TMI Blog2019 (2) TMI 1806X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 260A of the said Act unless such findings are shown to be ex-facie perverse and unsustainable and exhibit a total non-application of mind. We are therefore of considered opinion that the present appeal filed by the Revenue does not give rise to any substantial question of law. The appeal filed by the Revenue is found to be devoid of merit and the same is liable to be dismissed. - INCOME TAX APPEAL NO. 1125 OF 2017 - - - Dated:- 27-2-2020 - UJJAL BHUYAN, MILIND N. JADHAV, JJ. Mr. A.R. Malhotra a/w. Mr. N.A. Kazi, Advocate for Appellant. Mr. Nishant Thakkar a/w. Ms. Jasmin Amalsadwala i/b. PDS Legal, Advocate for the Respondent. JUDGMENT (PER MILIND N. JADHAV, J.) :- 1. This appeal has been preferred under Section 260A of the Income Tax Act 1961 (for short the said Act ) for the assessment year 2010 2011, against the order dated 25th October 2016 passed by the Income Tax Appellate Tribunal K Bench, Mumbai (hereinafter referred to as Tribunal ). 2. The respondent / assessee entered into an international transaction of non-binding investment advisory services with its Associate Enterprises (for short A.E. ) and earned revenue of ₹ 25.83 cro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ue has projected the following substantial questions of law :- 6.1 Whether on the facts and circumstances of the case and in Law, the Hon ble ITAT was justified in directing to exclude for functionally comparable companies from the list of comparables selected by the TPO viz. M/s IDFC Investment Advisors Pvt. Ltd, M/s ICRA Online Ltd., M/s Motilal Oswal Investment Advisors Pvt. Ltd. and M/s Kshitij Investment Advisory Co.Ltd., on the ground of functional dissimilarity ? 6.2 Whether on the facts and circumstances of the case and in Law, the Hon ble ITAT was justified in directing to consider four companies viz. M/s ICRA Management Consulting Services Pvt. Ltd., M/s IDC India Limited, M/s Informed Technology Ltd. and M/s Kinetic Trust Ltd. as comparable even though these companies are not functionally comparable to that of the assessee ? 6.3 Whether on the facts and circumstances of the case and in Law, the Hon ble ITAT was justified in directing not to consider M/s IDFC Investment Advisors Ltd as a comparable, without appreciating the fact that the said company has earned ₹ 13.42 crores from Investment Advisory Services out of total revenue of ₹ 26.29 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Hon ble ITAT was justified in directing to consider M/s ICRA Management Consulting Services Pvt. Ltd. as a comparable without appreciating the fresh facts brought on record by the TPO in respect of functions performed and assets employed by the said company u/s 133 (6) to substantiate that the services provided to top ten clients of the said companies and its employee profile are different from that of assessee during the year under consideration ? 6.10 Whether on the facts and circumstances of the case and in Law, the Hon ble ITAT was justified in directing to consider M/s IDC India Ltd. as a comparable without appreciating the fact that the said company is not into Investment Advisory Services and the assessee company has also itself submitted in the course of TP proceedings that the functions performed by this company are not exactly similar to the Assessee company ? 6.11 Whether on the facts and circumstances of the case and in Law, the Hon ble ITAT was justified in directing to consider M/s Informed Technology Ltd. as a comparable without appreciating the fact that the said company is not into Investment Advisory Services and the assessee company has also itself ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted 7 Kinetic Trust Limited The TPO after considering various aspects of the comparable companies rejected six out of the aforesaid seven comparables chosen by the assessee. The TPO accepted only one company which was Future Capital Investment Advisors Limited and after undertaking a further detailed analysis of the entire matrix of acceptance and rejection based on profit and operating margin proposed to include five fresh / new comparables as under :- S. No. Name of the Company 1 Future Capital Holdings Limited (Segmental) 2 ICRA Online Limited (Segmental) 3 IDFC Investment Advisors Private Limited 4 Kshitij Investment Advisors Limited 5 Motilal Oswal Investment Advisors Private Limited The TPO included the above five comparable companies in the set of comparables and thus finalised a set of six comparables for the purpose of bench marking the internationa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y was primarily engaged in providing Portfolio Management Services (PMS). The assessee submitted that PMS and investment banking services were functionally different from investment advisory services undertaken by the assessee. The assessee company was an investment advisory service company as stated in its annual report in relation to IDFC which was actually a PMS. The assessee submitted