TMI Blog2006 (4) TMI 572X X X X Extracts X X X X X X X X Extracts X X X X ..... ny as per Section 40A(8) of the IT Act, 1961 (the Act). This ground was also a matter of adjudication in the appeals cited (supra) for asst. yr. 1984-85 and it was held that the assessee-company is a financial company and hence, disallowance under Section 40A(8) has to be deleted. The facts for the present year remaining the same, we follow the earlier order of the Tribunal and delete the disallowance of ₹ 10,25,032 made under Section 40A(8) of the Act. 5. Ground No. 4 is against disallowance of ₹ 35,24,873 being 10 per cent of the dividend income on ad hoc basis. This ground was not pressed at the time of hearing and hence the same is rejected as such. 6. Fifth ground in the appeal is against disallowance of ₹ 99,860 as prior period expenses. This ground was also not pressed at the time of hearing and hence, the same is dismissed as such. 7. The sixth ground is against not treating the company in which the publics are substantially interested as per Section 2(18) of the Act. In its return as well as by its letter dt. 15th July, 1987, assessee had claimed itself to be a company in which the public are substantially interested and it was also stated that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... extended definition of Section 2(18). 11. With regard to the term person having interest , our attention was invited to the provisions of Bombay Public Trust Act, 1950. Section 2(10)(e) of the said Trust Act included a beneficiary of a public trust as a person interested in the trust. Reference was also made to Sections 41B and 50 of the said Trust Act whereby trustees incurred liabilities for breach of trust and also entitled any beneficiary to lodge complaints before the Charity Commissioner. In the instant case, it was submitted, since the public at large were beneficiaries of the trust, automatically, by virtue of the trusts' shareholding in the assessee-company, it (i.e. public) became substantially interested in the assessee-company. In this connection, decision of the Supreme Court in the case of Deoki Nandan v. Murlidhar and of the Lahore High Court in the case of Nihal Chand v. Narain Das AIR 1934 Lahore 949 were referred to. 12. Reference was then made to the decision of the Madras High Court in the case of Amrutanjan Ltd. v. CIT (1961) 41 ITR 21 (Mad), wherein, the High Court's observations while dealing with identical provisions in Section 23A of the 1922 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es of Section 2 providing for various definitions were referred to. It was pointed out that whereas certain clauses used the word means , certain other clauses used the word includes . Reference was made to the order of the Tribunal in the case of Life Insurance Corporation of India v. Jt. CIT Interest-tax Appeal No. 9/Bom/1996 and Ors. reported at (2002) 74 TTJ (Mumbai) 624 Ed. In the said decision it was observed by the Tribunal that when the term means and includes is used, the definition is meant to be exhaustive and neither extensive nor inclusive. When the term means is used it gives a hard-and-fast definition. In Clause (18) of Section 2, it was submitted, the term is said to be is used which is qualified by the phrase if it is.... Thus, it was sought to be impressed by Mr. Srinivasulu that the phraseology used in Section 2(18) tantamounts to using the term means . 15. The use of the definition in Section 2(18) was broadly two-fold, viz. (a) difference in tax rate and (b) for the purpose of Section 104. Keeping these purposes in mind, it was contended, enlarged meaning could not be given. It was contended that if enlarged meaning is given, then it may lead to a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tels Co. Ltd. (supra), it was submitted that the provisions interpreted therein were no longer on the statute book. It was further contended that whereas the Bombay High Court in that case was seized with the interpretation of Section 2(18), the assessee's case in the present appeal was to remain outside the said provision and that it be dictated only by the natural meaning of the term a company in which public are substantially interested. 20. On a specific query from the Bench as to whether the aspect of control of the affairs of the company was of any relevance, the reply of Mr. Vyas was in the negative since Clause (iii) of Section 2(18)(b)(i) dealing with the control of the affairs of the company had been deleted after the amendment in 1983. On a specific query posed to the learned Departmental Representative as to whether he stands committed to the proposition that the words is said to be used in Section 2(18) have the same connotation as the term means , his answer was in the affirmative. 21. We have duly considered the rival contentions and the material on record. We pick up the issue from where the learned Departmental Representative replied to our query as m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the High Court in that case was concerned with a statutory provision which no longer exists for the assessment year with which we are concerned. In it, the words held by were interpreted by the High Court, which in our opinion, is a narrower concept, than the concept substantially interested. In this context, it is well established, as held by the Bombay High Court in the case of CIT v. Thane Electricity Supply Ltd. that what is binding on the Court in a subsequent case is not the conclusion arrived at in a previous decision, but the ratio of that decision for it is the ratio which binds as a precedent and not the conclusion. 