TMI Blog2009 (4) TMI 533X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Sub-Registrar in favour of donee and stamp duty has been paid. As such conditions laid down in sections 122 and 123 of Transfer of Property Act have been fulfilled. Thus it is a valid transfer of immovable asset in favour of the assessee donee. The Hon ble Supreme Court in the case of Sirehmal Nawalakha [ 2001 (8) TMI 109 - SUPREME COURT] held that requirement of complying with the provisions of Transfer of Property Act and Registration Act had to be fulfilled in order that there could be valid gift. However, transfer of capital asset as a gift is not a transfer u/s 47 for the purpose of capital gain and, therefore, provisions of section 50C cannot be applied. An asset cannot be termed, as any sum as used in various sub-clauses of section 2(24) or an income and therefore, agriculture land which was gifted cannot be taxed as income. It is not covered by and heads of income given in section 14 and therefore, neither agriculture land nor agriculture income is chargeable to tax under any heads of income. The application of provisions of section 56(1) therefore, cannot be upheld in the present case. Once donor expressed her intention to give gift and by registering th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... "Where any sum of money exceeding twenty five thousand rupees is received without consideration by an individual or a HUF from any person on or after 1-9-2004, the whole of such sum will be considered as income from other source." The Assessing Officer interpreted the word "money" by taking support from Oxford Advanced Learner s Dictionary and held that the words "sum of money" as given in section 56 could not be restricted to hard cash and it should be read in a broader sense because if it was restricted to hard cash the purpose of legislation would be defeated. The Assessing Officer with these findings applied provisions of section 56(2)( v ) and value of Rs. 40,80,380 was treated as income from other source. The Assessing Officer also held the gift received by the assessee as non-genuine and for this he gave his finding which is summarized below : ( i )There is no relationship between the donor and donee as both are from different caste or religion. ( ii )As affirmed by the assessee, husband of the donor and father of the donee are directors in one company which proves that both the families have business relationship. Under the circumstances it was beyond imaginatio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pplying the test of human probabilities. The Assessing Officer, therefore, considered the gift as non-genuine as the donor had no capacity to give such a huge gift and there was no occasion to make such a gift. The Assessing Officer, therefore, made addition of Rs. 40,80,380 under section 56(2)( v ) and also alternatively under section 56(1). 3. The ld. CIT(A) for the reasons mentioned in his order deleted the addition made by the Assessing Officer. 4. The ld. Counsel for the assessee Shri Sidharth Ranka argued and submitted that the assessee along with the return of income filed on 29-8-2005 for the assessment year 2005-06 submitted a note in the computation of income regarding receipt of agricultural land as a gift as follows [P.B. 90] : "The assessee received 33.7 bighas land in different Khasras on release by Smt. Navita Gupta, W/o Shri Ravi Kumar Gupta, Resident of L-1, Krishna Marg, C-Scheme, Jaipur vide release deed dated 25-10-2004 duly registered by the Sub-Registrar, Chaksu, Distt. Jaipur (copy enclosed)." The assessee has thus while filing the return of income, duly disclosed the transaction, there was no intention to hide the transaction. The assessee ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the property as was valued by the Sub-Registrar, Chaksu, District Jaipur as the income of the assessee. The Assessing Officer has sought to treat this transaction of receiving of agricultural land as gift as income liable to tax under the head "Income from other sources" either under clause ( v ) of sub-section (2) of section 56 or under sub-section (1) of section 56. By Finance Act, 2004 clause ( v ) to sub-section (2) of section 56 was inserted, which sought to treat certain receipts as income in the hands of the recipient. We are reproducing herewith the relevant portion of section 56(2)( v ) : "Where any sum of money exceeding twenty-five thousand rupees is received without consideration by an individual or a Hindu undivided family from any person on or after 1-9-2004...." Further the Assessing Officer in his paras 1.4 to 1.6 has sought to explain the term "sum of money" as mentioned under section 56(2)( v ) of the Income-tax Act, 1961. He has referred to Oxford Advanced Learner s Dictionary in para 1.5 of his assessment order where the term money has been defined to include wealth and wealth has further been defined as "total value of property" would also include mon ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... shall have to be given and not just the intended language. We are also reproducing hereunder some of the sections under the Income-tax Act, 1961 where the term "money" has been used and its intended meaning. If taken otherwise then the whole substance of the word would change. Section Language Interpretation 2(7) Assessee means a person by whom [any tax] or any other sum of money is payable under this Act. Sum of money is definitive amount and cannot be variable. 