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2017 (3) TMI 382 - ITAT MUMBAI

2017 (3) TMI 382 - ITAT MUMBAI - TMI - Income from sale of the scrips - LTCG and STCG or business income - Period of holding - Held that:- We as, independent of the concession allowed by the aforesaid CBDT Circular No. 6/2016 (supra), which as observed by us at length hereinabove would not be available to the assessee as regards the profit/gain on sale of scrips which were held by the assessee for a period of less than 12 months, are however of the considered view that the conduct of the assesse .....

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hat the shares as claimed by the assessee were in the nature of ‘Investments’, and had assessed the loss on the sale of shares under the head ‘Capital gain’ by making a specific mention in the body of the assessment order that the ‘Short term capital loss’ of ₹ 8,35,225/- shown by the assessee on sale of shares shall be C/forward to the succeeding years. We thus in the totality of the aforesaid facts, are thus of the considered view that the conduct of the assessee duly goes to fortify and .....

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matic purchase and sale transactions in shares, and thus was liable to be assessed as ‘business activity’ cannot be sustained and is thus vacated. We in the backdrop of our aforesaid observations are of the considered view that the assessee had rightly reflected the income arising in its hands from sale of shares under the head ‘Capital gain’. - Disallowance u/s 14A - Held that:- We are of the considered view that the CIT(A) had rightly relied on the judgment of the Hon’ble Bombay High Court .....

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been filed by the assessee against the order passed by the CIT(A)-5, Mumbai, dated 18.03.2011, which in itself arises from the assessment order passed under Sec. 143(3) of the Income Tax Act, 1961, (for short Act ), dated 29.12.2009. The assessee had assailed the order of the CIT(A) by raising the following grounds of appeal before us:- CONCISE GROUNDS OF APPEAL 1. The Learned Commissioner of Income-tax erred in confirming the action of A.O in treating Short term capital gains of ₹ 3,51,72 .....

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ent to be arising out of short term and long term capital gains and the A.O for making disallowance u/s. 14A also treated the shares as investments and not stock in trade and hence, the short term and tong term capital gains be accepted as declared by the appellant. 3. The appellant craves leave to add, amend, alter or delete all or any of the aforesaid grounds of appeal . 2. Briefly stated, the facts of the case are that the assessee company which is engaged in the business of rendering innovat .....

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57/- and Long term capital gain (LTCG) of ₹ 7,87,532/- on sale of shares, which was credited as Profit on sale of shares . It was observed by the A.O. that the STCG shown by the assessee in its return of income was in respect of transactions in shares of 13 different scrips, mainly those of M/s. India Bull, Lloyd Electricals, Unichem Laboratories etc., while for the LTCG pertained to purchase and sale of shares of M/s. Prakash Industries. That as per the A.O. the assessee company had durin .....

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order to fortify its claim that the profit/gain from the sale of the shares had rightly been reflected under the head Capital gain , therein inter alia submitted as under:- (i) That Memorandum of association of the assessee company did not authorize carrying of the business of purchase and sale of shares. (ii) That the assessee company which was incorporated to carry on the business of distribution, marketing and publicity of automobile spare parts and accessories, had carried out investment tow .....

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he object of the assessee company in carrying out investments towards purchase of shares was to derive dividend income. (vi) That both the purchase and sale transactions were delivery based and the STT had been added back in the computation of income and no rebate under Sec. 88E was claimed by the assessee. 3. The A.O. however not finding favor with the contentions raised by the assessee, therein refuted the same by observing as under:- (a). Regarding the claim that the transactions resulting in .....

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ssessee in its accounts as investments' or stock in trade', this cannot be decisive to determine the nature of the transaction, As highlighted in Circular No. 4 dated 15.6.2007 of the Board it has been held by the Hon bleSupreme Court in the case of Karamchand Thapar& Bros Pvt. Ltd. (83 ITR 899) that the classification by the assessee of shares as investment or stock in trade is by no means conclusive, Moreover, in the case of State Bank of Hyderabad vs CIT (151 ITR 703) (AP), the in .....

