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Idea Cellular Limited Versus Principal Commissioner of Income Tax-14, Mumbai

2017 (12) TMI 660 - ITAT MUMBAI

Revision u/s 263 - assessment order is erroneous and prejudicial to the interest of revenue in allowing depreciation on the 3G Spectrum cost claimed by the assessee under section 32(1) - CIT-A directing the AO to instead allow deduction under section 35ABB on the ground that the 3G Spectrum was only an extension of the original license for operating telecom services and not a separate intangible asset - Held that:- From the judgment of Hon’ble Supreme Court in the case of Smifs Securities Ltd. ( .....

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ar Pradesh West, Madhya Pradesh, Haryana. Andhra Pradesh, Kerala, Punjab telecom circles. In year 2001-02 it acquired rights for Himachal Pradesh, Uttar Pradesh East and thereafter in the year 2007-08 for Jammu & Kashmir. Even if 3G Spectrum was not applied or allotted, assessee could have still continued providing telecommunication services under existing license. The license to operate telecom services is issued u/s. 4 of the Indian Telegraph Act, 1885 which provide rights to establish and ope .....

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framing assessment under section 143(3) of the Act and the revision order of CIT Under section 263 of the Act is bad in law. - Decided in favour of assessee. - ITA No. 360/Mum/2016 - Dated:- 6-12-2017 - SRI MAHAVIR SINGH, JM AND SRI NK PRADHAN, AM For The Assessee : Jehangir D Mistri & Krupa P Gandhi, ARs For The Revenue : B.C.S. Naik, CIT-DR ORDER PER MAHAVIR SINGH, JM: This appeal by the Assessee is arising out of the Revision order passed under section 263 of the Income Tax Act, 1961(her .....

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t by the AO on the ground that the assessment order is erroneous and prejudicial to the interest of revenue in allowing depreciation amounting to ₹420.76 crores on the 3G Spectrum cost claimed by the assessee under section 32(1) of the Act and further directing the AO to instead allow deduction under section 35ABB of the Act on the ground that the 3G Spectrum was only an extension of the original license for operating telecom services and not a separate intangible asset. For this assessee .....

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t prays that it be held that the action of the Learned Pr. CIT in invoking provisions of section 263 of the Act and directing the AO to pass a fresh assessment order to be held to be ab-initio and/or otherwise void and bad in law. WITHOUT PREJUDICE TO GROUND NO. I GROUND NO.II: On the facts and circumstances of the case and in law, the Learned Pr.CIT erred in directing the AO to disallow depreciation amounting to ₹ 420.76 crores on the 3G Spectrum cost claimed by the Appellant under sectio .....

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s not in accordance with law and that disallowance of said depreciation is not called for. WITHOUT PREJUDICE TO GROUND NO.III: GROUNDNO.III On the facts and circumstances of the case and in law, the Learned Pr.CIT erred in not accepting the claim of the Appellant that the entire 3G Spectrum cost was deductible under section 37(1) of the Act on the ground that the Appellant has not made such claim in the return of income and that the said expenditure not incurred wholly and exclusively for the pu .....

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unabsorbed depreciation of ₹ 1,27,32,60,976/- under the normal provisions of the Act and ₹ 7,94,64,25,489/-income under section 115JB of the Act and claiming TDS credit of ₹ 1,56,89,92,736/-. Thereafter, the assessee revised ROI on 29.03.2013 declaring Nil taxable income after set-off of brought forward business losses / unabsorbed depreciation of ₹ 1,27,3240,974/- and ₹ 7,94,64,25,489/- income under section 115JB of the Act and claiming TDS credit of ₹ 2,73, .....

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0,59,052/-. The Pr.CIT, subsequently, issued show cause notice on two issues for revision of assessment under section 263 of the Act. The show cause notice was issued on the following two issues:- i) The claim of depreciation @25% on the amount paid being 3G-Spectrum Band License Fee allowed by the AO is erroneous in so far as it is prejudicial to the interest of revenue, within the meaning of Sec. 263 of the Act, and: ii) The claim of financial lease with M/s IBM Ltd for IT outsourcing as an op .....

