9911796707
TMI Blog2013 (11) TMI 1011X X X X Extracts X X X X X X X X Extracts X X X X ..... n of their use by the assessee, within the territory of India, the assessee is not liable to remit tax, under the reverse charge mechanism under Section 66A of the Act, in view of the provisions of the proviso to Rule 3(iii) of the Taxation of Service (provided outside India and received in India) Rules, 2006; Regarding agreements entered prior to 16.5.2008 - held that:- The transactions covered by long-term charter agreements - for the tankers "Disha" and "Raahi" are outside the purview of the taxable STGU, under Section 65 (105)(zzzzj); since the agreements and the delivery of these tankers pursuant to the agreements (the taxable event), occurred prior to 16.5.08, the date of introduction of this taxable service; and Penalty u/s 76 to 78 - Held that:- The facts and circumstances justify invocation of the provisions of Section 80, to delete imposition of penalties under Sections 76 to 78 of the Act. Consequently, the imposition of penalties is invalid. The amounts remitted by the appellant towards service tax and interest, under protest, shall be refunded forthwith - Decided in favor of assessee. X X X X Extracts X X X X X X X X Extracts X X X X ..... "Owners". The assessee also entered into a short term TCA. One such agreement was entered into with Trinity LNG Transport, vide agreement dated 30.4.2009 for hiring the LNG tanker "Trinity Glory". The short term TCA and the TCA's are collectively referred to as "Agreement". 6. The impugned adjudication order, in respect of the SCN dated 22.4.2010 confirmed the service tax demand of Rs.50,07,43,385/-; penalty of Rs.50,01,43,385/- under Section 78; penalty of Rs.5000/-under Section 77; besides interest under Section 75. There was no mention of penalty under Section 76. In respect of the SCN dated 12.9.2011, Rs.3,77,00,597/- was assessed towards service tax, besides penalties under Sections 76 and 77; penalty under Section 78 and interest levy was not indicated. In respect of the SCN dated 13.10.2011, Rs.38,58,43,597/- was assessed towards service tax besides penalties under Sections 76 and 77. No interest levy under Section 75 was specified but penalty under Section 78 was eschewed. 7. By the corrigendum dated 24.4.12 the quantum of penalty assessed under Section 76, (in respect of SCNs dated 12.9.11 and 13.10.11), was modified. The corrigendum dated 29.5.12, (in respect of SCN dat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ided the taxable service as enumerated in Section 65(105) (zzzzj), we extract the provision: Section 65(105): 'taxable service' means any service provided or to be provided: (zzzzj) "to any person, by any other person in relation to supply of tangible goods including machinery, equipment and appliances for use, without transferring right of possession and effective control of such machinery, equipment and appliances". It requires to be noticed that the assessee already deposited Rs.50,07,43,385/-; Rs.14,00,765/- and Rs.38,47,45,522/- as against the substantive tax demand assessed in respect of the three show cause notices covered by the impugned adjudication order, i.e. a substantial portion of the basic tax demand assessed. This fact is also recorded. This Tribunal on 11.6.12 granted waiver of pre-deposit of the balance adjudicated liability. 10. The case of the assessee, asserted before the adjudicating authority and reiterated before us:- a) That the assessee owns and operates LNG receiving, storage and re-gasification terminal at Dahej in Gujarat For re-gasification it imports LNG from its vendor RasGas, Qatar through cryogenic ships and after re-gasification delivers t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ensure that the tanker conforms fully to clause 5 and to the satisfaction of the assessee. - Clause 5 of the agreement stipulates the description of the tanker relating to its fitness; the classification of the tanker as per highest international standards including India; providing documents/information and manuals pertaining to the tanker to the assessee; registration of the tanker as approved by the assessee; obtaining and placing on board of the tanker valid registrations/ authorizations/ approvals/ permits etc. for safe navigation and Admiralty publications, as described in the clause. - Clause 6 of the agreement stipulates that the appointment of the Manager, Master and other crew of the tanker shall be to the satisfaction of the assessee; that the personnel on board the tanker must work under instructions and directions of the assessee; and that records must be maintained by the personnel and periodical returns submitted to the assessee. There are other stipulations in this clause which reveal a deep and pervasive control over the personnel, by the assessee. - Clause 7 stipulates owners obligations; to maintain and restore the tanker as per norms specified by the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ional deficit including strike, breach of orders etc. by the master, officers and crew and deviation of the tanker etc. - Clause 31 sets out conditions pertaining to the obligations of the owners to indemnify the