TMI Blog2023 (7) TMI 1305X X X X Extracts X X X X X X X X Extracts X X X X ..... t made by assessee ought not to have been interfered with unless it is shown to be incorrectly claimed by assessee. And we further note that by debiting such expenses to the profit and loss account, there is no loss to the revenue, as even by capitalization of such expenses, the same will be debited to the revenue in future years. Accordingly, the treatment of debiting interest expenses to the tune to the profit and loss account ought to have been allowed. And therefore, we dismiss the appeal of the revenue and allow the CO of the assessee and direct the AO to allow the claim of the assessee. Commission and brokerage of expenses - AO did not accept the assessee s reliance on para -19 of AS-7 issued by ICAI for Construction Contracts stating that the General Administration Cost and Selling Cost are to be excluded from the Construction Cost, since these costs/expenses cannot be attributed to contract activity or cannot be allocated to a contract - HELD THAT:- As noted that brokerage and commission is a financial cost/selling expenses which the assessee has incurred wholly and exclusively for the purpose of business. And the selling cost has been incurred by the assessee for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... revenue appeals against the order of the Ld. CIT(A)-48, Mumbai dated 10.05.2022 for AY 2014-15 AY. 2016-17 respectively. 2. First, we will deal with the appeal of Revenue CO of assessee pertaining to AY 2013-14 wherein the ground no. 1 of the revenue is against the action of the Ld. CIT(A) partly allowing the appeal of the assessee by which AO s action of capitalizing interest expenditure of Rs.7,55,87,118/- claimed by the assessee as revenue expenditure by holding that Rs.5,29,71,264/- as revenue expenditure, and balance Rs.1,40,18,981/- be capitalized as work-in-progress (WIP). Assessee is against the part-relief not granted by Ld CIT(A). 3. Brief facts are that the assessee is a Joint Venture carrying out business in the name of M/s. Rustomjee Evershine Joint Venture which is engaged in the business of Construction and Real Estate Development and Commercial and Residential Projects. The assessee filed its return of income for AY 2013-14 on 30.09.2013 declaring total loss at Rs.28,16,17,718/-. The assessee in its profit and loss account had shown revenue of Rs.211,95,60,101/-, and had shown interest income of Rs.7,55,87,187- from short term deployment of borrowed funds ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s that directly relate to that qualifying asset can be readily identified. 9. It may be difficult to identify a direct relationship between particular borrowings and a qualifying asset and to determine the borrowings that could otherwise have been avoided. Such a difficulty occurs, for example, when the is coordinated centrally or when the range of financing activity of an enterprise debt instruments are used to borrow funds at varying rates of interest and such borrowings are not readily identifiable with a specific qualifying asset. As a result, the determination of the amount of borrowing costs that are directly attributable to the acquisition, construction or production of a qualifying asset is often difficult and the exercise of judgment is required. Commencement of Capitalisation 16. The activities necessary to prepare the asset for its intended use or sale encompass more than the physical construction of the asset. They include technical and administrative work prior to the commencement of physical construction, such as the activities associated with obtaining permits prior to the commencement of the physical construction. However, such activities exclude ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /- added to the WIP. The relevant portion of the impugned order of Ld. CIT(A) is reproduced as under: - 7.4 Considering that in the present year i.e., A.Y. 2013-14, there is no change in the facts and circumstances of issue under consideration, I find no reason to differ with the decision of my Ld. Predecessor who has further relied on the decision of Ld. Commissioner of Income Tax (Appeals)-18 and 36, Mumbai. It can be seen that, consistently the decisions are given on same line, hence the same are to be followed. 