TMI Blog2019 (8) TMI 988X X X X Extracts X X X X X X X X Extracts X X X X ..... n to the assessee to substantiate it cost base with respect to the segment, which has been challenged by special auditor and the learned AO to derive at the correct income of the assessee - ground number 2 of the appeal of the assessee is set aside to the file of the learned AO with a direction to pass a draft assessment order after incorporating all the arguments of the assessee so that assessee gets an opportunity to file objections before DRP. Foreign exchange cost incurred on salaries of the expat employees - according to AO should have been charged with a markup of 12 % thereon - HELD THAT:- No infirmity in the order of the learned DRP in their direction to the AO to include the same for working out the correct revenue of the assessee. Admittedly even before us the assessee did not show any clauses in the agreement, which even remotely suggest that only operating cost , are to be charged to the AE. According to us the assessee is to be reimbursed on cost plus basis with 12% mark up. In the agreement there is no reference to exclusion of any foreign exchange loss or gain or same is not to be considered as cost . It was not denied that the expat of salary was not re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... learned AO may examine them and allow the credit in accordance with the law. Accordingly, ground number 7 of the appeal of the assessee is allowed. - ITA No. 6322/Del/2014 - - - Dated:- 14-8-2019 - Smt Beena A Pillai, Judicial Member And Shri Prashant Maharishi, Accountant Member For the Assessee : Shri K. M. Gupta, Adv, Ms. Chinu Bhasin, AR And Ms. Damini Agarwal, AR For the Revenue : Shri Raman Chopra, CIT DR ORDER PER PRASHANT MAHARISHI, A. M. 1. This appeal is filed by AT T Communications Services India private limited (appellant) against the order of The Deputy Commissioner Of Income Tax, circle 2 (1), New Delhi on 30/10/2014 u/s 143 (3) read with section 144C of The Income Tax Act 1961 determining the total income of the assessee at INR 470472900/ against the returned income of INR 178707586/ . The above assessment order was passed by the learned Assessing Officer pursuant to the direction of the learned Dispute Resolution Panel 1, New Delhi (DRP) dated 27/8/2014 against the objections filed in the draft assessment order dated 25/11/2013. 2. The asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in disallowing an amount of ₹ 3,09,418 (out of the total disallowance of ₹ 26,93,256 mentioned above) for which evidence/ details were submitted by the Appellant before the learned AO duly substantiating that these expenses relate to the subject assessment year. 4.4 Without prejudice to the above, the learned AO has erred in disallowing ₹ 3,09,418 on the basis that the expenditure, being road tax and MCD charges relatable to the car taken on lease by the Appellant, should be capitalised with the cost of the car, without taking cognizance of the fact that the car is not owned by the Appellant and has not been capitalised for income-tax purposes. 5. Ground No. 5 - Addition on account of non-charging of mark-up on support service charges billed to AT T Global Network Services India Private Limited ( AGNSI ) 5.1 On the facts and in the circumstances of the case and in law, the learned AO erred in making addition of ₹ 1,39,41,228 on account of non-charging of mark-up on support service charges billed to AGNSI, an Indian affiliate of the Appellant. 6. Ground No. 6 - Disallowance of vear- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. Brief facts of the case is that assessee is a company engaged in the business of telecommunication services, it filed its return of income on 30/9/2009 for assessment year 2009 10 declaring total income of INR 1 78707586/ . Draft assessment order in this case was passed on 25/11/2013 wherein the order of the learned transfer-pricing officer was also incorporated. 4. The assessee is a wholly owned subsidiary of AT T company services International incorporation. Business of the assessee is divided into 3 broad segments of liaison support services business segment, managed network services business segment and network connectivity services business segment. The assessee has entered into a master service agreement with AT T USA under which it provides market updates liaison and administrative support services along with other source support services to its overseas group companies and is compensated on a cost plus basis at a markup of 12% for the impugned financial year. These services are classified as liaison and support services (LSS) business segment. In this segment, the assessee is also rendering services to AT T global network service ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ead of that the learned assessing officer has granted the credit of only INR 3 5505064/ . 