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2015 (10) TMI 598 - ITAT BANGALORE

2015 (10) TMI 598 - ITAT BANGALORE - TMI - Accrual of income - addition made in the case of interest income on non performing assets on account of method of accounting followed by the assessee - assessee has neither followed mercantile nor cash system but followed hybrid system - assessee is a cooperative society engaged in the business of banking and providing credit facilities to its members - CIT(A) delted theaddition - Held that:- In light of the pronouncement of Hon’ble High Court of Karnat .....

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ccrual of liability - disallowance of expenses relating to earlier years - Held that:- It is clear from the facts as it emanates from the record that announcement of schemes by NABARD happened during the previous year. Therefore accrual of liability as far as assessee is concerned is only when subvention percentage is announced by NABARD. Till such time, the assessee’s liability cannot be said to have accrued. Since liability relates to the previous year in which subvention is announced by NABAR .....

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r the directions of its controlling authority and no documentary evidence was furnished before the A.O. to prove to his satisfaction that on account of this expenditure, the assessee derived certain income or benefits? - CIT(Appeals) observed that though the expenditure is made on account of directive from NABARD, there is also commercial exigency, and the assessee could fairly establish that there was sufficient mobilization of loans and advances and deposits directly relatable to this expendit .....

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UPREME Court ) wherein reference was made to the expression “wholly or exclusively” used in section 37(1) of the Act and was of the view that the expression used is not “necessarily”. In light of the legal position as explained in the judicial pronouncements and keeping in view the facts of the present case, we are of the view that the order of CIT(Appeals) does not call for any interference - Decided in favour of assessee.

Amortization of premium paid on government securities - CIT(A .....

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ccepted by the revenue in the past. In view of the aforesaid decision, we are of the view that the order of the CIT(A) does not call for any interference. Consequently, the relevant grounds of appeal raised by the revenue are dismissed. - ITA No.34/Bang/2014 - Dated:- 4-9-2015 - SHRI N.V. VASUDEVAN, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER For The Revenue : Shri V. Rajendra, CIT(DR) For The Assessee : Shri S. Ramasubramanian, CA ORDER Per N.V. Vasudevan, Judicial Member ITA N .....

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r cash system but followed hybrid system. By virtue of the provisions of section 145 of the Income Tax Act, the assessee is required to follow either cash or mercantile system of accounting to compute the real income. No adjustment could be made to the income assessed on accrual basis. 3. The learned CIT(A) has erred in deleting the addition on account of interest on non performing assets as the assessee has already identified and accounted the interest on NPAs and as such it can be clearly held .....

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d providing credit facilities to its members. In the course of assessment proceedings, the Assessing Officer noticed that the system of accounting followed by the assessee was mercantile system of accounting . The AO further noticed that the assessee had accounted interest income on accrual as well as cash basis as follows:- a. Interest receivable on all loans advanced on mercantile/accrual system ₹ 97,02,82,492 b. Interest collected during the year on cash system ₹ 77,96,96,653 c. T .....

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of section 145(1) of the Act, the assessee cannot follow mixed system of accounting i.e., both cash as well as mercantile systems. He was therefore of the view that the assessee ought to have accounted for interest receivable on standard loans as well as interest receivable on Non- Performing Assets (NPA) to taxation on mercantile system of accounting. He accordingly brought to tax a sum of ₹ 19,05,85,839 to tax towards interest accrued to the assessee on the mercantile system of accounti .....

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resaid decision, the CIT(Appeals) was of the view that interest on NPA to the extent of ₹ 16.89 lakhs cannot be brought to tax. 7. Aggrieved by the order of CIT(Appeals), the Revenue has raised grounds 2 & 3 before the Tribunal. 8. As can be seen from the grounds raised, the Revenue does not dispute the proposition of law laid down by the Hon ble High Court of Karnataka in Canfin Homes (supra) and the fact that the said ratio is applicable to the case of the assessee. The only grievanc .....

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ue has preferred SLP against the decision of the Hon ble High Court cannot be a ground to take any different view on the issue. We therefore uphold the order of CIT(Appeals) and dismiss ground Nos.2 & 3. 9. Ground No.4 reads as follows:- The Ld. CIT(Appeals) ought to have upheld the decision of the Assessing Officer in disallowing the expenses relating to earlier years. As the assessee is following mercantile system of accounting according to which the actual claim on payment basis made by t .....