7.5 On this issue, the appellant has already filed submission during the appellate proceedings the same is considered by me. No new submission has been made. At the outset I would like to clarify that there are no doubts about the genuineness of interest expenditure, which has been paid to the financial institutions on borrowed funds. The issue is only with respect to apportioning, the interest in the ratio of percentage of projects completed, in view of accounting standard AS-16. I have also examined the working given by the assessee. Undoubtedly, the assessee had revenue from sale of flats of Rs. 212 Crs, as is clear from statement of profit and loss account ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - - Total 1,91,48,11,481 7,55,87,117 85,96,871 6,69,90,245 5,29,71,264 1,40,18,981 Amount of interest to be disallowed 1,40,18,981 7.6 Therefore, following the decision of my Ld. Predecessor as well as of Ld. Commissioner of Income Tax (Appeals)-18 and 36, Mumbai, in the case of the assessee, on identical issue, the amount of interest to be disallowed works out to Rs. 1,40,18,981/- which is confirmed and balance of the expenditure amounting to Rs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for reasonable expenditure in the nature of interest for earning such a turn-over, he computed the interest expenditure allowable as per the chart given therein, wherein he agreed with the apportionment of interest in respect of projects of assessee i.e. Avenue G, Avenue H, Avenue J, Avenue M and Avenue I, which according to Ld. CIT(A), the assessee s claim of interest expenditure is only in the ratio of percentage of project completed. After having made such a finding at para 7.5 (last line), the Ld. CIT(A) has worked out the allowable interest expenditure in the ratio of project completed and disallowed interest expenditure in respect of two (2) projects i.e. Avenue G Rs.47,00,898/- and Avenue J Rs.93,18,083/-. Thus, disallowed total interest expenditure of Rs.1,40,18,981/- which is to be taken to the closing WIP. The impugned action of Ld. CIT(A) is under challenge. In this regard, we note that the assessee has followed accounting policy for recognition and capitalization of borrowing cost as per the Accountant Standard-16 Borrowing Cost as recognized by the ICAI for determining the quantum of interest cost has been debited to P L account. The assessee company has followed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e incurred directly in relation to the project should only be capitalized. The Ld. CIT(A) has restricted an amount capitalized to the tune of Rs.1,40,18,981/- and allowed the revenue expenditure to the tune of Rs.5,29,71,264/-. We do not countenance the action of the Ld. CIT(A) for partially allowing the claim of the assessee of Rs.5,29,71,264/- as revenue expenditure and balance to be added as WIP. According to us, the Ld. CIT(A) has not given any reason for making such an adjustment without pointing out any mistake in working as shown by assessee in this regard. Since the assessee has been following the AS-16 and since there is no doubt about genuineness of the interest expenditure as well as the fact that the assessee has debited the financial cost which are not directly attributed to the project as revenue expenditure, the same ought to be allowed unless the Ld. CIT(A) is able to show that the amount of Rs.1,40,18,981/- was interest cost which was directly attributable to the project and therefore, should have been capitalized to the cost of WIP. Since the Ld. CIT(A) have not given any such reasons, and since we note that the interest expenditure fulfil the criteria mentioned i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... commission and brokerage, sales promotion expenditure and fair and exhibitions etc. In this connection, the appellant has relied upon the appellate order passed by my Ld. Predecessor for AY 2013-14 and AY 2014-15 in the case of Kapstone Construction Private Limited, the group company of the appellant on the similar issue. The relevant part of the said decision is reproduced as under for the sake of clarity: 6.4 I have considered the facts of the case and submissions of the assessee. The expenditure in the nature of selling cost consists of various heads of expenditure, like advertisement, publicity, fair exhibition, sales promotion, brokerage etc.. I agree with the ld. AR that the expenditure in the nature of advertisement, fair exhibition, pamphlets and sales promotion etc. has to be allowed in full in the year of incurring such expenditure. I also agree with the ld.AR that the expenditure in the nature of brokerage, discount etc. is to be allowed in full in the year where liability has arisen. Further as long as the expenditure is genuine, it should be allowed in the year of sale/ booking of flat. If that be the case, the entire expenditure in the nature of selling costs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uipment and materials to and from the project site; f) costs of hiring plant and equipment; g) costs of design and technical assistance that is directly related to the project; h) estimated costs of rectification and guarantee work, including expected warranty costs; and i) claims from third parties. 6.8 However as per the above principle, the following costs should not be considered as part of the construction costs and development costs: (a) General administration costs; (b) selling costs; (c) research and development costs; (d) depreciation of idle plant and equipment; (e) cost of unconsumed or uninstalled material delivered at site; and (f) payments made to sub-contractors in advance of work performed . 