9911796707
TMI Blog2024 (9) TMI 1312X X X X Extracts X X X X X X X X Extracts X X X X ..... related to assessee in any manner) recorded during the course of search conducted at his premises. Appellant prays that reopening is thus made by Id.AO on borrowed satisfaction and without independent application of mind, which is not in accordance with law and order so passed deserves to be quashed. 2. On the facts and in the circumstances of the case, the Ld. CIT(A) grossly erred in confirming the actions of Id. AO, in treating the share application money of Rs. 60,00,000/- received by assessee from various companies as undisclosed income of the assessee company arbitrarily. 2.1 That Id. CIT(A) further erred in confirming the action of Id. AO in making addition of Rs. 60,00,000/- without considering the submission made and evidence adduced. Thus the additions made solely on the basis of statement of third party, which stood retracted subsequently and without even bringing any corroborative evidence is not in accordance with law and deserves to be deleted. 2.2 That the Id. CIT(A) has grossly erred in confirming the additions, which were made by Id. AO without even providing complete statements of third party when specific requests were made before Ld. AO which were turned d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rved upon the assessee. Vide letter dated 09-03-2015 assessee submitted that the original return of income filed u/s 139(1) may be considered as return filed in response to notice u/s 148 of the IT. Act. 3.3 During the assessment proceeding ld. AR of the assessee raised objections on the re-opening of the case and also requested to provide the statement of Shri Praveen Jain, which was provided to the assessee and the rest of the objections raised was disposed by the ld. AO. 3.4 Considering the reasons so recorded the ld. AO asked the assessee to furnish various details about the share application money. The assessee vide letter dated 21.03.2016 replies to the queries raised by the ld. AO. Thereafter, the assessee was asked to show cause as to why the accommodation entries of Rs. 60,00,000/- received in the form of share application money should not be added to its income. In response the assessee filed a written response. The reply / submission of the assessee was considered by the ld. AO carefully but he considered it not found tenable and acceptable on the following grounds : "A. The payment by cheque does not make the transaction genuine. The Hon'ble ITAT, Jaipur, in the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in the order of the assessment the ld. AO held that Shri Praveen Kumar Jain has provided accommodation entry of Rs. 60,00,000/- to the assessee company though the dummy company M/s Alka Diamond Industries Ltd., Ms Anchal Properties P. Ltd., M/s Atharv Business P. Ltd. (Faststone Tred (I) Ltd, M/s Casper Enterprises P. Ltd. (Oswal Trading (I) P. Ltd.), M/s Nakshatra Business P. Lid. (Hema Trading Co. P. Ltd.), M/s Olive Overseas P. Ltd. (Realgold Trading Co. P. Ltd.) & M/s Vanguard Jewels Ltd., managed by Shri Praveen Kumar Jain. Based on these ld. AO noted that the transaction made by the assessee with the concerns owned or operated by Shri Praveen Kumar Jain are non-genuine and there are only paper transactions that took place instead of actual transaction. Therefore, the share application money of Rs. 60,00,000/- shown by the assessee is treated as diversion of profit to evade the tax liabilities. 4. Aggrieved from the order of the assessing officer, the assessee preferred an appeal before the ld. CIT(A)/NFAC. Apropos to the grounds so raised the relevant finding of the ld. CIT(A)/NFAC is reiterated here in below: 7. As per the facts noted in the assessment order, AO come in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed the credit by furnishing his own bank account showing the credit entries, by furnishing certificate (from a private practicing company secretary) reflecting active status of the 7 companies as on 31.07.2017 and the share application money was converted into allotted shares to the 7 investors and by pointing out that the 7 companies continued to be shareholders till 31.07.2017. However, the fact remains that the 7 investor companies were in the business of providing accommodation entries of various types and Shri. Pravin Kumar Jain had provided accommodation entries to various beneficiaries from the said companies as well as many other companies controlled by him and many beneficiaries had admitted the fact when confronted by the Income Tax Department. Moreover, the financials of the assessee do not have anything to invite/attract an independent person to invest in the assessee company. In view of these facts, I find that AO was justified in treating the amount of Rs. 60,00,000/- as undisclosed income of the assessee. Accordingly, the addition made on that account is confirmed. 