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2016 (4) TMI 83 - ITAT DELHI

2016 (4) TMI 83 - ITAT DELHI - TMI - Disallowance of depreciation on software purchased by assessee - Held that:- Assessee could not prove the facts that assessee has used these software in the business of the assessee except merely stating that These softwares were installed in the company and all the purchases were duly incorporated in the books of account of the company. Merely such a bald statement coupled with evidence against the assessee does not prove that an asset if at all owned by the .....

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the issue of allowance of depreciation on the assets purchased by the company which assessee has failed miserably to prove . Assessee could not prove the strength of the supplier to provide the software mentioned in the bills, assessee could not produce the details whether it has hardware strength of installing such software . it could not also established giving the softwares to sobha developers, It could not establish how the seven other persons have got right to waive the compensations, It i .....

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d against assessee. - ITA No.4808/Del/2012, ITA No.4809/Del/2012, ITA No.4810/Del/2012 - Dated:- 10-3-2016 - SHRI A.T.VARKEY, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER For The Assessee : Sh.S.M. Mathur, CA For The Revenue : Sh. Sunil Chander Sharma, CIT DR ORDER PER PRASHANT MAHARISHI, A. M. 1. These are three appeals preferred by the assessee for Assessment Year 2008-09, 2009-10 and 2010-11 against the order dated 18.07.2012 of learned Commissioner of Income-tax (Appeals)-X .....

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owance made by the learned Assessing Officer of depreciation of ₹ 84.84,910/- on the purchase of Software of ₹ 4,24,25,05O/- from M/s Macro Infotech Ltd. by the appellant company. 2. That the Hon'ble Commissioner of Income Tax (Appeals) while sustaining the disallowance of deprecation has erred in law as much as facts of the case in violating the principle of natural justice by not providing any opportunity of confronting the information and documents received by the learned Asse .....

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ied upon the information received from the learned Director of Income Tax (Inv.) on the face of it without independently verifying the facts of the case. Likewise the Hon'ble Commissioner of Income Tax (Appeals) also followed the same and had erroneously sustained the disallowance of depreciation. 5. That the Hon'ble Commissioner of Income Tax (Appeals) while sustaining the disallowance of claim of depreciation has not brought on record any tangible material on record to hold that the as .....

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n of false documents. In the absence of such material disallowance of depreciation is totally unwarranted and unsustainable in law. 6. That on the facts and circumstances of the case the Hon'blc Commissioner of Income Tax (Appeals) had erred in law is not appreciating that the appellant already proved the ownership of the said Softwares purchased by it and also proved its user in the business carried by the appellant. 3. The grounds of appeal raised by the assessee for the Assessment Year 20 .....

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the case by upholding the disallowance of depreciation of ₹ 81,14,514/- on Softwares by following the findings of the immediate proceeding years relevant to Assessment Year 2008-09 and 2009-10. 5. The assessee has also raised additional grounds of appeal for Assessment Year 2008-09 vide application dated 15th September 2015. The reason given for filing the additional grounds of appeal is that it has inadvertently escaped the attention while preparing the original grounds. The additional g .....

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res of ₹ 4,24,25,050/-purchased by the appellant from M/s Macro Infotech Ltd. 2. That the Hon'ble Commissioner of Income Tax (Appeals) while sustaining the aforesaid disallowance of deprecation has erred in law as much as facts of the case in violating the principle of natural justice by not providing any opportunity of being heard to the appellant for confronting the informations and documents received by the learned Assessing Officer from the learned Director of Income Tax (Inv.) New .....

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gus bills and in lieu of cheque payable giving back cash to the appellant company. 4. That on the facts and circumstances of the case the Hon'ble Commissioner of Income Tax (Appeals) had erred in law is not appreciating that the appellant already proved the ownership of the said Softwares purchased by it and also proved its user in the business carried by the appellant. 6. The ld DR did not object to the additional grounds of appeal for all the three years and therefore the same are admitted .....