2(22)( e )( ia ) Dividend does not include : any advance or loan made to a share-holder [or the said concern] by a company in the ordinary course of its business, where the lending of money is a substantial part of the business of the company Money-lending has to be in cash, cheque, drafts, it does not mean lending of jewellery, properties, etc. 2(24)( iv ) Income includes: the value of any benefit or perquisite, whether convertible into money or not, obtained from a company either by a director or by a person who has a substantial interest in the company, or by a relative of the director or such person, and any sum paid by any such compa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g anything contained in sub-section (1), where any person receives at any time during any previous year any money or other assets under an insurance from an insurer on account of damage to, or destruction of, any capital asset, as a result of incomplete sentece Term other assets separately used to denote insurance compensation received. Thus the Legislature has differentiated between the term money and other asset . 46(2) Where a shareholder on the liquidat-ion of a company receives any money or other assets from the company, he shall be chargeable to income-tax under the head Capital gains , in Term other assets separately used to denote proceeds received on liquidation of a Company. Thus the Legislature has differentiated Section Language Interpretation respect of the money so received or the market value of the other assets on the date of distribution, as reduced by the amount assessed as dividend within the meaning of sub-clause ( c ) of clause ( 22 ) of section 2 and the sum so arrived at shall be deemed to be the full value of the consideration for the purposes of section 48 betwee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the form of money. Donation other than money/in kind is not eligible for deduction u/s 80G. 92B(1) For the purposes of this section and sections 92, 92C, 92D and 92E, international transaction means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money. The term money is used separately from the term tangible or intangible property, provision of services. 93(4)( d ) Capital sum means : ( i )any sum paid or payable by way of a loan or repayment of a loan; and ( ii ) any other sum paid or payable otherwise than as income, being a sum which is not paid or payable for full consideration in money or money s worth. The term money or money s worth has been used separately. 132(1)( c ) any person is in possession of any money, bullion, jewellery or other valuable article or thing and such money, bullion, jewellery or other valuable article or thing represents either wholly or partly income or property The term money is separately mentioned apa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cution of the instrument of transfer and such sum In case of exchange it includes also the sum of money. The term is used separately. 269SS Explanation ( iii ) Loan or deposit means loan or deposit of money If loan or deposit, consists of jewellery, immovable property, bullion, articles then it is not covered under section 269SS. If loan is in form of guarantee, then also it is not covered. Only when money is received, then the provisions of this section are attracted. 269T Explanation ( iii ) Loan or deposit means loan or deposit of money which is repayable. . . . If loan or deposit consists of jewellery, immovable property, bullion, articles then it is not covered under section 269T. If loan guarantee is cancelled, then also it is not covered. Only when money Section Language Interpretation is repaid by way of sum of money, then the provisions of this section are attracted. 