TMI Blog2018 (5) TMI 506X X X X Extracts X X X X X X X X Extracts X X X X ..... t. Hence, we cancel the orders passed by the ld. Pr. CIT u/s 263 of the Act and allow all these four appeals of the assessee. - ITA Nos.813 to 816/Kol/2017 - - - Dated:- 2-5-2018 - Shri J. Sudhakar Reddy, AM And Shri A.T. Varkey, JM For The Appellant : Shri A.K.Tulsiyan, FCA For The Respondent : Shri G. Mallikarjuna, CIT (DR) ORDER PER J.SUDHAKAR REDDY, AM: All these appeals are filed by the Assessee directed against separate but identical orders passed by the Principal Commissioner of Income Tax, Central-1, Kolkata u/s 263 of the Income Tax Act, 1961 (Act) for A.Y.2009-10, 2010-11, 2011- 12 and 2012-13, wherein the orders passed by the AO u/s 153A r.w.s. 143(3) of the Act dated 31.03.2015 were revised. 2. As the issues arising in all these appeals are common, for the sake of convenience they are heard together and disposed off by way of this common order. 3. The facts in brief are that the assessee is company and is engaged in the business of manufacturing of iron and steel having its plants at Vill-Gokulpur, Kharagpur, Dist West Medinipur, West Bengal and Vill-Mathurakismat, Kharagpur, Dist West Medinipur, West Bengal. 4. A search and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... benefit and thus the infrastructure facility was inaccessible to the general public and hence the infrastructure developed by you was not of general public utility. However, you were not contributing anything to the development of Infrastructure sector of the country as a whole but you have claimed deduction u/s 80lA(4) for your Private Railway Sidings though there is no such provision in the Act which extend the benefit u/s 80IA for any Private Railway Sidings. Hence, an amount of ₹ 17,62,41,550/- is required to be disallowed while arrive at the total income while passing order u/s 153A/143(3) dated 31.03.2015 in your case, thereby rendering the Assessment Order dated 31.03.2015, erroneous in so far as it is prejudicial to the interest of revenue. 7. In response to the said notice the assessee filed a detailed letter dated 10th March, 2017 objecting to the proposed revision. It was contended by the assessee that : (a) During the course of search and seizure operation conducted on 18.02.2013 no incriminating documents relating to the issue were found and seized relatable to the claim of deduction u/s 80IA of the Act and as the assessments for A.Y.2009-10, 2010-11 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the AO and the assessee being aggrieved the same had carried the matter before the ld. CIT(A) and that it was adjudicated by the ld. CIT(A) during the course of appellate proceedings, the ld. Pr.CIT held that the same was not examined by the ld. CIT(A) as the same was not examined by the AO. On merits, he held that, the assessee had developed and was managing and operating the railway sidings for his own benefit and not extending this infrastructure facility to the general public and as such the assessee was not contributing anything to the development of infrastructure sector of the country as a whole and hence the claim for deduction u/s 80IA of the Act was not allowable in the case of the assessee. 10. After observing so, he set aside the assessments to the file of the AO to examine and verify the complete data base and findings of the SIT report as well as the claim of deduction u/s 80IA of the Act. 11. Aggrieved, the assessee has raised the following grounds : 1) That the Ld. PCIT was wrong in exercising jurisdiction u/s 263 of the I. T. Act on the order passed u/s 143(3)/153A of the I. Tax Act, on the issue of claim of deduction u/s. 80IA(4), on the assessment a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... result of search operation u/s 132 of the Act relatable to the issue of claiming of deduction u/s 80IA of the Act, the AO could not have disallowed this claim of the assessee and consequently the Pr. CIT was wrong in holding that there was an error in the order of the A.O. which caused prejudice to the interest of the revenue. On the documents listed by the ld. Pr. CIT at page 12 of his order, he submitted that page nos 31 to 33 of RCL-07 are nothing but part of the profit and loss account of the assessee company wherein expenditure on account of hire charges, repairs and maintenance of the railway siding along with other expenditure claimed by the assessee are disclosed. He contended that this was part of the regular books of accounts and cannot be treated as incriminating material. 