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2016 (5) TMI 107

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..... lease line charges should not be reduced from the export turnover of the assessee while computing the deduction u/s.10A of the Act. Exclusion of leased line charges from the export turnover and the total turnover both for computing the deduction u/s.10A - Held that:- CIT(A) following the decision of the Hon’ble Bombay High Court in the case of CIT Vs. Gemplus Jewellery India Ltd. reported in [2010 (6) TMI 65 - BOMBAY HIGH COURT ] directed the AO to exclude the lease line charges from the export turnover and the total turnover both for computing deduction u/s.10A. We do not find any infirmity in the order of the CIT(A) who has followed the decision of the Hon’ble Bombay High Court while directing the AO to exclude the lease line charges from the export turnover and the total turnover for computing deduction u/s.10A of the Act. MAT - deduction of reversal of provisions made for employees stock option plan while computing book profit under section 115JB disallowed - Held that:- We find merit in the submission of the Ld. Counsel for the assessee that whether the same has been added under clause (f) or as per clause (c) to Explanation 1 of section 115JB, there will be no differe .....

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..... - ITA Nos.17 and 18/PN/2014, ITA Nos.902/PN/12 and 796/PN/13, ITA Nos.978/PN/12 and 776/PN/13 - - - Dated:- 21-3-2016 - SHRI R.K. PANDA, AM AND SHRI VIKAS AWASTHY, JM For The Assessee : Shri Farrokh Irani For The Revenue : Shri S.B. Morey ORDER PER R.K. PANDA, AM : ITA No.902/PN/2012 filed by the assessee and ITA No.978/PN/2012 filed by the Revenue are cross appeals and are directed against order dated 17-11-2011 of the CIT(A)-I, Pune relating to Assessment Year 2007-08. ITA No.796/PN/2013 filed by the assessee and ITA No.776/PN/2013 filed by the Revenue are cross appeals and are directed against the order dated 11-01-2013 of the CIT(A)-I, Pune relating to Assessment Year 2008-09. ITA Nos. 17 and 18/PN/2014 filed by the assessee are directed against the separate orders dated 30-09-2013 of the CIT(A)-I, Pune relating to Assessment Year 2009-10. For the sake of convenience all these appeals were heard together and are being disposed of by this common order. ITA No.902/PN/2012 (By Assessee) (A.Y. 2007-08) : 2. Grounds of appeal No.1 and 1.1 by the assessee read as under : Ground 1 : Set off of brought forward business loss and unabsorbed de .....

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..... rities also requires the assessee to compute the income before set off of losses. It was accordingly argued that losses and unabsorbed depreciation of ₹ 143,335,955/- brought forward by the assessee company from A.Y. 2005-06 has correctly been set off against the residual income of the company after claiming deduction u/s.10A of the Act. 6. However, the AO was not satisfied with the explanation given by the assessee. According to him, section 10A has to be allowed from the total income. The total income is determined after taking into the provisions of section 28 to 44D of the Act which includes section 32(2). Impliedly, the effect to section 32(2) has to be given before arriving at net profit and gains as per business and profession. The AO further held that for computing the total income, the effect to provisions of section 72 has to be given and what remains finally is the total income of eligible business which will be allowed as exemption u/s.10A of the Act. Therefore, the contention of the assessee that the losses deserves to be carried forward is misplaced. Relying on the decision of Hon ble Karnataka High Court in the case of Himatasingika Seide Ltd. reported in 28 .....

