TMI Blog2020 (12) TMI 534X X X X Extracts X X X X X X X X Extracts X X X X ..... users that the product and services of the brand have the level of excellence comparable to that of the celebrity. It is only promotion or marketing or sale of goods produced, provided or belonging to a client and promotion of marketing of services provided by the client that are covered under BAS and they would continue to be covered under BAS. The Instructions further notes that many important companies were associated with a range of activities including production, marketing, sale of goods, provision of services, holding of events, undertaking social activities and if the brand name/house mark is promoted by a celebrity, without reference to any specific product or services, the service would not be classified under BAS, but would be classifiable under the newly added service under section 65(105)(zzzzq) of the Finance Act - there is no manner of doubt that the activity carried out by the appellant would be classifiable under the new taxable service contemplated under section 65(105((zzzzq) of the Finance Act. This issue has been settled by the Bombay High Court in INDIAN NATIONAL SHIPOWNERS' ASSOCIATION VERSUS UNION OF INDIA [ 2009 (3) TMI 29 - BOMBAY HIGH COURT] . The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rovide a measure or value of the rate to be applied and any vagueness in the legislative scheme makes the levy fatal. Whether the extended period of limitation contemplated under the proviso to section 73(1) of the Finance Act could have been invoked in the facts of the present case and whether penalty under section 78 of the Finance Act could have been imposed? - HELD THAT:- The show cause notice was issued to the appellant on September 26, 2011 in regard to the demand covering the period from May 1, 2006 to June 30, 2010 by invoking the extended period of limitation contemplated under the proviso to section 73(1) of the Finance Act as the limitation contemplated under section 73(1) Finance Act was one year from the relevant date. The allegation made in the show cause notice regarding the applicability of the extended period of time limit - The Commissioner has not dealt with the issue of limitation and only a statement has been made, while dealing with the imposition of penalty under section 78 of the Finance Act, that the issue of limitation was dealt earlier. It would be seen from a perusal of section 73(1) of the Finance Act read with its proviso and section 78 of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er business auxiliary service [ BAS ] and support services of business or commerce [ BAS ] with interest and penalty, are for setting aside the aforesaid order passed by the Commissioner and for granting interest to the appellant on the amount of ₹ 1,51,66,500/- deposited with the Department on February 26, 2014 towards the demand of service tax as also ₹ 50 lacs deposited on March 26, 2014 towards penalty, from the date of deposit till the date the amount was transferred to the account of the Registrar General of the Calcutta High Court. 2. BAS has been defined under section 65 (19) of the Finance Act 1994 [The Finance Act] to mean inter-alia, any service in relation to promotion or marketing or sale of goods produced or provided by or belonging to the client; or any service in relation to promotion or marketing of service provided by the client. This service is taxable under section 65(105) (zzb) of the Finance Act which defines taxable service to mean any service provided or to be provided to a client by any person in relation to BAS. 3. Section 65(104c) of the Finance Act defines BSS to mean services provided in relation to business or commerce. It i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vices of that brand have the level of excellence comparable to that of the celebrity. Thus, a brand ambassador works under a contract for a reasonably long period and promotion or marketing of sale of goods or services are covered under BAS. The show cause notice thereafter distinguishes BAS and the newly introduced service of promotion of brand of goods and services w.e.f. July 1, 2010 in the following terms: The difference between the services classifiable under BUSINESS AUXILIARY SERVICE (effective from 1-7-2003 10-92004) i.e., BAS and newly introduced service of PROMOTION OF BRAND OF GOODS, SERVICES, EVENTS, BUSINESS ENTITY ETC SERVICES (effective from 01-7-2010) is that the latter has a wide coverage in the sense that mere promotion of a brand would attract tax under this service even if such promotions cannot be directly linked to promotion of a particular product or service. Many companies/ corporate houses (for example Sahara, ITC or Tatas) are associated with a range of activities including production/ marketing/ sale of goods, provision of services, holding of events, undertaking social activities etc. If the brand name/ house mark etc is pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sorers. Such fees/remunerations have been paid to Shri Sourav Ganguly by the franchisee in addition to