that, functions performed by this company such as investment and brokerage were performed by an Investment Advisor (IA). After a detailed scrutiny of the profit and loss account of this company, it was revealed that this company was engaged in a number of activities as reported by the revenue under one segment. Unlike the assessee, the functions performed, assets employed and risks undertaken by this company were totally different than the functions performed by the assessee company. Therefore it could not be treated as a comparable. In support of the above propositions to challenge the inclusion of IDFC Investment Advisors Pvt. Ltd as comparable by the TPO / DRP, assessee relied upon the following judgments. i) AGM India Advisors Pvt. Ltd. v/s DCIT, ITA no.4757/Mum./2015, A.Y. 2010-11, orde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The assessee submitted that performance of the aforesaid activities made this company financially different from the assessee and hence, it could in no way be treated as comparable with the assessee company. The Tribunal on perusal of the information submitted in the annual report of this company as well as its financials, returned a finding that the functions undertaken by this company were totally different from the assessee company and therefore the company failed in the FAR analysis itself. Thus, the Tribunal rejected this company i.e. ICRA Online Limited (Segmental) as a comparable. 5.8 Motilal Oswal Investment Advisors Pvt. Ltd. (MOIAPL) The assessee objected to this company as a comparable selected by the TPO as it derived its business verticals from equity capital market, mergers and acquisition, private equity syndication and structural debts. The assessee submitted that as per this company s annual report, the company advised Indian Corporates on cross border acquisitions and this company was a SEBI regulated merchant Banker which provided investment banking services in the nature of acquisition equity placements, IPOs, syndication, etc. and had undertaken activit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oss account statement of this company, the assessee submitted that this company derived its revenue from consulting fees. It was the assessee s case that the functions performed by this company with respect to management consultancy service involved analysis of business and operations of a company, its profitability, operational efficiency, future outlook, etc. based on which consultancy or advise is given to the management of a company. Such functions were similar to that of a non-binding investment advisory and related services rendered by the assessee. The assessee submitted that this company had undertaken activities in other fields like business and operations, geographic research discussing the regulations laid out in the biogenerics globally, market research in respect of various products, business and operation analysis and therefore, this company ought to have been accepted as a comparable in the assessee s own case by the TRO / DRP. The case of the DR was that this company operated in various verticals as also conducted its business through various practice divisions such as Government and infrastructure practice, energy practice, banking and financial service, corporate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case for assessment year 2009 2010, this company should not be excluded from the list of comparables. 6.4 Kinetic Trust Limited This company was rejected by the TPO / DRP as comparable. On the basis of annual report of this company, the fact of this company was accepted as a comparable to the asssessee by the TRO / DRP for the assessment year 2009 2010 was considered by the Tribunal. Referring to the decision of Temasek Holdings Advisors India Pvt. Ltd. (supra), as also the decision of the Tribunal, Delhi Bench, in Nortel Network India Pvt. Ltd. (supra) which was affirmed by the Delhi High Court in Nortel Network India Pvt. Ltd., ITA No.3043/2015, the issue of application of Turnover filter was analysed and the Tribunal concluded that if this company was functionally similar, only because of low turnover filter it could not be rejected. The Tribunal included this company as a comparable. 6.5 The Tribunal by the impugned order directed the AO / TPO to determine the arm s length price afresh in terms of the directions contained in the order. 7. We have perused and considered the draft assessment order dated 26th February 2014, the assessment order under Section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to 6 therein which read thus : 3. The Indian Income Tax Act, 1961 contains Special Provisions relating to Avoidance of Tax in Chapter X of the Act comprising of Sections 92 to 94-B with regard to assessment to be done for computation of income from international transactions on the principles of Arm s Length Price (ALP) and the relevant Rules for computation of such income under the aforesaid provisions of Chapter X are enacted in the form of Rule 10-A to 10-E in the Income Tax Rules, 1962. Perspective of International Trade and Transactions: 4. With the ever increasing international Trade and transactions, particularly, in the Software Industries and Bangalore, being the Silicon Valley of India where many big, small and medium size Software Industries have their Offices and Units in this Software Industry, and Bengaluru is a hub of this Service Industry and essentially the Indian Companies have business linkages with large Companies spread worldwide particularly in the Western Hemisphere of the Globe. 