9911796707
TMI Blog2011 (3) TMI 1426X X X X Extracts X X X X X X X X Extracts X X X X ..... be upheld because the Tribunal by its order dt. 8th Nov., 2002 has merely held the assessment order for asst. yr. 1985-86 as invalid on the ground that since sale deed was executed on 1st Feb., 1982, the capital gain can be assessed in asst. yr. 1982-83 and not in asst. yr. 1985-86. It is thus evident that the Tribunal without final determination of valuation of the land and the capital gain thereon, simply deleted such addition for the asst. yr. 1985-86. It cannot therefore be said to have given finality to valuation of land submitted by the transferor. Amount received as service charges - So far as assessee is concerned, said amount was receivable as service charges from construction company in question in the previous year relevant to assessment order under reference. - There is no reason to hold that it was not includible in assessee's income. The allowance or disallowance of the same in the hands of the payer is of no relevance in deciding the taxability of the same in the hands of the recipient. The present matter does not fall in any of five categories enumerated in para 52 above and, therefore, we answer all the four questions of law enumerated in para 6 of this j ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... said land. The agreement to sell was executed on 2nd Oct., 1974 for sale of said land by M/s Jai Marwar Co. (P) Ltd. to appellant. According to the agreement, land was agreed to be sold @ Rs. 8 per sq. yd. A sum of Rs. 10,101 was paid in advance towards sale consideration. Balance sale consideration was agreed to be paid within 120 days. A stipulation however was made in the agreement to sell that in case of non-payment of rest amount within 120 days, the rate of the land would be increased by Re. 1 per sq. yd. per year. However, on 18th Aug., 1980 a substituted agreement was executed revising the amount. Eventually the sale deed was executed and presented for registration on 1st Feb., 1982 but it could be registered only on 27th July, 1984. Delay in execution of sale deed is attributed to restrictions placed by Rajasthan Urban Property (Restriction of Transfer) Act, 1973. The agreement to sell was approved by Urban Ceiling Authority vide order dt. 7th July, 1981. The Addl. Collector (Stamps and Registration), Jodhpur, however, did not approve the claim of reduction of Rs. 1,00,000 claimed by appellant-assessee on account of levelling and other expenses and registered the sale deed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Revenue, and Shri Shiv Charan Gupta for intervener. 8. Shri N.M. Ranka, learned senior counsel for assessee, has argued that Competent Authority illegally initiated acquisition proceedings under Chapter XX-A of the Act of 1961 by issuing notice under s. 269D of the Act of 1961. In fact, the notice was never served on the appellant-assessee. Copy of notice dt. 15th March, 1985 was served on Shri Bhanwar Lal Goyal, a member of the executive committee of the appellant-Samiti on 13th June, 1986. Whereas the same notice was served on the transferor in March, 1986. The notice was defective because it did not contain description of land with its total area and boundary. Mere mention that land was situated near Ratanada, Circuit House, Jodhpur, was vague, ambiguous and insufficient, it did not contain full and complete address of transferor and transferee. The notice is only reproduction of language of provisions contained in s. 269D. The Competent Authority did not care to strike out either of two words "and/or" and has lifted the same from the statute book. This shows total non-application of mind in as much as vagueness and uncertainty as to which of two reasons should prevail. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... compliance of provisions contained in s. 269D(2)(a) and (b) of the Act of 1961. There was also non-compliance of r. 48E of the IT Rules, 1962 because substance of notice was not affixed at conspicuous place in said locality. Statutory requirements contained in s. 269D(2)(a) and (b) are also absent. When the appellant applied for inspection of record, it was denied. The appellant was merely provided with copy of "Aam Suchna" (public notice) dt. 25th Oct., 1985. 