6.9 From the above discussion, it is quite clear that the administrative expenses are not related to the project cost and hence should not be capitalized. It is in these circumstances that the company has charged off the said administrative expenses to profit and loss account, as against capitalizing the same to the WIP of an under construction project. Besides the assesse has been executing several projects a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on'ble Delhi High Court held that Advertisement expenditure for launching products is an allowable revenue and expenditure and therefore does not call for any interference and therefore, no substantial question of law arises. In doing so the Hon'ble court confirmed the finding of ITAT Tribunal that the assessee had to incur such expenditure to meet the competition in the market for selling its products. The ratio of this judgment is squarely applicable to the facts of the case. 6.15 Similarly in the case of Commissioner of Income Tax vs.Citi Financial Consumer Fin. Ltd. (2011) 335 ITR 0029 it was held that the entire expenditure on publicity and advertisement incurred by the assessee is allowable fully in the year in which it was incurred; there being no advantage which has accrued to the assessee in the capital field and there is no concept of deferred revenue expenditure in the IT Laws, the expenditure has to be allowed if the tests laid down in s. 37 are fulfilled. 6.16 The Karnataka High Court in the case of Mysore Tobacco Co. Ltd. vs. CIT (1978) 115 ITR 698 (Kar) observed as under: An expenditure which can be claimed as a deduction in any assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T Mumbai IT.A. No. 6820/Mum/2012 Vardhman Developers Ltd. ITO Ward 2(3X4) Mumbai under identical circumstances held that no disallowance with regards to the said selling expenses should be done for the year under consideration and entire expenditure is allowable. The ratio of above judgments and decisions supports assessee's view point. 6.20 Therefore in view of the discussion in foregoing paras and considering the overall facts of the case, the addition/ disallowance of Rs. 10,53,40,913/- made by the AO becomes unsustainable in law and is therefore is directed to be deleted. This ground of the assessee is accordingly allowed. 8.4 Considering that in the present year i.e. A.Y. 2013-14, there is no change in the facts and circumstances of issue under consideration, I find no reason to differ with the decision of my Ld. Predecessor. Also, in his assessment order the AO has concluded that the Selling costs are to be allowed as revenue expenditure to the extent of attribution to the revenue offered. On verification of the details of commission and brokerage expenses it is seen that the appellant has rightly offered revenue recognized for F.Y. 2012-13. Therefore, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... spect of the interest expenditure as revenue in nature]. We, for the same reasoning stated therein for ground no. 1 of revenue and CO of assessee for AY. 2013-14 decide the same by confirming the action of Ld. CIT(A) and our decision will apply mutatis mutandis for this year. Therefore, the action of the Ld. CIT(A) reversing the action of the AO for capitalization of interest expenditure of Rs.51,18,152/- need to be allowed as revenue expenditure. 12. Ground no. 3 is against the action of the Ld. CIT(A) allowing the commission and brokerage cost of Rs.1,31,20,709/- which is found similar to ground no. 2 for AY. 2013-14, and no change in facts or law could be pointed out by the department. So for the same reasoning stated therein for AY. 2013-14, we confirm the action of Ld. CIT(A) which will apply mutatis mutandis for this year. Therefore, the impugned action of the Ld. CIT(A) is upheld. 13. Coming to appeal of revenue for AY. 2016-17, we note that first ground is similar to ground no. 1 for AY. 2013-14 (and ground no. 1 2 for AY. 2014-15) and since there is no change in facts or law, for the same reasoning stated therein for AY. 2013-14, the action of the Ld. CIT(A) is uph ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 17 w.e.f. 01/04/2018 wherein a new subsection (5) was inserted in Section 23 of the Act to the effect that the property held as stock in trade which are not let out during the previous year, the annual value of the said property, for a period up to one year from the end of the financial year in which the certificate of completion of construction and property is obtained from the competent authorities. This amendment was brought in the section 23 sub section (5) of the Act, effective from AY 2018-19 onwards which is not retrospective in nature. Hence, no addition can be made based on notional rental income or deemed rental income in the hands of the appellant in respect of unsold flats held as stock in trade by the appellant during the year under consideration. For this reliance of the Ld. AR on the decision of Hon'ble Gujarat High Court in the case of CIT vs. Neha Builders Pvt. Ltd., reported in 296 ITR 661 (Guj) is found to be in order. In