23. In short, we are satisfied that the assessee-company before us is a company in which the public are substantially interested. Though our conclusion is mainly based on two specific arguments of the learned Counsel namely, the meaning of the term is said to be and the decision in Indian Hotels (supra), we are also convinced that the context in which the definition has to be read is the concessional rate of tax. In other words, since the context does not require us to travel beyond the scope of the issue before us, no other meaning can be ascribed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in construction of enactments that unless the context otherwise requires, the definition of an expression contained in the Act should prevail throughout the Act. Therefore, whenever a different meaning is sought to be given to that expression occurring at different places in the Act, it is necessary to point out why the context requires different meaning to be given to the same expression occurring at different places in the Act. (Reference is invited to the decision in the case of CIT v. Dredging Corporation of India. 4. Unless the context otherwise requires means that the same words should have been used elsewhere is the Act in a different context. If we were to interpret those words in that context, one may ignore the definition given under Section 2(18). However, in this case, there is no such expression elsewhere in the Act so as to protect or give benefit to the company such as the assessee herein. Absence of any such clause in respect of the companies who should otherwise have been held as a company in which the public are substantially interested , has unnecessarily affected some companies and the legislature realised this difficulty and by Finance Act, 1971 suitably ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ip and other relevant considerations. The Board is empowered to issue such direction even in respect of a past year and the direction will have effect for the assessment year or years specified therein. 5. In this case of Chamber of Commerce, Club etc., a pragmatic view would have been to treat them as companies in which public are substantially interested. But probably it was found difficult to raise such contentions, i.e. of including such companies in the definition of Section 2(18), and, thus, the legislature had to intervene. The case of the assessee-company cannot be said to be any different. The following observations of the Hon'ble Bombay High Court in the case of CIT v. Indian Hotels Co. Ltd. in my sincere view, leads to the only interpretation that the assessee-company does not fall under Section 2(18) of the Act: Now, the arguments before the Tribunal in the instant case had proceeded on the footing that 81 per cent of the shares held by the three public trusts must be treated as being held by the public. As indicated by the decisions referred to above, two questions will have to be answered. Firstly, whether there is any group of shareholders who can be consid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... have otherwise been brought within the fold of Section 2(18) would also cushion the conclusion reached by me. 7. In the result I reject the contention of the assessee-company with regard to treatment of the assessee as a company in which public are substantially interested. 8. With regard to grounds other than the ground No. 6, I agree with the views and findings of my learned Brother. REFERENCE UNDER Section 255(4) OF THE IT ACT, 1961 23rd July, 2001 We the members of the Mumbai Bench 'C' have differed on one issue in the case of Tata Sons Ltd. v. Dy. CIT in ITA No. 8231/Bom/1991. Hence, this reference is made to the Hon'ble President of the Tribunal to nominate a Third Member to decide the point of difference. The point of difference is as follows: Whether, on the facts and in the circumstances of the case and in law, the assessee-company is a company in which the public are substantially interested as per Section 2(18) of the Act. The AM has held that the same to be a company in which the public are substantially interested whereas the JM has held it to be a company in which the public are not substantially interested. R.P. Garg, Vice Presid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... c are substantially interested cannot be destroyed; that the provisions contained in Section 2(18) are inclusive one and serve the purpose of only extending the ordinary meaning of the said term; that as far as the facts are concerned, there is no dispute that the public trusts are holding 78.71 per cent of the shares and therefore the public have an interest in the trusts by virtue of Sections 2(10), 41B and 50 of the Bombay Charity Trust Act, 1950 and consequently the public are interested in the assessee-company through the trusts; that the decision of the Bombay High Court in the case of CIT v. Indian Hotels Co. Ltd. (1982) 30 CTR (Bom) 12 : (1983) 141 FIR 343 (Bom) as relied upon by the Revenue is not an authority for any of the issues to be decided in this appeal and consequently, the assessee-company has to be treated as a company in which the public are substantially interested . He also referred to certain decisions wherein the defined meaning has been extended keeping into consideration the term 'unless the context otherwise require'. 