12. Shri N.M. Ranka, learned senior counsel for appellant, argued that agreement that was entered into between parties was bona fide and genuine wherein they agreed for increase of rate of sale consideration by Re. 1 per sq. yd. for each passing year. There was no material on which Competent Authority could infer evasion of tax or understatement of value of sale consideration. No assessment of tax has been made in the hands of the transferor. The value adopted for the purpose of capital gain is sufficient evidence for the market price. learned counsel argued that in this connection the value recorded and accepted by registering authority is the correct index. The Revenue failed to prove to the contrary. Heavy burden lay o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , they have to be completed expeditiously without any delay and without negligence and inaction on the part of Competent Authority. The legislature purposely inserted such proviso in s. 269UD under Chapter XX-C of the Act of 1961 for providing two months. Revenue has not given any satisfactory explanation for this enormous delay of 17 years. The acquisition proceedings under Chapter XX-A should be informed of expediency. While provisions of s. 269J provide for payment of apparent sale consideration for transfer + 15 per cent of the said amount by way of compensation but s. 269J(1) of the Act does not provide for payment of any interest or damages on account of delay on the part of Competent Authority. The plea set up by Revenue that acquisition proceedings could not be finalized earlier because separate proceedings for acquiring this land under ceiling law were pending is totally irrelevant. It was argued that the Supreme Court in Government of India vs. Citadel Fine Pharmaceuticals and Ors. (1990) 184 ITR 467 (SC) observed that every authority has to exercise its power within a reasonable period and whenever a question regarding inordinate delay is raised, it would be open to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd unreasonable basis. He did not base his valuation on sale instances of similar land with similar dispute. Those plots were situated at some distance and were of very small size admeasuring between 207 to 240 sq. yds. whereas the land in dispute was a big chunk of land. 17. It is argued that observations made by Competent Authority are contrary to material on record. This Court stayed proceedings pending before Competent Authority under urban ceiling law by order dt. 16th Dec., 1985. There was no stay on acquisition proceedings or any other proceedings under any other law or Act except ceiling law. There was then no reason to keep acquisition proceedings under Chapter XX-A in abeyance for such a long period. Observations made by the Tribunal on this aspect in para 38 of the judgment are contrary to the material on record. In para 40 of the judgment, the Tribunal observed about publication of notice and requirement under s. 269D(2)(b) of the Act of 1961. The Tribunal was wholly unjustified in doubting bona fides of the assessee on the ground that some paper was produced by Shri Naveen Dangi on 21st Jan., 1974. There was nothing unusual. In this case, Shri Naveen Dangi was auth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 21. It was argued that sub-Registrar accepted the sale consideration indicated in the sale deed as just, correct and reasonable. There was therefore no occasion for the Competent Authority to doubt correctness of the sale consideration. Learned counsel relied on judgment of Madras High Court in C7T us. Dr. V.K. Bhaskaran Nair and Anr. 1978 CTR (Mad) 347 : (1979) 116 ITR 873 (Mad), wherein it was held that the value adopted by sub-Registrar, who had a right to independently value the property not only for assessment to stamp duty but also for purposes of charging appropriate registration fee, is a proper guide and has to be taken note of. Karnataka High Court in IAC vs. National Flag Perfumery Works (1986) 56 CTR (Kar) 113 : (1986) 159 ITR 737 (Kar), held that power of acquisition has to be exercised with full responsibility and onus of proving the market value was on Competent Authority. 22. Shri N.M. Ranka, learned senior counsel appearing on behalf of assessee, argued that Competent Authority has on extraneous, irrelevant and arbitrary considerations, come to conclusion about evasion of tax by transferor or transferee. Admittedly, in present case, the assessment of transfe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty, therefore, it was incumbent upon the Competent Authority to arrive at satisfaction about prima Jade foundation that:- (i) the apparent sale consideration was less than fair market value by 15 per cent, (ii) the consideration stated in instrument was at a lesser figure than that actually received by assessee, (iii) it was to facilitate evasion of tax liability by transferor, or (iv) to facilitate concealment of income by transferee for IT Act or WT Act. In present case, none of these ingredients were proved in as much as it was also not proved as to what amount was actually received by transferor, which was more than fair market price nor the Department has made out a case of concealment of income as against transferee, rather in assessment of transferor, it was held that Department has not been able to discharge burden of evidence cast upon it to show that assessee had understated sale consideration. Learned counsel in this connection relied on judgment of Supreme Court in K.P. Varghese vs. ITO (1981) 24 CTR (SC) 358 : (1981) 4 SCC 173. It was argued that DVO has illegally made valuation of land on the basis of plots of smaller size about 200 sq. yds., which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , including the colony roads, gardens, parks, play grounds, community center, schools, dispensary etc., which are basic amenities. 