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TMI BlogThe Finance Act, 1987-Explanatory Notes on the provisions relating to direct taxesX X X X Extracts X X X X X X X X Extracts X X X X ..... 0ZA, 285 and 286; (v) amended sections 2, 25, 35, 22B, to 22F, 22H, 22K, 31, 43 of the Wealth-tax Act, 1957; (vi) inserted sections 22BA to 22BD, 22HA of the Wealth-tax Act, 1957; (vii) substituted section 22A if the Wealth-tax Act, 1957; (viii) omitted section 22M of the Wealth-tax Act, 1957: (ix) amended sections 2 and 42 of the Gift-tax Act, 1958. PROVISIONS IN BRIEF 3. The provisions in the Finance Act, 1987, in the sphere of direct taxes relate to the following matters:- (i) Prescribing the rates of income-tax on incomes liable to tax for the assessment year 1987-88; the rates at which income-tax will be deductible at source during the financial year 1987-88 from interest (including interest on securities), dividends, salaries, insurance commission, winnings from lotteries and crossward puzzles; horse races and other categories of income liable to such deduction under the Income-tax Act; rates for computation of advance tax and charging of income-tax on current incomes in certain cases for the financial year 1987-88; (ii) Abolitation of provisions relating to additional income-tax on undistributed profits of certain companies; (iii) Amendment of the Income-tax Act, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of tax deduction account numbers; modifying the provisions relating to settlement of cases; providing that no suit shall lie in any civil court to set aside or modify any order made under the Income-tax Act; modifying the Eleventh Schedule to the Income-tax Act, 1961; (iv) Amendment to the Wealth-tax Act, 1957, with a view to providing that a building or part thereof shall be includible in the net wealth of a person who is deemed to be the owner as per the provisions of the Finance Act, 1987, relating to income-tax; exempting any deposit made under the national savings scheme; modifying the provisions relating to settlement of cases; empowering Commissioners of Wealth-tax to reduce or waive interest paid or payable on account of non-payment or delay in the payment of tax; barring the jurisdiction of civil courts in respect of any order passed under the Act; (v) Amendment of the Gift-tax Act, 1958, with a view to enlarging the meaning of "gift" to include transfer of property controlled by persons who are owners of house property as per the provisions of the Finance Act, 1987, relating to income-tax; barring the jurisdiction of civil courts in respect of any order under this Act. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a to non-residents, assessment of persons leaving India for good during the financial year 1987-88, assessment of persons who are likely to transfer property to avoid tax, where an order has to be passed in a case of search and seizure for calculating the amount of tax on the estimated undisclosed incomes etc. (iv) Rates of tax applicable to individuals, Hindu undivided families, unregistered firms, etc., co-operative societies, registered firms and local authorities: 7. In the case of individuals, HUFS, unregistered firms, etc., the rates of income-tax have been specified in Paragraph A of Part III of the First Schedule to the Finance Act. In the case of co-operative societies, registered firms and local authorities, the rates of income-tax have respectively been specified in Paragraph B, Paragraph C and Paragraph D of Part III of the First Schedule to the Finance Act. These rates are the same as those specified in the corresponding Paragraphs of Part I of the First Schedule. (v) Rates of tax applicable to companies: 8. In the case of companies, the rates of income-tax have been specified in Paragraph E of Part III of the First Schedule to the Finance Act. These rates are the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) of Explanation 3 is deemed to be one who is beneficially entitled to not less than 20 per cent. of the income of such concern. 10.3 The new provision would therefore, be applicable in a case where a shareholder has 10 per cent. or more of the equity capital. Further, deemed dividend would be taxed in the hands of a concern where all the following conditions are satisfied: (i) where the company makes the payment by way of loans or advances to a concern; (ii) where a member or a partner of the concern holds 10 per cent. of the voting power in the company; and (iii) where the member or partner of the concern is also beneficially entitled to 20 per cent. of the income of such concern. With a view to avoid the hardship in cases where advances or loans have already been given, the new provisions have been made applicable only in cases where loans or advances are given after 31st May, 1987. These amendments will apply in relation to assessment year 1988-89 and subsequent years. [Sections 3(a) and 41 of the Finance Act, 1987] Definition of "transfer" widened to