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o the claim of depreciation on the amount paid being 3G-Spectrum Brand License Fee allowed by the AO as erroneous in so far as prejudicial to the interest of revenue. 4. The Pr.CIT finally passed revision order under section 263 of the Act as under:- 4. I have carefully considered the assessee's submission and arguments. The same is discussed on merit iii the following paragraphs. 4.1.i. At the outset, the assessee has stated that the conditions laid down in section 263 that the assessment o .....

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63 are not satisfied cannot be accepted on the facts and merits of the case which is discussed in the following paragraphs. 4.2.ii On the legal front, the Hon'ble Supreme Court in the case of M/s Malabar industrial Co. Ltd. 243 ITR 83 (SC) has laid down the conditions precedent by which the CIT can invoke the provisions of section 263. The Hon'ble Supreme Court has held that if the order of the A.O. is erroneous in so far as it is prejudicial to the interest of the Revenue. It is further .....

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venue. If due to an erroneous order of the ITO, the Revenue is losing tax lawfully payable by a person, it will certainly be prejudicial to the interest of the Revenue. Moreover, the Hon ble Kerala High Court in the case of English Indian Clays Ltd. 331 ITR 219 (Ker.) has held that a lack of proper enquiry by the Assessing Officer will render the order erroneous and prejudicial to the interest of the Revenue. Reliance is also placed oil Delhi High Court decision in the case of CIT vs. Goetze (In .....

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CIT had recorded how the order of Assessing Officer was erroneous and prejudicial to interests of revenue. Order of the CIT could be set-aside only if findings accorded by CIT were incorrect or if order of Assessing Officer was not prejudicial to interest of Revenue. HC observed that CIT could examine the issue on merits even when the same was examined by Assessing Officer and that principles of 'change of opinion' did not apply. HC noted that Revenue did not have any right to appeal ag .....

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onstrate that the view taken by the Assessing Officer was not plausible, being legally unsustainable and incorrect . 4.2.ii The argument that two views possible at the time of passing the assessment order, will hold good only in respect of questions of fact - When it comes to questions of law, the law laid down by the competent constitutional Courts has to be invariably followed. It is a settled law that when the Supreme Court or a High Court declares the law on a subject, the declaration go bac .....

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on the following decisions: a. Vijay Kiran Hotels (P) Ltd. Vs CIT (P&H) 196 Taxation 336 b. Simran Farms Ltd. Vs CIT (MI') 300 ITR 270 c. Intellinet Technologies India P Ltd. Vs ITO (ITAT Bang) 5 ITR 96 4.2.iii. The contention of the assessee that the stand taken in the notice u/s 263 is a mere change of opinion is also not tenable. Reliance in this regard is placed on the Chennai ITAT decision in the case of NI/s Coimbatore Cable Net Private Limited Vs ACIT, Coimbatore 2012 TIOL 60 whe .....

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s of the assessee, the Commissioner well within his jurisdiction to invoke section 263 as the Order of the Assessing Officer is erroneous and prejudicial to the interest of the revenue, though the Assessing Officer has passed the order after taking a possible view. Reliance in this regard is also placed in the Kerala High Court Judgement in the case of Bhatsons Acquatic Products 329 11'R 67 (Ker). 4.2.iv. It has been held by the Calcutta High Court in the case reported in 31 ITR 872 that if .....

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Commissioner was competent to revise it. Reliance is also placed on the decision of Honorable ITAT, Indore Bench in the case of Frigoscandia Winner Food Process System (79 lTD 357). 4.2.v. Hence, the contentions raised by the assessee against the invocation of section 263 are not tenable and the same are rejected. 4.3 Coming to the facts and merits of the case, the same are discussed under: 43. i. The assessee was allotted spectrum for 20 years and paid onetime cost. The assessee capitalized th .....

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eparate intangible assets as claimed by the assessee. Thus the assessee is entitled to claim deduction of 1/20th of the spectrum fees paid as per provision of section 35 ABB of the I.T. Act. It is further pertinent to mention here that one of the eligibility criteria of the bidders who could participate in 3G auction was that any entity that holds Unified Access services. (UAS)/Cellular Mobile Telephone Service (CMTS) Licensee can participate in bid for auction of 3G spectrum. 4.3.ii. The assess .....