27. Shri S.C. Gupta, learned counsel further argued that the Chapter XX-A of the Act of 1961 stood already repealed w.e.f. 1st Oct., 1986 and further that proceedings pending thereafter were ordered to be dropped in view of Circular No. 455 dt. 16th May, 1986 [(1986) 54 CTR (St) 27] where value of the property was upto Rs. 5,00,000. The main object behind all these enactments was to prevent evasion of tax liability but when it was realized that the provisions were being misused, the same was repealed. It is further argued that observations of the Competent Authority that agreement was vicious and was prepared with oblique motive to escape from the proceedings of Rajasthan Urban Property (Restriction on Transfer) Act, 1973 and that the agreement was not genuine, were not only extraneous but had influenced the decision-making process of the Competent Authority as well as of the Tribunal and as such same suffers from malice in law. 28. Per contra, Shri J.K. Singhi, learned counsel for Revenue, argued that on receipt of information regarding transfe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssible time-limit which time-limit expired on 30th April, 1985. It was argued that assessee is a society registered as co-operative society. It represents interests of its members. Membership keeps changing with approval of the society at different points of time. The society was always in effective occupation and control and use of said land. Service of notice on the society has to be taken as service effected also on its members for purposes of s. 269D(2). In any case, it is the society which purchased the disputed land against sale consideration and in whose favour the agreement to sell was executed and ultimately sale deed was registered and instrument of transfer was executed. Members of assessee-society have been allotted plots subsequently. None of its members has filed appeal against the impugned order under s. 269F of the Act of 1961 raising objection regarding non-service of notice under s. 269D(2). This objection about non-service of notice on its members was not available to assessee-society. The notice was in any case published in Official Gazette and also affixed in the locality and was affixed in office of Competent Authority. Learned counsel in this connection relie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fied reasons and does not affect the validity of the impugned order. 32. Shri J.K. Singhi, learned counsel for Revenue, argued that mere non-providing opportunity to cross-examine the DVO does not have any effect of violating the principles of natural justice as per the ratio of judgment of Supreme Court in State of Jammu and Kashmir vs. Bakshi Gulam Mohammad AIR 1967 SC 122. Even otherwise, the appellant-society failed to show as to what prejudice was caused to it by mere non-providing opportunity to cross-examine the DVO. On the question of prejudice, the learned counsel has relied on judgments of Supreme Court in Union of India and Ors. vs. Alok Kumar (2010) 5 SCC 349, Sarva U.P. Gramin Bank vs. Manoj Kumar Sinha (2010) 3 SCC 556, Om Prakash Mann vs. Director of Education (Basic) and Ors. (2006) 7 SCC 558 and Aligarh Muslim University vs. Mansoor Ali Khan AIR 2000 SC 2783. 33. Shri J.K. Singhi, learned counsel for Revenue, further argued that Competent Authority was fully justified in arriving at valuation of property on the basis of sale deed and in doing so he rightly accepted the sale consideration declared by the society at Rs. 25,45,452 on 2nd Oct., 1974 as per agre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on behalf of the transferee and given valid reasons in para 17.5 of the order as to why it cannot be accepted. After considering the objections and relevant legal provisions, the Competent Authority has concluded that the fair market value of the disputed property should be determined as on the date of sale deed i.e. 1st Feb., 1982. The Competent Authority has found that the agreement to sell dt. 1st Oct., 1974 cannot be relied on for that purpose. He has agreed that the date of execution of instrument of transfer, the date of sale deed i.e. 1st Feb., 1982 should be the date for determining fair market value and not the date of its registration i.e. 27th July, 1984. It is on that basis that Competent Authority has determined the value of Rs. 61,31,630 as fair market value as on 1st Feb., 1982 as against Rs. 24,45,452, as stated in the said deed. The Competent Authority has further relied on the judgment of the learned District Judge, Jodhpur, in the case of a similarly situated land across the road measuring 35,553 sq. yds. at Rs. 49.50 per sq. yd. as on 10th Oct., 1974 and has thus arrived @ Rs. 154.67 per sq. yd. as on 1st Feb., 1982, and thus was awarded compensation in a land ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... istration) Act