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profit on sale of shares cannot be taxed as business income since the Memorandum of Association of the company does not permit trading in shares, it needs to he emphasized that the head under which income is taxable under the Income Tax Act, 1961, has to be decided with regard to the inherent nature of the transaction vis-à-vis. the head of income specified in the Act. The income Tax Act also defines what is business u/s 2(13) of the Income Tax Act, 1961. Hence, the 'Memorandum' .....

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s own funds instead of relying on the borrowed funds. Though this is an aspect which has a bearing on the question whether the purchase and sale amounts to trading or not, it is by no means the only or crucial factor. What matter is a combination of all the relevant factors. The A.O. thereafter proceeded with and therein concluded that the amount of ₹ 3,51,72,755/- and ₹ 7,87,532/- claimed by the assessee as income under the head STCG and LTCG were liable to be assessed as the normal .....

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in Rule 8D, which though was made available on the statute from 24.03.2008 was to be applied even to the preceding years, thus computed a disallowance of ₹ 78,848/- under Sec. 14A in the hands of the assessee company. The A.O. thus deliberating on the aforesaid issues assessed the income of the assessee company as per the normal provisions at ₹ 3,77,70,750/- and computed the book profits at ₹ 3,69,78,459/- under Sec. 115JB. 5. The assessee being aggrieved with the order of the .....

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has relied requires him to take an overall and holistic view, all that he has really done is to summarily dismiss the following vital facts of our case by expressly suggesting in respect of each one of them that it was not conclusive or decisive. b) A bare reading of our Memorandum, of Association showed that it did not permit us to carry on any business in securities; that all that it did was to permit us to make investments in securities. c) The investments in question were made from our own .....

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nts and not stock-in-trade and that the investments have been consistently shown in the Schedule of investments in the audited Balance Sheet every Year. e) All the transactions of purchase and sale of shares resulting into short term capital gain/ long term capital gains were delivery based transactions. That in respect of every single transaction resulting into the gain, Security Transaction Tax has been paid. The Assessing Officer has failed to appreciate that a company incorporated under the .....

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lude that they amounted to business. f) The appellant had surplus funds. The management of the Appellant decided to make investment with the available funds in various share/ securities to earn and for the appreciation of the capital rather than keep the funds idle. The resolution was passed in the meeting of the Board of Directors held on 27 January, 2003 wherein the Board resolved to acquire and hold shares/securities out of surplus funds to be held as part of the investment portfolio of the c .....

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is lower, whereas 1ong term investments are required to be valued at cost, unless there is a permanent diminution in their value. Similarly, AS-2 on Valuation of Inventories require stock-in-trade to be valued at cost or market price whichever is lower and not at cost. h) Classification of shares/securities by the Appellant as 'investments' has been accepted by the department in the assessment years 2005-06 and 2006-07. The brokerages paid for purchasing the shares were included in the p .....

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the assessees as well as for guidance of the Assessing Officers. Thus the Circular seeks merely to update the instruction and does not replace it. The assessment order shows, the Assessing Officer has gone only by the above Circular and paid no heed to the earlier Instruction. In the peculiar facts and circumstances of the appellants case, the emphasized portion of the instruction quoted below ought to have been considered by him. Attention was invited to instruction No. 1827 dated 31.8.1989. R .....

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inciples/criteria culled out from judicial decisions rendered in the context of the law as it then read, have become redundant, that the decision of the Supreme court in CIT v. H. Holck Larsen (160 ITR 67) where the Supreme Court has upheld the decision of the High Court reversing the decision of the Appellate Tribunal, (even in a case where the assessee investor had borrowed money) provides a very good guide of the kind of approach which must be adopted while deciding the issue as to whether pr .....

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rkets, the real intention of making the investment cannot be overturned and regarded as to trade in securities . 6. That it was further submitted by the assessee before the CIT(A) that it had in the immediately preceding year, viz. A.Y: 2006-07, shown the income from sale of shares under the head Capital gains , which was accepted by the A.O after thorough verification in the assessment framed under Sec. 143(3). It was thus submitted by the assessee that now when the facts and circumstances duri .....

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the inconsistent approach adopted by the A.O, and holding to the contrary while assessing the sale transactions of shares as business transactions during the year, thus on the said count too could not be sustained and was liable to be vacated. The CIT(A) however not being persuaded to subscribe to either of the aforesaid contentions of the assessee, therein observed as under :- 2.3. I have considered the assessment order and the submissions of the appellant. Looking into the nature of the transa .....