the said decision, it is held that where the property has been held as stock in trade of the assessee, then the said property would partake character of stock and any income derived from stock would be income from business and not income fro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s cannot be termed as income from house property. While holding so the Hon'ble High Court observed as under:- 8. True it is, that income derived from the property would always be termed as 'income' from the property, but if the property is used as 'stock in-trade, then the said property would become or partake the character of the stock, and any income derived from the stock, would be 'income' from the business, and not income from the property. If the business of the assessee is to construct the property and sell it or to construct and let out the same, then that would be the business' and the business stocks, which may include movable and immovable, would he taken to be stock-in trade, and any income derived from such stocks cannot be termed as income from property. Even otherwise, it is to be seen that there was distinction between the income from business' and 'income from property on one side, and 'any income from other sources. The Tribunal, in our considered opinion, was absolutely unjustified in comparing the rental income with the dividend income on the shares or interest income on the deposits. Even otherwise, this question w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y engaged in the activity of letting out properties and the rental income received was shown as business income, the action of AO treating the rental income as income from house property in place of income from business shown by the assessee was held to be not justified. The Hon'ble Supreme Court held that since the assessee company's main object, is to acquire and held properties and to let out these properties, the income earned by letting out these properties is main objective of the company, therefore, rent received from the letting out of the properties is assessable as income from business. On the very same analogy in the instant case, assessee is engaged in business of construction and development, which is main object of the assessee company. The three flats which could not be sold at the end of the year was shown as stock-in-trade. Estimating rental income by the AO for these three flats as income from house property was not justified insofar as these flats were neither given on rent nor the assessee has intention to earn rent by letting out the flats. The flats nor sold was its stock-intrade and income arising on its sale is liable to be taxed as business income. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... closing stock of unsold flats/shops for which occupancy certificates was received by the assessee. It is noted that the AO from perusal of the balance-sheet found the inventories (unsold flats) as on 31.03.2016 was to the tune of Rs.54,41,25,101/-. On being asked, as to why the ALV of the finished properties held as stock should not be assessed under the head income from house property as per section 23 of the Act, the assessee submitted that it had received occupancy certificate of the unsold flats and shops only to the tune of Rs.20,52,53,093/- (and not Rs.54,41,25,101/- shown as inventories in balance-sheet) and pleaded that the decision of the Hon ble Delhi High Court in the case of CIT Vs. Ansal Housing and Construction (389 ITR 373) was not applicable to the facts of the case; and also cited the decision of this Tribunal in M/s. Runawal Construction Pvt. Ltd. which was based on the decision of the Hon ble Gujarat High Court in the case of CIT Vs. Neha Builders Pvt. Ltd., (296 ITR 661). However, the AO rejected the contention of the assessee and was of the opinion that the decision of the Hon ble Gujarat High Court in the case of M/s Neha Builders Pvt. Ltd. (supra) was disti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd to be subject to tax under the head profit and gains of business and profession . Here in the present case, the assessee failed to show that its business/trading operation was to earn any rental income. Therefore, the Ld. CIT(A) s reliance on the decision of the Hon ble Supreme Court in the case of M/s. Chennai Properties (supra) is misplaced. Similarly, the decision of the Hon ble Gujarat High Court in the case of M/s. Neha Properties (supra) is also not applicable to the facts of this case. In the case of M/s. Neha Properties (supra), the Hon ble Gujarat High Court did not have any occasion to decide the deemed rent (ALV) arising from unsold flats/closing stock. In that case, actual rent was received from property which was included in the closing stock and the question was whether the rental income derived from letting out of the property shown in closing stock is assessable under the head income from house property or from business income. And the Hon ble High Court held that it should be assessed as business