5. The implementation of the Tax laws in this field in a smooth, clear and quick manner is of utmost importance to build an image of an efficient Tax Administra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee s activities with the comparable, it could be seen that the assessee is only providing advisory service to its A.E. which is non binding in nature, therefore, is totally different from the functions performed by IDFC. Considering the aforesaid aspect, the Tribunal, Mumbai Bench, in Carlyle India Advisors Pvt. Ltd. (supra), has held that this company is not comparable to an investment advisor service provider. Same view has also been expressed by the Tribunal, Mumbai Bench, in AGM India Advisors Pvt. Ltd. v/s DCIT, ITA no.4757/Mum./2015, A.Y. 2010 11, order dated 18th May 2016, and 7 FIL Capital Advisors India Pvt. Ltd. other decisions of the Tribunal, Mumbai Bench, relied upon by the learned Sr. Counsel. The Bench in the case of AGM Advisors India Pvt. Ltd. (supra), ultimately concluded as under: 7. We find that the assessee objected to the inclusion of ICRA 0 and IDFC on the ground that the TPO had applied no scientific method in arriving at the said two companies that the companies had been cherry picked by the TPO and he had not furnished the process applied by which he had come to select the said two companies, that such an approach to select comparables was im ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a valid comparable. Considering the above discussion, we are of the option that the order of the FIRST APPELLATE AUTHORITY and exclude both the comparables does not suffer from any legal or factual infirmity. So, confirming his order, we decide the issue against the AO. 5. It is also relevant to observe, the Hon'ble Jurisdictional High Court in General Atlantic Pvt. Ltd. (supra), while approving the view expressed in Carlyle India Advisors Pvt. Ltd. (supra) has observed that where a company is remunerated on cost plus basis, it is risk insulated, therefore, on application of FAR, it cannot be compared with other companies if there is any difference. Therefore, respectfully following the decision of the co ordinate bench of the Tribunal referred to above as well as the principle laid down by the Hon'ble Jurisdictional High Court, we reject this company as a comparable. 11.2 Paragraph No.8 of the Tribunal s order pertaining to exclusion of ICRA Online Limited reads thus : 8. We have considered the submissions of the parties and perused the material available on record in the light of the decisions relied upon. On a perusal of the information submitted in the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... estment banking solutions and transaction expertise covering private placement of equity, debt and convertible instruments in international and domestic capital markets, monitoring mergers and acquisitions and advising M A as professional and restructuring advisory and implementations. It is also involved in various professional activities of the merchant banking. A merchant banker provides capital to companies in the form of share ownership instead of loans. It also provides advisory on corporate matters to the companies in which they invest. The focus is on negotiated private equity investment. The wide range of activities include portfolio management, credit syndication, counseling on M A, etc. This whole range of functions and activities carried out by Motilal Oswal is definitely are far wider and much different from investment advisory services where core functions is to give advices for making the investments in diversified fields. A company which is engaged in merger and acquisitions, private equity syndication, loan/credit syndication and performing most of the function of a merchant banker, then the entire functions and transactions affects the generation of revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of Kshitij Investment Advisory Co. Ltd. from the final set of comparables. The first and the foremost resistance articulated by the Revenue to oppose the exclusion of the said concern from the final set of comparables is the fact that such concern was included by the assessee itself as a comparable in its transfer pricing study. As per the Revenue, since the said concern has been adopted by the assessee as a comparable, it is impermissible for the assessee to raise a plea asking for its exclusion in the process of determination of average margins under the TNM method. In our considered opinion, the proposition