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TMI Blog2008 (1) TMI 834X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 of the Jharkhand Value Added Tax Act, 2005 and the amendment made therein by Jharkhand VAT (Amendment) Act, 2007 are ultra vires and unconstitutional as being opposed to article 301 of the Constitution and are not saved by article 304 of the Constitution of India. W.P. allowed. X X X X Extracts X X X X X X X X Extracts X X X X ..... islation, namely, Jharkhand Value Added Tax Act, 2005. By the said Act, the Bihar Tax on Entry of Goods into Local Areas for Consumption, Use or Sale Therein Act, 1993 as adopted in the State of Jharkhand was repealed. By the said Act, 2005 (the VAT Act), the provisions for imposition of entry tax on entry of goods into a local area in the State of Jharkhand have been introduced. Before discussing the issue involved in these writ applications, I would first like to refer relevant provisions of the Jharkhand Value Added Tax Act, 2005 (in short, "the VAT Act") and subsequent amendments made in the said Act by the Jharkhand Value Added Tax (Amendment) Act, 2007 (in short, "the Amendment Act, 2007"). (1)See [1995] 97 STC 538 (Pat); AIR 1995 Pat 144. In the VAT Act, 2005, preamble of the Act reads as under: "An Act to provide for and consolidate the law relating to levy of value added tax on sales or purchases of goods and on entry of goods into local area in the State of Jharkhand." The said Act was published in Jharkhand Gazette (Extraordinary) dated February 15, 2006. In the original Act of 2005, the word "entry of goods" as defined in sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r any other person who in course of his business or otherwise brings or causes to be brought into the local area, such goods mentioned in the Third Schedule whether on his own account or on account of his principal or takes delivery or is entitled to take delivery of such goods on such entry: Provided no tax shall be leviable in respect of entry of such goods effected by a person other than the dealer if the value of such goods does not exceed Rs. 10,000 (ten thousand) in a year. (3) The liability to pay tax under this section, on goods mentioned in the Third Schedule shall be only at the point of first entry into the State or into a local area and any subsequent sale or sales into the State or into any local area or areas of the said goods, shall not be subject to tax under this section, provided the subsequent selling dealer or registered dealer produces before the prescribed authority, original copy of bill, invoice, cash memo or challan issued to him by the dealer from whom he purchased or received the said goods and files a true declaration in the form and manner prescribed." In 2007 the respondents-State amended various provisions of the VAT Act, 2005 by enacting Jhar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3) The liability to pay tax under this section, on goods mentioned in the Third Schedule shall be only at the point of first entry into the State or into a local area and any subsequent sale or sales into the State or into any local area or areas of the said goods, shall not be subject to tax under this section, provided the subsequent selling dealer or registered dealer produces before the prescribed authority, original copy of bill, invoice, cash memo or challan issued to him by the dealer from whom he purchased or received the said goods and files a true declaration in the form and manner prescribed." Various other sections of the VAT Act, 2005 have been amended. However, it is worth to mention here that no amendment has been made in sections 12, 15 to 21. As noticed above, during pendency of the writ petitions, relevant provisions of the VAT Act, 2005 have been amended by Jharkhand Value Added Tax (Amendment) Act, 2007. Immediately thereafter, in order to give effect to the amended provisions, a notification was issued by the Finance Department vide S.O. No. 48 dated March 29, 2008 describing the procedure for levy and collection of tax on import price on entry of goods ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sary facilities and infrastructure to be created for the benefit of entry tax payers as far as possible commensurate with their respective contribution by such class of taxpayers. 7.. The Member Secretary of the Committee shall convene the meeting, at least once a year to allocate the proceeds of the amount so collected, to the different respective departments in order to achieve the objective of this 'fund'. 8.. High Level Committee shall monitor the utilisation of fund for the purposes specified in the clause (3) from time to time with a view to ensure full and proper utilisation thereof. 9.. The entry tax deposited under Jharkhand Value Added Tax Act, 2005 under minor Head-106 of the major Head-0042 shall be deemed to have been appropriated into the fund. 10.. Any amount credited to the fund and unutilised during any financial year shall be utilised for the same purpose in the subsequent financial year in accordance with the direction of the High Level Committee. 