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income of Rs,6,16,00,000/- under the head provision for NABARD sub-venation to PACs. This claim was made vide schedule 20 - Other Expenses - to the P&L Account for the year ending 31.3.2010. The assessee was asked to explain the same and justify the claim. 11. In reply dated 14.08.2012, the assessee stated as under:- The claim for interest sub-vention of 2% front the Central Govt. is also like in interest subsidy from the State Govt. It is prepared at the member PACs level. This claim is inc .....

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ral Govt., on 28.01.2011 and the Bank has paid a sum of ₹ 6,34,81,506/- to the PACS on the same day. The difference of ₹ 3,74,68,506/- (Rs. 6,34,81,506 - ₹ 2,60,13,000) is an expenditure to the Bank. This liability was ascertained during the year 2009-10. Out of this ascertained liability, the Bank has made a provision for ₹ 1,99,29,238/- under the head Provision for NABARD subvention to PACS in the Income & Expenditure a/c under the head other expenditure on 31.03.20 .....

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,73,000/- out of the above referred ₹ 7,08,43,762/- in the Financial Year 2009-10. The balance amount of ₹ 4,16,70,762/- was claimed, by the assessee as actual expenditure made to the PACs during the F.Y. 2009-10 i.e. A.Y. 2010-11. From the above, it is clear that the actual claim on payment basis made by the assessee amounting to ₹ 4,16,70,762/- does not pertain to the previous year relevant to the Asst. Year 2010-11. These expenditures pertains to prior period i.e., for the A .....

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ead provision of NABARD sub-vention to PACs. This is basically a subsidy given by NABARD on the advances made to primary agricultural co-operative societies (PACs). NABARD has framed certain schemes where, it charges loan at concessional rate on agricultural loans granted to targeted sections of agriculturists. As per the scheme, initially the banks are required to charge the normal rate of interest. After the year end, the primary agricultural co-operative societies (PAC) would submit a claim f .....

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2009-10 relevant to the AY 2010-11, the balance amount of ₹ 4,16,70,762/- was claimed by the appellant as accrued expenditure during the AY 2010-11. 15. Before the CIT(Appeals), it was argued by the assessee that the liability arises only when the claims are made by PACs. The PACs have to verify the eligibility and submit their bills to the assessee. After scrutiny by the assessee, the payments are made. Hence, it was submitted that though the basis of arriving at the expenditure is the d .....

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bills are received. 16. Further, relying on the decision of Hon ble Delhi High Court in CIT vs. Jagatjit Industries Ltd 339 ITR 382, it was argued that the method of accounting consistently followed in respect of this expenditure should not be disturbed. 17. The ld. CIT(Appeals) found strength in the argument of the assessee that though the basis of calculation for arriving at the expenditure is based on the disbursement of loans to targeted sections of agriculturists, the liability for the sam .....

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of CIT(Appeals). 20. We have given a very careful consideration to the rival submissions. It is clear from the facts as it emanates from the record that announcement of schemes by NABARD happened during the previous year. Therefore accrual of liability as far as assessee is concerned is only when subvention percentage is announced by NABARD. Till such time, the assessee s liability cannot be said to have accrued. Since liability relates to the previous year in which subvention is announced by N .....

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he decision of the Assessing Officer towards additions made on account of nonbusiness expenditure as this expenditure is incurred as per the directions of its controlling authority and no documentary evidence was furnished before the A.O. to prove to his satisfaction that on account of this expenditure, the assessee derived certain income or benefits. 6. The Ld. CIT(Appeals) has relied on the decision of Hon ble Supreme Court in the case of Sir Venkata Sathyanarayana Rice Mills Vs CIT (223) ITR .....

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e Tax Vs Rajasthan Spinning and Weaving Mills Ltd. 274 ITR 465. The Ld. CIT(Appeals) has failed to appreciate that the facts and circumstances of the quoted case are different for the instant case. 22. On going through the assessee s claim of other expenditure amounting to ₹ 2,81,57,340/-, the AO noticed that the assessee has made payments of ₹ 6,51,200/- each for six months and ₹ 9,11,000/- each for the remaining six months during the financial year relevant to the Asst. Year .....

