9911796707
TMI Blog2025 (5) TMI 900X X X X Extracts X X X X X X X X Extracts X X X X ..... 82, PHASE II RIICO INDUSTRIAL AREA PO NEWAI, NEWAI, TONK - 304021, Rajasthan (hereinafter "the applicant") is fit to pronounce advance ruling as they have deposited prescribed Fee under CGST Act and it falls under the ambit of the Section 97 (2) given as under: (a) classification of goods and/or services or both (g) whether any particular thing done by the applicant with respect to any goods and/or services or both amounts to or results in a supply of goods and/or services or both, within the meaning of that term A. SUBMISSION OF THE APPLICANT (in brief) :- Brief facts of the case : 1.1 M/s. Kamal Coach Works Private Limited [hereinafter referred to as "Applicant"] is a private limited company incorporated under the Indian Company Law and has its head office located at SP 282, Phase II, RIICO Industrial Area, Newai, Tonk, Rajasthan, 304 021, and its additional place of business located at RIICO Industrial Area Sitapura, E 523, Near Chatrala Circle, Jaipur, Rajasthan - 302 022. 1.2 The Applicant is engaged in the business of supplying job work services towards fabrication and attachment of Body of various commercial vehicles such as Tipper Trucks, Bus etc., and various types ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ocal unit of Tata Motor are enclosed as Annexure-3 and Annexure-4 respectively. 1 * The scope of the processing to be undertaken by the Applicant is to fabricate and attach the tipper body to the vehicle. The said attachment is being done by the Applicant on/ to the chassis of the unfinished vehicle provided by Customer. The Tippers on which the Applicant performs its job work activity are unfinished vehicles such as 'Signa 2830.TK BSVI' and others as the requirement maybe from time to time. * For attaching the tipper body, the Applicant procures the required goods for developing the 'tipper body'. Given the standard size of the tipper body, the tipper body is already developed by the Applicant even without the physical presence of chassis. The different types of 'tipper body' manufactured by the Applicant including '24 Cube Box Body Tipper', '16 Box Body Tipper' etc. * The Applicant procures all the goods required for developing the 'tipper body' on his own account from the approved vendors of the Customer to ensure the quality of goods. The Applicant deploys its own experienced manpower and utilises its own machinery in order to carry out the fabrication and attaching the ' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CGST Act, 2017 defines job work as 'any treatment or process undertaken by a person on goods belonging to another registered person'. The one who does the said job would be termed as 'job worker'. The ownership of the goods does not transfer to the job-worker but it rests with the principal. The job-worker is required to carry out the process specified by the principal, on the goods." 2. Circular No. 38/12/2018-GST dated 26.03.2018 "5. Scope / ambit of job work: ... Further, it is clarified that the job worker, in addition to the goods received from the principal, can use his own goods for .providing the services of job work." - 3. Circular No. 52/26/2018-GST, dated 09.08.2018 "12.3 In the above context, it is hereby clarified that in case as mentioned at Para 12.2 (a) above, the supply made is that of bus, and accordingly supply would attract GST @ 28%. In the case as mentioned at Para 12.2(b) above, fabrication of body on chassis provided by the principal (not on account of body builder), the supply would merit classification as service, and 18% GST as applicable will be charged accordingly." * Further, there is a plethora of GST Advance Rulings pronounced by various Sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 2 (68) "job work" means any treatment or process undertaken by a person on goods belonging to another registered person and the expression "job worker" shall be construed accordingly." ... Emphasis Supplied * In view of the above definition, job work can be understood as performance or carrying out of any activity or treatment or work done by one person on the goods, which belongs to another person. * In view of the definition under Section 2 (68) of the CGST Act, the essential characteristics or test of job work can be understood as below: * There is some treatment or process done. * The treatment or process is done on goods. * The goods must belong to the person other than the person ['principal'] who undertakes the treatment or process. * The person who undertakes the treatment or process is the job-worker. * It is submitted that the term 'treatment' or 'process' is not defined under the CGST Act or Rules. The dictionary