11.. This notification shall remain valid for ten years, provided the State Government may extend its validity for such period as it may deem necessary in this regard. This notification shall be deemed to h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and in what manner the proceeds of entry tax are to be utilised for the purpose of the benefit and interest of trade people of the local area in which such entry tax is sought to be levied. In view of the judgment of the Supreme Court in the case of Jindal Stainless Ltd. v. State of Haryana reported in [2006] 145 STC 544; [2006] 7 SCC 241, the burden therefore lies upon the State to place materials before the court as to how the proceeds of entry tax are sought to be utilised for the benefit and interest of the trade people of the local area. 73.. That the State has failed to discharge that burden under the Jharkhand VAT Act, 2005. Faced with the said situation when the matter came up before this honourable court, the counsel for the petitioner had made submissions on the basis of the Constitution Bench judgment in Jindal Stainless Ltd. [2006] 145 STC 544; [2006] 7 SCC 241. The State had made the submission that a Bill has been introduced and therefore they took time for the adjournment of the case. Even on the last day when the matter was heard, the State could not produce any material to show that the Bill has already been made into an Act. After the case was adjourned by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpensatory in nature so as to constitute special advantage to trade, commerce and intercourse. Even otherwise welfare State is bestowed with the responsibilities of providing good roads and bridges for the tax-paying citizens and hence to contend that the impugned levy is being raised for that purpose, viz., for providing roads and bridges and for maintaining such roads and bridges for the benefit and interest of the trading people of the local areas is not justified. 77.. That in fact maintenance and construction of roads and bridges are met from the general revenue of the State. Whether the goods are transported into the State or abroad, the State has a duty to provide facilities like roads, bridges, etc., which is not only enjoyed by persons who bring the notified goods for levy of entry tax but also others. Roads and bridges are not special benefits to the trade people of the local area. No exclusive or special advantage is provided to the trade people. 78.. That similarly clause (b) of sub-section (6) of section 11 provides for finance, aids, grants and subsidies to financial, industrial and commercial units. It is submitted that financial aid is granted by the financial in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... industries of the State of Jharkhand. In the absence of any such notification in terms of sub-section (7) of section 11 of the Act, the Trade Development Fund is only a hypothetical and notional until the proper notification is issued in terms of sub-section (7) of section 11 of the Act. The said provision therefore is only dormant until it is brought to light by appropriate notification. Therefore, the Trade Development Fund is not workable till such time as the notification in terms of the statute is made. The petitioner reserves its right for making further submission regarding the propriety, legality and validity as and when such notification is issued. 83.. That the petitioner further states that according to the scheme of the Jharkhand VAT Act particularly section 17 and the proviso to section 18(6) of the original Act the input tax includes, according to section 2(xxix), tax payable on the entry of goods into the local area. Such entry tax is to be treated as input tax credit by the dealer and shall be adjustable against the output tax payable by the dealer which is nothing but a tax on the sale of the finished products, viz., output tax. Therefore the input tax which is p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l was introduced or the amendment introduced in the State Legislature. 86.. That moreover, entry tax is levied only on the goods which are imported from outside the State and does not apply to the goods which are moved from one local area into another. The Act therefore is discriminatory in character and violates article 304(a) of the Constitution. Therefore the Act cannot be saved by the provisions of article 304 of the Constitution and the Act remains a legislation which violates article 301 as being not compensatory in nature. 