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..... , brought forward unabsorbed depredation and losses of ₹ 14,33,35,955 is to be first set off. The Assessing Officer also held that the interest income of ₹ 3,31,827 included in the profit of eligible business is required to be taken off for computing the deductions. In other words, the Assessing Officer computed the profit from the eligible business available for computation of deduction u/s 10A at ₹ 98,99,16,361. After considering the exclusion of receipts relating to leased line charges for software development services from the ambit of export turnover, the Assessing Officer computed the deduction u/s 10A at ₹ 98,54,88,881 and the excess deduction was computed at ₹ 14,47,63,434. It has been further submitted during the course of the appeal filed for the assessment year that the above assessment order has been rectified by the Assessing Officer vide order u/s 154 dated 13.1.2011, and now the adjustment or total income chargeable to tax has been reduced to ₹ 17,59,308. The appellant has made an elaborate submission vide their letter dated 15.11.2011 and has also relied on different judgments to claim that the deduction computed by it u/s 10A is .....

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..... of the assessee. Therefore, the original sec. 10A was fitting into the concept of Chapter III. After amendment w.e.f. 1.4.2001 the income of the eligible unit is to be allowed as deduction and therefore, the income of the eligible business has to form part of the gross total income. The legislature, even after amendment has retained this provision in Chapter III and therefore, it would be incorrect to hold that the meaning to the words total income cannot be given as is available in sec. 2(15) of the I.T. Act. The claim of the appellant in this respect is farfetched. Similarly, the Assessing Officer has very correctly stated that the deduction is to be computed out of the income of the eligible business which can only be computed after applying sec. 28 to 44D including sec. 32(2). It is important in this respect to point out that before effect to section 32(2) is given effect to section 72(2) has to be given. The appellant also claims the same. Hence both the unabsorbed depreciation and loss will have to be considered. Furthermore, the deduction is to be given on the income of the eligible business and not to the business as a whole and therefore, it will be incorrect to say tha .....

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..... oordinate Bench of the Tribunal in various decisions. He accordingly submitted that the grounds raised by the assessee should be allowed. 10. The Ld. Departmental Representative on the other hand heavily relied on the order of the CIT(A). 11. We have considered the rival arguments made by both the sides, perused the orders of the AO and CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the only issue to be decided in the instant case is as to whether the claim of deduction u/s.10A is to be allowed before set off of brought forward unabsorbed business loss and depreciation or after set off of brought forward business loss and depreciation. We find the issue has been thoroughly discussed by the Tribunal in the case of M/s. Vishay Components India Pvt. Ltd. (Supra) and it has been held that deduction u/s.10B of the Act has to be computed in the hands of the assessee before adjusting brought forward unabsorbed business loss/depreciation. We find following the above decision the Tribunal in the case of Precision Camshafts Ltd. (Supra) has held that deduction u/s.10B of the Act would be allowed to the a .....

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..... o 1990-91 i.e. the years where the benefit under section 10B of the Act was for being exempt from total income. However, the year under appeal before us is assessment year 2005-06, wherein the said section has been amended and the deduction now is allowable to the assessee as against the said income being exempt in the earlier years. The issue is settled by the Hon ble Bombay High Court in CIT Vs. Black Veatch Consulting Pvt. Ltd. (2012) 348 ITR 72 (Bom), wherein it was held as under:- The deduction under s. 10A, has to be given effect to at the stage of computing the profits and gains of business. This is anterior to the application of the provisions of s.72 which deals with the carry forward and set off of business losses. A distinction has been made by the Legislature while incorporating the provisions of Chapter VI-A. Section 80A(1) stipulates that in computing the total income of an assessee, there shall be allowed from his gross total income, in accordance with and subject to the provisions of the Chapter, the deductions specified in ss.80C to 80U. S.80B(5) defines for the purpose of Chapter VI-A gross total income to mean the total income computed in accordance with .....