278D(1) Where during the course of any search made under section 132, any money, bullion, jewellery or other valuable article or thing (hereafter in this section referred to as the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Act has to be interpreted only as actual money or cash and not as any other thing or benefit which could be evaluated in terms of money." ( c )The Hon ble Gujarat High Court in the case of CIT v. Miss Yeraben R. Amin [1993] 115 CTR 120 observed as follows : "For the purpose of claiming deduction under section 80G(2)( a ), the donation must be a sum of money and not donation in kind, donation of shares therefore, does not qualify for deduction under section 80G(2)." ( d )The Hon ble Bombay High Court in the case of CIT v. Godavari Sugar Mills Ltd. [1993] 203 ITR 773 observed as follows: "Equity shares donated by assessee. Not entitled for relief under section 80G." ( e )The Income-tax Appellate Tribunal, Bombay A Bench in the case of Trustees of Mount Nepean Trust v. First GTO [1987] 20 ITD 365 observed as follows : "Consideration has to be for the money or money s worth. If it is money, the inadequacy is easy to determine. If the consideration is not in money but in other forms, the determination of its monetary value and inadequacy is as per judicial decisions, estimated with reference to fair equivalent test, i.e., whether what is given is fair equ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act is treated as part of income. Clause ( xiii ) was included in the above definition which is related to section 56(2)( v ) from Finance Act, 2004 with effect from 1-9-2004. In the inclusive definition given of the word Income , income under section 56(1) is not mentioned. Section 14 above speaks of the words total income . The words total income is defined under section 2(45) of the Income-tax Act as follows : "Total income" means the total amount of income referred to in section 5, computed in the manner laid down in this Act. Section 5 is defined as : "(1)Subject to the provisions of this Act, the total income of any previous year of a person who is a resident includes all income from whatever source derived which ( a )is received or is deemed to be received in India in such year by or on behalf of such person; or ( b )accrues or arises or is deemed to accrue, or arise to him in India during such year; or ( c )accrues or arises to him outside India during such year : Provided that, in the case of a parson not ordinarily resident in India within the meaning of sub-section (6) of section 6, the income which accrues or arises to him outside India sh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rved as follows: "One of the essential ingredients constituting a gift under section 2( xii ) of the Gift-tax Act, 1958, is that the transfer of property by one person to another must be without consideration in money or money s worth." According to Oxford Dictionary , the term "income" means "that which comes in as the periodical produce of one s work, business, land or investments (considered in reference to its amount and commonly expressed in terms of money) or annual or periodical receipts accruing to a person or corporation". Can the act of receipt of gift be equated to produce of one s work? Eric. L. Kohler in A Dictionary for Accountants at page 2255 speaks of income as "Money or money s equivalent earned or accrued and includes profits gained through a sale or conversion of capital asset". Can the act of receipt of gift be equated to money or money s worth earned? According to Webster s Dictionary , the term "income" means "that gain or recurrent benefit (usually measured in money) which proceeds from labour, business or property, commercial revenue or receipts of any kind, including wages or salaries, the proceeds of agriculture or commerce, the rent of hous ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aracter fell outside the purview of income as defined under section 2(24). The Hon ble Madras High Court in the case of CIT v. Balamuralikrishna [1988] 171 ITR 447 where an amount of Rs. 30,000 was received by an artist held that there was no direct nexus between the payment received and his vocation. It is clear that the receipts cannot be treated as income liable to tax. Similarly in the case of CIT v. Sarbamangala Devi [1987] 163 ITR 898 (Patna), CIT v. Dr. P.R. Chakravarty [1987] 165 ITR 345 (Patna), CIT v. Abdul Gani Gurdeji [1995] 213 ITR 798 (Raj.), Maharaj Shri Govindlalji Ranchhodlalji v. CIT [1958] 34 ITR 92 (Bom.), CIT v. Girdharram Hariram Bhagat [1985] 154 ITR 10 (Guj.), CIT v. Ramdeo Samadhi [1986] 160 ITR 179 (Raj.) where the gift was made out of love and affection it was held not liable to be treated as income. In Reed v. Seymour 11 Tax Cases 625 (HL). Viscount Cave L.C. enumerated a principle : "Is it in the end a personal gift or is it remuneration? If the latter, it is subject to tax; if the former, it is not". The Hon ble Supreme Court of India in the case of Mahesh Anantrai Pattani v. CIT [1961] 41 ITR 481 held "whe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... one so and fulfilled all the conditions as required under the Transfer of Property Act and the Registration Act. Shri Ravi Kumar Gupta, husband of Smt. Navita Gupta a