meaning of the said terms is mentioned below as: Merriam Webster Law Dictionary "Process" a series of actions or operations conducing to an end especially a continuous operation or treatment especially in manufacture "Treatment" ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity qualify as 'process' or 'treatment' done by the Applicant on goods belonging to Tata Motors. * In light of the above, the activity performed by the Applicant duly qualify as 'job work' in terms of Section 2 (68) of the CGST Act. * The Applicant also rely upon the clarifications issued by the CBIC as below: C.B.E.C. Flyer No. 27 dated 01.01.2018 "What is Job work? Section 2 (68) of the CGST Act, 2017 defines job work as 'any treatment or process undertaken by a person on goods belonging to another registered person'. The one who does the said job would be termed as 'job worker'. The ownership of the goods does not transfer to the job-worker but it rests with the principal. The job-worker is required to carry out the process specified by the principal, on the goods." * As the Applicant is performing the process which is specified by Tata Motors on the goods of Tata Motors, the present activity qualify as job work in line with the above clarification. * It is further submitted that merely because the Applicant is using its own goods which are getting consumed in the processing carried out on the goods of Tata Motors does not change the characteristic of the present a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tatute. Strictly one has to look to the language used; there is no room for searching intendment nor drawing any presumption. Furthermore, nothing has to be read into nor should anything be implied other than essential inferences while considering a taxation statute." ... Emphasis Supplied * The Applicant also relies on the decisions of Hon'ble Supreme Court in the cases of Hemraj Gordhandas [1978 (2) E.L.T. (J 350) (S.C.)] and Ajmera Housing Corporation &Anr. Etc. [2010 (8) SCC 739] wherein the Court categorically held that strict interpretation is required while interpreting a tax statute. * The Applicant further relies upon the 'Principles of Statutory Interpretation-15th Edition' By G.P. Singh [Pg. 39] wherein the settled principle of strict interpretation is highlighted as below: "When a language is plain and unambiguous and admits of only one meaning no question of construction of a statue arises, for the Act speaks for itself." .... As stated by Gajendra gadkar J: " If the words used are capable of one construction only then it would not be open to the courts to adopt any other hypothetical construction on the ground that such hypothetical construction is more con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsideration. * Further, the term 'services' is defined under Section 2 (102) of the CGST Act as anything other than goods. Hence, the definition and scope of 'services' is very wide to include any activity or work performed by any person. * In this regard, we refer to the definition of 'services' as defined under Section 65B (44) of the erstwhile Finance Act, 1994 ['service tax'] which means any activity carried out by one person for another for consideration. Therefore, the activity performed by the Applicant by way of fabricating and attaching the tipper body [with painting] to the chassis tantamount to "services" under Section 2 (102) of the CGST Act. * The Applicant is undertaking the above activity against consideration received from Tata Motors and hence it is submitted that the Applicant is engaged in supplying the services as per Section 7 (1) (a) of the CGST Act. * The Applicant also submits that as per Section 7 (1A) of the CGST Act, certain supplies shall be treated as either 'supply of goods' or 'supply of services' as listed in Schedule II of the CGST Act. The relevant provision reads as below: "Section 7 (1A) where certain activities or transactions constitu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as per the Explanatory Notes to the scheme of classification of "services" issued by the CBIC reads as below: "9988 Manufacturing services on physical inputs owned by others The services included under Heading 9988 are performed on physical inputs owned by units other than the units providing the service. As such, they are characterized as outsourced portions of a manufacturing process or a complete outsourced manufacturing process. Since this Heading covers manufacturing services, the output is not owned by the unit providing this service. Therefore, the value of the services in this Heading is based on the service fee paid, not the value of the goods manufactured. 