being canvassed by the Revenue is not absolute, but it has to be considered in the facts and circumstances of each case. No doubt in a situation of the type before us, the burden lies on the assessee to justify exclusion of Kshitij Investment Advisory Co. Ltd., considering the fact that initially assessee had taken it as a good comparable. Our aforesaid approach is founded on a well accepted proposition that in the course of determination of correct tax liability, it is impermissible for the Revenue to take advantage of an ignorance or mistake of the assessee in offering c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ote also suggests that the said concern did not enter into any non compete agreement with Everstone Investment Advisors Pvt. Ltd. but was free to pursue any activity, including the activity in relation to investment advisory services. The aforesaid aspect has been highlighted by the Revenue to say that the said concern continues to be in the business of rendering investment advisory services and, therefore, the restructuring does not impact the comparability of the concern. In our considered opinion, the approach of the Revenue in this context is quite flawed. Firstly, it is not disputed that the activity of investment advisory services has been realighed which included the transfer of all employees to Everstone Investment Advisory Pvt. Ltd. The averments in the Director s Report suggest that post realignment, the concern is only evaluating its options to commence business operations either in some other line or in the similar line of investment advisory services. What we are trying to emphasize is that there is no averment in the Directors Report to suggest that the said concern has actually carried out any investment advisory services post realignment w.e.f. 1.1.2010. In fact, i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and communication. Thus, as could be seen, though, the service provided by the assessee covers the wide spectrum of activities, however, the nature of service is virtually one viz. advisory services. The same is the case with the comparable. Though, it is alleged by the learned Departmental Representative, the comparable is providing service through various sectors, however, the nature of service is advisory. We have also noted that absolutely similar argument was advanced by the learned Departmental Representative in relation to this comparable in case of Temasec Holdings Advisors India Pvt. Ltd. (supra) in A.Y. 2010 11. The Tribunal, after considering the submissions of the learned Departmental Representative and also the proposition advanced by him in relation to the principles of res judicata and the decision of Kalpetta Estates Ltd. (supra) relied upon by him in this regard, ultimately treated this company as a good comparable observing as under: 20. At the outset, this comparable was subject matter of consideration before the Tribunal in AY 2008-09 2009-10, wherein this company was held to be good comparable both on the ground of functional similarity and in view of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sts or net margin or has a bearing in the generation of revenue itself, then it cannot be considered to be a fit comparable for benchmarking the net margins. Here it is not the case where there is any unique functions materially affecting the revenue or net margins vis -vis the functions performed by ICRA. Hence on functional level it is a good comparable. As stated earlier, in the earlier years, the Transfer Pricing Officer has accepted ICRA to be a comparable and in later years the Tribunal in AY 2008-09 2009-10 has held ICRA Management to be good comparable qua the functions of the assessee and there being no material change on facts, functional profile or any other factor in this year, then as matter of consistency, we do not want do deviate from our findings given in the earlier years. There cannot be a pick and choose of comparables every year unless there are some material difference in facts and circumstances compelling to take a different conclusion. Thus, we hold that ICRA Management is a good comparable and should be included in the list of final comparables. 25. Again, in the case AGM India Advisor Pvt. Ltd. (supra), the Tribunal, after considering almost simi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... investment advisory services. This decision of the Carlyle Advisors have also upheld by the Hon ble Bombay High Court. Moreover, we have already discussed the functions performed by the IDC India Ltd while dealing with Ld. Counsel s argument that functions of advisory services are quite similar to the functions of the assessee and, therefore, we accept the assessee s contention that this comparable cannot be rejected. Accordingly, same is directed to be included in the comparability list. 31. In case of AGM India Advisors Pvt. Ltd. (supra), the co ordinate bench after considering the very same argument advanced by the learned Departmental Representative and following the decision