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as claimed the depreciation u/s.32 is allowable being intangible assets is not acceptable as the assessee itself claimed that 3G Spectrum allocation is not a license and it is only right to use spectrum service. Spectrum has not been provided for one and all time and it is only for 20 years only, therefore the same cannot be claimed as an intangible asset. The assessee has claimed that without prejudice to above the entire expenditure can be claimed as business expenditure u/s.37(i) of l.T. Act. .....

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rest of revenue therefore the order passed by AO under revision is set aside to this extent. The AO is directed to allow 1/20th of the spectrum fees against the claim of the assessee as per provision of section 35ABB of the IT Act after allowing opportunities of being heard to the assessee. Aggrieved, assessee is in appeal before Tribunal. 5. Before us, Sh. J.D. Mistry Ld. Senior Counsel for the assessee narrated the facts of the case that coming to the Order under review, the AO has conducted t .....

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nder: Sr. NO Particulars Remarks As regards depreciation claimed under section 32(1) of the Act on 3G spectrum 1. Director Report for the caption financial year See heading capital Expenditure and launch of 3G services under Significant Developments under the Director Report (see page No. 1 to 6 of APB) 2. Schedule -5 Fixed Assets to the Audited Financials Statement. See Page No. 19 of APB 3. Note B1 to Schedule 22 to the Audited Financial statements See page No. 30 of APB 4. Explanatory notes t .....

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ng of 3G Spectrum and copies of wireless operating license from Wireless Planning and Coordination Wing to our letter dated March 4,2014 filed with the AC) (See page no. 74 to 452 of APB). 6. Accordingly, depreciation was claimed by the assessee under section 32(l) of the Act on the cost of 3G Spectrum and allowed by the AO. Ld. Counsel explained that Wireless spectrum in the context of telecom industry refers to electromagnetic radiation and frequency bands. The wireless Spectrum frequencies us .....

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nt that meets the prescribed standards. He further explained that the New Telecom Policy 1999 of the Government of India ( NTP-99 ) recognised that with proliferation of new technologies and growing demand for telecommunication services, the demand on spectrum had increased manifold. It laid down as one of its objectives that spectrum be utilized efficiently, economically, rationally and optimally. It recognised that there was a need for a transparent process of allocation of frequency spectrum .....

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band (the BWA Spectrum band ) by means of auctions in various telecom service areas in India. The Notice inviting Applications dated 25.02.2010 ( the Notice ), which is available in public domain, sets out the objectives of the spectrum auction as under: a) Obtain a market determined price of 3G/BWA spectrum through a transparent process; b) Ensure efficient use of spectrum and avoid hoarding; c) Stimulate competition in the sector, d) Promote rollout of 3G and Broadband services; e) Maximize r .....

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z) for 20 years from the date of award of right to commercially use the allocated spectrum block. However, it also directed that mere awarding of spectrum did not confer a right to provide mobile telephone services on the awardee, successful bidders also needed to acquire UAS/CMTS license for the awarded service areas. The Notice further set out the eligibility criteria of the bidders who could participate in the 3G auction as under: Any Entity; (i) that holds a Unified Access Services ( UAS' .....

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eady hold the license for cellular services or 2) must obtain such license separately before rolling out telecom services by paying the required entry fee. Thus, learned Counsel explained that the spectrum allotted to the Successful Bidders is distinct from the UAS/CMTS license of the awardees. This is also evident from the individual Letters of Intent ( LAM ) issued by the WPC Wing for earmarking spectrum frequency in the respective service areas submitted to the AO with assessee s letter dated .....

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services as per the conditions specified there under. Thus, it is only with the earmarked spectrum that the awards can render services. Clause 3.7 of the Notice lays down the consequences on breach, revocation and surrender of the allotted spectrum. Under this clause, the telecom operator may surrender the spectrum, by giving notice of at least 60 calendar days in advance. In that case, it shall also notify all its customers of consequential withdrawal of service by giving 30 calendar days noti .....

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at pages no. 78 to 255 of APB. The successful bidders were allowed to use the spectrum frequencies for commercial operations from the designated date. As per clause 6.4 of the Notice, specific frequencies were earmarked for the Successful Bidders which shows that there was an identified block of spectrum available for use by the bidders. Thus, during the period of allotment, spectrum was used by the allottee to provide mobile telephone services or, in other words, it was an apparatus used in th .....