13. On page 89 of INDA-4, he submitted that the document is a letter issued by Sr. DCM, ORE, South Eastern Railway to the assessee in connection with the alleged evasion of railway freight. He pointed out that the document has been considered by the AO while passing the assessment order and an addition was made on the ground that freight has been evaded by the assessee. He submitted that the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deduction u/s 80IA of the Act and also to disturb the grant of deduction u/s 80IA of the Act without disturbing the deduction granted in the first year of claim. He relied on a number of decisions for this proposition, where various benches of ITAT as well as High Courts have held that the assessee s claim for deduction u/s 80IA of the Act was to be examined and granted in the first year and cannot be disturbed in the subsequent years. 18. He further drew our attention to clause 19 of the agreement entered into by the assessee with the Indian railway authorities and pointed out that the railways have a right regarding usage of the sidings for any purpose free of charge. He also filed copies of letters wherein this facility was allowed to be used by the railways, by other concerns. Thus on facts, it was argued that, this facility is not exclusively used by the assessee alone for its business purpose but could be and is also used by other enterprises as well as by the railways itself and in that on facts the order of the CIT(A) is wrong and perverse. He further argued that even if it assumed that this facility is a captive unit of the assessee, deduction u/s 80IA cannot be denied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... submitted that the addition of ₹ 102 crores was on the disclosure made by the assessee and that even addition was made on the issue of wrong claims of railway freight. He relied on the order of the ld. Pr.CIT and submitted that the material cited by him at page -12 of his order is incriminating material found during the course of search and that this material relates to claim of deduction u/s 80IA of the Act. On query by the bench he submitted that the statement recorded was not the basis found in the impugned revision u/s 263 of the Act. 22. He relied on the case laws cited by the ld. Pr. CIT in his order and prayed that the order passed u/s 263 be upheld. 23. In reply the ld. Counsel for the assessee once again pointed out the clause which give full rights to the railways as well as the third parties who use the facility. He submitted that the agreements with railways are in standard formats and hence there is no difference in the facts of the case of the assessee and the facts of the case of JSW Steel (P) Ltd as claimed by the ld. DR. He argued that no difference on facts were pointed out by the ld. DR. He further relied on certain decision for the proposition that, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 18.08.2014 03.11.2014 18.08.2014 Date of Completion of Assessment u/s 143(3)/153A 31.03.2015 31.03.2015 31.03.2015 Assessed Income Rs.88,73,75,956/- Rs.59,30,06,740/- Rs.1,97,75,62,511/ - Deduction Allowed u/s 80IA Rs.17,62,41,550/- Rs.19,37,58,406/- Rs.31,39,28,826/- 26. A perusal of the above demonstrates that the assessments for all these three assessment years have not abated. Under the circumstances, it is well settled that no addition can be made on an issue, where no incriminating material relatable to that issue was found during the course of search and seizure operations. We would deal with the case law on this issue in due course. 27. The issue before us is whether there was any incriminating material relatable to the issue of claim of deduction u/s 80IA(4) of the Act was found during the course of search, warranting a fresh adjudication of the issue, as to whether the assessee is entitled to a clai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l/2015,Assessment Year: 2010-11, order dt. August 25, 2017, has considered the entire jurisprudence on the issue of revisionary powers u/s 263 of the Act. This is extracted for ready reference:- The Hon ble Andhra Pradesh High Court in the case of Spectra Shares and Scrips Pvt. Ltd. V CIT (AP) 354 ITR 35 had considered a number of judgments on this issue of exercise of jurisdiction u/s 263 of the Act by the Principal Commissioner of Income Tax and culled the principles laid down in the judgments as below : 24. In Malabar Industrial Co.Ltd. ( 2 Supra), the Supreme Court held that a bare reading of Sec.263 makes it clear that the prerequisite for the exercise of jurisdiction by the Commissioner suomotu under it, is the order of the Income Tax Officer is erroneous in so far as it is prejudicial to the interests of the Revenue. The Commissioner has to be satisfied of twin conditions, namely, (i) the order of the Assessing Officer sought to be revised is erroneous; and (ii) it is prejudicial to the interests of the Revenue. If one of them is absent if the order of the Income Tax Officer is erroneous but is not prejudicial to the Revenue or if it is not erroneous bu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat section; that the said section was amended eleven times; that different views existed on the day when the Commissioner passed his order; that the mechanics of the section had become so complicated over the years that two views were inherently possible; and therefore, the subsequent amendment in 2005 even though retrospective will not attract the provision of Sec.263. 