include certain transactions: 11.1 The existing definition of the word "transfer" in section 2(47) does not include ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e date". Due date means the date by which an employer is required to credit the "contribution" to the employee's account in the relevant fund under the provisions of any law or term of contract of service or otherwise. [Explanation to section 36(1)(va)] 12.2 In addition, contribution of the employees to the various funds which are deducted by the employer from the salaries or wages of the employees will be taxed as income [insertion of new sub-clause (x) in clause (24) of section 2] of the employer, if such contribution is not credited by employer in the account of the employee in the relevant fund by the "due date". Where such income is not chargeable to tax under the head "Profits and gains of business or profession", it will be assessed under the head "Income from other sources". 12.3 Payment by way of tax on duty, liability for which has accured in the previous year, will be allowed as a deduction if it is made by the due date of furnishing the return under section 139(1) in respect of the assessment year to which the aforementioned previous year relates. 12.4 These amendments will take effect from 1-4-1988 and will, accordingly, apply from the assessment year 1988-89 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ad "Capital gains" assessable for assessment year 1988-89 or any subsequent assessment year(s). This short-term capital loss, however, would not be carried forward for more than 8 years succeeding the assessment year in which the loss was first computed. 13.5 In respect of long-term capital loss relating to the period to the date of coming into effect of the new section 74, this would be carried forward and set off against income under the head "Capital gains" assessable for that assessment year. Carry forward of loss would not be allowed beyond the 4th assessment year immediately succeeding the assessment year for which the loss was first computed. [Sections 3(c), 3(f), 28, 29, 30, 31 of the Finance Act, 1987] Tax incentive for investment in shares: 14.1 Under the existing provisions of section 2(42A) of the Income-tax Act, short-term capital asset means the capital asset held by the taxpayer for a period of 36 months of less, immediately proceeding the date of its transfer. With a view to providing tax incentive for investment in shares held in a company, the share shall be treated as a short-term capital asset if it is held by the assessee for 12 months or less immediately ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fect. It now refers to the rules currently applicable for the rules which are now not legally in force. The interest on deposits made in the Post Office Savings Banks under these rules continue to qualify for exemption from income-tax. 16.4 The amendment is with the retrospective effect from 1st April, 1983, and will, accordingly, apply to the assessment year 1983-84 and subsequent years. Interest which may have accured after 1st April, 1982, on the deposits made under the revised rules would, therefore, be eligible for exemption. [Section 4(b)(i) of the Finance Act, 1987] Exemption of interest on bonds issued by certain public sector undertakings: 17.1 In his Budget Speech for the year 1986-87, the Finance Minister had announced that "the Government will introduce another series of Public Sector Bonds with a tax-free return". Pursuant to this announcement, certain public sector enterprises such as Mahanagar Telephone Nigam Limited, National Thermal Power Corporation and Indian Railway Finance Corporation had issued these tax-free bonds. 17.2 By insertion of item (h) in sub-clause (iv) of clause (15) of section 10, the Amendment Act provides that interest payable by the publi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ountry being the value added. As an incentive for earning foreign exchange, section 10A has been amended w.e.f. 1st April, 1981, when it was first introduced, to clarify that units that merely assemble or process goods for export would also get the benefit of the tax holiday. The amendment also covers units which carry out recording of programmes on any disc, tape, perforated medial or other information sorage device. In this regard, the Board has already issued instruction in November, 1986. 