8. After hearing the parties on this issue, we direct the learned assessing officer to verify and grant the credit of the tax deduction at source to the assessee, as claimed, if the certificates are in proper form. The learned assessing officer may examine them and allow the credit in accordance with the law. Accordingly, ground number 7 of the appeal of the assessee is allowed. 9. Ground number 8 of the appeal is with respect to the levy of interest u/s 234B of the income tax act, which is consequential in nature and therefore it is dismissed. 10. Ground number 9 of the appeal is with respect to the initiation of penalty proceedings u/s 271 (1) (c) of the income tax act. The above ground is premature and therefore it is dismissed. 11. Ground number 2 of the appeal is with respect to the addition because of rejection of cost allocation as per the master service agreement of the assessee between various segments. As already stated the business of the company is divided into 3 statements and in the master service agreement the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... satisfied based on details furnished by the assessee and held that assessee has failed to substantiate the cost base. In absence of the complete detail the learned assessing officer, special auditor both adopted an ad hoc approach of allocating 50% of INR 2 70490602/ as the cost amounting to INR 1 35245301/ which has escaped from billing to the associated enterprise. Further markup of 12% was charged of INR 1 6229436/ as according to the agreement the assessee is deriving revenue from cost plus markup basis, was further determined and total addition of INR 1 51474737/ was made. 12. The ld AR submitted methodology of booking expenses by the Company under each of the business segments as under : i. Each business segment of the Company has its own independent customers for which it renders services and earns revenue there from. For rendering such services, all business segments incur expenses, which are booked under the respective business segment. Thus, every business segment within ACSI is a profit center in itself and incurs costs for performing specific services for its separately identifiable customers, which in turn generates revenues for t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... expense code of E720 would remain constant. v. The PR Form generated by an employee under the MNS division then undergoes an approval process, which is also authorized by the MNS division employees. Thereafter a Purchase Order ( PO ) for such expense is generated. For instance, in the enclosed Annexure - 3, the POs numbered 20801400, 2080401, 20801402 2080403 are placed at Pages 15, 17, 19 and 21. These PO numbers are also reflected in the summary sheet for this voucher ( Refer Page 3 of the Annexure ). vi. The PO is then sent to the vendor/ service provider who raises an invoice giving reference to such PO number. In our example, the invoice numbers B32 (₹ 2,95,922), B33 (₹ 4,47,870), B34 (₹ 58,750) and B35 (₹ 67,500) corresponding to these POs are placed at Pages 14, 16, 18 and 20 of the Annexure. vii. Once the invoice is received, an Accounts Payable voucher is generated for making payment of such invoice. In our example, the voucher placed at Page 10 captures the organization code (ATUKMHG3K) as well as the expense code (E720) on the basis of the PR Form which was initially raised by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y cost) has been allocated to the Non-MSA segments. In view of above, there is no under charging in respect of salary cost to MSA segment. He also pressed that other than salary expenses (i.e. ₹ 49.39 crores), assessee submitted ledger accounts substantiating entries for expenses of ₹ 41.88 crores (i.e. almost 85% of the cost other than salary and wages costs) bifurcating them into MSA and Non-MSA segments and the underlying vouchers/ invoices for expenses of ₹ 19.72 crores in relation to the costs relatable to both MSA and non MSA business segments. He therefore submitted that based on the documents/ details submitted by ACSI, it is clear that out of aggregate expenses of ₹ 26.72 crores recorded under the Non - MSA business segments (other than salary and wages expenditure of ₹ 10.46 crores), the Appellant has furnished invoices/ vouchers to corroborate expenses of ₹ 16.29 crores (i.e. more than 61% of the costs incurred in relation non-MSA business segments). He therefore stated that in view of the voluminous details submitted before the leaned AO and/ or the Hon ble DRP as stated above, the Ld. AO has grossly erred in observing that the Appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g an ad-hoc adjustment to the extent of 50% of the aggregate costs incurred in relation to services provided under the Managed Network Services ( MNS ) business segment by alleging that such costs relate to the LSS business segment and thus, should have been charged to AT T US/ AGNS along with a mark-up of 12% is bad in law and ought to be deleted. 