26. In Vikas Polymers (4 Supra), the Delhi High Court held that the power of suomotu revision exercisable by the Commissioner under the provisions of Sec.263 is supervisory in nature; that an erroneous judgment means one which is not in accordance with law; that if an Income Tax Officer acting in accordance with law makes a certain assessment, the same cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have been written differently or more elaborately; that the section does not visualize the substitution of the judgment of the Commissioner for that of the Income Tax Officer, who passed the order unless the decision is not in accordance with the law; that to invoke suomotu revisional powers to reopen a concluded assessment under Sec.263, the Commissioner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Assessing Officer that expenditure on tools and dies by the assessee, a manufacturer of Car parts, is revenue expenditure where the said claim was allowed by the latter on being satisfied with the explanation of the assessee and where the same accounting practice followed by the assessee for number of years with the approval of the Income Tax Authorities. It held that the Assessing Officer had called for explanation on the very item from the assessee and the assessee had furnished its explanation. Merely because the Assessing Officer in his order did not make an elaborate discussion in that regard, his order cannot be termed as erroneous. The opinion of the Assessing Officer is one of the possible views and there was no material before the Commissioner to vary that opinion and ask for fresh inquiry. 28. In Gabriel India Ltd. (6 Supra), the Bombay High Court held that a consideration of the Commissioner as to whether an order is erroneous in so far as it is prejudicial to the interests of the Revenue, must be based on materials on the record of the proceedings called for by him. If there are no materials on record on the basis of which it can be said that the Commissioner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r in exercise of revisional powers cancelled assessee s assessment for the years 1952-1953 to 1960-61 because he found that the income tax officer was not justified in accepting the initial capital, the gift received and sale of jewellery, the income from business etc., without any enquiry or evidence whatsoever . He directed the income tax officer to do fresh assessment after making proper enquiry and investigation in regard to the jurisdiction. The assessee complained before the Supreme Court that no fair or reasonable opportunity was given to her. The Supreme Court held that there was ample material to show that the income tax officer made the assessments in undue hurry; that he had passed a short stereo typed assessment order for each assessment year; that on the face of the record, the orders were pre-judicial to the interest of the Revenue; and no prejudice was caused to the assessee on account of failure of the Commissioner to indicate the results of the enquiry made by him, as she would have a full opportunity for showing to the income tax officer whether he had jurisdiction or not and whether the income tax assessed in the assessment years which were originally passed were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... already concluded; that the department cannot be permitted to begin fresh litigation because of new views they entertain on facts or new circumstance; that if this is permitted, litigation would have no end except when legal ingenuity is exhausted f) Whether there was application of mind before allowing the expenditure in question has to be seen; that if there was an inquiry, even inadequate that would not by itself give occasion to the Commissioner to pass orders under Sec.263 merely because he has a different opinion in the matter; that it is only in cases of lack of inquiry that such a course of action would be open; that an assessment order made by the Income Tax Officer cannot be branded as erroneous by the Commissioner simply because, according to him, the order should have been written more elaborately; there must be some prima facie material on record to show that the tax which was lawfully exigible has not been imposed or that by the application of the relevant statute on an incorrect or incomplete interpretation, a lesser tax than what was just, has been imposed. g) The power of the Commissioner under Sec.263 (1) is not Commissioner is entitled to examine any ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ication has not been made and not because a wrong order has been