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TMI Blog2017 (6) TMI 514X X X X Extracts X X X X X X X X Extracts X X X X ..... reated as bogus and not genuine - merely because the assessee is able to produce the purchase bills evidencing the VAT charged to the assessee, does not establish the factum of purchases being made by the assessee - the assessee has not maintained any stock details Before the CIT(A), the assessee submitted that if most of the purchases are unverifiable GP rate could be applied to make the addition - assessee claims that the purchases were made in the regular course of carrying on the business from parties who were registered with the Sales Tax Department and had VAT number - also VAT collected by the said dealers has not been deposited with the Sales Tax Department, assessee voluntarily revised his return under MVAT Act by withdrawing the set off of claim in the earlier return and paid the taxes with interest - hence CIT(A) is confirmed in estimating the addition @10% of alleged hawala purchases In the case of M/s. Chhabi Electricals Pvt. Ltd - the AO before making the addition has not even supplied the copy of statement to establish that the purchases made by the assessee were bogus thus no additioncan be made in the hands of assessee - assessee has established the trail of goods ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 17.02.2014 confirming the action of the Ld. A.O. in making the addition of ₹ 3,23,691/- treating the same as bogus purchases without appreciating the facts and circumstances of the case. 2. The Ld. CIT(A) failed to appreciate that the purchases was duly accounted in the books of the appellant. Hence, treating the purchases as bogus and thereby' making addition of ₹ 3,23,691/- under section 69C of the Act is unjustified and the same may be deleted. 3. The Ld. CIT(A) further erred in confirming the action of the Ld. A: O. in making the addition of ₹ 3,23,691/- invoking the provisions of section 69C of the Act without appreciating that the Appellant has proved the purchases made during the impugned assessment year with supporting evidence. Hence, the addition of ₹ 3,23,691/- under section 69C of the Act is unjustified and the same may be deleted. 4. Without prejudice to the above the Ld. A. O. erred in making addition of ₹ 3,23,691 /- under section 69C of the Act merely on the basis of certain investigation carried out by the Sales Tax Department without providing the Appellant an opportunity to cross examine the department's witnesses. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the assessee had submitted the information with regard to the goods received and material issued and the accounts statement of the concerned party. The Assessing Officer also reports that the statement of the Manager (Accounts) was recorded. Further, a letter was addressed to the Joint Commissioner of Sales Tax vide letter dated 15.10.2013 seeking the information such as copy of affidavit of hawala dealer, bank statement and copies of statements recorded of such hawala dealers. The said information was not received and follow up letter was issued and even the office inspector was deputed by the Assessing Officer. However, no information was received from the Sales Tax Office of Dhule. The Assessing Officer during the course of remand proceedings asked the assessee to produce the representative of M/s. Siddhi Vinayak Traders. However, the assessee submitted a letter stating that the said party was not traceable now, hence, could not be produced. The Assessing Officer vide para 5 of the remand report stated that the assessee had only substantiated its books of account, however, the related party was not produced by the assessee. The Assessing Officer acknowledged that no doubt, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... purchased switches from M/s. Siddhi Vinayak Traders, which was based in Thane. All the items were of raw material. He further referred to the documentation relating to the transit of raw material, wherein a gate entry was made at the factory gate and thereafter, Goods Receipt Note i.e. GRN was issued at factory, which has cross reference of the gate entry. Thirdly, issue note is issued when raw material is released for production. The learned Authorized Representative for the assessee pointed out that all the details were maintained and against the purchases, the payment was made through cheque. He further stated that the Sales Tax Department through investigation had found that VAT was not paid by the said party, whose name appeared in the list of hawala traders. The assessee when confronted, paid the VAT. 9. The learned Authorized Representative for the assessee referring to the order of Assessing Officer, pointed out that during the course of assessment proceedings, the Assessing Officer did not have the copy of statement recorded of the hawala dealer. On 13.10.2013, for the first time, the Assessing Officer requisitioned and gets the copy of the statement. He further stated th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Revenue on the other hand, placed reliance on the ratio laid down by the Hon'ble High Court of Rajasthan in Indian Woollen Carpet Factory Vs. ITAT & Ors. (2003) 260 ITR 658 (Raj). 