TMI Blog2024 (3) TMI 686X X X X Extracts X X X X X X X X Extracts X X X X ..... nt with the help of technical support received from Denso, Japan. Maruti does not have the necessary technology to manufacture the products. As such, the technology has been patented by the parent company of the appellant, namely Denso, Japan for which the appellant has also been paying running royalty amount for receipt of technical support. The appellant has also included the cost incurred towards preparation of detailed drawings and designs in the assessable value of the final products. The specifications provided by the Maruti were merely layout or dimensions of the desired parts or components. The appellant prepared detailed drawings and designs for alternator assembly in line with the specifications provided by Maruti. The designs prepared by the appellant contain details of various elements to be used in the manufacture of alternator assembly. It contains 23 sub-components required for manufacturing alternator assembly, which is not even referred to in the specification drawings provided by Maruti to the appellant. This would show that it is the responsibility of the appellant to design and manufacture the parts or components. Thus, the specification drawings are neither use ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt E/52247/2022, E/52252/2022, E/52258/2022, E/52297/2022, E/52248/2022, E/52254/2022, E/52267/2022, E/52298/2022, E/52249/2022, E/52255/2022, E/52268/2022, E/52299/2022, E/52250/2022, E/52256/2022, E/52273/2022, E/50004/2023, E/52251/2022, E/52257/2022, E/52296/2022, E/52389/2022, E/52413/2022, E/52432/2022, E/50044/2023, E/52390/2022, E/52414/2022, E/52433/2022, E/50055/2023, E/52391/2022, E/52415/2022, E/52434/2022, E/50056/2023, E/52392/2022, E/52416/2022, E/52435/2022, E/51271/2023, E/52393/2022, E/52417/2022, E/52436/2022, E/51272/2023, E/52394/2022, E/52418/2022, E/52437/2022, E/51273/2023, E/52395/2022, E/52420/2022, E/52438/2022, E/51274/2023, E/52396/2022, E/52421/2022, E/52439/2022, E/51275/2023, E/52397/2022, E/52422/2022, E/52440/2022, E/51276/2023, E/52398/2022, E/52423/2022, E/52441/2022, E/51277/2023, E/52399/2022, E/52424/2022, E/52442/2022, E/51729/2023, E/52400/2022, E/52425/2022, E/52443/2022, E/53920/2023, E/52407/2022, E/52426/2022, E/52444/2022, E/53921/2023, E/52408/2022, E/52428/2022, E/52445/2022, E/53922/2023, E/52409/2022, E/52429/2022, E/52470/2022, E/52410/2022, E/52430/2022, E/52471/2022, E/52412/2022, E/52431/2022, E/50028/2023, E/52406/2022, E/52411 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ble the potential vendors to properly understand the requirements and provide the best price quotations for the manufacture and supply of the desired parts or components. Once the vendor is selected and a letter of intent is issued, the vendor prepares detailed drawings and designs for the products to be supplied, corresponding to the specifications received from Maruti. The final products are then manufactured with the help of detailed drawings and designs prepared by the vendors. According to the vendors, the cost incurred by them towards the manufacturing activity includes the development cost incurred in the preparation of the detailed drawings and designs by them. 3. The department, however, believed that the cost of the specifications supplied by Maruti to the vendors free of cost should be included in the assessable value of the final products manufactured by the vendors in terms of rule 6 of the Central Excise Valuation (Determination of Price of Excisable Goods) Rules, 2000 [The 2000 Valuation Rules]. Accordingly, show cause notices were issued to the vendors. The adjudicating authority confirmed the duty demand holding that the cost of the specifications provided by Marut ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... articles (including the final products) under a licensed patent and technical information owned by Denso Corportion, Japan. In terms of the said License Agreement, the appellant paid running royalty to Denso, Japan at the rate of 3% of the net sales of licensed articles (including the final products) in lieu of receipt and use of technical support. The appellant also paid service tax on such royalty amount under the reverse charge mechanism. 