passed on merits. Thus, in cases of wrong opinion or finding on merits, the CIT has to come to the conclusion and himself decide that the order is erroneous, by conducting necessary enquiry, if required and necessary, before the order under s. 263 is passed. In such cases, the order of the Assessing Officer will be erroneous because the order passed is not sustainable in law and the said finding must be recorded. CIT cannot remand the matter to the Assessing Officer to decide whether the findings recorded are erroneous. In cases where there is inadequate enquiry but not lack of enquiry, again the CIT must give and record a finding that the order/inquiry made is erroneous. This can happen if an enquiry and verification is conducted by the CIT and he is able to establish and show the error or mistake made by the Assessing Officer, making the order unsustainable in Law. In some cases possibly though rarely, the CIT can also show and establish that the facts on record or inferences drawn from facts on record per se justified and mandated further enquiry or investigation but the Assessing Officer had erroneously not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Revenue that power under Section 263 of the Act can be exercised even in a case where the issue is debatable, it was held that the case of CIT vs. M. M. Khambhatwala was not applicable. The observation that the Commissioner can exercise power under Section 263 of the Act even in a case were the issue is debatable was a mere passing remark which is again contrary to the view taken by the Apex Court in thecase of Malabar Industrial Company Ltd. Max India Ltd. If the Assessing Officer has taken a possible view, it cannot be said that the view taken by him is erroneous nor the order of the Assessing Officer in that case can be set aside in revision. It has to be shown unmistakably that the order of the Assessing Officer is unsustainable. Anything short of that would not clothe the CIT with jurisdiction to exercise power under Section 263 of the Act. CIT vs. M. M. Khambhatwala reported in 198 ITR 144; CIT vs. Ralson Industries Ltd. reported in 288 ITR 322 (SC), not applicable; Malabar Industrial Co. Ltd. v. CIT reported in 243 ITR 83, relied on. ( Para 72) As regard the third question as to whether the assessment order was passed by the Assessing Officer without a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... judicial to the interest of the Revenue. The jurisdiction could be exercised if the CIT was satisfied that the basis for exercise of jurisdiction existed. No rigid rule could be laid down about the situation when the jurisdiction can be exercised. Whether satisfaction of the CIT for exercising jurisdiction was called for or not, has to be decided having regard to a given fact situation. In the present case, the Tribunal has held that the assessee had disclosed that out of sale consideration, a sum of ₹ 1 lakh was to be received for sale of permit. If that is so, there was no error in the view taken by the AO and no case was made out for invoking jurisdiction under s. 263. 10.1. Applying the propositions of law laid down by the various Courts in these case-law, to the facts of this case, we hold as follows:- 11. For the Assessment Year 2008-09 2009-10, assessments were completed u/s 143(3) of the Act, on 31st December, 2009 and 30th December, 2011, respectively. No order passed u/s 143(2) of the Act, for the Assessment Year 2010-11. The assessee had filed his return of income u/s 139 (1) of the Act, for the Assessment Year 2010-11, on 13/10/2010. Time provided i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... these are based on material found and seized during the course of search in his order. The ld. D/R, has also made submissions on this legal issue that incriminating material was found during the search and that the addition can be made on the facts of this case. 12. This brings us to the factual issue as to whether any incriminating material was found and seized during the course of search. 13. The ld. Pr. CIT, at para 4(a) of his order, held as follows:- 4 a The Assessee stated that there was no incriminating evidence found during the course of search operations which could be linked with the claim of deduction u/s 80 IA. In this regard, I would like to refer to Inventory of seized material bearing marks SRK- 20 and SRK-21. Page number 82 of SRK-20 contains a duly notarized affidavit of Sri Raj Kumar Chander, GM (Project) of M/s Jain Infraprojects Ltd, filed before the Government of Bihar and has claimed that the assessee IS a registered contractor of Road construction Department of Government of Bihar is also observed form seized material numbered SRK-21 [Page 99 - Part B of VAT Return], that the assessee has filed its VAT return claiming itself to be a work ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee, certifying