Budget - Finance Bill 2023 The new post of Joint Commissioner (Appeals) and related procedures will delay disposal of appeals instead new officers can be appointed / promoted in rank of CIT(A) with policy decision for disposal of small appeals by junior CIT(A).

[DEV KUMAR KOTHARI]

Budget - Finance Bill 2023

The new post of Joint Commissioner (Appeals) and related procedures will delay disposal of appeals instead new officers can be appointed / promoted  in rank of CIT(A) with policy decision for disposal of small appeals by  junior CIT(A).

Author feels  that it is  not necessary to create a new post or authority with more than one designation (JCIT(A) and Addl CIT(A).  100 new officers could be appointed / promoted  with designation of Commissioner (Appeals). And an administrative policy decision could  be taken to the effect that  small matters will be assigned to newly appointed / junior CIT(A).  Small cases can be defined to mean where disputed additions / tax demand is below certain limit say Rs. one crore. Instead of orders passed by or under instructions of senior officers like JCIT/ Addl CIT.

Complexity of tax laws – even for providing one more authority so many amendments are required – why not to attempt to simplify law – creation of new post is avoidable. New officers in rank of  CIT(A) can be appointed and vide an internal   administrative order / policy decisions  small appeals can be assigned to newly appointed/ junior  officers  holding the same post CIT(A).

The complexity of law- an example:

Complexity of tax laws is well known. This can be well illustrated by a look on budget proposals for appointment of Joint Commissioner (Appeals). In the Finance Bill and notes thereon  in search within document we find 75 results for joint commissioner. On reading of provision it is found that in search result some places are not captured for example amendment of S.295 vide clause 122 is not captured in search. Similarly some provisions concerns new authority also  but they are not captured in search of ‘joint commissioner’, because there is no mention of Joint Commissioner in some of consequential amendment.

In search with ‘additional Commissioner’ we find only three results all  of which  concerns  definition clause and there is no mention in any of  consequential amendments

With search of Joint Commissioner (Appeals ) 54 results are found.

In the newly inserted definition vide clause 28CA of S.2 Joint Commissioner (Appeals) has been given meaning  as follows:

‘(28CA) “Joint Commissioner (Appeals)” means a person appointed to be a Joint Commissioner of Income[1]tax (Appeals) or an Additional Commissioner of Income[1]tax (Appeals) under sub-section (1) of section 117;’;

In the Budget Speech of honorable Finance Minister also we find mention of two designations  as follows in para 141 of speech  

          To reduce the pendency of appeals at Commissioner level, I propose to deploy about 100 Joint Commissioners for disposal of small appeals.

In paragraph  E2 . under heading and table E  IMPROVING COMPLIANCE AND TAX ADMINISTRATION To expedite the disposal of certain appeals pending with Commissioner (Appeals), it is proposed to introduce a new authority in the rank of Joint Commissioner/ Additional Commissioner [JCIT(Appeals)],

At the  end of Explanatory  Memorandum relevant clauses numbering 28  of the FB concerning Joint Commissioner (Appeals) are indicated as follows:

11. These amendments will take effect from the lst day of April, 2023.

 [Clauses 3, 60, 61, 62, 64, 65, 73, 75, 76, 78, 79, 98, 99, 100, 101, 102, 103, 104, 107, 109, 110, 111, 112, 115, 117, 120, 121 & 122

This shows the complexity of law even in respect of a mid-level authority proposed to be appointed.

In past we have faced lot of litigation due to different designation used for same ranking officers.

This is likely to delay in disposal of appeals presently  pending before CIT(A). Because as usual , there will be tendency and  approach to keep  appeals pending  ( which is presently prevailing) because of apprehension about Appeals which  can be transferred to Joint Commissioner.

During last more than one year we have experienced that many  appeals are fixed again and again, although appellant / assessee has filed all explanations and documents and relied on the same. Ld.CIT(A) has not even requisitioned any more documents or a remand report from AO meaning thereby that appeal can be disposed of but it is kept pending may be in hope of  PHYSICAL HEARING AND ACHHE DIN of meeting appellants and their representatives as against face less appeals.

Appeals before Joint Commissioner (Appeals)

As per speech of FM small appeals will be decided by JC (A). There is no definition of small appeals. However proposed amendment in S.246 we find that it is intended to mean appeal against appealable  order passed by an authority below the rank of JCIT/ Addl CIT.

