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Deputy Commissioner of Income-Tax Versus Sindhu Realtors Pvt. Ltd. and Vice Versa

2016 (5) TMI 58 - ITAT DELHI

Deemed dividend u/s 2(22) - Loan / Advances received from public company cum NBFC - Held that:- The assessee before the Assessing Officer and the learned Commissioner of Income-tax (Appeals) has submitted that both these companies are public limited companies and they have produced evidences to substantiate that the STLL is a listed company at the Delhi Stock Exchange and Jaipur Stock Exchange and also the shareholding pattern as on March 31, 2008. And that section 2(22)(e) is not applicable to .....

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he deeming provision can be literally interpreted. Nothing can be added or implied while interpreting a deeming provision. One can only look at the language used. Therefore, we concur with the learned Commissioner of Income-tax (Appeals) that the lender company, i.e., M/s. STLL is a public limited company and so the loan/advance/ICD given to the assessee does not fall in the ken of section 2(22)(e) and moreover, the lender company is a NBFC which is also excluded from the said deeming provision, .....

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authorities below. The Assessing Officer erred in concluding that since the assessee-company is incurring interest expenditure so no surplus fund is available to the assessee-company is erroneous on the fact that the total shareholder fund without interest burden is to the tune of ₹ 34.46 crores and, therefore, thus we have no hesitation to delete the disallowance. See East India Pharmaceutical Works Ltd. v. CIT [1997 (3) TMI 5 - SUPREME Court ] - Decided in favour of assessee. - I. T. A. .....

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ing I. T. A. No. 2768/Del/2012. 3. The solitary ground taken by the Revenue is against the deletion of addition of ₹ 1,03,12,934 made by the Assessing Officer under section 2(22)(e) of the Income-tax Act, 1961 (hereinafter "the Act"). 4. The assessee is engaged in the business of civil construction. During the year under consideration, the return of income declaring total income of ₹ 35,26,578 was filed on September 30, 2008. The case was processed under section 143(1) of t .....

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7; 1,03,12,934 under section 2(22)(e) of the Act, which is the dispute in the present appeal. The facts relating to this issue are as follows. 6. The Assessing Officer vide show-cause notice dated December 9, 2010, asked the assessee to explain as to why loan of ₹ 1,03,12,934 taken from M/s. Sindhu Trade Links Ltd. (hereinafter "STLL") be not treated as deemed dividend in view of the facts that directors of the assessee- company are substantially interested in the said companies .....

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Delhi stock exchange and Jaipur stock exchange. Proof of being listed is enclosed herewith. Section 2(22)(e) of the Income-tax Act, 1961, is applicable only in respect of closely held companies. (iii) M/s. Sindhu Realtor Pvt. Ltd. is not holding more than 10 per cent. shares in M/s. STLL. (copy of shareholding of M/s. Sindhu Trade Links Ltd. is enclosed herewith). Hence section 2(22)(e) of the Income-tax Act, 1961, is not applicable. (iv) There is no single shareholder holding more than 10 per .....

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pany and is in the category of NBFC, the Assessing Officer observed that it has no merit on the issue because of the following reasons : (i) "Sindhu Trade Links Ltd." (STLL) is a limited company only because its paid-up share capital base is more than ₹ 5 crores but it is not a widely held public limited company in which the public are substantially interested, as envisaged in section 2(22)(e) of the Income-tax Act, 1961. Provisions of section 2(22)(e) of the Act is being reprodu .....

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s) holding not less than ten per cent. of the voting power, or to any concern in which such shareholder is a member or a partner and in which he has a substantial interest (hereafter in this clause referred to as the said concern) or any payment by any such company on behalf, or for the individual benefit, of any such shareholder, to the extent to which the company in either case possesses accumulated profits ; (ii) Although the STLL has claimed that the equity shares of the company is listed on .....

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deposit as on date and will not accept the same in future without the prior approval of the Reserve Bank of India in writing. (iv) The authorised representative vide letter dated December 13, 2010, has furnished shareholding pattern of STLL as on March 31, 2008. It is seen from there that though the authorised representative submitted that the STLL is a public limited company, but has failed to substantiate that it is a public limited company in which public are substantially interested. As per .....