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ness income. On this I find that the essence of the CBDT Circular is that transactions have to be examined in their totality before coming to the finding in the matter. For example, the CBDT Circular refers to the volume of the transactions, their magnitude, the ratio between purchase and Sales, the intention and many other such factors. Pitted against these tests, I find that the transactions in the Appellants case being voluminous, numerous, consistently spread over the year, and very signific .....

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few months. This would show the high volume, high magnitude and high frequency of transactions. Further, I find that the transactions were carried out consistently throughout the year. Most significantly, the holding period of the shares transacted are very low as low as even 7 to 22 days in many cases indicating very clearly that the appellant did not want to stay invested in these shares. In this light, when the volume magnitude, frequency and average period of holding are seen together, it i .....

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. v/s Addl. CIT Range 4(2) 41 SOT 200 bears special mention. In this case the share broker tried to pass off his trading transactions in shares after 1.10.2004 as investment in light of the possibility of availing lower tax rate. In this backdrop, in this case, after analyzing all facts, the Hon. ITAT has agreed with the assessment made holding the income as business income. In face of those overwhelming features, the appellants arguments are found to be out of place. As I find, the reference to .....

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e the character of income also becomes clear from the fact that, as pointed out by the Assessing Officer, no STCG or LTCG was claimed prior to A.Y 2005-06, when section 111A came into effect. In this respect, on account of the profile of the transactions indicating Appellant's intention to make profits, I agree with Assessing Officer's observations as given on pages 3 to 8 of the assessment order. Further, in view of the peculiar facts of the appellants case, I find the appellant's c .....

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been assessed in the hands of the assessee under the head Capital gain in the immediately preceding year, viz. A.Y. 2006-07, therefore the A.O in the absence of the facts and circumstances witnessing any change could not take a contrary view, and hold otherwise. The assessee still further to support his contention that the profit/gains on sale of shares was liable to assessed under the head Capital gain , therein submitted that now when the A.O himself while computing the disallowance u/s 14A in .....

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m as being core to the issue, I do not find them unreasonable. However, considering my discussion above, with respect to the main grounds on the issue, I do not find any merit in the additional grounds. Besides, my discussion made in the foregoing pares, I further find that the principles of res-judicata do not apply to income-tax proceedings. In this respect, I particularly observe that the appellant also did not show any STCG/LTCG prior to AY 2005-06, when section 111A came into effect. Furthe .....

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e assessee at the very outset of the hearing of the appeal therein submitted that the authorities below had gravely erred in law and facts of the case in treating the profit/gain arising in the hands of the assessee from the sale of shares which were held as investments, as business profits. The Ld. A.R reiterating the submissions made before the lower authorities, therein tried to drive home and support his contention that the income from the sale of shares had rightly been shown under head LTC .....

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ew our attention to Page 35-38 of his Paper book (for short APB ), wherein the various purchase/sale transaction of scrips carried out by the assessee during the year stands recorded. The Ld. A.R referring to the aforesaid chart therein averred that in the case of purchase/sale of shares reflected under the head STCG the period of holding ranged between 19 days to 242 days, which therein glaringly revealed that the assessee was neither carrying on any business, nor was holding the said shares as .....

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return of income for the immediately preceding years, viz. A.Y. 2006-07 under the head Capital gain , and on the said basis Short term capital loss of ₹ 8,35,225/- was shown, which was accepted by the A.O in the assessment framed under Sec.143(3) for the said preceding year, viz. A.Y. 2006-07, and the carry forward of the said Short term capital loss of ₹ 8,35,225/- was allowed by the A.O. in light of a categorical observation recorded in the body of the said assessment order. Still .....

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ments , and had neither shown nor treated the same as Stock in trade , which fact had been accepted by the department in the assessment framed under Sec. 143(3) of the assessee for A.Y. 2006-07, and the carry forward of the Short term capital loss had been specifically allowed, therefore the department thereafter cannot be allowed to turn around and take a contrary view during the year under consideration, and thus in a whimsical and fanciful manner therein categorize the said scrips as stock in .....

