value makes it as a component and whereas even without a part if the main product of the machinery is functional and can be used and a combination used for other product, makes it an accessory, may be for enhancing the efficiency or performance or even for enhancement of the look and appearance or like. It was held in this case that television antenna is to be held as an accessory of TV set. This decision was, no doubt, rendered in the contest of the provisions of the KST Act and on the question as to whether TV antenna constitutes an accessory and therefore liable to tax or it was a component of a TV set and it cannot be taxed independently. 50. Appearing on behalf of the assessee, Sri K.S. Suryanarayan, learned counsel, has urged several contentions. It is firstly contended that the assessee had claimed the subject goods as consumables and therefore nonscheduled and not taxable; that the assessing officer taking the view that it is a consumable tool and fitting into entry 52 of First Schedule to the Act in itself was not correct and this aberration on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... scope of entry 52 of the First Schedule to the Act. It is on this premise, the further argument that goods dealt with by the assessee being in the nature of tools and wear parts should also automatically be excluded from entry 52 of the First Schedule to the Act, etc. 52. In support of this submission, Sri Suryanarayan has placed reliance on the decision of a single Bench of this court in the case of Raja Motors v. Additional Deputy Commissioner of Entry Taxes-Cum-Commercial Taxes, Assessments-III, Bangalore City [1997] 106 STC 309 (Karn); [1997] 42 KAR LJ 57. Reliance is also placed on the judgment of this court in the case of Kennametal Widia India Ltd. v. State of Karnataka [2010] 69 KAR LJ 284 to urge that small machine tools manufactured and sold to another dealer for use as component and raw material are consumable to manufacture of other goods and recognizing this position, a notification has been issued under section 8A of the KST Act providing for concessional rate of tax, etc. This judgment is called in aid to submit that raw material or consumables are treated differently from parts and accessories thereof. 53. One another main argument urged on behalf of the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hedule as it stood at the relevant point of time and therefore all these decisions may not be of much use for the purpose of understanding the scope of entry 52 of the First Schedule to the Act. 56. The learned Government advocate has strongly urged that these are arguments sought to be urged before the court for the first time without any basis and it is not even proper on the part of the assessee to call in such arguments and supporting decisions and examination cannot be go beyond the taxability under entry 52 of the First Schedule to the Act in the context of the facts of the case and in the light of the judgment of the Supreme Court in the case of Addison Co. Ltd. [2009] 23 VST 5 (SC). 57. Even otherwise, we find the argument of interpreting or understanding the scope of entry 52 of the First Schedule to the Act by referential legislation fails on many counts. First of all, it is to be borne in mind that the understanding of a word or expression in the Act is not the same as interpreting a word or phrase which is used in a particular context in a different enactment, even when the words and expressions not specifically defined or sought to be understood in the context ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e a criterion to hold that the charging section in another enactment should also be understood in a like manner. 62. In fiscal statutes, interpretation of provisions of one enactment definitely cannot constitute an authority for interpreting the provisions or for understanding the purpose or even words occurring in a different fiscal enactment. Mere fact that octroi was a tax at the entry point and levy of tax under the provisions of the Act is also only after entry of the goods into the local area in itself cannot be a conclusive factor to understand the scope of chargeability under the provisions of the Uttar Pradesh Nagar Mahapalika Adhiniyam, 1959 and its Rules and Regulations should be assigned in understanding the provisions of the present Act. 63. Yet another reason why the judgments of this nature cannot constitute an authority is that examination by courts was provisions of different enactments and if it is an examination by the Supreme Court and a decision is rendered in the context of a particular statutory provisions in an enactment, the judgment can constitute a law declared by the Supreme Court within the meaning of article 141 of the Constitution of India, only ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ting scope of the words part and accessory to machinery and examination can only be in that context. 66. It is also evident from a reading of the above judgments that mere fact that a goods or product appears to be consumable does not necessarily mean being a part or accessory. It is, therefore, we reject the argument that mere fact that the goods/products of the assessee can happen to be a consumable by itself cannot take it out of the taxability under entry 52 of the First Schedule to the Act, as even otherwise it is a part or accessory to a machinery. 67. Though Sri Suryanarayan, learned counsel for the assessee, has urged that the assessing officer had described the product as a consumable tool, but that by itself does not absolve the assessee of the liability, as the assessee's effort rested with an attempt to show that the tool is consumable and therefore within the scope of entry 52 of the First Schedule to the Act. A tool in a given situation can also be part, and otherwise it can even be an accessory. It may be one consumed in the course of the application of the tool with the machinery or become useless over a period after use. These are all, in our considered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es to the use along with machinery employed by the assessee for producing its products. Assessment years are 1999-2000 and 2000-01 in CRP Nos. 295 and 333 of 2010 and 2001-02 and 2002-03 in CRP Nos. 235 and 289 of 2010. The views of the assessing officer having been affirmed in the appeal by the first appellate authority, the assessee was before the Tribunal questioning the correctness of these orders. Tribunal having taken the view that these products are goods brought into the local area by the assessee being in the nature of consumables and therefore not taxable as parts or accessories on the authority of the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC), the State is in revision to get over the orders of the Tribunal. 