soon after registration of sale deed. Those proceedings were assailed by none other than the appellant herein i.e. M/s Naveen Grah Nirman Sahakari Samiti by filing Writ Petn. No. 101 of 1986. This Court by order dt. 10th Jan., 1986 while issuing notice to the Government directed that in the meantime further proceedings pending before Competent Authority-cum-Addl. Collector, Urban Land (Ceiling and Registration) Act, Jodhpur shall remain stayed. The Competent Authority in the present case therefore was advised by their standing counsel on 23rd Feb., 1999 that in view of stay order granted by this Court, Department could not proceed to acquire the land under Chapter XX-A of the Act. In our view, the Department was justified in taking that approach because if the land was already subject-matter of acquisition under Urban Land (Ceiling and Registration) Act, 1976, there was no point in continuing with the proceedings for acquisition of this very land under Chapter XX-A of the Act by the Central Government. The IT Department on this aspect was thus rightly advised in taking that view because the proceedings under the Act could not have been concluded prior to finalization ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lieve that fair market value of the immovable property was exceeding Rs. 1,00,000, and land situated at Jodhpur, has been transferred under the Registration Act, 1908 in the office of the registering officer at Jodhpur on 27th July, 1984 for an apparent consideration, which is less than the fair market value of the aforesaid property and that the fair market value of the property as aforesaid exceeds the apparent consideration thereof by more than fifteen per cent of such apparent consideration and the consideration for such transfer as agreed to between the parties has not been truly stated. The notice was accompanied by the reasons which were that while the sale consideration of the property has been declared to be Rs. 24,45,452 whereas its prevalent market value was estimated as high as Rs. 1,20,91,000 and difference between the two is by more than 25 per cent. The Competent Authority in doing so relied on the report of the DVO, which is on record. In column No. 4 of the said valuation report, it is mentioned that the said land is situated near Ratanada Circuit House, Dhanwantari Nagar, Jodhpur and the total land area is 1,81,818 sq. yds. In column No. 6 it is described to be a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... relevant bearing on the formation of the belief, which postulates that there must be a direct nexus or live link between the material coming to the notice of the ITO and the formation of his belief that there has been escapement of the income of the assessee from assessment in the particular year because of his failure to disclose fully and truly all material facts. It was held that the Court cannot go into sufficiency or adequacy of material and substitute its own opinion for that of the ITO on the point as to whether action should be initiated for reopening the assessment. At the same time, however the Supreme Court held that it should be borne in mind that it is not any and every material, howsoever vague and indefinite or distant, remote and far-fetched, which would warrant the formation of such belief. 40. In CIT vs. Smt. Vimlaben Bhagwandas Patel and Anr. (supra) what was held by Gujarat High Court was that satisfaction of the Competent Authority for initiation of acquisition proceedings is a subjective satisfaction of the objective facts. The reasons for formation of belief must have a rational and direct connection with the material coming to the notice of the Competent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome material on the basis of which he could have come to hold such "reason to believe" that the consideration in instrument of transfer was not truly stated for prima facie object of facilitating the reduction or evasion of liability of transferor/transferee to pay tax. At that stage, he could not be expected to come to final conclusion so as to make determination of fact with certainty that this was done for facilitating reduction or evasion of liability of transferor/transferee to pay tax. At such initial stage, what is required is that thefe is some relevant material on the basis of which a reasonable person can form requisite belief; although such subjective satisfaction has to be based on objective material. In the present case, we are not inclined to hold that comparable sale instances which were made basis for the purpose of valuation by the DVO and which report was relied by the Competent Authority for the limited purpose of initiation of proceedings under Chapter XX-A, were either vague and indefinite or distant or remote or far-fetched. This Court cannot go into the sufficiency or adequacy of such material and all that it has to see is whether there was some material with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 