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TMI Blog2019 (6) TMI 1489X X X X Extracts X X X X X X X X Extracts X X X X ..... elevant facts has rightly deleted additions made by the AO towards disallowance of depreciation, hence, we are inclined to uphold the findings of the ld CIT(A) and reject the ground taken by the Revenue. TP Adjustment - inclusion of Allsec Technologies Ltd., as comparable - It is an admitted fact that the Allsec Techonlogy Ltd. has incurred losses for past three financial years - HELD THAT:- CIT(A) has recorded categorical finding to the effect that the PBIT margins for the aforesaid years have turned negative on account of charges towards depreciation and amortization which is a normal cost which arises during the course of business operations and not on account of some extraordinary factors. The Ld. CIT(A) further stated that for the previous year ended 31st March, 2007, the company had positive PBIT - once comparable is similar to the functions carried out by the assessee, then consistent loss of one or two years is not good ground for rejection of company for comparables. See JOY ALUKKAS INDIA PVT. LTD. [ 2014 (6) TMI 80 - KERALA HIGH COURT]. Exclusion of Eclerx Services Ltd. as comparable - As in Maersk Global Service Centres [ 2015 (1) TMI 917 - ITAT MUMBAI] had taken similar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ement Consulting Services Ltd. as comparable for the purpose of determination of ALP of international transaction. X X X X Extracts X X X X X X X X Extracts X X X X ..... loss maker in the current year but a consistent loss maker and various judicial pronouncements have already held that a consistent loss cannot be treated as valid comparable. 3. Whether on the facts and in the circumstances of the law, the ld. CIT(A) was justified in deleting the adjustment of ₹ 1,05,26,570/- in respect of providing Information Technology Enabled Support Services to AEs by wrongly (excluding) two comparables viz. "Allsec Technologies Ltd." and "E-clerx Services Ltd." without appreciating the fact that "E-clerx' Services Ltd." is a KPO and is comparable with the assessee. 4. The brief facts of the case are that the assessee company is engaged in the business of providing Information Technology Enabled Support (ITES) services and Business Support (BS) services to its AE, The services rendered by the assessee to its AE includes IT infrastructure implementation support services, Internet data centre services, managing software, computer system and programmes, internet and intranet application services/facilities, Database and system networking, project management, training on functional and technical aspects and end user trai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... O has referred the case to the jurisdictional Transfer Pricing Officer for determination of ALP of International Transactions with its AE. During the Transfer pricing proceedings, the TPO has issued notice 92CA(2) of the Act along with questionnaire, dated 12/08/2013 and requested the assessee to furnish all the necessary details and documents in respect of Arm's Length Price. In response, the ld. AR for the assessee attended from time to time and furnished information called for. During the course of TP proceedings, the AO called upon to assessee to explain as to why certain comparables chosen for benchmarking, its international transactions cannot be accepted/rejected for the reasons stated in show-cause notice. The assessee has filed detailed reply in respect of comparables selected for benchmarking in its international transactions. The TPO after considering relevant submissions of the assessee, analyzed the comparables selected by the assessee, and after considering relevant facts, rejected certain comparables and selected five set of comparables with average margin of 25.15%. Further, the TPO after considering the value of international transactions arrived at an adjustme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unt of ₹ 7,64,30,544 the total cost for the ITES services rendered to the AE was ₹ 6,94,82,313. The assessee had adopted Transactional Net Margin (TNM) Method as the most appropriate method to benchmark the aforesaid transaction. Further, the assessee has used the ratio of operating margin (operating profits after depreciation (i.e. PBIT) to operating costs including depreciation) as the best profit level indicator (PLI) for testing the assessee's transfer prices. A detailed search process was carried out the assessee on Prowess Database for benchmarking ITES services. Based on the filters applied by the assessee, a final set of 6 comparable was arrived for ITES services whose margin's based on the PLI were worked out as under: Details of Operating Margins earned by Comparables Companies - ITES Support services Sr. Profit level Indicator ['PLI - PBIT/Operating cost including dep)] (Amount in Cr Rs) Company Name Year Service Income Operating Cost including