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ds the assertion of the authorised representative that the company STLL is a public limited company, it is being demonstrated here with that this is not "a company in which public are substantially interested" because- This is a company in which shares have not been traded by the public at large ; a. Although the authorised representative has claimed that the STLL is a listed company at Delhi Stock Exchange and Jaipur Stock Exchange but once again it may be pointed out here against the .....

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uantity of shares were held by Mr. Sindhu and his family members/associates. 8. The Assessing Officer observed that out of five directors, Sindhu and his family members themselves control nearly 59 per cent. shareholdings of the STLL and in this situation, it could not be accepted that the STLL was a public company where public was substantially interested. He further observed that the percentage of shares of other directors and their family members would again go on to prove that it was not a c .....

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y interested and the onus was also on the assessee-company that the shares of the STLL were widely traded and its shares were available in the open market for purchase and sale by any common man/person and held that the assessee failed to discharge its onus and the Assessing Officer countered the submissions of the assessee that the STLL was an NBFC and therefore the deeming provision of section 2(22)(e) would not be applicable by giving the following reasons : "The Income-tax Act provides .....

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iate that the transactions by the STLL in the form of advances or loans were 'in the ordinary course of its business'. The onus was cast on the assessee-company to substantiate that the loans and advances received by it from the group company or associates company (STLL), in which common directors are beneficial shareholders, were in the ordinary course of business, i.e., advancing of loans and advances on interest of the payer company. Same is the case of PHDL. The assessee has failed t .....

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ned Commissioner of Income-tax (Appeals) who deleted the addition by observing as under : "Ground Nos. 4, 5, 6 and 7 : Addition of ₹ 1.03 crores under section 2(22)(e) of the Income-tax Act, 1961, being inter corporate deposit received from company holding NBFC certificate. The Assessing Officer made the above addition on account of loans received from two companies, holding them to be associated companies as well as companies in which public are not substantially interested. The Asse .....

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r since the material issue is whether section 2(22)(e) of the Act is applicable in this case. b. The appellant has submitted extensive arguments on this issue. Again, the crucial issue is found to be whether the lender companies are ones in which the public are substantially interested. Section 2(22)(e) : Not applicable to widely held companies : Section 2(22)(e) uses the words : any payment by a company 'not being a company in which the public are substantially interested' meaning there .....

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shares in the company (not being shares entitled to a fixed rate of dividend whether with or without a further right to participate in profits) were, as on the last day of the relevant previous year, listed in a recognised stock exchange in India in accordance with the Securities Contracts (Regulation) Act, 1956 (42 of 1956), and any rules made thereunder ;' It was vehemently argued that these conditions are fulfilled by the lender companies and hence they are companies in which the public .....

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and Revenue Commissioners [1921] 1 KB 64 at page 71, that : '. . . in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used'. Even while quoting this in the assessment order the Assessing Officer seeks to go beyond the intention of the Act. Especially in deeming provisions, the in .....

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t; 11. The Revenue, being aggrieved, is in appeal before us on the aforesaid issue. 12. The learned Departmental representative relied on the order of the Assessing Officer and submitted that loan of ₹ 1.03 crores taken from M/ s. Sindhu Trade Links Ltd. (STLL) was rightly treated as deemed dividend in view of the facts that directors of the assessee-company are substantially interested in the said company and also some of the shareholders are common in both the companies. He further submi .....

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omoter Mr. Sindhu and his family members and therefore the saving clause (ii) of section 2(22) of the Act would not be applicable and come to the rescue of the assessee- company insofar as invoking section 2(22)(e) was concerned. The learned Departmental representative submitted that the assessee failed to prove the onus that STLL was a widely held public limited company in which the public were substantially interested and that the shares of the STLL were widely traded and its shares were avail .....

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presentative for the assessee reiterated the submissions made before the learned Commissioner of Income-tax (Appeals) and for the sake of clarity, the same are reproduced hereunder : "Ground III-Amount involved is ₹ 1,03,12,934 The appellant-company has received inter corporate deposits of ₹ 1.03 crores from M/s. Sindhu Trade Links Ltd. (STLL) during the year under assessment. The appellant-company was show-caused vide notice dated December 9, 2010, during the course of assessme .....