72. The grounds in support of these revision petitions are the same as in the above revision petitions which we have disposed of and therefore arguments on behalf of the State-revision petitioner by Ms. S. Sujatha, learned Additional Government Advocate are the same. It is submitted by the learned Government Advocate the very arguments as are urged in the above cases equally hold good for the present revision petitions al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Nagar Mahapalika, Bareilly [1988] 70 STC 97 (SC) as also the judgment of this court in the case of Assistant Commissioner of Entry Tax (Assessment I) v. Mysore Sales Corporation [1992] 84 STC 461 (Karn) to contend that taxable event is one of causing entry of goods into the local area and examination as to what is the goods brought at the entry point of local area and not the manner of use of the goods later and as to whether it can be used in combination with some other machinery to become an accessory to some other machinery or even if it can be used as part of some other machinery at a later point of time after getting the goods into the local area. 76. Sri Rabhinathan has also placed reliance on the judgment of this court in the case of K.B. Dani v. State of Karnataka [1979] 44 STC 276 (Karn), where this court had occasion to examine the question as to a trailer is part or accessory of a tractor and having opined that a tractor is in the nature of an agricultural machinery and that contention that tractor trailer is not in the nature of machinery was not taxable within the scope of entry 20 of the Second Schedule to the KST Act and on the same analogue, cutting tools bro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions of the Act. 80. We have already noticed the scope and meaning of understanding the words and expressions as defined in the Act to be the same meaning as in the KST Act. In so far as the argument relating to purposive interpretation while the principle is, undoubtedly and readily accepted, it is not attracted to the present situation and is not at all applicable. A purposive interpretation is given for effectuating some words and phrases expressly mentioned and provisions made for a particular purpose. The manner of under standing section 2(B) of the Act is only for the purpose of filling the gap or a vacuum in understanding any of the phrase or expression used in this enactment. Understanding of the scope of entry is not one such situation. It is, therefore, the argument that by giving a purposive interpretation to section 2(B) of the Act one should travel to the provisions of the KST Act and look into the scope and manner of entry 1(iii)(e) of Part M of the Second Schedule to the KST Act to be outside the scope of entry 1(iii)(a) of the same part and therefore a meaning of this nature should be attributed for understanding entry 52 of Schedule I to the Act does not stand t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se of use, consumption or sale, the charge is effectuated by issue of a notification in respect of any of the specified goods in the First Schedule to the Act. Unless notified goods are brought into the local area, with the intention of use, consumption or for sale by a dealer, there is no charge. The fact of the notified goods coming into local area and the purpose for which it is brought are both significant and it is a combined operation of the two, which completes the charges in respect of the specified goods. Therefore, assuming that use, application or consumption, etc., takes places not at the entry point but later cannot make any difference to the charge so long as the purpose for which the goods have been brought into the local area is for one of the three enumerated purposes such as use, consumption or sale by the dealer which manner of application of goods may occur later. 84. It is, therefore, we accept the arguments of learned Government Advocate and rejected the arguments of the learned counsel for the assessee. Therefore these revision petitions are also allowed, orders of the Tribunal set aside by answering the question accordingly and the orders passed by the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y [1988] 70 STC 97 (SC) and in addition has placed reliance on the judgment of the Allahabad High Court in the case of Commissioner of Sales Tax, U.P. v. Punjab Gramophone House reported in [1979] 43 STC 141 and submits that the Allahabad High Court had an occasion to examine the meaning of the word component part of machinery and had opined that the needles used in a gramophone for the purpose of playing a record is not component part of a gramophone and therefore submitted that the view taken by the assessing authority and affirmed by the appellate authority that the products are component parts of the cutting machineries in combination with which the subject goods are used cannot form part of the cutting machinery or tool cutting machinery and therefore submits that the view of the Tribunal should be affirmed. 