99888 Transport equipment manufacturing services 998881 Motor vehicle and trailer manufacturing services This service code includes motor vehicle manufacturing services, trailers and semi-trailer manufacturing services and motor vehicle parts and accessories manufacturing services." * The above Explanation clarifies that any service which is used in the course of manufacturing of motor vehicles can be classified under the tariff heading 9988. Hence the above Explanation also supports the case of the Applican ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... troduction of the above-referred Explanation in Rate Entry 26 (i) (ic) vide Amendment Notification No. 26/2019-Central Tax (Rate) dated 22.11.2019. * The GST Council has proposed GST rate change in respect of job work related services and, in this context, the GST Council examined, this issue in detail and decided that the job work services in relation to Body Building shall remain unchanged at 18%, thereby clarifying the position that body building is a job work service to attract 18% GST. The relevant part of the minutes of GST Council Meeting is as below: "B. In respect of GST Rate on Services, the Council decided as follows: a. In respect of the Annexure IV of Agenda item 8, recommending changes in the GST rate of the Services or for issuance of clarifications in relation of Services: i. The Council approved the Fitment Committee recommendations in respect of SI. No 1 and 2 of the Annexure IV. The Council recommended to reduce rate of GST from 5% to 1.5% on supply of job work services in relation to diamonds and to reduce rate of GST from 18% to 12% on supply of all job work services which are not currently eligible for 5% rate, such as in engineering industry, except s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... chassis. The Applicant is merely undertaking the body building activity on the chassis owned by Tata Motors. Hence, applying the above Circular, the present supply of services shall attract 18% GST. * The Applicant submits that the Advance Ruling Authorities of different States have categorically held that the body building activity shall attract GST @ 18% in line with the above Circular and the Applicant relies upon the rulings cited below. State Case Name Citation Gujarat AB N Dhruv Autocraft (India) Pvt. Ltd. 2020 (9) TMI 689 Vasant Fabricators Pvt. Ltd. 2022 (4) TMI 1340 Hasmukh lal Jivanlal Patel 2022 (9) TMI 201 Karnataka SLN Tech-Fabs (Bengaluru) Pvt. Ltd. 2020 (1) TMI 791 Kerala New Grand Auto Body Works 2022 (10) TMI 862 Kondody Autocraft (India) Pvt. Ltd. 2019 (4) TMI 110 M/s. CC Fabs 2021 (7) TMI 481 Sri. Puthusseri kudy Thankappan Santhosh, M/S. Oyester Auto Body 2022 (10) TMI 866 Shri. Aromal Manoj, M/S. Aromal Autocraft 2023 (7) TMI 522 Madhya Pradesh Rohan Coach Builders 2019 (7) TMI 41 Sanghi Brothers (Indore) Private Limited 2019 (7) TMI 45 Punjab Raj Agro Aids (Pushkar RJ Si ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... form a cube shaped tipper body as per the desired specifications along with a hydraulic cylinder. 6. The attachment of the tipper body on/ to the chassis is through a welding process and it also include attachment through usage of nuts and bolts. The above attachment to the chassis is not easily detachable. Thereafter, the Applicant performs the painting job on the 'tipper body'. Post attachment process, the fully built vehicle is dispatched to Customer. 7. The customers of the Applicant include vehicle manufacturing companies such as Tata Motors Ltd. ['Tata Motors'] and in some cases dealers of the vehicles and in few cases even the individual customers. 8. The Applicant charges its consideration for the supply of its services to Tata Motors by raising GST invoice. The Applicant presently treats the supply as supply of 'body' being goods and uses the tariff heading 8707 and discharges GST @ 28% on a conservative basis to avoid any tax dispute. SUBMISSIONS A. THE ACTIVITY UNDERTAKEN BY THE APPLICANT WOULD QUALIFY AS 'JOB WORK' AS PER THE PROVISIONS OF SECTION 2 (68) OF THE CGST ACT A.1 The term 'job work' is defined in Section 2 (68) of the CGST Act. In view of the definition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o qualify under the purview of "job work" and the same is explained as below: * The unfinished vehicles are transferred from the premises of Tata Motors to the premises of the Applicant on Free of Cost basis. * Hence, the unfinished vehicles which are movable objects clearly qualify as 'goods' under Section 2 (52) of the CGST Act. * The ownership of the Chassis remains with Tata Motors at all time. * Hence, the activity performed by the Applicant is on goods belonging to another person namely, Tata Motors. * The Applicant had engaged its manpower and machinery for carrying out the fabricating, attaching