income tax deducted at source. We are unable to understand how a VAT return or a tax deduction at source certificate would tantamount to incriminating material. These are part of the official assessment record and recorded in the regular books of account. Every document or books of account or statements found during search would not become incriminating material. Thus the conclusion of the ld. Pr. CIT, that these are incriminating material, is factually incorrect and bad in law. 15. Thus, the propositions of law extracted by us that no addition or disallowance can be made in an assessment order passed u/s 153A r.w.s. 143(3) of the Act, without any incriminating material found during the course of search u/s 132 of the Act, when applied to the facts of the case, takes us to a conclusion that the A.O. could not have made a disallowance of the claim of the assessee u/s 80- IA(4) of the Act in the assessment order passed by him u/s 153A r.w.s. 143(3) of the Act and hence the ld. Pr. CIT s impugned order is not in accordance with law. 15.1. What the Assessing Officer could have done in an order passed u/s 153A r.w.s. 143(3) of the Act, cannot be done by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pletely ignored by the Id CIT while directing the Id AO to frame the assessment afresh. We hold that when an addition could not be made as per law in section 153A proceedings, then the said order cannot be construed as erroneous warranting revisionary jurisdiction UIS 263 of the Act by the Id CIT. We hold that even on merits, there is no case made out by the Id CTT for making any addition towards deemed dividend or disallowance of excess depreciation on motor lorries. In these facts and circumstances, we find that the order of the Id CIT u/s 263 of the Act deserves to be quashed Accordingly, the preliminary ground raised by the assessee on the issue of assumption of jurisdiction u/s 263 of the Act is allowed. b) Mls Shalimar Pellet Feeds Ltd. vIs DCIT, ITAT Kolkata in ITA No. 948 to 952/Kol/2017 dated 17.10.2017; 9. We have heard the rival submissions and perused the materials available on record including the paper books filed by the assessee containing the seized documents and explanations given by the assesee thereon before the Id. AD and the Ld. CIT. It is not in dispute that as on the date of search the original assessments for Asst Years 2008-09 to 2011-12 w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion in 153C proceedings in respect ofcompleted assessments. We hold that when an addition could not be made as per law in section 153C proceedings, then the said order cannot be construed as erroneous warranting revision jurisdiction u/s 263 of the Act. This addition was made based on audited accounts already available with the revenue. Hence on this count also, the addition contemplated by the Learned CIT in section 263 proceedings is not in accordance with law. Reliance in this regard placed by the Learned AR on the decision of the Bombay High Court in the case of CITvsMudi Agro Products Ltd ( ITA NO. 36 of 2009 dated 29.10.2010- Bombay HC) is very well placed............................... In view of the aforesaid findings and judicial precedent relied upon, we hold that the addition towards deemed dividend u/s 2(22)(e) of the Act in the assessments framed u/s 153C of the Act for the Asst Years 2007-08 to 2010-11 without any incriminating materials found during the course of search with respect to those assessment years, is not warranted and held as not in accordance with law. 5.6. We hold that the Learned CIT had just entertained a belief that order passed by the L ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t, the infrastructure facility in question is not used by the public at large but by the assessee only for its business. 35. Section 80IA(4) of the Act reads as follows :- 80IA(4) This section applies to ( i)Any enterprise carrying on the business of (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining] any infrastructure facility which fulfils all the following conditions, namely :- ( a) It is owned by a company registered in India or by a consortium of such companies [ or by an authority or a board or a corporation or any other body established or constituted under any Central or State Act;] ( b) It has entered into an agreement with the Central Government or a State Government or a local authority or any other statutory body for (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining a new infrastructure facility; ] ( c) It has started or starts operating and maintaining the infrastructure facility on or after the 1st day of April, 1995; 36. A plain reading of the section does not demonstrate that there is a condition that the infrastructure facility ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t upon payment by such person or persons to the applicant of either such