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..... e hands of assessee and the same was whether the brought forward losses had to be adjusted before computing deduction under section 10A of the Act. It may be pointed out that the provisions of section 10A and 10B of the Act are at parametria. Following the ratio laid down by the Hon ble Bombay High Court, we hold that the deduction under section 10B of the Act is to be computed in the hands of the assessee before adjusting brought forward unabsorbed losses / depreciation. The ground of appeal No.3 raised by the assessee is thus, allowed. 6. The said ratio laid down by the Tribunal was later applied while deciding similar issue in Precision Camshafts Limited Vs. ACIT (supra). The Tribunal vide order dated 10.11.2015 after considering the ratio laid down by the Tribunal in M/s. Vishay Components India Pvt. Ltd. Vs. Addl.CIT Anr. (supra), observed as under:- 17. The Tribunal relying on the ratio laid down by the Hon ble Bombay High Court in CIT Vs. Black Veatch Consulting Pvt. Ltd. (2012) 348 ITR 72 (Bom) and other decisions of the Hon ble Bombay High Court, held that the deduction under section 10B of the Act was to be computed before adjusting brought forward unabsorbed .....

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..... n by the Tribunal in M/s. Vishay Components India Pvt. Ltd., Vs. Addl.CIT (supra) and Precision Camshafts Limited Vs. ACIT (supra), we hold that the assessee is entitled to the claim of deduction under section 10A of the Act before setting up of brought forward losses and unabsorbed depreciation. The deduction under section 10A of the Act is first allowed against the eligible profits and in case there are certain left over profits for the year under appeal, then the same are to be adjusted against the brought forward losses and unabsorbed depreciation / loss as claimed by the assessee in return of income. Accordingly, we direct the Assessing Officer to re -compute the deduction under section 10A of the Act. The grounds of appeal Nos.1 and 7 raised by the assessee are thus, allowed and balance grounds of appeal raised by the assessee are dismissed being argumentative. 9. In the result, the appeal of the assessee is partly allowed. 12. Respectfully following the decision of the Coordinate Bench of the Tribunal cited (supra) we hold that deduction u/s.10A of the Act is to be allowed against the eligible profits and in case there are certain left over profits for the year under .....

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..... s were also brought to the notice of the AO. However, the AO was not satisfied with the explanation given by the assessee. According to him certain expenses such as freight, telecommunication charges etc. have been specifically excluded from the export turnover under clause (iv) of Explanation 2 to section 10A. If the legislature intent were to effect exclusion of identical amounts from total turnover, then the same would have been specifically provided for/mandated in this section. That is not the case, therefore, doing so would amount to imputing an interpretation to the statutory provisions where such interpretations are not warranted in view of the provisions being unambiguous. Rejecting the various explanations given by the assessee and distinguishing the various decisions, the AO held that the expenses incurred for telecommunication charges of ₹ 53,79,131/- attributable to the delivery of the computer software outside India is not to be included in the export turnover eligible for computation of exemption u/s.10A of the Act. 17. In appeal the Ld.CIT(A) upheld the action of the AO by observing as under : 4.3. I have carefully considered the facts of the case and t .....

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..... 0A. However the expression 'export turnover' has been defined. The definition of export turnover excludes freight and insurance. Since export turnover has been defined by the Parliament and there is a specific exclusion of freight and insurance, the expression 'export turnover' cannot have a different meaning when it forms a constituent part of the total turnover for the purpose of the application of the formula. Undoubtedly, it was open to Parliament to make a provision to the contrary. However, no such provision having been made, the principle which has been enunciated earlier must prevail as a matter of correct statutory interpretation. Any other interpretation would lead to an absurdity. If the contention of the revenue were to be accepted, the same expression viz. 'export turnover' would have a different connotation in the application of the same formula. The submission of the revenue would lead to a situation where freight and insurance, though it has been specifically excluded from export turnover for the purpose of the numerator would be brought in as part of the export turnover when it forms an element of the total turnover as a denominator in the f .....