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tions of our controlling authority - NABARD. Through the said Trust the bank is promoting the formation of Self Help Groups in the districts of Dakshina Kannada and Udupi. The bank has been advancing loans to those self help groups for generating income. The loans are given to SHGs for home industries like Candle making, soap making and such other activities. The income generated by such self help groups come back to our bank as deposits. Under this Micro Financing scheme rural poor and uneducat .....

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ork of liaisoning, training, monitoring and guiding such SHGs. They are also promoting various loan products of our bank and are also work as the persons canvassing for the deposits of the bank. At present there are 250 Animators and 8 coordinators working under this scheme. Since inception in 2004, the bank has advanced various loans amounting to over ₹ 500 crores. The present advance outstanding balance of various advances to different SHGs is over ₹ 100 crores with very high recov .....

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as clear that the assessee has incurred the expenditure towards the above referred Trust mainly as per the directions of their controlling authority viz., NABARD. The AO further noticed that the assessee has further stated that since the inception of the Trust the bank has advanced huge loans. The assessee also relied on the MOU between the Bank and the said Trust to justify the claim. He was of the view that in order to qualify for a deduction/allowance under the Act, the expenditure incurred a .....

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diture, as this has no relevance to the taxable income and as admitted by the assessee, this expenditure is incurred as per the directions of its controlling authority. The AO also observed that the assessee has also not proved with documentary evidence that on account of this expenditure, the assessee derived certain income or benefits. The MOU relied on by the assessee has no relevance to this issue. Considering the above, a sum of ₹ 93,73,200/- was disallowed by the AO treating the same .....

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n of ₹ 85 crores from these SHGs. There was no adverse findings on these facts by the AO. The assessee has no exempted income. 26. The assessee relied on the decision of Sri Venkata Sathyanarayana Rice Mills Vs CIT (223) ITR 101 wherein it was observed that What is to be seen is not whether it was compulsory for the assessee to make the payment or not but whether it was expended out of consideration of commercial expediency. As long as the payment is made for the purpose of business and th .....

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ing against the public policy and the expenditure has been motivated purely by commercial consideration. Applying the ratio of the above decision to the facts of the present case, it was submitted that the expenditure has been motivated purely by commercial consideration. The assessee has established as to how it is in its business and commercial interest to ensure the wellbeing of Self-Help Groups. Hence, the expenditure was for the purpose of business. The assessee also relied on the decisions .....

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its directly relatable to this expenditure. There was no adverse findings to this effect. Keeping in view the decisions cited by the assessee, the CIT(A) was of the view that expenditure has relevance to the business of the assessee and also generated substantial income though the objective is also laudable which may not be relevant for business. Under these circumstances, he directed the AO to delete the addition. 28. Aggrieved by the order of CIT(Appeals), the Revenue has raised grounds No.5 & .....

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districts of Dakshina Kannada and Udupi. The Assessee has been advancing loans to those self help groups for generating income. The loans are given to SHGs for home industries like Candle making, soap making and such other activities. The income generated by such self help groups come back to the Assessee as deposits. Under this Micro Financing scheme rural poor and uneducated people get to know banking, learn to handle finance and increase their income level. They also develop the habit of thri .....

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sessee s bank and are also work as the persons canvassing for the deposits of the bank. Further it is clear from the factual finding rendered by the CIT(Appeals) that the assessee could generate disbursements to the tune of ₹ 500 crores and deposit mobilization to the extent of ₹ 85 crores from the Self Help Groups. It is also clear that the expenditure in question was incurred by the assessee keeping in mind the commercial exigency. The decision of the Hon ble Rajasthan High Court i .....

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see, then the expenditure has to be regarded as incurred for the purpose of business of the assessee and allowed as a deduction. The Hon ble Rajasthan High Court followed the decision of the Hon ble Supreme Court in the case of Sasoon J. David & Co. P. Ltd. v. CIT, 118 ITR 261 (SC) wherein reference was made to the expression wholly or exclusively used in section 37(1) of the Act and was of the view that the expression used is not necessarily . In light of the legal position as explained in .....