9. In few cases, where alternators are to be manufactured for a new model of vehicle, third parties prepare their own drawings and designs for the necessary tooling/ dies/moulds [Moulds] manufactured and sold to the appellant. The appellant sold the moulds to Maruti and Maruti, in turn, supplied the moulds to the appellant free of cost in terms of rule 4(5)(b) of the CENVAT Credit Rules, 2004 [Credit Rules]. The appellant, thereafter, manufactured the final products with the help of detailed drawings and designs as well as the moulds (wherever required) after amortising the cost of moulds and cleared the final products to Maruti on payment of the applicable central excise duty. 10. The appellant incorporated all costs incurred towards its manu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded in the assessable value of the final products manufactured by the appellant and cleared to Maruti during the period of dispute. However, the adjudicating authority partially dropped the proposed duty demand by holding that the amount of running royalty paid by Maruti to Suzuki Motor Corporation, Japan is not includible in the assessable value of the final products, but only the amount of lump-sum royalty is includible in such assessable value as the notional cost of specifications provided by Maruti. Accordingly, partial duty demand has been confirmed against the appellant under the extended period of limitation along with interest and penalty has also been imposed equal to the duty demand. The impugned order has dropped the proposal to impose penalty on the employees of Maruti. 15. The facts of the other appeals, except five Excise Appeal No s. 52406, 52411, 52427, 52472 of 2022 and Excise Appeal No. 51985 of 2023, are more or less similar. These five Excise Appeals have been filed by traders to whom show cause notices were also issued on the assumption that they are manufacturers and excise duty has been fastened upon them. One such trader, namely, Minda D-Ten India Pvt. Ltd. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nents/parts. 20.3 ***** When such licensed information i.e, the drawings are provided to the vendors free of cost there is an element of additional consideration flowing from MSIL to the vendors which is required to be added to the assessable value of the goods manufactured by Noticees No. 1 in terms of the provisions of Section 4(1)(b) read with Rule 6 of Excise Valuation (Determination of Price of Excisable Good) Rules 2000. ***** 20.5 It has been contended by the Noticees that Sh. Anil Sahani, DGM Finance of M/s MSIL in his five voluntary statements stated that MSIL merely provided its requirement for the components to be manufactured to the vendors as it is a pre-requisite that the component must conform to the drawing/ specification provided by MSIL. I find the contention that the MSIL issues only specifications of the final product, the Internal/child parts are developed and conceptualized by Notices itself does not make any difference as the amount of R D Incurred by the Noticees on the drawing supplied by MSIL would any way is already accounted for in the assessable value of the final product. However the technical specification supplied by MSIL and cast incurred by MSIL is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ection 4(1)(b) read with Rule 6 of Central Excise Valuation (Determination of Price of Excisable Goods) Rules 2000. (emphasis supplied) 19. Shri B.L. Narasimhan, learned counsel of the appellant assisted by Shri S.C. Vaidyanathan led the arguments on behalf of the appellants and made the following submissions : (i) The entire proceedings initiated by the show cause notice which has culminated in the impugned order shows complete callousness and arbitrariness on the part of the department to somehow fasten huge duty liability on the appellant, without considering the correct factual aspects, even though pointed out at the time of investigation itself. Elaborating this submission, learned counsel pointed out that show cause notices were issued even to traders who had not even manufactured the components on the presumption that they were manufacturers and though even before the issuance of the show cause notice and also in reply to the show cause notice this factual position was pointed out but neither the show cause notice or the adjudication order deal with this aspect; (ii) The show cause notice refers