renowned architect of Rajasthan and Shri Kushal Chand Bader, father of Shri Komal Bader are Directors in M/s. Arihant Jewels Limited. Shri Ravi Kumar Gupta and Shri Kushal Chand Bader are very close child-hood friends, having studied together in St. Xavier School, Jaipur and thereafter and continue to be very close family friends. Both families have travelled together widely. The two families have close family ties and bonds for the last 3-4 decades. Several photographs of the two families when they travelled together outside Jaipur on several occasions at places like Jammu Kashmir, Kulu Manali, Shimla, Mt. Abu, Dharamshala, etc. are also enclosed [PB 72-83]. Statements under section 131 was recorded of Smt. Navita Gupta by the ld. Assessing Officer at the back of the assessee on 14-11-2007 [P.B. 51-57]. The assessee was not provided a copy of the statements recorded under section 131 before passing of the assessment order. Thus, the material on which the ld. Assessing Officer has relied upon was not confronted to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Hon ble Supreme Court in Kalra Glue Factory v. Sales Tax Tribunal [1987] 167 ITR 498 set aside the order of the Tribunal as well as order in revision of High Court on the ground that the statements of a partner of another firm upon which the Sales Tax Tribunal relied, had not been tested by cross examinations. ( iv )The Hon ble Rajasthan High Court in CTO v. Haryana Dal Mill [1993] 90 STC 519 dismissed the departmental revision petitions on the ground that the respondent not having been given opportunity to discredit the entries or cross examine the agent and the entries not having been proved nor the agent examined, the order of the Board of Revenue was justified. ( v )The Hon ble Kerala High Court in P.S. Abdul Majeed v. Agricultural Income tax Sales Tax Officer [1994] 209 ITR 821 in a writ petition by the petitioner-assessee held that there were two inspections to the petitioner s holdings on 3-11-1981, and on 19-9-1985, before and after the assessment year in question, when the inspecting authorities estimated the yield of cardamom from the petitioner s holdings at 180 Kgs. The order of reassessment was made without any reference to either of these inspectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ady been proved and in response to question No. 6 Smt. Navita Gupta has clearly mentioned that Shri Komal Bader is like a son to her. In our historical manuscripts it is written that Lord Krishna gave so many jagirs, etc. to his friend Sudama. If Income-tax Act was prevalent during that time then Assessing Officer would have sought to tax such an act. An act of gift arises from personal feeling and bonding towards one person, such bonding is not restricted to blood relations only [PB 54-55]. 2. No statement of affairs are being prepared and enclosed with the return of income by Smt. Navita Gupta. Is there a requirement of the Income-tax Act that statement of affairs has to be enclosed by all the assessees along with the return of income ? Further Smt. Navita Gupta had provided following papers to the ld. Assessing Officer : ( a ) Copy of balance sheet for year ended 31-3-1994 along with computation of income and Sl. No. Defects pointed by AO Our Submissions assessment order. The Assessing Officer has conveniently ignored the same [PB 69-71]. ( b ) Copy of balance sheet for year ended 31-3-1998 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ificate from Smt. Navita Gupta which proves the status of the family [PB 48-50]. Inference so drawn by the Assessing Officer deserves to be ignored. 4. Source of income of Smt. Navita Gupta is very less. The ld. Assessing Officer has simply mentioned the returned income, ignoring the agricultural receipts received by Smt. Navita Gupta. The ld. Assessing Officer has very conveniently ignored to ask the donor or her husband who was also present during the statements were recorded the source of income of the family/husband of Smt. Navita Gupta. Smt. Navita Gupta was not required to struggle for her own livelihood. She was dependent on her husband and in-laws for support. For a lady income need not be substantial - more particularly when she is dependent a house-wife. Shri Ravi Kumar Gupta is one of the leading and best known architects from Rajasthan. He belongs to illustrious family of Rajasthan. The family of Smt. Navita Gupta consisted of just 3 members. Inference so drawn by the Assessing Officer deserves to be ignored. 