Depreciation Operating Margin PBIT Op margin as % of Op Cost 1 A B C D E F G = F/EMWT 1 Allsec Technologies Ltd March 11 0.142 0.149 -0.007 (4.69) 2 Caliber Point Bu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or its exclusion. - Cameo Corporate Services - The assessee contended that "M/s. Cameo Corporate Service Ltd is a BPO service provider, providing services to a wide range of clients. Its main business is in the areas of registry and securities transfer services, document management solutions, e-publishing etc. Your honour has proposed to reject the said company on the ground that the same ix already considered ax a comparable in BS services. On perusal of the scope of work for ITES services provided by the assessee to AE's it can 'be observed that the assessee is engaged in the business of providing IT Infrastructure implementation and support services as 'well as managing software, computer systems and programs etc. Although, services rendered by M/s Cameo Corporate Services Ltd w.r.t. registry and securities transfer services, document management solutions, e-publishing etc. are not identical to the services rendered by the assessee to its AE, the same can be considered as comparable on the ground that these are more in (he nature of support services and hence this company was considered as a comparable. The fact that this is already considered as a compa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 'KPO') company (refer page 79 of annual, accounts) providing data analytics services and process solutions to verticals like financial services, sales and marketing divisions of largest Fortune 500 scale companies-1: provides critical processes and analytics to the top 14 global investment banks. It Supports key sales and marketing functions -which includes web content management and merchandising execution, web analytics, social media moderation and analytics, search engine analytics and support, CRM platform support etc. Its client include companies in financial services, broadband, cable & telecom, e-commerce and retail, high tech, industrial manufacturing & distribution, software, media & entertainment and travel companies. " -Infosys BPO Ltd. The assessee has contended that this company should be rejected on the ground of high turnover. The contentions of the assessee have been examined. However the same are not acceptable for the reasons stated below: (i) Allsec Technologies Ltd; From the perusal of the annual report it is seen that the company has incurred losses in FYs. 2007-08, 2008-09 and 2009-10 of ₹ 11.06 crore, ₹ 7.02 crore and ₹ 6. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he issue of inclusion or exclusion of comparables is to be decided on the factors mentioned in Rule 10B{2) and not on the ground of abnormal or high profit margins. Eclerx has been held to be providing data processing and data analytics services which are in the nature of ITeS. Similar view has been held by ITAT Delhi also in Agilent Technologies case in view of this, the assessee's contention is rejected (vi) Infosys BPO The assessee has contended that this company has high turnover on the basis on which it should be treated as functionally different and thus, not comparable. The assessee's hypothesis that there is a direct co-relation between turnover and profit margins of the company is not acceptable. The Transfer pricing rules or the OECD guidelines do not prescribe any specific range of turnover for comparability corresponding to size and scale of operations. Once functional similarity is accepted, companies can be compared irrespective of the turnover, size or scope of operation. Particularly in the' service industry where not much of infrastructure is needed to set up business, The fixed costs in the software/ITES industry are insignificant compared to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch 2011) should not be rejected on account of exception year since the company increased its installed capacity by 45% during the financial year ended 31st March 2011. The assessee explained that on perusal of Schedule E of the annual accounts (which provides the detail of Fixed Asset) it can be observed that the addition to Fixed assets during FY 2010-11 is only 17% of the total gross block of fixed assets as on 1st April 2010 (i.e. ₹ 49,5,42,473/ ₹ 290,368,943* 100). Hence, although during FY 2010-11, the company increased its installed capacity by 45%, this year cannot be considered as an exception year. The explanation provided by the assessee has been considered. Since addition to fixed asset made by M/s. Jindal Intellicom Limited during FY 2010-11 is only 17%, the same is not considered as an exception year and hence the same is accepted as a comparable. Accordingly, in light of the aforesaid discussions, the margins of comparable companies for benchmarking ITES services provided by the assessee to its AE are arrived as under: Details of Operating Margins earned by