assessee in specified circumstances. - Clause 34 stipulates that the owner shall obtain and maintain marine and war risk insurance for the tanker and specifically that the assessee's name must be included as a co-assured. The assessee is also authorized to seek additional insurance. - Under Clause 38 the owner is required to obtain prior written consent of the assessee before transferring its rights for financing or refinancing of the tanker. The assessee is specifically authorized the right to sub-let the tanker, after notice to the owner. - Clause 39 stipulates the owner's responsibility to comply with pollution norms etc. - Clause 46 authorises the assessee to inspect the tanker during construction, maintenance, dry-docking etc. - Clause 47 sets out terms relating to shipbuilding. The assessee has the right to approve the builder of the tanker before entering into shipbuilding contract; to approve specifications and plars for shipbuilding; to inspect and mon ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ea. The consultant, on authorisation by the assessee took delivery of the tankers on its behalf . The delivery was effectuated under certificates of delivery, which clearly indicate that the delivery was given by the builder to the authorised representative of the assessee. (i) As mandated by provisions of the Merchant Shipping Act, the assessee obtained necessary licences for the tankers from the Directorate General of Shipping, for facilitating entry of the tankers into India. Licences were obtained in the assessee's name. Copy of the licence is on record. (j) The specification as to the flag, the country of registration (Malta), the names of the tankers (Disha and Rahi), the logo, the colour of the funnel (specifying the logo and name of the assessee) are in compliance with the specifications of the assessee; (k) Even in the case of short term charter of "Trinity Glory", the terms and conditions o the agreement entered into on 30.4.2009 (between the assessee and Trinity LNG Transport SA) clearly establish that the assessee had possession and effective control of the tanker during the period of its hire. To illustrate this fact, suffice it to notice that: (a) Master and t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... possession and control by the owner in favour of the assessee, which is a pre-condition for the levy. For this conclusion, the Commissioner set out three principal reasons:- (i) All the statutory licences, permissions, insurance etc are in the name of the owners; not the assessee; (ii) Though the assessee has the right to inspect the vessels this does not detract from the authority of the owner over the vessels. Consequently, the legal consequence as to use of the vessels, remains with the owner; and (iii) The agreement provides that the in case Government requisitions the vessels, the hire charges paid by the Government shall be retained by the owners. Thus, the legal right over the vessels is not completely extinguished in favour of the assessee and the legal right is not to the exclusion of the owner; (b) Dealing with the assessee's contention that the service, if any provided, was prior to introduction of 'STGU' as a taxable service, the adjudicating authority ruled that though the Agreements were signed prior to 16.5.2008 (the date of introduction of STGU as a taxable service), the supply of vessels being a continuous process, the liability to service tax exists and th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t specifically excluded transactions involving "transfer of the right of possession and effective control of tangible goods" from the purview of service tax, by incorporating the exclusionary clause in Section 65(105)(zzzzj). 14. The scope of the 46th amendment to the Constitution and introduction of the concept of 'deemed sale', was considered in several judgments. In 20th Century Finance Corporation and Anr. Vs. State of Maharashtra (2000) 6. SCC. 12 the Supreme Court clarified that the levy of (sales) tax is not on the use of goods but on the transfer of the right to use goods. The right to use goods accrues only on account of transfer of the right; the right arises only on the transfer of such right; and unless there is a transfer of the right, the right to use does not arise. The specific observations of the Court (relevant to this appeal) are extracted: "27. ...Therefore, it is the transfer which is sine qua non for the right to use any goods. If the goods are available, the transfer of the right to use takes place when the contract in respect thereof is executed. As soon as the contract is executed, the right is vested in the lessee. Thus, the situs of taxable event of su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o enjoy annexed to the right of property and the fact of the real intention. If involves power of control and intent to control". 