to a specific purchase agreement of the year 2007, which has been enclosed as An ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... buted to the specifications supplied by Maruti; (vii) Explanation (1) to rule 6 of the 2000 Valuation Rules is analogous to rule 10(1)(b) of the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007 [The 2007 Customs Valuation Rules] [corresponding to Rule 9(1)(b) of the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988) and the true scope of the aforesaid clauses (ii) and (iv) of Explanation (1) to rule 6 of the 2000 Valuation Rules can be better understood by analysing the said provisions of the 2007 Customs Valuation Rules; (viii) The decision of the Tribunal in Commissioner of Central Excise, Jamshedpur vs. Tata Motors [2009 (237) ELT 147 (Tri.-Kolkata)] and AVTEC Ltd. vs. CCE, Indore; and AVTEC Ltd. vs. CCE, New Delhi [2017 (358) ELT 700 (Tri.-Del)] relied upon by the department are not applicable to the facts and circumstances of the case; (ix) The extended period of limitation under section 11A(4) of the Excise Act is not invokable in the present case; (x) Penalties are also not imposable under section 11AC of the Excise Act; (xi) The duty demand confirmed in respect of the vendors operating as registered dealers of excisable goods i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 22. The submissions advanced by the learned counsel for the appellants and the learned authorized representative appearing for the department have been considered. 23. The issue that arises for consideration in these appeals is whether the department is justified in demanding the differential central excise duty from the vendors by including the notional cost of specification drawings and deigns supplied free of cost by Maruti in the assessable value of parts or components of motor vehicles manufactured by the appellants and cleared to Maruti. 24. To appreciate this issue, it would be useful to refer to the relevant provisions of the Central Excise Act and the 2000 Valuation Rules. 25. Section 4 of the Central Excise Act deals with valuation of excisable goods for the purposes of charging of duty of excise and the relevant portion is reproduced below: 4. Valuation of excisable goods for purposes of charging of duty of excise- (1) Where under this Act, the duty of excise is chargeable on any excisable goods with reference to their value, then, on each removal of the goods, such value shall- (a) in a case where the goods are sold by assessee, for delivery at the time and place of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... yer free of charge or at reduced cost for use in connection with the production and sale of such goods, to the extent that such value has not been included in the price actually paid or payable, shall be treated to be the amount of money value of additional consideration flowing directly or indirectly from the buyer to the assessee in relation to sale of the goods being valued and aggregated accordingly, namely:- (i) value of materials, components, parts and similar items relatable to such goods; (ii) value of tools, dies, moulds, drawings, blue prints, technical maps and charts and similar items used in the production of such goods; (iii) value of material consumed, including packaging materials, in the production of such goods; (iv) value of engineering, development, art work, design work and plans and sketches undertaken elsewhere than in the factory of production and necessary for the production of such goods. 29. It clearly transpires from the aforesaid provisions that something can be treated as an additional consideration for sale of goods only when there exists a contract of sale or an agreement to sell between the two parties and in terms of such an agreement the buyer pay ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... anufacturer and relieves the seller-manufacturer from incurring such expenses. Thus, the expressions drawings, blue prints, technical maps and charts and similar items mentioned in clause (ii) of Explanation (1), and design work and plans and sketches mentioned in clause (iv) of Explanation (1) can only mean those drawings and designs which a manufacturer would have prepared for use in the manufacture of the product but were prepared by the buyer and supplied to such manufacturer on free of cost or at reduced cost. This is clear from the language used in clauses (ii) and (iv) of Explanation (1) to rule 6 of the 2000 Valuation Rules. It covers drawings which are used in the production of such goods and those designs which are necessary for the production of such goods. 