9. In view of the above, the grounds of appeal stand dealt with and are dismissed." 5. As the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rred a present appeal before the Hon'ble Bench. Grounds of Appeal Nos. 1: In these grounds of appeal, assessee has challenged the reopening of assessment u/s 147 of the Income tax Act, solely on the basis of information received from the DGIT (Inv.) Mumbai. Facts pertaining to the grounds of appeal are that the case of assessee was reopened on the basis of following information: "Reasons for the belief that income has escaped assessment The assessee M/s Padmawati Agrico (India) Pvt. Ltd. filed its Return of income for AY 2010-11 on 25.09.2010 declaring total income as Nil. The return was processed u/s 143(1) on 28.04.2011. As per the information available on record, it is found that the assessee has received accommodation entries from Sh. Praveen Kumar Jain, in whose case search was conducted at Mumbai by investigation wing. Shri Praveen Kumar Jain admitted in his statement recorded u/s 132(4) of the I.T. Act, 1961 that he provided accommodation entries in the form of bogus share application money. After examination of the facts available on record, I found that in case of M/s Padmawati Agrico(India) Pvt. Ltd. following accommodation entries in the Loan of bogus share ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... B 22-23) primarily objecting to recording of reasons done in a mechanical manner, i.e. on discussion of general information and modus operandi of entry providers and not specifically mentioning as to how transaction of assessee was also accommodation entry & how funds have been routed for such alleged accommodation entry. Also, neither statements recorded nor any such information wherein name of assessee was appearing was supplied to the assessee. It is further relevant to state that ld. AO disposed-off the objection raised by assessee vide notice dated 22.02.2016 (APB 24-26) in mechanical manner, wherein ld.AO straightaway solely relied upon the information received from Investigation wing and repeated the same. It simply shows that Ld.AO himself was not sure while forming his belief for re-opening, as to whether there was actually escapement of Income or not. On perusal of aforesaid para, it is relevant that ld.AO formed belief regarding escapement of income solely on the basis of information supplied by investigation wing and without cross verifying the same/making enquiries as to how transaction of assessee was also accommodation entry/how funds have been routed for such al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ding his own independent satisfaction deserves to be held illegal. In this regard reliance is placed on the decision of Hon'ble Delhi High court in case of Sarthak Securities Co. Pvt. Ltd. Vs. ITO reported in 329 ITR 110 wherein it has been held as under: Reassessment - Notice - Condition precedent - Formation of belief that income escaped assessment - Assessing Officer treating share application money as bogus accommodation entries - Payments through banking channel and companies investing money genuine - No independent application of mind by Assessing Officer but acting under information from investigation wing - Notice to be quashed - Income Tax Act, 1961, ss. 147, 148. Uma Strips Ltd. vs DCIT 3284/Del/2019 decision dated 11.05.2022 (Delhi ITAT) (decision para reproduced): 9. From the above, we find that there is no live link presented by the AO between the material available with him i.e. the report of the investigation and to reason to belief that the assessee has tried to evade the assessment for the particular year in question. Simply stating and doubting that the assessee is involved in obtaining accommodation entries without providing proof, reason, information to ba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat assessee had taken accommodation entries from 'H' during relevant year when assessee, in course of original assessment proceedings, had supplied all relevant details; in assessment order which were verified and moreover, in reasons supplied to assessee there was no allegation that it had failed to disclose fully and truly all material facts necessary for assessment and because of its failure there had been an escapement of income chargeable to tax, reopening of assessment after expiry of four years from end of relevant assessment year was without jurisdiction. It is