87.. That it is further submitted that the amendment introduced by the Amendment Act of 2008 is a mere colourable piece of legislation intended to avoid and get over the Constitutional requirements laid down by the Constitution Bench in the case of Jindal Stainless Ltd. v. State of Haryana reported in [2006] 145 STC 544; [2006] 7 SCC 241. The Constitution Bench has categorically stated that if the Act does not facially or patently indicate that the proceeds of the entry tax are specially earmarked for the benefit and interest of the trade people, the burden lies upon the State to satisfy the court with materials as to how the utilisation of the entry ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ke goods manufactured within the State are subjected to the same tax. Article 304(b) vests the State Legislature with the authority or competence to impose restrictions on the freedom of trade, commerce or intercourse provided that such restrictions are imposed by the Legislature in public interest with the previous sanction of the President. The vires of section 11 and subsequent amendment made in the VAT Act has also been challenged in these writ petitions on the ground that imposition of entry tax is not compensatory in nature and, therefore, restrictions imposed on the movement of goods and imposition of entry tax without the sanction of the President are unconstitutional. The Constitution Bench of the Supreme Court in the case of Jindal Stainless Ltd. v. State of Haryana [2006] 145 STC 544; [2006] 7 SCC 241, has considered the correctness of earlier judgment rendered by the Supreme Court in Bhagatram Rajeev Kumar v. Commissioner of Sales Tax [1995] 96 STC 654 (SC); [1995] Supp. 1 SCC 673 and also subsequent decision in the case of State of Bihar v. Bihar Chamber of Commerce [1996] 103 STC 1 (SC); [1996] 9 SCC 136. On this subject, the Supreme Court in the case of Atiabari Te ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inless Ltd.'s case [2006] 145 STC 544; [2006] 7 SCC 241. The Constitution Bench has considered all the earlier decisions in detail and laid down the law as to when imposition of tax can be held to be compensatory in nature. At this juncture, it would be very useful to refer some of the paragraphs of the judgment rendered in Jindal Stainless Ltd.'s case [2006] 145 STC 544; [2006] 7 SCC 241, which read as under: "41(1). On the other hand, a fee is based on the 'principle of equivalence'. This principle is the converse of the 'principle of ability' to pay. In the case of a fee or compensatory tax, the 'principle of equivalence' applies. The basis of a fee or a compensatory tax is the same. The main basis of a fee or a compensatory tax is the quantifiable and (1)See para 38 at page 571 of [2006] 145 STC. measurable benefit. In the case of a tax, even if there is any benefit, the same is incidental to the Government action and even if such benefit results from the Government action, the same is not measurable. Under the principle of equivalence, as applicable to a fee or a compensatory tax, there is an indication of a quantifiable data, namely, a be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e reimbursed by compensatory tax or in the form of compensatory tax. In other words, compensatory tax is a recompense/ reimbursement. 43(1). In the context of article 301, therefore, compensatory tax is a compulsory contribution levied broadly in proportion to the special benefits derived to defray the costs of regulation or to meet the outlay incurred for some special advantage to trade, commerce and intercourse. It may incidentally bring in net-revenue to the Government but that circumstance is not an essential ingredient of compensatory tax. 44(2). Since compensatory tax is a judicially evolved concept, understanding of the concept, as discussed above, indicates its parameters. 45(3). To sum up, the basis of every levy is the controlling factor. In the case of 'a tax', the levy is a part of common burden based on the principle of ability or capacity to pay. In the case of 'a fee', the basis is the special benefit to the payer (individual as such) based on the principle of equivalence. When the tax is imposed as a part of regulation or as a part of regulatory measure, its basis shifts from the concept of 'burden' to the concept of measurable/quantifiabl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e is some link between the tax and the facilities extended to the trade directly or indirectly, the levy cannot be impugned as invalid. In our view, this test of 'some connection' enunciated in Bhagatram's case [1995] 96 STC 654 (SC); [1995] Suppl 1 SCC 673 is not only contrary to the working test propounded in Automobile Transport's case AIR 1962 SC 1406, but it obliterates the very basis of compensatory tax. We may reiterate that when a tax is imposed in the regulation or as a part of regulatory measure the controlling factor of the levy shifts from burden to reimbursement/recompense. The working test propounded by a Bench of seven Judges in the case of Automobile Transport AIR 1962 SC 1406 and the test of 'some connection' enunciated by a Bench of three Judges in Bhagatram's case [1995] 96 STC 654 (SC); [1995] Suppl 1 SCC 673 cannot stand together. Therefore, in our view, the test of 'some connection' as propounded in Bhagatram's case [1995] 96 STC 654 (SC); [1995] Suppl 1 SCC 673 is not applicable