Comparable Companies - ITES Support services Pro Fit level Indicator ['PLI = PBI'/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r procurement of goods and services for execution of the project and provide ♦ Providing back office support in matters relating to accounting, taxation, insurance, HR & Administration An arm's length markup of 7% was added to the cost of ₹ 7,93,50,250 [which included all the personnel cost and all overhead expenses (including depreciation)] to determine the arm's length price of the international transaction. Accordingly, RGMSL (amalgamated with the assessee) had raised the following invoices on respective AE's. Name of the AE Invoice No Date Amount in USD Amount in Rs M/s. GKL 72 31.07.2010 3,95,000 4,30,51.840 192 31.12.2010 5,53.000 M/s. GOTL 70 31.07.2010 1,13,500 1,23,70,592 190 31.12.2010 1,58,900 M/s. GTL 73 31.07.2010 1,13,500 1 23 70,592 193 31.12-2010 1,58,900 M/s. GUL 71 31.07.2010 1,48,000 1.61.30.816 191 31.12.2010 2,07,200 M/s. GRL 74 31.07.2010 9,000 9,80,928 194 31.12.2010 12,600 Total 18,69,600 8,49,04,768 As against the realized amount of ₹ 8,49,04,7687- the total cost for the BS rendered to the AE was ₹ 793,50,250. The assessee had adopted Transactional Net Margin (TNM) M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed for the reasons specified therein:- Sr in the final set of Name of the comparable company Reason for rejection from the final set of comparable 3 GMR Corporate Affairs Pvt. Ltd. Substantial related party transactions-more than 25% 4 TVS-E Servicetec Ltd. Functionally different Further, the assessee was requested to show cause as to why the following companies should not be included in the final set of BS service comparable. Sr. Name of the comparable company 1 Apitco 2 ICRA Management Consulting Services Ltd. 3. India Cements Capital Ltd. In this connection, the assessee vide its letter, dated 05/14/2014. The summary of the assessee's contentions and the analysis is given as under:- S. No. Company Assessee's contention TPO's comments 1 GMR Corporate Affairs Pvt, Ltd. The assessee has admitted that on facts this company cannot be taken as a comparable This company is rejected as comparable. 2 TV S-E Servicetec Ltd. The assessee contended that this company provides services similar to the assessee's On perusal of the annual report, it is seen that the company deals in repairing of electronic devices and other such activity. Thu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ments in determining ALP of international transactions are proposed and summarised as under: Sr Transaction Adjustment (in Rs.) 5.1 Providing Information Technology Enabled Support Services to AEs 1,05,26,570 5.2 Providing Business Support Services to AE's 59,94,192 Total 1.65.20,762 It is hereby clarified that the findings and discussions made in this order are applicable only in respect of reference received for A. Y. 2011 -2012 and not for subsequent assessment years." 7. During the course of assessment proceedings, the AO in order to give opportunity to the assessee to comment on TP adjustment suggested by the TPO vide its order u/s 92CA(3) of the Act, dated 31/12/2015 issued show-cause notice, dated 12/12/2015 and called upon the assessee to explain as to why transfer pricing adjustment suggested by the TPO should not be made to the total income. In response, the assessee vide its letter dated, 17/03/2015 stated that the company do not accept any of the transfer pricing adjustment made by the ld. Transfer Pricing Officer, therefore, the AO after considering relevant submissions of the assessee and also taken note of transfer pricing adjustment suggested ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion in respect of leased assets, because the ownership of the asset remains with the assessee even though the same has been shifted to the lessee's premises. 9. The AO after considering relevant submissions of the assessee and also taking note of accounting standard-19 issued by ICAI observed that as per the AS-19, the term finance has been defined, as per which, finance lease means any lease that transfers all the risks and rewards incidental to ownership of an asset. Since, the assessee has leased plant to M/s Reliance Industries Ltd. and entire such unit has been dismantled, transported and re-installed at the premises of lessee, the risk' and rewards of the assets in question were completely transferred to the lessee and the assessee is therefore not entitled to claim any depreciation on the plant and machinery leased out. The AO further observed that a careful reading of AS-19 reveal that in a finance lease, the lease term-will be for the major part of the economic life of the asset even if title is not transferred and generally the leased asset is of a specialized nature such that only the lessee can use it without major modifications being made. Thus, as per the ab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er it is not material, the location of the asset whether it is in the possession of the lessee or lesser, but it should be used for the purpose of business. Accordingly, he directed the AO to delete addition made towards disallowance of depreciation on leased assets. 