New appeals in such small cases can be filed by assessee/ appellant before JCIT. In case of pending appeals before CIT(A) the Board / designated authority will review and  may order to transfer small appeals to JC(A). It seems discretionary and not compulsory to transfer such appeal and they can still be disposed off by CIT(A), if not transferred.

A new scheme is also intended to be introduced regarding appeals to be decided by JC (A).

So there are  and there will be many hurdles and speed breakers in process of disposal of appeals by JC(A).

Author feels  that it is  not necessary to create a new post or authority with more than one designation (JCIT(A) and Addl CIT(A).  100 new officers could be appointed with designation of Commissioner (Appeals). And an administrative policy decision could  be taken to the effect that  small matters will be assigned to newly appointed / junior CIT(A).

Due to complexity of provision requiring amendment in so many sections and vide so many clause it is likely that in future question will arise and litigation will take place about authority and jurisdiction of Joint Commissioner (Appeals)  and  Additional  Commissioner (Appeals) vis a vis Commissioner (Appeals)

In an attempt to understand the significance of proposed new authority the following are reproduced with high lights and observations  added by the author:

From Budget   speech:

Appeals

141. To reduce the pendency of appeals at Commissioner level, I propose to deploy about 100 Joint Commissioners for disposal of small appeals. We shall also be more selective in taking up cases for scrutiny of returns already received this year.

E. IMPROVING COMPLIANCE AND TAX ADMINISTRATION

E.2 To expedite the disposal of certain appeals pending with Commissioner (Appeals), it is proposed to introduce a new authority in the rank of Joint Commissioner/ Additional Commissioner [JCIT(Appeals)], for appeals against certain orders passed by or with the approval of an authority below the rank of Joint Commissioner. Certain related and consequential amendments are also proposed in this regard.

Finance Bill 2023 - Proposals relating to proposed authority Joint Commissioner (Appeals):

3. In section 2 of the Income-tax Act,––

(a) in clause (19B), the words and brackets “or an Additional Commissioner of Income-tax (Appeals)” shall be omitted;

(c) after clause (28C), the following clause shall be inserted, namely:–– ‘(28CA) “Joint Commissioner (Appeals)” means a person appointed to be a Joint Commissioner of Income[1]tax (Appeals) or an Additional Commissioner of Income[1]tax (Appeals) under sub-section (1) of section 117;’;

Per  author the above clauses one omitting and another inserting Addl CIT  are contradictory. Vide clause 3 (a) an Additional Commissioner of Income-tax (Appeals)” shall be omitted, and vide clause 3 (c)  Additional Commissioner of Income[1]tax (Appeals) is inserted.

Amendment of section 116.

60. In section 116 of the Income-tax Act, in clause (cca), after the words “Joint Commissioners of Income-tax”, the words and brackets “or Joint Commissioners of Income-tax (Appeals)” shall be inserted.

Observations in this and all other consequential amendments we do not find ‘Additional Commissioner (Appeals).

Amendment of section 131

62. In section 131 of the Income-tax Act, for the words and brackets “, Commissioner (Appeals)”, the words and brackets “, Joint Commissioner (Appeals), Commissioner (Appeals)” shall be substituted.

Amendment of section 133.

64. In section 133 of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)” wherever they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Observations:  in many of consequential amendments similar changes are made.

Amendment of section 134.

65. In section 134 of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)” at both the places where they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Observations:  in many of consequential amendments similar changes are made.

Amendment of section 154.

73. In section 154 of the Income-tax Act, in sub-section (2), in clause (b), for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Observations:  in many of consequential amendments similar changes are made.

Amendment of section 158A.

75. In section 158A of the Income-tax Act, in the Explanation, for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Observations:  in many of consequential amendments similar changes are made.

Amendment of section 158AB

76. In section 158AB of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)” wherever they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Observations:  in many of consequential amendments similar changes are made.

Amendment of section 177

78. In section 177 of the Income-tax Act, in sub-section (2), for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Observations:  in many of consequential amendments similar changes are made.

Amendment of section 189.

79. In section 189 of the Income-tax Act, in sub-section (2), for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Observations:  in many of consequential amendments similar changes are made.

Amendment of Chapter XX.

98. In Chapter XX of Income-tax Act,–– (a) for the sub-heading “A.––Appeals to the Deputy Commissioner (Appeals) and Commissioner (Appeals)”, the sub-heading “A.––Appeals to the Joint Commissioner (Appeals) and Commissioner (Appeals)” shall be substituted;

Observations:  in many of consequential amendments similar changes are made.

 (b) for section 246, the following section shall be substituted, namely:––

Appealable orders before Joint Commissioner (Appeals).