12. Shri M.K. Kulkarni, the learned Authorized Representative for the assessee in the case of M/s. Anant Chemicals has relied on the decision of the Pune Bench of Tribunal in M/s. Chetan Enterprises Vs. ACIT (supra). 13. The learned Departmental Representative for the Revenue on the other hand, pointed out that the facts of the case were different where the copy of the statement was supplied to the assessee and the person from whom purchases were made was summoned but because of non-compliance, it was fit case for higher GP to be applied. The appeal is filed by the Revenue against the order of CIT(A), who has applied GP rate to estimate the income in the hands of assessee on account of bogus purchases. The assessee is not in appeal against the order of CIT(A). 14. In the case of Apex Ecotech Pvt. Ltd., none appeared on behalf of the assessee, but the CIT(A) in para 8 had applied the ratio laid down by the Pune Bench of Tribunal in Shri Mukeshkumar Pukhraj Mehta Vs. ITO (supra) and upheld the addition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee. The Revenue is not in appeal against the relief allowed by the CIT(A), was fairly admitted by the learned Departmental Representative for the Revenue. 20. Smt. Deepa Khare, the learned Authorized Representative for the assessee, appearing for Maa Saraswati Steel Industries and referring to para 4.2 of the assessment order, pointed out that the assessee maintains Inward records of the goods received, but admittedly, no system of quantity control was being maintained. She further pointed out that all details of Inward records were filed before the Assessing Officer, wherein the Assessing Officer had sought information under section 133(6) of the Act. The learned Authorized Representative for the assessee pointed out that the assessee was engaged in manufacture of items which were excisable and consequently Excise records were also maintained. She further stressed that no addition is warranted in the hands of assessee as the statement recorded of person indulging in bogus purchases, was not given to the assessee, but the Assessing Officer relied on the said statement to make the addition in the hands of assessee. 21. The learned Departmental Representative for the Revenue fairly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... egard, was placed on the ratio laid down by the Hon'ble High Court of Bombay in H.R. Mehta Vs. ACIT in Income Tax Appeal No.58 of 2001, judgement dated 30.06.2016. 25. The learned Departmental Representative for the Revenue on the other hand, pointed out that the Assessing Officer had issued summons under section 131 of the Act, which was returned back and the person from whom the said purchases were made, was not traceable. 26. Shri Sanket Joshi, the learned Authorized Representative for the assessee in the case of Smt. Sujata Shreyas Yande pointed out that cross appeals are filed by the assessee and the Revenue relating to assessment year 2009-10 and the Revenue is in appeal against the order of CIT(A) in assessment year 2010-11. He further pointed out that no appeal has been filed by the assessee for assessment year 2010-11, where the CIT(A) had applied GP rate of 25% on hawala purchases. The learned Authorized Representative for the assessee fairly admitted that the purchases were made from the same parties as in assessment years 2009-10 and 2010-11. He admitted that the statements recorded were confronted to the assessee and because of low tax effect, after the CIT(A)'s orde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Kulkarni, learned Authorized Representative for the assessee appearing in the case of Flow Control Pumps & Systems Pvt. Ltd., pointed out that the so called bogus purchases has duly been consumed in the manufacturing process of the assessee. Attention was drawn to the details placed at page 3 of the Paper Book. He admitted that the party was not traceable but the assessee deposited VAT against the alleged default of hawala dealer. 32. The learned Departmental Representative for the Revenue however, placed reliance on the order of CIT(A). 33. On perusal of record and after hearing different learned Authorized Representatives for different assessee and the learned Departmental Representative, the issue arising in this bunch of appeals is in relation to the investigation made by the Sales Tax Department, wherein it was detected that certain persons had not deposited VAT against the sale of goods made by them. The Sales Tax Department thus, drew up list of such dealers, who had not deposit VAT against goods sold by them and such persons were termed as 'hawala dealers'. The related transactions of purchases made by different entities were questioned by the Income Tax Department, where ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ll the above said parties from whom purchases were made were located in Mumbai i.e. outside the area of operation of the assessee in Bhosari, Pune. The case of the Sales Tax Department against the said parties was that they were providing accommodation entries and though there was a TIN number allotted to each of them, but they had not paid