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..... e foreign exchanges while computing the export turnover. Referring to the decision of the Mumbai Bench of the Tribunal in the case of Wills Processing Services India Pvt. Ltd. Vs. DCIT reported in 151 TTJ 555 he submitted that the Tribunal in the said decision has held that satellite charges are not telecommunication charges to be excluded from the export turnover for purpose of computing deduction u/s.10A. 21. The Ld. Departmental Representative on the other hand heavily relied on the order of the CIT(A). Referring to the bills raised by Amdocs he submitted that the telecommunication charges are embedded in it, therefore, in view of the definition of export turnover as per clause (iv) of Explanation 2 to section 10A telecommunication charges should be excluded from the export turnover. He accordingly submitted that the CIT(A) is justified. 22. As regards the contention of the assessee that the telecommunication charges are not embedded or not recovered he submitted that it was never brought to the notice of the AO or the CIT(A) that telecommunication charges are not embedded in the bills and are not recovered from the customers. 23. The Ld. Counsel for the assessee in his .....

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..... e course of assessment proceedings before the AO vide letter dated 31-08-2010 at Para 4.1.5 and 4.1.6 has stated as under : 4.1.5 In the process of computation of export turnover, the starting point to be considered is sale consideration received. Only if the sale consideration includes telecommunication charges, i.e. if the charges are recovered from the purchaser, they have to be excluded from the export turnover. But where the sale consideration is a single consolidated amount it should not be split into individual components and to exclude some of them for the purpose of section 10A of the Act. 4.1.6 The rationale behind the said proposition, as upheld by various courts, is what is included in the invoice value can only be excluded . In this regard, your attention is invited to the decision of the Honourable Hyderabad Tribunal in the case of Patni Telecom (P) Limited Vs. ITO (22 SOT 26) (Hyd), wherein it has been held that telecommunication charges cannot be reduced from the export turnover if export turnover does not specifically include recovery on account of telecommunication expenses. Relevant extract from the para 7.2 of the said decision is reproduced below : .....

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..... expenses. If at all on presumption, it is to be excluded for the purpose of 'export turnover' then on the same assumption, reason and analogy it should be excluded from 'total turnover'. The simple reason is that such expenditure is also included in consolidated consideration which is forming part of total turnover . In order to make the formula for the purpose of 'export turnover' in s. 10A workable one has to give a schematic interpretation to the formula. Elimination should be from both the denominator and the numerator. We therefore find that the AO was not correct in excluding ₹ 40,93,493 from consideration received in convertible foreign exchange while calculating export turnover for the purpose of s. 10A of the IT Act. 27. In view of the categorical submission of the assessee before the AO that sale consideration includes telecommunication charges and it is not separately charged to customers and following the decision of the Hyderabad Bench of the Tribunal in the case of Patni Telecom Pvt. Ltd. (Supra) we are of the considered opinion that the lease line charges should not be reduced from the export turnover of the assessee while computin .....

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..... ESOP Cost) : The company has entered into an Equity Award Reimbursement Agreement (Reimbursement Agreement) with its parent company i.e. Amdocs Limited on 1 February 2006 (in respect of shares of the parent company allotted to the employees under an ESOP scheme). As per the agreement, the Company shall pay Amdocs Limited the cost, computed as per the mechanism provided in the reimbursement agreement, in relation to the Options exercised by the employees 1 right in the Restricted Shares vested in the employees. During the year ended 31 March 2007, the Company had made provision in its books of accounts for payments to be made by it to Amdocs Limited in terms of the Reimbursement Agreement, computed with reference to the Fair Market Value ('FMV') of the shares of Amdocs Limited as on 31 March 2007. The Provision had been suo motto offered for taxation under the normal provisions of the Act as well as in the computation of books profits of the Company for the purposes of section 115JB of the Act. However, as on 31 March 2008, there was a significant reduction in the FMV of the shares as compared to the FMV as on 31 March 2007. Accordingly, the Company reversed the p .....