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rried out at the business and residential premises of the assessee who belongs to Ashok Solomen and Chintels Group of cases. Notice u/s 153A of the Act was issued on 10.03.2011 and in response to that return of income was filed on 28.04.2011 u/s 153A of the Act declared income of ₹ 2,31,47,987/- . On post search enquiry it was found that one Shri Tarun Goyal was subjected to search u/s 132 of the Act on 1st September 2008 and wherein it was found that he has created more than 90 companies .....

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n Goyal was recorded where he has accepted that he is engaged in providing accommodation entries and bogus bills to various persons. During the course of investigation it was found that one company M/s Macro Infotech Ltd was also formed by Shri Tarun Goyal, who is engaged in issuing bogus bills and it does not have any expertise in software business. During the enquiry after the search and seizure operation it was found that the assessee has purchased software of ₹ 42424550/- from M/s. Mac .....

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nsaction made with M/s. Macro Infotech Ltd. In response to this the assessee submitted on 28.11.2011 that M/s. Macro Infotech Ltd is engaged in the business of supply of various kinds of the computer software, graphics and other elite products and during FY 2007-08 the assessee has purchased software of ₹ 424245050/- from these companies and payment for which is made through account payee cheques. It was further submitted that these software were installed in the company and recorded in th .....

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efore it cannot be returned. It was submitted that the bills have been debited in the books of account and depreciation has been claimed. As the AO was not satisfied with this explanation of the assessee the depreciation on the software amounting to ₹ 8484910/- being 20% depreciation on the cost of software of ₹ 42424550/- was disallowed. The assessee preferred an appeal before the learned Commissioner of Income-tax (Appeals), who confirmed the disallowance as the assessee has failed .....

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rocessed u/s 143(1) on 27.03.2010. Therefore it was argued that processing u/s 143(1) is an assessment which is already completed and not pending‟ at the time of search and therefore for assessment for A.Y. 2008-09 can be made only if there is an incriminating material found during the course of search. Therefore according to AR this assessment is not pending and in absence of any incriminating material the assessment is bad in law. For this he also relied on the decision of Honorable Delh .....

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es has shown that there are incriminating documents and hence the assessment is correctly made. 11. Provisions of section 153A are as under :- ASSESSMENT IN CASE OF SEARCH OR REQUISITION (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, .....

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o be furnished under section 139 ; (b) assess or reassess the total income of six assessment years immediately proceeding the assessment year relevant to the previous year in which such search is conducted or requisition is made : Provided that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years : Provided further that assessment or reassessment, if any, relating to any assessment year falling within the peri .....

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fore the assessment can be made with respect to assessment years which are pending on the date of initiation of the search. Then the total income of the assessee for such assessment years will have to be computed by the AO as a fresh exercises. 13. In this case the assessee has submitted a copy of Panchnama dated 27.03.2010 which shows that the search commenced on 26.03.2010 based on the authorization dated 25.03.2010. Therefore the date of initiation of the search is 25.03.2010 and the date of .....

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any incriminating material same is required to be quashed, is rejected. Therefore in that case the assessment of the assessee for Assessment Year 2008-09 is required to be made as unabated assessment. 14. Hence the additional grounds raised by the assessee are dismissed. 15. Other grounds of the appeal are on the merits of the case that the assessee is eligible for depreciation on the software purchased of R 42425050/-. The main argument of the assessee is that the assessee has purchased this s .....

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try of payment. All the invoices of Macro Infotech Ltd were in the month of July and August 2007. The bank statement of the assessee also showed that cheques have been issued in favour of M/s. Macro Infotech Ltd. and for this the assessee submitted the bank statement of its bank account with Bank of Rajasthan Ltd. Subsequently, certificate dated 20th June 2012 from ICICI Bank Ltd ( in which the Bank of Rajasthan has merged with ICICI bank Ltd) was given showing the date of payment, amount, chequ .....

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parties which shows that joint development agreement entered into between them have been cancelled. According to Clause No.6 of that agreement it was mentioned that the second party i.e. Sobha Developers Ltd has agreed to hand over the first party i.e. seven different parties , including the sophisticated software presentation and other material. It was mentioned that the software which has been given by first party to the second party have been damaged and destroyed and therefore could not ret .....