33. The contention of the learned authorized representative appearing for the department, however, is that the drawings/designs supplied by Maruti were only and exclusively instrumental in development of the product by the appellants. Learned authorized representative also pointed out that it is not even the case of the appellant that they could have manufactured the parts or component without reference to the specifi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gs by making payment of royalty to Suzuki Maruti Corporation, Japan, the position would not change as this cannot be said to form an additional consideration for sale of parts or components. It also needs to be noted that these specification drawings provided by Maruti to the potential vendors cannot be said to be used in the production of the components or necessary for the production of the components in terms of rule 6 of the 2000 Valuation Rules. Thus, clauses (ii) or (iv) to Explanation (1) of rule 6 of the 2007 Valuation Rules cannot be invoked in the facts and circumstances of the present case. 37. At this stage, it would also be appropriate to compare Explanation (1) to rule 6 of the 2000 Valuation Rules to an analogous rule 10(1)(b) of the 2007 Customs Valuation Rules. This rule 10(1)(b) is reproduced below: 10. Cost and services (1) In determining the transaction value, there shall be added to the price actually paid or payable for the imported goods- (a) ***** (b) the value, apportioned as appropriate, of the following goods and services whether supplied directly or indirectly by the buyer free of charge or at reduced cost for use in connection with the production and sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be a part of the production process. Up to that point, each specification and instruction is more appropriately regarded as an added requirement or burden imposed upon the manufacturer, rather than a form of assistance. Otherwise expressed, these are buying costs, not costs of the seller from which he is being relieved by the buyer. (emphasis supplied) 40. The Tribunal in Mangalore Refinery Petrochemicals Ltd. vs. C.C., Mangalore [2014 (313) E.L.T. 353 (Tri. Bang.)] also held that there is a distinction between mere specifications and detailed engineering drawing. It is only the latter which is covered under rule 9(1)(b)(iv) of the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988 (which is now rule 10(1)(b)(iv) of the 2007 Customs Valuation Rules). The relevant portion of the decision of the Tribunal is reproduced below: 9.3 When a person buys a product available, off-the-shelf, he need not be concerned with the Engineering Design and services which have gone into the manufacture of such product. He has to merely order by giving the specifications. If a person wants to buy an air-conditioner, he may specify whether it should be window type or split type and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red is only in the nature of buyers assist. Cost incurred towards buyers assist cannot be included in the value of imported goods. (d) When the technical know-how and engineering services are not related to the equipment designs but are for the purpose of preparation of tender documents and for recommending for selection of the equipments the cost of the same cannot be included in the value of imported goods. (emphasis supplied) 41. The same view was taken by the Tribunal in G.E. Plastics India Ltd. vs. Commissioner of Customs, Mumbai-I [2004 (169) E.L.T. 46 (Tri. Del.)] and the observations are as follows: 6. It is the Revenue s case that the process diagram and equipment specification supplied by M/s. GE Plastics India Pvt. Ltd. BV, Netherlands were vital for the preparation of detailed engineering drawings for the manufacture of the imported equipment and that is sufficient to attract the provisions of the Rule. The Commissioner (Appeals) has noted that the enquiry documents were prepared on the basis of Basic Engineering Package. This reasoning of the Commissioner is not supported by the Rule. Rule does not take in such remote connection. The Rule permits inclusion of only engi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd suppliers shall be responsible for designing the part(s)/assembly to meet Suzuki s requirements shown in the drawing without infringing upon any third party s intellectual property rights and submit the drawing . 