rendered in Temasec Holdings Advisors India Pvt. Ltd. (supra), held that the company is a good comparable. While doing so, the Tribunal had given a categorical finding that IDC India Ltd. is not a product company. Since the aforesaid decisions of the Tribunal are for the very same assessment year, they will squarely apply to the facts of the present case. Moreover, we have noted the fact that in assessee s own case for the assessment year 2009 10, this company has been accepted as a comparable by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1.8 Paragraph Nos.41 and 42 of the Tribunal s order pertaining to exclusion of Kinetic Trust Limited reads thus : 41. We have considered the submissions of the parties and perused the material available on record in the light of the decisions relied upon. The major thrust of argument of the learned Departmental Representative for excluding this company is on account of its low turnover. However, as it appears from the material on record, though, in the show cause notice the Transfer Pricing Officer proposed to apply a low turnover filter of less than ₹ 1 crore, following the same logic, he should have applied a high turnover filter. Further, in the order passed under section 92CA(3), the Transfer Pricing Officer has not emphasized the filter finally applied by him and the selection process undertaken, therefore, it cannot be said with any degree of certainty that he applied low turnover filter. Even, assuming that such filter was applied, following the same logic, he should have applied high turnover filter to exclude companies. We have further noted that the Tribunal, Delhi Bench, in Mckinsey Knowledge Centre India Pvt. Ltd. (supra) has held that if a company is functio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ase. On the contrary in the case of Nortel Networks India P Ltd, reported in [2014] 44 taxman.com 46 the Delhi Tribunal has held that, if the functional profile of the comparable is the same with that of the assessee then, it cannot be excluded from the list of the comparables merely for the reason of low turnover. He submitted that the said decision of the Tribunal has been now been upheld by the Hon ble High Court vide order dated 24.02.2015 in ITA No. 3043/2015, wherein, the Hon ble High Court observed that, whether the turnover filter is appropriate one and applicable, cannot be answered in the abstract and is entirely fact dependent. Lastly, the Tribunal in assessee s own case for the assessment year 2008-09 2009-10 has accepted the Kinetic Trust Ltd as a comparable company so far as the functions performed by the assessee. The Ld. TPO in utter disregard to the Tribunal s order has stated that the said decision of the ITAT cannot be accepted, because the finding was given on the ground that the TPO has accepted this comparable in the earlier years. This cannot be the ground for rejection, rather the Kinetic Trust Ltd is to be included as the comparable company following ju ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nts in the declared income of the assessee, resulting in fetching of more revenue. From the aforesaid quoted paragraphs from the Tribunal s order, it is evident that, individual cases of such comparables have been juxtaposed with the functionality of the assessee considered, analyzed and discussed by the Tribunal in respect of comparables which were excluded by the TPO as also in the case of those comparables which were included by the TPO. It is quite common to note that, while some comparables are found to be appropriate and really comparable to the facts of the assessee company, some are not and it would ultimately result in whether the correct filters have been properly applied or not or whether the most appropriate method of determination of arm s length price has been adopted or not to make fair and reasonable transfer pricing adjustments in the hands of the assessee. However, the entire exercise of making transfer pricing adjustments on the basis of comparables is nothing but a matter of estimate of a broad and fair guess-work of the authorities based on factual relevant materials brought before the authorities i.e. the TPO, the DRP and the Tribunal, which are the fact findi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Section 260- A of the Act which we have already said is in pari materia with Sections 100 and 103 of the Civil Procedure Code. 19. The said provisions are quoted below for ready reference and comparison. Section 260-A of the Income Tax Act, 1961 reads as under: 260A - Appeal to High Court: (1) An appeal shall lie to the High Court from every order passed in appeal by the Appellate Tribunal [before the date of establishment of the National Tax Tribunal], if the High Court is satisfied that the case involves a substantial question of law. (2) [The [Principal Chief Commissioner or] Chief Commissioner or the [Principal Commissioner or] Commissioner or an assessee aggrieved by any order passed by the Appellate Tribunal may file an appeal to the High Court and such