19.2 The amendment will come into force retrospectively from 1st April, 1981, and will, accordingly, apply in relation to the assessment year 1981-82 and subsequent years. [Section 5 of the Finance Act, 1987] Modification of provisions relating to investment deposit account: 20.1 The Finance Act, 1986, introduced section 32AB relating to investment deposit account. The provisions apply in relation to the assessment year 1987-88 and subsequent years. Under these provisions, and assessee is entitled to a deduction of an amount up to 20 per cent. of the profits of 'eligible business or profession', if the said amount is either deposited with the Development Bank within the period up to six ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Investment Deposit Account Scheme permits withdrawals for some purposes which are even otherwise deductible under the Income-tax Act. In order to secure that such assessees are not allowed deduction twice in respect of the same expenditure, the Amending Act clarifies, that where any expenditure is made wholly or partly by utilising the amount credited to the taxpayer in the deposit account, in respect of which deduction is allowed under section 32AB(1), then such expenditure shall not be reduced under the other provisions of the Act. 20.7 Section 32AB(6) lays down that any amount withdrawn by an assessee from his account with the Development Bank but not utilised in accordance with the scheme during the previous year will be treated as income of the year during which the withdrawal was made. There may be a situation where an assessee withdraws the amount and utilises the same in accordance with the scheme for specified purposes within the period permitted by the scheme but a part of such period may fall in the next accounting year. In such cases, the effect of the existing provisions is that though an assessee has utilised the amount in accordance with the scheme, the amount will ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ication in the computation of income in respect of foreign airlines: 22.1 Presently the income of a non-resident engaged in the business of operation of aircraft is computed after allowing deduction for certain expenses and statutory deductions. This involves complications in determining the income accuring or arising in India to such a person. 22.2 With a view to simplify the existing provisions, the Amending Act has inserted a new section 44BBA which provides that the income from such business shall be computed at a flat rate of 5 per cent. of the amount received or receivable by or on behalf of the taxpayer for carriage of persons, livestock, mail or goods from any place in India and the amount received or deemed to be received within India on account of such carriage from any place outside India. 22.3 The amendment will come into force with effect from 1st April, 1988, and will, accordingly, apply in relation to the assessment year 1988-89 and subsequent years. [Section 12 of the Finance Act, 1987] Enlarging the meaning of ownership of house property: 23.1 The Amending Act has extended the meaning of the expression "ownership" for the purpose of computing income under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ift-tax Act have also been made as a similar situation exists in the allied statutes. [Section 2(m) of the Wealth-tax Act and section 2(xii) of the Gift-tax Act] 23.4 The Amending Act has shifted the liability to taxation, from the legal owner to the real owner in respect of some transfers by introducing deeming provisions. The question of taxing the legal owner, e.g., a builder of multi-storeyed flats under the head "Income from house property" would, consequently, not arise. 23.5 This amendment will come into force with effect from 1st April, 1988, and will, accordingly, apply in relation to the assessment year 1988-89 and subsequent years. [Sections 3(g), 6, 75 and 90 of the Finance Act, 1987] Capital gains on transfer of firms' assets to partners and vice versa and by way of compulsory acquisition: 24.1 One of the devices used by assessees to evade tax on capital gains is to convert an asset held individually into an asset of the firm in which the individual is a partner. The decision of the Supreme court in Kartikeya V. Sarabhai v. CIT [1985] 156 ITR 509 has set at rest the controversy as to whether such a conversion amounts to transfer. The court held that such conver ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsation is awarded in several stages by different appellate authorities and necessitates rectification of the original assessment at each stage. This causes great difficulty in carrying out the required rectification and in effecting the recovery of additional demand. Another difficulty which arises is in cases where the original transferor dies and the additional compensation is received by his legal heirs. In the latter type of cases, proceedings have to be initiated against the legal heirs. Repeated rectification of assessment on account of enhancement of compensation by different courts often results in mistakes of computation of tax. 24.6 With a view to removing these difficulties, the Finance Act, 1987, has inserted a new sub-section (5) in section 45 to provide for taxation of additional compensation in the year of receipt instead of in the year of transfer of the capital asset. The additional compensation will be deemed to be income in the hands of the recipient even if the actual recipient happens to be a person different from the original transferor by reason of death, etc. For this purpose, the cost of acquisition in the hands of the receiver of the additional compensat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve in Category I, and the balance, if any, against the assets referred to in Category II. 25.4 In cases of compulsory acquisition, the threshold deduction will be restricted to a total amount of Rs. 10,000 in relation to the initial compensation as well as additional compensation received in subsequent years. 