his playing skills and thus the services rendered by the notice in this regard in this regard is squarely classifiable under the taxable service head of Business Support Service as per the provisions of Section 65(104c) read with Section 65(105)(zzzq) of the Finance Act 1994. ******** 5.2. It is admitted position on record that the Shri Ganguly (the Noticee) obtained service tax registration only on 03-8-2010 relating to the service of Promotion of Brand of Goods, Services, Events, Business Entity etc Services - but did not discharge his service tax liabilities before that under the BAS (Business Auxiliary Services) that appears to be lawfully due from him with appropriate interest as detailed herein above. Similarly, Shri Ganguly did not obtain service tax registration under BSS (Business Support Services) relating to service charges received from M/s Knight Riders Sports Pvt. Ltd and thus did not discharge his service tax liabilities that appears to be lawfully due also with appropriate interest . In view of the fact that Shri Ganguly (the notice) had rendered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation Cess of ₹ 95,765/- relating to Business Support Service (as in Table-II) totaling to Service Tax of ₹ 14729457/- plus Education Cess of ₹ 2,94,589/- plus S H Education Cess of ₹ 1,42,454/- [Grand Total of ₹ 1,51,66,500/-] should not be demanded and recovered from Shri Sourav Ganguly invoking the extended period of time limit as envisaged under first proviso to the Sub-Section (1) of Sec. 73 of the Finance Act, 1994 as amended. (ii) Interest at the appropriate rate as applicable during the material period should not be charged/demanded and recovered from him under section 75 of chapter V of the Finance Act, 1994, as amended for the delayed payment of Service Tax including Education Cess and S H Edu. Cess as in [i] above; (iii) Penalty should not be imposed upon the Noticee in terms of Section 76, 77 and 78 of Finance Act, 1994 as amended for willful non-payment of the amount of Service Tax including Education Cesses and for contravention of the provisions of Sec. 68,69 and 70 of Chapter V of the Finance Act, 1994. 13. The receipt from the various activities performed by the appellant, on which service tax has been computed in Table ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f articles on the game of cricket as an expert in all fields of the game of cricket. (iv) Hosting (or acting as an anchor) television shows (reality shows)-, and in this case his high positive visibility was encashed by various television channels. (v) Allowance of commercial use of still photographs, Video photo, image, name etc. in the promotion of brands owned by various corporate house, business house or like organization. 15. It was, therefore, asserted that the basic nature of the entity Sourav Ganguly was as follows: (i) An individual being absolute owner of the brand Sourav Ganguly . (ii) Except the absolute ownership of the brand Sourav Ganguly ,- he did not have any active role or organization or infrastructure for doing any business or offering any business services. 16. It was, accordingly, stated in the reply that the appellant as an entity had only allowed the brand Sourav Ganguly to be the content for purpose of brand endorsement or like purpose. 17. In regard to BAS , the appellant stated: The basic nature of the entity as discussed in paras-10 and 11 can never be said to be any Auxiliary to any main business activity- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... also stated that all demand is barred by limitation also under section 73 as it is not a case of suppression of facts and also stated that the CBEC itself in the letter DY.No.42/Commr(ST)/2008 dated 26.07.2010 has clarified that no service tax is leviable only fee received for paying fee and in the statement dated 28.01.2011 recorded by DGCEI of authorized representative of the Appellant, it is clearly stated that the Appellant has received fee only for playing cricket, and in said statement it was also denied that fee for cricket will be taxable under business support service, and said statement has been relied upon by the Department, while issuing the show cause notice. It was also submitted that no allegations have been made in the show cause notice regarding amount received for writing article on sports and also no allegation have been made in the show cause notice regarding the amount received for anchoring the TV show on Zee Bengla, therefore, service tax on the same has been wrongly computed, and in any case not taxable under business auxiliary service. It was also submitted that so far the amount received for the brand promotion activity is concerned, same is taxable w.e. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... epresenting Kolkata Knight Rider besides playing also undertook promotional activity and against such promotion had received ₹ 87087857/-. The noticee has never denied that he has not promoted logos/brands/marks of franchisee/sponsors who are Kolkata Knight Riders in the instant case. I also note that the noticee performed the entire activity under contract because he himself declared so in the Annexure-1 to his reply. From above it can be clearly seen that Mr. Sourav Ganguly during the material period while under contract with various organizations provided certain taxable services and they are classifiable under Business Support Services. Thus, the demand of ₹ 9863839/- made in this regard is proper. (emphasis supplied) 23. The Commissioner also imposed penalty under section 78 of the Finance Act and the relevant portion of the order dealing with this aspect is reproduced below:- I find that the show cause notice has proposed penal action in terms of section 76, 77 and 78. In his submission made after the personal hearing the notice himself asserted that he had obtained registration under service tax legislation for the provision ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3 (SC) (2006) 7 SECT 592] and Precision Rubber Industries Pvt. Ltd. vs. Commissioner of Central Excise, Mumbai, 2017[2016 (334) ELT 577 (SC)]. Fee for Anchoring in TV Shows (ii) There is no allegation in the show cause notice that service tax is leviable on fees received for anchoring TV shows. The Commissioner, however, has confirmed service tax demand of ₹ 20,60,000/- on fees received for anchoring TV show. The demand is, therefore, liable to be set aside. Brand Ambassador Fee (iii) The show cause notice mentions that the appellant rendered his celebrity image as Brand Ambassador for promotion, marketing/sale of various products . It alleges that the said service prior to July 1, 2010 was taxable under BAS and w.e.f July 1, 2010, the said service was separately placed under section 65(105)(zzzzq) of the Finance Act. The Commissioner has given a finding that the appellant accepted that he had received brand endorsement fees , but service tax on brand promotion was levied w.e.f July 01, 2010, when section 65(105)(zzzzq) was incorporated in the Finance Act. Thus, the alleged service was not taxable prior to July 01, 2010. In this connection reliance has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , if the tax is payable. Interest to the Appellant (viii) The appellant is entitled to interest on ₹ 1,51,66,500/- from the date of deposit on February 26, 2014 and on ₹ 50 lacs from the date of deposit on March 21/26, 2014 till February 16, 2017, when the said amount was deposited by the Government with the Registrar General of the High Court. 26. Shri Manish Mohan, learned authorized representative of the Department, however supported the order passed by the Commissioner and made the following submissions. (i) The Commissioner has correctly held that the appellant provided BAS and BSS services during the period May 1, 2006 to June 30, 2010; (ii) The Commissioner was justified in imposing penalty under section 78 of the Finance Act for the reason that all that ingredients mentioned in the section for imposing penalty were satisfied; (iii) The Commissioner (Service Tax) CBEC, New Delhi by a letter dated July 26, 2010 clarified that remuneration paid to players for promoting or marketing of logo/brands/marks of the franchisee/ sponsorers would fall under BSS and would be chargeable to service tax and that in case it was not possible to segregate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ***** ***** ****** 30. BAS is taxable under section 65 (105)(zzb) of the Finance Act and this section is reproduced below: 65(105)(zzb)- taxable service means and service provided or to be provided to a client, by any person in relation to business auxiliary service. 31. It has been pointed out by the learned counsel of the appellant that brand endorsement/brand promotion services were made taxable w.e.f July 1, 2010 by introducing sub-clause (zzzzq) in section 65(105) of the Finance Act and the appellant sought registration for the above mentioned activity which was granted on August 3, 2010, where after the appellant paid service tax from July 1, 2010 for the services relating to brand endorsement/brand promotion. The contention, therefore, is that no demand could have been made or confirmed for this service for the period May 1, 2006 to June 30, 2010 under BAS. 32. This submission of learned counsel for the appellant deserves to be accepted. 33. Paragraph 4.1 of the show cause notice, which has been reproduced above, mentions that the appellant had rendered his celebrity image as a Brand Ambassador for promotion, marketing/sale of various pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpaigns to be launched by CHIRAG in respect of the products and act as an ambassador of CHIRAG during all his public appearances and endorse the products. The contract with Vibgyor Allied Industries Ltd. indicates that Vibgyor was in search of a celebrity suitable for advertising their retail products under the company name M/s Vibgyor Gold Ltd. and the appellant had communicated his willingness to act as a model/brand ambassador for the Company in connection with the promotion of the products. The appellant, therefore, granted the right and license to use the