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ated December 13, 2010 (copy enclosed) that STLL is a NBFC certificate holding company and also stock exchange listed company. Proof of being NBFC and listed companies was submitted during the course of assessment proceedings. It was also pleaded while submitting the shareholding charts of STLL that the appellant-company is not holding shares exceeding 10 per cent. of M/s. Sindhu Trade Links Ltd.'s total shareholding. Also none of the shareholder holding more than 10 per cent. in STLL is hol .....

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ly interested, of any sum (whether as represent ing a part of the assets of the company or otherwise) made after the 31st day of May, 1987, by way of advance or loan to a shareholder, being a person who is the beneficial owner of shares (not being shares entitled to a fixed rate of dividend whether with or without a right to participate in profits) holding not less than ten per cent. of the voting power, or to any concern in which such shareholder is a member or a partner and in which he has a s .....

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pany ; The assessee-company submitted the interpretation of the section point-wise vis-a-vis observation of the learned Assessing Officer as follows : 1. Section 2(22)(e) : Shareholding conditions not applicable Section 2(22)(e) of the Income-tax Act, 1961, is attracted when a shareholder having shares not less than 10 per cent. receive any advance or loan from such company or any concern receive any advance or loan from such company in which a shareholder holding more than 10 per cent., also ho .....

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in these companies, who is further holding 20 per cent. in the assessee-company. Hence section 2(22)(e) of the Income-tax Act, 1961, is not applicable since shareholding condition, mandatory for applicability of section 2(22)(e) of the Income-tax Act, 1961, are not satisfied. Section 2(22)(e) applicable in the hands of shareholder : Neither the appellant-company is shareholder in these companies nor there is a shareholder holding 10 per cent. in these companies, is holding 20 per cent. in the ap .....

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antially interested'-A company is said to be a company in which the public are substantially interested- (b) if it is a company which is not a private company as defined in the Companies Act, 1956 (1 of 1956), and the conditions specified either in item (A) or in item (B) are fulfilled, namely :- (A) shares in the company (not being shares entitled to a fixed rate of dividend whether with or without a further right to participate in profits) were, as on the last day of the relevant previous .....

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as on March 31, 2008, of the assessee- company. Stand taken by the learned Assessing Officer : a. The learned Assessing Officer has observed on page 10-paras (ii) and (iii) that for STLL, in the director's report, it has been stated that shares were not traded during the year and also further stated that company has not accepted the public deposits. b. The learned Assessing Officer observed at page 11 that STLL has claimed that it is a listed company but no evidence has been provided regard .....

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ompany replied to the observations made by the learned Assessing Officer point-wise : a. Trading of shares and acceptance of public deposit are no parameters to check whether a company is a widely held company or not. It is section 2(18) definition which should prevail while assessing whether a company is a company, in which public is substantially interested or not. b. The allegation of the learned Assessing Officer that the appellant- company has failed to evidence that STLL and PHDL continues .....

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the annual listing fee bills. Further as per information available in public domain on Delhi Stock Exchange website at http://www.dseindia.org.in/sitepages/list companies.php it can be seen that STLL is a listed company on Delhi Stock Exchange. Since the list involve 2830 companies, the assessee- company submitted the relevant extract showing evidence in regard to STLL only. Further submitted that there was no adverse material on record or brought on record by the learned Assessing Officer to s .....

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Consultancy Services Ltd., Reliance Ltd. as on March 31, 2008 have been placed on record. The same is available in public domain on the websites of NSE and BSE. The assessee-company submitted that from the shareholding pattern of these companies, it can be seen that promoter shareholding for these companies is much more that what is for the assessee- company. Somewhere it is hovering around 88 per cent. Still they are regarded as listed and widely held companies. So the same parameter shall be .....

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kind of securities issued by a company was offered to the public for subscription through advertisement in newspapers for a period not less than two days and that applications received in pursuance of such offer were allotted subject to the following conditions : (a) minimum 20 lakhs securities (excluding reservations, firm allotment and promoters contribution) was offered to the public ; Provided that if a company does not fulfil the conditions, it shall offer at least 25 per cent. of each clas .....