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..... ook profit for the current year, since the assessee company has not added back the ESOP provision in terms of clause (c) of Explanation 2 to section 115JB. 34. Aggrieved with such order of the CIT(A) the assessee is in appeal before us. 35. The Ld. Counsel for the assessee strongly challenged the order of the CIT(A). He submitted that as per ESOP norms the employees have a right to subscribe to the shares at a certain price. The parent company recovers the difference from the Indian company which is the difference between the market price and the option price. The provision was made in this case in A.Y. 2007-08. During this year, the market price has fallen down for which excess provision was credited to the profit and loss account. Referring to Explanation (2) to provisions of section 115JB he submitted that as per Explanation (1) book profit means the net profit as shown in the profit and loss account for the relevant previous year and reduced by the amount withdrawn from any reserves or provision, if any such amount is credited to the profit and loss account. He submitted that assessee fulfils these conditions. He submitted that upto A.Y. 2007-08 there was specific exempti .....

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..... allowed. 38. The Ld. Departmental Representative on the other hand heavily relied on the order of the CIT(A). He submitted that provision was made for meeting the expenses on account of ESOP on 31-03-2007. The provision was revised next year because of decrease in fair market value of shares. Therefore, it was an unascertained liability. Therefore, clause (a) of Explanation 1 to provisions of section 115JB are applicable. Referring to page 83 of the paper book he drew the attention of the Bench to the computation of income u/s.115JB of the Act which results into loss, therefore, whole exercise shows a negative income for which the purpose of the scheme is defeated. He accordingly submitted that the CIT(A) was fully justified in rejecting the claim of the assessee. 39. The Ld. Counsel for the assessee in his rejoinder submitted that the quarrel between the assessee and the department is under which clause the amount has to be added. According to the assessee it is as per clause (f) whereas as per the Revenue it is clause (c). Therefore, as per the assessee there is no difference. The result would have been same had the assessee added under clause (c). He accordingly submitted .....

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..... Total (2) = (A) + (B) 290,02,02,097 4 Less: Income to which section 10A applies Clause (ii) to Explanation 1 373,02,71,818 5 Book profits as per section 115JB of the Act (1) +(2) (3) (1,88,09,370) As is evident from the working above, the provision in respect of options granted/allotted to employees under ESOP Scheme had been added back to the book profits for A.Y. 2007-08 under Explanation 1. 40.2 In view of the above clarification/submission by the assessee before the Ld. CIT(A) which is not controverted by the revenue, we find merit in the submission of the Ld. Counsel for the assessee that whether the same has been added under clause (f) or as per clause (c) to Explanation 1 of section 115JB, there will be no difference and the result would have been same had the assessee added the ESOP provision under clause (c) instead of clause (f). Since an amount of ₹ 7,67,47,000/- has already been added by the assessee while computing the book profit as per section 115JB of the I. .....

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..... 538/- on lease lined charges from export turnover of the appellant while computing deduction u/s.10A of the Act. 44. After hearing both the sides, we find the above ground is identical to ground of appeal No. 2 in ITA No.902/PN/2012 for A.Y. 2007-08. We have already decided the issue and the grounds raised by the assessee have been allowed. Following the same reasonings the above grounds by the assessee are allowed. ITA No.776/PN/2013 (By Revenue) (A.Y. 2008-09) : 45. Ground of appeal Nos. 1, 6 and 7 being general in nature are dismissed. 46. Ground of appeal Nos. 2 to 4 by the revenue read as under : 2. The Ld.CIT(A) grossly erred in allowing the provision of ₹ 86,14,207/- in respect of lease rent equalization while computing the book profits u/s.115JB. 3. The Ld.CIT(A) grossly erred in failing to appreciate that the provision made of for future liabilities which cannot be said ascertained liabilities and which is not pertains to the year under consideration. 4. The Ld.CIT(A) grossly erred in deciding the issue in favour of the assessee on the additional evidences i.e. rental agreement signed by the assessee in respect of lease premises at Cyber C .....