17. The Gauhati High Court in HLS Asia Ltd, vs. State of Assam and Ors. (2003) 132 STC 217 (Gauhati), considered whether the transaction in issue therein was a 'deemed sale', warranting imposition of sales tax. The petitioner before the High Court was the owner of high technology equipment used in wire line logging and perforation activities. The operations are done by the use of the high technology equipment deep into the earth through holes drilled into the oil field for identification and mapping of electronic seismic impulses, which are then processed through special software and recorded on magnetic tapes. The Court had therefore to consider whether the relevant contract involved a lease as defined under the Assam General Sales Tax Act, 1993. The relevant provision of the State legislation brought to sales tax the transfer of the right to use any goods for valuable consideration, without the transfer of the ownership i.e. excluding transfer of ownership. The High Court observed that once it is shown that the right to use any goods is transferred by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sales tax under Andhra Pradesh General Sales Tax Act, 1957, as a 'deemed sale' . The High Court held that since the effective control of the machinery even during use by the contractor remained with the petitioner and the contractor was not free to make use of the same for other his works or to move them out during the period the machinery was in his use; despite a condition that the contractor would responsible for the custody of the machinery while on the site, there was no transfer of the right to use of the machinery. Therefore the transaction was not liable to be treated as a (deemed) sale. 20. In G.S. Lamba and Sons vs. State of A.P. (2011) 43 VST. 323 (AP), the issue was whether hiring transit mixers by the petitioner to M/s Grasim Industries Ltd. a unit of M/s Birla Ready Mix Concrete was a deemed sale. The contracts were for providing transportation service for shipping ready mix concrete by hiring specially designed transit mixers. Transit mixers were never transferred and the effective control over running, use of these vehicles and the disciplinary control over the drivers, always remained with the petitioners. The responsibility to obtain route permits; to take the r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ake care of transporting solution needs' is used the real purpose, as can be seen from the second part, is to enable Grasim to have the right to use the Transit Mixers. The agreement requires the Petitioners to provide drivers to be dressed in uniform, and all of them are to obey the lawful instructions issued by Grasim. Further RMC has to be delivered by these drivers in Transit Mixers only at the time and places as instructed by the officials of Grasim, and the Petitioners have no right to carry RMC wherever and whenever they like. Thus the full control on the method, manner and time of using the Transit Mixers, owned by the Petitioners vests absolutely in Grasim. (43) ...These dedicated vehicles are to be painted in a particular style and colour which has to be re-painted once in six months. For any third party, during these 42 months, the goods as visible in use would create an immediate impression that they belong to Grasim. No reasonable man would even think that the Transit Mixers, being used for transporting RMC of Grasim, belong to the Petitioners and they are only being used to meet the transportation needs of Grasim. (45) Reading the recitals and various clauses, ind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owner is concerned. There is thus transfer of possession of the bus as both the aspects mentioned by Salmond in this regard, which have been noted above, are satisfied and consequently there is transfer of the right to use the same. 14. In view of the above, we are of the opinion that the present was the case of "sale" within the extended meaning of this word, inasmuch as there was transfer of the right to use the vehicle for valuable consideration". 22. In Great Eastern Shipping Company Limited vs. State of Karnataka and Ors. [2004] 136 STC. 519 (Kar), the appellant a public limited company owned towing vessels and entered into a charter party agreement with the New Mangalore Port rust (Port Trust) whereby the appellant agreed to make available services of its vessels for the purposes enumerated in agreement alongwith the master and other personnel of the appellant to the Port Trust for a period if six months from the date of commencement of the service. When the taxable event of the transfer of the right to use the goods occurred, for the purpose of application of the Karnataka Sales Tax Act, 1957, was the issue for consideration. Analysing the terms of the agreement between ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any manner, support the contention of the appellant that there has not been a transfer of right to use the tug by the appellant to the NMPT". 23. Administrative understanding/construction of STGU: Board Circular No.334/1/2008-TRU dated 29.02.2008, inter alia issued clarifications in respect of the proposed taxable service - STGU. Paragraph 4.4 of the circular clarified that the transfer of the right to use any goods is leviabe to sales tax/ VAT as deemed sale of goods; the transfer of the right to use involves transfer of both possession and control of the goods to the user of the goods; and that the proposal is to levy service tax on such services provided in relation to STGU, with no legal right of possession or effective control. The circular specifically clarified that STGU which is leviable to sales tax as deemed sale of goods is outside the purview of the proposed service. 