further relevant to state that ld. CIT(A) during the course of appellate proceedings without adjudicating on the legal ground and solely on the basis of information of third party confirmed the additions made by ld. AO. Thus In the circumstances it is submitted that there was no independent application of mind neither by Ld. AO while issuing notice u/s 148 nor by ld. CIT(A) while passing the order. They simply proceeded on borrowed satisfaction formed by some other officials on the basis of survey conducted and statements recorded in the case of third party, the same has no evidentiary value, therefore, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ding receipts of share application money from the above parties before the Ld. AO as well as Ld. CIT(A) details of which are summarized as under- 1. Copy of documentary evidences to prove identity, creditworthiness and genuineness of M/s Alka Diamond Ind. Ltd. a. Copy of Share application form 60-61 b. Copy of Board Resolution 62-63 c. Copy of PAN Card 64 d. Copy of Bank Statement 65 e. Copy of ITR for A.Y. 2009-10 & 2010-11 66-67 f. Copy of company master data as on 31.03.2009 & 31..03.2015 68-69 g. Copy of Confirmations & Affidavit 70-73 2. Copy of documentary evidences to prove identity, creditworthiness and genuineness of M/s Anchal Properties Pvt. Ltd. a. Copy of Share application form 74-75 b. Copy of Board Resolution 76-77 c. Copy of PAN Card 78 d. Copy of Bank Statement 79 e. Copy of ITR for A.Y. 2009-10 & 2010-11 80-81 f. Copy of company master data as on 31.03.2009 & 31..03.2015 82-83 g. Copy of Confirmations & Affidavit 84-87 3. Copy of documentary evidences to prove identity, creditworthiness and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Confirmations & Affidavit 158-160 At this juncture, provisions of section 68 are reproduced for the sake of convenience: "68. Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the [Assessing] Officer, satisfactory, the sum so credited may be charged to income-tax as the income of the assessee of that previous year Provided that where the assessee is a company (not being a company in which the public are substantially interested), and the sum so credited consists of share application money, share capital, share premium or any such amount by whatever name called, any explanation offered by such assessee-company shall be deemed to be not satisfactory, unless- (a) the person, being a resident in whose name such credit is recorded in the books of such company also offers an explanation about the nature and source of such sum so credited; and (b) such explanation in the opinion of the Assessing Officer aforesaid has been found to be satisfactory" It is further relevant to state that First Proviso to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd assessing them to tax in accordance with law. It does not entitle the Revenue to add the same to the assessee's income as unexplained cash credit." Further reliance is being place on the decision of Hon'ble Bombay High Court (Nagpur Bench) in the case of Principal Commissioner of Income Tax vs. M/s Apeak Infotech and Ors. reported in 397 ITR 148, wherein it is held as under- "8. Regarding Question B: (a) We find ........................................................................ ....... (b) It is further pertinent to note that the definition of income as provided under section 2(24) of the Act at the relevant time did not define as income any consideration received for issue of share in excess of its fair market value. This came into the statute only with effect from April 1, 2013 and thus, would have, no application to the share premium received by the respondent-assessee in the previous year relevant to the assessment year 2012-13. Similarly, the amendment to section 68 of the Act by addition of proviso was made subsequent to previous year relevant to the subject assessment year 2012-13 and cannot be invoked. It may be pointed out that this court in CIT v. Gag ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... acquired the money deposited with him. Hon'ble jurisdictional High Court has held that merely because the depositors' explanation about the sources of money was not acceptable to the AO, it cannot be presumed that the deposit made by the creditors is money belonging to the assessee itself. (ii) Genuineness of Transaction:- The assessee has filed confirmation letter along with affidavit of the investors. The assessee also filed copy of account statement of cash credit where the amount of payment is reflected in bank statement. (iii) Capacity proved:- The assessee has also filed copy of bank statement of the investors which shows huge number