‘246. (1) Any assessee aggrieved by any of the following orders of an Assessing Officer (below the rank of Joint Commissioner) may appeal to the Joint Commissioner (Appeals) against-

(a) an order being an intimation under sub-section (1) of section 143, where the assessee objects to the making of adjustments, or any order of assessment under sub-section (3) of section 143 or section 144, where the assessee objects to the amount of income assessed, or to the amount of tax determined, or to the amount of loss computed, or to the status under which he is assessed;

(b) an order of assessment, reassessment or recomputation under section 147; (c) an order being an intimation under sub[1]section (1) of section 200A; (d) an order under section 201; (e) an order being an intimation under sub-section (6A) of section 206C; (f) an order under sub-section (1) of section 206CB; (g) an order imposing a penalty under Chapter XXI; and (h) an order under section 154 or section 155 amending any of the orders mentioned in clauses (a) to (g):

 Provided that no appeal shall be filed before the Joint Commissioner (Appeals) if an order referred to in this sub-section is passed by or with the prior approval of, an income-tax authority above the rank of Deputy Commissioner.

(2) Where any appeal filed against an order referred to in sub-section (1) is pending before the Commissioner (Appeals), the Board or an income-tax authority so authorised by the Board in this regard, may transfer such appeal and any matter arising out of or connected with such appeal and which is so pending, to the Joint Commissioner (Appeals) who may proceed with such appeal or matter, from the stage at which it was before, it was so transferred.

(4) Where an appeal is transferred under the provisions of sub-section (2) or sub-section (3), the appellant shall be given an opportunity of being reheard.

 (5) For the purposes of disposal of appeal by the Joint Commissioner (Appeals), the Central Government may make a scheme, by notification in the Official Gazette, so as to dispose of appeals in an expedient manner with transparency and accountability, by eliminating the interface between the Joint Commissioner (Appeals) and the appellant, in the course of appellate proceedings to the extent technologically feasible and direct that any of the provisions of this Act relating to jurisdiction and procedure for disposal of appeals by the Joint Commissioner (Appeals), shall not apply or shall apply with such exceptions, modifications and adaptations as may be specified in the notification.

 (6) For the purposes of sub-section (1), the Board may specify that the provisions of that sub-section shall not apply to any case or any class of cases.

Explanation.-For the purposes of this section, “status” means the category under which the assessee is assessed as “individual”, “Hinduundivided family” and so on.’.

Amendment of section 249.

99. In section 249 of the Income-tax Act,–– (a) in sub-section (1), in the opening portion, after the figures, letters and words “1st day of October, 1998”, the words, brackets, figures and letters “or to the Joint Commissioner (Appeals) on or after the 1st day of April, 2023,” shall be inserted;

(b) in sub-section (3), for the words and brackets “Commissioner (Appeals)”, the words and brackets “Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted;

(c) in sub-section (4), in the proviso, for the words and brackets “Commissioner (Appeals)”, the words and brackets “Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 250.

100. In section 250 of the Income-tax Act,––

(a) in sub-sections (1), (3), (4), (5), (6) and (7), for the words and brackets “Commissioner (Appeals)” wherever they occur, the words and brackets “Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted;

(b) for sub-section (6A), the following sub-section shall be substituted, namely:––

“(6A) In every appeal, the Joint Commissioner (Appeals) or the Commissioner (Appeals), as the case may be, where it is possible, may hear and decide such appeal within a period of one year from the end of the financial year in which such appeal is filed before him under sub[1]section (1) or transferred to him under sub-section (2) or sub-section (3) of section 246 or filed before him under sub-section (1) of section 246A, as the case may be.”;

(c) in sub-section (6C), after the proviso, the following proviso shall be inserted and shall be deemed to have been inserted with effect from the 1st day of April, 2022, namely:–

“Provided further that the Central Government may amend any direction, issued under this sub-section on or before the 31st day of March, 2022, by notification in the Official Gazette.”.

Amendment of section 251.