69C of the Act. In Apeejay Premises Co-operative Society Ltd. vs. Nishar Ahmed and Anr. (supra), though this very argument was considered by the Court to hold that use of both words "and/or" is reflecting non-application of mind on the part of the Competent Authority that he was uncertain as to whether the understatement was with the object of one or the other. But, in this connection the counsel for Revenue has cited judgment of Madras High Court in 7. Devarajan and Ors. vs. Tamil Nadu Farmers Service Co-operative Federation and Ors. (supra). In that case, an argument was raised that Form No. 45, in the context of search and seizure under s. 132 of the IT Act, had not been properly filled up and that the exercise of power under s. 132 was invalid and illegal. What was pointed out was that in the whole body of the first page of Form No. 45 after the words "whereas information has been laid before me and on the consideration thereof I have reason to believe that...." a part of the form has been left intact while the rest has been scored out. The argument was that this shows that the authority did not apply its mind properly and that in a serious matter like this, where the right of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lment of income, should always fall in one clause to the exclusion of another and that proceeding must always be initiated only against transferee and not against transferor or vice versa. 48. In present case, the notice for initiation of such proceedings was served upon the transferor and the transferee both and therefore at that stage, the Competent Authority did not in our view commit any mistake in using both words "and/or" because that was the stage of initiation of proceedings, he could not have let off one and merely proceeded against another while in his prima facie view both the transferor and transferee, may have been responsible for not stating the true sale consideration for facilitating reduction or evasion of liability to pay tax, insofar as transferee was concerned and for transferee, the Competent Authority entertained a prima facie belief that he did so though for facilitating concealment of his income or any money or other assets, which he ought to have disclosed for the purpose of IT Act or the WT Act. 49. In this view of the matter, use of words "and/or" together can at the maximum be described as a mere technical omission or defect and in view of provis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or (ii) irrelevant or erroneous material has been considered, or (iii) it has been passed in utter violation of principles of natural justice, or (iv) there has been infraction of any statutory provision in the process of decision-making, or (v) decision is such which no reasonable person could on available material arrive at. We have to therefore examine the arguments and counter-arguments advanced in this case on the touchstone of these parameters. 53. This shall have to be decided on the basis of material whether or not the Revenue has been able to discharge its burden which material has been taken into consideration by Competent Authority in arriving at such decision. The Competent Authority for the purpose of valuation relied on the sale deed dt. 1st Feb., 1982 wherein it is stated that consideration of sale as on 2nd Oct., 1974 was Rs. 25,45,452. It is on that basis that the fair market value was computed and arrived at by the Competent Authority as on 1st Feb., 1982, the date on which the sale deed was executed. The Competent Authority has also taken into consideration the fact that the agreement to sell dt. 2nd Oct., 1974 was superseded on 18th Aug., 1980 on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rity in para 17.1 of its order dt. 16th Oct., 2002 has noticed the comparable sale instances produced by the assessee. The land size whereof ranged between 655 sq. mtrs. to 1409 sq. mtrs. But the Competent Authority found that the land of which instances were given by the DVO was closer to the disputed land and therefore they could form better basis for arriving at fair market value of disputed land. The Competent Authority has noted that the disputed land touches the main road for its whole length for nearly 1000 sq. yds. and that it has tremendous commercial value as is borne out by the fact that the assessee itself sold 66 commercial plots as per list submitted by the assessee and the map of the land prepared by the assessee shows land was left for cinema halls and hotels etc. therein. The valuation submitted by the assessee from registered valuer was not accepted because he deducted the cost of construction from sale consideration in three comparable instances cited by him, which was not held to be according to the prevalent market practice. 