Player Identification in connection with the advertisement and promotion of the business of the Company. The contract with BMA Stainless Ltd. indicates that BMA was desirous of engaging the services of the appellant and the appellant had agreed to provide services in connection with the advertisement, promotion, marketing and endorsement of the products under the trade mark CAPTAIN or BMA . The contract also mentions that the appellant will act as a brand ambassador for BMS Stainless Ltd. 37. The terms of the aforesaid contracts clearly indicate that the appellant was required to provide services in connection ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f customers or users is that the products and services of that brand have the level of excellence comparable to that of the celebrity. Unlike in case of advertisements using models, a brand ambassador works under a contract of a reasonably long period, where under he is not only required to advertise the goods or service in different media but also to attend promotional, product launching events, make appearances in public activities related to the brand or the brand holder or use such goods or services in public. The contractual amounts are substantial and it may not only involve an individual celebrity but a group of celebrities such as a cricket team or the actors of a successful film. 4.2 It is important to note that promotion or marketing sale of goods produced, provided or belonging to a client and promotion or marketing of services provided by the client are already covered under Business Auxiliary Services (BAS). Such activities would continue to remain classified under B.A.S. The difference between the services classifiable under B.A.S and the newly proposed service is that the latter has a wider coverage in the sense that mere promotion of a brand would attract tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ourt in Indian National Shipowners Association. The High Court held that introduction of a new entry and inclusion of certain services in that entry would pre-suppose that there was no earlier entry covering the said service. The portion of the judgment on this aspect is reproduced below: 37. Entry (zzzzj) is entirely a new entry. Whereas entry (zzzy) covers services provided to any person in relation to mining of mineral, oil or gas, services covered by entry (zzzzj) can be identified by the presence of two characteristics namely (a) supply of tangible goods including machinery, equipment and appliances for use, (b) there is no transfer of right of possession and effective control of such machinery, equipment and appliances. According to the members of the 1st petitioner, they supply offshore support vessels to carry out jobs like anchor handling, towing of vessels, supply to rig or platform, diving support, fire fighting etc. Their marine construction barges support offshore construction, provide accommodation, crane support and stoppage area on main deck or equipment. Their harbour tugs are deployed for piloting big vessels in and out of the harbour and for husbanding mai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld not be leviable to service tax under a pre-existing category, if that activity was brought under a tax net from a later date. The Tribunal, after noticing the difference between promotion of a brand and promotion of a particular product, concluded that the assessee was promoting a brand and not marketing a particular product. The relevant portion of the decision is reproduced below: 9.2 Brand endorsement is a form of brand promotion or advertising campaign that involves a well known person using his or her fame to help promote a product or a service. Examples of such brand endorsements are manufacturers of perfumes, cosmetics and clothing using the services of well known film actors or fashion models for promoting their brand by the appearance of such celebrities in advertisements in audio-visual media, product launch events. Such promotional activity for the goods produced or being traded by a person under a brand or services provided by a person under a brand by celebrity appearance in advertisements or promotional events for such goods or services against a contract is covered by the definition of brand promotion service under Section 65(105)(zzzzq), as such activity a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he more famous the Celebrity endorser, the more impact it can have on enhancing the brand value. Though clause (i) and (ii) of Section 65 (19) also cover marketing or promotion of goods produced/provided or services provided by a client, when such marketing or promotion of branded goods/services is by Celebrity endorsement which involves promotional events being carried out by the Celebrity or advertisements by the Celebrity in audio visual or print media, this activity becomes brand promotion. (d) The contracts of the respondent with her clients have all the features of the contracts for Celebrity endorsement, the purpose of which is promoting a brand and not merely marketing or promoting some particular goods or services. 