44. It is apparent from the aforesaid that the specifications provided by the Maruti were merely layout or dimensions of the desired parts or components. The appellant prepared detailed drawings and designs for alternator assembly in line with the specifications provided by Maruti. The designs prepared by the appellant contain details of various elements to be used in the manufacture of alternator assembly. It contains 23 sub-components required for manufacturing alternator assembly, which is not even referred to in the specification drawings provided by Maruti to the appellant. 45. The Letter of Intent issued to the appellant also states that: We are pleased to inform that you have been selected as one of our vendors for the following components. We intend placing an order on you for the design, manufacture, testing and supply of the subject component(s) for MARUTI vehicles at prices indicated below. ***** (emphasis supplied) 46. This would show that it is the responsi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned counsel for the appellants that the extended period of limitation could not have been invoked in the facts and circumstances of the present case. 52. Thus, for all the reasons stated above, all the Excise Appeals have to be allowed. The five Excise Appeals filed by traders have also to be allowed for the additional reason that in any view of the matter central excise duty could not have been levied on them. 53. In the result, the impugned orders dated 29.07.2022, 25.08.2022, 30.11.2022, 30.12.2022, 10.01.2023, 23.02.2023, 30.03.2023 and 28.04.2023 passed by the adjudicating authority deserve to be set aside and are set aside. All the Excise Appeals are, accordingly, allowed. (Order Pronounced on 12.03.2024) Cause list sl. no. Appeal No. Duty demand confirmed (in Rs.) Show Cause Notice dated Period of dispute in Appeal Period time barred Duty demand confirmed for the normal period (in Rs.) Order dated 29.07.2022 7 E/52247/2022 38,845 21.02.2019 April 2013 to June 2017 Upto January 2017 (April 2013 to January 2014 is beyond 5 years) 2,229 8 E/52248/2022 2,05,782 10.01.2020 April 2014 to June 2017 Upto June 2017 (April 2014 to December 2014 is beyond 5 years) - 9 E/52249/2022 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to December 2013 is beyond five years) 10,74,560 30 E/52394/2022 1,14,758 01.02.2019 April 2017 to June 2017 Not applicable 1,14,758 31 E/52395/2022 1,51,33,338 12.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 13,33,940 32 E/52396/2022 1,68,60,063 01.02.2019 November 2013 to June 2017 Up to December 2016 (November 2013 to December 2013 is beyond five years) 12,86,858 33 E/52397/2022 41,70,890 01.02.2019 November 2013 to June 2017 Up to December 2016 (November 2013 to December 2013 is beyond five years) 4,13,578 34 E/52398/2023 22,92,994 09.05.2019 April 2014 to June 2017 Up to March 2017 75,186 35 E/52399/2022 49,97,368 08.02.2019 November 2013 to June 2017 Up to December 2016 (November 2013 to December 2013 is beyond five years) 3,46,885 36 E/52400/2022 19,35,238 25.04.2019 November 2013 to June 2017 Up to March 2017 (November 2013 to March 2014 is beyond five years) 56,733 37 E/52406/2022 3,45,043 09.05.2019 April 2014 to June 2017 Not applicable Not applicable 38 E/52407/2022 4,59,176 27.03.2019 November 2013 to June 2017 Up to February 2017 (November 2013 to February 2014 is beyond five years) 36,672 39 E/52408/2022 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pril 2014 is beyond five years) 66,829 58 E/52427/2022 1,90,188 07.05.2019 October 2015 to June 2017 Not Applicable Not Applicable 59 E/52428/2022 2,97,236 22.05.2019 April 2014 to June 2017 Up to April 2017 (April 2014 is beyond five years) 9,536 60 E/52429/2022 49,68,377 25.01.2019 November 2013 to June 2017 Up to December 2016 (November 2013 to December 2013 is beyond five years) 4,16,136 61 E/52430/2022 5,69,222 04.02.2019 November 2013 to June 2017 Up to December 2016 (November 2013 to December 2013 is beyond five years) 62,039 62 E/52431/2022 9,68,265 09.01.2020 April 2014 to June 2017 Entirely time barred (April 2014 to November 2014 is beyond five years) Entirely time barred 63 E/52432/2022 19,69,949 10.01.2020 April 2014 to June 2017 Entirely time barred (April 2014 to November 2014 is beyond five years) Entirely time barred 64 E/52433/2022 7,74,844 12.