101. In section 251 of the Income-tax Act,––

(i) for the marginal heading, the following marginal heading “Powers of the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted;

(ii) after sub-section (1), the following sub-section shall be inserted, namely:––

“(1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers-

(a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment; (b) in an appeal against an order imposing a penalty, he may confirm or cancel such order or vary it so as either to enhance or to reduce the penalty; (c) in any other case, he may pass such orders in the appeal as he thinks fit.”;

(iii) in sub-section (2), for the words and brackets “Commissioner (Appeals)”, the words and brackets “Joint Commissioner (Appeals) or the Commissioner (Appeals), as the case may be,” shall be substituted;

(iv) in the Explanation,––

(a) for the words and brackets “an appeal, the Commissioner (Appeals),”, the words and brackets “an appeal, the Joint Commissioner (Appeals) or the Commissioner (Appeals),” shall be substituted;

(b) for the words and brackets “raised before the Commissioner (Appeals)”, the words and brackets “raised before the Joint Commissioner (Appeals) or the Commissioner (Appeals), as the case may be,” shall be substituted.

Amendment of section 253

102. In section 253 of the Income-tax Act,––

(a) in sub-section (1),––

(A) in clause (a), after the word, figures and letter “section 271A,”, the words, figures and letters “section 271AAB, section 271AAC, section 271AAD,” shall be inserted;

(B) after clause (a), the following clause shall be inserted, namely:––

“(aa) an order passed by a Joint Commissioner (Appeals) under section 154, section 250, section 270A, section 271, section 271A, section 271AAC, section 271AAD or section 271J; or”;

(C) for clause (c), the following clause shall be substituted, namely:––

“(c) an order passed by,––

(i) a Principal Commissioner or Commissioner under section 12AA or section 12AB or under clause (vi) of sub-section (5) of section 80G or under section 263 or under section 270A or under section 271 or under section 272A or an order passed by him under section 154 amending any such order; or

(ii) a Principal Chief Commissioner or Chief Commissioner or a Principal Director General or Director General or a Principal Director or Director under section 263 or under section 272A or an order passed by him under section 154 amending any such order; or”;

(b) in sub-section (2), for the words and brackets “Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted;

(c) in sub-section (4),––

(i) for the words and brackets “against the order of the Commissioner (Appeals)”, the words “against an order” shall be substituted;

(ii) for the words and brackets “any part of the order of the Commissioner (Appeals)”, the words “any part of such order” shall be substituted.

Amendment of section 264.

103. In section 264 of the Income-tax Act, in sub-section (4), for the words and brackets “the Commissioner (Appeals)” wherever they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 267.

104. In section 267 of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 270A.

107. In section 270A of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)” wherever they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 270AA.

108. In section 270AA of the Income-tax Act, in sub-section (6), after the words “No appeal under”, the words and figures “section 246 or” shall be inserted.

Amendment of section 271.

109. In section 271 of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)” wherever they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 271A.

110. In section 271A of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 271AAC.

111. In section 271AAC of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 271AAD.

112. In section 271AAD of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)” at both the places where they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 271J.

115. In section 271J of the Income-tax Act, for the words and brackets “the Commissioner (Appeals)” at both the places where they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

Amendment of section 275.

117. In section 275 of the Income-tax Act,––

(a) for the words and brackets “the Commissioner (Appeals)” wherever they occur, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted;

(b) for the words and brackets “to the Commissioner (Appeals)” wherever they occur, the words and brackets “to the Joint Commissioner (Appeals) or to the Commissioner (Appeals)” shall be substituted.

Amendment of section 279.

120. In section 279 of the Income-tax Act, in sub-section (1), for the words and brackets “or Commissioner (Appeals)”, the words and brackets “or Joint Commissioner (Appeals) or Commissioner (Appeals)” shall be substituted.

Amendment of section 287.

121. In section 287 of the Income-tax Act, in sub-section (2), for the words and brackets “to the Commissioner (Appeals)”, the words and brackets “to the Joint Commissioner (Appeals) or to the Commissioner (Appeals)” shall be substituted.

Amendment of section 295.

122. In section 295 of the Income-tax Act, in sub-section (2),

(i) in clause (eec), after the word “audit”, the words “or inventory valuation” shall be inserted;

(ii) in clause (mm), for the words and brackets “the Commissioner (Appeals)”, the words and brackets “the Joint Commissioner (Appeals) or the Commissioner (Appeals)” shall be substituted.