15. The learned DR vehemently supported the order of the learned DRP and the learned assessing officer. 16. We have carefully considered the rival contentions and perused the orders of the lower authorities. The Company s business is divided into three broad segments namely: (i) Market research, administrative support and liaison services ( MSA ); (ii) Managed Network Services ( MNS ); and (iii) Network Connectivity Services ( NCS ) 17. Under the MSA business segment, assessee has entered into a Service Agreement ( MSA Agreement ) with AT T US whereby it would provide the following services to AT T US: (i) Providing market update and identifying investment opportunities in India for the AT T group; (ii) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It simply attached a list of employees claimed to be segment -wise without any supporting documents. In the light of the above, the argument of the assessee is rejected. Further, with respect to remaining non-salary expenses of ₹ 49.40 crores, the assessee has produced invoices before the Dispute Resolution Panelof INR 8.89 crores (on sample basis) out of the total expenditure of INR 31.78 crores for which Ledger was submitted. Further, it has submitted additional invoices of INR 7.39 crore in this office during verification. Thus, it is clear that assessee has submitted the invoices of INR 1 6.29 crores which is just 32% of the total non salary cost of ₹ 49.40 crores and 17% of the total cost of INR 9.37crores. From the above, it is very clear that assessee has no basis/justification of allocation of cost amongst various segments. Further, despite so many opportunities accorded to the assessee by special auditor, Dispute Resolution Paneland at the stage of finalization of the order, the assessee could produce invoices to the extent of 32%/17% only. Thus contentions of the assessee were rejected. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee fails to furnish the adequate evidence with respect to the cost base, the AO may decide the issue accordingly. Needless to say that for adoption of the any methodology by the assessing officer in absence of submission of details by the assessee, proper opportunity of hearing is given to the assessee. In the result ground number 2 of the appeal of the assessee is set aside to the file of the learned assessing officer with a direction to pass a draft assessment order after incorporating all the arguments of the assessee so that assessee gets an opportunity to file objections before DRP. Consequently in accordance with the law the final assessment order should be passed. 23. Accordingly Ground no 2 of the appeal is allowed with above directions for statistical purposes. 24. Ground No 3 of the appeal is with respect to foreign exchange cost incurred on salaries of the expat employees, which according to AO should have been charged with a markup of 12 % thereon. According to the assessee, as assessee has entered into MSA with AT T US for provision of market research, administrative support, liaison services and other support ser ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... operating costs incurred and charged to AT T US for provision of services under the MSA. Even the MSA does not provide that any foreign exchange loss incurred by ACSI would be billed to AT T US under the MSA. It may be noted that foreign exchange gain/ loss arises on account of change in foreign currency exchange rate at the time of payment of the expense vis-a-vis at the time of booking of the expense. This does not have any bearing on the services, which have already been rendered and therefore, cannot have any bearing on the operating cost of such services and the resultant price to be charged, where such price is a function of the costs incurred for provision of the services. Accordingly, it should not be considered for determining the cost base for charging the mark-up to be recovered from the service recipient. Ld AR referred to Safe Harbour Rules, wherein the Central Board of Direct Taxes (`CBDT') has clearly mentioned that foreign exchange gain / loss should not be, considered while computing the operating margin of taxpayers. Since the same is not to be considered as part of the cost base, no mark-up is required to be charged on such expenses. As per the Safe Harbor R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pats is incidental and ancillary to the services rendered under the MSA and should have been billed to AT T US along with a 12% mark-up is erroneous and the addition warrants to be deleted. 