25.5 The above deductions referred to in section 48(2) will be given after providing for the exemptions specified in sections 54, 54B, 54D, 54E, 54F and 54G. 25.6 The exemptions provided in sections 53, 54 and 54F in respect of capital gains which are hitherto allowed only to individuals has now been extended to Hindu undivided families also. 25.7 These amendments will take effect from 1st April, 1988, and will, accordingly, apply in relation to the assessment year 1988-89 and subsequent years. [Sections 15 and 18 of the Finance Act, 1987] New scheme for deposits in respect of exemption from capital gains: 26.1 Under the existing provisions of sections 54, 54B, 54D, and 54F, long-term capital gains arising from the transfer of any immovable property used for residence, land used for agricultural purposes, compulsory acquisition of lands and buildings and other capital ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ment year 1988-89 0.75 SITUATION 2: Amount deposited as per scheme by the due date of filing the return for the assessment year 1988-89 3 Hence, amount deemed utilised for the acquisition of new asset 7 Capital gain liable for tax for the year 1988-89 : (i) If the amount of Rs. 3 lakhs is utilised in the construction by 2-6-1990, capital gain in the assessment year 1991-92 Nil (ii) If the amount of Rs. 3 lakhs not utilised in the construction of the property, capital gain for the assessment year 1991-92 Nil Amount of deposit 3 Less : Deduction under section 48(2) (initial deduction of Rs. 10,000 not being allowed), 50% of the amount 1.5 Net capital gain charged to tax in the year 1991-92 1.5 1.5 " 26.4 These amendments will take effect from 1st April, 1988, and will, accordingly, apply in relation to the assessment year 1988-89 and subsequent years. [Sections 19, 20, 21 and 23 of the Finance Act, 1987] Exemption of capital gains on shifting of industrial undertakings from urban areas: 27.1 Under section 280ZA, if a company owning an industrial undertaking shifts the undertaking from an urban area, it qualifies to receive a tax credit certificate in respect o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ount to capital gains liable to tax. The judicial view, however, has been that it is only where an asset costs something to an assessee in terms of money, that the provisions relating to levy of capital gains tax can apply. Good will being a self-generated asset, not costing anything in terms of money, has been held to be outside the purview of capital gains tax [CIT v. B.C. Srinivasa Setty [1981] 128 ITR 294 (SC)]. Even in a case where an assessee transferred goodwill which he had acquired earlier on payment of a price, the gain from such transfer was held by a High Court to be not taxable, on the ground that the cost of improvement in respect of this asset could not be ascertained in terms of money. 28.2 The Finance Act, 1987, by amending section 55 has provided for the method of computing the cost of acquisition as well as the cost of improvement, where goodwill is transferred. Where goodwill is purchased by the transferor the cost of acquisition will be taken to be the purchase price and in all other cases it shall be taken to be nil. The cost of improvement in either case would be taken to be nil. 28.3 The intention in bringing to tax the capital gains on transfer of goodwil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed) or the cost of any addition or alteration; (b) any expenditure in respect of which a deduction is allowable under section 24; (v) If, for any reason, any instalment or part payment made in advance in respect of which deduction has been claimed is refunded, the deduction already allowed will be deemed to be the income of the assessee chargeable to tax under the head "Income from other sources" of the year in which the money was received back. In addition, no deduction would be allowed in respect of any payment made during that year; (vi) it is necessary for the assessee to hold the property for a minimum period of 5 years from the end of the year in which the possession was taken. In case of transfer of such property before the period of 5 years the total amount of the deduction allowed to him under these provisions will be deemed to be the assessee's income of the year in which the property is transferred and shall be chargeable to tax under the head "Income from other sources". 