12.1 Therefore, notwithstanding the language of the respondents contracts with her clients that she was to provide the services of endorsement/promotion of the clients services and products, on going through the details of the activities through which the service of endorsement/promotion of the clients product/services is to be provided, it is clear that the overall objective of these agreements is the brand promotion and not mere promotion or market ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pect in the show cause notice. 50. This contention of the learned counsel for the appellant also deserves to be accepted for the reason stated while dealing with the Second Issue. FOURTH ISSUE 51. The show cause notice alleges that the appellant had received remuneration from IPL franchisee-KKR, in addition to playing skill, for promotional activities to market logos/brands/marks of franchisee/sponsors and the demand has been confirmed under BSS on the assumption that the amount received was a composite fee and, therefore, leviable to service tax in terms of the Instructions dated July 26, 2010 issued by CBEC. In this connection the Commissioner has also referred to the answers given by the appellant to question nos. 4 and 8. 52. The contention of learned counsel for the appellant is that the findings recorded by the Commissioner that the appellant did not deny that he had promoted logo/ brands/ marks of franchisee/ sponsors is factually incorrect and even otherwise the said activity would not be covered under BAS. 53. It would, therefore, the appropriate to reproduce question numbers 4 and 8 and the answers given by the appellant and they are as foll ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reement entered into with them . Question No. 8 required a response from the appellant on the issue as to whether service provided by a cricket player/celebrity for promoting or marketing of logos/brand/ marks of franchisee/ sponsors falls under BSS. The answer given by the appellant is that it would not fall under BSS for the reason that there is a separate classification of service under Brand Ambassador for promoting brands of goods/ services and the appellant had obtained service tax registration as a service provider under this category. 55. The appellant had, therefore, categorically stated that the amount received from KKR was only for playing cricket, yet an inference had been drawn by the Commissioner that the appellant had not denied this fact. 56. Even otherwise, for the reasons stated in the First Issue, the confirmation of demand under this head is bad. 57. The Commissioner has also placed reliance on the Instructions dated July 26, 2010 issued by CBEC. They are reproduced below: Government of India Ministry of Finance Department of Revenue (Central Board of Excise Customs) **** New Delhi the July 26, 2010 Sir, Subject: Serv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... osed to demand service tax on the fees received by the appellant during the period May 1, 2006 to June 30, 2010 by invoking the extended period of limitation contemplated under the proviso to section 73(1) of the Finance Act. Section 73 (1) of the Finance Act, as it stood at the relevant time, with the proviso is reproduced below. 73(1) Where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded, the Central Excise Officer may, within one year from the relevant date, serve notice on the person chargeable with the service tax which has not been levied or paid or which has been short-levied or short-paid or the person to whom such tax refund has erroneously been made, requiring him to show cause why he should not pay the amount specified in the notice: PROVIDED that where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded by reason of- (a) fraud; or (b) collusion; or (c) wilful mis-statement; or (d) suppression of facts; or (e) contravention of any of the provisions of this Chapter or of the rules made thereunder with intent to evade payment of s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2010 by invoking the extended period of limitation contemplated under the proviso to section 73(1) of the Finance Act as the limitation contemplated under section 73(1) Finance Act was one year from the relevant date. The allegation made in the show cause notice regarding the applicability of the extended period of time limit is as follows: Shri Sourav Ganguly by way of his act of omission and failure, suppression of material facts with the intend to evade payment of service tax, did not discharge the due service tax liability . 64. The Commissioner has not dealt with the issue of limitation and only a statement has been made, while dealing with the imposition of penalty under section 78 of the Finance Act, that the issue of limitation was dealt earlier. 