26. The learned departmental representative vehemently supported the order of the lower authorities and submitted that when the salary payable to the expat employees is part of the cost basis then foreign exchange loss incurred by the assessee should also be passed on to the associated enterprise with markup thereon. He therefore submitted that there is no error in the order of the learned assessing officer as well as the direction of the learned dispute resolution panel. He further stated that the argument of the learned authorised representative with respect to the safe harbour rules does not apply, as assessee has not adopted the same. He submitted that safe harbour rules can be taken shelter under only when the assessee adopts the same otherwise not. He as such stated that the foreign exchange loss incurred by the assessee is on account of salary of the expat employees, which is not denied to be the cost of the agreement therefore foreign exchange loss thereon, should also b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rvices provided by the assessee with a markup of 12% of such cost. The term cost has not been defined in the said revised and restated service agreement and therefore the meaning of this word cost shall be derived as a normal parlance. It cannot be restricted to operating cost was claimed by the assessee particularly because of the fact that it will lead to a conclusion that all cost have not to be reimbursed along with the agreed-upon markup. The fundamental basis on which such cost sharing through Intra /inter group service agreement is done is that the services rendering entity is firstly, not to suffer any loss on account of cost incurred by it and secondly, the services rendering entity is given suitable markup, on arm s-length principle. In other words, the service rendering entity makes the transaction on commercial basis rather than making it either as a non-profit organization or as a charitable organization. In the instant case there is no dispute that such forex loss has been incurred with relation to the 5 expat employees who services have been used by AT T US and therefore, there is no basis for the assessee s argument that it was not the cost which wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o agree with the finding of the ld DRP with respect to applicability of safe Harbour rule. Naturally assessee has not opted for it and so cannot claim so. Further in many judicial precedents, the Forex gain and loss were held to be operating income/ loss. In view of this we do not find any infirmity in the order of the learned assessing officer. Accordingly ground number 3 of the appeal of the assessee is dismissed. 30. Ground number 5 of the appeal of the assessee is against the addition on account of non charging of the markup on support service charges billed to AGNS amounting to INR 13,900,000. The brief facts of the issue is that AT T Global Network Services India Pvt. Ltd. ( AGNSI ), a group company of the Appellant, commenced its business operations from AY 2008-09 onwards and did not have its own support service functions such as tax, legal, finance, HR etc., which are imperative for any business organization to carry on its business. The appellant, already in operation for more than 10 years, had a fully developed support service functions. Accordingly, since such functions were already housed in Appellant, AGNSI entered i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as failed to controvert the invoices, the details of payment made and evidencing the payments thereof to dispute the genuineness of the expenses and the fact that the taxpayer as well as AGNSI are profit making entities and there was no tax incentives for the purpose to deflate the revenues earned by the taxpayer, the Revenue has based its decision on commercial consideration. Moreover, in case of both the resident parties, terms and conditions of the arrangement cannot be questioned by the Revenue unless specifically provided under the Act. In case of a contract by both the parties who are admittedly resident Indian entities, they make the law for themselves which cannot be interfered unless contract is unlawful or specially barred by the law of the land. Moreover by such a decision of not charging mark up by the taxpayer on support services charges billed to AGNSI, no loss of tax has been caused to Revenue. So, the findings of the TPO/DRP that the taxpayer is not only to cut charges but mark up also is not sustainable in the eyes of law. So, we order to delete the addition on account of not charging of mark up on support services charges bill ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... addition on account of not charging of mark up on support services charges billed to AGNSI. 