and painting the 'tipper body' on/ to the chassis to convert the chassis into a complete Tipper Truck. The abovesaid activity qualify as 'process' or 'treatment' done by the Applicant on goods belonging to Tata Motors. A.6 The Applicant, therefore, submits that the activity performed by the Applicant duly qualify as 'job work' in terms of Section 2 (68) of the CGST Act. A.7 In this regard, the Applicant also relies upon the clarifications issued by the CBIC as below: C.B.E.C. Flyer No. 27 dated 01.01.2018 "What is Job work? Section 2 (68) of the CGST Act, 2017 defi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fied by the CBIC vide Circular No. 52/26/2018-GST, dated 09.08.2018 and the relevant extract of the said Circular is as under: 12.1 Applicable GST rate for bus body building activity : Representations have been received seeking clarifications on GST rates on the activity of bus body building. The doubts have arisen on account of the fact that while GST applicable on job work services is 18%, the supply of motor vehicles attracts GST @ 28%. 12.2 Buses [motor vehicles for the transport of ten or more persons, including the driver] fall under headings 8702 and attract 28% GST. Further, chassis fitted with engines [8705] and whole bodies (including cabs) for buses [8707] also attract 28% GST. In this context, it is mentioned that the services of bus body fabrication on job work basis attracts 18% GST on such service. Thus, fabrication of buses may involve the following two situations : (a) Bus body builder builds a bus, working on the chassis owned by him and supplies the built-up bus to the customer, and charges the customer for the value of the bus. (b) Bus body builder builds body on chassis provided by the principal for body building, and charges fabrication charges (includ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s in relation to diamonds and to reduce rate of GST from 18% to 12% on supply of all job work services which are not currently eligible for 5% rate, such as in engineering industry, except supply of job work in relation to bus body building which would remain at 18%." A.15 Further, there are plethora of Rulings pronounced by the Hon'ble Advance Ruling Authorities of various States holding that the activity of fabricating and attaching body [including tipper body] to the chassis, owned by vehicle manufacturer will qualify as job work service. Gist of the rulings holding this position is as below: State Case Name Citation Rajasthan M/s. Jeet & Jeet Glass And Chemicals Pvt. Ltd 2021 (1) TMI 1097 Gujarat Vasant Fabricators Pvt. Ltd. 2022 (4) TMI 1340 AB N Dhruv Autocraft (India) Pvt. Ltd. 2020 (9) TMI 689 Hasmukh lal Jivanlal Patel 2022 (9) TMI 201 Karnataka SLN Tech-Fabs (Bengaluru) Pvt. Ltd. 2020 (1) TMI 791 Kerala New Grand Auto Body Works 2022 (10) TMI 862 Kondody Autocraft (India) Pvt. Ltd. 2019 (4) TMI 110 M/s. CC Fabs 2021 (7) TMI 481 Sri. Puthusseri kudy Thankappan Santhosh, M/S. Oyester Auto Body 2022 (1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed 28.06.2017 ['hereinafter referred to as 'GST Rate Notification'] wherein, the services by way of job work in relation to bus body building has been classified under Heading 9988 [Manufacturing services on physical inputs (goods) owned by others]. The relevant entry reads as below: -. SI.No. Chapter, Section or Heading Description of Service Rate (%) Condition 26 Heading 9988 (Manufacturing services on physical inputs (goods) owned by others) (i) (ic) Services by way of job work in relation to bus body building; Explanation - For the purposes of this entry, the term "bus body building" shall include building of body on chassis of any vehicle falling under chapter 87 in the First Schedule to the Customs Tariff Act, 1975. 9 Note: The above Explanation was introduced on the basis of 37th GST Council Recommendation and Notified vide Amendment Notification No. 26/2019-Central Tax (Rate) dated 22.11.2019. B.5 Further, as per the Explanatory Notes to the scheme of classification of "services" issued by the CBIC reads as below: "9988 Manufacturing services on physical inputs owned by others The services included under Heading 9988 are performed on physical inpu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... C. QUESTIONS ON WHICH THE ADVANCE RULING IS SOUGHT: Question No 1: In view of the above facts and circumstances, whether the activity undertaken by the Applicant would qualify as 'job work' as per the provisions of Section 2 (68) of the CGST Act? Question No 2: In view of the above facts and circumstances, whether the activity undertaken by the Applicant would qualify as 'supply of service' under Section 7 (1A) read with Para 3 of Schedule-Il of the CGST Act? Question No 3: In view