any VAT alleged to have been collected from the respective persons to whom sales had been made. The assessee was one such person to whom the sales were made by the said parties who were enlisted by the Sales Tax Department. The Sales Tax Department also found that the said parties were not available at the given addresses and hence, these were treated as hawala dealers. The Assessing Officer during the course of assessment proceedings after noting that the assessee had made the purchases from the said hawala dealers, had asked the assessee to produce the said parties for verification. In addition, the Assessing Officer also requisitioned the assessee to produce the supporting bills along with related details i.e. delivery challans for the goods, receipts from octroi paid in respect of goods alleged to have been purchased from the above said part ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... However, the assessee categorically before the Assessing Officer admitted that he was not in a position to produce any of the above. 12. Before the CIT(A), the assessee though had first admitted that the purchases should be added as its income, changed its stand that the entire purchases could not be disallowed as bogus, once it was held that the sales were genuinely effected. The case of the assessee before the CIT(A) and even before us is that the said purchases could not be disallowed on the basis of matching principles. Another plea raised by the assessee in this regard was that one of the parties i.e. M/s. Sidhivinayak Enterprises, Mumbai from whom purchases of ₹ 12,73,892/- had been made were not found in the list of hawala dealers. The assessee in this regard submitted that if most of the purchases are unverifiable, at best reasonable GP rate could be applied to make the addition in the hands of assessee and the entire purchase could not be disallowed. 13. The onus is upon the assessee to establish the entries passed in the books of account by first proving that the transaction entered into is genuine, incurred for the purpose of business and also by establishing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Representative for the assessee, he admitted that the alleged purchases made from the hawala dealers should be treated as income. At no point of time during the course of assessment proceedings, the assessee raised the plea of matching principles, under which it claimed that there was tally between the purchases and sales and also the closing stock shown by it. Only before the CIT(A), the concept of matching principles was raised, but in the absence of any details whatsoever, the CIT(A) vide para 10 has given a finding that Even at this stage, the appellant is not in position to discharge the onus cast upon him by producing the parties, their confirmations, transport details, weigh bridge and octroi receipts, etc. to support his case so that remand order u/s.250(4) of Income-tax Act can be passed, and in view of thereof, the plea of the assessee regarding matching principles was dismissed by the CIT(A). 14. The learned Authorized Representative for the assessee filed before us a voluminous compilation of data, which was headed as the charts showing details of purchases effected from so called Hawala Parties and corresponding sales turned out from such purchases also quantity - wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... being maintained by the assessee, the alleged re-conciliation exercise has no basis and cannot be relied on to establish the case of the assessee on matching principles. Another aspect to be kept in mind is that the Assessing Officer had further confronted the assessee with the valuation of closing stock at the end of the year. During the course of assessment proceedings, the Assessing Officer found the assessee had not maintained any day-to-day stock register and was of the view that the valuation of stock could not be verified. When confronted on the said issue, the learned Authorized Representative for the assessee submitted that due to large number of items involved, it was not practical to maintain the stock register. As against the same, now the case of the assessee before us is that it is in a position to reconcile the purchases made from hawala dealers with the sales made by it to different parties. However, in the absence of any day-to-day stock register being maintained by the assessee, we find no merit in the said plea of the assessee. The CIT(A) while deciding the case of the assessee has further gone on the issue that without prejudice even where it has accepted that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ls being maintained by the assessee, the exercise of picking up of one item and matching with the another item of sales, around the same date, the data of purchases cannot be verified by any of the authorities as the assessee is a trader in the goods. He was not a manufacturer of items, wherein some kind of exercise would be established that certain items were utilized to give the desired manufactured results. In case of trading, where no quantity-wise or amount-wise or date-wise purchases have been maintained by the assessee to reconcile that a particular