25. Respectfully following the findings of the coordinate Bench, we direct the Assessing Officer to delete the impugned addition. Ground No.4 is allowed. d. The matter is also squarely covered by the recent order of Hon ble Tribunal, Delhi Benches, in its own case in AY 2008-09 (ITA No. 1015/Del/2015) dt. March 26, 2019. In this regard, it is submitted that the facts of the present year are exactly similar to that of the preceding year. Relevant para of the order is produced below: (Para 5.6.0-5.6.1, Page 38-43 of the ITAT Order) 5.6.1 Therefore, respectfully following the order of the Coordinate Bench in assessee s own case for assessment year 2010-11 as aforementioned, we order deletion of addition on account of notional charging of mark-up as sustained by the Ld. DRP . e. The matter is also squarely covered by the recent order of Hon ble Tribunal, Delhi Benches, in its own case in AY 2014-15 (ITA No. 6703/Del/2018) dt. March 28, 2019. In this regard, it is submitted that the facts of the presen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Thus, in the present case as well, any adjustment/ addition on account of non-charging of mark-up by ACSI from AGNS would be unwarranted, unjustified and untenable in law. i. It has been judicially upheld that commercial expediency of a particular transaction (including expenses incurred by a businessman) would be examined from the perspective of a business man and no third party, including the tax authorities, are entitled to question the commercial reasoning/ justification of the transaction. Similarly, prudency of revenue to be charged from a domestic entity should be seen from the point of view of the businessman and not from the point of view of the outsiders (including the Revenue authorities). j. Further, both AGNSI and appellant are profit making entities and hence, there was no tax incentive for the parties to deflate the revenues earned by appellant. Where a higher amount would have been charged by appellant from AGNSI, deduction for such higher amount would have been available to AGNSI and hence, no added tax advantage is being availed by appellant by charging support services cost from AGNS at cost (i.e. withou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... commercial reasoning/justification of the expenditure so incurred. Reliance in this regard is placed on the following judicial precedents furnished by the assessee: b. CIT v. Panipat Woollen General Mills Co Ltd (103 ITR 66) (Supreme Court) c. CIT v. Sales Magnesite (P) Ltd [1995) 214 ITR 1 d. Binodiram Balchand vs. Commissioner of Income Tax (48 1TR 548) e. Calcutta Landing and Shipping Co Ltd vs. CIT (65 ITR 1) (Cal High Court) f. CIT Vs B Dalmia Cement Ltd (254 ITR 377) g. 76. Respectfully following the principles laid down in the aforesaid judicial precedents, we find that where the appellant has actually incurred the aforesaid support services cost and no evidence has been brought by the Department to controvert the same, such expenditure cannot be disallowed merely on suspicion. We affirm the finding of the ld DRP on this issue. In view of the above, the appeal of the revenue on this ground is dismissed. h. Since the said expense is allowed in the case of AGNSI, still notional markup cannot be imputed in the case of appellan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... yer is following mercantile system of accounting and the expenses are having element of estimation as well as scientific basis, keeping in view the past trend, the expenses are required to be allowed in the year of creation itself, particularly, when the Revenue authorities has allowed the entire claim of expenditure in the subsequent years. 26. So, following the law laid down by the Hon ble Apex Court in Rotork Controls India (P) Ltd. (supra) and the decision rendered by the coordinate Bench of the Tribunal in AGNSI in ITA No.1059/Del/2015 for AY 2010-11, we are of the considered view that when the taxpayer has worked out the liability by using a substantial degree of estimation by proving 95% of the invoices on the basis of historical trend, no disallowance can be made. So, we order to delete this addition. c. The matter is also squarely covered by the recent order of Hon ble Tribunal, Delhi Benches, in its own case in AY 2011-12 (ITA No. 1653/Del/2016). In this regard, it is submitted that the facts of the present year are exactly similar to that of the preceding year. Relevant para of the order is produced below: (Para 35, Page 14 of the IT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... provisioning amounting to ₹ 1,26,30,579/-, it isseen that this issue is also covered in favour of the assessee bythe order of the Tribunal in assessee s own case for assessmentyear 2010-11 in ITA No. 1016/Del/2015. 5.9.1 In the present appeal also, undisputedly no mistakehas been pointed out by the Assessing Officer in the calculationand nor is it the case of the Revenue that the taxpayer has notpaid certain bills. It is also undisputed that more than 80% ofthe evidence/s for the year end provisioning have been producedby the assessee and there is no finding by the Assessing Officerthat the provisioning was not reasonable or did not have anyscientific basis. Therefore, respectfully following the law laiddown by the Hon ble Apex Court in the case of Rotork ControlsIndia Pvt. Ltd. and also the order of the Coordinate Bench inassessee s own case for assessment year 2010-11 as aforesaid,we order deletion of this addition. 