91. An alternative argument is also addressed by Sri Keshavamurthy, learned counsel for the assessee, to submit that the assessee being new industrial unit has enjoyed certain benefits during its early stages; that the industry had a general exemption for a period of three years from the date of its setting up and which ended by March 31, 2004 and thereafter the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ming exemption with reference to entry 80, it is claimed as a component part; that the initial exemption was specifically with reference to machinery and equipment whereas the second notification under which the assessee can claim exemption for a period of five years is confined to raw materials, component parts, semi-finished goods, etc., and entry itself is different and therefore the benefit under the second notification cannot be sought to be availed of in respect of items or goods covered under entry 52 and with reference to which perhaps the first notification was issued. 96. We have bestowed our attention to the rival submissions and insofar as the judgment of the Tribunal purporting to follow the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) is concerned, we have already elaborately discussed the issue and opined on the same in the other revision petitions preferred by the State as mentioned earlier. 97. Insofar as reliance placed on the judgment of the Allahabad High Court in the case of Punjab Gramophone House [1979] 43 STC 141 is concerned, the judgment was particularly in the context of examination undertaken by the court un ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is to be as understood in the market parlance as can be distinguished with the understanding of the goods on a technical view point or from a scientific point of view. But, the understanding even in the case of Mysore Industrial Supplies [1997] 106 STC 585 (Karn); [1997] 42 KLJ 150 was in the context of examining the scope of entry 7 as it stood then reading as Industrial machineries and parts and accessories thereof'. 104. It is of significance to notice that parts and accessories are only such parts and accessories to the main description in the entry, namely, industrial machinery . 105. We notice the corresponding present entry is entry 52 and reads as machinery of all kinds and parts and accessories thereof , but excluding agricultural machinery. If machinery is not an industrial machinery, parts and accessories thereof also does not arise. Entry 7 while covered only parts and accessories of industrial machinery, the present entry covers parts and accessories of all kinds of machinery excluding agricultural machinery. Therefore, the meaning of the words parts and accessories also has to be understood in a generic context and the test has to be as to whether the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... achinery employed or used by the assessee and therefore we accept the submissions on behalf of the Revenue, particularly, based on the judgment of the Supreme Court in the case of Addison Co. [2009] 23 VST 5 (SC). 111. Insofar as reliance placed on the notification is concerned and even as submitted by learned Additional Government Advocate, an exemption notification issued with reference to entry 80 cannot be employed for claiming exemption under the levy of tax with reference to goods in entry 52 and it is well known exemption notifications should be construed strictly and scope of the exemption notification cannot be enlarged either by way of analogy or logic. It operates only in respect of the specific goods mentioned and not beyond. Therefore, the argument that the assessee can even otherwise claim exemption from levy of tax with reference to second exemption notification cannot be accepted. Such being the finding of the Tribunal, we do not find anything wrong in the order. 112. Therefore, this revision petition is allowed answering the question accordingly. RE: CRP No. 292 of 2010 and CRP Nos. 308-309 of 2010 connected with CRP NO. 165 of 2011 and 166-167 of 2011: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... contention that the products dealt with by the assessee which are brought into local area being in the nature of consumables, the judgment of the honourable Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) to be applied and therefore contended that it is not taxable. This argument having found favour before the Tribunal, the present revision petitions before us by the State. 117. It is also the submission of Mr. Gurudatta Shenoy, learned counsel for the assessee that the assessee has its manufacturing unit at Nasik and these goods are brought into local area where it has received the goods on stock transfer basis to its branch at Bangalore and placing reliance on the decision of this court in the case of Mysore Industrial Supplies [1997] 106 STC 585 (Karn); [1997] 42 KLJ 150, his submission is that the goods are not brought into local area as parts or accessories of any machinery at the point of entry and therefore, he is not liable to pay tax under entry 52 of the First Schedule to the Act. Mr. Shenoy has also pointed out that there are certain anomalies in the orders of the assessing authority and the first appellate authority that the assessing authority ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ade available for these assessment years is also an argument which cannot be examined in these revision petitions at the instance of the State wherein it was not an issue before the authorities particularly in the context of these assessment years and allowing or otherwise as a discounts or as deduction is based on fact and not on principle of law. Basically, it is on fact and if it enables the provision, it may be so claimed as deduction and not otherwise. Therefore, we do not propose to examine further the merits of these contentions urged in these revision petitions. 121. In fact, Smt Sujatha, learned Additional Government Advocate, joins issue and the main argument sought to put forth before this court in the revision petitions preferred by the State to the extent the matter was in issue earlier is, if the order of the Tribunal does not mention that one way or the other, the assessee having succeeded, his arguments can be called in aid only to that extent, we examine the submission made on behalf of the assessee. 122. Insofar as reliance placed on the decision of this court in Subhash Marketing's case [2000] 118 STC 136 (Karn) is concerned, we have already clarified t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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