to the concept of compensatory tax and accordingly to that extent, the judgments of this court in Bhagatram Rajeev Kumar v. Commissioner of Sal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rned State Legislature were considered. Therefore, it would be useful to discuss the view taken by the different High Courts on the question as to whether the provision of entry tax is compensatory in nature. (1)See para 48 at page 575 of [2006] 145 STC. (2)See para 49 at page 575 of [2006] 145 STC. (3)See para 50 at page 575 of [2006] 145 STC. In Madras High Court, the Constitutional validity of the Tamil Nadu Tax on Entry of Goods in Local Areas Act, 2001 and various notifications issued by the State Government in exercise of powers conferred by section 15 of the Act were challenged. The Act was enacted to provide for the levy of tax on entry of goods into local areas for consumption, use or sale therein. Section 3 empowers the State Government to levy and collect tax on entry of Scheduled goods into any local areas for consumption, use or sale. The main ground of challenge was that the tax levied under the Act was neither regulatory in nature nor does it satisfy the test laid down for a compensatory tax. Further, no Presidential assent was obtained under article 304(b) of the Constitution. In those writ petitions, the State of Tamil Nadu by counter-affidavit brought certain ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oads, providing bridges etc., is compensatory in nature so as to constitute special advantage to trade, commerce and intercourse. Even otherwise, a welfare State is bestowed with the responsibilities of providing good roads and bridges for the benefit of the tax paying citizens and hence to contend that the impugned levy is being raised only for the said purpose is not justified. Maintenance of roads, bridges, etc., is generally met from the general funds or revenue. Whether goods are transported into the State or outside State or abroad, the State has got a duty to provide facilities like roads, bridges, etc., which are being enjoyed not only by the persons who bring the goods notified for levy of entry tax, but also by others." The Bench further held: "27. If an entry tax levied under entry 52 is at all to be substantiated as a compensatory tax, then it has to be done with reference to the nature of such tax, i.e., a tax payable by a special class of dealers in a local area who import only the specified goods from outside the State and the special benefits/facilities provided to such payers of the tax within the local area concerned. As to what could satisfy such a te ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... officio members: (2) The headquarter of the Board shall be at Chandigarh. (3) The Board shall perform the following functions: (i) It shall ensure balanced development of the local areas falling within the domain of the urban as well as rural local bodies. (ii) It shall identify the areas which require immediate development/maintenance of infrastructure facilities out of proceeds of tax. (iii) It shall accordingly recommend allotment of proceeds of tax for developing and maintaining infrastructure facilities like roads, bridges, culverts, sewerage, drainage, sanitation, waste management, electricity, drinking water and other infrastructural facilities. (iv) It shall recommend changes in the rate of tax in order to keep the levy as per the guidelines issued in this behalf from time to time. (v) It shall ensure that the proceeds of tax collected under this Act are not much more than the amount actually required for development of local areas." In the case of Jindal Strips Limited v. State of Haryana [2008] 12 VST 149 (P&H), while considering the vires of the Haryana Local Area Development Tax Act, 2000, the Division Bench of the Punjab and Haryana High Court after analy ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs or facilities generally for water supply, hygiene, sanitation, waste-management, etc. 33.. The defence on behalf of the State is that the statutory provisions for constituting a Board and requiring the Board to ensure that the tax collected was not much more than the amount actually required and provision for utilising at least 60 per cent for development facilitating free-flow of trade and commerce of the payers of the tax was not enough to meet the facial test, if the payers of the tax are taken to be the ultimate payers to whom the burden was passed on, which include farmers, transporters and consumers. 