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the classification of tangible or intangible asset, under section 32 of the Act; (b) Such asset is owned by the assessee; and (c) Such asset must be used for the purpose of the business or profession of the assessee. He explained that Section 32(I)(ii) of the Act describes intangible assets as know-how, patents, copyrights, trademarks, licenses, franchisees or any other business or commercial rights of similar nature, being intangible assets acquired on or after assets acquired on or after the .....

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he assessee framed the following propositions:- (i) When two views are possible and the AO has taken one of the possible view, which resulted in loss of revenue, the order cannot be treated as erroneous for the purposes of section 263 of the Act. (ii) Both conditions of section 263 of the Act i.e. the assessment order is erroneous and pre-judicial to the interest of the Revenue are conjuctive. (iii) On merits also the assessee is entitled to depreciation for the reason that any right obtained fo .....

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ction 263(l) of the Act is in the nature of supervisory jurisdiction and the same can be exercised only if the conditions specified therein exist. He referred to the expressions 'erroneous', 'erroneous assessment' and 'erroneous judgment as defined in Black's Law Dictionary. According to the definition 'erroneous' means involving error deviating from the Law. 'Erroneous assessment' refers to an assessment that deviates from the law and creates a jurisdicti .....

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of tax. This phrase has to be read in conjunction with an erroneous order passed by the AO. Every loss of revenue as a consequence of an order of the AO cannot be treated as prejudicial to the interests. For example, when an AO adopted one of the courses permissible in law and it has resulted in loss of revenue, or where two views are possible and the AO has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order so as to prejudicial to the interests .....

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m depreciation on the same at the rate of 25%. The CIT(A) charge in his revision order is that the 3G Spectrum Bank License fee has been paid for a period of 20 years and accordingly, It should be amortized over a period of 20 years and only 1/20th of the license fee should be allowed as deduction for the year under consideration. From the above facts it is clear that AO has conducted detailed examination of the issue involved, made enquiries as is cleared from documents asked for and replies fi .....

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ercise of jurisdiction by the CIT is that the order of the AO is erroneous in so far as it is prejudicial to the interest of the revenue. Hon ble Supreme Court observed as under: - The phrase prejudicial to the interests of the revenue has to be read in conjunction with an erroneous order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of Assessing Officer cannot be treated as prejudicial to the interests of the revenue, for example, when an Income-tax Officer .....

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rder passed by the Assessing Officer accepting the same as such will be erroneous and prejudicial to the interests of the revenue. Rampyari Devi Saraogi Vs. Commissioner of Income-tax (1968) 67 ITR 84 (SC) and in Smt. Tara Devi Aggarwal Vs. Commissioner of Income-tax, West Bengal (1973) 88 ITR 323 (SC). 14. Similarly, the learned Counsel for the assessee relied on the judgment of Hon ble Bombay High Court in the case of CIT vs. Gabriel India Ltd. (1993) 203 ITR 108 (Bom.), wherein it is held as .....

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also held as to what is prejudicial to the interests of the Revenue. An order can be said to be prejudicial to the interests of the Revenue if it is not in accordance with the law in consequence whereof the lawful revenue due to the State has not been realised or cannot be realised. There must be material available on the record called for by the Commissioner to satisfy him prima facie that the aforesaid two requisites are present. If not, he has no authority to initiate proceedings for revision .....

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ords called for and examined by such authority. Our aforesaid conclusion gets full support from a decision of Sabyasachi Mukharji J. (as his Lordship then was) in Russell Properties Pvt. Ltd. v. A. Chowdhury, Addl. CIT . In our opinion, any other view in the matter will amount to giving unbridled and arbitrary power to the revising authority to initiate proceedings for revision in every case and start re-examination and fresh enquiries in matters which have already been concluded under the law. .....

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he whole machinery of re-examination and reconsideration of an order of assessment, which has already been concluded and controversy which has been set at rest, is set again in motion. It is an important decision and the same cannot be based on the whims or caprice of the revising authority. There must be materials available from the records called for by the Commissioner. 15. We may now examine the facts of the present case in the light of the powers of the Commissioner set out above. The Incom .....