of the above facts and circumstances, what is the tariff classification of the supply made by the Applicant and the applicable rate of GST on the said supply? D. COMMENTS OF THE JURISDICTIONAL OFFICER: - Comments received from Assistant Commissioner, DIVISION-H Sector-10; Vidhyadhar Nagar, Jaipur vide letter C. No: V(GST-H)/30/02/Misc Report/01/2024-25/1340 dated 31.12.2024are as under: '1) In view of the above facts and circumstances, whether the activity undertaken by the Applicant would qualify as "job work" as per the provision of Section 2 (68) of the CGST Act? 2) In view of the above facts and circumstances, whether the activity undertaken by the Applicant would qualify as ' supply of serv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tariff classification of the supply made by the Applicant and the applicable rate of GST on the said supply? Ministry of Finance has issued clarification in Circular No. 52/26/2018-GST dated 09.08.2018, regarding applicability of GST on various goods and services. The relevant portion of the Circular stated supra, is as under. "12.1 Applicable GST rate for bus body building activity: Representations have been received seeking clarifications on GST rates on the activity of bus body building. The doubts have arise non account of the fact that while GST applicable on job work services is 18%, the supply of motor vehicles attracts GST @ 28%. 12.2 Buses [motor vehicles for the transport of ten or more persons, including the driver] fall under headings 8702 and attract 28% GST. Further, chassis fitted with engines [8705] and whole bodies (including cabs) for buses [8707] also attract 28% GST. In this context, it is mentioned that the services of bus body fabrication on job work basis attracts 18% GST on such service. Thus, fabrication of buses may involve the following two situations: a) Bus body builder builds a bus, working on the chassis,owned by him and supplies the built-up ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to develop the 'tipper body', alloy steel sheets, pipes, angles, etc. are cut and bend in respective size to fabricate the body and thereafter adjoined together through the welding process to form a cube shaped tipper body as per the desired specifications along with a hydraulic cylinder. 4. Given the above scenario, the applicant submitted in their view, their process of manufacturing tipper body and mounting on vehicle provided by their customer amounts to job work process and the activity undertaken by them would qualify as 'supply of service' classifiable under SAC 9988-Manufacturing services on physical inputs owned by others, and GST would be charged on the same @18%. They have sought advance ruling on the given supply, as summarized in the following questions :- Question No 1: In view of the above facts and circumstances, whether the activity undertaken by the Applicant would qualify as 'job work' as per the provisions of Section 2 (68) of the CGST Act? Question No 2: In view of the above facts and circumstances, whether the activity undertaken by the Applicant would qualify as 'supply of service' under Section 7 (1A) read with Para 3 of Schedule-Il of the CGST Act? ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , their customer is Tata Motors Ltd, which must be a GST registered person. 5.5 The sub-section 1A of Section 7 of the CGST Act, 2017 provides the scope of supply differentiating supply of goods and services as follow as :- (1A) where certain activities or transactions constitute a supply in accordance with the provisions of sub-section (1), they shall be treated either as supply of goods or supply of services as referred to in Schedule II. 5.6 Further, Schedule Il provides the list of activities or transactions to be treated as supply of goods or supply of services. The para 3 of the Schedule II provides that, :- (3) Treatment or process Any treatment or process which is applied to another person's goods is a supply of services. In the instant case, the applicant is undertaking process or treatment on goods belonging to another person, therefore, the activities undertaken by the applicant are clearly falls under scope of 'supply of services'. 5.7 I find that the classification and rate of tax to be charged on activity of bus body building has been clarified by the CBIC vide Circular No. 52/26/2018-GST, dated 09.08.2018 and the relevant extract of the said Circular is as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ould be supply of goods. On the other hand, if the company builds the body on the chassis belonging to some else, it would be supply of services. 