12. Insofar as, additions made towards transfer pricing adjustment in respect of information technology support services (ITES), the ld. CIT(A) after considering relevant submissions of the assessee and also taken note of transfer pricing adjustment suggested by the TPO accepted Allsec Technologies Ltd. as comparables to the assessee by following the decision of the ITAT, Mumbai in the case of Maersk Global Service Centres (India) (P.) Ltd. v. Dy. CIT [2015] 56 taxmann.com 129/69 SOT 33 (URO) on the ground that when the company is functionally comparable to the assessee, it cannot be rejected merely for the reason that it has incurred losses during the year under consideration, more so when the assessee has brought out to the notice to the TPO that only because of losses, the company cannot be rejected. Similarly, the ld. CIT(A) has rejected E-clerx Services Ltd. selected by the TPO for determining the ALP on the grou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... depreciation on the asset and not the lessor. Therefore, the assessee's claim for depreciation on the ground that the lessee did not claim depreciation on leased plant and machinery is incorrect. The Ld. DR further submitted that the ld. CIT(A) even failed to comment on case laws relied upon by the AO in the case of Industrial Finance Corpn. of India (supra), where it was held that in finance lease lessee is entitled for depreciation whether or not lessor claimed depreciation in its books of account. 15. The ld. AR for the assessee, submitted that the ld. CIT(A) has appraised the facts in right perspective in light of number of case laws, where it was held that for the purpose of claiming depreciation assessee should be owner of the asset. In this case, the AO never disputed this fact that the assessee is owner of the asset. The AO has disallowed depreciation claimed on the basis of AS-19 issued by ICAI, as per which, in case of finance lease, the lessee is entitled to depreciation. The ld. AR further submitted that assessee has followed AS-19 for the purpose of preparation of financial statement, because it is required to follow accounting standard issued by ICAI, but when i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rial Finance Corpn. of India's case (supra) (6) SBI Home Finance Ltd. v. CIT [2005] 148 Taxman 585 (Cal.) (7) Rajshree Roadways v. Union of India [2003] 129 Taxman 663 (Raj.) (8) K.M. Sugar Mills Ltd. v. CIT [2015] 57 taxmann.com 68/231 Taxman 245/373 ITR 42 (SC) 16. We have heard both parties, perused the material available on record and gone through the orders of authorities below. The assessee had entered into lease agreement with M/s Reliance Industries Ltd. and leased out Polymer Plant located at 5, TTC Industrial area, Ghansali, Thane, Belapur road, Navi Mumbai. As per lease agreement, dated 31/12/2008, the assessee has used said asset for more than five years before the same was leased out to Reliance Industries Ltd. As per lease and licence agreement between assessee and Reliance Industries Ltd. more particularly clauses 2, 3, 4, 5 and 8, during the subsistence of the lease agreement, the ownership of the asset rest with the assessee. In the said agreement, it was clearly mentioned that the lessor is the owner of the plant and machinery which the lessee has agreed and acknowledged. It was further stated that ownership of the plant and machinery and equipment at a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the method prescribed in AS-19 per se will not effect the claim of depreciation in the hands of the owner of the assets and the depreciation on assets will be guided by ownership of the asset and use of assets for the purpose of business. As regards the location of the asset, the physical shifting of the relevant plant and machinery from its present location to the location of the lessee was carried out for better utilisation of the asset in the business which has been leased out, otherwise the AO has never disputed the fact of the ownership of the asset i.e. remains with the assessee and also use of such asset is in the business of the assessee. 