65. It will, therefore, be necessary to reproduce section 78 of the Finance Act, which deals with penalty for suppressing value of taxable services. It is reproduced below: 78 Penalty for suppressing value of taxable service Where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded, by reason of- (a) fraud; or (b) collusion; or (c) wilful m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ils regarding the applicability of the proviso to section 73(1) of the Finance Act, nor has the Commissioner recorded any finding regarding the applicability of the said proviso. 71. The Delhi High Court in Bharat Hotels Limited vs. Commissioner of Central Excise (Adjudication) [2018 (12) GSTL 368 (Del.)] had examined at length the issue relating to the extended period of limitation under the proviso to section 73 (1) of the Act and the following observation was made: 27. Therefore, it is evident that failure to pay tax is not a justification for imposition of penalty. Also, the word suppression in the proviso to Section 11A(1) of the Excise Act has to be read in the context of other words in the proviso, i.e. fraud, collusion, wilful misstatement . As explained in Uniworth (supra), misstatement or suppression of facts does not mean any omission. It must be deliberate. In other words, there must be deliberate suppression of information for the purpose of evading of payment of duty. It connotes a positive act of the assessee to avoid excise duty. xxxxx Thus, invocation of the extended limitation period under the proviso to Section 73(1) does not refer to a sc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... liberately to escape from payment of duty. Where facts are known to both the parties the omission by one to do what he might have done and not that he must have done, does not render it suppression. (emphasis supplied) 73. This decision was referred to by the Supreme Court in Anand Nishikawa Company Ltd. vs. Commissioner of Central Excise [16] and the observations are as follows: 26 .. This Court in the case of Pushpam Pharmaceutical Company v. Collector of Central Excise, Bombay, while dealing with the meaning of the expression suppression of facts in proviso to Section 11A of the Act held that the term must be construed strictly. It does not mean any omission and the act must be deliberate and willful to evade payment of duty. The Court, further, held :- In taxation, it ( suppression of facts ) can have only one meaning that the correct information was not disclosed deliberately to escape payment of duty. Where facts are known to both the parties the omission by one to do what he might have done and not that he must have done, does not render it suppression. 27 . Relying on the aforesaid observations of this Court in the case of Pushpam Pharmaceutical ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... clear that even when an assessee has suppressed facts, the extended period of limitation can be invoked only when suppression is wilful with an intent to evade payment of service tax. 77. It also needs to be noted that the show cause notice was issued after about two years from the date the enquiry was initiated against the appellant. This fact assumes importance as section 73 (1) of the Finance Act requires that a show cause notice should be issued within one year from the relevant date. No explanation has been given by the Department for this inordinate delay. It also needs to be noted that though information was supplied by the appellant to the Department, but letters were written by the Department to the appellant in a routine manner seeking information and even the date for personal appearance was fixed after a long gap of ten months. 78. Thus, for the reasons stated above it is not possible to hold that the extended period of limitation contemplated under the proviso to section 73 (1) of the Finance Act could have been invoked in the facts and circumstances of the case. SIXTH ISSUE 79. The appellant has also claimed interest from the date the amount was dep ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ar General of the High Court, if it is ultimately held that the appellant is not entitled to pay service tax. 82. As the appeal filed by the appellant is being allowed and the demand confirmed by the Commissioner is being set aside, there is no reason why the appellant should not be granted interest on the amount of (₹ 1,51,66,500 and 50,00,000) deposited with the Government from the date of deposit of the amount upto the date of transfer of the said amount to the Registrar General of the High Court. 83. Thus, for all the reasons above, the impugned order dated November 12, 2012 passed by the Commissioner is set aside and the appeal is allowed. The appellant shall also be entitled to interest on the amount of ₹ 1,51,66,500/- and ₹ 50,00,000/- from the date of deposit of the amount with the Government upto the date the amount was transferred to the Registrar General of the Calcutta High Court at the rate of ten percent per annum. This amount shall be paid to the appellant within a period of one month from the date of this order, failing which the appellant would be entitled to get interest at the same rate from the date of this order upto the date of paymen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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