item purchased on a particular date, had been sold by the assessee to a particular person on a particular date, it is not only difficult, but impossible to match the purchases and sales. Even in accounting principles, it is recognized that where the assessee is a trader, then at best FIFO method or LIFO method may be applied i.e. First In First Out and Last In First Out to match the movement of goods. The accounting principles provided that the assessee can maintain the quantity-wise or bill-wise and date-wise details of the items purchased by it. But in the absence of any such details being maintained by the assessee and in view ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer of the non-genuineness of the parties and the same being declared as bogus by the Sales Tax Department, the learned Authorized Representative for the assessee admitted before the Assessing Officer that the same may be treated as bogus and amount may be added in his hands. The onus is upon the assessee to establish that it had made the said purchases from the said parties. However, where the assessee has failed to discharge his onus and has made a statement before the Assessing Officer, then the retraction of such statement is possible only if the assessee files the relevant corroborative evidence to establish the transaction. In the absence of the assessee having established this transaction by way of corroborative evidence, mere exercise of matching some purchases with some sales, in the absence of any stock details being maintained by him from date to date, we find no merit in the stand of the assessee and the same is rejected. The exercise of matching principles has no basis and is futile exercise. 19. The learned Authorized Representative for the assessee placing reliance on various decisions as referred above, pointed out that in the absence of the Assessin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot been able to trace the said parties. In the absence of any confirmation being filed by the said parties or the evidence of the bank statement of the said parties having been placed on record by the assessee to prove its case, merely because such view has been taken in any other decision, the same cannot be applied where the assessee has not discharged its onus. Even before us, the assessee has not furnished any evidence of payment except for making the statement that the amounts were paid by way of cheques. In view thereof, we find no merit in the said stand of the assessee. Upholding the order of CIT(A), we dismiss the ground of appeal Nos.1 to 4. 35. Another aspect which was considered by the Tribunal was admission of the assessee before the Assessing Officer for the addition of purchases made from the aforesaid parties and in the absence of the assessee having filed any corroborative evidence of delivery of goods, the addition was sustained in the hands of assessee. 36. The Tribunal further in ITO Vs. Shri Purushottam Shankar Kulkarni (supra) had considered the case of bogus purchases made from a concern, wherein no confirmation was filed nor any copy of the account of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arose before the Tribunal in M/s. Chetan Enterprises Vs. ACIT (supra) and in M/s. Patco Precision Components Pvt. Ltd. Vs. ACIT (supra), wherein the case of the assessee was that in the absence of the Assessing Officer providing statement and also cross-examination to the assessee, on the basis of which statement, addition was made in the hands of assessee, the said addition is not warranted in the hands of assessee. In the facts of the case before the Tribunal, the Sales Tax Department had declared the said parties to be hawala dealers and information in respect of the same was sent to the Assessing Officer, wherein the assessee had made purchases from six of the parties, who were in the list of hawala dealers. The Assessing Officer therein had received the information and had confronted the assessee with the said information and had also issued summons under section 133(6) of the Act from whom purchases were made, but the notices were returned unserved. Since none of the parties were available on given address, the assessee was asked to produce the said parties and confirm the transaction. The assessee in turn, submitted the purchase bills, consequent sale bills, weight bridge re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ies who were registered with the Sales Tax Department and had VAT number. However, the Sales Tax Department had declared them to be hawala dealers i.e. parties who were registered with the Sales Tax Department but had not paid the requisite VAT. Information in respect of aforesaid hawala dealers were sent to the Assessing Officer since the assessee had made purchases from six of the parties who were in the list of hawala dealers. The said dealers had collected VAT from the customers including the assessee but had not paid the same to the State Treasury. The Assessing Officer on receiving the aforesaid information had reopened the assessment in the case of assessee and had confronted the assessee with the aforesaid information. The Assessing Officer also issued summons under section 