29.2 This amendment comes into force with effect from 1st April, 1988, and will, accordingly, apply to the assessment year 1988-89 and subsequent years. [Section 32 of the Finance Act, 1987] Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ds, institutions, etc. The amount of deduction which qualifies for deduction is limited to 10% of the gross total income of the donor, subject to a monetary limit of Rs. 5 lakhs. With the amendment of section 80G by the Finance Act, 1987, donations to any Regimental Fund (Funds set up by the Army) or Non-Public Fund (Funds set up by the Navy and Air Force), established by the Armed Forces of the Union, for the welfare of the past and present members of such forces or their dependants, shall also qualify for deduction subject to the limit and conditions laid down in section 80G. 32.2 This amendment will come into force with effect from 1st April, 1988, and will, accordingly, apply in relation to the assessment year 1988-89 and subsequent years. [Section 35 of the Finance Act, 1987] Modification in the provisions relating to deduction in respect of royalties, etc., from certain foreign enterprises: 33.1 Under the existing provisions of section 80-O of the Income-tax Act, an Indian company is entitled to a deduction, of an amount equal to 50 per cent. of the income, by way of royalty, commission, fees and similar payments, received from the Government of a foreign State or a fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... efore, been deleted. 33.4 The deletion of the words "or having.......dealing in foreign exchange" has been done only to simplify the section. It does not, in any manner, reduce or narrow down the scope of application of the section itself. In other words, as long as the payment made by the foreign State or foreign enterprise in convertible foreign exchange is received within the specified period in India by or on behalf of the assessee in accordance with the law in this regard (Foreign Exchange Regulation Act, 1973), the assessee would be entitled to the deduction under this section, if the other requirements in this regard are satisfied. 33.5 These amendments will come into force with effect from 1st April, 1988, and, will, accordingly, apply to the assessment year 1988-89 and subsequent years. [Sections 36 and 44 of the Finance Act, 1987] Modification of provisions in respect of remuneration received for services rendered outside India: 34.1 Presently section 80RRA of the Income-tax Act provides for deduction of an amount equal to 50 per cent. of any remuneration received by an individual who is a citizen of India, if such remuneration is received by him in foreign exchange ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or payable or the provision thereof, amount carried to any reserve, provision made for liabilities other than ascertained liabilities, provision for losses of subsidiary companies, etc., if the amount are debited to the profit and loss account. Liabilities relating to expenditure which has been incurred or which has accrued in respect of expenses which are otherwise deductible in computing income will not be added back. The amount so arrived at is to be reduced by- (i) amounts withdrawn from reserves if any, such amount is credited to the profit and loss account; (ii) the amount of income to which any of the provisions of Chapter III applies, if any such amount is credited to the profit and loss account; and (iii) the amount of any brought forward losses or unabsorbed depreciation whichever is less as computed under the provisions of section 205(1)(b) of the Companies Act, 1956, for the purposes of declaration of dividends. Section 205 of the Companies Act requires every company desirous of declaring dividend to provide for depreciation for the relevant accounting year. Further, the company is required under section 205 to set off against the profit of the relevant accounting y ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Companies Act, 1956 Profit under the Income-tax Act Year 1984 Rs. Rs. Loss excluding Loss excluding depreciation 3,00,000 depreciation 80,000 Depreciation 1,00,000 Depreciation 4,00,000 Year 1985 Profit before Profit before depreciation 5,00,000 depreciation 5,00,000 Less : Depreciation as per books 2,00,000 Less : Depreciation 4,00,000 3,00,000 1,00,000 Less : Deduction Less : Business loss for under section205(2) for the year 1984 1,00,000 2,00,000 1984 80,000 20,000 C.F. Business loss 1984 3,00,000 Less : Unabsorbed depreciation 20,000 Nil C.F. unabsorbed depreciation 1985 3,80,000 Year 1986 Net loss as per Business loss (—) 10,00,000 books before (—) 10,00,000 Add : Depreciation as depreciation per Income-tax Depreciation 2,00,000 Rules (—) 4,00,000 Business loss to be carried forward (—) 10,00,000 Unabsorbed depreciation to be carried forward (—) 2,00,000 Year 1987 Net profit 10,00,000 Profit before depreciation 10,00,000 Book depreciation 2,00,000 Less : Depreciation as per Income-tax Rules 8,00,000 2,00,000 Less : Carried forward business loss for 1986 to the extent adjusted 2,00,000 As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... om former or other employer). 