5. Bank balance was maximum of Rs. 5.22 lakhs and lowest was Rs. 665. Average balance is less than Rs. 1.00 lakh duri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he ld. Assessing Officer [PB 146-216]. Properties are purchased/sold on the advice of close friends, confidants, relatives. Smt. Navita Gupta being a house-wife could not be expected to find a property being more than 35 KMs away from Jaipur 25 years back. Shri Ravi Kumar Gupta and Shri Kushal Chand Bader are child-hood friends, having studied together in St. Xavier School, Jaipur and thereafter. On the contrary it was a generous and futuristic act by Shri Kushal Chand Bader, who himself is a renowned jeweller and belonging to an illustrious family of Jaipur to invite her to invest together while purchasing the property, not out of need but just as an act of solidarity/friendship. Inference so drawn by the Assessing Officer deserves to be ignored. 9. Smt. Navita Gupta failed to provide clear details and source of Rs. 90,000 towards purchase of land. An investment done 25 years back by Smt. Navita Gupta of just Rs. 90,000 is being questioned by the ld. Assessing Officer now. This is surprising. Smt. Navita Gupta had provided following papers to the ld. Assessing Officer : ( a ) Copy of balance sheet for year ended as on 31-3-1994 along with computation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hom the giver thinks, he ought to supply with funds for one reason or another. Gifts are given to people in whom they place faith, or for whom they have limitless regards Sl. No. Defects pointed by AO Our Submissions and an element of reverence, veneration or personal esteem and faith - all depend upon personal feelings and desire; no probe can easily be made into such aspects of human psychology and best persons to explain such feelings and desires are those who execute same. Questioning the timing of gift is totally baseless and it will always be on individuals whims and fancies when the gift is to be made. The donor will not ask the Income-tax Officer or refer to the Income-tax Act to decide when he/she should make a gift. Inference so drawn by the Assessing Officer deserves to be ignored. 11. No occasion to make a gift. Market value of the land is much more than what is valued by the Stamp Valuation Authority. Stating that the land value is more than what is valued by the Stamp Valuation Officer is totally baseless, without any basis and supporting. The donor will not ask the Inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of solidarity. Inference so drawn by the Assessing Officer deserves to be ignored. 13. Total value of assets side is not more than Rs. 2.00 lakhs and donor has no capacity and having a son to inherit the property has gifted the property to a person not related to her. From where the Assessing Officer has arrived at this figure of Rs. 2.00 lakhs is best known to him, earlier he has mentioned that Smt. Navita Gupta has not provided any statement of affairs. The fact that she was living in her husband s posh house situated in one of the best localities of Jaipur in C-Scheme has been ignored. In addition she already owned plot at Kalwad Road. The gifted property is agricultural land not a residential house that she would have been dependent on. Smt. Navita Gupta or her family members were/are not dependent on the agricultural land which was gifted. The ld. Assessing Officer has very conveniently ignored to ask the donor or her husband who was also present during the statements were recorded the immovable-movable assets owned by the family of Smt. Navita Gupta. Smt. Navita Gupta in response to question No. 1 that she is a housewife. A housewife would naturally ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... acts as required under sections 122 and 123 of the Transfer of Property Act have been accomplished and they have not been challenged by the ld. Assessing Officer. 11.We are enclosing herewith a detailed certificate from Smt. Navita Gupta who elaborates about her family status, etc. Her family owns and possesses several properties. [PB 48-50]. She comes from a family of illustrious and renowned Persons, Professionals, Ministers, Bureaucrats, etc., etc. The Assessing Officer has referred to certain judgments in his support. Our comments on the same are as follows : The Assessing Officer has referred to the decision in the case of Chain Sukh Rathi ( supra ) this case was relating to search and seizure holding where some incrementing documents were found. Not related to the facts and circumstances of the case of the assessee and cannot be relied upon. The Assessing Officer has referred to the decision in the case of R.S. Sibal ( supra ) where the Delhi High Court has held that mere identification of the donor was not sufficient. On the contrary the above order is in favour of the assessee as there was an act of gift between Donor a NRI and the Donee who were non-relative ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... examining the witnesses of the registered gift deed, it could be said that, gifts of immovable properties satisfied all conditions laid down in sections 122 and 123 of Transfer