24. From the statutory provision (Section 65(105)(zzzzj), in particular the exclusionary clause therein and the constitutional position flowing from Article 366 (29A)(d), it is clear that a transaction which involves transfer of control and possession of tangible goods amounts to 'sale' liable to the le ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er to change the personnel, to complain of their conduct to the owner and on such complaint, the owner must investigate and if reasonable cause exists, must change the appointment of crew or personnel. These factors are considered significant indicators of transfer of possession and effective control - vide Krushna Chandra Behera and G S Lamba; (v) The voyages, the loading and unloading of LNG are to be in terms of and under instructions/directions of the assessee. The bills of lading to be filed for and on behalf of the assessee and as per its direction. The Manager though engaged by the owner must operate the tankers as per the assessee's directions, failing which the owner would be responsible and the assessee such case may seek replacement of the manager. These circumstances indicate effective control - vide Great Eastern Shipping (supra). The assessee exercises deep and pervasive control over the crew in respect of the journey, speed and fuel consumption parameters and is authorised to order a tanker to any part of the world for carrying LNG. Vide the judgment in Krushna Chandra Behera this factor is clearly indicative of possession and effective control by the assessee (use ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of such requisitioned period shall be retained by the owner though such period shall be counted as part of the charter. From this clause in the agreement, the authority infers that the legal right of the owner over the tankers is not completely extinguished in favour of the assessee. According to the Authority, this condition is inconsistent with clause (e) of the ingredients of the transfer of the right to use goods, spelt out in para 91 of the BSNL judgment. This conclusion by the adjudicating authority is equally misconceived. When goods are requisitioned by Government or other competent authority, such requisition is only under authority of a legislation or in exercise of other statutory power. Such power to requisition prevails over any other right, whether in terms of ownership or under a lease/charter. The clause in the contract recognizing such overarching right of the State or other competent authority, cannot be considered to be in derogation of the transaction, which clearly amounts to transfer of the right to use, in favour of the user. Further clause (d) in paragraph 91 of the BSNL judgment stipulates an attribute of transfer of the right to use goods, as being the di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mong the reasons recorded by the adjudicating authority for coming to the conclusion that there was no transfer of the right to use, of the tankers. It is axiomatic that it is impermissible for the respondent-Revenue to invent new grounds, not forming part of the adjudication order to sustain the adjudication order. As pointed out by the Supreme Court in Commissioner of Police, Bombay vs. Gordhandas Bhanji AIR 1952 SC 16; a public order publicly made must be tested on the basis of reasons recorded therein and cannot be supplemented by reasons contrived in a later affidavit or as in this case by way of written submissions in the appellate forum. In the adjudication order the analysis of law and consideration of the relevant facts of the transaction occurs only in paragraph 37.3, in relation to taxability of the transaction, under Section 65 (105) (zzzzj). Further the mere fact that the Manager, Master, personnel and other crew are employed by the owner does not in any manner derogate from the fact that the transaction constitutes transfer of the right to use the tangible goods, including possession and effective control of the tankers. This is so since there are several other clause ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rers were required to pay to the owners of the ship was not payable on account of carriage of the goods but was payable on account of the use and hire of the ship. The following observations, forming part of the analysis by the Supreme Court clarify the nature of the transaction:- "Indeed, the other terms of the charter party and the general tenor of the document show that the payment was in fact to be made by the time-charterers for use and hire of the ship. Under the agreement, charterers had the "liberty to sublet" the vessel for all or any part of the time covered by the agreement. The Captain of the ship was to be under the orders and directions of the, charterers as regards employment and agency. And if the vessel be lost, money paid in advance and not earned was to be returned by the owners to the charterers at once. These terms and conditions of the