133(6) of the Act to the said six parties from whom purchases were made but the said notices were returned unserved since none of the parties were available on the given addresses. The assessee in this regard was asked to produce the said parties and confirm the transactions. The assessee in reply, claims that it had submitted purchase bills, consequent sale bills, weighbridge receipts and transportation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee, then the same should be confronted to the assessee before it can be relied upon. The assessee admittedly, had asked for statements and / or any other documents which have not been supplied to the assessee. The learned Authorized Representative for the assessee before the Tribunal pointed out that the Assessing Officer had provided statements of three parties from whom the purchases totaling ₹ 9,49,240/- were made and no statements of other parties totaling purchases ₹ 22,49,425/- were made available to the assessee. However, the perusal of list of the companies filed before the CIT(A), copy of which is filed along with Appeal Memo reflects that there is difference in the figures of purchases though the total is shown at ₹ 31,98,665/-. Further, the assessee claims in the statement of facts that the Assessing Officer had not supplied any evidence in respect of purchases of ₹ 13,18,943/- to prove that the same were non-genuine. It is further stated that in respect of remaining purchases of ₹ 18,79,722/-, the Assessing Officer has relied on statements of four suppliers, whose bills were supplied to the Tribunal. In the Paper Book, the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Now, coming to the ratio laid down by the Tribunal in Kolte Patil Developers Ltd. Vs. DCIT (supra), wherein the statements of hawala suppliers were recorded by the Assessing Officer and were confronted to the assessee and the opportunity of cross-examination is also granted. However, the assessee did not avail the same. Further, transportation receipts could not be furnished in respect of any of the suppliers and in this view, the purchases made from the said parties were added as income of the assessee. Another proposition which has been laid down by the Tribunal in the case of ITO Vs. Shri Purushottam Shankar Kulkarni in ITA No.991/PN/2012, relating to assessment year 2009-10, order dated 07.04.2016, wherein the Assessing Officer has noted the payments in respect of alleged bogus purchases were outstanding even as on the date of completion of assessment. Further, the assessee was not able to furnish any evidence relating to transportation of goods. Further, in the case of Mukeshkumar Pushkaraj Mehta Vs. ITO (supra), the assessee himself admitted before the Assessing Officer that the purchases made from the impugned hawala dealers was treated as bogus and added to its income. In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ne of ₹ 13,48,537/-. The assessee had asked for copies of statements recorded by the Sales Tax Department of the suppliers and to allow cross-examination. The Assessing Officer in the present case has also not supplied the said statements to the assessee and the case of the assessee though was that, the first aspect in the present case is the availability of statements recorded by the Sales Tax Department and in case no such evidence is available, then there is no basis for making aforesaid addition. As directed in the above appeals, the matter is set aside to the file of Assessing Officer to verify the contention of assessee in this regard. In case, no document is available with the Assessing Officer, then no addition is warranted on account of hawala purchases. Otherwise, the addition has to be restricted to 10% of quantum of purchases as directed in the earlier appeals." 38. The Tribunal thus, concluded by holding that where the assessee has not been confronted with the copies of statements recorded by the Sales Tax Department of the suppliers and no cross-examination has been allowed, then no addition is warranted. There are set of cases where the said statements recorde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alled list of hawala dealers. There are other cases, where the Assessing Officer had received the statement of the persons who were hawala dealers and who had admitted to have just issued bills of sale without delivery of goods. In such circumstances, there is evidence against the respective assessee that where the seller of the goods, has admitted not to have entered into real transaction of sale of goods. Against such non-transaction, there can be no delivery of goods, then it is case of passing of bills of sale and purchases, against which no VAT has been paid. Such bogus purchases are then to be added in the hands of assessee. Where the Assessing Officer had confronted the assessee with the information received, supplied copies of statements and where the persons have not been traced and no confirmation has been filed by the assessee in this regard, then the addition is to be made in the hands of assessee on account of such bogus purchases. In the facts and circumstances of some cases, the goods have been transferred by such hawala dealers to