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n that regard. Moreover, in the instant case, the Commissioner himself, even after initiating proceedings for revision and hearing the assessee, could not say that the allowance of the claim of the assessee was erroneous and that the expenditure was not revenue expenditure but an expenditure of capital nature. He simply asked the Income-tax Officer to re-examine the matter. That, in our opinion, is not permissible. Further inquiry and/or fresh determination can be directed by the Commissioner on .....

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assed the order under review after detailed enquiry examination and verification of facts of the issue of claim of depreciation on 3G Spectrum cost of license fee and after considering the submissions made by the assessee which are on records, taken a view. According to us, this is one of the permissible view, which is taken by the AO during assessment proceedings under section 143(3) of the Act. We are of the view that pursuant to the NTP-99, the Government separated Cellular Licenses from spec .....

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.02.2010 ( the Notice ), which is available in public domain, sets out the objectives of the spectrum auction. We also find from the term and conditions of spectrum auction details that as per the Clause 2.1 of the Notice specified that under the auction process, the Successful Bidders would be granted the right to use spectrum at specified frequencies for 20 years from the date of award of right to commercially use the allocated spectrum block. However, it also directed that mere awarding of sp .....

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s letter dated 04.03.2014, since each LOI specifically states that It is not a license . Hence, we are of the view that on jurisdiction the revision order passed by CIT cannot be sustained and accordingly, reversed. 17. Now, coming to merits of the case, the learned Counsel stated that the AO after going through the facts of the case particularly note B.1 to the audited financial statements for the year ended on 31.03.2011 gave the disclosure on the accounting treatment of the 3G spectrum charge .....

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oyment of the asset. The assessee became the beneficial owner of the spectrum allotted under the auction process as it could use it for the purpose of its business and, hence, the test of ownership is satisfied. This fact is also evident from the LOI for the respective circles, under which frequencies are earmarked for the use of the assessee and makes it available to the assessee to render services. There is no ambiguity on the fact that it is used for the purpose of the business of the assesse .....

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angible Asset since such cost satisfies the conditions of section 32(1) of the Act. Accordingly, assessee claimed depreciation on the cost of 3G Spectrum under the provisions of section 32 of the Act by treating it as intangible assets. The details of cost capitalised and depreciation thereon are available in Annexure 2 of Form No. 3CD (i.e. Tax Audit Report) submitted to the AO. 18. In view of the above facts, we find that Revenue now before us could not controvert the facts narrated by the lea .....

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with the method of charging depreciation under the Block of Asset concept applicable from 01.04.1988. The spectrum allotted for 20 years does not change its nature under the Act and once an asset qualifies to be an Intangible Asset , depreciation is to be allowed under section 32 of the Act, regardless of the period for which it is owned by the assessee. The assessee claimed that the telecom license and the spectrum are independent of each other and there is no case to allow deduction in respect .....

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goodwill and held as under: - 3. The Assessing Officer held that goodwill was not an asset falling under Explanation 3 to Section 32(1) of the Income Tax Act, 1961 [ Act', for short]. We quote hereinbelow Explanation 3 to Section 32(1) of the Act: Explanation 3.- For the purposes of this sub-section, the expressions assets' and block of assets' shall mean- [a] tangible assets, being buildings, machinery, plant or furniture; [b] intangible assets, being know-how, patents, copyrights, .....

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ess or commercial right of a similar nature'. The principle of ejusdem generis would strictly apply while interpreting the said expression which finds place in Explanation 3(b). 5. In the circumstances, we are of the view that Goodwill' is an asset under Explanation 3(b) to Section 32(1) of the Act. 6. One more aspect needs to be highlighted. In the present case, the Assessing Officer, as a matter of fact, came to the conclusion that no amount was actually paid on account of goodwill. Th .....

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e Company in the process of amalgamation had acquired a capital right in the form of goodwill because of which the market worth of the assessee-Company stood increased. This finding has also been upheld by Income Tax Appellate Tribunal [ ITAT', for short]. We see no reason to interfere with the factual finding. 7. One more aspect which needs to be mentioned is that, against the decision of ITAT, the Revenue had preferred an appeal to the High Court in which it had raised only the question as .....

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