9. Shri P.K. Das, the learned Departmental Representative made elaborate arguments in support of the orders of the authorities ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e impugned year reads as under: 2. In this Act, unless the context otherwise requires,- (18) company in which the public are substantially interested -a company is said to be a company in which the public are substantially interested- (a) if it is a company owned by the Government or the RBI or in which not less than forty per cent of the shares are held (whether singly or taken together) by the Government or the RBI or a corporation owned by that bank; or (aa) if it is a company which is registered under Section 25 of the Companies Act, 1956 (1 of 1956); or (ab) if it is a company having no share capital and if, having regard to its objects, the nature and composition of its membership and other relevant considerations, it is declared by order of the Board to be a company in which the public are substantially interested: Provided that such company shall be deemed to be a company in which the public are substantially interested only for such assessment year or assessment years (whether commencing before the 1st day of April, 1971, or on or after that date) as may be specified in the declaration; or (b) if it is a company which is not a private company as defin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t, 1956 (1 of 1956), and the conditions specified either in item (A) or in item (B) are fulfilled, namely (A) shares in the company (not being shares entitled to a fixed rate of dividend whether with or without a further right to participate in profits) were, as on the last day of the relevant previous year, listed in a recognized stock exchange in India in accordance with the Securities Contracts (Regulation) Act, 1956 (42 of 1956) and any rules made thereunder; (B) shares in the company (not being shares entitled to a fixed rate of dividend whether with or without a further right to participate in profits) carrying not less than fifty per cent of the voting power have been allotted unconditionally to, or acquired unconditionally by, and were throughout the relevant previous year beneficially held by the Government, or a corporation established by a Central, State or Provincial Act or, any company to which this clause applies or any subsidiary company of such company where such subsidiary company fulfils the conditions laid down in Clause (b) of Section 108. 12. The provision as it stood prior to the present one and as was subject-matter of consideration of the Bombay High Cour ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s not apply); (ii) the said shares were, during the relevant previous year, freely transferable by the holder to the other members of the public; and (iii) the affairs of the company or the shares carrying more than fifty per cent held by five or less persons. Explanation 1 : In computing the number of five or less persons aforesaid,- (i) the Government or any corporation established by a Central, State or Provincial Act or a company to which this clause applies or the subsidiary company of such company shall not be taken into account, and (ii) persons who are relatives of one another, and persons who are nominees of any person together with that other person, shall be treated as a single person. Explanation 2 : In its application to an Indian company whose business consists mainly in the construction of ships or in the manufacture or processing of goods or in mining or in the generation or distribution of electricity or any other form of power, item (B) shall have effect as if for the words not less than fifty per cent , the words not less than forty per cent had been substituted; 13. It may be noted that the portion typed (d), (ii), (iii) and Expln. 1 w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ic trustee was a nominee of the Government and the Government would represent the people, it could be said that the voting power in respect of the shares held by the trust is ultimately exercisable by the Government on behalf of the public and so, the shares were held by the public. Having accepted the alternative argument advanced before it, the Tribunal came to the conclusion that as the shares in the assessee-company were held by the three trusts, the same can be said to be held by the public and the assessee-company should be held as a company in which the, public are, substantially interested. 