of transaction of high value. There is no onus on the assessee to prove source of source. Once the assessee is able to establish that he has in fact received money from third party, it can't be burdened with a further onus of establishing the source from which such third party had been able to obtain the money. Reliance is placed on the following decisions: - a. 24 Tax World 146 Sideways Investment Pvt. Ltd. Vs DCIT (JP ITAT) b. 87 ITR 349 CIT Vs. Daulat Ram Rawatmal (SC) c. 103 ITR 344 Saraogi Credit Corp. Vs. CIT (PAT) It is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he entire addition was made solely on the basis of conjectures and surmises and theory of probability. In the appellate proceeding all these were brought to the notice of the Ld. CIT(A) who has summarily rejected the claim of the assessee and evidences brought on record by the assessee by observing as under in para 8 of the order: "The details of the compliance of the assessee in appeal proceedings, have already been described above in this appeal order. It has been contended that assessee has proved the credit by furnishing his own bank account showing the credit entries, by furnishing certificate (from a private practicing company secretary) reflecting active status of the 7 companies as on 31.07.2017 and the share application money was converted into allotted shares to the 7 investors and by pointing out that the 7 companies continued to be shareholders till 31.07.2017. However, the fact remains that the 7 investor companies were in the business of providing accommodation entries of various types and shri. Pravin Kumar Jain had provided accommodation entries to various beneficiaries from the said companies as well as many other companies controlled by him and many beneficiar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 216 CTR 195 and has not even discussed the same in his order which squarely applicable in the present case as the assessee has filed the necessary confirmation and other particulars of share holders and incidentally all the subscribers are Private Limited Companies and the appellant had received the application money through banking channel. It was further held that the Hon'ble Chhattisgarh High Court in the case of ACIT Vs. Venkateshwar Ispat (P) Ltd. Reported in 319 ITR 393 had held as under:- "In the matters of CIT V/s. Lovely Exports (supra), the question before the Hon'ble Supreme Court was whether the amount of share money can be regarded as undisclosed income u/s 68 of the Act? Answering the above question, the Hon'ble Supreme Court has held that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the AO, then the Department is free to proceed to reopen their individual assessments in accordance with law, but if cannot be regarded as undisclosed income of the assessee company." In case of the assessee, the assessee has not only given the names and addresses of the shareholders but has also given ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of assessee to prove whether that person itself has invested said money or some other person had made investment in the name of that person. The burden then shifts on Revenue to establish that such investment has come from assessee-company itself. - CIT Vs. Shree Barkha Synthetics Ltd. (2003) 270 ITR (Raj.) 477 followed. 2. 126 ITR 48 Yadu Hari Dalmia Vs. CIT (Delhi) Income from undisclosed sources - Expenditure not accounted for - Can be estimated and treated as income from undisclosed sources - Correctness of estimate is question of fact and degree - Absence of direct evidence does not preclude assessment by inference and estimate - Duty of ITO to make exhaustive enquiries and gather some material as basis - Estimate without details may not be accepted - I.T. Act, 1961, ss. 68, 69, 69A, 69B, 69C. 3. 100 ITTD 5 (Jodh.) (T.M.) Uma Polymers (P) Ltd. Vs. DCIT, Sp. Range Section 68 of the Income Tax Act, 1961 - Cash credits - Assessment year 1989-90 - Whether distinction between a public and a private limited company is not very material, as far as introduction of share capital money is concerned - Held, yes - Whether in respect of share application money received from invest ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d under section 68 and added it to income of assessee - On appeal, Commissioner (Appeals) deleted addition - On revenue's appeal to Tribunal, assessee showed that 111 deposits of Rs. 19,000/- each in cash were made in bank account of 'D' Ltd. which were converted into drafts and in this manner 'D' Ltd. subscribed to share capital of assessee company - Whether, on facts, it was not for assessee- company to prove as to source from where 