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) of the Income-tax Act, 1961, are not applicable to inter corporate deposits. They are applicable to payments by way of advance or loans only. Reliance in this regard has been placed on Bombay Oil Industries Ltd. v. Deputy CIT [2009] 28 SOT 383 (Mumbai) (copy placed on record) wherein the hon'ble Income-tax Appellate Tribunal, Mumbai, has held that since there is a clear distinction between the words advance or loan and inter corporate deposits and hence deeming provisions of section 2(22)( .....

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ompany is not a shareholder in the STLL, further note that the STLL is a non- banking finance company and registered with the Reserve Bank of India since 1998 in category of loan investment company and engaged in activities of shares sale, financial activities, loan syndication activities and hypothecation activities. Proof of being NBFC companies was submitted during the course of assessment proceedings vide letter dated December 13, 2010. Further the profit and loss account of the STLL as on M .....

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corporate deposit has also been advanced in the ordinary course of activities." 14. We have heard both sides and perused the material on record. The only dispute is whether the lender companies which has made deposits (inter corporate deposits (ICD)) will fall under the deeming provision under section 2(22)(e) of the Act or not. We find that section 2(22)(e) excludes public company "not being a company in which the public are substantially interested". Section 2(18) of the Act def .....

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ipate in profits) were, as on the last day of the relevant previous year, listed in a recognised stock exchange in India in accordance with the Securities Contracts (Regulation) Act, 1956 (42 of 1956), and any rules made thereunder." 15. We find that the assessee before the Assessing Officer and the learned Commissioner of Income-tax (Appeals) has submitted that both these companies are public limited companies and they have produced evidences to substantiate that the STLL is a listed compa .....

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activities. It is a well-settled principle of law that deeming provision has to be interpreted strictly and it cannot be stretched to more than that for which the deeming provision can be literally interpreted. Nothing can be added or implied while interpreting a deeming provision. One can only look at the language used. Therefore, we concur with the learned Commissioner of Income-tax (Appeals) that the lender company, i.e., M/s. STLL is a public limited company and so the loan/advance/ICD given .....

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assessee is against confirming the disallowance of total interest debited to profit and loss account of ₹ 16,15,903 in view of the fact that the assessee has given share application money of ₹ 9.86 crores which is not earning any interest income and the assessee has no surplus funds without appreciating that the assessee-company is available with interest-free shareholder funds of ₹ 34.46 crores. 18. The Assessing Officer observed that as per the Schedule "E" of the .....

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on-allotment of such shares why not an appropriate rate of interest be charged thereupon in view of the facts that it is bearing an interest burden of ₹ 16,15,903 apart from bank charges of ₹ 47,906. He further observed that the assessee had made a veiled attempt to show that it was not bearing any interest burden due to amount paid as share application money. After observing the assessee's contention and the details furnished, the Assessing Officer found that the assessee had gi .....

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BFC company it could not be said that it had advanced this much huge amount in the ordinary course of business. He further opined that the assessee was in the business of civil construction where money was very much required and further, the assessee had not proved that the money which it advanced in the form of/in the garb of share application money were actually allotted to the assessee. He held that the assessee had failed to substantiate as to whether the money advanced in the garb of share .....

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the various hon'ble courts, interest could be disallowed from the profit and loss account to the extent of quantum of fund diverted by the assessee to other persons and where no interest was charged or interest was charged at lower rate of interest. Accordingly, the Assessing Officer was of the opinion that interest was disallowable for diversion of fund of ₹ 9,86,87,800 and if the same was calculated at the rate of 18 per cent. per annum that would come to ₹ 1,77,63,804. But, t .....

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w the interest debited to the profit and loss account and made an addition of ₹ 16,15,903 to the income of the assessee. 19. Aggrieved, the assessee went in appeal before the learned Commissioner of Income-tax (Appeals) who confirmed the action of the Assessing Officer on this issue. 20. The learned authorised representative reiterated the submissions made before the learned Commissioner of Income-tax (Appeals) and the relevant submissions made are reproduced below for the sake of clarity .....