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the lower authorities, which shows PAN No, Central Sales Tax No etc of the suppliers of the software. It was further stated that the assessee has discharged its onus that it is a business income, the software asset is owned by him, if that no question have been asked by the AO and therefore disallowance of depreciation cannot be made in the hands of the assessee. 16. Against this the ld DR submitted that the learned Commissioner of Income-tax (Appeals) has given detailed reasons at Page 10 to 12 .....

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is no confirmation from Sobha Developers Ltd. that how the software destroyed. Regarding the issue of the cross examination of by the assessee, the he relied on the para No.2.3.2 of the learned Commissioner of Income-tax (Appeals) order and said that independent to the statement of other party, assessee could not establish the ownership and user of the asset purchased and further this fact has been corroborated by the statement of Shri Tarun Goyal. In view of this he submitted that depreciation .....

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n Goyal, search and seizure operation u/s 132 of the Income Tax Act 1961 had been conducted on 15-09-2008 by the Unit-IV of the Directorate of Income Tax (Investigation), New Delhi. Shri Tarun Goyal has created more than 90 non Prescript companies. The main business of Shri Tarun Goyal, to issue bogus bills and providing accommodation entries in the nature of share capital, share application money, loans and advances etc. and charge commission accordingly. During the post search enquiry in the c .....

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dation entries and bogus bills to number of persons. Company named M/s. Macro Infotech Ltd. was formed by Shri Tarun Goyal. The main task of the company is to issue bogus bills. On the verification it comes to the notice that M/s. Macro Infotech Ltd. has no expertise in software business. The addresses of the company were also verified during the post search enquiry and it was found that air the addresses were bogus. The information about the beneficiaries had been sent to the office of concerne .....

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Ltd, They have taken bogus bills to inflate their expenditures and take back cash after the payment of commission. When the enquiry conducted by the intelligence unit the assessee has not offered explanation in this regard. 6.2 Vide questionnaire dated: 19-08-2011 assesses was asked that: "What is the business of M/s, Marco Infotech Limited? What are the goods and services they are dealing in? Furnish ledger extract of your transactions with M/s. Marco Infotech Limited during the financial .....

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ion of both the addresses, it had come to the notice that no such company is running from Dehradun's address and the Delhi's address belongs to one Shri Tarun Goyal, who is a Chartered Accountant. The search and seizure action was also conducted at the office of Shri Tarun Goyal by the Investigation Wing, Delhi. During the search It was found that numbers of bogus concerns are running from the address 13/34, WEA Chamber No, 404, Main Arya Samaj Road, Karol Bagh, New Delhi and M/s. Macro .....

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ssessee has submitted "M/s Marco Infotech is engaged in the business of supply of various kinds of computer software, graphics and other allied products. The company during the financial year 2007-08 had purchased software in aggregate ₹ 4,24,25,050/- from them. Payment of all the bills for the supply of software were made by the assessee company through payees cheque drawn on Bank of Rajasthan as per confirmation, of account sent by M/s Macro Infotech. These softwares were installed .....

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upon cancellation of the 19.768 acres Project vide agreement dated 8/10/2011, we were informed that it has been damaged/destroyed by Sobha and hence cannot be returned. The aforementioned agreements along with details of supply of software and copy of purchase bills issued by M/s Macro Infotech are enclosed herewith for your ready reference. The company has debited these purchases in the computer software and claimed depreciation thereon. As per the bills available with us issued by M/s Macro I .....

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case, our explanation is found unsatisfactory and unconvincing, show cause notice is given to explain as to why the transactions made with M/s Macro Infotech to the extent unexplained may not be treated as "Undisclosed Income" and added to in our returned income for assessment years 2004-05 to 2010-11. We hope the above explanation will be up to your satisfaction as the expenditure incurred by the company .in purchase of the softwares, therefore, it cannot be treated as "Unexplai .....

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filed any documentary evidence in respect to the software destroyed because of M/s. Sobha Developers. Ltd. The assessee company has taken the bogus purchase bills of software ₹ 42424550/-from the M/s. Macro Infotech Ltd. For the payment of these gobus bills they have issued cheques and taken back cash from Shri Tarun Goyal after payment of commission. The assessee company has shown the expenditure of ₹ 4,24,24,550/- as capital expenditure and claimed depreciation @ 20% in the year in .....