15. At the instance of Revenue the question referred to the Bombay High Court was: Whether the assessee-company is a company in which the public are substantially interested as the majority of the shares are held by charitable trusts. The High Court rejected the claim on both the grounds. As regards alternate arguments, it held that the limited effect of Section 187B is that the rights and powers exercisable at a meeting of the company or at any meeting of any class of members of a company cease to be exercisable by the trustee and those rights and powers become-exercisable by the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the statute must be reasonably construed and a construction in consonance with justice should be adopted. The High Court observed that while it is hard to dispute the proposition that tax laws are to be interpreted reasonably and in consonance with justice, it is also well established that any equitable considerations are wholly irrelevant in interpreting tax laws. 16. Quoting Raghuvanshi Mills Ltd. v. CIT, the Bombay High Court held that the observations of the Supreme Court will thus indicate that when the definition in Section 2(18)(b) requires that the prescribed number of shares should be beneficially held by the public, it contemplates that person must hold the shares for his own benefit and no person who holds a share or shares not for his own benefit but for the benefit of another will fall within the body which is designated public in Section 2(18)(b)(i). One of the important considerations, therefore, for deciding whether company can be said to be a company in which the public are substantially interested is whether the prescribed number of shares are held by the member concerned for his own benefit or for the benefit of another. Beneficially holding a share i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er hand, if the members of the public hold shares of the company (not being shares entitled to a fixed rate of dividend, whether with or without a further right to participate in profits), carrying not less than twenty five per cent of the voting power allotted unconditionally to, or acquired unconditionally by, them, the company shall be deemed to be one in which the public are substantially interested. Now, the arguments before the Tribunal in the instant case had proceeded on the footing that 81 per cent of the shares held by the three public trusts must be treated as being held by the public. As indicated by the decisions referred to above, two questions will have to be answered. Firstly, whether there is any group of shareholders who can be considered as a block and whose voting power is more than 50 per cent and, secondly, are 50 per cent of the shares acquired unconditionally and beneficially held by the public. As a matter of fact, any view which we may take on the argument which is advanced before us at considerable length on behalf of the assessee that the shares held by the trustees must be treated as shares held by the public, would be sufficient to answer the questi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he extent of 1,051, that person and there are 8 such groups of 6 shares each, out of which the joint holders in 4 groups are trustees in one or the other trust. Looking at the manner in which the shares are held, either way, it was held that therefore, the prescribed 50 per cent of the shares, as required by Clause (i) of Section 2(18)(b), could not be said to be held by the public. If this condition is not satisfied, then irrespective of the question as to whether the second or the third condition is satisfied or not, the company will not be one which falls within Section 2(18)(b) of the Act. 19. The expression company in which the public are substantially interested came up before the Supreme Court in CIT v. Amrutanjan Ltd. with reference to provisions of Section 23A of the IT Act, 1922. The Court after noticing the fact that the Act did not define explained it as : Normally a company would be deemed to be one in which the public are substantially interested, where more than half the voting power is vested in the public. Where the controlling interest i.e. a minimum of fifty-one per cent of the voting rights is held by a single individual or a group of individuals acting in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he public under Section 41B to file a complaint, resulting in the Charity Commissioner exercising his power to institute an enquiry with regard to the affairs of the trust and that every member of the public has the right to resort to the provisions of Section 50 that may result in the filing of an appropriate suit in an appropriate Court for redressal of justice. The above statutory provisions and fact do not establish that every member of the public has substantial interest in the assessee-company through the public trusts. It may be that the general public are the beneficiaries in a public trust and are persons interested in the public trust in view of the Supreme Court in the decision of Deoki Nandan v. Murlidhar as also the decision of the Lahore High Court in the case of Nihal Chand v. Narain Das AIR 1934 Lahore 949, but that does not mean that public are substantially interested in the company of which the shares are held by the four charity trusts. It is the trust as such that could be said to have substantial interest in the company and not the beneficiaries thereof. Trusts being only who hold more than 50 per cent (exactly 78.71 per cent), it cannot be said that public ar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oncept substantially interested . But both are associated with public and the public trusts are held to be not public in itself it gives the same result-in the first case, shares held by public and in the later case, where public is substantially interested. If the trusts are not public, both fail. It may not be out of place to mention that Clause (d) in the earlier definition 2(18)(b)(B) making holding of shares by public which was subject-matter of consideration of Bombay High Court was deleted, though by certain more companies were included under the coverage of Section 2(18) of the Act. That shows that even when public holding was one of the criteria to determine the character of the company in which public are substantially interested the shareholding by trust was not held to be public; it would all the more be logical that such shareholding by the trust will not be taken as a criteria when such requirement of holding by public is deleted from the definition of such a company. 