the respective purchasers, against which the assessee has to discharge onus of establishing the trail of goods which are transferred and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dition is to be upheld in the hands of assessee on account of such bogus purchases. IV. The next instance is the case of goods which have been admittedly sold by the hawala dealer and has been received by the assessee, who in turn had maintained quantitative details and also evidence of its movement i.e. transportation details and quality control details of consumption of the said material or exact details of sale of the same consignment through same transporter directly to the party, then the total purchases cannot be added in the hands of assessee. However, since the purchases are made from the grey market, some estimation needs to be made in the hands of assessee. The Tribunal in M/s. Chetan Enterprises Vs. ACIT (supra) has already held that the addition be made by estimating the same @ 10% of the alleged hawala purchases, over and above the GP shown by the respective assessee. V. Another set of cases where the statements recorded by the Sales Tax Department have been handed over to the assessee and the copies of same have been supplied to the assessee, then where the assessee established the case of receipt of goods and its onward transmission, then the factum of purchases ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l of assessee is allowed. 44. The facts and issue in Mahendra Shantilal Chaturmutha, HUF are also similar, wherein the assessment was reopened under section 148 of the Act. The assessee time and again asked for information and also made request for confronting the evidence which were relied upon to make the addition on account of bogus purchases. However, no such evidence was confronted to the assessee and even the copies of statements recorded were not given to the assessee. In the absence of same, there is no merit in making any addition in the hands of assessee. 45. The learned Authorized Representative for the assessee has relied on the ratio laid down by the Hon'ble Bombay High Court in H.R. Mehta Vs. ACIT in Income Tax Appeal No.58 of 2001, judgment dated 30.06.2016, which in turn, has relied on various decisions including the decision of apex court in M/s. Andaman Timber Industries Vs. Commissioner of Central Excise, Kolkata in Civil Appeal No.4228 of 2006, judgment dated 02.09.2015 and the Hon'ble High Court of Delhi in CIT Vs. Ashwani Gupta reported in 322 ITR 396 (Del) and held that where the Assessing Officer has failed to provide copies of seized material to the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oods and the CIT(A) has restricted the addition to 25% of the bogus purchases as income of the assessee. The assessee has failed to controvert the findings of CIT(A) and has even failed to appear on the appointed date of hearing. This is case where the bogus purchases are to be added but the Revenue is not in appeal. Consequently, the order of CIT(A) is upheld. The grounds of appeal raised by the assessee are thus, dismissed. Both the appeals of assessee are thus, dismissed. 50. In the case of Cronimate India Metals Pvt. Ltd., the learned Authorized Representative for the assessee stressed that it was maintaining complete quantitative details of goods dealt in and hence, had clear trail of purchases and the sales thereof of the so called bogus purchases. Finding merit in the plea of assessee, I hold that the total purchases cannot be added in the hands of assessee. However, the Assessing Officer is directed to restrict the addition to the extent of 10% of hawala purchases in the hands of assessee as the purchases are admittedly, made from hawala parties. The grounds of appeal raised by the assessee are thus, partly allowed and appeal of assessee is thus, partly allowed. 51. In th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee claims to have filed confirmation from the said dealer, who acknowledged the amount received against the said purchases by way of different cheques on different dates. The learned Authorized Representative for the assessee in this regard pointed out that no addition is warranted where the said party acknowledges the payment against the purchases. He also stressed that where it is not case of the Revenue that the money had travelled back to the assessee, then there is no merit in holding the purchases to be bogus. Reliance in this regard was placed on the ratio laid down by the Pune Bench of Tribunal in Siddarth Engineering Corporation Vs. ACIT in ITA No.1502/PN/2013, relating to assessment year 2009-10, order dated 29.12.2015. I find merit in the plea of the assessee in this regard. The dealer of goods has acknowledged the sales made by it and also the payments received through RTGS totalling ₹ 10,59,646/-. In view of this additional evidence, there is no merit in making any addition in the hands of assessee on account of bogus purchases. Hence, the claim of assessee raised by way of cross objections is allowed and appeal of the Revenue is dismissed. 55. In the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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