income. Therefore, the ratio/decision of the Hon ble Gujarat High Court is distinguishable and not applicable in the facts/issue of the present case. However, on this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issue raised in ground no.1 are that, Assessee is engaged in the business of Real Estate development, leasing and management of shopping malls etc. During the course of assessment proceeding the Assessing Officer has noted that the appellant has a stock of completed units totaling to Rs. 151,13,53,919/- out of which, it has received advances in respect of properties to the extent of Rs 39,12,96,068/-. The net unsold units with the assessee in closing stock was Rs 112,00,57,852/-. The Assessing Officer relying upon the Hon‟ble Delhi High Court decision in the case of Ansal Housing Finance and Leasing Company, reported in 354 ITR 180, held that the vacant units in the possession of the appellant are liable to be charged of notional rental income under the head Income from house property‟ on the basis of their ALV. Rejecting the submissions made by the Assessee and in light of the failure of the assessee to provide the Annual Ratable Value (ALV) of the these shops and units, the Assessing Officer computed the ALV relying on certain ITAT decisions that, a return of 8.5% as rent on these properties is rational and acceptable. AO accordingly, proceeded to compute the income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wherein the Tribunal has held that if Assessee is a builder but business of the Assessee is not letting of property, then rent from unsold stock is to be assets has income from house property, after following the decision of Hon‟ble Delhi High Court in the case of CIT vs. Ansal Housing Financial and Leasing Company Ltd (Supra). He pointed out that Tribunal has also considered the decision of Gujarat High Court in the case of CIT Vs. Neha Builders Pvt. (Supra). 6. On the other hand, Learned counsel for the Assessee referred to the decision of K. Raheja Corporate Services Pvt. Ltd vs. ACIT ITA No. 7109/Mum/2018, 3862 4085/Mum/2019 order dated 25.10.2021, where in the Tribunal has referred to other decisions of this Tribunal including M/s. Osho Developers Mumbai vs. ACIT, ITA No. 2372 and 1860/Mum/2019 dated 03.11.2020. 7. We have heard the rival submissions and perused the relevant finding given in the impugned orders. The main controversy as raised in ground No.1 is, whether notional income from unsold units held as stock-in-trade can be assessed under the head, income from house property . It has been canvassed before us that, there are divergent views on this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome derived under the head of rent would also become income from the property, it accordingly allowed the appeal and directed reconsideration of the matter. 8.1 The Hon‟ble High Court, then observed and held as under; 9. From the order passed by the learned Commissioner of Income-tax 7 (Appeals), it would clearly appear that the case of the assessee was that the company was incorporated with the main object of purchase, take on lease, or acquire by sale, or let-out the buildings constructed by the assessee. The development of land or property would also be one of the businesses for which the company was incorporated . 10. True it is, that income derived from the property would always be termed as income from the property , but if the property is used as stock-in-trade , then they said property would become or par take the character of the stock, and any income, derived from the stock, would be income from the business, and not income from the property. If the business of the assessee is to construct the property and sell it or to construct and let-out the same, then that would be the business and the business stocks, which may include movable and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uses. The ancillary object was to carry on business of leasing, hire purchase, renting, selling, re-selling or otherwise dispose of all forms of movable or immovable properties and assets including buildings, godowns, warehouses and real estate of any kind. The Assessee claimed by the assessee that the flat could not be sold because of recession in the market and hence it let out the flats on license basis for temporary period and earned monthly rental income as license fees. The assessee treated the said rental income as income from the business. The authorities below have concurrently found in favor of the revenue that the rental income cannot be treated as income from business and treated it as income from house property under section 22 of the Income-tax Act. The question thus raised was whether the Tribunal is right in so concluding that the rental income is an income from house property. Hon‟ble High Court after referring to various decisions of the Hon‟ble Supreme Court held that rental income owned by the Assessee was assessable as income from house property. 