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 63,201 65 E/52434/2022 5,74,808 18.03.2019 November 2013 to June 2017 Up to February 2017 (November 2013 to February 2014 is beyond five years) 29,238 66 E/52435/2022 2,97,464 18.02.2019 November 2013 to June 2017 Up to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to February 2017 (November 2013 to February 2014 is beyond five years) 37,365 86 E/51272/2023 3,03,973 14.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 22,190 87 E/51273/2023 6,59,513 07.05.2019 April 2014 to June 2017 Up to March 2017 25,346 88 E/51274/2023 81,14,928 21.05.2019 November 2013 to June 2017 Up to April 2017 (November 2013 to April 2014 is beyond five years) 2,39,410 89 E/51275/2023 2,69,740 11.06.2019 April 2014 to June 2017 Up to May 2017 (April 2014 to May 2014 is beyond five years) 28,746 90 E/51276/2023 16,14,111 14.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 1,51,533 91 E/51277/2023 8,12,718 14.08.2019 October 2015 to June 2017 Entirely time barred Entirely time barred 92 E/51729/2023 10,58,804 12.03.2019 April 2013 To June 2017 Up to February 2017 (April 2013 to February 2014 is beyond five years) 66,151 109 E/51985/2023 98,086 14.08.2019 April 2014 to June 2017 Not Applicable Not Applicable 167 E/53920/2023 17,16,606 16.08.2019 April 2014 to June 2017 Entirely time barred Entirely time barred 168 E/53921/2023 25,50,552 19.03.2019 Novembe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2014 to June 2017 Up to February 2017 2,84,566 115 E/52486/2023 7,90,202 (7,80,503 + 9,699) 14.02.2019 February 2014 to June 2017 Up to January 2017 80,911 116 E/52487/2023 19,21,841 (18,99,945 + 21,896) 12.02.2019 February 2014 to June 2017 Up to January 2017 1,47,304 117 E/52488/2023 1,612 10.06.2019 June 2014 to June 2017 Up to April 2017 72 118 E/52489/2023 20,98,624 (20,70 ,262 + 28,362) 14.02.2019 February 2014 to June 2017 Up to January 2017 1,15,431 119 E/52490/2023 1,14,127 (1,11,705 + 2,422) 07.03.2019 February 2014 to June 2017 Up to January 2017 9,081 120 E/52491/2023 1,86,049 16.08.2019 August 2014 to June 2017 Entirely time barred Entirely time barred 121 E/52492/2023 8,01,374 13.01.2020 January 2015 to June 2017 Entirely time barred Entirely time barred 122 E/52632/2023 77,56,201 (76,73,597 + 82,604) 11.02.2019 February 2014 to June 2017 Up to January 2017 6,75,962 123 E/52637/2023 1,73,141 (1,72,685 + 456) 08.04.2019 March 2014 to June 2017 Up to February 2017 14,747 124 E/52638/2023 2,24,603 (2,21,387 + 3,216) 19.02.2019 February 2014 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 12,398 125 E/52639/2023 4,96,499 11.09.2019 Apr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /2023 23,49,639 (23,24,304 + 25,335) 14.02.2019 February 2014 to June 2017 Up to January 2017 1,66,678 146 E/53895/2023 81,39,708 (80,46,778 + 92,930) 01.02.2019 February 2014 to June 2017 Up to December 2016 7,69,469 147 E/MISC/50543/ 2023 E/53896/2023 1,04,15,049 (1,02,24,291 + 1,90,758) 28.01.2019 January 2014 to June 2017 Up to December 2016 12,76,120 148 E/MISC/50541/ 2023 E/53897/2023 54,64,448 (54,01,970 + 62,478) 28.01.2019 January 2014 to June 2017 Up to December 2016 6,18,855 149 E/53898/2023 31,16,816 (30,84,711 + 32,105) 20.02.2019 February 2014 to June 2017 Up to January 2017 2,75,876 150 E/53899/2023 36,84,119 (36,55,337 + 28,782) 14.02.2019 February 2014 to June 2017 Up to January 2017 3,14,014 151 E/53900/2023 15,56,095 16.08.2019 August 2014 to June 2017 Entirely time barred Entirely time barred 152 E/53901/2023 22,58,708 (22,42,116 + 16,592) 28.03.2019 March 2014 to June 2017 Up to February 2017 1,26,103 153 E/53902/2023 7,58,596 14.05.2019 May 2014 to June 2017 Up to April 2017 17,733 154 E/53903/2023 8,80,309 07.05.2019 April 2014 to June 2017 Up to March 2017 72,000 155 E/53904/2023 14,78,830 20.04.2019 April 2014 to June 2017 Up to March 2017 77,161 156 E/5390 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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