From Memorandum

Introduction of the authority of Joint Commissioner (Appeals) As per the current scheme for appeals under the Act, the first appellate authority for an assessee aggrieved by any order issued under the Act is the Commissioner (Appeals). Such Commissioner (Appeals) has the powers to confirm, reduce, enhance or annul/ cancel an order of assessment or an order of penalty, after providing an opportunity of being heard to the assessee and the AO. The order passed by the Commissioner (Appeals) are appealable before the Appellate Tribunal. 2. It has been noted that as the first authority for appeal, Commissioner (Appeals) are currently overburdened due to the huge number of appeals and the pendency being carried forward every year. In order to clear this bottleneck, a new authority for appeals is being proposed to be created at Joint Commissioner/ Additional Commissioner level to handle certain class of cases involving small amount of disputed demand. Such authority has all powers, responsibilities and accountability similar to that of Commissioner (Appeals) with respect to the procedure for disposal of appeals. 3. The earlier section 246 was providing for the appeal functions of Deputy Commissioner (Appeals). That institution was discontinued in the year 2000. Accordingly, it is proposed  to substitute section 246 of the Act to provide for appeals to be filed before Joint Commissioner (Appeals). Sub-section (1) of the proposed section seeks to provide that any assessee aggrieved by any of the following orders of an Assessing Officer (below the rank of Joint Commissioner) may appeal to the Joint Commissioner (Appeals) against- (i) an order being an intimation under sub-section (1) of section 143, where the assessee objects to the making of adjustments, or any order of assessment under sub-section (3) of section 143 or section 144, where the assessee objects to the amount of income assessed, or to the amount of tax determined, or to the amount of loss computed, or to the status under which he is assessed; (ii) an order of assessment, reassessment or re-computation under section 147; (iii) an order being an intimation under sub-section (1) of section 200A; (iv)an order under section 201; (v) an order being an intimation under sub-section (6A) of section 206C; (vi)an order under sub-section (1) of section of section 206CB; (vii) an order imposing a penalty under Chapter XXI; and (viii) an order under section 154 or section 155 amending any of the orders mentioned in (i) to (vii) above:

2. It is proposed to insert a proviso under sub-section (1) that an appeal cannot be filed before the Joint Commissioner (Appeals) where an order referred to under this sub-section is passed by or with the approval of an income-tax authority above the rank of Deputy Commissioner

3. Sub-section (2) of the proposed section seeks to provide that where any appeal filed against an order referred to in sub-section (1) is pending before the Commissioner (Appeals), the Board or an income-tax authority so authorised by the Board in this regard, may transfer such appeal and any matter arising out of or connected with such appeal and which is so pending, to the Joint Commissioner (Appeals) who may proceed with such appeal or matter, from the stage at which it was before it was so transferred. This will enable transfer of certain existing appeals filed before the Commissioner (Appeals) to the Joint Commissioner (Appeals)

4. Sub-section (3) of the proposed section seeks to provide that notwithstanding anything contained in sub-section (1) or sub-section (2), the Board or an income-tax authority so authorised by the Board in this regard, may transfer any appeal which is pending before a Joint Commissioner (Appeals) and any matter arising out of or connected with such appeal and which is so pending, to the Commissioner (Appeals) who may proceed with such appeal or matter, from the stage at which it was before it was so transferred.

5. Sub-section (4) of the proposed section seeks to provide that where an appeal is transferred under the provisions of sub-section (2) or sub-section (3), the appellant shall be provided an opportunity of being reheard

6. Sub-section (5) of the proposed section seeks to provide that for the purposes of disposal of appeal by the Joint Commissioner (Appeals), the Central Government may make a Scheme, by notification in the Official Gazette, so as to dispose appeals in an expedient manner with transparency and accountability by eliminating the interface between the Joint Commissioner (Appeals) and the appellant in the course of appellate proceedings to the extent technologically feasible and direct that any of the provisions of this Act relating to jurisdiction and procedure for disposal of appeals by Joint Commissioner (Appeals) shall not apply or shall apply with such exceptions, modifications and adaptations as may be specified in the notification.

7. Sub-section (6) of the proposed section seeks to provide that for the purposes of sub[1]section (1), the Board may specify that the provisions of that sub-section shall not apply to any case or any class of cases.

8. It is also proposed to insert an Explanation in this section to define “status” to mean the category under which the assessee is assessed as "individual", "Hindu undivided family" and so on.

9. It is also proposed to amend section 2 of the Act by inserting a definition for Joint Commissioner (Appeals) and to amend section 116 of the Act to make Joint Commissioner (Appeals) an income-tax authority under the Act.

10. Further, consequential amendments are proposed in relevant provisions of the Act in order to ensure that functioning of the Joint Commissioner (Appeals) is aligned with that of the Commissioner (Appeals).

11. These amendments will take effect from the lst day of April, 2023.

[Clauses 3, 60, 61, 62, 64, 65, 73, 75, 76, 78, 79, 98, 99, 100, 101, 102, 103, 104, 107, 109, 110, 111, 112, 115, 117, 120, 121 & 122