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not an allowable deduction as in the assessee s case the securities classified as Held to Maturity are permanent long term investment made by the assessee bank, which are predominantly capital in nature. Ratio of the decision of Hon ble Madras High Court judgement in TN Power Finance & Infrastructure Development Corporation Ltd. vs JCIT (2006) 280 ITR 491 (Mad) wherein, it is held that RBI guidelines cannot override the mandatory provisions of income tax is applicable in this case. 32. The .....

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ion and offered the remaining interest for taxation. The AO vide requisition dated 25.6.2012 asked the assessee to justify this claim as under: To file detail of amortization expenses, giving detail of govt. security on which this premium was paid. Please explain as to how the amortization expenses is a revenue expenses. 33. The assessee in its reply dated 14.08.2012 has stated as under:- This method of amortization of premium on investment is in line with the guidance notes on audit of the Bank .....

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Available for Sale; as per circular/instruction from RBI. Such purchases of securities involve payment of premiums over the face value at the time of acquiring the, security. The premium so paid is added to the value of security cost. When such securities are held under the category Held to Maturity, the premiums so paid s equally spread over maturity date and amortised annually as per RBI guidelines. Such premiums amortised and pertaining to the current year is debited to the Profit and Loss A .....

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ssee like Available for Sale and Held for Trading category. So once it is established that these are not stock-intrade no charge can be made on revenue. But, however, at the time of disposing off the asset, relevant capital gain or loss can be booked. 36. The AO was of the view that in the instant case, the securities classified as Held to Maturity are permanent long term investment made by the assessee bank, which are predominantly capital in nature. Ratio of the decisions of the Hon ble High C .....

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he CIT(Appeals) deleted the addition made by the AO observing as under:- 7.2 In appeal, the appellant relied on the binding decision of Jurisdictional Hon ble ITAT Bangalore Bench in Sri M. Visweswraya Co-operative Bank Ltd vs JCIT in ITA No. 1122/Bang/2010 wherein, it is held that the amortized premium is allowable as expenditure / deduction. Hon ble ITAT also relied on Board instruction no. 17/208 which also states that amortization premium is to be allowed as deduction. 7.4 I have perused the .....

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issue raised by the assessee in ground No.8 & 9 is no longer res integra and has been decided by this Tribunal in the case of M/s. Sir M. Visweswaraya Cooperative Bank Ltd. Vs. JCIT, ITA No.1122/Bang/2010 for AY 07-08 order dated 11.5.2012. The following were the relevant observations of the Tribunal: 03. Let us first take up the issue relating to amortization of premium on investment in government securities. Relevant grounds read as under : " i) The learned Commissioner (Appeals) oug .....

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t take away the benefit which the appellant was entitled to and he ought to have appreciated that the case law referred were distinguishable and accordingly he ought to have allowed the deduction as claimed in full." 04. The brief facts pertaining to this issue are that while framing the assessment u/s.143(3) of the IT Act, for the assessment year 2007-08, the Assessing Officer noticed that the assessee has claimed a sum of ₹ 26,40,237/- under amortization of premium on investments an .....

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sion of the Madras High Court cited supra, came to the conclusion that the Hon'ble Madras High Court has that merely because the RBI had directed the assessee to provide for nonperforming assets, that direction cannot override the mandatory provisions of the Income-tax Act contained in section 36(1)(viia) which stipulate for deduction not exceeding 5 per cent of the total income only in respect of the provision for bad and doubtful debts which are predominantly revenue in nature or trade rel .....

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benches of the Hon'ble Tribunals, namely : • Catholic Syrian Bank Ltd., v. ACIT - Cochin (2010) 38 SOT 553 ; • Khanapur Coop.Bank Ltd., v. ITO in ITA.141/PNJ/2011 (Panaji); • Corporation Bank v. ACIT, M'lore in ITA.112/Bang/2008 (Bang) The learned counsel also placed reliance on Board's Instructions No.17 of 2008(vii) and pleaded that the claim of the assessee be allowed as the assessee had the powers to debit in its P&L account a sum of ₹ 29,02 lakhs of amor .....