appeal under this sub-section shall be-] (a) filed within one hundred and twenty days from the date on which the order appealed against is [received by the assessee or the [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner]; (b) [*******] (c) in the form of a memorandum or appeal precisely stating therein the substantial question of law ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he question so formulated and the respondent shall, at the hearing of the appeal, be allowed to argue that the case does not involve such question: Provided that nothing in this sub- section shall be deemed to take away or abridge the power of the Court to hear, for reasons to be recorded, the appeal on any other substantial question of law, not formulated by it, if it is satisfied that the case involves such question. Section 103 - Power of High Court to determine issues of fact - In any second appeal, the High Court may, if the evidence on the record is sufficient, determine any issue necessary for the disposal of the appeal, - (a) which has not been determined by the lower Appellate Court or both by the Court of first instance and the lower Appellate Court, or (b) which has been wrongly determined by such Court or Courts by reason of a decision on such question of law as is referred to in section 100. What is a Substantial Question of Law? 20. From a bare comparison of the provisions quoted above and as discussed in various judgments of the Constitutional Courts, which we will refer in brief herein below, it is clear that the Scheme of bo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... other enterprise by holding not less than 26% of the voting power in the other enterprise and satisfies the other criteria as stated in Section 92-A of the Act. 14.1. Relevant portion of Section 92-B of the Act reads thus : international transaction means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises, and shall include a mutual agreement or arrangement between two or more associated enterprises for the allocation or apportionment of, or any contribution to, any cost or expense incurred or to be incurred in connection with a benefit, service or facility provided or to be provided to any one or more of such enterprises. 14.2. Section 92-C (1) of the Act reads thus : (1) The arm's length price in relation to an international transaction (or specified domestic transaction) shall be determined by any of the following methods, being the most appropriate method, having regard to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d and vi) Kinetic Trust Limited. The Transfer Pricing Officer (TPO) only accepted one company as a comparable company being Future Capital Investment Advisors Limited but undertook a further detailed analyses and proposed to include the following five more companies as comparables namely i) Future Capital Holdings Limited (Segmental); ii) ICRA Online Limited (Segmental); iii) IDFC Investment Advisors Private Limited; iv) Kshitij Investment Advisors Limited and v) Motilal Oswal Investment Advisors Private Limited. 16. The submissions advanced on behalf of the respective parties are mostly based upon the filters which have been applied which are essentially related to turnover filter, the comparable entities being functional entities, higher transfer pricing adjustments, transfer pricing analyses and profits declared by the companies. We have quoted the specific findings given by the Tribunal and would therefore, not like to dwelve deeper or reiterate the same. We would however like to say that the Tribunal has considered the case of each comparable company and discussed the parameters of comparables for the purposes of including the same as a c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Court after due consideration dismissed the appeal of the revenue holding that no substantial question of law arose from the order of the Tribunal. 20. On a thorough consideration we find that the rational for inclusion of the six comparables excluded by the TPO have been dealt with in extensive detail by the Tribunal and we are in agreement with the reasons recorded by the Tribunal. Further the reasons given for inclusion of the five new comparables by the TPO have been decidedly set aside by the Tribunal on the basis of decisions rendered by this Court either in the case of the assessee itself and / or in other cases after proper consideration. 21. At this stage we would like to refer to paragraph No.54 in the judgment of Principal Commissioner of Income Tax Vs. M/s. Softbrands India Pvt. Ltd. (supra), which reads thus : 54. The procedure of assessment under Chapter X relating to international transactions as indicated above is already a lengthy one and involves multiple Authorities of the Department. A huge, cumbersome and tenacious exercise of Transfer Pricing Analysis has to be undertaken by the Corporate Entities who have to comply with the various provisions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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