'D' Ltd. collected aforesaid money - Held, yes - Whether it was for Assessing Officer to inquire into affairs of 'D' Ltd. which was an independent company inasmuch as no finding was arrived at by Assessing Officer that two companies were umbrella companies or had any relationship with each other - Held, yes - Whether in view of aforesaid, impugned order passed by Tribunal deleting addition was to be upheld - Held, yes. In light of the contentions raised above, supported with the relevant case-laws, it is most humbly submitted that the addition of Rs. 60,00,000/- on account of treating the share application money received from various companies as undisclosed income of assessee, despite of fact that assessee company duly substantiated its claim with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R for A.Y. 2009-10 & 2010-11 80-81 f. Copy of company master data as on 31.03.2009 & 31..03.2015 82-83 g. Copy of Confirmations & Affidavit 84-87 14. Copy of documentary evidences to prove identity, creditworthiness and genuineness of M/s Athrav Business Pvt. Ltd a. Copy of Share application form 88-89 b. Copy of Board Resolution 90-91 c. Copy of PAN Card 92-93 d. Copy of Bank Statement 94 e. Copy of ITR for A.Y. 2009-10 & 2010-11 95-96 f. Copy of company master data as on 31.03.2009 & 31..03.2015 97-98 g. Copy of Confirmations & Affidavit 99-102 15. Copy of documentary evidences to prove identity, creditworthiness and genuineness of M/s Casper Enterprises Pvt. Ltd. a. Copy of Share application form 103-104 b. Copy of Board Resolution 105-106 c. Copy of PAN Card 107 d. Copy of Bank Statement 108 e. Copy of ITR for A.Y. 2009-10 & 2010-11 109-110 f. Copy of company master data as on 31.03.2009 & 31..03.2015 111-112 g. Copy of Confirmations & Affidavit 113-116 16. Copy of documentary evidences to prove id ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rt in the case of PCIT vs Meenakshi Overseas Pvt Ltd reported in 82 taxmann.com 300 31-40 5. Copy of order passed by Hon'ble Bombay High Court in the case of Commissioner of Income Tax vs M/s. Gagandeep Infrastructure Pvt. Ltd. reported in 394 ITR 680 41-47 6. Copy of order passed by Hon'ble Bombay High Court in the case of PCIT vs Apeak Infotech and Ors reported in 397 ITR 148 48-57 7. The ld. AR of the assessee stated that the re-opening done in this case is based on the borrowed satisfaction and there is no finding of the ld. AO in the reasons recorded that in fact the income has escaped the assessment. In support of this contention the ld. AR of the assessee relied upon the decision of the Hon'ble Gujarat High Court in the case of Seth Brothers vs. CIT 169 CTR 519. Revenue while re-opening the cash relied upon the statement of Shri Praveen Kumar Jain which has been retracted by him by filling the affidavit on 15.05.2014 (APB-17-21). As is evident from the retraction statement the whole basis of re-opening of the case does not exist. In support of this contention, he relied upon the decision of the PCIT Vs. RMG Polyvinyl (I) Ltd. 83 taxmann.com 348 (Delhi) and PCIT Vs. M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y the assessee. The ld. DR relying on the observation of AO at para 3.9 stated that at the premises of Shri Praveen Kumar Jain compute hard disc, PEN drive and tally data which contain the books of accounts of these companies. In addition the cheque book, and the detail of various middlemen have been found recorded. Thus, the retraction statement made by the Shri Praveen Kumar Jain will not change the facts. The ld. DR also relied upon the decision of M/s. Kanchwala Gems Vs. JCIT wherein it was held that merely cheque payment is not sufficient to establish the genuineness of the transaction. Assessee was provided the relied upon the statement of Shri Praveen Kumar Jain the based on the decision of the Swati Bajaj it is not necessary to provide the cross examination to the assessee. The ld. DR also rely on the statement of the brother-in-law of Shri Praveen Kumar Jain who has also confirmed the facts. So, the re-opening in the case is based on the cogent material available on record and the addition is based on the detailed statement of Shri Praveen Kumar Jain which is based on the evidence found at his premises. Based on these arguments he relied upon the findings recorded in the o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion money received from various companies as undisclosed income of assessee. All these grounds are related to the merits of the case and the same were contended together decided together. The dispute relates to the fact that during the year under consideration assessee company has received alleged accommodation entries