contract between the parties are not consistent with the theory that the charterers were liable to pay to the owners any amount on account of the carnage of goods. In order that it may be said that the amount was payable on account of the carriage of goods. Under the terms of charterparty, the consideration for the other, that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h referred to as time charters as distinguished from category (iii), and they have this in common that the shipowner's remuneration is reckoned by the time during which the charterer is entitled to the use of services of his ship". The Supreme Court concluded that the Clause 4 in the charterparty (in issue before it) provides for payment "for the use and hire" of the vessel at the stipulated rate for the stipulated period and duration; that the relevant clauses of the charterparty show that the Aluminium Company took the ship from its owners on a time-charterparty; that the owners were entitled to the payment for the use and hire of the ship; that the amount was payable irrespective of what use the ship was put to by the time-charterers or indeed, whether it was put to any use at all and that no part of the payment can therefore be said to have been made on account of the carnage of goods. The appeal by the Union of India was dismissed, with costs. 32. The Supreme Court in British India Steam Navigation Co. Ltd. referred to a passage in Halsbury's Laws of England 4th edn. Vol. 43, para 401 to explain the distinction between "Voyage charterparty" and "time charterparty". Suffice i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng/ conclusion (para 58) that there was no demise of the ship and therefore no transfer of the vessel, ruled that the consideration received for the time charter did not amount to a deemed sale attracting levy under the Tamil Nadu General Sales Tax Act, 1959. The Court concluded that the contract was not for hire of the vessel but for hiring the services to be provided to the owner, as a carrier to carry the goods which are put on board of the ship by the time-charterer. 34. Another contention by Revenue in the written submission is that the BSNL judgement does not specifically require delivery of physical possession of the tankers. This is a contention that is stated to be rejected. Para 91 of the BSNL judgment which enumerates ingredients of a transfer of the right to use goods clearly indicates that there must be goods available for delivery. The fact that goods must be available for delivery indicates that delivery of physical possession of the goods is a sine qua non for a transaction to qualify to be a transfer of the right to use goods. Clauses (b) to (e) of the Supreme Court judgment in BSNL also clearly postulate that there should be delivery of goods. Without delivery of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... date of introduction of the taxable service); and (iii) The right to possession and effective control over the tangible goods are not transferred in favour of the user by the supplier of the goods. (D) From the ingredients of the architecture of the taxable service (noticed above), it is clear that the taxable event is the supply of the tangible goods for use and not the use of the tangible goods supplied. Therefore, the date on which the tangible goods (tankers) are supplied for use by the owner to the assessee, is the date on which the taxable event has taken place. From the facts on record the tankers "Disha" and "Raahi" were supplied for the use of the assessee under agreement and deliveries, both of which events were prior to 16.05.2008. (E) Revenue, (in its written submissions), argues that provisions of Clauses 14 and 15 of the long term charter agreements must lead to the inference that the supply of the tankers was not a one time event which occurred on the signing of the agreements and delivery of the tankers, but was a continuing event. This contention is predicated on the argument that under these clauses effective possession and control of the tankers was not tr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt that occurred prior to 14.05.2003), for the service provided were remitted by the service recipient after 14.05.2003. (I) The position as to taxability and when service tax is leviable, (though in the context of "Banking and other Financial" services and Hire purchase agreements) was clarified by the Board vide the letter dated 09.07.2001. At para 2.1.4. the Board clarifies that where the hire-purchase agreement is executed prior to the date of introduction of the levy, no service tax is leviable on such service provided that the goods are delivered prior to the date of introduction of the taxable service. (J) This position was also considered in Modi Mundi Pharma Pvt. Ltd., vs. CCE, Meerut. The Tribunal held that there was no continuous providing of information and/or know-how; the know-how was received in 1990, prior to introduction of "intellectual property" service as a taxable service. Though royalties in the form of deferred payments were remitted subsequent to introduction of the taxable service, in installments, the taxable service cannot be considered to have