5.9.2 Ground no. 10 accordingly stands allowed The matter is also squarely covered by the recent order of Hon ble Tribunal, Delhi Benches, in its own case in AY 2014-15 (ITA No. 6703/Del/2018) dt. March 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... close of the financial year, by way of year-end accruals. As and when the invoices relatable to the aforesaid year-end accruals, were received/ paid by appellant in the subsequent year(s), the actual expenses were charged in the books of accounts after appropriate deduction of tax on such expenses. h. Accordingly, since the year-end accruals created by appellant represent accruals towards normal business expenditure incurred by appellant for the financial year relevant to the subject assessment, deduction in respect thereof should be allowed to appellant. i. Further, the Appellant has been able to produce documentary evidence supporting payment/reversal of majority of the expenses represented by year end accruals, it substantiates the fact that even the balance accruals have also been created on a reasonable basis and hence, no disallowance in this regard can be made against appellant . j. From above, it is clearly evident that the Appellant has been able to produce documentary evidence supporting payment/reversal of more than 99% of the expenses represented by year - end accruals. It substantiates the fact that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e ld AR submitted that :- i. Out of the aggregate disallowance of year-end accruals of ₹ 10.18 crores, an amount of ₹ 9.49 crores (this includes amount of ₹ 5.84 crores out of the amount mentioned in point (i) above disallowed for non-production of evidences) has been disallowed by the Ld. AO on account of non-deduction of tax at source from such accruals. ii. Out of the aforesaid disallowance, ₹ 4.63 crores pertained to accruals which were subsequently utilized towards payments made to Cisco Netherlands ( CISCO ), a tax resident of the Netherlands, for provision of offshore maintenance support services to ACSI. The Appellant, vide its letter dated November 12, 2013 filed detailed submission explaining that the services rendered by CISCO were standard services, and did not make available any technical skill, knowledge or experience to the Appellant. Thus the same would not fall under the purview of FTS as contemplated by the India Netherlands tax treaty. Further, in the absence of CISCO s Permanent Establishment in India (evidenced by a no PE certificate), such payments would also not be chargeable to tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a Power Transmission Corporation Pvt Ltd vs DCIT (2016) 383 ITR 59 (Kar.) d. Dishnet Wireless Ltd vs. DCIT ( Chennai Tribunal) 172 TTJ 394 1. Ld DR Could not point out any contrary decision . Therefore respectfully following the above decisions and in light of the factual matrix of the case we are of the considered view that since creation of the year end accruals does not result accrual of income to an identified vendor, the same cannot trigger a withholding tax liability on the part of the appellant. ii. Reliance is also placed on the decision of the Hon ble Delhi High Court in the case of a. DIT vs. Ericsson Communication Ltd (2015) 378 ITR 395 (Del.) wherein it was held that: 1. 22. In our view, mere passing of the book entries, which are reversed, would not give rise to an obligation to deduct TAS by the Assessee, as clearly, there is no debt that can be said to be acknowledged by the Assessee. Imposition of an obligation to deduct TAS in these circumstances would amount to enforcing payments from one person towards a tax liability of another, even where the person does not acknowledge that any sum is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hoorji Vallabhdas Co. 46 ITR 144 wherein it was held as follows; 2. That the subsequent agreement had altered the rate of commission in such a way as to make the income which really accrued to the assessee different from what had been entered in the books of account. This was nota case of a gift by the assessee to the managed companies of a portion of income which had already accrued, but an agreement to receive a lessor remuneration than what had been agreed upon. The assessee had in fact received only the lesser amount in spite of the entries in the account books, and this lesser amount alone was taxable. Incometax is a levy on income. Though the Income-tax Act, takes into accounts two points of time at which the liability to tax is attracted, viz. the accrual of the income or its receipt, yet the substance of the matter is the income. If income does not result at all, there cannot be a tax, even though in book-keeping, an entry is made about a hypothetical income;, which does not materialize. Where income has, in fact, been received and is subsequently, given up in such circumstances that it remains the income of the recipient, even though given up, the ta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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