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alleged to have been purchased from M/s Macro Infotech Ltd., in the background of the information received from the Investigation Directorate regarding the accommodation entry network being operated by Shri Tarun Goyal through the 90-odd companies and over 200 bank accounts that he formed and controlled for this purpose as admitted by him before the Department at the time of search conducted in his case. The appellant had claimed that it had purchased software worth ₹ 4,24,25,050/- from M .....

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of its claim of depreciation on software claimed to have been purchased from M/s Macro Infotech Ltd. and used in its business. Relevant portions of this show cause have been extracted by the AO in his assessment order itself. In reply, the appellant reiterated that it had purchased software from M/s Macro Infotech Limited and payments were made through account payee cheques as reflected in the bank account of the appellant. However, ho evidence whatsoever regarding the actual user of the softwar .....

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nt owns it and actually uses it in his business during the previous year relevant. In the instant case, though the appellant, prima facie, produced the invoice as the evidence of purchase of software from M/s Macro Infotech Ltd., but the invoice lost its evidentiary value as soon as it was found that no such company being engaged "in software development business was available on its given address of Dehradun and the address touted as its branch office address was, in fact, "the office .....

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ppellant an opportunity to cross examine Shri Tarun Goyal and had based his conclusions on the information received from the Directorate of Investigation which was obtained at the back of the appellant is also misplaced in view of the fact that the AO had not solely based his conclusions on the information received from the Directorate of Investigation but had further made enquiries and had given an opportunity to the appellant to justify its claim by producing evidence of ownership and user of .....

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it said before the AO. No evidence other than the Invoice which already lost its evidentiary value due to non- existence of its issuer at the given address has been furnished to support either the ownership or user of the software by the appellant. The appellant has claimed that the software claimed to have been purchased from the said M/s Macro Infotech Ltd. was a specialised, sophisticated software which was to be used as a marketing/sales tool in the development of the Group Housing Projects .....

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of the software's user in the appellant's business, the appellant evaded issue the by stating that the software was destroyed by M/s Sobha Developers. Thus, no evidence of the existence of the software was ever -brought on record. Neither the hardcoded documents were produced nor the digital form was ever shown to have been used by the appellant. The alleged developer of the software was also a physically nonexistent, non- descript company, having no expertise of software development. T .....

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any connivance between the appellant and Shri Tarun Goyal, its claim of depreciation should not be disallowed. I have perused the cited case law. In that case, the assessee had entered into a transaction of purchase and lease out of GAS CYLINDERS through a broker. All the documentations were received by her according to which she had purchased the gas cylinders from one Modern Engineering and leased the same to one Seers Leasing Company. Payment for purchase of the gas cylinders were made throu .....

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e owner of the Gas cylinders supposed to have been purchased by her from Modern. The AO disallowed depreciation on the gas cylinders and also made addition of ₹ 13,70,000/- as income from undisclosed sources in the hands of the assessee. The disallowance of depreciation was upheld ip further appeal. However, when the AO imposed penalty for concealment on the same issue, his order was assailed in appeal. The CIT(A) decided the penalty appeal in favour of the assessee on the ground that she! .....

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s concerned, the depreciation claimed on non-existent gas cylinders was disallowed which was also upheld in appeal. Therefore, to that extent the cited case is in favour of the AO and not in favour of the appellant. Secondly, the issues of assessment and issues of penalty are clearly distinguishable. Further, in the cited case, the assesses might have got cheated because she never physically saw the goods she was purchasing or leasing out, whereas in the instant case, the appellant has claimed t .....

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t work itself indicates towards a pre-ordained transaction entered into by the appellant for getting the benefit of depreciation on such non-existent asset. 2.3.6 Taking into consideration the totality of facts and circumstances as discussed above, it is held that the appellant has not been able to establish either the ownership or user of the alleged software on which depreciation of ₹ 84,84,910/- was claimed and accordingly the action of the AO in disallowing the claim of such depreciati .....