been provided after introduction of the provision, ruled this Tribunal. (K) In the above circumstances, fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s is outside India, either in the high seas beyond the territorial limits of India or in another country. As the tankers (tangible goods) supplied for use of the assessee cannot be said to located in India during the period of use of such tangible goods, the transactions fall outside the purview of the proviso. (iii) The assessee also contended that the 2006 Rules classified the taxable services considered therein into three categories and specified distinct criteria for each of the categories, subject to exceptions specified. For services falling under Rule 3(ii), performance of the service in India is the specified criterion. The first proviso to this sub-rule states that where a part of the service is performed in India, the whole of the service shall be treated as performed in India. STGU is not one of the taxable services covered by Rule 3(ii). (iv) STGU is considered only in the proviso to Rule 3(iii). It is therefore impermissible to read a criterion enacted in the proviso to Rule 3(ii) (that part performance of a service in India shall be treated as performance in India), into the proviso to Rule 3(iii). This would lead to a manipulative interpretation; not a permissibl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... therefore, on a true and fair construction of the provisions of Rule 3, a stand-alone provision specifically and exclusively applicable to the taxable STGU. Accordingly, tangible goods supplied for use must be located in India during the period of use of such goods by the recipient, for the charge of service tax to apply under the reverse charge mechanism enjoined by Section 66A (ix) "Located in India during the period of use of such tangible goods" is the governing criterion for applicability of the reverse charge mechanism in the case of STGU. The expression "during" does not occur in isolation but occurs in the company of the other expression "located in India". Applying the principle of noscitor a sociis, the inference is compelling that for the charge of service tax to apply the tangible goods must be located in India during the entire course of their use. (x) In the case of the LNG tankers, undisputedly a substantial period of their use by the assessee is outside the Indian territorial waters, either during loading of LNG at the Qatar port or during voyage on the high seas towards the destination at the Dahej, Gujarat; and while heading back to Qatar for loading LNG afres ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cording a statement on 29.6.09. The statement was recorded on 26.6.09 under Section 14 of the Central Excise Act, 1944. On 28.8.09, the assessee received a detailed legal advice from a Senior Advocate clearly advising that no service tax is leviable on the hiring charges paid by the assessee for hiring the tankers. On 9.9.09, the assessee addressed the Department, informing about the legal advice; asserting that there is no liability to service tax and requested dropping of proceedings. On 7.10.09, the Commissioner, Service Tax addressed the assessee appreciating its initiative in depositing service tax under protest and stated that discharge of service tax would also obviate the need for issuing a show cause notice or invoking penal provisions and requested details of service tax deposited. On 15.10.09, the assessee addressed the Superintendent, Service Tax, New Delhi intimating deposit of specified amounts of service tax including the interest component. A tabular statement of the tax, cess and interest deposited was also furnished. (iii) The show cause notices were issued nevertheless. 39. Since we have concluded that the transactions in issue, covered by the long-term charte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... violates principles of natural justice and cannot be sustained, Since the corrigenda were issued without notice or opportunity to the petitioner we hold that these are unsustainable. In any event since we have concluded that the transactions in issue do not fall within the taxable service, the corrigenda issued amending the adjudication order, with regard to interest or penalties components would also be invalid. 42. On the analyses above, we hold: (i) That the transactions in issue (covered by the two long-term agreements both dated 31.3.01 for charter of the tankers "Disha" and "Raahi" and the short-term charter agreement dated 30.4.09, for charter of the tanker "Trinity Glory") amount to transfer of the right to use tangible goods, with possession and effective control of such goods, in favour of the assessee by owners of the tankers. These transactions fall within the ambit of the exclusionary clause of Section 65(105) (zzzzj) of the Act and are therefore immune to the liability to service tax; (ii) Since the tankers were not located during the entire duration of their use by the assessee, within the territory of India, the assessee is not liable to remit tax, under the r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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