25. Mr. Vyas further submitted that the Courts are entitled to resort to the ordinary and natural meaning of a term and that the Courts should refrain from destroying the basic concept or essential m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rt has also in CGT v. Dr. R.B. Kamdin reiterated the above view by observing that the essential meaning or the basic idea of a term must be borne in mind while interpreting it and on pp. 481-2 observed as under: It (Supreme Court) further observed that where, within the framework of the ordinary acceptation of a word, every single requirement of the definition clause was fulfilled, it would be wrong to take the definition as destroying the 'essential meaning' of that word. With respect, I agree with the approach commended in the judgments delivered in both these cases. In view of the above discussion, it is necessary to resort independently to the natural and ordinary meaning of the term company in which the public are substantially interested , in the present appeal. 26. The argument has no force. As aforesaid, the public at large having interest in these trusts cannot be said to have interest in the company when the shares in that are held by these trusts and therefore, it is not a case of destroying the natural and ordinary meaning of the term. Even as per natural and ordinary meaning of the term a company in which public are substantially interested the share ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT v. Harrisons Crossfield (India) Ltd. the Revenue contended that the Tribunal has entered a clear finding to the effect that the five persons did hold (less than six) 50 per cent of the voting power in the assessee-company, that this finding was entered on a consideration of the provisions of Section 2(18)(b)(B)(iii) of the Act and that after entering such a clear finding the Tribunal was not justified in approaching the question in a different manner with reference to the purpose and in holding that the company is one in which the public are substantially interested. The attention of the Court was drawn to the decision of the Supreme Court in Punjab Produce Trading Co. Ltd. v. CIT (1971) 82 HP, 619 (SC). The Court answered the question referred in favour of the assessee and against the Department and held that: We could not find any assistance from the said decision so far as this case is concerned. The question for consideration in the Supreme Court decision was entirely different from the one for consideration in the present case. In that case, in the applicant-company shares carrying more than 50 per cent of the total voting power were held by less than six persons. In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l to the taxpayer must be adopted. 30. It is a cardinal principle in construction of enactments that, unless the context otherwise requires, the definition of an expression contained in the Act should prevail throughout the Act. Whenever a different meaning is sought to be given to that expression occurring at different places in the Act, it is necessary to point out why the context requires different meaning to be given to the same expression occurring at different places in the Act. Reference is invited to the decision in the case of CIT v. Dredging Corporation of India. Unless the context otherwise requires means that should have been used elsewhere in the Act in different context. If we were to interpret those words in that context, one may ignore the definition given under Section 2(18) of the Act. 31. Mr. Vyas further contended that whereas the term means is exhaustive in nature, the expression is said to be is illustrative in nature. Section 2(18) uses the expression is said to be and not the term means . Therefore, the categories of companies expressly specified in Section 2(18) are illustrative and are in addition to those companies, which are on ordinary an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... term 'means' instead of 'is said to be'. 32. Mr. Vyas then referred to the decision of the Supreme Court in Printers (Mysore) Ltd. v. Asstt. CTO rendered in the context of a concessional rate of tax, the decision in the case of N.K. Jain v. C.K. Shah dealing with a welfare legislation; the decision in Workmen of American Express International Banking Corporation v. Management of American Express International Banking Corporation, a three Judge Bench of the Supreme Court in The Vanguard Fire General Insurance Co. v. Fraser Ross several tax cases including CIT v. B.C. Srinivasa Setty Bombay High Court in Ritz Ltd. v. CIT (1995) 126 CTR (Bom) 33 : (1995) 216 LTR 138 (Bom). The discussions on the above cases compel one to look into the provisions of Section 2(18) in the relevant context. It is clear that the concessional rate of taxation was provided in the Finance Act to a company in which public are substantially interested and, therefore, it is one's duty to ensure that this legislative intention is fulfilled. The rate undoubtedly was concessional in comparison to the rates for other companies. If it were not the intention of the legislature to provide a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... preme Court observed that The opening words in Section 2 viz. 