11. Then, again in the case of CIT Vs. Sane Doshi Enterprises reported in (2015) 377 165 (Bomb ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on‟ble Bombay High Court same would have been assessed under the head income from house property. 15. Now, coming to the decision of Hon‟ble Delhi High Court in the case of CIT Vs. Ansal Housing Finance Leasing Company Ltd (Supra), one of the question of law referred before the Hon‟ble High Court was as under; Whether the assessee was liable to pay income tax on the annual letting value of unsold flats owned by it under the head income from house property ? 15.1 There the facts relevant to the issue raised relate to the addition on account of annual letting value (ALV) of flats, added on notional basis are that the assessee-company engages itself in the business of development of mini-townships, construction of house property, commercial and shop complexes etc. In the assessment completed for the year under consideration, the AO assessed the ALV of flats which the assessee had constructed, but were lying unsold under the head Income from house property . The assessee however, contended that the said flats were its stock-in trade and therefore the ALV of the flats could not be brought to tax under the head Income from house property . The AO ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e letting value, if the property were to be leased out in the marketplace. If the Assessee's contention were to be accepted, the levy of income tax on unoccupied houses and flats would be impermissible which clearly not the case is . 17. Though, the judgment which has been referred by the Hon‟ble Delhi High Court in the case in East India Housing Land Development Trust (Supra) , Sultan Bros and Karan Pura Development Company Ltd . (Supra) wherein, in all the cases the issue whether the rental income received from the property is to be assessed as business income or income of house property. No where, the Hon‟ble Supreme Court in any of the cases which has been referred by the Hon‟ble Delhi High Court dealt with issue of notional rental income when the property held as stock-in-trade or closing stock which has not been actually let out, is liable to be taxed as income from house property. However, be that as maybe, there is no contrary decision of any other High Court and therefore, this decision Hon‟ble Delhi High Court will have both binding and persuasive value. No direct contrary decision has been brought to our knowledge of any other High ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... plied retrospectively, then in our humble opinion it cannot be imputed that ALV of the flats held as stock in trade should be taxed on notional basis prior to AY 2018-19. Without any legislative intent or specific provision under the Act, such notional or deeming income should not be taxed as cardinal principle, because assessee is not aware that any hypothetical income is to be shown when he has not received any real or actual income. In our view of Hon‟ble Delhi High Court is too harsh an interpretation. 20. Since, even prior to the amendment, there is one High Court judgment of Hon‟ble Delhi High Court which is directly on this issue and against the Assessee, therefore same needs to be followed. Accordingly, we hold that Assessing Officer is correct in computing ALV on notional rent on unsold stock, but with following riders and directions to the AO as discussed herein after. 21. Firstly, the flats or units on which assessee has received any advance in this year or in the earlier years but has not delivered or given final possession of the said flat/unit to the buyer, then no notional rent can be charged as it tantamount to sale. Secondly, if unit of flat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e AO and direct as given at para no. 21 (supra) of the order in M/s. Inorbit Malls (supra) wherein the Tribunal has held that the AO was correct in computing ALV on deemed rent on unsold stock. However, the Tribunal directed the AO to do so by considering the following facts. Firstly, the flats or units on which assessee has received any advance in this year or in the earlier years but has not delivered or given final possession of the said flat/unit to the buyer, then no notional/deemed rent can be charged as it tantamount to sale. Secondly, if unit of flat is shown as work-in- progress in the books then also no notional rent be computed. And Lastly, the AO to estimate the ALV after ascertaining Municipal Letable Value for computing the notional rent as held by the Hon ble Bombay High Court in the case of CIT Vs. Tip Top Typography reported in 368 ITR 30 or @ 2% which was estimated by AO whichever is less. Therefore, the ground no. 3 of the revenue is partly allowed for statistical purposes. 19. In the result, the appeals filed by the revenue for AY 2013-14 AY 2014-15 dismissed, and cross-objection filed by the assessee for AY 2013-14 is allowed and Revenue appeal for AY 2016 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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