55. Most importantly, the Competent Authority in para 19 of its order has observed that the disputed land comes closest to the land of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 49.50 per sq. yd. as on 10th Oct., 1974 on which basis acquisition was made in the cited sale instance, the Competent Authority noted that compensation under land acquisition proceedings was always paid towards lower side and was usually less than the fair market value therefore it should be enhanced by 50 per cent, thus the rate was increased to Rs. 74.25, and a further enhancement on appreciation of land price from 1974 to 1982 was made at 150 per cent. Even otherwise, as per the bank rate prevailing in that period, a deposit used to double in 5-14 per cent years and triple in eight years. Thus, a sum of Rs. 111.37 per sq. yd. was further added to the aforesaid amount of Rs. 74.25 so as to arrive @ Rs. 185.62 per sq. yd. 25 per cent was added for commercial potential of the land. Thus taking the rate to Rs. 232.02 and a reduction of 1 /3rd i.e. 33 per cent of that price, was given for the reason that the land was in a less developed area as compared to the land for which acquisition case was decided by learned District Judge. The net amount that was arrived at was Rs. 154.67 per sq. yd. As against this, the DVO had computed the fair market value of the disputed land only at Rs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... count if they are very proximate, genuine and acquisition itself has not motivated the purchaser to pay a higher price on account of the resultant improvement in development prospects. A balance sheet of plus and minus factors may be drawn for this purpose and the relevant factors evaluated in terms of price variation as a prudent purchaser would do. The Supreme Court in Rishi Pal Singh and Ors. vs. Meerut Development Authority and Anr. (2006) 3 SCC 20 and Land Acquisition Officer vs. Smt. L. Kamalamma AIR 1998 SC 781 also expressed the same view. 58. Contention of learned counsel for assessee that since the agreement to sell that was executed on 2nd April, 1974 provided an increase in the rate of the land by Re. 1 per sq. yd. the rate was settled on the said date at Rs. 8 per sq. yd. as per the stipulation of increase of Re. 1 per sq. yd. for every passing year, the rate should be taken to have been enhanced accordingly in 1982 when sale deed was presented for registration, cannot be accepted. This would mean that only Rs. 6 should be increased in the rate of land price for six years that have gone by in between whereas according to normal market conditions actual appreciation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come forward to either raise objection or file appeal against acquisition order. It is the members who can come forward and take such objection and not the assessee-society which itself claims to represent the cause of the members. Reference in this connection may be usefully made to the judgment of Gujarat High Court in CIT vs. Premanand Industrial Cooperative Service Society Ltd. (supra), wherein the Division Bench of Gujarat High Court analyzing the meaning of phraseology "persons interested" while dealing with objection of non-service of notice under s. 269D(2), held that such objection can be properly taken not by the third party but only by the person on whom notice is not. served and we are in respectful agreement with that view. 61. Merely because the certificate under s. 230A of the Act was issued, it cannot be held that the option of the IT Department to compulsorily acquire this land stood foreclosed. This provision simply intends to ensure whether any payment of tax is pending against assessee or not, and if it is so, whether satisfactory arrangement has been made for its payment. Issuance of certificate under that provision cannot be taken as approval of the corre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an invariable attribute of requirement of the dictum of audi alteram partem; if witnesses whose statements are only secondary and of subordinate material used to buttress main matter connected with amount of additions, are not allowed to be cross-examined being secondary in nature. 63. The Supreme Court in Transmission Corporation of A.P. Ltd. and Ors. vs. Sri Rama Krishna Rice Mill (2006) 3 SCC 74, held that one is required to make out a case of prejudice so as to establish that cross-examination is necessary. The nature of adjudication under cl. 39.9.2 of terms and conditions of supply of electrical energy of A.P. State Electricity Board, is somewhat different from an enquiry under Art. 311(2) of the Constitution. It cannot be laid down as a rule of universal application whenever the statement of Departmental officer is pressed into service for the purpose of adjudication, a right of cross-examination is inbuilt. It was further held by Supreme Court that in order to establish that cross-examination is necessary, the affected party has to make out a case for the same. Merely stating that statement of an officer is being utilized for the purpose of adjudication, would not be su ..... X X X X Extracts X X X X X X X X Extracts X X X X
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