37.4 Under the existing provisions of section 89(1), it is the Income-tax Officer who is empowered to give relief from the incidence of tax at a higher rate in a case where an employee receives salary in arrears or in advance. The Amending Act by inserting sub-section (2A) in section 192 provides that in respect of salary payment of employees of Government or public sector undertakings, deduction of tax at source may be made after allowing relief under section 89(1). 37.5 Presently the person making payment of salary cannot take into account other incomes of the employee for the purpose of deduction of tax at source. The Amending Act by inserting sub-section (2B) enables a taxpayer to furnish particulars of income other than salaries to his employer who shall deduct out of the salary payment, the tax due on the total income subject to the condition that the total amount of tax deducted shall not be less than the amount deductible from income from salaries only. 37.6 These amendments will come into force with effect from 1st June, 1987. [Section 45 of the Finance Act, 1987] Modification of the provisions relating to tax deduction at source: 38.1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es of tax deduction at source. Similarly, the tax borne by the employer, to the extent it is exempt under section 10(6)(viia), shall not be grossed up for purposes of tax deduction at source. 38.6 These amendments will come into force from 1st June, 1987. [Sections 46, 47, 48, 49, 50, 51, 56 and 71 of the Finance Act, 1987] Amendment of provisions relating to issue of certificate for tax deduction: 39.1 Under the provisions of section 203 of the Income-tax Act any person responsible for deduction of tax at source is required, at the time of credit or payment of the amount, etc., to issue a certificate that tax has been deducted and to specify the amount deducted. The amount deducted at source has to be deposited within a certain period of time from the date on which the said amount was deducted. As the certificate for tax deduction has to be issued at the time of credit or payment of the amount, in most of the cases it cannot be ascertained that the amount deducted at source has been credited to the Government account. Section 203 has been amended so as to provide that the certificate for deduction of tax shall be issued, within such time, as may be prescribed. 39.2 This amendm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the majority decisions will prevail. Where the Members are equally divided, they will refer the points or refer the point(s), for hearing by one or more of the other Members of the Settlement Commission. The Amending Act has conferred powers on the Central Government to authorise a Voice Chairman to act as Chairman in certain situations. 41.2 The experience of the Department has been, that when evasion of tax is detected in a case, the assessee deliberately omits to file tax returns and makes an application to the Settlement Commission, so as to escape penalty for concealment. Proviso to section 245C(1) has, therefore, been amended so that no application can be made to the Settlement Commission unless the assessee furnishes the return required to be filed under the Act. 41.3 The Amending Act has rationalised the mode of computation of additional amount of income-tax payable, in relation to the income disclosed in the application for settlement. Under the existing provisions of sub-clause (iii) of clause (1B) of section 245C, where an assessment has been completed, the additional amount of tax payable is calculated by aggregating the tax assessed and tax on disclosed income. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o prosecution, suit or other proceedings shall lie against the Government or any officer of the Government for anything done in good faith or intended to be done under the Act. Similar provisions are contained in section 43 of the Wealth-tax Act, 1957, and section 42 of the Gift-tax Act, 1958. These provisions have been interpreted to mean that the bar of suits in civil courts is confined to assessment orders only and not to other orders under the Income-tax, Wealth-tax and Gift-tax Acts. 42.2 Direct tax laws contain very detailed provisions relating to appeals against orders passed by various authorities. They are self-contained codes. It is, therefore, not appropriate for civil courts to assume jurisdiction in respect of orders made under the Act. Section 293 of the Income-tax Act and the corresponding provisions of the Wealth-tax Act and the Gift-tax Act have been amended to provide that no suit shall be brought in any civil court to set aside or modify any order made under the said Acts. 42.3 These amendments will come into force with effect from 1st March, 1987. [Sections 72, 89 and 91 of the Finance Act, 1987] Amendment of the Eleventh Schedule to the Income-tax Act: ..... X X X X Extracts X X X X X X X X Extracts X X X X
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