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side by the A.O., who as averred by the Ld. A.R had approached the matter with a prejudiced mind and a predetermined approach, and as such cannot be sustained. 9. The Ld. A.R further relied on the Circular No. 6/2016, dated 29.02.2016, issued by the Central Board of Direct Taxes (CBDT), and therein submitted that the CBDT referring to its earlier Instruction No. 1827, dated August 31, 1989 and Circular No. 4 of 2007, dated June 15, 2007, had therein observed that though parameters had been laid .....

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e the character of income arising from sale of shares and securities (i.e whether the same is in the nature of capital gain or business income ), read in light of the fact that as major shares/securities transactions takes place in respect of the listed ones, had thus in the backdrop of the said factual position , therein came up with certain modifications, and had laid down some broad guidelines/parameters which shall be taken into account by the A.O. while concluding as to whether the surplus .....

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e assessee. (ii) Where an assessee in respect of listed shares and securities which are held by him for a period of more than 12 months immediately preceding the date of its transfer, therein desires to treat the income arising from the transfer thereof as capital gain , then the same shall not be put to dispute by the A.O., though subject to the condition that once such a stand is taken by the assessee in a particular assessment year, the same shall remain applicable in subsequent assessment ye .....

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he Ld. A.R that the aforesaid CBDT circular No. 6/2016, dated 29.02.2016 had been followed by ITAT, Ahmedabad D bench in the case of Smt. Neelam Shukla Vs. ACIT, Circle 6, Surat (ITA No. 2974/Ahd/2008 A.Y. 2005-06 and ITA No. 132/Ahd/2010 A.Y. 2006-07; dated 11.03.2016) and therein placed on record the copy of the aforesaid order. The Ld. A.R further in support of his aforesaid contention relied on the order of a coordinate bench of the Tribunal, viz. ITAT, Mumbai of H bench, in the case of Mr. .....

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that the profit/gain from the transfer of the shares was liable to assessed in the hands of the assessee company as the latters business income . It was thus submitted by the Ld. D.R that the appeal of the assessee was devoid and bereft of any force and was liable to be dismissed. 10. We have heard the Ld. Authorized Representatives for both the parties, perused the orders of the lower authorities and the material produced before us. We herein advert to the facts as had emerged from the records, .....

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Bulls, Lloyd Electricals, Unichem laboratories and M/s. Prakash Industries, which were reflected as Investments in the books of accounts . We though are not oblivious of the fact that the absence of the enabling clause in the Memorandum of association of the assessee company to carry on the business of purchase and sale of shares would not be decisive for adjudging the color and character of the share transactions carried out by the assessee, viz. short term capital gain/long term capital gain o .....

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in the case of Short term capital gains the average period of holding of the shares by the assessee ranged between 19 to 242 days. It is not the case of the A.O. that the assessee had purchased and sold the shares on daily basis or without taking/giving delivery. That another important aspect which supports the contention of the assessee on the issue under consideration is that the entire investments had been made by the assessee out of its own funds, and no investment towards purchase of share .....

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. The conduct of the assessee which goes to support his aforesaid contention can also be gathered from the fact that the STT had been added back in the Computation of income , and no rebate was claimed by the assessee under Sec. 88E. 11. We are further of the considered view that independent of the aforesaid facts which would reasonably justify and therein support the contention of the assessee company that the shares were held by it as Investment , and as such the profit/gain from the purchase .....

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A.O while specifically allowing the carry forward of the Short term Capital Loss of ₹ 8,35,225/-, had observed as under:- Short Term Capital Loss of ₹ 8,35,225/- is allowed to be carry forward . We further find substantial force in the contention of the assessee that if the aforesaid shares would have been held by the assesee as stock in trade , then the loss suffered on the sale of the same would have been claimed as business loss in aforesaid preceding year, viz. A.Y. 2006-07, and .....

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ng the shares were included by the assessee in the purchase , while for that paid on the sale of shares was deducted from the sales . 12. We have further given a thoughtful consideration to the facts of the case and find that the CBDT realizing that despite the Instruction No. 1827, dated August 31, 1989 and Circular No. 4/2007, dated June 15, 2007, which laid down certain parameters to distinguish the shares held by an assessee as Investment , as against those held or treated as Stock in trade .....