in the form of share application money from the following companies which are allegedly controlled/managed by the Shri Praveen Kumar Jain :- Sl. No. Name of party Amount Ch./DD No. & date Assessee's A/c no. & Branch Name 1 M/s Alka Diamond Ind. Ltd. 5,00,000/- RTGS dt.17.08.2009 Account No. 61073593863 Kishangarh ND. Area (10746) State Bank of Bikaner & Jaipur (APB 43-44) 2 M/s Anchal Properties P. Ltd. 5,00,000/- RTGS dt.17.08.2009 3. M/s Atharv Business P. Ltd. (Faststone Tred (I) Ltd.) 5,00,000/- RTGS dt.17.08.2009 4. M/s Casper Enterprises P. Ltd. (Oswal Trading (1) P. Ltd. 20,00,000/- RTGS dt.10.08.2009 5. M/s Nakshatra Business P. Ltd. (Hema Trading Co. P. Ltd.) 10,00,000/- RTGS dt.20.08.2009 6. M/s Olive Overseas P. Ltd. (Realgold Trading Co. P. Ltd.) 10,00,000/- RTGS dt.20.08.2009 7. M/s Vanguard Jewels Ltd. 5,00,000/- RTGS d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o offers an explanation about the nature and source of such sum so credited; and (b) such explanation in the opinion of the Assessing Officer aforesaid has been found to be satisfactory" Here it is worthwhile to note that First Proviso to Section 68 wherein addition on account of Share Application Money / Share Capital can be made, stood inserted to the statue book, by Finance Act 2012, w.e.f. 01.04.2013 and therefore that addition made by ld. AO on account of Share Application Money u/s 68 for the year under consideration is not in accordance with law and it is made without considering the provision of law stood related to the year under consideration. The relied upon by the assessee the facts of the case of the assessee being similar with the case of decision of Hon'ble Bombay High Court in the case of Commissioner of Income Tax - 1 vs. M/s Gagandeep Infrastructure Pvt. Ltd. reported in 394 ITR 680, wherein court held that; "(e) We find that the proviso to Section 68 of the Act has been introduced by the Finance Act 2012 with effect from 1st April, 2013. Thus it would be effective only from the Assessment Year 2013-14 onwards and not for the subject Assessment Year. In fact, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and source of credits but also supported the same with documentary evidences in the shape of PAN, ITRs, Confirmations, Affidavit, Share Application Form, Board Resolution and Bank Statement of the different investor. All these records so placed on record were not at all dealt with so as to doubt the same by ld. AO but all such vital evidences have been ignored solely on the basis of recorded statements of third party recorded by some other officials during the course of search & survey operation conducted in that case. Whereas the assessee has already discharged his initial onus laid down u/s 68 of Income Tax Act. By proving the 3 main ingredients of share application money as under:- (iv) Identity:- The identity of investors stood proven as details of PAN card along with ITR's and copies of bank statement and other documentary evidence already shared. (v) Genuineness of Transaction:- The assessee has filed confirmation letter along with affidavit of the investors. The assessee also filed copy of account statement of cash credit where the amount of payment is reflected in bank statement. (vi) Capacity proved:- The assessee has also filed copy of bank statement of the i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ailing and the evidence placed on record by the assessee. We get support of our view from the decision of apex court in the case of M/s Lovely Exports Pvt. Ltd. reported in 216 CTR 195. This view also further accepted and expanded by the Hon'ble Chhattisgarh High Court in the case of ACIT Vs. Venkateshwar Ispat (P) Ltd. Reported in 319 ITR 393 wherein it has been held that; "In the matters of CIT V/s. Lovely Exports (supra), the question before the Hon'ble Supreme Court was whether the amount of share money can be regarded as undisclosed income u/s 68 of the Act? Answering the above question, the Hon'ble Supreme Court has held that if the share application money is received by the assessee company from alleged bogus shareholders, whose names are given to the AO, then the Department is free to proceed to reopen their individual assessments in accordance with law, but if cannot be regarded as undisclosed income of the assessee company." As we have noted here in above that the assessee has not only given the names and addresses of the shareholders but has also given their PANs. Further assessee to prove genuineness of the transaction also submitted the Share Application form, Board ..... X X X X Extracts X X X X X X X X Extracts X X X X
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