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..... rovision for increase in the monthly rent by 15% of the last paid rent at the end of each three year period. Effectively therefore, the appellant has signed lease agreement for 9 years with a provision for escalation of the rent at the end of every three years. The ARs of the appellant have argued that the appellant has effectively signed rent agreement for 9 years since substantial investments in the lease premises have been incurred by the appellant. The provision made on account of lease is made by apportioning the lease payments due over a period of 9 years (i.e. the lease term) on a straight line basis and taking into account the escalation clause provided in the lease agreement. No doubt creation of the liability provision for lease equalization cannot be said to be an unascertained liability. It, on the contrary, amounts to an ascertained liability, being a reasonable estimate in the context of the above, the Hon'ble Delhi ITAT in Goodwill India Ltd. vs ACIT reported in 306 ITR (AT) 34 While adjudicating on the Explanation to sec. 115JA held as under: As far as asst. yr. 1998-99 is concerned, the question revolves around as to whether the lease equalization have to b .....

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..... AO has never asked for the rent agreements. Referring to the decision of the Delhi Bench of the Tribunal in the case of U.P. Ceramics and Potteries Ltd. Vs. DCIT reported in 52 ITD 334 he drew the attention of the Bench to the following observation of the Tribunal. In the present case, Assessing Officer did not ask the assessee to furnish certificates/confirmations from the dealers whose turnover was included in the turnover of others. The Assessing Officer also did not make any enquiries of his own from such dealers. The taxpayers are not experts so as to judge the mind of quasi-judicial authority. Sometimes assessee considers some evidence to be sufficient to support its claim. If the Assessing Officer thinks otherwise, nothing prevents him in informing the assessee about the inadequacy of the evidence. An Assessing Officer exercising quasi-judicial authority is not supposed to take advantage of ignorance of the assessees. The job of the Assessing Officer is to make a fair and reasonable assessment and not to fight a ping pong battle of write with the assessees. A fair and reasonable assessment is possible only by giving a fair and reasonable opportunity to the assessee and .....

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..... the lease agreement for 9 years with provision for escalation of rent at the end of every 3 years. The Ld. Departmental Representative neither could point out any infirmity in the order of the CIT(A) appeal nor could controvert the factual findings given by the CIT(A). Accordingly, we do not find any infirmity in the order of the CIT(A) on this issue. Grounds raised by the revenue are accordingly dismissed. 53. As regards the grievance of the revenue that CIT(A) has violated provisions of section 46A by deciding the issue on the basis of additional evidence, i.e. rent agreement, we do not find any merit in the same. From the copy of the assessment order we find the AO has given a finding that provision for rent and maintenance is only in the nature of unascertained liability without going through the clauses of the rent agreement. He has not specifically asked for the copy of the rent agreement. Therefore, when the assessee was not called upon to produce the rent agreement by the AO and since the same was produced before the CIT(A), whose powers are coterminous with that of the AO, for proper adjudication of the matter, therefore, we do not find any merit in the grounds raised .....

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..... (A)'], under section 250 of the Income-tax Act, 1961 ('Act') and based on the facts and circumstances of the case, Amdocs Development Centre India Private Limited [ as a successor of Amdocs Business Services Private Limited [hereinafter referred to as 'Appellant ] respectfully submits that the Honble CIT(A) erred in disposing off the appeal of the Appellant, on the following ground which are without prejudice to each other: Ground 1 : Set off of brought forward business loss and unabsorbed depreciation before allowing deduct ion under Section 10A 1.1 The Hon ble CIT(A) has erred in facts and law in holding that deduction under section 10A of the Act is allowable after set off of brought forward business loss and unabsorbed depreciation. 1.2 The Hon ble CIT(A) erred in facts and law in not allowing set off of brought forward loss from profits / gains from business for the year amounting to ₹ 5,97,306/-. 1.3 The Hon ble CIT(A) erred in facts and law in not allowing carry forward of business loss and unabsorbed depreciation amounting to ₹ 7,24,67,850/-. 59. After hearing both the sides we find the grounds of appeal No.1 and 1.1 by the asse .....

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