of Property Act and was valid ? The Hon ble jurisdictional Rajasthan High Court recently in the case of CIT v. Padam Singh Chouhan [2008] 215 CTR 303 approved the genuineness of the gift where the donor was a non-resident and there was no blood relationship or close relationship between the donor and the donee. It observed that assessee had produced copies of gift deeds and affidavits of NRI donors and there was no case of money laundering [P.B. 277-280]. The Income-tax Appellate Tribunal, Jodhpur Bench in the case of DCIT v. Ramdeo Kumar 140 Taxman 102 approved the genuineness of the gift when the donor was a non-resident Punjabi whereas the donee was Maheshwari and of Sriganganagar. However, the identity, capacity and friendship was established. It observed that for making gift, it is not necessary that there should be some blood relation or gift should be made only to relatives and not to friends. The Income-tax Appellate Tribunal, Chandigarh Bench in the case of R.K. Shyal v. ACI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of agricultural land and the valuation under section 50C is to be adopted in the case of transferor. 2.Gift of capital asset is not treated as transfer in the hands of the donor or donee under section 47( iii ) of the Income-tax Act, hence provisions of section 50C are erroneously taken." Section 49( ii ) of the Income-tax Act provides for valuation of cost in case the property is received by the assessee under a gift. It says that the cost of acquisition of the assessee shall be deemed to be the cost for which the previous owner of the property acquired it, as increased by the cost, any improvement of the asset incurred or borne by the previous owner, or the assessee as the case may be. Thus valuation of the gift as valued by the registered valuer would lead to double taxation as far as assessee is concerned. Since at the time of subsequent transfer by the assessee, the value which shall be adopted in his hands shall be Rs. 90,000. Thus in our humble submission, since the donor is not held to be a benami, the addition if any, on this account can be to the extent of cost at the hands of the donor. In GTO v. Vinod Kumar Hansaria [2003] 131 Taxman 134 (Jodh.)(Mag.) ITAT Jodhp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eds twenty five thousand rupees and it is received without any consideration then whole of such sum will be taxed as income from other source. Whether "sum of money" may include an immovable property also - is the issue to be decided. The Assessing Officer has observed that it should not be restricted to hard cash and it should be read in a broader sense because otherwise the purpose of legislation would be defeated. As the ld. AR in his submission has stated that when these provisions were introduced through Finance Act, 2004, the Finance Minister in his budget speech maintained that to prevent money laundering, loophole was required to be plugged and, accordingly, purported gifts from unrelated persons above Rs. 25,000 should be taxed as income in the hands of the donee. "Money laundering" denotes siphoning off money from country by illegal channels. Changing hands of an agricultural land within the country and between two citizens cannot be considered as money laundering. Thus it cannot be said that the provisions were introduced to stop such transfer of capital assets within India. Further when the language of the section is clear, there is no need to interpret in own s way. If ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee, executed her intention and by getting registered in his name, the donee accepted the gift and in absence of any material with the Assessing Officer to prove that any consideration was paid in lieu of the gift, all the ingredients of a gift are fulfilled. Now coming to the capacity of the donor, it is an admitted fact that the donor had agricultural land in question in her possession and she had been showing agriculture income also from the land. She has been staying with her husband who is a well-known architect. For her livelihood, she was not depending on the agriculture land gifted but only on her husband. As long she was not living alone and independent, capacity of her family cannot be ignored. Once capacity of the donor is proved and all other ingredients to make a gift complete also fulfilled, there is no reason to disbelieve the gift as agriculture land given, by Smt. Gupta to the assessee. In such circumstances and facts of the case, we find no infirmity in the order of the ld. CIT(A) who has rightly deleted the addition made by the Assessing Officer. Thus the solitary ground of the revenue is dismissed. 7. In the result the appeal of the revenue in ITA No. 1253/Jp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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