5.9 Once, I find that the process undertaken by the applicant amounts to job work and fit for classifiable under 'supply. of services', now coming to classification of services, the Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017 provides that the services by way of job work in relation to bus body building has been classified under Heading 9988 [Manufacturing services on physical inputs (goods) owned by others]. Further vide Notification No. 26/2019-CT(Rate) dated 22.11.2019, an explanation was inserted to the entry Heading 9988 [Manufacturing services on physical inputs (goods) owned by others], so that "Bus body building" covers building of body on chassis of any vehicle falling under chapter 87. The relevant entry reads as below: SI.No. Chapter, Section or Heading Description of Service Rate (%) Condition 26 Heading 9988 (Manufacturing services on physical inputs (goods) owned by others) (i) (ic) Services by way of job work in relation to bus body building; Explanation - For the purposes of this entry, the term ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ipper-body along with hydraulic-cylinder and supply of services i.e. fabrication/mounting of tipper body on the chassis supplied by the customer. Now, classification of this composite supply, as goods or service would depend on which supply is the principal supply which is to be determined on the basis of facts and circumstances of the present case .. 6.3 Further, Principal supply has been defined under Section 2 (90) of the CGST/SGST Act, 2017, as under: "principal supply" means the supply of goods or services which constitutes the predominant element of a composite supply, and to which any other supply forming part of that composite supply is ancillary; From the above definition of principal supply, it is clear that in the present case there is a principal supply of goods or services which constitutes the predominant element of a composite supply. The predominant element of the composite supply is to be determined on the basis of facts and circumstances of the present case. Now, classification of this composite supply, as goods or service would depend on which supply is the principal supply which is also to be determined on the basis of facts and circumstances of the present ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der the HSN 9988. 6.7 It will be relevant to go through carefully the CBIC Circular No. 52/26/2018-GST dated 9th August, 2018, relevant para 12 is reproduced here: 12.1 Applicable GST rate for bus body building activity: Representations have been received seeking clarifications on GST rates on the activity of bus body building. The doubts have arisen on account of the fact that while GST applicable on job work services is 18%, the supply of motor vehicles attracts GST @ 28%. 12.2 Buses [motor vehicles for the transport of ten or more persons, including the driver] fall under headings 8702 and attract 28% GST. Further, chassis fitted with engines [8705] and whole bodies (including cabs) for buses [8707] also attract 28% GST. In this context, it is mentioned that the services of bus body fabrication on job work basis attracts 18% GST on such service. Thus, fabrication of buses may involve the following two situations: (a) Bus body builder builds a bus, working on the chassis owned by him and supplies the built-up bus to the customer, and charges the customer for the value of the bus. (b) Bus body builder builds body on chassis provided by the principal for body building, and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 38000RBPF4. The nature of the transactions and classification of supply is correctly understood by the applicant as supply of goods i.e. motor body and being charged @ 28%. 6.8 Here, I differ from the view of respected member Central tax as in the instant case, it is the chassis which is supplied by the customer and in fact no treatment or process is undertaken by the applicant (i.e. tipper body builder) on the chassis itself, except fabrication/mounting of tipper body on the same. At the same time, applicant involves use of raw materials/inputs etc for manufacture/fabrication/mounting of tipper body and the cost of these inputs etc., do form the part of value which is being charged by the applicant from the customer. Thus, it emerges that the customer whether a dealer or an agent is providing only chassis. All inputs/materials required for fabrication of tipper body, has to be used by the applicant (i.e. tipper body builder) from its own account. Under such situation, it is the tipper-body which is being fabricated and also being mounted on the chassis provided by the customer. Therefore, it is not merely job-work rather it is supply of tipper body and the activity of fitting/f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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