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adopted an assessee friendly approach and by resorting to a liberal view, therein came up with a Circular No. 6/2016, dated 29.02.2016 ,relevant extracts of which read as under :- a).Where the assessee itself, irrespective of the period of holding the listed shares and securities opts to treat them as stock in trade the income arising from transfer of such shares/securities would be treated as its business income. b) In respect of listed shares and securities held for a period of more than 12 mo .....

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ransaction (i.e. whether the same is in the nature of capital gain or business income) shall continue to be decided keeping in view the aforesaid circulars issued by the CBDT . It was further observed by the CBDT in its aforesaid circular, as under:- 2. It is reiterated that the above principles have been formulated with the sole objective of reducing litigation and maintaining consistency in approach on the issue of treatment of income derived from transfer of shares and securities. All the rei .....

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t to dispute by the A.O. However, the said stand once so taken, shall thereafter remain applicable in subsequent assessment years also and the tax payers shall not be allowed to adopt a different/contrary stand as regards the same in the subsequent years. We are of the considered view that in the backdrop of Para 1(b) of the aforesaid Circular, which we find is though applicable only as regards the listed shares and securities held for a period more than 12 months, immediately preceding the date .....

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ssesse for a period of less than 12 months and claimed by the latter as income under the head STCG . We are of the considered view that as the aforesaid scrips had not been held by the assessee for a period of more than 12 months immediately preceding date of its transfer, therefore the said fact in itself would take it beyond the sweep of applicability of Para 3(B) of the CBDT Circular No. 6/2016 (supra). We thus, independent of the concession allowed by the aforesaid CBDT Circular No. 6/2016 ( .....

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of business of the assessee company, source of purchase of shares and last but not the least, the very fact that the A.O. while framing regular assessment under Sec. 143(3) in the hands of the assessee for the immediately preceding year, viz. A.Y. 2006-07, had accepted that the shares as claimed by the assessee were in the nature of Investments , and had assessed the loss on the sale of shares under the head Capital gain by making a specific mention in the body of the assessment order that the S .....

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o be in agreement with the view taken by the CIT(A) that the doctrine of res judicata is not strictly applicable in income tax proceedings, but then we cannot remain oblivious of the settled position of law, as had been emphasized by the Hon ble Supreme Court in the case of Radha Swami Satsang Vs. CIT (1992) 193 ITR 321 (SC) and CIT Vs. Excell India Ltd. (2013) 358 ITR 295 (SC), that an inconsistent approach adopted by an A.O in the backdrop of the same set of facts, cannot be permitted. Thus in .....

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the A.O in the aforementioned preceding year, viz. A.Y. 2006-07, as against those involved in the year under consideration, we therefore in totality of the aforesaid facts, are thus unable to persuade ourselves to subscribe to the view of the lower authorities. We further find that the conduct of an assessee and other such factors from where its intention at the time of purchase of the shares and thereafter can be fairly gathered, which as per our considered view would be materially decisive in .....

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ajor income of the assessee is income from sports endorsement and other shares. In addition to that assessee had made investment into shares. The entire investment has been made by the assessee out of its own funds. No amount of shares has been invested from any borrowing. Huge amount of dividend income has been earned by the assessee which is roughly 3.25 times of the amount of capital gain. The investment in shares with Portfolio Manager is merely to the extent of 4.8% of the total investments .....

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brought before us that in the case of short term capital gains average period of holding ranged between from 82 days to 123 days. It is not the case of the A.O. that shares have been purchased and sold on daily basis or without taking delivery and giving delivery. It is further noted by us that Ld. CIT(A) has rightly analysed the facts with proper reasoning to reach on the conclusion that conduct of the assessee and facts and circumstances of the case indicate that the assessee did not carry ou .....

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to the taxpayers under the law that whether shares are to be kept by them as part of investment or stock in trade for the purpose of business. The Tribunal further held as under:- 19. Turning back to the facts of the case before us, it is apparent that the assessee had adopted a particular course. He explicitly categorized the amount invested in shares as part of investments and not as part of stock in trade . In our considered opinion, AO s allegation that assessee did not make investment into .....

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