portion of the cost originally paid by the Applicant to the Railway Administration, m respect of the land and sub-grade work or such tollage for such use as aforesaid as shall be decided by the General Manager for the time being of the Railway Administration or such other Officer as may be nominated by him whose decision shall be final, conclusive and binding on the Applicant as to whether a portion of the aforesaid cost shall be payable and if so, the amount thereof or whether a tollage shall be payable and if so, the amount or rate thereof. The Railway Administration shall collect such proportionate cost on behalf of the Applicant' but shall not be responsible for collection of tollage for and on behalf of the Applicant, but the Applicant may enter into agreement' with the person or persons who has/have been permitted the use of Siding or part thereof by the railway Administration on the payment by the latter of tollage. 38. The assessee also filed letters as evidence that M/s. Rashmi Cement Pvt. Ltd and M/s. Orissa Metaliks Pvt. Ltd have for certain periods, have used the railway sidings ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fulfills anyone or more activity of any infrastructure facility. Hence this proposition of Ld. PCIT is not sustainable. The facts of the above case are identical with that of the assessee and the assessee has also a same clause in the agreement entered with the railway authorities as discussed in para 16 above. 16. With respect to the Rail System, Learned Counsel for the assessee further submits that, as apparent from the show cause notice issued u/s.263 by Ld. PCIT, the Ld CIT(A)-5 has concluded that: a. As per para 2.3(i) of the show cause notice, Rail System developed by the assessee company is simply Private facility . b. As per para 2,3(ii) of the show cause notice, agreement were not for developing, operating and maintaining any Rail System. c. As per para. 2.3(v) of the show cause notice, shunting of wagons cannot be termed as operation or (of) any Rail System. 17. Dealing specifically with the reasons mentioned by the learned CIT(A) in the case of Ultratech Cements the Learned Counsel for the assessee submitted that, the word Private Facility does not find mention in the statue. He submits that it is trite law that law has to be read a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We have heard-the. rival submissions, perused the orders of the authorities below and the materials placed before us. In this case, order u/s. 263 was passed by the Ld. PCIT holding that assessee is not entitled for deduction u/s. 80lA in respect of the Railway System and water supply system holding that they are not infrastructure projects. In coming to such conclusion Ld. Pr.CIT basically relied on the proceedings in the case of M/s. Ultratech Cements Limited for the Assessment Year 2009-10 and 2010-11 by the CIT -5, Mumbai wherein a view has been taken that the Claim for deduction u/s. 80IA on profit of Railway System was denied The Ld PCIT relying on the findings given in M/s.Ultratech Cements Limited for the Assessment Year 2009-10 and 2010-11 and by stating that the. CIT in that case had passed detailed order after making enquiries from the Railway Department confirming the disallowance. Therefore, Ld. PCIT is of the view that in view of the investigations made in the case of M/s. Ultratech Cements Limited and since it was held that Railway System is not entitled for the deduction u/s. 80lA of the Act as it is not an infrastructure facility, he directed the Assessing Office ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ay system we find clauses in the agreement are exactly identical to the agreement entered into by M/s.Ultratech Cements Limited for the railway siding in its premises. On analyzing the agreement and clauses thereon and the provisions of the Act it has been 'held by the Coordinate Bench in the case of M/s. Ultratech Cements Limited (supra) that the Railway System operated by the assessee is an infrastructure facility and entitled for the deduction u/s. 80IA of the Act . 39. We further find that revenues appeal against the decision of Hon 'ble ITAT in the case of M/s. Ultratech Cement Ltd. for A. Y. 2006-07 in ITA.No.6070 of 2010, has been admitted by Hon'ble Bombay High Court vide order dated 02.04.2014 on limited issue of as to whether railway siding can be treated as profit Centre or cost Centre for the purpose of determination of eligible profit. As regards revenue s ground of. appeal against very availability of deduction u/s. 80IA in respect of railway siding the Hon 'ble High Court rejected the same holding as under: After hearing the counsel at some length and perusing with their assistance the order passed by the Commissioner of Income Tax (Appea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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