18. The fact with regard to claim of depreciation by the assessee for earlier two years is not disputed by the revenue. In fact, even after lease from 31/12/2008, the assessee continued to claim depreciation on leased asset for AYs 2009-10 and 2010-11 and same has been allowed in assessment under section 143(3) of the Act, for AY-2010-11. Although, the ld CIT(A) invoked revisional jurisdiction u/s 263 of the Act to , withdraw depreciation claimed on leased asset, the Tribunal has quashed 263 proceedings in ITA No.2748/Mum/2015, where ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ich ownership of an asset is must for claiming depreciation and in this case, there is no doubt of whatsoever with regard to ownership which is clearly evident from the lease agreement and accordingly we are of the considered view that the assessee is rightly claimed depreciation on leased asset under the Income Tax Act. 19. Coming back to the case laws relied upon by the assessee. The assessee has relied upon the decision of Hon'ble Supreme Court in the case of ICDS (supra). We find that Hon'ble Supreme Court had considered an issue of depreciation in case of leased asset, where it was held that in case of lease transaction, the leasing company was held to be owner of the asset and accordingly entitled to claim depreciation, the relevant findings of the Court are as under:- "19. We may now advert to the first requirement i.e. the issue of ownership. No depreciation allowance is granted in respect of any capital expenditure which the assessee maybe obliged to incur on the property of others. Therefore, the entire case hinges on the question of ownership; if the assessee is the owner of the vehicles, then he will be entitled to the claim on depreciation, otherwise, n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd its meaning is to be gathered from the connection in which it is used, and from the subject matter to which it is applied." 22. A scrutiny of the material facts at hand raises a presumption of ownership in favour of the assessee. The vehicle, along with its keys, was delivered to the assessee upon which, the lease agreement was entered into by the assessee with the customer. Moreover, the relevant clauses of the agreement between the assessee and the customer specifically provided that: (i) The assessee was the exclusive owner of the vehicle at all points of time; (ii) If the lessee committed a default, the assessee was empowered to re-possess the vehicle (and not merely recover money from the customer); (iii) At the conclusion of the lease period, the lessee was obliged to return the vehicle to the assessee; (iv) The assessee had the right of inspection of the vehicle at all times. For the sake of ready reference, the relevant clauses of the lease agreement are extracted hereunder:- "2. Lease Rent The lessee shall, during the period of lease punctually pay to the lessor free of any deduction whatsoever as rent for the assets the sum of moneys specified ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... icle, making the assessee in effect a finance. However we are not persuaded to agree with the Revenue. As long as the assessee has a right to retain the legal title of the vehicle against the rest of the world, it would be the owner of the vehicle in the eyes of law. A scrutiny of the sale agreement cannot be the basis of raising question against the ownership of the vehicle. The clues qua ownership lie in the lease agreement itself, which clearly point in favour of the assessee. We agree with the following observations of the Tribunal in this regard: "20. It is evident from the above that after the lessee takes possession of the vehicle under a lease deed from the appellant-company it (sic.) shall be paying lease rent as prescribed in the schedule. The ownership of the vehicles would vest with the appellant-company viz., ICDS as per clause (4) of the agreement of lease. As per clause (9) of the Lease agreement, M/s. ICDS is having right of inspection at any time it wants. As per clause (18) of the Lease agreement, in case of default of lease rent, in addition to expenses, interest etc. the appellant company is entitled to take possession of the vehicle that was leased out. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cisions on the said point." 20. The assessee has relied upon the decision of ITAT, Delhi in the case of Minda Corpn. Ltd. (supra). We find that the Tribunal has considered identical issue in light of AS-19 issued by ICAI and held that AS-19 on account of lease issued by ICAI only applicable for the accounting lease transactions in the books of account. We further noted that it is settled law that treatment in the books of account is not determinative of liability towards income tax and the liability under the Act is governed by the provisions of the Act. A similar view has been considered by ITAT Delhi 'A' Bench in the case of Bharti Hexacom Ltd. (supra), where it was held that merely because assessee in books of account had given some treatment to the transaction, the claim of the revenue expenditure are on account of lease rental paid including depreciation on the asset treating the whole transaction as capital in nature could not disentitled the assessee's claim in computation of Income on the basis of true nature of the transactions. 