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Bench. After analyzing the issue in depth, the bench has observed that with regard to amortization of premium on purchase of Government securities, it was clarified that this was made as per the prudential norms of the RBI. Following the Tribunal decision in the assessee's own case and considering that the assessee bank is following consistent and regular method of accounting system, there is no justification in interfering with the order of the Commissioner of Income-tax (Appeals) on this i .....

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tegory 'held to maturity'. The Assessing Officer has taken them as long term investments. In other words, he has accepted the assessee's claim that the securities are 'held to maturity'. That being so and having regard to the CBDT Instruction No.17 of 2008 dated.26.11.2008 as reproduced herein above, the premium paid on such government securities is required to be amortized over the period remaining to maturity ………." (iii) In the case of Corporation .....

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red by the Tribunal, the claim made by the assessee was rightly allowed by CIT(A). Accordingly, the relevant ground of appeal is dismissed. 41. Thus, appeal by the Revenue is dismissed. 42. ITA No.1266/B/13 is also an appeal by the Revenue against the order dated 18.3.2014 relating to AY 2011-12. Ground No.1 is general in nature and calls for no adjudication. 43. Ground Nos.2 & 3 are identical to ground Nos. 2 & 3 raised by the Revenue in ITA No.34/Bang/2014 for the AY 2010-11. For the r .....

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ble Karnataka High Court in CIT vs The Karnataka Bank Ltd. ITA No.433/2006 without appreciating the fact that the Department has not accepted the decision and since the SLP filed has been dismissed without going into the merits of the case, the question of law continues to remain unsettled. 45. On perusal of the assessee s P&L A/c, the AO noticed that an amount of ₹ 35,77,41,170/- has been credited to the P&L A/c. When specifically asked as to why this amount had not been offered .....

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opted by the Assessee Bank since the same has been followed consistently. However, as required by you we are herewith annexing to this letter working in relation to interest accrued on investments. The amount of interest accrued on investments for the year ended 31- March-2011 in ₹ 15,08,94,552/-. Furthermore, we would also wish to bring to your notice that the same method of accounting for interest is adopted by the assessee every year. Thus, the income which is not offered to tax in this .....

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.27 As can be observed, the assessee has stated that income from interest on investments has also been offered on cash basis and it should not be added as the same had been accepted by the Ld. JCIT during the course of assessment proceedings for A.Y. 2011-11 and the same would lead to double taxation as the same income has been offered on cash basis for A.Y. 2012-13. 6.1.28 At the cost of repetition, it is to be noted that each assessment year is to be treated as an independent unit and merely o .....

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In view of the above, an amount of ₹ 15,08,94,552/- being interest accrued on investments for A.Y. 2011-12 is added to the income. 46. In appeal before the CIT(Appeals), it was argued by the assessee that the interest accrues on bonds on the due date specified at the time of issuing the bond which has fallen due after the previous year. Hon ble High Court of Karnataka in the case of CIT vs. The Karnataka Bank Ltd., held that the taxing authority have no right to tax interest on investment .....

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be deleted. 48. Aggrieved by the order of CIT(Appeals), the Revenue has raised ground Nos.4.1 & 4.2 before the Tribunal. 49. We have heard the rival submissions. We have given a careful consideration to the rival submissions. At the time of hearing before us, it was agreed by the parties that the issue raised by the revenue in this appeal has already been decided by the Hon ble Madras High Court in the case of CIT v. Tamil Nadu Mercantile Bank Ltd., 291 ITR 137 (Mad). The question of law bef .....

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, 1989, which is a saving clause. Although the amendment was with effect from April 1, 1989, it clearly provides that any income by way of interest on securities shall be chargeable to tax as the income of the previous year in which such interest is due to the assessee only where no method of accounting is regularly employed by the assessee. In other words, if the assessee is maintaining cash system of accounting, the aforesaid proviso would not apply. The legislative intent is that when the ass .....

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nt years, in respect of the securities held by it on the ground that it did not become due in the respective previous years and that even after the omission of section 18, the interest on securities should be charged only when it became due for payment as it did not accrue on day-to-day basis. The Assessing Officer, however, disallowed the claims of the assessee, holding that after the omission of section 18 of the Act, i.e., after July 8, 1988, interest is to be assessed under the head Business .....

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