34.. We find merit in the contention raised on behalf of the petitioners. The levy is not to meet the cost of any specific facility already provided or planned to be provided. The parameters clearly laid down in Jindal [2006] 145 STC 544; [2006] 7 SCC 241 [particularly paras 16 and 41 to 45 (paras 15 and 38 to 42 in 145 STC)] are that compensatory tax represents the costs incurred in procuring facilities/services on the principle of 'pay for value'. It is a charge for offering trade facilities. It adds to value of trade and commerce. It is based on the principle of e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he defence on facts. There is absolutely no correlation to the revenue generated under the specific Act to the so-called expenditure incurred by the local authorities for providing the services mentioned by the respondents. I say so for the reason that the local authorities have their own means of raising revenues and in respect of the expenditure for meeting such benefits, 30 per cent of the expenditure is sought to be collected from the assessees under the Act. There are other levies imposed under the other enactments by the State and the local authorities and such revenue is not at all accounted for. In fact, there is no serious attempt at all on the part of the State to demonstrate either that the expenditure incurred towards the so-called services provided to the trading community in general is a particular amount and that the assessees under the Act constitute 30 per cent of such members of the trading community, for whose benefit the expenditure is incurred. 50.. This apart no material at all is placed about the revenue to the State and the local authorities under the other enactments, which have link or nexus to the kind of the facilities sought to be provided by the Sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unds, to enable panchayats and local bodies who otherwise fail to earn revenue on their own and thus to facilitate them to carry out their statutory/constitutional obligations, i.e., implementation of 'Welfare Schemes' and maintain 'civic services' in general. 'Entry tax', under impugned Act, 2000 has no identifiable or specified link with the 'trades' enumerated in the Schedule in the Act." The Bench further held: "29. It is clear from the perusal of documents annexed with the affidavit of Amitabh Mishra that the amount of revenue earned from 'entry tax' under the Act is pooled in the 'consolidated fund'--which is utilised under budgetary allocation to the States, which is also utilised as 'grant-in-aid' by 'State' to make up the budgetary deficit of a local bodies to discharge their statutory/constitutional obligations-- which apart from others include construction of roads, bridges, etc. The respondents have placed figures relating to the 'funds' given as 'grant-in-aid' to panchayats/local bodies from 'consolidation fund'-- as part of its share received by State of U.P." A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ider of services/facilities. From the point of view of Government, as stated by the apex court in Jindal Stainless Ltd.'s case [2006] 145 STC 544; [2006] 7 SCC 241, a compensatory tax is a charge for offering trading facilities and they are based on the principles of equivalence. Applying the above test, it cannot be said that maintaining of roads, providing bridges, etc., is compensatory in nature so also meet the outlay incurred for some special advantage to trade, commerce and intercourse. Providing the above facilities and its use may incidentally bring in net revenue to the Government, but that circumstance is not an essential ingredient of compensatory tax. We may in this connection point out that in the counter-affidavit filed by the State in Rajan's case [2003] 133 STC 598 (Ker); [1995] 2 KLT 369, the stand of the State was that entry tax was collected in lieu of sales tax and to compensate the loss of sales tax revenue. Some indirect connection or some connection, more or less commensurate, etc., are not the tests, but the direct and immediate effect is the test. Maintaining of roads, bridges, etc., and promotion of SSI units, etc., are generally met from the gener ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... before court that payment of compensatory tax is reimbursement/recompense, quantifiable/measurable benefit provided or to be provided to the payers or there is any broad correlation between the entry tax being realised and the services rendered, it cannot sustain levy of entry tax. We are of the view, State has not discharged its burden by providing quantitative data on the basis of which compensatory tax is sought to be levied and the working test laid down in Automobile Transport (Rajasthan) Ltd.'s case AIR 1962 SC 1406, Jindal Stainless Ltd.'s case [2006] 145 STC 544; [2006] 7 SCC 241 or Vijayalashmi Rice Mill's case [2006] 147 STC 609 (SC); [2006] 6 SCC 763 is not satisfied in these cases for levying entry tax." Dr. Debiprasad Pal, learned Senior Counsel appearing for the petitioners, assailed the provision of section 11 of the VAT Act and the amendment made therein levying tax on entry of goods mentioned in Third Schedule of the said Act as ultra vires of the Constitution of India which does not comply with the requirement of articles 301 and 304 of the Constitution. The learned counsel submitted that article 301 subsequently provides that trade, commerce a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt made therein and submitted