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making investments in other companies. Allegation No. 2 The assessee-company has failed to substantiate as to whether the money advanced in the garb of share application money will give any income to the assessee-company in the ordinary course of business. The assessee-company has not shown any return on income/interest on these amounts. (page 3 of the assessment order). Reply to allegation : The investment are generally made to gain in strategic manner in long term, out of which capital gain wi .....

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ts. Though in the case of appellant-company, no allotment was made but this is purely normal. Even in the case of IPDs, people do get back their money back due to non-allotment of shares. Also there is no binding provision in SEBI or Companies Acts for non-listed companies to pay interest if no share allotment has been made in reasonable time. Merely the fact that no income has accrued, is that mean that transaction was for non-business purposes ? Hence the allegations of learned AD are purely b .....

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that the appellant-company has sufficient free funds and it is free to use them at his own discretion according to needs. It is not open to the learned Assessing Officer to assess what the need of the appellant-company is ? It is a decision which is normally entrusted by the shareholders of the company to its faithful management who take the decisions depending upon the financial needs, aspirations, goals or objects set for the company. Nobody can dictate terms to a appellant as to how to condu .....

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y was available with more than sufficient free funds for use at its own discretion. Reliance is placed on CIT v. Hotel Savera [1999] 239 ITR 795 (Mad), wherein the hon'ble Madras High Court has held that once it is established that the assessee-company is having sufficient free funds, presumption would always be made that advances to third parties have been made out of own free funds. Further the assessee-company submitted that where there are both borrowed funds as also interest-free funds, .....

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., I. T. A. No. 1398 of 2008 (Mumbai High Court) pronounced on January 9, 2009 [2009] 313 ITR 340 (Bom). (Copy of judgment placed on record). Hence the assessee-company pleaded disallowance made of interest shall be deleted since the appellant-company has utilised borrowed money for the purposes of earning income and interest-free funds of ₹ 34.46 crores means they are in abundance considering the amount of share application money of ₹ 9,86,87,800 paid by the appellant- company." .....

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assessee-company has given advance/share application money of ₹ 9.86 crores which is not yielding any interest income and made a finding also that the assessee- company has no surplus fund since it has also borrowed funds which is bearing an interest burden of ₹ 16,15,903 apart from bank charges of ₹ 47,906. So, according to the Assessing Officer, since share certificates have not been allotted to the assessee-company, the money has been advanced in the garb of share applicati .....

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fact that the assessee had taken interest bearing loans shows that the assessee does not have any surplus funds. During the appellate proceedings, the assessee's claim that it had sufficient surplus fund which is to the tune of ₹ 34.46 crores and the amount of share application money/advances paid is only ₹ 9.86 crores that works out to 28.63 per cent. of the total shareholder funds has not been taken into consideration by the learned Commissioner of Income-tax (Appeals) who has .....

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learned authorised representative took our attention to the following facts which are revealed by perusal of balance-sheet as on March 31, 2008, which is as below : Following is the shareholders fund position of the appellant-company as on March 31, 2008 : (Rs.) Paid-up share capital 2,62,00,000 Share premium 2,34,00,000 Profit and loss account 62,84,839 Share application money 28,88,00,000 Total shareholder fund available without interest burden 34,46,84,839 24. A perusal of the above reveals .....

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the case of CIT v. Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom), wherein the judgment of the hon'ble Supreme Court in the case of East India Pharmaceutical Works Ltd. v. CIT [1997] 224 ITR 627 (SC) and the hon'ble Calcutta High Court in Woolcombers of India Ltd. v. CIT [1982] 134 ITR 219 (Cal) relied on, held as under (page 344 of 313 ITR) : "16. If there be interest-free funds available to an assessee sufficient to meet its investments and at the same time the assess .....

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f the profits of the relevant year and not out of the overdraft account for the running of the business and in these circumstances the appellant was entitled to claim the deductions. The Supreme Court noted that the argument had considerable force, but considering the fact that the contention had not been advanced earlier it did not require to be answered. It then noted that in Wool comber's case (supra) the Calcutta High Court had come to the conclusion that the profits were sufficient to m .....

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