'In this Act, unless the context otherwise requires' must be examined in the light of the context, the title, the preamble and all the other enacting parts of the statute. Due weight ought to be given to the opening words. The subject matter and the context in which a particular word is used are of great importance and it is axiomatic that the object underlying the Act must always be kept in view in construing the context in which a particular word is used. So construed there is much in the context to show that the restricted meaning in the definitions should not be applied. It may be that even where the definition is exhaustive inasmuch as the word defined is said to mean a certain thing, it is possible for the word to have a somewhat different meaning in different sections of the Act depending upon the subject or the context. Further, that a definition or interpretation clause which extends the meaning of a word should not be construed as taking away its ordinary meaning is a proposition well established by the cases of CGT v. N.S. Getti Chettiar (supra), CIT v. Straw-Board Mfg. Co. Ltd. (supra) and Jagatram ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... p of the shares in, and control over the affairs of, the company. Further, in order to cover the entities which are not registered as companies but are declared to be companies for tax purposes and to companies limited by guarantee which are not registered under Section 25, the CBDT has been empowered to direct that any such entity or company shall be treated as a company in which the public are substantially interested having regard to the objects of the company, the nature and composition of its membership and other relevant considerations. 36. Notes on Clauses of the Finance Bill, 1983 may also be referred to for amended provisions which is applicable to the impugned year. It reads: Sub-clause (b) seeks to amend Clause (18) of Section 2 of the IT Act. Under the proposed amendment, a company whose shares are not listed in a recognised stock exchange in India in accordance with the Securities Contracts (Regulation) Act, 1956, and any rules made thereunder will not be treated as a company in which the public are substantially interested unless the shares in the company (not being shares entitled to a fixed rate of dividend whether with or without a further right to partici ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d be beneficially held by: (a) the Government, or (b) a statutory corporation, or (c) any other widely held company or a wholly owned subsidiary of such company, or (d) the public (other than a director of the company or a closely held company). 140. Two other conditions laid down are that the shares of the company should be freely transferable by the holders to other members of the public and the affairs of the company or the shares carrying more than 50 per cent, of its total voting power should, at no time during the relevant previous year, be controlled or held by five or less persons. For the purposes of determining whether the affairs of a company or shares in the company are controlled or held by five or less persons, persons who are relatives of one another and persons who are nominees of any other person together with that person are treated as a single person. 141. Under the proposed amendment, a company whose shares are not listed in a recognised stock exchange in India will not be treated as a widely held company. However, a company whose equity shares carrying not less than 50 per cent, of the voting power are held by the Government, a statutory corpo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ess than 50 per cent, of the voting power (40 per cent, in the case of Indian companies engaged in manufacturing activities, etc.) have been allotted unconditionally to, or acquired unconditionally by, and were throughout the relevant previous year beneficially held by the Government, or a statutory corporation, or a widely held company or a wholly owned subsidiary of such company. If the requisite percentage of the shares of the company are not so held, the company would be regarded as a closely held company even though fifty per cent, or more of its shares are held by the public generally. 39. In view of these extracts of circulars, notes on clauses and memo explaining the objects and reasons, it is evident that the items enumerated in the definition clause are all those which are widely held companies. But as they were not finding inclusion in the definition, a need was felt to incorporate them specifically. Therefore there is no force in the submission of the assessee that some companies which were not of the nature of widely held companies are also included. In any case even if that were so, it does not help in importing a company in the definition if that does not satisfy ..... X X X X Extracts X X X X X X X X Extracts X X X X
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