21. Coming back to the case laws relied by the ld DR. The Ld DR has also relied upon the decision of the Hon'ble Delhi High ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that it has incurred consistent loss in last three financial years. The ld AR further submitted that it has positive margin and is having positive PBITD margin for the past three years. The PBITD margin for the aforesaid years is negative on account of depreciation and amortization, which is a normal cost arising during the normal course of business and not on account of extraordinary factors. The slow down was primarily on account of the prevailing market conditions and hence, the company's results represent the economic conditions in the industry. He, further submitted that there is no Indian Transfer Pricing rules that required de facto rejection of loss making companies. The ALP cannot be compared only on the basis of arithmetic mean of operating margin of profitable comparable company. In any industry, there are some or many unprofitable companies that are equally comparable. This view also found support from the OECD guidelines. He further submitted that various Tribunal and Courts have consistently held that losses cannot be sole ground for rejecting of a comparable. 25. We have heard both parties, perused the material available on record and gone through orders of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the assessee. 28. The Ld. AR for the assessee, on the other hand, strongly supported the order of the ld. CIT(A) and submitted that Eclerx Services Ltd. is a KPO company providing data analytics services and process solutions to verticals like financial services, sales and marketing divisions of largest fortune 500 scale companies. The KPO services rendered by Elcerx are not functionally comparable to the low-end ITES services rendered by the assessee. Further, Eclerx services Ltd. is a giant company having huge turnover which cannot be compared to the assessee which is rendering services to its AE and its turnover is for ₹ 7.64 crore. 29. We have heard both parties, perused the material available on record and gone through orders of the authorities below. The ld. CIT(A) has recorded categorical fact to the effect that Eclerx Services Ltd. is a KPO company providing data analytics services and process solutions to verticals like financial services, sales and marketing divisions of largest fortune 500 scale companies. The ld. CIT(A) further noted KPO services rendered by the Eclerx services Ltd. cannot be functionally comparable to the low-end ITES services rendered by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of business support services. Therefore, it is functionally similar to the functions carried out by the assessee and hence the Ld. CIT(A) was erred in rejection of TVS-E Services Ltd. from the list of comparables. 33. The Ld. DR, on the other hand, strongly supported the order of the TPO/CIT(A) and argued that at any stretch of imagination TVS-E Services Ltd. cannot be compared with the assessee which is providing ITeS services to its AE. Therefore, there is no error in the findings of the ld. CIT(A) in rejection of TVS-E Service Ltd, 34. We have heard both parties, perused the material available on record and gone through orders of the authorities below. The assessee is engaged in providing business support services to its AE which include evaluation and recommendation for finalization of contracts for procurement of goods and services for execution of the project and providing back office support in matters relating to accounting, taxation, insurance, HR & Administration. We further noted that TVSE Services Ltd. is providing warranty management services for leading IT brands, break fix services for credit cards terminals and e-auction services which is mainly an electronic sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... view that this company cannot be comparable to the assessee which is mainly engaged in providing business support services to its AE in the area of evaluation and recommendation for finalization of contracts for procurement of goods and services and also back office support in matters relating to accounting, taxation, insurance, HR & Administration. Further, this company has been considered in the light of business support services related services to AE by various Tribunal including ITAT Delhi in the case of Rolls-Royce India (P.) Ltd. (supra), where it was held that Apitco Ltd. cannot be comparable on account of functional in comparability. Therefore, we are of the considered view that the ld. CIT(A) was incorrect in inclusion of Apitco Ltd. in the final set of comparables, hence, we direct the TPO to exclude Apitco Ltd. for the purpose of determination of ALP of transactions with AE. ICRA Management Consulting Services Ltd. 39. The ld. AR for the assessee submitted that ICRA Management Consulting Services Ltd. is not functionally comparable for the reason that it is a multi-line management and development consulting firm. It provides strategy, risk management, process improve ..... X X X X Extracts X X X X X X X X Extracts X X X X
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