that maintaining of roads, providing bridges is not compensatory in nature so as to constitute special advantage to trade, commerce and intercourse. Even otherwise welfare State is bestowed with the responsibilities of providing good roads and bridges for the tax-paying citizens and therefore levy of entry tax for these purposes are not justified. The learned counsel also attacked the provisions contained in section 16 of the VAT Act which provides that input tax in relation to a registered dealer to mean the tax charges under this Act by selling dealer from such dealer on the sale to him of any goods for resale or for use in manufacturing or processing of goods for sale or for direct use in mining or use as containers or packing materials or for the execution of works contract. The learned counsel submitted that once entry tax is made adjustable against the output tax payable by a dealer, it becomes abundantly clear that entry tax forms part of the consolidated fund of the State. The learned counsel submitted that after entry tax collected is merged in the general revenue of the State, it is neither possible nor conceivable that the proceeds of entry ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ption, use and sale therein. (v) Newly added sub-section (4) of section 11 says that entry tax levied and collected under this section shall be appropriated into the fund, i.e., Jharkhand Trade Development Fund as created under clause (xxiA) of section 2 of the Act. (vi) In section 11(5), tax payable under sub-section (1) shall continue to be levied till such time as is required to improve infrastructure within the State such as, power, road, market condition, etc., with a view to facilitate the better market condition for trade, commerce and industry. (vii) Under section 11(7), the State Government can, by notification, specify the manner of deposit of tax under appropriate head of account and the manner in which proceeds of the fund shall be utilised exclusively for the development of trade, commerce and industry of the State of Jharkhand. (viii) Finance Department of the State of Jharkhand has issued S.O. No. 48 dated March 29, 2008 creating Jharkhand Trade Development Fund, wherein in Part 2 it has been specified that proceeds of entry tax levied and collected under section 11 of the Act shall be appropriated into the fund. The learned counsel further submitted that the no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... per cent. The learned counsel referred the decision of the Gujarat High Court in the case of Eagle Corporation Pvt. Ltd. v. State of Gujarat [2007] 6 VST 560 (Guj) wherein the court held that ultimate liability of the tax on both categories of persons bringing goods from outside the State and persons bringing goods from one local area to another local area of the same State is the same. There is eventually no differentiation between the goods imported from outside the State or the goods moved from one local area to another local area inside the State. The learned Advocate-General submitted that entry tax is payable only by persons who bring goods from outside the State. There is no discrimination between the persons who bring goods from outside the State and pay entry tax. Distinguishing the ratio decided by other High Courts on the issue whether levy of entry tax is compensatory in nature, learned AdvocateGeneral submitted that none of those provisions of different State Acts imposing entry tax facially and patently discloses that the tax is compensatory in nature. On the contrary provisions of the VAT Act and notification issued by the State Government patently and facially dem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stood, ex facie is violative of provision of articles 301 and 304 of the Constitution of India inasmuch as it imposes limitations and restrictions in the free movement of goods. In course of hearing of the writ petitions, the State came with an amendment, namely, Jharkhand Value Added Tax (Amendment) Act, 2007. By the aforesaid amendment, sub-sections (4), (5), (6) and (7) have been inserted. According to sub-section (4), entry tax levied and collected shall be appropriated into funds. According to sub-section (6) of section 11, the proceeds of the fund shall be utilised exclusively for the development of trade and industry in the State of Jharkhand. According to the provision, the fund collected is to be used for construction, development and maintenance of roads and bridges providing finances, aids, grants, subsidies to the financial, industrial and commercial units, creating infrastructure for supply of electrical energy and water supply to the industries, marketing and other commercial complexes, etc. In 2008, a notification was issued by the Finance Department vide S.O. No. 48, dated March 29, 2008 prescribing the procedures for levy of tax on import price on entry of goods ..... X X X X Extracts X X X X X X X X Extracts X X X X
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