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etails of software purchased from Macro Infotech next details d) details of payment made to the supplier of software showing check number, date, amount and of the SSC reflecting these payments made to the supplier for purchase of software e) Details of payment of tedious on payment made to supplier. 20. Now we proceed to examine each of this evidence furnished by the assessee. Looking at the Ledger of the company of computer printers & software‟ as on 01/04/2007 it has block of this it .....

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, single sport disc/tape, multi segment tapes timing/transfer management software, video fileserver, VTR , Sony protocol, venous router, switches etc. This software was purchased for 19 users. Undoubtedly it shows spend number, CST number, UATT number of the supplier. 22. The 2nd software was purchased by assessee by invoice No. 2 dated 16/07/2007 ₹ 75 lakhs/-, the narration of the software purchases web-based managed to monitoring computer software for assignment in his display of analog .....

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e software is OpenView software with built-in RITE punctuation on Linux platform for building designing architectural construction module Vectastar 3500 print to multilevel radio platform. Cost of this software is ₹ 85, 50, 000. 25. The 5th software was purchased by invoice No. 5 dated 08/08/2007 for 19 users at the rate of ₹ 3,50,000/- per user amounting to ₹ 66, 50, 000/-. The nomenclature of the software is Open View software with built-in rite fluctuation on Linux platform .....

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at company has purchased six huge software however there is no expenditure on hardware by the company. Therefore how these softwares are installed and how they were used is not demonstrated by the assessee. 28. The details of payments made to this party are as under. Cheque no Date Amount Date of clearance 701067 24/08/2007 9595000 27/08/2007 701069 26/08/2007 4242000 27/08/2007 701072 26/08/2007 7575000 27/08/2007 701078 28/08/2007 8635500 30/08/2007 701079 29/08/2007 6716500 30/08/2007 701080 .....

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know that no such companies was running from that address Therefore AO was of the view that this supplier is non-existent and also the software purchased by the asssessee is fictitious. Before CIT (A) assessee was asked to prove the existence of software which was denied by the assessee. 31. For the purposes of the claim of the depreciation u/s 32 of the act the assessee is required to establish following with reference to evidences a. There is a specified assets b. Such assets is partly or ful .....

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he address provided by the assessee of the supplier is fictitious and assessee could not demonstrate capability of the supplier. b) Further contention of the assessee that the payments are made by cheque does not prove anything about the existence of the asset. It can never be said that transactions made by the cheque are sacrosanct , particularly in the facts of this case. Payments by chaeque are the mode of settlement of the account between the parties. c) It was submitted that these softwares .....

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ar no such hardware have been purchased. Only addition to the computer is ₹ 4,30,53,004/- which consist of the above software of ₹ 4.25 Crores. Therefore the fact of installing the software in the office of the company is not proved by the assessee. d) Further assessee has purchased the huge software however the assessee could not establish that the software do exits by producing the existence of any source code‟, utility report, Request for proposal etc. e) Whenever such softw .....

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sessee shows that the parties to that agreement have entered in to a joint development agreement and in cancellation agreement the assessee is shown as confirming party . Therefore it is apparent that the assessee is just a confirming party in this cancellation agreement where in it is stated that software is destroyed and no compensation is payable which is waived by party of the first part which is not the assessee but the 7 other persons who are different companies and individuals. It is ment .....

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ftware as are purchased by the assessee but it talks about the software presentations. Hence assessee has failed to provide any evidence that it has such software were given to Sobha Developers. i) These facts are also coupled with the unusual facts of the case that all these software were purchased by the assessee in a single month and for which payments have also been made immediately. It is also an unusual fact that the date of installation of all the software purchased is shown as 02.10.2008 .....

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as per schedule 6 of the balance sheet. It could also not establish that what are the uses of these software purchased by the assessee and what are the functionality of such software. 33. Assessee could not prove the facts that assessee has used these software in the business of the assessee except merely stating that These softwares were installed in the company and all the purchases were duly incorporated in the books of account of the company. Merely such a bald statement coupled with evidenc .....

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